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 UNITED STATES DEPARTMENT OF AGRICULTURE

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 NATIONAL ORGANIC STANDARDS BOARD

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 WEBINAR

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 TUESDAY

 APRIL 16, 2019

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 The National Organic Standards Board

conducted a webinar at 1:00 p.m., Harriet Behar,

Chair, presiding. 

PRESENT 

HARRIET BEHAR, Chair

STEVE ELA, Vice Chair

SCOTT RICE, Secretary

JESSE BUIE 

SUE BAIRD 

ASA BRADMAN 

TOM CHAPMAN 

LISA DE LIMA 

RICK GREENWOOD 

DAVE MORTENSEN 

EMILY OAKLEY 

A-DAE ROMERO-BRIONES 

DAN SEITZ 

ASHLEY SWAFFAR 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
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NATIONAL ORGANIC PROGRAM STAFF 

PAUL LEWIS, Director, Standards Division

MICHELLE ARSENAULT, Advisory Committee 

 Specialist

DEVON PATTILLO, Materials Specialist, Standards 

 Division 

MATT PAVONE, Policy Analyst, Standards Division

CLARISSA MATTHEWS, National List Manager 

ALSO PRESENT 

JULIA BARTON, Ohio Ecological Food and Farm

 Association 

COLEHOUR BONDERA, Kanalani Ohana Farm

ROLAND CARGILL, Product Registration Specialist, 

 Fair Product Inc. 

BILLY CARTER, Carter Farms

DAVE CHAPMAN, Real Organic Project, Organic

 Farmers Association 

JENNIFER DANIELS, Windy Creek Farms

NICOLE DEHNE, Certification Director, Vermont 

 Organic Farmers

KATHERINE DIMATTEO, Wolf, DiMatteo + Associates

LINLEY DIXON, Real Organic Project

STEVEN ETKA, Policy Director, National Organic 

 Coalition 

RAY FRIZZELL, Full Measure Industries

JAYDEE HANSON, Policy Director, Center for

 Food Safety

JANE ISELEY, Iseley Farms

KELLY KERSTON, Senior Livestock Certification 

 Specialist, CCOF

JENNIE LANDRY, DSM Nutritional Products

AMALIE LIPSTREU, Policy Director, Ohio 

 Ecological Food and Farm Association

PEYTON MCDANIEL, Hickory Meadows Organics

DANA PERLS, Senior Food and Technology 

 Campaigner, Friends of the Earth

AMBER POOL, Senior Farm Certification 

 Specialist, CCOF 

MICHAEL SLIGH, Citizen

JESSICA SHADE, The Organic Center

ALEX WATKINS, Alex Watkins Farm

BILL WOLF, Wolf, DiMatteo + Associates 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
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 P-R-O-C-E-E-D-I-N-G-S

 (1:00 p.m.)

 MS. ARSENAULT: Hi, everyone. Welcome. 

This is Michelle from the National Organic 

Program. We're going to get started now. I have 

top of the hour here.

 Just a reminder, if you are not 

speaking -- and actually only the Board Chair and 

a couple of other NOP staff members will be 

speaking -- in the next few minutes, please put 

yourself on mute.

 The background noise is kind of a 

challenge sometimes, and we've heard people 

yelling at their dog or their kids. And unless 

you want the group to hear that, it's best to put 

yourself on mute.

 So welcome. It's the first webinar 

for the April 2019 NOSB meeting. We have a 

webinar today for three hours and then the 

remainder of it will be Thursday. The schedule's 

not full on Thursday, so we'll be about an hour 

to an hour and a half on Thursday, if you're 

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going to join us then as well.

 So first of all, we've going to have 

Paul Lewis, the Standards Division from NOP, 

officially open the meeting. And then I'll run 

through a little bit of housekeeping and the run 

of show for today. And you'll hear from both me 

and Harriet during that period.

 So here's Paul.

 MR. LEWIS: Thank you, Michelle. And 

good afternoon or good morning, depending on 

where you are timewise. I'd like to welcome NOSB 

members and the public to today's National 

Organics Standards Board public comment webinar.

 I appreciate NOSB members for 

participation on this call and for all your hard 

work and energy and thought serving on the Board. 

 This webinar provides the opportunity 

to the public to offer comments to the Board as 

part of the NOSB's upcoming public face-to-face 

meeting scheduled for October 24th to 26th in 

Seattle, Washington. Please consult the NOP 

website for further information about the faceNeal R. Gross and Co., Inc. 

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to-face meeting.

 The meeting we're having today, like 

other meetings of the National Organic Standards 

Board, operate under the provisions of the 

Federal Advisory Committee Act.

 I look forward to hearing comments 

from the public to assist the NOSB in preparing 

the recommendations to the USDA in response to 

NOSB work agenda items. 

 I also want to thank my colleagues, 

the National Organic Program, in the Standards 

Division, for all their help behind the scenes to 

bring today's teleconference to a success.

 I'd like to close by turning to 

Harriet, chair to the board. And Harriet, again, 

thank you for chairing this webinar. We, again, 

appreciate all your efforts and your leadership 

on the Board. Thank you. 

 MS. BEHAR: Thank you, Paul. Hello, 

everyone. I'm going to just do a little bit of 

housekeeping here. All the phone lines will be 

open unless we start to get a lot of background 

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noise, and then we'll have to mute everyone. But 

that, then, does take quite a bit of time to 

unmute each individual person.

 If your phone does not have a mute 

button, you can press Star 6 to mute yourself, 

and then Star 7 to unmute. 

 So first a reminder, you had to have 

pre-registered in order to comment on this 

webinar. And I, the NOC chair, Harriet Behar, 

will announce ahead of time who is going to be 

the next two commenters on deck as well the 

previous -- the person who will speak next to 

just give you a heads-up on when you'll be coming 

on.

 There's also going to be a timer. 

Michelle, do you want to let people hear that 

buzzer so they know when their three minutes is 

up?

 MS. ARSENAULT: Indeed. I'm going to

 MS. BEHAR: Okay, thank you, Michelle, 

for the --

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 MS. ARSENAULT: Sorry. It'll ring a 

second time. And sometimes it's hard to hear on 

the phone, but hopefully everyone could hear that 

fairly clearly.

 MS. BEHAR: Okay. And when you hear 

that noise please wrap up your comments because 

you've reached the end of your three minutes. 

 Board members, if you have a question, 

you can raise your hand, I believe, or write in -

- put it in a question box. And if, for some 

reason, you can't do either, you can just say you 

have a question. I will ask for questions after 

each speaker.

 Also, just so everyone knows that this 

webinar is being recorded and then will be 

transcribed and will be part of the official 

record for the Spring 2019 NOSB meeting.

 I want to thank everyone, also, for 

taking the time out of their busy day to make a 

comment. This is one of the strengths of the 

National Organic Program, is all of the 

engagement we receive from the public. 

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 And, I believe, for any of you that 

are long-time commenters and for first-time 

commenters, be assured that we, on the National 

Organic Standards Board do listen to your 

comments and take them into account when we are 

making decisions that we know affect your 

livelihood as well as your lifestyle of promoting 

organic agriculture and the consumption of 

organic food and fiber.

 So, if for some reason, I miss 

someone, they're not on the line, I will try at 

the end to call them again. So, of course, if 

you're not on the line, you won't know that. But 

I will try if someone fell off the line or 

whatever to, at the very end, keep track of who 

did not fit in their spot and give them a chance 

at the very end.

 So, with that, Michelle, I believe 

that we can start. Billy Carter is our first 

commentator.

 MS. ARSENAULT: Hey, Harriet? Hang on 

one second. Just one other note for people on 

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the phone. We do have a transcriptionist who is 

taking, transcribing the call. And to start that 

off, I'm going to read roll call for the board 

members so I can make sure --

 MS. BEHAR: Oh, perfect.

 MS. ARSENAULT: -- everyone's present. 

So, all right. So, Harriet, I know you're here. 

And for those who don't know, Harriet's the Chair 

of the NOSB. 

 And, Steve Ela, are you on the line 

with us?

 MR. ELA: I am on the line.

 MS. ARSENAULT: Great. Steve is Vice 

Chair of the NOSB. And, Scott Rice? You're on 

the line. Scott, you're muted. Let me unmute 

you. Scott -- oh, two of us unmuted you, which 

canceled each other out. There we go. There we 

go. Scott, you're going to be able to talk now. 

Scott's the Secretary of the NOSB.

 MR. RICE: I am present. 

 MS. ARSENAULT: Scott, if you're 

talking, I actually can't hear you. But I see 

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you.

 MR. RICE: Can you hear me now?

 MS. ARSENAULT: There we go. Gotcha, 

excellent. Okay.

 MR. RICE: Present. 

 MS. ARSENAULT: Sue Baird -- thanks. 

Sue Baird?

 MS. BAIRD: Yes, I'm here on my cell 

phone. I couldn't get access to the Internet, 

but I have my phone.

 MS. ARSENAULT: Okay. That's fine. 

I can hear you. Asa Bradman?

 MR. BRADMAN: Yes.

 MS. ARSENAULT: Hi, Asa. We can hear 

you.

 MR. BRADMAN: Hi.

 MS. ARSENAULT: Jesse Buie?

 MR. BUIE: Present.

 MS. ARSENAULT: Gotcha. Thank you, 

sir. Tom Chapman?

 MR. CHAPMAN: Present.

 MS. ARSENAULT: Thank you. Lisa De 

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(202) 234-4433 Washington DC www.nealrgross.com 
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Lima?

 MS. DE LIMA: Here.

 MS. ARSENAULT: Hi, Lisa. Rick 

Greenwood? Rick, I see you now on the --

 MR. GREENWOOD: Yes.

 MS. ARSENAULT: -- on the list.

 MR. GREENWOOD: I'm here.

 MS. ARSENAULT: Thank you. Emily 

Oakley?

 MS. OAKLEY: Present.

 MS. ARSENAULT: Hi, Emily.

 MS. OAKLEY: Hi.

 MS. ARSENAULT: A-dae Briones?

 MS. ROMERO-BRIONES: Present.

 MS. ARSENAULT: Hi, A-dae. Dan Seitz?

 MR. SEITZ: Present.

 MS. ARSENAULT: Great. Thank you. 

And Ashley Swaffar?

 MS. SWAFFAR: I'm here.

 MS. ARSENAULT: Hi, Ashley. Dave 

Mortensen will be with us. He's going to join a 

little bit late. He had a faculty meeting. So 

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he'll be on the line with us. 

 All right, so, and for those who don't 

know, we are currently at 14 NOSB members. We 

had a member resign when he got a new position 

and had a time conflict. So for this upcoming 

meeting in Seattle we'll have 14 NOSB members as 

well as for the fall meeting in 2019, we'll be a 

14-member board.

 All right, Harriet, all yours.

 MS. BEHAR: Okay. Thank you. Yes, I 

had forgotten the roll call. That's an important 

thing. 

 Okay, so we will start with our first 

commenter, and Michelle does have your phone 

numbers, hopefully, so if, for some reason, 

you're on mute, she will try to unmute you.

 So the first person is Billy Carter 

with Peyton McDaniel and Jennifer Daniels 

following. So, Billy, are you there?

 MR. CARTER: Yes, ma'am. I -- yes, 

ma'am, I am. 

 MS. BEHAR: Okay. 

Neal R. Gross and Co., Inc. 

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 MS. ARSENAULT: So, Harriet, if I --

can I just interrupt one more moment? If you are 

on the line with us, to keep background noise 

down, we'd appreciate it if you could self-mute 

yourself. That will be really helpful. Thank 

you. 

 MS. BEHAR: So, to start --

 MS. ARSENAULT: Also, one other 

reminder for people. If you put us on a hold you 

usually subject us to muzak, if you're calling 

from a business. So please don't put us on hold. 

All right, thank you.

 MS. BEHAR: Okay. And I think we're 

now ready for Billy.

 MR. CARTER: Okay. Thank you. So 

thank you all for your time and, obviously, for 

the commitment that you made to serve on this 

NOSB. 

 And my name is Billy Carter. I'm an 

organic farmer in Eagle Springs, North Carolina. 

And on our farm we grow tobacco, sweet potatoes, 

field corn and small grain organically. 

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 Our first parcels were certified in 

1998, but I have farmed since 1983. And we 

currently have over 1,300 acres certified as 

organic, of which 220 was dedicated to organic 

tobacco in 2019.

 My comments pertain to using fatty 

alcohols to control suckers in tobacco. So in 

order to grow and get yields of high quality 

desirable tobacco, you have to remove the blooms 

and also the suckers or axillary buds that 

develop once that flower has been removed. And 

fatty alcohols allow us to effectively deal with 

controlling sucker growth.

 And, of course, effectively 

controlling sucker growth allows for reductions 

in pests as well as more efficient use of 

fertilizers. And, obviously, both of those are 

desirable outcomes in any organic system plant.

 And without the fatty alcohol, it 

would be very difficult for us to produce more 

than just a very small quantity of organic 

tobacco, if any at all. And in the past, I have 

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used both soy bean and mineral oil as sucker 

control materials. 

 And both of those materials have 

proved really grossly inadequate in their sucker 

control as well as involving many hours of vast 

and grueling work for my employees to apply by 

hand. 

 So we have to go to -- yields better 

quality tobacco with the fatty alcohol. And it 

does remove the workers from what is inherently a 

dangerous job because of the great length of time 

that was involved to apply those materials in the 

hottest part of summer -- because it was all done 

by hand.

 And while we would still have some 

organic production if we no longer had fatty 

alcohols to use, I'm relatively certain that the 

number of certified acres on our farm would be 

drastically reduced. 

 Organic tobacco projection is with 

time very great generator of approved growth and 

that income on our farm. And I'm really proud of 

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the improvements in the health of our soil and 

our farm and our ability that we've seen improve 

because of our commitment to organic production.

 And so today, I'd like to make two 

requests. And I request that USDA grant a 

temporary allowance for fatty alcohols until the 

NOSB has a chance to review it, until that's 

complete.

 And also I'd like to request that NOSB 

and USDA add fatty alcohols to the national list 

of allowed substances. So, again, thank you for 

your time and commitment to the work of this 

board and for considering my comments today. And 

I'm finished. Thank you. 

 MS. BEHAR: Well, okay, well stay 

there, Billy. Are there any comments from the 

Board? Or questions?

 MR. PATTILLO: This is Devon. Do we 

want --

 MS. BEHAR: Okay.

 MR. PATTILLO: -- NOP to comment on 

that, on this at this time? Ms. President? 

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 MS. BEHAR: Well, I'm not sure. I 

think what you want to know is -- I believe that 

there is an allowance for the use of fatty 

alcohols if you have currently been using them 

for this clock year. Billy, are you aware of 

that?

 MR. CARTER: Yes, ma'am. And, 

fortunately, we had inventory less than the 

previous year, so we're in good shape for this 

year. Our interpretation of it was, if you did 

not have inventory going into this year, that you 

did not have the opportunity to utilize it in 

2019.

 Certainly, after we've used up that 

inventory, we were concerned that we would not 

have the opportunity going forward, after this 

current year. So we were aware that we did have 

some relief, if you were in the right position, 

for this year. 

 MS. BEHAR: Okay. I don't know if 

Paul wants to make a comment, if he would be able 

to purchase more for the year? 

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 MR. LEWIS: Yes -- sure, so we'll be 

talking more about the fatty alcohols this year 

at the full board meeting. And Dr. Tucker, the 

deputy administrator of NOP, will be talking more 

about that at the full board meeting.

 MS. BEHAR: So we'll have an answer 

somewhat next week. 

 MR. LEWIS: Right.

 MS. BEHAR: So, Billy, anybody else 

have any questions? 

 MS. OAKLEY: Harriet, this is Emily. 

I have a question.

 MS. BEHAR: Okay.

 MS. OAKLEY: Thank you. And, Billy, 

can I ask why manual removal is not an option? 

If you could elaborate more on that. Is it 

mainly an issue of time constraint and worker 

exposure?

 MR. CARTER: Well, actually, we 

already do some hand removal anyway. But the 

issue was is that there was no way that you could 

keep up with -- it is a timing thing. It's a 

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worker exposure thing. 

 And it's also a limitation in terms of 

the quantity that you could grow. It's severely 

limiting because to really effectively control it 

by hand removal, that's a job that really needs 

to be done, at the minimum, once a week for about 

an eight-week period of time.

 And it's just -- it's very onerous. 

It's very difficult on your health. In fact, 

just anecdotally, I had one of my best workers, 

you know, many years ago, before we had fatty 

alcohols, simply say, you know, he just -- if 

this is the only work I had for him he'd just 

have to do something else. I mean, it's just --

it's very difficult work for a long period of 

time.

 MS. OAKLEY: Thank you. 

 MR. CARTER: You're welcome.

 MS. BEHAR: Any other questions from 

the Board? 

 MR. BRADMAN: Yes, I have a quick 

question. You mentioned exposure, I think you 

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mentioned heat exposure. Are there other 

exposures that are a concern?

 MR. CARTER: Well, of course there's 

always risk --

 COURT REPORTER: Could the speaker 

identify themselves?

 MR. CARTER: -- in tobacco sickness, 

which is, you know, basically, if you, you know, 

if you're in a situation where you're either so 

hot that you sweat, that your body absorbs the 

nicotine or if you're working with tobacco. 

 And where, the answer to that is, you 

know, is to be in protective garb whenever it is 

wet, and not to be in the field when it's 

exceedingly hot. And whenever you start 

eliminating those time periods, it really does 

make it difficult to be able to hand sucker.

 So, yes, we're very concerned of our 

employees. Now, granted, tobacco sickness is not 

something that this routinely happens, but you 

have to be aware of the circumstances that does 

cause it and be prepared for it. 

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 And, having experience myself, I was 

working and all a few times. You know, it's --

you're not going to die, but you think you will 

just because it'll make so nauseated. But, yes, 

certainly, we are concerned about our employees 

whenever we think about, when they're -- the 

amount of time they have to be in the field. 

Mainly, they're removing suckers. 

 COURT REPORTER: This is the --

 MR. BRADMAN: Thank you.

 COURT REPORTER: -- Court Reporter.

 MS. BEHAR: What was that?

 COURT REPORTER: Hi. Sorry, this is 

Court Reporter. Would the speakers mind 

identifying themselves?

 MS. BEHAR: Oh -- thank you for that. 

That was Billy Carter, with Carter Farms. 

 COURT REPORTER: And --

 MR. BRADMAN: And who asked the 

question, that was Asa Bradman.

 COURT REPORTER: Okay, thank you. If 

they could continue to identify themselves, 

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everybody that has a question during the course 

of the meeting, that would be helpful.

 MS. BEHAR: Thank you. Okay, Billy. 

Anyone else on the Board? I do have a few 

questions. I'm wondering, how many times do you 

spray the tobacco during the season with the 

fatty alcohol?

 MR. CARTER: It's usually four to five 

times. 

 MS. BEHAR: Okay. Can you explain how 

tobacco fits into your crop rotation?

 MR. CARTER: Yes, ma'am. So 

traditionally, we've been on a three-year 

rotation. We're starting to gravitate toward a 

four-year rotation because of additional 

certified land. 

 So we're sort of working three from 

the left. But generally we have sweet potatoes 

that proceed tobacco in that crop rotation. In 

between those, between the sweet potatoes and 

tobacco, will be a winter cover crop, usually 

cereal or -- but does not include a legume 

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because, tobacco, we have to be careful about the 

nitrogen fertility.

 After the tobacco, we'll have a cereal 

grain crop, and it'd typically be followed by 

summer cover crop with a legume producer and some 

type of cereal grain, and that'll lead back into 

sweet potatoes. 

 And then we have a sort a different 

rotation where we work through some field corn. 

And of course, we also work small grain, and some 

of that small grain is for harvest. But it's 

typically cereal rye on their farm, where we are 

using for our small grain, not only for cover 

crop but for harvest.

 MS. BEHAR: And then are you aware if 

your buyer of your tobacco then sells that as a 

certified organic product, are there certified 

organic cigarettes or other, whatever they claim?

 MR. CARTER: Yes. Yes, ma'am. Yes, 

ma'am. They are marketed as a certified organic 

product. And their facility is, to the best of 

my knowledge, where we sell our tobacco and where 

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they process, they manufacture, there's processed 

tobacco. 

 And then the manufacturer, their 

cigarettes is all certified. And the product is 

noted as organic tobacco whenever it's sold to 

the cigarette folks, yes, ma'am.

 MS. BEHAR: Okay. Well, I don't --

are there any other questions from the Board.

 MR. CHAPMAN: This is Tom. I had a 

follow-up question.

 MS. BEHAR: Okay.

 MR. CHAPMAN: Billy, does your crop 

rotation impact your need to use fatty alcohols?

 MR. CARTER: Could you restate that 

question, I think you wanted to ask me? I'm 

sorry. 

 MR. CHAPMAN: Yes. Yes, we had a 

question about your crop rotation. I'm just 

curious, does that have any impact at all on your 

need for fatty alcohols in the tobacco 

production?

 MR. CARTER: Well, I was -- no, yes, 

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I get your question now. Not that I'm aware of. 

We, see tobacco's actually an interesting crop in 

terms of you need the proper real amount of 

fertility to grow a good crop, at least so that 

they have a process of nitrogen deprivation in 

order for it to ripen correctly if it's the right 

type of tobacco. This is not true of other types 

of other tobacco.

 The type we grow does require that. 

And because of that, we have to be careful about 

how much the nitrogen's present before that crop, 

so we do not put a million in our cover crop in 

the winter before tobacco, whereas we do with our 

field corn in that sort of rotation than ran.

 Basically we try not to, because of 

our long history of growing tobacco and 

understanding our soil, you know, we try to be 

careful about the nitrogen present in that 

rotation so that we don't have excess sucker 

growth that requires the use of more hand labor 

and/or fatty alcohols to try to control the 

suckers. 

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 So we're mindful of how we've 

approached the fertility of that crop. And 

that's one of the reasons that we don't want a 

lot of sucker growth, because the sucker growth 

actually takes nitrogen away from the tobacco too 

quickly and makes it ripen too quickly. 

 And it requires more fertility up 

front whenever you're contemplating that you 

might have more suckers to contend with if you 

don't control them in order not to have that cost 

lead to fertility. Sorry, a big complaint for 

some sort.

 MR. FREEMAN: Harriet, this is this 

is Nick Freeman. I have a question for Billy. 

Is there an increasing demand for organic 

tobacco? Do you see that, since you're selling? 

Are more people interested in it, in growing it?

 MR. CARTER: Well, you just -- are 

more people interested in growing it? Well, 

there's primarily one new entity that utilizes 

organic tobacco on a commercial scale in the U.S. 

 And their domestic business is 

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increasing. They sold their international brands 

a few years back and that impacted the overall 

quantity of organic tobacco that was being grown 

or just utilized. 

 But domestic consumption's actually 

increasing, so we were on a graphic grade page, 

we plateaued, declined some and we seem to be 

plateauing again at that level.

 MR. FREEDMAN: Thanks.

 MS. BEHAR: Okay, just so you know, 

only the NOSB is allowed to ask questions. Are 

we done with the board members asking questions? 

Okay, we're going to move on to -- thank you, 

Billy, for being patient with all of our 

questions. Next is --

 MR. CARTER: No, I thank you.

 MS. BEHAR: Peyton McDaniel is next 

with Jennifer Daniels and Jane Iseley on deck. 

 MS. ARSENAULT: Hey, Peyton, if I can 

just interrupt you for one moment. This is 

Michelle from NOP. We're getting a little 

background noise from unmuted lines, so if you're 

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not talking, please mute yourself. Thank you. 

 MS. BEHAR: Okay, Peyton, I believe 

we're ready for you.

 MR. MCDANIEL: All right, I'm just 

going to kind of follow up on what Billy had to 

say. So my name is Peyton McDaniel. I'm from 

Eastern North Carolina. I grow about 50 acres of 

organic tobacco. I grow a mixture of sweet 

potatoes, corn, soybeans, cabbage and winter 

squash over the remaining 600 acres.

 I've been growing organic tobacco for 

over ten years now, and it's the most important 

crop in my operation. Fatty alcohols are 

essential to the production of organic tobacco. 

They can free us of unwanted suckers which 

improve yield and quality, ultimately sustaining 

our crops.

 Again, during this trial, there are 

different products and none have offered the 

effectiveness and economic feasibility that fatty 

alcohols do. Pulling suckers is not a viable 

option because of time it takes as well as the 

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increased risk for workers as far as tobacco 

sickness. 

 If we're not allowed to use fatty 

alcohols again for organic tobacco, we're not --

it won't allow me to grow the crop because of 

increased costs associated with that. And also, 

giving other countries producing organic tobacco 

and the upper hand. 

 They can produce it at a much lower 

cost and they have the ability to take over our 

market because our products are too expensive to 

produce and the companies, they can't afford the 

process. 

 I ask the USDA to grant temporary 

allowance for fatty alcohols until the Standard 

Board review is complete and also I ask that USDA 

and NOP add fatty alcohols to the list of allowed 

substances. Thank you. 

 MS. BEHAR: Okay, thank you. Anyone 

on the Board have a question? Okay, I have a 

question. Peyton, have you been using fatty 

alcohols so far, and how many years? 

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 MR. MCDANIEL: Yes, I've been using it 

now for the last, oh, I would say, seven or eight 

years, as -- a big part of what he did. And so, 

yes, it's been great, and I hope that we can 

somehow continue to make this thing work. 

 And I know that, like you said, with 

Billy, that we had the ability to use it this 

year if we previously purchased it, and we do 

have a lot of inventory for this year.

 MS. BEHAR: Okay, any other 

questions?

 MS. OAKLEY: Hi, this is Emily, just 

a point and reminder. I do wonder if people 

could state their name and affiliations before 

they speak.

 MS. BEHAR: Okay. So, thanks. Okay, 

so we're going to Jennifer Daniels. So she's 

with Windy Creeks Farms. And on deck is Jane 

Iseley and Alex Watkins. Jennifer, go ahead.

 MS. DANIELS: Okay. As you just 

stated, my name is Jennifer Daniels, and we 

operate or have about a 250-acre organic farm 

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that operates under Windy Creek. And we are 

located in eastern North Carolina as well, in 

Sampson county.

 And thank you for having me or 

allowing us to be able to share our comments on 

this because it is important to our livelihood. 

I am following what Billy and Peyton have already 

said. 

 The use of fatty alcohols in our 

operation is of primary importance. The main 

reason of that is because tobacco, typically 

the organic tobacco brings us in triple the 

revenue that our small grains bring in.

 We do typically grow about 40 acres of 

organic tobacco out of the 250. We grow some 

sweet potatoes and then we have the grains, wheat 

and soybeans. And every year we have, we're 

trying to add a little more produce. And the 

last two years, we've grown organic pickling 

cucumbers. And this year we're actually trying 

to grow some organic jalapeno peppers.

 So with all of that in mind, the main 

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reason we need this fatty alcohol support is to 

help reduce our labor and time in the field to 

remove these suckers. We need to be able to do 

that because those suckers actually attract 

pests, the way the aphids there, which also 

damage our tobacco.

 And if the suckers remain in there, 

the energy goes to feeding those instead of the 

leaf, which is where we actually, you know, make 

our money, is harvesting that leaf.

 So without the sucker control, it's 

going to damage our yield and our quality of our 

tobacco, so, therefore, it takes affects our 

margin of profit. 

 And in our operation, the labor, hand 

labor, does actually go in with the crop rotation 

and it can inhibit it, the more time that we have 

to stay on top of it and suckling.

 Because we typically do the cucumbers 

that start off in June, and then we'll -- well, 

where we're just in peppers, the whole time we're 

growing tobacco, it's harvesting our cucumbers 

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and our peppers as well. 

 And managing that labor, so you have 

time to do all of those things makes a 

difference. And I personally love the fact that 

we're feeding people organic food, you know, so 

that organic tobacco it actually sustains our 

farms as far as the overhead with equipment and 

the cost of land rent. 

 There are a lot of conventional 

farmers. The organic community is growing in our 

area, but land rent is, in my opinion, it is high 

and a big portion of our cost. So the use of 

fatty alcohols helps make our tobacco more 

productive as far as claimed income. 

 I have asked when, about two years 

ago, when we first got -- oh, I talked too much. 

Anyway, wrapping up then, I sent an email to NC 

State inquiring about what in the world we were 

going to be able to use. And he has told me 

there is not an effective -- anything else, 

effectively, that we could use to be able to 

replace that fatty alcohol. 

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 MS. BEHAR: Okay, well, I thank you, 

Jennifer. Any questions from the Board? 

 MR. ELA: Harriet, this is Steve Ela, 

if I could ask a question. 

 MS. BEHAR: Okay. 

 MR. ELA: Given -- and I could have 

asked this from the previous two speakers as 

well, but given that, if you -- that you're able 

to move -- it wouldn't matter if you used that 

clause, if you had that on hand, if you use it 

up, will this be a problem for you if the Board 

doesn't act this in the fall, but you have to 

carry it over to the spring, a year from now, 

would that problem inhibit your ability to use 

this -- you know, assuming we had approval of 

that. But would it cause a problem, would that 

be a delay or, in looking back to?

 MS. DANIELS: I am concerned with the 

amount that -- we do have some on hand, but it's 

a narrow margin for what we'll need. So I am 

definitely for the temporary allowance if that's 

possible. 

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 MS. BEHAR: Thank you, Steve. Anyone 

else from the Board have a question? Okay, I 

have one question. What type of insects are 

attracted to the suckers and what materials do 

you use to control them?

 MS. DANIELS: The aphids, they just 

suck -- anyway, they take the nutrients and 

basically take the quality from the roots. And 

basically we don't use anything against them. 

Just the sooner you can get the flowers and the 

suckers off, and that actually gets rid of the 

problem.

 MS. BEHAR: Okay, that was Harriet, 

for the transcription. Okay, anyone else? Well, 

thank you so much, Jennifer. You did a -- well, 

the three of you and thank you for their 

comments, have been very useful on that material.

 So next up is Jane Iseley with Alex 

Watkins and Steve Etka on deck. Jane?

 MS. ISELEY: Yes, thank you. I 

appreciate you all speaking with us today. This, 

as we've indicated, this is sort of a do or die 

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project for those of us who grow organic. I've 

been growing organic for about --

 MS. ARSENAULT: Ms. Iseley, I'm sorry, 

this is Michelle from the National Organic 

program. Jane, could you just state your name 

and affiliation, for the record? It's for the 

transcriptionist that's on the phone with us, and 

then you can start. And I haven't started your 

timer yet. Thank you. 

 MS. ISELEY: Well, I'm short spoken, 

so maybe I'll be fine. 

 MS. ARSENAULT: Okay.

 MS. ISELEY: My name is Jane Iseley, 

and I appreciate you all talking with us today. 

I'm on a farm in Burlington, North Carolina. The 

family's been here since 1790, and a good part of 

that time we've been growing tobacco.

 I started growing organic tobacco 

maybe 22 or 23 years ago. I'm my grandfather's 

only grandchild, and that's the reason I'm 

farming now. We start with strawberries in the 

spring and move into vegetables with a farm 

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market in the summer and then pumpkins in the 

fall with hay rides and try to get as many people 

to the farm and encourage the people to come out 

so that we can build our agricultural base of 

support.

 We also have 150 head of beef cattle. 

But what pays the bills for us and keeps us 

farming is organic tobacco. It's -- you've 

talked about the time involved in it. And I'm a 

curiosity devil. I've done some work with it.

 The nature of the plant is to 

reproduce seeds, of course. And this is done 

with a flower. And you break that, what's called 

topping. And you break that top flower out. And 

when that happens, that wakes up the plant, and 

it wants to grow suckers. And each of --

approximately 22 leaves will grow on one plant. 

 And at that axis, each leaf produces 

3 suckers. So that was the reason, when Billy 

was saying that he had to spray four or five 

times, that's what we're trying to do, is to get 

those new suckers taken care of. 

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 So that math adds up to that 20 

leaves, and you've got three suckers per leaf. 

So you're up to 60 suckers per plant and then we 

have about 6000 plants per acre. We plant them 

22 inches apart. So you're at 360 suckers that 

you've got to deal with per acre.

 Now we, as those -- we don't have as 

much as we used to have. We only have 20 acres. 

And so that equates to -- we've got 7.2 million 

suckers to deal with. And you can imagine what 

kind of labor that takes. 

 And when you get right down to it, 

folks, as far as I'm concerned, if we lose this 

opportunity to control the suckers, I'm out of 

the tobacco business and basically out of 

farming. There's no way that we can pay the 

labor and make it all come out. Thank you. 

 MS. BEHAR: Thank you, Jane. Any 

questions from the Board? I have a comment, 

Jane. I live in Wisconsin, and we used to grow 

quite a bit of tobacco in southern Wisconsin, 

mostly for wrappers for the cigars and the 

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chewing tobacco. There is very little of that 

anymore. The government bought out a lot of our 

tobacco allotments.

 So to understand the culture, the 

entire tobacco in a region and that high-value 

crop that many smaller family farms relied upon 

to make the farming operation viable. So it may 

not be in North Carolina, but Wisconsin has -- I 

actually have a tractor on my farm that came from 

a tobacco operation.

 MS. ISELEY: It's probably a 140 

offset motor?

 MS. BEHAR: You got it. 

 MS. ISELEY: Yes, that was the 

farmer's green. You had to be able to seed that 

plant while you cultivated. In fact, I guess we 

were one of the few farms left doing that. We --

I have three 140s. They're great tractors.

 MS. BEHAR: Any other comments?

 MR. ELA: Harriet, this is Steve Ela. 

Jane, I'm going to ask you some questions that I 

asked Jennifer. 

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 If you -- if this product isn't 

reviewed thoroughly and expediently, do you have 

enough on-hand for another year at least or do 

you just have enough supply for this year?

 MS. ISELEY: I have enough for this 

year, and barely enough for this year.

 MS. ARSENAULT: Hi, everyone. This is 

Michelle from NOP. We're hearing some background 

conversations, so if you are not speaking, please 

put yourself on mute. Thanks.

 MS. ISELEY: Thank you, folks. We 

appreciate your time. And I hope I get to farm 

some more.

 MS. BEHAR: Okay, thanks. Well, thank 

you. Okay, next up is Alex Watkins and 

Steve Etka after that and Amalie Lipstreu. And 

please state your name and affiliation.

 MR. WATKINS: My name is Alex Watkins. 

I'm an organic farmer from Creedmoor, North 

Carolina, and I am 48 years old. I want to thank 

you all today for allowing me to speak.

 I have 350 acres of organic land 

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certified. I'm a 4th generation tobacco farmer. 

I grow 100 acres of organic tobacco and 125 of 

organic wheat and 80 acres of soy bean.

 I started in 2003 with 10 acres 

organic tobacco. I increased it to 25 the next 

year, and then I was sick. I really couldn't 

plant any more. That was all I could actually 

attend. 

 We couldn't keep up with our labor 

costs and time needed to take care of it because 

everything was done by hand. And we did reap some 

soybeans and some mineral oil. Had a lot of 

issues with it. And when fatty alcohols were 

allowed, it really helped me to increase my 

productions. 

 And I grew, and it also freed me up. 

And I just want to say if you decide not to allow 

the fatty alcohols, I think it would be -- it 

would cut organic production and possibly in 

North Carolina or, in my opinion, possibly by 75 

percent.

 And because of this, the wheat prices 

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and the soybean prices can't sustain us, and we 

can't keep our land rent paid and land certified 

because we can only make a small profit on the 

small grain.

 I went to planting wheat and soybeans 

as rotational crop for tobacco, you know, to also 

help me do my organic matter in the soil. And I 

think this would probably be the end of farming 

for me, at 49, if it was not considered next year 

because I just couldn't go back, with the labor 

costs and the fuel costs that we have now, to 

sustain, to be able to farm.

 I just want to thank you all today for 

allowing me speak, and I would to ask all of you 

on the Board to consider to allow the use of 

fatty alcohols for us in the future. Thank you 

so much. 

 MS. BEHAR: Any Questions from the 

Board for Alex?

 MS. OAKLEY: This is Emily Oakley. I 

just wanted to make a comment, thanking all the 

farmers for being on the webinar, and it's always 

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very helpful to hear directly from growers, so 

thank you.

 MR. ELA: Harriet, this is Steve Ela.

 MS. BEHAR: Any other --

 MR. ELA: I'll just ask you some 

questions that I've actually asked the previous 

two speakers. I asked, do you have -- how much 

supply do you have? Do you have enough for this 

year? And do you have enough for another year, 

if you need it?

 MR. WATKINS: Yes sir, I do have 

enough for the upcoming 2019 year, yes.

 MR. ELA: And what about 2020?

 MR. WATKING: No. No, sir.

 MR. ELA: Thank you. 

 MR. WATKINS: You're welcome. 

 MS. BEHAR: Okay, anyone else? Okay, 

next up is Steve Etka and then Amalie Lipstreu --

she can tell me how to say her name -- and Julia 

Barton. Please state your name and affiliation. 

 MR. ETKA: I'm Steve Etka, Policy 

Director for the National Organic Coalition. And 

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I greatly appreciate NSOB and NOP efforts to seek 

feedback about actions needed to address 

organic fraud. 

 NSOB discussion documented addresses 

a broad list of actions that NOP and Congress 

should take to address fraud. Areas that should 

be prioritized, in our view, include, one, 

eliminating exclusions from certification for 

uncertified handlers in the international supply 

chain.

 The 2018 Farm Bill gives NOP the core 

authority and mandate to issue regulations to 

take this action by December of 2019. And, two, 

make improvements to the organic integrity 

database because significant drops in data 

collection, especially for organic acreage data, 

greatly impeded the ability to deter fraud.

 In addition to the newly appointed 

enforcement authorities in the 2018 Farm Bill, we 

are also hearing additional authorities that 

maybe even by entity include staff sale authority 

and authority to take action against fraud 

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involving operations that have surrendered their 

organic certificates.

 We should explore short term 

administrative solutions to these problems, if 

possible, because the next Farm Bill process will 

not start until the year 2022. NOC's written 

testimony includes a prioritized list of these 

and other actions that should be taken to deter 

fraud.

 In additional, NOC members recently 

met with staff from Customs and Border 

Protection, the lead enforcement agency at the 

U.S. ports of entry. We were alarmed to learn 

the CBP has little advance information about 

cargoes headed for U.S. ports of entry and that 

additional legislation would be needed to require 

manifests including those details.

 We also learned that CBP has MOUs with 

USDA that are not procedures used in handling 

imported agricultural products. There's -- MOUs 

should be updated to address procedures for 

imported organic products, specifically --

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particularly requires CBP to check organic 

certificates at ports of entry.

 Lastly, we have many domestic 

enforcement problems as well, particularly in the 

organic livestock and dairy sectors. And, 

therefore, we think that we'd like to see NOP 

issue a final origin of livestock rule that will 

clarify the requirement for the transition of 

dairy cows into organic, to take enforcement 

action against bad actors in the dairy sector and 

their certifying agents who have not -- who 

are not following the access to pasture standards 

and unlikely to reinstate the organic livestock 

and culture practices rule to require greater 

consistency in organic standards, particularly 

with regard to providing true access to the 

outdoors for poultry.

 In closing, in recognition of the need 

for NOP to have adequate resources to do this 

work, NOC has advocated for and Congress has 

provided increased funding over the last couple 

of years, and NOC is continuing to seek 

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additional funding for NOP for 2020 as well. 

Thank you. 

 MS. BEHAR: Thank you, Steve. Any 

questions for Steve from the Board? Okay, thank 

you, Steve. Next up is Amalie, and please state 

your full name, so I can learn how to pronounce 

your last name, and your affiliation. 

 MS. LIPSTREU: My name is Amalie 

Lipstreu, and I'm the policy director for the 

Ohio Ecological Food and Farm Association.

 First OEFFA thanks the Board for 

requesting the energy infrastructure on organic 

farms be added to their work agenda. 

 While we understand there are a number 

of pressing issues to be addressed, inclusion of 

this issue will provide resources for farmers and 

certifiers, help organic farmers keep their 

certifications and foster consistent 

implementation of how these issues are addressed.

 Secondly, OEFFA appreciates the work 

of the Board and the NOP to address the issue of 

import fraud. OEFFA has provided detailed 

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organizational comments and you have the 

opportunity to hear directly from many of our 

farmers on the importance of this issue and I 

would say their sense of urgency remains.

 We request that rulemaking and process 

improvements happen in the short term. Our 

producers and the markets have little patience 

for belabored politics. 

 We need rulemaking, and we need 

discreet actions in the near term including 

propose a rule requiring certification of 

handlers who take possession of organic products 

in unsealed containers, handlers who buy, sell or 

broker product while taking possession as well as 

handlers who manage private labels that have an 

organic claim.

 Do whatever it takes to get harmonized 

tariff codes into aid before the end of this 

year. The NOP should set up a meeting with 

International Trade Commission in the coming 

months to establish an ambitious goal for the 

number of HT codes that can be completed by the 

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end of 2019 with at-risk commodities being 

prioritized.

 Recommend the USDA target specific 

ports of entry for green commodities until 

Customs and Border Protection has legislative 

authority needed to gather detailed ship manifest 

data that will allow for advanced tracking of 

organic shipments into the U.S.

 This will allow for the targeting of 

staff and resources closest to these ports for 

review of certification documents. Direct the 

USDA to raise awareness of organic import fraud 

agency wide and prioritize inspection of at-risk 

commodities providing comprehensive oversight and 

support that will ensure the NOP is successful in 

their efforts.

 And finally, the Board should 

recommend the NOP pursue legislative stop sale 

authority in addition to the authorities 

previously mentioned, for Customs and Border 

Protection.

 We appreciate the work of the Board 

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and the opportunity to comment via webinar. 

Thank you. 

 MS. BEHAR: Okay, any comments from 

the Board, questions? Amalie, I have a question 

about the energy infrastructure on organic farms.

 MS. LIPSTREU: Mm-hmm.

 MS. BEHAR: I'm wondering, what do you 

see this work agenda item resulting in? Would it 

be like an instruction to certifiers on how to 

work with operations that control --- they've 

been told there'll be a pipeline or something 

coming through the land and -- with that? Or 

would that be a rule change? Or what are you 

looking at? 

 MS. LIPSTREU: Well, what we're 

hopeful to see, Harriet, is some guidance on 

instructions to certifiers so that they have more 

tools and resources in working with producers 

that are facing this kind of infrastructure so 

that they can do what they need to do to protect 

their organic certification and stay in 

production. 

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 You know, we brought up the issue of 

the organic agriculture impact mitigation plan 

before, which is a tool that's been very 

successfully, with the Federal Energy Regulatory 

Commission, with pipeline companies, producers 

and certifiers.

 So I think, you know, some kind of 

guidance or instruction that can provide tools 

and consistency will be beneficial in the long 

term.

 MS. BEHAR: Thank you. 

 MS. LIPSTREU: Thank you. 

 MS. BEHAR: Any other comments from 

the Board? Okay, next up is Julia Barton with 

Michael Sligh and Amber Pool deck. Julia, please 

state your name and affiliation.

 MS. BARTON: Good afternoon. This is 

Julia Barton with the Ohio Ecological Food and 

Farm Association. Can you hear me okay?

 MS. BEHAR: Yes.

 MS. BARTON: Okay, thank you to the 

Board for your service and for the opportunity to 

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offer public comment over the phone. We would 

like to thank the Board, again, for its efforts 

to add energy infrastructure impact on organic 

farms to its work agenda.

 We see some potential positive 

outcomes of this topic being added to the work 

agenda that could include a potential panel 

discussion, maybe at the fall '19 NSOB meeting, a 

discussion document that could help unpack the 

issue. 

 And as Amalie and Harriet just 

discussed, we'd love to see an assessment of the 

utility and applicability of organic agricultural 

impact mitigation planning for producers as well 

as an eventual proposed guidance for instruction 

for certifiers regarding how to work with farmers 

that are faced with this infrastructure so that 

certification can be maintained.

 We urge the NOP, in the spirit of 

consistency of enforcement, to support the NOSB 

as it begins to engage with this issue. As you 

know, farmers are faced with these challenges 

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even as we speak.

 Further, OEFAA appreciates the NOSB 

work to address the difficult of GE contamination 

and its proposal and questions for the community 

regarding genetic integrity transparency of seeds 

grown on organic land.

 In preparation for this semester's 

comments, we held two calls with OEFFA grain 

growers to gain feedback on this proposal. The 

growers were very clear that the work and 

financial burden concern them. 

 They feel strongly that the burden of 

testing for organic seed should fall on seed 

companies and that the level of contamination 

should be provided to the farmer ahead of time so 

that one knows what one is purchasing. It ought 

to be printed clearly on the seed tag or invoice. 

 They also suggested that suppliers 

stack one sample per lot, which would be far more 

efficient and effective than analyzing data from 

each individual grower across the country.

 Regarding who ought to compile and 

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hear the data, OEFFA prefers that the NOP 

subcontract with an entity to receive and 

summarize this information for the public. 

Perhaps, if just in groups within the community 

even, which are used to this sort of data 

gathering and analysis would be well-suited to 

the task.

 Most importantly, we must get started 

with this work so that we can build from the 

information gathered and address GE contamination 

in seed across the Board.

 We support the initial focus on corn, 

on transparency and on data gathering to foster 

the eventual development of special levels for 

contamination. Given the current climate, we are 

supportive of the recommendations for the NOP to 

achieve this brand instruction to certifiers.

 We appreciate your efforts, and we 

urge for a re-movement of this proposal. We wish 

you a productive meeting in Seattle, and thank 

you again for your time and your service. Thank 

you. 

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 MS. BEHAR: Okay, any questions form 

the Board?

 MR. BRADMAN: This is Asa Bradman. I 

have a question. You mentioned the organic 

mitigation plan and protecting certification. Do 

you of growers, farmers who have lost their 

certification because of issues with energy 

infrastructure? And can you give some specific 

examples, just to make it more personal, if 

possible?

 MS. BARTON: Sure, be happy to. And 

we have several specific examples that we'd be 

happy to share if you'd like more information on 

that, Asa. 

 One comes to mind, in particular, 

however. We have a grower that's just a little 

bit south of where I am today, in Apple Creek, 

Ohio, which is kind of a hilly -- rolling, hilly 

area, a lot of Amish and Mennonite producers in 

that area.

 And he had a pipeline come through his 

farm, just two seasons ago. The challenge there 

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was not that he lost his entire certification of 

the farm, but that he had to retransition the 

area adjacent the pipeline because of the 

materials that were used both in the pipeline's 

construction and in the management of that area 

thereafter.

 So the company did not adhere to 

organic production practices in terms of the --

after the pipeline went in and the way that they 

annexed the land. 

 So he is currently in --

retransitioning the land near the pipeline. In 

his case, it was particularly challenging because 

he was managing an organic dairy herd during that 

time and the herd had to cross the area where the 

pipeline was located. 

 And he had to somehow make sure that 

the herd was not grazing in that lane where the 

pipeline, you know, it impacted, if you can 

imagine, kind of a hundred-foot block where the 

pipeline goes through, the edge of the lot, on 

either end of the pipeline. 

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 And he had to make sure that the cows 

weren't grazing there. So working for OEFFA's 

education staff, we were able to brainstorm ways 

to mitigate that, but, you know, they were pretty 

labor-intensive management strategies when the 

cows have to be able to get up to the parlor and 

access water in various ways, meaning being able 

to access that lane freely.

 So this is one example, but we have 

several others we'd happy to provide to you if 

you'd like to discuss it further. 

 MR. BRADMAN: Yes, thank you. That 

was really informative. And something that might 

be helpful, which is perhaps you could write up a 

little report that just gives case studies and --

 MS. BARTON: Sure.

 MR. BRADMAN: -- even -- I think 

that'll help guide the conversation and also 

bring it down to a very concrete, personal level. 

And that would be --

 MS. BARTON: And I'd be really happy 

to. 

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 MR. BRADMAN: Thank you. 

 MS. BARTON: Sure. Thank you. 

 MS. OAKLEY: Harriet, this is Emily. 

Could I ask a question of the --

 MS. BEHAR: Go ahead, Emily.

 MS. OAKLEY: Thank you. Could I ask 

a question of the program to see if they have an 

update on this work agenda item request?

 MR. LEWIS: Thank you, Emily. This is 

Paul. Yes, we have the work agenda item request. 

It's still in review, in the clearance process 

here. Obviously, the requests that come in 

require different levels of review here in the 

department. 

 So it's still in the review process. 

I don't have anything more to update in terms of 

timeline.

 MS. OAKLEY: Thanks.

 MS. BEHAR: Any other questions? I 

had a question, Julia, on the genetic integrity 

of organic seed. So I just want to get clear, it 

sounded like your group of growers are supportive 

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of transparency. There was some concern if it 

would make the seed cost more.

 But I think we have found that many of 

the seed suppliers that sell, that are already 

organic, they already do the testing, so I'm not 

sure they'll be a greater cost. 

 But I'm just wondering if they 

suffered at all by not knowing which is the 

current atmosphere that they inform in, where 

they buy a seed and they don't know what they're 

planting.

 MS. BARTON: Yes, Thank you, Harriet. 

The growers that we spoke with about this issue -

- so OEFFA has a very active grain grower's 

chapter, and I think you all heard several of 

them in the fall, in the webinar, were able to 

provide some comment.

 We stay in close touch with them on 

these issues that directly impact their work. 

And they understand that the costs, specific 

costs ultimately will alter the farmer. They're 

aware of that. 

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 They are concerned about that 

additional cost, but more in terms of the time 

that they would spend than they were in terms of 

the cost of kind of the -- that's necessary for 

the transparency. Because they recommended, like 

I said in the comment there, let's think this 

through and, from their perspective, be as 

efficient as possible.

 And they think that we've got a lot of 

seed for the folks handling that feed, to take 

the sample rather than for, say, a hundred 

farmers, to apply for that lot and take a sample. 

That was one recommendation they made.

 They would appreciate knowing upfront 

what they're paying for. So some of them already 

buy some of the more pure varieties and pay a 

premium for those. So they're aware of that 

concept. 

 And I think Albert Lea is one of the 

companies they noted that was providing a more 

pure corn seed currently. And some of them are 

already paying for that additional kind of 

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service that Albert Lea is providing in doing the 

testing and providing that transparency. 

 So they were not opposed to that. 

They just -- they want to see to it that as much 

of the burden that can be placed doesn't all fall 

to the farmer. They know they're going to be 

paying more. They just would like us to be kind 

of thoughtful and intentional about the profits, 

that they don't have to do a whole bunch more 

sample taking and record keeping on their end. So

 MS. BEHAR: But we were kind of 

talking about --

 MS. BARTON: -- their positive about 

the idea of moving forward. Yes, ma'am?

 MS. BEHAR: Well, thank you. And I 

also enjoyed your written comments on that 

subject.

 MS. BARTON: Thank you. 

 MS. BEHAR: Any other comments for 

Julia? Okay, I'm going to move on to Michael --

 MS. ARSENAULT: Hey, Harriet? Sorry, 

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this is Michelle. Michael, if you don't mind me 

interrupting and stealing -- I won't take your 

time, actually. I won't start the timer. 

 I just wanted to do a time check, let 

folks know, you know, we're an hour in now to the 

three-hour webinar. Thank you so much for 

keeping the background noise to a minimum. I 

appreciate it. It makes my job -- makes my blood 

pressure stay down, so I appreciate it.

 And also, just a reminder to keep 

yourself self-muted if you are not talking. 

Thanks, everyone. All right --

 MS. BEHAR: Thank you, Michelle.

 MS. ARSENAULT: -- Harriet, all yours 

again.

 MS. BEHAR: Okay, thank you. Next up 

is Michael Sligh with Amber Pool and Nicole Dehne 

on deck. And, Michael, please state your name 

and affiliation.

 MR. SLIGH: Michael Sligh, former NOSB 

member. Thank you for your commitment to 

ensuring organic integrity and trust in the USDA 

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label, which is at the heart of our success to 

date.

 I'm summarizing my written comments. 

First, I would like to support the organic 

tobacco farmers that you heard from earlier today 

on their essential need for fatty alcohol use in 

tobacco suckering. 

 It is urgent that this petition be 

completed in time this year to allow clarity for 

the 2020 farming season. 

 Secondly, I strongly support the NOSB 

work on new genetic techniques, to continue to 

move forward and that the existing 

recommendations moved into guidance to certifying 

operators as soon as possible. It's critical 

that we remain proactive to avoid problems in our 

market as we move forward.

 And, thirdly, I want to bring up a 

larger issue of consistency of our organic 

conformity assessment system as well as our 

enforcement and the need for ongoing peer review. 

 As we all know, the OFPA's promising 

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key goal was to develop a level playing field 

where all operators would be held to the same 

standard regardless of size, geography or 

approved organic production or processing system.

 I remain alarmed that we have yet to 

deliver on this key goal in several important 

ways. We continue to have a lack of consistency 

across inspections, certifications and 

accreditation as well as the interpretation of 

regulations across our system for standards that 

have been approved, especially for large scale 

livestock systems.

 Secondly, the allowance of production 

systems for which there are no standards, which 

would include broad categories of hydroponic and 

container grown production systems which have not

 MS. ARSENAULT: Michael, we just lost 

you. I'm going to pause your time here.

 MR. SLIGH: Hello? Hello? I'm here.

 MS. ARSENAULT: All right, we just 

lost you momentarily, so if you want to repeat 

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the last few words you said.

 MR. SLIGH: Well, I'm not sure where 

you lost me. I'm sorry that I was lost. It 

won't be the first time. 

 I was speaking about production 

systems for which there are no organic standards. 

Particularly, my concerns around the allowance of 

hydroponic and container grown production systems 

which have not been approved and may not be 

compliant with organic standards.

 Thirdly, the urgent need to publish 

the 2018 NOP Peer Review Findings and an urgent 

need to conduct the 2019 Peer Review and strongly 

urge that the focus be on these issues of 

consistency. 

 I also strongly urge all stakeholders 

to continue urging Congress and USDA to move 

forward as quickly as possible on implementing 

new Farm Bill enforcement regulations as every 

day organic farmers continue to be harmed by 

employing products that may not meet our strong 

U.S. organic standards. 

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 This is another example of this uneven 

playing field that must be corrected. And then, 

finally, I draw your attention to a 

infographic which I have included in my written 

comments as an illustration of how, if our 

organic integrity and trust is eroded by 

inconsistency and failure to comply, it all ties 

together into this larger issue. 

 I strongly urge the NOSB to take up 

these urgent issues. Thank you very much.

 MS. BEHAR: Any questions for Michael? 

Michael, I have a question. A case over time, 

this, the peer review has been kind of a 

continuous issue that the NOP has not been able 

to kind of get a consistent flow of this where it 

just happens every year and it's by the same 

agency that oversees, so there's continuity.

 What do you recommend that the NOP and 

the NOSB could do to encourage this consistency 

and improvement in a peer review?

 MR. SLIGH: Well, first of all, it is 

just as important as inspection and certification 

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and accreditation. It is the only tool that both 

the NOSB and the NOP have to look at the overall 

whole system. 

 And it is the intended by law and 

regulation to happen on a regular basis, every 

year, and that those findings will improve our 

organic integrity and identify those places where 

we either have gaps or inconsistencies.

 My recommendation would be to attempt, 

in all due diligence, to complete these peer 

reviews within the allotted year and to get the 

findings out so that that learning can be built 

on in moving forward.

 I have submitted this infographic to 

show the importance of how inconsistency can lead 

to greater chances of fraud and an unlevel 

playing field for farmers. And so I would urge 

at looking at 2019 agenda, that that would be a 

very appropriate area for peer review this year.

 MS. BEHAR: Thank you, Michael. And 

that was a very interesting infographic. 

 MR. SLIGH: I'm glad you like it. I'm 

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merely passing this on. And it represents 20 

years of international organic conformity 

assessment and it was developed by the 

International Organic Accreditation Service.

 MS. BEHAR: Okay, anyone else?

 MR. ELA: Harriet, this is Steve Ela. 

I have a question.

 MS. BEHAR: Okay.

 MR. ELA: Michael, I guess two 

questions. The first is, at the start you were 

talking about fatty alcohols and you were urging 

us to take action as quickly as we can. 

 What are the -- could you talk about 

that a little bit more in terms of what the 

problems are if we aren't able to take action 

fairly quickly?

 MR. SLIGH: Sure. I think, as you 

heard from the farmers earlier in the call, 

they're using up what they have. They need to 

know with certainty that they can continue to 

grow this crop.

 As you heard, it's kind of a lynch pin 

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in their economic model for organic rotation. 

And my worry is that, while we had hoped that 

this topic could have been taken up at this 

meeting, we understand there were various delays.

 And so now you have the petition, but 

you won't be able to vote on it until the fall. 

That's about as late as we want to push this 

thing in order for them to be able to know what 

they're going to do for 2020. 

 As you heard, some of these farmers 

may not even continue farming if they don't know 

the answer. So I guess, Steve, my concern is I 

just hate to see this thing get strung out any 

further than we can possibly avoid because of the 

uncertainty. They need to know early.

 MR. ELA: Great, thanks. Thanks for 

that. And then my second question is, with 

regard to hydroponics and container production of 

not having standard or consistent standards, is 

there anything particular on that, that you see? 

 I mean, I know it's a broad key 

question, but is there anything specifically, 

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that you're seeing issues on right?

 MR. SLIGH: Well, I think the macro 

concern is that if we are allowing operations to 

be included in organic that do not have specific 

standards, then it is very difficult and creates 

an inconsistent marketplace in terms of 

inspectors knowing what should be allowed and 

what should not be allowed.

 And the fact there is not specific 

standards creates this unlevel playing field and 

a potential for operations to be included that 

are not compliant with all of the other critical 

components of the organic regulation such as 

biodiversity, such as crop rotation, such as 

building of soil. 

 All of these are essential components 

of the organic system. And to allow hydroponic 

and container operations by some certifiers and 

not others without any common standards is a 

recipe for failure to comply. Hello?

 MS. BEHAR: Yes, hello. Thank you.

 MR. SLIGH: Hello? Okay. Couldn't 

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tell if I lost you or not. 

 MS. BEHAR: No. We heard you. Good 

words.

 MR. SLIGH: All right. Keep up the 

good work. Thank you very much.

 MS. BEHAR: Okay. Anyone else on the 

Board have a question? Okay, we're going to move 

on to Amber Pool.

 MR. SLIGH: Thank you. 

 MS. BEHAR: You're welcome, Michael. 

Nicole Dehne and Jaydee Hanson on deck. And 

please state your name and affiliation. Amber?

 MS. POOL: Hi, I'm Amber Pool. I work 

as a senior farm certification specialist at 

CCOF. CCOF is a nonprofit organization governed 

by the people who grow and make our food.

 305 CCOF members list horticultural 

oils on those OSP. These horticultural oils are 

used for both insect and plant disease 

management. Horticultural oils are often used in 

combination with other allowed plant disease 

management practices to ensure crops are 

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protected.

 MS. BEHAR: Excuse me. Michelle, can 

you -- are other people having a hard time 

hearing Amber? 

 MS. ARSENAULT: I can hear you, but, 

Amber, if you could get a little closer to the 

mic, that would great. Thanks.

 MS. POOL: Is this better?

 MS. BEHAR: Are you on a speaker phone 

or a headset or --

 MS. POOL: I'm on a conference room 

that has a conference room setup.

 MS. BEHAR: Is there any way you could 

actually get on a handset?

 MS. POOL: Yes, I can call you back.

 MS. BEHAR: Maybe we should do that 

because I was kind of catching only every third 

word or so.

 MS. POOL: Okay.

 MS. BEHAR: Great.

 MS. POOL: I will call back right now.

 MS. BEHAR: All right, we'll go to 

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Nicole next, and then we'll bring back Amber. 

So, Nicole, please state your name and your 

affiliation.

 MS. DEHNE: Okay, can you hear me? 

This is Nicole Dehne.

 MS. BEHAR: Yes.

 MS. DEHNE: Oh, great. Okay. So my 

name's Nicole Dehne. I'm the certification 

director for Vermont Organic Farmers. And VOF, 

we're the USDA accredited certifier owned by 

NOFA, Vermont. We certify over 700 organic 

producers just in Vermont. 

 And I just want to start by thanking 

the NOSB and all the members for all your hard 

work and the opportunity to give comment today on 

a few agenda items.

 The first one, I just wanted to say 

that we appreciate the NOSB adding paper products 

to your work agenda in a timely manner. VOF 

continues to stress the importance of this 

product of small scale vegetable producers in 

Vermont. 

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 We request that when the NOSB reviews 

this material, that virgin paper be included as 

part of that review. This may mean requesting 

that the technical report includes virgin paper 

as well as recycled paper.

 If additives such as synthetic fibers 

are a concern, then allowing the virgin paper may 

offer better control over what additives the 

paper contains. 

 And in addition, we ask that the NOSB 

take a practical approach to reviewing this 

material, understanding that paper is already 

widely used in organic systems as mulch, pots, 

compost, seed stock, et cetera.

 Secondly, on vaccines, we appreciate 

the subcommittee's emphasis on the importance of 

vaccines to organic livestock producers. We 

acknowledge vaccines play a critical role in 

preventing disease. 

 We believe that the current 

regulations prohibit the use of vaccines that are 

produced with excluded methods unless they're on 

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the national list specifically. Currently, we 

are reviewing all the vaccines used by our 

producers to determine if those vaccines have 

been produced with excluded methods.

 We have not found that the livestock 

producers we certify, which are mainly dairy, 

small scale beef operations, pork and poultry, 

have needed a vaccine produced with excluded 

methods. 

 But we acknowledge we do not certify 

large poultry or pork operations, and we 

understand that there may be vaccines needed by 

livestock producers in other parts of the country 

that are not needed in Vermont.

 Therefore, we support the change 

proposed by the subcommittee that would allow 

producers to use vaccines made from excluded 

methods when alternatives are not commercially 

available.

 And for clarity, we suggest using a 

definition of commercial availability that's 

similar to what's used in seeds and plants and 

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stuff, so quality, quantity and maybe specificity 

to a disease or a health issue. And if 

documentation of commercial availability could 

include statements from a veterinarian and 

statements from suppliers of vaccines. 

 And then lastly, just to remark on the 

embryo transfer, over the last 15 years we've 

gotten maybe one or two questions about the use 

of embryo transfer on organic farms.

 So it's always been kind of our 

interpretation that as long as no hormones were 

used to synchronize the animals who received the 

transferred embryo, that the process could be 

approved. But having said that, we've not had 

any producer interested in the process who felt 

willing to take the risk of the transfer, of the 

embryo transfer without using the hormones to 

synchronize the estrus.

 So I think, therefore, we're kind of 

sharing our experience that, in -- this 

technology has not been in high demand nor a 

necessity for livestock producers in Vermont. 

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And that's all I've got today. 

 MS. ARSENAULT: Perfect timing. Oh, 

Harriet, we have you muted. Hold on one second. 

I'm unmuting. Sorry.

 MS. BEHAR: You muted me??

 MS. ARSENAULT: All right, go ahead, 

Harriet. Thank you, Nicole. 

 MS. BEHAR: Any other questions from 

the board? Okay, well, Nicole, you had a few 

issues that are on the lead on. So thank you for 

the information on the vaccines.

 And, but I want to ask you something 

about the embryo transfer. So if a producer did 

approach you and the embryos came from an animal 

that had been treated with hormones, but the 

receiving animals had not, that would be okay 

under Vermont? Is that what you said?

 MS. DEHNE: That's, I mean, we never 

-- that had been kind of our interpretation of it 

a few years ago when we had been asked that. But 

we never necessarily had to make a final policy 

on it because it became a moot point once we told 

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the producer that they couldn't use any 

synchronizing hormones on the receiving animal.

 So we never really had to make a final 

policy, but we were leaning in that direction of, 

well, you know, you could have 

semen from a non-organic animal, but you know, 

like you said, collects embryos as well.

 MS. BEHAR: All right, but the semen, 

I don't believe, comes from animals that have 

been treated with hormones. 

 MS. DEHNE: Yes, that might be true. 

But we weren't testing, so it was kind of like an 

understanding that you weren't starting until 

they were being placed inside the -- an organic 

animal.

 MS. BEHAR: Right. Has there been any 

discussion about well if it became less expensive 

to do this type of embryo transfer would -- is 

there any concern about the narrowing of the gene 

pool or whatever if, you know, people are kind of 

mostly preferring these kind of super animals?

 MS. DEHNE: I mean, there might be 

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that concern. I guess what -- I don't -- it 

doesn't seem to me over the time that I've been 

doing this work that it has been a necessity for 

our producers. 

 So that was sort of the point that I 

wanted to make today, was we haven't -- this 

doesn't come up a lot. In my 15 years of being 

here, I think we've maybe been asked twice. So 

it's not -- you know, that could be because 

people have the understanding that it's not 

allowed but it's not something I've spoken to 

producers about, that they've been upset that 

it's not an allowed practice.

 MS. BEHAR: Okay. Any other 

questions?

 MR. ELA: Harriet, this is Steve Ela. 

I have a question.

 MS. BEHAR: Okay.

 MR. ELA: At the start of your, of 

this, you talked about paper products and 

encouraging us to allow the use of virgin paper, 

which we're certainly considering. 

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 But I did want to follow up a little 

more. One of the things we're running up against 

is finding out that there are synthetic fibers 

often used in some of these paper products. 

 So I have two questions. One, do you 

have any comments about whether we should allow 

synthetic fibers, plastics, for example, in those 

paper products or other paper products? And do 

you think we should just look at paper products 

or the use of paper in general, for example, 

paper mulch, other paper planting needs?

 MS. DEHNE: I guess my perspective 

would be that we need to be careful about 

requiring like a perfect material or thinking 

that we have a perfect material for use on 

organic farms.

 So, for example, I would liken it to, 

when our farmers apply a prohibited, you know, 

fertilizer or herbicide to their land, there's a 

three-year wait period for, you know, that land 

can qualify as organic.

 Now, we all know that that doesn't 

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necessarily mean that there are no residues three 

years after an application of a prohibited 

substance. But it's sort of the compromise that 

we've taken to say that this is doable and then 

this discourages the use of these materials.

 So I guess I'm likening that to this 

idea that, yes, I'm kind of leaning towards there 

may be some synthetic fibers but, you know, the 

amount that is actually being applied to the land 

is not very significant. And I think we need to 

be careful about being too idealistic and too 

pure in what we're allowing for farmers to use on 

their farms.

 MR. ELA: And would you have any, 

given that you think some is okay, would you have 

any thoughts on how much? I mean, I guess we --

you know, we're trying getting information on 

that. You know, what are the boundaries?

 MS. DEHNE: Right.

 MR. ELA: You know, if you allow some 

synthetic fibers, should it be less than 5 

percent? Should it be less than 50 percent? 

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Less than a hundred percent?

 MS. DEHNE: Yes, well, I guess if 

we're wanting to like avoid a situation like the 

bio-based mulch, then we should probably look to 

see what is doable in the marketplace to say, 

okay, but right now, the marketplace is, like 

most of these products have 10 percent of 

synthetic -- of their mass is synthetic fibers.

 Then maybe we start there with an 

encouragement for the market to reduce it to 5 

percent. So I think well the idea is to allow 

these products. So I think we want to do some 

research to say what's doable for the marketplace 

and start there, and maybe push the marketplace 

towards the use of less synthetic fibers once 

we've granted allowance. 

 MR. ELA: And then, finally, do you 

have any sense of whether we should expand the --

you know, other than distribution in paper pots, 

you know, where paper isn't production made 

without being necessarily specific to paper 

products? 

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 MS. DEHNE: Oh, sorry. Yes, you did 

ask that. Thank you. 

 MR. ELA: That's fine.

 MS. DEHNE: I think, yes, I think that 

would be good because we're -- now that this 

paper product issue has come up, we're starting 

to look at it's exposing other areas that, you 

know, we could potentially resolve these issues 

all at once.

 So I think it should be an allowance 

for, you know, paper as a synthetic potentially. 

It would be a broader and more useful thing for 

NOSB to pick up.

 MR. ELA: Great, thanks.

 MS. BEHAR: Okay. Any other 

questions for Nicole?

 MS. ARSENAULT: Harriet, I see Asa's 

-- this is Michelle. I see Asa's hand raised. I 

don't know if Asa has a question or not.

 MR. BRADMAN: I think Steve kind of 

asked my question, and I think this will be a big 

discussion item at the in-person meeting. 

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 MS. ARSENAULT: Okay, thanks.

 MS. BEHAR: I don't see the hands.

 MS. ARSENAULT: Okay, he put it down.

 MS. BEHAR: Okay, Jaydee Hanson with 

Dana Perls and Marina Abitia on deck. Jaydee, 

please state your name and affiliation.

 MS. ARSENAULT: Harriet --

 MS. BEHAR: Yes?

 MS. ARSENAULT: Sorry, we're going to 

go back to Amber because --

 MS. BEHAR: Oh, that's right. I 

forgot about her. Okay, Amber --

 MS. ARSENAULT: Amber, did you -- were 

you able to dial in?

 MS. POOL: Yes, I called in on a 

phone. Does it sound better.

 MS. BEHAR: Oh, so much better. 

 MS. POOL: Oh, okay, great. I tested 

it before I dialed in.

 MS. BEHAR: So you don't have a 

mouthful of marbles now.

 MS. POOL: Oh, okay, great. Okay. 

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Hi, I'm Amber Pool. I work as the senior farms 

certification specialist at CCOF. CCOF is a 

nonprofit organization governed by the people who 

grow and make our food.

 Currently 305 CCOF members list 

horticultural oils on those OSP. These oils are 

used for both insect and plant disease 

management. Horticultural oils are often used in 

combination with other allowed pest and disease 

management practices to ensure crops are 

protected.

 Typical brand names that we see 

farmers using are the IAP High 444 Supreme spray 

and the IAP Summer 415 spray oils. We don't 

currently know of any better alternative to 

horticultural oils. 

 Right now, 465 CCOF members list 

pheromones on their OSPs. Pheromones are used in 

a variety of ways to manage insect populations. 

Some pheromones are used to disrupt insect mating 

and others are used to monitor insects present 

and population densities. 

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 Pheromone use continues to grow in 

organic crop production as various formulations 

have been developed for specific target species. 

Common formulations we see farmers using are 

Checkmate and Isomate products.

 These materials are often the best 

choice for organic farmers dealing with invasive 

insects. And I'm complete. So if you have any 

questions, let me know.

 MR. ELA: Harriet I have a question. 

This is Steve Ela. I wanted to ask on these 

pheromones, do any of you -- do you allow any of 

your growers to use sprayable formulations? Or 

are they all put up in some sort of dispenser?

 MS. POOL: I can't - I don't know off 

the top of my head, but I can definitely get you 

that information. Most of the ones I'm familiar 

with are in a dispenser. But I can find out for 

you if we have any that are sprayed on.

 MR. ELA: Yes, I'd be curious if 

you're able to do that. Thank you. 

 MS. POOL: Okay. 

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 MS. BEHAR: Okay. We are behind a 

little bit on time. So just thought I'd put that 

out there. Next up is Jaydee Hansen with 

Dana Perls, Marina Abitia on chat. And, Jaydee, 

please state your name and affiliation.

 MR. HANSEN: This is Jaydee Hansen. 

I'm the policy director at the Center for Food 

Safety. And I'm I coming through?

 MS. BEHAR: Yes.

 MR. HENSEN: Okay. First, I want to 

thank the Board and its committees for all the 

work that you've been doing. 

 And I want to quickly highlight just 

three items. One, we were very surprised at the 

meeting in October when we learned from the staff 

of the NOP that the NOP itself was taking off its 

work agenda EPA.

 We had asked that EPA be, continue to 

do research. But also that other fact suppliers 

be looked at as well. These chemicals mimic 

hormones. They're endocrine disrupting 

chemicals. And we are going to be writing with 

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other groups to the Secretary of the Department 

of Agriculture asking that this be put back on 

the agenda. 

 But wanted to highlight that this 

year. This is essentially a loophole because 

these are used in contact substances, but they 

move into foods, particularly foods in the dairy 

range because these chemicals are attracted to 

fats. 

 I urge you to go to our comments and 

look at all of the ways these chemicals can 

disrupt development, in particular development of 

fetuses and young children. And I'll stop that 

there.

 We appreciate -- I'll move to excluded 

methods. We appreciate the materials that the 

subcommittee comments on, how transposons arrive 

from environmental stress, et cetera. And, you 

know, we agree that in the main, they are 

natural. Barbara McClintock even got a Nobel 

Prize for her work in this years ago. 

 But when they are developed with the 

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use of in vitro nucleic acids, they should be 

considered excluded methods. That doesn't mean 

they're natural any more once you've manipulated 

them with in vitro nucleic acid techniques.

 Moving on to cisgenics and 

intragenics, we support the intent of the 

proposed definitions, but we urge you to make 

them a bit more expansive. And we've given you 

language for that, making clear when this is a 

natural cisgenic product and when it might be 

considered a gene-edited product.

 We've added something I don't think 

your folks -- yes?

 MS. ARSENAULT: Yes, you've reached 

your time.

 MR. HENSEN: Yes, okay, well --

 MS. BEHAR: And thank you. I know you 

have very extensive written comments. But thank 

you for all those links.

 MR. HENSEN: Yes, thank you. Yes, I 

would just, in closing, thank you also for your 

work on silver dihydrogen citrate. It should not 

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be allowed. And thank you again. 

 MS. BEHAR: Okay. Any questions for 

Jaydee? 

 MR. BRADMAN: Yes. This is Asa 

Bradman. I have a question. Thank you for your 

written comments and the review of phthalates. 

Perhaps you could comment a little bit on the 

regulations and law within the OFPA and the 

justification for continuing with our BPA review 

and perhaps even expanding to other food contact 

materials.

 MR. HANSON: Yes. I mean, you know, 

one of the problems we have now is that we have 

not been taking food contact materials seriously 

enough. And BPA is -- if there is a huge camel 

in the tent, it's BPA and orthophthalates. These 

are active chemicals that aren't needed in 

packaging other than they make inner plastics 

more pliable.

 But, you know, I mean, they're counter 

to what organic is about, which is not using 

dangerous chemicals. And these are chemicals 

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that the more we study them, the more we are 

learning that at incredibly small amounts they 

make significant changes.

 They are chemicals like hormones that 

we need to move to get the guidance or, if 

necessary, the legislative language to exclude 

from organic.

 MS. BEHAR: Okay. Any questions?

 MR. CHAPMAN: This is Tom.

 MS. BEHAR: Anyone have questions?

 MR. CHAPMAN: This is Tom. I have a 

question. Jaydee, building on Asa's questions 

about BPA, what information -- what has Center 

for Food Safety done to survey to determine the 

usage of BPA in the organic industry? Is it 

widely used in the organic industry? Do you have 

any data?

 MR. HANSON: Well, we participated in 

a couple groups in having products tested. In 

particular, we chose products from Kraft Company 

that were both organic and non-organic and found 

that the organic products contained the same 

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levels of orthophthalates and BPA as did nonorganic.

 So there's no protection from BPA and 

orthophthalates just by being organic. The fact 

that you're wrapping these products in a plastic 

that does leach is a reason to, you know, totally 

exclude this from organic.

 MR. CHAPMAN: Is the orthophthalates 

about BPA or was it about phthalates or am I --

 MR. HANSON: Orthophthalates, the good 

news is BPA is being phased out because there's 

been so much attention. The bad news is 

orthophthalates are what's replacing it as 

plasticizers. So you really need to look at both 

at the same time.

 MR. CHAPMAN: Thank you.

 MR. HANSON: Thank you.

 MR. BEHAR: Okay. Just reminding 

people that we are getting a little bit behind 

here. So next up is Dana Perls with I'm not sure 

if Marina Abitia is on tap. If not then Jessica 

Shade will come after Dana. Dana, please state 

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your name and affiliation.

 MS. PERLS: Hi. Thanks so much. My 

name is Dana Perls, and I am the Senior Food and 

Technology Campaigner with Friends of the Earth. 

Thank you so much to the Board. And I'm going to 

provide comments specifically on the materials 

subcommittee, which was on the heated method.

 My comments echo the previous speaker, 

Jaydee Hanson. We would like to strongly urge 

the subcommittee to include transposons when 

produced using in vitro nucleic acid techniques 

as well as directed mutagenesis, cisgenesis and 

intragenesis in the excluded methods terminology.

 You know, we want to ensure that we 

have an organic certification that is actually 

addressing the emerging biotechnologies and the 

new techniques which are being applied to 

agriculture that otherwise NOSB in 2016 voted 

unanimously to update its organic standards to 

exclude ingredients derived from these next 

generation genetic engineering and gene editing.

 And as the NOSB has already 

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established, the new genetic engineering 

techniques are incompatible with organic and 

sustainable ag. And currently the list of 

techniques that are excluded methods is 

incomplete although we are doing a lot of work on 

them.

 So cisgenesis, including when 

techniques like gene editing are involved, and 

intragenesis both involve intentional genetic 

modification and therefore they should clearly 

fall under the NOSB's adaptive definition of 

modern biotechnology and should be excluded 

techniques.

 We also note that transposons, as was 

mentioned earlier, although they may occur 

naturally they may also be developed in a lab 

using in vitro nucleic acid techniques, in which 

case they fall under the criteria for the 

excluded methods.

 So we noted in our written comments, 

which we submitted, that there is a way that 

transposons could be more clearly defined so as 

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to indicate when the method would be considered 

an excluded method.

 And similarly while some mutagenesis 

arises from things like environmental stress, we 

note that directed mutagenesis should be 

considered an excluded method as it also involved 

in vitro nucleic acid techniques that are not 

part of the organism's natural evolution.

 So we really support the improvements 

and the updates to the organic standards, which 

are going to help preserve the integrity of our 

organic classification. And we strongly urge the 

NOSB to exclude new gene editing and synthetic 

biology techniques from organic by updating this 

list to include the noted excluded methods and 

the excluded techniques and also to continue this 

work to include additional genetic engineering 

techniques. Thank you so much.

 MS. BEHAR: The Board?

 MS. ARSENAULT: Sorry, Harriet. Go 

ahead. You were muted there for a moment. Go 

ahead and say again. 

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 MS. BEHAR: Okay. Thank you, Dana. 

Any questions from the Board?

 MR. MORTENSEN: Harriet, this is Dave.

 MS. BEHAR: Hey, Dave Mortensen.

 MR. MORTENSEN: Yes. I just wanted to 

thank the caller for the detailed comments and 

the written materials. I think it definitely 

helps us. Thank you.

 MS. BEHAR: Dave, you're breaking up 

a bit. And I'm not entirely sure if it's your 

line or if it's somebody else. So if you're not 

talking, please put yourself on mute. Thanks.

 MR. MORTENSEN: Okay. Yes, I was just 

thanking the last caller for the detailed written 

materials and comments. They were very helpful 

in us getting the kind of feedback that helps us 

with the new documents we've been working on.

 MS. BEHAR: Okay. Next up, I'm not 

sure. Is Marina Abitia with us from Porterville 

Citrus? Okay. We can come back to her at the 

end. Michelle did send me a note that she didn't 

see her name or a phone number for her. 

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 Okay. So next up is Jessica Shade and 

on deck will be Kathleen Mellone and Dallas 

McCann. So, Jessica, please state your name and 

affiliation.

 DR. SHADE: All right. Hi, everyone. 

Thank you so much for giving me time to comment. 

I'm Dr. Jessica Shade, the Director of Science 

Program for The Organic Center. We're a 

nonprofit that communicates and conducts organic 

research.

 And we are commenting in support of 

the continued listing of celery powder on the 

National List until we can find a commercially 

available substitute.

 And we've been working on this in 

collaboration with the Organic Trade Association, 

the University of Wisconsin and several other 

researchers, growers and processors. But a lot 

more work still needs to be done, and we need 

time to do that work.

 We worked with the Organic Food 

Association to convene the National List 

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Innovation Working Group. And their first 

priority was to find an organic alternative to 

conventional celery powder.

 We were awarded a small scale Organic 

and Research and Extension Initiative, OREI, 

Planning Grant. And then they complemented that 

with funding from the Farmers Advocating for 

Organic. And that was enough for us to build 

kind of the scaffolding for understanding what 

partners we need to work with, what crops would 

be most promising to investigate, what data we 

needed to collect and what research questions 

were most pressing.

 And we also developed a pilot project 

doing initial varietal testing in organic celery 

crops and broader testing of production scale 

organic celery.

 We have some preliminary data on 

feasibility to include in a NOFO for a million 

dollar OREI grant proposal. So, unfortunately, 

our OREI proposal wasn't funded last year, but it 

ranked really highly. 

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 So we're going to be resubmitting that 

this year. And what we're planning to do is 

identify a potential variety in management of 

organic crops even beyond celery that would meet 

the chemical specifications that we need for 

curing and can be easily incorporated into the 

crop rotation system.

 We also want to make sure that the 

crops we choose don't make the meat a funny color 

or change the flavor profile of the meat. My 

daughter loves the book Green Eggs and Ham, but 

the idea of green ham kind of makes my stomach 

turn.

 So crops like spinach with strong 

green coloring are more difficult to use. We're 

also thinking about how to make this profitable 

for farmers. So we're looking at crops that 

might be an incentive for expanding organic 

acreage. Plus we want to identify potential 

challenges that might be associated with the 

production of a high nitrate crop, especially 

with things like nutrient pollution. 

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 So all of this to say that, like, any 

resource project, replacing conventional celery 

powder isn't a simple task. It's pretty complex 

and so the timeline is slow, but we're working 

towards a solution.

 We have an amazing multi-regional, 

multi-stakeholder interdisciplinary team. What 

we really need to increase the pace of the 

project is funding, which we're hoping to get 

from an OREI grant in the next funding cycle. So 

thank you all for giving me this time.

 MS. BEHAR: Thank you. Any questions 

from the Board?

 MR. BRADMAN: Yes. This is Asa. More 

of a comment. Just as you know, this will be a 

big item for discussion at the in-person meeting 

in Seattle. But one thing I've learned in the 

discussions leading up to this is really the 

importance of more research and more work on 

this.

 So as a member of the Board, I 

definitely see the need for more research and 

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funding for the kinds of work that you're 

proposing, and I think that would help move 

things forward. Thanks.

 MS. BEHAR: Okay. Anyone else? Okay. 

Thank you, Asa. Next up, no, Marina. Okay. 

Next up is Kathleen Mellone with Dallas McCann 

and Andrew Dykstra on deck. Kathleen, please 

state your name and affiliation. Kathleen, are 

you there? If you're speaking, you're on mute.

 MS. ARSENAULT: Hey, this is Michelle. 

I have not been able to locate Kathleen on the 

webinar or on the phones. I'm not sure if she is 

on the call with us.

 MS. BEHAR: Okay. Okay. Well, I will 

then move to Dallas with Andrew Dykstra and 

Roland Cargill on deck. Dallas, please state 

your name and affiliation. Dallas, are you 

there?

 MS. ARSENAULT: He also may not be on 

the call with us. I haven't been able to locate 

him or her.

 MS. BEHAR: Okay. 

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 MS. ARSENAULT: I guess that's a 

unisex name.

 MS. BEHAR: From Tannersville, New 

York. I know where that is. Okay. Well, then 

it would be Andrew next with Roland Cargill and 

Kelsey Kerston on deck. Andrew, are you there 

and can you please your name and affiliation? 

Andrew? Michelle, do you have his phone number?

 MS. ARSENAULT: I see two other phone 

numbers from the same area code. Andrew, I just 

unmuted a 360 area code. Was that you? No. I'm 

not hearing anything. I have not been able to 

locate him in the phone list either.

 MS. BEHAR: Okay. Well this helps 

make up time, I suppose. But I do want to hear 

from people signed up. But okay, so next is 

Roland Cargill with Kelsey Kerston and, no, Andy 

Hudson, is he?

 MS. ARSENAULT: Andy cancelled.

 MS. BEHAR: Okay. Okay. So it's 

Roland Cargill up next, Kelsey Kerston on deck 

and Jennie Landry after Kelsey. Roland? 

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 MR. CARGILL: This is Roland Cargill. 

Can you hear me okay?

 MS. BEHAR: Yes. Please state your 

name and affiliation.

 MR. CARGILL: I'll do that. My name 

is Roland Cargill. I am a product registration 

specialist for Fair Products, Inc. I also serve 

as a consultant to Green Egg Supply, which is the 

petitioner for the fatty alcohols.

 My comments today will be directed 

primarily in response to the NOSB's earlier 

rejection of the petition to approve the fatty 

alcohols produced in organic tobacco.

 The NOSB determined that the use of a 

synthetic growth regulator in fatty alcohol was 

not compatible with a system of sustainable 

performance in agriculture.

 This statement by the NOSB was 

published without any rationale for such a 

statement. Our response to the statement was 

that with respect to the compatibility to new 

sustainable agriculture, which in its simplest 

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terms is the production of food, fiber or other 

plant or animal products using farming techniques 

that protect the environment, public health, 

human communities and animal welfare.

 We also contend that the use of the 

fatty alcohol product on organic tobacco was 

compatible with this process and this concept.

 Furthermore, since the natural source 

of the fatty alcohol is derived from palm oil and 

palm kernel oil, it is certified sustainable. 

And this fact should support that the fatty 

alcohol derived from palm oil and palm kernel oil 

should be judged sustainable.

 Therefore, we contend that the fatty 

alcohol derived from natural sources is 

compatible with organic agriculture, particularly 

organic tobacco agriculture.

 In addition to the 16 page TAP report, 

which provided a very thorough and comprehensive 

review, indicates that fatty alcohols do not, in 

fact meet -- that do, in fact, meet the Organic 

Food Production Act criteria for use in organic 

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production at Section 6517 on the National List.

 Specifically, the technical report 

determined that fatty alcohols would not be 

harmful to human health or the environment. The 

technical report stated there appears to be no 

known detrimental chemical reactions between 

fatty alcohols and other materials used in 

organic farming systems.

 It goes on to describe that toxicity 

is moderately low. And it indicates that fatty 

alcohols are suspected to be of low concern for 

environmental contamination.

 Furthermore, the report defines that 

there is no evidence to suggest that fatty 

alcohols cause an increase in susceptibility to 

human health, infants and children. It explains 

that no readily observable affects occur in the 

agri ecosystem and that they're known for their 

high degree of biodegradability in the 

environment.

 MS. BEHAR: Okay. Thank you. You did 

reach your three minutes. Are there any 

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questions from the Board?

 MS. BRADMAN: Hi, Harriet. This is 

Asa. I was on mute. I just have a quick 

question and maybe it's kind of internal 

struggle. I'll just make a comment and maybe 

this is for discussion at another point.

 But you mentioned public health and 

the effects on infants and humans. As a parent 

with teenagers, I have seen an enormous increase 

in use of tobacco products and the very serious 

health impacts of that. You know, of course, 

what's linked here is a reproductive toxicant. 

Cigarettes are carcinogens. There are many, many 

other problems with these products.

 I'm kind of, like, torn in a way, 

perhaps a little heartbroken over this, you know, 

in terms of the argument and in terms of being 

able to support other kinds of organic 

agriculture.

 And I'm not sure where that leads us. 

And I really think we need to focus on the 

agricultural activity. But since its human 

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health and environment, I don't think that's so 

relevant here in the sense that all of us know it 

is really a danger to public health.

 And I know tobacco has a long history 

and centuries of use. And it's used in many 

different settings. But there's a level to this 

that perhaps maybe we can discuss more at the inperson meeting. Thanks.

 MR. CARGILL: So was that a question? 

Comment? Okay. Thank you.

 MR. BRADMAN: Yes.

 MR. BUI: This is Jesse. Are you 

familiar that alcohol has been listed in 

California as a carcinogen?

 MR. CARGILL: Listed as a carcinogen?

 MR. BUI: Yes, sir.

 MR. CARGILL: Not to my knowledge. 

Fatty alcohols are naturally occurring in the 

environment in plants. And so in fact, this 

alcohol is approved as a food additive by the 

FDA. So I don't. And I know of no published 

information that says they are carcinogens. At 

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least the chain links that we're talking about 

which are C8, C10, primarily --

 MR. BUI: Thank you.

 MR. CARGILL: -- carbon chains.

 MS. BEHAR: Okay. Any other -- okay, 

thank you. Any other questions from the Board? 

Okay. Thank you.

 MR. CARGILL: Okay. Thank you.

 MS. BEHAR: Next up is Kelsey Kerston, 

with Jennie Landry and Katherine DiMatteo on 

deck. Kelsey, please state your name and 

affiliation.

 MS. KERSTON: Hello. My name is 

Kelsey Kerston, and I work as a senior livestock 

certification specialist at CCOF. I'd just like 

to thank the NOSB for the opportunity to speak 

today.

 I just wanted to touch on the 

discussion document regarding vaccines produced 

with excluded methods. At CCOF, vaccines play an 

important role in maintaining animal health and 

are used by the majority of our CCOF certified 

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livestock operations as a preventative health 

care practice.

 The discussion document proposed three 

options on excluded methods of vaccines. The 

individual review of vaccines before at the NOSB. 

Furthermore, we're concerned that individual 

reviews could delay producers from being able to 

administer these vaccines, especially for 

operations using the less common or custom 

vaccines.

 Option 2, the allowance of excluded 

method vaccines as a class or a type of vaccines 

would be a simpler solutions but allows for the 

possibility of greater use of excluded methods in 

organic production and allowing vaccines produced 

to exclude the method if there's no commercial 

available options to organic producers.

 Or the third option, it's a middle 

ground offered in the discussion document. 

However, we don't see it as a perfect solution 

either. Excluded methods are still being 

defined. And collecting information from vaccine 

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manufacturers could prove difficult especially if 

manufacturers are unresponsive when asked to 

share information about their products.

 Our thought is that NOSB should 

carefully consider the impact as well of each of 

these options on organic livestock producers with 

state mandated livestock vaccinations.

 For instance, CBSA in California 

requires cattle entering the space to have 

histophilus vaccinations. Depending on the 

options supported by NOSB, if a state mandated 

vaccination was produced using excluded methods, 

organic producers could be limited in their 

ability to purchase out-of-state cattle and also 

limited in moving cattle in and out of the state.

 Other states may also have specific 

state-mandated vaccination requirements, although 

I'm not aware of other state requirements.

 CCOF does not support the use of 

excluded methods in organic production. But many 

organic livestock producers rely heavily on 

vaccines to ensure the health of their herds and 

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stock.

 In order to have a safe and stable 

food system, we think the use of vaccines in 

organic livestock could be essential.

 CCOF simply encourages the NOSB to 

invite organic producers and vaccine 

manufacturers as well as other potential 

stakeholders to present further information on 

this topic at our next NOSB meeting.

 Thank you so much for the review of 

our comments. And if you have any questions, I'm 

happy to answer them.

 MS. ARSENAULT: Hold on one second. 

Harriet. Sorry, you are on mute again. All 

right. You are unmuted, Harriet.

 MS. BEHAR: Okay. Any questions from 

the Board?

 MS. SWAFFAR: Hi, Harriet. It's 

Ashley. I have a question.

 MS. BEHAR: Okay, good.

 MS. SWAFFAR: Yes, so, Kelsey, we kind 

of struggled a lot with all of the points you 

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raised. Do you have a suggestion of is there an 

Option 4 that you would recommend?

 MS. KERSTON: Hi, Ashley. We don't 

have an answer at this time. We're happy that 

it's being discussed, and it is a bit of a tricky 

situation.

 The third option presented of 

exploring commercial availability seems like the 

potentially best option. We just think that 

there's a lot of potential for unintended 

consequences just in that most certifies aren't 

currently going through that process of checking 

with manufacturers and the fact that it seems 

that some excluded methods are still being 

defined.

 So we think potentially exploring that 

option but waiting to suggest anything until that 

option has been sort of tested out may be the 

best route.

 MS. SWAFFAR: Thank you.

 MS. BEHAR: Okay. I also have a 

comment to review the written comments of Michael 

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Hanson. He's got some unexcluded methods 

vaccines. He's got some pretty detailed 

resources on how to find out which ones are 

clearly genetically engineered.

 So I found that interesting. And 

maybe you will, too. So those are the comments 

from Michael Hanson from the Center for Food 

Safety.

 Any other questions or comments from 

the Board? Okay. Next up -- thank you, Kelsey. 

Next up is Jennie Landry, and on deck is 

Katherine DiMatteo and Tom Honingford.

 Jennie, please state your name and 

affiliation.

 MS. LANDRY: Hello. Can you hear me 

okay?

 MS. BEHAR: Yes, thank you.

 MS. LANDRY: Okay. Okay. My name is 

Jennie Landry. I represent DSM Nutritional 

Products, the manufacturer of omega-3, EPA and 

DHA based products from fish oil.

 DSM strongly recommends the relisting 

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of fish oil to the National List of nonorganically produced ingredients in processed 

products labeled as organic.

 The re-listing of fish oil is critical 

for its continued use as a nutritional ingredient 

in organic certified products. This is because 

organic fish oil is not commercially available 

due to the absence of organic production 

standards for aquaculture.

 When added as a nutritional ingredient 

to foods, fish oil provides a reliable source of 

EPA and DHA omega-3 fatty acids that are highly 

desired by consumers, including those who choose 

organic products.

 These omega-3 fatty acids are sought 

after because they have been proven to support 

overall health across several systems of the 

body, including contributing to healthy brain 

development and reducing the risk of 

cardiovascular disease.

 Evidence supporting these benefits 

spans the past four plus decades and remain 

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favorable. Organic consumers recognize the 

benefits and should have access to these valueadded products.

 Fish oil is a naturally sourced 

byproduct of fish meal in edible canning 

industries. Despite contradictory statements in 

the fish oil technical evaluation report, most 

fish are caught for the exclusive production of 

oil for use as a nutritional ingredient.

 It is highly inaccurate to suggest 

that fish oil production would contribute to 

global extinction of fish species.

 Fish oil manufacturers, especially 

DSM, are committed to the responsible and 

sustainable use of natural marine resources. 

It's the only business model that ensures 

continued profitability that only for the fish 

oil industry but for all value chains and those 

who rely on them.

 One more thing, DSM only considers 

fisheries who have the proper equipment, 

practices and procedures and legislative controls 

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in place to protect their stock. DSM sets 

expectations for environmental quality, social 

responsibility and sustainability, which are 

evaluated during a rigorous qualification 

process.

 Lastly, to address the misconceptions 

that exist regarding health risks which have been 

associated with consumption of fish oil, due to 

the presence of environmental contaminants, fish 

oil for human consumption follows classical 

production techniques that include refining, 

bleaching and deodorization to control the risks 

of potential contaminants.

 Fish oil has been proven to be 

generally recognized as safe with no FDA 

questions and all industry leaders who are 

members of the global organization for EPA and 

DHA must abide by the contaminant limits that are 

based on the strictest global regulations.

 In closing, DSM strongly recommends 

the relisting of fish oil to the National List. 

As a leading producer of omega-3, we understand 

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that protecting our marine environment is 

crucial, and we are committed to sustainability 

now and in the future.

 I will conclude by saying thank you to 

the NOSB for your time and opportunity to provide 

comments in this webinar.

 MS. BEHAR: Thank you. Am I off mute 

there, Michelle? Hello? Whoa. Michelle, can 

people hear me? This is Harriet.

 MS. ARSENAULT: I can hear you, 

Harriet, yes.

 MS. BEHAR: Okay. Well, I didn't 

know. You keep putting me on mute. I do have a 

question, Jennie. In one of our questions in our 

document, we asked about if there's any limits on 

possible contaminants and how that purity is 

assessed and tested and if it is made available 

to the purchasers of the fish oil.

 MS. LANDRY: Yes. So for the first 

part of that question there's no U.S. regulatory 

limits on contaminants in fish oil specifically 

although all industry players in the fish oil 

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industry follow the GOED voluntary monograph to 

have compiled all of the restrictive global 

regulatory limits that are in place and put it 

together in one monograph.

 So members of GOED need to comply to 

those strict limits. In terms of assessing the 

purity and ensuring that those limits are met, 

it's likely individual for each manufacturer 

industry.

 I mean, we, ourselves have a very --

we follow a quality management program, and we 

have strict quality procedures in place for the 

evaluation of our incoming materials and then 

routine contaminant testing. And then we have 

specifications on all of our finished products, 

which are available to our customers.

 MS. BEHAR: Okay. Thank you. Any 

other questions from the Board?

 MR. CHAPMAN: This is Tom. I have a 

question. Thank you for responding to our 

specific questions in your written comments. And 

we asked, you know, the fourth question was about 

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how we could potentially modify the listing to 

control for conservation concerns.

 You guys offered four responses. Do 

you have a preference out of those four options?

 MS. LANDRY: The options that we 

proposed are ones that today we would comply 

with. I think industry-wide, the one that makes 

sense to address the concerns that have been 

expressed previously with regards to the fish oil 

is that it must be sourced as a byproduct and not 

a result of direct fishing. That's a fairly 

straightforward one that has been expressed as a 

concern. And it's one that the industry already 

follows.

 MR. CHAPMAN: As a follow-up to that, 

if, like, when we introduce in terms, like, 

byproduct in direct fishing, those will also have 

to be defined. Are you guys able to provide 

suggested definitions for byproduct in direct 

fishing?

 MS. LANDRY: We certainly can put some 

better definition behind that to support that. 

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 MR. CHAPMAN: Yes. If you could send 

that through, that would be appreciated.

 MS. LANDRY: Yes. Will do.

 MR. CHAPMAN: Thank you.

 MS. BEHAR: Thank you. Any other 

questions from the Board? Okay. We will move on 

to Katherine DiMatteo, with Tom Honingford and 

Ray Frizzell on deck. Katherine, please state 

your name and affiliation.

 MS. DiMATTEO: Thank you. My name is 

Katherine DiMatteo. I am the senior associate 

and partner of Wolf, DiMatteo & Associates, a 

consulting service to the organic sector since 

1995.

 We support the relisting of hydrogen 

peroxide as a disinfectant, algaecide and for 

plant disease control in organic crop production. 

It breaks down rapidly in the environment to 

oxygen and water leaving no residue.

 It is a better alternative to process 

copper products for algae control and to chlorine 

materials as a sanitizer. As a plant disease 

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control, hydrogen peroxide based products show 

good to excellent efficacy under fire, blight, 

infection conditions in recent field trials at 

Oregon State University in 2016 and Connecticut 

Agricultural Experiment Station in 2018.

 We also support the relisting of 

ammonia soaps as a large animal repellent. Yes, 

there are other alternatives such as fencing, 

coyote yarn and human hair.

 However, for farms with large areas to 

protect, these alternatives are not sufficient, 

practical and are cost prohibitive. Other 

contact repellents like black pepper oil must be 

frequently reapplied.

 Ammonia soaps work, are non-toxic, are 

readily biodegradable and do not migrate to cause 

harm to non-target organisms.

 We support the review of paper 

planting aids in organic farming, in particular 

evaluation of the risks to the environment and 

human health. We encourage the NOSB to utilize 

the ASTM D5988 biodegradation standard as one 

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tool in determining if the paper and the 

additives used in manufacturing these paper 

planting aids that they meet National List 

criteria.

 Finally, we support a low vetted 

National List but not decisions made that take 

away materials that can provide the needed tools 

for organic farmers. One material cannot be 

appropriate for all situations. Removing 

material from the list based on amount of current 

use and the consistence of other ordinates that 

may or may not be as effective is not reasonable.

 Farmers need to be able to choose the 

material that fits their needs when they need it.

 Thank you for the opportunity to 

comment and for your good, hard work for our good 

health.

 MS. BEHAR: Okay. Any comments or 

questions from the Board? I have one question 

for you, Katherine. So one thing that we have 

been doing is not just looking to see if a 

material is biodegradable but the effect then 

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that material, as its biodegrading, has on soil 

biology.

 Does this encourage one type of soil 

microbe to increase over another? Does it cause 

any kind of nutrient imbalances or whatever?

 So I don't think that those 

biodegradable standards deal with that deeper 

effect. Do you think that we should be looking 

at that, or do you think that the soil is 

resilient enough that it's not so much of an 

issue?

 MS. DiMATTEO: Well, I think this --

I have two answers for that.

 MS. BEHAR: Okay.

 MS. DiMATTEO: One is that I think 

that biodegradation standard includes the impact 

on soil as well, not necessarily the testing of 

it. There is also testing and certification of 

impacts on soil that can be done in conjunction 

with some of these ASTM standards.

 So there are two ways in application 

that you can use it. But just looking at the 

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standard, you can at least get some criteria and 

tools that may be helpful in determining these 

paper pots and other paper planting aids that as 

you consider them whether or not they are going 

to impact both in degradation and in 

environmental impact.

 But rather than suppose that there's 

any one specific testing method or certification 

that can be used to ensure that, I wouldn't make 

that suggestion. And I'm not sure that the NOSB 

or the NOP could, you know, just say one 

verification system is the only one that's being 

used. So it may be that you want to include 

testing as part of the guidance that you give on 

paper pots and other planting aids.

 MS. BEHAR: Okay. Great. Any other 

comments from the Board?

 MR. BRADMAN: This is Asa. I just had 

a quick question. You're saying that ASTM 6954-

18?

 MS. DiMATTEO: It's 5988.

 MR. BRADMAN: Okay, 59. 

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 MS. DiMATTEO: 5988.

 MR. BRADMAN: Thank you.

 MS. BEHAR: Okay. Anyone else? Okay. 

We will move on to Tom Honingford, with Ray 

Frizzell and Linley Dixon on deck. Tom, please 

state your name and affiliation.

 MS. ARSENAULT: Harriet, we haven't 

been able to find Tom on either list, the webinar 

or the phone. So he may not be with us. I also 

don't see his area code phone number.

 MS. BEHAR: Okay. Okay. Well, then, 

Ray, you're up next. Hello?

 MR. FRIZZELL: Can you hear me?

 MS. BEHAR: Is that Tom?

 MR. FRIZZELL: This is Ray Frizzell.

 MS. BEHAR: Oh, that's Ray. Okay, 

Ray. You are next. But Linley Dixon and Bill 

Wolf are on deck. Ray, please state your name 

and affiliation.

 MR. FRIZZELL: I want to thank the 

Board for giving me this opportunity. My name is 

Ray Frizzell. I'm the CEO at Full Measure 

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Industries.

 MS. ARSENAULT: Ray, this is Michelle 

at NOP. I'm sorry. You're a little faint. Is 

it possible that you could get a little closer to 

the microphone or -- okay? Harriet, are you 

okay? Can you hear him all right?

 MS. BEHAR: Yes. But I'm wondering if 

you're on a speaker phone if you could get on a 

handset.

 MR. FRIZZELL: I raised the handset. 

Can you hear me now?

 MS. BEHAR: Well, we can hear you. 

You sound a little fuzzy.

 MR. FRIZZELL: Can you hear me better 

now?

 MS. BEHAR: We're getting a little 

background, I think. Come again, Tom? Sorry, 

Ray.

 MR. FRIZZELL: How about now?

 MS. BEHAR: Now we're getting really 

bad feedback and an echo. If you are near your 

computer and your speakers and mic are on your 

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computer as well, usually that's the cause of 

feedback like that.

 MR. FRIZZELL: I'm away from my 

computer now. Can you hear me better now?

 MS. BEHAR: Brilliant. Thank you. 

All right.

 MR. FRIZZELL: I have run a half a 

mile out of the area.

 MS. BEHAR: All right. Well, thank 

you. State your name.

 MR. FRIZZELL: My name is Ray 

Frizzell. I am the President and CEO of Full 

Measure Industries, LLC, the organization that 

has put the discussion in for calcium acetate to 

be considered by the Board.

 Full Measure Industries is a small 

family run business, and my son Nathan is an 

owner as well. And he will be going to the 

Board's meeting in Seattle at the end of the 

month. And he looks forward to meeting you all 

there.

 What we are looking to do is to get 

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calcium acetate accepted as an organic material. 

Calcium acetate is an item that is created in 

nature specifically by the plant interaction with 

the microbes in the soil that create the calcium 

acetate, which makes it an available calcium.

 So what we have done is we have taken 

pharmaceutical grade limestone, and we have 

created two products that take vinegar, 

concentrated vinegar, which is acidic acid and a 

portion of that calcium is created with that 

vinegar and that converts it to calcium acetate.

 Calcium acetate has been found to be 

an unusually available calcium. And we have been 

able to make a 30 percent calcium where most 

other calcium products out there are excluded at 

10 percent calcium. This is a huge advantage for 

organic farmers because you are going to get the 

benefit of the calcium up into the plants.

 And we have research and studies that 

we have done that Nathan will be bringing to the 

Board at the end of the month for you to take a 

look at. 

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 What else do I have to tell you on 

this? In addition, to being linked as a 

nutrient, our product also has the ability to 

help with prevention of sunscald. It has become 

more and more of an issue for crop growers 

throughout the United States and the rest of the 

world.

 We've had great success with 

watermelon growers. In fact, we have watermelon 

processing companies that refuse to use the clay 

based calciums or clay-based shade guards because 

they foul up their equipment and leave residue 

where our product doesn't do that.

 Our product is very easy to apply. 

You spray, rinse. And growers for the last 12 

years have been using our product in agriculture. 

And we've got numerous requests by organic 

farmers to have an organic product in the 

marketplace. And we are now making that effort 

to make that happen. And I've run out of time.

 MS. BEHAR: Okay. Any questions from 

the Board? 

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 MR. ELA: Yes. This is Steve Ela, I 

have a question.

 MR. FRIZZELL: Yes, Steve.

 MS. BEHAR: Hi, Steve, go ahead.

 MR. ELA: Could you elaborate a little 

more on why this product would be essential to 

organic production? I mean, there's certainly --

it may be slightly different in concentration or 

form than other calcium products. I mean, is it 

critical for organic production?

 MR. FRIZZELL: I think it's very 

critical for organic production because it allows 

for the natural uptake of the other nutrients 

that are trying to be uptaken by the plants.

 And it gives you the ability to move 

that material into the plant and give them much 

stronger cell wall development and it gives them 

crops that resist disease better and are more 

resilient once it gets harvested and they're put 

in the supply chain to stores due to the strength 

of the plant.

 MS. BEHAR: Any other questions or 

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follow-up? Okay. We will move ahead to Linley 

Dixon is on deck, with Bill Wolf and Dave Chapman 

on deck. Linley, please state your name and 

affiliation.

 MS. DIXON: Hi. I'm Linley Dixon the 

associate director of the Real Organic Project. 

So the Real Organic Project is a farmer-led and 

grassroots effort to get organic standards back 

in line with the law.

 The formation of ROP is a result of 

major failures of the NOP, including the failure 

to enforce the livestock raising standard and 

implement the origin of livestock rule.

 The direct result of these failures is 

the loss of many organic dairy farms that follow 

the rules and that were unable to compete under 

the same label and had misled organic consumers 

into thinking they were getting the nutritional 

benefits of real pasture organic milk in the 

marketplace.

 The NOP failed to require real outdoor 

access for poultry, resulting in the dominance of 

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mega confinement chicken houses under the organic 

seal. The loss of pasture and organic poultry 

production has resulted in the emergence of 

pasture-based poultry labels, and those are 

directly competing with the organic label, but 

they're not using organic feed.

 So the integrity of their organic 

label has been severely harmed by the failure to 

enforce real outdoor access for chickens.

 Both the NOP and the NOSB failed to 

enforce 20520(c), control fertility and crop 

nutrient management practice standards again 

leading to unfair competition under the same 

organic label.

 There are pre-certified berry farmers 

right now struggling to stay in business because 

they're losing markets to hydroponic berries 

under the same label despite extreme differences 

in cost of production due to the failure to 

follow soil fertility standards.

 ROP is an attempt to restore fair 

competition under the organic seal. Under the 

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standards that follow the principle of AFSA 

(phonetic), of course, the lifeline were 

providing to farmers under the organic label will 

be too late for many producers.

 Many pasture poultry farms have either 

long abandoned the field or gone out of business. 

The same is true for dairy, field grown tomatoes, 

cucumber, pepper and berry operations are 

experiencing the squeeze right now.

 As NOSB members, we urge you to make 

the Real Organic Project obsolete by working to 

prohibit hydroponics and endorse the still 

standing 2010 recommendation on the requirements 

to foster soil fertility in both livestock and 

crop production.

 Some have changed the meaning of 

organic to simply a product that doesn't come 

into contact with a particular substance. This 

fails to acknowledge all the prohibited 

substances that have been used to bring that 

product to the market.

 Consider the chemicals applied to the 

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thousands of acres of conventional soybeans that 

are exclusively used to make hydrolyzed soy that 

fertilizes hydroponic crops.

 Consider the prohibitive substances 

used to produce the substrates that hydroponic 

crops grow in. The increased use of prohibitive 

substances for the production of hydroponic crops 

is a direct result of the NOSB decision to allow 

hydroponic production without any standards to go 

with it.

 There are many certification bodies 

that still uphold the soil fertility and crop 

production principles in AFSA. This is an unfair 

advantage to those APAs that have chosen to 

ignore parts of ERSA and go along with 

management's lack of enforcement of law.

 The APAs with integrity who refuse to 

say if I don't certify them, someone else will, 

they're losing business.

 We are working with some of these high 

integrity APAs to implement the ROP program this 

coming season. We have significant farmer 

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momentum behind us.

 Thank you for your time.

 MS. BEHAR: Any questions from the 

Board? Okay. Thank you, Linley. Next up is 

Bill Wolf, with Dave Chapman and Colehour Bondera 

on deck. Bill, please state your name and 

affiliation.

 MR. WOLF: Hello. Can you hear me?

 MS. BEHAR: Yes.

 MR. WOLF: Great. I'm Bill Wolf, and 

I'm here representing both Thorvin Kelp and Wolf, 

DiMatteo & Associates, a leading organic 

consultancy.

 I will amplify on our written comments 

about marine materials. We agree strongly that 

seaweed harvest must be sustainable, but we 

suggest a different solution.

 My seaweed company only uses certified 

organic marine algae and would certainly benefit 

from your proposal to require certification of 

all marine algae used as crop inputs.

 However, we do not support this. 

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Neither adding individual annotations to the 

National List nor requiring that input sources be 

certified is in the best interest of the organic 

community. Instead, I ask that you consider 

three overarching principles and comments.

 One, apply the organic preference 

principle to the entire National List that when 

organic inputs and ingredients are commercially 

available, they must be chosen first.

 Requiring the use of certified organic 

sources for all inputs when commercially 

available will solve both discrimination and 

phase-in problems, encourage innovation and 

continuous improvement.

 This actually can be applied to 601, 

603 and 605, not just 606. Although we haven't 

been the loudest, we've been making this 

recommendation for over a decade.

 Of course, we would also support 

published and fully vetted guidance documents 

about inputs and sustainability measurement.

 Two, our second issue is we suggest 

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that the Board triage the issues that are 

presented to the Board. Only select the core 

issues that advance responsible organic 

agriculture and don't overreact to the loudest 

voice in the room.

 Organic regulations can't tackle all 

social and environmental issues. Farming itself 

is less than sustainable. There are much bigger 

organic farming inputs that would not meet such 

scrutiny from tractor fuel to mined minerals.

 Number three, I encourage the Board to 

get more professional help from the USDA and NOP 

to study the issues and to help develop your 

positions.

 As an Advisory Board with incredible 

volunteer citizens, you should demand to have a 

professional staff to help further gather 

accurate information and carry the primary burden 

of preparing your options and position papers.

 Thank you for your time. I welcome 

questions.

 MS. BEHAR: Okay. Any questions from 

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the Board for Bill?

 MS. OAKLEY: Harriet, this is Emily. 

I have a question.

 MS. BEHAR: Go right ahead.

 MS. OAKLEY: Thank you, Bill, for your 

written comments on reading materials. And I 

have been hearing you over the past many meetings 

about the organic preference being applied to the 

entire national list.

 In terms of how that might spillover 

into this discussion of marine algae, I have a 

question. Specifically, if we had some species 

for which there were no producers entering the 

marketplace with a certified organic product or a 

certified organic marine algae species, and that 

never developed over time but it happened to be a 

species that was definitely in critical 

environmental situations in terms of its harvest, 

how would that suggestion that you are 

recommending then address the issue of 

environmental impact and harm and the avoidance 

of what we are trying to come up with as we 

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explore this issue?

 MR. WOLF: A really good question. 

Thank you. Well, first of all, history has shown 

that organic preference does cause this 

continuous improvement to occur. People innovate 

and look for opportunities to fill niches. And 

that has held true across how 606 has been shrunk 

over the years or changed over the years.

 So it would be hard to imagine if that 

pressure were available that that effort would 

not occur. Harvesters and processors would look 

for that innovation and that opportunity.

 But assuming that that doesn't 

adequately address the risk of either damage to 

the environment from harvest, that can be 

addressed several ways. But I think that can be 

addressed through guidance and can be addressed 

by including in guidance reviews of 

sustainability of methods of production of all 

inputs.

 I think we are opening the door to 

some very important issues. But I think going 

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item by item is scary because it creates an 

uneven playing field, and it creates a place for 

the loudest voice in the room as I said.

 I think that are some very strong 

efforts being made worldwide to assure best 

practices in marine algae harvest. I've been 

observing that in some places for as long as 37 

years in terms of government oversight and the 

like.

 MS. OAKLEY: Thank you.

 MS. ARSENAULT: Harriet, you are --

 MS. BEHAR: Okay.

 MS. ARSENAULT: -- not on mute.

 MS. BEHAR: Okay. Okay. Any other 

questions for Bill? Okay. Next up is Dave 

Chapman, and Colehour Bondera is on deck. Dave, 

please state your name and affiliation.

 MR. CHAPMAN: Hello. I am Dave 

Chapman. I am speaking today as Executive 

Director of The Real Organic Project, and I am 

also a former member of the USDA Hydroponic Task 

Force. And I'm also proud of the fact that I'm a 

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long-time organic farmer.

 As many of you know, I participated in a 

recent OFPA meeting with NOP Deputy Director 

Jennifer Tucker, and the following items came up 

that were important.

 The pasture rule is not being properly 

enforced. The NOP acknowledges this and promises 

to do better. But they have been promising the 

same thing for nine years since Miles McEvoy 

announced the age of enforcement.

 The origin of livestock rule is 

languishing in the NOP after passing the NOSB. 

Without my saying anything, Dr. Tucker said it 

would take years more to come to an action on 

this.

 Associate Director Tucker said that 

she has no power to pass new regulations but the 

OFA members pointed out that she does have the 

responsibility and power to hold certifiers 

accountable for enforcing the current rules. 

This is not being done.

 In an earlier conversation, Dr. Tucker 

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had made clear to NOC that there is no transition 

time required for hydroponic operations.

 In the OFA meeting, Dr. Tucker said 

that the use of herbicides immediately prior to 

getting certified would not disqualify a facility 

from organic certification.

 By implication there is also no 

restriction on the use of prohibited pesticides 

the day before changing substrate in a 

conventional greenhouse and then qualifying for 

organic certification the next day.

 There's also no limitation on a 

greenhouse spraying a prohibited pesticide 

between crops, changing the substrate and 

reapplying for organic certification with no 

transition period. The allowance of herbicides 

and pesticides in this manner is the logical 

conclusion for the allowance of hydroponics in 

organic.

 Hydroponic cannot and should not be 

called organic. These NOP positions are 

indefensible and unacceptable to consumers. They 

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are not outlier issues but cut to the very heart 

of organic. The only hope for the NOP is that 

consumers don't find out what is being allowed.

 We all know this is not a good 

strategy. Consumers are going to find out if 

we're going to preserve a meaningful organic 

program in America, we need to bring great 

pressure to bear.

 If we fail, there will be tremendous 

damage to caring consumers, the organic trade and 

to the real organic farmers of America. 

Ultimately, the entire $50 billion organic 

industry will suffer.

 I urge the NOSB to challenge the NOP's 

reduction of your importance and to take a more 

activist role in representing the American people 

and protecting the meaning of organic. Thank 

you, and I welcome any questions.

 MS. BEHAR: Okay. Any questions for 

Dave from the Board?

 MR. ELA: Harriet, this is Steve Ela. 

I have a question. 

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 MS. BEHAR: Go right ahead.

 MR. ELA: Dave, I just want to followup and make sure I'm understanding correctly. 

So, for example, in a facility with container 

production, what you're advocating for is that 

the land that those containers sit on top of 

should go through the three year transition 

period. Am I understanding correctly?

 MR. CHAPMAN: Well, Steve, what I'm 

actually advocating for is that America follow 

the EU standard, grandfather all of the existing 

container facilities out and require that organic 

be in the ground.

 But if that were not the path that was 

followed then at the very least, yes, I'm 

honestly not advocating for just reforming the 

standards around hydroponics because I don't 

think if there's a logical path to allowing 

hydroponics, it's going to end up being very 

strange compromises.

 MR. ELA: Yes. Thank you for that 

clarification. So are there -- so at this point, 

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are there farms with containers that -- I mean, 

you've mentioned -- I'm assuming you have real 

world examples where an herbicide for example is 

sprayed and then containers are put right on top 

of that ground?

 MR. CHAPMAN: That has been reported 

to me, yes.

 MR. ELA: Okay.

 MR. CHAPMAN: I've been told that by 

people in Florida and California who are 

trustworthy people. But I don't have cameras. I 

don't have people who are willing to come forward 

because they're afraid of repercussions. But I'm 

sure if a serious effort were made to research 

this, the answer would be that it is happening.

 I know of one certifier on record as 

saying they do allow that. And, again, it is the 

stated position of the NOP that it is allowed, 

that there is no transition period, and that's 

what that means is that you could use an 

herbicide or prohibited pesticide today, change 

the substrate and tomorrow you can be certified. 

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 And, you know, we do have large 

greenhouse facilities that were conventional 

hydroponics that are now becoming organic 

overnight. So of course they were using 

prohibited pesticides.

 MR. ELA: Thanks, Dave.

 MR. CHAPMAN: Yes.

 MS. OAKLEY: Harriet, this is Emily. 

Can I ask a question?

 MS. BEHAR: Yes. Sure. Go ahead. Go 

ahead.

 MS. OAKLEY: This is a question for 

the program. I don't know, Paul, if you're still 

on, but when I hear this discussion, I think 

immediately, no, there's absolutely no way that a 

prohibitive substance could be allowed and then a 

container could be certified as organic without 

following the three year transition period. 

Because in my view it's not the container that's 

getting certified, it's the land on which the 

container is sitting.

 And I don't -- I think many organic 

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farmers feel the same that it's the land upon 

which the facility for a crop is grown regardless 

of how it's grown or where it's grown that is 

getting certified. So, Paul, could you please 

kind of answer some of the discussion that's 

going on?

 MR. LEWIS: Yes. Thanks, Emily. So, 

yes, I'm aware, Dave, of what you're asking and 

the communication that we recently had on this.

 I've been having conversations with 

NOP about this in terms of addressing this. 

We're going to have more to say next week. I 

know you want to be talking about it now, but I 

know Jennie will be talking about this next week 

at the Board meeting. So if you can just hold 

your question on this, Emily, until next week 

we'll have more share.

 MS. OAKLEY: Sure. I absolutely will. 

I'll just say, though, that I hope that the 

clarification can be that the three year 

transition applies to any producer, land, farm, 

regardless of what's grown, the size or the 

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geographic region.

 But I will wait to see what happens at 

the meeting next week to see where we go from 

there. So thank you, I appreciate getting more 

information.

 MR. LEWIS: And thanks, Emily, for 

your understanding.

 MS. BEHAR: Yes, thank you. Any other 

questions for Dave? Thank you, Dave.

 MR. CHAPMAN: Thank you.

 MS. BEHAR: And next up is Colehour 

Bondera. And I don't know if Tom Honingford, 

Andrew Dykstra, Dallas McCann or Marina Abitia 

are there. But if you are, you would be on deck 

after Colehour. Okay, Colehour, please state 

your name and affiliation and thanks for getting 

on the webinar. If he's there? If you're 

speaking, you're on mute.

 MS. ARSENAULT: Colehour, I see you on 

the list, but we are not hearing you speak. It 

looks like you're on a headset, maybe if you can 

dial-in on a handset, or unmute your mic on your 

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computer maybe. Still not hearing you, but I can 

see you.

 MS. BEHAR: So Colehour, we want to 

hear you. Maybe he's out snorkeling.

 MS. ARSENAULT: Well, Harriet, if you 

want to run through the few folks that we skipped 

over or that weren't on the line when we called 

their name, and that may give Colehour a minute 

or two to get his audio worked out.

 MS. BEHAR: Okay. Marina --

 MS. ARSENAULT: Oh, sorry. He's 

dialing in.

 MR. BONDERA: This is Colehour.

 MS. ARSENAULT: Hey, Colehour.

 MS. BEHAR: Okay, great. Hi, 

Colehour.

 MR. BONDERA: Aloha. I was on the 

phone saying. I don't know. Let's try again.

 MS. BEHAR: Okay. State your name and 

affiliation.

 MR. BONDERA: Again, my apologies. 

Aloha, NOSB members. My name is Colehour Bondera 

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of Kanalani Ohana Farm in Honaunau, Hawaii. I 

want to say welcome.

 If you don't know me, I want to thank 

you all for your service. It's a lot of serious 

work, which I know as an alum. I was a small 

scale producer from 2011 to 2016 on the NOSB.

 And since NOSB cannot do all that is 

needed, Dave Chapman took it upon himself to seek 

integrity and stay true to what organic means, 

and my sincere thanks to Dave who in my opinion 

is going to be difficult to follow honestly.

 I'm going to start with a few general 

comments and then end with some specific 

materials as you are considering.

 First, I want to encourage you to 

remember that with roots back to 1949 that in 

1998 a verbiage was put together called the Wing 

Spring Statement -- Wing Spread Statement, excuse 

me -- that reads, "When an activity raises 

threats of harm to human health or the 

environment, precautionary measures should be 

taken even if some cause and effect relationships 

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are not fully established scientifically."

 All that NOSB is working from, OFPA, 

is grounded in this concept. And it is important 

when making decisions that if there is a question 

raised that seems valid, even if not proven 

scientifically, then substances are best kept out 

of organic systems based on the precautionary 

principle.

 With the five year concept of the 

material being taken off the National List, the 

sunset clause is for exceptions, which must be 

few. The NOSB should ensure that exceptions are 

just that, and not increasing in number or being 

kept in sunset mode in perpetuity.

 As a teenager, one of my earliest 

memories as I became interested in food choices 

was related to learning about the animal and 

synthetic components of gel casings. And in fact 

this is not already in the past.

 The non-organic produced collagen gel 

casings could be permitted in organic systems is 

like continuing to permit non-organic seeds for 

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planting. Please do not allow non-organic 

collagen gel casings to be added to the list of 

permitted non-organic materials. Get me out of 

the early 1980s, please.

 Based on health and environmental 

risks, please reject petitions to add silver 

dihydrogen citrate and AITT, allyl 

isothiocyanate, to material listings as well.

 Further, having worked directly while 

they were last reviewed, it is my sincere request 

that chlorine based sanitizers do not get 

relisted again still using the excuse of no other 

options when they are not necessary and/or not 

safe.

 Finally, it is, after so many delays, 

in my opinion, time for synthetic methionine to 

sunset off the list of permitted substances.

 Changing management practices and 

breeding choices and/or using natural methionine 

are all available. As a direct neighbor of mine 

who raises chickens and eggs here in Hawaii, she 

practices these behaviors with no problems for 

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organic chickens or the eggs at all. And even 

though that's just an example, I think it's 

vital. Thank you.

 MS. BEHAR: Okay. Well, that was jam 

packed. Any question for Colehour.

 MR. ELA: This is Steve Ela. I had a 

question.

 MS. BEHAR: Colehour, just so you --

oh, go ahead, Steve. Go ahead.

 MR. ELA: Colehour, with respect to 

your comment on sanitizers, and given Food Safety 

Modernization Act regulations, what is your 

alternative to chlorine materials?

 MR. BONDERA: Well, I'm not going to 

be able to address details of that question. You 

know, I just remember quite directly from our 

research, and I'm not going to be able to comment 

on the Food Safety Modernization Act implications 

honestly.

 But I am just full aware that there 

are other alternatives. You know, I go to my own 

personal bathroom, and I pull out my non-chlorine 

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bleach. And I look and there it is, hydrogen 

peroxide.

 So I think that there are other 

alternatives that are readily available that can 

be made use of. And I just think that it's not 

as simple as we must use chlorine or we can't 

have organics. So I think it's too simplistic of 

a summary.

 MS. BEHAR: Okay. Any other questions 

or comments for Colehour? I have one, Colehour, 

we are going to hear from the methionine task 

force. And they're going to be talking to us 

about what natural methionine materials they have 

tried and why they didn't work, and what they're 

planning to do.

 So I know this has been a long time 

material that causes consternation on the Board, 

and we're doing the best we can to get good 

information on where we go next.

 MR. BONDERA: I appreciate that. And 

I thank you for your continuing down the path in 

a healthy manner. And I think that needs to be 

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our shared goal.

 MS. BEHAR: Okay. So I am going to 

ask for the people who were listed but did not 

speak during their allotted time.

 Marina Abitia, A-B-I-T-I-A? Kathleen 

Mellone, a USC anthropology student? Dallas 

McCann, Fromer Market Gardens in Tannersville, 

New York? Andrew Dykstra, an Organic Valley 

dairy farmer and ex-WODPA President? And Tom 

Honingford from Hurricane Flats Farms? Those 

were the people that I have that had signed up 

but that did not give their public comments. 

Michelle, did I get everybody?

 MS. ARSENAULT: I believe so, yes.

 MS. BEHAR: Okay. Okay. Well, I 

guess I want to say thank you to everyone who is 

still on the line who participated and gave us 

some great comments.

 On Thursday, same time, same place, we 

will have an abbreviated, it won't be quite as 

long as today because we have less of a list. So 

if you want to hear some more public comments, 

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the Board members will all be there. And we will 

be hearing from approximately 10 people on 

Thursday.

 I want to say thank you all and any of 

you who will be in Seattle, see you in person 

next week and have a great rest of your 

afternoon.

 Michelle, do you have anything else to 

say?

 MS. ARSENAULT: No. I think you 

covered what I was going to say. Just that the 

next portion of the webinar is on Thursday at 

1:00 Eastern.

 So thank you, Harriet, thank you, 

everyone who participated. Great job keeping the 

noise in the background down. And we appreciate 

it. Thank you, Board members, and we'll talk to 

you guys on Thursday.

 MS. BEHAR: Okay. Thank you. Byebye.

 MS. ARSENAULT: All right. Bye-bye.

 MR. ELA: Thank you, Harriet. Thank 

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you, Michelle.

 (Whereupon, the above-entitled matter 

went off the record at 3:48 p.m.) 

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A-B-I-T-I-A 155:5 

A-dae 1:19 11:13,15 

abandoned 133:6 

abbreviated 155:20 

abide 116:18 

ability 16:2 29:10 30:7 

34:14 44:17 110:14 

129:3 130:15 

Abitia 84:5 87:4 92:21 

96:19 148:13 155:5 

able 9:18 17:21 20:17 

31:5 32:3 33:19,21 

34:8 39:15 42:12 57:3 

57:6,7 59:16 66:14 

68:15 69:6,8 84:14 

86:21 101:11,20 

102:12 106:18 109:7 

119:18 122:13 125:8 

128:14 153:15,17 

above-entitled 157:2 

absence 114:8 

absolutely 146:15 

147:18 

absorbs 20:10 

accepted 128:1 

access 10:9 46:12,16 

57:7,8 115:2 131:22 

132:9 

account 8:5 

accountable 141:20 

accreditation 64:9 67:1 

68:4 

accredited 73:10 

accurate 137:18 

acetate 127:14 128:1,2 

128:5,11,12 

achieve 54:17 

acid 89:4 93:11 94:17 

95:7 128:9 

acidic 128:9 

acids 89:1 114:12,15 

acknowledge 74:18 

75:10 133:19 

acknowledges 141:7 

acre 38:4,6 

acreage 44:16 99:19 

acres 14:3 15:18 28:7 

28:10 31:14 38:8 

40:22 41:2,3,4 134:1 

act 5:5 34:12 104:22 

153:12,18 

action 44:13,22 46:10 

68:12,15 141:14 

actions 44:2,5 45:8 

48:10 

active 59:14 90:17 

activist 143:16 

activity 106:22 150:19 

actors 46:10 

adaptive 94:11 

add 16:10 29:17 31:18 

52:3 152:6 

added 47:13 52:6 89:12 

114:10 115:3 152:2 

adding 73:18 136:1 

addition 44:18 49:19 

74:10 104:18 129:2 

additional 22:15 44:20 

45:10,16 47:1 60:2,22 

95:17 

additive 107:20 

additives 74:6,8 122:2 

address 44:2,6 45:21 

47:21 53:3 54:10 

116:6 119:8 138:20 

139:14 153:15 

addressed 47:15,19 

139:16,17,17 

addresses 44:4 

addressing 93:16 

147:11 

adds 38:1 

adequate 46:19 

adequately 139:14 

adhere 56:7 

adjacent 56:3 

administer 109:8 

administrative 45:4 

administrator 18:4 

advance 45:14 137:3 

advanced 49:7 

advantage 128:16 

134:14 

Advisory 2:2 5:5 

137:15 

advocated 46:20 

advocating 98:7 144:5 

144:10,16 

affect 8:6 

affiliation 36:6 40:17 

43:20 47:7 51:16 

62:19 71:12 73:3 84:6 

87:5 93:1 97:4 101:8 

101:17 102:7 103:4 

108:12 113:14 120:9 

125:6,19 131:4 135:7 

140:17 148:16 149:20 

affiliations 30:14 

afford 29:12 

afraid 145:13 

AFSA 133:1 134:13 

afternoon 4:10 51:17 

156:7 

ag 94:3 

age 141:10 

agency 45:12 49:13 

66:17 

agenda 5:9 47:13 50:8 

52:4,7 58:8,10 67:18 

73:16,19 87:17 88:3 

agents 46:11 

ago 19:11 33:16 36:19 

55:22 77:20 88:21 

agree 88:19 135:15 

agri 105:18 

agricultural 37:4 45:20 

52:13 106:22 121:5 

agriculture 1:1 8:8 51:2 

88:2 93:18 103:17,22 

104:16,17 106:19 

129:16 137:4 

ahead 6:10 30:19 53:15 

58:5 77:6 95:21,22 

130:4 131:1 138:4 

144:1 146:10,11 

153:9,9 

aid 48:18 

aids 121:19 122:3 124:3 

124:15 

AITT 152:7 

alarmed 45:13 64:5 

Albert 60:19 61:1 

alcohol 14:19 15:9 22:7 

32:1 33:22 63:6 

103:15 104:6,9,12,15 

107:13,20 

alcohols 14:7,12 15:17 

16:6,10 17:4 18:2 

19:12 24:13,20 25:21 

28:13,21 29:4,15,17 

29:22 31:9 33:13 

41:13,18 42:16 68:11 

103:9,13 104:20 

105:3,7,11,15 107:18 

Alex 2:21,21 30:19 

35:18 40:15,18 42:19 

algae 120:21 135:19,21 

138:11,15 140:6 

algaecide 120:16 

allotments 39:3 

allotted 67:11 155:4 

allow 14:12 29:5 41:17 

42:15 49:7,9 63:9 

70:17 75:16 79:21 

80:6 81:20 82:11 

86:12 134:8 145:17 

152:1 

allowance 16:6 17:3 

29:15 34:21 64:13 

65:7 82:16 83:10 

109:11 142:16,18 

allowed 16:11 27:11 

29:3,17 41:14 70:7,8 

71:21 79:11,13 85:9 

90:1 143:3 145:18 

146:16 

allowing 31:5 40:21 

42:14 70:3 74:7 81:12 

109:15 144:18 

allows 14:15 109:13 

130:12 

allyl 152:7 

Aloha 149:17,22 

alter 59:21 

alternative 85:15 98:2 

120:20 153:13 

alternatives 75:18 

121:8,11 153:21 

154:4 

alum 150:5 

Amalie 2:17 40:16 

43:18 47:5,8 50:4 

52:11 

amazing 100:6 

Amber 2:19 51:15 

62:17 71:8,12,13 72:4 

72:6 73:1 84:10,12,13 

85:1 

ambitious 48:21 

America 143:7,11 

144:10 

American 143:16 

Amish 55:19 

ammonia 121:7,15 

amount 21:7 25:3 34:19 

81:9 122:10 

amounts 91:2 

amplify 135:14 

analysis 54:6 

Analyst 2:4 

analyzing 53:20 

and/or 25:21 152:13,19 

Andrew 101:7,15 102:5 

102:6,8,10 148:13 

155:8 

Andy 102:17,19 

anecdotally 19:10 

animal 77:14 78:2,6,15 

104:2,4 108:21 121:7 

151:17 

animals 76:12 77:16 

78:9,21 

annexed 56:10 

annotations 136:1 

announce 6:10 

announced 141:10 

answer 18:6 20:12 

69:12 111:12 112:4 

145:15 147:5 

answers 123:13 

anthropology 155:6 

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anymore 39:2 

anyway 18:20 33:17 

35:7 

apart 38:5 

APAs 134:14,17,21 

aphids 32:5 35:6 

apologies 149:21 

appears 105:5 

Apple 55:17 

applicability 52:13 

application 81:2 123:21 

applied 81:9 93:17 

133:22 136:15 138:8 

applies 147:21 

apply 15:6,12 60:12 

80:18 129:14 136:6 

appointed 44:18 

appreciate 4:14 5:17 

13:4 35:21 36:14 

40:12 44:1 49:22 

54:18 60:14 62:8,9 

73:18 74:15 88:15,16 

148:4 154:20 156:16 

appreciated 120:2 

appreciates 47:20 53:2 

approach 74:11 77:14 

approached 26:2 

appropriate 67:19 

122:9 

approval 34:15 

approve 103:12 

approved 15:21 64:4,11 

65:9 76:14 107:20 

approximately 37:17 

156:2 

April 1:7 3:18 

aquaculture 114:9 

area 33:11 55:19,20 

56:3,5,15 67:19 

102:10,11 125:10 

127:8 

areas 44:6 83:7 121:10 

argument 106:17 

arises 95:4 

arrive 88:17 

ARSENAULT 2:2 3:3 

6:19 7:1 8:21 9:6,13 

9:21 10:3,6,11,14,17 

10:19,22 11:3,6,8,11 

11:13,15,17,20 13:1,8 

27:19 36:3,12 40:7 

61:22 62:14 64:18,21 

72:5 77:2,6 83:17 

84:1,3,7,9,13 89:14 

95:20 101:10,19 

102:1,9,19 111:13 

117:10 125:7 126:2 

140:11,13 148:19 

149:5,11,14 155:14 

156:10,21 

Asa 1:15 10:12,14 

21:20 55:3,14 83:19 

90:4 100:14 101:5 

106:3 124:18 

Asa's 83:17,18 91:12 

Ashley 1:21 11:18,20 

111:19 112:3 

asked 21:19 33:15 34:7 

39:22 43:6,7 77:20 

79:8 83:21 87:18 

110:2 117:15 118:22 

asking 27:12 88:2 

147:8 

assessed 117:17 

assessing 118:6 

assessment 52:12 

63:20 68:3 

assist 5:7 

associate 120:11 131:6 

141:16 

associated 29:6 99:20 

116:8 

Associates 2:11,22 

120:12 135:12 

Association 2:6,9,17 

47:10 51:19 97:16,22 

assuming 34:15 139:13 

145:2 

assure 140:5 

assured 8:3 

ASTM 121:22 123:20 

124:19 

at-risk 49:1,13 

atmosphere 59:9 

attempt 67:9 132:21 

attend 41:8 

attention 66:3 92:12 

attract 32:4 

attracted 35:4 88:8 

audio 149:9 

authorities 44:19,20 

49:19 

authority 44:12,21,22 

49:6,19 

availability 75:21 76:3 

112:8 

available 75:19 97:14 

109:17 114:7 117:17 

118:16 128:5,13 

136:9,12 139:10 

152:20 154:4 

avoid 63:16 69:14 82:3 

avoidance 138:21 

awarded 98:4 

aware 17:5,17 20:21 

23:15 25:1 59:22 

60:17 110:18 147:8 

153:20 

awareness 49:12 

axillary 14:10 

axis 37:18 

B

back 23:6 27:2 34:17 

42:10 72:15,21 73:1 

84:10 88:2 96:20 

131:8 150:16 

background 3:12 5:22 

13:3 27:22 40:8 62:7 

126:17 156:16 

bad 46:10 92:12 126:21 

Baird 1:14 10:6,7,8 

Barbara 88:20 

barely 40:6 

Barton 2:6 43:20 51:14 

51:17,18,21 55:11 

57:16,21 58:2 59:12 

61:14,19 

base 37:4 

based 113:21 116:19 

121:1 122:10 129:11 

151:7 152:5,11 

basically 20:8 25:15 

35:8,9 38:15 

basis 67:5 

bathroom 153:22 

bean 15:1 41:3 

bear 143:8 

becoming 146:3 

beef 37:6 75:7 

begins 52:21 

behaviors 152:22 

belabored 48:8 

believe 7:9 8:1,18 17:2 

28:2 74:20 78:9 

155:14 

beneficial 51:9 

benefit 128:18 135:19 

benefits 114:21 115:2 

131:19 

berries 132:17 

berry 132:15 133:8 

best 3:15 19:10 23:21 

86:6 112:9,19 136:3 

140:5 151:6 154:18 

better 15:8 72:8 74:8 

84:16,17 85:15 

119:22 120:20 126:14 

127:4 130:18 141:8 

beyond 99:4 

big 26:11 30:3 33:12 

83:21 100:16 

bigger 137:8 

Bill 2:22 44:11,19 45:5 

65:19 125:17 131:2 

135:5,6,10 138:1,5 

140:15 

billion 143:12 

bills 37:7 

Billy 2:8 8:19 12:17,19 

13:14,19 16:16 17:5 

18:9,14 21:17 22:3 

24:12 26:14 27:14 

28:5 30:7 31:7 37:19 

bio-based 82:4 

biodegradability

105:19 

biodegradable 121:16 

122:22 123:7 

biodegradation 121:22 

123:16 

biodegrading 123:1 

biodiversity 70:14 

biology 95:14 123:2 

biotechnologies 93:16 

biotechnology 94:12 

bit 4:5 5:20 6:2 11:22 

38:21 55:17 68:14 

87:2 89:8 90:7 92:19 

96:10 112:5 

black 121:13 

bleach 154:1 

bleaching 116:12 

blight 121:2 

block 56:20 

blood 62:8 

blooms 14:9 

board 1:3,9 3:8 4:13,16 

4:18 5:4,15,18 7:8 8:4 

9:3 12:8 16:13,17 

18:3,5 19:20 22:4 

24:8 27:12 29:16,20 

34:2,11 35:2 38:19 

42:15,19 47:4,11,21 

49:17,22 50:4 51:14 

51:22 52:2 54:11 55:2 

71:7 77:9 87:11 93:5 

95:19 96:2 100:13,21 

106:1 108:6 111:17 

113:10 118:18 120:6 

122:19 124:17 125:21 

127:15 128:21 129:22 

135:4 137:1,2,11,15 

138:1 143:20 147:15 

154:17 156:1,17 

Board's 127:19 

bodies 134:11 

body 20:10 114:18 

Bondera 2:7 135:5 

140:16 148:12 149:13 

149:17,21,22 153:14 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
160 

154:20 

book 99:11 

Border 45:11 49:5,20 

bought 39:2 

boundaries 81:18 

box 7:10 

BPA 90:9,15,16 91:13 

91:15 92:1,3,9,11 

Bradman 1:15 10:12,13 

10:16 19:21 21:10,19 

21:20 55:3,3 57:12,17 

58:1 83:20 90:4,5 

100:14 106:2 107:11 

124:18,22 125:2 

brain 114:18 

brainstorm 57:3 

brand 54:17 85:12 

brands 27:1 

break 37:13,14 

breaking 96:9 

breaks 120:18 

breeding 152:19 

Brilliant 127:5 

bring 5:13 31:13 57:19 

63:18 73:1 133:20 

143:7 

bringing 128:20 

brings 31:12 

Briones 11:13 

broad 44:5 64:15 69:21 

broader 83:12 98:16 

broker 48:14 

brought 51:1 

buds 14:10 

BUI 107:12,16 108:3 

Buie 1:14 10:17,18 

build 37:4 54:9 98:8 

building 70:15 91:12 

built 67:12 

bunch 61:9 

burden 53:11,12 61:5 

137:18 

Burlington 36:15 

business 13:11 26:22 

38:15 115:16 127:17 

132:16 133:6 134:19 

busy 7:19 

button 6:5 

buy 48:13 59:10 60:16 

buyer 23:16 

buzzer 6:17 

bye 156:20 

Bye- 156:19 

Bye-bye 156:21 

byproduct 115:5 

119:10,17,19 

C

C10 108:2 

C8 108:2 

cabbage 28:9 

calcium 127:14 128:1,2 

128:4,5,10,11,12,13 

128:14,15,16,18 

130:9 

calciums 129:11 

California 107:14 110:8 

145:10 

call 4:15 8:12 9:2,3 

12:11 68:18 72:15,21 

101:13,20 

called 37:13 84:15 

142:21 149:7 150:17 

caller 96:6,14 

calling 13:10 

calls 53:8 

camel 90:15 

cameras 145:11 

Campaigner 2:19 93:4 

canceled 9:17 

cancelled 102:19 

canning 115:5 

carbon 108:4 

carcinogen 107:14,15 

carcinogens 106:13 

107:22 

cardiovascular 114:20 

care 37:22 41:10 109:2 

careful 23:1 25:10,18 

80:13 81:11 

carefully 110:5 

Cargill 2:7 101:16 102:5 

102:17,21 103:1,1,5,6 

107:9,15,17 108:4,8 

cargoes 45:15 

caring 143:10 

Carolina 13:20 28:7 

31:2 36:15 39:8 40:20 

41:20 

carry 34:13 137:18 

Carter 2:8,8 8:19 12:17 

12:20 13:15,19 17:7 

18:19 19:18 20:3,7 

21:17,17 22:8,12 

23:19 24:14,22 26:18 

27:16 

case 56:13 57:15 66:12 

94:18 

casings 151:18,21 

152:2 

catching 72:17 

categories 64:15 

cattle 37:6 110:9,14,15 

caught 115:8 

cause 20:22 34:16 

105:15 121:16 123:4 

127:1 139:4 150:22 

causes 154:17 

CBP 45:14,18 46:1 

CBSA 110:8 

CCOF 2:16,20 71:15,15 

71:17 85:2,2,5,17 

108:15,20,22 110:19 

111:5 

celery 97:12 98:3,15,17 

99:4 100:2 

cell 10:8 130:17 

Center 2:14,21 87:7 

91:13 97:8 113:7 

centuries 107:5 

CEO 125:22 127:12 

cereal 22:22 23:3,6,12 

certain 15:17 

certainly 17:14 21:5 

79:22 119:21 130:7 

135:19 

certainty 68:20 

certificates 45:2 46:2 

certification 2:10,15,19 

44:8 48:11 49:11 

50:21 52:18 55:5,7 

56:1 66:22 71:14 73:8 

85:2 93:15 108:15 

123:18 124:8 134:11 

135:20 142:6,11,15 

certifications 47:18 

64:8 

certified 14:1,3 15:18 

22:16 23:17,17,20 

24:4 41:1 42:2 104:10 

108:22 114:6 135:18 

136:3,10 138:14,15 

142:5 145:22 146:17 

146:20 147:4 

certifier 73:10 145:16 

certifiers 47:17 50:9,17 

51:6 52:16 54:17 

70:18 141:19 

certifies 112:11 

certify 73:11 75:6,10 

134:18 

certifying 46:11 63:14 

cetera 74:14 88:18 

chain 44:10 108:1 

130:20 

chains 108:4 115:18 

chair 1:10,12,13 3:8 

5:15 6:9 9:8,14 

chairing 5:16 

challenge 3:13 55:22 

143:14 

challenges 52:22 99:20 

challenging 56:13 

chance 8:16 16:7 

chances 67:16 

change 50:13 75:15 

99:10 145:21 

changed 133:16 139:8 

changes 91:3 

changing 142:9,14 

152:18 

Chapman 1:15 2:9 

10:20,21 24:9,12,17 

91:9,11 92:8,16 

118:19 119:15 120:1 

120:4 131:2 135:5 

140:16,18,19 144:9 

145:6,9 146:7 148:10 

150:8 

chapter 59:15 

chat 87:4 

check 46:1 62:4 

checking 112:12 

Checkmate 86:5 

chemical 99:5 105:6 

chemicals 87:20,22 

88:8,11 90:17,22,22 

91:4 133:22 

chewing 39:1 

chicken 132:1 

chickens 132:9 152:21 

153:1 

children 88:13 105:16 

chlorine 120:21 152:11 

153:13 154:6 

choice 86:7 

choices 151:16 152:19 

choose 99:9 114:13 

122:13 

chose 91:20 

chosen 134:14 136:9 

cigarette 24:6 

cigarettes 23:18 24:4 

106:13 

cigars 38:22 

circumstances 20:21 

cisgenesis 93:12 94:7 

cisgenic 89:10 

cisgenics 89:5 

Citizen 2:20 

citizens 137:16 

citrate 89:22 152:7 

Citrus 96:20 

claim 23:18 48:16 

claimed 33:14 

clarification 144:22 

147:20 

clarify 46:8 

CLARISSA 2:4 

clarity 63:9 75:20 

class 109:12 

classical 116:10 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
161 

classification 95:12 

clause 34:10 151:11 

clay 129:10 

clay-based 129:11 

clear 53:10 58:21 89:9 

142:1 

clearance 58:11 

clearly 7:4 53:17 94:10 

94:22 113:4 

climate 54:15 

clock 17:5 

close 5:14 59:18 

closer 72:6 126:4 

closest 49:10 

closing 46:18 89:21 

116:20 

Coalition 2:13 43:22 

code 102:10,11 125:10 

codes 48:18,22 

Colehour 2:7 135:5 

140:16 148:11,15,15 

148:19 149:3,8,13,14 

149:16,22 153:5,8,10 

154:10,10 

collaboration 97:16 

collagen 151:20 152:2 

colleagues 5:10 

collect 98:12 

collecting 109:22 

collection 44:16 

collects 78:7 

color 99:9 

coloring 99:15 

combination 71:21 

85:9 

come 37:3 38:17 55:21 

58:12 79:7 83:6 92:22 

96:20 126:17 133:17 

138:22 141:14 145:12 

comes 55:15 78:9 

coming 6:13 48:20 

50:12 87:8 134:22 

comment 4:13 6:8 7:20 

16:21 17:21 38:19 

42:21 50:1 52:1 59:17 

60:6 73:15 90:7 97:6 

100:15 106:5 107:10 

112:22 122:16 153:11 

153:17 

commentator 8:20 

commenter 12:14 

commenters 6:11 8:2,3 

commenting 97:11 

comments 4:18 5:6 7:6 

8:5 14:6 16:13,16 

31:5 35:17 39:19 48:1 

50:3 51:13 53:8 61:17 

61:20 63:3 66:5 80:6 

88:10,17 89:18 90:6 

93:6,8 94:20 96:6,15 

103:10 111:11 112:22 

113:6,9 117:6 118:21 

122:18 124:17 135:14 

136:5 138:6 150:13 

154:10 155:12,18,22 

commercial 26:21 

75:21 76:3 109:16 

112:8 

commercially 75:18 

97:13 114:7 136:8,11 

Commission 48:20 

51:5 

commitment 13:17 

16:3,12 62:21 

committed 115:14 

117:2 

Committee 2:2 5:5 

committees 87:11 

commodities 49:1,4,14 

common 70:19 86:4 

109:9 

communicates 97:9 

communication 147:9 

communities 104:4 

community 33:10 53:4 

54:4 136:4 

companies 29:12 51:5 

53:14 60:20 129:10 

company 56:7 91:20 

135:18 

compatibility 103:21 

compatible 103:16 

104:7,16 

compete 131:16 

competing 132:5 

competition 132:13,22 

compile 53:22 

compiled 118:2 

complaint 26:11 

complemented 98:6 

complete 16:8 29:16 

67:10 86:8 

completed 48:22 63:9 

complex 100:3 

compliant 65:10 70:12 

comply 66:7 70:20 

118:5 119:6 

components 70:13,16 

151:18 

compost 74:14 

comprehensive 49:14 

104:19 

compromise 81:3 

compromises 144:20 

computer 126:22 127:1 

127:4 149:1 

concentrated 128:9 

concentration 130:8 

concept 60:18 104:7 

151:3,9 

concern 20:2 53:11 

59:1 69:12 70:3 74:7 

78:19 79:1 105:11 

119:13 

concerned 17:15 20:18 

21:5 34:18 38:13 60:1 

109:6 

concerns 65:7 119:2,8 

conclude 117:4 

conclusion 142:18 

concrete 57:19 

conditions 121:3 

conduct 65:13 

conducted 1:10 

conducts 97:9 

conference 72:11,12 

confinement 132:1 

conflict 12:5 

conformity 63:20 68:2 

Congress 44:5 46:20 

65:17 

conjunction 123:19 

Connecticut 121:4 

consequences 112:11 

conservation 119:2 

consider 42:15 110:5 

124:4 133:22 134:4 

136:4 

considered 42:9 89:2 

89:11 95:1,6 127:15 

considering 16:13 

79:22 150:14 

considers 115:20 

consistence 122:11 

consistency 46:15 51:9 

52:20 63:19 64:7 

65:15 66:19 

consistent 47:18 66:15 

69:19 

consternation 154:17 

constraint 18:17 

construction 56:5 

consult 4:21 

consultancy 135:13 

consultant 103:8 

consulting 120:13 

consumers 114:13 

115:1 131:17 142:22 

143:3,5,10 

consumption 8:8 116:8 

116:10 

consumption's 27:5 

contact 88:6 90:10,14 

121:13 133:18 

contained 91:22 

container 64:16 65:8 

69:18 70:18 144:4,12 

146:17,19,21 

containers 48:13 144:6 

145:1,4 

contains 74:9 

contaminant 116:18 

118:14 

contaminants 116:9,13 

117:16,21 

contamination 53:3,14 

54:10,15 105:12 

contemplating 26:8 

contend 26:9 104:5,14 

continue 21:22 30:5 

63:12 64:7 65:17,20 

68:20 69:11 87:18 

95:16 

continued 97:12 114:5 

115:17 

continues 73:20 86:1 

continuing 46:22 90:9 

151:22 154:21 

continuity 66:17 

continuous 66:14 

136:14 139:5 

contradictory 115:6 

contribute 115:11 

contributing 114:18 

control 14:7 15:2,5 19:4 

25:21 26:10 32:11 

35:5 38:14 50:10 74:8 

116:12 119:2 120:17 

120:21 121:1 132:11 

controlling 14:13,15 

controls 115:22 

convene 97:22 

conventional 33:9 98:3 

100:2 134:1 142:10 

146:2 

conversation 57:18 

141:22 

conversations 40:9 

147:10 

converts 128:11 

copper 120:21 

core 44:11 137:2 

corn 13:22 23:9 25:14 

28:9 54:12 60:21 

corrected 66:2 

correctly 25:6 144:3,8 

cost 26:10 29:10 33:8 

33:12 59:2,6 60:2,4 

121:12 132:19 

costs 29:6 41:10 42:11 

42:11 59:20,21 

counter 90:20 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
162 

countries 29:7 

country 53:21 75:13 

county 31:3 

couple 3:9 46:21 91:19 

course 8:12 14:14 20:3 

22:1 23:10 37:12 

106:11 133:2 136:19 

146:4 

Court 20:5 21:9,11,11 

21:13,14,18,21 

cover 22:21 23:5,13 

25:12 

covered 156:11 

cows 46:9 57:1,6 

coyote 121:9 

create 128:4 

created 128:2,8,10 

creates 70:5,10 140:1,2 

Creedmoor 40:19 

Creek 2:10 31:1 55:17 

Creeks 30:18 

criteria 94:18 104:22 

122:4 124:1 

critical 63:15 70:12 

74:18 114:4 130:10 

130:12 138:17 

crop 22:11,19,21 23:4,5 

23:14 24:12,18 25:2,4 

25:11,12 26:2 28:13 

29:5 32:16 39:6 42:6 

68:21 70:14 86:2 99:7 

99:21 120:17 129:5 

132:11 133:15 134:12 

135:21 147:2 

crops 28:17 71:22 

85:10 98:10,16 99:4,9 

99:14,17 130:18 

134:3,6,7 142:14 

cross 56:15 

crucial 117:2 

cucumber 133:8 

cucumbers 31:20 32:19 

32:22 

cultivated 39:16 

culture 39:4 46:14 

curing 99:6 

curiosity 37:10 

curious 24:19 86:20 

current 17:17 54:15 

59:9 74:20 122:10 

141:20 

currently 12:3 14:3 

17:4 56:11 60:21 75:1 

85:5,15 94:3 112:12 

custom 109:9 

customers 118:16 

Customs 45:11 49:5,20 

cut 41:19 143:1 

cycle 100:10 

D

D5988 121:22 

dairy 46:5,9,10 56:14 

75:6 88:7 131:15 

133:7 155:9 

Dallas 97:2 101:6,15,16 

101:17 148:13 155:6 

damage 32:6,12 139:14 

143:10 

Dan 1:20 11:15 

Dana 2:18 84:5 87:4 

92:20,22,22 93:3 96:1 

danger 107:3 

dangerous 15:11 90:22 

Daniels 2:10 12:18 

27:18 30:17,20,21 

34:18 35:6 

data 44:15,16 49:7 

53:20 54:1,5,13 91:17 

98:11,18 

database 44:15 

date 63:2 

daughter 99:11 

Dave 1:17 2:9 11:20 

96:3,4,9 131:2 135:5 

140:15,16,18 143:20 

144:2 146:6 147:8 

148:9,9 150:8,10 

day 7:19 65:20 142:9,11 

De 1:16 10:22 11:2 

deal 14:12 38:6,10 

123:7 

dealing 86:7 

decade 136:18 

decades 114:22 

December 44:13 

decide 41:17 

decision 134:8 

decisions 8:6 122:6 

151:4 

deck 6:11 27:18 30:18 

35:19 51:15 62:18 

71:11 84:5 97:2 101:7 

101:16 102:6,21 

108:11 113:11 120:8 

125:5,18 131:2,3 

135:6 140:16 148:14 

declined 27:7 

dedicated 14:4 

deeper 123:7 

defined 94:22 109:22 

112:15 119:18 

defines 105:13 

definitely 34:21 86:16 

96:7 100:22 138:17 

definition 75:21 94:11 

119:22 

definitions 89:7 119:19 

degradation 124:5 

degree 105:19 

Dehne 2:10 62:17 71:11 

73:4,5,7,8 77:18 

78:11,22 80:12 81:19 

82:2 83:1,4 

delay 34:17 109:7 

delays 69:4 152:15 

deliver 64:6 

demand 26:15 76:21 

137:16 

densities 85:22 

deodorization 116:12 

department 1:1 58:14 

88:1 

depending 4:10 110:10 

deprivation 25:5 

deputy 18:4 141:3 

derived 93:20 104:9,12 

104:15 

describe 105:9 

desirable 14:9,18 

desired 114:13 

despite 115:6 132:18 

detailed 47:22 49:6 

96:6,14 113:2 

details 45:17 153:15 

deter 44:17 45:8 

determine 75:3 91:14 

determined 103:14 

105:3 

determining 122:1 

124:2 

detrimental 105:6 

develop 14:11 64:1 

137:13 

developed 68:3 86:3 

88:22 94:16 98:14 

138:16 

development 54:14 

88:12,12 114:19 

130:17 

devil 37:10 

Devon 2:3 16:18 

DHA 113:21 114:12 

116:18 

dial 84:14 

dial-in 148:22 

dialed 84:19 

dialing 149:12 

die 21:3 35:22 

difference 33:4 

differences 132:18 

different 23:8 28:19 

58:13 107:6 130:8 

135:17 

difficult 14:20 19:9,15 

20:17 53:3 70:5 99:15 

110:1 150:11 

dihydrogen 89:22 

152:7 

diligence 67:10 

DiMatteo 2:11,11,22 

108:10 113:12 120:7 

120:10,11,12 123:12 

123:15 124:21 125:1 

135:12 

direct 49:11 119:11,17 

119:19 131:14 134:8 

152:20 

directed 93:12 95:5 

103:10 

direction 78:4 

directly 43:1 48:2 59:19 

132:5 152:9 153:16 

director 2:1,10,12,14 

2:17 43:22 47:9 73:9 

87:7 97:7 131:6 

140:20 141:3,16 

discourages 81:5 

discreet 48:10 

discrimination 136:12 

discuss 57:11 107:7 

discussed 52:12 112:5 

discussion 44:4 52:8,9 

78:17 83:22 100:16 

106:6 108:19 109:3 

109:19 127:14 138:11 

146:14 147:5 

discussions 100:18 

disease 71:19,21 74:19 

76:2 85:7,9 114:20 

120:17,22 130:18 

disinfectant 120:16 

dispenser 86:14,18 

disqualify 142:5 

disrupt 85:20 88:12 

disrupting 87:21 

distribution 82:19 

Division 2:1,3,4 4:3 

5:12 

Dixon 2:12 125:5,17 

131:2,5,5 

doable 81:4 82:5,13 

document 52:9 108:19 

109:3,19 117:15 

documentation 76:3 

documented 44:4 

documents 49:11 96:17 

136:20 

dog 3:14 

doing 39:17 61:1 79:3 

87:12 94:5 98:15 

122:21 154:18 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
163 

dollar 98:20 

domestic 26:22 27:5 

46:3 

dominance 131:22 

door 139:21 

Dr 18:3 97:5,7 141:13 

141:22 142:3 

drastically 15:19 

draw 66:3 

drops 44:15 

DSM 2:16 113:19,22 

115:14,20 116:1,20 

due 67:10 114:8 116:8 

130:20 132:19 

Dykstra 101:7,15 

148:13 155:8 

E

Eagle 13:20 

earlier 63:5 68:18 94:15 

103:11 141:22 

earliest 151:15 

early 69:15 152:4 

Earth 2:19 93:4 

easily 99:6 

eastern 28:7 31:2 

156:13 

easy 129:14 

echo 93:8 126:21 

Ecological 2:6,17 47:10 

51:18 

economic 28:20 69:1 

ecosystem 105:18 

edge 56:21 

edible 115:5 

editing 93:21 94:8 

95:13 

education 57:3 

effect 122:22 123:8 

150:22 

effective 33:20 53:20 

122:12 

effectively 14:12,14 

19:4 33:21 

effectiveness 28:20 

effects 106:8 

efficacy 121:2 

efficient 14:16 53:20 

60:8 

effort 129:19 131:8 

139:10 145:14 

efforts 5:17 44:1 49:16 

52:2 54:18 140:5 

Egg 103:8 

eggs 99:11 152:21 

153:1 

eight 30:2 

eight-week 19:7 

either 7:11 20:9 56:22 

67:8 102:13 109:21 

125:8 133:5 139:14 

Ela 1:13 9:10,12 34:3,3 

34:6 39:20,20 43:3,3 

43:5,13,15 68:6,6,9 

69:16 79:16,16,19 

81:14,20 82:17 83:3 

83:14 86:10,11,20 

130:1,1,5 143:21,21 

144:2,21 145:8 146:6 

153:6,6,10 156:22 

elaborate 18:16 130:5 

eliminating 20:16 44:8 

email 33:17 

embryo 76:7,9,13,17 

77:13 78:18 

embryos 77:14 78:7 

emergence 132:3 

emerging 93:16 

Emily 1:18 11:8,11 

18:11 30:12 42:20 

58:3,5,9 138:2 146:8 

147:7,16 148:6 

emphasis 74:16 

employees 15:6 20:19 

21:5 

employing 65:21 

encourage 37:3 66:19 

121:21 123:3 136:13 

137:11 150:15 

encouragement 82:10 

encourages 111:5 

encouraging 79:21 

endocrine 87:21 

endorse 133:12 

energy 4:16 32:8 47:12 

50:5 51:4 52:3 55:7 

enforce 131:12 132:9 

132:11 

enforced 141:7 

enforcement 44:19 

45:12 46:4,9 52:20 

63:21 65:19 134:16 

141:10 

enforcing 141:20 

engage 52:21 

engagement 7:22 

engineered 113:4 

engineering 93:21 94:1 

95:17 

enjoyed 61:17 

enormous 106:9 

ensure 49:15 71:22 

85:10 93:14 110:22 

124:9 151:12 

ensures 115:16 

ensuring 62:22 118:7 

entering 110:9 138:13 

entire 39:5 56:1 136:7 

138:9 143:12 

entirely 96:10 

entity 26:20 44:21 54:2 

entry 45:13,15 46:2 

49:4 

environment 104:3 

105:4,20 107:1,19 

117:1 120:18 121:20 

139:15 150:21 

environmental 88:18 

95:4 105:12 116:2,9 

124:6 137:7 138:18 

138:21 152:5 

EPA 87:17,18 113:20 

114:12 116:17 

equates 38:9 

equipment 33:7 115:21 

129:12 

eroded 66:6 

ERSA 134:15 

especially 44:16 64:11 

99:21 109:8 110:1 

115:13 

essential 28:14 63:6 

70:16 111:4 130:6 

essentially 88:5 

establish 48:21 

established 94:1 151:1 

estrus 76:18 

et 74:14 88:18 

Etka 2:12 35:19 40:16 

43:18,21,21 

EU 144:11 

evaluated 116:4 

evaluation 115:7 

118:13 121:20 

eventual 52:15 54:14 

everybody 22:1 155:13 

everyone's 9:6 

evidence 105:14 

114:21 

evolution 95:8 

ex-WODPA 155:9 

example 57:9 66:1 80:7 

80:10,17 144:4 145:3 

153:2 

examples 55:9,12 

145:3 

exceedingly 20:15 

excellent 10:4 121:2 

exceptions 151:11,12 

excess 25:19 

exclude 91:6 92:7 

93:20 95:13 109:16 

excluded 74:22 75:4,8 

75:17 88:15 89:2 

93:13 94:4,12,19 95:2 

95:6,15,16 108:20 

109:4,11,14,21 

110:12,20 112:14 

128:15 

exclusions 44:8 

exclusive 115:8 

exclusively 134:2 

excuse 72:2 150:18 

152:12 

Executive 140:19 

exist 116:7 

existing 63:13 144:11 

expand 82:18 

expanding 90:10 99:18 

expansive 89:8 

expectations 116:2 

expediently 40:2 

expensive 29:11 78:17 

experience 21:1 76:20 

experiencing 133:9 

Experiment 121:5 

explain 22:10 

explains 105:16 

explore 45:3 139:1 

exploring 112:8,16 

exposing 83:7 

exposure 18:18 19:1,22 

20:1 

exposures 20:2 

expressed 119:9,12 

Extension 98:5 

extensive 89:18 

extinction 115:12 

extreme 132:18 

F

face- 4:22 

face-to-face 4:19 

faced 52:17,22 

facilities 144:12 146:2 

facility 23:21 142:5 

144:4 147:2 

facing 50:19 

fact 19:9 33:4 39:16 

70:9 87:19 92:4 

104:11,21,21 107:19 

112:13 129:9 140:22 

151:18 

faculty 11:22 

fail 143:9 

failed 131:21 132:10 

fails 133:19 

failure 66:7 70:20 

131:11 132:8,19 

failures 131:11,14 

faint 126:3 

fair 2:8 103:7 132:21 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
164 

fairly 7:4 68:16 119:11 

fall 12:7 34:12 37:2 52:8 

53:13 59:16 61:5 69:6 

94:11,18 

familiar 86:17 107:13 

family 39:6 127:17 

family's 36:16 

far 29:1,22 33:7,14 

38:13 53:19 

farm 2:6,7,17,19,21 

13:21 15:18,22 16:2 

23:12 30:22 36:15,22 

37:3 39:9 40:12 42:12 

44:11,19 45:5 47:10 

51:19 55:22 56:2 

65:19 71:14 147:21 

150:1 

farmed 14:2 

farmer 13:20 40:19 41:1 

53:15 59:21 61:6 

134:22 141:1 155:9 

farmer's 39:15 

farmer-led 131:7 

farmers 2:9,11 33:10 

42:22 47:16,17 48:3 

52:16,22 55:6 60:12 

63:5 65:20 67:17 

68:18 69:10 73:9 

80:18 81:12 85:13 

86:4,7 98:7 99:17 

122:8,13 128:17 

129:18 132:15 133:3 

143:11 147:1 

farming 36:21 37:8 

38:16 39:7 42:8 63:10 

69:11 104:2 105:8 

121:19 137:7,9 

farms 2:8,10,15 21:17 

30:18 33:7 39:6,17 

47:13 50:5 52:4 76:9 

80:16 81:13 85:1 

121:10 131:15 133:5 

145:1 155:10 

fats 88:9 

fatty 14:6,12,19 15:9,16 

16:6,10 17:3 18:2 

19:11 22:7 24:13,20 

25:21 28:13,20 29:3 

29:15,17,21 31:9 32:1 

33:13,22 41:13,18 

42:16 63:6 68:11 

103:9,12,15 104:6,9 

104:11,14,20 105:3,7 

105:10,14 107:18 

114:12,15 

favorable 115:1 

FDA 107:21 116:15 

feasibility 28:20 98:19 

Federal 5:5 51:4 

feed 60:10 132:6 

feedback 44:2 53:9 

96:16 126:21 127:2 

feeding 32:8 33:5 

feel 53:12 147:1 

fell 8:14 

felt 76:15 

fencing 121:8 

fertility 23:2 25:4 26:2,7 

26:11 132:11,20 

133:14 134:12 

fertilizer 80:19 

fertilizers 14:17 

fertilizes 134:3 

fetuses 88:13 

fiber 8:9 104:1 

fibers 74:6 80:3,7 81:8 

81:21 82:8,15 

field 13:22 20:14 21:7 

23:9 25:14 32:2 64:1 

66:2 67:17 70:10 

121:3 133:6,7 140:2 

fill 139:6 

final 46:7 77:21 78:3 

finally 49:17 66:3 82:17 

122:5 152:15 

financial 53:11 

find 86:18 97:13 98:2 

113:3 125:8 143:3,5 

finding 80:3 

findings 65:12 67:6,12 

fine 10:11 36:11 83:3 

finished 16:14 118:15 

fire 121:2 

first 3:17 4:2 6:7 8:19 

12:13,17 14:1 33:16 

47:11 63:4 65:4 66:21 

68:10 73:17 87:10 

98:1 117:19 136:9 

139:3 150:15 

first-time 8:2 

fish 113:21 114:1,4,7 

114:11 115:4,5,7,8,11 

115:12,13,17 116:8,9 

116:14,21 117:18,21 

117:22 119:9 

fisheries 115:21 

fishing 119:11,17,20 

fit 8:16 

fits 22:11 122:14 

five 22:8 37:20 151:9 

Flats 155:10 

flavor 99:10 

Florida 145:10 

flow 66:15 

flower 14:11 37:13,14 

flowers 35:10 

focus 54:12 65:14 

106:21 

folks 24:6 38:13 40:11 

60:10 62:5 89:13 

149:6 

follow 28:5 80:1 118:1 

118:11 131:15 132:20 

133:1 144:10 150:11 

follow- 144:2 

follow-up 24:10 119:15 

131:1 

followed 23:4 144:15 

following 12:19 31:7 

46:12 141:4 146:18 

follows 116:10 119:14 

food 2:6,14,17,18 8:9 

33:5 47:10 51:18 

71:16 85:4 87:7 90:10 

90:14 91:14 93:3 

97:21 104:1,22 

107:20 111:3 113:7 

151:16 153:11,18 

foods 88:7,7 114:11 

force 140:22 154:12 

forgot 84:12 

forgotten 12:11 

form 55:1 130:9 

formation 131:10 

former 62:20 140:21 

formulations 86:2,4,13 

fortunately 17:8 

forward 5:6 17:16 61:15 

63:13,17 65:18 67:13 

101:3 127:20 145:12 

foster 47:18 54:13 

133:14 

foul 129:12 

found 59:3 75:5 91:21 

113:5 128:12 

four 22:8 37:20 114:22 

119:3,4 

four-year 22:15 

fourth 118:22 

fraud 44:3,6,17,22 45:9 

47:22 49:12 67:16 

free 28:15 

freed 41:16 

FREEDMAN 27:9 

freely 57:8 

Freeman 26:13,14 

frequently 121:14 

Friends 2:19 93:4 

Frizzell 2:13 120:8 

125:5,13,15,15,20,22 

126:10,14,19 127:3,7 

127:11,12 130:3,11 

Fromer 155:7 

front 26:8 

fuel 42:11 137:10 

full 2:13 3:21 18:3,5 

47:6 125:22 127:12 

127:16 153:20 

fully 136:20 151:1 

funded 98:21 

funding 46:21 47:1 98:7 

100:9,10 101:1 

funny 99:9 

further 4:22 53:2 57:11 

69:14 111:8 137:17 

152:9 

Furthermore 104:8 

105:13 109:6 

future 42:16 117:3 

fuzzy 126:13 

G

gain 53:9 

gaps 67:8 

garb 20:13 

Gardens 155:7 

gather 49:6 137:17 

gathered 54:10 

gathering 54:6,13 

GE 53:3 54:10 

gel 151:18,20 152:2 

gene 78:19 93:21 94:8 

95:13 

gene-edited 89:11 

general 80:10 150:12 

generally 22:18 116:15 

generation 41:1 93:21 

generator 15:21 

genetic 53:5 58:20 

63:12 93:21 94:1,9 

95:17 

genetically 113:4 

geographic 148:1 

geography 64:3 

getting 27:21 81:17 

92:19 96:16 126:16 

126:20 131:18 142:5 

146:20 147:4 148:4 

148:16 

give 6:13 8:16 55:8 

73:15 124:14 130:16 

149:8 155:12 

given 34:6,8 54:15 

81:15 89:8 153:11 

gives 44:11 57:15 

130:15,17 

giving 29:7 97:6 100:11 

125:21 

glad 67:22 

global 115:12 116:17 

116:19 118:2 

goal 48:21 64:1,6 155:1 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
165 

GOED 118:1,5 

Gotcha 10:3,19 

gotten 76:8 

governed 71:15 85:3 

government 39:2 140:8 

grade 27:6 128:7 

grain 13:22 23:4,6,10 

23:11,13 42:4 53:8 

59:14 

grains 31:13,16 

grandchild 36:20 

grandfather 144:11 

grandfather's 36:19 

grant 16:5 29:14 98:6 

98:20 100:10 

granted 20:19 82:16 

graphic 27:6 

grassroots 131:8 

gravitate 22:14 

grazing 56:18 57:2 

greater 46:14 59:6 

67:16 109:14 

greatly 44:1,17 

green 39:15 49:4 99:11 

99:12,15 103:8 

greenhouse 142:10,13 

146:2 

Greenwood 1:16 11:4,5 

11:7 

grew 41:16 

grossly 15:4 

ground 109:19 144:13 

145:5 

grounded 151:3 

group 3:15 58:22 98:1 

groups 54:4 88:1 91:19 

grow 13:21 14:8 19:3 

25:4,9 28:7,8 29:5 

31:14,15,21 36:1 

37:16,17 38:20 41:2 

68:21 71:16 85:4 86:1 

134:6 

grower 53:21 55:16 

grower's 59:14 

growers 43:1 53:9,10 

55:6 58:22 59:13 

86:13 97:18 129:5,9 

129:15 

growing 25:16 26:17,19 

28:11 32:22 33:10 

36:2,17,18 

grown 27:3 31:19 53:6 

64:16 65:8 133:7 

147:2,3,3,22 

growth 14:13,15 15:21 

25:20 26:4,4 103:15 

grueling 15:6 

guards 129:11 

guess 39:16 68:9 69:12 

79:1 80:12 81:6,16 

82:2 102:1 155:16 

guidance 50:16 51:8 

52:15 63:14 91:5 

124:14 136:20 139:17 

139:18 

guide 57:18 

H

hair 121:9 

half 3:22 127:7 

ham 99:11,12 

hand 7:9 15:7,14 18:20 

19:5 20:17 25:20 29:8 

32:15 34:10,19 41:11 

83:18 

handlers 44:9 48:12,13 

48:15 

handling 45:19 60:10 

hands 84:2 

handset 72:14 126:9,10 

148:22 

Hang 8:21 

Hansen 87:3,6,6 

Hanson 2:14 71:11 84:4 

90:12 91:18 92:10,17 

93:9 113:1,7 

happen 48:6 67:5 

129:20 

happened 138:16 

happening 145:15 

happens 20:20 37:15 

66:16 148:2 

happy 55:11,13 57:10 

57:21 111:12 112:4 

hard 4:15 7:2 72:3 

73:14 122:16 139:9 

harm 121:17 138:21 

150:20 

harmed 65:20 132:8 

harmful 105:4 

harmonized 48:17 

Harriet 1:10,12 4:7 5:15 

5:15 6:9 8:21 9:7 12:9 

13:1 18:11 26:13 34:3 

35:13 39:20 43:3 

50:16 52:11 58:3 

59:12 61:22 62:14 

68:6 77:3,7 79:16 

83:17 84:7 86:10 

95:20 96:3 106:2 

111:14,15,18 117:9 

117:11 125:7 126:5 

138:2 140:11 143:21 

146:8 149:5 156:14 

156:22 

Harriet's 9:8 

harvest 23:11,14 

135:16 138:18 139:15 

140:6 

harvested 130:19 

Harvesters 139:11 

harvesting 32:10,22 

hate 69:13 

Hawaii 150:1 152:21 

hay 37:2 

he'll 12:1 

head 37:6 86:16 

headed 45:15 

heads-up 6:13 

headset 72:10 148:21 

health 16:1 19:9 76:2 

104:3 105:4,16 106:7 

106:11 107:1,3 

108:21 109:1 110:22 

114:17 116:7 121:21 

122:17 150:20 152:5 

healthy 114:18 154:22 

hear 3:15 4:6 6:16 7:2,3 

7:5 9:22 10:2,12,14 

43:1 48:2 51:19 54:1 

72:5 73:4 102:15 

103:2 113:15 117:9 

117:10 125:13 126:6 

126:11,12,14 127:4 

135:8 146:14 149:4 

154:11 155:22 

heard 3:13 59:15 63:5 

68:18,22 69:10 71:2 

hearing 5:6 40:8 44:20 

72:4 102:12 138:7 

148:20 149:1 156:2 

heart 63:1 143:1 

heartbroken 106:16 

heat 20:1 

heated 93:7 

heavily 110:21 

held 53:8 64:2 139:7 

hello 5:19 64:20,20 

70:20,21,22 108:13 

113:15 117:8 125:12 

135:8 140:18 

help 5:12 32:2 42:7 

47:17 52:9 57:18 

95:11 101:2 129:4 

137:12,13,17 

helped 41:14 

helpful 13:5 22:2 43:1 

57:14 96:15 124:2 

helps 33:13 96:8,16 

102:14 

HENSEN 87:10 89:16 

89:20 

herbicide 80:19 145:3 

145:21 

herbicides 142:4,16 

herd 56:14,15,18 

herds 110:22 

Hey 8:21 27:19 61:22 

96:4 101:10 149:14 

Hi 3:3 10:14,16 11:3,11 

11:12,15,20 21:13 

30:12 40:7 71:13 85:1 

93:2 97:5 106:2 

111:18 112:3 130:4 

131:5 149:15 

Hickory 2:18 

high 14:8 33:11 76:21 

85:13 99:21 105:19 

134:20 

high-value 39:5 

highlight 87:13 88:4 

highly 98:22 114:12 

115:10 

hilly 55:18,18 

histophilus 110:10 

history 25:16 107:4 

139:3 

hold 13:9,11 77:3 

111:13 141:19 147:15 

Honaunau 150:1 

honestly 144:16 150:11 

153:19 

Honingford 113:12 

120:7 125:4 148:12 

155:10 

hope 30:4 40:12 143:2 

147:19 

hoped 69:2 

hopeful 50:16 

hopefully 7:3 12:15 

hoping 100:9 

hormones 76:11,17 

77:15 78:2,10 87:21 

91:4 

horticultural 71:17,18 

71:20 85:6,8,16 

hot 20:10,15 

hottest 15:13 

hour 3:6,21,22 62:5 

hours 3:19 15:5 

housekeeping 4:5 5:21 

houses 132:1 

HT 48:22 

Hudson 102:18 

huge 90:15 128:16 

human 104:4 105:4,16 

106:22 116:10 121:9 

121:21 150:20 

humans 106:8 

hundred 60:11 82:1 

hundred-foot 56:20 

Hurricane 155:10 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
166 

hydrogen 120:15 121:1 

154:1 

hydrolyzed 134:2 

hydroponic 64:15 65:8 

70:17 132:17 134:3,5 

134:7,9 140:21 142:2 

142:20 

hydroponics 69:18 

133:12 142:18 144:17 

144:19 146:3 

I

IAP 85:13,14 

idea 61:15 81:7 82:11 

99:12 

idealistic 81:11 

identify 20:6 21:22 67:7 

99:3,19 

identifying 21:15 

ignore 134:15 

illustration 66:5 

imagine 38:10 56:20 

139:9 

imbalances 123:5 

immediately 142:4 

146:15 

impact 24:13,19 51:2 

52:3,14 59:19 110:5 

123:16 124:5,6 

138:21 

impacted 27:2 56:19 

impacts 106:11 123:19 

impeded 44:17 

implement 131:13 

134:21 

implementation 47:19 

implementing 65:18 

implication 142:7 

implications 153:18 

import 47:22 49:12 

importance 31:10 48:3 

67:15 73:20 74:16 

100:19 143:15 

important 12:11 28:12 

31:6 64:6 66:22 

108:21 139:22 141:5 

151:3 

importantly 54:8 

imported 45:20,22 

improve 16:2 28:16 

67:6 

improvement 66:20 

136:14 139:5 

improvements 16:1 

44:14 48:6 95:9 

in- 107:7 

in-person 83:22 100:16 

inaccurate 115:10 

inadequate 15:4 

incentive 99:18 

inches 38:5 

include 22:22 44:7,21 

52:7 64:15 76:4 93:10 

95:15,17 98:19 

116:11 124:13 

included 66:4 70:4,11 

74:2 

includes 45:7 74:4 

123:16 

including 45:17 48:10 

94:7 114:13,18 

131:11 139:18 

inclusion 47:15 

income 15:22 33:14 

incoming 118:13 

incompatible 94:2 

incomplete 94:5 

inconsistencies 67:8 

inconsistency 66:7 

67:15 

inconsistent 70:6 

incorporated 99:6 

increase 41:14 100:8 

105:15 106:9 123:4 

increased 29:1,6 41:5 

46:21 134:6 

increasing 26:15 27:1,6 

151:13 

incredible 137:15 

incredibly 91:2 

indefensible 142:22 

indicate 95:1 

indicated 35:22 

indicates 104:20 

105:10 

individual 6:3 53:21 

109:5,6 118:8 136:1 

industries 2:13 115:6 

126:1 127:13,16 

industry 91:15,16 

115:18 116:16 117:22 

118:1,9 119:13 

143:13 

industry-wide 119:7 

infants 105:16 106:8 

infection 121:3 

infographic 66:4 67:14 

67:21 

inform 59:9 

information 4:22 45:14 

54:3,10 55:13 77:11 

81:17 86:17 91:13 

107:22 109:22 110:3 

111:8 137:18 148:5 

154:19 

informative 57:13 

infrastructure 47:12 

50:5,19 52:3,17 55:8 

ingredient 114:5,10 

115:9 

ingredients 93:20 

114:2 136:8 

inherently 15:10 

inhibit 32:17 34:14 

initial 54:12 98:15 

Initiative 98:5 

inner 90:18 

innovate 139:5 

innovation 98:1 136:13 

139:12 

input 136:2 

inputs 135:21 136:8,11 

136:21 137:9 139:20 

inquiring 33:18 

insect 71:19 85:7,19,20 

insects 35:3 85:21 86:8 

inside 78:14 

inspection 49:13 66:22 

inspections 64:8 

inspectors 70:7 

instance 110:8 

instruction 50:9 51:8 

52:15 54:17 

instructions 50:17 

integrity 44:14 53:5 

58:20 62:22 66:6 67:7 

95:11 132:7 134:17 

134:21 150:9 

intended 67:4 

intent 89:6 

intentional 61:8 94:9 

interaction 128:3 

interdisciplinary 100:7 

interest 136:3 

interested 26:17,19 

76:15 151:16 

interesting 25:2 67:21 

113:5 

internal 106:4 

international 27:1 44:9 

48:20 68:2,4 

Internet 10:9 

interpretation 17:10 

64:9 76:11 77:19 

interrupt 13:2 27:20 

interrupting 62:2 

intragenesis 93:13 94:9 

intragenics 89:6 

introduce 119:16 

invasive 86:7 

inventory 17:8,11,15 

30:9 

investigate 98:11 

invite 111:6 

invoice 53:17 

involve 94:9 

involved 15:12 37:9 

94:8 95:6 

involving 15:5 45:1 

Iseley 2:15,15 27:18 

30:19 35:18,20 36:3 

36:10,13,13 39:11,14 

40:5,11 

Isomate 86:5 

isothiocyanate 152:8 

issue 18:17,21 44:12 

46:7 47:16,21 48:3 

51:1 52:10,21 59:13 

63:19 66:8,14 76:2 

83:6 123:11 129:5 

136:22 138:20 139:1 

issues 41:13 47:15,19 

55:7 59:19 65:14 

66:10 70:1 77:10 83:8 

137:1,3,7,13 139:22 

143:1 

it'd 23:4 

it'll 7:1 21:4 

item 50:8 58:8,10 83:22 

100:16 128:2 140:1,1 

items 5:9 73:16 87:14 

141:4 

J

jalapeno 31:21 

jam 153:4 

Jane 2:15 27:18 30:18 

35:18,19 36:5,13 

38:18,20 39:21 

Jaydee 2:14 71:11 84:4 

84:5 87:3,4,6 90:3 

91:12 93:9 

Jennie 2:16 102:22 

108:10 113:11,13,19 

117:14 147:14 

Jennifer 2:10 12:18 

27:18 30:17,19,21 

34:2 35:15 39:22 

141:4 

Jesse 1:14 10:17 

107:12 

Jessica 2:21 92:21 97:1 

97:3,7 

job 15:11 19:5 62:8 

156:15 

join 4:1 11:21 

judged 104:13 

Julia 2:6 43:19 51:14,15 

51:18 58:20 61:21 

June 32:20 

justification 90:9 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
167 

K

Kanalani 2:7 150:1 

Katherine 2:11 108:10 

113:12 120:7,8,11 

122:20 

Kathleen 97:2 101:6,7,8 

101:11 155:5 

keep 8:15 13:3 18:22 

41:9 42:2 47:17 62:10 

71:4 117:13 

keeping 61:10 62:7 

156:15 

keeps 37:7 

KELLY 2:15 

Kelp 135:11 

Kelsey 102:6,17,21,22 

108:9,11,14 111:21 

113:10 

kept 151:6,14 

kernel 104:10,12 

Kerston 2:15 102:6,17 

102:21 108:9,13,14 

112:3 

key 64:1,6 69:21 

kids 3:14 

kinds 101:1 106:18 

knowing 59:8 60:14 

70:7 

knowledge 23:22 

107:17 

known 105:6,18 

knows 7:14 53:16 

Kraft 91:20 

L

lab 94:16 

label 63:1 131:17 132:5 

132:8,14,18 133:3 

labeled 114:3 

labels 48:15 132:4 

labor 25:20 32:2,15,16 

33:2 38:11,17 41:9 

42:10 

labor-intensive 57:5 

lack 64:7 134:16 

land 22:16 33:8,11 

40:22 42:2,2 50:12 

53:6 56:10,12 80:19 

80:20 81:9 144:6 

146:20 147:1,21 

Landry 2:16 102:22 

108:10 113:11,15,18 

113:19 117:19 119:5 

119:21 120:3 

lane 56:18 57:8 

language 89:9 91:6 

languishing 141:12 

large 64:11 75:11 121:7 

121:10 146:1 

larger 63:19 66:8 

lastly 46:3 76:6 116:6 

late 11:22 69:7 133:4 

law 67:4 90:8 131:9 

134:16 

Lea 60:19 61:1 

leach 92:6 

lead 23:6 26:11 45:12 

67:15 77:10 

leaders 116:16 

leadership 5:17 

leading 100:18 116:22 

132:13 135:12 

leads 106:20 

leaf 32:9,10 37:18 38:2 

leaning 78:4 81:7 

learn 45:13 47:6 

learned 45:18 87:15 

100:17 

learning 67:12 91:2 

151:17 

leave 129:12 

leaves 37:17 38:2 

leaving 120:19 

left 22:18 39:17 

legislation 45:16 

legislative 49:5,18 91:6 

115:22 

legume 22:22 23:5 

length 15:11 

let's 60:6 149:18 

level 27:8 53:14 57:19 

64:1 107:6 

levels 54:14 58:13 92:1 

Lewis 2:1 4:3,9 18:1,8 

58:9 147:7 148:6 

lifeline 133:2 

lifestyle 8:7 

liken 80:17 

likening 81:6 

Lima 1:16 11:1,2 

limestone 128:7 

limitation 19:2 142:12 

limited 110:13,15 

limiting 19:4 

limits 116:18 117:15,21 

118:3,6,7 

line 8:11,13,14 9:10,12 

9:15 12:1 13:3 96:11 

131:9 149:7 155:17 

lines 5:21 27:22 

linked 106:12 129:2 

links 89:19 108:1 

Linley 2:12 125:5,17 

131:1,3,5 135:4 

Lipstreu 2:17 40:16 

43:18 47:8,9 50:6,15 

51:12 

Lisa 1:16 10:22 11:3 

list 2:4 11:6 16:10 29:17 

44:5 45:7 71:17 75:1 

85:5,17 94:3 95:15 

97:13,22 102:13 

105:1 114:1 116:21 

122:3,6,10 125:8 

136:2,7 138:9 148:20 

151:10 152:2,17 

155:21 

listed 107:13,15 155:3 

listen 8:4 

listing 97:12 119:1 

listings 152:8 

little 4:5 5:20 11:22 

27:21 31:18 39:1 

45:14 48:7 55:16 

57:15 68:14 72:6 80:1 

87:2 90:7 92:19 

106:16 126:3,4,13,16 

130:5 

live 38:20 

livelihood 8:7 31:6 

livestock 2:15 46:5,7 

46:13 64:12 74:17 

75:5,13 76:22 108:14 

109:1 110:6,7,21 

111:4 131:12,13 

133:14 141:11 

LLC 127:13 

locate 101:11,20 

102:13 

located 31:2 56:16 

logical 142:17 144:18 

long 19:15 25:16 51:9 

76:11 107:4 133:6 

140:7 154:16 155:21 

long-time 8:2 141:1 

longer 15:16 

look 5:6 67:2 80:9 82:4 

83:7 88:11 92:14 

128:22 139:6,11 

154:1 

looked 87:20 

looking 34:17 50:14 

67:18 99:17 122:21 

123:8,22 127:22 

looks 127:20 148:21 

loophole 88:5 

lose 38:13 

losing 132:17 134:19 

loss 131:15 132:2 

lost 55:6 56:1 64:18,22 

65:3,3 71:1 

lot 5:22 26:4 30:9 33:9 

39:2 41:12 53:19 

55:19 56:21 60:9,12 

79:7 94:5 97:18 

111:22 112:10 150:4 

loudest 136:17 137:4 

140:3 

love 33:4 52:12 

loves 99:11 

low 105:10,11 122:5 

lower 29:9 

lynch 68:22 

M

ma'am 12:20,21 17:7 

22:12 23:19,20 24:6 

61:15 

macro 70:2 

main 31:10,22 88:19 

maintained 52:18 

maintaining 108:21 

major 131:11 

majority 108:22 

making 8:6 89:9 129:19 

136:17 151:4 

manage 48:15 85:19 

management 56:5 57:5 

71:20,22 85:8,10 99:3 

118:11 132:12 152:18 

management's 134:16 

Manager 2:4 

managing 33:2 56:14 

mandate 44:12 

mandated 110:7,11 

manifest 49:6 

manifests 45:17 

manipulated 89:3 

manner 73:19 142:17 

154:22 

manual 18:15 

manufacture 24:1 

manufacturer 24:3 

113:20 118:8 

manufacturers 110:1,2 

111:7 112:13 115:13 

manufacturing 122:2 

marbles 84:21 

margin 32:14 34:20 

Marina 84:5 87:4 92:21 

96:19 101:5 148:13 

149:10 155:5 

marine 115:15 117:1 

135:15,19,21 138:11 

138:15 140:6 

market 29:11 37:1 

63:17 82:10 133:21 

155:7 

marketed 23:20 

marketplace 70:6 82:5 

82:6,13,14 129:19 

131:20 138:14 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
168 

markets 48:7 132:17 

mass 82:8 

material 35:17 74:2,12 

80:14,15 122:8,10,14 

122:22 123:1 128:1 

130:16 151:10 152:8 

154:17 

materials 2:3 15:2,3,12 

35:4 56:4 81:5 86:6 

88:16 90:11,14 93:6 

96:7,15 105:7 118:13 

120:22 122:7 135:15 

138:6 150:14 152:3 

153:13 154:13 

math 38:1 

mating 85:20 

MATT 2:4 

matter 34:9 42:7 157:2 

MATTHEWS 2:4 

McCann 97:3 101:6 

148:13 155:7 

McClintock 88:20 

McDaniel 2:18 12:18 

27:17 28:4,6 30:1 

McEvoy 141:9 

Meadows 2:18 

meal 115:5 

mean 19:14 69:21 74:3 

77:18 78:22 81:1,16 

89:2 90:12,20 118:10 

130:7,9 145:1 

meaning 57:7 133:16 

143:17 

meaningful 143:6 

means 145:20 150:9 

Measure 2:13 125:22 

127:13,16 

measurement 136:21 

measures 150:21 

meat 99:9,10 

meet 65:21 99:4 104:21 

104:21 122:3 137:9 

meeting 3:18 4:4,20 5:1 

5:2 7:17 11:22 12:6,7 

18:3,5 22:2 48:19 

52:8 54:20 69:4 83:22 

87:15 100:16 107:8 

111:9 127:19,20 

141:3 142:3 147:15 

148:3 

meetings 5:3 138:7 

mega 132:1 

Mellone 97:2 101:6 

155:6 

member 12:4 62:21 

100:21 140:21 

members 3:9 4:12,14 

7:8 9:4 12:3,6 27:12 

45:10 71:17 73:14 

85:5,17 116:17 118:5 

133:10 141:18 149:22 

156:1,17 

memories 151:16 

Mennonite 55:19 

mentioned 19:22 20:1 

49:20 55:4 94:15 

106:7 145:2 

merely 68:1 

met 45:11 118:7 

methionine 152:16,19 

154:11,13 

method 93:7 95:1,2,6 

109:12,16 124:8 

methods 74:22 75:4,9 

75:18 88:16 89:2 

93:13 94:4,19 95:15 

108:20 109:4,14,21 

110:12,20 112:14 

113:1 139:19 

mic 72:7 126:22 148:22 

Michael 2:20 51:15 

61:21 62:1,17,18,20 

64:18 66:11,12 67:20 

68:9 71:10 112:22 

113:7 

Michelle 2:2 3:4 4:9 

6:16,21 8:18 12:14 

27:21 36:4 40:8 62:1 

62:13 72:2 83:18 

96:21 101:10 102:8 

117:8,8 126:2 155:13 

156:8 157:1 

microbe 123:4 

microbes 128:4 

microphone 126:5 

middle 109:18 

migrate 121:16 

mile 127:8 

Miles 141:9 

milk 131:19 

million 25:12 38:9 

98:19 

mimic 87:20 

mind 21:14 31:22 55:15 

62:1 

mindful 26:1 

mine 152:20 

mined 137:10 

mineral 15:1 41:12 

minerals 137:10 

minimum 19:6 62:7 

minute 149:8 

minutes 3:10 6:17 7:7 

105:22 

misconceptions 116:6 

misled 131:17 

mitigate 57:4 

mitigation 51:2 52:14 

55:5 

mixture 28:8 

mode 151:14 

model 69:1 115:16 

moderately 105:10 

modern 94:12 

Modernization 153:12 

153:18 

modification 94:10 

modify 119:1 

moment 13:2 27:20 

95:21 

momentarily 64:22 

momentum 135:1 

money 32:10 

monitor 85:21 

monograph 118:1,4 

month 127:20 128:21 

months 48:21 

moot 77:22 

morning 4:10 

Mortensen 1:17 11:21 

96:3,4,5,13 

motor 39:12 

MOUs 45:18,20 

mouthful 84:21 

move 27:13 34:9 36:22 

61:21 63:13,17 65:17 

71:7 88:7,15 91:5 

101:2,15 120:6 125:4 

130:15 131:1 

moved 63:14 

moving 61:15 67:13 

89:5 110:15 

mulch 74:13 80:11 82:4 

multi-regional 100:6 

multi-stakeholder

100:7 

mutagenesis 93:12 

95:3,5 

mute 3:11,16 6:1,4,5 

12:16 28:1 40:10 

96:12 101:9 106:3 

111:14 117:7,13 

140:13 148:18 

muted 9:15 77:3,5 

95:21 

muzak 13:10 

N

name 13:19 28:6 30:14 

30:21 36:5,13 40:17 

40:18 43:19,20 47:6,7 

47:8 51:16 62:18 

71:12 73:2 84:6 87:5 

93:1,3 96:22 97:3 

101:8,17 102:2,7 

103:4,5 108:11,13 

113:13,18 120:9,10 

125:6,18,21 127:10 

127:11 131:3 135:6 

140:17 148:16 149:8 

149:19,22 

name's 73:8 

names 85:12 

narrow 34:20 

narrowing 78:19 

Nathan 127:17 128:20 

national 1:3,9 2:1,4,12 

3:4 4:12 5:3,11 7:21 

8:3 16:10 36:4 43:22 

75:1 97:13,22 105:1 

114:1 116:21 122:3,6 

136:2,7 138:9 151:10 

natural 88:20 89:3,10 

95:8 104:8,15 115:15 

130:13 152:19 154:13 

naturally 94:16 107:18 

115:4 

nature 37:11 128:3 

nauseated 21:4 

NC 33:17 

near 48:10 56:12 

126:21 

necessarily 77:21 81:1 

82:21 123:17 

necessary 60:4 91:6 

152:13 

necessity 76:22 79:3 

need 24:13,20 25:3 

32:1,3 34:20 43:10 

46:18 48:9,9 50:20 

63:6,21 65:11,13 

68:19 69:15 80:13 

81:10 91:5 92:14 

97:19 98:10 99:5 

100:8,22 106:21 

118:5 122:13,14 

143:7 

needed 41:10 44:2 

45:16 49:6 75:8,12,14 

90:17 98:12 122:7 

150:8 

needs 19:5 80:11 97:19 

122:14 154:22 

neighbor 152:20 

Neither 136:1 

never 77:18,21 78:3 

138:16 

new 12:4 26:20 37:22 

63:12 65:19 93:17 

94:1 95:13 96:17 

102:3 103:21 141:17 

155:8 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
169 

newly 44:18 

news 92:11,12 

niches 139:6 

Nick 26:14 

Nicole 2:10 62:17 71:11 

73:1,2,5,8 77:7,9 

83:16 

nicotine 20:11 

nine 141:9 

nitrate 99:21 

nitrogen 23:2 25:5,18 

26:5 

nitrogen's 25:11 

Nobel 88:20 

NOC 6:9 45:10 46:20,22 

142:1 

NOC's 45:6 

NOFA 73:11 

NOFO 98:19 

noise 3:12 6:1 7:6 13:3 

27:22 62:7 156:16 

non- 92:1 114:1 

non-chlorine 153:22 

non-organic 78:6 91:21 

151:20,22 152:1,3 

non-target 121:17 

non-toxic 121:15 

nonprofit 71:15 85:3 

97:9 

NOP 3:9 4:3,21 16:21 

18:4 27:21 29:17 40:8 

44:1,5,11 46:6,19 

47:1,21 48:19 49:15 

49:18 52:19 54:1,16 

65:12 66:14,18 67:2 

87:16,16 124:11 

126:3 131:11,21 

132:10 137:12 141:3 

141:7,12 142:21 

143:2 145:18 147:11 

NOP's 143:14 

North 13:20 28:7 31:2 

36:15 39:8 40:19 

41:20 

NOSB 3:18 4:11,14 5:7 

5:9 7:17 9:9,14,19 

12:3,6 13:18 16:7,9 

27:11 52:20 53:2 

62:20 63:11 66:9,19 

67:2 73:14,18 74:1,10 

83:13 93:18,22 95:13 

103:14,18 108:16 

109:5 110:4,11 111:5 

111:9 117:5 121:21 

124:10 132:10 133:10 

134:8 141:12 143:14 

149:22 150:6,7 151:2 

151:12 

NOSB's 4:19 94:11 

103:11 

note 8:22 94:14 95:5 

96:21 

noted 24:5 60:20 94:20 

95:15 

NSOB 44:1,4 52:8 

nucleic 89:1,4 93:11 

94:17 95:7 

number 15:18 47:14 

48:22 96:22 102:8 

125:10 137:11 151:13 

numbers 12:15 102:10 

numerous 129:17 

nutrient 99:22 123:5 

129:3 132:12 

nutrients 35:7 130:13 

nutritional 2:16 113:19 

114:5,10 115:9 

131:18 

O

Oakley 1:18 11:9,10,12 

18:11,14 19:17 30:12 

42:20,20 58:3,6,18 

138:2,5 140:10 146:8 

146:12 147:18 

observable 105:17 

observing 140:7 

obsolete 133:11 

obviously 13:16 14:17 

58:12 

occur 94:15 105:17 

139:5,11 

occurring 107:18 

October 4:20 87:15 

OEFAA 53:2 

OEFFA 47:11,20,22 

53:8 54:1 59:14 

OEFFA's 57:2 

OFA 141:18 142:3 

offer 4:18 52:1 74:8 

offered 28:19 109:19 

119:3 

official 7:16 

officially 4:4 

offset 39:12 

OFPA 90:8 141:3 151:2 

OFPA's 63:22 

Ohana 2:7 150:1 

Ohio 2:6,17 47:10 51:18 

55:18 

oil 15:1 41:12 104:9,10 

104:12,12 113:21 

114:1,4,7,11 115:4,7 

115:9,11,13,18 116:8 

116:10,14,21 117:18 

117:21,22 119:9 

121:13 

oils 71:18,18,20 85:6,6 

85:8,14,16 

old 40:20 

omega-3 113:20 114:12 

114:15 116:22 

on-hand 40:3 

once 14:11 19:6 77:22 

82:15 83:9 89:3 

130:19 

onerous 19:8 

ones 86:17 113:3 119:6 

ongoing 63:21 

open 4:4 5:22 

opening 139:21 

operate 5:4 30:22 

operates 31:1 

operation 28:13 31:10 

32:15 39:7,10 

operations 45:1 50:10 

70:3,11,18 75:7,11 

109:1,9 133:8 142:2 

operators 63:15 64:2 

opinion 33:11 41:20 

150:10 152:16 

opportunities 139:6 

opportunity 4:17 17:12 

17:16 38:14 48:2 50:1 

51:22 73:15 108:16 

117:5 122:15 125:21 

139:12 

opposed 61:3 

option 18:15 28:22 

109:11,18 112:2,7,9 

112:17,18 

options 109:4,17 110:6 

110:11 119:4,5 

137:19 152:13 

order 6:8 14:8 25:6 

26:10 69:8 111:2 

ordinates 122:11 

Oregon 121:4 

OREI 98:5,20,21 100:10 

organically 13:22 114:2 

organics 2:18 4:13 

154:7 

organism's 95:8 

organisms 121:17 

organization 71:15 

85:3 116:17 127:13 

organizational 48:1 

origin 46:7 131:13 

141:11 

orthophthalates 90:16 

92:1,4,8,10,13 

OSP 71:18 85:6 

OSPs 85:18 

ought 53:16,22 

out-of-state 110:14 

outcomes 14:18 52:6 

outdoor 131:21 132:9 

outdoors 46:17 

outlier 143:1 

overall 27:2 67:2 

114:17 

overarching 136:5 

overhead 33:7 

overnight 146:4 

overreact 137:4 

oversees 66:17 

oversight 49:14 140:8 

owned 73:10 

owner 127:18 

oxygen 120:19 

P

P-R-O-C-E-E-D-I-N-G-S

3:1 

p.m 1:10 3:2 157:3 

pace 100:8 

packaging 90:18 

packed 153:5 

page 27:6 104:18 

paid 42:2 

palm 104:9,10,12,12 

panel 52:7 

paper 73:18 74:2,4,5,7 

74:9,12 79:20,21 80:4 

80:8,8,9,10,11,11 

82:19,20,21 83:6,11 

121:18 122:1,2 124:3 

124:3,15 

papers 137:19 

parcels 14:1 

parent 106:8 

parlor 57:6 

part 4:19 7:16 15:13 

30:3 36:16 74:3 95:8 

117:20 124:14 

participated 91:18 

141:2 155:17 156:15 

participation 4:15 

particular 55:15 69:20 

88:12 91:20 121:19 

133:18 

particularly 46:1,4,15 

56:13 65:7 88:7 

104:16 

partner 120:12 

partners 98:10 

parts 75:13 134:15 

pass 141:17 

passing 68:1 141:12 

pasture 46:12 131:19 

132:2 133:5 141:6 

pasture-based 132:4 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
170 

path 144:14,18 154:21 

patience 48:7 

patient 27:14 

PATTILLO 2:3 16:18,21 

Paul 2:1 4:3,8 5:19 

17:21 58:10 146:13 

147:4 

pause 64:19 

PAVONE 2:4 

pay 38:16 60:16 

paying 60:15,22 61:7 

pays 37:7 

peer 63:21 65:12,13 

66:13,20 67:10,19 

people 3:13 6:16 8:22 

13:9 26:17,19 30:13 

33:5 37:2,3 71:16 

72:3 78:20 79:10 85:3 

92:19 102:16 117:9 

139:5 143:16 145:10 

145:11,12 155:3,11 

156:2 

pepper 121:13 133:8 

peppers 31:21 32:21 

33:1 

percent 41:21 81:22,22 

82:1,7,11 128:14,16 

perfect 9:5 77:2 80:14 

80:15 109:20 

performance 103:17 

period 4:7 19:7,15 

80:20 142:16 144:8 

145:19 146:18 

periods 20:16 

Perls 2:18 84:5 87:4 

92:20 93:2,3 

permit 151:22 

permitted 151:21 152:3 

152:17 

peroxide 120:16 121:1 

154:2 

perpetuity 151:14 

person 6:3,12 12:17 

107:8 156:5 

personal 55:9 57:19 

153:22 

personally 33:4 

perspective 60:7 80:12 

pertain 14:6 

pest 85:9 

pesticide 142:13 

145:21 

pesticides 142:8,17 

146:5 

pests 14:16 32:5 

petition 63:8 69:5 

103:12 

petitioner 103:9 

petitions 152:6 

Peyton 2:18 12:18 

27:17,19 28:2,6 29:21 

31:7 

pharmaceutical 128:7 

phase-in 136:13 

phased 92:11 

Pheromone 86:1 

pheromones 85:18,18 

85:20 86:12 

phone 5:21 6:4 7:3 9:1 

10:9,10 12:14 36:7 

52:1 72:9 84:16 96:22 

102:8,9,13 125:9,10 

126:8 149:18 

phones 101:12 

phonetic 133:2 

phthalates 90:6 92:9 

pick 83:13 

pickling 31:19 

pilot 98:14 

pin 68:22 

pipeline 50:11 51:5 

55:21 56:3,9,12,16,19 

56:21,22 

pipeline's 56:4 

place 116:1 118:3,12 

140:2 155:19 

placed 61:5 78:14 

places 67:7 140:7 

plan 51:2 55:5 

planning 52:14 98:6 

99:2 154:15 

plant 14:18 37:11,15,17 

38:3,4 39:16 41:7 

71:19,21 85:7 104:2 

120:17,22 128:3 

130:16,21 

planting 42:5 59:11 

80:11 121:19 122:3 

124:3,15 152:1 

plants 38:4 75:22 

107:19 128:18 130:14 

plastic 92:5 

plasticizers 92:14 

plastics 80:7 90:18 

plateaued 27:7 

plateauing 27:8 

play 74:18 108:20 

players 117:22 

playing 64:1 66:2 67:17 

70:10 140:2 

please 3:10 4:21 7:6 

13:11 28:1 40:9,17 

43:20 47:5 51:15 

62:18 71:12 73:2 84:6 

87:5 92:22 96:12 97:3 

101:7,16 102:7 103:3 

108:11 113:13 120:8 

125:5,18 131:3 135:6 

140:17 147:4 148:15 

152:1,4,6 

pliable 90:19 

plus 99:19 114:22 

point 30:13 77:22 79:5 

106:6 144:22 

pointed 141:18 

points 111:22 

policy 2:4,12,14,17 

43:21 47:9 77:21 78:4 

87:7 

politics 48:8 

pollution 99:22 

pool 2:19 51:15 62:17 

71:8,13,13 72:8,11,15 

72:19,21 78:20 84:15 

84:18,22 85:1 86:15 

86:22 

population 85:22 

populations 85:19 

pork 75:7,11 

Porterville 96:19 

portion 33:12 128:10 

156:12 

ports 45:13,15 46:2 

49:4,10 

position 12:4 17:18 

137:19 145:18 

positions 137:14 

142:21 

positive 52:5 61:14 

possession 48:12,14 

possibility 109:14 

possible 34:22 45:5 

55:10 60:8 63:15 

65:18 117:16 126:4 

possibly 41:19,20 

69:14 

potatoes 13:21 22:18 

22:20 23:7 28:9 31:16 

potential 52:5,7 70:11 

99:3,19 111:7 112:10 

116:13 

potentially 83:8,11 

112:9,16 119:1 

pots 74:13 82:19 124:3 

124:15 

poultry 46:17 75:7,11 

131:22 132:2,4 133:5 

powder 97:12 98:3 

100:3 

power 141:17,19 

practical 74:11 121:12 

practice 79:13 109:2 

132:12 

practices 46:14 56:8 

71:22 85:10 115:22 

140:6 152:18,22 

pre-certified 132:15 

pre-registered 6:8 

precautionary 150:21 

151:7 

preference 119:4 136:6 

138:8 139:4 

preferring 78:21 

prefers 54:1 

preliminary 98:18 

premium 60:17 

preparation 53:7 

prepared 20:22 

preparing 5:7 137:19 

presence 116:9 

present 1:12 2:5 9:6,20 

10:5,18,21 11:10,14 

11:16 25:11,18 85:21 

111:8 

presented 112:7 137:2 

preserve 95:11 143:6 

President 16:22 127:12 

155:9 

presiding 1:10 

press 6:5 

pressing 47:15 98:13 

pressure 62:9 139:10 

143:8 

pretty 57:4 100:3 113:2 

preventative 109:1 

preventing 74:19 

prevention 129:4 

previous 6:12 17:9 34:7 

43:6 93:8 

previously 30:8 49:20 

119:9 

prices 41:22 42:1 

primarily 26:20 103:11 

108:2 

primary 31:10 137:18 

principle 133:1 136:7 

151:8 

principles 134:13 136:5 

printed 53:17 

prior 142:4 

prioritize 49:13 

prioritized 44:7 45:7 

49:2 

priority 98:2 

private 48:15 

Prize 88:21 

proactive 63:16 

probably 39:11 42:8 

82:4 

problem 34:11,14,16 

35:12 

problems 45:4 46:4 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
171 

63:16 68:15 90:13 

106:14 136:13 152:22 

procedures 45:19,21 

115:22 118:12 

proceed 22:19 

process 24:1 25:5 

29:13 45:5 48:5 58:11 

58:15 76:13,15 104:7 

112:12 116:5 120:20 

processed 24:1 114:2 

processing 64:4 129:10 

processors 97:18 

139:11 

produce 14:20 29:9,12 

31:18 134:5 

produced 74:22 75:4,8 

93:11 103:13 108:19 

109:15 110:12 114:2 

151:20 

producer 23:5 76:15 

77:13 78:1 116:22 

147:21 150:6 

producers 48:7 50:18 

51:5 52:14 55:19 

73:12,21 74:17 75:3,6 

75:13,17 76:22 79:4 

79:12 109:7,17 110:6 

110:13,21 111:6 

133:4 138:13 

produces 37:18 

producing 29:7 

product 2:7,8 23:17,21 

24:4 40:1 48:14 73:21 

83:6 89:10,11 103:6 

104:6 129:3,13,14,16 

129:18 130:6 133:17 

133:21 138:14 

production 15:16 16:3 

24:21 28:14 41:19 

50:22 56:8 64:4,13,16 

65:5,8 69:18 82:20 

86:2 98:16 99:21 

104:1,22 105:1 

109:15 110:20 114:8 

115:8,11 116:11 

120:17 130:7,10,12 

132:3,19 133:15 

134:7,9,13 139:19 

144:5 

productions 41:15 

productive 33:14 54:20 

products 2:16 28:19 

29:11 45:20,22 48:12 

65:21 73:18 79:20 

80:4,8,8,9 82:7,12,22 

86:5 91:19,20,22 92:5 

103:7 104:2 106:10 

106:14 110:3 113:20 

113:21 114:3,6,14 

115:3 118:15 120:21 

121:1 128:8,15 130:9 

professional 137:12,17 

profile 99:10 

profit 32:14 42:3 

profitability 115:17 

profitable 99:16 

profits 61:8 

program 2:1 3:5 5:11 

7:21 36:5 58:7 97:8 

118:11 134:21 143:7 

146:13 

prohibit 74:21 133:12 

prohibited 80:18 81:2 

133:19 142:8,13 

145:21 146:5 

prohibitive 121:12 

134:4,6 146:16 

project 2:9,12 36:1 

98:14 100:2,9 131:6,7 

133:11 140:20 

projection 15:20 

promises 141:7 

promising 63:22 98:11 

141:8 

promoting 8:7 

pronounce 47:6 

proper 25:3 115:21 

properly 141:6 

proposal 53:4,9 54:19 

98:20,21 135:20 

propose 48:11 

proposed 52:15 75:16 

89:7 109:3 119:6 

proposing 101:2 

protect 50:20 104:3 

116:1 121:11 

protected 72:1 85:11 

protecting 55:5 117:1 

143:17 

protection 45:12 49:5 

49:21 92:3 

protective 20:13 

proud 15:22 140:22 

prove 110:1 

proved 15:4 

proven 114:16 116:14 

151:5 

provide 47:16 51:8 

57:10 59:17 93:6 

117:5 119:18 122:7 

provided 46:21 47:22 

53:15 104:19 

provides 4:17 114:11 

providing 46:16 49:14 

60:20 61:1,2 133:3 

provisions 5:4 

public 4:12,13,18,19 

5:7 7:22 52:1 54:3 

104:3 106:7 107:3 

155:12,22 

publish 65:11 

published 103:19 

107:21 136:20 

pull 153:22 

Pulling 28:21 

pumpkins 37:1 

purchase 17:22 110:14 

purchased 30:8 

purchasers 117:18 

purchasing 53:16 

pure 60:16,21 81:12 

purity 117:16 118:7 

pursue 49:18 

push 69:7 82:14 

put 3:10,15 7:10 13:9 

13:11 25:12 40:10 

84:3 86:14 87:2 88:2 

96:12 118:3 119:21 

127:14 130:19 145:4 

150:17 

putting 117:13 

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qualification 116:4 

qualify 80:21 

qualifying 142:10 

quality 14:8 15:9 28:16 

32:12 35:8 76:1 116:2 

118:11,12 

quantity 14:21 19:3 

27:3 76:1 

question 7:8,10,12 

18:12 19:22 21:20 

22:1 24:10,15,18 25:1 

26:14 29:20,21 34:4 

35:2,3 50:4 55:4 58:4 

58:7,20 66:12 68:7 

69:17,22 71:7 79:17 

83:19,21 86:10 90:5 

91:12 106:4 107:9 

111:19 117:14,20 

118:20,22 122:19 

124:19 130:2 138:3 

138:12 139:2 143:22 

146:9,12 147:16 

151:4 153:5,7,15 

questions 7:12 16:17 

18:10 19:19 22:5 24:8 

27:11,12,15 30:11 

34:2 38:19 39:21 

42:18 43:6 47:4 50:4 

53:4 55:1 58:19 66:11 

68:10 76:8 77:8 79:15 

80:5 83:16 86:9 90:2 

91:8,10,12 96:2 98:12 

100:12 106:1 108:6 

111:11,16 113:9 

116:16 117:14 118:18 

118:21 120:6 122:19 

129:21 130:22 135:3 

137:21,22 140:15 

143:18,19 148:9 

154:9 

quick 19:21 106:3 

124:19 

quickly 26:6,6 65:18 

68:12,16 87:13 

quite 6:2 38:21 153:16 

155:20 

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raise 7:9 49:12 

raised 83:18 112:1 

126:10 151:5 

raises 150:19 152:21 

raising 131:12 

ran 25:14 

range 88:8 

ranked 98:22 

rapidly 120:18 

rationale 103:19 

Ray 2:13 120:8 125:4 

125:12,15,16,17,18 

125:22 126:2,18 

127:11 

re-listing 114:4 

re-movement 54:19 

reach 105:22 

reached 7:7 89:14 

reactions 105:6 

read 9:3 

readily 105:17 121:16 

154:4 

reading 138:6 

reads 150:19 

ready 13:14 28:3 

real 2:9,12 25:3 131:6,7 

131:19,21 132:9 

133:11 140:20 143:11 

145:2 

reap 41:11 

reapplied 121:14 

reapplying 142:15 

reason 7:11 8:10 12:15 

31:11 32:1 36:20 

37:19 92:6 

reasonable 122:12 

reasons 26:3 

receive 7:22 54:2 

received 76:12 

receiving 77:16 78:2 

recipe 70:20 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
172 

recognition 46:18 

recognize 115:1 

recognized 116:15 

recommend 49:3,18 

66:18 112:2 

recommendation 60:13 

67:9 133:13 136:18 

recommendations 5:8 

54:16 63:14 

recommended 60:5 

recommending 138:20 

recommends 113:22 

116:20 

record 7:17 36:6 61:10 

145:16 157:3 

recorded 7:15 

recycled 74:5 

reduce 32:2 82:10 

reduced 15:19 

reducing 114:19 

reduction 143:15 

reductions 14:15 

refining 116:11 

reforming 144:16 

refuse 129:10 134:17 

regard 46:16 69:18 

regarding 52:16 53:5 

53:22 108:19 116:7 

regardless 64:3 147:2 

147:22 

regards 119:9 

region 39:5 148:1 

registration 2:7 103:6 

regular 67:5 

regulation 67:5 70:13 

regulations 44:12 

64:10 65:19 74:21 

90:8 116:19 137:6 

141:17 153:12 

regulator 103:15 

regulatory 51:4 117:20 

118:3 

reinstate 46:13 

reject 152:6 

rejection 103:12 

related 151:17 

relationships 150:22 

relatively 15:17 

relevant 107:2 

reliable 114:11 

relied 39:6 

relief 17:18 

relisted 152:12 

relisting 113:22 116:21 

120:15 121:6 

rely 110:21 115:19 

remain 32:7 63:16 64:5 

114:22 

remainder 3:20 

remaining 28:10 

remains 48:4 

remark 76:6 

remember 150:16 

153:16 

reminder 3:7 6:7 13:9 

30:13 62:10 

reminding 92:18 

removal 18:15,20 19:5 

remove 14:9 15:10 32:3 

removed 14:11 

removing 21:8 122:9 

rent 33:8,11 42:2 

repeat 64:22 

repellent 121:7 

repellents 121:13 

repercussions 145:13 

replace 33:22 

replacing 92:13 100:2 

report 57:15 74:4 

104:18 105:2,5,13 

115:7 

reported 145:6 

Reporter 20:5 21:9,11 

21:11,13,14,18,21 

represent 113:19 

representing 135:11 

143:16 

represents 68:1 

reproduce 37:12 

reproductive 106:12 

request 16:5,9 48:5 

58:8,10 74:1 152:10 

requesting 47:12 74:3 

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129:17 

require 25:9 45:16 

46:14 58:13 131:21 

135:20 144:12 

required 142:2 

requirement 46:8 

requirements 110:17 

110:18 133:13 

requires 25:20 26:7 

46:1 110:9 

requiring 48:11 80:14 

136:2,10 

research 82:13 87:19 

97:10 98:5,12 100:19 

100:22 128:19 145:14 

153:17 

researchers 97:18 

residue 120:19 129:12 

residues 81:1 

resign 12:4 

resilient 123:10 130:19 

resist 130:18 

resolve 83:8 

resource 100:2 

resources 46:19 47:16 

49:10 50:18 113:3 

115:15 

respect 103:21 153:10 

responding 118:20 

response 5:8 103:11,20 

responses 119:3 

responsibility 116:3 

141:19 

responsible 115:14 

137:3 

rest 129:6 156:6 

restate 24:14 

restore 132:21 

restriction 142:8 

restrictive 118:2 

resubmitting 99:1 

result 119:11 131:10,14 

134:8 

resulted 132:3 

resulting 50:8 131:22 

retransition 56:2 

retransitioning 56:12 

revenue 31:13 

review 16:7 29:16 49:11 

58:11,13,15 63:21 

65:12,13 66:13,20 

67:19 74:3 90:6,9 

104:20 109:5 111:10 

112:22 121:18 

reviewed 40:2 152:10 

reviewing 74:11 75:2 

reviews 67:11 74:1 

109:7 139:18 

Rice 1:13 9:14,20 10:2 

10:5 

Rick 1:16 11:3,4 

rid 35:11 

rides 37:2 

rigorous 116:4 

ring 7:1 

rinse 129:15 

ripen 25:6 26:6 

risk 20:4 29:1 76:16 

114:19 139:14 

risks 116:7,12 121:20 

152:6 

Roland 2:7 101:16 

102:5,17,21,22 103:1 

103:6 

role 74:18 108:21 

143:16 

roll 9:3 12:11 

rolling 55:18 

ROMERO-BRIONES

1:19 11:14 

room 72:11,12 137:5 

140:3 

roots 35:8 150:16 

ROP 131:10 132:21 

134:21 

rotation 22:11,14,15,19 

23:9 24:13,18 25:14 

25:19 32:16 69:1 

70:14 99:7 

rotational 42:6 

route 112:19 

routine 118:14 

routinely 20:20 

rule 46:7,14 48:11 

50:13 131:13 141:6 

141:11 

rulemaking 48:5,9 

rules 131:16 141:20 

run 4:4,5 127:7,17 

129:20 149:6 

running 80:2 

rye 23:12 

S

safe 111:2 116:15 

152:14 

Safety 2:14 87:8 91:14 

113:8 153:11,18 

sale 44:21 49:18 

sample 53:19 60:11,12 

61:10 

Sampson 31:3 

sanitizer 120:22 

sanitizers 152:11 

153:11 

saying 37:20 117:4 

124:19 141:13 145:17 

149:18 

says 107:22 

scaffolding 98:9 

scale 26:21 64:11 73:21 

75:7 98:4,16 150:6 

scary 140:1 

scenes 5:12 

schedule's 3:20 

scheduled 4:20 

Science 97:7 

scientifically 151:1,6 

Scott 1:13 9:14,15,16 

9:18,21 

Scott's 9:19 

scrutiny 137:10 

seal 132:2,22 

season 22:6 63:10 

134:22 

seasons 55:22 

Seattle 4:21 12:6 54:20 

100:17 127:19 156:5 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
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seaweed 135:16,18 

second 7:2 8:22 69:17 

77:3 111:13 136:22 

Secondly 47:20 63:11 

64:13 74:15 

Secretary 1:13 9:19 

88:1 

Section 105:1 

sector 46:10 120:13 

sectors 46:5 

seed 39:15 53:13,13,17 

54:11 58:21 59:2,4,10 

60:10,21 74:14 

seeds 37:12 53:5 75:22 

151:22 

seeing 70:1 

seek 44:1 46:22 150:8 

seen 16:2 106:9 

Seitz 1:20 11:15,16 

select 137:2 

self-mute 13:4 

self-muted 62:11 

sell 23:22 48:13 59:4 

selling 26:16 

sells 23:16 

semen 78:6,8 

semester's 53:7 

send 96:21 120:1 

senior 2:15,18,19 71:14 

85:1 93:3 108:14 

120:11 

sense 48:4 82:18 107:2 

119:8 

sent 33:17 

serious 106:10 145:14 

150:4 

seriously 90:14 

serve 13:17 103:7 

service 51:22 54:21 

61:1 68:4 120:13 

150:4 

serving 4:16 

set 48:19 

sets 116:1 

settings 107:6 

setup 72:12 

seven 30:2 

severely 19:3 132:8 

shade 2:21 92:22 97:1 

97:5,7 129:11 

shape 17:9 

share 31:5 55:13 110:3 

147:17 

shared 155:1 

sharing 76:20 

ship 49:6 

shipments 49:8 

short 36:10 45:3 48:6 

show 4:6 67:15 121:1 

shown 139:3 

shrunk 139:7 

sick 41:6 

sickness 20:7,19 29:2 

signed 102:16 155:11 

significant 44:15 81:10 

91:3 134:22 

silver 89:22 152:6 

similar 75:22 

similarly 95:3 

simple 100:3 154:6 

simpler 109:13 

simplest 103:22 

simplistic 154:7 

simply 19:12 111:5 

133:17 

sincere 150:10 152:10 

sir 10:20 43:11,14 

107:16 

sit 144:6 

sitting 146:21 

situation 20:9 82:3 

112:6 

situations 122:9 138:18 

size 64:3 147:22 

skipped 149:6 

Sligh 2:20 51:15 62:17 

62:20,20 64:20 65:2 

66:21 67:22 68:17 

70:2,22 71:4,9 

slightly 130:8 

slow 100:4 

small 13:22 14:21 23:10 

23:11,13 31:13 42:3,4 

73:21 75:7 91:2 98:4 

127:16 150:5 

smaller 39:6 

snorkeling 149:4 

soaps 121:7,15 

social 116:2 137:7 

soil 16:1 25:17 42:7 

70:15 123:1,3,9,17,19 

128:4 132:20 133:14 

134:12 

sold 24:5 27:1 

solution 100:5 109:20 

135:17 

solutions 45:4 109:13 

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somebody 96:11 

somewhat 18:7 

son 127:17 

soon 63:15 

sooner 35:10 

sorry 7:1 21:13 24:16 

26:11 36:3 61:22 65:3 

77:4 83:1 84:9 95:20 

111:14 126:3,17 

149:11 

sort 22:17 23:8 25:14 

26:12 35:22 54:5 79:5 

81:3 86:14 112:18 

sought 114:15 

sound 84:16 126:13 

sounded 58:22 

source 104:8 114:11 

sourced 115:4 119:10 

sources 104:15 136:2 

136:11 

south 55:17 

southern 38:21 

soy 15:1 41:3 134:2 

soybean 42:1 

soybeans 28:9 31:17 

41:12 42:5 134:1 

space 110:9 

spans 114:22 

speak 6:12 30:15 40:21 

42:14 53:1 108:16 

148:20 155:4 

speaker 7:13 20:5 72:9 

93:8 126:8 

speakers 21:14 34:7 

43:7 126:22 

speaking 3:8,10 35:21 

40:9 65:5 101:9 

140:19 148:18 

special 54:14 

specialist 2:2,3,7,16,20 

71:14 85:2 103:7 

108:15 

species 86:3 115:12 

138:12,15,17 

specific 49:3 55:8,12 

59:20 70:4,9 82:21 

86:3 110:16 118:21 

124:8 150:13 

specifically 45:22 

69:22 75:1 93:6 105:2 

117:21 128:3 138:12 

specifications 99:5 

118:15 

specificity 76:1 

spend 60:3 

spillover 138:10 

spinach 99:14 

spirit 52:19 

spoke 59:13 

spoken 36:10 79:11 

spot 8:16 

spray 22:6 37:20 85:13 

85:14 129:15 

sprayable 86:13 

sprayed 86:19 145:4 

spraying 142:13 

Spread 150:18 

spring 7:17 34:13 36:22 

150:18 

Springs 13:20 

squash 28:10 

squeeze 133:9 

stable 111:2 

stack 53:19 

staff 2:1 3:9 44:21 

45:11 49:10 57:3 

87:15 137:17 

stakeholders 65:16 

111:8 

standard 29:15 64:3 

69:19 121:22 123:16 

124:1 131:12 144:11 

standards 1:3,9 2:1,3,4 

4:3,13 5:3,11 8:4 

46:12,15 64:10,14 

65:6,10,22 69:19 70:5 

70:10,19 93:19 95:10 

114:9 123:7,20 131:8 

132:12,20 133:1 

134:9 144:17 

standing 133:13 

Star 6:5,6 

start 5:22 8:19 9:2 

12:13 13:7 20:15 

32:20 36:8,21 45:6 

62:3 68:10 73:13 

79:19 82:9,14 150:12 

started 3:5 36:8,18 41:4 

54:8 

starting 22:14 78:13 

83:6 

state 30:14 33:18 36:5 

40:17 43:20 47:5 

51:16 62:18 71:12 

73:2 84:6 87:5 92:22 

97:3 101:8,16 103:3 

108:11 110:7,11,15 

110:18 113:13 120:8 

121:4 125:6,18 

127:10 131:3 135:6 

140:17 148:15 149:19 

state-mandated 110:17 

stated 30:21 105:5 

145:18 

statement 103:18,20,20 

150:18,18 

statements 76:4,5 

115:6 

states 1:1 110:16 129:6 

Station 121:5 

stay 16:15 32:18 50:21 

59:18 62:9 132:16 

150:9 

stealing 62:2 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
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Steve 1:13 9:10,13 34:3 

35:1,19 39:20 40:16 

43:3,18,21 47:3,4,5 

68:6 69:12 79:16 

83:20 86:11 130:1,3,4 

143:21 144:9 153:6,9 

STEVEN 2:12 

stock 74:14 111:1 

116:1 

stomach 99:12 

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stores 130:20 

straightforward 119:12 

strange 144:20 

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strategy 143:5 

strawberries 36:21 

strength 130:20 

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strong 65:21 99:14 

140:4 

stronger 130:17 

strongly 53:12 63:11 

65:13,16 66:9 93:9 

95:12 113:22 116:20 

135:15 

struggle 106:5 

struggled 111:22 

struggling 132:16 

strung 69:13 

student 155:6 

studies 57:15 128:19 

study 91:1 137:13 

stuff 76:1 

subcommittee 75:16 

88:17 93:7,10 

subcommittee's 74:16 

subcontract 54:2 

subject 13:10 61:18 

submitted 67:14 94:21 

substance 81:3 133:18 

146:16 

substances 16:11 

29:18 88:6 133:20 

134:4,7 151:6 152:17 

substitute 97:14 

substrate 142:9,14 

145:22 

substrates 134:5 

success 5:13 63:1 

129:8 

successful 49:15 

successfully 51:4 

suck 35:7 

sucker 14:13,15 15:1,4 

20:17 25:19 26:4,4 

32:11 

suckering 63:7 

suckers 14:7,10 21:8 

25:22 26:9 28:15,21 

32:3,4,7 35:4,11 

37:16,19,22 38:2,3,5 

38:10,14 

suckling 32:18 

Sue 1:14 10:6,7 

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suffered 59:8 

sufficient 121:11 

suggest 75:20 105:14 

112:17 115:10 135:17 

136:22 

suggested 53:18 

119:19 

suggestion 112:1 

124:10 138:19 

summarize 54:3 

summarizing 63:3 

summary 154:8 

summer 15:13 23:5 

37:1 85:14 

sunscald 129:4 

sunset 151:11,14 

152:17 

super 78:21 

suppliers 53:18 59:4 

76:5 87:19 

supply 40:4 43:8 44:9 

103:8 130:20 

support 32:1 37:5 

49:15 52:20 54:12 

63:4,11 75:15 89:6 

95:9 97:11 104:11 

106:18 110:19 114:16 

119:22 120:15 121:6 

121:18 122:5 135:22 

136:19 

supported 110:11 

supporting 114:21 

supportive 54:16 58:22 

suppose 102:15 124:7 

Supreme 85:13 

surprised 87:14 

surrendered 45:1 

survey 91:14 

susceptibility 105:15 

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sustain 42:1,12 

sustainability 116:3 

117:2 136:21 139:19 

sustainable 94:3 

103:16,22 104:10,13 

115:15 135:16 137:8 

sustaining 28:16 

sustains 33:6 

Swaffar 1:21 11:18,19 

111:18,21 112:20 

sweat 20:10 

sweet 13:21 22:18,20 

23:7 28:8 31:16 

synchronize 76:12,18 

synchronizing 78:2 

synthetic 74:6 80:3,7 

81:8,21 82:8,8,15 

83:11 95:13 103:15 

151:18 152:16 

system 14:18 63:20 

64:4,10 67:3 70:17 

99:7 103:16 111:3 

124:12 

systems 64:12,14,16 

65:6,8 74:13 105:8 

114:17 151:7,21 

T

tackle 137:6 

tag 53:17 

taken 37:22 45:8 69:3 

81:4 128:6 150:22 

151:10 

takes 26:5 28:22 32:13 

38:11 48:17 

talk 9:18 68:13 156:17 

talked 33:16 37:9 79:20 

talking 9:22 18:2,4 28:1 

36:14 61:13 62:11 

68:11 96:12 108:1 

147:13,14 154:12 

Tannersville 102:3 

155:7 

tap 92:21 104:18 

target 49:3 86:3 

targeting 49:9 

tariff 48:18 

task 54:7 100:3 140:21 

154:11 

team 100:7 

technical 74:4 105:2,5 

115:7 

techniques 63:12 89:4 

93:11,17 94:2,4,8,13 

94:17 95:7,14,16,18 

104:2 116:11 

technology 2:18 76:21 

93:4 

teenager 151:15 

teenagers 106:9 

teleconference 5:13 

tell 43:19 71:1 129:1 

temporary 16:6 29:14 

34:21 

ten 28:12 

tent 90:16 

term 45:3 48:6,10 51:10 

terminology 93:13 

terms 19:2 25:3 56:8 

58:16 60:2,3 68:14 

70:6 104:1 106:17,17 

118:6 119:16 138:10 

138:18 140:8 147:11 

tested 84:18 91:19 

112:18 117:17 

testimony 45:7 

testing 53:13 59:5 61:2 

78:12 98:15,16 

118:14 123:17,18 

124:8,14 

thanking 42:21 73:13 

96:14 

thanks 10:6 27:9 30:16 

40:10,14 47:11 58:18 

62:12 69:16,16 72:7 

83:14 84:1 93:2 96:12 

101:3 107:8 146:6 

147:7 148:6,16 

150:10 

things 33:3 80:2 95:4 

99:22 101:3 

third 72:17 109:18 

112:7 

thirdly 63:18 65:11 

thorough 104:19 

thoroughly 40:2 

Thorvin 135:11 

thought 4:16 87:2 

110:4 

thoughtful 61:8 

thoughts 81:16 

thousands 134:1 

threats 150:20 

three 3:19 6:17 7:7 

22:17 35:16 38:2 

39:18 81:1 87:14 

105:22 109:3 136:5 

137:11 144:7 146:18 

147:20 

three-hour 62:6 

three-year 22:13 80:20 

Thursday 3:20,21,22 

155:19 156:3,12,18 

ties 66:7 

timeline 58:17 100:4 

timely 73:19 

timer 6:15 36:9 62:3 

times 21:2 22:5,9 37:21 

timewise 4:11 

timing 18:22 77:2 

to-face 5:1 

tobacco 13:21 14:5,7,9 

14:22 15:9,20 20:7,11 

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20:19 22:6,11,19,21 

23:1,3,16,22 24:2,5 

24:20 25:7,8,13,16 

26:5,16,21 27:3 28:8 

28:11,14 29:1,4,7 

31:11,12,15 32:6,13 

32:22 33:6,13 36:17 

36:18 37:8 38:15,21 

39:1,3,5,10 41:1,2,5 

42:6 63:5,7 103:13 

104:6,17 106:10 

107:4 

tobacco's 25:2 

today 3:19 4:6 5:2 16:4 

16:13 35:21 36:14 

40:21 42:13 55:17 

63:5 73:15 77:1 79:6 

103:10 108:17 119:6 

140:19 145:21 155:21 

today's 4:12 5:13 

told 33:19 50:11 77:22 

145:9 

Tom 1:15 10:20 24:9 

91:9,11 113:12 

118:19 120:7 125:4,5 

125:8,14 126:17 

148:12 155:9 

tomatoes 133:7 

tomorrow 145:22 

tool 51:3 67:1 122:1 

tools 50:18 51:8 122:7 

124:2 

top 3:6 32:18 37:14 

86:16 144:6 145:4 

topic 52:6 69:3 111:9 

topping 37:14 

torn 106:15 

totally 92:6 

touch 59:18 108:18 

toxicant 106:12 

toxicity 105:9 

track 8:15 

tracking 49:7 

tractor 39:9 137:10 

tractors 39:18 

trade 48:20 97:16 

143:10 

traditionally 22:13 

transcribed 7:16 

transcribing 9:2 

transcription 35:14 

transcriptionist 9:1 

36:7 

transfer 76:7,9,16,17 

77:13 78:18 

transferred 76:13 

transition 46:8 142:1 

142:16 144:7 145:19 

146:18 147:21 

transparency 53:5 

54:13 59:1 60:5 61:2 

transposons 88:17 

93:10 94:14,22 

treated 77:15 78:10 

tremendous 143:9 

triage 137:1 

trial 28:18 

trials 121:3 

tricky 112:5 

tried 154:14 

triple 31:12 

true 25:7 46:16 78:11 

133:7 139:7 150:9 

trust 62:22 66:6 

trustworthy 145:11 

try 8:11,14 12:16 25:15 

25:17,21 37:2 149:18 

trying 31:18,20 37:21 

81:17 130:14 138:22 

Tucker 18:3 141:4,13 

141:16,22 142:3 

TUESDAY 1:7 

turn 99:13 

turning 5:14 

twice 79:8 

two 6:11 9:16 16:4 

31:19 33:15 34:7 43:7 

44:13 53:8 55:22 68:9 

76:8 80:5 102:9 

123:13,21 128:8 

136:22 149:9 

type 23:6 25:7,9 35:3 

78:18 109:12 123:3 

types 25:7 

Typical 85:12 

typically 23:4,12 31:11 

31:14 32:19 

U

U.S 26:21 45:13,15 49:8 

65:22 117:20 

ultimately 28:16 59:21 

143:12 

unable 131:16 

unacceptable 142:22 

unanimously 93:19 

uncertainty 69:15 

uncertified 44:9 

understand 39:4 47:14 

59:20 69:4 75:12 

116:22 

understanding 25:17 

74:12 78:13 79:10 

98:9 144:3,8 148:7 

uneven 66:1 140:2 

unexcluded 113:1 

unfair 132:13 134:13 

unfortunately 98:20 

unintended 112:10 

unisex 102:2 

United 1:1 129:6 

University 97:17 121:4 

unlevel 67:16 70:10 

unmute 6:3,6 9:15 

12:16 148:22 

unmuted 9:16 27:22 

102:11 111:15 

unmuting 77:4 

unpack 52:9 

unresponsive 110:2 

unsealed 48:13 

unusually 128:13 

unwanted 28:15 

upcoming 4:19 12:5 

43:12 

update 58:8,16 93:19 

updated 45:21 

updates 95:10 

updating 95:14 

upfront 60:14 

uphold 134:12 

upper 29:8 

upset 79:12 

uptake 130:13 

uptaken 130:14 

urge 52:19 54:19 65:14 

65:16 66:9 67:17 

88:10 89:7 93:9 95:12 

133:10 143:14 

urgency 48:4 

urgent 63:8 65:11,12 

66:10 

urging 65:17 68:11 

usage 91:15 

USC 155:6 

USDA 5:8 16:5,10 29:14 

29:16 45:19 49:3,12 

62:22 65:17 73:10 

137:12 140:21 

use 14:16 15:17 17:3 

24:13 25:20 29:3 30:7 

31:9 33:12,19,21 

34:10,14 35:5,9 42:15 

63:6 74:21 75:17 76:8 

78:1 79:21 80:10,15 

81:5,12 82:15 86:1,13 

89:1 99:15 103:14 

104:5,22 106:10 

107:5 109:14 110:19 

111:3 114:5 115:9,15 

122:11 123:22 129:10 

134:6 136:10 142:4,8 

145:20 154:5,6 

useful 35:17 83:12 

uses 135:18 

usually 13:10 22:8,21 

127:1 

utility 52:13 

utilize 17:12 121:21 

utilized 27:4 

utilizes 26:20 

V

vaccination 110:12,17 

vaccinations 110:7,10 

vaccine 75:8 109:22 

111:6 

vaccines 74:15,17,18 

74:21 75:2,3,12,17 

76:5 77:11 108:19,20 

109:4,5,8,10,12,12,15 

110:22 111:3 113:2 

valid 151:5 

Valley 155:8 

value 115:18 

value- 115:2 

varietal 98:15 

varieties 60:16 

variety 85:19 99:3 

various 57:7 69:4 86:2 

vast 15:5 

vegetable 73:21 

vegetables 36:22 

verbiage 150:17 

verification 124:12 

Vermont 2:10 73:9,11 

73:12,22 75:14 76:22 

77:17 

veterinarian 76:4 

vetted 122:5 136:20 

viable 28:21 39:7 

Vice 1:13 9:13 

view 44:7 146:19 

vinegar 128:8,9,11 

virgin 74:2,4,7 79:21 

vital 153:3 

vitro 89:1,4 93:11 94:17 

95:7 

VOF 73:9,19 

voice 137:5 140:3 

voluntary 118:1 

volunteer 137:16 

vote 69:6 

voted 93:18 

W

wait 80:20 148:2 

waiting 112:17 

wakes 37:15 

wall 130:17 

wanted 24:15 42:21 

62:4 73:17 79:6 86:11 

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88:4 96:5 108:18 

wanting 82:3 

wants 17:21 37:16 

Washington 4:21 

wasn't 98:21 

water 57:7 120:19 

watermelon 129:9,9 

WATKING 43:14 

Watkins 2:21,21 30:19 

35:19 40:15,18,18 

43:11,16 

way 18:21 32:5 38:16 

56:9 72:13 94:21 

106:15 146:15 

ways 57:3,7 64:7 85:19 

88:11 123:21 139:16 

webinar 1:5,10 3:17,19 

4:13,17 5:16 6:9 7:15 

42:22 50:1 59:16 62:6 

101:12 117:6 125:8 

148:17 156:12 

website 4:22 

week 18:7 19:6 147:12 

147:14,16 148:3 

156:6 

welcome 3:3,17 4:11 

19:18 43:16 71:10 

137:20 143:18 150:2 

welfare 104:4 

well-suited 54:6 

went 42:5 56:9 157:3 

weren't 57:2 78:12,13 

149:7 

wet 20:14 

wheat 31:16 41:3,22 

42:5 

Whoa 117:8 

wide 49:13 

widely 74:13 91:16 

willing 76:16 145:12 

Windy 2:10 30:18 31:1 

Wing 150:17,18 

winter 22:21 25:13 28:9 

Wisconsin 38:20,21 

39:8 97:17 

wish 54:19 

Wolf 2:11,22,22 120:12 

125:18 131:2 135:5,8 

135:10,10,11 139:2 

wonder 30:13 

wondering 22:5 50:7 

59:7 126:7 

word 72:18 

words 65:1 71:3 

work 4:16 5:9 15:6 

16:12 19:13,15 23:9 

23:10 30:5 37:10 

46:20 47:13,20 49:22 

50:8,10 52:4,6,16 

53:3,10 54:9 58:8,10 

59:19 63:12 71:5,13 

73:15,19 79:3 85:1 

87:12,17 88:21 89:22 

94:5 95:17 97:19,20 

98:10 100:19 101:1 

108:14 121:15 122:16 

150:5 154:14 

worked 97:21 149:9 

152:9 

worker 18:17 19:1 

workers 15:10 19:10 

29:1 

working 20:11 21:2 

22:17 50:18 57:2 

96:17 97:15 98:1 

100:4 133:11 134:20 

151:2 

world 33:18 129:7 

145:3 

worldwide 140:5 

worry 69:2 

wouldn't 34:9 124:9 

wrap 7:6 

wrappers 38:22 

wrapping 33:17 92:5 

write 7:9 57:14 

writing 87:22 

written 45:6 61:17 63:3 

66:4 89:18 90:6 94:20 

96:7,14 112:22 

118:21 135:14 138:6 

X

Y

yarn 121:9 

year 17:5,9,10,11,17,19 

17:22 18:2 30:8,9 

31:17,20 34:13 40:3,4 

40:6,6 41:6 42:9 43:9 

43:9,12 45:6 48:19 

63:9 66:16 67:6,11,19 

88:5 98:21 99:2 144:7 

146:18 147:20 151:9 

years 19:11 27:2 28:12 

29:22 30:3 31:19 

33:15 36:19 40:20 

46:22 68:2 76:7 77:20 

79:7 81:2 88:21 

129:16 139:8,8 140:8 

141:9,14 

yelling 3:14 

yield 28:16 32:12 

yields 14:8 15:8 

York 102:4 155:8 

young 88:13 

Z

0

1

1,300 14:3 

1:00 1:10 3:2 156:13 

10 41:4 82:7 128:16 

156:2 

100 41:2 

12 129:15 

125 41:2 

14 12:3,6 

14-member 12:8 

140 39:11 

140s 39:18 

15 76:7 79:7 

150 37:6 

16 1:7 104:18 

1790 36:16 

18 124:20 

19 52:8 

1949 150:16 

1980s 152:4 

1983 14:2 

1995 120:14 

1998 14:2 150:17 

2

2 109:11 

20 38:1,8 68:1 

2003 41:4 

2010 133:13 

2011 150:6 

2016 93:18 121:4 150:6 

2018 44:11,19 65:12 

121:5 

2019 1:7 3:18 7:17 12:7 

14:5 17:13 43:12 

44:13 49:1 65:13 

67:18 

2020 43:13 47:1 63:10 

69:9 

2022 45:6 

20520(c) 132:11 

22 36:19 37:17 38:5 

220 14:4 

23 36:19 

24th 4:20 

25 41:5 

250 31:15 

250-acre 30:22 

26th 4:20 

3

3 37:19 

3:48 157:3 

30 128:14 

305 71:17 85:5 

350 40:22 

360 38:5 102:11 

37 140:7 

4

4 112:2 

40 31:14 

415 85:14 

444 85:13 

465 85:17 

48 40:20 

49 42:9 

4th 41:1 

5

5 81:21 82:10 

50 28:7 81:22 143:12 

59 124:22 

5988 124:21 125:1 

6

6 6:5 

60 38:3 

600 28:10 

6000 38:4 

601 136:15 

603 136:16 

605 136:16 

606 136:16 139:7 

6517 105:1 

6954- 124:19 

7

7 6:6 

7.2 38:9 

700 73:11 

75 41:20 

8

80 41:3 

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C E R T I F I C A T E 

This is to certify that the foregoing transcript 

In the matter of: Webinar

Before: USDA/NOSB

Date: 04-16-19

Place: webinar

was duly recorded and accurately transcribed under 

my direction; further, that said transcript is a 

true and accurate record of the proceedings. 

 ----------------------- Court Reporter 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 
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 UNITED STATED DEPARTMENT OF AGRICULTURE

 + + + + +

 NATIONAL ORGANIC STANDARDS BOARD

 + + + + +

 PUBLIC HEARING WEBINAR

 + + + + +

 THURSDAY

 APRIL 18, 2019

 + + + + +

 The Webinar commenced at 1:00 p.m.,

Harriet Behar, Chairperson, presiding. 

PRESENT 

HARRIET BEHAR, Chairperson

SUE BAIRD 

ASA BRADMAN 

JESSE BUIE 

TOM CHAPMAN 

LISA de LIMA 

STEVE ELA 

JAMES "RICK" GREENWOOD 

DAVE MORTENSEN 

EMILY OAKLEY 

SCOTT RICE 

A-DAE ROMERO-BRIONES 

DAN SEITZ 

ASHLEY SWAFFAR 

ALSO PRESENT 

PAUL LEWIS, Director, Standards Division, NOP 

MICHELLE ARSENAULT, Advisory Board Specialist 

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 1:00 p.m.

 MS. ARSENAULT: Hi, everybody. It's 

Michelle from NOP again. I have straight up 1:00 

o'clock Eastern time here. So, I think we'll get 

started.

 It looks like some -- well, you know 

what? Actually, let me wait a couple of minutes. 

It looks like folks are still joining in and 

rather than have interruptions and have to -- I'm 

sorry, I can't talk anymore.

 Let's give it another minute or two 

and then we'll get started.

 (Whereupon, the above-entitled matter 

went off the record at 1:00 p.m. and resumed at 

1:01 p.m.)

 MS. ARSENAULT: Hello, again, 

everyone. It's Michelle.

 I think we're going to maybe get 

started. It looks like the majority, if not all, 

of the Board members are here. So, I think we're 

ready to begin. 

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 So, welcome. We would appreciate it 

if you could self-mute yourself while we're on 

the call just to keep the background noise level 

down. Otherwise, we have to mute everybody at 

once and then we have to search for the people 

that are going to be providing comments to unmute 

them and it just takes a little bit extra time to 

do that.

 So, Tuesday ran really well and 

background noise was at a minimum. So, I really 

appreciate that, thank you, everyone.

 All right, we're going to get started 

and, first of all, Paul Lewis, the Director of 

Standards is going to call the meeting to order 

and then we'll dive into some logistics.

 MR. LEWIS: Thank you, Michelle.

 And, good afternoon, everyone. I'd 

like to welcome NOSB members and the public today 

to today's, and actually, our second day this 

week on the National Organic Standards Board 

Public Comment Webinar.

 And, as I said before, I really 

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appreciate all the work of the NOSB members 

taking this call and for getting us ready for 

this public comment webinar. Thank you for all 

of your work serving on the Board.

 This webinar provides the opportunity 

for the public to provide comments to the NOSB as 

part of the Board's upcoming public face to face 

meeting scheduled next week in Seattle, 

Washington. And, please consult the NOP website 

for information about the face to face meeting.

 This meeting, like other meetings, the 

National Organic Standards Board will meet face 

to face and our public webinar operates under the 

provisions of the Federal Advisory Committee Act.

 And, I look forward to hearing 

comments from the public to assist the NOSB 

preparing their recommendations to USDA in 

response to NOSB work agenda items.

 I'd be remiss without thanking 

personally my colleagues in the Standards 

Division, Michelle in particular, for their work 

behind the scenes to bring us today's 

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teleconference.

 I'd like to close by turning now to 

Harriet Behar, Chair of the Board.

 Harriet, thank you, again, for 

chairing this webinar and for your upcoming 

serving as Chair for next week's NOSB meeting.

 MS. BEHAR: Thank you, Paul. It's 

more fun than it might seem.

 Okay, so, I will go through some 

housekeeping and if Michelle has any points to 

make after I'm done, she can chime in.

 We're going to leave those phone lines 

open unless there's too much background noise, as 

Michelle stated. So, if you have a mute, please 

mute it. If not, you can press star, six to mute 

or star, seven to unmute.

 Just as a reminder, you had to preregister in order to comment on this webinar. 

So, as we are going through our 12 speakers, I 

will announce who's on deck, there's the 

following two people. So, you'll be ready to 

join in when the -- when we're done with the 

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previous person and any questions that the Board 

might have.

 There is a timer which Michelle will 

show us or sound us when I'm done speaking so 

that will go off when you have done your three 

minutes of public comment. And so, when you hear 

that timer, please, finish up because you're at 

the end.

 Board members, I think it worked 

pretty good the last time. Just I have a hard 

time, I don't really see people raising their 

hands. So, I will just ask for Board members to 

let me know who wants to speak and then you can 

ask questions.

 It was very engaging on Tuesday and I 

really appreciate all the input from the Board 

members.

 Just to let you know, this webinar 

will be transcribed and in print as part of the 

official public record for the Seattle 2019 NOSB 

meeting.

 And, I just want to say, thank you to 

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all the public for their comments. It's really 

important for us to hear from the organic 

community so we know which way to head on these 

various issues facing us, materials, and practice 

standards that we are working on. And so, thank 

you so much for taking time out of your busy day.

 Now, I'm going to go to Michelle and 

she can let us hear what the time sounds like and 

she will also do the roll call so you know which 

NOSB members are on the call.

 MS. ARSENAULT: Thank you, Harriet.

 All right, I'm going to hit the timer 

and give us three seconds here. Hopefully 

everyone can hear that okay. I know when you're 

speaking, sometimes, you know, it's not as loud 

as it needs to be.

 All right, and I just want to touch on 

-- Harriet covered pretty much everything, I 

think. I just want to cover a couple of things.

 Comments, our participants are able to 

chat into the Chairperson which is me and a 

couple of other staff members. And so, if we 

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have problems finding you in the list to speak, I 

may go ahead and send out a chat. So, kind of 

keep an eye on that.

 The chat is not part of the public 

record. So, we don't accept comments through 

chat. So, please, don't do that.

 And then, just for reference --

(telephonic interference) -- hi, if you're on the 

phone with us, please put yourself on mute. 

We're getting some background conversation. 

Thanks.

 The other thing is, on the screen, I 

have displayed the readytalk.com help. If you're 

having technical problems, there's readytalk.com 

or you can dial that 800 number.

 I've always had a good response and a 

good experience with their technical support. 

So, you can always call that number if you're 

having any audio problems or trouble with the 

website.

 And, as Harriet said, there's a 

transcriptionist on the line with us, so the 

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notes will be transcribed and be part of the 

record after the spring meeting that ends in 

April.

 All right, I'm going to take roll call 

of the Board members, so everybody knows who's on 

the call.

 Sue Baird?

 If you're speaking, Sue, you're on 

mute.

 MS. BAIRD: So sorry. Yes, I'm here.

 MS. ARSENAULT: That's okay.

 Harriet is here. Harriet, you want to 

say --

 MS. BEHAR: Yes.

 MS. ARSENAULT: Thank you.

 Asa Bradman? Asa, I see you, but we 

can't hear you. So, I think you may be muted as 

well. Or, you're on a headset, so maybe your mic 

is not working. So, I see you on there. We'll 

come back. Just be brief.

 MR. BRADMAN: I'm here.

 MS. ARSENAULT: Hello, sir. 

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 Tom Chapman?

 MR. CHAPMAN: Present.

 MS. ARSENAULT: Hello there.

 Lisa de Lima?

 MS. DE LIMA: Here.

 MS. ARSENAULT: Thank you.

 Steve Ela?

 MR. ELA: I'm here.

 MS. ARSENAULT: Thank you, Steve. I 

see you there.

 Rick Greenwood?

 MR. GREENWOOD: Here.

 MS. ARSENAULT: Hi, Rick.

 MR. GREENWOOD: Hi.

 MS. ARSENAULT: Dave Mortensen?

 MR. MORTENSEN: I'm here.

 MS. ARSENAULT: Hello, Dave.

 Emily Oakley?

 MS. OAKLEY: Present.

 MS. ARSENAULT: Thank you.

 Scott Rice?

 MR. RICE: Present. 

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 MS. ARSENAULT: Hi, Scott.

 A-dae Briones?

 MS. ROMERO-BRIONES: Here.

 MS. ARSENAULT: Hi, A-dae.

 Dan Seitz?

 MR. SEITZ: I'm here.

 MS. ARSENAULT: Okay.

 And, Ashley Swaffar?

 MS. SWAFFAR: I'm here.

 MS. ARSENAULT: Hi, Ashley.

 And, for those of you keeping track, 

I called 14 names. We had an unexpected vacancy 

on the Board a couple of months ago, so we are a 

14 member Board at the moment. We will be 14 for 

the two 2019 meetings, so in April and October, 

we'll have 14 members present.

 All right, Harriet, I believe it is 

all yours.

 MS. BEHAR: Okay. So, first up is 

Allison Schmidt. And, after Allison, Berit 

Dockter, and Deborah Attwood are on deck.

 And, I believe that Allison has 

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PowerPoint.

 MS. SCHMIDT: Indeed, yes.

 MS. BEHAR: Allison, you can start 

speaking.

 MS. SCHMIDT: Okay. Can you hear me?

 MS. BEHAR: Yes.

 MS. SCHMIDT: Hello. Good afternoon, 

thank you for the opportunity to speak today. My 

name is Allison Schmidt. I'm a marine ecologist 

and my research focuses on marine plants, 

including algae and how human activities in 

Atlantic Canada impact the services that these 

ecosystems provide.

 And, what I mean by ecosystem services 

are the benefits that contribute to the wellbeing of all species including humans, that these 

ecosystems provide through their normal 

functioning.

 And, you can see from the chart that 

the services fall into four categories. And, 

algae ecosystems do provide services in all four 

categories and harvesting algae would fall 

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specifically into the provisioning category.

 Our current economic system does not 

capture ecosystem services unless they are goods 

like products, commodities, or tourism.

 And, as such, economists have been 

trying to put a value on all ecosystem services.

 And, in 2011, globally, there were 

estimated to be worth $125 trillion U.S. dollars 

per year.

 MS. ARSENAULT: Allison, this is 

Michelle. I'm sorry, I'm going to interrupt you. 

Your slides are not advancing automatically 

inside the software, so I'm going to have to do 

it for you.

 MS. SCHMIDT: Absolutely.

 MS. ARSENAULT: So, that will be me, 

I'm afraid. Thank you.

 MS. SCHMIDT: That's fine, I can do 

that. So, if you could advance the slides to the 

next one.

 MS. ARSENAULT: Okay, thank you.

 MS. SCHMIDT: Okay. So, it pretty 

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much just states what I said. And, you can see 

that value there of $125 trillion U.S. dollars 

per year.

 So, if you could advance to the next 

slide, please?

 So, just to orient you to this slide, 

the pie chart is the percent that each natural 

ecosystem contributes to that $125 trillion 

estimate.

 And, if you go on, the last shows the 

size of the ecosystem as a percent of total 

global area.

 If you could advance, again, please?

 So, what I want you to focus on are 

tropical forests and sea grass and algae 

categories that are highlighted in red.

 And, what we can see in the pie chart 

is that the value of sea grass and algae is 

comparable to tropical forests. So, when you 

look at the table, you can see that the area 

covered by sea grass is an algae is actually five 

times smaller which means that these ecosystems 

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are disproportionately contributing services for 

their size which makes it essential that we 

maintain their functioning.

 Next slide, please?

 So, the global monetary value of sea 

grass is in algae is $6.2 trillion per year which 

is more than what harvesting and tourism in these 

ecosystems actually contribute to the economy.

 For example, in 2014, marine algal 

landings in the Canadian Maritime Provinces 

contributed $1.3 million to the Canadian economy.

 Next slide, please?

 And, beyond harvesting raw materials, 

you can see that marine algo ecosystems provide a 

long list of services that directly and 

indirectly benefit us and range from providing 

nursery habitat for commercially important 

fishery species to oxygen production.

 So, keeping this in mind, next slide, 

please?

 The question is, how can we best 

mitigate harvesting impacts so that algo 

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ecosystems can contribute or continue to provide 

a full fleet of services that we currently do?

 One way to do this is to ensure that 

harvested materials conform to the wild harvest 

standards. And, that wildcrafting standard 

language be added to the marine algae and their 

products on your national list.

 Next slide, please?

 MS. ARSENAULT: This is you last 

slide, so.

 MS. SCHMIDT: It is, yes. Can I 

finish it?

 MS. ARSENAULT: Harriet?

 MS. BEHAR: Yes, you can.

 MS. SCHMIDT: Thank you.

 So, here, I've listed some key aspects 

that need to be considered within the not 

destructive to the environment amendment proposed 

by Beyond Pesticides in their comment posted on 

April 1st. And, we need to ensure that these 

points are addressed since they are important in 

maintaining the long-term health and resiliency 

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of algo ecosystems as well as the essential 

services they provide.

 And, thank you.

 MS. BEHAR: Are there any questions 

from the Board members?

 (SIMULTANEOUS SPEAKING)

 MS. BEHAR: And, maybe Emily has a 

question.

 MS. OAKLEY: I do, thank you so much 

for your presentation.

 And, I'm wondering if you feel that 

the wildcraft standard as it's currently written, 

I'm not sure how familiar you are with it, but 

also with the additional language that I know 

you've listed that Beyond Pesticides put in their 

public comments, if you feel that this is an 

adequate start for addressing this issue or if 

you have other suggestions that were not in the 

discussion document that you think might also 

help with protecting marine algae and the 

environmental impact of harvesting?

 Thank you. 

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 MS. SCHMIDT: I think that -- I have 

read over the language in both the original 

document of the wildcraft as well as the 

amendment from Beyond Pesticides.

 I think that the amendment that they 

have written does a good job. It's a good start, 

but that's one of the reasons why I listed all of 

those items on my last slide. And, it's also in 

my written comments that those would be things 

that need to be considered within the definition 

that they are proposing.

 So, I'm not sure if the language would 

need to change to reflect some of those points 

that I'm bringing up, but I think that would be a 

good discussion for the committee that I saw that 

you were proposing to put together a committee 

for the fall. And, I think that would be a good 

discussion for that group to have.

 MS. OAKLEY: So, Harriet, can I ask a 

follow up question?

 MS. BEHAR: Sure.

 MS. OAKLEY: So, some people have 

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expressed concern that a fund buried under the 

spectrum, one that we don't need any additional 

regulations or standards because government 

regulations are currently sufficient or 

harvesters are following their practices in terms 

of their harvesting methods.

 And then, on the other end of the 

spectrum, those are concerned that even if we 

applied organic certification of the rule for 

the, you know, marine algae ingredients, that 

would be a not organic crop input product. But 

that wouldn't go far enough to protecting marine 

ecosystems.

 So, we're trying to figure out, you 

know, how to wade through those various ends of 

the spectrum in terms of public comments.

 And, I'm wondering if you have any 

thoughts on that? And, I know that that's a 

pretty broad question, so if you don't, that's 

fine. But, I just appreciate that you're on the 

call so that I can see if you have any thoughts 

on this. 

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 MS. SCHMIDT: Sure. I think that 

clarifying the no harm to the environment needs 

to be clarified in terms of the marine 

environment because it's not the same as the 

terrestrial environment. 

 So, I think that it would be important 

to make sure that that language be clarified 

specifically for marine algae.

 MS. OAKLEY: Okay, great. Thank you.

 MS. BEHAR: Any other questions from 

the Board?

 (NO AUDIBLE RESPONSE)

 MS. BEHAR: I have a question. I'm 

not sure how, but somebody sent me a video of 

kelp harvesting with something that looked kind 

of like a vacuum.

 And, I just wondered if we should be 

looking at the types of harvest, too? Because I 

don't know if that would have, perhaps, a more 

broad catch than other methods. Because it 

seemed to just be kind of sucking up everything 

in sight. 

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 Maybe can you speak to the specific 

types of harvest if there's more than one type?

 MS. SCHMIDT: Yes, I think that when 

it comes to harvesting, that was actually one of 

my points that I think needs to be considered 

within that definition of no harm to the 

environment is the type of harvest.

 Mechanical harvesting, at least in the 

Atlanta Canada, we had a history with it. And, 

we have had elimination of rock reed beds in 

areas that have taken a long time, decades to 

recover because of mechanical harvesting. So, 

that's the vacuum like harvester.

 There are a number of different kinds 

of mechanical type harvesting, but any mechanical 

harvesting tends to do more harm than hand type 

harvesting.

 So, using hand tools, either a knife 

for cutting it or a cutter rake or some other 

form that requires actual manpower rather than a 

machine.

 Those would be preferred methods 

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because they do the least amount of damage in 

terms of not just by catch, but also damage to 

the remaining plants that are left behind.

 Because, often times, some of these 

species will regenerate from pieces that are left 

behind. So, if it's being completely removed, 

then that makes it difficult for those species to 

come back in that way.

 MS. BEHAR: Are there people currently 

hand cutting and raking? And, is it kind of 

environment -- I'm sorry -- economically viable 

method?

 MS. SCHMIDT: That is the only way to 

harvest rock reed here in Nova Scotia is using a 

hand rake harvester.

 I know that also in British Columbia, 

they use knife hand harvesting. There's not a 

lot of harvesting on the West Coast of Canada but 

what they do harvest usually uses a knife to cut 

the tops of the large kelp fronds from the 

surface of the water. And those tend to be more 

sustainable in the long term. 

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 But that also has to -- there's also 

the caveat of how much you're allowed to take 

because no matter what method you use, if you can 

-- it has to be guided by a maximum amount as 

well.

 MS. BEHAR: Sure.

 Anyone else have a comment?

 Dan, are you speaking?

 MR. SEITZ: I'm not speaking.

 MS. BEHAR: Oh, okay. For some reason 

it's showing up as you are speaking.

 Okay, I'm not hearing anything else. 

Thank you so much and thank you for your written 

comments as well.

 MS. SCHMIDT: Thank you for your time. 

Have a great day.

 MS. BEHAR: Okay, next up is Berit 

Dockter, Deborah Attwood, and Jane DeMarchi on 

deck.

 Berit, please state your name and 

affiliation.

 MS. DOCKTER: Sure. My name is Berit 

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Dockter. I represent the International Food 

Additives Council. IFAC is a global association 

representing manufacturers and end users of food 

ingredients including a number of substances that 

are permitted in organic foods.

 IFAC supports maintaining citric acid 

on the national list at 205.605a. Citric acids 

serve many purposes, including pH control and 

stabilization of processed food products as well 

as extending the shelf-life of fresh fruit and 

vegetables in addition to cut fruit.

 IFAC is not aware of an organic source 

for citric acid that will meet the needs of 

organic producers in terms of quantity and 

quality.

 IFAC also supports maintaining lactic 

acid on the national list. Lactic acid is a 

natural organic acid present in milk, meat, and 

beer. IFAC is not aware of organic alternatives 

to lactic acid.

 IFAC supports relisting yeast at 

205.605a. Yeast is extremely important to 

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organic food production, particularly in baking 

operations. A supply of organic yeast remains 

very limited and costly which is why we support 

continued use of nonorganic yeast.

 IFAC supports maintaining enzymes on 

the national list. Enzymes are critical for the 

production of organic cheeses and dairy products.

 Regarding the Handling Subcommittee's 

request for additional ancillary substances, IFAC 

provided a list with our written comments.

 IFAC supports the continued listing of 

dairy cultures and micro-organisms. We also 

support combining these listings under the term 

Food Cultures.

 Without dairy cultures and microorganisms, many products like dairy foods, 

breads, fruit and vegetables, and meats would be 

unavailable to consumers of organic food. We 

also provided a list of additional ancillary 

substances for use in dairy cultures and microorganisms with our written comments.

 IFAC supports maintaining potassium 

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phosphate on the national list at 205.605b. 

Potassium phosphate may be used to provide a low 

sodium alternative to health and sodium reduction 

efforts.

 IFAC also supports relisting sodium 

acid pyrophosphate, or SAPP. It's the only 

product capable of chemical leavening that is 

allowed by the National Organic Standards Board. 

And, leavens bake foods faster than yeast. We 

are not aware of a comparable ingredient that can 

be substituted for SAPPY.

 And, lastly, IFAC supports maintaining 

alginic acid on the national list. Alginic acid 

is important in the stabilization and thickening 

of many foods. There is not an adequate supply 

or organically produced alginic acid available, 

so it remains essential to organic food 

production.

 The seaweed used to produce alginic 

acid is harvested in a sustainable manner and 

we're not aware of any damage to local 

ecosystems. 

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 So, thank you for the opportunity to 

provide comments and I'm happy to answer 

questions.

 MS. BEHAR: Any members of the Board 

have questions?

 MR. BRADMAN: This is Asa.

 In terms of the alginic acid, what's 

your basis for the statement that it's harvested 

in a sustainable manner?

 MS. DOCKTER: That's feedback we've 

received from our membership, but I'm happy to 

follow up if we have additional information to 

provide you.

 MR. BRADMAN: That would be great.

 MS. BEHAR: Yes, I second that. If 

you could get us the standards by which they are 

harvesting the algae, that would be useful.

 MS. DOCKTER: Sure.

 MS. BEHAR: Any other -- thank you.

 Any other comments from NOSB Board 

members?

 (NO AUDIBLE RESPONSE) 

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 MS. BEHAR: Okay, well, thank you very 

much, Berit.

 MS. DOCKTER: Thank you.

 MS. BEHAR: And, for your written 

comments as well.

 Next up is Deborah or Deborah Attwood 

and on deck is Jane DeMarchi and Francis Thicke. 

So, Deborah, please state your and affiliation.

 MS. ATTWOOD: Can you hear me okay?

 MS. BEHAR: Yes.

 MS. ATTWOOD: Okay, great. Good 

afternoon. My name is Deborah Attwood. I'm an 

attorney with Steptoe and Johnson and I'm 

commenting today on behalf of PURE Bioscience.

 Thanks for the opportunity to provide 

additional support for silver dihydrogern 

citrate, or SDC, would be a worthwhile addition 

to the national list.

 For the full 2018 meeting, the 

Handling Subcommittee recommended that the NOSB 

should approve SDC for addition to the national 

list on the basis that it is of low risk to the 

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environment and human health and would represent 

a valuable addition to available antimicrobials.

 Also, recognizing these benefits, the 

Subcommittee has now recommended against listing 

SDC due to concerns about environmental disposal, 

the alleged presence of nanosilver and the 

intended use of sodium lauryl sulfate.

 PURE Bioscience has provided extensive 

comments to the public docket that address these 

concerns. And, we note that there is now no 

legal or regulatory reason why the NOSB, on the 

basis of these written comments and other oral 

comments, could not now approve SDC for inclusion 

on the national list and for the benefits of 

organic processes we strongly urge NOSB to do so 

without further delay.

 I'd like to use the remainder of my 

time to talk about the role of antimicrobials 

generally.

 In an ideal world, there would be no 

need for antimicrobials in food processing. But, 

in reality, bacteria such as Salmonella, and 

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Listeria, and E. Coli naturally are present 

everywhere, and so far, it has proven 

extraordinarily difficult to find reasonable and 

feasible natural methods to eliminate them. 

 And, these bacteria kill people. But 

the use of antimicrobials generally helps to 

reduce that threat. The antimicrobials 

themselves present a hazard to human health and 

human and environmental, yes, they do.

 But the evaluations conducted by EPA 

and FDA are not just about recognizing a 

potential hazard, but about whether the risk from 

that hazard is sufficiently controlled.

 Neither FDA nor EPA considers a 

products potential benefits as part of a safety 

evaluation, instead, they only consider whether 

the intended use of an antimicrobial on food 

represents a reasonable certainty of no harm.

 The expertise of these agencies is 

recognized in the organic food production as 

recommendations. NOSB consults with these 

agencies on the safety of substances for 

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additional list.

 Based on how SDC is intended to be 

used in food processing facilities currently not 

in the fields or in post-harvest applications, 

both FDA and EPA have concluded that SDC does not 

represent unreasonable risk of harm.

 The NOSB has the advantage of being 

able to consider the benefits of SDC. There is 

no one antimicrobial that can be or do everything 

and SDC would simply be an alternative for 

processors to use as part of their pathogen 

management program.

 It would allow them to conduct better 

antimicrobial rotation practices and thus reduce 

the threat of antimicrobial resistance.

 It reduces the threat from food borne 

illnesses.

 On these bases, we respectfully submit 

that SDC would be a valuable addition to the 

national list.

 Thank you.

 MS. BEHAR: Thank you. 

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 Any questions from the Board?

 MR. GREENWOOD: Yes, this is Rick.

 I just had a question. You had 

mentioned, for instance, that Salmonella is 

everywhere. In fact, it isn't everywhere and 

mostly it's controlled by good growing practice 

and harvest.

 So, I don't think that that's always 

a necessary addition to the processing and it's 

more of a shotgun approach.

 I have some concerns about those kinds 

of statements.

 MS. ATTWOOD: Yes, and then, 

certainly, there is no intent here to minimize 

the need for good manufacturing, good harvesting 

practices. That's absolutely a key and essential 

component on producing safe food.

 You know, use of antimicrobials, it 

certainly has some issues. They're costly, you 

have disposal issues.

 But the -- unfortunately, the fact 

still remains that for a variety of reasons, 

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whether it's through source material such as MRSA 

or manure, that food borne pathogens still 

remain.

 I mean, if we look at the number of 

recalls last year, just as one example, related 

to produce, while, you know, absolutely, we 

should be encouraging good growing practices, we 

still want to use additional means to help reduce 

the impact of food borne illness.

 And, antimicrobials, for now, are one 

method to do that.

 MR. GREENWOOD: Yes, what my concern 

is, sometimes with the use of antimicrobials, 

people at the start of the food chain get sloppy 

because they think, hey, I can just let it go 

because somebody's going to throw an 

antimicrobial on this at the end.

 And, even that doesn't always work 

because of contact time and how things are 

processed. 

 So, I think it's just a slippery slope 

sometimes. 

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 MS. ATTWOOD: And, that's certainly a 

reasonable concern. Although I would -- that's 

not necessarily a rationale for why silver 

dihydrogern citrate shouldn't be added to the 

national list.

 I mean, that's certainly an important 

overarching concern. But in terms of, you know, 

making sure that processors have the necessary 

tools available to them to produce safe food, 

antimicrobials, for better or for worse, are very 

effective, generally.

 And, when you properly, also a very 

good point, when used properly are one tool for 

reducing that risk.

 MR. GREENWOOD: Okay, thank you.

 MS. BEHAR: Any other questions for 

Deborah?

 (NO AUDIBLE RESPONSE)

 MS. BEHAR: I have one, maybe two. 

The first one is, can you tell me what other 

sanitizers have been typically used in rotation? 

And, what resistance is it trying to avoid by 

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being part in that rotation? What virus, fungi, 

or bacteria? Why would it be used in rotation 

with other sanitizers?

 MS. ATTWOOD: Well, so, antimicrobials 

and sanitizers can be used at a number of 

different stages in processing. And, each 

sanitizer may have different approvals from EPA 

or from FDA.

 So, EPA, you know, may have approved 

it for use only in hard surface sanitizing. They 

may have approved it for post-harvest use.

 Whereas, some sanitizes are approved 

purely for use in food processing facilities, but 

only in spray applications or others may be used 

in dip applications as well. It really just 

depends on the product themselves.

 So, depending on the point at which 

you are -- you want to use the antimicrobial, you 

can use one that's best suited to your product, 

the pathogen of -- I mean, it really just depends 

on what products you're processing and what 

issues are of particular concern to your product 

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and to your facility.

 I mean, one, I mean, you know, the 

pathogens of concern are going to be different 

for poultry versus produce.

 But, I mean, I even noted in a recent, 

well, I'm not entirely sure how recent it is, but 

an FSIS Listeria compliance guideline for ready 

to eat poultry products, they recommend sanitizer 

rotation as one method to help prevent Listeria 

contamination.

 So, the -- it depends on the products, 

it depends on the facility, but sanitizer 

rotation can be used based on the individual 

approvals for each product.

 MS. BEHAR: So, for instance, it's not 

used specifically in rotation chlorine or 

peracetic acid or --

 (SIMULTANEOUS SPEAKING)

 MS. ATTWOOD: I don't know the answer 

to that question. I -- we could certainly follow 

up with some more information on what -- would 

you be primarily interested on product or poultry 

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or both?

 MS. BEHAR: So, both.

 MS. ATTWOOD: Okay, yes, we can 

certainly follow up with some more information on 

that.

 MS. BEHAR: Okay. And then, my other 

question is if you had a chance to look at the 

comments of Consumers' Union, Michael Hansen?

 He talked some about silver being used 

in human health. And that there was some concern 

about carping pathogen resistance and that having 

it in the food supply when it's also used in 

human health could be an issue. Have you had a 

chance to look at those comments?

 MS. ATTWOOD: I have seen those 

comments. And, silver does have -- silver has a 

long, very, very long, hundreds of years long 

history of being used in medical applications.

 And, actually, that lengthy history is 

in part good evidence of the fact that 

antimicrobial resistance to silver is -- it's not 

easy for bugs to develop because of its centuries 

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long use, one would think that by now, you might 

have seen some more resistance developing to it.

 The science on antimicrobial 

resistance is certainly always advancing. I 

mean, it's a huge issue that the FDA is looking 

at. And, will continue to evaluate and it 

wouldn't surprise me if EPA also considered that.

 But there are, for a couple of 

reasons, SDC uses extremely low levels of silver 

to achieve its technical effect. And so, you're 

not adding a whole lot of new silver out there 

into the food supply.

 I mean, indeed, we talk in our written 

comments about how -- what SDC gets out in the 

environment is actually not really adding to the 

background levels that are already there.

 And then, the other is the evidence 

for silver actually significantly contributing to 

antimicrobial resistance has been -- really 

haven't been demonstrated very strongly. They're 

-- they've shown some evidence in lab against 

some organisms, but their primarily not the 

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organisms that are of primary concern for our 

purposes.

 So, I mean, it is, antimicrobial is a 

concern for all sanitizers used in food 

processing but where SDC is particularly 

concerned, it's on the pretty low risk end of 

that spectrum.

 MS. BEHAR: Thank you.

 Any other questions from Board 

members?

 (NO AUDIBLE RESPONSE)

 MS. BEHAR: Okay, I'm trying to get 

back to my list here.

 Thank you. And, next on deck is Jane 

DeMarchi, and Francis Thicke, Elizabeth Miller 

are both on deck.

 Jane, please state your name and 

affiliation.

 MS. DEMARCHI: Hi, my name is Jane 

DiMarchi. I'm from the American Seed Trade 

Association. ASTA was founded in 1883 and we 

represent over 700 member companies involving 

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seed production, distribution, plant breeding, 

and related industries in North America.

 And, our members produce seed for row 

crops, vegetables, grasses, cover crops, and, 

obviously, for the organic food market as well.

 I'm going to comment on three 

different proposals, including the excluded 

methods, genetic integrity, and also, the NOP 

guidance of food usage.

 In regards to the excluded methods 

comments, you know, we continue to have concerns 

about the criteria that has been established for 

the excluded methods. We know that it is -- that 

criteria has not been formally approved by the 

National Organic Program, but it is now being 

considered in some ways, we're starting to see it 

in other guidance documents which is of a concern 

to us.

 We know these existing and the allowed 

methods and some of the methods that have been 

considered to be excluded or on the list for 

further consideration of excluded methods, we see 

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that reduction could really ultimately reduce 

seed availability because you're potentially 

excluding methods that are using the plant's own 

defense mechanism to address pest and diseases.

 In the genetic integrity proposal, we 

are looking forward to the opportunity to 

participate in the survey proposed. And, you 

know, we still feel that the marketplace is the 

best place to address genetic integrity, 

freshness, et cetera.

 And, the many businesses or members 

are providing testing information to their farmer 

customers.

 Lastly, on the NOP guidance on food 

usage, you know, you'll note in our comments, we 

are very strong supporters of using trialing for 

large scale organic producers versus the 

catalogue where you're generally just using a 

small scale.

 And, we note that there continue to be 

some species and crops that do not have true 

sources of organic seed at this moment. And, 

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it's likely that that will continue into the near 

future.

 And, lastly, you know, most crops do 

not have a GMO equivalent and so we are concerned 

about the requirements for non-GMO declarations 

if they are not considered to be at risk crops.

 And, just noting that AMS is now 

asserting the bioengineering disclosure 

regulations which do have a list of bioengineered 

crops that are available in the U.S. on the USDA 

website.

 And, with that, I will conclude.

 MS. BEHAR: Thank you.

 Any questions from the Board?

 (NO AUDIBLE RESPONSE)

 MS. BEHAR: I have a question because 

I was reading your written comments. And, on the 

seed genetic integrity document, you used still 

that the cost of testing would become very 

prohibitive, but you've just mentioned here that 

many organic seed suppliers are already doing the 

testing. 

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 And, really, the main purpose of this 

proposal was that we had heard from farmers that 

they are getting rejected at -- when they deliver 

a crop. And, they don't know if it's happened on 

their own farms, if they're getting seed that is 

somewhat contaminated.

 And so, they really wanted to have 

some sort of baseline on what they're starting 

out with. So, when they sign a contract or 

trying to get into a certain marketplace that has 

a tolerance, they know where they're at.

 For farmers that are using the seed on 

their own, they may not care as much for what 

presence of genetic engineering might be in their 

seed, but for others, it really makes the 

difference between a lucrative contract and 

conventional price many times.

 So, I'm just wondering, since so many 

organic seed producers are already doing this, 

why would we not want to provide the farmers that 

information?

 MS. DEMARCHI: So, I think one of the 

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things that we're wanting in terms of price is an 

additional amount of oversight testing that would 

be the responsibility of the farmer. And, I 

think that's one of the reasons why we feel like 

the survey and additional work on what is the 

testing program can have a huge impact on the 

expense.

 If you're, you know, is there a 

requirement that the grower has to do their own 

testing in addition to whatever the seed company 

is providing? That's a potential for additional 

testing, you know, additional testing expense.

 You know, there needs be -- really can 

very dramatically, I think, where different 

conversations about what all would actually be 

tested for and that can drive up the cost of 

testing as well.

 So, I think, as I was saying, I think 

we're open to discussions about making testing 

data available, but we'd have to be mindful as 

programs are developed that there is potential 

costs involved that could add to the testing and 

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to the cost of the seed.

 MS. BEHAR: Okay. Anybody else have 

any questions?

 (NO AUDIBLE RESPONSE)

 MS. BEHAR: Thank you very much. 

Sorry I mispronounced your name.

 Next up is Francis Thicke, with 

Elizabeth Miller and Michael Huber on deck.

 Francis, please state your name and 

your affiliation.

 MR. THICKE: Okay, Harriet. My name 

is Francis Thicke. I'm speaking today on behalf 

of the Rural Organic Project which was created to 

bring the organic standards back into line with 

the original vision of the Organic Foods 

Production Act.

 I'm going to focus my comments on the 

origin of livestock rule. Today, we have a 

national crisis in the organic dairy world. Many 

organic dairy farms are going bankrupt in record 

numbers. However, the large CAFO dairies seem to 

have enough capital backing to supply them for 

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organic dairy crisis.

 The family dairy farms where the 

capital management and labor are embodied by the 

family are struggling and going bankrupt. I 

believe that a lot of the blame for this organic 

dairy crisis should be attributed to a loose 

interpretation of the origin of livestock rule.

 Whereby some certifiers are allowing 

continuous transition with conventional cows for 

organic, that has allowed the CAFO dairy industry 

to grow rapidly and dominate organic dairy 

markets.

 Today, we have a two track system. 

Some certifying organizations require all dairy 

animals brought into an organic herd to be 

organic from the last sort of gestation. Other 

certifiers are allowing some organic dairies to 

continuously transition conventional animals to 

organic.

 Even when USDA Office of Inspector 

General in 2013 published an audit report that 

stated that certifying agents were interpreting 

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the origin of livestock requirements differently.

 But some certifiers allow producers to 

continuously transition additional herds to 

organic milk production while others did not 

permit that practice. We all know this is wrong, 

the OIG said that it is wrong. It's time to fix 

it. Between 1994 and 2006, the NOSB made six 

recommendations for dairy and origin of dairy 

animals. By now, we all know what the solution 

is. In its most recent proposed rule of 2015, 

USDA actually had it right, but that rule was 

never finalized.

 The 2015 proposed rule stated, quote, 

once the transition into organic production is 

complete, the producer will not be allowed to 

conduct any additional transitions. After the 

transition, the producer would only be able to 

expand the number of dairy animals or replace 

culinary animals on any dairy farm in two ways.

 One, add dairy animals that had been 

under continuous organic management since the 

last third of gestation. Or, two, transition 

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dairy animals that had already completed the 

transition on another dairy farm. So, this is 

really quite straightforward. The USDA could 

issue a final rule on the origin of livestock 

tomorrow and has the will to do so.

 Actually, I believe the NOP could fix 

this problem simply with a directive to 

certifiers to close this loophole. That would 

probably be the best route given the current 

climate against rulemaking in the administration.

 And, there are precedents for this 

kind of action, actually. In 2014, the NOP put 

out a directive that certifiers could certify 

hydroponic operations even in the absence of any 

standards for hydroponic production.

 And, in 2013, the NOP unilaterally 

changed the rules for sunset process without 

consulting the NOSB or taking public comments. 

So, it would be really very simple and 

straightforward for the NOP to put out a 

directive to all certifiers that continuous 

transition of dairy animals is no longer allowed. 

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 Thank you.

 MS. BEHAR: Thank you, Francis.

 Are there any questions from the 

Board?

 MR. SEITZ: This is Dan. Can you hear 

me?

 MS. BEHAR: Hey, Dan.

 MR. SEITZ: Hi, Francis, thank you for 

that comment. And, I think nearly all of us on 

the Board probably share your concern about the 

inconsistency and lack of enforcement in these 

areas. And, you referenced the actions that the 

NOSB has taken up until now to try to encourage 

stronger enforcement.

 Do you see any steps that the NOSB can 

take as opposed to the NOP at this point? Or, is 

it entirely in the NOP's hands to act on this 

situation? To address this situation?

 MR. THICKE: Well, it's actually in 

the NOP's hands. But, of course, the NOSB can 

continue to prod them on the, you know, the 

squeaky wheel gets the grease kind of thing. 

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 It's very straightforward and I'd 

actually addressed my comments to the NOP and I 

would hope they would do something. Because we 

really have a crisis out here. And, we can do 

something to help that.

 MR. SEITZ: Great, thank you.

 MS. BEHAR: Any other questions? I have 

a question for you, Francis. If the NOP does not 

have a final rule out by 2022 or 2023, what do 

you think the organic dairy landscape will look 

like at that time?

 MR. THICKE: Well, that all depends 

upon how the circles of organic milk goes. Right 

now, we're seeing a trend that were the CAFO core 

organic dairies are growing and new ones are 

starting.

 And, a lot of that is attributed to 

the fact that they can continuously transfer 

animals.

 So, if we don't have this stopped, 

we're going to see a continual growing of the 

CAFO organic dairies and we're going to see a 

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loss of the family organic dairies and it's 

happening very rapidly. It's actually kind of 

scary out here.

 You know, farmers suicides today are 

twice the rate of Veterans, military Veterans. I 

don't know about organic dairy farmers, but I 

presume they aren't immune from that.

 MS. BEHAR: Thank you, Francis. And, 

coming from Wisconsin where there are over 500 

big dairy farms, I very much know that this is a 

crisis. I hear it all the time. And so, I agree 

that the National Organic Program really needs to 

look at this and move as quickly as possible, 

sooner than two or three years from now. Okay, 

next up is Elizabeth Miller with Michael Huber 

and Jim Paskind on deck. Elizabeth, please state 

your name and affiliation.

 MS. ARSENAULT: Harriet, I haven't 

been able to find Elizabeth on the speaker list 

here. I'm not sure if she's with us today.

 MS. BEHAR: Okay. We will come back 

to her later. So, next up is Michael Huber, I 

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believe you have a PowerPoint. And, Jim Paskind 

and Sam Hardin are on deck. Michael, please state 

your name and affiliation. And, there's your 

PowerPoint.

 MR. HUBER: Thank you. My name is 

Michael Huber and I represent ICL Specialty 

Products, Inc. ICL is a manufacturer of food 

additives and specifically phosphates.

 So, today, I will be talking about 

sodium acid pyrophosphate and potassium 

phosphates and the benefits and using them in 

certain applications. And, in addition, more 

detailed comments will be submitted in writing 

through the International Food Additives Council.

 Next slide, please. So, sodium acid 

pyrophosphate has a long history of safe use 

known as grass. It is actually patented in 1938 

specifically for chemical weapons.

 Aside from being the only chemical 

leavening agent listed, it's heat activated 

properties is what makes it really near 

impossible to use other acids in its place. Next 

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slide, please.

 So, here we see photos comparing SAPP 

to citric acid. The cake made with citric acid 

looks like a football. It actually has less 

color and it's a lot more dense, which is -- may 

be fine if you're trying to go for a pound cake, 

or if you like football shaped cakes.

 This is due to the fact that citric 

acid can't really control when its gas production 

occurs. But that mainly is taking place even 

before the product goes into the over. And, 

that's why you need something that will only be 

heat activated like SAPP.

 Next slide, please. So, in biscuits, 

you also see that citric acid doesn't even really 

provide any leavening. And, even gets splits in 

it, although SAPP actually provides a lot of 

leavening and keeps the biscuit structure intact 

so you won't have any splits in the biscuits.

 Next slide, please. And continuing to 

list SAPP, you basically you'll offer 

conventional leavening based products, bakery 

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products such as tortillas, waffles, cakes, and 

baking mixes.

 Next slide, please. By listing 

phosphates like SAPP also have grass status and 

have a long history of use. It is mainly used to 

provide buffering capacity, but has the added 

benefit of providing potassium which is, of 

course, an important nutrient to that.

 The alternate added buffering agents, 

it performs quite well and only in combination 

with citrates, carbonates seem to have a higher 

buffering capacity around pH of 6.5. Calcium 

phosphates also provide for cellular reduction as 

a function pretty much like a sodium phosphate 

would, so you could use them interchangeably.

 Next slide, please? With potassium 

phosphates, you could even products whether they 

are cheese based products like mac and cheese, 

they can have dairy beverages and plant based 

beverages and, of course, you get the benefit of 

having potassium rather than sodium, if you 

choose to use that. Next slide? 

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 And, that's it. Thank you and if 

there's any questions I'd be happy to answer 

them.

 MS. BEHAR: Thank you. Are there any 

questions from NOSB members? Okay, thank you very 

much.

 MR. HUBER: Not a problem, thank you.

 MS. BEHAR: Okay, next up is Jim 

Paskind with Sam Hardin and Jessica Gigot, I'm 

really not sure if I'm saying that right, on 

deck. Jim, please state your name and 

affiliation.

 MR. PASKIND: I will. Thanks very 

much for the time.

 My name is Jim Paskind. I'm an 

executive with Salm Partners, LLC. Salm Partners 

is a contract manufacturer. We make sausage. Our 

product portfolio includes many dairy free 

products, including many all natural sausages. 

Our sausage products are made with collagen gel 

as the product casing.

 I'm speaking today in support of the 

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Devro petition to add collagen gel to the 

national list and in alignment with the Handling 

Subcommittee's recommendation. My primary purpose 

today is to summarize the marketplace demand for 

organic sausages in collagen casing. And, 

therefore, the growth opportunity for the entire 

organic meat market.

 Collagen casing sausages have 

basically taken over the fully cooked sausage 

category, transitioning that category from 

sausages stuffed in processed pig intestine as 

the casing. Collagen casing sausage does now 

represent about half of the fully cooked sausage 

category. So, they've proven to be consumer 

preferred.

 Regarding organic sausages, all the 

recipe ingredients, the meats, the seasonings, 

the condiments, are available as organic 

ingredients. The options for the casing, 

however, are much more limited.

 Currently, the only casing option for 

an organic sausage is processed intestines which 

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is included in the national list. So, while the 

sausage category has evolved towards collagen 

casings made from collagen gel, there is no 

opportunity for an organic sausage made with 

collagen gel.

 Specifically, among the potential 

market growth opportunities, collagen gel would 

enable production, for example, of a single 

species organic sausage such as a 100 percent 

chicken -- chicken sausage versus the chicken 

sausage in pig intestine casings. It would also 

provide the pathway to market a kosher organic 

beef sausage product.

 So, the use of collagen gel will 

develop what is now the relatively new category 

of consumer preferred organic sausage. In turn, 

this will directly increase the market for 

organic meats, providing added value to the 

organic livestock grower as well as providing the 

same sort of value to suppliers or other 

ingredients used in organic sausage recipes.

 So, this approval will benefit both 

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the consumer with a consumer preferred product 

and the organic producer community. I appreciate 

the time today to address the group and glad to 

answer any questions.

 MS. BEHAR: Any questions from the 

Board members?

 MR. BRADMAN: Yes, this is Asa 

Bradman. So, one, you know, if we list this under 

606, we have the stipulation that you will use 

only the product is not term or available in 

organic form.

 And, I want to, if you could comment 

on the availability of collagen gel in organic 

form and then also what steps can be taken to 

source organic material to make these -- to make 

the collagen casing?

 MR. PASKIND: Sure. I think it is to 

a great extent or entirely a numbers issue. The 

availability of organically raised animals to 

provide the quantity needed of collagen gel is 

just not available.

 Just considering a couple of the 

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numbers, the -- well, the casing is -- the 

collagen is a very small percentage of the total 

sausage. The corium layer in speaking of beef 

cows and specifically the corium layer of beef 

hides, is a very small percentage of the total 

animal weight.

 So, right now, it's nowhere near the 

availability of organically grown animals to 

provide this. Now, I think part of the benefit of 

approving collagen gel as on the national list is 

to grow the organic meat market, because we will 

grow -- and it can apply beyond sausages, but we 

will grow the market for this type of consumer 

product.

 Therefore, growing the need or 

increasing the need for more -- to raise more 

organic animals. So, we are moving in that 

direction with this approval but a good way to go 

to get to get to the point where organic gel, 

organic collagen from organically raised animals 

exists.

 MR. BRADMAN: Thank you. Something 

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that would be really interesting to me would be 

kind of an analysis that kind of puts the numbers 

on, you know, the availability of organic 

animals, how, you know, what would be the 

geographic distribution that would be needed to 

have actions to their hides and processing and 

then, you know, are there plants available to 

actually process them?

 It just makes it easier to see as kind 

of part of this, you know, almost a business plan 

for what steps can be taken to bring this to an 

organic resource material?

 MR. PASKIND: Sure. So, I understand 

that. So, a review of availability now versus 

demand and what it would take to get to a viable 

level?

 MR. BRADMAN: Yes.

 MR. PASKIND: Yes, understood. I can 

-- we can certainly chase that down and provide 

it. Thank you.

 MR. BRADMAN: Thank you.

 MS. BEHAR: Any other questions? I 

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have a question. Can the collagen gel be kept 

refrigerated or frozen to hold it until there was 

enough of it to then process? Just wondering if 

freezing it might somehow degrade it so it could 

not be like saved up to get enough of it to then 

make the collagen gel. Do you know about the 

processing?

 MR. PASKIND: Sure, I do. I do. The 

collagen gel is currently stored -- it can be 

stored ambient, but it is currently stored and 

refrigerated.

 It does have rather extended 

refrigerated shelf life, not nearly what it would 

be if you could freeze it. In terms of freezing, 

there would be a direct degradation of the 

physical characteristics. The collagen gel is 96 

percent water and 4 percent collagen protein. 

And, forming ice crystals and then attempting to 

thaw that product would cause physical separation 

and entirely eliminate the functionality of the 

gel.

 So, unfortunately, freezing is not an 

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option. But we do refrigerate it and we do have 

rather extended shelf life. But certainly not 

enough to be in a position to, you know, to store 

enough gel to achieve what you're suggesting.

 MS. BEHAR: How long is the shelf life 

in refrigeration?

 MR. PASKIND: I'm sorry?

 MS. BEHAR: How long is the shelf life 

in refrigeration?

 MS. PASKIND: We are -- depending on 

the species, we are in the six month shelf life 

range refrigerated.

 MS. BEHAR: Any other questions from 

the Board? Thank you very much.

 MR. PASKIND: Thank you.

 MS. BEHAR: Sam Hardin is up next with 

Jessica Gigot, I'm saying it like it's French, on 

deck as well as Harold Austin.

 So, Sam, please state your name and 

affiliation.

 MR. HARDIN: Thank you.

 I'm Sam Hardin and I'm speaking this 

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afternoon on behalf of PURE Bioscience. I'm an 

environmental engineer, I work for Clearwater 

Consultants in Mississippi and we have a lot of 

experience in the design and operation of waste 

water treatment plants, predominantly serving 

food processors.

 We also work from the side of 

municipalities in working with industry to 

determine incoming waste loads from cities and 

from industry on that side.

 I understand there's been some 

previous discussion concerning the use of SDC in 

produce processing applications which might 

utilize an onsite zero discharge waste water 

treatment system.

 Now, that is a big umbrella that can 

describe a variety of waste water disposal 

systems. But they all have the one thing in 

common that treated effluent, and I emphasize 

treated, is applied to the ground for further 

treatment and eventual return to ground water.

 So, the treatment part of any zero 

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discharge system is typically going to be either 

aerobic with a small aerator or facultatively 

anaerobic where any available oxygen is used in 

treatment.

 But, for the most part, bacteria are 

grown in the presence of no oxygen and organic 

material which we would consider waste, they 

consider food and they grow biomass.

 Now, SDC is, you know, containing the 

silver ion is -- it complexes quickly with the 

organics in the waste water environment. Both 

the organics present in the raw waste water and 

in the biomass that's grown during treatment.

 What would happen in a treatment 

system locally would be in the -- would observe 

the same mechanics that a municipal large waste 

water treatment system would where basically 

biomass is grown from waste water and is settled 

out and contained within the treatment system. 

And then, the effluent is disposed of elsewhere. 

 In small systems, that sludge 

accumulates and it typically accumulates slowly 

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and then, at some point, it needs to be disposed 

of. The typical method of disposal will be a 

suction truck which will vacuum that sludge out 

and then carry it to a larger treatment facility 

where it is combined with the sludge handling 

operation at a larger facility.

 So, it's basically kind of a 

microbiological system that eventually joins its 

larger counterpart in the form of the eventual 

waste.

 If, you know, following that treatment 

line through, the silver is basically meeting the 

same fate in the small rural septic system that 

it would meet where it discharged directly to the 

larger system in the first place.

 With that, I'll be happy to answer any 

questions about, you know, what I've just talked 

about.

 MS. BEHAR: Are there any questions 

from the Board?

 MR. ELA: Harriet, this is Steve Ela. 

I have a question. 

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 MS. BEHAR: Thank you.

 MR. ELA: So, just to follow on your 

train of thought, you're saying that there would 

be no discharge of the silver to the groundwater, 

that it would be tied up in the sludge like, for 

example, in a septic tank?

 MR. HARDIN: That's correct. But I 

might need to elaborate a little more why it 

wouldn't get to groundwater. Typically, when we 

say groundwater, particularly as it concerns 

public health, we're talking about a significant 

depth that water needs to travel. The level of 

treatment that a typical waste water would get in 

a septic system, we would not think of that water 

as being applied directly to an aquifer being 

used for a public water supply.

 There is further treatment that is 

applied all the way down through the soil column 

until it reaches, you know, a depth where it 

could be used. So, in that line of thinking, yes, 

the vast majority of silver ion will be in the 

form of a salt and be disposed of with sludge. 

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 There would be some level of silver 

that could be expected in the effluent, but in 

thinking about where it's traveling to, where 

there is also an abundance of organic material 

for it to absorb, too, the likelihood that it 

would be mobile enough to travel all the way to a 

groundwater source is not of, you know, great 

concern.

 MR. ELA: Harriet, can I ask a couple 

follow up questions?

 MS. BEHAR: Sure, please do.

 MR. ELA: So, I hear what you're 

saying about depth to groundwater, but we know 

across the country there are areas with very 

shallow water tables.

 So, would this material be restricted 

in those area where there isn't a significant 

depth to groundwater?

 MR. HARDIN: Typically, constituents 

which are of great concern in groundwater 

contamination are mobile in water. In other 

words, they would stay in the ionic form where 

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they would be able to basically hydraulically be 

continuously supplied to the water table.

 In this case, ionic silver would 

simply not be able to survive very long in a 

mobile phase. It would transition quickly to the 

stationary phase. The vast majority or that 

occurring, again, in the treatment system but, 

you know, in the portion that would make it to 

effluent, it would, again, be facing the same 

obstacle in terms of being in contact with a 

complex environment of materials to absorb to and 

to precipitate out of.

 MR. ELA: And, would there -- we know, 

especially with the Food Safety Modernization Act 

now that in some cases, producers field harvested 

and actually being -- having a sanitizer applied 

to it in the field, not necessarily, you know, 

any waste water treatment system being available.

 What would be your issue with that? 

Whether there, you know, there is no waste water 

system, it's just being field applied?

 MR. HARDIN: Well, if you're talking 

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about the processing of harvested produce, are 

you saying, and I'm not an expert in produce 

harvest practices, but are you -- is the idea in 

your question that produce is processed onsite 

using water without treatment available?

 MR. ELA: No, more that it's actually 

processed in the field, it's not run through a 

packing shed. So, in some cases, the sanitizer 

is not being applied to that produce, you know, 

with clean water, but with the sanitizer added, 

but not necessarily as part of the packing house, 

they're actually out in the field itself.

 MR. HARDIN: I understand.

 MR. ELA: And, in that case, then it 

wouldn't be any disposal system available.

 MR. HARDIN: It's my understanding 

that SDC is not approved for that use in the 

first place. So, that would not be an approved 

use for the product.

 MR. ELA: Okay, thank you.

 MR. HARDIN: Yes.

 MS. BEHAR: Okay, is there any other 

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questions?

 MR. GREENWOOD: Yes, Harriet, Rick 

Greenwood.

 MS. BEHAR: Hi, Rick.

 MR. GREENWOOD: I have a question --

 MS. BEHAR: Go ahead.

 MR. GREENWOOD: Hi. I have a question 

for you. I'm very familiar with mercury, another 

metal, and how it gets magnified in the 

environment. Are there any studies that show 

there's accumulation of silver as it goes up the 

food chain that you know of?

 MR. HARDIN: No, I'm not aware of any.

 MR. GREENWOOD: Okay. Because, it 

seems to me, they're very similar in many ways 

and I was just curious how it could end up being 

in higher concentrations even though, you know, 

mercury goes out in very low concentrations 

sometimes but ends up in high concentration in 

animals and other forms of flora and fauna. So, 

I was just curious if you knew of anything.

 MR. HARDIN: I'm not aware of any 

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silver bioaccumulation. And, you know, and I'm 

familiar with what you're talking about and this 

is just a conjecture on my part, with silver 

being, you know, a part of the natural 

environment, there would be every opportunity for 

it to -- for it bioaccumulate in organisms.

 MR. GREENWOOD: Yes, I would assume so 

because mercury is also part of the environment 

from mining and galling and all the other sorts 

of things, ends up in high concentrations. So, 

that was one of my concerns.

 MR. HARDIN: But no, to answer your 

question, I'm not aware of any bioaccumulation 

issues proceeding through the food chain.

 MR. GREENWOOD: Okay, thank you.

 MS. BEHAR: Okay, any other questions? 

Okay, next up is Jessica Gigot and up on deck are 

Harold Austin and Michael Hansen.

 Jessica, please state your name so I 

know if I'm saying it right and your affiliation. 

Jessica, are you there?

 MS. ARSENAULT: Jessica, I see you on 

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the line on a headset, but we're not hearing you. 

Maybe your mic is muted. No, we're still not 

hearing you if you're talking. So, Jessica, if 

you -- are you there?

 MS. GIGOT: Can you hear me?

 MS. ARSENAULT: Yes, we can hear you 

now, great.

 MS. GIGOT: Great. Thank you. Great, 

My name is Jessica Gigot. I own Harmony Fields, 

a small farm in the Skagit Valley of Washington. 

We raise certified organic sheep and herbs.

 Originally, our farm put in full scale 

vegetables and fresh culinary herbs. Since the 

beginning of the farm, we've refocused our goals 

and we have added a sheep creamery and we produce 

sheep milk (Telephonic interference.)

 We are also considering the production 

of organic freshly died culinary individual 

herbs.

 I believe in the organic label and the 

National Organic Program and want to make sure 

that it continues into the future. I know that a 

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lot of hard work and that dedication can help to 

create and implement this important program and I 

don't want to lose confidence in customer support 

of all that the certified organic label has come 

to represent in this country.

 I'm also here on behalf of the Organic 

Farmer Associates as a member of the circle 

(Telephonic interference.)

 This has been the second year in this 

industry. This organization represents the 

farmer's life. And I hope that organic 

agriculture gains more visibility, interest, and 

(Telephonic interference.)

 Key aspects and priorities that are 

most important to me are natural, organic program 

integrity, the (Telephonic interference.) 

hydroponic organic production.

 I do not want to (Telephonic 

interference.) program and its values. And, 

continue our organic community for Washington 

State and I want us to (Telephonic interference.) 

move ahead. 

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 National Organic Program rules needs 

to be enforced and that all practitioners could 

(Telephonic interference.) in their sectors.

 While actually hydroponic vegetable 

and herb production may be included in the 

(Telephonic interference.) food production, I do 

not believe that these (Telephonic interference.) 

the core values of organic production.

 Also, organic producers that are 

embedded in their communities and driven by 

(Telephonic interference.) to not have to take 

(Telephonic interference.) these facilities.

 Organic production is pretty big in 

this product. I can't say today whether that 

product is good or bad. I would say personally 

that it is not organic.

 And (Telephonic interference.) you 

offer inflow and output (Telephonic 

interference.) impacts the viability of this 

(Telephonic interference.).

 I urge the National Organic Standards 

Board to, number one, help the National Organic 

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Program to move the (Telephonic interference.) 

and recommendations and not allow for the 

(Telephonic interference.) hydroponics to the 

federal rule as recommended nine years ago.

 I also felt that the National Organic 

Program to fully implement the enforcement rule 

of putting (Telephonic interference.) organic and 

in products.

 If I have any time left, I'd like to 

mention as a small (Telephonic interference.) 

we're actually moving forward with the animal 

welfare certification, listed organic 

certification. At this time (Telephonic 

interference.) requirement. And, I'm curious 

about (Telephonic interference.) more dairy or 

micro dairy operations that are (Telephonic 

interference.) Thank you.

 MS. BEHAR: Thank you. Any questions 

from the Board?

 MS. OAKLEY: This is Emily, it's not 

a question, it's just a comment. I just want to 

thank you for speaking as a farmer representative 

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on that. I appreciate hearing from farmer 

voices. So, thank you.

 MS. GIGOT: Thank you. 

 MS. BEHAR: Any questions? I have a 

question. Do you think your customers care if 

their vegetables are grown hydroponically or in 

soil? Do they have a preference? And, have it 

be labeled as organic?

 MS. GIGOT: I think there's been a lot 

of different types of customers. So, the 

customers that I see at the farmer's market or 

the (Telephonic interference.) are either 

interested in knowing the farmer, knowing the 

(Telephonic interference.)

 I think the customers that (Telephonic 

interference.) be aware of their (Telephonic 

interference.) organic fruit (Telephonic 

interference.)

 But I feel like there'll be more 

opportunities for soil farms like ours to succeed 

economically if certain (Telephonic 

interference.) to buy organic or (Telephonic 

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interference.)

 MS. BEHAR: Thank you. Any other 

comments from the Board? Okay, we're going to 

move ahead to Harold Austin, an NOSB alumni, and 

on deck is Michael Hansen and he will be our last 

speaker unless we go back and find Elizabeth 

Miller. Okay, Harold, please state your name and 

affiliation.

 MR. AUSTIN: Thanks, Harriet. Good 

morning, Harold Austin, Director of Orchard 

Administration for Zirkle Fruit Company. I'm an 

organic consumer and past member of the NOSB, as 

you mentioned. And, I'm the current Chair of the 

Northwest Horticultural Council Science Advisory 

Committee and also their Organic Subcommittee 

Chair.

 I had intended to be at the Seattle 

meeting in person, but unfortunately, got a 

family medical issue that is going to have to 

take and be dealt with. So my plans have had to 

change.

 But I do appreciate the opportunity to 

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speak to each of you today via the webinar 

process even though it doesn't allow me to see 

each of your bright, smiling faces up close and 

in person. Maybe at the fall meeting.

 I hope that you will all enjoy your 

stay in the Pacific Northwest, home to some of 

the longest certified organic farms in the 

nation.

 We are proud of where we have come 

from and we look forward to what the future had 

in store for our organic stakeholders and our 

community as a whole.

 I'd like to thank you each for all of 

your service in the organic community and various 

stakeholders that you each represent, the time 

and the energy that you have each spent with the 

preparation of the materials is greatly 

appreciated.

 I have provided written comments in 

support of the continued listing for all of the 

materials currently under sunset review by the 

Crop Subcommittee, especially hydrogen peroxide, 

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horticultural oils, pheromones, potassium 

bicarbonate, magnesium sulfate.

 These are essential materials for 

organic tree, fruit, berry, grape growers, not 

only here in the Northwest, but where ever these 

types of organic crops happen to be grown.

 I've also provided written comments in 

support of all of the materials listed under 

sunset review by the Handling Subcommittee, 

especially for activated charcoal, hydrogen 

peroxide and peracetic acid.

 These are important materials on the 

handling process whether it be in our organic 

wine grapes, organic blueberries, or in organic 

apple, cherry, and handling facilities.

 I have also provided written comments 

on the assessing and cleaning and sanitation 

materials discussion document.

 It's imperative that both of our 

organic crop producers and handlers have the much 

needed access to the key essential materials 

currently allowed for use as listed on the 

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national list as either a sanitizer or as a 

disinfectant.

 Having adequate flexibility to alter 

the materials for the resistance management or 

use the appropriate material in either the dry or 

the wet side of our organic handling facilities 

critically important.

 Using the long systems approach or the 

materials I mentioned can also actually be more 

detrimental for pathogen control and doing 

nothing at all.

 At the end of the day, we have both 

the legal and moral obligation to provide the 

safest organic product to the consumer that we 

possibly can provide.

 Again, I wish to thank all of you for 

all that you do for the organic community as a 

whole. I know it takes a lot of time and energy 

away from your jobs, away from your families to 

be a part of this process. And, I'm eternally 

grateful that you all are there repressing our 

organic community. 

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 Thank you.

 MS. BEHAR: Okay, any comments from 

Board members? Questions? Okay. All right, 

thank you, Harold.

 MR. AUSTIN: Thank you.

 MS. BEHAR: And, just to let you know 

that we are considering all sanitizers and 

actually hoping that our review will make an even 

a couple of sides within areas with our gaps.

 But just help us in our overall review 

when new products come to us where they sit in 

the constellation of what we already have versus 

what we need.

 MR. AUSTIN: Thank you.

 MS. BEHAR: Okay, and last and not 

least is Michael Hansen. Michael, please state 

your name and affiliation.

 MR. HANSEN: First, can people hear 

me?

 MS. BEHAR: Yes.

 MR. HANSEN: Okay. My name's Michael 

Hansen. I'm a senior scientist at Consumer 

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Reports. And, I'll be trying to make three 

points, you know, from our written comments.

 First, for the Materials and GMO 

Subcommittee, we agree that the proposed 

definitions of both cisgenesis and intragenesis 

for the excluded methods terminology chart.

 We are supporting those because 

they're basically similar to the definitions that 

we suggested last fall.

 In terms of transbovines, we also 

support adding transbovines develop be of use of 

in vitro and nucleic acid techniques to the 

excluded method terminology chart since they're 

clearly not natural because they were constructed 

in vitro and then inserted into an organism.

 However, and this -- there's a mistake 

in our written comments. We're saying we don't 

support listing of transbovines developed by 

environmental stress on the table on not excluded 

methods because we don't think natural occurring 

transbovines are really -- they're not a method.

 So, they're naturally -- there are 

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different things that cause them to move around, 

different forms of stress, whether it's 

environmental stress or chemical or radiation.

 And, those really aren't methods. So, 

I don't think we should even be considering them. 

So, and for the same reason, we think NOSB should 

drop the decision on whether transprotons that 

whether they're -- the use of chemical or 

radiation that that would make that use of 

transbovines and exclude nothing.

 And, again, we're saying that since 

transbovines are natural, they really shouldn't 

be. They're not really a method. 

 It's different if you're making them 

in the lab and inserting them.

 And then, on a second point for the 

Livestock Committee, we're glad that they have 

begun work on vaccines and organic. 

 And, of the three proposed regulatory 

solutions, we support the third one which is to 

change 2015-105e basically to read that excluded 

methods except for vaccines provided that there 

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are no commercial available vaccines that are not 

products to excluded methods to prevent that 

specific animal to ease their health problem.

 We're also urging NOP to develop a 

list of which veterinary vaccines have not been 

produced using excluded methods. And, I think 

this can start, as we said in our comments, by 

the updating of this APHIS's current list of 

veterinary biologic including vaccines product 

catalogues.

 There's already enough information in 

there to tell that a bunch of the vaccines are 

GMO. And, I think with a little bit more work, 

that can be done.

 And then, finally, for the Handling 

Subcommittee, we oppose the recommendation to 

accept petition for silver dihydrogen citrate 

because we believe it poses a risk of increasing 

resistance to antibiotics and silver based 

medications used in wound management.

 We also don't think the technical 

review has not shown that silver dihydrogern 

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citrate is essential for organic production and 

handling.

 And, all right, I'll stop there. If 

you want to ask questions about dihydrogern 

citrates in response to some of the previous 

folks, I can talk about that.

 MS. BEHAR: Okay. Any questions from 

the Board?

 MR. BRADMAN: Yes, this is --

 MS. BEHAR: I said, go ahead, Asa.

 MR. BRADMAN: Okay, sorry. I -- yes, 

yes. You mentioned SDC and that the potential 

for increased resistance -- antibiotic 

resistance. And, I've been looking for 

information on cost resistance, the cost, you 

know, species, and you know, is it SDC versus 

other antibiotics.

 And, you know, I work with people who 

are very steeped in issues around antimicrobial 

resistance, antibiotic resistance, and I haven't 

found anything to suggest that SDC would increase 

resistance to other frontline antibiotics. And, 

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if you could perhaps send us some, that would 

great.

 MR. HANSEN: Yes, I actually, I think 

the point is is that there is the study from 2015 

also clearly showed that for, at least for 

Klebsiella pneumonia and Enterobacter cloacae 

that the resistance to silver was high enough 

that the level of silver in this -- the silver 

impregnated burn and wound dressings, they could 

still continue to grow.

 And so, those findings, they provide 

the first evidence of clinical bacteria that are 

capable of expressing silver resistance at high 

levels that could significantly impact wound 

management.

 And, since there are many different 

types of these silver impregnated wound 

dressings, that nine of them tested two of them 

max or silver and duplex ad, both contained 

dianic silver and showed no reduction in bacteria 

levels after exposure to very high silver 

concentration. 

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 So, there clearly is that is the 

concern, that it could select for resistance and 

become clinically significant bacteria that could 

adversely impact wound management.

 MR. BRADMAN: Yes, that I understand. 

What I'm -- so there's been an implication in 

some studies that we're also talking about 

resistance to other antibiotics. And, that's 

where I saved my -- and I'm not too --

 MR. HANSEN: So, yes, you know, part 

of the issue there is they should do more 

metagenomics and stuff because they often have 

found silver resistance genes, for example, in 

MRSA and other things.

 And, even though the genes are there, 

in those cases, they remain sensitive for low 

silver concentrations. And, that was just that 

one MRSA.

 But it is known that they're often 

found together. Right? So, that the first time 

silver was really discovered on this plasma PMG101 from Salmonella which that was resistance to 

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silver, other heavy metals and multiple 

antibiotics.

 Now, you can have the genes there, 

whether they're being expressed as high enough 

levels to cause a concern, that's a different 

issue. 

 But the fact that in main management 

where it's used, it's clear evidence that the 

ionic silver and selected for enough resistance 

that the bacteria, even at high concentrations 

weren't even -- their growth wasn't even 

decreased.

 So, that was, you know, part of the 

main risk we see.

 Now, the fact that there is a linked 

gene all over the place, you know, I reference 

that paper from 2005 that had two silver 

resistant strains of Enterobacter cloacae from 

infected genes, the nose drops resistant to 

ampicillin, erythromycin, and clindamyocin.

 So, you know, more work needs to be 

done on that. I think the main concern is with 

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the gene management. But clearly, these genes 

are often linked together.

 MR. BRADMAN: Okay, thank you.

 MS. BEHAR: Okay, Emily?

 MS. OAKLEY: No, Asa asked what I was 

going to ask about. So, thank you.

 MS. BEHAR: Oh, okay.

 Okay, any other questions?

 MR. HANSEN: Can I say one thing?

 MS. BEHAR: Sure, I wanted to ask you 

another question, Michael.

 MR. HANSEN: Oh, okay.

 MS. BEHAR: But if you -- but on a 

different topic. So, on silver Dihydrogern 

citrate, go ahead.

 MR. HANSEN: Yes, and that someone had 

said that there's no evidence that there could be 

any bioaccumulation, I was just sitting here and 

Googling and I've already found an article from 

2013 called Bioaccumulation and toxicity of 

silver nanoparticles and silver nitrate to the 

soil arthropod Folsomia candida. And, I'll just 

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read the last sentence.

 It says, bioaccumulation factor was 

higher for silver nitrate an average 5.64 than 

for silver nanoparticles, 1.12). These findings 

indicate that silver ions are more toxic than 

Ag-nanoparticles and silver nanoparticles and 

have a potential -- higher potential to 

accumulate in Folsomia candida.

 And, if you look, there's other 

studies out there that are looking into the 

biomagnification issue.

 So, clearly, there is something here. 

If I can find it in, you know, five minutes, 

people, if they did more study on that, you could 

dive into that issue more deeply.

 So, there is evidence that there is 

bioaccumulation.

 MS. BEHAR: Okay, thank you.

 So, I have a question going back to 

the excluded methods and the naturally occurring 

transprotons. So, you're saying that's not 

really a method? 

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 But I would think that a radiation in 

a laboratory that would cause the transproton, 

why would that not be a method? Or would that be 

considered induced mutagenesis?

 MR. HANSEN: Yes, that's right. Using 

radiation or chemicals to do this induced 

mutagenesis, it's going to be hard to figure out 

how much of those mutations are being caused by 

transbovines moving around internally as opposed 

to chromosomal breaks or other things that we 

know radiation does and that some of the chemical 

mutagens do.

 So, rather than try to tease those 

out, we are not saying, don't look at the issue 

of these induced mutations, just don't 

necessarily consider there's no need to look at 

transprotons for that because you're still going 

to be trying to determine whether, you know, 

radiation or, you know, chemicals caused too much 

mutation.

 MS. BEHAR: Yes --

 MR. HANSEN: And, again, I'd separate 

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out -- I don't see any study yet which would be 

able to separate out from all the mutations 

caused, for example, by radiation, how much is 

due to the breakthrough to the radiation versus 

internal movement of transprotons.

 MS. BEHAR: Okay. So, then the way 

that we're looking at it in putting some of this 

into the induced mutagenesis basket is the way we 

should go?

 MR. HANSEN: Yes, you know, right. 

So, the only thing that really needs to be 

considered is when it's constructed outside the 

cell, then it's clearly a not natural method and 

that's why those transprotons, yes, those -- that 

is a method because those were developed to 

engineer animals.

 But the naturally occurring ones, I 

just don't see them as a method. So, you know, 

you look at issues such as radiation and 

chemicals and just determine whether the 

mutations that are causing, whatever the 

mechanism. And there might be multiple ones with 

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these protons. That's a decision that the 

committee's going to have to make. And that 

raises some sticky issues, I think, for marketing 

that need to be discussed.

 MR. BEHAR: Okay. Okay, I'm not sure, 

Michelle, did you find Elizabeth Miller?

 MS. ARSENAULT: I don't see the number 

she provided on the list, but, Elizabeth, are you 

on the line with us? No? Okay.

 MS. BEHAR: Okay, everyone. We, 

again, thank you so much for being with us for 

this webinar, for beginning the public comments 

for the spring 2019 NOSB meeting. We greatly 

appreciate the Board members and all the 

participants.

 And, for those of you who will see us 

in Seattle next week, let's hope that it's not 

raining or we bring umbrellas.

 So, with that, Michelle, I think we 

can close, is that right?

 MS. ARSENAULT: Yes, that's excellent. 

Thank you, Harriet. Thank you, everyone, for 

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participating. I have to say this is probably 

the quietest webinar I've ever been on, so I 

appreciate everyone keeping themselves muted or 

quiet.

 Thank you so much, we'll see you guys 

next week.

 MS. BEHAR: Okay.

 (Whereupon, the above-entitled matter 

went off the record at 2:27 p.m.) 

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A

A-dae 1:17 11:2,4 

able 7:20 31:8 47:17 

51:19 68:1,4 92:2 

above-entitled 2:14 

94:8 

absence 48:14 

absolutely 13:15 32:16 

33:6 

absorb 67:5 68:11 

abundance 67:4 

accept 8:5 84:17 

access 79:21 

accumulate 90:8 

accumulates 64:22,22 

accumulation 70:11 

achieve 38:10 62:4 

acid 24:6,13,17,17,18 

24:20 26:6,13,13,16 

26:20 27:7 36:17 

52:10,15 53:3,3,9,15 

79:11 82:12 

acids 24:7 52:22 

act 4:14 45:16 49:17 

68:14 

action 48:12 

actions 49:12 60:6 

activated 52:20 53:13 

79:10 

activities 12:11 

actual 21:20 

ad 86:19 

add 44:22 47:20 56:1 

added 16:6 34:4 54:6,9 

57:18 69:10 72:15 

adding 38:11,15 82:11 

addition 24:11 28:17,21 

29:2 31:19 32:9 44:10 

52:12 

additional 17:14 19:2 

25:9,19 27:12 28:16 

31:1 33:8 44:2,5,11 

44:12 47:3,16 

additives 24:2 52:8,14 

address 29:9 41:4,9 

49:18 58:3 

addressed 16:21 50:2 

addressing 17:17 

adequate 17:17 26:15 

80:3 

administration 48:10 

77:11 

advance 13:19 14:4,13 

advancing 13:12 38:4 

advantage 31:7 

adversely 87:4 

Advisory 1:22 4:14 

77:14 

aerator 64:2 

aerobic 64:2 

affiliation 23:21 28:8 

39:18 45:10 51:17 

52:3 55:12 62:20 

71:20 77:8 81:17 

afraid 13:17 

afternoon 3:17 12:7 

28:12 63:1 

Ag-nanoparticles 90:6 

agencies 30:19,22 

agenda 4:18 

agent 52:20 

agents 46:22 54:9 

ago 11:13 75:4 

agree 51:11 82:4 

agriculture 1:1 73:12 

ahead 8:2 70:6 73:22 

77:4 85:10 89:15 

algae 12:11,21,22 14:15 

14:18,21 15:6 16:6 

17:20 19:10 20:8 

27:17 

algal 15:9 

alginic 26:13,13,16,19 

27:7 

algo 15:14,22 17:1 

alignment 56:2 

alleged 29:6 

Allison 11:20,20,22 

12:3,9 13:10 

allow 31:13 47:2 75:2 

78:2 

allowed 23:2 26:8 40:19 

46:10 47:15 48:22 

79:22 

allowing 46:8,17 

alter 80:3 

alternate 54:9 

alternative 26:3 31:10 

alternatives 24:19 

alumni 77:4 

ambient 61:10 

amendment 16:18 18:4 

18:5 

America 40:2 

American 39:20 

amount 22:1 23:4 44:2 

ampicillin 88:20 

AMS 42:7 

anaerobic 64:3 

analysis 60:2 

ancillary 25:9,19 

animal 59:6 75:11 84:3 

animals 46:15,18 47:9 

47:18,19,20 48:1,22 

50:19 58:19 59:8,17 

59:20 60:4 70:20 

92:16 

announce 5:20 

answer 27:2 36:19 55:2 

58:4 65:16 71:12 

antibiotic 85:13,20 

antibiotics 84:19 85:17 

85:22 87:8 88:2 

antimicrobial 30:17 

31:9,14,15 33:17 

35:18 37:21 38:3,19 

39:3 85:19 

antimicrobials 29:2,18 

29:21 30:6,7 32:18 

33:10,13 34:10 35:4 

Anybody 45:2 

anymore 2:11 

APHIS's 84:8 

apple 79:15 

applications 31:4 35:14 

35:15 37:18 52:12 

63:13 

applied 19:9 63:20 

66:15,18 68:16,21 

69:9 

apply 59:12 

appreciate 3:1,11 4:1 

6:16 19:20 58:2 76:1 

77:22 93:14 94:3 

appreciated 78:18 

approach 32:10 80:8 

appropriate 80:5 

approval 57:22 59:18 

approvals 35:7 36:14 

approve 28:21 29:13 

approved 35:9,11,12 

40:14 69:17,18 

approving 59:10 

April 1:7 9:3 11:15 

16:20 

aquifer 66:15 

area 14:12,20 67:17 

areas 21:11 49:12 

67:14 81:9 

ARSENAULT 1:22 2:3 

2:17 7:11 9:11,15,22 

10:3,6,9,13,15,17,20 

11:1,4,7,10 13:10,16 

13:21 16:9,13 51:18 

71:22 72:6 93:7,21 

arthropod 89:22 

article 89:19 

Asa 1:13 9:16,16 27:6 

58:7 85:10 89:5 

Ashley 1:18 11:8,10 

Aside 52:19 

asked 89:5 

aspects 16:16 73:14 

asserting 42:8 

assessing 79:17 

assist 4:16 

Associates 73:7 

association 24:2 39:21 

assume 71:7 

ASTA 39:21 

Atlanta 21:9 

Atlantic 12:12 

attempting 61:18 

attorney 28:13 

attributed 46:6 50:17 

Attwood 11:21 23:18 

28:6,9,11,12 32:13 

34:1 35:4 36:19 37:3 

37:15 

AUDIBLE 20:12 27:22 

34:18 39:11 42:15 

45:4 

audio 8:19 

audit 46:21 

Austin 62:18 71:18 77:4 

77:9,10 81:5,14 

automatically 13:12 

availability 41:2 58:13 

58:19 59:8 60:3,14 

available 26:16 29:2 

34:9 42:10 44:20 

56:18 58:10,21 60:7 

64:3 68:18 69:5,15 

84:1 

average 90:3 

avoid 34:22 

aware 24:12,19 26:10 

26:21 70:13,22 71:13 

76:16 

B

back 9:20 22:8 39:13 

45:14 51:21 77:6 

90:19 

background 3:3,10 

5:13 8:10 38:16 

backing 45:22 

bacteria 29:22 30:5 

35:2 64:5 86:12,20 

87:3 88:10 

bad 74:15 

Baird 1:12 9:7,10 

bake 26:9 

bakery 53:22 

baking 25:1 54:2 

bankrupt 45:20 46:4 

based 31:2 36:13 53:22 

54:18,19 84:19 

baseline 43:8 

bases 31:18 

basically 53:21 56:9 

64:17 65:7,12 68:1 

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basis 27:8 28:22 29:12 

basket 92:8 

beds 21:10 

beef 57:13 59:3,4 

beer 24:19 

beginning 72:14 93:12 

begun 83:18 

behalf 28:14 45:12 63:1 

73:6 

Behar 1:10,12 5:3,7 

9:14 11:19 12:3,6 

16:14 17:4,7 18:21 

20:10,13 22:9 23:6,10 

23:17 27:4,15,19 28:1 

28:4,10 31:22 34:16 

34:19 36:15 37:2,6 

39:8,12 42:13,16 45:2 

45:5 49:2,7 50:7 51:8 

51:21 55:4,8 58:5 

60:22 62:5,8,13,16 

65:19 66:1 67:11 

69:22 70:4,6 71:16 

75:18 76:4 77:2 81:2 

81:6,15,20 85:7,10 

89:4,7,10,13 90:18 

91:21 92:6 93:5,10 

94:7 

believe 11:17,22 46:5 

48:6 52:1 72:20 74:7 

84:18 

benefit 15:16 54:7,20 

57:22 59:9 

benefits 12:15 29:3,14 

30:15 31:8 52:11 

Berit 11:20 23:17,20,22 

28:2 

berry 79:4 

best 15:21 35:19 41:9 

48:9 

better 31:13 34:10 

beverages 54:19,20 

beyond 15:13 16:19 

17:15 18:4 59:12 

bicarbonate 79:2 

big 51:10 63:16 74:13 

bioaccumulate 71:6 

bioaccumulation 71:1 

71:13 89:18,20 90:2 

90:17 

bioengineered 42:9 

bioengineering 42:8 

biologic 84:9 

biomagnification 90:11 

biomass 64:8,13,18 

Bioscience 28:14 29:8 

63:1 

biscuit 53:18 

biscuits 53:14,19 

bit 3:7 84:13 

blame 46:5 

blueberries 79:14 

Board 1:3,22 2:21 3:20 

4:4,12 5:3 6:1,9,12,16 

9:5 11:13,14 17:5 

20:11 26:8 27:4,20 

32:1 39:9 42:14 49:4 

49:10 58:6 62:14 

65:20 74:22 75:19 

77:3 81:3 85:8 93:14 

Board's 4:7 

borne 31:16 33:2,9 

Bradman 1:13 9:16,21 

27:6,14 58:7,8 59:22 

60:17,21 85:9,11 87:5 

89:3 

breads 25:17 

breaks 91:10 

breakthrough 92:4 

breeding 40:1 

brief 9:20 

bright 78:3 

bring 4:22 45:14 60:11 

93:18 

bringing 18:14 

Briones 11:2 

British 22:16 

broad 19:19 20:20 

brought 46:15 

buffering 54:6,9,12 

bugs 37:22 

BUIE 1:13 

bunch 84:12 

buried 19:1 

burn 86:9 

business 60:10 

businesses 41:11 

busy 7:6 

buy 76:22 

C

CAFO 45:21 46:10 

50:14,22 

cake 53:3,6 

cakes 53:7 54:1 

Calcium 54:12 

call 3:3,14 4:2 7:9,10 

8:18 9:4,6 19:21 

called 11:12 89:20 

Canada 12:12 21:9 

22:18 

Canadian 15:10,11 

candida 89:22 90:8 

capable 26:7 86:13 

capacity 54:6,12 

capital 45:22 46:3 

capture 13:3 

carbonates 54:11 

care 43:13 76:5 

carping 37:11 

carry 65:4 

case 68:3 69:14 

cases 68:15 69:8 87:16 

casing 55:21 56:5,8,12 

56:12,19,21 58:16 

59:1 

casings 57:3,11 

catalogue 41:18 

catalogues 84:10 

catch 20:20 22:2 

categories 12:20,22 

14:16 

category 13:1 56:10,10 

56:14 57:2,15 

cause 61:19 83:1 88:5 

91:2 

caused 91:8,19 92:3 

causing 92:21 

caveat 23:2 

cell 92:13 

cellular 54:13 

centuries 37:22 

certain 43:10 52:12 

76:21 

certainly 32:14,19 34:1 

34:6 36:20 37:4 38:4 

60:19 62:2 

certainty 30:18 

certification 19:9 75:12 

75:13 

certified 72:11 73:4 

78:7 

certifiers 46:8,17 47:2 

48:8,13,21 

certify 48:13 

certifying 46:14,22 

cetera 41:10 

chain 33:14 70:12 

71:14 

Chair 5:3,6 77:13,16 

chairing 5:5 

Chairperson 1:10,12 

7:21 

chance 37:7,14 

change 18:13 77:21 

83:21 

changed 48:17 

Chapman 1:14 10:1,2 

characteristics 61:16 

charcoal 79:10 

chart 12:19 14:7,17 

82:6,13 

chase 60:19 

chat 7:21 8:2,4,6 

cheese 54:18,18 

cheeses 25:7 

chemical 26:7 52:18,19 

83:3,8 91:11 

chemicals 91:6,19 

92:20 

cherry 79:15 

chicken 57:10,10,10 

chime 5:11 

chlorine 36:16 

choose 54:22 

chromosomal 91:10 

circle 73:7 

circles 50:13 

cisgenesis 82:5 

cities 63:9 

citrate 28:17 34:4 84:17 

85:1 89:15 

citrates 54:11 85:5 

citric 24:6,7,13 53:3,3,8 

53:15 

clarified 20:3,7 

clarifying 20:2 

clean 69:10 

cleaning 79:17 

clear 88:8 

clearly 82:14 86:5 87:1 

89:1 90:12 92:13 

Clearwater 63:2 

climate 48:10 

clindamyocin 88:20 

clinical 86:12 

clinically 87:3 

cloacae 86:6 88:18 

close 5:2 48:8 78:3 

93:20 

Coast 22:18 

Coli 30:1 

collagen 55:20 56:1,5,8 

56:12 57:2,3,5,7,14 

58:13,16,20 59:2,10 

59:20 61:1,6,9,16,17 

colleagues 4:20 

color 53:5 

Columbia 22:16 

column 66:18 

combination 54:10 

combined 65:5 

combining 25:13 

come 9:20 22:8 51:21 

73:4 78:9 81:11 

comes 21:4 

coming 51:9 

commenced 1:9 

comment 3:21 4:3 5:18 

6:6 16:19 23:7 40:6 

49:9 58:12 75:21 

commenting 28:14 

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38:14 40:11 41:15 

42:17 45:17 48:18 

50:2 52:13 77:3 78:19 

79:7,16 81:2 82:2,17 

84:7 93:12 

commercial 84:1 

commercially 15:17 

committee 4:14 18:15 

18:16 77:15 83:17 

committee's 93:2 

commodities 13:4 

common 63:19 

communities 74:10 

community 7:3 58:2 

73:20 78:12,14 80:17 

80:22 

companies 39:22 

company 44:10 77:11 

comparable 14:19 

26:10 

comparing 53:2 

complete 47:15 

completed 48:1 

completely 22:6 

complex 68:11 

complexes 64:10 

compliance 36:7 

component 32:17 

concentration 70:19 

86:22 

concentrations 70:17 

70:18 71:10 87:17 

88:10 

concern 19:1 33:12 

34:2,7 35:22 36:3 

37:10 39:1,4 40:17 

49:10 67:8,20 87:2 

88:5,22 

concerned 19:8 39:6 

42:4 

concerning 63:12 

concerns 29:5,10 32:11 

40:11 66:10 71:11 

conclude 42:12 

concluded 31:5 

condiments 56:18 

conduct 31:13 47:16 

conducted 30:10 

confidence 73:3 

conform 16:4 

conjecture 71:3 

consider 30:16 31:8 

64:7,8 91:16 

consideration 40:22 

considered 16:17 18:10 

21:5 38:7 40:16,21 

42:6 91:4 92:12 

considering 58:22 

72:17 81:7 83:5 

considers 30:14 

constellation 81:12 

constituents 67:19 

constructed 82:14 

92:12 

consult 4:9 

Consultants 63:3 

consulting 48:18 

consults 30:21 

consumer 56:14 57:16 

58:1,1 59:13 77:12 

80:14 81:22 

consumers 25:18 

Consumers' 37:8 

contact 33:19 68:10 

contained 64:19 86:19 

containing 64:9 

contaminated 43:6 

contamination 36:10 

67:21 

continual 50:21 

continue 16:1 38:6 

40:11 41:20 42:1 

49:21 73:20 86:10 

continued 25:4,11 

78:20 

continues 72:22 

continuing 53:20 

continuous 46:9 47:21 

48:21 

continuously 46:18 

47:3 50:18 68:2 

contract 43:9,16 55:17 

contribute 12:15 15:8 

16:1 

contributed 15:11 

contributes 14:8 

contributing 15:1 38:18 

control 24:8 53:9 80:10 

controlled 30:13 32:6 

conventional 43:17 

46:9,18 53:22 

conversation 8:10 

conversations 44:15 

cooked 56:9,13 

core 50:14 74:8 

corium 59:3,4 

correct 66:7 

cost 42:19 44:16 45:1 

85:15,15 

costly 25:3 32:19 

costs 44:22 

Council 24:2 52:14 

77:14 

counterpart 65:9 

country 67:14 73:5 

couple 2:8 7:19,22 

11:13 38:8 58:22 67:9 

81:9 

course 49:20 54:8,20 

cover 7:19 40:4 

covered 7:18 14:21 

cows 46:9 59:4 

creamery 72:15 

create 73:2 

created 45:13 

crisis 45:19 46:1,6 50:4 

51:11 

criteria 40:12,14 

critical 25:6 

critically 80:7 

crop 19:11 43:4 78:22 

79:20 

crops 40:4,4 41:21 42:3 

42:6,10 79:6 

crystals 61:18 

culinary 47:19 72:13,18 

cultures 25:12,14,15,20 

curious 70:16,21 75:14 

current 13:2 48:9 77:13 

84:8 

currently 16:2 17:12 

19:4 22:9 31:3 56:21 

61:9,10 78:21 79:22 

customer 73:3 

customers 41:13 76:5 

76:10,11,15 

cut 22:19 24:11 

cutter 21:19 

cutting 21:19 22:10 

D

dairies 45:21 46:17 

50:15,22 51:1 

dairy 25:7,12,15,16,20 

45:19,20 46:1,2,6,10 

46:11,14 47:8,8,18,19 

47:20 48:1,2,22 50:10 

51:6,10 54:19 55:18 

75:15,16 

damage 22:1,2 26:21 

Dan 1:18 11:5 23:8 49:5 

49:7 

data 44:20 

Dave 1:16 10:15,17 

day 3:19 7:6 23:16 

80:12 

de 1:14 10:4,5 

dealt 77:20 

Deborah 11:21 23:18 

28:6,6,8,12 34:17 

decades 21:11 

decision 83:7 93:1 

deck 5:20 11:21 23:19 

28:7 39:14,16 45:8 

51:16 52:2 55:11 

62:18 71:17 77:5 

declarations 42:5 

decreased 88:12 

dedication 73:1 

deeply 90:15 

defense 41:4 

definition 18:10 21:6 

definitions 82:5,8 

degradation 61:15 

degrade 61:4 

delay 29:16 

deliver 43:3 

demand 56:4 60:15 

DeMarchi 23:18 28:7 

39:15,19 43:22 

demonstrated 38:20 

dense 53:5 

DEPARTMENT 1:1 

depending 35:17 62:10 

depends 35:16,20 

36:11,12 50:12 

depth 66:12,19 67:13 

67:18 

describe 63:17 

design 63:4 

destructive 16:18 

detailed 52:13 

determine 63:9 91:18 

92:20 

detrimental 80:10 

develop 37:22 57:15 

82:11 84:4 

developed 44:21 82:18 

92:15 

developing 38:2 

Devro 56:1 

dial 8:15 

dianic 86:20 

died 72:18 

difference 43:16 

different 21:14 35:6,7 

36:3 40:7 44:14 76:10 

83:1,2,14 86:16 88:5 

89:14 

differently 47:1 

difficult 22:7 30:3 

dihydrogen 84:17 

dihydrogern 28:16 34:4 

84:22 85:4 89:14 

DiMarchi 39:20 

dip 35:15 

direct 61:15 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
98 

direction 59:18 

directive 48:7,13,21 

directly 15:15 57:17 

65:14 66:15 

Director 1:21 3:13 

77:10 

discharge 63:14 64:1 

66:4 

discharged 65:14 

disclosure 42:8 

discovered 87:21 

discussed 93:4 

discussion 17:19 18:15 

18:18 63:12 79:18 

discussions 44:19 

diseases 41:4 

disinfectant 80:2 

displayed 8:13 

disposal 29:5 32:20 

63:17 65:2 69:15 

disposed 64:20 65:1 

66:22 

disproportionately

15:1 

distribution 40:1 60:5 

dive 3:15 90:15 

Division 1:21 4:21 

docket 29:9 

Dockter 11:21 23:18,22 

24:1 27:10,18 28:3 

document 17:19 18:3 

42:18 79:18 

documents 40:17 

doing 42:21 43:19 

80:10 

dollars 13:8 14:2 

dominate 46:11 

dramatically 44:14 

dressings 86:9,18 

drive 44:16 

driven 74:10 

drop 83:7 

drops 88:19 

dry 80:5 

due 29:5 53:8 92:4 

duplex 86:19 

E

E 30:1 

ease 84:3 

easier 60:9 

Eastern 2:5 

easy 37:22 

eat 36:8 

ecologist 12:9 

economic 13:2 

economically 22:11 

76:21 

economists 13:5 

economy 15:8,11 

ecosystem 12:14 13:3 

13:6 14:8,11 

ecosystems 12:13,17 

12:21 14:22 15:8,14 

16:1 17:1 19:13 26:22 

effect 38:10 

effective 34:11 

effluent 63:19 64:20 

67:2 68:9 

efforts 26:4 

either 21:18 64:1 76:12 

80:1,5 

Ela 1:15 10:7,8 65:21 

65:21 66:2 67:9,12 

68:13 69:6,14,20 

elaborate 66:8 

eliminate 30:4 61:20 

elimination 21:10 

Elizabeth 39:15 45:8 

51:15,16,19 77:6 93:6 

93:8 

embedded 74:10 

embodied 46:3 

Emily 1:16 10:18 17:7 

75:20 89:4 

emphasize 63:19 

enable 57:8 

encourage 49:13 

encouraging 33:7 

ends 9:2 19:15 70:19 

71:10 

energy 78:16 80:18 

enforced 74:2 

enforcement 49:11,14 

75:6 

engaging 6:15 

engineer 63:2 92:16 

engineering 43:14 

enjoy 78:5 

ensure 16:3,20 

Enterobacter 86:6 

88:18 

entire 56:6 

entirely 36:6 49:17 

58:18 61:20 

environment 16:18 

20:2,4,5 21:7 22:11 

29:1 38:15 64:11 

68:11 70:10 71:5,8 

environmental 17:21 

29:5 30:9 63:2 82:19 

83:3 

enzymes 25:5,6 

EPA 30:10,14 31:5 35:7 

35:9 38:7 

equivalent 42:4 

erythromycin 88:20 

especially 68:14 78:22 

79:10 

essential 15:2 17:1 

26:17 32:16 79:3,21 

85:1 

established 40:12 

estimate 14:9 

estimated 13:8 

et 41:10 

eternally 80:20 

evaluate 38:6 

evaluation 30:16 

evaluations 30:10 

eventual 63:21 65:9 

eventually 65:8 

everybody 2:3 3:4 9:5 

evidence 37:20 38:17 

38:21 86:12 88:8 

89:17 90:16 

evolved 57:2 

example 15:9 33:5 57:8 

66:6 87:13 92:3 

excellent 93:21 

exclude 83:10 

excluded 40:7,10,13,21 

40:22 82:6,13,19 

83:21 84:2,6 90:20 

excluding 41:3 

executive 55:16 

existing 40:19 

exists 59:21 

expand 47:18 

expected 67:2 

expense 44:7,12 

experience 8:17 63:4 

expert 69:2 

expertise 30:19 

exposure 86:21 

expressed 19:1 88:4 

expressing 86:13 

extended 61:12 62:2 

extending 24:10 

extensive 29:8 

extent 58:18 

extra 3:7 

extraordinarily 30:3 

extremely 24:22 38:9 

eye 8:3 

F

face 4:7,7,10,10,12,13 

faces 78:3 

facilities 31:3 35:13 

74:12 79:15 80:6 

facility 36:1,12 65:4,6 

facing 7:4 68:9 

fact 32:5,21 37:20 

50:18 53:8 88:7,15 

factor 90:2 

facultatively 64:2 

fall 12:20,22 18:17 78:4 

82:9 

familiar 17:13 70:8 71:2 

families 80:19 

family 46:2,4 51:1 

77:19 

far 19:12 30:2 

farm 47:19 48:2 72:10 

72:12,14 

farmer 41:12 44:3 73:7 

75:22 76:1,13 

farmer's 73:11 76:11 

farmers 43:2,12,20 51:4 

51:6 

farms 43:5 45:20 46:2 

51:10 76:20 78:7 

faster 26:9 

fate 65:13 

fauna 70:20 

FDA 30:11,14 31:5 35:8 

38:5 

feasible 30:4 

federal 4:14 75:4 

feedback 27:10 

feel 17:11,16 41:8 44:4 

76:19 

felt 75:5 

field 68:15,17,21 69:7 

69:12 

fields 31:4 72:9 

figure 19:14 91:7 

final 48:4 50:9 

finalized 47:12 

finally 84:15 

find 30:3 51:19 77:6 

90:13 93:6 

finding 8:1 

findings 86:11 90:4 

fine 13:18 19:20 53:6 

finish 6:7 16:12 

first 3:13 11:19 34:20 

65:15 69:18 81:18 

82:3 86:12 87:20 

fishery 15:18 

five 14:21 90:13 

fix 47:6 48:6 

fleet 16:2 

flexibility 80:3 

flora 70:20 

focus 14:14 45:17 

focuses 12:10 

folks 2:9 85:6 

follow 18:20 27:12 

36:20 37:4 66:2 67:10 

following 5:21 19:5 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
99 

65:11 

Folsomia 89:22 90:8 

food 24:1,3,9 25:1,14 

25:18 26:17 29:21 

30:17,20 31:3,16 

32:17 33:2,9,14 34:9 

35:13 37:12 38:12 

39:4 40:5,9 41:14 

52:7,14 63:6 64:8 

68:14 70:12 71:14 

74:6 

foods 24:5 25:16 26:9 

26:15 45:15 

football 53:4,7 

forests 14:15,19 

form 21:20 58:11,14 

65:9 66:22 67:22 

formally 40:14 

forming 61:18 

forms 70:20 83:2 

forward 4:15 41:6 75:11 

78:10 

found 85:21 87:13,20 

89:19 

founded 39:21 

four 12:20,21 

Francis 28:7 39:15 45:7 

45:9,12 49:2,8 50:8 

51:8 

free 55:18 

freeze 61:14 

freezing 61:4,14,22 

French 62:17 

fresh 24:10 72:13 

freshly 72:18 

freshness 41:10 

fronds 22:20 

frontline 85:22 

frozen 61:2 

fruit 24:10,11 25:17 

76:17 77:11 79:4 

FSIS 36:7 

full 16:2 28:19 72:12 

fully 56:9,13 75:6 

fun 5:8 

function 54:14 

functionality 61:20 

functioning 12:18 15:3 

fund 19:1 

fungi 35:1 

further 29:16 40:22 

63:20 66:17 

future 42:2 72:22 78:10 

G

gains 73:12 

galling 71:9 

gaps 81:9 

gas 53:9 

gel 55:20 56:1 57:3,5,7 

57:14 58:13,20 59:10 

59:19 61:1,6,9,16,21 

62:4 

gene 88:16 89:1 

General 46:21 

generally 29:19 30:6 

34:11 41:18 

genes 87:13,15 88:3,19 

89:1 

genetic 40:8 41:5,9 

42:18 43:14 

geographic 60:5 

gestation 46:16 47:22 

getting 4:2 8:10 43:3,5 

Gigot 55:9 62:17 71:17 

72:5,8,9 76:3,9 

give 2:12 7:13 

given 48:9 

glad 58:3 83:17 

global 14:12 15:5 24:2 

globally 13:7 

GMO 42:4 82:3 84:13 

goals 72:14 

goods 13:3 

Googling 89:19 

government 19:3 

grape 79:4 

grapes 79:14 

grass 14:15,18,21 15:6 

52:17 54:4 

grasses 40:4 

grateful 80:21 

grease 49:22 

greatly 78:17 93:13 

Greenwood 1:15 10:11 

10:12,14 32:2 33:12 

34:15 70:2,3,5,7,14 

71:7,15 

ground 63:20,21 

groundwater 66:4,9,10 

67:7,13,18,20 

group 18:18 58:3 

grow 46:11 59:11,12,13 

64:8 86:10 

grower 44:9 57:19 

growers 79:4 

growing 32:6 33:7 

50:15,21 59:15 

grown 59:8 64:6,13,18 

76:6 79:6 

growth 56:6 57:7 88:11 

guidance 40:9,17 41:14 

guided 23:4 

guideline 36:7 

H

habitat 15:17 

half 56:13 

hand 21:16,18 22:10,15 

22:17 

handlers 79:20 

handling 25:8 28:20 

56:2 65:5 79:9,13,15 

80:6 84:15 85:2 

hands 6:12 49:17,20 

Hansen 37:8 71:18 77:5 

81:16,18,21,22 86:3 

87:10 89:9,12,16 91:5 

91:22 92:10 

happen 64:14 79:6 

happened 43:4 

happening 51:2 

happy 27:2,11 55:2 

65:16 

hard 6:10 35:10 73:1 

91:7 

Hardin 52:2 55:9 62:16 

62:21,22 66:7 67:19 

68:22 69:13,16,21 

70:13,22 71:12 

harm 20:2 21:6,16 

30:18 31:6 

Harmony 72:9 

Harold 62:18 71:18 

77:4,7,10 81:4 

Harriet 1:10,12 5:3,4 

7:11,18 8:21 9:12,12 

11:17 16:13 18:19 

45:11 51:18 65:21 

67:9 70:2 77:9 93:22 

harvest 16:4 20:18 21:2 

21:7 22:14,19 32:7 

69:3 

harvested 16:4 26:20 

27:8 68:15 69:1 

harvester 21:13 22:15 

harvesters 19:5 

harvesting 12:22 15:7 

15:13,22 17:21 19:6 

20:15 21:4,8,12,15,16 

21:17 22:17,18 27:17 

32:15 

hazard 30:8,12,13 

head 7:3 

headset 9:18 72:1 

health 16:22 26:3 29:1 

30:8 37:10,13 66:11 

84:3 

hear 6:6 7:2,8,14 9:17 

12:5 28:9 49:5 51:11 

67:12 72:5,6 81:18 

heard 43:2 

hearing 1:5 4:15 23:12 

72:1,3 76:1 

heat 52:20 53:13 

heavy 88:1 

Hello 2:17 9:22 10:3,17 

12:7 

help 8:13 17:20 33:8 

36:9 50:5 73:1 74:22 

81:10 

helps 30:6 

herb 74:5 

herbs 72:11,13,19 

herd 46:15 

herds 47:3 

hey 33:15 49:7 

hi 2:3 8:8 10:13,14 11:1 

11:4,10 39:19 49:8 

70:4,7 

hides 59:5 60:6 

high 70:19 71:10 86:7 

86:13,21 88:4,10 

higher 54:11 70:17 90:3 

90:7 

highlighted 14:16 

history 21:9 37:18,19 

52:16 54:5 

hit 7:12 

hold 61:2 

home 78:6 

hope 50:3 73:11 78:5 

93:17 

Hopefully 7:13 

hoping 81:8 

horticultural 77:14 79:1 

house 69:11 

housekeeping 5:10 

Huber 45:8 51:15,22 

52:5,6 55:7 

huge 38:5 44:6 

human 12:11 29:1 30:8 

30:9 37:10,13 

humans 12:16 

hundreds 37:17 

hydraulically 68:1 

hydrogen 78:22 79:10 

hydroponic 48:14,15 

73:17 74:4 

hydroponically 76:6 

hydroponics 75:3 

I

ice 61:18 

ICL 52:6,7 

idea 69:3 

ideal 29:20 

IFAC 24:2,6,12,16,19 

24:21 25:5,9,11,22 

26:5,12 

illness 33:9 

illnesses 31:17 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
100 

immune 51:7 

impact 12:12 17:21 

33:9 44:6 86:14 87:4 

impacts 15:22 74:19 

imperative 79:19 

implement 73:2 75:6 

implication 87:6 

important 7:2 15:17 

16:21 20:6 24:22 

26:14 34:6 54:8 73:2 

73:15 79:12 80:7 

impossible 52:22 

impregnated 86:9,17 

included 57:1 74:5 

includes 55:18 

including 12:11,16 24:4 

24:8 40:7 55:19 84:9 

inclusion 29:13 

incoming 63:9 

inconsistency 49:11 

increase 57:17 85:21 

increased 85:13 

increasing 59:16 84:18 

indicate 90:5 

indirectly 15:16 

individual 36:13 72:18 

induced 91:4,6,15 92:8 

industries 40:2 

industry 46:10 63:8,10 

73:10 

infected 88:19 

inflow 74:18 

information 4:10 27:12 

36:21 37:4 41:12 

43:21 84:11 85:15 

ingredient 26:10 

ingredients 19:10 24:4 

56:17,19 57:21 

input 6:16 19:11 

inserted 82:15 

inserting 83:15 

inside 13:13 

Inspector 46:20 

instance 32:4 36:15 

intact 53:18 

integrity 40:8 41:5,9 

42:18 73:16 

intended 29:7 30:17 

31:2 77:17 

intent 32:14 

interchangeably 54:15 

interest 73:12 

interested 36:22 76:13 

interesting 60:1 

interference 8:8 72:16 

73:8,13,16,19,21 74:3 

74:6,7,11,12,17,19,20 

75:1,3,7,10,14,15,17 

76:12,14,16,17,18,22 

77:1 

internal 92:5 

internally 91:9 

International 24:1 

52:14 

interpretation 46:7 

interpreting 46:22 

interrupt 13:11 

interruptions 2:10 

intestine 56:11 57:11 

intestines 56:22 

intragenesis 82:5 

involved 44:22 

involving 39:22 

ion 64:10 66:21 

ionic 67:22 68:3 88:9 

ions 90:5 

issue 17:17 37:13 38:5 

48:4 58:18 68:19 

77:19 87:11 88:6 

90:11,15 91:14 

issues 7:4 32:19,20 

35:22 71:14 85:19 

92:19 93:3 

items 4:18 18:8 

J

JAMES 1:15 

Jane 23:18 28:7 39:14 

39:17,19 

JESSE 1:13 

Jessica 55:9 62:17 

71:17,19,21,22 72:3,9 

Jim 51:16 52:1 55:8,11 

55:15 

job 18:6 

jobs 80:19 

Johnson 28:13 

join 5:22 

joining 2:9 

joins 65:8 

K

keep 3:3 8:3 

keeping 11:11 15:19 

94:3 

keeps 53:18 

kelp 20:15 22:20 

kept 61:1 

key 16:16 32:16 73:14 

79:21 

kill 30:5 

kinds 21:14 32:11 

Klebsiella 86:6 

knew 70:21 

knife 21:18 22:17,19 

knowing 76:13,13 

known 52:17 87:19 

knows 9:5 

kosher 57:12 

L

lab 38:21 83:15 

label 72:20 73:4 

labeled 76:8 

labor 46:3 

laboratory 91:2 

lack 49:11 

lactic 24:16,17,20 

landings 15:10 

landscape 50:10 

language 16:6 17:14 

18:2,12 20:7 

large 22:20 41:17 45:21 

64:16 

larger 65:4,6,9,15 

lastly 26:12 41:14 42:3 

lauryl 29:7 

layer 59:3,4 

leave 5:12 

leavening 26:7 52:20 

53:16,18,22 

leavens 26:9 

left 22:3,5 75:9 

legal 29:11 80:13 

lengthy 37:19 

let's 2:12 93:17 

level 3:3 60:16 66:12 

67:1 86:8 

levels 38:9,16 86:14,21 

88:5 

Lewis 1:21 3:13,16 

life 61:13 62:2,5,8,11 

73:11 

likelihood 67:5 

Lima 1:14 10:4,5 

limited 25:3 56:20 

line 8:22 45:14 65:12 

66:20 72:1 93:9 

lines 5:12 

linked 88:15 89:2 

Lisa 1:14 10:4 

list 8:1 15:15 16:7 24:7 

24:17 25:6,10,19 26:1 

26:13 28:18,22 29:14 

31:1,20 34:5 39:13 

40:21 42:9 51:19 

53:21 56:2 57:1 58:8 

59:10 80:1 84:5,8 

93:8 

listed 16:16 17:15 18:7 

52:20 75:12 79:8,22 

Listeria 30:1 36:7,9 

listing 25:11 29:4 54:3 

78:20 82:18 

listings 25:13 

little 3:7 66:8 84:13 

livestock 45:18 46:7 

47:1 48:4 57:19 83:17 

LLC 55:16 

loads 63:9 

local 26:21 

locally 64:15 

logistics 3:15 

long 15:15 21:11 22:22 

37:17,17,17 38:1 

52:16 54:5 62:5,8 

68:4 80:8 

long-term 16:22 

longer 48:22 

longest 78:7 

look 4:15 14:20 33:4 

37:7,14 50:10 51:13 

78:10 90:9 91:14,16 

92:19 

looked 20:15 

looking 20:18 38:5 41:6 

85:14 90:10 92:7 

looks 2:7,9,20 53:4 

loophole 48:8 

loose 46:6 

lose 73:3 

loss 51:1 

lot 22:18 38:11 46:5 

50:17 53:5,17 63:3 

73:1 76:9 80:18 

loud 7:15 

low 26:2 28:22 38:9 

39:6 70:18 87:16 

lucrative 43:16 

M

mac 54:18 

machine 21:21 

magnesium 79:2 

magnified 70:9 

main 43:1 88:7,14,22 

maintain 15:3 

maintaining 16:22 24:6 

24:16 25:5,22 26:12 

majority 2:20 66:21 

68:6 

making 34:8 44:19 

83:14 

management 31:12 

46:3 47:21 80:4 84:20 

86:15 87:4 88:7 89:1 

manner 26:20 27:9 

manpower 21:20 

manufacturer 52:7 

55:17 

manufacturers 24:3 

manufacturing 32:15 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
101 

manure 33:2 

marine 12:9,10 15:9,14 

16:6 17:20 19:10,12 

20:3,8 

Maritime 15:10 

market 40:5 56:7 57:7 

57:12,17 59:11,13 

76:11 

marketing 93:3 

marketplace 41:8 43:10 

56:4 

markets 46:12 

material 33:1 58:15 

60:12 64:7 67:4,16 

80:5 

materials 7:4 15:13 

16:4 68:11 78:17,21 

79:3,8,12,18,21 80:4 

80:9 82:3 

matter 2:14 23:3 94:8 

max 86:19 

maximum 23:4 

mean 12:14 33:4 34:6 

35:20 36:2,2,5 38:5 

38:13 39:3 

means 14:22 33:8 

meat 24:18 56:7 59:11 

meats 25:17 56:17 

57:18 

mechanical 21:8,12,15 

21:15 

mechanics 64:16 

mechanism 41:4 92:22 

medical 37:18 77:19 

medications 84:20 

meet 4:12 24:13 65:14 

meeting 3:14 4:8,10,11 

5:6 6:21 9:2 28:19 

65:12 77:18 78:4 

93:13 

meetings 4:11 11:15 

member 11:14 39:22 

73:7 77:12 

members 2:21 3:18 4:1 

6:9,12,17 7:10,22 9:5 

11:16 17:5 27:4,21 

39:10 40:3 41:11 55:5 

58:6 81:3 93:14 

membership 27:11 

mention 75:10 

mentioned 32:4 42:20 

77:13 80:9 85:12 

mercury 70:8,18 71:8 

metagenomics 87:12 

metal 70:9 

metals 88:1 

method 22:12 23:3 

33:11 36:9 65:2 82:13 

82:21 83:13 90:22 

91:3 92:13,15,18 

methods 19:6 20:20 

21:22 30:4 40:8,10,13 

40:20,20,22 41:3 82:6 

82:20 83:4,22 84:2,6 

90:20 

mic 9:18 72:2 

Michael 37:8 45:8 51:15 

51:22 52:2,6 71:18 

77:5 81:16,16,21 

89:11 

Michelle 1:22 2:4,18 

3:16 4:21 5:10,14 6:3 

7:7 13:11 93:6,19 

micro 75:16 

micro- 25:15,20 

micro-organisms 25:12 

microbiological 65:8 

military 51:5 

milk 24:18 47:4 50:13 

72:16 

Miller 39:15 45:8 51:15 

77:7 93:6 

million 15:11 

mind 15:19 

mindful 44:20 

minimize 32:14 

minimum 3:10 

mining 71:9 

minute 2:12 

minutes 2:8 6:6 90:13 

mispronounced 45:6 

Mississippi 63:3 

mistake 82:16 

mitigate 15:22 

mixes 54:2 

mobile 67:6,21 68:5 

Modernization 68:14 

moment 11:14 41:22 

monetary 15:5 

month 62:11 

months 11:13 

moral 80:13 

morning 77:10 

Mortensen 1:16 10:15 

10:16 

move 51:13 73:22 75:1 

77:4 83:1 

movement 92:5 

moving 59:17 75:11 

91:9 

MRSA 33:1 87:14,18 

multiple 88:1 92:22 

municipal 64:16 

municipalities 63:8 

mutagenesis 91:4,7 

92:8 

mutagens 91:12 

mutation 91:20 

mutations 91:8,15 92:2 

92:21 

mute 3:4 5:14,15,15 8:9 

9:9 

muted 9:17 72:2 94:3 

N

name 12:9 23:20,22 

28:12 39:17,19 45:6,9 

45:11 51:17 52:3,5 

55:11,15 62:19 71:19 

72:9 77:7 81:17 

name's 81:21 

names 11:12 

nanoparticles 89:21 

90:4,6 

nanosilver 29:6 

nation 78:8 

national 1:3 3:20 4:12 

16:7 24:7,17 25:6 

26:1,8,13 28:18,21 

29:14 31:20 34:5 

40:15 45:19 51:12 

56:2 57:1 59:10 72:21 

74:1,21,22 75:5 80:1 

natural 14:7 24:18 30:4 

55:19 71:4 73:15 

82:14,20 83:12 92:13 

naturally 30:1 82:22 

90:20 92:17 

near 42:1 52:21 59:7 

nearly 49:9 61:13 

necessarily 34:3 68:17 

69:11 91:16 

necessary 32:9 34:8 

need 16:17,20 18:10,13 

19:2 29:21 32:15 

53:12 59:15,16 66:8 

81:13 91:16 93:4 

needed 58:20 60:5 

79:21 

needs 7:16 20:2 21:5 

24:13 44:13 51:12 

65:1 66:12 74:1 88:21 

92:11 

Neither 30:14 

never 47:12 

new 38:11 50:15 57:15 

81:11 

nine 75:4 86:18 

nitrate 89:21 90:3 

noise 3:3,10 5:13 

non-GMO 42:5 

nonorganic 25:4 

NOP 1:21 2:4 4:9 40:8 

41:14 48:6,12,16,20 

49:16 50:2,8 84:4 

NOP's 49:17,20 

normal 12:17 

North 40:2 

Northwest 77:14 78:6 

79:5 

NOSB 3:18 4:1,6,16,18 

5:6 6:20 7:10 27:20 

28:20 29:11,15 30:21 

31:7 47:7 48:18 49:13 

49:15,20 55:5 77:4,12 

83:6 93:13 

nose 88:19 

note 29:10 41:15,20 

noted 36:5 

notes 9:1 

noting 42:7 

Nova 22:14 

nucleic 82:12 

number 8:15,18 21:14 

24:4 33:4 35:5 47:18 

74:22 93:7 

numbers 45:21 58:18 

59:1 60:2 

nursery 15:17 

nutrient 54:8 

O

o'clock 2:5 

Oakley 1:16 10:18,19 

17:9 18:19,22 20:9 

75:20 89:5 

obligation 80:13 

observe 64:15 

obstacle 68:10 

obviously 40:5 

occurring 68:7 82:20 

90:20 92:17 

occurs 53:10 

October 11:15 

offer 53:21 74:18 

Office 46:20 

official 6:20 

OIG 47:6 

oils 79:1 

once 3:5 47:14 

ones 50:15 92:17,22 

onsite 63:14 69:4 

open 5:13 44:19 

operates 4:13 

operation 63:4 65:6 

operations 25:2 48:14 

75:16 

opportunities 57:7 

76:20 

opportunity 4:5 12:8 

27:1 28:15 41:6 56:6 

57:4 71:5 77:22 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
102 

oppose 84:16 

opposed 49:16 91:9 

option 56:21 62:1 

options 56:19 

oral 29:12 

Orchard 77:10 

order 3:14 5:18 

organically 26:16 58:19 

59:8,20 

organics 64:11,12 

organism 82:15 

organisms 25:16,21 

38:22 39:1 71:6 

organization 73:10 

organizations 46:14 

orient 14:6 

origin 45:18 46:7 47:1,8 

48:4 

original 18:2 45:15 

Originally 72:12 

output 74:18 

outside 92:12 

overall 81:10 

overarching 34:7 

oversight 44:2 

oxygen 15:18 64:3,6 

P

P-R-O-C-E-E-D-I-N-G-S

2:1 

p.m 1:9 2:2,15,16 94:9 

Pacific 78:6 

packing 69:8,11 

paper 88:17 

part 4:7 6:19 8:4 9:1 

30:15 31:11 35:1 

37:20 59:9 60:10 

63:22 64:5 69:11 71:3 

71:4,8 80:20 87:10 

88:13 

participants 7:20 93:15 

participate 41:7 

participating 94:1 

particular 4:21 35:22 

particularly 25:1 39:5 

66:10 

Partners 55:16,16 

Paskind 51:16 52:1 

55:9,13,15 58:17 

60:13,18 61:8 62:7,10 

62:15 

patented 52:17 

pathogen 31:11 35:20 

37:11 80:10 

pathogens 33:2 36:3 

pathway 57:12 

Paul 1:21 3:13 5:7 

people 3:5 5:21 6:11 

18:22 22:9 30:5 33:14 

81:18 85:18 90:14 

peracetic 36:17 79:11 

percent 14:7,11 57:9 

61:17,17 

percentage 59:2,5 

performs 54:10 

permit 47:5 

permitted 24:5 

peroxide 78:22 79:11 

person 6:1 77:18 78:4 

personally 4:20 74:15 

pest 41:4 

Pesticides 16:19 17:15 

18:4 

petition 56:1 84:17 

pH 24:8 54:12 

phase 68:5,6 

pheromones 79:1 

phone 5:12 8:9 

phosphate 26:1,2 54:14 

phosphates 52:8,11 

54:4,13,17 

photos 53:2 

physical 61:16,19 

pie 14:7,17 

pieces 22:5 

pig 56:11 57:11 

place 41:9 52:22 53:10 

65:15 69:18 88:16 

plan 60:10 

plans 77:20 

plant 40:1 54:19 

plant's 41:3 

plants 12:10 22:3 60:7 

63:5 

plasma 87:21 

please 4:9 5:14 6:7 8:6 

8:9 14:5,13 15:4,12 

15:20 16:8 23:20 28:8 

39:17 45:9 51:16 52:2 

52:15 53:1,14,20 54:3 

54:16 55:11 62:19 

67:11 71:19 77:7 

81:16 

PMG- 87:21 

pneumonia 86:6 

point 34:13 35:17 49:16 

59:19 65:1 83:16 86:4 

points 5:10 16:21 18:13 

21:5 82:2 

portfolio 55:18 

portion 68:8 

poses 84:18 

position 62:3 

possible 51:13 

possibly 80:15 

post-harvest 31:4 

35:11 

posted 16:19 

potassium 25:22 26:2 

52:10 54:7,16,21 79:1 

potential 30:12,15 

44:11,21 57:6 85:12 

90:7,7 

potentially 41:2 

poultry 36:4,8,22 

pound 53:6 

PowerPoint 12:1 52:1,4 

practice 7:4 32:6 47:5 

practices 19:5 31:14 

32:16 33:7 69:3 

practitioners 74:2 

pre- 5:17 

precedents 48:11 

precipitate 68:12 

predominantly 63:5 

preference 76:7 

preferred 21:22 56:15 

57:16 58:1 

preparation 78:17 

preparing 4:17 

presence 29:6 43:14 

64:6 

present 1:11,20 10:2,19 

10:22 11:16 24:18 

30:1,8 64:12 

presentation 17:10 

presiding 1:10 

press 5:15 

presume 51:7 

pretty 6:10 7:18 13:22 

19:19 39:6 54:14 

74:13 

prevent 36:9 84:2 

previous 6:1 63:12 85:5 

price 43:17 44:1 

primarily 36:22 38:22 

primary 39:1 56:3 

print 6:19 

priorities 73:14 

probably 48:9 49:10 

94:1 

problem 48:7 55:7 84:3 

problems 8:1,14,19 

proceeding 71:14 

process 48:17 60:8 

61:3 78:2 79:13 80:20 

processed 24:9 33:20 

56:11,22 69:4,7 

processes 29:15 

processing 29:21 31:3 

32:9 35:6,13,21 39:5 

60:6 61:7 63:13 69:1 

processors 31:11 34:8 

63:6 

prod 49:21 

produce 26:19 33:6 

34:9 36:4 40:3 63:13 

69:1,2,4,9 72:15 

produced 26:16 84:6 

producer 47:15,17 58:2 

producers 24:14 41:17 

43:19 47:2 68:15 74:9 

79:20 

producing 32:17 

product 19:11 26:7 

35:16,19,22 36:14,22 

53:11 55:18,21 57:13 

58:1,10 59:14 61:19 

69:19 74:14,15 80:14 

84:9 

production 15:18 25:1 

25:7 26:18 30:20 40:1 

45:16 47:4,14 48:15 

53:9 57:8 72:17 73:17 

74:5,6,8,13 85:1 

products 13:4 16:7 

24:9 25:7,16 30:15 

35:21 36:8,11 52:7 

53:22 54:1,17,18 

55:19,20 75:8 81:11 

84:2 

program 31:12 40:15 

44:6 51:12 72:21 73:2 

73:15,19 74:1 75:1,6 

programs 44:21 

prohibitive 42:20 

Project 45:13 

properly 34:12,13 

properties 52:21 

proposal 41:5 43:2 

proposals 40:7 

proposed 16:18 41:7 

47:10,13 82:4 83:19 

proposing 18:11,16 

protecting 17:20 19:12 

protein 61:17 

protons 93:1 

proud 78:9 

proven 30:2 56:14 

provide 4:6 12:13,17,21 

15:14 16:1 17:2 26:2 

27:2,13 28:15 43:20 

53:16 54:6,13 57:12 

58:20 59:9 60:19 

80:13,15 86:11 

provided 25:10,19 29:8 

78:19 79:7,16 83:22 

93:8 

provides 4:5 53:17 

providing 3:6 15:16 

41:12 44:11 54:7 

57:18,19 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
103 

Provinces 15:10 

provisioning 13:1 

provisions 4:14 

public 1:5 3:18,21 4:3,6 

4:7,13,16 6:6,20 7:1 

8:4 17:16 19:16 29:9 

48:18 66:11,16 93:12 

published 46:21 

PURE 28:14 29:8 63:1 

purely 35:13 

purpose 43:1 56:3 

purposes 24:8 39:2 

put 8:9 13:6 17:15 

18:16 48:12,20 72:12 

puts 60:2 

putting 75:7 92:7 

pyrophosphate 26:6 

52:10,16 

Q

quality 24:15 

quantity 24:14 58:20 

question 15:21 17:8 

18:20 19:19 20:13 

32:3 36:20 37:7 42:16 

50:8 61:1 65:22 69:4 

70:5,7 71:13 75:21 

76:5 89:11 90:19 

questions 6:1,14 17:4 

20:10 27:3,5 32:1 

34:16 39:9 42:14 45:3 

49:3 50:7 55:2,5 58:4 

58:5 60:22 62:13 

65:17,19 67:10 70:1 

71:16 75:18 76:4 81:3 

85:4,7 89:8 

quickly 51:13 64:10 

68:5 

quiet 94:4 

quietest 94:2 

quite 48:3 54:10 

quote 47:13 

R

radiation 83:3,9 91:1,6 

91:11,19 92:3,4,19 

raining 93:18 

raise 59:16 72:11 

raised 58:19 59:20 

raises 93:3 

raising 6:11 

rake 21:19 22:15 

raking 22:10 

ran 3:9 

range 15:16 62:12 

rapidly 46:11 51:2 

rate 51:5 

rationale 34:3 

raw 15:13 64:12 

reaches 66:19 

read 18:2 83:21 90:1 

reading 42:17 

ready 2:22 4:2 5:21 

36:7 

readytalk.com 8:13,14 

reality 29:22 

reason 23:10 29:11 

83:6 

reasonable 30:3,18 

34:2 

reasons 18:7 32:22 

38:9 44:4 

recalls 33:5 

received 27:11 

recipe 56:17 

recipes 57:21 

recognized 30:20 

recognizing 29:3 30:11 

recommend 36:8 

recommendation 56:3 

84:16 

recommendations 4:17 

30:21 47:8 75:2 

recommended 28:20 

29:4 75:4 

record 2:15 6:20 8:5 9:2 

45:20 94:9 

recover 21:12 

red 14:16 

reduce 30:7 31:14 33:8 

41:1 

reduces 31:16 

reducing 34:14 

reduction 26:3 41:1 

54:13 86:20 

reed 21:10 22:14 

reference 8:7 88:16 

referenced 49:12 

reflect 18:13 

refocused 72:14 

refrigerate 62:1 

refrigerated 61:2,11,13 

62:12 

refrigeration 62:6,9 

Regarding 25:8 56:16 

regards 40:10 

regenerate 22:5 

register 5:18 

regulations 19:3,4 42:9 

regulatory 29:11 83:19 

rejected 43:3 

related 33:5 40:2 

relatively 57:15 

relisting 24:21 26:5 

remain 33:3 87:16 

remainder 29:17 

remaining 22:3 

remains 25:2 26:17 

32:22 

reminder 5:17 

remiss 4:19 

removed 22:6 

replace 47:18 

report 46:21 

Reports 82:1 

represent 24:1 29:1 

31:6 39:22 52:6 56:13 

73:5 78:15 

representative 75:22 

representing 24:3 

represents 30:18 73:10 

repressing 80:21 

request 25:9 

require 46:14 

requirement 44:9 75:14 

requirements 42:5 47:1 

requires 21:20 

research 12:10 

resiliency 16:22 

resistance 31:15 34:22 

37:11,21 38:2,4,19 

80:4 84:19 85:13,14 

85:15,20,20,22 86:7 

86:13 87:2,8,13,22 

88:9 

resistant 88:18,19 

resource 60:12 

respectfully 31:18 

response 4:18 8:16 

20:12 27:22 34:18 

39:11 42:15 45:4 85:5 

responsibility 44:3 

restricted 67:16 

resumed 2:15 

return 63:21 

review 60:14 78:21 79:9 

81:8,10 84:22 

Rice 1:17 10:21,22 

Rick 1:15 10:11,13 32:2 

70:2,4 

risk 28:22 30:12 31:6 

34:14 39:6 42:6 84:18 

88:14 

rock 21:10 22:14 

role 29:18 

roll 7:9 9:4 

ROMERO-BRIONES

1:17 11:3 

rotation 31:14 34:21 

35:1,2 36:9,13,16 

route 48:9 

row 40:3 

rule 19:9 45:18 46:7 

47:10,11,13 48:4 50:9 

75:4,6 

rulemaking 48:10 

rules 48:17 74:1 

run 69:7 

rural 45:13 65:13 

S

safe 32:17 34:9 52:16 

safest 80:14 

safety 30:15,22 68:14 

Salm 55:16,16 

Salmonella 29:22 32:4 

87:22 

salt 66:22 

Sam 52:2 55:9 62:16,19 

62:22 

sanitation 79:17 

sanitizer 35:7 36:8,12 

68:16 69:8,10 80:1 

sanitizers 34:21 35:3,5 

39:4 81:7 

sanitizes 35:12 

sanitizing 35:10 

SAPP 26:6 53:2,13,17 

53:21 54:4 

SAPPY 26:11 

sausage 55:17,20 56:9 

56:12,13,22 57:2,4,9 

57:10,11,13,16,21 

59:3 

sausages 55:19 56:5,8 

56:11,16 59:12 

saved 61:5 87:9 

saw 18:15 

saying 44:18 55:10 

62:17 66:3 67:13 69:2 

71:20 82:17 83:11 

90:21 91:14 

says 90:2 

scale 41:17,19 72:12 

scary 51:3 

scenes 4:22 

scheduled 4:8 

Schmidt 11:20 12:2,5,7 

12:9 13:15,18,22 

16:11,15 18:1 20:1 

21:3 22:13 23:15 

science 38:3 77:14 

scientist 81:22 

Scotia 22:14 

Scott 1:17 10:21 11:1 

screen 8:12 

SDC 28:17,21 29:5,13 

31:2,5,8,10,19 38:9 

38:14 39:5 63:12 64:9 

69:17 85:12,16,21 

sea 14:15,18,21 15:5 

search 3:5 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
104 

seasonings 56:17 

Seattle 4:8 6:20 77:17 

93:17 

seaweed 26:19 

second 3:19 27:15 73:9 

83:16 

seconds 7:13 

sectors 74:3 

seed 39:20 40:1,3 41:2 

41:22 42:18,21 43:5 

43:12,15,19 44:10 

45:1 

seeing 50:14 

seen 37:15 38:2 

Seitz 1:18 11:5,6 23:9 

49:5,8 50:6 

select 87:2 

selected 88:9 

self-mute 3:2 

send 8:2 86:1 

senior 81:22 

sensitive 87:16 

sent 20:14 

sentence 90:1 

separate 91:22 92:2 

separation 61:19 

septic 65:13 66:6,14 

serve 24:8 

service 78:14 

services 12:12,14,20 

12:21 13:3,6 15:1,15 

16:2 17:2 

serving 4:4 5:6 63:5 

settled 64:18 

seven 5:16 

shallow 67:15 

shaped 53:7 

share 49:10 

shed 69:8 

sheep 72:11,15,16 

shelf 61:13 62:2,5,8,11 

shelf-life 24:10 

shotgun 32:10 

show 6:4 70:10 

showed 86:5,20 

showing 23:11 

shown 38:21 84:22 

shows 14:10 

side 63:7,10 80:6 

sides 81:9 

sight 20:22 

sign 43:9 

significant 66:11 67:17 

87:3 

significantly 38:18 

86:14 

silver 28:16 34:3 37:9 

37:16,16,21 38:9,11 

38:18 64:10 65:12 

66:4,21 67:1 68:3 

70:11 71:1,3 84:17,19 

84:22 86:7,8,8,13,17 

86:19,20,21 87:13,17 

87:21 88:1,9,17 89:14 

89:21,21 90:3,4,5,6 

similar 70:15 82:8 

simple 48:19 

simply 31:10 48:7 68:4 

SIMULTANEOUS 17:6 

36:18 

single 57:8 

sir 9:22 

sit 81:11 

sitting 89:18 

situation 49:18,18 

six 5:15 47:7 62:11 

size 14:11 15:2 

Skagit 72:10 

slide 14:5,6 15:4,12,19 

16:8,10 18:8 52:15 

53:1,14,20 54:3,16,22 

slides 13:12,19 

slippery 33:21 

slope 33:21 

sloppy 33:14 

slowly 64:22 

sludge 64:21 65:3,5 

66:5,22 

small 41:19 59:2,5 64:2 

64:21 65:13 72:10 

75:10 

smaller 14:22 

smiling 78:3 

sodium 26:3,3,5 29:7 

52:10,15 54:14,21 

software 13:13 

soil 66:18 76:7,20 89:22 

solution 47:9 

solutions 83:20 

somebody 20:14 

somebody's 33:16 

somewhat 43:6 

sooner 51:14 

sorry 2:11 9:10 13:11 

22:11 45:6 62:7 85:11 

sort 43:8 46:16 57:20 

sorts 71:9 

sound 6:4 

sounds 7:8 

source 24:12 33:1 

58:15 67:7 

sources 41:22 

speak 6:13 8:1 12:8 

21:1 78:1 

speaker 51:19 77:6 

speakers 5:19 

speaking 6:4 7:15 9:8 

12:4 17:6 23:8,9,11 

36:18 45:12 55:22 

59:3 62:22 75:22 

Specialist 1:22 

Specialty 52:6 

species 12:16 15:18 

22:5,7 41:21 57:9 

62:11 85:16 

specific 21:1 84:3 

specifically 13:1 20:8 

36:16 52:8,18 57:6 

59:4 

spectrum 19:2,8,16 

39:7 

spent 78:16 

splits 53:16,19 

spray 35:14 

spring 9:2 93:13 

squeaky 49:22 

stabilization 24:9 26:14 

staff 7:22 

stages 35:6 

stakeholders 78:11,15 

standard 16:5 17:12 

standards 1:3,21 3:14 

3:20 4:12,20 7:5 16:5 

19:3 26:8 27:16 45:14 

48:15 74:21 

star 5:15,16 

start 12:3 17:17 18:6 

33:14 84:7 

started 2:6,13,20 3:12 

starting 40:16 43:8 

50:16 

state 23:20 28:8 39:17 

45:9 51:16 52:2 55:11 

62:19 71:19 73:21 

77:7 81:16 

stated 1:1 5:14 46:22 

47:13 

statement 27:8 

statements 32:12 

states 14:1 

stationary 68:6 

status 54:4 

stay 67:22 78:6 

steeped 85:19 

steps 49:15 58:14 

60:11 

Steptoe 28:13 

Steve 1:15 10:7,9 65:21 

sticky 93:3 

stipulation 58:9 

stop 85:3 

stopped 50:20 

store 62:3 78:11 

stored 61:9,10,10 

straight 2:4 

straightforward 48:3 

48:20 50:1 

strains 88:18 

stress 82:19 83:2,3 

strong 41:16 

stronger 49:14 

strongly 29:15 38:20 

structure 53:18 

struggling 46:4 

studies 70:10 87:7 

90:10 

study 86:4 90:14 92:1 

stuff 87:12 

stuffed 56:11 

Subcommittee 28:20 

29:4 77:15 78:22 79:9 

82:4 84:16 

Subcommittee's 25:8 

56:3 

submit 31:18 

submitted 52:13 

substances 24:4 25:9 

25:20 30:22 

substituted 26:11 

succeed 76:20 

sucking 20:21 

suction 65:3 

Sue 1:12 9:7,8 

sufficient 19:4 

sufficiently 30:13 

suggest 85:21 

suggested 82:9 

suggesting 62:4 

suggestions 17:18 

suicides 51:4 

suited 35:19 

sulfate 29:7 79:2 

summarize 56:4 

sunset 48:17 78:21 

79:9 

supplied 68:2 

suppliers 42:21 57:20 

supply 25:2 26:15 

37:12 38:12 45:22 

66:16 

support 8:17 25:3,13 

28:16 55:22 73:3 

78:20 79:8 82:11,18 

83:20 

supporters 41:16 

supporting 82:7 

supports 24:6,16,21 

25:5,11,22 26:5,12 

surface 22:21 35:10 

surprise 38:7 

survey 41:7 44:5 

survive 68:4 

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sustainable 22:22 

26:20 27:9 

Swaffar 1:18 11:8,9 

system 13:2 46:13 

63:15 64:1,15,17,19 

65:8,13,15 66:14 68:7 

68:18,21 69:15 

systems 63:18 64:21 

80:8 

T

table 14:20 68:2 82:19 

tables 67:15 

taken 21:11 49:13 56:9 

58:14 60:11 

takes 3:7 80:18 

talk 2:11 29:18 38:13 

85:6 

talked 37:9 65:17 

talking 52:9 66:11 

68:22 71:2 72:3 87:7 

tank 66:6 

tease 91:13 

technical 8:14,17 38:10 

84:21 

techniques 82:12 

teleconference 5:1 

telephonic 8:8 72:16 

73:8,13,16,18,21 74:3 

74:6,7,11,12,17,18,20 

75:1,3,7,10,13,15,16 

76:12,14,15,16,17,21 

76:22 

tell 34:20 84:12 

tend 22:21 

tends 21:16 

term 22:22 25:13 58:10 

terminology 82:6,13 

terms 19:5,16 20:3 22:2 

24:14 27:7 34:7 44:1 

61:14 68:10 82:10 

terrestrial 20:5 

tested 44:16 86:18 

testing 41:12 42:19,22 

44:2,6,10,12,12,17,19 

44:22 

thank 3:11,16 4:3 5:4,7 

6:22 7:5,11 9:15 10:6 

10:9,20 12:8 13:17,21 

16:15 17:3,9,22 20:9 

23:13,13,15 27:1,19 

28:1,3 31:21,22 34:15 

39:8,14 42:13 45:5 

49:1,2,8 50:6 51:8 

52:5 55:1,4,5,7 59:22 

60:20,21 62:14,15,21 

66:1 69:20 71:15 72:8 

75:17,18,22 76:2,3 

77:2 78:13 80:16 81:1 

81:4,5,14 89:3,6 

90:18 93:11,22,22 

94:5 

thanking 4:19 

Thanks 8:11 28:15 

55:13 77:9 

thaw 61:19 

Thicke 28:7 39:15 45:7 

45:11,12 49:19 50:12 

thickening 26:14 

things 7:19 18:9 33:19 

44:1 71:10 83:1 87:14 

91:10 

third 47:22 83:20 

thought 66:3 

thoughts 19:18,21 

threat 30:7 31:15,16 

three 6:5 7:13 40:6 

51:14 82:1 83:19 

throw 33:16 

THURSDAY 1:7 

tied 66:5 

timer 6:3,7 7:12 

times 14:22 22:4 43:17 

today 3:18 12:8 28:14 

45:12,18 46:13 51:4 

51:20 52:9 55:22 56:4 

58:3 74:14 78:1 

today's 3:19 4:22 

tolerance 43:11 

Tom 1:14 10:1 

tomorrow 48:5 

tool 34:13 

tools 21:18 34:9 

topic 89:14 

tops 22:20 

tortillas 54:1 

total 14:11 59:2,5 

touch 7:17 

tourism 13:4 15:7 

toxic 90:5 

toxicity 89:20 

track 11:11 46:13 

Trade 39:20 

train 66:3 

transbovines 82:10,11 

82:18,21 83:10,12 

91:9 

transcribed 6:19 9:1 

transcriptionist 8:22 

transfer 50:18 

transition 46:9,18 47:3 

47:14,17,22 48:2,22 

68:5 

transitioning 56:10 

transitions 47:16 

transproton 91:2 

transprotons 83:7 

90:21 91:17 92:5,14 

travel 66:12 67:6 

traveling 67:3 

treated 63:19,20 

treatment 63:5,15,21 

63:22 64:4,13,14,17 

64:19 65:4,11 66:13 

66:17 68:7,18 69:5 

tree 79:4 

trend 50:14 

trialing 41:16 

trillion 13:8 14:2,8 15:6 

tropical 14:15,19 

trouble 8:19 

truck 65:3 

true 41:21 

try 49:13 91:13 

trying 13:6 19:14 34:22 

39:12 43:10 53:6 82:1 

91:18 

Tuesday 3:9 6:15 

turn 57:16 

turning 5:2 

twice 51:5 

two 2:12 5:21 11:15 

34:19 46:13 47:19,22 

51:14 86:18 88:17 

type 21:2,7,15,16 59:13 

types 20:18 21:2 76:10 

79:6 86:17 

typical 65:2 66:13 

typically 34:21 64:1,22 

66:9 67:19 

U

U.S 13:8 14:2 42:10 

ultimately 41:1 

umbrella 63:16 

umbrellas 93:18 

unavailable 25:18 

understand 60:13 

63:11 69:13 87:5 

understanding 69:16 

understood 60:18 

unexpected 11:12 

unfortunately 32:21 

61:22 77:18 

unilaterally 48:16 

Union 37:8 

UNITED 1:1 

unmute 3:6 5:16 

unreasonable 31:6 

upcoming 4:7 5:5 

updating 84:8 

urge 29:15 74:21 

urging 84:4 

usage 40:9 41:15 

USDA 4:17 42:10 46:20 

47:11 48:3 

use 22:17 23:3 25:4,20 

29:7,17 30:6,17 31:11 

32:18 33:8,13 35:10 

35:11,13,18,19 38:1 

52:16,22 54:5,15,22 

57:14 58:9 63:12 

69:17,19 79:22 80:5 

82:11 83:8,9 

useful 27:17 

users 24:3 

uses 22:19 38:9 

usually 22:19 

utilize 63:14 

V

vacancy 11:12 

vaccines 83:18,22 84:1 

84:5,9,12 

vacuum 20:16 21:13 

65:3 

Valley 72:10 

valuable 29:2 31:19 

value 13:6 14:2,18 15:5 

57:18,20 

values 73:19 74:8 

variety 32:22 63:17 

various 7:4 19:15 78:14 

vast 66:21 68:6 

vegetable 74:4 

vegetables 24:11 25:17 

40:4 72:13 76:6 

versus 36:4 41:17 

57:10 60:14 81:12 

85:16 92:4 

Veterans 51:5,5 

veterinary 84:5,9 

viability 74:19 

viable 22:11 60:15 

video 20:14 

virus 35:1 

visibility 73:12 

vision 45:15 

vitro 82:12,15 

voices 76:2 

W

wade 19:15 

waffles 54:1 

wait 2:8 

wanted 43:7 89:10 

wanting 44:1 

wants 6:13 

Washington 4:9 72:10 

73:20 

wasn't 88:11 

waste 63:4,9,14,17 64:7 

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64:11,12,16,18 65:10 

66:13 68:18,20 

water 22:21 61:17 63:5 

63:14,17,21 64:11,12 

64:17,18 66:12,13,14 

66:16 67:15,21 68:2 

68:18,20 69:5,10 

way 7:3 16:3 22:8,13 

59:18 66:18 67:6 92:6 

92:8 

ways 40:16 47:19 70:15 

weapons 52:18 

webinar 1:5,9 3:21 4:3 

4:5,13 5:5,18 6:18 

78:1 93:12 94:2 

website 4:9 8:20 42:11 

week 3:20 4:8 93:17 

94:6 

week's 5:6 

weight 59:6 

welcome 3:1,18 

welfare 75:12 

well- 12:15 

went 2:15 94:9 

weren't 88:11 

West 22:18 

wet 80:6 

wheel 49:22 

wild 16:4 

wildcraft 17:12 18:3 

wildcrafting 16:5 

wine 79:14 

Wisconsin 51:9 

wish 80:16 

wondered 20:17 

wondering 17:11 19:17 

43:18 61:3 

words 67:22 

work 4:1,4,18,21 33:18 

44:5 63:2,7 73:1 

83:18 84:13 85:18 

88:21 

worked 6:9 

working 7:5 9:19 63:8 

world 29:20 45:19 

worse 34:10 

worth 13:8 

worthwhile 28:17 

wouldn't 19:12 38:7 

66:9 69:15 

wound 84:20 86:9,14 

86:17 87:4 

writing 52:13 

written 17:12 18:6,9 

23:13 25:10,21 28:4 

29:12 38:13 42:17 

78:19 79:7,16 82:2,17 

wrong 47:5,6 

X

Y

year 13:9 14:3 15:6 

33:5 73:9 

years 37:17 51:14 75:4 

yeast 24:21,22 25:2,4 

26:9 

Z

zero 63:14,22 

Zirkle 77:11 

0

1

1.12 90:4 

1.3 15:11 

1:00 1:9 2:2,4,15 

1:01 2:16 

100 57:9 

101 87:22 

12 5:19 

125 13:8 14:2,8 

14 11:12,14,14,16 

18 1:7 

1883 39:21 

1938 52:17 

1994 47:7 

1st 16:20 

2

2:27 94:9 

2005 88:17 

2006 47:7 

2011 13:7 

2013 46:21 48:16 89:20 

2014 15:9 48:12 

2015 47:10,13 86:4 

2015-105e 83:21 

2018 28:19 

2019 1:7 6:20 11:15 

93:13 

2022 50:9 

2023 50:9 

205.605a 24:7,22 

205.605b 26:1 

3

4

4 61:17 

5

5.64 90:3 

500 51:9 

6.2 15:6 

6.5 54:12 

606 58:9 

700 39:22 

7

8

6

800 8:15 

9

96 61:16 

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C E R T I F I C A T E 

This is to certify that the foregoing transcript 

In the matter of: Public Hearing Webinar

Before: USDA/NOSB

Date: 04-18-19

Place: webinar

was duly recorded and accurately transcribed under 

my direction; further, that said transcript is a 

true and accurate record of the proceedings. 

 ----------------------- Court Reporter 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 
1

 UNITED STATES OF AMERICA

 + + + + + 

 DEPARTMENT OF AGRICULTURE

 + + + + +

 NATIONAL ORGANIC STANDARDS BOARD

 + + + + +

 SPRING 2019 MEETING

 + + + + +

 WEDNESDAY

 APRIL 24, 2019

 + + + + +

 The Board met in the Courtyard Ballroom at

the Renaissance Seattle Hotel, 515 Madison

Street, Seattle, Washington at 8:30 a.m., Harriet

Behar, Chair, presiding. 

PRESENT 

HARRIET BEHAR, Chair

SUE BAIRD 

ASA BRADMAN 

JESSE BUIE 

TOM CHAPMAN 

LISA DE LIMA 

STEVE ELA, Vice Chair

RICK GREENWOOD 

DAVE MORTENSEN 

EMILY OAKLEY 

SCOTT RICE, Secretary

A-DAE ROMERO-BRIONES 

DAN SEITZ 

ASHLEY SWAFFAR 

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2 

STAFF PRESENT 

MICHELLE ARSENAULT, NOSB Advisory Board 

 Specialist, National Organic Program

DAVID GLASGOW, Associate Deputy Administrator, 

 National Organic Program

DR. PAUL LEWIS, Ph.D., Director, Standards 

 Division, National Organic Program

CLARISSA MATHEWS, Ph.D., National List Manager

DEVON PATTILLO, Materials Specialist, National 

 Organic Program

DR. JENNIFER TUCKER, Ph.D., Deputy 

 Administrator, National Organic Program; 

 Designated Federal Official 

ALSO PRESENT 

KRISTJAN BREGENDAHL, Devenish Nutrition

HEATHER BURLEY, McDaniel College

ADAM CLINE, USDA National Agricultural 

 Statistics Service (NASS)

STEVE FULLER, Washington State Department of 

 Agriculture (WSDA)

ANDREW MILKOWSKI, Ph.D., University of Wisconsin

 - Madison 

LOGAN PETERMAN, Organic Valley/CROPP Cooperative

ERIN SILVA, Ph.D., University of Wisconsin -

 Madison 

JENNIFER WASIELESKI, Kerry Foods

DAVID WILL, Chino Valley Ranchers; Methionine 

 Task Force 

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 CONTENTS 

Call to Order, Agenda Overview, 

 Introductions. . . . . . . . . . . . . . . . 4 

Secretary's Report . . . . . . . . . . . . . . . .13

 Scott Rice 

Welcome. . . . . . . . . . . . . . . . . . . . . .15

 Steve Fuller 

NOSB Report. . . . . . . . . . . . . . . . . . . .21

 Harriet Behar 

USDA, AMS, NOP Update. . . . . . . . . . . . . . .31

 Dr. Jennifer Tucker 

NASS 2019 Organic Survey . . . . . . . . . . . . .97

 Adam Cline 

Celery Powder Panel 

Dr. Erin Silva . . . . . . . . . . . . . . . . . 120 

Mr. Logan Peterman . . . . . . . . . . . . . . . 154 

Dr. Andrew L. Milkowski. . . . . . . . . . . . . 165 

Methionine Update 

Dr. Kristjian Bregendahl . . . . . . . . . . . . 211 

Dr. Heather Burley . . . . . . . . . . . . . . . 218 

Public Comments. . . . . . . . . . . . . . . . . 237 

Adjourn. . . . . . . . . . . . . . . . . . . . . 453 

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 P-R-O-C-E-E-D-I-N-G-S

 (8:32 a.m.)

 MS. TUCKER: Okay, good morning 

everyone. We're going to get started here. 

Welcome. We are officially opening the spring 

2019 National Organic Standards Board meeting.

 My name is Jennifer Tucker. I'm the 

deputy administrator for the National Organic 

Program, which is part of USDA's Agricultural 

Marketing Service.

 I'll serve as USDA's designated 

federal official for the meeting. First, thank 

you for being here and making the trip to 

Seattle.

 I'm going to start by introducing the 

USDA team. First, next to me here is Dr. Paul 

Lewis, our Standards Division director.

 Also supporting the meeting is our 

National List manager, Dr. Clarissa Mathews. 

Clarissa, stand up and wave.

 And next to her, Devon Pattillo, our 

agriculture marketing specialist and policy 

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analyst extraordinaire. So, say hello.

 Okay. Also in the room, we have David 

Glasgow. David, wave to everyone. David started 

as NOP's associate deputy administrator in 

January. 

 David has attended a couple of NOSB 

meetings before as he was previously the AMS 

director of public affairs. David has been with 

USDA for over 15 years. 

 Before he came to AMS, he was with 

USDA Office of Communications, the White House's 

Strong Cities, Strong Communities Initiative, 

rural development, and the Appalachian Regional 

Commission.

 He holds an undergraduate in economics 

and political science, and a law degree. 

 So, David has been a wonderful 

addition to the team. I've really appreciated 

our partnership, so thank you.

 We also brought with us Adam Cline. 

Adam, where are you?

 (No audible response.) 

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 MS. TUCKER: There's Adam right there. 

Adam is with the National Agricultural Statistics 

Service. 

 We invited Adam to join us because of 

the universally strong interest in organic 

surveys and data quality, both from the board and 

the community during our last meeting.

 So, Adam is an expert on USDA's 

organic surveys, and will give a talk after my 

NOP update this morning.

 To close the USDA introductions, I 

want to give a huge thank you to Michelle 

Arsenault, our advisory board specialist. 

 As always, this meeting would not be 

possible without Michelle. She does amazing work 

to bring us together. So let's give her a hand.

 Now, I want to thank the National 

Organic Standards Board who devote themselves to 

the organic community every day, and in a 

multitude of ways.

 There are currently 14 members on the 

board. We had a vacancy when Eric Schwartz left 

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for a new role earlier this year.

 That means we are currently recruiting 

for five new members of the board. The call for 

nominations is open, and will close May 20. I'll 

talk a little bit more about that later. 

 For reference, even with 14 members, 

the number of decisive votes needed to send a 

recommendation to the program is the same as when 

we had 15 members. Ten votes are needed.

 So, here's a quick overview of our 

three day agenda. 

 This morning, we'll hear from a very 

special guest, Steve Fuller, with the Washington 

State Department of Agriculture.

 Then, we'll hear an NOSB update, I'll 

provide an NOP update, and Adam Cline will speak 

with the group.

 After that, we're going to have a 

celery powder panel and a methionine update. 

 These segments really illustrate the 

unique collaborative relationship that the NOP 

and NOSB enjoys. 

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 We're trying new approaches together 

in a way that supports community needs and 

advances our work in an effective way.

 The rest of the day will be dedicated 

to public comments. 

 Tomorrow, we'll continue public 

comments, and then we'll turn to the 

subcommittees. 

 This will continue into Friday, when 

we'll have another panel. This one on 

biodegradable mulch film. 

 Again, this is another great example 

of collaboration, where both the NOP and the NOSB 

identified subject matter experts to speak to the 

group about the current research.

 We'll close on Friday with 

administrative activities and a look ahead. 

 So to close, I'd like to give a 

special thank you to Harriet, the chair of the 

board and this meeting. Let's give her a round 

of applause in advance for the great meeting.

 And now, Harriet, I turn the meeting 

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over to you, and to introduce the board.

 CHAIR BEHAR: Thank you very much, 

Jenny. Hello and welcome everyone to the 55th 

publically attended National Organic Standards 

Board meeting.

 Yes, we've been through 55 of these 

already. In the beautiful Pacific Northwest, in 

the vibrant city of Seattle, Washington.

 This time around, it's the East Coast 

folks who will be getting up in the middle of the 

night until they acclimate to the new time zone.

 The NOSB work is done by a dedicated 

group of board members, and I would like to let 

them introduce themselves now.

 Please state your name, where you're 

from, and what seat you hold on the board, 

starting with Ashley.

 MS. SWAFFAR: So, I'm Ashley Swaffar. 

I'm from Fayetteville, Arkansas. I sit in the 

farmer's seat.

 I work for Handsome Brook Farms and 

have a small organic vegetable farm in Arkansas. 

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 MR. CHAPMAN: Tom Chapman. I'm from 

Belmont, California. I work for Clif Bar & 

Company as a director of ingredient sourcing, and 

I sit in the handler's seat. 

 MS. BAIRD: I'm Sue Baird. I'm from 

Missouri. Executive director of the Mid-America 

Food Hub, and Mid-America Organic Association. I 

currently am serving as chair of the CACS.

 MR. SEITZ: Good morning. My name is 

Dan Seitz. I'm a public member on the NOSB. 

 I live in Great Barrington, 

Massachusetts, and I work as the executive 

director for the Council on Naturopathic Medical 

Education. 

 MR. MORTENSEN: Good morning. I'm 

Dave Mortensen, and I, back in August, moved to 

assume the role of chair of the Agriculture and 

Nutrition and Food Systems Program at the 

University of New Hampshire, in Durham, New 

Hampshire. I am the scientist on the board.

 MR. BRADMAN: Asa Bradman, and I'm in 

the Center for Environmental Research and 

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Children's Health in the School of Public Health 

at UC Berkeley.

 MR. RICE: Scott Rice. I sit in the 

certifier's seat. 

 I'm the external affairs coordinator 

for the Washington State Department of 

Agriculture Organic Food Program. And I serve as 

the secretary of the board.

 MR. ELA: Steve Ela, Ela Family Farms 

in Hotchkiss, Colorado. Western side of the 

state. 

 I sit in the farmer's seat, I serve as 

vice chair, and I am chair of the crop 

subcommittee. 

 MS. OAKLEY: Emily Oakley from Oaks, 

Oklahoma. I have a farm, Three Springs Farm, and 

I sit in the farm seat. And I'm a full-time 

farmer.

 MR. BUIE: I'm Jesse Buie, president 

of Ole Brook Organics in Brookhaven, Mississippi. 

I sit in the farmer's seat, and I'm the vice 

chair of crops. 

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 MS. ROMERO-BRIONES: I'm A-dae 

Briones. 

 I work for First Nations Development 

Institute out of Longmont, Colorado, but I run 

the California office, and we serve indigenous 

producers in Alaska, the mainland, and Hawaii. 

And I live in Lodi, California. Public seat.

 MS. DE LIMA: Hi, Lisa de Lima. I sit 

in the retailer's seat. 

 I live in Gaithersburg, Maryland. 

It's a suburb of Washington, D.C. And I'm vice 

president of grocery at MOM's Organic Market.

 MR. GREENWOOD: I'm Rick Greenwood. 

I sit in the environmental seat. 

 I'm a professor at UCLA in the School 

of Public Health, and I'm a certified organic 

avocado grower. And I'm from San Diego, 

California. 

 CHAIR BEHAR: I'm Harriet Behar. I 

sit in the environmental seat. And what am I? 

I'm an organic educator, an organic inspector, an 

organic farmer, an organic advocate, and organic 

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consumer. 

 And I've been to not all, but most of 

the 55 meetings of the National Organic Standards 

Board. With that, Scott, would you like to give 

the secretary's report?

 MR. RICE: Sure. Madam Chair, the 

summary notes of the October 2018 biannual 

meeting in Saint Paul have been distributed to 

the board members. Are there any corrections or 

comments?

 (No audible response.)

 MR. RICE: All right. I had one 

comment. I was a little flummoxed by a bit of an 

anomaly in the transcripts that I found in the 

fall meeting. I found roughly 19 separate 

references to beards.

 I'm going to get the Livestock 

Committee to look into that and I'll report back. 

Thank you. 

 CHAIR BEHAR: Living beards? Okay, so 

with that, I would like to turn it back over to 

Jenny, and she will introduce our first speaker. 

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 MR. RICE: All right. Thanks, 

Harriet. Back to me. 

 I have the pleasure of introducing 

Steve Fuller, the assistant director of Food 

Safety and Consumer Services Division of our 

Department of Agriculture. 

 It's the division in which our program 

resides. One moment here. 

 Steve leads the Food Safety and 

Consumer Services Division, which ensures the 

availability, safety, and integrity of the 

state's food supply.

 He previously served as policy advisor 

to the director, working on legislation, budget 

requests, and policy decisions. 

 Before joining the director's office, 

Steve built WSDA's first food emergency response 

team. 

 And Steve has a Master's degree in 

Public Health from UCLA, a Bachelor's degree in 

Environmental Health from California State 

University in Fresno. Steve, welcome. 

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 MR. FULLER: Great, well thanks very 

much for having me. I really appreciate being 

here. 

 And I apologize for having my back to 

all of you, but my intent is to welcome everyone 

to the meeting. 

 So, good morning. Thank you so much 

for coming to Washington state. It's a 

tremendous pleasure to have the board and all of 

its guests here with us.

 We hold your work in very high esteem. 

And it's an honor to be able to provide whatever 

modest support we can to your work.

 We're very happy to have our own Scott 

Rice holding the certifier seat on the board. 

Scott's a tremendous asset to our program, and 

we're happy to share him with you.

 We have a rich organic tradition here. 

We trace the roots of Washington's organic sector 

to a farmer-driven movement in the early 1970s to 

found Tilth Producers. 

 Tilth Producers' work over a dozen or 

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more years led us to the state legislature, 

passing the Washington Organic Food Products Act 

in 1985.

 The State Department of Agriculture 

began certifying farming operations to our state 

standard in 1987 under the leadership of someone 

you may know, Miles McEvoy. 

 Today, Brenda Book leads our Organic 

Certification Program. On paper, I became 

Brenda's supervisor a little more than a year 

ago. But I can tell you that in the course of 

that year, I've come to appreciate that she's 

just as good at managing up as she is at leading 

the team under her. I'd describe her less as a 

program manager and more as a force of nature. 

 I've become so proud to have a small 

role on our team. We certify over 1,300 

operations of all shapes and sizes to the USDA 

organic regulations.

 Agriculture in this state is a very 

big umbrella, and we're proud to support both 

small, diversified, direct market growers, 

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alongside row crop producers exporting to 

international markets.

 Over 90 percent of the organic apples 

and sweet cherries that this entire country can 

squeeze from the earth are grown right here in 

Washington state.

 Now, I hear that cherry harvest may be 

a couple of weeks late this year, but don't fret. 

They're still on their way.

 By some unjust quirk of latitude, 

California seems to beat us to market every year, 

but hang on just a little bit, and the superior 

Washington organics are on their way.

 You know, agriculture in general has 

some really significant challenges on its hands 

these days.

 For the average farm, revenue is down 

and debt is up. Most farmers have other jobs off 

the farm to try to make ends meet.

 And when a farmer whose land has 

supported the family for generations has to sell, 

I can only imagine the level of heartbreak and 

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sense of failure. Even though the cause very well 

may be something macroeconomic, beyond his or her 

control.

 On average, our farmers are getting 

older. We're having trouble attracting younger 

people to the profession. And we're losing 

valuable crop land to urbanization and climate 

change. And into this fray, steps the audacious 

idea of organic. 

 The idea that if we can connect 

consumers to a production ethic that resonates 

with them, they might be willing to pay a little 

bit more for that.

 And if we can get our farmers a little 

better return, well then maybe not so many farms 

will have to be sold.

 Maybe a new generation full of vigor 

will put their hand to the plow. Maybe farming 

communities, with their roads and warehouses and 

schools can continue to be a thing.

 But the only possible way organic can 

keep providing its returns is if people keep 

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trusting that organic means something.

 So, I hope I'm not being cliche by 

reading you this 1997 quote that I read from 

Michael Sligh, in his editorial on the original 

development of the U.S. Organic Standards.

 The soul of organics is at stake. If 

this process proves to be too onerous or false, 

the soul of organic will be lost. Then, those 

who love organic will have two choices.

 To reclaim the word and the concept, 

or to find new words and concepts. The future 

will determine this. 

 Meanwhile, the central guiding 

principles for our work, including the evaluation 

of any proposed rules, should be integrity, 

fairness, and transparency.

 So that resonates with me, and that's 

why I feel so honored to be able to welcome you 

to this event in this place.

 The board's work here, with broad 

community input, influencing and sometimes making 

public policy, can be the embodiment of those 

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principles.

 I have no idea what the board should 

do with allyl isothiocyanate, but I very much 

believe in the value of your doing it.

 There will be disagreements over the 

next few days. You will wrestle with hard 

things, and that's very good.

 To the degree that you can all listen, 

advocate, and for a few of you, vote, with 

integrity, fairness, and transparency, you will 

create the value of organic. 

 So again, welcome. Thank you all for 

being here. May you do your work with the best 

that you have to offer. May it begin.

 CHAIR BEHAR: Thank you very much, 

Steve. 

 MR. RICE: Thanks, Steve.

 CHAIR BEHAR: I know Michael Sligh 

will appreciate that he was brought here through 

your words. 

 MR. RICE: Thanks, Steve. I wanted to 

also remind everyone that WSDA and Tilth Alliance 

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will be hosting a reception tomorrow evening from 

6:00 to 8:00. And that's taking place in the 

Northwest Room, which is on the third floor. So, 

just a quick couple floors up above us.

 We've got some reminder flyers out on 

the front table with a reminder of that room, as 

well. So, it's Northwest Room, third floor. We 

hope you guys can join us.

 CHAIR BEHAR: Sounds like fun. Okay, 

so now, next on the agenda is I will give the 

NOSB chair report. 

 This is my first public meeting as 

chair of the National Organic Standards Board, 

and I want to say what an honor it is to work 

with such a fine group of dedicated board members 

who truly work to represent their constituency's 

concerns, as well as the overall health and 

vitality of organic agriculture, and the 

marketplace, as we debate and decide materials, 

guidance, and regulations for submission to the 

National Organic Program.

 I especially thank the subcommittee 

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chairs, who have put in extra time to make sure 

that everything goes smoothly and gets done on 

time.

 I've spent many years as a member of 

the public watching these meetings, and I can say 

that being on the inside has greatly increased my 

understanding of the process, both the 

opportunities and challenges.

 There is much positive to congratulate 

ourselves as organic advocates. The organic 

market is growing.

 Organic consumers have access to food 

and fiber that is healthier for them and 

represents so many answers to the environmental 

challenges we face, both regionally and globally.

 More farmers are continually improving 

their farming systems by adopting fundamental and 

advanced organic farming practices, providing a 

healthy lifestyle and environment for themselves, 

their livestock, and their local communities.

 In my mind, there's nothing more 

beautiful than working with and within the 

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natural systems that have evolved so beautifully 

on our precious planet.

 This is not an unachievable dream. I 

see it all the time on the many excellent organic 

farms and the processors that I visit.

 And in my life, I am greatly enriched, 

both by continually improving my organics farm, 

my farm's organic system, and biodiversity every 

year. 

But there are dark clouds obscuring some of this 

sunshine. 

 Known cases of fraud and subsequent 

sale of non-organic grains as organic into our 

markets has highlighted the need to deal with the 

loopholes and gray areas in our regs, and 

enforcement is an immediate need.

 This fraud has been discovered not 

only from foreign markets, but also domestically. 

There is unfortunately a long list of areas where 

enforcement and additional rulemaking is sorely 

needed.

 Pasture for ruminants, origin of 

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livestock, outdoor access for poultry and other 

livestock, questionable uses of various 

materials, approval of hydroponic operations that 

do not meet the same standard as soil-based ones, 

lack of consistency by many certifiers, and the 

organic certification system needs more oversight 

and accountability.

 Fear that a client might legally 

challenge a certifier decision has kept both the 

certifiers and the NOP from regulating to the 

clear wording and intent in many of these areas.

 Instead, allowing clients to massage 

the regulatory language to fit their own needs 

and their own operation, and their own 

interpretation.

 This does not hold everyone to the 

same high standard, and is one of the 

contributors to our current problematic 

situation. 

 The NOP has also limited their own 

work of what they're going to put to regulations 

based on the many recommendations given to them 

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by the NOSB, as well as the work of the NOSB.

 Various issues have been taken off the 

work agenda, or the NOP has decided not to work 

on implementation of various NOSB 

recommendations.

 Examples of areas that the public has 

noted in their recent comments include, whatever 

happened to work on inerts?

 You know, why don't we have the animal 

welfare standards? Why aren't we looking at 

hydroponic? It's such a different system. 

 What about BPA in packaging? Why 

aren't we hearing more about the peer review 

system of the NOP? And maybe we will. Whatever 

happened to the apiculture standards? Pet food, 

and more.

 These items were all mentioned many 

times by various commenters at this meeting, 

including the former deputy administrator of the 

National Organic Program, and expressing great 

frustration.

 The public has stated the NOP needs to 

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develop better systems to address these important 

areas in a more timely way. 

 We are a young program in the bigger 

scheme of things at the USDA. And when we find a 

gray area or a loophole in the reg, we should be 

allowed to fix it as soon as possible, before it 

becomes the norm. Since this reg is still in its 

infancy, and these problems are bound to come up, 

and need to be addressed.

 So, I think we need special 

dispensation from this administration to 

understand that when we need regulations, we need 

them sooner rather than later because we are so 

new.

 However, our community is tenacious. 

And I do not doubt that these issues will 

continue to be part of the conversation until 

they are resolved.

 I can see that the hardworking NOP 

staff is working towards solving these problems, 

and I commend the deputy administrator, Jennifer 

Tucker, for her willingness to engage openly and 

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transparently with the community.

 However, we are playing catch-up in 

many ways to tighten up the oversight and 

enforcement of numerous areas of organic 

production, which is causing hardship in many 

sectors of organic.

 We need to become more proactive to 

catch the problems before they become the norm. 

This is the responsibility of both the organic 

community and the program.

 It is obvious we have the passion and 

drive to keep pushing for consistency in the 

implementation of the high standards we all 

worked so hard to develop, and provide the 

guidance to the National Organic Program.

 We are a very unusual agricultural 

sector. We want to be regulated. We want those 

regulations to be followed, and we want them to 

be strict yet practical. I have visited 

literally thousands of organic farms, and many 

hundreds of organic processors.

 Organic productions is not just 

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something they do, and not just for the money. 

It comes from their hearts, and has deep meaning 

in their lives.

 That organic certificate is something 

they are proud of since it represents their 

intense commitment and good work that they are 

doing.

 Organic consumers count on us to make 

sure the food they are getting is what they 

expect it to be. Organic. The NOSB and the NOP 

have a responsibility to live up to their trust 

in our work.

 We, the organic community, the organic 

marketplace, organic advocates, the NOSB, and the 

National Organic Program cannot let down the 

consumers and the vast majority of owneroperators on the farms, and processors, who are 

doing it right, and are now competing with others 

who cut corners or commit fraud.

 We understand there are problems, but 

I encourage all commenters and board members to 

keep in mind that we are here to find solutions. 

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 I believe that if we are willing and 

we work together, we should be able to find a way 

to improve our rules and enforcement in a more 

timely way, and honor the hard work and desires 

of the organic community.

 The entire organic community and the 

marketplace depends on the integrity of the 

organic label. Without integrity, we are 

nothing. 

 Lastly, I sit on the environmental 

seat of the board, and I continuously find myself 

in awe of the beauty and diversity of life on our 

planet.

 I've brought along a variety of 

creatures that each of you should be able to 

choose from during public comment and after, as 

well as the board members. 

 There are little animals. Marine 

life, farm animals. There's a variety of little 

finger puppets. 

 There's wind-up baby chicks, because 

after all, we are talking about methionine. And 

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especially, there's some really cute frogs if you 

go in the bottom of the basket.

 So, I will invite -- you know, over in 

the next few days, but I'm going to pass it 

around to the board members first so they get 

their first choice to choose one of whatever 

calls you first.

 So, I brought a whole bowl full. So 

these are the farm animals, if you're called to 

farm animals. And there you go. So, thank you 

for that. Next up is. 

 (Off-microphone comments.) 

 CHAIR BEHAR: The chicks are really 

cute, don't you think? But the frogs are, too. 

Don't forget about the frogs. Okay, so next up 

we have Adam Cline.

 (Off-microphone comments.)

 CHAIR BEHAR: Oh, you're going to? 

Okay.

 (Off-microphone comments.)

 CHAIR BEHAR: Okay, I'm sorry. Next 

up is -- I had it on my -- okay, wrong. All 

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right, next up is Jennifer Tucker with the NOP 

update. 

 MS. TUCKER: Okay, good morning 

everybody. Okay, let's get started with the 

National Organic Program update. 

 I'm very pleased to be here today, and 

again, thank you for being here.

 So first, I always like to open my 

section by acknowledging our certified organic 

operations. 

 There are 75 certified organic farms 

and businesses here in Seattle alone, and more 

than 1,400 across the state. 

 So, if you are one of them, a 

certified business from Washington state, please 

go ahead and stand up so we can give you a round 

of applause.

 There you are. Welcome. We're very 

happy that you are here. 

 Now, let's take a look at the countrylevel and worldwide numbers. Our end of 2018 

certified operations count was just over 43,000. 

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 So, 43,004 certified farmers around 

the world. That was approximately a four percent 

increase over 2017.

 That means that more than 1,000 new 

farms and businesses got certified in the United 

States between the end of 2017 and the end of 

2018, so we're about 27,500 U.S. producers.

 So, that pride that people can take in 

their new certificates, there were 1,000 of those 

folks who received new certificates last year, 

so, good for them.

 Internationally, we're at about 

15,500, which is an increase of just over 700. 

So, the count of certified operations does 

continue to go up.

 So before I start the formal 

presentation, I'd like to clear the air. There 

have been some recent discussions about a 

conversation that the National Organic Program 

had with an organic group that visited D.C. a 

while ago.

 The group asked about a scenario 

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involving hydroponics and container growing. The 

scenario was pretty specific, so we asked for the 

specific operation and the certifier involved.

 In the absence of a specific case, I 

allowed myself to get drawn into a hypothetical, 

which is always risky.

 I was sharing thoughts on policy 

complexities and nuances that can play into any 

particular case evaluation.

 We emphasis that we would evaluate any 

complaint on a case-by-case basis, and asked the 

group for the certifier and operation.

 The comments in that meeting and the 

case study itself have since been taken out of 

context and out of proportion.

 The comments were not a judgment on a 

particular case. They were not a program 

decision or policy statement. 

 Whether an operation is soil-based, 

hydroponics, or container-based, the National 

Organic Program follows the rules and applies 

them to specific case facts. 

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 We have since learned who the 

certifier in question is, and we've engaged with 

them to learn about what's happening on the 

ground.

 We've also raised specific regulatory 

questions with our council's office. Those 

questions are currently being evaluated, and I'm 

happy to talk about what they are.

 Here are some key points. Glyphosate 

is not allowed in organic production. 

 The National Organic Program reaffirms 

the need for all organic operations, including 

hydroponic and container operations, to 

demonstrate compliance with the regulations.

 This includes confirming that no 

prohibited substances come in contact with an 

organic crop, and requiring that production 

practices maintain or improve the natural 

resources of the organic operation.

 Certifiers are responsible for 

assessing individual operation compliance with 

the rules based on site-specific situations. 

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 The work of the National Organic 

Program is based on regulations and on facts. 

Bring us facts and give us complaints with 

evidence.

 Large and small, soil-based or not 

soil-based, we will investigate those complaints 

using the regulations and the evidence before us.

 We do that every day. It's the core 

of our mission. We know that some in the organic 

community do not want hydroponics to be part of 

organic. And there was a 2010 board 

recommendation on that topic. That 

recommendation did not have enough details to 

support a rule.

 To further explore those details to 

support rulemaking, between 2015 and '17, the 

National Organic Program supported a fair, open, 

and transparent process to support a task force.

 We also supported the board's 

deliberation on this issue. After a lot of work 

and time, the community did not reach consensus 

on specific recommendations for hydroponics. 

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 Therefore, hydroponics and container 

growing continue to be allowed in the organic 

program. The program and its certifiers continue 

to use the regulations and concrete facts to 

certify and oversee these operations.

 Soil-based systems, hydroponic 

systems, and container-based systems are all 

accountable to the same standards, and we enforce 

accordingly.

 So now, let's go back to the main 

presentation. NOP has four key priority areas. 

Everything we do, all the projects that we select 

fit into these four areas, and they are all 

oriented towards protecting organic integrity.

 The first goal area is strong organic 

control systems, which lead to trusted people, 

processes, and rules. 

 Our second priority area is farm to 

market traceability, which supports worldwide 

supply chain integrity.

 Third, robust enforcement. Core to 

all of our work is creating a level playing field 

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for all.

 And then, fourth, we continue to 

support the standards and collaborate with the 

community, increasing engagement and 

transparency.

 All our priorities are oriented around 

these four priorities, which reflect the needs of 

organic integrity around the world.

 So, we have a lot to cover in a short 

time, so here's an overview of my update topics.

 I'll give some program updates. I'm 

going to give an overview of the Farm Bill. I'll 

review the call for board nominations. 

 I want to talk about organic imports 

and the enforcement activities we're doing there 

using risk-based oversight approaches.

 I'll highlight our Dairy Compliance 

Project. We'll talk about the Strengthening 

Organic Enforcement proposed rule.

 I'll be pleased to launch the Organic 

Integrity Learning Center. And then, we will 

celebrate our INTEGRITY Data Quality Award 

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winners.

 First, let's start with program 

updates. Our first update is on origin of 

livestock. AMS is grateful for NOSB's and 

organic stakeholder interest in this rulemaking.

 A lot of letters have come in very 

thoughtfully describing the need for this rule. 

AMS is exploring having a second origin of 

livestock proposed rule on the fall 2019 OMB 

regulatory agenda.

 So, due to the length of time from the 

first proposed rule, and changes in the industry, 

the current thinking is to do a second proposed 

rule, not a final rule.

 We've gotten a lot of feedback on that 

point. We will continue to explore that within 

USDA, and with Office of Management and Budget, 

to determine what our options might be in that 

case.

 However, I can reaffirm that AMS is 

exploring moving ahead with this rule. 

 Our second program updates relates to 

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the National List. The team's doing a fabulous 

job of moving National List rules through the 

system.

 There was a final rule published on 

December 27. It had 35 changes. Most of those 

changes were effective at the end of January 

2019.

 We have a final rule in clearance 

right now to implement the fall 2017 NOSB 

recommendations, and we also have a proposed rule 

out.

 The comments for that closed April 16. 

That relates to spring 2018 NOSB recommendations. 

So, you can see these rules. 

 We'll have shorter rules coming 

through the pipeline faster to get tools out to 

the organic community in an efficient and 

effective way.

 Upcoming in development, we have the 

2019 sunset materials renewal. That will be a 

Federal Register notice. We expect to publish 

that this summer. 

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removals. That will be a proposed rule. 

Recommendations are currently under review.

 And then, we will have a proposed rule 

for the fall 2018 NOSB recommendation. So, we 

expect to publish that proposed rule this fall.

 So, next, I'd like to give an update 

on our compliance database. 

 Last fall at our meeting, I mentioned 

that we had just started building a new database 

to better align our electronic systems with other 

federal enforcement agencies.

 Our new compliance system was launched 

in March. And this was the direct result of the 

increased funding that we received last year. 

 It is already helping us see patterns 

across our cases. It's providing more tracking 

for our investigative reports, tracking our 

corrective actions from violators.

 We are doing a lot of enforcement 

work. A lot is happening out in the community. 

We can't always talk about our enforcement 

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successes. 

 This compliance database will help us 

get more visible data to keep the pipeline of 

investigations moving, and to get you, the 

community, better information about our 

enforcement work.

 Next, some program updates on 

staffing. We have some new NOP leadership and 

staff. I just introduced David earlier as our 

new associate deputy administrator.

 We're also bringing in a trade systems 

director. He starts in mid-May, and we actually 

stole him from Customs and Border Protection.

 He wants to come over. He grew up on 

a dairy farm. We wants to come over from CBP to 

help us understand how to most effectively work 

with CBP.

 And so, I think he'll be a wonderful 

addition to the team.

 We added an accreditation manager last 

fall, and we finally, woohoo, have a quality 

manager. 

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quite some time, and so, I'm really pleased to 

have that position filled.

 So, upcoming announcements. I'm going 

to change that to open announcements. We have 

job announcements on the street right now, and 

please, please, please tell your friends.

 So, Insider came out yesterday. 

Another Insider came out today. 

 We are hiring livestock compliance 

specialists. That's a position that was 

announced just this morning. 

 We will hire up to two or three of 

those. They will be based in Washington, D.C. 

 They'll do both policy development and 

compliance and enforcement work, including 

leading the Dairy Compliance Project.

 So, please, if you know qualified 

livestock compliance specialists, please 

encourage them to apply. 

 We are recruiting from across the 

nation for this, and you do not need to be a 

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current federal employee to apply.

 And so, very important to get the word 

out. It will be capped at 75 people. So, if you 

know somebody, please have them get in their 

application early.

 Yesterday, we announced remote 

accreditation auditors. So, this is new for us. 

 We're going to hire multiple auditors. 

They can be based in Washington, D.C., or 

anywhere in the country.

 This is incredibly rare for us to do. 

Recruiting accreditation managers and auditors is 

really difficult. It's hard to get folks to come 

to D.C. full-time.

 So, we are experimenting with 

recruiting for auditors out there in the world.

 Now, the government has fairly short 

time frames on application dates, so please, 

please take a look at those applications, and if 

you're interested, and interested in helping 

spread the word, please do so as soon as 

possible. 

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 So, anyone who does end up working for 

the National Organic Program will have the 

privilege of attending our holiday sweater 

contest next year. So, there we are. We have a 

motley crew there.

 But, this is the National Organic 

Program at the end of December at our end of year 

celebration party.

 Happy Administrative Professionals' 

Day. So, last April, the NOSB also started on 

Administrative Professionals' Day.

 So, that day, I acknowledged and 

thanked our National Organic Program secretary, 

Joan Avila, who is fabulous and continues to take 

hundreds of calls into the front office.

 So, this year, I get to say thank you 

again to Joan. 

 But I also want to tell you a story 

about how another administrative assistant is 

making a real difference in another organic 

organization.

 So later this morning, I'm going to 

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share that the Georgia Crop Improvement 

Association is one of this year's winners of our 

Data Quality Award.

 This award is given to the certifiers 

with the best data quality in the Organic 

INTEGRITY Database. 

 When I told the Georgia team about 

their award, Terry, who is in charge over there, 

shared with me that Jeanne Gonzales, their 

administrative assistant, is the person 

responsible for designing and maintaining 

Georgia's inputs to the Organic INTEGRITY 

Database.

 Terry shared with me that Jeanne's 

investment in data and the database is what 

happens when a person truly believes in and 

dedicates themselves to a project.

 There are administrative professionals 

like Joan and Jeanne across the organic community 

who protect organic integrity every day. Let's 

give them a hand.

 Now, let's take a look at the Farm 

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Bill, which passed in December, so since we've 

last seen you. 

 There were a number of provisions 

directly related to the National Organic Program, 

so I'm going to review those here.

 A number of provisions have already 

been integrated into our Strengthening Organic 

Reinforcement rulemaking. That rule was already 

on the regulatory agenda when the Farm Bill 

passed. 

 And so, that rule is integrating and 

expanding language from the Farm Bill into the 

rule itself.

 So, three areas in particular there 

are eliminating exclusions, import certificates, 

and certifier office oversight.

 The Farm Bill also called for a 

collaborative working group between Customs and 

Border Protection, NOP, and the Animal and Plant 

Health Inspection Service within USDA.

 We have already identified members 

from that. CBP and APHIS have been 

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extraordinarily responsive. We have the work 

group identified, and we'll kickoff in the 

upcoming weeks.

 The next category is technology. In 

May, we're going to be sending over money to 

Customs and Border Protection to develop the 

organic import certificate module in their 

existing import system.

 That will get data into the system 

from organic trade. We also need to be able to 

get data out to see what is happening and to 

pursue investigations.

 That requires both Memorandum of 

Agreement and data access. So, we're working 

closely with CBP to make sure both happen.

 The Farm Bill also included additional 

funding for an organic oversight system globally. 

 And so, we are envisioning what that 

system is. A lot of it will start with the 

import certificate project.

 Finally, there were changes in the 

Farm Bill related to the NOSB. The call for 

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nominations this brings includes the changes 

required in the Farm Bill. 

 And the Farm Bill also formalized 

voting rules already in practice with the board.

 So, let's talk about the call for 

board nominations. Nomination period is open. 

It is due May 20, 2019. It was announced in the 

Federal Register in mid-March.

 There are five vacancies. Up here on 

the board, we've got environmental protection 

resource conservation. 

 Someone who owns and operates, or an 

employee of an organic farming operation, two 

people who own or operate, or employees of an 

organic handling operation, and one person who 

owns or operates or is an employee of a retail 

establishment with significant trade in organic 

products.

 And I believe we have a flyer out 

front if you want more information. It's also 

posted on the NOSB website. Just search Google 

for NOSB nomination process, and you will find 

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it.

 So I'd like to take some time to talk 

about our organic import oversight, some of the 

risk-based oversight projects we've been working 

on.

 Before I get into that, I do also want 

to highlight what we're doing domestically, as 

well. There is domestic fraud, and we are much 

better able to address that fraud given our 

current capabilities and tools.

 We have built our relationships with 

the Office of Inspector General. They have taken 

on a number of cases with us. 

 What used to take months and years, in 

terms of investigations, is down to weeks and 

months. Investigations do take time, and they do 

take evidence, and we're not always able to talk 

about that work while it is underway.

 It does get communicated in different 

ways on the website and in the public sphere as 

word gets out.

 Enforcement is central to our mission 

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and we spend an awful lot of time on it. Our 

Compliance and Enforcement Division has expanded, 

using additional support made possible by 

incremental funding last year.

 So, that work continues. It's often 

quiet, but it is happening. 

 Let me talk about six specific 

projects that we're doing related to import 

oversight. And some of these projects can also 

relate to our domestic work, as well.

 So I'm going to run across these six, 

from left to right. First, I want to talk about 

the role of farm-level yield analysis in our 

approach to import oversight.

 We recently completed a 100 percent 

review of farm-level records coming from three 

specific countries and three specific commodities 

in the Black Sea region.

 We did this because we've talked a lot 

about supply chain traceability. And supply 

chain traceability is vital, but we also must 

know what's actually happening on these farms. 

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 So, we took a look at all of these 

farms' Organic System Plans and inspection 

reports. 

 In doing this, we found that some 

yields are much higher. The reported yields are 

much higher than we would expect, given regional 

yield statistics.

 So, sometimes farms are reporting up 

to two and three times the average for the 

region. And that's a problem.

 So, we are now investigating that 

further. We have farm-level data that supports 

those investigations.

 Second, we are continuing supply chain 

research. We have started a new project to map 

specific supply chains and relationships that may 

not reveal themselves by looking at official 

paperwork. 

 So, using advanced dark web research 

techniques, we are finding patterns of ownership 

and business relationships that may support 

further investigations. 

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 Third, fumigation investigations. We 

are continuing to work closely with APHIS. 

 I'm going to share some more 

information and success story on that when we get 

to the next slide. They've been very supportive 

of our efforts, both in data and on the ground 

boots efforts.

 Fourth, ship-specific surveillance. 

We do continue to conduct ship-specific 

surveillance when we get credible and supported 

information about incoming organic commodities. 

More details helps.

 This supply chain analysis is helping 

us learn about patterns. And even when 

everything is confirmed to be organic and in good 

standing, which it often does, it does signal to 

the community and that trade that we are 

watching. 

 We will ask about any ship at any 

time, and that surveillance is essential to 

keeping everybody honest out there.

 All of this work has supported our 

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ongoing oversight and investigations of 

certifiers, particularly in the Black Sea region.

 So, certifiers are investigating their 

operations, and then we are investigating and 

overseeing certifiers.

 For example, we have found that two 

certifiers oversee most of the farms that have 

abnormally high yield figures.

 So, we are taking the necessary steps 

to hold those certifiers accountable for the 

certification decisions.

 They need to explain to us how those 

yields are as high as they are. Those 

investigations will continue. 

 Finally, our sixth project is that we 

are working with IOAS, which is an international 

organic accreditation body, to conduct two 

country commodity studies.

 Our goal is to develop standardized 

approaches for examining high-risk or emerging 

risks at a commodity level across an entire 

country. 

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 This will further advance our ability 

to rapidly respond to emerging concerns. 

 So, all six of these initiatives have 

been underway and are continuing. They directly 

support our investigation and enforcement action.

 So, let's take a look at some of the 

successes. As a result of the new directives on 

unannounced inspections and residue GMO testing, 

100 operations -- about 60 percent of operations 

in the Black Sea region -- have lost 

certification. And there is continuous 

scrutiny of the remaining certified operations.

 The impact is real. There's been a 

reduction in the organic grain and oil seed 

imports from the Black Sea region in Turkey.

 In 2016, those imports represented 

almost 50 percent of the dollar value of those 

imports. In 2018, they represented just 21 

percent.

 In terms of fumigation, we are seeing 

increased importer awareness, and our partnership 

with APHIS is working well. 

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 There are shipments that have not been 

sold as organic. They have been relabeled. So, 

let me tell you a specific illustration of how 

this has worked. 

 In March, the Port of Philadelphia 

notified the National Organic Program that they 

had fumigated a shipment of bell peppers that had 

organic label. The shipment included about 350 

boxes. 

 So, this was actually the second 

report that we had received from Philadelphia 

about fumigation, and they included label 

photographs and supply chain documentation, like 

invoices.

 Unfortunately, the first notice 

arrived during January, when the NOP was out on 

furlough. 

 So, label photographs are critical 

evidence, but they're actually not included in 

the text-only automated fumigation reports that 

come to us from the APHIS database.

 So, we were able to use the 

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photographic evidence and available trade data to 

identify and contact our bell pepper importers.

 The importer reconditioned the 

peppers. That's the term they use. 

 By removing they literally removed 

every single sticker off every single pepper, and 

replaced those individual stickers with a nonorganic sticker number. They also papered over 

the word organic on all bulk containers. 

 So, in addition to providing evidence 

of this reconditioning, the importer also shared 

that a similar shipment was on route to Miami, 

and would also be reconditioned to remove the 

organic claims.

 So, to further this work, the NOP has 

proposed a statement of work to APHIS.

 In order to expand this type of 

information sharing, we want to expand to the 

ports of Miami and Long Beach, where a lot of 

organic products come in.

 Next, I'd like to give a report out of 

our Dairy Compliance Project. And this has been 

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a significant domestic initiative this year.

 I'll talk about the process, the 

policy outcomes, and the compliance outcomes. 

 First, we'll take a look at the 

players. Who's been involved in this project? 

We have AMS auditors and NOP compliance 

specialists. Our auditors are coming from across 

AMS, particularly the livestock and poultry 

programs. 

 They have a lot of auditors who know 

a lot about livestock, and we've given them 

specialized training on the organic standards.

 Many of them had done accreditation 

audits with us before, so they already are 

familiar with the regulations.

 On selected cases, the Office of 

Inspector General has also gotten involved, as 

has the Animal and Plant Health Inspection 

Services. Certifiers have been an important part 

of this work, as well. 

 All of our visits for the Dairy 

Compliance Project have been unannounced. These 

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have all been unannounced visits. They've 

occurred nationwide.

 They have been single day and multi 

day, depending on the circumstances of the 

operation. 

 We consider the project to be highly 

successful, and our 2019 program has already 

started. The unannounced visits will begin 

actually this week. Our assistant director of 

compliance and enforcement right now is in the 

Midwest at a dairy farm. 

 We have done auditor training with 

about 17 auditors to lead this program this year. 

 So, policy outcomes from year one. 

This was our first year of doing a structured 

surveillance project in dairy. And we learned a 

lot about the training needs for our certifiers 

and operations.

 The Pasture Rule is a good rule. It 

is well written. It needs to be better enforced. 

And so, there are training needs that need to be 

done with certifiers in some very specific areas. 

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 So first, we saw some challenges with 

how the regional grazing season is defined. 

 That there are some large dairies that 

are near each other that have very different 

declared grazing seasons, and we need to have 

certifiers really looking at what is the regional 

grazing season? Not just what somebody writes 

down on an OSP. 

 We need to carefully teach and review 

justifications for breaks in the grazing season. 

So, discontinuous grazing season. 

 There is an allowance for it in the 

regulations, but the regulations are pretty 

specific about the allowance that is provided. 

 This is an area where we believe more 

training is needed, both with certifiers and 

operations, to ensure that those justifications 

are aligned with the regulations.

 We also need to do more training on 

crop rotations and natural resource management. 

And we had some observations related to access to 

shade and water sources. 

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 So, unfortunately, our training in 

dairy -- we were going to do face-to-face 

training in January with our certifiers, and it 

was impacted by the shutdown.

 We have talked to certifiers, and 

certifiers would prefer getting online, selfserve training, so lots of people can take it in 

their organization to get the word out.

 We need to train certifiers to be 

asking the right questions at the right time, to 

look for the right things, and to have the right 

inspectors assigned to the right operations.

 So, we will be launching self-guided 

training in the Organic Integrity Learning Center 

this summer. 

 Anyone will be able to register for an 

account and view that training, both operations 

and certifiers.

 Part of that training will involve 

some sort of case studies where different parts 

of the regulations need to be considered against 

each other. 

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 So, for example, pasture quality 

changes over the course of a season, and can be 

impacted by season lengths.

 So, your pasture season can directly 

impact DMI values. It's very important that 

certifiers know the right questions to ask to 

consider both of those variables to maximize 

compliance with the regulations.

 Finally, compliance outcomes. We did 

find that all operations that we visited 

demonstrated at least 120 days of grazing.

 So, even with the discontinuous 

grazing season, every farm that we visited did 

meet that requirement. 

 There had been some rumors that maybe 

that wasn't the case. It was the case. They all 

hit the 120 minimum.

 All cows got 30 percent DMI from 

pasture during the season. And so, that was 

another concern that we had -- was looking at DMI 

values. All the farms that we visited were 

hitting that 30 percent. 

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 So, where supported by the evidence, 

investigations are ongoing. And this is both at 

the operation level and at the certifier level.

 Do keep in mind the non-compliance and 

adverse action process that we take, both with 

farms and with certifiers, where there are 

correctable violations are allowed to correct 

those non-compliances.

 So, certifiers who are found to have 

gaps in the system will receive a non-compliance 

in order to be able to correct those gaps, as 

will farmers.

 So, we are continuing investigations. 

We are taking enforcement action. There has 

already been a significant civil penalty levied 

against a livestock operation.

 Okay, let's move to our Strengthening 

Organic Enforcement proposed rule. 

 You'll be grateful that I'm not 

reading this list to you, but this is a snapshot 

of a number of areas that are being considered 

for the rulemaking. 

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 You will note that this is an update 

of the last slide I did, and it has changed a bit 

based on feedback from the community. We had a 

webinar and have gotten some very thoughtful 

letters. There's also the Farm Bill happening.

 And so, this list is a little bit 

different than the list you've seen before. But 

the rule is very, very well underway and we're 

feeling very good about a fall 2019 publication.

 So, can't be more specific than that. 

This is considered a significant rule, which 

means that it will go through inter-agency 

review.

 So, agencies like CBP, for example, 

will be able to read our rule and comment on it, 

which we think is a very strong benefit. And it 

will lead to a fall 2019 opening of public 

comments. That will be announced in an Organic 

Insider.

 So next, our final two updates are 

really good news updates. First, I am pleased to 

announce the launch of the Organic Integrity 

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Learning Center.

 So, this is another project that we 

had just started when we met last fall, and that 

directly results from the increased funding that 

we received last year.

 The core idea behind the Learning 

Center is that qualified and trained organic 

professionals lie at the heart of strong organic 

control systems.

 It is the strong organic control 

systems that lead to fair and consistent 

certification, and ultimately drive organic 

integrity.

 So the Organic Integrity Learning 

Center offers free online training that supports 

the professional development and continuing 

education of all professionals working to protect 

organic integrity.

 So the system is live. So, we assign 

the accounts at NOP, so you're not able to selfregister. And that has to do with the way we 

manage seats. 

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 So, every seat is a subscription 

service to the learning management system, so we 

need to register you into the system. 

 So, the way that this is going to work 

is that organic certifiers, inspectors, and 

reviewers, and compliance and enforcement 

professionals are the target audience.

 That may include operations that are 

interested in understanding how to comply with 

the regulations.

 It can include quality assurance 

representatives within companies. So, anyone who 

is responsible for compliance and enforcement of 

the regulations can get an account.

 So, the way this will work is 

certifiers -- for certifiers in the room -- the 

primary and secondary contacts the NOP has for 

you are automatically enrolled.

 We have already auto-enrolled the 

primary and secondary contacts at each certifier. 

And you will be receiving your account 

information either later today or tomorrow. 

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outreach to staff to get their staff registered. 

And we have a sort of two-way sign up process for 

that.

 So, for example, groups and certifier 

groups can send an Excel spreadsheet to us with 

information to basically do a bulk account 

assignment to all of their inspectors and 

certifier staff. The public can also make 

individual requests for accounts.

 So, what I'm asking is if you lead an 

organization, please coordinate with your group 

to let them know whether you want them to sign up 

for accounts individually, or you're going to 

enroll everybody as a group.

 We're going to do our best to manage 

double accounts. 

 It will help if organization leaders 

help work with their organizations to signal 

whether you want them to register themselves, or 

whether you're going to do it as a group.

 Now, we do have a flyer about this, 

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and so the flyer is going to be out on the table 

once we're done here. And I made 200 copies, so 

there should be enough.

 So, it has instructions for how to 

sign up for an account. Again, the system is 

live. It is working. And so, we're pleased to 

get the word out about that. 

 Again, if you are a certifier lead or 

a secondary contact, you'll be getting your 

registration information with login and password 

today. These login and passwords are for 

individuals because it does track your 

individualized learning. 

 So please don't register a group email 

address, because then your individual folks won't 

get credit for the courses that they complete.

 So, let's talk about next steps. On 

the left side is a list of the courses that are 

in there right now. And so, we have introduction 

to the organic system, we have sound and sensible 

organic certification, we have fundamentals of 

inspection, we have compliance and enforcement, 

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adverse actions, appeals and reinstatements, and 

we have import oversight essentials.

 This is just the start to launch the 

system. We are in the process of developing more 

courses. 

 So, first stop. I already mentioned 

dairy compliance. We're doing an entire course 

on traceability techniques, so that's, for 

example, how to do mass balance calculations, how 

to do traceback audits. 

 There are lots of different 

traceability techniques that will be included in 

that training. 

 We will be doing an advanced 

inspections training, which will be more 

investigations focused.

 We'll have a material review course, 

a certification administration course, and a 

course on sampling and testing.

 So, another goal is to deepen our 

assessments and reporting. This is a very young 

system, so we've really just started. We didn't 

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have this even six months ago, so brand new.

 Right now, at the end of each lesson, 

there is a multiple choice quiz at the end of it, 

and you do tracked for credit on that. 

 We would like to deepen those 

assessments so we have better ways of tracing 

what people really learned and are able to apply.

 And we are working on better reports 

so an inspector can print it out and say, here 

are all the courses I've taken. Here are the 

course hours I completed, and my grades on the 

assessments.

 So that is still in progress and is 

going to be what's happening in the next few 

months. 

 So, a number of these courses will 

launch in 2019, and we're going to continue to 

develop them. We consider this a long-term 

investment. 

 Organic training and education is 

going to be in the proposed rule requirements 

related to continuing education and training, for 

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both inspectors and reviewers, and that makes it 

super important that we continue to load new 

content into the training system over time.

 So, look forward to getting those 

accounts assigned, and let the learning begin. 

 So, for our final topic, I am pleased 

to announce our Organic INTEGRITY Data Quality 

Awards winners.

 So, a little bit of background here. 

Let's look at the context behind these awards. 

Protecting organic integrity requires accurate 

and timely data from our certifiers.

 Unfortunately, data management is 

often invisible labor. It costs money to do data 

well. It's a reality of data management -- is it 

takes a lot of time, and it takes a lot of effort 

and investment.

 So, we, a couple years ago built the 

Organic INTEGRITY Database's Data Quality 

Dashboard in order to make data labor more 

visible and show certifiers the strengths and 

weaknesses in their data. 

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 So, certifiers can look at a number of 

factors to see how they're doing with their data 

submittals in the Organic INTEGRITY Database.

 And certifiers have really upped their 

game on data quality. And so, the investing in 

INTEGRITY Awards for this year were based on data 

quality and quantity at the start of 2019.

 So, what we were looking for were 

regular data updates, use of the product 

taxonomy, the inclusion of acreage and livestock 

counts, and complete information.

 And what we've seen over the last 

year, since our first round of awards, is that 

the data quality and completeness has gone up 

significantly across certifiers.

 Certifiers are really coming into 

their own, both in the frequency of data updates, 

and in the completeness of the data.

 Now, the proposed rule that'll be 

published this fall will also make some of this 

reporting mandatory.

 So for example, acreage will be a 

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required piece of reporting, as will item level 

information in the proposed rule. And so, if you 

find that data useful, look for the public 

comment opportunities this fall when that comes 

out.

 And so, now, we're going to do -- drum 

roll, please, for the winners. Come on, help me 

out here. All right.

 We have eight winners this year, and 

I'm going to ask them to stand so we can 

recognize the folks in the room. So, if you are 

a representative of these organizations, please 

go ahead and stand up.

 California Certified Organic Farmers, 

CCOF. Where are you?

 DR. TUCKER: Stay standing. We've got 

the Colorado Department of Agriculture. We have 

the County of Marin Organic Certified 

Agricultural. Let's give both of them a hand.

 We have the Georgia Crop Improvement 

Association. They couldn't be with us today. 

But give them a hand. GOA, we've got the Global 

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Organic Alliance here. Go ahead and stand up. 

Stay standing.

 We've got the New Mexico Department of 

Agriculture. Unfortunately, they couldn't be 

with us today, but let's give them a hand. We 

have One-Cert, Incorporated. So I think I saw 

Sam here earlier. Congratulations.

 And we have Primus Labs. So is Primus 

here? Let's give them a hand. So 

congratulations to all of you. This reflects a 

lot of investment in data quality.

 We're going to take a picture with all 

the awards winners at the break. So if you are 

an award winner and you want to be in the 

picture, please meet us at the base of the 

elevators at the beginning of the break.

 We promise it will be quick. But if 

we all convene quick we can take the picture. So 

we'll take pictures with the award winners at the 

bottom of the -- we'll meet at the bottom of the 

escalator at the beginning of the break.

 I just want to note that of these 

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three -- of these eight winners, only three won 

it two years in a row. That's how much the 

quality game has increased, is that there were a 

number of winners last year that got bumped off 

the list because some certifiers said hey, we're 

really going to invest in this.

 So we do -- we will continue to award 

these each year, and it will be interesting to 

see how the list continues to evolve.

 The winners this year met a higher 

baseline than the winners last year. So I think 

it's a great example of continuous improvement 

across the organic community. And there we have 

it. So that concludes the NOP update, and I am 

happy to take questions from the Board.

 CHAIR BEHAR: Dan.

 DR. SEITZ: Jenny, thank you for that 

very informative report. And I appreciated 

hearing your perspective on how to regulate the 

hydroponic operations. I appreciated hearing 

yesterday during the NOC meeting that you're in a 

fact-finding mode. 

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 You're trying to understand what's 

happening out there in the field. And that 

there's a strong commitment that you have to 

enforcing the rules, the current organic rules 

when dealing with the hydroponic operations.

 My question is as you do your fact 

finding and you explore what's actually happening 

out there in the field, if you discover that 

there are novel aspects to hydroponics that can't 

be covered by the existing rules, because many of 

those were developed with in-soil farming in 

mind, do you see yourself coming back to the NOSB 

and working with us to develop additional rules 

that will address the novel aspects of 

hydroponics and other ponic operations?

 DR. TUCKER: Okay. Thanks very much 

for the question. There are legal and policy 

questions. We are gathering information, you 

have called it well, sir, data gathering mode 

right now.

 The growth of hydroponics and 

containers has raised some new policy questions. 

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We do need more information and data in order to 

make concrete policy decisions based on the 

reality based facts.

 So I think there is -- there's been 

specific questions about sort of the soil-based 

aspects of the regulations. And I think in 

general USDA disagrees that the provisions in the 

Act and regulations related to soil mean that all 

soil must be soil-based.

 Rather, those provisions apply to the 

systems that do use soil. And so that is I think 

an important part of, when we're looking at these 

systems, that the provisions related to soil 

apply to soil-based operations.

 Now there is the natural resources 

element of an operation, which involves the 

entire environment of the operations. That's an 

important separate component of the regulation.

 So there are policy questions. I 

think we are going to learn a lot. I think if 

there are areas where the rules are being broken, 

we're going to take enforcement action. 

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 So if the rules aren't being met, that 

is a compliance problem, and it needs to be 

addressed as an enforcement issue. If there are 

policy inconsistencies and policy questions, 

generally we communicate those through handbook 

documents and communication with certifiers on 

that.

 If there are novel policy questions 

that we feel are best handled at the Board, in 

the Board forum, we would certainly consider 

that. The Board had a lot of opportunities to 

work on this topic, and I'm not sure that a lot 

has changed at this point.

 So right now we have the regulations. 

We have the Act. And we are able to make 

judgments about these policy issues. We get 

complex policy questions all the time at the 

National Organic Program, and the vast majority 

of them don't need to come to the Board. That's 

just what we do every day.

 And so we would like the opportunity 

to do this research. I think there's also some 

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urgency to answering these questions. And so I 

think we can do that at the program level 

effectively and in a transparent way.

 CHAIR BEHAR: Steve. Oh, I thought 

you said -- oh, Emily, and then Dan -- Dave.

 MS. OAKLEY: Thank you, Jenny. I was 

glad to hear you say that all systems are 

accountable to the same standards. So I'm 

wondering if you can clarify for everyone that 

all farm operations, regardless of location, 

crop, size, or growing system must adhere to OFPA 

Section 2105(2).

 Not be produced on land to which any 

prohibited substances, including synthetic 

chemicals, have been applied during the three 

years -- sorry if you can't hear me, during the 

three years immediately preceding the harvest of 

the agricultural products.

 DR. TUCKER: Sorry. We are absolutely 

committed to upholding OFPA. And so I'll say 

that again. We are absolutely committed to 

upholding the Organic Foods Production Act and 

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the USDA organic regulations.

 There are questions about the scope of 

the land requirements for -- and the regulations 

in 205.202. And so what does define the 

boundaries of hydroponic and container systems? 

I think that's sort of an essential question that 

has been raised through some of the recent sort 

of policy questions that have come up. And how 

should certifiers consider those land use 

histories?

 So you're mentioning that three years. 

How should certifiers consider that land history? 

So take, for example, in urban agriculture you 

have a, you know, greenhouse that's built on the 

roof of a building. There's -- does a three year 

transition of a greenhouse built at the roof of a 

building, it's not really applicable. There's 

nothing to transition.

 And so I think that those are the 

types of policy questions that need to be 

carefully looked at. We need to understand 

what's really happening on the ground with these 

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operations. And we are committed to upholding 

the Organic Foods Production Act in full.

 MS. OAKLEY: Could I have a follow-up 

to that? So, yes, I understand that's sort of a 

unique situation. But, for example, you might 

have a greenhouse that was previously 

conventional that's transitioning to organic. So 

I'm hoping for clarity that in that situation 

they would follow the three year transition 

period. And I'll just give an example.

 My whole farm is certified organic. 

So if I were to build a greenhouse in an enclosed 

environment, but I decided to spray a prohibited 

substance before that on my land, you know, that 

would seem to be in conflict with what my 

certifier would allow.

 DR. TUCKER: Sorry. You know, one of 

the reasons I gave the statement this morning was 

that I engaged in hypotheticals, and 

hypotheticals are really risky. So I would 

prefer not to engage in hypotheticals here. We 

need to learn what specific systems are out 

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there, what certifiers specifically are doing, 

and we need to pursue the policy questions that 

those raise. But I got myself in trouble with 

hypotheticals last time. So I'm not going to do 

that.

 MS. OAKLEY: One more follow-up? Is 

that okay? Sorry. Okay. I totally understand 

that. And I also don't want to put you in a 

situation of hypotheticals.

 And I think though that some of that 

can be clarified by, as you say, you know, 

following OFPA with every operation. And I think 

what would satisfy a lot of concern, at least for 

me, because when I first heard this situation I 

thought there is no way that's happening. You 

know, that's just not allowed. And I think a lot 

of people would think that initially. Like, that 

can't possibly be allowed because we have a three 

year transition period.

 So if the program could please 

clarify, maybe not on the spot right now but very 

soon after this meeting, that a three year 

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transition period is required for all operations. 

I mean, that would really resolve the issue right 

there.

 DR. TUCKER: Yes. We appreciate the 

urgency with which these questions are being 

asked, and I am committed to reviewing the policy 

questions that have been raised and getting 

clarity where it's needed out into the -- out to 

the world.

 CHAIR BEHAR: Dave.

 MR. MORTENSEN: Jenny, I just wanted 

to come back to Dan's question. I don't -- you 

know, and when we think about facts and what we 

voted on and what we didn't vote on, when we 

voted on the soil versus hydroponic issue in 

Jacksonville, we did not get into defining what 

is an acceptable suite of practices, that once 

we've then decided that hydroponics is going to 

be in play, we've never had that discussion as a 

Board. That's a fact.

 And it's my view that there are a lot 

of dimensions. And I've been in probably 30 

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hydroponic production facilities, most recently 

two last week. That we would consider, I think, 

or at least we should discuss. I'm not sure that 

we would all agree.

 But we should discuss whether or not 

those practices conform to an organic label or 

not, that have to do with a whole host of issues 

around plastics, metals, pumps, lubricants, lack 

of vegetation, lack of bio-diversity, plastic 

covering the complete ground of a farmed lot, 

including truck traffic ways with plastic, and no 

green vegetation.

 I think that it's incumbent on the 

Board to take a critical look at what constitutes 

the suite of practices that are in play and where 

are we really going off the rails with a, you 

know, with a production system that really has --

that really violates many of the principles, I 

think, upon which the label is granted.

 DR. TUCKER: So I appreciate the 

comment. I'd like the opportunity to learn more 

about what's happening and then make the best 

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next steps that we need to take, based on what we 

learn.

 CHAIR BEHAR: Scott.

 MR. RICE: Thanks. Jenny, in your 

dairy compliance project report you mentioned 

that all of those operations that you looked at 

were meeting the 120 day minimum, which was great 

to see. Can you just clarify that is regardless 

of, like, any confinement period?

 DR. TUCKER: Correct. So temporary 

confinement is allowed as part of the regulations 

under, again, very specific circumstances. And 

so that would need -- it's also going to be part 

of the training. That 120 days was met, even 

with any temporary confinement due to the 

allowable reasons in the regs.

 MR. RICE: Okay. Thanks.

 CHAIR BEHAR: Ashley.

 MS. SWAFFAR: So, Jenny, thanks for 

the program, for updating us on origin of 

livestock. I understand that the industry's 

changed, and you need to do a new proposed rule. 

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 But I will say that, you know, we've 

heard from dairy farmers for quite some time now 

how much they needed this rule and need it now.

 So I would encourage the program to 

not slow it down like they have in the past, to 

move this rule through. We hear from dairy 

farmers every meeting and through the public 

comment process that they need this out there to 

continue their businesses. So --

 DR. TUCKER: Yes. I think from every 

meeting, after every meeting I go back to our 

leadership. And I tell them here are the big 

topics that were raised. Origin of livestock is 

clearly something where the message here has been 

clear that the community is very interested in 

going to a final rule.

 I think one of the questions is -- so 

when we're looking at regs there are kind of two 

opposing arguments here. We need the rule 

quickly, and the industry has changed a lot.

 Well, if the industry's changed a lot, 

that increases the need for public comment in a 

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second proposed rule because you have market 

participants that maybe didn't comment the first 

time because they weren't in the market.

 So if you believe that the market has 

changed, but not in such a way that it 

fundamentally alters the public comments that 

came in, we need that feedback.

 And so this is where if the community 

can articulate why you believe, you know, the 

public, despite the growth of the industry, that 

the controversies and the comments at the time 

are still relevant, despite those changes in the 

market, those are the kinds of arguments that may 

have more weight.

 This is not a program decision, right. 

This is a decision that will be made by USDA and 

likely Office of Management and Budget. They're 

the ones who make these kinds of decisions. But 

those are the arguments that they would likely be 

more compelled by.

 Okay, you say the market's changed a 

lot. Why wouldn't you need a second proposed 

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rule, given those changes? If you can articulate 

how the market's actually pretty much the same 

but has increased, and why you're not shutting 

out -- why we're not shutting out people by not 

having a second proposed rule, those are 

important arguments that would need to be 

articulated.

 I will take back the interest in a 

final rule, back to the administration. I think 

-- we hear often the need for openness and public 

comment and transparency. And now you're saying 

oh, no, no, don't do another round of public 

comment, and that can be a little bit 

contradictory in a community that so values 

public comment.

 MS. SWAFFAR: One follow-up to that, 

Jenny. For the dairy industry, if they feel 

that, who should they direct those comments to, 

that they need -- they don't need a new proposed 

rule, just a final? Straight to the Secretary?

 DR. TUCKER: Honestly, on that one, we 

are the ones who end up writing the work plan 

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that goes up, and that's where those arguments 

are articulated. There's a very formal process 

for all of these. So, honestly, sending letters 

to me and Paul would be useful.

 The best letters are those that are 

really thoughtful, contain unique information 

about -- through your perspective and your 

understanding of the market. Those are the most 

helpful. Often when they come in from an 

organization representing a group, those are just 

-- tend to have more content that we can use in 

formal documents.

 CHAIR BEHAR: Steve.

 MR. ELA: Jenny, I'm curious. On the 

dairy inspections, and I know you can't comment 

on specific ways you select farms because that's 

part of your process.

 But did that -- I mean, of the -- all 

the farms inspected, and you said they all 

complied with 120 days. Was that a cross section 

of regions, sizes?

 I mean, do you feel -- I guess, you 

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know, there's always concern with big operations 

versus small, and I know they each have their own 

issues. But do you feel like you had an adequate 

cross section of those?

 DR. TUCKER: Yes. So I can talk a bit 

about the selection criteria. So I won't tell 

you who the farms were, and I'm not going to say 

how many there were either because those are 

investigative techniques.

 I will share some of the criteria. We 

are using a risk-based approach. And so I think 

with respect to dairies, given the complexity of 

those operations, large operations are 

particularly a high risk.

 I would also say that any operation, 

large or small, that hovers right around that 30 

percent DMI and right around that 120 days, we 

would consider that to be a risk factor with 

respect to the regulations.

 Operations that have had multiple 

complaints against them, or compliance history. 

Now the fact that somebody's had a complaint 

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against them does not make them guilty.

 And in fact, an awful lot of 

complaints that we get are actually from 

competitors. And so that is a nature of the 

business.

 And in fact, actually the majority of 

our complaints are about uncertified operations. 

So a lot of our enforcement time is actually 

spent regulating people who are using the organic 

name without certification. So that just is a 

little bit of a sidebar.

 So but having a history of either 

compliance issues, where they've actually been 

issued non-compliances by the certifier. So that 

is a risk factor.

 We did go across the country. So we 

visited Western dairies, upper Midwest, East, 

Central. So we've been all over the place. Up 

here in the Pacific Northwest. We've been around 

the country. And we'll go to even more 

operations this year.

 So we did take a pretty broad view of 

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the distribution. So those are some of the 

factors that we use to make those decisions.

 CHAIR BEHAR: Tom.

 MR. CHAPMAN: Hi, Jenny. Thank you 

for sharing that information about the USDA 

enforcement activities. It's reassuring to see 

the program working in this space so actively.

 And I look forward to seeing that 

proposed rule in the fall. I just want to 

continue to encourage the program to advertise 

and inform the public of its enforcement 

activities.

 In the absence of information I think 

most folks will generally make up their own 

stories to connect the dots and generally assume 

the worst. So that enforcement activity is not 

occurring or is not occurring at the robust level 

that it is.

 So just want to continue to encourage 

you. I like the sharing of information here and 

encourage the program to find -- continue to 

share in this forum and find other forums to 

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share that information out to the public, so they 

can continue to establish, or hold their trust in 

the organic program.

 DR. TUCKER: I appreciate the 

comments. You know, that was a big take home 

from the meeting yesterday with the National 

Organic Coalition, is that we need to do a better 

job of communicating what we are doing in 

enforcement.

 You know, I'll repeat that actually 

the majority of our enforcement actions are --

were -- are against non-certified farms. So 

farms, businesses that are representing 

themselves as organic without certification. And 

so that is a top priority in protecting organic 

farmers who have gone through the certification 

process.

 We have improved reporting on our 

website, are going to continue to do so. I think 

that the new database gives us the ability to see 

patterns in enforcement that will make it much 

easier to report on those to the public. 

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 We are committed to sharing more 

within the constraints of investigative 

techniques and due process. So, and there are 

some things I'd love to tell you and just can't.

 You know, I do encourage folks right 

now, what we do have posted on our website is we 

do post, for example, final suspensions and 

revocations of both certifiers and operations.

 We post settlement agreements. We 

post consent orders. And if you look at the ones 

that have been issued over the past few months, 

there will be more coming. So encourage folks to 

keep an eye on those pages.

 You know, again, I can't say hey, look 

at this page today, you know. But I think there 

are folks out there who regularly look at those 

pages. And we are committed to getting the word 

out, and if you can help us in that, we 

appreciate it.

 CHAIR BEHAR: Emily.

 MS. OAKLEY: Sorry. I don't want to 

belabor the point, and I know that we have other 

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things to go to. I just want to re-emphasize 

that consumers understand many things about 

organic, and things they don't understand about 

organic are also very vast.

 But one thing that they do understand, 

surprisingly in large numbers, is the three year 

transition point. And I think that -- I hear you 

saying you need to do some investigating and see 

what's out there.

 I just want to reiterate that I think 

it can really be clearly established, not by 

looking to see what people are doing necessarily. 

We don't need to engage in hypotheticals. We 

just need to clearly assert what the rules state.

 And I know you mentioned the issue of 

land. I think it's possible that we could guess 

that perhaps when that law was written there 

wasn't an expectation that that might then be 

produced in a building or in a facility.

 And perhaps you're thinking that it --

on land, or the operation, that that might 

provide different clarity. I don't know. But I 

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just want to say that for me this strikes at the 

heart of why I'm here and why I'm an organic 

farmer.

 And I really hope that you can issue 

clarity on this immediately. Because it is an 

extremely important issue. Thank you.

 DR. TUCKER: Yes. I appreciate that, 

and I hear you, and we will move quickly.

 CHAIR BEHAR: Yes, thank you. I want 

to say thank you, Jenny, for the wide-ranging 

amount of work happening at the National Organic 

Program, and reiterate what Tom said.

 I believe both for the trust of those 

who are doing it right, to hear the work that you 

are doing, as well as to those who maybe want to 

skirt around the rules a little bit, to know that 

they will be caught, or at least they'll have 

scrutiny. I think that is super important.

 So a little bit more outreach on your 

activities and, you know, that you are going to 

be out there looking, I think does a lot to deter 

some of the problems that we have. 

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 DR. TUCKER: Yes. I just want to say 

I am fully committed to protecting both farmers 

and consumers.

 You know, every time I go to the 

grocery store, it's inevitable that the person in 

front of me has an organic product on that belt. 

They're handing it to the checkout person. And 

they're making a choice with that purchase.

 And I am -- we are all devoted to 

protecting that choice and protecting the 

integrity of the seal. So thank you for 

listening to the update, and looking forward to 

the rest of the meeting.

 CHAIR BEHAR: Let's give Jenny a round 

of applause. Thank you. Okay. Finally, I can 

do what I thought I was going to do earlier. I'd 

like to introduce Adam Cline.

 Adam is the head of the Census Section 

in the Census and Survey Division at the USDA's 

National Agricultural Statistics Service. Adam 

directs the day to day operations for the 

Agency's census of agriculture program and the 

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organic program. Multiple national level surveys 

are conducted on an annual basis.

 Prior to that Adam worked as a 

statistician and project manager, where he 

coordinated data collection and analyzed 

agricultural data for over 15 years.

 Adam is here to talk today about 

USDA's organic surveys and data quality. Thank 

you, Adam.

 MR. CLINE: Thank you to Jenny and 

Harriet and the rest of the Board for having me 

here today to speak about organic data. As far 

as data goes, organic is still fairly new in the 

game.

 And I fully understand that there is 

at many times confusion as to what numbers to 

review and what numbers can be trusted. So I 

will attempt to clarify that as we -- as well as 

provide some information on the upcoming 2019 

organic survey.

 So I will provide some explanations of 

the different surveys, the different data 

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sources, as well as the challenges that USDA 

faces when it comes to capturing these data and 

how we can succeed in providing accurate and 

reliable data, as I know the policy changes we 

all look for start with good data.

 Additionally, we recently released the 

2017 Census of Agriculture data. And I will 

provide a couple organic highlights from that.

 So we'll start with the NASS producer 

surveys. The upcoming 2019 survey will be the 

sixth producer survey that we have conducted. 

And while all the surveys -- organic surveys we 

have conducted so far are similar, there are a 

couple of differences to note.

 We receive appropriations to conduct 

a special study following the Census of 

Agriculture, and the first was conducted in 2008, 

and then we did another one in 2014.

 2019 will be a special study to the 

2017 Census of Agriculture. And I will provide 

some further information on that on the next 

slide. 

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 In the in between years of those 

special studies, NASS has collaborated with the 

RMA, Risk Management Agency, to conduct organic 

surveys in direct support of their price 

selection program.

 And while the content for these are 

similar, we do ask a few more questions on the 

Census of Agriculture program special studies.

 So as I mentioned, the 2019 organic 

survey will be the next data collection effort 

conducted and is part of the 2017 Census of 

Agriculture.

 The Federal Register was posted on 

February 28th, and it will close on April 29th. 

If you have already provided comments, thank you. 

And if you would like to provide comments and 

have not done so yet, there's still some time.

 We're currently conducting field 

testing on some questionnaire changes that we 

hope will provide more accurate data. Some of 

these changes include simple wording and section 

ordering. 

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 We also included some more information 

on food marketing practices that will correlate 

closely with the questions that we had on the 

Census of Agriculture and a 2015 local food 

survey.

 We recently enjoyed meeting with a 

number of USDA stakeholders, as well as external 

stakeholders from the National Organic Coalition, 

to determine the needs of the industry.

 And the survey will continue to 

collect data on production quantity and values, 

as well as production and marketing practices. 

We'll begin data collection in December of this 

year, and we will release results in October of 

next year.

 So along with the producer surveys, we 

also have conducted the certifier surveys to get 

certifier, acreage, and livestock data. AMS 

began this effort in 1992 and followed that by 

Agrisystems, a private company that conducted it 

in 1995.

 Economic Research Service provided the 

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longest tenure of data, from 1997 to 2011, before 

they lost resources to continue. At that time 

NASS took over for a couple of years in 2014 and 

'15. And now we've come full circle, and that 

data will be provided by the NOP through the 

Organic Integrity Database.

 And kudos to the NOP for taking the 

transition to collecting and reporting the 

acreage and livestock data seriously. Stacy 

Swartwood did an amazing job at ensuring all 

stakeholders were consulted along the way. That 

included NASS, ERS, and certifying agencies.

 Our goal was to create a database that 

allows the certifiers to report their acreage and 

livestock data easily and in a structure that 

will provide data that could be compared to that 

of the previous efforts of NASS and ERS and 

others.

 The first data report was completed in 

2017, and NOP has provided multiple reports since 

then. While the reporting of these fields is 

currently voluntary, the stats do show that 

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participation is consistently increasing.

 As you know, there is a proposed rule 

to make reporting mandatory. And that will go a 

long way in improving the accuracy of this data.

 So with the multiple surveys and data 

sources there of course comes confusion of which 

numbers to trust and what do the numbers actually 

represent.

 I'll start with the number of 

operations. The NASS producer surveys are selfreported and represent certified organic crop and 

livestock operations that have production in the 

given survey reference year.

 This number does not include 

processing and handling operations. On the other 

hand, the NOP operation counts are from mandatory 

and regulated reporting and do include operations 

and businesses such as processors and handlers.

 Another thing to keep in mind is 

methodology differences. While NASS may count a 

single entity with multiple locations as one 

operation, NOP may count that as multiple 

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operations, or vice versa.

 Next we have the difference in the 

certifier and acreage livestock data that NASS 

and ERS have provided in the recent data from the 

Organic Integrity Database.

 A couple of items to note here are 

that NAS and ERS had very long data collection 

timeframes. We also had resources to interact 

with the certifiers.

 On many occasions we went and visited 

the certifiers ourselves, in person, and went 

through the files and entered the data ourselves 

from paper. Or they would send us a spreadsheet, 

and we'd enter it that way. We also have the 

expertise to review and edit the reported data, 

looking for duplication or obvious key entry 

errors.

 The NOP currently has limited 

resources for certifier interaction and data 

review and must rely on the assumption that the 

data is being reported and reported accurately.

 So to further dive into the challenges 

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from getting acreage and livestock data from the 

Organic Integrity Database, first and foremost is 

reporting is voluntary.

 Working in a data collection agency I 

know first-hand that getting responses on a 

voluntary survey is very difficult and often 

requires multiple contacts. And as I mentioned 

previously, the data issues, such as duplication 

and key entry mistakes are not corrected.

 The record keeping varies greatly 

among certifiers. While some have very 

sophisticated systems that sync with our 

integrity database, others are working off of 

paper only.

 And while this data may be currently 

a bit less reliable, it does have the capability 

of being much more accurate, timely, and 

available to users.

 So how do we get reliable, accurate, 

and timely acreage and livestock data from the 

Organic Integrity Database? I absolutely believe 

that we will get there, and there a few steps 

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that will assist in this effort.

 The first is mandatory reporting. 

More data means better data. NASS and NOP have 

also begun discussing a data validation project 

that will allow NASS experts to consult with NOP 

to ensure reported data is being analyzed and 

corrected accurately.

 And finally, certifier support from 

you, the industry. Simply talking to the 

certifiers about the importance of this data will 

help tremendously.

 With these three steps I am confident 

that in a short time the USDA will have the 

ability to provide accurate acreage and livestock 

data.

 I mentioned earlier that NASS recently 

released the results from the 2017 Census of 

Agriculture. I'd like to point out a couple of 

highlights from that data.

 The first is the number of organic 

farms and value of sales are up from 2012. The 

number of certified operations is up 39 percent, 

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and the value of sales is up 57 percent, at $7.2 

billion dollars.

 The other takeaway is that the organic 

producer is younger and more likely to be a fulltime farmer than those -- than non-organic 

farmers. As you can see the average age of the 

organic farmer is 51.3, while all farms is 57.5.

 Another interesting highlight is that 

64 percent of organic farmers noted that their 

primary occupation was farming, comparted to 42 

percent of non-organic farms.

 So thank you again for having me and 

allowing me to speak about USDA's organic data. 

I hope I have cleared up a little bit of 

confusion when it comes to all of the different 

numbers out there.

 CHAIR BEHAR: Any questions from the 

Board? Emily.

 MS. OAKLEY: It's really just a 

comment. I just want to say that I find this 

data very helpful, and I appreciate its 

collection. I know that it's hard to get data 

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from farmers. But I think it's a great tool.

 And it's a bright spot in terms of 

data collection and what can be gained from it. 

And also, your staff is very accessible, in terms 

of mining through that data for more details. So 

thank you.

 MR. CLINE: Thank you.

 CHAIR BEHAR: Steve. We're not done 

yet.

 MR. ELA: With total sales going up, 

what, from, what was it, $7.1 billion from two 

point -- I can't remember the numbers. But did 

you, obviously -- and the number of farms went 

up.

 But is income per farm up as well? Or 

how does that, I mean, in those smaller, I mean, 

I know those are kind of micro details. But 

where are you seeing that trend going?

 MR. CLINE: Well, the average, the row 

just below that $7.2 billion average value of 

sales per farm, went from 401, or went from 218 

to 401, up 84 percent. 

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 But, you know, what it doesn't show 

is, you know, the size of that farm. And there's 

a number of other things that are in that data 

point that really kind of skew that number. It's 

hard to really look at just that one single data 

point and really make a decision on it.

 But I think in the end it increased, 

you know, per farm. And, you know, whether it 

was that drastic for all size of farms, probably 

not. But --

 MR. ELA: And do you have any -- I 

can't remember the questions, it's been long 

enough since I filled them out. I hope I did. 

But that would be gross income per farm. Any 

information on net income?

 MR. CLINE: We don't have it for 

strictly just the organic farms. We do have it 

for the overall farm. But not just only organic 

sector.

 CHAIR BEHAR: Any other questions? 

Dave.

 MR. MORTENSEN: Yes. I also wanted to 

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thank you. That's really interesting data and a 

summary. I was curious, is there any way of 

linking the data that you're collecting here, or 

maybe it's already in the data set, based on the 

acreages that you're reporting in transition, 

where you could probe the data set to determine 

whether farms are increasing in size?

 What the nature of changes in farm 

number and size are as a function of production 

type? Those are some of the sorts of things that 

could help inform the Board on some of the 

thinking about, you know, are dairy operations 

getting much larger? Do we have a bi-modal 

distribution emerging in agriculture, or things 

like that?

 I was just curious. I know MacDonald 

and the Economic Research Service published a 

really helpful guide on how farms' size is 

changing. And then he argued how practices that 

go along with farm size change almost in 

lockstep. And I was just curious if we could do 

that with this data. 

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 MR. CLINE: I feel that we could do it 

with, you know, some of the overall data we have 

for all farms. You know, with the census the 

organic section is really just two questions.

 It's, you know, are you certified, 

exempt? Do you have acres in transition? And 

then your total value. So we're really limited 

on what we can do with that, with the organic 

piece.

 MR. MORTENSEN: And the details of the 

production --

 MR. CLINE: And the details of it.

 MR. MORTENSEN: -- system.

 MR. CLINE: Yes. And we do try to, 

you know, with the 2019 survey coming up, we try 

to ask some, you know, probing questions on what 

their future plans are and what they're -- if 

they're going to enter or exit any -- in the next 

five year. And so we do try to get a little bit 

of that information there.

 MR. MORTENSEN: Okay. And one other 

question. Is the data publicly available to the 

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group here? All of this data? Or not yet?

 MR. CLINE: 2017 Census?

 MR. MORTENSEN: Yes.

 MR. CLINE: Yes.

 MR. MORTENSEN: It is? Great. 

Thanks.

 MR. CLINE: Yes. It's on the -- if 

you go to the -- well, I don't have it on there. 

Sorry. It's AgCensus.USDA.gov, I believe.

 CHAIR BEHAR: Rick and then Jesse.

 MR. GREENWOOD: Yes. Question. Can 

you do production by a particular commodity by 

acre? And what I'm interested in, my commodity 

is avocados.

 There's always talk that organic 

groves are less productive. But I'd like to be 

able to see if you could get a dollar value per 

acre for conventional versus organic.

 MR. CLINE: We -- you can compare it 

a little bit just from our -- from the different 

surveys that we've done. And I know that ERS has 

actually tried to do some conventional versus 

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organic price research as well.

 It wouldn't be from the 2017. Because 

we only have the conventional. Well, the organic 

commodities are included in the conventional, but 

it's not broken out by organic. So we can't get 

-- you can't make that distinction from the 

census of organic and conventional to get to that 

price difference.

 MR. GREENWOOD: Okay. Thank you.

 CHAIR BEHAR: Jesse.

 MR. BUIE: Yes. In reference to data 

accuracy, this is just an aside. I notice that 

during my most recent inspection that the 

inspector made a real effort to really document 

my acreage.

 And we spent a lot of time going over 

exactly what I had and what the plans were. So, 

you know, that gives me encouragement that this 

is a, you know, data is moving in a accurate 

direction.

 MR. CLINE: Yes. That's good to hear.

 CHAIR BEHAR: I have one comment and 

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maybe a question. In the State of Wisconsin, I 

am on the Wisconsin Organic Advisory Council, 

along with someone else in the audience.

 And we have been kind of struggling 

about the economic impact of organic, especially, 

you know, there's kind of this gap between we 

know what the sales are of organic products, you 

know, in stores.

 And we know what the farm gate prices 

are. But there's this whole gap there in the 

middle that, trying to understand like what the 

multiplier effects might be for organic.

 You know, there's -- in conventional 

world they'll say, you know, every ten cows is 

one, you know, person employed or whatever it 

might be. But we feel like there is more 

economic activity around organic because of the 

somewhat higher price and the need for more labor 

and that sort of thing.

 Is there any way to distill any of 

these statistics to help understand if, you know, 

an organic farm in the neighborhood is generating 

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more ripple effects throughout the local economy 

than perhaps a conventional farm?

 MR. CLINE: Yes. That's a great 

question. You know, I know AMS does a lot of 

their own kind of that retail price for organic. 

And, you know, what we're getting is really what 

the farmer is receiving.

 So what happens kind of in between 

there, it's hard to say. And, you know, 

something to think about for sure, if there's 

some type of questions or some set of questions 

we could add in there to maybe get to that.

 CHAIR BEHAR: Okay. Thank you. With 

no other questions, I say thank you to Adam.

 MR. CLINE: All right. Thank you.

 CHAIR BEHAR: Okay. So we are 

scheduled for a break, and I just want everyone 

to know that we are three minutes early. So 

we'll see if we can hold on to that one. So we 

will come back at 10:45 a.m.

 (Whereupon, the above-entitled matter 

went off the record at 10:27 a.m. and resumed at 

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10:48 a.m.)

 CHAIR BEHAR: Okay. Thank you, 

everyone. We are now going to move into a 

discussion on celery powder with the panel. And 

I'm going to turn this over to Asa Bradman, who 

is the Chair of the Handling Subcommittee.

 MR. BRADMAN: Thank you. I'm pleased 

to introduce the session today addressing celery 

powder. And also just to provide a little 

context, celery powder, as many of you know, is a 

material that is in many ways essential for 

curing organic meats as an alternative to 

synthetic nitrate and nitrites.

 And this material has been on the 

National List for a bit over ten years now. It's 

gone through one Sunset Review and is now going 

through another Sunset Review. And as you know, 

it's listed on 606 as a non-organically produced 

agricultural product, allowed in processing.

 And it's kind of a, really a test case 

for how we can take important and critical 

organically or agriculturally produced materials, 

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and get them off 606 and into -- and sourced 

organically.

 So this discussion really is a time to 

evaluate this material, which in many ways is 

critical to a large industry related to organic 

production. But at the same time we would like 

to kind of extend the full range of materials 

used in producing meat products to organic 

sources.

 First, I want to thank the panel 

member. As part of this Sunset Review we felt 

like this was such a critical material it would 

be better to have an in person discussion with 

experts, rather than a relatively brief Sunset 

Review.

 So I want to thank the panel members 

for their volunteering to come and attend this 

meeting and educate us on this issue. And also I 

want to thank the National Organic Program for 

sponsoring this, allowing the NOSB to convene 

this panel and have this discussion.

 So I won't speak too long here. I 

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want to turn it over now to Dr. Mathews, who will 

be introducing the panel members and reading the 

bios.

 And then we'll follow along with the 

first series of presentations by the panel 

members and then opportunities for discussion and 

questions by the Board.

 I want to say one thing. We want to 

limit questions during the presentation period 

only to very brief clarification questions about 

the content of a specific, any specific points 

raised in the presentation and then save more 

broader discussion or in depth questions for 

afterwards. Thank you.

 DR. MATHEWS: Thank you. Starting 

with our first panelist, I'll be introducing in 

the order in which our panelists will be speaking 

today.

 We have Erin Silva, an assistant 

professor in the Plant Pathology Department at 

the University of Wisconsin Madison. Dr. Silva's 

research and extension program focuses on 

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sustainable and organic cropping systems, 

including cover crops and cover crop based no 

till production, variety selection in organic 

environments, and the impact of organic 

management on slow biology and physical 

properties.

 She teaches food sustainability and 

climate change and organic system health. And 

she has launched a comprehensive organic grain 

training program for farmers in the upper 

Midwest. Dr. Silva also serves on the Wisconsin 

Organic Advisory Council.

 Jennifer Wasieleski holds a bachelor's 

degree in microbiology from the University of 

Minnesota and a master's degree in food science 

from the University of Illinois.

 She's currently the RD&A Director for 

the Food Protection and Fermentation Department 

at Kerry in Beloit, Wisconsin. Ms. Wasieleski 

leads a team focused on developing clean label 

solutions to replace chemical preservatives in a 

wide variety of food products and has been a key 

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participant in celery power working group 

initiatives.

 Logan Peterman has a background in 

ecology, statistics, and research design. He 

grew up on an apple orchard in central Wisconsin 

and has worked in the organic sector for a decade 

advising state, federal, NGO, and private 

organizations in data analysis and research 

interpretation and application.

 Mr. Peterman currently serves as the 

Director of Agricultural Research and Analytics 

at Organic Valley, America's largest cooperative 

of organic farmers, representing more than 2,000 

farmers in 36 states. Mr. Peterman chairs the 

Science Committee for the Organic Center and 

serves as an active member of the Board of 

Trustees.

 And Andrew Milkowski holds a 

bachelor's degree in chemistry from the 

University of Illinois and a PhD in biochemistry 

from the University of Wisconsin.

 Dr. Milkowski conducted research on 

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food chemistry, ingredient technology, sensory 

evaluation, product quality evaluation, shelf 

life measurement, nutritional labeling, and food 

safety for Oscar Mayer Foods.

 He retired in 2006 as a Kraft Foods 

Fellow after 29 years with the company. Dr. 

Milkowski is currently an adjunct professor of 

meat science at the University of Wisconsin and a 

member of the University of Wisconsin Madison 

Food Research Institute Executive Committee.

 Thank you to all of our panelists. 

And we'll begin first with a presentation by Dr. 

Silva.

 DR. SILVA: Thank you, Dr. Mathews, 

for that introduction. And thank you to the 

Board for allowing me the opportunity to speak 

about the research we've done over the last, 

gosh, you know, at least four years now, and talk 

about what we've learned in terms of producing an 

organic celery powder alternative. It's really -

- it's been an exciting project, and I've learned 

a lot along the way. 

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 So as Dr. Mathews said, I'm at the 

University of Wisconsin Madison. I'm an 

assistant professor in organic and sustainable 

cropping systems. And I've worked in organic 

vegetable production for about 15 years now.

 So my expertise is really more 

holistically in organic production. I'm not a 

nitrate expert. I'm not an expert on celery 

production, but looking more at how to grow 

organic crops, what are the opportunities to grow 

organic crops in different regions, and how do we 

optimize different production aspects to get the 

quality that we're looking to achieve from that 

product.

 So I'm going to start, and this is a 

little hard to see on this. But I just want to 

put some context on our efforts. So I was pulled 

into this project back in 2015 and pulled into it 

from a working group that was organized under the 

Organic Trade Association.

 And it really was looking to address 

in a very systematic way how to, with 

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collaboration from universities, with USDA, with 

industry, how to find a solution for an 

alternative, organic alternative to celery 

powder.

 So it really has been a very 

collaborative, participatory, grass roots 

movement to find an alternative. So getting 

together, discussing the issue, discussing where 

our state of the knowledge was, and then 

generating a plan for research, and requesting 

funding to conduct that research.

 So initially that funding came through 

an OREI, a USDA Organic Research and Extension 

Initiative planning grant, which was extremely 

helpful to better understand the landscape, to 

understand where the bottlenecks were, to 

understand who the key players were.

 Securing that grant, and with 

additional funding from Organic Valleys, Farmers 

Advocating for Organic fund, and with in-kind 

donations from industry, such as Kerry, we were 

able to collect some preliminary data. 

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 And with that preliminary data have 

been attempting to apply for a larger research 

grant, again from the Organic Research and 

Extension Initiative.

 You know, we've submitted that 

proposal a couple of times. Have gotten 

extremely, extremely good reviews back. But 

unfortunately that program is extremely 

competitive. So have not got funded yet for that 

full proposal. But next week we'll be submitting 

that proposal again. And hopefully third time is 

a charm on that one.

 But regardless, what I'm going to be 

presenting to you today is the research that we 

have conducted with the initial funding, which I 

think has gotten us quite far in terms of 

understanding and making progress in terms of 

finding an organic alternative.

 So I'm going to through, we were give 

questions by the Board. So I'm going to go 

through systematically what those questions were 

and what I'm able to contribute from the work 

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that I've conducted since 2015.

 And the first question was compared to 

growing celery for vegetable production, is the 

increased use of synthetic nitrogen fertilizers 

required to produce source plants with enough 

nitrate for celery powder production?

 And, you know, this, as part of that 

initial planning grant we did do interviews with 

different industry players and different aspects 

of the celery powder chain, and unfortunately 

this was not a question we were able to get a 

definitive answer to. And it was -- there's not 

a lot of publicly available data on this.

 I do have to say that Jeff Sindelar, 

who is a professor in the Animal Science 

Department, who has done a lot of work in terms 

of natural curing products, it's his 

understanding that there are specific 

recommendations for the production of celery 

powder for juicing as a meat curing agent. We 

don't know specifically what those 

recommendations are or if they're calling for 

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excessive use of nitrogen fertilizers.

 But regardless to say, and I think 

this is important in the context of what we need 

to accomplish to get to an organic alternative is 

it is different.

 There is different production 

parameters for this product versus celery that's 

grown as a fresh market vegetable crop. So no 

specifics but knowing that there are different 

recommendations there.

 So the third question is really where 

I'll spend my time. Since 2015 what progress has 

been made on the production of organic celery for 

powder production?

 So this is where the majority of my 

investment has been. So like I mentioned, our 

current grant funding to date, we did obtain an 

Organic Research and Extension Initiative 

planning grant. We applied in 2016. That was 

awarded in June. Those efforts have been led by 

UW Madison.

 But we did receive some very important 

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and generous funding from Organic Valley's 

Farmers Advocating for Organics fund, which 

allowed us to move this work even further from 

that initial planning grant.

 So our experimental approach. Again, 

we did a comprehensive survey of what the state 

of the industry was, what were some of the key 

questions in terms of how to produce organic 

celery for a curing powder.

 So we looked at several variables that 

we knew could potentially influence the amount of 

nitrate within that product. That was variety 

selection, what types of celery were we growing, 

fertility management strategies, the farm 

environment, the harvest date of the product, and 

then looking at an entirely different alternative 

to celery, looking at yellow and white beets as 

an alternative plant source.

 So we had a core experiment that was 

conducted at certified organic land at the UW 

West Madison Ag Experiment Station. This land 

has been certified for over ten years. It's been 

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managed per very sound organic practices using 

good fertility practices, good rotation 

practices.

 We're certified by MOSA. So we get 

the same checks as any farmer would. This 

particular plot of land was under a vegetable 

rotation with extensive cover cropping done for 

soil building, 3.5 percent organic matter. It 

was a silt loam soil

 And we fertilize annually using 

pelletized poultry manure, aiming for about 125 

or 120 pounds of nitrogen per acre, estimating 

about 50 percent of that N will be available in a 

given year.

 We had three replications in a split 

plot design, with the celery planted as eight 

week old transplants, drip irrigating as needed, 

and harvested in late September. So really 

trying to do what we thought were best practices 

to obtain a quality crop.

 We then juiced and froze the samples 

at UW Madison, aiming to do that within 24 hours 

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of receiving the samples. And then the samples 

were sent to Kerry Ingredients for further 

testing.

 So what did we find? So getting into 

the nuts and bolts of where we are right now at 

2019. So these were the nitrate concentrations 

of the organic celery samples by variety.

 Again, knowing that different crops 

will differ in their nitrogen, nitrate 

concentrations, depending on what the genetics 

are.

 So these are all organically produced 

varieties. We got all organic seed from any of 

the varieties that we chose. These are standard 

cultivars that are used by the industry.

 These are two years' worth of data, 

2016 and 2017. My understanding, talking to 

Jennifer, is the threshold that we're looking at 

is about 12,000 ppm.

 So the samples varied in terms of how 

close they came to hitting that threshold. Some 

exceeded that threshold, and some came under that 

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threshold.

 But a couple of things to note. That 

indeed we did see differences in nitrate 

concentrations depending on variety, which offers 

an opportunity for optimization by looking at 

what variety is going to consistently produce the 

highest amount of nitrates.

 Again, we are not excessively 

fertilizing these plots. We're fertilizing them 

as we would per standard vegetable 

recommendations. So we're not dumping on extra 

nitrogen on these by plots by any means.

 But I do want to note that there's a 

great degree of variability from year to year. 

We only had half the amount of nitrate from that 

high nitrate producing variety, Tall Utah, in 

2017 versus 2016.

 So this is something that we 

definitely need to understand, what is that 

source of that annual variation, because we did 

not alter the production practices from 2016 to 

2017. 

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 Some of these varieties, like safir, 

this was actually kind of interesting because 

this was a variety that we chose because it's 

actually an Asian variety that's more used as an 

ingredient for soups, or more of a flavorant, 

versus a fresh market variety. But actually, 

that was very, very low in nitrate, which 

differed from these more typical fresh market 

varieties.

 This is a graph showing effective time 

to juicing on nitrate concentration, so one of 

the things we were concerned about, just in terms 

of the logistics of what this industry would look 

like if we had an organic source of celery.

 The bars here, this is 1-1/2 days 

post-harvest, 5 days post-harvest, and 8 days 

post-harvest. There was no consistent trends 

here, depending on the variety, it differed in 

terms of whether time from harvest to juicing 

actually increased or decreased the level of 

nitrate, so again, this is another aspect in 

terms of optimizing the production chain that we 

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need to understand as we go further into 

developing an organic alternative.

 We also looked at harvest date, so 

looking at the literature and seeing what 

scientists have done to understand what 

influences nitrate concentrations in vegetables.

 And interestingly, the vast majority 

of literature focuses more on lowering nitrate 

concentrations, because typically, we're looking 

at keeping concentrations low in plants versus 

increasing them, but, you know, looking at light 

conditions certainly influences nitrate variety, 

nitrogen fertilization, but also, where that 

plant is in maturity.

 So we looked at impacts of harvesting 

early, 145 days after initial seeding, versus 

late, 171 days after initial seeding, and again, 

there were very inconsistent results, depending 

on variety.

 So this is where more work needs to be 

done to identify what is the most consistent 

high-producing nitrate variety, and then within 

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that variety, determine what is the best 

management of that variety in terms of postharvest and harvest date.

 Again, our focus was to look at, what 

are the nitrate concentrations being responsible 

in terms of the nitrate or nitrogen fertilization 

strategies we're using, but we also wanted to see 

if we split the nitrogen applications, if that 

influenced the nitrate levels in the organic 

celery.

 So we did this for two years, doing 

two different strategies. In 2016, we used a 

foliar feed with a fish fertilizer. So we 

applied the nitrogen directly to the above ground 

parts of the plant.

 We did not see a difference of 

anything and these were not statistically 

different, but if anything, we saw a trend to the 

unfertilized plants having a higher level of 

nitrate.

 So in 2017, we took a different 

strategy, and instead, side-dressed the plants 

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with pelletized poultry manure, and we saw a 

slight increase, but not significantly so.

 So at this point, we're not able to 

dial in on a specific fertility management 

program using split applications that would 

significantly increase the amount of nitrate in 

the product.

 We also did some on-farm sampling as 

well, and Harriet might recognize some of these 

names of these farms that we -- that generously 

provided us samples and these are all organic 

farms around the Madison area.

 Very good organic farms using sound 

organic practices. We did this for two different 

years. The first column here is 2016, the second 

column is 2017.

 Again, you can see this variability 

that, in 2016, overall, we had higher 

concentrations versus 2017, so there's some 

influence of environment and weather conditions 

between years that's influencing those varieties, 

but the other thing I want to know, and again, is 

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just the huge variability in nitrate levels that 

we're seeing, depending on where those are grown.

 Interestingly, our experiment station 

consistently gives us the highest levels of 

nitrate, which I'm not sure if we just spend more 

on inputs, but our soil type, or why we tend to 

consistently produce more higher levels of 

nitrate in the plant.

 Just some notes here in terms of some 

of the varieties that were used in some of the 

fertility strategies, composted poultry manure, 

CPM, but the farm that was using cover crops as 

well. This is a not-replicated design. This is 

just more of an exploratory set of data, but it 

is kind of interesting to see these trends.

 We also got, in 2016, a sample that 

was sent out to us from California, just to see 

what the California environment might produce, 

but again, I just want to highlight that we're 

looking for a 1200-ppm threshold here.

 So sometimes we are able to achieve 

that minimum threshold and sometimes we're not, 

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so there's a lot of work we need to do to better 

understand this source of variability that we're 

seeing between farms, between environments, and 

between years.

 So for the last question, are there 

commercially available agricultural products 

produced alternatives to celery powder, what is 

our experience with them, are they organic, does 

their use vary by application, and are they more 

effective in one application compared to another?

 And my contribution to this question 

would be the data that we obtained using organic 

beet as an alternative to organic celery, and I 

believe Jennifer's going to talk a lot more about 

what the different plant-based alternatives are 

and why they -- or why not they may be 

appropriate.

 But I just want to note that these 

were not any better in terms of accumulating 

nitrate than celery, and they do have other 

aspects that may make them less suitable in terms 

of imparting other flavor profiles to the cured 

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meat product that they may not necessarily be 

appropriate or any better, more suitable, than 

celery as we're looking to doing organic 

production chain for celery as the primary source 

of natural curing powder.

 So for our continued work, again, like 

I mentioned, we are submitting, next Thursday, 

that proposal for a third time, because we would 

like to build off of this work. We feel like 

we've learned a lot.

 We've developed a very strong 

collaborative team as part of this proposal. We 

have Jeff Sindelar, who's an expert in natural 

curing, we have myself, we have a collaborator 

from the University of Florida to bring in a 

different environment, and we have an Ageconomist that's going to look at more of the 

economics of production and look at more of 

logistics of supply chain.

 So we have a very strong team that 

we've assembled, we regularly meet, we talk about 

what we need to do in our progress. It's been 

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frustrating that we have not gotten this larger 

amount of funding to be able to push this project 

forward, but we do feel like we've achieved a lot 

with the initial minimal amount of funding that 

we have had and understand what we're facing and 

what challenges we need to overcome to get this 

organic celery powder alternative.

 So with that, we can pass it on to the 

next panelist.

 DR. MATHEWS: Thank you, Dr. Silva. 

To the board members, we have just one minute if 

you have any immediate questions for Dr. Silva. 

If not, we'll move onward.

 MR. BRADMAN: Just clarification 

questions.

 CHAIR BEHAR: Will you be able to do 

any studies this summer or is it totally 

dependent on the incoming grant?

 DR. SILVA: At this point, it's 

dependent on funding and so we hadn't planned on 

doing anything else this summer because we won't 

find out about the outcome of this submission, 

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probably, until July at the soonest.

 MR. BRADMAN: Emily, just --

 MS. OAKLEY: Do you think there's a 

chance that the variation in levels between years 

was related to rainfall levels?

 DR. SILVA: Yes, I mean, I definitely 

think that that could be a primary driver. And 

it may be also interesting to dissect the weather 

data a bit more and look at cloud cover, or days 

of sunlight, looking at soil temperature and soil 

biological activity may be impacting 

mineralization.

 There's a lot of different aspects 

that we need to put together, but certainly, I 

think rainfall could be a primary driver.

 DR. MATHEWS: Thank you. Now we'll 

move to the presentation by Ms. Wasieleski.

 MR. WASIELESKI: Thank you. I'd like 

to take this as an opportunity as well to thank 

all of you for allowing me to come here and 

present to you on the data.

 Since the celery powder working group 

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has been formed, there's been a lot of great 

work, and I'm really excited to share my 

learnings with you alongside the other panelists 

here today.

 And so as I was thinking about a title 

for my presentation I felt it was important to 

take a step back and really think about what the 

goal is of this project, and it really is not 

just around celery powder, but, on a larger 

picture, growing the market for sustainable, 

profitable organic vegetables.

 And so to start, I'd like to share 

this illustration with you of the celery cycle. 

So there's a number of different steps that are 

involved in the supply chain in order to create 

celery powder that can be used in organic meat 

production to make bacon, and hot dogs, and ham.

 And so all of these steps in the 

process provide -- you know, have their own 

unique hurdles that need to be overcome. And 

ultimately, our goal is to try to figure out how 

we can develop a robust and sustainable process 

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so that we can get the organic celery grower into 

this cycle.

 So the first question that I'll begin 

with is on strategies to produce organic celery 

powder that's standardized to consistently meet 

the safety and other requirements of the meat 

processing industry.

 And so in order to develop a strategy 

to create an organic celery powder, there's a 

number of boxes that need to be checked, and to 

date, the large majority of the work that Erin's 

presented on has been focused on the cultivar as 

well as the different growing practices that are 

needed to achieve the high nitrate levels.

 The reason these nitrate levels are 

important is because you're putting an 

agriculturally produced product, you know, a 

vegetable, celery, into meat that's not a common 

flavor that goes into meat products.

 And so the higher the nitrate levels 

we have, the less celery that goes into it, and 

so that means it's less impact to color and less 

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impact to flavor to keep the desirable flavor and 

organoleptic properties that we like in our cured 

meats.

 But there's other boxes that we need 

to continue to focus our research on, definitely 

around the juicing process, identifying where the 

juicer is in location to where the crops are.

 So there has been some work done and 

we believe that there is enough acreage 

available, but that acreage needs to be in a 

proximity close enough to a juicing facility, 

because we know that raw celery does have a short 

shelf life, and we also need to understand, how 

short is that shelf life, how many days, 

depending on the variety, can it be held before 

it needs to be processed, or do we start losing 

nitrate levels because the normal enzymes within 

the plant are continuing to operate until the 

celery is blanched?

 And then once we identify, you know, 

the distance that's needed, the shelf life of the 

celery, the next hurdle that needs to be overcome 

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is, is the juicers that we've identified, will 

they have capacity within that limited timeframe 

to start harvesting these vegetables?

 Because I'm sure at that the same time 

that celery is coming out of the field, so are 

lots of other vegetables that they're currently 

processing.

 And so we need to make sure that 

there's also a juicer with the appropriate amount 

of capacity.

 Moving into the fermentation step, 

which is an area that Kerry and other suppliers 

participate in, there's also some questions that 

have come up in the research that surprised us 

about whether the bacterial strain has the 

capability to convert the nitrate to nitrite in 

these organic varieties.

 And this step is actually really 

important and critical to creating a standardized 

meat -- or standardized product for the meat 

processors so that they're delivering the correct 

amount of nitrites into their meat to make sure 

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that their food product is, in turn, a safe food 

product for consumers to eat.

 And then obviously, because this is an 

agricultural product, we can't expect that 100 

percent of the time, that all of the celery 

that's grown is going to meet these requirements.

 And so I think the most critical part 

and the critical box that needs to be checked in 

order to have full success in this process is, 

where is the outlet for the celery that doesn't 

meet the nitrate characteristics or won't be able 

to convert?

 And hopefully, we'll be able to find 

a cultivar that is suitable for celery powder 

production, but is also suitable for, say, other 

industries, like the fresh market or even 

culinary applications.

 But we do need to be mindful that, you 

know, growing celery for culinary applications, 

for whether it's color or flavor, may not be an 

ideal attribute for meat production, but it's 

important that we find that outlet to reduce the 

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amount of risk to the organic grower.

 Is an increased amount of synthetic 

nitrogen fertilizer required to produce plants 

with high nitrate levels for celery powder 

production?

 So we do know that there's a question 

out there as to whether conventional celery 

growers, the suppliers that we're currently using 

today, if they just apply fertilizer prior to 

harvest, and that's how they achieve their high 

nitrate levels.

 And so Kerry had worked with a 

conventional celery grower to do a small plot 

study, so they were growing -- the celery variety 

here is used in the fresh market, and we asked 

them to apply a handful treatment of urea at the 

time that they would harvest their crop.

 And so as Erin had mentioned, we take 

eight-week old seedlings and transplant them into 

the soil. At that point, the growing cycle is 

about 90 days.

 And so in this particular crop, at 95 

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days, that's when they would have deemed their 

crop at full maturation. And so they measured --

they gave us samples so that we could measure the 

nitrate levels, they applied a foliar feed, and 

then we monitored it at Day 96 and 97.

 And we were actually surprised to see 

that there wasn't a significant impact on the 

nitrate levels. However, it was really 

interesting to see that the nitrate levels were 

almost double at Days 75 and 81.

 And so my first thought there was, was 

there a significant amount of rainfall that 

reduced the nitrate levels of the plant?

 So we looked through the historical 

weather data and there actually wasn't a 

significant difference in the rainfall levels. 

Between Days 75 and 81, there was just less than 

an inch of rainfall, and between Days 81 and 95, 

there was just under an inch and a half, so not a 

significant difference there to explain why the 

nitrate levels had dropped to almost half.

 But I would suspect that knowing that 

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as in the last month of maturation of the celery 

plant, that's when it takes up most of it growth, 

that it was probably converting the nitrates, at 

some point, to other compounds that are needed 

necessarily for its growth and development.

 And so I think an area that our next 

research will focus on is not necessarily 

thinking that it's all around the foliar feed 

application, but is a strategy to continue to 

monitor the levels as it approaches maturation 

and find that sweet spot between plant size, even 

if it means sacrificing some pounds to achieve 

the high nitrate levels that are needed.

 Since 2015, what progress has been 

made on the production of the organic celery for 

powder production?

 So Erin had obviously shared a lot of 

the data that she did on the growing side with 

the different vegetables. From the Kerry side, 

she also shared some of the samples that were 

grown at the West Madison Agricultural Research 

Station. 

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 And I'm only showing the data of the 

four varieties that had been grown both in 2016 

and 2017. And so we had taken this juice and we 

had put it into our fermentation process, and in 

2016, we had seen that, if not all, the majority 

of the nitrate had been successfully converted to 

nitrite by the bacterial strain that we're using.

 But in 2017, we didn't see the same 

trend and this was actually really surprising to 

us, because this was the same varieties, grown in 

the same field, under the same growing 

conditions, you know, Erin had said that they 

standardized it to the same nitrogen levels, and 

fertilizers and nutrients at the start, yet, 

there's a significant difference in the percent 

conversion.

 And so we had discussed that there 

could be, in future research, we need to better 

understand the bacterial nitrate reductase 

enzyme. Are there certain cofactors needed for 

that enzyme to work or was there an unintentional 

inhibitor that was added between 2016 and 2017 

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that could have accounted for this difference?

 So I don't see this as a significant 

setback, but it's just a point that highlights 

the complexity of this process as more than just, 

can we grow celery organically, because we know 

we can for the fresh market, but the 

characteristics that are required to create the 

consistent and safe product for meat processors 

involves a bit more complexity than it originally 

looked like from the beginning.

 Are there commercially available 

agriculturally produced alternatives to celery 

powder? And so over the years, Kerry has tested, 

as we come across suppliers that offer different 

high-nitrate vegetable sources, whether it be 

conventional or organic, we do request samples.

 And so we've tested a number of 

different products. Unfortunately, you know, 

most of them either had issues with nitrates or 

there were issues with the conversion.

 There was one vegetable that did make 

it through the first two qualifying 

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characteristics, however, once it got put into 

meat applications, we realized that it had a 

strong negative flavor impact.

 And when I was talking with Andy and 

Erin about that, they pointed out to me that it 

makes sense because Chinese cabbage is a 

cruciferous vegetable, which has high sulfur 

compounds, and so going forward, we would try to 

avoid that family of vegetables when we're 

looking at alternatives going forward.

 But these challenges that we face in 

terms of nitrate levels, conversion, flavor, 

color, we put Swiss chard into meat applications 

and it has seen impacts on the color.

 This is why celery is still the chosen 

vegetable and why it's the ideal vegetable, 

because it has the high nitrate levels needed for 

functionality, but low organoleptic impact in 

meat.

 And lastly, if not enough organic 

celery is being produced to support the meat 

industry, why not? 

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 And so I bring it back to this celery 

cycle and like I had mentioned before, we believe 

that there's enough organic celery -- or organic 

acreage out there to grow celery, but that 

there's other areas that we need to investigate 

further so that we can create this robust supply 

chain so that it reduces to the risk to the 

organic celery grower in creating a sustainable, 

profitable process for them to create celery 

powder.

 And so with that, I conclude my 

presentation. I do want to say thank you for 

allowing Kerry to be a strong industry partner in 

this area.

 I do believe that we will find a 

solution with the proper time and adequate 

funding, and in collaboration with all of the 

groups that I have on this slide here, but it's 

been really exciting on the progress that we've 

made and we're continuing to looking forward to 

working together.

 DR. MATHEWS: Thank you, Ms. 

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Wasieleski. To the board members, we do have two 

minutes if you have questions for brief 

clarifications.

 MR. BRADMAN: Harriet.

 CHAIR BEHAR: Could you, in a short 

way, explain the fermentation process that you do 

and what properties does it impart to the celery 

powder that's part of, you know, when you're 

using it for curing meat.

 MR. WASIELESKI: So the main purpose 

of the fermentation process is just to take the 

nitrates and convert them to nitrites.

 So before a pre-converted product came 

out on the market, meat processors would be just 

putting these vegetables into their meats, as 

well as the starter culture that has that 

capability, but if you have issues in your 

processing, your temperature control isn't as 

tight, you can have inconsistent results, and 

that's where this pre-converted product provides 

a benefit to the meat processors, because they 

know that when they put this product in, they're 

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delivering exactly the amount of nitrite that 

they need for the safety of the product.

 Whereas, if they did the conversion 

process in the meat itself, there's a lot of 

variability that can happen.

 MR. ELA: Is there any evidence, I 

mean, obviously, in 2017, with the nitrate levels 

being lower, is the conversion process 

concentration dependent at all?

 MR. WASIELESKI: It's not. No. So we 

can run the process at any -- either really 

dilute or more high solids, so we don't feel that 

that's a part of it, but there's -- yes, there's 

definitely something interesting going on there.

 MR. BRADMAN: Rick, and very briefly, 

and this'll be the last question.

 MR. GREENWOOD: Yes, just a quick 

question. Do you add standard microbial 

cultures? Do you have stock cultures that you 

use or do you just use natural fermentation?

 MR. WASIELESKI: So we use cultures, 

specific cultures, so in the process, we would 

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sterilize all of the raw materials going in, and 

then add our specific strain.

 MR. GREENWOOD: Okay. Do you try 

different cultures, over time, do you get better 

conversion?

 MR. WASIELESKI: We have looked at --

there's a number -- there's, like, three strains 

that I can think of that all our capable of 

converting nitrate to nitrite, but we haven't 

seen any differences between the conversion, and 

we did test those different strains, with the 

material from 2017, but didn't see any 

differences.

 MR. GREENWOOD: Thank you.

 MR. WASIELESKI: Although, sorry, I 

will comment on that, if you look at the actual 

genetic makeup of the strains, they all have the 

same nitrate reductase enzyme within them, even 

though they're different stains, they all have 

the same. There's four different nitrate 

reductase enzymes and they all have the exact 

same one. 

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 MR. GREENWOOD: Okay. What genera are 

they in?

 MR. WASIELESKI: It could be 

micrococcus or staphylococcus.

 MR. GREENWOOD: Oh, okay. Thank you.

 MR. WASIELESKI: Yes.

 DR. MATHEWS: Thank you. We'll hear 

next from Mr. Peterman.

 MR. PETERMAN: Just making sure I'm on 

here so I don't blow everybody out of the room. 

Good morning, all, and again, like the other 

panelists, I'd like to thank you for the 

opportunity to have this discussion.

 We've been working on this for some 

time. Organic Valley has certainly has a 

concern, and I should probably clarify that 

Organic Valley is actually a brand name owned by 

the farmer-owned cooperative, CROPP Cooperative, 

and that cooperative also owns a wholly-owned 

subsidiary, the Organic Meat Company.

 So if you hear me rattling off 

acronyms without realizing it, OMC stands for the 

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Organic Meat Company and is where our primary 

interest in celery powder lies.

 The first question I'd like to address 

is, is celery powder, conventional celery powder 

in particular, still an essentially ingredient? 

And the answer is, unequivocally, yes.

 It is the, essentially, the only 

ingredient that we have access to that can 

fulfill the FSIS food safety requirements and I 

think that it warrants mention of the stakes that 

celery presents from the standpoint of cured 

meat.

 As you can see in that third bullet, 

cured meat products represent nearly 25 percent 

of the Organic Meat Company's gross revenue. And 

beyond that, the organic meat industry has been 

growing consistently over the last 20 years.

 And in 2017, the OTA reported that all 

organic meat sales amounted to about $1.1 billion 

and they've got a couple of subdivisions in there 

that I think are very helpful.

 We estimate that almost our entire 

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pork sales revenue is in cured products that use 

celery powder and on a national level, those pork 

sales amount to about $32 million annually.

 Sausage and deli meats, which would 

also be heavily dependent on celery powder in 

this context, amount to about $119 million, and 

beef, which would have a smaller component, but 

certainly would have some, amounts to about $263 

million.

 So you can tell that de-listing 

conventional celery powder without an organic 

alternative would be very destabilizing move in 

the industry as it stands now, and it's certainly 

an area of great concern for us.

 So I found myself thinking, you know, 

about the questions that all of you might have in 

your minds, and one of the first ones that came 

to mind was one that I carried for about the 

first year working with this group, and that was, 

why isn't the market just answering this demand, 

right?

 These are large industries, right? I 

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mean, millions and millions of dollars. And what 

we found through this process is that there are 

numerous constraints on this product that have 

been limiting it.

 Jennifer very eloquently put many of 

them, in terms of the conversion rates from 

nitrate to nitrite. These varietal differences 

that Dr. Silva mentioned, are extreme. And in 

some cases, you know, we're still trying to 

understand why they exist.

 The fertility and the regional 

variation, as we saw from year-to-year, even 

seasonal, but within OMC, the other thing that I 

started to recognize was that the sensory panel 

approval is also critical, right?

 So as we start looking at alternatives 

and even within organic celery powder itself, we 

still have to get this out in front of consumers, 

we still have to ensure that the ingredients that 

we are including are not compromising the quality 

of our products that consumers then buy and 

ultimately associate with our brand. 

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 So with all of these constraints, 

there's inherently a great deal of risk for 

anyone that might be looking to get into this 

market, might be looking to fill this demand.

 And the financial risk to the farmers, 

I think, is fairly apparent. They would very 

likely be under contract with an organization 

like Kerry, and it's going to be really hard to 

get a farmer to sign-up when they don't have 

varietal recommendations, they don't have 

fertility recommendations, and even if they 

follow those things to the T, to the best of our 

knowledge, we may see seasonal variation that 

would essentially put that entire crop below 

specification.

 Beyond that, the financial risk to 

processors would also be considerable. An 

alternative to that circumstance where the farmer 

takes the risk, a processor might contract and 

say, you can have a flat rate, right? We won't -

- if it doesn't meet spec, we'll take that on.

 We've seen that in the seed industry. 

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Unfortunately in this case, you have -- that 

amounts to a great deal of risk because not only 

is the processor then taking on the production 

risk, but they also have the risk of that product 

not necessarily being consumed or utilized in the 

way that they think it will be.

 So the demand for that organic celery 

powder on the other end is also not assured. And 

then finally, the product is used in extremely 

small amounts.

 The recommendation that our 

certification department gave to me was 

approximately 0.4 to about 0.9 percent of the 

green, what is the called the green weight. So 

it's a by-weight calculation, but it essentially 

amounts to ounces per 100 pounds.

 So it's a very, you know, small part, 

but also, a very critical part of the process. 

And then that, in and of itself, dictates that 

the gain for processors or farmers in this 

context is fairly limited.

 So you're essentially, in this case, 

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asking farmers to adopt a crop that they may or 

may not already produce, and the profit on the 

other end, certainly, doesn't justify the risk.

 And that's why we find ourselves, I 

anticipate, in this circumstance where it kind of 

languishes in-between a market-driven 

investigation and a grant or public research 

investigation.

 I bring all of this up because I think 

it bears heavily on a number of products that are 

currently listed on the 606. I think it's a 

problem we're going to see ourselves finding in 

the future, and that we probably need to work to 

identify, where are these products that don't 

necessarily represent a large enough opportunity 

for the market to get traction, develop a 

product, and then move forward on the basis of 

the risk.

 And finally, I just wanted to mention, 

and it's been covered by a number of the other 

panelists, but is the use of synthetic nitrogen 

increasing the conventional celery production. 

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 As Dr. Silva reported, our experience 

engaging our farmer network is that the 

contracted growers have been very unwilling to 

share in-field practices, so it's largely 

speculative from our perspective.

 We don't really have data, and, you 

know, it also, to a degree, seems somewhat beside 

the point. From our perspective, we would 

maintain and pursue an organic source of this 

material regardless. It just, as a measure of 

integrity, and as Jennifer very eloquently 

pointed out, as a way to expand organic vegetable 

production and demand.

 So I will leave it there.

 DR. MATHEWS: Thank you, Mr. Peterman. 

To the board, we have time for clarification 

questions.

 MR. BRADMAN: Harriet?

 CHAIR BEHAR: Where is the 

conventional celery grown for celery powder 

grown?

 MR. PETERMAN: Great question. We 

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identified three major regions that we looked at 

through the Working Group. Florida, the upper 

Midwest, and California are the predominant 

areas.

 MR. BRADMAN: Steve?

 MR. ELA: So, don't the same problems 

exist in the conventional celery powder thing as 

in the organic? 

 Don't those growers take the same risk 

because there's the same problem with 

alternatives if they don't meet spec? Or how do 

they control that? 

 I guess I'm not clear where that break 

is, between conventional and organic. 

 MR. PETERMAN: It's a good point and 

I think that it relates to scale of these 

industries. So, if you look at the conventional 

industry, whether it be conventional meat curing 

or other uses for that celery powder, you have a 

much larger pool of potential buyers and also 

potential demand. 

 So, as I mentioned in the organic seed 

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issues where we've seen this, it is also an 

element of companies that do not entirely produce 

organic products. 

 There are many, many companies that 

are producing conventional products and then they 

open up organic lines. 

 And so we see that the organic demand 

is enough to get their attention but not 

necessarily enough to justify that either 

business unit or that new product development. 

 DR. SILVA: Could I add to that as 

well? So, we did not do within our experiments 

control plots with conventionally grown celery. 

 It was really our intention to 

optimize the organic system but in terms of 

nitrate or ammonium availability, crop available 

nitrogen, it's going to be significantly 

different in organic because it's going to be a 

biologically driven process that's going to be 

mediated by a variety of environmental impacts. 

 So, I think that that could be a key 

aspect of why. And again, it's very speculative, 

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but why they may have a more stable system in 

conventional if they're using synthetic nitrogen 

where that aspect of uncertainty is taken out. 

 MS. WASIELESKI: Sorry, and I'll also 

add that when it comes to the conventional 

growers, they've been doing it for at least the 

past decade. We've only spent since 2015 

researching this topic. 

 But to Logan's point, there was a 

large enough market demand for them to want to 

develop that themselves, whereas, the demand on 

the organic and the usage levels are so low that 

it really needs to be an industry research 

project as opposed to the industry doing the 

research. 

 DR. MATHEWS: Just as a reminder, we 

will have an extended Q&A session following our 

final presenter.

 MR. BRADMAN: Exactly, so these 

questions should be just clarification. Let's 

move to the next presentation. 

 DR. MATHEWS: Okay, thank you, and 

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finally, we'll hear from Dr. Milkowski. Your 

slides are ready. 

 DR. MILKOWSKI: Thank you very much. 

Okay, now we're on. Thank you very much for the 

ability to comment here. 

 My friends here to my left have really 

answered most of the questions concerning 

production and the generation of nitrate and 

nitrite in celery powder. 

 I think what I will do in moving along 

is to respond to some of the questions a little 

bit that were directed towards me. But the last 

question, which I'm the sole responder to, is the 

one that I'll spend the most time on. 

 And I have that listed here as human 

nitrogen oxide physiology because it's very 

interesting and reinforces the complexity of 

nitrate and nitrite and where does it come from, 

where does it go? And all of that. 

 So, first question is, is non-organic 

celery powder still essential for production of 

non-processed meats? I'm not aware of anything. 

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I think they have answered the question much 

better than I could. 

 I would tell you that from the 

perspective of a meathead like me who would be 

more focused on making the meat product, nitrite 

and nitrate are the same ion regardless of the 

source. 

 And through thousands of years of the 

development in curing meat products and the 

increase in scientific knowledge in the twentieth 

century, we know that in order to properly cure 

processed meats and get the benefits that we want 

in terms of pathogen safety and the color that 

characterizes these products, we need about 80 to 

200 parts per million on a meat basis going into 

that mixture. 

 And if you apply a dilute source, you 

need lots of it. If you apply a concentrated 

source, you need less of it. So, if you take 

pure nitrite and nitrate, you would be talking 

about 0.01, 0.02 percent. 

 If you are talking about the celery 

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powders, you need 100-fold of those types of 

levels. And this is what's going on in the 

biochemistry there in that we characterize it by 

a cured meat color, which relates to nitrate 

reacting with myoglobin. 

 There is a lot of oxidoreductive 

chemistry going on in its conversion to nitrite 

and a rereduction of the myoglobin, the iron in 

the myoglobin, to an iron plus two state, which 

will then also be coincident with formation of 

nitric oxide, a gas. 

 So, we go from NO3 to NO2 to NO. Two 

charged compounds to an uncharged molecule and 

they become increasingly unstable as you move 

down that pathway. 

 The half-life of nitric oxide and 

biological tissues is a few milliseconds. It's 

going to react with something and typically 

sulphidal groups or with the iron in a heme 

group. 

 When it binds to a heme iron in the 

plus two state, you get a nitrosohemochrome, 

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which is the characteristic pigment that we call 

cured meat. 

 And from that we get the benefits of 

color, we get an antioxidant effect, and we get 

very important antimicrobial effects in terms of 

we have a more stable system with respect to 

potential for botulism growth under anaerobic 

conditions or clostridium perfringens growth if 

you're cooking a product and then trying to chill 

it and not have perfringens spores be activated 

by cooking and then grow out and cause problems. 

 And it has in the last 20 years been 

recognized that it's an important factor in the 

safety system for listeria monocytogenes in 

processed meats. 

 And that nitrate and nitrite can come 

from either celery powder or a purified source. 

Question 4, are there strategies to produce 

organic celery powder that's standardized? 

 I'm totally unqualified to answer 

that question so I'll have to defer to my 

colleagues here. And are there other available 

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alternatives to celery powder? Well, we've heard 

about a number of them. 

 In the 40 years that I've been 

involved in nitrite and meat curing, a number of 

high nitrate vegetable sources have been 

identified. These have all been reported to have 

north of 1000 ppm of nitrate in them on an as-is 

basis. 

 And when they've been tested in one 

way or another in a meat product, there have been 

problems in the quality of the meat product. And 

so any further work has been discontinued, which 

I think is consistent with what you've heard. 

 And then the last question that 

perhaps we'll spend the most time on is what's 

the latest information on human health risks of 

nitrates and nitrites present in processed meats 

from either the synthetic or organic or plantbased sources? 

 So, I'm sure all of you are aware that 

IARC, the International Agency for Research on 

Cancer, classified processed meats, which may or 

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may not be cured, as Group 1 carcinogens, meaning 

that they consider them to be a cancer hazard. 

 And in the final report that they 

issued, I would note that in all of their work, 

they were noting that cured meats are a minor 

source of nitrate and nitrite in human 

physiology, which I'll expand on. And they also 

indicated that the source doesn't matter in this 

case. 

 Although, if we go back 30, 40 years 

there was a great controversy around nitrite and 

its safety, our modern knowledge is that these 

classifications are probably due to some other 

mechanism and it's not likely to be the nitrite 

and nitrate. 

 However, there is this persistent 

feeling that that's what it is. But I'm here to 

tell you that it's very likely not for a number 

of reasons that we were totally ignorant of 30 or 

40 years ago. And that is nitrogen oxide 

physiology. 

 When I was in graduate school and we 

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were being taught about metabolic control, there 

was a factor called the endothelial relaxation 

factor that lowered blood pressure, relaxed 

smooth muscle and so forth. And it was very 

mysterious, nobody knew what it was. 

 Well, in the mid-1980s it was 

discovered to be nitric oxide, that same compound 

that is forming the nitrosohemochrome pigment in 

cured meats, and that there is a pathway in the 

human body to take the amino acid arginine and to 

do a six electron reduction and convert it into 

nitric oxide. 

 And it has profound physiological 

effects. Everything that allows us to live is in 

some part touched by this. It's involved in 

blood pressure control, in memory, in immune 

response, wound healing, all types of functions 

in one way or another. 

 And what's become realized now is that 

there is a nitrogen oxide in human physiology 

where nitric oxide is synthesized in the body, it 

is ingested in the form of nitrate and nitrite 

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from dietary sources, it's recycled in the body 

through saliva, and we have a huge exposure to 

nitrate and nitrite that is entirely natural. 

 In fact, our largest exposure to 

nitrate is from vegetables. And this is a 

summary of some of that work that's been updated 

to reflect that. 

 So if you were to look at the human 

diet formation or exposure to nitrate and 

nitrite, we would get up to 220 milligrams per 

day for an adult coming from the diet, except for 

cured meats. 

 Nitrite would be very, very small, 0.7 

milligrams. The exposure to 75 grams of cured 

meats, which is a fair amount, provides up to 6 

milligrams a day and next to nothing, 5 to 6 

milligrams a day, of nitrite. 

 Water with residual, water -- nitrate 

in water and lower levels of nitrite is an 

important source because we drink a lot of water. 

And saliva is an even more important source 

because of the recycling of nitrate in the body. 

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 And the endogenous synthesis of nitric 

oxide is about 1 milligram per kilogram of body 

weight. And that winds up being broken down into 

nitrite and nitrate and then are converted, and 

is both excreted and recycled into saliva with 

all of the exogenous sources. 

 And so nitrate is secreted in the 

saliva so the salivary glands actively accumulate 

nitrate from blood plasma as it's circulating. 

And about 25 percent of the circulating nitrate 

winds up back in your mouth and is swallowed 

again as nitrate is recycled. 

 The bacteria in your mouth are likely 

to have some level of nitrate reductase activity 

and that will form nitrite. And roughly 20 

percent of the nitrate that's secreted in the 

saliva goes into nitrite. 

 And then people swallow that nitrate 

and nitrite and in the acid environment of the 

stomach, that nitrite may be converted some to 

nitric oxide but it also has a biological 

function. 

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 And you would wonder why in the world 

would we have this pathway for us to recycle all 

of these nitrogen oxides if it wasn't beneficial?

 Well, there have been a number of 

studies that if you take gastric juice and 

supplement it with nitrite, it is much more 

inhibitory and bactericidal towards a number of 

the pathogens that we're inevitably going to 

swallow whenever we eat any food, especially raw 

commodities. 

 And so there's a proposal that this is 

a form of human innate immunity, which I find is 

fascinating. And I tell students that if you 

think everything's been discovered, think again. 

 This was totally unknown 30 years ago. 

So, in our lifetimes this is a great new 

discovery. 

 And so with that, I think I'm going to 

stop so that we can take on questions. And 

perhaps later during the question-and-answer 

period or if the Committee would like to look at 

it later, I'd suggest you test your own salivary 

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nitrate and nitrate levels. 

 I have these little test strips and 

the process of doing that would be to wet your 

finger, put it on the pads of the test strips, 

and then read them against the scale on here. 

And I'll leave this with you and you can do that.

 And you will be surprised that the 

younger you are and the more vegetables that you 

consume in your diet, the higher the nitrate and 

nitrite will be.

 If you use a lot of antiseptic 

mouthwash, you will probably see a low nitrite 

level because that is inhibiting the commensal 

bacteria in your oral cavity, which would be 

doing the reduction of nitrate to nitrite. 

 So, with that, I will end and thank 

you very much. 

 DR. MATHEWS: Thank you, Dr. 

Milkowski. To the Board members, do we have any 

very brief clarification questions for Dr. 

Milkowski before we move on to the Q and A 

session. 

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 MR. BRADMAN: Harriet.

 CHAIR BEHAR: Why is it that nitrate 

and water is hurtful to especially babies and 

pregnant women, but consuming nitrate in food 

does not have these same blue baby effect, for 

instance?

 DR. MILKOWSKI: Okay. Newborn infants 

have a high residual content of fetal hemoglobin 

in their system, which if you think about it 

biologically it's designed to bind oxygen more 

strongly than the oxygen in the blood of the 

mother. So the gradient for oxygen transfers 

towards the fetus prior to being born.

 After birth, that is replaced by what 

you'd say is normal human hemoglobin. Fetal 

hemoglobin is very sensitive to nitrite. That's 

one factor. The second factor is that the 

gastrointestinal tract of the newborn is 

virtually sterile, but as it gets colonized by 

bacteria, there will be bacteria in the 

intestinal tract that will reduce nitrate to 

nitrite. 

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 And so they are explicitly sensitive 

to having nitrite bind to their hemoglobin, and 

in essence create anoxia for them. That's a 

problem through about six months of life, and 

that's why we have so much medical concern about 

that. When you have adult human hemoglobin, this 

pathway is pretty innocuous. 

 So the toxic dose for nitrite in 

humans gets to be very, very high, although there 

is one. 

 MR. BRADMAN: Looks like we should 

open it up now for broader discussion.

 CHAIR BEHAR: Okay.

 MR. BRADMAN: Okay. So at this point, 

we want to open up the Board to ask any questions 

related to the presentations, and also on 

discussion related to the sunset and how to move 

this forward. I think both David and -- had a 

question and also Dan.

 DR. SEITZ: Can you give us some 

background material. Are there methods apart 

from celery powder that are used to cure meats, 

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and also or also going back traditionally, I 

imagine there have been cured meats for 

centuries, perhaps millennia, I have no idea. 

What were the methods that have been used 

traditionally to cure meats?

 DR. MILKOWSKI: So I'm not aware of 

any fractions of celery, but let me go back to 

the historical context of curing meat. The word 

for sausage in Greek is related to botulism.

 It was just by experience and 

coincidence that in preserving meat by salting a 

millennia ago, meat that happened to be -- or 

salt that happened to be a particular salt called 

saltpeter, potassium nitrate, was very, very 

effective at preserving meat when you salted it, 

to dry it out, to keep it from spoiling 

microbiologically.

 That coincidentally turned it pink, 

and that association was a way to recognize that 

you didn't have a preserved meat that would be 

toxic to you if you ate it. In societies where 

food was scarce, that was an issue. Today, we've 

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worked out a lot of the science and we certainly 

have a lot further to go.

 But the findings that nitrate gets 

converted to nitrite and where that pathway is 

early 20th century, and regulations and knowledge 

about using nitrite as the curing agent, which is 

more efficient and we can use less of it. Those 

were initially developed in the 1920's, and then 

refined in the late 1970's. 

 DR. SEITZ: But I mean is, can you 

take pure nitrite, I'm not a chemist, so I don't 

know if there's such a thing as pure nitrite that 

you can add to meat, or does everyone use 

something like celery powder that --

 DR. MILKOWSKI: Oh no. Most of the 

meat that's conventionally produced is cured with 

nitrite and some with nitrate. It's the -- the 

process is if you cure with nitrate, if you want 

to say produce a ham, it will take you three to 

six days. 

 If you use sodium nitrite, it will 

take you less than a day, and it's simply that 

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reduction of nitrate to nitrite as a time factor.

 MS. WASIELESKI: On that though, what 

I will say is in the last decade, there has been 

an increase in consumers demanding food 

ingredients that have clean label and 

recognizable ingredients. So that's why the 

demand and why celery powder has started to be 

used, because consumers recognize that ingredient 

as opposed to sodium nitrite.

 If you do go to the grocery store and 

look at those meats that are produced with sodium 

nitrite, compared to the meats that are produced 

with celery powder, you'll see that there's a lot 

more than just that ingredient that's been 

replaced or removed to create the cleaner label 

food products.

 MR. MORTENSEN: Thanks for the 

presentations. I had two unrelated questions. 

The first one had to do with most of the data 

that Aaron and Jennifer, that you guys were 

presenting was in parts per million 

concentration, and I was thinking to myself you 

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have concentration by mass to get the total 

amount of whatever it is that's coming into the 

processing facility, right.

 So you could have 400 PPM in 2017 and 

one quarter of the amount of celery mass, and 

then it's -- and then you're compounding the loss 

of the nitrate in the celery processing line. So 

my question is how critical -- maybe you spoke to 

this, but I wasn't really hearing it. How 

critical is it in the fermentation process that 

something comes in at 400 PPM or 2,000 PPM, when 

the end product of the celery powder is a dry 

powder with, you know, with some amount of the 

transformed nitrite in the powder?

 MS. WASIELESKI: Yeah. So the reason 

that we focus a lot on PPM is because in the meat 

regulations, the minimum amounts or maximum 

amounts that they're allowed to use are in the 

form of PPM. But at the levels that we're trying 

to target here, on a percentage basis it would be 

.4 to .9 percent. But that's at the targets 

we're trying to meet. 

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 If you met a third of that level, then 

you would be adding 1.2 to 2.7 percent of the 

product if it had a lower nitrite level coming 

out of the fermentation. 

 So the target levels that we're 

looking to achieve actually have nothing to do 

with the fermentation aspect, but how much of the 

actual celery biomass you're going to be putting 

into the meat product, and whether that's going 

to start having a color or an organoleptic issue 

in the meat application.

 MR. MORTENSEN: Okay thanks. That's 

very helpful, thank you. The second question had 

to do with Logan's comments that, you know, this 

is just the first of a number of kinds of natural 

ingredients, where the economic incentive may not 

be there for any one or several companies to 

pursue this.

 And OREI is one of the funding paths, 

and that's cool. USDA also has programs like the 

Small Business Innovation and Research Program 

and other things that are explicitly targeting 

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this, it seems to me this sort of application, a 

sort of a smaller application that might result 

in something bigger but maybe not. 

 I was curious if that has been 

explored as a mechanism for bringing industry or 

two partners together to do something.

 MR. PETERMAN: So it's a great point. 

To my knowledge, we haven't applied for an SBIR. 

We essentially initially used the farmers 

advocating for organics as that pilot funding, 

along with the OREI planning grant, so it was --

but similar, similar circumstance, that that 

organization is a farmer-appointed board within 

Organic Valley, that then makes the planning 

decisions, but the awards are below $50,000.

 So at this point, I find myself 

wondering if we've -- if we've exceeded the range 

of an SBIR grant, just because of the 

variability, because the questions that we're 

finding ourselves asking are pretty large in 

scope. But great suggestion and certainly worth 

looking into this round. 

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 MR. BRADMAN: So I'm going to 

intervene here and follow up one of David's 

questions, and then we'll have Tom, Harriet and 

Steve. About the parts per million, is it parts 

per million of the solid, the whole plant, or is 

it parts per million of the juice, or is it parts 

per million of the fiber that's the most 

important piece? And because you talked about 

getting it to a juicing facility.

 So it wasn't clear to me whether 

you're actually grinding up the plant drying and 

grinding up the plant, or whether you're perhaps 

evaporating the liquid fraction and therefore 

maybe in concentrating the nitrate and nitrite?

 MS. WASIELESKI: So when we refer to 

parts per million, we're talking about parts per 

million of nitrate or nitrite. So it doesn't 

matter how much celery fiber versus celery liquid 

that is in there; it's whatever the nitrate or 

nitrite concentration is. So I would --

 MR. BRADMAN: So the concentration as 

a substrate. So you're talking about the whole 

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plant?

 MS. WASIELESKI: We would expect that 

the juicers are using the whole plant, because 

that's the most economical. So I know in fresh 

market that they would cut the leaves off the 

top, but we would expect because the leaves do 

also contain high levels of nitrate, that they 

would be using the whole plant. 

 I think based off of the different --

the slide where I said that we had evaluated 

different sources, I think that there's probably 

some suppliers who are separating the solid plant 

portion from the liquid portion.

 I also think that there's some who are 

just grinding them up and drying the whole plant. 

So I think it depends on the company and their 

process.

 MR. BRADMAN: Okay, Tom.

 MR. CHAPMAN: I'm thinking about your 

question too. I'm not sure. Did you get it 

fully answered? 

 MR. BRADMAN: Not quite actually. 

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 MR. CHAPMAN: But I mean is that on a 

dry basis or a wet basis that you're measuring 

it? I mean I guess couldn't you take the juice 

and evaporate it in concentrate?

 MS. WASIELESKI: Yes, you can. But 

what needs to be delivered into the meat product 

is a specific PPM amount. So if you have a 

liquid at 50 bricks, you might be adding one 

percent of the celery product. But if it was 

dried, so then you'd assume 100 bricks, you might 

be only delivering half a percent of that celery 

product. 

 So the -- it's the concentration of 

the nitrate in the product. It doesn't matter 

whether it's diluted or concentrated. You still 

have to deliver that same amount of PPM. But the 

percentage of the celery then changes.

 MR. CHAPMAN: In the meat application?

 MS. WASIELESKI: Correct.

 MR. CHAPMAN: So I think maybe that's 

the confusion. In the farm side, the celery 

itself coming out of the farm, is concentration a 

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way to increase nitrate content that would be a 

viable method?

 MS. WASIELESKI: No, because you would 

-- all you're doing is evaporating water. You're 

still --

 MR. CHAPMAN: And you do that later 

anyway? Is that why or --

 MS. WASIELESKI: Right. So if you --

if you have something that's like when you 

concentrate it, either through evaporation or 

drying, all you're doing is removing water. 

You're not actually increasing the amount of 

nitrate per bricks of celery or for salads, 

amount of celery. 

 And so we -- we would receive say a 

concentrated liquid, because the benefit of 

concentrating the liquid increases the stability 

of the raw material. So if you think about meat 

is produced year-round, so we have to produce our 

ingredient year-round. When you juice celery, 

it's around four bricks.

 That four bricks liquid has a really 

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high water activity, and unless it's aseptically 

packaged and stored that way, you're going to 

have challenges with microbial control. So 

usually the products that we receive are in a 

concentrated form or a dried form, so that we can 

store it because, you know, celery is at least in 

the Midwest only one growing cycle per year.

 So that that can all be generated and 

then stored for nine months as we continue to 

work off the supply.

 MR. CHAPMAN: Good answer, but that 

wasn't my question. But did that answer yours?

 MR. BRADMAN: I think it does. 

Basically what we're saying is we can't remove 

water and concentrate the nitrate to the point 

where it's functional for the project.

 MR. CHAPMAN: So I have two questions. 

I was just trying to follow up on yours. I think 

they're quick, but the first one is we received 

some public comment talking about the use of 

nitrate in meat products and suggest that we can 

-- and you guys presented information about its 

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application, and it's a 200 parts per million 

range.

 And we had someone that had commented 

that we should compare it to drinking water 

requirements at ten parts per million, and I want 

to know how relevant that comparison is, if it's 

relevant at all.

 DR. MILKOWSKI: Well, that's a safety 

requirement related to drinking water that's 

consumed in large volumes, and you also have the 

concern about very young children. So I don't 

think it is directly comparable to that. 

 The stoichiometric amount, you know, 

the nitrogen attached to that iron is really 

about the equivalent of one to three parts per 

million of nitrite going in. However, the 

efficiency of getting it to that point is so low 

that you have to start with a higher amount.

 Those levels are regulated through 

USDA. It's in 9 C.F.R., and for ground products, 

comminuted products which is the definition, the 

maximum allowable is 156 parts per million of 

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sodium or potassium nitrate, nitrite on a meat 

basis. So you subtract any of the other things 

that you might add in making the product. Any 

added water, any added sugar, spices and so 

forth.

 If you have a whole muscle product 

where you have to worry about diffusing the 

material through a mass of the tissue that's not 

been disrupted, 200 parts per million are 

allowed. The one exception to that is with 

bacon, which is a special different product and 

is one product that was deemed to have a 

nitrosamine formation risk during the reviews in 

the late 1970's into about 1980-81.

 The requirement for enduring in bacon 

is you must use 120 parts per million, no more, 

no less of sodium nitrite or sodium nitrate, and 

you must use 550 parts per million of sodium 

erythorbate, which is vitamin C, or the 

stereoisomer sodium erythorbate. The reason for 

that is when bacon is fried at high temperatures, 

you do have the risk of forming nitrosamines. 

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 And so the ascorbate or erythorbate 

are there because they are very potent 

nitrosamine formation inhibitors, and the nitrite 

is lowered compared to the other products because 

that was a happy place to be when this evaluation 

was done at that point. To still allow you to 

make a product that was functional and would be 

accepted by consumers, yet add a minimal risk of 

forming nitrosamines.

 There's some other language in that 

regulation around nitrosamine monitoring with a 

protocol that defines testing for nitrosamines in 

fried bacon. They have a specific period after 

production too, which is 21 days and a frying 

protocol and limits for nitrosamines that would 

be detected to consider that product safe.

 MR. CHAPMAN: Thank you, and my second 

question is in your guys opinion, if we were to 

remove or recommend the removal of celery powder 

from the National List now, what would that 

impact be on the work you discussed? Would it 

accelerate or decelerate resolving the barriers 

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to producing an organic celery powder?

 MR. PETERMAN: That's a good question. 

You've got us thinking. I think the immediate --

I think the immediate response in the industry 

would probably be to destabilize development of 

new cured meat products because of that 

liability. Then from there, I think I would 

anticipate anyways pretty high variability in the 

way that the companies reacted. 

 Some may sort of steer into that skid 

and say, you know, we're going to trust that this 

is going to happen. Others may shy away, 

depending on how many other products they've got 

in their portfolio. So I think it's going to be 

a mixed bag, but I can assure you that it would 

be -- it would be a lot of anxiety.

 You know, I mean in the industry I 

think there would be a lot of anxiety. There 

would be a lot of destabilization. In terms of 

accelerating/decelerating the work, at this point 

I don't know how much effect it would have on the 

work. You know, I can't say assuredly that it 

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would go one way or the other.

 There may be certainly more interest 

in driving the research forward, but at the same 

time if you have people, if you have companies 

that are reducing their product investment in 

cured meats, there's going to be less income and 

less drive to pursue that ingredient. 

 So again, I think it's going to be a 

real mixed bag. You may motivate, you know, one 

or two companies to come forward and say we want 

to help with this, you know. We may also 

inadvertently motivate a number of folks to sort 

of step away and actually reduce demand for the 

product, and make it harder to bring it out.

 DR. SILVA: With any research, we need 

the research, the financial investment. So 

we've, I feel we have been as aggressive. I will 

look into Dave's SBIR suggestion and see if 

that's another potential source. But that's a 

factor that is going to be a reality of driving 

this forward no matter what.

 And then we're also under the reality 

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of this being an agronomic system where we're 

-- to be able to collect data, we have to wait 

the season and then evaluate and look at new 

factors. So there's those continued feedback 

loops and the reality of having this be a crop 

that's grown in the field and having to wait that 

time to harvest, and there's really no way to 

accelerate the growth of the crop.

 So but in terms of, again I think 

we've been successful with obtaining initial 

funding that's definitely gotten us a lot further 

ahead, and we've -- hopefully we will be able to 

push this forward. I just don't know in terms of 

an approach or trying to make this a more 

critical issue, if that would spur on further 

investments. 

 I think I can divulge this. In the 

reviews of the projects that we have put forward, 

there was definitely a recognition that this is 

an important issue. It's a critical issue. It's 

a critical aspect of organic and even supporting 

the other aspects of organic industry like the 

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organic dairy farms, where that's an important 

part of the economics of that industry.

 So I think that there is a realization 

that this is an important issue. We need to find 

a solution, but bringing all these pieces in 

place in terms of partners and field sites and 

funding is just taking some time.

 DR. MATHEWS: Thank you. Board 

members, we're at the five minute mark just for 

time management here.

 MS. WASIELESKI: And I think the 

complexity of the supply chain. I mean if I go 

back to the celery circle slide, I would say that 

depending on how you look at it, there's probably 

three or four specifically different types of 

companies that are involved in it.

 And so if removing it from the list 

ultimately impacts Logan's business, he's three 

steps removed from the grower. So to try to 

explain to a grower, you know, you need to take 

this risk on to grow this vegetable that we don't 

know the variety, we don't know the fertilization 

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practices and, you know.

 Between them, the juicer, a company 

like Kerry and Logan, who's going to accept the 

risk, and how do you get all four of those people 

together and linked together and say yeah, we're 

all going to accept the risk and if your field 

fails, he's going to pay for some of that too.

 I think that type of connection 

certainly doesn't happy today in the conventional 

industry, that each company kind of operates 

separately and you kind of know the people below 

you and above you. But that Logan isn't 

necessarily working with the growers that I'm 

sourcing my juice from, and neither are we.

 So I think that because of that, you 

know, disjointed, so many different companies 

involved, if at any step in that chain there is a 

company or the companies aren't willing to take 

on that risk, it's just going to fall apart.

 MR. BRADMAN: Harriet and then Steve, 

and then also if we go a little bit over, we'll 

just shorten our lunch so we won't ruin the 

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afternoon schedule. I hope no one's going to 

shoot me for that.

 CHAIR BEHAR: I have somewhat, I think 

somewhat short questions, two. Do they allow 

sodium nitrate in Europe? I believe they do eat 

quite a few cured meats, especially in Northern 

Europe, and the second question is in the 

subsequent OREI grant, do you have any 

cooperators on the conventional side? 

 It's somewhat disturbing to me that 

there's a lot of knowledge on how they grow it 

and then we're just starting from scratch on the 

organic side, not understanding their varieties, 

their fertility management, their harvest times, 

I mean all of these things. I'm just kind of 

wondering too if there's other universities that 

have worked on the conventional side, where at 

least maybe we would be a few steps ahead.

 So the first question is what do they 

use in Europe, and the second is what about 

future study?

 DR. MILKOWSKI: Yes, the nitrate and 

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nitrite are allowed in Europe. In the European 

Union, there is an E number assigned to those two 

ingredients.

 CHAIR BEHAR: I guess I meant in 

organic. Do they allow sodium nitrate in 

organic? I believe they do. No?

 DR. MILKOWSKI: Yes, they do.

 CHAIR BEHAR: Well Logan? I don't 

know.

 DR. MILKOWSKI: So organic nitrite and 

nitrate? 

 CHAIR BEHAR: Do they allow sodium 

nitrate in organic cured meats in Europe?

 DR. MILKOWSKI: Oh, in those products? 

I don't know that particular question. They do 

use it in conventional products, and there are 

regulations concerning its usage level. I think 

there may be some publications from the EU that 

talk about that.

 MS. WASIELESKI: I do think though 

there's -- I don't know about organic meats in 

Europe, but there's a distinct difference between 

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the organic in U.S. regulations is because of 

their E number system. Even if they were to add 

celery powder, they would still need to label it 

with an E number.

 And so in the U.S., one of the 

benefits of using celery powder is for the clean 

label declaration, whereas in Europe that benefit 

doesn't exist between the celery powder and the 

sodium nitrite curing salt.

 CHAIR BEHAR: And the university, the 

further research? Is there any way to have some 

conventional collaborators that maybe will help 

us move along, in understanding how to get the 

correct nitrate levels?

 DR. SILVA: We are partnering with 

University of Florida to bring in some different 

perspectives in terms of celery growing. It's 

been hard to connect, for whatever reason, with 

the conventional industry. But bringing in our 

collaborators and the expertise from the 

University of Florida, we're hoping to be able to 

gain some of that knowledge that you're talking 

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about.

 MR. BRADMAN: Steve.

 MR. ELA: I have to keep the trend to 

two questions, but in the nitrate/nitrite 

conversion, I mean you mentioned the one that 

there are four enzymes or whatever that change 

that. If you add that celery powder that is 

poorly converted like from 2017 to a meat, do 

those meats have those -- I mean does that 

continue to convert, or have you fermented it to 

its maximum point and it's done?

 MS. WASIELESKI: So I'll admit that 

I'm not an expert on enzymes. I just know that 

when we were trying to investigate where these 

issues came from and we looked at the genome 

sequencing of the available bacterial strains, 

that they all fall under this one specific 

nitrate reductase, as opposed to the others that 

are available. 

 Where they come from, I don't know. 

But in terms of the bacterial strains that we 

use, and if you were to put that celery powder in 

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in its nitrate form into a meat with those same 

starter cultures, because they're the only 

cultures, they're the cultures that would be 

approved for use in meat, you would still see 

that inconsistent conversion, and then 

potentially not be delivering the appropriate 

amount of nitrate PPM subsequently to make a safe 

food product.

 MR. ELA: And then my final question 

goes back to Andrew. So I didn't, and maybe I 

missed it, but so between the research over the 

last 30 years, where we show that nitrates and 

nitrites are cancer-causing agents and that our 

body is really good at recycling them and they 

have these gastrointestinal benefits, where does 

the health data fall?

 DR. MILKOWSKI: We're a curious 

species. We have on one hand a number of people 

who are very, very suspicious of nitrite and 

nitrate and their exposure in their diet, and we 

have all this newer information that says well, 

maybe we shouldn't worry about it. 

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 It's more of a sociological question 

than a scientific one. I can tell you that if 

you went to clinicaltrials.gov, you'll see 

hundreds of studies going on to use different 

forms of nitrite in nitric oxide delivery drugs 

to treat human health conditions, including 

direct sodium nitrite.

 There are few notable things that 

we've known about on nitroglycerine, which has 

been used since the 1860's to treat angina, is a 

nitrite and nitric oxide delivery drug that 

relaxes muscle and it allows better heart 

perfusion.

 Another one that's more recent is 

Viagra, which has a targeted tissue for release 

of nitric oxide to give its biological effect. 

Yet on the other side, we worry about it. The 

last thing I note is if you go to a drug store 

and go look at the toothpaste aisle and pick up 

any tube of toothpaste that has a designation for 

sensitive teeth, you'll find that on the 

ingredient list is potassium nitrate at five 

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percent, which is 50,000 parts per million.

 Now we don't swallow nitrate, but some 

of it is going to be swallowed and with our 

ecology and oral cavity, we're going to generate 

some nitrite and expose ourselves to that too. 

So I don't understand the psychology and 

sociological of the conundrum we're in, but 

that's where we are.

 MR. BRADMAN: I think we're going to 

get close to wrapping up. But Tom, could you 

answer a question. I think we've talked about 

this before, but nitrate, sodium nitrates are 

allowed in Europe for organic meat; is that 

correct?

 MR. CHAPMAN: I'd look to the 

certifier on the panel to answer that question. 

That's my understanding, is that the nitrates are 

allowed to cure meats via the EU regulations.

 MR. RICE: Yeah. I just looked at the 

sunset that we had in the packet. Sodium nitrate 

is allowed for meat products, but yeah.

 MR. BRADMAN: All right. Well, I 

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think we're a little bit over time but not too 

badly right now, so it's time to wrap up. If 

there are any last minutes questions, or if not, 

I want to thank the panel again for this 

presentation, and I think this is such of an 

important issue for important, you know, a huge 

portion of the organic industry.

 This is a really, been a valuable 

discussion, and again thank you to the NOP and 

the program for supporting this discussion. So 

Paul.

 (Applause.)

 DR. LEWIS: I want to just echo the 

remarks here by Asa. I want to thank Asa and 

working with us in the program. Also Clarissa 

for helping facilitate this panel. You know, 

we've been working for some time in terms of 

developing this panel, in terms of dealing with 

some challenging technical issues.

 I think we can all look about this as 

a success in terms of bringing people in, talking 

to the Board and really help facilitate a 

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conversation to help the Board do its work as 

part of a sunset review. So Asa again, thank you 

for helping working on this.

 MR. BRADMAN: Thank you.

 CHAIR BEHAR: Okay. With that, we 

will take a lunch recess, and I will keep us 

back, coming back at 1:45 for the methionine 

update, and then we will go to Public Comments. 

So thank you.

 (Whereupon, the above-entitled matter 

went off the record at 12:25 p.m. and resumed at 

1:47 p.m.)

 CHAIR BEHAR: Hello, everyone. Board 

members, please take your seats. Everyone looks 

pretty good here. Okay. We are starting the 

afternoon session of our first day of the 55th 

in-person NOSB meeting, and what we're going to 

start with is a methionine update, and I'm going 

to turn it over to the Livestock Subcommittee 

chair, Scott Rice. 

Methionine Update

 MR. RICE: Thank you, Harriet. If 

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you've been coming to these meetings for any 

length of time or any of the last 54, you've 

probably uttered or heard the words methionine, 

DL-methionine or some variation thereof, and 

you'll no doubt be familiar with our discussions 

regarding DL-methionine in organic poultry diets.

 We're continuing that discussion this 

afternoon, and are fortunate to have with us 

three individuals to give us an update on where 

things are at with the Methionine Task Force. We 

have Dr. Kristjan Bregendahl. Dr. Bregendahl 

grew up in Denmark and has lived in the U.S. for 

more than 25 years.

 He has a Ph.D. in Animal Nutrition 

from Iowa State University, and after a post-doc 

at University of Guelph in Canada, served as an 

assistant professor of Poultry Nutrition at Iowa 

State University. He taught nutrition classes 

there and conducted laying hen nutrition 

research. 

 Dr. Bregendahl is the author or coauthor of 22 peer-reviewed scientific journal 

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articles, two book chapters in a college level 

animal nutrition textbook. After leaving 

academia, Dr. Bregendahl has spent the last ten 

years as a poultry nutritionist with specialty in 

laying hen nutrition.

 He provides nutrition and management 

consulting for conventional and organic laying 

hens, and works with independent organic 

producers, companies and feed mills. Welcome, 

Dr. Bregendahl.

 We also have Heather Burley. Heather 

is currently a lecturer and lab coordinator in 

the Biology Department at McDaniel College in 

Westminster, Maryland. She completed her 

master's and Ph.D. work from 2007 to 2012 at the 

Pennsylvania State University in the field of 

Poultry Nutrition specializing in projects 

focused on amino acid nutrition and the study of 

potential alternatives to synthetic methionine in 

organic laying hen and broiler chicken diets. 

Welcome, Dr. Burley.

 And to kind of give us some historical 

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perspective and a general update on the 

Methionine Task Force we have David Will, who 

serves as the chair of the Methionine Task Force. 

David with Chino Valley Ranchers, and with that 

David, I'll pass it over to you. Thank you all 

for being here.

 MR. WILL: Thank you very much. I 

don't know. Is this -- there it goes. So I just 

have a real quick two little presentations that 

will take very quick, as soon as they get up, 

just to give you a little history and background 

so you can see where we are as a group and where 

we are an industry, and then we'll let the 

experts who you guys graciously brought in to 

discuss this.

 We appreciate the invitation of the 

chair to come in. Just to give you a quick 

update, you know, we have to be a certified 

organic feed. We can't use animal proteins due 

to the National Organic Program rules. So that's 

kind of where the need for this synthetic 

methionine came in. 

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 What goes forward, Michelle. There, 

okay. The Task Force was actually formed in '07, 

and then we are an industry group put together. 

We are funded through ourselves. We represent 

about 85 percent of the organic layers in the 

United States. It may be a little higher than 

that.

 We represent everything from pastured 

to small independent family-owned and operated 

farms to larger scale producers, and we also have 

three of the probably largest broiler people a 

part of us. No turkeys. So if you know any 

turkey people, we'd love to talk to them.

 We've researched, we've done some 

trials and we've given regular updates to the 

NOSB. We've done some work by Organic Valley. 

They did some milk whey protein, some potato 

starches and a high methionine corn study that 

they funded and did some work with.

 Then through our company, we did a no 

outdoor access, non-methionine ration for an 

entire flock that went to 65 weeks of age. We 

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looked at mulberry leaves as a source because 

silkworms, as you hear, are a great source of 

methionine, and they're a single feed ingredient, 

and then also brazil nuts.

 As a Task Force, we funded a high 

methionine corn trial that took about three 

years. We're still in the process of using that 

and we've got a field study growing some corn 

this year for some independent small producers. 

UC-Davis did a two year a black soldier fly 

study. 

 You'll see some information on that 

coming out. They're publishing, so expect 

something quickly, and then we're funding a 

literature review. The UC-Davis study was, took 

80 birds for 65 weeks of age. We funded 67,000. 

That was their study goals. It's in your pack.

 The big thing about it was if you took 

the 14 million layers, it takes about 910,000 

pounds per day of black soldier fly to feed them 

when they're young, and as they get older it goes 

to about 238,000 pounds. But that's as a dried, 

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so you need to multiply all those by seven, and 

then the next one real quick.

 You know, just skip it. Let's go to 

the experts, because you're -- they're better off 

with this anyhow, and I met my two minutes. It's 

in your packets if you want it.

 DR. BREGENDAHL: Well, thank you for 

having me here today. I'm going to talk about 

the need for DL-methionine in organic poultry 

diets, and just to give a little background about 

amino acids is that we put protein in diets for 

birds, but bird actually need amino acids, not 

the protein in there.

 And there are 12 amino acids, well 20 

amino acids in protein, 12 of those that must be 

fit into the diet. The thing about these 20 

amino acids is that they need to be fit in 

different amounts. 

 Birds need in different amounts, and 

as far as the traditional, the classic way of 

looking at this, this is a stave barrel here, 

which each stave here would be like one of the 

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amino acids, and you can only -- and this barrel 

here, it can only hold water up to the lowest 

stave.

 That's part of the production welfare 

of birds here. You can only have production up 

to the lowest amino acids in the diet here. So 

that's the first limiting amino acids, it's the 

lowest stave in there, and that one is methionine 

for poultry. It doesn't really matter how much 

of all the other amino acids are in there. It's 

the first limiting amino acid that kind of runs 

the show, and that's methionine for poultry.

 All right. So that's why we're here 

talking about in part about methionine. So this 

is what I do for a living. I make organic laying 

hen diets, and this is what laying hen diets 

would look like here. Typically, in the areas I 

work, Midwest, we've got corn and soybean meal, 

so that's what I use.

 And I put in two pounds of methionine 

in here. I do this to meet the requirements for 

methionine, which is shown at the very bottom 

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there. So that's how much methionine you should 

put in there, and I can get that corn soy and the 

DL-methionine. 

 If we work to make the same diet here 

meet the same amino acid requirements here 

without DL-methionine, I would have to increase 

soybean meal by quite a bit to get the methionine 

in the diet here, to make the methionine 16 at 

the bottom there equal.

 Well, that's a lot of soybean meal I 

have to put in there, 250 pounds a ton. That's a 

lot, and the protein goes up from about 18 

percent to 22-1/2 percent, just to get that 

methionine, extra methionine in there. The 

flocks I usually work with is around 20,000 hens. 

So that's individual organic producers.

 And so if I had to do this for them, 

one flock with 20,000 hens, I would need another 

100 tons of organic soybean meal per year to feed 

this flock here. To grow 100 tons of soybean 

meal, you need 100 acres of organic land, just to 

get the methionine in here. 

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 The use of protein in diet comes with 

some issues too, because the excess protein can't 

be used by the animal. It's back to that barrel 

again here. And so when you feed excess protein 

to birds, you end up with wet litter, basically 

because birds have to drink more water to get rid 

of that extra nitrogen in there, extra protein.

 That usually leads to ammonia issues, 

footpad lesions, burns on the feet. If you have 

high enough ammonia in the barn, you see 

blindness and respiratory issues, e coli 

peritonitis, mortality that comes with that. So 

there are some issues with extra protein, other 

than just the land needed to grow it there.

 So if we can't use methionine, you 

know, what can we use instead? Well so what we 

need in the DL-methionine is the methionine 

itself. So I put methionine levels in here and 

corn soy, just as an example here. But what also 

matters is the amount of lysine of the other 

amino acids, right.

 So I put lysine on here, but I could 

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have put total protein as well here. But the 

ratio, the balance between those two amino acids 

is what's important when you formulate the diets. 

So we could use corn, high methionine corn. As 

you can see it has more methionine, but it also 

has more lysine, it has more protein.

 So I kind of end up with the same 

issue as before. I just put more protein in the 

diet, it doesn't really help anything. Some of 

the other ingredients that are available, 

sunflower meal, canola meal, linseed or flax 

meal, same thing. They've got pretty good 

methionine contents but they also are high in 

lysine. So it doesn't help anything from a 

formulation standpoint. I still end up with high 

protein diets, way more than I need.

 There has been some interest in insect 

meal. So here's silk worm and black soldier fly 

larvaes, and you can see they have high 

methionine, but again they have crazy high 

lysine, so the ratio between those are actually 

not very good. So they don't really help either. 

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 The only thing I found so far that 

seems to work in literature, at least I found in 

literature it's not commercially available yet, 

but that's Brazilian tree nut protein powder. 

You can see that has a really high methionine. 

It has a pretty high lysine too, but the ratio 

between those is really good. It's way high in 

methionine.

 So that would probably work if it 

wasn't because it was grown in Brazil and it 

would have to fly to Iowa, Indiana where we feed 

the stuff. So you say well, let's just not put 

methionine in there and leave the protein where 

it is. 

 So here's back to the same diets 

again, 570 pounds of soybean. Now in both of 

them, I don't use methionine in the one on the 

right. So now I come up with a methioninedeficient diet, and so this is, you know, maybe a 

little extreme here. But you could maybe put it 

a little higher, but my point here is that you 

end up with a deficient diet that's too low in 

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methionine for the bird's needs.

 And so, you know, we need all these. 

I mentioned before the methionine kind of runs 

the show here. So the methionine, that level 

here, kind of limits everything now. And so when 

you have a marginal methionine deficiency in 

here, you get some production issues. The birds 

need this methionine to produce eggs and also to 

have a nice egg weight.

 But for perhaps what more importantly 

what you see is you get some issues with animal 

welfare. I see these in flocks here that are fed 

low methionine diets. I see those on the farms I 

feed right now, where you get these poor 

feathering, because feathers are high in 

methionine.

 Birds actually will get aggressive and 

other animals too if there isn't enough 

methionine in there. So they kind of start 

pulling feathers. They might even peck each 

other and die from this. So they kind of -- they 

need that methionine there for welfare and for 

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production both. With that, I will let Heather 

speak here.

 DR. BURLEY: Thank you very much for 

having me. I'll wait til they get loaded. 

There's a little bit of overlap in the beginning 

here, but I'm going to try very hard to boil down 

my last kind of decade of between research and 

literature reviews on different ingredients and 

strategies and things that we've looked at as 

replacements to synthetic methionine.

 So I'll talk a little bit less about 

the metabolism, since that was covered. So as I 

said, I'll kind of breeze through this, that 

methionine is one of ten plus essential amino 

acids for poultry, and these are the building 

blocks of poultry.

 So my analogy is kind of like when 

you're building a protein, it's like building a 

full size puzzle, and when you're missing one 

essential amino acid, it's like missing one of 

those puzzle pieces, and that's going to lead to 

those deficiencies that he just talked about, in 

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terms of the loss of feather coverage and feather 

pecking and cannibalism, and reduced weight, 

growth and egg weight.

 Then if you have that excess protein 

that he talked about in formulation, it's like 

you have the full size puzzle, but you have all 

these extra puzzle pieces that you can't include 

in anything, so they excrete it through their 

urinary system and it causes manure moisture, 

footpad lesions, breast blisters, increased 

ammonia and air, which is bad for the birds and 

for human health workers.

 So there's a lot of down sides to both 

of those situations, and poultry, like humans, 

like swine, are naturally omnivorous. So when 

they're fed plant-based diets, these are 

considered what are known as incomplete proteins 

for poultry.

 So they're not providing that complete 

complement of all those amino acids that they 

need like animal proteins would. So since 

organic birds are fed entirely vegetarian diets, 

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it's very challenging to find alternatives to 

synthetic amino acids without those meat-based 

ingredients.

 So I'm going to cover four different 

categories very, very quickly. One is looking at 

alternative breeds, alternative feeding 

strategies. I was asked to cover pasture as an 

alternative, and a little bit on ingredients. 

But again that was covered, so I'll kind of 

devote a little more time to the other three.

 So one thing we looked at in some of 

the literature review that I did was looking at 

breed alternatives. So the bottom line for this 

one is that there are different categories of 

poultry. So laying hens, broilers, turkeys, 

etcetera, that do differ in their amino acid 

needs based on their age, size and the purpose of 

them. 

 So they need to build different 

proteins for meat, versus different proteins for 

eggs. So they do have slightly different amino 

acid needs. But when you consider a category of 

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poultry, so your laying hens or your broilers, 

within that category they don't differ in the 

ratio of amino acids that they need.

 So you still need those same puzzle 

pieces to build that whole puzzle. You still 

need to build that whole barrel that he talked 

about. So commonly or more commonly used in 

Europe, there were these slower-growing strains 

that are studied.

 So these grow out for 12 weeks, 

instead of the typical five to seven weeks of 

conventional breeds, and they do have lower daily 

amino acid requirements, but it's mainly due to 

their lower growth and their lower production 

rates. One of the big things with these is that 

these breeds are not readily available in the 

United States right now.

 So this is not something that could 

happen overnight for that sort of thing, and they 

do take twice as long as grow out as well. Then 

there is a couple of different alternative 

feeding strategies that were looked at. One was 

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lowering dietary energy to kind of influence the 

birds to eat more, to try to make up for 

marginally methionine-deficient diets, and it was 

not found to be effective, to make up for 

methionine deficiency in any remarkable manner.

 Another thing that they looked at in 

another study was giving the birds a choice 

between energy-rich ingredients and protein-rich 

ingredients for them to try to naturally select 

for methionine deficient diets, but instead they 

kind of went for the more tasty corn-based 

ingredients for the high palatability. So that 

was not effective either. 

 So a whole bunch on pasture and 

forage. So for this one, pasture intake for 

birds is actually quite low. It's only about two 

to eight percent of the diets. They are 

consuming some grass if they're out on pasture, 

but it's not a significant amount.

 Palatability of plant species differs. 

So their consumption of it greatly would differ 

based on whatever pasture is available. One big 

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thing is the moisture level of the grass. So 

with the -- as is wet grass, methionine is 

actually very low in the sources. So it's not 

providing a very significant source, because most 

poultry feed is dried, it's fat-extracted, things 

are done to enrich those nutrients, which pasture 

does not have.

 The digestibility for birds is also 

very low, because like us and like swine, we 

cannot digest pasture. So ruminants such as 

cattle and goats can; they have adaptive 

mechanisms, different stomach systems which have 

bacteria that can digest it, but poultry cannot 

do that. Pasture is also not available in cold, 

winter months and you need pasture rotation to 

prevent burnout from the type of manure that they 

have.

 And insect and worm consumption we 

also looked at because this question came up, and 

that is also very low. It's only about .42 

percent of crop content, so the crop is an 

outpocketing of the esophagus that was sampled, 

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and the percentage in there was very low. So 

they are eating insects, but it's very low 

consumption.

 Then you also have that potential 

disease parasite risk from them being exposed to 

soil and insects. 

 So ingredients were kind of covered, 

but we've looked at a whole list, a whole slew of 

different ingredients that range from all the way 

as high as this brazil nut meal, which is one of 

the studies that I did. 

 But again, these are only found in 

specific countries on these very well-established 

trees. So this is a very finite available 

ingredient. It's really not practical for the 

large scale we need it at.

 There's other more animal-based 

sources such as dried egg and milk powders, which 

there's no organic allowance for because they're 

animal products. Fish meal is also very low 

availability and could have palatability issues 

at high levels for eggs and meat products. 

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Potato protein and other ingredients have antinutritional factors that interfere with 

digestions, and a corn gluten meal is not 

organically available.

 Sunflower seed meal, again limited for 

organic and has that issue with the 

methionine/lysine ratio. The same thing with 

those black soldier fly larvae. So the kind of 

take-home note is that many things have been 

investigated. Some have some promise, but all of 

them do present challenges and the availability 

is one of the big aspects of that.

 So my big take-home messages are 

insufficient methionine leads to issues. 

Extremely high crude protein diets leads to 

different issues, both of which impact the health 

of the birds. Right now, there's no single 

strategy or ingredient that's been identified or 

a combination of methods that can fully replace 

the need for synthetic methionine in organic 

poultry diets, despite extensive research over 

the past decade. 

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 Pasture access does not provide any 

aid in meeting those methionine needs. So my 

recommendation at this time would be to continue 

this average lifetime allowance for organic 

poultry until an effective alternative can be 

identified. Thank you.

 MR. RICE: Thanks very much to the 

panelists. It looks like we have some questions. 

Harriet and then Emily.

 CHAIR BEHAR: I have two questions, 

because that's what we always do now. The first 

one is have you tried some of them in groups? So 

I know like if it's something's kind of low in 

lysine and high in methionine, because it seems 

like you're trying single ingredients to replace 

the synthetic, and I'm wondering if blending a 

few together might be good?

 And then the second question is in the 

Organic Valley written public comments, they 

talked about a product called Methiomax, and I'm 

wondering if any of you know about that? It's an 

herbal -- I don't know. I was talking with David 

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Bruce. It's kind of -- it's herbally-based. I 

don't know how it's made or what other 

ingredients are in there, though it looks like 

it's just three herbs.

 That enhances methionine somehow, so 

then you need to use less. So I'm just wondering 

if you know about that. So the first one is have 

you tried blending agricultural products, and the 

second is about this product Methiomax.

 DR. BURLEY: All right. I'll do one 

take on it and then I'll see what I can add. So 

the herbal methionine I did look into for one of 

my literature reviews, a couple of different 

papers, and I saw a couple of different issues 

with it, the main one being that I did notice 

that they wrote it was -- it consisted of several 

herbs.

 But in many cases, they did not list 

what those herbs were, and I could not find what 

the source was, what the plant was, any details 

on it or even sometimes what country it came 

from. Another issue was a lot of those papers 

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came from the same company that was also selling 

that herbal methionine.

 So I have not seen anything that would 

lead me to believe that it is a strong 

alternative source at this time. A lot of the 

studies that I read through, they were also using 

other ingredients that were higher in methionine 

that were not necessarily organic to balance 

those diets. Do you want to take the next?

 DR. BREGENDAHL: Yeah. This the 

combination of the various ingredients, and 

that's what we do in practical diets. I just 

showed corn and soybean meal here. But in 

reality, we will add a little bit of sunflower 

meal, a little bit of canola meal if it's 

available at the feed mill.

 But because the methionine might be 

high in there, but again it's all the amino acids 

that matter. So we still have a lot of protein 

in those diets. Lysine is not the right, is not 

low enough in there. So it doesn't really help 

much over just straight corn and soybean meal. 

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 CHAIR BEHAR: I just want to tell you 

that I was able to find the herbal ingredients in 

that, and it's andrographis and tulsi and neem. 

It said 40 percent andrographis, 30 percent 

tulsi. I mean they gave the Latin names. I had 

to look it up and I said well the first two I'm 

growing right now in my greenhouse and I'll have 

out in my field this summer. I've grown them for 

years.

 I don't grow neem. I don't quite have 

the right climate in Wisconsin. But I was just 

interested in, you know, that possibility. It 

was kind of an interesting -- and it was part of 

the public comment from Organic Valley.

 MR. RICE: Emily.

 MS. OAKLEY: Thank you. So this was 

a question about the worms and insects that were 

.42 percent of crop contents on pastures. How 

many studies was that referencing, and is there 

information about the type of forage on that 

pasture and the frequency with which the birds 

were rotated or moved to fresh pasture, and does 

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that affect the outcome?

 DR. BURLEY: This was a very limited 

study. I have not been able to locate another 

study similar to that, getting that exact 

information. This was done by a master's student 

at Penn State slightly after I graduated from the 

program, and I dug back to her study. She did 

not publish the work, but she presented it, the 

findings in a poster session at a conference.

 And she had done the pasture 

quantification and insect and just anything that 

was in those crop contents. So I believe for 

that study, the pasture was not rotated. So that 

might make a minor difference. 

 But again -- and this was during the 

summer. So it would have been when there was a 

heavily populated insect population. So that 

would probably be even lower in winter months I 

would imagine. But yeah, this is only a single 

study. So there could be more research in that 

area.

 MR. RICE: Next, we had Dan. 

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 DR. SEITZ: My question is similar to 

Emily's. I've read about and have talked with 

small scale egg producers, who rotate their hens 

to follow the -- follow their ruminant animals, 

and time their pasture to correspond with the 

development of grubs due to manure and so forth.

 I was wondering if producers like that 

have the same problems as producers whose hens 

have the same type of methionine deficiency 

problems as large scale producers?

 MR. WILL: Yeah, I'm not familiar with 

that. I can't answer that.

 DR. BURLEY: I would imagine that 

they're also supplementing them with additional 

feed. I wouldn't think that they'd be able to 

support the production of those birds or, you 

know, just maintaining their growth or body size. 

Was this for layers or broilers? I imagine it 

was layers.

 DR. SEITZ: Layers. I believe so, 

yeah.

 DR. BURLEY: Layers, yes. 

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 MR. WILL: Dan, I'll just throw one 

thing in there, that of the three largest 

pastured producers out there, and I mean largest 

as far as bird count, most of them operate on 

very small, independently owned and operated 

farms, they're all members of our Task Force.

 DR. BURLEY: Another issue with the 

insects consumed from field and pasture that we 

didn't kind of touch on in the presentation is 

that the ones that are fed as a meal are 

dehydrated. So the moisture stayed down and 

we're actually concentrating the protein and 

we're concentrating the methionine content.

 So they're much richer in that dried 

form than they would be out in the field. So 

they're not contributing as much to the 

methionine as they would be as a meal.

 MR. RICE: And finally Ashley?

 MS. SWAFFAR: Thanks. Dan, you can 

ask me that question during our Board 

deliberations, because I've worked for two of the 

three of those pastured companies. But I do have 

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a question, a follow up on the alternative breeds 

that you talked about. Are there alternatives 

for layers or broilers? You kind of went over 

that pretty quick, and then could you explain a 

little bit more on the difference between the 

daily lower rates for the slow-growing birds? 

I'd just like to -- you touched very quickly and 

that's a huge topic.

 DR. BURLEY: Yeah, yeah, yes. It is 

a very huge topic, and I had only a few minutes. 

So there were both laying hens and broilers. The 

laying hens just produced less eggs and broilers 

in general just took longer grow-out times, as 

kind of the generalized statement there.

 So you can feed slightly lower levels 

on a daily basis because they don't have as high 

-- you're not putting on as much muscle per day 

or you're not producing as much of those egg 

proteins per day. So it's lower production that 

you're trading off for providing lower 

methionine.

 DR. BREGENDAHL: And also if I may, 

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just remember that you have to also feed those 

birds, those broilers longer, right.

 DR. BURLEY: Yeah.

 DR. BREGENDAHL: So that your total 

feed use probably is the same as the fastergrowing one.

 MS. SWAFFAR: Yeah. That was going to 

be my follow-up as overall, the birds still 

probably would ingest the exact same amount of 

methionine over --

 DR. BREGENDAHL: It would still be a 

longer period, yeah.

 MR. RICE: We need to wrap it up here 

pretty quickly. Dave.

 MR. MORTENSEN: Yeah, just to follow 

on Dan's question. I have an impression, but I'm 

not an expert in this area, that there is a scale 

of dependency. The larger the flock, the less 

likely they are to get out into a pasture, and 

this is based on listening to growers talking 

about this.

 And therefore the more likely they are 

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to need to be sure that critical amino acid 

concentrations are met by supplements rather than 

some other form. Is there any truth in that?

 DR. BREGENDAHL: Yeah. From what I 

see in organic flocks, they do have outside 

access obviously, and there are birds outside. 

But most of the chickens are actually inside the 

barn. They don't necessarily go outside even if 

they can.

 I work with a certain producer that 

requires the pasture feedings. So they have 

really big doors, they must, so they can't go 

out. So there's fewer, a little more birds going 

outside but they're still, I say, no more than 

half of the birds are outside at any one time. 

 MR. MORTENSEN: I would say that I 

did, just like two weeks ago I was listening to a 

guy who has small flocks, but not tiny flocks. 

Like you know hundreds, not like the 20,000 bird 

flock you showed, who had the birds out because 

of the way they were being managed.

 They were out -- he was ensuring they 

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were outside by design, and doing rotational 

grazing in the way that Emily mentioned. So I 

had the impression he was of the opinion that you 

needed less supplements when you managed the 

birds that way. I'm just trying to --

 MR. WILL: Dan, I'll add two things to 

that. First, our company has 50 producers that 

have 2,000 or less birds. The majority of those 

are organic and on five foot per bird or more, 

outside access in a very wet climate. So they 

have good growth outside, good access.

 They all use synthetic methionine in 

their rations. Part of that is because the birds 

are conditioned from day of age when we can't let 

them out to know where their food comes from. As 

you saw on the one slide early, only two to eight 

percent of their nutritional consumption comes 

from the pastured area. It's kind of are you 

going to eat in a restaurant or go field strip 

and kill your own cow?

 The birds are kind of conditioned to 

where their food comes from and what it looks 

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like. And then second on that is annual. This 

is seasonal. There's a lot of great areas we can 

grow a lot of good pasture area, but they're also 

under three feet of snow part of the year.

 So they're forced into that. But even 

the people who are all small producers, all of 

them still use the average on their flocks.

 MR. MORTENSEN: Thanks.

 MR. RICE: Thanks everyone for the 

comments and to the panel for joining us. I 

really appreciate that and thank you for making 

the effort to be here. We're going to need to 

move on.

 (Applause.)

 CHAIR BEHAR: And enjoy your chickens.

 (Laughter.)

 CHAIR BEHAR: Okay. So we are going 

to move to Public Comment, but first I will kind 

of pass on some information. The National 

Organic Standards Board's conflict of interest 

policy can be found in our policies and 

procedures manual. Prior to this meeting and 

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every meeting, a spreadsheet of all the proposals 

and discussions documents is distributed to the 

Board members.

 They are then asked to declare any 

conflicts of interest in writing to the NOP. At 

this time, no conflicts of interest were 

disclosed, and in the interest of public 

transparency, I ask any of the Board members if 

they have any conflicts of interest on any of the 

items that are up for vote or for discussion at 

this meeting.

 (No response.)

 CHAIR BEHAR: Seeing none, we will 

move on and we will not do that before every 

Subcommittee. We've done our work. So we're 

going to move now to the Public Comment portion 

of the meeting. Public input is an essential 

part of the NOSB decision-making, and be assured 

that we do listen and depend upon your ideas and 

suggestions.

 We have already held two public 

comment sessions in a webinar conference call 

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type format for the spring 2019 meeting. All 

persons wishing to provide public comment sign up 

prior to the meeting and speaking slots are 

assigned on a first come basis. When we hit our 

limit, we put people on a wait list in case there 

are cancellations.

 Comments are limited to one per person 

for each NOSB meeting. So if you spoke at the 

webinar, then you cannot speak in person here, 

and we take as many written comments as you want 

to give us and sometimes we get buried. But it 

wasn't too bad this time. As well proxies are 

not allowed.

 If we call your name and you're not in 

the room, we'll try to come back to you if time 

allows. We're going to try to have everyone 

who's on the schedule for today speak today. We 

may cut out some breaks or go a bit late if we 

run long, so we really would like, we know that 

many people are leaving, and so to stay on our 

schedule we'll run everyone today who is signed 

up for today. 

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 For members of the public, if you have 

to talk to someone next to you, please take that 

conversation outside. Everyone, Board members 

and the public, please silence your cellphones 

and your computers so that we can clearly hear 

the speakers who are providing comment without 

distractions. 

 You can take photographs of speakers, 

but please do it in such a way to not disturb 

that speaker or the Board and, you know, stay 

kind of behind the table and the tapes there. 

Okay. I am going to -- each speaker has three 

minutes, and I'm going to ask Michelle to go over 

the --

 It's a little bit different than we 

had in the past. There is a three color. It's 

green, then it goes to yellow and then red, and I 

believe there's actually a clock in front of you, 

right?

 MS. ARSENAULT: That's correct. So 

for people that have commented in the past, 

there's a new timer on the podium and there's a 

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countdown clock, so you don't have to remember 

what the colored lights mean, and it has a less 

obnoxious beep than it has in the past. 

 CHAIR BEHAR: So there's no beep at 

the end?

 MS. ARSENAULT: There is a beep; it's 

just not a loud buzzing noise.

 CHAIR BEHAR: Great, okay. So --

 MS. ARSENAULT: One other thing. So 

it will beep when you reach your three minute 

time limit, and then it starts counting up so you 

know how far you've gone over. 

 CHAIR BEHAR: Okay. So when the red 

light comes on and the beep starts, you can 

finish that sentence, but please refrain from 

taking more time than that. We have many 

speakers to listen to, and only a limited amount 

of time. We ask that the commenters start with 

their name and affiliation at the beginning of 

their public comment.

 If any member of the Board has a 

question about the affiliation of the speaker, 

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please hold that question until the end of that 

speaker's comment. Once the commenter has 

completed their three minutes, I will then ask 

the Board members if they have questions for that 

individual speaker. 

 Lastly, individuals providing public 

comment to the Board are asked to refrain from 

public attacks that might impugn the character of 

any individual. If I hear that type of speech, I 

will interrupt the speaker and ask them to 

refrain from that activity.

 So I will call on the person who's the 

next speaker and also the person who's on deck. 

The on deck person will sit in the chair next to 

Michelle, and you can then feel free to take one 

of the animals on the table, to share the great 

biodiversity that we have. So first up -- yep, 

another point Michelle?

 MS. ARSENAULT: Can I just say one 

thing? I have one video for today's commenters, 

and no other PowerPoint presentations. If you 

think you have PowerPoint presentation for today, 

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I don't think I have it, so come see me. 

 CHAIR BEHAR: Yes Dave?

 MR. MORTENSEN: Some of us are just 

mildly hearing challenged. These mics are highly 

directional, so if you could -- if you're tall, 

move it up or otherwise we don't hear very well. 

Thank you.

 CHAIR BEHAR: Okay, thank you for that 

Dave. Okay first up is Kiki Hubbard, with Lynn 

Coody on deck, and Lynn there are border collies 

over there for you. Please state your name and 

affiliation. 

Public Comment

 MS. HUBBARD: Good afternoon. My name 

is Kiki Hubbard. I'm the Director of Advocacy 

and Communications for Organic Seed Alliance. We 

are a mission-driven organization that works 

nationally to ensure that organic farmers have 

the seed they need. Our home office is in Port 

Townsend, Washington, so welcome to our backyard.

 My comments are going to touch on two 

topics today. First, OSA appreciates the 

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Materials Subcommittee's work to provide further 

clarity on excluded methods. We are generally 

supportive of the proposal on the agenda, and we 

offer detailed recommendations in our written 

comments for further strengthening this document.

 The science involved in this 

particular area of the Subcommittee's work 

requires a steep learning curve to be sure, so we 

applaud these efforts and want to underscore the 

importance of this work to the growth and 

integrity of organic plant breeding and organic 

seed production.

 Secondly, OSA appreciates the 

Materials Subcommittee's work on the challenging 

issue of genetic integrity and transparency in 

the seed supply. We very much agree that testing 

for and monitoring the presence of genetically 

engineered material in seed use by organic 

growers is important, and we share the 

Subcommittee's concerns that some organic farmers 

are facing real market problems because of GE 

material in their seed and crops, despite their 

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best efforts to avoid it.

 We remain concerned, however, with the 

general approach outlined in the proposal that 

was presented last fall, which would require 

organic farmers as part of a pilot project to 

request detectable levels of GE materials in the 

seed they're sourcing.

 This project appears to try to achieve 

two goals, both to collect more information to 

understand the problem of contamination, and to 

establish a reporting protocol in the 

marketplace. In our view, it's necessary to 

decouple these efforts because the current 

approach is trying to understand the problem at 

hand, while at the same time trying to solve it.

 Because organic field corn represents 

a very small fraction of overall corn acreage in 

the U.S., organic field corn producers have 

limited choices in organic seed in conventional 

untreated options, and much fewer options in 

varieties that are actually bred for organic 

production systems. 

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 We remain concerned about implementing 

a pilot project outside of an expert body. We 

are also concerned about implementing a project 

without data that helps us understand what the 

feasibility as well as potential unintended 

consequences, including fewer organic seed 

varieties available.

 We believe data collection needs to 

happen, and that it should happen in a systematic 

and scientific way, and that this collection 

should be not put on -- should not be put on the 

backs of organic farmers and the certification 

and enforcement system.

 We're very hopeful that we can find a 

path forward that both supports more transparency 

in the seed marketplace, while encouraging much 

needed investments in organic seed production. 

Increasing the availability of organic seed will 

lead to more organic acreage, more organic 

farmers using organic seed that wasn't produced 

in conflict with organic principles and -- wow, 

this is a new system. 

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 (Laughter.)

 MS. HUBBARD: All of these factors 

strengthen organic integrity overall, and we 

shouldn't lose sight of that bigger picture as we 

grapple with this challenge. Thank you.

 CHAIR BEHAR: Hi Kiki.

 MS. HUBBARD: Hi Harriet.

 CHAIR BEHAR: So the discussion 

document from the fall and this one does not stop 

any farmer from using any corn seed with any 

limit of genetic contamination. 

 So I'm just not sure if a farmer 

wanted to buy a certain variety, knowing that it 

is high or not high or whatever level it is of 

having genetic contamination, I just am not sure 

why that would stop them from using it if they 

were not trying to get into a market that 

required less?

 MS. HUBBARD: I don't believe that any 

of our comments spoke to a concern like that 

Harriet, to be honest. So I'm not concerned 

about farmers feeling discouraged from using a 

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particular variety, if that's what you're getting 

at. 

 We are very concerned based on 

preliminary conversations with seed companies and 

other stakeholders, including certifiers, that 

there needs to be a lot more information 

collected before moving forward with confidence 

with this type of a pilot project.

 We are concerned about the unintended 

consequences of this establishing a de facto 

threshold that organic seed companies, despite 

their best efforts, might not be able to reliably 

meet, and therefore produce fewer organic seed 

options for the marketplace. 

 We're concerned that it sets a bad 

precedent of keeping the costs associated with 

contamination, the responsibility of identifying 

the problem and then dealing with it on the 

shoulders of the organic community alone. We 

have a number of concerns that OSA has outlined 

in previous comments. The one that you're 

speaking to isn't necessarily a concern of ours 

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at this time.

 CHAIR BEHAR: Okay. I guess what I'm 

hearing then is that perhaps the seed producers 

would not produce the seed because there's 

concern that they might not be able to sell it if 

it had a high GE content.

 MS. HUBBARD: Gosh. Well first of 

all, most seed companies are testing. Organic 

seed companies are often redirecting seed lots 

that test high in contamination to the 

conventional seed marketplace. They're already 

dealing with the problem internally, because they 

care about the integrity of the organic label and 

want to meet the expectations of their 

customers.

 We don't know. I can't answer your 

question because we don't know. We need more 

information. We need seed companies to respond 

to both the feasibility of this proposal and any 

ways that it could affect the way they operate, 

and whether it's even feasible to achieve current 

expectations when it comes to levels of 

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contamination.

 CHAIR BEHAR: Sue.

 MS. BAIRD: Hi. Thank you for this 

presentation. You're saying that you would like 

to see it decoupled. So would you have a plan, a 

proposed plan that would implement the 

decoupling, a plan that would say we're going to 

test for two years or three years or -- do you 

have a plan proposed, since you would like to see 

that done?

 MS. HUBBARD: Yeah. In previous 

comments by Organic Seed Alliance, as well as 

previous discussion documents by the Materials 

Subcommittee, going back I think six or seven 

years, when the focus was more on exploring 

whether it was feasible to establish a threshold 

at the seed level, we have long called for a task 

force made up of experts that could collect this 

data so we have a baseline to really understand 

the problem to begin with, and then to inform 

what is feasible on behalf of the organic 

community for addressing the problem of genetic 

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integrity.

 And so we very believe we need to be 

calling for a body of experts, be it a USDA task 

force or another body of experts, to carry out 

the much-needed research and data collection. I 

think a lot of these companies would provide 

years of testing data under a non-disclosure 

agreement. 

 So there's one idea. Moving forward, 

there are other low-hanging fruit opportunities 

such as really educating organic growers who are 

supplying to a sensitive market to be asking 

these questions of their seed suppliers. There 

should be more transparency. Some companies are 

already doing it.

 Let's encourage growers to ask those 

questions, as some of them already are, and to 

remind them that integrity begins with seed. And 

also we support the Organic Trade Association's 

recommendations to move forward with guidance for 

certifiers, to help them understand the best 

practices involved with testing protocols for GMO 

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contamination. Those are just a few ideas.

 CHAIR BEHAR: Sue.

 MS. BAIRD: Yes. Do you think that it 

would be a deterrent if this was passed, and we 

would require the farmer to incur the cost of 

genetic testing? Would it be a deterrent to a 

farmer to have to pay that cost, and would it be 

by lot or would it be by the season?

 MS. HUBBARD: So we are very -- we are 

very opposed to the particular part of the 

proposal that would require organic farmers to do 

their own testing should their seed supplier not 

provide detectable levels of the seed that 

they're buying. We do not think that is fair, 

and we do think that added burden could deter 

organic farmers in ways that are not supportive 

of the ongoing growth and success of organic 

agriculture.

 CHAIR BEHAR: Emily.

 MS. OAKLEY: Do you have some specific 

examples or suggestions for ways that we can 

encourage farmers to ask their seed companies to 

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provide that information if it's not actually 

stipulated as a requirement?

 MS. HUBBARD: That's a great question, 

Emily. Again, off the top of my head I think 

it's going to need to come from the certifying 

and inspecting community, perhaps from extensions 

who are fielding these types of questions from 

buyers. I think it's -- there are a number of 

ways to encourage that.

 I think at this time, given all the 

unknowns, it's not wise to require that of all 

growers, especially since not all growers are 

supplying to a sensitive market. That is not to 

minimize the importance of that information. We 

are certainly not advocating for ignorance here.

 We are advocating for a cautious 

approach in a way that keeps the big picture in 

mind, and that doesn't further burden organic 

farmers and further limit organic seed options 

available in the marketplace.

 CHAIR BEHAR: Thank you, Kiki. Next 

up is Lynn Coody, and on deck is Roland 

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McReynolds.

 MS. COODY: Hi. My name is Lynn Coody 

and I'm presenting comments for the Organic 

Produce Wholesalers Coalition, seven businesses 

that distribute fresh organic produce across the 

United States and internationally. In our 

comments to the NOSB, we express our own ideas 

and also provide a conduit for the voices of the 

many certified growers who supply our businesses.

 OPWC has provided detailed comments on 

14 of the 2021 sunset materials. We solicit 

comments from growers and handlers, and present 

their own words in our comments to show how these 

materials are currently used and needed in the 

produce sector.

 OPWC thanks the Subcommittees for 

their work, and we agree that with almost all the 

recommendations for this meeting. However, our 

written comments do address some points of 

disagreement and today we'll focus on three of 

these. 

 First is assessing cleaners and 

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sanitizers. We do disagree with many points in 

this discussion document, as well as a decision 

to move forward with a TR prior to presentation 

of this topic to the public. My colleague, Mike 

Dill, will address this in more detail.

 AITC. OPWC asserts that the long-term 

reliance on regulatory exemption for the use of 

conventionally sourced planting stock blocks 

continuous improvement in production of organic 

crops that are propagated through nursery stock. 

 Unless organic standards can provide 

practical methods of protection against spread of 

diseases and nematodes via planting stock, there 

is no incentive for nurseries to grow varieties 

that are specifically oriented to the needs of 

organic production systems and the organic 

marketplace.

 In response to a question about 

phytosanitary programs at the last Board meeting, 

our comments present our research on potential 

for AITC for making incremental improvements in 

nursery stock production. We urge the Board to 

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approve AITC with the annotation only on nursery 

stock subject to phytosanitary programs, and to 

add a research topic to find other possibilities 

for organic nursery stock to comply with these 

programs.

 We respectfully disagree with the Crop 

Subcommittee's recommendation not to list 

ammonium citrate and ammonium glycolate. We 

reviewed the technical report and the 

Subcommittee's evaluation checklist and found the 

recommendation is not well supported by these 

background materials. 

 OPWC supports listing multiple types 

of chelates so that growers have the opportunity 

to determine which works best in their specific 

conditions of soil type, soil temperature, water 

availability and crop mix.

 The TR supports the idea, stating the 

presence of other approved chelating agents on 

the National List does not make the petition's 

substance unnecessary. Further, we concur with 

the TR statement that the effect of chelation 

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becomes more dramatic in alkaline and waterdeficient settings, and note that many fruits and 

vegetables that enter the organic are grown in 

areas subject to these conditions.

 We urge the Board to take another look 

at background documents on these materials when 

considering the Subcommittee's recommendation. 

Thank you.

 (Laughter.)

 CHAIR BEHAR: Any questions for Lynn? 

Ashley.

 MS. SWAFFAR: Thanks, Lynn. I thought 

no one was going to ask you a question there. So 

I do have a question about the sanitizer and 

discussion document, and I'll ask Mike some more 

detailed stuff there. You had put in your 

comments that you were concerned with the 

intended outcome of this evaluation system. Do 

you see how we could use this -- how would you 

see that we could use this document looking at 

sanitizers?

 MS. COODY: I think I'd rather answer 

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the question a little bit differently than that. 

We had, we had a lot of concerns about not only 

the content of the specific document, but the 

concept behind it, as far as trying to define 

sanitizers in terms of uniqueness.

 First of all, that was not a defined 

term in the document, and secondly we are unclear 

how the -- why the idea of uniqueness is so 

important in sanitizers, when we know that they 

must be rotated in order to prevent their -- well 

in practical use, they need to be rotated, and 

that there are so many widely diverse situations 

in which they are used.

 So we're seeing that actually, instead 

of looking for uniqueness, we need to try to 

understand more like what is a range of things 

that we need and what types of things in general. 

What are the situations in organic processing, 

livestock and crop production where sanitizers 

are needed, and why are they needed? 

 So we feel like we're starting at the 

wrong point with this paper, and we need to like 

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have a very different concept for trying to 

understand the use of sanitizers in organic 

production systems. We note that sanitizers are 

used in every scope, and I would contend in 

almost every single organic operation.

 So any, any effort to regulate 

sanitizers has to really take into account all of 

the impacts that this would have on all the many, 

many organic operations. 

 CHAIR BEHAR: Dave was first, and then 

Emily and Jesse. Emily and then Jesse.

 MS. OAKLEY: Okay, just to clarify, we 

were trying to decide who got to go first. Just 

to clarify, the intent of this technical review 

is not at all to take away sanitizers. It's not 

to limit them. It's not to try to make it more 

difficult for producers.

 In fact, I think it compliments a lot 

of the concerns that you said you were worried it 

wouldn't do. That's in fact I think why we're 

trying to get this technical review. So I just 

wanted to assuage your concerns on that front, 

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and it is absolutely not the case for everyone 

who's coming forward in the future, that the 

intent is to limit people's tools. It is to try 

to help us determine as we get these materials, 

where their necessity falls.

 Because right now it's sort of 

happening and I don't want to say like in a 

vacuum, but to some extent it is, because it is 

hard to evaluate them based on this holistic 

approach that we don't really have at this point. 

A lot of them are not getting passed, and perhaps 

this would actually change some of that.

 CHAIR BEHAR: Jesse.

 MR. BUIE: On AITC, can you address 

the variability and the effectiveness of AITC 

across these various nematodes? The TR talked 

about how the effectiveness was so variable.

 MS. COODY: Okay. Thank you, 

Michelle. The number of nematodes and diseases 

that are addressed by phytosanitary programs are 

vast. So of course you would expect certain 

variability because each nematode is affected 

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differently by any given material.

 My interest in a material like this is 

not so much exactly which nematode that it's 

going to be effective for, but rather that it 

could help organic growers. So you're talking 

about a grower trying to produce organic nursery 

stock for use by other organic growers.

 I think that they are still, they are 

still subject to phytosanitary programs that 

require a very high level of cleanliness before 

the nursery stock is moved to another area. So 

AITC is not, would not in my view be a perfect 

material for every single, compliance with every 

single phytosanitary program.

 You would have to pick and choose to 

see which ones it would work for. So it might 

work for blueberries in Oregon, but not so much 

for, you know, garlic in Arkansas. You'd have to 

be careful. You'd have to choose and see which 

ones it would work for.

 MR. BUIE: Yes. It seems that the 

concentration needed for the various nematodes 

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has not been determined yet is what I'm saying. 

Is that --

 MS. COODY: Yeah. From the TR, there 

was, there was -- yeah. There's not a lot of 

research on how this could work. But I think 

that we need to take incremental steps forward, 

with trying to provide tools for organic nursery 

stock production, because otherwise, we sit here 

with problems where there's no path forward. So 

I think that approving this with the annotation, 

as I said, for use only in the case of 

phytosanitary programs would allow for a tool 

that could allow experimentation and could allow 

for just steps forward in production of organic 

nursery stock.

 We dealt with this before, where when 

we had our famous debates about antibiotics for 

fire blight, the main fix was let's have 

different -- let's have different types of 

varieties developed for organic production, and 

that was a 20 year horizon, and then at the end 

of the 20 year horizon we get stymied by 

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phytosanitary programs. So I'm looking at kind 

of a longer-term approach to trying to solve a 

really difficult problem of this organic nursery 

stock.

 I don't know that AITC is -- it's 

certainly not a panacea for all problems with 

organic nursery stock. But I think it would be 

an incremental step to give growers something to 

try. Additionally, it would not necessarily --

it wouldn't be a substitute for allowing full 

compliance. 

 What it would do would be to provide 

a tool for reducing the amount of nematodes and 

diseases present. That's all it can do. It's 

not going to be the same as using methyl bromide, 

that's for sure.

 CHAIR BEHAR: Dave is next, and then 

Tom.

 MR. MORTENSEN: Yeah, and Lynn I 

think, I think Jesse's point also applies to the 

ammonium citrate and glyconate examples. Over 

the past two years or so or something like that 

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we've realized that we really need to knuckle 

down on asking for efficacy data, as opposed to 

saying to an applicant saying or someone 

defending a sunset, you know, it works or, you 

know, it might work in the Pacific Northwest 

under this or that condition.

 MS. COODY: Right.

 MR. MORTENSEN: So I think as we go 

forward, we have to continue as a community to 

insist that we have some sort of, whether it's 

farmer to farmer on farm trial data or some kind 

of data, so that we can determine that we're not 

just, you know, just adding things to the list 

where we actually don't have compelling evidence 

that they're even worth buying.

 MS. COODY: Uh-huh, although I remind 

you that efficacy is not an OFPA criteria. So it 

does play into kind of a risk-benefit analysis, 

but it's not an OFPA criteria.

 MR. MORTENSEN: But I also think that 

we are not, at least we're not wanting to add 

things if we don't have evidence that they're 

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going to do good.

 MS. COODY: Yep, yeah.

 MR. MORTENSEN: So that's just a 

working principle that we're using.

 MS. COODY: I hear you.

 CHAIR BEHAR: Okay, Tom.

 MR. CHAPMAN: SDC. Should I ask you 

or should I hold it for Mike?

 MS. COODY: If it's not too technical 

you can ask me.

 MR. CHAPMAN: Did you see the 

petitioner's public comments about applicable 

areas and applications like that they did not 

think it was applicable for field applications 

based on the licensing. 

 Did you find that sufficient to meet 

your concerns about this material? And as a 

second part to it, if we were to annotate to 

restrict its usage to say municipal water 

systems, would your position on it change?

 MS. COODY: Yeah. It does change. 

OPWC was the one if you remember at the last 

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meeting, we were the ones that pointed out that 

tough language in the EPA background documents, 

and also expressed concerns about its use outside 

of municipal systems.

 So I did read that petition 

information again very carefully, and I did note 

that it was not -- they said it was not 

registered for those uses. If it were clearly 

annotated, then it would change my position. I 

feel like SDC has some good benefits as far as a 

sanitizer because its mode of action is so 

different than the ones that we have now.

 So if there could be annotation 

crafted, I would feel good about it. Our written 

comments do say we regretfully wish we could 

have sanitizers that have different modes of 

action such as SDC and, yeah. So an annotation 

could work from my perspective, and that's about 

as technical as I can get on that one.

 MR. CHAPMAN: Just as a quick followup, the human health concerns, the fate of some 

of the other environmental concerns, do you think 

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those are outweighed by the benefit if we do, you 

know, resolve this issue about municipal waste?

 MS. COODY: Well actually, some of the 

information that was presented by other public 

commenters in the webinars was compelling to me 

in that they said even for the case that it was 

going into a septic tank, that the sludge would 

be taken away and then treated independently as 

it would be treated as in a municipal system.

 So that was new information to me. 

I'm not an expert in sludge treatment, believe it 

or not, but I thought that was pretty interesting 

information, and I felt like it was kind of 

confined, and if it were additionally handled 

with an annotation to make sure that it was 

handled carefully, that's okay. 

 That to me, there again the efficacy 

of the sanitizer having another mode of action, 

that's pretty important to me. So I feel like 

the risk benefit is creeping along to the 

positive side for me. 

 MR. CHAPMAN: Thank you. 

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 MS. COODY: That's not very technical, 

but that's kind of what I can tell you. 

 CHAIR BEHAR: Okay.

 MS. COODY: Okay, thanks a lot. 

 CHAIR BEHAR: I just have one short 

comment and I have a question. I received a 

Stark Brothers catalogue in the mail, I don't 

know if anybody knows them, it's kind of a 

homeowners fruit tree. They ship fruit trees all 

over. They had a huge insert full of organic 

fruit trees, certified organic fruit trees. So 

they have figured out a way to be able to meet 

some phytosanitary. 

 I don't know where they're growing 

them or whatever, but there was at least 20 or 25 

different varieties of organic fruit trees for 

home gardeners to purchase, and I was thrilled.

 MS. COODY: Well each state has 

different programs for each individual type of 

crop. So like Oregon has blueberry phytosanitary 

programs. They're extremely diverse. So 

depending on where they're growing and where 

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they're shipped to, the programs are different. 

 So I can't speak for Stark Brothers 

but yeah, I'm happy they're giving organic 

growers -- organic trees for home growers too. 

 CHAIR BEHAR: Thanks Lynn.

 MS. COODY: Okay, thanks everybody. 

 CHAIR BEHAR: And so next is Roland 

McReynolds. I'm sure he has nothing interesting 

to say, and then -- so we won't have any 

questions, and then Cathleen McCluskey. No 

offense, Roland.

 MR. McREYNOLDS: None taken Madam. 

Madam Chair, members of the Board, thank you very 

much for the opportunity to speak with you here 

today. My name is Roland McReynolds. I'm the 

executive director with the Carolina Farm 

Stewardship Association. 

 We're a 40 year-old farmers 

organization working to build a sustainable, 

regional food systems in North and South Carolina 

that is based on organic farming and local food, 

and I'm here to speak to you today in support of 

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the petition that has been approved for your 

review, to add fatty alcohols to the National 

List as an allowed synthetic for use in sucker 

control in the production of organic tobacco.

 There are approximately 220 organic 

tobacco farmers in the United States, and people 

representing 169 of those farms signed a petition 

in support of the materials petition, and 

requesting that you make a temporary allowance 

for continued use of fatty alcohols in organic 

tobacco until you make a final decision on the 

materials petition.

 You received at least 26 written and 

oral comments from organic tobacco farmers in the 

docket for this meeting, requesting the same two 

actions. The average organic acreage of these 

family farms in North Carolina is 54 acres. 

These are the mid-scale family farms that are 

disappearing in America today.

 These family farmers have made clear 

in their comments why sucker control is such a 

critical issue for their farms, and how fatty 

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alcohols address their needs. You received 

comments from faculty at NC State University 

documenting their research that is no nonsynthetic material available that provides 

adequate sucker control in organic tobacco.

 You've heard from farmers that the 

alternative of hand suckering tobacco plants is 

economically unfeasible and unhelpful for farm 

workers. Organic tobacco pays the bills for 

these family farmers. It allows them to accept 

greater risk on other organic row crops and 

achieve the soil health and ecological benefits 

of soil-building crop rotations without putting 

their families' livelihoods at risk.

 Organic tobacco has converted 

thousands of acres to organic production in the 

Carolinas. You've received comments from other 

actors in the organic food supply chain in the 

Carolinas about how organic tobacco farmers have 

become the backbone of that supply chain. The 

crops these farmers grow in rotation with their 

organic tobacco have made our region a leader in 

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organic sweet potato production, have helped 

launch North Carolina in the top ten in value of 

organic production, and have fueled a market for 

locally milled and locally consumed organic 

cereal grains.

 All of this has been made possible by 

the availability of fatty alcohols for sucker 

control. These farmers have relied on this 

product for the last ten years. It is essential 

not only for them, but to the organic food system 

in the Carolinas. 

 If you did not take up the materials 

petition at your fall 2019 meeting, then next 

January when these farmers are offered tobacco, 

organic tobacco contracts, they will not know if 

they can meet those contracts.

 And they will be faced with the 

decision about whether to stay in organic 

agriculture or not. That is why it is so 

critical that you at this meeting make a 

recommendation to the NOP to grant a temporary 

allowance for fatty alcohols in sucker control in 

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organic tobacco, until such time as the materials 

petition receives your full consideration. Thank 

you.

 CHAIR BEHAR: Thank you, Roland. Any 

questions? Emily.

 MS. OAKLEY: Thank you for your 

comments, and I just wanted to just say that the 

webinar and the written comments were very 

compelling, and it's very helpful to hear from 

the growers. 

 However, my concern is that the 

essentiality is based on economic need, and in my 

own experience I've grown organic blueberries in 

a place that they really didn't apparently like 

to grow.

 And for the first time I understood 

why people loved herbicides, although I've never 

used one. I could understand why they make crops 

economically viable, and organic blueberry 

growers in my state all use herbicides, because 

that is what makes it an economically viable crop 

in my area. I actually no longer grow 

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blueberries.

 So I'm wondering if you think that 

economics really is a compelling reason for us to 

list an ingredient, especially a synthetic for 

which we have a high threshold for review?

 MR. McREYNOLDS: Well, I think that 

the technical evaluation report that was prepared 

in 2016 for a prior petition on this material 

definitely identifies that the evaluation 

criteria in 6518(m) are satisfied, you know. 

This does meet. It is -- the toxicity and mode 

of action is -- it breaks down very easily in the 

environment. 

 The probability of environmental 

contamination during its manufacture, use is very 

low, according to the TER. EPA calls it a safer 

choice. 

 It states that although there can't --

there are no human health risks of concern and it 

has -- and it is a benefit for worker safety, 

right, because they're not having to go into the 

field in the hot summer sun and subject 

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themselves to dermal contact with the plants, and 

so avoid green tobacco sickness.

 So it is -- the essentiality 

economically is, I believe, a fundamental factor 

that has not been brought forward. But I do 

think that the technical review that you've 

received so far definitely demonstrates that this 

meets the requirements for addition of the 

material to the List.

 CHAIR BEHAR: I see Jesse and Steve.

 MR. BUIE: Just a comment. Do you 

think that to further this discussion, if we 

decoupled tobacco from fatty alcohol, that would 

make this discussion a little bit more palatable?

 MR. McREYNOLDS: I'm not sure I'm 

following. I mean I believe -- the petition is 

limited to the use of this material on tobacco, 

not other crops.

 MR. BUIE: Right, right.

 MR. McREYNOLDS: Is that what you're 

getting at or --

 MR. BUIE: Oh no, no. I'm just saying 

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 MR. McREYNOLDS: Because I'm not sure 

that OFPA, you know, gets to whether or not, you 

know, we like the crop.

 MR. BUIE: Oh no. I'm talking fatty 

alcohol. That's what I was saying.

 MR. McREYNOLDS: Right, okay. I'm not 

sure I'm following.

 MR. BUIE: Okay. I'm just saying if 

we focused on fatty alcohol and not tobacco, 

would that -- that's the question.

 MR. McREYNOLDS: Right. It's 

difficult for me to decouple that, yes. I mean I 

-- in terms of the impact that it has on these 

family farmers, it is -- this is the crop that 

makes their rotation economically viable.

 CHAIR BEHAR: Okay Steve, and then 

Dave.

 MR. ELA: I think what Jesse's asking 

is there's been some discussion of -- people have 

various views of tobacco.

 MR. McREYNOLDS: Sure. 

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 MR. ELA: But our discussion is really 

about fatty alcohols. It's not about tobacco, 

just like it is for any material.

 MR. McREYNOLDS: Yes, yes.

 MR. ELA: So I think that's where he's 

getting at.

 MR. McREYNOLDS: Okay. I apologize.

 MR. ELA: One thing I wanted to ask 

some follow-up on from the webinar, and I don't 

know if you can speak to it, is one of the 

presenters noted that their insect problems went 

down using fatty alcohols versus hand sucking, 

and it was because they understand the aphids 

tend to be attracted to the suckers, and if 

they're removed then you don't have to spray or 

do you have aphid issues?

 MR. McREYNOLDS: I believe that it's 

not that -- it's the topping of the plants that 

reduces the aphid issues, because there's no 

flower to attract them, and regardless of whether 

you do it top, by hand or with a material, that's 

still the effect. It's then it forces -- the 

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topping is what forces the sucker growth, and 

that therefore that makes the necessity of 

suckering.

 MR. ELA: But the aphids were 

attracted to the sucker as I understood. So if 

you didn't have suckers, then you didn't have as 

many aphid problems?

 MR. McREYNOLDS: I believe yes, that's 

correct.

 MR. ELA: Okay. I just wanted, 

because I think that deals a little bit with it's 

not just economics. It actually does help reduce 

the potential of another insect.

 CHAIR BEHAR: Dave.

 MR. MORTENSEN: Yeah. Roland, I also 

wanted to just say thank you to you and the many 

others that have spoken and to the farmers, 

because I'll tell you. The last time we looked 

at this, we had very, very little input from 

farmers, and the idea as we were saying before 

about efficacy and need is definitely part of 

something that we're all thinking about when 

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we're looking at these things. So the case is 

made in a much more compelling way this go-round.

 MR. McREYNOLDS: I appreciate that. 

Certainly, it's been -- the farmers that we work 

with have been very responsive to this, to this 

risk that they're facing, for sure.

 CHAIR BEHAR: And I guess I would just 

say too that it was very compelling on the 

webinar to hear about the need for it in a crop 

rotation, and in Wisconsin we also have a tobacco 

culture and understand that that is a very high 

value crop in rotation, and whether you like 

tobacco or not, it is a legal crop to grow in the 

United States. And that's it. Okay, thank you 

Roland. Next.

 MR. McREYNOLDS: Thank you all very 

much.

 CHAIR BEHAR: Next up is Cathleen 

McCluskey, with Alan Lewis on deck.

 MS. McCLUSKEY: Good afternoon. My 

name is Cathleen McCluskey, and I am the 

Communications and Outreach Associate for Organic 

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Seed Alliance. We're a mission-driven 

organization that works nationally through 

research, education and advocacy to ensure 

organic farmers have the seed they need.

 My comments will touch on the Crop 

Subcommittee proposal to strengthen the organic 

seed guidance. OSA supports the Subcommittee's 

revised proposal, and we are pleased to see past 

public comments incorporated into the most recent 

version. 

 The Subcommittee has put forth four 

years of hard work into this document, and we're 

grateful for the progress demonstrated in the 

latest version. In our written comments, we 

provide additional suggestions for the 

Subcommittee and NOP to consider, as you finalize 

and implement these final recommendations.

 Improving the sourcing of organic seed 

will have far-reaching impacts far beyond helping 

organic growers meet a regulatory requirement. 

More consistent enforcement and more sourcing of 

organic seed will lead to more investments in 

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organic plant breeding and seed production, and 

ultimately more high quality varieties available 

for organic farmers to choose from.

 We believe it's imperative to the 

success of organic farmers that they have many 

options of high quality seeds and cultivars bred 

for organic systems. In particular, we 

appreciate that in this proposal the Subcommittee 

has emphasized the quality of seed searches, the 

need to encourage timely seed ordering, and the 

importance of demonstrating measurable increases 

in organic seed use over time.

 We also appreciate the additional 

language that clarifies what constitutes a noncompliance, in addition to the language that 

clarifies the role variety trials can play in 

identifying equivalent organic varieties, given 

the enormous value the trials and the resulting 

data provides growers.

 We also support the language that 

calls for growers to engage their current nonorganic suppliers in dialogue about their desire 

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to purchase equivalent organic varieties or 

cultivars. We see this recommendation as helping 

demonstrate the market demand for organic 

varieties and cultivars to seed suppliers.

 Further, the documentation of these 

requests may serve useful to encourage both nonorganic and organic suppliers to invest in 

organic breeding and production to serve the need 

of organic producers. We hope to see the NOSB 

pass this proposal at this meeting, and encourage 

the NOP to swiftly implement these 

recommendations.

 This improved guidance complements the 

seed regulatory language approved by the NOSB 

last year, which will require demonstrated 

improvement in sourcing organic seed and planting 

stocks on an annual basis. Together, these 

actions represent a milestone.

 We view this evolution in organic seed 

policy as a significant step towards a future 

where the integrity of the organic label is 

stronger because the critical first link in the 

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organic production chain, the seed the farmers 

plant, is also consistently organic. Thank you 

very much for your time and for your service.

 CHAIR BEHAR: Any questions? Thank 

you. We did work hard on it, so thank you for 

noticing.

 MS. McCLUSKEY: Yes, thank you.

 CHAIR BEHAR: Okay. Alan Lewis up 

next. Please state your name and affiliation 

with Zea Sonnabend on tap, on deck.

 MR. LEWIS: Thank you Harriet and 

Jenny and Board members. Alan Lewis, Natural 

Grocers. We're up to 150-some stores, 19 states 

west of the Mississippi, and as a starting point 

we still only sell certified organic produce. 

I'm here again talking yet again about 

hydroponics, because there's housekeeping to be 

done. 

 We don't have labeled hydroponics. So 

it's coming in on the trucks and we don't know 

whether it's hydroponic, grown in water, whether 

it's actual -- excuse me, but actual certified 

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organic grown in soil. You have to imagine that 

it's 5:30 in the morning. You're 18 years old, 

you're a little hung over, and you're pulling 500 

cases off.

 We already have huge problems knowing 

whether it's really certified organic or not due 

to unlabeled cases and missing logos and bad 

invoicing. So we don't know what to tell our 

people. So I'm going to make a proposal here 

today, which is that there are three triggers, 

potential triggers.

 Are the items in that case potentially 

hydroponic items, things like berries, tomatoes, 

peppers. Are they with brands that are known to 

be grown without soil, and the last trigger would 

be a certifier known to certify hydroponics. 

Somehow in there, you have a trigger so I can 

tell that young man or woman at 5:30 in the 

morning if you see these, then a placard goes on 

them in the store and it says may be grown 

without soil, because consumer trust and 

transparency remains critical. 

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 And in the hydroponic world, not only 

is it unlabeled and undisclosed, but their 

practices and inputs are largely trade secrets. 

So it's really incumbent on the retail industry 

to be a last line of defense here, to make sure 

customers maintain their confidence.

 Now customers are going to see the 

placard, and they're going to have questions. So 

a bit tongue in cheek, let me give you five 

things that the organic or the hydroponic 

industry presented over the last five years as 

reasons to promote hydroponic.

 One, improve the appearance and lower 

our dependence on an environment by not having 

soil, insects, wildlife, bugs, rain, sun or wind 

or snow. Two, school the organic Luddites who 

fear new technologies. Three, reduce the number 

of inefficient small holder soil-based farms. 

Four, avoid the dark arts and black magic, quoteunquote of soil biology, and lastly, keep food 

away from dangerous soil microbes.

 It leaves me a little bit speechless. 

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I think we will help the hydroponic people work 

on their messaging before we take those five 

points to our consumers. But in all seriousness, 

we have housekeeping to do because hydroponic 

needs to be labeled if the organic seal is to 

incorporate it and maintain the confidence of 

consumers in the seal.

 Give them the choice, give them fully 

informed choice. I yield the rest of my 12 

seconds. Thank you.

 (Laughter.) 

 (Applause.)

 CHAIR BEHAR: Thank you, Alan. 

Questions from the Board? I have one. How do 

you know that your consumers don't want 

hydroponic organic?

 MR. LEWIS: Harriet, I don't know. I 

don't assume, but I do know that some would 

clearly not choose it if they had a choice. 

 CHAIR BEHAR: Dan.

 DR. SEITZ: This is actually a 

question for the program. When we were 

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discussing hydroponics previously, the question 

came up of -- the mic's on, or at least there's a 

green light.

 FEMALE PARTICIPANT: I can hear you.

 DR. SEITZ: Okay. Maybe I'm not 

directional enough. When we were discussing 

hydroponics previously, the question came up 

about whether you could have a supplement label 

that would identify a product as organic and 

hydroponic.

 I never understood if that's something 

that is allowable under the organic law and 

regulations. Is it something that's not 

addressed at all? I just was wondering about the 

feasibility about that, if it ever seemed like a 

prudent idea from the standpoint of transparency 

and consumer knowledge.

 DR. TUCKER: Okay, thanks for the 

question. We support opt-in labeling as long as 

the labeling is truthful. So for example, there 

are a number of wrap-around we'll call them 

labels, that could be considered, for example, 

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organic something. As long as the organic claim 

is truthful, that the operation is certified.

 So somebody could advertise themselves 

as certified organic hydroponic or certified 

organic soil-based. But we support opt-in 

labeling to help people differentiate their 

product through truthful statements about it.

 DR. SEITZ: Sure, and just from a 

theoretical -- 

 DR. TUCKER: We don't do 

hypotheticals.

 DR. SEITZ: We don't do theoretical 

questions, but rather a legal question. 

 (Laughter.)

 DR. SEITZ: I understand that you 

might prefer a opt-in label, but could just --

could a segment of the organic industry be 

required to have an extra descriptor?

 DR. TUCKER: So to require somebody to 

put on a label, so non-optional, would require a 

change in the regulations. So that would be --

in all seriousness, that would require regulatory 

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change to impose that label on someone. Yeah, 

that's why we support opt-in labeling. It's much 

more positive, yeah.

 CHAIR BEHAR: Anyone else? Thank you, 

Alan.

 MR. LEWIS: Thank you.

 CHAIR BEHAR: Oh there was? I'm 

sorry, Tom.

 MR. CHAPMAN: Hey Alan. So I'm 

looking at your comments from the Jacksonville 

meeting, and you were asked questions directly 

about supporting an organic hydroponic label at 

that time, and you stated quite clearly no, you 

don't support it. What's changed? Why do you 

support it now?

 MR. LEWIS: What's changed? About I 

think two years ago, Sonny Perdue, our Secretary 

of Agriculture, stated unequivocally that 

hydroponics could be, could use the organic seal 

that you see on the screen. So we as a retailer 

that only sells certified organic, and the 

structure coming in from Albert's, organically 

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grown and the hydroponic is undisclosed, we don't 

have a choice right now, and neither do our 

consumers.

 So it was never being against 

hydroponic. It was this confusion that's now 

created between vastly different scales, 

different economies and different practices and 

different inputs, that have created really two 

brands under one seal. 

 CHAIR BEHAR: Thank you. 

 MR. LEWIS: Thank you.

 CHAIR BEHAR: Zea Sonnabend is next 

with --

 MR. BRADMAN: Harriet, I just have a 

quick comment.

 CHAIR BEHAR: Okay.

 MR. BRADMAN: Sorry. I just want to 

say I agree. There needs to be some resolution 

to this issue, and I think labeling is one 

approach that we should consider, and also 

developing concrete standards that address the 

different production systems. I hope that's a 

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discussion that as a community we can have and 

move forward on.

 MR. MORTENSEN: And I enthusiastically 

feel the same way about that.

 CHAIR BEHAR: Okay. We're going to 

move ahead. Oh, you want to say something else.

 MR. LEWIS: Can I go?

 CHAIR BEHAR: Yes, you are excused. 

 (Laughter.)

 MR. LEWIS: Thank you.

 CHAIR BEHAR: Zea Sonnabend with Phil 

LaRocca on deck.

 MS. SONNABEND: Good afternoon 

everybody. Zea Sonnabend from Fruitilicious Farm 

and CCOF, and a former NOSB member. I'm going to 

speak today about excluded methods, genetic, 

whatever you call it for seed planted in organic 

ground and the seed guidance.

 Starting with the seed guidance, we're 

very happy to see that this is going to move 

forward as something that I initiated when I was 

on the Board and now it looks like it's reaching 

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its summation, and we do recommend passage at 

this meeting.

 In our written comments, CCOF proposed 

a few little wording tweaks, including especially 

the planting stock language about the vegetative 

harvest of parts of planting stock, which 

shouldn't be a substantive change and you should 

be able to do. 

 We also pointed out that doing your 

own variety trials is not the only way to access 

variety trial information. You can go to Field 

Days, you can talk to your farm advisor. You can 

go to your neighbors. It's not just your own 

variety trials as a variety trial sufficiency, 

but these are very small things that we hope you 

don't let this hang you up from passing the 

document.

 On the excluded methods terminology in 

general, this is also something we initiated from 

the Board and we realize that this what -- we did 

all the things that were very clear at the 

outset, and the things that are left are very 

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complicated and confusing.

 So we do urge you to take your time, 

and I'm sure, I did not read all the public 

comments this time, but I'm sure you got quite a 

few with an unclear message about the docket, you 

know, what you've proposed so far as far as the 

embryos and mutagenesis. I just urge you to take 

your time to work through all the issues, but 

keep working on it because it is very important 

work.

 On the genetic integrity of seed grown 

in organic, this was very unclear what the goal 

of this was as stated in the document, and it's 

become a little more clear from talking to 

people. But I see that it needs to be reworked 

to state what a clear goal is.

 In general, we agree with a lot of 

Kiki's comments, although we do think a pilot 

program could work if only to see how many 

entities would voluntarily disclose on a seed 

bag, because we do think that disclosing on a 

seed bag is an end goal that we should look 

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towards, because that's the only way we're going 

to be able to stop things from becoming more 

contaminated if we can finally get to the point 

where we know what we're starting with for 

contamination.

 So an absolute requirement at the 

beginning isn't necessary, and I don't know the 

logistics of how you'll get there. This is why 

we wanted to have a seed purity task force, so 

that people with more expertise could hammer out 

these details of how you could conduct such a 

pilot program. So thank you very much

 CHAIR BEHAR: Questions? Sue.

 MS. BAIRD: Thank you, Zea. My 

question for you is, if we implemented a pilot 

program and we would require the organic seed 

companies to disclose on their seed label the 

genetic materials within it, at least in the midwest, many of our grain farmers do not choose 

because of contracts or because of just climate 

differences, to use organic seed.

 So how would the fact that we have no 

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control over non-organic seed companies, if we're 

going to require --

 MS. SONNABEND: Well --

 MS. BAIRD: -- organic seed companies 

to have this --

 MS. SONNABEND: But see, I'm not, if 

you're talking about a pilot project, I'm not 

talking about requiring necessary right at the 

outset. But why don't you see, why don't you put 

it out there and say, well, let's have this pilot 

program.

 The only thing you're required to do 

is ask if your company will disclose it. Organic 

or not organic seed, the farmer only has to ask.

 So if you ask, there's no harm in 

that. If they say no, you're not penalized. And 

if they say yes, you get the information.

 And along with asking, the farmer 

would then have the choice to either plant that 

seed or not, or to perform their own testing at 

their own expense or not. And they just would 

tell you, they could tell the inspector or the 

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certifier that they did that.

 So then you could at least get some 

information about how many are willing to do that 

and how many aren't. Because right now, you 

don't even know what the universe is.

 And we, by no means, want to jump 

right into everyone has to do this. And we don't 

want to restrict the amount of varieties that 

growers have. I mean, that's very, very clear, 

because genetic diversity is paramount in keeping 

our germplasm good.

 But at least you could have a pilot 

that you saw what was going on out there, 

somewhat.

 CHAIR BEHAR: Dave.

 MR. MORTENSEN: I think we are all in 

agreement that we want to get somewhere with 

this. And I think that's what you're saying, 

Zea.

 I mean, we've had genetically modified 

corn since 1998. And our poor organic farmers 

are living in a matrix of 90 plus percent GM corn 

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grown around them.

 MS. SONNABEND: Yes.

 MR. MORTENSEN: The longer we put this 

off, I think the longer it is that we just 

continue to scratch our head and wonder where are 

we with this.

 MS. SONNABEND: Right.

 MR. MORTENSEN: So, the Board is 

feeling a sense of urgency that we get on with 

it. And I know you, and others, Kiki and others, 

agree with that.

 It's, like I said, a question of how 

we get there. But I think some of the 

suggestions have been very helpful.

 MS. SONNABEND: Yes. I mean, it's 

similar to right now, you're required to use 

organic seed. And if you can't get organic seed, 

you're at least required to ask if they have 

organic seed.

 So you can ask for a disclosure of 

genetic content and see if you get it. Like some 

people have said, some companies have the 

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information, and some will disclose it. 

Especially if, it's not like they have to 

disclose it to the public.

 You'd be disclosing it in confidence 

to your inspector and it might go into your 

report, but it doesn't have to be public 

information necessarily.

 CHAIR BEHAR: Sue, and then that will 

be the last person.

 MS. BAIRD: Yes. Could it perhaps be 

crafted such as commercial availability that 

handlers do, they don't, or especially pesticide, 

herbicidal people, they don't want to discuss or 

disclose their formulation, but they will to the 

certifier because it's protected. Maybe we can 

do that same kind of thing with the genetic.

 MS. SONNABEND: Yes. It's the same 

thing, if I'm not, don't grow vegetables but if I 

do and I have the best tomato, I don't want 

everyone else to know what variety I'm using.

 So I'll tell the inspector what 

variety I'm using, but I don't want that in, to 

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the public. And it's really no different than 

any amount of confidential information you tell 

your certifier, which is really quite a bit.

 CHAIR BEHAR: Just for clarification. 

It was never considered to be public, the 

information for the data collection, it was going 

to be anonymous. It wouldn't have --

 MS. SONNABEND: Yes. The thing is --

 CHAIR BEHAR: -- tied to a seed 

company, tied to a grower.

 MS. SONNABEND: Right.

 CHAIR BEHAR: Anything like that.

 MS. SONNABEND: But the seed companies 

still have to be reassured of that. And the 

growers too.

 CHAIR BEHAR: Right.

 MS. SONNABEND: So yes.

 CHAIR BEHAR: Right. But that was 

what --

 MS. SONNABEND: I know.

 CHAIR BEHAR: -- the idea behind it, 

was not to have it be a list of this variety, 

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this lot was, had this --

 MS. SONNABEND: Right.

 CHAIR BEHAR: -- not available. Okay, 

anybody else? Thank you, Zea.

 MS. SONNABEND: Thank you.

 CHAIR BEHAR: Phil is next. And don't 

get yourself an animal there, Phil, he's sitting 

with the wrong chair.

 MR. LAROCCA: I don't want animals 

already.

 (Laughter.)

 MR. LAROCCA: Thank you.

 CHAIR BEHAR: And Peter Nell is on 

deck.

 MR. LAROCCA: Good afternoon. Phil 

LaRocca, I'm the owner of LaRocca Vineyards. I'm 

also the chairman of the board for CCOF and I'm 

proud to say that this is my 45th year as an 

organic farmer.

 And I had totally different thoughts 

to express to this Board till about ten days ago, 

when I saw emails coming in saying that it was 

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okay for a container grower to herbicide his 

ground, put a piece of plastic on top of it and 

then grow inside a container. I got to be honest 

with you, I was actually shocked.

 I've been around this industry, like 

I said, for 45, I was certified back in '75. So, 

I had a conference call scheduled with our 

executive director and sure enough, she confirmed 

that the NOP does accept this. This is wrong. 

I'm sorry, but it's wrong.

 I know yesterday at the NOC meeting, 

the argument from the NOP was that it does not 

make contact with the food. Well, I've had three 

different ranches over the past and one of them I 

leased.

 And I had a, my landlord hated weeds. 

And this guy begged me to spray the roads. No 

way in hell would I allow any of my fruit to 

touch the road, but I had that entire property 

certified, as most growers do.

 So, to see this exemption here is just 

beyond me. This is, the whole system should be 

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certified organic.

 I'm sorry, having a piece of plastic 

in between, you take that plastic off, there's 

going to be residue of glyphosate for years down 

the road.

 Which also, let's address, somebody 

brought up here earlier the idea of the plastic. 

So if you're a row crop grower, even a fruit 

grower, strawberries for example, that uses 

plastic mulch, you have standards in the rule 

that you have to follow. These people don't.

 What are we doing with all this 

plastic? We talk about climate change, that's a 

problem. But also, our landfills are just 

filling up. We have plastic up the gazoo.

 So this is just a little side note, 

you know. From being over the years when I was 

heavily involved in certification, I used to see 

this and it would fry me.

 For example, rice farmers. If 

conventional rice tanked and organic rice was 

high, you would get a grower come in and he would 

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put so many herbicides on that field to hold him 

for the three years, go in, and after the three 

year period, which was great, we at least had 

three years of no contamination to the earth, but 

as soon as that price changed, this goes back to 

your introduction here, which was quite eloquent 

and passionate, I thank you for that, they were 

gone.

 So, let's certify the whole process. 

The whole property, just as every other organic 

farmer has to do. And let's put some standards 

on what they're doing with that plastic. Thank 

you.

 (Applause.)

 CHAIR BEHAR: Thank you, Phil. Any 

comments from the Board, questions? Emily.

 MS. OAKLEY: I guess you're not 

surprised that I heartedly agree with you. I did 

just want to confirm that I heard what you just 

said right.

 You said that you spoke with CCOF's 

executive director and that they confirmed that 

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the NOP accepts --

 MR. LAROCCA: That's what --

 MS. OAKLEY: -- this practice?

 MR. LAROCCA: Yes. And I believe 

Jenny agreed to that yesterday.

 MS. OAKLEY: Could I ask Jenny to 

comment on that?

 DR. TUCKER: Yes. I would say again 

that my comments at the time have been taken out 

of context. It was a hypothetical in a meeting.

 I asked several times for the name of 

the operation. This has not been a program 

decision, it is not a policy, it has not been a 

decision about any particular farm.

 So, we are doing data gathering --

 MR. LAROCCA: No, no, no.

 DR. TUCKER: -- we need to go back. 

But NOP has not made any kind of policy statement 

to this effect.

 MR. LAROCCA: I'm sorry, then I 

misunderstood you. Yesterday I think you said, 

if there was no contact with the product that was 

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growing and therefore it was okay. Maybe I 

misunderstood you. If I did, I apologize.

 DR. TUCKER: So when I was talking 

about the hypothetical --

 MR. LAROCCA: No, this wasn't the 

hypothetical, this was yesterday at the NOC 

meeting, Jenny.

 DR. TUCKER: Okay, I think I, at the 

NOC meeting yesterday I said that we had not made 

a program decision on this. I said there were a 

number of policy questions. But I wasn't 

answering any of those policy questions.

 MR. LAROCCA: Okay.

 DR. TUCKER: So, there were a number 

of policy questions related to land use 

histories, related to methods of separating 

organic from non-organic. I mean, there are 

split operations.

 The same kinds of questions come up of 

how do you separate out of complete parcels apart 

at an organic farm.

 In this case, there are questions 

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about the land use histories and what certifiers 

are expected to do. And what 205.202 really 

speaks to, related to land management.

 Again, I shared a number of questions 

yesterday. There has not been any policy 

decision here or any determination on a 

particular farm.

 I made the mistake of speculating 

during a meeting on potential legal 

hypotheticals, and I will not do that again.

 MR. LAROCCA: Okay. Well, this is a 

direct question. You're saying there is no rule 

that says you can or cannot glyphosate and then 

put plastic and then grow on it?

 DR. TUCKER: I said, we're gathering 

information about what is going on out in the 

world.

 MR. LAROCCA: Okay.

 DR. TUCKER: You cannot apply, 

glyphosate is not allowed in organic production -

-

 MR. LAROCCA: I understand that. 

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 DR. TUCKER: -- period.

 MR. LAROCCA: And that's why I came up 

here to speak.

 DR. TUCKER: Yes. Glyphosate is not 

allowed in organic production, and I will keep on 

saying it.

 MR. LAROCCA: What if there's a piece 

of plastic between it?

 DR. TUCKER: I'm not going to engage 

in hypotheticals.

 MR. LAROCCA: Okay.

 CHAIR BEHAR: Okay, so we are on to --

 MR. LAROCCA: Thank you.

 CHAIR BEHAR: Thank you, Phil. You 

sure you don't want to take a lobster or 

something over there.

 Peter Nell, please state your name and 

affiliation, and Tom Harding is on deck.

 MR. NELL: As a tall person, Dave, am 

I okay with the volume? Okay.

 So, hello, my name is Peter Nell, I 

work for CCOF. Today I'm commenting on the 

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materials subcommittee's discussion document on 

marine materials.

 First, I would like to praise NOSB for 

the well written and thoughtful discussion 

document. The discussion document addresses many 

concerns posed by organic stakeholders. It also 

further explains NOSB's thoughts behind ideas of 

requiring certification of marine materials used 

in organic crop production inputs.

 I would also like to express 

appreciation to the NOSB for considering the 

impacts of nonsynthetic inputs. These substances 

are not given the same attention synthetic 

substances are through the sunset review process.

 However, CCOF does not support 

requiring organic certification under the wild 

crop standards, for marine materials used in 

organic crop production.

 I'd like to also say though, we do 

support NOSB's continued work on this. We 

support convening an expert panel at the fall 

meeting, like what was proposed. 

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 We would also recommend that NOSB form 

a taskforce or a working group of some sort, with 

diverse experts in these fields, to determine 

which species of marine algae are most at risk 

and prohibit those specific species from use in 

organic crop production.

 Those experts should work closely with 

NOSB throughout the development of any and all 

proposals and recommendations on this topic.

 Importantly, NOSB should also consider 

the precedent it may set regarding organic 

certification of marine materials. Other 

nonsynthetic inputs used in organic crop 

production, such as peat moss or mine minerals, 

also have negative environmental impacts.

 Should NOSB recommend certification of 

marine algae, a lengthy phase-in period will be 

required. This phase-in period should account 

for the impacts to organic crop producers, 

organic crop input manufacturers, marine algae 

harvesters and NOP and all of you guys, in 

developing and refining this complex guidance, 

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instruction or what have you.

 I'm happy to ask, or answer any 

questions. Hopefully not ask any. Thank you so 

much.

 MR. ELA: Questions for Peter? Emily.

 MS. OAKLEY: Surprise. Okay, so thank 

you so much for speaking on marine materials. 

And I have a question for you and then a question 

for the program. Or I guess a comment for you.

 MR. NELL: Sure.

 MS. OAKLEY: A lot of people have 

expressed concern about the potential for a 

precedent setting that this might create, and I 

tried to address some of that in the discussion 

document in terms of this being a unique 

situation where we're harvesting an organism from 

a wild native ecosystem, a native organism from a 

wild native ecosystem. In this case a plant.

 And I was discussing this with a 

fellow Board Member earlier, maybe another 

analogy might be, if we culled and harvested deer 

for bone meal or for blood meal, which is, I mean 

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obviously, kind of an exaggerated example, but 

can you see or would you agree that there might 

be a uniqueness in this situation that might not 

be the same for other naturals?

 Although I do agree with you that they 

deserve more examination to make sure that 

they're meeting that OFPA criteria, but that this 

doesn't at all lead to a statement that all 

naturals should be required to be certified 

organic or that that's the correct approach for 

addressing environmental issues in every case?

 MR. NELL: Yes.

 MS. OAKLEY: Is that too long of a 

question?

 MR. NELL: No. No, I think it was a 

great question. And I want to really commend 

your work on this, Emily.

 I think, I think you wrote the 

discussion document and I think you did a really 

great job addressing a lot of the concerns that 

people have, including the CCOF.

 You're right that this is a unique 

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situation. And for that reason, we would love 

for you guys to continue to work on it. I think 

if you can build a really solid case then 

obviously it makes sense.

 Especially given that crop inputs for 

livestock, you know, there is reasons why it does 

make sense. So, yes, sure.

 MS. OAKLEY: So, could I just ask this 

question of the program, just because that will 

help the many other commenters who did provide 

written comments about a taskforce, which I found 

really interesting that that came up by over half 

a dozen people on their own, it was not in the 

discussion document.

 So, just a question. If the taskforce 

is something that the program would see as 

feasible for this, following an expert panel in 

the fall?

 DR. TUCKER: I think we're interested 

in learning what happens in an expert panel, and 

we'll take it from there.

 MR. NELL: Us too. 

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 CHAIR BEHAR: Okay, anyone else?

 MR. BRADMAN: Just a quick comment. 

I think it's really important that you brought 

this up about peat moss and other materials, and 

really all inputs that have an impact on the 

environment, we should consider.

 I mean, one relevant to this of course 

is the liquid fish products and whether wild fish 

are being harvested exclusively to transfer 

nutrients onto land to grow food. I think peat 

moss is a good example of something that we 

should evaluate.

 And marine materials is particularly 

complex. We have issues of climate change. We 

don't even know if the current science would be 

meaningful about what's going forward.

 And this could be a situation where we 

may want to basically even take any use of this 

material out of an agricultural system just 

because we don't know what the impacts are in the 

environment.

 So, I just want to reiterate, I think 

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these are really important issues. And with the 

changing world, we have to think carefully about 

how we move ahead with them.

 MR. NELL: Yes, if I can respond, I 

think you put it really well, Asa. In our 

spring, sorry, this is spring, in our fall 

comment, we included a little brief section that 

talked about how we should, you all should 

consider whether all ocean-based inputs should be 

moving towards a third-party verification system.

 So that would include those liquid 

fish-based, fish meal, things like that. I think 

that's an important aspect that could also be 

included in a further examination, through a 

taskforce, working in conjunction with NOSB 

members.

 CHAIR BEHAR: Okay, moving forward. 

It's okay? Tom Harding is next. Thank you, 

Peter. And Tony Schilter is on deck. And just a 

time check, we're about a half hour behind.

 MR. HARDING: Good afternoon. I want 

to thank the Board and the NOP for your 

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continuous good work.

 I represent the Green Ag Supply, the 

petitioner of fatty alcohols for the use in 

organic tobacco production.

 Recently we supported and submitted to 

the NOP, and it has been moved forward, a revised 

petition based on the input we received from the 

NOSB. Including having major data supporting the 

alternative, meaning fatty alcohols against the 

alternatives that were recommended.

 It's really important to us that we 

move forward with the idea that fatty alcohols 

are very important. It's not just about 

essentialities, it's also about the health and 

welfare of the workers and the green tobacco 

disease, a number of other things that happen 

within that system. It's also the most 

environmental choice.

 So, I want to mention just briefly, 

some important things. Plant sucker control is 

essential to the organic tobacco production and 

leaf quality, and there is no acceptable 

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alternatives.

 Without the availability of fatty 

alcohols, organic tobacco will not be a viable 

crop for century-old family farmers and will lose 

all organic cash crops within that rotation.

 Loss of fatty alcohols will cause a 

huge economic, huge economic damage to the 

organic family farmers, estimated, just in our 

region, around $23 million. That doesn't include 

all the way to Tennessee.

 When this revised petition comes 

before the crops subcommittee, and subsequently 

the NOP, we hope that you will not only ask us 

for any further questions but consider that it's 

not just about essentialities, it's about health 

and welfare.

 We are asking you to revise, to read 

our revised petition thoroughly, to incorporate 

all of the data that we have supported. We are 

passing around my comments, along with the data 

from North Carolina State University, supporting 

the research done, and the trials that were done 

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specifically for alternative materials based on 

the NOP.

 We are available at any time to answer 

any of your questions. You've heard some of our 

farmers on the webinars.

 I think we've been very clear, it's 

not a material that we can choose otherwise, it's 

a material that has been very beneficial to 

family farms, to the quality. Which raises by --

and not only the economic benefits, but the whole 

health and welfare of the system. And has huge 

environmental impact that's positive.

 We encourage you to move forward with 

this. We hope that if there are any questions 

that come up, that you in fact will ask us. And 

we plan to have our growers very active when this 

material comes forward for a final vote.

 I thank you very much, continue the 

good work.

 CHAIR BEHAR: Any comments, questions?

 MR. BRADMAN: I have a comment and 

question. 

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 CHAIR BEHAR: Asa.

 MR. BRADMAN: Can you clarify your use 

of the words, health and welfare?

 MR. HARDING: Yes. When suckering and 

topping happens in tobacco, when you do it by 

hand, what happens is workers have to go in 

there, they're exposed to that tobacco leaf.

 They have to top, and they will be 

touched, and then they apply, in a very old 

fashioned way, versus using boon sprayers and 

things like that. So it does have a health and 

welfare benefit.

 There's a safety issue involved. But 

it's been going on for centuries. This material 

has helped us to prevent that from occurring, and 

no longer will that practice, has that practice 

been used, where we're allowed to use fatty 

alcohols.

 MR. BRADMAN: Okay, so you're using 

that in the context of occupational exposures to 

the poison, essentially, that's produced by the 

tobacco? 

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 MR. HARDING: Correct.

 MR. BRADMAN: Okay. Not more broadly?

 MR. HARDING: Pardon me?

 MR. BRADMAN: Not more broadly? I 

mean --

 MR. HARDING: No.

 MR. BRADMAN: Thank you.

 CHAIR BEHAR: Emily.

 MS. OAKLEY: This may not be for you, 

but I didn't want to belabor it with Mr. 

McReynolds.

 It sounded like he was saying that 

there have been some growers who have been using 

this material already for a number of years, 

maybe up to seven or more.

 Do you know the process by which it 

happened that they were using a material and then 

it became petitioned after such a long history of 

use?

 MR. HARDING: There was a request to 

certifiers, three of them in fact, and they 

approved the material based on the fact that it 

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has been classified for decades as a natural 

fatty alcohol. When it was reviewed, they came 

back and said, well, it just crosses the border 

in the esterification process that in fact it is 

a synthetic material.

 Subsequently, we then prepared to 

petition. And we went forward with the first 

petition.

 But it has been used and it will 

continue to be used until we're told not to. 

Although we have advice and we've asked for a 

continuance this year.

 And we hope if this petition is 

approved, that we will continue to use it through 

that process. And the benefits far exceed 

anything with that.

 Now we've had a discussion with all of 

those certifiers, and we're still looking for 

alternatives. We've found nothing, Emily.

 CHAIR BEHAR: I have a question.

 MR. HARDING: Sure.

 CHAIR BEHAR: Would you prefer we 

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continue discussing this for a few more meetings 

or would you like us to go to a vote in the fall?

 MR. HARDING: Well, let's go forward.

 CHAIR BEHAR: Why would that be 

important to you?

 MR. HARDING: Well, because the next 

season will be in question and that's very 

important to us. So we need to have some 

determination.

 I won't want to add to that. I want 

to go forward, but I want to make sure we have a 

balanced and thorough review and that in fact we 

look at it, not simply as tobacco, but as a crop 

production aid that's very important to the 

family farm.

 So, some people say, well, if it was 

marijuana it would be okay. No, it wouldn't be 

okay. The fact is, it's very important that our 

family farms have a choice, that it's working for 

them and has proven to be beneficial.

 CHAIR BEHAR: Dave.

 MR. MORTENSEN: Tom, how would you say 

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this process has worked for you?

 I personally think that our asking for 

farmer input and efficacy data was a reasonable 

thing, and then you come back and now we've heard 

a great deal more this go-round.

 How has the review process worked for 

you?

 MR. HARDING: Well, obviously, it's 

been very difficult for us. Because, first of 

all, I'm under the impression that certain of the 

questions you asked, and we answered, you did not 

get that information. I can't verify that any 

way, shape, or form.

 The other thing is, is that when we 

asked for the continuance the last time, the 

reasons was, and why you didn't hear from growers 

is because we couldn't get on the public comments 

agenda because we felt in-person testimony was 

really important.

 So, specifically, the processes work. 

I think we've been, we've all benefitted from it. 

It's given you a lot more information to 

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consider.

 You know, fair and balanced is all 

we're asking. And so, I would say, overall it's 

been good for everybody.

 MR. MORTENSEN: All right, thanks.

 MR. HARDING: And I thank you very 

much.

 CHAIR BEHAR: All right, thank you, 

Tom. Next up is Tony Schilter with Ryan 

Mensonides on deck.

 MR. SCHILTER: No, Bert Haugen. We're 

both dairy farmers. He milks 300 cows about 50 

miles south of here, I milk 250, a hundred miles 

south of here. And we both have to go because we 

both have to run farms and we need to be there 

tonight and tomorrow morning.

 He's here to correct me if I say 

something wrong.

 (Laughter.)

 MR. SCHILTER: My story, what happened 

since 2015 we entered a, in 2007 we entered, both 

him and I entered the organic field and we were 

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shipping to Horizon and things went well for a 

while.

 And there was a law implemented in 

2002 called point of origin that I think is being 

highly abused. And it's really making it 

difficult for us to keep farming.

 And how to explain all that would be 

to tell you that with the animals that I calve 

every year, and he calves every year, that calf, 

when it's born, is organic. And there is people, 

farms, that take that calf, sell it to somebody 

else or give it to somebody else and they go into 

the feedlot. And at the time of the third 

trimester, they bring it home and they breed that 

cow. And by the time that cow comes into 

gestation, she is supposedly organic.

 Very, very hard on the person that him 

and I, and a few other people in this room, to 

keep that animal organic is very, very much more 

expensive for me than it is that individual that 

puts them in the feedlot.

 If we don't, due to this we have an 

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oversupply of milk. And personally I, he's 

lucky. He did something four years ago, he left 

Horizon and he went with another company called 

Organic West, and I didn't. And I stayed with 

Horizon.

 And through all this process, Horizon 

is a given name that I'm sure that everybody sees 

it on the grocery shelf. And, geez, I lost my 

train of thought. Three minutes already?

 CHAIR BEHAR: One minute left.

 PARTICIPANT: Two.

 MR. SCHILTER: Oh. They were bought 

out by a company called Danone, and I became a 

number on a board in France. And through all, to 

make a long story short, they cancelled my 

contract last January 1st.

 And I've always been a member of a Coop here in the Pacific Northwest called Darigold. 

There was seven other producers that were in the 

same situation that I was, and through that 

transition and everything, Darigold took it upon 

themselves to start a pool within the pool. And 

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we seven producers belong to that pool.

 And Darigold sells whatever milk, mind 

you we just started January 1st, mind you, they 

sell whatever milk they can organically. And the 

rest will go on the conventional market.

 And if you guys would just implement 

the rule that's in place and have the certifiers 

do what you're supposed to do, in my opinion, it 

would alleviate the surplus we have. And break 

even for me is about $2,300 a hundred weight, I'm 

getting $1,900 right now within that pool. And 

it should be around $27 or $28.

 And I think that if you guys 

implemented that point of origin law that is in 

place, that we would all benefit from it. And 

the exodus of the farmers would stop.

 I'm not, public speaking is not my 

strong suit.

 MR. HAUGEN: But he's better than me.

 (Laughter.)

 CHAIR BEHAR: Okay. Well thank you. 

Thank you for speaking from your heart. 

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 (Applause.)

 MR. SCHILTER: I'll answer questions.

 CHAIR BEHAR: The Board have any 

comments? Dan.

 DR. SEITZ: I just want to thank you 

and say that I think all the Board is concerned 

about producers who don't really produce in 

accordance with the spirit of organic. And we'd 

like to see a level playing field and an up 

leveling of practices.

 MR. SCHILTER: That's all I'm asking.

 DR. SEITZ: So thank you.

 MR. SCHILTER: Level playing field.

 CHAIR BEHAR: Okay, thank you.

 MR. SCHILTER: Okay.

 CHAIR BEHAR: Next up is Ryan 

Mensonides. I hope I'm saying that right. And 

Christie Badger on deck.

 MR. MENSONIDES: Mensonides, you were 

pretty close. That's actually impressive. I'll 

give it to you.

 I have a dairy, my wife and I have a 

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dairy just east of here. I'm just going to read 

you off some statistics. And they're as close as 

they can be since the census of 2016.

 We typically need about a ten percent 

growth within the dairy industry to maintain the 

purchase of milk. Since this rule did not get 

implemented on the origin of livestock, there was 

a massive abuse from this rule.

 And essentially, we have seen about a 

25 to 30 percent growth in cattle, which is 

outpacing our growth in milk sales.

 So here's my numbers, personally. 

I've had a 48 percent loss in equity. I've lost 

about $500,000 in equity in the last two years. 

I've gotten a 33 percent drop in my pay price.

 Last year alone I lost $150,000, which 

equates to three years' worth of profit 

previously. And it's because we have an 

oversupply of milk.

 The only stats that are important to 

me is, I've got 90 vendors that rely on me, one 

of which is my brother. I've got four employees 

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that will lose their job. I've got one disabled 

father that lives on my property, four kids that 

lose a house and a wife that's put up with a 

bunch of crap for seven years for nothing.

 So I'm going to leave you guys with a 

video of, this is what we're losing if you guys 

don't follow through with this rule on origin of 

livestock.

 One dairy of mine, BJ's and Tony's, is 

being replaced a year. There is, one of our 

dairies is equivalent to, the number of cows that 

have come on is equivalent to 140 of our dairies 

a year. It's outpacing and it's because of the 

fraud. Go ahead.

 (Video played.)

 CHAIR BEHAR: All right.

 (Applause.)

 MR. MENSONIDES: Does anyone have any 

questions?

 CHAIR BEHAR: Emily.

 MS. OAKLEY: Just a clarification that 

this Board doesn't have control over whether or 

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not the origin of livestock gets implemented. 

So, wanted to just give the program a chance to 

comment on that.

 DR. TUCKER: So thank you both for 

your comment and for your story. I heard you 

speak yesterday too.

 Origin of livestock, the agency is 

open to that being added to the regulatory 

agenda, which would mean that a rule would move 

forward. We've heard a lot of comments here 

about interest in moving to a final rule, so it 

would be implemented as soon as that rule, with a 

publication of that rule. And we will see if 

that's possible.

 If that's not possible, we will have 

what's called a second proposed rule to get more 

comments from the public, to make sure that that 

final rule incorporates the public's view. So 

thank you for your comment.

 MR. MENSONIDES: Can I add one thing? 

I know my time is up, but if this is going to be 

a one to two to three year process, I'm out of 

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business. I've refinanced twice in the last 

three years, I can't do it again. My equity has 

dropped in half.

 You guys, there has to be a sense of 

urgency. Your boss needs to know this. We're 

going out of business. And I don't have another 

year for this to sit in a committee. I don't.

 And I lose my home if we do. So I 

just want to make sure you guys are aware of 

that. And I appreciate the time. Thank you.

 CHAIR BEHAR: Thank you. Okay, next 

up is Christie Badger with Albert Straus on deck.

 MS. BADGER: My name is Christie 

Badger. I'm here representing NOC.

 I wanted you to know my family lost 

our dairy this year, so this is very hard for me. 

I've changed my comments a bit based on what I 

need people to hear.

 I'll start by saying a public thank 

you to the National Organic Program for 

reinstating the posting of the subcommittee 

notes. And a further thank you for the expanded 

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use of the open docket as a means of 

communication.

 We encourage the continuation and 

expansion of this practice as a way to begin to 

address perpetual delay in published materials 

that create a shortened comment period through 

the publication of discussion documents and 

proposals to the open docket, as they become 

available from subcommittees. A repeated 

request.

 When I opened my comments, I used to 

say that I was excited to be here and excited to 

be a part of this process. And while I still 

feel this way on the whole there are times when 

my resolve to being excited is being tested.

 NOSB work agenda. During the fall 

2018 NOC pre-NOSB meeting I asked the following 

question, stakeholders are feeling pressure to 

agree to documents that they have reservations 

about, out of concern the item will be pulled 

from the work agenda, can you offer any 

reassurance that this isn't the case? 

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 I was in fact reassured that this was 

not the case and told by Dr. Tucker, "I do not 

think that disagreement on a particular item 

would discourage us from putting it on the work 

agenda."

 During the introductory comments 

today, and in the NOC meeting yesterday, we were 

told that the NOSB had the opportunity to discuss 

hydroponics between 2015 and 2017, but it was 

pulled from the agenda due to disagreement within 

the organic community.

 NOP priorities. At yesterday's 

meetings, and again today, we've heard repeatedly 

that the NOP, that the NOP, must work quickly to 

address issues within hydroponic certification. 

This is a program priority. Even without clear 

stakeholder consensus.

 While there is large stakeholder 

agreement that this issue of hydroponics and 

container growing are priority issues, I'd like 

to be clear in my statement that we are not in 

agreement to surrender our voice to the program. 

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 Since 2010 we have been unable to get 

the origin of the livestock rule passed. This is 

not a program priority, despite clear widespread 

stakeholder consensus.

 It is beyond frustrating that 

somewhere along the line the USDA and the 

National Organic Program decided that their 

priorities outweigh the priorities of our 

existing organic farmers.

 CHAIR BEHAR: Comments or questions? 

I want to tell you, Christie, myself, being an 

organic inspector, I understand the emotion 

behind seeing these beautiful farms go out of 

business. Emily.

 MS. OAKLEY: This isn't a question, 

this is just a comment that it is very hard not 

to cry from these stories. And it is very 

frustrating to sit on this Board and feel like 

your hands are tied over very urgent issues and 

having farmers in a serious predicament, as 

someone who sits on the farmer seat.

 It is a very disempowering and very 

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frustrating experience and I echo your 

sentiments.

 MS. BADGER: Thank you.

 CHAIR BEHAR: Thank you, Christie. 

And we have Albert Straus next with Bob McGee on 

deck.

 MR. STRAUS: Hi, my name is Albert 

Straus. I'm founder and CEO of Straus Creamery 

and I have an organic dairy.

 We just celebrated our 25th year and 

I feel we're in a crisis. I feel that family 

farms in our community are disappearing as well 

as our rural communities.

 And I think one thing that Ryan didn't 

say is that farmers don't pay themselves. They 

don't pay themselves to manage their own 

business. And when they lose everything, they 

lose everything.

 And I think that's something that we 

really, we need to point out. There's such a 

disconnect between consumers and the public and 

farmers that we need to really look at how can we 

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work together, educate and really help everybody 

working towards the same conclusion.

 I heard Jenny say that there's, 

something had changed in the origin of livestock 

that, in organic dairy, that we need to 

reevaluate. And I think nothing has changed in 

organic dairy, we're still in the same crisis 

that we've been, and nothing has happened in the 

origin of livestocks.

 Also, as a longtime dairyman, I offer 

to review the dairy compliance training document 

because I feel that there's things that we have 

knowledge, as dairymen, and I want to offer my 

experience and see if there's things that we can 

do to help strengthen the training document.

 So, with the organic integrity at 

risk, I think that retailers and brands need to 

work together to say we're not accepting milk 

from dairies that don't meet the regulations, as 

we interpret them, and keep the organic 

integrity.

 I'm approaching the retailers and 

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brands and see how we can work together to keep 

those out.

 Also, we need to train certifiers to 

kind of be consistent, as well as inspectors, to 

be trained on dairy, but also look at metrics. 

What dairies are reporting as metrics for farms.

 We don't measure crops as, excuse me, 

we don't measure pasture as a crop. I'm doing it 

on my farm by a rising plate meter, and we have 

it all recorded in our computer so we know 

exactly how much dry matters come from each cow.

 We also, dairymen don't, they estimate 

what they're feeding their cows. So the other 70 

percent is an estimate, it's not, I have an 

actual dry matter per day, per cow, that I get, 

which I've testified before.

 So, I think there's opportunities to 

have metrics and measurements that dairymen can 

report that inspectors can verify to and so we 

can work a lot closer together. Thank you.

 CHAIR BEHAR: Any comments? Ashley.

 MS. SWAFFAR: So I got two different 

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questions. First question, you're about the only 

livestock producer that said they don't want 

vaccines available, made from excluded methods. 

Do you know if the vaccinations that you give 

your cattle are in fact not made from excluded 

methods?

 MR. STRAUS: Yes. We have to verify 

with our, the companies that we buy them from 

that they're not made from it and get letters 

from that.

 MS. SWAFFAR: And are any cattle 

vaccinations made from excluded methods, do you 

know?

 MR. STRAUS: I think there are, but I 

can't name anything right now.

 MS. SWAFFAR: Okay. One more 

question. On iodine, we saw a lot of folks say 

that we should do an annotation with NPEs 

restricting iodine made without NPEs. Do you 

have an opinion on that?

 MR. STRAUS: I don't have anything 

right off the top of my head. Thank you. Thank 

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you.

 CHAIR BEHAR: Thank you, Albert.

 MR. STRAUS: Thank you.

 CHAIR BEHAR: I remember 26 years ago, 

when we first met, and I just say that you were 

kind of a star there in the organic dairy world. 

And you've put a lot of effort into having a 

value-added product. And in some ways protect 

your market.

 But there's a lot of farmers that are 

reliant on a buyer who, on a whim, can send them 

packing.

 MR. STRAUS: And I think as has been 

stated, there's a lot of dairymen that have 

called me because they've lost their contracts, 

they're about to, the price is so low that they 

can't even make, they can't make it after the 

pasture season.

 So I've had at least a half dozen 

farmers call me and say desperately they need 

someone to take their milk. And I can't take 

everybody's milk. But thank you. 

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 CHAIR BEHAR: Okay. Next is Bob McGee 

with Jenny Cruse on deck.

 MR. MCGEE: Good afternoon. My name 

is Bob McGee and I'm the president of Straus 

Family Creamery.

 I'm here representing nine family 

farms, and a tenth joining us in July. A younger 

farmer, which we're very excited, is coming 

onboard bringing an idle farm back into 

production.

 First of all, I do want to thank the 

NOSB and the NOP. There are a lot of good things 

that are happening and we shouldn't lose sight of 

that. It is appreciated.

 At the same time, when I asked our 

farmers what's the one thing you would like me to 

convey to the NOSB, and more directly to the NOP, 

not surprisingly it was around pasture standard 

enforcement and the origin of livestock.

 Some of what I'm going to share is 

going to be duplicative, and I apologize for that 

but, Jenny, I think I heard you asked, you wanted 

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to hear more public input about this, so, I'm 

going to fulfill that wish for you.

 One of the things I've heard the last 

two days is a reference to changes in the 

industry that make it necessary to have a second 

origin of livestock rule. I've checked the 

website, I've checked a couple of places, I can't 

find what those changes are.

 You asked us this morning to give you 

feedback if we had a different point of view 

about those changes. If you could communicate 

those to the community, we'll be able to do that, 

but right now it's not clear what you're asking 

us to comment on.

 The idea of starting all over again 

probably means a one, two, three, maybe even four 

year process for a new rule to come forward. 

Changes will happen in the industry, in that time 

span.

 Are we going to hear in 2022 or 2023 

that there are changes in the industry, so we 

again need to go back to rulemaking to find a new 

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rule.

 Finally, as has already been stated, 

many farmers don't have two to three years to 

wait. Some are going to go out of business, 

which will lead to consolidation in the milk 

industry, which is already creating challenges 

for us as a community.

 Others will decide that they're going 

to take advantage of the cost benefits, being 

taken advantage of by other suppliers.

 When we get to that new rule, are we 

going to hear the genie is out of the bottle now, 

and there's no way we can turn back and be unfair 

to those operations?

 I think most of us in this room feel 

pretty confident that we're going to have our 

jobs in the next two to three years. As Albert 

said just a minute ago, we're hearing from 

farmers that aren't sure what's going to happen 

in the next two to three months, after the end of 

the pasture season.

 So what am I asking? I'm asking a 

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greater sense of urgency than has been apparent, 

up until today, to bring forward the 2015 rule. 

The community came together, talked about what 

needed to be changed, collaborated, brought 

together suggestions and then it stopped. Thank 

you.

 CHAIR BEHAR: Questions from the 

Board?

 (Applause.)

 CHAIR BEHAR: Thank you, Bob. 

Questions or comments from the Board?

 Jenny, do you want to have a reply? 

You don't have to. I don't want to put you on 

the spot.

 DR. TUCKER: I'll be more specific. 

A few commenters have asked about, what 

additional data would be needed.

 Again, we will, a key message coming 

back from this meeting for our leadership is the 

strong, strong desire to move directly to a final 

rule. To give, instead of a second proposed rule 

for organic, for the origin of livestock, our, I 

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call to him, our wonderful policy analyst over 

here, Devon, has been sending some data here.

 And so, just to provide some of the 

changes in the industry that we are talking about 

here, according to the NASS data, so that the 

data used in the 2015 proposed rule said there 

were about 1,848 organic dairy farms. The 2016 

data actually indicated that that increased by 38 

percent, up to about 2,560.

 So those are the kinds of data points 

that an organization like Office of Management 

and Budget would look at to say, okay, how has 

the industry changed since the proposed rule.

 It is unusual to go this long between 

a proposed rule and a final rule. It's just 

unusual.

 We will, I commit to going back and 

talking about the possibilities of going to a 

final rule. Changes in the industry, such as 

growth, an increase in the number of organic 

farms, we saw an increase even from 2017-2018 in 

total organic farms, those are numbers that 

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matter to folks over at the Office of Management 

and Budget.

 And so, again, we will take the 

message back. These are decisions that are made 

at sort of an institutional level.

 And I hear the urgency coming from the 

commenters in this room and will communicate that 

back. And thank you to everyone who has 

commented.

 CHAIR BEHAR: Steve.

 MR. ELA: Jenny, just to reiterate 

what you said this morning, I know not everybody 

was here, but you said comments that the industry 

hadn't changed or, I'm going to struggle with the 

words here, should be addressed to you or the 

program?

 I mean, public comments that, to go 

ahead and continue with the rule and that changes 

in the industry aren't substantiated might be 

important, is that correct?

 DR. TUCKER: So, explanations as to 

why it would be appropriate to move ahead to a 

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final rule, rather than a second proposed rule. 

So there is legal risk in moving to a final rule 

after so long after a proposed rule.

 Somebody could say, well, I didn't get 

a chance to give public comment, that was four 

years ago, and look how much the industry has 

grown, I should have had an opportunity to give 

my comments and I didn't get to do that.

 And those kinds of legal challenges 

are something that administration is going to 

take very, very seriously. And I would take very 

seriously because it would prevent a rule from 

being implemented.

 And so, those are the kinds of things 

we have to think about in these kinds of 

questions. So, I think articulating why the 

problems are sort of the same, why the challenges 

in the proposed rule remain the same, reiterating 

the, there was actually a fair amount of 

agreement on the proposed rule, so reiterating 

that people still agree with the same comments 

that they made four years ago, those could help 

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us in making that argument of going to a final 

rule.

 Again, if you send those to me and 

Paul, we're the ones that pull together all the 

documentation to support these proposals. It is 

ultimately not our decision, but we will try and 

shape that as well as we can.

 I would love to go to a final rule, 

believe me. That would be, I would love it. 

There's no resistance from here.

 And, we have to follow, we have to 

follow the rules. We all want us to follow the 

rules. This is a different kind of rule that 

also has to be followed.

 MR. MORTENSEN: Harriet, I just have

 CHAIR BEHAR: Oh, Dave.

 MR. MORTENSEN: I guess the other 

thing that we're hearing, and we heard in the 

webinar and we heard here, and I hear where I am 

in New Hampshire and I was hearing it in 

Pennsylvania before I moved in July, is that the 

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change that's happening, that folks are telling 

us is happening and why it's so much more urgent, 

is the whole structure of dairy is changing as we 

lose small and medium sized farms and we have an 

increase in the number of very, very large 

dairies that are exacerbating the problems.

 So the longer we wait, the lack of 

implementation in the rule is allowing these 

large farms to get larger and is making it more 

and more difficult for the medium and smaller 

sized farms.

 (Applause.)

 CHAIR BEHAR: Okay. So, Michelle 

reminded me that not everyone has an iron bladder 

and maybe we want to, maybe how does the Board 

feel? Would they like to take, I'm seeing some 

yeses.

 But I'm going to keep it to ten 

minutes. And if I'm even here alone I'm going to 

start. Okay, so, Jenny, sorry, we're going to go 

to a break.

 MR. CHAPMAN: Can I ask where we're at 

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in the agenda?

 CHAIR BEHAR: We're about a half hour 

behind.

 MR. CHAPMAN: Okay.

 CHAIR BEHAR: And so Jenny Cruse up 

next with Pryor Garnett on deck. And ten 

minutes, which is 4:25. So, everybody back here 

at 4:25.

 (Whereupon, the above-entitled matter 

went off the record at 4:15 p.m. and resumed at 

4:25 p.m.)

 CHAIR BEHAR: Okay. Please take your 

seats. Okay. We are about a half hour behind. 

So we're staying about the same amount and not 

really catching up. So Jenny Cruse is next with 

Pryor Garnett on deck.

 MS. CRUSE: Good afternoon. I'm Jenny 

Cruse with the Accredited Certifiers Association. 

The ACA represents 58 USDA-accredited 

certification agencies and agencies in the 

process of becoming accredited.

 First, I'd like to address the Crop 

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Subcommittee regarding the proposal for 

strengthening the organic seed guidance. For the 

most part, we really support the proposal as 

written and feel that it lines up nicely with ACA 

best practices that have recently been drafted on 

issues related to organic seed search 

requirements.

 Our members have expressed one main 

concern with the proposal. And that has to do 

with the amendment of NOP guidance 5029 Part 416, 

which says use of non-organic planting stock to 

produce organic crops is subject to commercial 

availability as per 205.204(a)(1).

 If planting stock is from a nonorganic source and is used to produce perennial 

crops, then that planting stock may be sold, 

labeled, or represented as organic planting stock 

or an organic vegetative crop only after 12 

months of organic management.

 205.204(a)(1) says that nonorganically produced, untreated seeds and 

planting stock may be used to produce organic 

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crop when an equivalent organically produced 

variety is not commercially available.

 Some ACA members found the guidance 

revision to clarify 205.204(a)(1), but others 

found that it seemed to be in conflict with the 

standard. So I think a lot of the question has 

to do with the definition of vegetative crop and 

what that means.

 I'd also like to address the Livestock 

Subcommittee on the topic of vaccines from 

excluded methods.

 We appreciate the time that the 

subcommittee has put into the topic. We didn't 

feel like we could support any of the three 

regulatory solutions as discussed without 

gathering more information first.

 Option one, adding individual vaccines 

to the National List is not ideal because of the 

amount of time that would pass as specific 

vaccines were added to the National List and the 

effects on producers in the meanwhile.

 Option two enables a broad allowance 

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of excluded methods in vaccine production, which 

doesn't sit well.

 Then there's option three, which would 

include a commercial availability provision. The 

ACA would likely support this option if 

certifiers can make clear determinations about 

which vaccines have been produced with excluded 

methods.

 Publicly information, publicly 

available resources that have been suggested in 

the past do not seem to provide the information 

that's needed. And historically, certifiers have 

found it difficult to obtain the information 

directly from manufacturers.

 We are renewing some attempts at this 

to see if the information seems to be obtainable 

and plan to report back when the discussion comes 

back around at the proposal stage.

 The main thing is we don't want to 

support a requirement that doesn't end up to be 

possible. So we're glad to have the time to do a 

little bit of ground-truthing first. 

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 Thank you again for your work and for 

the chance to provide comments.

 CHAIR BEHAR: Any comments from the 

Board? I have a quick comment. Can I contact 

you before we go to proposal and see what your 

research has done as far as finding?

 MS. CRUSE: Yes, please do.

 CHAIR BEHAR: Okay. I know where she 

lives.

 (Laughter.)

 CHAIR BEHAR: Okay. Next up is Pryor 

Garnett, and on deck is Aimee Simpson.

 MR. GARNETT: Thank you all for the 

opportunity to provide comments here today. My 

name is Pryor Garnett. And I grow certified 

organic grain on 85 acres in western Oregon.

 These comments are in my individual 

capacity, although I chair the policy committee 

over the Organic Farmers Association.

 I'd like to comment today on 

contributions that organic agriculture can make 

toward mitigating climate change and action 

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needed from the NOSB and the NOP to further 

organic's contributions. And I'd like to thank 

Harriet. I have chosen a polar bear.

 Greenhouse gases in the atmosphere are 

the principal drivers of climate change. And 

reducing new emissions and removing greenhouse 

gases are both necessary to mitigate climate 

change. Organic agriculture uniquely does both 

and can be agriculture's key contribution to 

mitigating climate change.

 Organic reduces greenhouse gas 

emissions by eliminating the use of nitrogen 

fertilizers and other chemicals. Now right there 

it makes a meaningful contribution toward 

mitigating climate change, slowing the emissions.

 Even after accounting for reduced 

yields and increased tillage per acre, organic 

has lower emissions per pound of food produced.

 Instead of nitrogen fertilizers, 

organic ag relies on nutrient cycling with a 

robust soil ecosystem creating lots of organic 

matter, containing lots of organic matter, plant 

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residues created from carbon dioxide removed from 

the atmosphere through photosynthesis. We all 

know this.

 So organic's biggest, bigger 

contribution to mitigating climate change is 

removing CO2 from the atmosphere and sequestering 

its carbon in the soil.

 We know that soils in organic farms 

have 13 percent more organic matter than 

conventional farm's soils. And 1 percent more 

organic matter per acre represents 21 tons of 

carbon dioxide removed from the atmosphere.

 And that's where the NOP and the NOSB 

need to act, because where plants are grown 

without soil there's no carbon sequestration.

 Practices which grow plants separate 

from the underlying soil, hydroponic, aquaponic, 

aeroponic, containers in general, don't sequester 

atmospheric carbon in the soil. And they don't 

foster soil fertility as required by OFPA. They 

may be good, say, no pesticides. But without 

roots in the soil, they are not organic. 

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 Indeed, there's a strong case for 

removing the ponics and containers from 

eligibility for organic certification based on 

their elimination of fertile soils, the loss of 

beneficials in habitat, and problematic disposal 

of containers and fabric.

 Consumers associate the organic label 

with chemical-free produce, natural biological 

processes, and healthy soils, and hopefully soon 

with progress toward mitigating climate change.

 I, therefore, ask the NOSB to 

reiterate its 2010 opinion that hydroponic 

agriculture is not eligible for organic 

certification and to extend that opinion to 

aquaponic, aeroponic, container, and any other 

practice where plant roots are not in the soil.

 And I ask the NOP to impose an 

immediate moratorium on certifying those 

practices as organic. Thank you.

 CHAIR BEHAR: Thank you, Pryor.

 (Applause.)

 CHAIR BEHAR: Do I see any Board 

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comments, questions? Thank you.

 MR. GARNETT: You're welcome.

 CHAIR BEHAR: Okay. Aimee Simpson is 

next with Amanda Fulmer on deck.

 MS. SIMPSON: Thank you for this 

opportunity. My name is Aimee Simpson. I am the 

Director of Product Sustainability with PCC 

Community Markets.

 Retailers occupy a unique space in the 

organic marketplace and community as we are the 

interface between producers and consumers.

 Within the space of retailers, we like 

to think that PCC is unique as well, given that 

we are the largest member-owned food cooperative 

in the country with 66,000 members, 11 stores, 

soon to be 15, and a passionate customer base.

 Just as our customers rely on the 

organic label, so too do we. This is why we are 

a certified organic retailer, ensure that 95 

percent of our produce is organic, and have 

pledged to add 1,000 organic SKUs to our shelves 

by 2022. 

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 We want to see organic grow. But this 

is not to the detriment of the standards and 

consistency that we and our customers rely on.

 As discussed in our written comments, 

there are a number of issues concerning organic 

integrity, some addressed on the Board's agenda, 

but most absent, that need attention.

 First, the NOP must finalize the 

origin of livestock rule. This is not a case 

where the organic community is not asking for 

public comment. We've already provided it.

 The NOP made the improper decision to 

delay rulemaking. And there is no time to waste. 

An already-vetted rule should be finalized at the 

earliest convenience.

 Second, hydroponically-produced crops 

should not be certified organic. Soil matters to 

organic production, now even more so with the 

promising research, as just discussed earlier, 

showing organic farming's potential to combat 

climate change.

 Finally, many of these and other 

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issues seem to stem from a common and overarching 

problem, organic certifiers need to be better 

aligned.

 OFPA was established to bring 

consistency and unification to a patchwork of 

organic standards, labels, and certifications. 

Now consumers and retailers are increasingly 

unsure of what the national label means and are 

left to investigate individual certifier 

standards that are not transparent or easily 

ascertained.

 And this last piece that causes the 

most concern for us, because we must answer to 

our members on these very issues and the many 

issues discussed here today.

 Here is just a sampling of some of the 

questions we receive on a continuing basis. Are 

PCC department buyers aware of the infiltration 

of non-organic feed fed to animals? Why does 

organic butter have natural flavors? Why isn't 

there any organic local honey? And my personal 

favorite, how reliable is the organic label? 

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 Focusing on this last question, how 

would you answer it? PCC continues to believe 

the answer is yes. But the increasing amount of 

exceptions and here is what to look for beyond 

organic not only make our job harder, but raise 

concern.

 Too often we have to note that NOP has 

elected not to address the problem, ignored 

recommendations from this Board, or taken a 

position completely at odds with OFPA. Too often 

we are having to do the work of the NOP in 

creating our own standards to fill the gaps.

 PCC is grateful for this Board's 

incredible investment of time and energy on so 

many of these issues and recognize that much like 

PCC as a retailer you are the interface between 

the public and those responsible for upholding 

the organic standards.

 But just as our customers ask us to 

keep the hard questions, we must ask you to keep 

doing the hard work and pressing for the 

strongest and most consistent standards. Thank 

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you.

 CHAIR BEHAR: Thank you, Aimee.

 (Applause.)

 CHAIR BEHAR: Dan?

 DR. SEITZ: Holding a consumer seat on 

the NOSB and also being a board member of a food 

co-op, I've always taken it for granted that the 

consumer really does equate organic with inground production, partly because any time I've 

ever walked into a grocery store I see pictures 

of farms and I've never seen a picture of an 

industrial hydroponic operation.

 But I -- you just said that that's 

what your, what consumers are expecting. I've 

only had an impressionistic feeling. Is that 

something that you have, you can speak 

confidently about based on any research that 

you've done?

 MS. SIMPSON: Yeah, I mean, it doesn't 

take much research. We get questions daily. I 

mean, literally, these were just three questions 

of the many that we receive. 

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 And we frequently receive comments 

that say we do not support hydroponics being 

labeled organic. We believe that soil should be, 

you know, it matters to organic, that we believe 

in fostering fertility.

 And a lot of this is driven, you know, 

by the science that was just discussed earlier, 

that now there's this great connection between, 

you know, the possibility of organic offering 

solutions to the climate change problem and the 

fact that agriculture has really struggled with 

how to become a part of that conversation.

 And we have a very driven, passionate, 

educated member base who, they're aware of these 

issues. And they not only want to support 

family, independent farms and that concept of 

what they have always associated with food, but 

now knowing what we know about the science, 

that's becoming important to them as well.

 So we are attempting to label 

hydroponics that are organic. But that's very 

difficult. And we'd rather just not see them be 

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a part of organic.

 CHAIR BEHAR: Okay. Thank you. I 

don't see any other comments from the Board.

 MS. SIMPSON: Thank you.

 CHAIR BEHAR: Next up is Amanda Fulmer 

with Kyla Smith on deck.

 MS. FULMER: Hi. Thank you for this 

opportunity to address the Board. My name is 

Amanda Fulmer. And I'm here in my personal 

capacity as a consumer and a PCC member.

 I'll keep my comments brief. They 

concern the inclusion of so-called natural 

ingredients in organic foods.

 It's my basic position that natural 

ingredients labeled as such should not be 

permitted at all in organic foods. I personally 

would rather they not be included at all on any 

label, but especially I think it's important they 

not be part of organics.

 Transparency and documentation are a 

few of the core tenets of the organic movement. 

They're simply core principles for anyone who 

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cares about organics.

 Natural ingredients are really the 

black box of ingredient labels. And they may 

hide ingredients that people may want to be aware 

of.

 Certain things that could be labeled 

as natural ingredients, which could be just about 

anything, might include sources that, foods that 

are sourced that might not be appropriate for 

vegetarians or people following a kosher or halal 

diet, for example.

 They may not be appropriate for people 

with certain allergies. My children have a 

number of friends with sesame allergies, for 

example. You see a lot of labeling for other 

allergens. But sesame, despite being one of the 

top ten allergens in the United States, is not 

typically required to be labeled.

 If it says natural ingredients, our 

friends fear that it might include sesame, that 

it might not be appropriate for their children. 

And there's simply no way to know. 

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 Although natural ingredients are, of 

course, required to be generally regarded as 

safe, consumers might have personal concerns 

about safety, but they have no way to find out 

more.

 People might have environmental 

concerns based on the particular ingredients. 

But, again, there's simply no way to know.

 So I just want to state my position 

that natural ingredients have no place on labels 

at all. Why have ingredient labels if there is 

this black box? But especially with organic 

foods, it seems to be important to hold ourselves 

to higher standards, especially regarding 

transparency.

 CHAIR BEHAR: Comments? Lisa?

 MS. DE LIMA: Hi. Can you just 

clarify when you say natural ingredients what 

you're talking about? Are you talking about 

natural flavors?

 MS. FULMER: Yeah, so there might be 

natural flavors or natural colors. I was 

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actually the consumer who submitted the question 

about butter that was referenced in the previous 

presentation. So that would be one example. 

When you buy butter, it says, most brands, most 

organic brands now say natural flavor on the 

ingredient label.

 CHAIR BEHAR: Tom?

 MR. CHAPMAN: So natural flavors are 

regulated by the FDA. There is a definition for 

them. I believe colors have to be labeled with 

their source, but I could be wrong in that 

regard. But you're talking flavors and colors, 

not ingredients per se. Is that correct?

 MS. FULMER: Yes, that's correct.

 MR. CHAPMAN: Okay.

 CHAIR BEHAR: Anything else? Sounds 

like the Board has to go to a grocery store and 

look around at those labels. Okay. Thank you. 

Next up is Kyla Smith with Eric Mandel on deck.

 MS. SMITH: Good afternoon. My name 

is Kyla Smith. I'm the Interim Co-Executive 

Director at Pennsylvania Certified Organic. PCO 

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certifies 1,600 operations throughout the U.S., 

around 1,600.

 I'll be commenting on the Crop 

Subcommittee's proposal on strengthening the 

organic seed guidance and on the Material 

Subcommittee's cleaners and sanitizers discussion 

document.

 First regarding the seed guidance 

proposal, I'll focus my comments specifically on 

the proposed addition to section 4.1.6 to include 

the phrase, quote, or on organic vegetative crop 

only, which would require organic management of 

non-organic perennial planting stock for 12 

months in order for the vegetative crop material 

to be sold as organic.

 The intent of this inclusion, as well 

as what is meant by vegetative crop, is unclear 

and seems to go beyond the seeds and planting 

stock practiced standard regulatory language.

 205.204(a)(4) specifically addresses 

the management of non-organic perennial planting 

stock, not the crop. If the operation, if an 

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operation plants a non-organic perennial planting 

stock and then wants to sell the perennial 

planting stock as organic, then that planting 

stock must have been managed organically for 12 

months.

 Meanwhile, 205.204(a)(1) addresses the 

management of the crop from annual or perennial 

planting stock and does not include a 12-month 

organic management timeframe.

 Additionally, the proposed rule 

introduced the new term of, quote, vegetative 

crop, which does not meet the definition of 

planting stock.

 If the intent of the proposed language 

is to require the 12-month organic management of 

perennial planting stock to sell the crop, 

whether it's the fruit, nut, shoots, or leaves, 

then this would require a rule change.

 PCO requests that during the revision 

process of this guidance that the program 

clarifies exactly what is and is not allowed to 

be sold, labeled, or represented and when in 

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order to be compliant with both 205.204(a)(1) and 

(4).

 We thought the original publication of 

the seed guidance did clarify this to the 

industry. But perhaps there is still the need 

for further clarification.

 Second, I'd like to briefly address 

the cleaners and sanitizers discussion document 

by simply encouraging the Board to include in 

your discussions on this topic how and/or if 

inactive ingredients in these products should or 

should not be reviewed. Certifiers are not 

aligned in their material review process, with 

some reviewing inactive ingredients and some not.

 Thank you all for your service on this 

Board and for the opportunity to comment.

 CHAIR BEHAR: Comments, questions? 

We're good.

 MS. SMITH: Thanks.

 CHAIR BEHAR: Thank you, Kyla. Okay. 

Next up is Eric Mandel with Leslie Touzeau, I'm 

messing that one up, I'm sure, on deck from QCS. 

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 MR. MANDEL: Okay. Well, thank you 

very much. Appreciate the time to speak. And 

thank you all for the hard work that you do. We 

do appreciate it.

 I'm speaking as an interested consumer 

on my own. I am a proud member of Puget Consumer 

Co-op as well.

 And I just wanted to ask that you 

continue in your work to prioritize and emphasize 

both transparency in all the labeling and all the 

work that's being done throughout the system to 

bring it to consumers so that consumers have the 

ability to make choices that are informed 

choices.

 And I know a lot of your work is on 

that. I'll give some examples where I think it 

can improve.

 And the other thing that I ask that 

you continue to emphasize is public health and 

the outcomes associated with the decisions and 

the recommendations that you make.

 On the transparency side of the 

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equation, two things I know you're, you either 

have been grappling with or are being asked to 

are dealing with hydroponic labeling. You've 

heard earlier speakers talk about that.

 I do think that most consumers assume 

that organic is talking about farms, soil, the 

whole system that produces food in that way and 

that hydroponics, whatever its pros and cons, 

should at least be acknowledged and labeled as 

such so consumers can know that. And I would 

urge you to continue to push for that in 

mandatory labeling until that's clarified.

 Other speakers have also talked about 

the issues around natural flavors. I know from 

research there's very little difference between 

natural and artificial. But I think, again, 

consumers deserve the information. And I would 

urge organics to phase that out or at least label 

what is going into them to the extent that it's 

possible.

 And then on the public health side, I 

think one of the things that really you should 

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reemphasize is the BPA packaging. For some 

reason, that's been deemphasized. And I don't 

understand that. I think it's a significant 

potential issue, so please push that forward.

 And the other one that I would ask 

about is pushing, again, to include having the 

impacts of fracking, which I know is beyond your 

bailiwick.

 But as far as it impacts organic farms 

in terms of the ground water and other impacts to 

those soils, I think that's very important and we 

need to protect our food system. And that's a 

big part of it. Thank you very much.

 CHAIR BEHAR: Thank you. Any comments 

or questions from the Board? Emily?

 MS. OAKLEY: Just a question about BPA 

and its status since it was brought up for 

whomever that might be either --

 CHAIR BEHAR: With the program?

 MS. OAKLEY: -- the subcommittee or 

the program --

 (Simultaneous speaking.) 

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 CHAIR BEHAR: Would the program like 

to address it?

 DR. TUCKER: So the status of that 

work agenda is that it had been on a sort of 

holding. And we have deprioritized that work 

agenda. There are a lot of critical topics being 

addressed by the Board right now, including the 

integrity of imports. And so we have 

deprioritized that item for now.

 MR. MANDEL: Disappointed.

 CHAIR BEHAR: Any other comments? 

Thank you. Okay. Let's see. Where am I? 

Leslie, can you say your name, please --

 MS. TOUZEAU: Yes.

 CHAIR BEHAR: -- and your affiliation?

 MS. TOUZEAU: Good afternoon. My name 

is Leslie Touzeau.

 CHAIR BEHAR: Okay. And then Abby 

Youngblood is on deck. Thank you. Go ahead. I 

just wanted to know how to say your name.

 MS. TOUZEAU: Sure. You were close. 

I'm the Material Review Specialist for Quality 

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Certification Services or QCS. QCS is an 

accredited organic certifying agent of the USDA.

 So thank you for this opportunity to 

provide comments pertaining to the petition to 

add fatty alcohols to the National List of 

Allowed and Prohibited Substances. QCS strongly 

supports the addition of synthetic fatty alcohols 

to the National List at 205.601.

 QCS certifies over 50 organic tobacco 

operations across the country. Prior to the 2017 

petition to add fatty alcohols to the National 

List, numerous organic certifiers determined 

these substances were non-synthetic.

 All QCS-certified organic tobacco 

growers use them for sucker control. QCS 

recently surveyed the tobacco operations we 

certify about their use of and reliance on fatty 

alcohols. All 28 respondents indicated that 

fatty alcohols were critical to the success of 

their organic tobacco operations and without them 

they may be forced to discontinue organic 

farming. 

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 Without fatty alcohols to control 

suckers, producers would be back to the slow and 

costly practice of suckering with vegetable oils 

or by hand. Our clients were unanimous in their 

agreement that there is no effective alternative 

to fatty alcohols.

 Vegetable oil, as the only available 

non-synthetic alternative to hand picking, does 

not adequately meet the needs of organic farmers. 

If applied more than once, vegetable oils can 

cause leaf drop, plant burning, or otherwise 

damage the tobacco crop.

 Suckering by hand is also not a 

feasible alternative as it requires a significant 

amount of additional labor. Our producers agree 

that the chance that they could find reliable 

help due to this laborious task in the hottest 

part of the summer is diminished by shrinking 

rural economies and limited labor availability.

 Several producers noted that labor 

costs would not allow them to sufficiently hand 

sucker their crop, leading to lower yields and a 

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lower quality product.

 A QCS inspector noted that inspecting 

tobacco farms for the last three years is like 

watching the slow death of an industry and of a 

region.

 Many of our clients have invested 

heavily into their organic operations only to 

experience cuts to contracts followed by the 

current prohibition of fatty alcohols.

 One of our growers mentioned that 

organic tobacco is what has enabled his family to 

make the transition into organic production and 

explore the production of other organic crops. 

For others, organic tobacco is not only essential 

to the profitability of their farm, it is also 

important to the economy of their region.

 Many organic tobacco farmers don't 

have access to alternative markets. They cannot 

turn to vegetable farming because there is no 

market to sell organic vegetables.

 If fatty alcohols continue to be 

prohibited, it is very likely that our organic 

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tobacco producers will be forced to discontinue 

organic farming altogether.

 On February 11, 2019, QCS received 

confirmation from the NOP that a use-up period 

would be allowed for our producers who had 

existing supplies of fatty alcohols.

 We urge the NOP to extend this use-up 

period until the NOSB has made a final 

recommendation on the petition.

 QCS hopes that the NOSB recognizes the 

urgency of this issue and promptly recommends 

adding fatty alcohols to the National List as 

farmers' livelihoods are at stake. Thank you.

 CHAIR BEHAR: Any comments, questions? 

Steve?

 MR. ELA: So we allowed the use-up for 

this year. I mean, use-up generally is using up 

materials on hand. What does that mean for the 

growers for next year, for the 2020 season?

 MS. TOUZEAU: Right. So right now we 

are asking to extend that period to have a 

temporary allowance so that farmers for next year 

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would be able to purchase the products to, for 

the 2020 season.

 CHAIR BEHAR: Anyone else? Okay. 

Thank you.

 MR. MORTENSEN: Yeah, I just wanted to

 CHAIR BEHAR: Oh, I'm sorry.

 MR. MORTENSEN: -- just say thank you 

to Leslie and to the others that have brought the 

kind of information that we needed the last goround. So this has been very helpful. Thanks.

 MS. TOUZEAU: Yeah, thank you to you 

as well.

 CHAIR BEHAR: Okay. Thank you. Next 

up is Abby Youngblood, and on deck is Anne Ross.

 MS. YOUNGBLOOD: Hi. I'm Abby 

Youngblood, Executive Director at the National 

Organic Coalition. And thank you, NOSB members, 

for the work that you do to protect organic 

integrity.

 NOC is deeply disturbed by the lack of 

consistency across certifiers. A primary goal 

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for the organic law was to create a level playing 

field for organic operations regardless of size, 

geography, or production system.

 But we're falling short in several key 

areas on outdoor access for organic poultry and 

on the continuous conversion of conventional 

dairy livestock into organic herds or origin of 

livestock.

 We appreciate that the NOSB has taken 

a stance on these issues and put forward 

resolutions.

 The lack of clear standards for 

hydroponic and container systems is another area 

that requires the Board's attention. We urge the 

Board to call for a moratorium on the 

certification of new operations given that the 

current situation is opening organic up for 

abuse.

 We also urge the Board to pay close 

attention to the annual peer review audits of the 

National Organic Program. The lack of 

consistency across certifiers points to serious 

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problems in the NOP accreditation process. And 

the peer review audits are a mechanism to gauge 

the health of the NOP.

 NOC supports the NOSB proposal to add 

energy infrastructure impacts to your work 

agenda. And we urge you to bring together a 

panel of experts and affected organic growers at 

the Pittsburgh NOSB meeting this fall. That 

region has been severely affected by this issue.

 We think this panel is a good first 

step and will inform an NOSB discussion document 

on this topic.

 On excluded methods and induced 

mutagenesis specifically, we're grateful for the 

Board's continued efforts to move this work 

forward.

 We need more input from stakeholders 

to understand how frequently this method is used 

in plant breeding. We encourage the NOSB to work 

closely with the Organic Seed Alliance and other 

plant breeding experts to come up with a plan to 

move this work forward. 

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 We're concerned about the chilling 

effect on organic breeding if this method remains 

on the TBD list long term. And we also agree 

with Zea's earlier comments about ensuring due 

diligence with some of these methods that have a 

long history of use, including induced 

mutagenesis.

 On nutrient, vitamins, and minerals, 

NOC opposes the relisting with the current 

annotation because it's used by some food 

manufacturers to justify adding synthetic and 

non-organic ingredients to organic foods when 

they do not appear on the National List. This 

includes several additives that have been 

reviewed and rejected by the NOSB.

 Synthetic or non-organic additives 

used for nutrient fortification should be limited 

to those that are essential because they're 

required by law. Thank you for considering my 

comments.

 CHAIR BEHAR: Okay. Tom and then 

Dave. 

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 MR. CHAPMAN: Hi, Abby. I have a 

question for you on your fish oil comments. You 

guys wrote NOC doesn't support relisting fish oil 

due to concerns related to environmental impacts 

and ecological sustainability. But in 2018 in 

the fall, NOC supported the relisting of liquid 

fish products.

 I guess I'm curious to know what's the 

difference in terms of environmental impacts and 

ecological sustainability concerns between those 

two products.

 MS. YOUNGBLOOD: Let me consult with 

our membership and our NOSB consultant on that 

comment and get back to you.

 MR. CHAPMAN: Okay. Thank you.

 MR. MORTENSEN: Abby, I was wondering 

if you could say a little bit more about the 

moratorium idea that you mentioned at the 

beginning of your comments.

 MS. YOUNGBLOOD: Sure. I mean, I 

think this idea has been out there for a while. 

We've been asking for this for a while. 

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 And, you know, it's a recognition that 

if we allow the continued certification without 

standards in place that we're on this slippery 

slope without clarity. And, you know, in fact, 

we would ask certifiers to step up to that call 

as well given the uncertainty right now.

 MR. MORTENSEN: Thank you.

 CHAIR BEHAR: Anyone else? Thank you. 

Thank you, Abby, wide-ranging comments. Anne 

Ross is next with Carol McRoberts on deck.

 MS. ROSS: Good afternoon. My name is 

Anne Ross. I'm an attorney, and I hold an 

advanced law degree in agricultural and food law. 

First, I want to thank you very much for your 

time and your service to this Board.

 For the past two years, I have worked 

as a farm policy analyst for the Cornucopia 

Institute. My primary responsibility has been to 

work on import fraud.

 It's hard to believe that the time has 

passed. But at my first NOSB meeting in Tucson, 

I stood before the Board with a petition in hand 

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asking that the NOP take immediate action. The 

action requested was that the NOP address on an 

expedited basis the regulatory loopholes that 

have contributed to fraudulently labeled organic 

grain imports crossing U.S. borders.

 Two years later, I still get calls 

almost every week from U.S. organic grain farmers 

asking what's happening and what's being done. 

They tell me about their struggles and how they 

just want a level playing field. I tell these 

farmers there's progress thanks to the efforts of 

many people in this room.

 The 2018 Farm Bill provisions are 

positive developments, and rule drafting is 

underway. But we cannot rest here. Additional 

work is needed, and it has to start now.

 First, I encourage the NOP to take all 

steps necessary to attain Stop Sale authority. 

Stop Sale authority would allow the NOP to 

prevent fraudulent organics from entering the 

stream of commerce. Ultimately, one cannot 

effectively enforce what one cannot stop when no 

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other agency exercises that role.

 Stop Sale authority is a powerful 

deterrent and protects the organic market. The 

NOP should work with Congress to address any due 

process concerns and statutory hurdles.

 Second, when a foreign certifier has 

been penalized by regulations, by regulators in 

other countries, this ought to immediately 

trigger an investigation of that certifier in any 

of the implicated operations it certifies to 

establish organic authenticity of those imported 

products.

 As stated in my written comments, 

earlier this month the EU limited the authority 

of a foreign certifier to certify products in 

several high risk countries, the reason, fraud. 

Where is that product headed now? And where are 

those operations turning for certification?

 Third, weak penalties for regulatory 

violations are no match for bad actors with deep 

pockets. We all know fraud is about money. And 

as long as cheating is cheap, the conduct will 

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continue.

 Fines need to be meaningful, otherwise 

those operations intent on committing fraud will 

continue to conclude the rewards of cheating 

outweigh the risk of getting caught.

 I strongly urge the NOP to not only 

impose aggressive fines under the current 

regulations, but to work with Congress to impose 

greater penalties.

 Thank you for your service. And I'm 

happy to answer any questions.

 CHAIR BEHAR: Anybody here on the 

Board? Thank you.

 MS. ROSS: Thank you.

 CHAIR BEHAR: Very good comments. 

Okay. Next up, I think we have a little treat 

here, Carol McRoberts and Jay Feldman on deck.

 MS. McROBERTS: Good afternoon, all. 

Can you hear me? We're the Seattle Raging 

Grannies, and we're going to sing a couple of 

songs. The first one is the signature song, and 

our second one will be a restaurant that no one 

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should eat in.

 (Singing.)

 MS. McROBERTS: We understand that 

fracking is very bad for the earth around it, and 

we think that maybe some of the food served at 

our restaurants may be growing there.

 (Singing.)

 CHAIR BEHAR: Thank you. Tom has a 

question.

 MR. CHAPMAN: I think a statement, 

really. I think John Ashby has been replaced.

 (Laughter.)

 CHAIR BEHAR: Thank you very much. 

And someday I'll be a member of the Raging 

Grannies. Okay. Jay Feldman is ready to roll.

 MR. FELDMAN: I have a tap dance for 

you guys.

 CHAIR BEHAR: Okay. And Kate 

Mendenhall is on deck. Don't forget to get your 

animal, Jay.

 MR. FELDMAN: I'm Jay Feldman, 

Executive Director of Beyond Pesticides. So, 

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yes, we're here to celebrate organic after that 

presentation. Our goal is to ensure its 

alignment with the principles in the Organic 

Foods Production Act, but we have serious 

challenges. Congress created the NOSB to provide 

leadership and forward movement, not simply to 

protect the status quo. We have to embrace 

continuous improvement across the board. We have 

to grow the organic market exponentially. To do 

this, we have to ensure public trust in the 

organic label. We must be transparent. 

Ultimately, we are only as strong as our weakest 

link.

 Organic stands at the threshold of the 

future. The context in which we are working on 

organic falls at the intersection of human health 

and environmental protection. It is our only 

hope for the future.

 Organic addresses the climate crisis 

by adopting soil-based practices embedded in the 

Organic Foods Production Act. Organic must 

support a system that protects and enhances 

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biodiversity and staves off the insect 

apocalypse.

 But if the public does not support 

organic, then none of this much matters. And the 

only way the public will support organic, pay 

premium prices, understand that their investment 

in the future is important is if there is 

transparency and trust in the process.

 Standards must be in compliance with 

the Act. NOP must implement NOSB decisions on 

the National List. There must be rigorous 

enforcement, and organic certifiers must operate 

under uniform standards that are seen as 

transparent in their methods and free of conflict 

of interest.

 One more thing. It feels sometimes 

that independent science, hearing both sides of 

an issue, identifying hazards of materials is 

somehow an attack on organic, when in fact it 

strengthens organic and is compliant with the 

law. So here are four things: The program should 

be able to clearly articulate the law and the 

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rules. It has not been true for glyphosate. The 

lack of clarity we heard today about specific 

container operation scenarios, not abstract, 

damages organic and the label.

 Two, it is painful to see the lack of 

action on previous Board decisions, as a former 

NOSB member. Inerts review, animal welfare 

recommendations, access to pasture, origin of 

livestock, BPA in packaging, infant formula, 

remember corn steep liquor, sodium nitrite, 

methionine. The European Union does not allow 

the use of synthetic methionine in organic 

poultry but does require more space for birds, 

fewer birds per house, and more access to the 

outdoors.

 Three, identifying cutting-edge issues 

like you're doing on sanitizers, marine 

materials. Keep doing that. We appreciate your 

efforts to evaluate and find solutions to 

problems.

 Hydroponics. Labeling is something 

you can address with annotation. 

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 And finally what more can you do as 

NOSB members? Exercise your statutory authority 

to advise the Secretary of Agriculture. Get 

together as a group or individually, as small as 

a subset of this group, and tell the Secretary of 

Agriculture what you've heard here today.

 Thank you very much for your service.

 (Applause.)

 CHAIR BEHAR: Thank you, Jay. Jay, 

can you tell me are you a membership 

organization, Beyond Pesticides?

 MR. FELDMAN: Yes, we are.

 CHAIR BEHAR: And how many members do 

you have?

 MR. FELDMAN: Well, we have, we have 

a network of 50,000 people. In terms of paid 

membership, we have about a thousand groups, so 

we stress group memberships, local communitybased organizations. But our strategy is to 

bridge farmer and consumer interests, which I 

think are aligned in terms of advancing organic. 

But we believe very deeply through this 

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membership that exercising local democratic 

involvement in the marketplace and through the 

public hearing process in terms of what you're 

doing and being represented by the stakeholders, 

every one of the stakeholders on this board, is 

essential to our membership voice.

 CHAIR BEHAR: Thank you. Okay. Kate 

Mendenhall is up -- oh, I'm sorry. Emily? I'm 

sorry.

 MS. OAKLEY: Sorry. Just a question 

about marine materials. Thank you for your 

detailed comments. They were very thorough. I 

understand why Beyond Pesticides is suggesting an 

annotation in terms of specific detailed language 

for regulatory purposes, but I'm wondering if you 

would consider an annotation requiring organic 

certification in the future. If you're not 

prepared to answer that now, that's fine. But 

I'm just asking for that consideration. 

 MR. FELDMAN: Well, as you know, 

Emily, I think part of this process is finding a 

compromising common ground. Your discussion 

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document and the work of the subcommittee I think 

identifies a key issue that we must address. 

Consumers care not only about what they put in 

their mouths, but they care about how their food 

is grown and what impact it has on the 

environment. So we need to get to a compromise 

that advances this.

 We at Beyond Pesticides feel that 

annotations are the best way to ensure that the 

voice of the NOSB, whatever compromise that may 

be, is enforceable. And enforceability is key in 

coordination with certification. So to the 

extent that those work in tandem, we're all in. 

We support that and your efforts. Thank you.

 CHAIR BEHAR: Dan.

 DR. SEITZ: Jay, I didn't understand 

the point you made about annotating hydroponicproduced products.

 MR. FELDMAN: Well, again, you know, 

the question is if hydroponics is established as 

allowable under organic, which it has been, the 

issue is what materials are used in hydroponic 

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and to what extent you require the disclosure of 

those materials on hydroponic products. So to 

the extent that a user or a producer of 

hydroponic crops are using inputs that are 

allowed by the National List, you have the 

authority as a board to require annotations of 

those materials when used in different sites. 

You know, if it's a particular use pattern or a 

particular site, a particular crop. And in this 

case, I would argue that it's a particular method 

of farming that really does require, I believe 

consumers want to know that this is part of an 

organic operation. I'm sorry. A hydroponic 

operation.

 So that gives us, you know, we have a 

lot of authority, you guys, as a board, over this 

National List and how you convey the use patterns 

that you've permitted under the law. You can 

require all kinds of specific disclosures along 

with that use pattern.

 DR. SEITZ: Great. Thank you. I'd be 

curious to hear from you in the future, perhaps 

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some specific example of wording that you might 

have as an annotation for that.

 MR. FELDMAN: Okay, sure. Thank you.

 CHAIR BEHAR: Anyone else? Very good. 

Thank you very much, Jay. And I didn't see the 

tap dance. Kate, you're up there. Next up is 

Dave Colson on deck.

 MS. MENDENHALL: Thank you, members of 

the National Organic Standards Board, for the 

opportunity to speak before you today. My name 

is Kate Mendenhall. I'm the Director of the 

Organic Farmers Association, and I'm also an 

organic farmer in Northwest Iowa.

 Founded in 2016, Organic Farmers 

Association provides a strong and unified 

national voice for domestic certified organic 

producers. We are led and controlled by 

certified organic farmers. Only certified 

organic farmers drive our policy positions and 

our policy work agenda. We have farmer members 

in 48 of the 50 states.

 Organic Farmers Association greatly 

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supports the work and the role of the National 

Organic Standards Board and finds your role 

paramount in maintaining integrity in the USDA 

organic label. Organic farmers were active in 

every step towards building our national organic 

movement and market, and we believe that organic 

farmers deserve a driving seat in setting the 

future of the organic label.

 Our 2019 certified organic farmer 

policy identified five top priorities from the 

wider certified organic farmer community, 

feedback that extends beyond our membership and 

invites all U.S. certified organic farmers to 

participate. This winter, organic farmers ranked 

the top five priority issues as organic import 

frauds, number one; number two, NOP enforcement 

to ensure organic integrity; number three, 

prohibiting hydroponics in organic production; 

number four, pasture rule enforcement; and number 

five, organic dairy standards and enforcement.

 We urge the National Organic Standards 

Board to reaffirm their October 2018 resolution 

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regarding origin of livestock, urging the NOP to 

move to a final rule in 2019 immediately. 

 Number two, encourage the NOP to issue 

training and guidance for risk-based 

certification oversight in organic dairy, 

focusing on operations on the margins of the 30-

percent DMI rule and dairies with a thousand or 

more milking and dry cows. 

 Number three, call for the NOP to 

issue an immediate moratorium on any new 

hydroponic operations and return this issue to 

the NOSB work agenda as a top priority. OFA 

believes that the NOP should implement the 2010 

NOSB recommendation to not allow certified 

organic hydroponics, but we recognize that there 

is an immediate urgency to put a moratorium on 

new hydro operations so that we can have more 

conversation and consensus within the organic 

community. 

 The current lack of uniform standards 

implementation and enforcement of hydroponic 

certification is publicly undermining the 

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integrity of organic farmers nationwide. The 

lack of clarity around a three-year transition 

following the use of a prohibited substance is 

unacceptable. This ambiguity to a clear rule 

enforced throughout the life of organic 

certification calls to question the integrity of 

the entire NOP program.

 Thank you for the opportunity to 

address you today.

 CHAIR BEHAR: Emily.

 MS. OAKLEY: Could you elaborate on 

what you mean by a lack of clarity around a 

three-year transition period following the use of 

a prohibited substance?

 MS. MENDENHALL: Yes. I think the 

question has been asked many times today, and I 

think, you know, in one case, there's a 

hypothetical but farmers need to be able to call 

their certifier and get a clear answer on whether 

or not a practice is allowed or not allowed and 

certifiers need to have clear direction from the 

National Organic Program about whether or not you 

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can spray a prohibited substance and their 

certify your hydroponic operation without any 

transition. That is not a hypothetical. That is 

a direct question that requires a direct answer.

 CHAIR BEHAR: Jenny.

 DR. TUCKER: I want to clarify here 

that, again, I want to state incredibly clearly 

glyphosate is not allowed. And right now we have 

no specific case that is giving allegations of 

what is being talked about, this idea of 

glyphosate being put on the ground and then some 

kind of plastic there and then immediately 

covered. We do not have a specific case, so we 

have learned about one operation and have 

investigated. We have talked to that certifier 

about what is happening on the ground.

 We need specific cases where somebody 

believes the regulations have actually been 

broken on a farm and has evidence. So that is, 

when I talk about we need more information, 

that's what I'm looking for is case-specific 

information that we can then evaluate against the 

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regulation.

 So glyphosate is not allowed. We are 

looking for specific cases, actual on-the-ground 

realities where people know this is happening, so 

that we can investigate it and evaluate it 

against the rules. Give us a case, and we will 

enforce.

 MS. MENDENHALL: Could I respond? 

Clarify?

 CHAIR BEHAR: Yes, you can respond, 

Kate.

 MS. MENDENHALL: So I think that 

hopefully it's clear and will always be clear 

that any prohibited substance will never be 

allowed in organic production. If we're at a 

point where we're debating that, we have a very 

serious problem on our hands and we have no 

organic program.

 The question is clearly, if a 

prohibited substance is applied, can I certify my 

hydroponic production the next day? That is not 

a hypothetical. We need really clear instruction 

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about the transition period for a farmer growing 

in the soil and a farmer starting a new operation 

right next door. Can they spray a prohibited 

substance and then call their certifier and get 

their certificate?

 DR. TUCKER: We know of no certifier 

that is allowing that scenario, so again, if 

there is a specific case, then please, please 

bring it to us.

 MS. MENDENHALL: That kind of 

ambiguity leaves a lot of discontent.

 CHAIR BEHAR: Okay. Thank you, Kate. 

 MS. MENDENHALL: Thank you.

 (Applause.)

 CHAIR BEHAR: Up next is Dave Colson 

with Christopher Peterson on deck. And after 

Christopher, we have three more commenters.

 MR. COLSON: Good morning. My name is 

Dave Colson, and I have a certified organic farm 

in Durham, Maine and work as the Director of 

Agricultural Services for the Maine Organic 

Farmers and Gardeners Association. My job is not 

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to do the certifying of farms but to assist them 

in their production and marketing processes and 

to help them to understand and meet the 

regulations of organic certification.

 MOFGA first began certifying organic 

farms in the 1970s. At first, we only certified 

crop production but later added dairy and other 

livestock, processed products, and maple syrup. 

These days, it's easy to dismiss the early 

certifiers or anything that came before the 

national rule, but many years of discussion led 

to the development of what became the national 

rule in the organic standards as we sought to 

develop and articulate a vision of organic 

production.

 One of the things I appreciate about 

the way the rule is written is how each section 

starts with the affirmative methods of organic 

production. For instance, 205.203 on soil 

fertility and crop nutrient management begins 

with the producer must select and implement 

tillage and cultivation practices that maintain 

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or improve the physical, chemical, and biological 

condition of soil and minimize erosion. The 

producer must manage crop nutrients and soil 

fertility through rotations, cover crops, and the 

application of plant and animal materials.

 The rule goes on to describe crop 

nutrient management that does not contribute to 

contamination of crops, soil, or water by plant 

nutrients. And finally, crop nutrients that are 

allowed when included on the National List of 

synthetic substances.

 What I would like to highlight today 

is that these cultural methods are often 

overlooked in favor of inputs when debating what 

may be used in organic production. And I would 

point out that these meetings are largely about 

what is on the National List, but most of the 

organic growers I work with rely on using and 

developing those cultural methods. In this 

decision process, we never considered actually 

removing plants from their interaction with the 

soil. That seemed inconsistent with the cultural 

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growing practices defined in 205.203.

 Cultural innovations such as these and 

others are the heart of organic farming. I speak 

about it today because I don't want this to be 

lost in the discussions and disagreements over 

what products are on the National List. Organic 

farming is about living within the natural 

environment and learning to adapt our growing to 

its demands. I want to remember today the 

certified organic farmers around the country who 

farm by following these important cultural 

processes that incorporate the natural benefits 

of growing in soil.

 Therefore, MOFGA supports a moratorium 

on certification of new container and hydro 

operations until the details and possible 

standards for such production are developed. 

Thank you.

 CHAIR BEHAR: Thank you, Dave. Any 

questions or comments from the Board? Emily.

 MS. OAKLEY: Yes, I don't really 

remember in previous meetings hearing so much 

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about a call for a moratorium on hydroponics, and 

I don't know what's happening within the 

stakeholder community, if this is sort of a 

natural progression or, you know, it's coming 

spontaneously or if there's a conversation taking 

place. But I was just wondering if you could 

elaborate more on that.

 MR. COLSON: Well, I first kind of got 

aware of this discussion back in the meeting in 

Vermont, and I think that was in 2015. And at 

that point, that was the first that I heard about 

a call for a moratorium at that point. And some 

certifiers have honored that. I think the nuance 

of how that goes about has to do with not feeling 

like we do have standards that we're able to 

certify to. It seems to be picking and choosing 

from different parts of the rule.

 So MOFGA right now does not certify 

hydroponic or container production, and we feel 

it's important that those standards, if 

hydroponic is going to move forward, need to be 

developed so it's clear what it is we're actually 

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certifying.

 CHAIR BEHAR: Emily.

 MS. OAKLEY: Is it possible to kind of 

jump back to the previous commenter's comment, or 

is that not appropriate?

 CHAIR BEHAR: No, you could.

 MS. OAKLEY: I just wanted to say that 

I hope, Jenny, that there are no producers that 

are not following that three-year transition 

period. I hope actually no one will be able to 

give you an example of that taking place because 

I hope that that isn't happening within the 

organic system. So I hope there isn't even a 

need for someone to do that. I'm just asking and 

I think people are asking for clarity that that 

isn't allowed, and I understand your position but 

I just wanted to state that I hope that we can't 

even find an example because it's not taking 

place, and I would like that clarity at some 

point in the immediate future, if possible.

 CHAIR BEHAR: And I want to say, Dave, 

too, as an organic educator, the input 

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substitution, when someone comes to me and asks 

about transitioning to organic, the first 

question is, you know, where is the organic 

herbicide or, you know, and the inputs, and we go 

through the systems-based approach to farming. 

And most of the time, they're quite excited about 

it because it means less cost of inputs, but it 

also means, too, that they have a much more 

intimate relationship with their entire operation 

and they gain so much from being part of their 

farm, rather than doing to their farm.

 MR. COLSON: Yes. And I agree. One 

of the things that we used to do before the NOP 

program, which I know is not really relevant so 

much, but we had, rather than what was allowed 

and what was not allowed, we had not allowed, 

sorry, prohibited, allowed, and recommended. And 

often, what we now see as those cultural 

practices that are embedded in the rule that 

often don't get talked about a lot because we all 

accept them as the proper practices to use, those 

were the recommended practices and they became 

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the ideal to which we would try and move farms 

towards.

 CHAIR BEHAR: Thank you. Oh, Ashley.

 MS. SWAFFAR: Hi. So you had asked 

for a moratorium on hydroponics because we don't 

have standards. Would you also support a 

moratorium on apiary production, honey 

production, because we don't have standards, 

mushrooms -- 

 MR. COLSON: Well, in effect --

 MS. SWAFFAR: Wait. I'm not finished. 

You know, and then you also referenced how people 

pick and choose what part of the rule to follow. 

We also saw throughout the hydroponic things a 

lot of questions. I asked commenters about 

growing tomatoes in greenhouses. They don't 

rotate crops, so they're picking and choosing 

rules to follow there.

 MR. COLSON: That's a lot.

 MS. SWAFFAR: Yes, yes.

 MR. COLSON: And so I agree with most 

of what you're bringing up. Apiary standards, in 

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effect, we have a moratorium on it because I 

think there's only two or three in the country 

that can meet the standard. The rotation with 

tomatoes, I do recognize there are some small 

growers that only have one house, and they are 

growing tomatoes continuously in that house, 

although what we try to move folks towards is 

either multiple house or a moveable house so that 

they do have a crop rotation of some kind.

 So I would agree with you. I think in 

some of those cases it would be worthwhile to 

have a moratorium on some of those pieces in 

order to articulate exactly what we're talking 

about in terms of the standard we're hoping 

people will meet.

 MS. SWAFFAR: You referenced apiary 

standards and two people meeting them. What 

standard are your referencing?

 MR. COLSON: Well, we do have honey 

standards from what I understand.

 CHAIR BEHAR: We have an NOSB 

recommendation, but it has not been implemented. 

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 MR. COLSON: Okay. Thank you for that 

clarification.

 CHAIR BEHAR: But I do know that there 

are some certifiers who are referencing that, you 

know, as their own.

 MR. COLSON: I thought there was a 

certified beekeeper in New Mexico.

 CHAIR BEHAR: There are certified. 

The NOP does allow operations if they can show 

that it meets the current rule to be certified 

organic, and I know of a few. So various 

certifiers use various rules, you know. Some of 

them are following the recommendation and some 

are not.

 MR. COLSON: And we at MOFGA did have 

a honey standard at one time, and the way we went 

about that as we asked the honey producers to 

come to us and produce a standard that we could 

certify to. We didn't certify until we had 

someone develop a standard that we could work on, 

and that's part of what I'm talking about. I 

think to allow things to move ahead before we 

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have a standard that's nationally recognized does 

not seem to be in the service of the national 

organic program.

 CHAIR BEHAR: I had Scott next and 

then Tom and then Ashley.

 MR. RICE: To respond to Emily's 

response to an earlier comment, I just wanted to 

touch on, you know, when the sort of word came 

around about glyphosate use on a piece of land 

and then that going straight to organic 

production, that was quickly a conversation with 

my colleagues in the Accredited Certifiers 

Association and had a fairly participatory and 

robust kind of dialogue on that over email of, 

hey, are you doing this, is this something you 

would allow? And there was no answer that said, 

yes, we would do that. It was the complete 

opposite and very consistent of, no, this is not 

something that we would allow. And I just wanted 

to make that clear.

 As Jenny notes, there's no case that 

we, of course, could look at and kind of dig 

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into, as we often like to as certifiers. But 

it's the mission and kind of vision of the 

Accredited Certifiers Association to have 

consistency in standards, and on this particular 

issue I saw that consistency quickly and pretty 

loudly.

 CHAIR BEHAR: Tom and then Ashley.

 MR. CHAPMAN: Sorry to dig in on this 

one, but, I mean, there's a lot of production 

environments that don't have standards as 

outlined right now in the national organic 

standards. Apiculture is one of them, fungus 

production is another, aquatic plant life is a 

third. I could probably continue listing several 

more. Does MOFGA certify any of those operations

 MR. COLSON: Of course. You know we 

do. We do aquatic plants. Absolutely.

 MR. CHAPMAN: Yes, and mushrooms.

 MR. COLSON: Yes, and mushrooms.

 MR. CHAPMAN: Then how does that 

align? There's no production standard there. 

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 MR. COLSON: Oh, I agree. Yes, it's 

an inconsistency in my presentation definitely. 

That does not necessarily negate the need for 

consistent standards.

 MR. CHAPMAN: I agree with you there.

 CHAIR BEHAR: Do you have something to 

say Ashley, or are you okay?

 MS. SWAFFAR: I was just going to say 

an NOSB recommendation is not final rule.

 CHAIR BEHAR: Yes, I think we all 

understand that. Emily.

 MS. OAKLEY: Just a clarification. I 

think when MOFGA is certifying aquatic plants, 

they are following the wild crop standards. I 

mean, that might need way more elucidation than 

it currently has. Like, I definitely agree with 

that, and I think we've heard that in a lot of 

the comments, but that is the standard that they 

are certifying to.

 MR. CHAPMAN: Can I ask a follow-up 

question to that?

 MS. OAKLEY: To me or to --

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 MR. CHAPMAN: To Dave. Does your sea 

vegetable questionnaire involve cultured 

products?

 MR. COLSON: I'm not conversant enough 

in that to be able to answer directly, but I can 

try and find that information.

 MR. CHAPMAN: If I have it up in front 

of me, can I answer it for you?

 MR. COLSON: Absolutely.

 MR. CHAPMAN: It does.

 MR. COLSON: It does?

 MR. CHAPMAN: Yes.

 MR. ELA: Say that again, Tom.

 MR. CHAPMAN: The MOFGA sea vegetable 

addendum for certification also handles cultured 

sea vegetables, which would be not wild crop.

 CHAIR BEHAR: Dan.

 DR. SEITZ: I just want to comment 

that I can see that someone might in good faith 

take a position that may have some 

inconsistencies. So if you take the moratorium, 

for example, around hydroponic, the possibility 

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of new systems being carried out in wildly 

diverse ways and having an enormous economic 

impact on existing operations may warrant a 

moratorium in a way that a much smaller corner of 

the organic sector may be able to tolerate some 

inconsistency. And I can also imagine that 

certifiers might, in a sense, exercise extra care 

in an area where there may not yet be standards.

 And I think all of us, in principle, 

want to see consistency, but I think it's no 

accident that there's a famous quote that would 

say foolish inconsistency is the hobgoblin of 

small minds. I think the point there being, I 

think here it's not a foolish inconsistency. We 

strive for consistency. But the fact is in any 

situation like this where there's such a vast 

amount of information in situations to address, 

complete consistency is not possible.

 MR. COLSON: Yes, and I would just 

comment that farmers are innovative folks, 

organic especially, and there are reasons that 

folks have moved in a variety of directions. And 

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I think the raising of kelp would be a good 

example, in that originally kelp was not 

considered a food additive, and that's why the 

need to certify came into place, as you know. 

And so there was a quick push to develop a way to 

allow a use that had already been ongoing, and I 

do recognize that. And then that couples on with 

the idea of, well, if we're depleting a natural 

resource, how can we do it in a better way?

 So I'm not saying that that's the way 

to go. I think the idea of a moratorium or a 

pause when some of these things change so that 

the process that's being used right now for 

marine materials can be gone through so that we 

aren't then catching up with ourselves after the 

horse is out of the barn. And I think that's 

where we're consistently finding ourselves in a 

lot of these pieces right now. So that's where I 

think the pause or the moratorium might be worth 

considering on some of these things.

 CHAIR BEHAR: Okay. Thank you, Dave. 

We'll keep moving here. 

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 MR. BRADMAN: Sorry. I'm just going 

to restate my earlier comment. You know, I'm not 

sure where a moratorium fits in or not, but I 

really think it's essential that we develop 

standards and that we really think about what it 

means to produce food in different ways and that, 

I just think that's extremely important and that, 

as a board and as a community, we need to work 

towards that.

 CHAIR BEHAR: Thank you, Asa. So next 

up is Chris Peterson, and Andrew Dykstra is up 

next. And thank you, Chris. My chickens enjoy 

the feed from your mill.

 MR. PETERSON: Thank you. My name is 

Chris Peterson. I represent Cashton Farm Supply. 

We're an organic feed mill in Cashton, Wisconsin. 

We've been in business for over 30 years, and 

we've been working on organic feed for over 20 

years. We've got about 40 people that work for 

us and really appreciate the work that's done to 

support the industry because it is the industry 

that we focus on. We don't do conventional. 

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We're not using it as a segment. It's 100 

percent of what we do.

 We deliver bulk feed in our area. 

We're located in Southern Wisconsin. We hit most 

of Wisconsin, Southern Minnesota, Eastern Iowa, 

with our bulk trucks, and we're serving a lot of 

customers that are going to be feeding 1,000 to 

8,000 laying chickens typically. We're mostly in 

the laying hen market.

 In addition, we ship a lot of bagged 

feed either direct to farms, or we have a network 

of 19 independent farm stores and five 

cooperative stores that we ship bagged feed and 

sell bagged feed through. Obviously, that's 

going to be usually a smaller farm that's got 

chickens as part of a diversified organic 

operation. They might be doing vegetables, they 

might be doing dairy, and the hens and the 

broilers are there to supplement their farm 

income.

 We do encounter -- I should say I'm 

here to support listing of synthetic 

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DL-methionine and at the average rates throughout 

the life of the flock. We do see when we're 

feeding in a bagged ration a 17-percent protein 

ration with two pounds of methionine per ton. We 

do see feather pecking and aggressive behavior, 

which we attribute to a lack of methionine in 

those birds.

 And our bulk producers, when they 

bring a new flock in, they're usually going to be 

going to, like, an 18-percent protein. If 

they've got a flock that's coming out of the 

grower barn with a lot of variation in the bird 

weights, they might be going to an 18.5 or a 19-

percent even to try and grow those birds out, and 

the ammonia becomes a major problem in a hurry. 

Anytime from late August all the way through 

until mid-May, we'll have barns that have a lot 

of problems with ammonia because they're 

overfeeding the protein when those birds go in.

 We do have people that, I should say 

right in our neighborhood we've got a lot of 

2,000 to 5,000-bird barns. They do have really 

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good outdoor access, and the chickens do go out 

in the pasture, but they still have these ammonia 

problems. We have people that do birds on 

pasture, usually smaller operations, a couple 

hundred birds. And, you know, they can 

sometimes, for short periods of time, get the 

birds to subsist on the pasture, but we have a 

really short season. We had ice on the ground 

here about two weeks ago. By the time we get to 

the middle of July, the pastures are starting to 

slow down in their production. And they do see, 

whenever those birds get inside, they do see that 

issue with increasing protein makes the litter 

messy, a lot of ammonia. If they've got a few 

hundred birds, they will try to supplement that 

protein because they see they need the protein. 

So we don't see that that small-scale production 

exempts people from issues with methionine.

 Thank you very much.

 CHAIR BEHAR: Any questions from the 

board? I have one. How are you working with the 

new methionine annotation where it is so many 

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pounds over the life of the bird --

 MR. PETERSON: We're just starting 

with that because most of our producers have just 

gotten documents from their certifier. These 

flocks run for about 14 months, so obviously a 

flock that's already in, they're not averaging 

yet. So people are trying to work out how 

they're going to feed those, working with their 

certifiers to get a plan in place, get it written 

to their system plan, and actually start doing 

it. We have nobody that I know of that's really 

started doing it yet. But the people are working 

on that, and I think what we're looking at is 

averaging based on the requirement of the bird 

because right now, if you go back to where we 

have just a flat two-pounds per ton limit, you 

know, you're looking at the limit is flat but, 

based on what the bird requires, you're starting 

out at a low level and then increasing as the 

flock gets older and people see these issues 

resolve themselves as you get to the end, where 

you're feeding more of the requirement because 

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the bird's requirement is coming down. 

 So right now the people that are 

starting to work on it, they're kind of looking 

at how do we get that line to flatten out when we 

consider it as a percentage of the bird's 

requirements so we're not starting out at a low 

restriction and coming upward. It's still the 

restriction even under the average. You're still 

at a restricted level, but they're trying to get 

the restriction to be even to the bird's 

requirement throughout the flock, so you'll get a 

little more methionine early on.

 CHAIR BEHAR: So are you responding to 

their request, or are you working with them in 

the ration development?

 MR. PETERSON: So far, we're 

responding to their requests, but they'll have a 

breed spec based on the birds they've got, and we 

can ration it based off their breed spec.

 CHAIR BEHAR: I know that certifiers 

are looking at how to actually be able to 

document that this has occurred, and so as an 

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organic inspector, I know I'll be looking at a 

lot of invoices and tags and trying to figure 

that all out.

 MR. PETERSON: And from the producers, 

they're, you know, nobody is doing it yet, so 

people want to, they don't want to jump right in 

because it's not like your calcium where you can 

ration it up and down and if it's off a little 

bit you just fix it. They want to know where 

they're going to be, and so they need a plan, but 

they're getting there. And I think, once they 

get to doing that, I think most people are going 

to start out with trying to take it as a 

percentage of that bird's requirement and see how 

it works and go from there.

 CHAIR BEHAR: Okay. Emily has a 

question.

 MS. OAKLEY: It's actually just a 

comment that I just see this as a positive 

example of continuous improvements within the 

Board's work, and I thank the Livestock Committee 

for looking at this issue. Yes, I just think 

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this is a bright spot in the organic process of 

continuous improvement.

 MR. PETERSON: I don't think I got it 

in there. We really do support coming up with 

something that is national because we don't 

dismiss the concerns that people would have over 

the synthetic methionine. It's not something 

that we dismiss. We talk to those customers 

every day. We have people that, I had a customer 

that's good friends with my cousin call, and this 

was quite a while, but he said we talk about 

methionine and he said how come I can raise my 

chickens and not have any methionine? I said, 

well, you do, it's in the, you know, but he never 

had the label and he didn't know that it was 

there.

 So we don't miss that risk of using 

it. We want the natural alternative. But it 

also has to be something we can use and be legal, 

for one thing, but also that we can use a sell a 

product that will work for people.

 CHAIR BEHAR: Okay. Thank you. 

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 MS. SWAFFAR: I have a question.

 CHAIR BEHAR: Oh, now Ashley has a 

question. I just want to say we are not too far 

behind but -- 

 MS. SWAFFAR: I have one question. 

One question.

 CHAIR BEHAR: Okay.

 MS. SWAFFAR: Just for reference, what 

is the most expensive ingredient pound-per-pound 

in your feed ration?

 MR. PETERSON: I'd have to look into 

that. I always think of the macro ingredients, 

so you're looking at the soybean meal, flax meal, 

but your trace minerals are going to be higher.

 MS. SWAFFAR: Methionine would be 

probably one of your most --

 MR. PETERSON: It might be. Honestly, 

right now, I couldn't tell you what the 

methionine costs in our rations, but I know you 

know so --

 MS. SWAFFAR: It is. It's the most --

 CHAIR BEHAR: Thank you, Chris. And 

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say hi to Ernie for me.

 MR. PETERSON: I will do that. Thank 

you.

 CHAIR BEHAR: Okay. Andrew Dykstra 

and then Pete Zambetti is on deck, and then Laura 

Batcha will be our last speaker after that.

 MR. DYKSTRA: Hello. This is my first 

NOSB meeting. I didn't know what to think when I 

was going to get here. I was here yesterday and 

today, and I'll be gone tomorrow. I was 

absolutely encouraged by what I saw and heard and 

everything that happened yesterday. I think the 

whole organic industry is completely unified, 

except I was actually disappointed as to what was 

happening there in Washington, D.C. In fact, 

they told me to be polite, so that's all I'll say 

about that.

 I'm an organic dairy farmer. I was 

one of the first ones in Washington state. 

Actually, about ten percent of us dairy farmers 

from the state of Washington that are organic 

will be coming through here and plus the one from 

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California.

 So I had some stuff written down and 

didn't know if it was going to be good. But now 

that I've thought about it from yesterday and 

today, I think it's 100-percent valid. Anyway, 

I'm grateful to have a chance to comment.

 Our family has been farming 

organically since 1989, since 2004 in the dairy 

industry, organic dairy industry. The third 

generation is making a stab at it now. One of my 

sons is a mechanical engineer, and the other one 

has a degree in agronomy. So I'm not coming with 

a lot of verbiage or proposed regulations. I'm 

here to speak to the origin of livestock, just 

like everybody else, and the integrity of the 

organic seal.

 I really hope that the unification of 

the organic industry that was created by the 

Idaho issue will actually help us out. Now we 

just need the will to solve the origin of 

livestock issue. We need the will to get 

everybody to be playing by the same rules. Right 

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now, I don't think we have the will.

 I will fight for the integrity of 

organics as long and as hard as I can. But, you 

know, when the rules are done, I'll abide by 

them. Hopefully, it's not a watered-down 

product.

 Back when we were still conventional, 

we missed 90 days of milk chuck one winter. Why? 

Because 95 days were decided, or 90 days were 

decided by the Russian State Supreme Court that 

milk was not an agricultural product under the 

Perishable Commodity Act of 1937. That's about 

as nonsensical as what Idaho state allowed 

regarding the origin of livestock and Washington, 

D.C.

 After financing and refinancing, the 

expiration of depreciation, and so forth, it took 

us about ten years to get out of that hole. What 

is happening to the organic dairy industry right 

now will also take ten years for dairy farmers to 

get out of. Why is it the whole ten years? The 

USDA NOP is in park regarding the origin of 

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livestock. Somebody once told me God can't steer 

a parked car. Well, we can't steer the NOP. 

Why? Because the NOP is in park. So with 

verbiage of regulation and the will to get out of 

park isn't there, in my opinion.

 It's not this administration or the 

last administration. Origin of livestock has 

been a frontrunner for dairy farmers for years. 

So please, let's not keep blaming Trump or Obama. 

Take ownership. This is a generational problem. 

Take the NOP and put it in drive. Once we're in 

drive, we can discuss language and regulations. 

Until then, smoke is blowing out of the exhaust, 

it's coming out from under the hood, the engine 

RPMs are at 9,000, people are seat-belted, but 

the transmission is still in park.

 Nobody can defend what's happening to 

the consumers today. I would dare anybody to be 

able to defend it to the consumers.

 The hole that we created, the ten-year 

hole that we created now is by having the 

transmission in park. Thank you very much. 

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 CHAIR BEHAR: Thank you. Any comments?

 (Applause.)

 CHAIR BEHAR: Any comments from the 

Board? Thank you, Andrew, very much for coming 

away from your farm. I know that is a difficult 

thing when you're a dairy farmer. And I also 

know how hard dairy farmers work.

 Okay. Pete Zambetti is up next with 

Laura Batcha, our last speaker of the day.

 MR. ZAMBETTI: Good afternoon, 

everybody and thank you for your time today, and 

thank you for the hard work you do. My name is 

Peter Zambetti. I'm a representative of Capsugel, 

a manufacturer of capsules, and we're here to 

talk about the fact that, talk about to the NOSB 

for allowing to add pullulan to the National List 

of 205.605 as an allowed nonagricultural, 

nonsynthetic ingredient used in tablets and 

capsules so they can continue to be made with a 

category in the organics system.

 Just an opportunity to review some 

history. In 2004, Capsugel, the company I work 

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for, submitted a petition that was put on hold 

and never acted upon. In 2018, the Handling 

Subcommittee found the petition sufficient. So in 

fall of 2018, a full Board discussion happened 

and several certifiers and manufacturers wrote to 

support this effort. The Handling Subcommittee 

also recommends adding pullulan to the National 

List.

 So I know those things have already 

been said. I just want a little further 

information on this. Today, there's no other 

NOP-compliant vegetarian option that exists for 

encapsulations. There are some organic gelatins 

available but not nearly enough to satisfy the 

demand of either the organic consumer or the 

organic vegetarian consumer.

 Capsugel continues to work to make a 

truly organic pullulan capsule, but it will be 

years until this is commercially available and 

quantities exist to suffice the market integrity.

 So now I will also make myself 

available for any questions, and any questions 

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that are really hard I'm going to defer them to 

the Organic Trade Association who helped us with 

this petition. So thanks very much.

 CHAIR BEHAR: Well, I thank you very 

much for finally helping us understand how to 

pronounce pullulan. So we all have to practice 

that.

 MR. ZAMBETTI: That's all right. 

Tomato, tomato, it's the same thing.

 CHAIR BEHAR: Well, we did butcher it 

pretty good on the subcommittee. Any questions 

from the Board? Thank you very much.

 MR. ZAMBETTI: Great. Panda and I 

thank you very much.

 CHAIR BEHAR: Okay, good. You took a 

panda. That was cute. All right. Laura Batcha 

is our last speaker of the day. I just want to 

say that we are at 5:51. We were supposed to end 

at 5:37, so that's not too bad. Okay.

 MS. BATCHA: Thank you, Harriet. And 

thank you to the Board and happy to be your last 

speaker of the day. 

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 We have a letter that Michelle is 

circulating to the Board that we sent to the 

administrator earlier this week at the 

Agricultural Marketing Services regarding these 

questions around glyphosate in container 

production, and we sent that letter because, 

before coming to the meeting this week, our 

membership, particularly our members that are 

involved in the produce supply chain, felt like 

it was extremely important to hear a 

clarification right out of the gate from National 

Organic Program around the absolute prohibition 

on glyphosate, but also the signers of the letter 

and our membership as a whole are in agreement 

that there's an urgent need for instructions to 

clarify how to apply the practice standard to 

containerized production systems and hydroponic 

production systems under the current USDA 

allowance for those systems.

 So some of the questions that have 

come up today have, you know, really reinforced 

that this is extremely important. We do not want 

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to leave this hanging out there to end up five, 

ten years from now doing a compliance project 

because there was an OIG investigation about 

whether or not the standards were being applied 

appropriately. We have an opportunity with some 

questions being raised to go to instruction.

 I appreciate the need for complaints 

in order to follow investigations, but I think 

instructions to clarify how to interpret the 

standards don't have to be coupled to a complaint 

process. And we continue to hear questions 

around land use history and transition. And I 

appreciate that the certifiers truly, for the 

most part, want to do the right thing. But if 

you're not asking for land use history when a 

barrier is being used, like plastic for container 

production, you simply don't know what you don't 

know. And I think the instructions about how to 

interpret the rules could really help get 

everybody on the same page and do the right thing 

because that's doable in a timely manner, and we 

look forward to assisting with those discussions 

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as best we can.

 In addition to the land use history, 

there are areas that need to be dug into in terms 

of natural resources, the use of plastic. 

There's a lot of questions about really looking 

back at the Organic Foods Production Act, as well 

as the national listing on plastic, to ensure 

that those rules are being followed as well, and 

uniformly.

 The last thing that I just want to 

flag for you all is something that's not on the 

agenda but we see a lot of energy in the 

marketplace around hemp production and CBD in 

food products, particularly food grade I'm 

talking about. We have an opportunity over the 

next couple of years for organic to really 

capture market share in the food grade hemp, and 

I want to flag a few things. You know, we know 

we have the standards in place for crop 

production and handling. This is a no-brainer.

 I'll say one thing and then -- no CBD 

on 606. That's what we're concerned about, and we 

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want to put a marker out early that we want to 

drive this market to organic and really 

discourage entertaining any petitions around CBD 

on 606.

 CHAIR BEHAR: Okay. Any comments? I 

have Scott, Steve, Asa. Okay, go ahead.

 MR. RICE: Laura, you talked yesterday 

at the NOP meeting about, kind of related to your 

earlier comments of continuous improvement and 

some ideas about how to keep that moving forward. 

Could you share those with us for the folks that 

didn't hear that yesterday?

 MS. BATCHA: Sure, Scott. And I think 

some of it is relevant to the discussions that 

we're talking about about the need for some 

instruction around interpreting the standards for 

container production and hydroponic.

 On that topic, I failed to sort of 

reaffirm the Trade Association's support of the 

2010 NOSB recommendation to prohibit hydroponic 

and allow container production, and we had hoped 

that that process would have moved forward in 

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terms of the development of robust standards 

there. But we've taken a step back as we're 

seeing these issues come at us repeatedly, and 

you hear a lot of this from commenters.

 So how do we think about evolving the 

way the public-private partnership functions in 

terms of an affirmative obligation for USDA to 

move forward with NOSB recommendations? How do 

we create an environment where this voluntary 

opt-in standard has a little bit more flexibility 

and speed as it moves through government 

regulatory processes? And in addition to that, 

how do we think about what's next in the 

evolution of the accreditation process, 

specifically as it relates to outcomes?

 And, you know, we heard some good 

reports from the program at the meeting yesterday 

around the peer review audits, and we heard Jenny 

speak about that this morning, and that's great. 

But we think there's even more you can do around 

outcomes that are really around the relationship 

between NOP and the certifiers and requiring full 

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sort of compliance to outcomes via accreditation. 

 So examples of that might be, Scott, 

requiring that on an issue everybody articulate 

what their policy is so that NOP can quickly 

determine if there's conformance across the board 

on a question that comes up. Is there a way to 

establish annual reporting from the ACAs to NOP 

about what the certifiers have done to implement 

any new regulations, guidance, handbook updates, 

instructions over the course of the last year so 

that there's a check-back, is everybody doing, 

you know, what we put out there?

 You know, we have to remember that 

there are a lot of certifiers that are not 

operating in the United States. They don't show 

up at these meetings. It's a global program, and 

so how do we get real full visibility, not just 

audit visibility, on what's happening?

 And I think one of the last ideas that 

we have around the outcomes is, you know, 

requiring mandatory participation in trainings. 

Whether or not they're through that amazing 

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Organic Integrity Learning Center that the 

program just launched or whether or not they're 

in-person trainings or whatever, a lot of these 

issues get resolved by the National Organic 

Program investing in training, and we need to 

make sure that there's mandatory participation in 

those trainings.

 The last idea we had is a little bit 

more creative and sort of pushing the envelope a 

little bit, but it's the idea of establishing an 

interpretative review panel so that when 

questions come up about how to apply the full 

practice standard to a unique circumstance that 

certifiers are starting to see as a new 

production system comes into the marketplace, 

that there could be a convening to look at the 

whole standard and say what applies, how do we 

think about it, is there a reasonable place where 

there's consensus about the answer to the 

interpretation? And if there is, then NOP could 

go ahead and issue instructions.

 So this is like a proactive approach 

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to prevent some of the circumstances that we're 

experiencing now. If the interpretation is 

unclear or the results of that inquiry point to 

the need for a new standard, then that could get 

referred to the Board and get put on the National 

Organic Standards Board work plan. But it's a 

way to be more proactive about driving consistent 

interpretations.

 CHAIR BEHAR: So next was Steve.

 MR. ELA: Yes. I'm going to save 

Jenny on this one and turn it to Scott. So when 

you said that you talked to the certifiers about 

the issue of, like, the glyphosate and things, 

did that cover, like, spraying something down and 

putting plastic over it and then putting pots on 

it, or was it just -- I guess what was the 

question that was asked?

 MR. RICE: It was more a response to 

just the news that was coming that Jenny has been 

responding to in terms of that we've all been 

kind of hearing this week of spraying and then 

allowing production and at, I would say again, 

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without a specific case and without, you know, 

knowing details, you know, I'm not trying to move 

away from answering, just, on its face, we 

wouldn't allow that. That was the gist of that 

consensus.

 MR. ELA: And so even if plastic was 

laid down on top of the ground and there was 

theoretically a spatial differentiation, that 

wouldn't be allowed? And I'm not trying to put 

you on the spot.

 MR. RICE: You know, I don't think the 

conversation even went to that. It was just a 

reaction to spraying glyphosate, would this be 

allowed, no, it would not be allowed.

 CHAIR BEHAR: Okay. Next, I have Asa. 

Later? Next I have Tom. Is he ready to go? 

Ashley? Who wants to go?

 MR. CHAPMAN: I'm ready, I'm ready. 

Laura, transitioning to another topic, I really 

appreciated the OTA's detailed comments on the 

fraud initiatives and opportunities there. I 

also want to take this quick opportunity to thank 

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OTA for the leadership in terms of the fraud 

initiative it's taken with industry and trying to 

put preventative practices out there in the first 

place to root it out before enforcement is 

necessary, so thank you for that.

 But going back to your comments, you 

mentioned the 2018 farm bill and new authorities 

that were given to the National Organic Program, 

and that those authorities were not potentially 

there when we did our work in 2017 or 2018. And 

so I guess could you provide some examples of 

what those authorities are and maybe some of 

those opportunity areas for the NOSB and the NOP 

to work on that?

 MS. BATCHA: Sure. Thanks, Tom. I 

think first thank you for the recognition of the 

fraud prevention program, and I want to recognize 

that really all of the hard work on that 

development was led by Gwendolyn Wyard, VP of 

technical services. So when she's at the podium 

tomorrow, you can all give her a round of 

applause, and her and a very large industry task 

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force did some major heavy lifting on what we 

think will be an important private sector 

advancement. So thank you for that.

 Megan is going to talk a little bit 

more about sort of, comprehensively, what's in 

the authorities from the farm bill and how to be 

thinking about that. I think the one thing, a 

couple of things that I would share with the 

Board is, you know, make sure you take a look at 

it. We attached it to our comments as well, 

because there are authorities within the farm 

bill that the National Organic Program is able to 

use right out of the gate. They don't require 

regulatory action. They're authorities that they 

are utilizing now and a number of them that are 

funneling into this rulemaking that they're 

doing.

 Before I share my thoughts about where 

NOSB could add value in terms of this 

conversation going forward, because we know those 

two things are in play, I want to just say, you 

know, I understand, to the staff at the National 

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Organic Program, that we demand a lot of you guys 

and we can be hard on our issues because we care 

so much about the integrity. There is a 

marketplace out there that relies on these 

clarifications, and so we often all come up here 

and we're really focused on the things we need 

you to do, and we're really focused on the ways 

we need you all to do your best to help us move a 

political machine at times.

 But I don't think we've done enough 

today to thank you for the tremendous lift you 

guys have done on enforcement of feed grains 

coming into this country. To see that data this 

morning is remarkable, and, you guys, we owe you 

a debt of gratitude. You've applied creativity, 

full effort, prioritization to that task. And so 

I would be remiss to not take a moment and say 

that because really shutting down that flow out 

of the Black Sea, that is not an easy task.

 That leads into my, like, how do you 

guys think about adding value? You know, we're 

now in the United States, I believe, in a 

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position where we are ahead of the rest of the 

world in global enforcement, and that wasn't the 

case five years ago. And some of the things that 

put us in that position are our commitment to 

transparency in the system so that work, early 

work on the integrity database that's moving into 

this realm where we can see a future where, we 

just heard it this morning, mandatory reporting 

on acreage available to the public. There will 

not be a program in the world that has that kind 

of transparency about information to provide the 

public assurances and investigate things.

 So we've got to continue to follow 

those threads around transparency and then ask 

what happens when we're way out ahead of the rest 

of the world on transparency, on data, and it's 

not happening at other places.

 So I think places that you guys could 

be thinking about, you asked the question this 

morning, Tom, about, you know, encouraging 

communication around complaints. I think with 

NOP about to stand up this new database system 

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around complaint management, there's an 

opportunity for a conversation between the Board 

and the program about, within the parameters of 

protecting investigations and not exposing things 

that derail investigations, how far can we go to 

create transparency proactively? The farm bill 

does require that the program report annually to 

Congress on compliance activities, and so, you 

know, how do you build off of that, work with 

their new database systems, and come up with some 

recommendations about what you all think, with 

input from the community, should be an 

appropriate level of transparency around 

complaints.

 I think another area that we've looked 

at but we haven't come to a solution and the 

Board could maybe spend some time on it is: is it 

viable to develop some sort of trade alert 

system? You know, we know that the farm bill 

provides the authority to adopt a risk-based 

approach and to apply additional scrutiny under 

certain circumstances. We know the program is 

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obviously using a risk-based approach in their 

compliance, or we wouldn't be seeing the kind of 

results that we're seeing. But is there a way 

that is acceptable within protecting business 

confidentiality that, when things like the 

revocation of the accreditation of a certifier in 

an office in a region of concern happens, that 

there could be some sort of alert to say look 

sharp. You know, it doesn't need to disclose 

perhaps information that would compromise an 

investigation, but I think that whole idea of a 

trade alert system is new and requires some 

consultation.

 I think, you know, you've worked with 

the California Organic Products Advisory Council 

a lot. They've got a different approach to how 

they disclose complaints and stuff, so there's 

probably something to learn there as well. But I 

think those are both areas that the Board could 

really dig in on and provide a service to the 

industry and the public and the consumer.

 The other place that I would just flag 

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is that, as we're getting ahead of the rest of 

the world in transparency, it creates a situation 

where, until very recently, I think that the 

widely-held belief was that having an equivalence 

arrangement with another country with a net 

positive in terms of oversight because there was 

a government-to-government relationship that NOP 

could leverage to share information. But we have 

to contemplate, if we've got all this 

transparency in our database and we've got all 

this acreage and then we have an equivalence 

arrangement with Canada, and stuff is coming in 

under the arrangement and not under a direct 

compliance regime, we all of a sudden have 

opacity around acreage there and where those 

volumes are coming from, and we have opacity 

about something coming in from the EU.

 So as we've advanced our system, that 

needs to be looked at in my opinion, because 

we're pushing really hard as an industry. I 

mean, it's a big deal that we'll be the first in 

the world on mandatory public acreage reporting. 

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It's not -- that's a big, big deal, so I 

encourage you guys to think about that, as well.

 CHAIR BEHAR: Okay. Did Ashley have 

something? No. Asa? I did have one just 

comment that not only in the scenario where the 

glyphosate came up, there was also the land had 

been laser-leveled, you know, kind of scraped and 

then compacted and then herbicide and then 

plastic. And so I know the herbicide, you know, 

that's clear, you know, prohibited substance, but 

there's also something to treating the soil and 

turning it into concrete basically, you know, 

having it flat.

 That also is something that does not 

meet the rule, so, you know, so there's just this 

whole system of production that relies heavily on 

-- and this is not, like, on a half an acre. 

This is on 20, 30, 40 acres of complete landscape 

cloth. And even though it is somewhat -- it's 

woven, you know, so it does allow some air and 

some water infiltration, it's not the same as 

rain hitting grass or even soil. It runs off and 

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things like that.

 So there's just the greater system, 

and it's easy for us to jump on the glyphosate 

but there's other issues as well, when we're 

relying on covering the ground with many, many 

acres with solid plastic.

 MS. BATCHA: Yes, I totally appreciate 

that, Harriet. And that's why I think our 

suggestion is to sort of take a step back in 

those instructions and point to the different 

places in the standard that you need to be 

thinking about and how to apply them to different 

scenarios.

 You know, I appreciate the program's 

need to collect information, but I don't think we 

need to know everything everybody is doing to 

know what the regulations allow and don't allow. 

I think we just have to know enough to identify 

scenarios, and those scenarios can inform 

instructions.

 CHAIR BEHAR: Okay. Thank you. Oh, 

Asa is back. 

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 MR. BRADMAN: Yes. So I had a few 

comments. One, I think your approach to try to 

develop a system to anticipate and solve problems 

is really important. I think it's something that 

we should try to move ahead with, both as a 

program and also independently under the NOSB.

 To the issue of hydroponics and 

container growing, you know, I think we really do 

need some standards. Echoed just briefly by what 

Harriet just said, during the debates around the 

2017 votes I asked for, you know, those kinds of 

standards from some of the growers involved and 

really didn't get anything. CCOF did come up 

with a proposal that doesn't get into the nittygritty, but I think that there's a work agenda 

item both within the community and the NOSB to 

think about and develop some standards.

 And there's complexities. Harriet 

just mentioned issues around rain falling on 

soil, you know. I've seen many soil-based 

programs with big hoop houses, and they're 

planted in the ground but none of that rain is 

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falling on the soil. I've also seen big 

greenhouse operations in Maine or in the 

Northeast, where again it's a very controlled 

environment, it's in the ground, but the rain is 

not getting into that soil.

 And I think that there's really a lot 

of challenges here, but I think we can move 

forward and that there may be practices that are 

going on now that wouldn't be in a final 

standard, but I think there's been neglect to 

think about standards, and rather there's been an 

approach to ban a category, and I think that to 

move forward, that we need to think about a 

little differently and look at what we might want 

to make something acceptable. And I know that 

would be challenging, but I think that could be, 

to quote a recent suggestion, kind of a middle 

path forward.

 MS. BATCHA: Yes. And I think that 

that doesn't preclude the need for immediate 

instruction on what we know now and what we have 

no for the standard. And I think as I look back 

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at the debate, the recommendations, at least at 

the time that were moved forward for voting, were 

really much more about what was happening in the 

pot than what was happening on the farm. And 

maybe we weren't asking fully the right set of 

questions at the time.

 MR. BRADMAN: And, finally, to move 

forward, maybe, you know, I look at some of the 

signers on this letter, you know. Maybe we could 

convene a group that not just includes these, 

these are all pretty large producers, but perhaps 

on a regional basis or some other basis can 

really develop a template for an approach to 

developing standards. I think that would be a 

very positive move.

 CHAIR BEHAR: Well, thank you. And with 

that, I don't think I can use the gavel. That's 

only at the very end, but this just looks -- it's 

just calling to me. Anyway, thank you for the 

end of the day, and tomorrow morning, 8:30 a.m.

 (Whereupon, the above-entitled matter 

went off the record at 6:14 p.m.) 

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446:7 

anomaly 13:14 

anonymous 299:7 

anoxia 177:3 

answer 124:12 155:6 

168:20 188:11,12 

203:11,16 231:12 

249:16 257:22 310:2 

317:3 327:2 359:13 

360:2,3 386:11 

392:18 398:19 399:4 

411:16 414:5,8 

439:19 

answered 165:7 166:1 

185:21 322:11 

answering 78:1 156:20 

305:12 441:3 

answers 22:14 

anti- 225:1 

antibiotics 262:17 

anticipate 160:5 192:8 

451:3 

antimicrobial 168:5 

antioxidant 168:4 

antiseptic 175:11 

anxiety 192:16,18 

anybody 268:8 300:4 

386:12 429:18 

Anytime 419:16 

anyway 187:7 427:5 

453:19 

anyways 192:8 

apart 177:21 196:19 

305:20 

aphid 277:16,19 278:7 

aphids 277:13 278:4 

APHIS 46:22 52:2 54:22 

55:21 56:16 

apiary 408:7,22 409:16 

apiculture 25:15 412:12 

apocalypse 389:2 

apologize 15:4 277:7 

305:2 340:21 

Appalachian 5:13 

apparent 158:6 343:1 

apparently 273:14 

appeals 68:1 

appear 381:13 

appearance 285:13 

appears 245:8 

applaud 244:9 

applause 8:21 31:17 

96:15 204:12 237:14 

286:12 303:14 327:1 

329:17 343:9 348:12 

356:21 361:3 391:8 

401:14 430:2 442:22 

apple 119:5 

apples 17:3 

applicable 79:17 

265:12,14 

applicant 264:3 

application 43:5,18 

119:9 135:9,10 146:9 

182:11 183:1,2 

186:18 189:1 403:5 

applications 43:19 

132:8 133:5 143:17 

143:19 149:2,13 

265:13,14 

applied 78:15 125:19 

132:14 145:4 183:8 

375:10 400:20 434:4 

444:15 

applies 33:21 263:20 

439:17 

apply 42:20 43:1 69:7 

76:10,14 123:2 144:9 

144:16 166:17,18 

306:19 318:9 433:16 

439:12 446:21 450:12 

appreciate 15:2 16:12 

20:19 82:4 83:20 92:4 

93:19 95:7 106:21 

208:16 237:11 279:3 

281:8,13 331:10 

351:12 370:2,4 379:9 

390:18 402:16 417:20 

434:7,13 450:7,14 

appreciated 5:18 74:18 

74:20 340:14 441:20 

appreciates 243:22 

244:13 

appreciation 308:11 

approach 50:14 89:11 

126:5 194:14 245:3 

245:14 253:17 260:10 

263:2 290:20 311:10 

407:5 439:22 446:21 

447:1,16 451:2 

452:12 453:13 

approaches 8:1 37:16 

53:20 146:10 

approaching 336:22 

appropriate 135:17 

136:2 142:9 201:6 

345:22 364:9,12,21 

406:5 446:13 

appropriately 434:5 

appropriations 98:15 

approval 24:3 157:15 

approve 256:1 

approved 201:4 256:19 

270:1 282:14 319:22 

320:14 

approving 262:10 

approximately 32:2 

159:13 270:5 

April 1:9 39:12 44:10 

99:14 

aquaponic 355:17 

356:15 

aquatic 412:13,18 

413:13 

area 26:5 36:15,18 

59:15 133:12 142:12 

146:6 150:14 156:14 

230:21 234:17 236:18 

237:3 244:7 261:11 

273:22 379:13 415:8 

418:3 446:15 

areas 23:15,19 24:11 

25:6 26:2 27:4 36:11 

36:13 46:14 58:22 

62:21 76:21 150:5 

162:4 212:17 237:2 

257:4 265:13 379:5 

435:3 442:13 447:19 

arginine 171:10 

argue 394:10 

argued 109:19 

argument 301:12 347:1 

arguments 85:19 86:13 

86:19 87:6 88:1 

Arkansas 9:19,22 

261:18 

arrangement 448:5,12 

448:13 

arrived 55:16 

Arsenault 2:1 6:13 

240:20 241:6,9 

242:19 

articles 207:1 

articulate 86:9 87:1 

389:22 402:14 409:13 

438:3 

articulated 87:7 88:2 

articulating 346:16 

artificial 371:16 

arts 285:19 

as-is 169:7 

Asa 1:16 10:21 115:5 

204:14,14 205:2 

314:5 318:1 417:10 

436:6 441:15 449:4 

450:22 

ascertained 359:11 

ascorbate 191:1 

aseptically 188:1 

Ashby 387:11 

Ashley 1:22 9:17,18 

84:18 232:18 257:11 

337:21 408:3 411:5 

412:7 413:7 425:2 

441:17 449:3 

Asian 130:4 

aside 112:12 

asked 32:22 33:2,11 

82:6 144:15 220:7 

238:4 242:7 289:11 

304:11 320:11 322:11 

322:15 332:17 340:15 

340:22 341:9 343:16 

371:2 398:16 408:4 

408:15 410:17 440:17 

445:19 451:11 

asking 60:10 66:11 

160:1 183:20 251:12 

264:2 276:19 295:18 

316:17 322:2 323:3 

327:11 341:13 342:22 

342:22 358:10 377:21 

382:22 384:1,8 

392:19 406:14,15 

434:15 453:5 

asks 407:1 

aspect 130:21 163:22 

164:3 182:7 194:21 

314:13 

aspects 75:9,14 76:6 

121:12 124:9 135:21 

138:13 194:22 225:12 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
457 

assembled 136:21 

assert 94:14 

asserts 255:6 

assessing 34:21 

254:22 

assessments 68:21 

69:6,12 

asset 15:16 

assign 64:19 

assigned 60:12 70:5 

198:2 239:4 

assignment 66:8 

assist 105:1 402:1 

assistant 14:4 44:19 

45:10 58:9 117:19 

121:3 206:17 

assisting 434:22 

associate 2:2 5:4 41:10 

157:22 279:22 356:7 

associated 248:16 

362:17 370:20 

association 10:7 45:2 

72:21 121:20 178:19 

269:17 349:18 353:19 

395:12,15,22 401:22 

411:13 412:3 432:2 

Association's 251:19 

436:19 

assuage 259:22 

assume 10:17 91:15 

186:10 286:18 371:5 

assumption 103:20 

assurance 65:11 

assurances 445:12 

assure 192:15 

assured 159:8 238:18 

assuredly 192:22 

ate 178:21 

atmosphere 354:4 

355:2,6,12 

atmospheric 355:19 

attached 189:14 443:10 

attack 389:19 

attacks 242:8 

attain 384:18 

attempt 97:18 

attempting 123:2 

362:20 

attempts 352:15 

attend 116:17 

attended 5:6 9:4 

attending 44:3 

attention 163:8 308:13 

358:7 379:14,20 

attorney 383:12 

attract 277:20 

attracted 277:14 278:5 

attracting 18:5 

attribute 143:21 419:6 

audacious 18:8 

audible 5:22 13:11 

audience 65:7 113:3 

audit 438:18 

auditor 58:12 

auditors 43:7,8,12,16 

57:6,7,10 58:13 

audits 57:14 68:10 

379:20 380:2 437:18 

August 10:16 419:16 

authenticity 385:11 

author 206:21,22 

authorities 442:7,9,12 

443:6,11,14 

authority 384:18,19 

385:2,14 391:2 394:6 

394:16 446:20 

auto-enrolled 65:19 

automated 55:20 

automatically 65:18 

availability 14:11 

163:16 224:21 225:11 

246:18 256:17 272:7 

298:11 316:2 350:13 

352:4 375:19 

available 56:1 104:18 

110:22 124:13 127:13 

135:6 141:10 148:11 

163:16 168:22 200:16 

200:19 215:10 216:3 

221:16 222:22 223:14 

224:14 225:4 228:16 

246:7 253:20 271:4 

281:2 300:3 317:3 

332:9 338:3 351:2 

352:10 375:7 431:14 

431:19,22 445:9 

average 17:17 18:4 

51:9 106:6 107:19,20 

226:4 237:7 270:16 

419:1 422:8 

averaging 421:6,14 

Avila 44:14 

avocado 12:17 

avocados 111:14 

avoid 149:9 245:1 

275:2 285:19 

award 37:22 45:3,4,8 

73:14,19 74:7 

awarded 125:20 

awards 70:8,10 71:6,13 

73:13 183:15 

aware 165:22 169:20 

178:6 331:9 359:18 

362:14 364:4 405:9 

awareness 54:21 

awe 29:12 

awful 50:1 90:2 

B

babies 176:3 

baby 29:21 176:5 

bachelor's 14:20 

118:13 119:19 

back 10:16 13:18,21 

14:2 15:4 36:10 75:12 

82:12 85:11 87:8,9 

114:20 121:18 123:7 

139:7 150:1 170:10 

173:11 178:1,7 

195:13 201:10 205:7 

205:7 214:3 216:15 

230:7 239:15 250:14 

301:6 303:5 304:17 

320:3 322:4 340:9 

341:22 342:13 343:19 

344:17 345:4,8 349:7 

352:17,18 375:2 

382:14 405:9 406:4 

421:15 428:7 435:6 

437:2 442:6 450:9,22 

452:22 

backbone 271:20 

background 70:9 119:3 

177:21 208:11 211:10 

256:12 257:6 266:2 

backs 246:12 

backyard 243:20 

bacon 139:17 190:11 

190:15,21 191:13 

bacteria 173:13 175:14 

176:20,20 223:13 

bacterial 142:15 147:7 

147:19 200:16,21 

bactericidal 174:7 

bad 219:11 239:12 

248:15 284:7 385:20 

387:4 432:19 

Badger 327:18 331:12 

331:13,14 335:3 

badly 204:2 

bag 192:15 193:9 

293:21,22 

bagged 418:10,13,14 

419:3 

bailiwick 372:8 

Baird 1:15 10:5,5 250:3 

252:3 294:14 295:4 

298:10 

balance 68:9 215:2 

228:8 

balanced 321:12 323:2 

Ballroom 1:11 

ban 452:12 

Bar 10:2 

barn 214:10 235:8 

416:16 419:12 

barns 419:17,22 

barrel 211:21 212:1 

214:3 221:6 

barrier 434:16 

barriers 191:22 

Barrington 10:11 

bars 130:15 

base 73:15 357:16 

362:14 

based 24:22 34:22 35:2 

42:14 43:9 63:3 71:6 

76:2,3 84:1 109:4 

118:2 169:19 185:9 

220:17 222:22 234:20 

248:3 260:9 265:15 

269:21 273:12 315:7 

317:1 319:22 331:17 

356:3 361:17 365:7 

391:19 421:14,18 

422:18,19 

baseline 74:11 250:19 

basic 363:14 

basically 66:7 188:14 

214:5 313:18 449:12 

basis 33:11 97:2 160:17 

166:15 169:8 181:20 

186:2,2 190:2 233:16 

239:4 282:17 359:17 

384:3 453:12,12 

basket 30:2 

Batcha 426:6 430:9 

432:16,20 436:13 

442:15 450:7 452:19 

Beach 56:19 

bear 354:3 

beards 13:16,20 

bears 160:10 

beat 17:11 

beautiful 9:7 22:22 

334:13 

beautifully 23:1 

beauty 29:12 

becoming 294:2 349:21 

362:19 

beef 156:7 

beekeeper 410:7 

beep 241:3,4,6,10,14 

beet 135:13 

beets 126:17 

began 16:5 100:19 

402:5 

begged 301:17 

beginning 73:16,21 

148:10 218:5 241:19 

294:7 382:19 

begins 251:18 402:20 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
458 

begun 105:4 

behalf 250:21 

behavior 419:5 

belabor 93:22 319:10 

belief 448:4 

believe 20:4 29:1 48:19 

59:15 86:4,9 95:13 

104:21 111:9 135:14 

141:9 150:2,15 197:5 

198:6 228:4 230:12 

231:20 240:18 246:8 

247:19 251:2 267:11 

275:4,16 277:17 

278:8 281:4 304:4 

347:9 360:2 362:3,4 

366:10 383:20 391:22 

394:11 396:6 444:22 

believes 45:16 397:13 

399:18 

bell 55:7 56:2 

Belmont 10:2 

Beloit 118:19 

belong 326:1 

belt 96:6 

beneficial 174:3 317:8 

321:20 

beneficials 356:5 

benefit 63:16 151:21 

187:16 199:7 267:1 

267:20 274:20 318:12 

326:15 

benefits 166:12 168:3 

199:6 201:15 266:10 

271:12 317:10 320:15 

342:9 404:12 

benefitted 322:21 

Berkeley 11:2 

berries 284:13 

Bert 323:11 

best 20:13 45:5 66:16 

77:9 83:22 88:5 

127:19 132:1 158:12 

245:1 248:12 251:21 

256:15 298:19 350:5 

393:9 435:1 444:8 

better 18:15 26:1 40:11 

41:5 49:9 58:20 69:6 

69:8 92:7 105:3 

116:13 122:15 135:1 

135:19 136:2 147:18 

153:4 166:2 202:12 

211:4 326:19 359:2 

416:9 

beyond 18:2 155:16 

158:16 280:19 301:22 

334:5 360:4 367:18 

372:7 387:22 391:11 

392:13 393:8 396:12 

bi-modal 109:13 

biannual 13:7 

big 16:21 85:12 89:1 

92:5 210:18 221:15 

222:22 225:12,13 

235:12 253:17 372:13 

448:21 449:1,1 

451:21 452:1 

bigger 26:3 183:3 247:4 

355:4 

biggest 355:4 

bill 37:12 46:1,9,12,17 

47:16,22 48:2,3 63:5 

384:13 442:7 443:6 

443:12 446:6,19 

billion 106:2 107:11,20 

155:19 

bills 271:9 

bind 176:10 177:2 

binds 167:21 

bio-diversity 83:9 

biochemistry 119:20 

167:3 

biodegradable 8:11 

biodiversity 23:8 

242:17 389:1 

biological 138:11 

167:17 173:21 202:16 

356:8 403:1 

biologically 163:19 

176:10 

biology 118:5 207:13 

285:20 

biomass 182:8 

bios 117:3 

bird 211:12 232:4 

235:19 236:9 419:12 

421:1,14,18 

bird's 217:1 422:1,5,10 

423:14 

birds 210:16 211:12,19 

212:5 214:5,6 217:7 

217:17 219:11,22 

222:2,7,16 223:8 

225:17 229:21 231:16 

233:6 234:2,8 235:6 

235:13,15,20 236:5,8 

236:13,21 390:13,14 

419:7,14,19 420:3,5,7 

420:12,15 422:18 

birth 176:14 

bit 7:5 13:13 17:12 

18:13 63:2,6 70:9 

87:13 89:5 90:11 

95:16,19 104:16 

106:14 110:19 111:20 

115:15 138:9 148:9 

165:12 196:21 204:1 

213:7 218:5,11 220:8 

228:14,15 233:5 

239:18 240:15 258:1 

275:14 278:11 285:9 

285:22 299:3 331:17 

352:22 382:17 423:9 

437:10 439:8,10 

443:4 

BJ's 329:9 

black 50:18 53:2 54:10 

54:15 210:10,20 

215:18 225:8 285:19 

364:3 365:12 444:19 

bladder 348:14 

blaming 429:9 

blanched 141:19 

blending 226:16 227:8 

blight 262:18 

blindness 214:11 

blisters 219:10 

blocks 218:16 255:8 

blood 171:3,16 173:9 

176:11 310:22 

blow 154:10 

blowing 429:13 

blue 176:5 

blueberries 261:17 

273:13 274:1 

blueberry 268:20 

273:19 

board's 19:20 35:19 

237:20 358:6 360:13 

379:14 380:15 423:21 

Bob 335:5 340:1,4 

343:10 

body 53:17 171:10,21 

172:1,22 173:2 

201:14 231:17 246:2 

251:3,4 

boil 218:6 

bolts 128:5 

bone 310:22 

book 16:8 207:1 

boon 318:10 

boots 52:7 

border 41:13 46:19 

47:6 243:10 320:3 

borders 384:5 

born 176:13 324:10 

boss 331:5 

bottle 342:12 

bottlenecks 122:16 

bottom 30:2 73:20,20 

212:22 213:9 220:13 

botulism 168:7 178:9 

bought 325:12 

bound 26:8 

boundaries 79:5 

bowl 30:8 

box 143:8 364:3 365:12 

boxes 55:9 140:10 

141:4 

BPA 25:12 372:1,16 

390:9 

Bradman 1:16 10:21,21 

115:5,7 137:14 138:2 

151:4 152:15 161:18 

162:5 164:19 176:1 

177:11,14 184:1,21 

185:18,22 188:13 

196:20 200:2 203:9 

203:22 205:4 290:14 

290:17 313:2 317:21 

318:2,19 319:2,4,7 

417:1 451:1 453:7 

brand 69:1 154:17 

157:22 

brands 284:14 290:9 

336:17 337:1 366:4,5 

brazil 210:4 216:10 

224:10 

Brazilian 216:4 

break 73:13,16,21 

114:17 162:13 326:9 

348:21 

breaks 59:10 239:18 

274:12 

breast 219:10 

bred 245:21 281:6 

breed 220:13 324:14 

422:18,19 

breeding 244:11 281:1 

282:8 380:19,21 

381:2 

breeds 220:6 221:12,16 

233:1 

breeze 218:13 

Bregendahl 2:8 3:17 

206:11,11,21 207:3 

207:10 211:7 228:10 

233:22 234:4,11 

235:4 

Brenda 16:8 

Brenda's 16:10 

bricks 186:8,10 187:13 

187:21,22 

bridge 391:20 

brief 116:14 117:10 

151:2 175:20 314:7 

363:11 

briefly 152:15 315:19 

369:7 451:9 

bright 107:2 424:1 

bring 6:16 35:3 136:15 

150:1 160:9 193:14 

199:16 324:14 343:2 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
459 

359:4 370:12 380:6 

401:9 419:9 

bringing 41:11 183:5 

195:5 199:19 204:21 

340:9 408:22 

brings 48:1 

Briones 12:2 

broad 19:20 90:22 

351:22 

broader 117:13 177:12 

broadly 319:2,4 

broiler 207:20 209:11 

broilers 220:15 221:1 

231:18 233:3,11,12 

234:2 418:19 

broken 76:21 112:5 

173:3 399:19 

bromide 263:15 

Brook 9:21 11:20 

Brookhaven 11:20 

brother 328:22 

Brothers 268:7 269:2 

brought 5:20 20:19 

29:14 30:8 208:14 

275:5 302:7 313:3 

343:4 372:17 378:9 

Bruce 227:1 

budget 14:14 38:17 

86:17 344:12 345:2 

bugs 285:15 

Buie 1:16 11:19,19 

112:11 260:14 261:21 

275:11,19,22 276:5,9 

build 80:12 136:9 

220:19 221:5,6 

269:19 312:3 446:9 

building 40:10 79:15,17 

94:19 127:8 218:15 

218:18,18 396:5 

built 14:17 49:11 70:18 

79:14,16 

bulk 56:9 66:7 418:3,6 

419:8 

bullet 155:13 

bumped 74:4 

bunch 222:14 329:4 

burden 252:15 253:18 

buried 239:11 

Burley 2:9 3:18 207:11 

207:21 218:3 227:10 

230:2 231:13,22 

232:7 233:9 234:3 

burning 375:11 

burnout 223:16 

burns 214:9 

business 31:15 51:21 

90:5 163:10 182:21 

195:18 331:1,6 

334:14 335:17 342:4 

417:17 447:4 

businesses 31:12 32:5 

85:9 92:13 102:18 

254:4,9 

butcher 432:10 

butter 359:20 366:2,4 

buy 157:21 247:13 

338:8 366:4 

buyer 339:11 

buyers 162:20 253:8 

359:18 

buying 252:14 264:15 

buzzing 241:7 

by-weight 159:15 

C

C 190:19 

C.F.R 189:20 

cabbage 149:6 

CACS 10:8 

calcium 423:7 

calculation 159:15 

calculations 68:9 

calf 324:9,11 

California 10:2 12:5,7 

12:18 14:21 17:11 

72:14 134:17,18 

162:3 427:1 447:15 

call 3:2 7:3 37:13 47:22 

48:5 168:1 238:22 

239:14 242:12 287:21 

291:17 301:7 339:20 

344:1 379:15 383:5 

397:9 398:18 401:4 

405:1,12 424:10 

called 30:9 46:17 75:19 

159:14 171:2 178:13 

226:20 250:17 324:4 

325:3,13,18 330:16 

339:15 

calling 124:22 251:3 

453:19 

calls 30:7 44:15 274:16 

281:21 384:6 398:6 

calve 324:8 

calves 324:9 

Canada 206:16 448:12 

cancellations 239:6 

cancelled 325:15 

cancer 169:22 170:2 

cancer-causing 201:13 

cannibalism 219:2 

canola 215:11 228:15 

capabilities 49:10 

capability 104:16 

142:16 151:17 

capable 153:8 

capacity 142:2,10 

353:18 363:10 

capped 43:3 

Capsugel 430:13,22 

431:17 

capsule 431:18 

capsules 430:14,19 

capture 435:17 

capturing 98:2 

car 429:2 

carbon 355:1,7,12,15 

355:19 

carcinogens 170:1 

care 249:13 393:3,4 

415:7 444:2 

careful 261:19 

carefully 59:9 79:21 

266:6 267:16 314:2 

cares 364:1 

Carol 383:10 386:17 

Carolina 269:16,20 

270:17 272:2 316:21 

Carolinas 271:17,19 

272:11 

carried 156:18 415:1 

carry 251:4 

case 33:4,9,14,17,22 

38:19 60:20 61:16,16 

115:20 159:1,22 

170:9 239:5 260:1 

262:11 267:6 279:1 

284:12 305:22 310:18 

311:11 312:3 332:22 

333:2 356:1 358:9 

394:10 398:17 399:9 

399:13 400:6 401:8 

411:21 441:1 445:3 

case-by-case 33:11 

case-specific 399:21 

cases 23:12 40:17 

49:13 57:16 157:9 

227:18 284:4,7 

399:17 400:3 409:11 

cash 316:5 

Cashton 417:15,16 

catalogue 268:7 

catch 27:8 

catch-up 27:2 

catching 349:15 416:15 

categories 220:5,14 

category 47:4 220:22 

221:2 430:20 452:12 

Cathleen 269:10 279:18 

279:21 

cattle 223:11 328:10 

338:5,11 

caught 95:17 386:5 

cause 18:1 168:11 

316:6 375:11 

causes 219:9 359:12 

causing 27:5 

cautious 253:16 

cavity 175:14 203:4 

CBD 435:13,21 436:3 

CBP 41:15,17 46:22 

47:15 63:14 

CCOF 72:15 291:15 

292:3 300:17 307:22 

308:15 311:21 451:13 

CCOF's 303:21 

celebrate 37:22 388:1 

celebrated 335:10 

celebration 44:8 

cellphones 240:4 

census 96:18,19,22 

98:7,16,20 99:8,11 

100:4 105:17 110:3 

111:2 112:7 328:3 

Center 10:22 37:21 

60:14 64:1,7,15 

119:15 439:1 

central 19:13 49:22 

90:18 119:5 

centuries 178:3 318:14 

century 166:11 179:5 

century-old 316:4 

CEO 335:8 

cereal 272:5 

certain 147:20 235:10 

247:13 260:21 322:10 

364:6,13 446:22 

certainly 77:10 131:12 

138:14 154:15 156:8 

156:13 160:3 179:1 

183:21 193:2 196:9 

253:15 263:6 279:4 

certificate 28:4 47:7,20 

401:5 

certificates 32:9,10 

46:15 

certification 16:9 24:6 

53:11 54:11 64:12 

67:21 68:18 90:10 

92:14,16 159:12 

246:12 302:18 308:8 

308:16 309:12,16 

333:15 349:20 356:3 

356:14 374:1 379:16 

383:2 385:18 392:17 

393:12 397:5,22 

398:6 402:4 404:15 

414:15 

certifications 359:6 

certified 12:16 31:9,11 

31:15,22 32:1,5,14 

54:12 72:14,18 80:11 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
460 

102:11 105:22 110:5 

126:20,22 127:4 

208:18 254:9 268:11 

283:15,22 284:6 

288:2,4,4 289:21 

301:6,20 302:1 311:9 

353:15 357:19 358:17 

366:22 395:16,18,18 

396:9,11,13 397:14 

401:19 402:6 404:10 

410:7,8,10 

certifier 15:15 24:9 33:3 

33:12 34:2 46:16 62:3 

65:20 66:5,9 67:8 

80:16 90:14 100:17 

100:18 103:3,19 

105:8 203:16 284:16 

296:1 298:15 299:3 

359:9 385:6,9,15 

398:19 399:15 401:4 

401:6 421:4 447:6 

certifier's 11:4 

certifiers 24:5,10 34:20 

36:3 45:4 53:2,3,5,7 

53:10 57:19 58:17,22 

59:6,16 60:3,5,6,9,18 

61:6 62:6,9 65:5,16 

65:16 66:1 70:12,21 

71:1,4,15,16 74:5 

77:6 79:9,12 81:1 

93:8 101:14 103:9,11 

104:11 105:10 248:5 

251:21 306:1 319:21 

320:18 326:7 337:3 

349:18 352:6,12 

359:2 369:12 374:12 

378:22 379:22 383:5 

389:12 398:21 402:10 

405:13 410:4,12 

411:12 412:1,3 415:7 

421:9 422:20 431:5 

434:13 437:22 438:8 

438:14 439:14 440:12 

certifies 367:1 374:9 

385:10 

certify 16:17 36:5 

284:16 303:9 374:17 

385:15 399:2 400:20 

405:16,18 410:19,19 

412:15 416:4 

certifying 16:5 101:12 

253:5 356:18 374:2 

402:1,5 406:1 413:13 

413:19 

chain 36:20 50:20,21 

51:14 52:13 55:13 

124:10 130:22 136:4 

136:19 139:15 150:7 

195:12 196:17 271:18 

271:20 283:1 433:9 

chains 51:16 

chairman 300:17 

chairs 22:1 119:14 

challenge 24:9 247:5 

challenged 243:4 

challenges 17:15 22:8 

22:15 59:1 98:1 

103:22 137:6 149:11 

188:3 225:11 342:6 

346:9,17 388:5 452:7 

challenging 204:19 

220:1 244:14 452:16 

chance 138:4 330:2 

346:5 353:2 375:16 

427:6 

change 18:8 42:5 

109:20 118:8 200:6 

260:12 265:20,21 

266:9 288:21 289:1 

292:7 302:13 313:14 

348:1 353:22 354:5,8 

354:10,15 355:5 

356:10 358:21 362:10 

368:18 416:12 

changed 63:2 77:13 

84:22 85:20,21 86:5 

86:21 289:14,16 

303:5 331:17 336:4,6 

343:4 344:13 345:14 

changes 38:12 39:5,6 

47:21 48:1 61:2 86:12 

87:1 98:4 99:19,21 

109:8 186:17 341:4,8 

341:11,18,21 344:4 

344:19 345:18 

changing 109:19 314:2 

348:3 

Chapman 1:17 10:1,1 

91:4 185:19 186:1,18 

186:20 187:6 188:11 

188:17 191:17 203:15 

265:7,11 266:20 

267:22 289:9 348:22 

349:4 366:8,15 382:1 

382:15 387:10 412:8 

412:19,21 413:5,20 

414:1,7,10,12,14 

441:18 

chapters 207:1 

character 242:8 

characteristic 168:1 

characteristics 143:11 

148:7 149:1 

characterize 167:3 

characterizes 166:14 

chard 149:13 

charge 45:8 

charged 167:13 

charm 123:12 

cheap 385:22 

cheating 385:22 386:4 

check 314:20 

check-back 438:11 

checked 140:10 143:8 

341:6,7 

checklist 256:10 

checkout 96:7 

checks 127:5 

cheek 285:9 

chelates 256:14 

chelating 256:19 

chelation 256:22 

chemical 118:21 403:1 

chemical-free 356:8 

chemicals 78:15 

354:13 

chemist 179:11 

chemistry 119:19 120:1 

167:7 

cherries 17:4 

cherry 17:7 

chicken 207:20 

chickens 235:7 237:15 

417:12 418:8,16 

420:1 424:13 

chicks 29:21 30:13 

children 189:11 364:13 

364:21 

Children's 11:1 

chill 168:9 

chilling 381:1 

Chinese 149:6 

Chino 2:14 208:4 

choice 30:6 69:3 96:8 

96:10 222:7 274:17 

286:8,9,19 290:2 

295:19 315:18 321:19 

choices 19:9 245:19 

370:13,14 

choose 29:16 30:6 

261:15,19 281:3 

286:19 294:19 317:7 

408:13 

choosing 405:16 

408:17 

chose 128:14 130:3 

chosen 149:15 354:3 

Chris 417:11,12,15 

425:22 

Christie 327:18 331:12 

331:13 334:11 335:4 

Christopher 401:16,17 

chuck 428:8 

circle 101:4 195:13 

circulating 173:9,10 

433:2 

circumstance 158:18 

160:5 183:12 439:13 

circumstances 58:4 

84:12 440:1 446:22 

Cities 5:12 

citrate 256:8 263:21 

city 9:8 

civil 62:15 

claim 288:1 

claims 56:14 

clarification 117:10 

137:14 161:16 164:20 

175:20 299:4 329:21 

369:6 410:2 413:12 

433:11 

clarifications 151:3 

444:5 

clarified 81:11 371:12 

clarifies 281:14,16 

368:21 

clarify 78:9 81:21 84:8 

97:18 154:16 259:12 

259:14 318:2 351:4 

365:18 369:4 399:6 

400:9 433:16 434:9 

Clarissa 2:4 4:19,20 

204:15 

clarity 80:8 82:8 94:22 

95:5 244:2 383:4 

390:2 398:2,12 

406:15,19 

classes 206:18 

classic 211:20 

classifications 170:13 

classified 169:22 320:1 

clean 118:20 180:5 

199:6 

cleaner 180:15 

cleaners 254:22 367:6 

369:8 

cleanliness 261:10 

clear 24:11 32:17 85:15 

162:13 184:10 270:20 

292:21 293:14,16 

296:9 317:6 333:16 

333:21 334:3 341:13 

352:6 379:12 398:4 

398:19,21 400:13,13 

400:22 405:22 411:20 

449:10 

clearance 39:8 

cleared 106:14 

clearly 85:14 94:11,14 

240:5 266:8 286:19 

289:13 389:22 399:7 

400:19 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
461 

cliche 19:2 

client 24:8 

clients 24:12 375:4 

376:6 

Clif 10:2 

climate 18:7 118:8 

229:11 236:10 294:20 

302:13 313:14 353:22 

354:5,7,10,15 355:5 

356:10 358:21 362:10 

388:19 

Cline 2:9 3:10 5:20 7:16 

30:16 96:17 97:10 

107:7,19 108:16 

110:1,12,14 111:2,4,7 

111:19 112:21 114:3 

114:15 

clinicaltrials.gov 202:3 

clock 240:18 241:1 

close 6:11 7:4 8:16,18 

99:14 128:21 141:11 

203:10 327:20 328:2 

373:21 379:19 

closed 39:12 

closely 47:15 52:2 

100:3 309:7 380:20 

closer 337:20 

clostridium 168:8 

cloth 449:19 

cloud 138:9 

clouds 23:10 

co- 206:21 325:17 

Co-Executive 366:21 

co-op 361:7 370:7 

CO2 355:6 

Coalition 92:7 100:8 

254:4 378:18 

Coast 9:9 

cofactors 147:20 

coincidence 178:11 

coincident 167:10 

coincidentally 178:18 

cold 223:14 

coli 214:11 

collaborate 37:3 

collaborated 99:2 

343:4 

collaboration 8:13 

122:1 150:17 

collaborative 7:21 

46:18 122:6 136:12 

collaborator 136:14 

collaborators 199:12 

199:20 

colleague 255:4 

colleagues 168:22 

411:12 

collect 100:11 122:22 

194:2 245:9 250:18 

450:15 

collected 248:7 

collecting 101:8 109:3 

collection 97:5 99:10 

100:13 103:7 104:4 

106:22 107:3 246:8 

246:10 251:5 299:6 

college 2:9 207:1,13 

collies 243:10 

colonized 176:19 

color 140:22 143:20 

149:13,14 166:13 

167:4 168:4 182:10 

240:16 

Colorado 11:10 12:4 

72:17 

colored 241:2 

colors 365:22 366:10 

366:12 

Colson 395:7 401:15,18 

401:19 405:8 407:12 

408:10,19,21 409:19 

410:1,6,15 412:17,20 

413:1 414:4,9,11 

415:19 

column 133:15,16 

combat 358:20 

combination 225:19 

228:11 

come 16:12 26:8 34:16 

38:6 41:14,15 43:13 

55:21 56:20 72:7 

77:19 79:8 82:12 88:9 

101:4 114:20 116:17 

138:20 142:14 148:14 

165:18 168:16 193:10 

200:20 208:17 216:18 

239:4,15 243:1 253:5 

302:22 305:19 317:15 

322:4 329:12 337:11 

341:17 380:21 410:18 

424:12 433:21 437:3 

439:12 444:5 446:10 

446:16 451:13 

comes 28:2 72:4 98:2 

102:6 106:15 164:5 

181:11 214:1,12 

236:15,17,22 241:14 

249:22 316:11 317:17 

324:15 352:17 407:1 

438:6 439:15 

coming 15:8 39:15 

50:16 57:7 71:16 

75:12 93:12 110:15 

142:5 172:11 181:2 

182:3 186:22 205:7 

206:1 210:13 260:2 

283:20 289:22 300:22 

340:8 343:18 345:6 

405:4 419:11 422:1,7 

424:4 426:22 427:12 

429:14 430:4 433:7 

440:19 444:13 448:12 

448:16,17 

commend 26:21 311:16 

commensal 175:13 

comment 13:13 29:16 

63:15 72:4 83:21 85:8 

85:22 86:2 87:11,13 

87:15 88:15 106:20 

112:22 153:16 165:5 

188:20 229:14 237:18 

238:16,22 239:2 

240:6 241:20 242:2,7 

243:13 268:6 275:11 

290:15 304:7 310:9 

313:2 314:7 317:21 

330:3,5,19 332:6 

334:16 341:14 346:5 

353:4,20 358:11 

369:16 382:14 406:4 

411:7 414:18 415:20 

417:2 423:19 427:6 

449:5 

commented 189:3 

240:21 345:9 

commenter 242:2 

commenter's 406:4 

commenters 25:18 

28:21 241:18 242:20 

267:5 312:10 343:16 

345:7 401:17 408:15 

437:4 

commenting 307:22 

367:3 

commerce 384:21 

commercial 298:11 

350:12 352:4 

commercially 135:6 

148:11 216:3 351:2 

431:19 

comminuted 189:21 

Commission 5:14 

commit 28:19 344:17 

commitment 28:6 75:3 

445:4 

committed 78:20,21 

80:1 82:6 93:1,17 

96:2 

committee 13:18 

119:15 120:10 174:21 

331:7 353:18 423:21 

committing 386:3 

commodities 50:17 

52:11 112:4 174:10 

commodity 53:18,21 

111:12,13 428:12 

common 140:18 359:1 

392:22 

commonly 221:7,7 

communicate 77:5 

341:11 345:7 

communicated 49:19 

communicating 92:8 

communication 77:6 

332:2 445:21 

Communications 5:11 

243:16 279:22 

communities 5:12 

18:19 22:20 335:13 

community 6:7,19 8:2 

19:21 26:15 27:1,10 

28:13 29:5,6 35:10,21 

37:4 39:17 40:21 41:5 

45:19 52:17 63:3 

74:13 85:15 86:8 

87:14 248:19 250:22 

253:6 264:9 291:1 

333:11 335:12 341:12 

342:7 343:3 357:8,10 

358:10 396:11 397:19 

405:3 417:8 446:12 

451:16 

community- 391:18 

compacted 449:8 

companies 65:12 163:2 

163:4 182:17 192:9 

193:4,10 195:16 

196:16,18 207:9 

232:22 248:4,11 

249:8,9,18 251:6,14 

252:22 294:17 295:1 

295:4 297:22 299:13 

338:8 

company 10:3 100:20 

120:6 154:20 155:1 

185:16 196:2,10,18 

209:20 228:1 236:7 

295:13 299:10 325:3 

325:13 430:22 

Company's 155:15 

comparable 189:12 

compare 111:19 189:4 

compared 101:16 124:2 

135:10 180:12 191:4 

comparison 189:6 

comparted 106:10 

compelled 86:20 

compelling 264:14 

267:5 273:9 274:3 

279:2,8 

competing 28:18 

competitive 123:9 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
462 

competitors 90:4 

complaint 33:11 89:22 

434:10 446:1 

complaints 35:3,6 

89:21 90:3,7 434:7 

445:21 446:14 447:17 

complement 219:20 

complements 282:13 

complete 67:16 71:11 

83:10 219:19 305:20 

411:17 415:18 449:18 

completed 50:15 69:11 

101:19 207:14 242:3 

completely 360:10 

426:13 

completeness 71:14,18 

complex 77:17 309:22 

313:14 

complexities 33:8 

451:18 

complexity 89:12 148:4 

148:9 165:17 195:12 

compliance 34:14,21 

37:17 40:8,13 41:2 

42:10,16,17,19 50:2 

56:22 57:3,6,22 58:10 

61:8,9 65:6,13 67:22 

68:7 77:2 84:5 89:21 

90:13 261:13 263:11 

281:15 336:11 389:9 

434:2 438:1 446:8 

447:2 448:14 

compliant 369:1 389:20 

complicated 293:1 

complied 88:20 

compliments 259:18 

comply 65:9 256:4 

component 76:18 

156:7 

composted 134:11 

compound 171:7 

compounding 181:6 

compounds 146:4 

149:8 167:13 

comprehensive 118:9 

126:6 

comprehensively

443:5 

compromise 393:6,10 

447:10 

compromising 157:20 

392:22 

computer 337:10 

computers 240:5 

concentrate 186:4 

187:10 188:15 

concentrated 166:18 

186:15 187:16 188:5 

concentrating 184:14 

187:17 232:12,13 

concentration 130:11 

152:9 180:22 181:1 

184:20,21 186:13,22 

261:22 

concentrations 128:6 

128:10 129:4 131:6,9 

131:10 132:5 133:19 

235:2 

concept 19:10 258:4 

259:1 362:16 

concepts 19:11 

concern 61:20 81:13 

89:1 154:16 156:14 

177:5 189:11 247:20 

248:22 249:5 273:11 

274:19 310:12 332:20 

350:9 359:13 360:6 

363:12 447:7 

concerned 130:12 

245:2 246:1,3 247:21 

248:3,9,15 257:17 

327:6 381:1 435:22 

concerning 165:7 

198:17 358:5 

concerns 21:17 54:2 

244:20 248:20 258:2 

259:19,22 265:17 

266:3,21,22 308:6 

311:20 365:3,7 382:4 

382:10 385:5 424:6 

conclude 150:11 386:4 

concludes 74:14 

conclusion 336:2 

concrete 36:4 76:2 

290:21 449:12 

concur 256:21 

condition 264:6 403:2 

conditioned 236:14,21 

conditions 131:12 

133:20 147:12 168:8 

202:6 256:16 257:4 

conduct 52:9 53:17 

98:15 99:3 122:11 

294:11 385:22 

conducted 97:2 98:11 

98:13,17 99:11 

100:17,20 119:22 

123:15 124:1 126:20 

206:19 

conducting 99:18 

conduit 254:8 

conference 230:9 

238:22 301:7 

confidence 248:7 285:6 

286:6 298:4 

confident 105:12 

342:16 

confidential 299:2 

confidentiality 447:5 

confidently 361:17 

confined 267:14 

confinement 84:9,11 

84:15 

confirm 303:19 

confirmation 377:4 

confirmed 52:15 301:8 

303:22 

confirming 34:15 

conflict 80:15 237:20 

246:21 351:5 389:14 

conflicts 238:5,6,9 

conform 83:6 

conformance 438:5 

confusing 293:1 

confusion 97:16 102:6 

106:15 186:21 290:5 

congratulate 22:9 

congratulations 73:7 

73:10 

Congress 385:4 386:8 

388:5 446:8 

conjunction 314:15 

connect 18:10 91:15 

199:18 

connection 196:8 362:8 

cons 371:8 

consensus 35:21 

333:17 334:4 397:18 

439:19 441:5 

consent 93:10 

consequences 246:6 

248:10 

conservation 48:11 

consider 58:6 61:7 

69:18 77:10 79:9,12 

83:2 89:18 170:2 

191:16 220:22 280:16 

290:20 309:10 313:6 

314:9 316:14 323:1 

392:16 422:5 

considerable 158:17 

consideration 273:2 

392:19 

considered 60:21 62:21 

63:11 219:17 287:22 

299:5 403:20 416:3 

considering 257:7 

308:11 381:19 416:20 

consisted 227:16 

consistency 24:5 27:12 

358:3 359:5 378:22 

379:22 412:4,5 

415:10,15,18 

consistent 64:11 

130:17 131:21 148:8 

169:13 280:21 337:4 

360:22 411:18 413:4 

440:7 

consistently 102:1 

129:6 134:4,7 140:5 

155:17 283:2 416:17 

consolidation 342:5 

constituency's 21:16 

constitutes 83:14 

281:14 

constraints 93:2 157:3 

158:1 

consult 105:5 382:12 

consultant 382:13 

consultation 447:13 

consulted 101:11 

consulting 207:7 

consume 175:9 

consumed 159:5 

189:10 232:8 272:4 

consumer 13:1 14:5,10 

284:21 287:17 361:5 

361:8 363:10 366:1 

370:5,6 391:20 

431:15,16 447:21 

consumers 18:11 22:12 

28:8,16 94:2 96:3 

143:2 157:18,21 

180:4,8 191:8 286:3,7 

286:15 290:3 335:21 

356:7 357:11 359:7 

361:14 365:3 370:12 

370:12 371:5,10,17 

393:3 394:12 429:18 

429:19 

consuming 176:4 

222:18 

consumption 222:21 

223:18 224:3 236:17 

contact 34:16 56:2 67:9 

275:1 301:13 304:22 

353:4 

contacts 65:17,20 

104:7 

contain 88:6 185:7 

container 33:1 34:13 

36:1 79:5 301:1,3 

333:20 356:15 379:13 

390:3 404:15 405:19 

433:5 434:16 436:17 

436:21 451:8 

container-based 33:20 

36:7 

containerized 433:17 

containers 56:9 75:22 

355:18 356:2,6 

containing 354:22 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
463 

contaminated 294:3 

contamination 245:10 

247:11,15 248:17 

249:10 250:1 252:1 

274:15 294:5 303:4 

403:8 

contemplate 448:9 

contend 259:4 

content 70:3 88:11 99:6 

117:11 176:8 187:1 

223:21 232:13 249:6 

258:3 297:21 

contents 3:1 215:13 

229:18 230:12 

contest 44:4 

context 33:15 70:10 

115:10 121:17 125:3 

156:6 159:21 178:8 

304:10 318:20 388:15 

continually 22:16 23:7 

continuance 320:12 

322:15 

continuation 332:3 

continue 8:6,9 18:20 

26:17 32:15 36:2,3 

37:2 38:16 52:9 53:14 

69:17 70:2 74:7 85:9 

91:10,19,21 92:2,19 

100:10 101:2 141:5 

146:9 188:9 200:10 

226:3 264:9 297:5 

312:2 317:18 320:10 

320:14 321:1 345:18 

370:9,19 371:11 

376:21 386:1,4 

412:14 430:19 434:11 

445:13 

continued 136:6 194:4 

270:10 308:20 380:15 

383:2 

continues 44:14 50:5 

74:9 360:2 431:17 

continuing 51:14 52:2 

54:4 62:13 64:16 

69:22 141:18 150:20 

206:7 359:17 

continuous 54:11 

74:12 255:9 315:1 

379:6 388:8 423:20 

424:2 436:9 

continuously 29:11 

409:6 

contract 158:7,19 

325:16 

contracted 161:3 

contracts 272:15,16 

294:20 339:15 376:8 

contradictory 87:14 

contribute 123:22 

403:7 

contributed 384:4 

contributing 232:16 

contribution 135:11 

354:9,14 355:5 

contributions 353:21 

354:2 

contributors 24:18 

control 18:3 36:16 64:9 

64:10 151:18 162:12 

163:13 171:1,16 

188:3 270:4,21 271:5 

272:8,22 295:1 

315:20 329:22 374:15 

375:1 

controlled 395:17 

452:3 

controversies 86:11 

controversy 170:11 

conundrum 203:7 

convene 73:18 116:20 

453:10 

convenience 358:15 

convening 308:21 

439:16 

conventional 80:7 

111:18,22 112:3,4,7 

113:13 114:2 144:7 

144:13 148:16 155:4 

156:11 160:22 161:20 

162:7,14,17,18 163:5 

164:2,5 196:9 197:9 

197:17 198:16 199:12 

199:19 207:7 221:12 

245:19 249:11 302:21 

326:5 355:10 379:6 

417:22 428:7 

conventionally 163:13 

179:16 255:8 

conversant 414:4 

conversation 26:17 

32:19 205:1 240:3 

362:12 397:18 405:5 

411:11 441:12 443:20 

446:2 

conversations 248:4 

conversion 147:16 

148:20 149:12 152:3 

152:8 153:5,10 157:6 

167:7 200:5 201:5 

379:6 

convert 142:16 143:12 

151:12 171:11 200:10 

converted 147:6 173:4 

173:20 179:4 200:8 

271:15 

converting 146:3 153:9 

convey 340:17 394:17 

Coody 243:10 253:22 

254:2,2 257:22 

260:18 262:3 264:7 

264:16 265:2,5,9,21 

267:3 268:1,4,18 

269:6 

cooking 168:9,11 

cool 182:20 

cooperative 2:12 

119:12 154:18,18,19 

357:14 418:13 

cooperators 197:9 

coordinate 66:12 

coordinated 97:5 

coordination 393:12 

coordinator 11:5 

207:12 

copies 67:2 

core 35:8 36:21 64:6 

126:19 363:21,22 

corn 209:18 210:6,8 

212:18 213:2 214:19 

215:4,4 225:3 228:13 

228:22 245:16,17,18 

247:10 296:21,22 

390:10 

corn-based 222:11 

corner 415:4 

corners 28:19 

Cornucopia 383:17 

correct 62:7,11 84:10 

142:21 186:19 199:14 

203:14 240:20 278:9 

311:10 319:1 323:17 

345:20 366:13,14 

correctable 62:7 

corrected 104:9 105:7 

corrections 13:9 

corrective 40:19 

correlate 100:2 

correspond 231:5 

cost 252:5,7 342:9 

407:7 

costly 375:3 

costs 70:14 248:16 

375:21 425:19 

Council 10:13 113:2 

118:12 447:15 

council's 34:6 

count 28:8 31:22 32:14 

102:20,22 232:4 

countdown 241:1 

counting 241:11 

countries 50:17 224:13 

385:8,16 

country 17:4 43:10 

53:18,22 90:16,20 

227:21 357:15 374:10 

404:10 409:2 444:13 

448:5 

country- 31:20 

counts 71:11 102:16 

County 72:18 

couple 5:6 17:8 21:4 

70:18 98:8,14 101:3 

103:6 105:18 123:6 

129:2 155:20 221:21 

227:13,14 341:7 

386:20 420:4 435:16 

443:8 

coupled 434:10 

couples 416:7 

course 16:11 61:2 68:7 

68:17,18,19 69:11 

102:6 260:21 313:7 

365:2 411:22 412:17 

438:10 

courses 67:16,18 68:5 

69:10,16 

Court 428:10 

Courtyard 1:11 

cousin 424:10 

cover 37:9 118:2,2 

127:7 134:12 138:9 

220:4,7 403:4 440:14 

coverage 219:1 

covered 75:10 160:20 

218:12 220:9 224:7 

399:13 

covering 83:10 450:5 

cow 236:20 324:15,15 

337:11,15 

cows 61:18 113:14 

323:12 329:11 337:13 

397:8 

CPM 134:12 

crafted 266:14 298:11 

crap 329:4 

crazy 215:20 

Creamery 335:8 340:5 

create 20:11 101:13 

139:15 140:9 148:7 

150:6,9 177:3 180:15 

310:13 332:6 379:1 

437:9 446:6 

created 290:6,8 355:1 

388:5 427:18 429:20 

429:21 

creates 448:2 

creating 36:22 142:19 

150:8 342:6 354:21 

360:12 

creative 439:9 

creativity 444:15 

creatures 29:15 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
464 

credible 52:10 

credit 67:16 69:4 

creeping 267:20 

crew 44:5 

crisis 335:11 336:7 

388:19 

criteria 89:6,10 264:17 

264:19 274:10 311:7 

critical 55:18 83:14 

115:21 116:5,12 

142:19 143:7,8 

157:15 159:18 181:8 

181:10 194:15,20,21 

235:1 270:22 272:20 

282:22 284:22 373:6 

374:19 

crop 11:13 17:1 18:7 

34:17 45:1 59:20 

72:20 78:11 102:11 

118:2 125:8 127:20 

144:17,22 145:2 

158:14 160:1 163:16 

194:5,8 223:21,21 

229:18 230:12 256:6 

256:17 258:19 268:20 

271:13 273:21 276:4 

276:15 279:9,12,13 

280:5 302:8 308:9,17 

308:18 309:6,13,19 

309:20 312:5 316:4 

321:13 337:8 349:22 

350:18 351:1,7 367:3 

367:11,14,17,22 

368:7,12,16 375:12 

375:22 394:9 402:7 

402:20 403:3,6,9 

409:9 413:14 414:16 

435:19 

CROPP 154:18 

cropping 118:1 121:4 

127:7 

crops 11:22 118:2 

121:10,11 128:8 

134:12 141:7 244:22 

255:10 271:11,21 

273:18 275:18 316:5 

316:12 337:7 350:12 

350:16 358:16 376:13 

394:4 403:4,8 408:17 

cross 88:20 89:4 

crosses 320:3 

crossing 384:5 

cruciferous 149:7 

crude 225:15 

Cruse 340:2 349:5,15 

349:17,18 353:7 

cry 334:17 

culinary 143:17,19 

culled 310:21 

cultivar 140:12 143:14 

cultivars 128:15 281:6 

282:2,4 

cultivation 402:22 

cultural 403:13,19,22 

404:2,11 407:18 

culture 151:16 279:11 

cultured 414:2,15 

cultures 152:19,19,21 

152:22 153:4 201:2,3 

201:3 

cure 166:11 177:22 

178:5 179:18 203:18 

cured 135:22 141:2 

155:11,14 156:1 

167:4 168:2 170:1,5 

171:9 172:12,14 

178:2 179:16 192:6 

193:6 197:6 198:13 

curing 115:12 124:17 

124:20 126:9 136:5 

136:14 151:9 162:18 

166:9 169:4 178:8 

179:6 199:9 

curious 88:14 109:2,16 

109:21 183:4 201:17 

382:8 394:22 

current 8:15 24:18 

38:13 43:1 49:10 75:4 

125:17 245:13 249:21 

281:21 313:15 376:9 

379:17 381:9 386:7 

397:20 410:10 433:18 

currently 6:21 7:2 10:8 

34:7 40:3 99:18 

101:22 103:18 104:15 

118:17 119:10 120:7 

142:6 144:8 160:11 

207:12 254:14 413:16 

curve 244:8 

customer 357:16 424:9 

customers 249:15 

285:6,7 357:17 358:3 

360:19 418:7 424:8 

Customs 41:13 46:18 

47:6 

cut 28:19 185:5 239:18 

cute 30:1,14 432:16 

cuts 376:8 

cutting-edge 390:16 

cycle 139:13 140:2 

144:20 150:2 188:7 

cycling 354:20 

D

D.C 12:11 32:20 42:14 

43:9,14 426:15 

428:15 

daily 221:12 233:6,16 

361:20 

dairies 59:3 89:12 

90:17 329:11,12 

336:19 337:6 348:6 

397:7 

dairy 37:17 41:15 42:17 

56:22 57:21 58:11,16 

60:2 68:7 84:5 85:2,6 

87:17 88:15 109:12 

195:1 323:12 327:22 

328:1,5 329:9 331:16 

335:9 336:5,7,11 

337:5 339:6 344:7 

348:3 379:7 396:20 

397:5 402:7 418:18 

426:18,20 427:8,9 

428:19,20 429:8 

430:6,7 

dairyman 336:10 

dairymen 336:13 

337:12,18 339:14 

damage 316:7 375:12 

damages 390:4 

Dan 1:21 10:10 74:16 

78:5 177:19 230:22 

232:1,19 236:6 

286:20 327:4 361:4 

393:15 414:17 

Dan's 82:12 234:16 

dance 387:16 395:6 

dangerous 285:21 

Danone 325:13 

dare 429:18 

Darigold 325:18,21 

326:2 

dark 23:10 51:19 

285:19 

Dashboard 70:20 

database 40:8,10 41:2 

45:6,13,15 55:21 71:3 

92:20 101:6,13 103:5 

104:2,13,21 445:6,22 

446:10 448:10 

Database's 70:19 

date 125:17 126:15 

131:3 132:3 140:11 

dates 43:18 

Dave 1:19 10:16 78:5 

82:10 108:21 234:14 

243:2,9 259:10 

263:17 276:18 278:14 

296:15 307:19 321:21 

347:17 381:22 395:7 

401:15,19 404:19 

406:21 414:1 416:21 

Dave's 193:18 

David 2:2,14 5:2,3,3,6,8 

5:17 41:9 177:18 

208:2,4,5 226:22 

David's 184:2 

day 6:19 7:11 8:4 35:8 

44:10,11,12 45:20 

58:3,4 77:20 84:7 

96:21,21 145:5 

172:11,16,17 179:22 

205:16 210:20 233:17 

233:19 236:14 337:15 

400:21 424:9 430:9 

432:17,22 453:20 

days 17:16 20:6 30:4 

61:11 84:14 88:20 

89:17 130:15,16,16 

131:16,17 138:9 

141:14 144:21 145:1 

145:10,17,18 179:20 

191:14 292:12 300:21 

341:4 402:9 428:8,9,9 

de 1:17 12:8,8 248:10 

365:17 

de-listing 156:10 

deal 23:14 158:2 159:2 

322:5 448:21 449:1 

dealing 75:5 204:18 

248:18 249:12 371:3 

deals 278:11 

dealt 262:16 

death 376:4 

debate 21:19 453:1 

debates 262:17 451:10 

debating 400:16 403:14 

debt 17:18 444:15 

decade 119:6 164:7 

180:3 218:7 225:22 

decades 320:1 

decelerate 191:22 

December 39:5 44:7 

46:1 100:13 

decide 21:19 259:13 

342:8 

decided 25:3 80:13 

82:18 334:7 428:9,10 

decision 24:9 33:18 

86:15,16 108:6 255:2 

270:11 272:18 304:13 

304:14 305:10 306:6 

347:6 358:12 403:20 

decision-making

238:18 

decisions 14:15 53:11 

76:2 86:18 91:2 

183:15 345:4 370:20 

389:10 390:6 

decisive 7:7 

deck 242:13,14 243:10 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
465 

253:22 279:19 283:10 

291:12 300:14 307:18 

314:19 323:10 327:18 

331:12 335:6 340:2 

349:6,16 353:12 

357:4 363:6 366:19 

369:22 373:19 378:15 

383:10 386:17 387:19 

395:7 401:16 426:5 

declaration 199:7 

declare 238:4 

declared 59:5 

decouple 245:13 

276:13 

decoupled 250:5 

275:13 

decoupling 250:7 

decreased 130:20 

dedicated 8:4 9:12 

21:15 

dedicates 45:17 

deemed 145:1 190:12 

deemphasized 372:2 

deep 28:2 385:20 

deepen 68:20 69:5 

deeply 378:21 391:22 

deer 310:21 

defend 429:17,19 

defending 264:4 

defense 285:5 

defer 168:21 432:1 

deficiencies 218:22 

deficiency 217:6 222:5 

231:9 

deficient 216:19,22 

222:10 257:2 

define 79:4 258:4 

defined 59:2 258:6 

404:1 

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defining 82:16 

definitely 129:19 138:6 

141:5 152:14 194:11 

194:19 274:9 275:7 

278:21 413:2,16 

definition 189:21 351:7 

366:9 368:12 

definitive 124:12 

degree 5:16 14:19,20 

20:8 118:14,15 

119:19 129:14 161:7 

383:13 427:12 

dehydrated 232:11 

delay 332:5 358:13 

deli 156:4 

deliberation 35:20 

deliberations 232:21 

deliver 186:16 418:3 

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delivering 142:21 152:1 

186:11 201:6 

delivery 202:5,11 

demand 156:20 158:4 

159:7 161:13 162:21 

163:7 164:10,11 

180:7 193:13 282:3 

431:15 444:1 

demanding 180:4 

demands 404:9 

democratic 392:1 

demonstrate 34:14 

282:3 

demonstrated 61:11 

280:13 282:15 

demonstrates 275:7 

demonstrating 281:11 

Denmark 206:12 

department 1:3 2:10 

7:14 11:6 14:6 16:4 

72:17 73:3 117:20 

118:18 124:16 159:12 

207:13 359:18 

depend 238:19 

dependence 285:14 

dependency 234:18 

dependent 137:18,20 

152:9 156:5 

depending 58:4 128:10 

129:4 130:18 131:18 

134:2 141:15 192:13 

195:14 268:22 

depends 29:7 185:16 

depleting 416:8 

depreciation 428:17 

deprioritized 373:5,9 

depth 117:13 

deputy 2:2,6 4:8 5:4 

25:19 26:21 41:10 

derail 446:5 

dermal 275:1 

describe 16:14 403:6 

describing 38:7 

descriptor 288:18 

deserve 311:6 371:17 

396:7 

design 119:4 127:16 

134:13 236:1 

designated 2:7 4:11 

designation 202:20 

designed 176:10 

designing 45:11 

desirable 141:1 

desire 281:22 343:20 

desires 29:4 

desperately 339:20 

despite 86:10,12 

225:21 244:22 248:11 

334:3 364:16 

destabilization 192:19 

destabilize 192:5 

destabilizing 156:12 

detail 255:5 

detailed 244:4 254:10 

257:16 392:12,14 

441:20 

details 35:13,15 52:12 

107:5,17 110:10,12 

227:20 294:11 404:16 

441:2 

detectable 245:6 

252:13 

detected 191:16 

deter 95:21 252:15 

determination 306:6 

321:9 

determinations 352:6 

determine 19:12 38:18 

100:9 109:6 132:1 

256:15 260:4 264:12 

309:3 438:5 

determined 262:1 

374:12 

deterrent 252:4,6 385:3 

detriment 358:2 

develop 26:1 27:14 

47:6 53:19 69:18 

75:13 139:22 140:8 

160:16 164:11 402:14 

410:20 416:5 417:4 

446:18 451:3,17 

453:13 

developed 75:11 

136:11 179:8 262:20 

404:17 405:22 

developing 68:4 118:20 

131:2 204:18 290:21 

309:22 403:19 453:14 

development 5:13 12:3 

19:5 39:19 42:15 

64:16 146:5 163:10 

166:9 192:5 231:6 

309:8 402:12 422:15 

437:1 442:19 

developments 384:14 

Devenish 2:8 

Devon 2:5 4:21 344:2 

devote 6:18 220:10 

devoted 96:9 

dial 133:4 

dialogue 281:22 411:14 

dictates 159:19 

die 217:21 

Diego 12:17 

diet 172:9,11 175:9 

201:20 211:16 212:6 

213:4,8 214:1 215:9 

216:19,22 364:11 

dietary 172:1 222:1 

diets 206:6 207:20 

211:10,11 212:16,16 

215:3,16 216:15 

217:13 219:16,22 

222:3,10,17 225:15 

225:21 228:9,12,20 

differ 128:9 220:16 

221:2 222:21 

differed 130:8,18 

difference 44:20 103:2 

112:8 132:16 145:16 

145:20 147:15 148:1 

198:22 230:14 233:5 

371:15 382:9 

differences 98:14 

102:20 129:3 153:10 

153:13 157:7 294:21 

different 25:11 49:19 

59:4 60:20 63:7 68:11 

94:22 97:22,22 

106:15 111:20 121:11 

121:12 124:9,9 125:5 

125:6,9 126:16 128:8 

132:12,18,21 133:14 

135:15 136:16 138:13 

139:14 140:13 146:19 

148:14,18 153:4,11 

153:19,20 163:18 

185:9,11 190:11 

195:15 196:16 199:16 

202:4 211:18,19 

218:8 220:4,14,19,20 

220:21 221:21 223:12 

224:9 225:16 227:13 

227:14 240:15 259:1 

262:19,19 266:12,16 

268:16,19 269:1 

290:6,7,7,8,22 299:1 

300:20 301:14 337:22 

341:10 347:13 394:7 

405:17 417:6 447:16 

450:10,12 

differentiate 288:6 

differentiation 441:8 

differently 258:1 261:1 

452:14 

differs 222:20 

difficult 43:13 104:6 

259:17 263:3 276:13 

322:9 324:6 348:10 

352:13 362:22 430:5 

diffusing 190:7 

dig 411:22 412:8 

447:20 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
466 

digest 223:10,13 

digestibility 223:8 

digestions 225:3 

diligence 381:5 

Dill 255:5 

dilute 152:12 166:17 

diluted 186:15 

dimensions 82:22 

diminished 375:18 

dioxide 355:1,12 

direct 16:22 40:14 

87:18 99:4 202:7 

306:12 399:4,4 

418:11 448:13 

directed 165:12 

direction 112:20 398:21 

directional 243:5 287:6 

directions 415:22 

directives 54:7 

directly 46:4 54:4 61:4 

64:4 132:14 189:12 

289:11 340:17 343:20 

352:14 414:5 

director 2:3 4:17 5:8 

10:3,6,13 14:4,14 

41:12 58:9 118:17 

119:11 243:15 269:16 

301:8 303:22 357:7 

366:22 378:17 387:22 

395:11 401:20 

director's 14:16 

directs 96:21 

disabled 329:1 

disagree 255:1 256:6 

disagreement 254:20 

333:3,10 

disagreements 20:5 

404:5 

disagrees 76:7 

disappearing 270:19 

335:12 

disappointed 373:10 

426:14 

disclose 293:20 294:17 

295:13 298:1,3,14 

447:9,17 

disclosed 238:7 

disclosing 293:21 

298:4 

disclosure 297:20 

394:1 

disclosures 394:19 

disconnect 335:21 

discontent 401:11 

discontinue 374:21 

377:1 

discontinued 169:12 

discontinuous 59:11 

61:12 

discourage 333:4 436:3 

discouraged 247:22 

discover 75:8 

discovered 23:17 171:7 

174:14 

discovery 174:17 

discuss 83:3,5 208:15 

298:13 333:8 429:12 

discussed 147:17 

191:21 351:15 358:4 

358:19 359:15 362:7 

discussing 105:4 122:8 

122:8 287:1,6 310:19 

321:1 

discussion 82:19 115:4 

116:3,13,21 117:6,13 

154:13 177:12,17 

204:9,10 206:7 

238:10 247:8 250:13 

255:2 257:15 275:12 

275:14 276:20 277:1 

291:1 308:1,4,5 

310:14 311:19 312:14 

320:17 332:7 352:17 

367:6 369:8 380:11 

392:22 402:11 405:9 

431:4 

discussions 32:18 

206:5 238:2 369:10 

404:5 434:22 436:14 

disease 224:5 315:16 

diseases 255:13 260:19 

263:14 

disempowering 334:22 

disjointed 196:16 

dismiss 402:9 424:6,8 

dispensation 26:11 

disposal 356:5 

disrupted 190:9 

dissect 138:8 

distance 141:21 

distill 113:20 

distinct 198:22 

distinction 112:6 

distractions 240:7 

distribute 254:5 

distributed 13:8 238:2 

distribution 91:1 

109:14 

disturb 240:9 

disturbed 378:21 

disturbing 197:10 

dive 103:22 

diverse 258:12 268:21 

309:3 415:2 

diversified 16:22 

418:16 

diversity 29:12 296:10 

division 2:4 4:17 14:5,7 

14:10 50:2 96:19 

divulge 194:17 

DL-methionine 206:4,6 

211:9 213:3,6 214:17 

419:1 

DMI 61:5,18,20 89:17 

397:7 

doable 434:21 

docket 270:15 293:5 

332:1,8 

document 112:14 244:5 

247:9 255:2 257:15 

257:20 258:3,7 

280:12 292:17 293:13 

308:1,5,5 310:15 

311:19 312:14 336:11 

336:15 367:7 369:8 

380:11 393:1 422:22 

documentation 55:13 

282:5 347:5 363:20 

documenting 271:3 

documents 77:6 88:12 

238:2 250:13 257:6 

266:2 332:7,19 421:4 

dogs 139:17 

doing 20:4 28:7,18 

37:15 39:1 40:20 49:7 

50:8 51:4 58:15 68:7 

68:14 71:2 81:1 92:8 

94:12 95:14,15 

132:11 136:3 137:21 

164:6,14 175:3,15 

187:4,11 236:1 

251:15 292:9 302:12 

303:12 304:15 337:8 

360:21 390:17,18 

392:4 407:11 411:15 

418:17,18 421:10,12 

423:5,12 434:2 

438:11 443:17 450:16 

dollar 54:17 111:17 

dollars 106:2 157:1 

domestic 49:8 50:10 

57:1 395:16 

domestically 23:18 

49:7 

donations 122:21 

door 401:3 

doors 235:12 

dose 177:8 

dots 91:15 

double 66:17 145:10 

doubt 26:16 206:5 

dozen 15:22 312:13 

339:19 

drafted 350:5 

drafting 384:14 

dramatic 257:1 

drastic 108:9 

drawn 33:5 

dream 23:3 

dried 186:10 188:5 

210:22 223:5 224:18 

232:14 

drink 172:20 214:6 

drinking 189:4,9 

drip 127:17 

drive 27:12 64:12 193:7 

395:19 429:11,12 

436:2 

driven 163:19 362:6,13 

driver 138:7,15 

drivers 354:5 

driving 193:3,20 396:7 

440:7 

drop 328:15 375:11 

dropped 145:21 331:3 

drug 202:11,18 

drugs 202:5 

drum 72:6 

dry 178:16 181:12 

186:2 337:11,15 

397:8 

drying 184:11 185:15 

187:11 

due 38:11 48:7 84:15 

93:3 170:13 208:19 

221:13 231:6 284:6 

324:22 333:10 375:17 

381:4 382:4 385:4 

dug 230:7 435:3 

dumping 129:11 

duplication 103:16 

104:8 

duplicative 340:21 

Durham 10:19 401:20 

Dykstra 417:11 426:4,7 

E

e 198:2 199:2,4 214:11 

earlier 7:1 41:9 73:7 

96:16 105:16 302:7 

310:20 358:19 362:7 

371:4 381:4 385:14 

411:7 417:2 433:3 

436:9 

earliest 358:15 

early 15:20 43:5 114:18 

131:16 179:5 236:16 

402:9 422:12 436:1 

445:5 

earth 17:5 303:4 387:4 

easier 92:22 

easily 101:15 274:12 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
467 

359:10 

east 9:9 90:17 328:1 

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easy 402:9 444:19 

450:3 

eat 143:2 174:9 197:5 

222:2 236:19 387:1 

eating 224:2 

echo 204:13 335:1 

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ecological 271:12 

382:5,10 

ecology 119:4 203:4 

economic 100:22 

109:17 113:5,17 

182:16 273:12 316:7 

316:7 317:10 415:2 

economical 185:4 

economically 271:8 

273:19,21 275:4 

276:16 

economics 5:15 136:18 

195:2 274:3 278:12 

economies 290:7 

375:19 

economist 136:17 

economy 114:1 376:16 

ecosystem 310:17,18 

354:21 

edit 103:15 

editorial 19:4 

educate 116:18 336:1 

educated 362:14 

educating 251:11 

education 10:14 64:17 

69:20,22 280:3 

educator 12:21 406:22 

effect 168:4 176:5 

192:21 202:16 256:22 

277:22 304:19 381:2 

408:10 409:1 

effective 8:3 39:6,18 

130:10 135:10 178:15 

222:4,13 226:5 261:4 

375:5 

effectively 41:16 78:3 

384:22 

effectiveness 260:15 

260:17 

effects 113:12 114:1 

168:5 171:14 351:21 

efficacy 264:2,17 

267:17 278:21 322:3 

efficiency 189:17 

efficient 39:17 179:7 

effort 70:16 99:10 

100:19 105:1 112:14 

237:12 259:6 339:7 

431:6 444:16 

efforts 52:6,7 101:17 

121:17 125:20 244:9 

245:1,13 248:12 

380:15 384:11 390:19 

393:14 

egg 217:9 219:3 224:18 

231:3 233:18 

eggs 217:8 220:21 

224:22 233:12 

eight 72:9 74:1 127:16 

222:17 236:16 

eight-week 144:19 

either 65:22 89:8 90:12 

148:19 152:11 163:9 

168:17 169:18 187:10 

215:22 222:13 295:19 

371:1 372:18 409:8 

418:11 431:15 

Ela 1:18 11:9,9,9 88:14 

107:10 108:11 152:6 

162:6 200:3 201:9 

276:19 277:1,5,8 

278:4,10 310:5 

345:11 377:16 414:13 

440:10 441:6 

elaborate 398:11 405:7 

elected 360:8 

electron 171:11 

electronic 40:11 

element 76:16 163:2 

elevators 73:16 

eligibility 356:3 

eligible 356:13 

eliminating 46:15 

354:12 

elimination 356:4 

eloquent 303:6 

eloquently 157:5 

161:11 

elucidation 413:15 

email 67:14 411:14 

emails 300:22 

embedded 388:20 

407:19 

embodiment 19:22 

embrace 388:7 

embryos 293:7 

emergency 14:17 

emerging 53:20 54:2 

109:14 

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381:4 

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Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
468 

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439:10 

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437:14 

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234:9 

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263:21 370:16 438:2 

442:11 

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183:17 

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407:6 

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324:7 

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345:21 

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308:10 

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Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
469 

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F

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51:12 

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278:20 279:4 280:4 

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296:21 302:20 316:4 

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326:16 334:9,20 

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421:22 

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Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
470 

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Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
471 

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forward 70:4 91:8 96:12 

137:3 149:8,10 

150:20 160:17 177:18 

193:3,10,21 194:13 

194:18 209:1 246:15 

248:7 251:9,20 255:3 

260:2 262:6,9,14 

264:9 275:5 291:2,21 

313:16 314:17 315:6 

315:12 317:13,17 

320:7 321:3,11 

330:10 341:17 343:2 

372:4 379:10 380:16 

380:22 388:6 405:21 

434:22 436:10,22 

437:8 443:20 452:8 

452:13,18 453:2,8 

foster 355:20 

fostering 362:5 

found 13:14,15 15:21 

51:4 53:6 62:9 156:15 

157:2 216:1,2 222:4 

224:12 237:21 256:10 

312:11 320:19 351:3 

351:5 352:13 431:3 

Founded 395:14 

founder 335:8 

four 32:2 36:11,13 37:7 

120:18 147:2 153:20 

187:21,22 195:15 

196:4 200:6 220:4 

280:11 285:19 325:2 

328:22 329:2 341:16 

346:5,22 389:21 

396:19 

fourth 37:2 52:8 

fracking 372:7 387:4 

fraction 184:13 245:17 

fractions 178:7 

frames 43:18 

France 325:14 

fraud 23:12,17 28:19 

49:8,9 329:14 383:19 

385:16,21 386:3 

441:21 442:1,17 

frauds 396:16 

fraudulent 384:20 

fraudulently 384:4 

fray 18:8 

free 64:15 242:15 

389:14 

frequency 71:17 229:21 

frequently 362:1 

380:18 

fresh 125:8 130:6,8 

143:16 144:15 148:6 

185:4 229:22 254:5 

Fresno 14:22 

fret 17:8 

Friday 8:9,16 

fried 190:21 191:13 

friends 42:7 165:6 

364:14,20 424:10 

frogs 30:1,14,15 

front 21:6 44:15 48:20 

96:6 157:18 240:18 

259:22 414:7 

frontrunner 429:8 

froze 127:21 

fruit 251:10 268:9,9,11 

268:11,16 301:18 

302:8 368:17 

Fruitilicious 291:14 

fruits 257:2 

frustrating 137:1 334:5 

334:18 335:1 

frustration 25:21 

fry 302:19 

frying 191:14 

FSIS 155:9 

fueled 272:3 

fulfill 155:9 341:2 

full 18:17 30:8 80:2 

101:4 116:7 123:10 

143:9 145:2 218:19 

219:6 263:10 268:10 

273:2 431:4 437:22 

438:17 439:12 444:16 

full- 106:4 

full-time 11:17 43:14 

Fuller 2:10 3:5 7:13 

14:4 15:1 

fully 96:2 97:15 185:21 

225:19 286:8 453:5 

Fulmer 357:4 363:5,7,9 

365:21 366:14 

fumigated 55:7 

fumigation 52:1 54:20 

55:12,20 

fun 21:9 

function 109:9 173:22 

functional 188:16 191:7 

functionality 149:18 

functions 171:17 437:6 

fund 122:20 126:2 

fundamental 22:17 

275:4 

fundamentally 86:6 

fundamentals 67:21 

funded 123:9 209:4,19 

210:5,16 

funding 40:15 47:17 

50:4 64:4 122:11,12 

122:19 123:15 125:17 

126:1 137:2,4,20 

150:17 182:19 183:10 

194:11 195:7 210:14 

fungus 412:12 

funneling 443:16 

furlough 55:17 

further 35:15 51:12,22 

54:1 56:15 98:21 

103:22 126:3 128:2 

131:1 150:6 169:12 

179:2 194:11,15 

199:11 244:1,5 

253:18,19 256:21 

275:12 282:5 308:7 

314:14 316:14 331:22 

354:1 369:6 431:10 

future 19:11 110:17 

147:18 160:13 197:21 

260:2 282:20 388:15 

388:18 389:7 392:17 

394:22 396:8 406:20 

445:7 

G

gain 159:20 199:22 

407:10 

gained 107:3 

Gaithersburg 12:10 

game 71:5 74:3 97:14 

gap 113:6,10 

gaps 62:10,11 360:12 

gardeners 268:17 

401:22 

garlic 261:18 

Garnett 349:6,16 

353:12,13,15 357:2 

gas 167:11 354:11 

gases 354:4,7 

gastric 174:5 

gastrointestinal 176:18 

201:15 

gate 113:9 433:11 

443:13 

gathering 75:18,19 

304:15 306:15 351:16 

gauge 380:2 

gavel 453:17 

gazoo 302:15 

GE 244:21 245:6 249:6 

geez 325:8 

gelatins 431:13 

genera 154:1 

general 17:14 49:12 

57:17 76:7 208:1 

233:13 245:3 258:17 

292:19 293:17 355:18 

generalized 233:14 

generally 77:5 91:14,15 

244:2 365:2 377:17 

generate 203:4 

generated 188:8 

generating 113:22 

122:10 

generation 18:17 165:8 

427:10 

generational 429:10 

generations 17:21 

generous 126:1 

generously 133:10 

genetic 153:17 244:15 

247:11,15 250:22 

252:6 291:16 293:11 

294:18 296:10 297:21 

298:16 

genetically 244:17 

296:20 

genetics 128:10 

genie 342:12 

genome 200:15 

geography 379:3 

Georgia 45:1,7 72:20 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
472 

Georgia's 45:12 

germplasm 296:11 

gestation 324:16 

getting 9:10 18:4 28:9 

60:6 67:9 70:4 82:7 

93:17 104:1,5 109:13 

114:6 122:7 128:4 

184:9 189:17 230:4 

248:1 260:11 275:21 

277:6 326:11 386:5 

423:11 448:1 452:5 

gist 441:4 

give 6:9,12,16 8:18,20 

13:4 21:10 31:16 35:3 

37:11,12 40:7 45:21 

56:21 72:19,22 73:5,9 

80:10 96:14 123:19 

177:20 202:16 206:9 

207:22 208:11,17 

211:10 239:11 263:8 

285:9 286:8,8 324:12 

327:21 330:2 338:4 

341:9 343:21 346:5,7 

370:16 400:6 406:11 

442:21 

given 24:22 45:4 49:9 

51:6 57:11 87:1 89:12 

102:13 127:14 209:15 

253:10 261:1 281:17 

308:13 312:5 322:22 

325:7 357:13 379:16 

383:6 442:8 

gives 92:20 112:18 

134:4 394:15 

giving 222:7 269:3 

399:9 

glad 78:7 352:21 

glands 173:8 

Glasgow 2:2 5:3 

global 72:22 438:16 

445:2 

globally 22:15 47:17 

gluten 225:3 

glycolate 256:8 

glyconate 263:21 

glyphosate 34:9 302:4 

306:13,20 307:4 

390:1 399:8,11 400:2 

411:9 433:5,13 

440:13 441:13 449:6 

450:3 

GM 296:22 

GMO 54:8 251:22 

go- 378:10 

go-round 279:2 322:5 

GOA 72:22 

goal 36:15 53:19 68:20 

101:13 139:8,21 

293:12,16,22 378:22 

388:2 

goals 210:17 245:9 

goats 223:11 

God 429:1 

Gonzales 45:9 

Google 48:21 

gosh 120:18 249:7 

gotten 38:15 57:17 63:4 

123:6,16 137:1 

194:11 328:15 421:4 

government 43:17 

437:11 

government-to-gove...

448:7 

graciously 208:14 

grade 435:14,17 

grades 69:11 

gradient 176:12 

graduate 170:22 

graduated 230:6 

grain 54:14 118:9 

294:19 353:16 384:5 

384:7 

grains 23:13 272:5 

444:12 

grams 172:14 

Grannies 386:20 

387:15 

grant 122:14,18 123:3 

124:8 125:17,19 

126:4 137:18 160:7 

183:11,18 197:8 

272:21 

granted 83:19 361:7 

graph 130:10 

grapple 247:5 

grappling 371:2 

grass 122:6 222:18 

223:1,2 449:22 

grateful 38:4 62:19 

280:13 360:13 380:14 

427:6 

gratitude 444:15 

gray 23:15 26:5 

grazing 59:2,5,7,10,11 

61:11,13 236:2 

greater 271:11 343:1 

386:9 450:2 

greatly 22:6 23:6 

104:10 222:21 395:22 

Greek 178:9 

green 83:12 159:14,14 

240:17 275:2 287:3 

315:2,15 

greenhouse 79:14,16 

80:6,12 229:7 354:4,6 

354:11 452:2 

greenhouses 408:16 

Greenwood 1:18 12:13 

12:13 111:11 112:9 

152:17 153:3,14 

154:1,5 

grew 41:14 119:5 

206:12 

grinding 184:11,12 

185:15 

gritty 451:15 

Grocers 283:13 

grocery 12:12 96:5 

180:10 325:8 361:10 

366:17 

gross 108:14 155:15 

ground 34:4 52:6 79:22 

83:10 132:14 189:20 

291:18 301:2 361:9 

372:10 392:22 399:11 

399:16 420:8 441:7 

450:5 451:22 452:4 

ground-truthing 352:22 

group 7:17 8:15 9:13 

21:15 32:20,22 33:12 

46:18 47:2 66:12,15 

66:21 67:14 88:10 

111:1 119:1 121:19 

138:22 156:19 162:2 

167:20 170:1 208:12 

209:3 309:2 391:4,5 

391:18 453:10 

groups 66:5,6 150:18 

167:19 226:12 391:17 

groves 111:16 

grow 121:9,10 148:5 

150:4 168:11 195:21 

197:11 213:20 214:14 

221:10,20 229:10 

237:3 255:14 271:21 

273:15,22 279:13 

298:18 301:3 306:14 

313:10 353:15 355:16 

358:1 388:9 419:14 

grow-out 233:13 

grower 12:17 140:1 

144:1,13 150:8 

195:19,20 261:6 

299:10 301:1 302:8,9 

302:22 419:12 

growers 16:22 144:8 

161:3 162:9 164:6 

196:13 234:20 244:19 

251:11,16 253:12,12 

254:9,12 256:14 

261:5,7 263:8 269:4,4 

273:10,20 280:20 

281:19,21 296:9 

299:15 301:20 317:16 

319:13 322:16 374:15 

376:10 377:19 380:7 

403:18 409:5 451:12 

growing 22:11 33:1 

36:2 78:11 124:3 

126:13 139:10 140:13 

143:19 144:14,20 

146:18 147:11 155:17 

188:7 199:17 210:8 

229:7 234:6 268:14 

268:22 305:1 333:20 

387:6 401:1 404:1,8 

404:13 408:16 409:6 

451:8 

grown 17:5 125:8 134:2 

143:6 146:21 147:2 

147:10 161:20,21 

163:13 194:6 216:10 

229:8 257:3 273:13 

283:21 284:1,15,20 

290:1 293:11 297:1 

346:7 355:14 393:5 

growth 75:21 86:10 

146:2,5 168:7,8 194:8 

219:3 221:14 231:17 

236:11 244:10 252:17 

278:1 328:5,10,11 

344:20 

grubs 231:6 

Guelph 206:16 

guess 88:22 94:16 

162:13 186:3 198:4 

249:2 279:7 303:17 

310:9 347:18 382:8 

440:16 442:11 

guest 7:13 

guests 15:10 

guidance 21:20 27:15 

251:20 280:7 282:13 

291:18,19 309:22 

350:2,10 351:3 367:5 

367:8 368:20 369:4 

397:4 438:9 

guide 109:18 

guiding 19:13 

guilty 90:1 

Gwendolyn 442:19 

H

habitat 356:5 

halal 364:10 

half 129:15 145:19,21 

186:11 235:15 312:12 

314:20 331:3 339:19 

349:2,13 449:17 

half-life 167:16 

ham 139:17 179:19 

hammer 294:10 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
473 

Hampshire 10:19,20 

347:21 

hand 6:16 18:18 45:21 

72:19,22 73:5,9 

102:16 201:18 245:15 

271:7 277:12,21 

318:6 375:4,8,13,21 

377:18 383:22 

handbook 77:5 438:9 

handful 144:16 

handing 96:7 

handled 77:9 267:14,16 

handler's 10:4 

handlers 102:18 254:12 

298:12 

handles 414:15 

handling 48:15 102:15 

115:6 431:2,6 435:20 

hands 17:15 334:19 

400:17 

Handsome 9:21 

hang 17:12 292:16 

hanging 434:1 

happen 47:15 152:5 

192:12 221:19 246:9 

246:9 315:16 341:18 

342:19 

happened 25:8,15 

178:12,13 319:17 

323:20 336:8 426:12 

431:4 

happening 34:3 40:21 

47:11 50:6,22 63:5 

69:14 75:2,7 79:22 

81:15 83:22 95:11 

260:7 340:13 348:1,2 

384:8 399:16 400:4 

405:2 406:12 426:15 

428:19 429:17 438:18 

445:17 453:3,4 

happens 45:16 114:8 

312:20 318:5,6 

445:15 447:7 

happy 15:14,17 31:19 

34:8 44:9 74:15 191:5 

196:9 269:3 291:20 

310:2 386:11 432:21 

hard 20:6 27:14 29:4 

43:13 106:22 108:5 

114:9 121:16 158:8 

199:18 218:6 260:9 

280:12 283:5 324:17 

331:16 334:16 360:20 

360:21 370:3 383:20 

428:3 430:7,12 432:1 

442:18 444:2 448:20 

harder 193:14 360:5 

Harding 307:18 314:18 

314:21 318:4 319:1,3 

319:6,20 320:21 

321:3,6 322:8 323:6 

hardship 27:5 

hardworking 26:19 

harm 295:15 

Harriet 1:12,15 3:7 8:19 

8:22 12:19 14:2 97:11 

133:9 151:4 161:18 

176:1 184:3 196:20 

205:22 226:9 247:7 

247:21 283:11 286:17 

290:14 347:15 354:3 

432:20 450:8 451:10 

451:18 

harvest 17:7 78:17 

126:15 130:19 131:3 

132:3,3 144:10,17 

194:7 197:14 292:6 

harvested 127:18 

310:21 313:9 

harvesters 309:21 

harvesting 131:15 

142:3 310:16 

hated 301:16 

Haugen 323:11 326:19 

Hawaii 12:6 

hazard 170:2 

hazards 389:18 

he'll 41:18 

head 96:18 253:4 297:5 

338:22 

headed 385:17 

healing 171:17 

health 11:1,1 12:16 

14:20,21 21:17 46:20 

57:18 118:8 169:16 

201:16 202:6 219:12 

225:16 266:21 271:12 

274:19 315:14 316:15 

317:11 318:3,11 

370:19 371:21 380:3 

388:16 

healthier 22:13 

healthy 22:19 356:9 

hear 7:12,15 17:7 78:7 

78:16 85:6 87:10 94:7 

95:8,14 112:21 154:7 

154:21 165:1 210:2 

240:5 242:9 243:6 

265:5 273:9 279:9 

287:4 322:16 331:18 

341:1,20 342:12 

345:6 347:20 386:19 

394:22 433:10 434:11 

436:12 437:4 

heard 81:14 85:2 169:1 

169:13 206:3 271:6 

303:19 317:4 322:4 

330:5,10 333:13 

336:3 340:22 341:3 

347:19,20 371:4 

390:2 391:6 405:11 

413:17 426:11 437:16 

437:18 445:8 

hearing 25:13 74:19,20 

181:9 243:4 249:3 

342:18 347:19,21 

389:17 392:3 404:22 

440:21 

heart 64:8 95:2 202:12 

326:22 404:3 

heartbreak 17:22 

heartedly 303:18 

hearts 28:2 

Heather 2:9 3:18 

207:11,11 218:1 

heavily 156:5 160:10 

230:17 302:18 376:7 

449:16 

heavy 443:1 

held 141:15 238:21 

hell 301:18 

hello 5:1 9:3 205:13 

307:21 426:7 

help 41:2,16 66:18,19 

72:7 93:18 105:11 

109:11 113:21 193:11 

199:12 204:22 205:1 

215:9,14,22 228:21 

251:21 260:4 261:5 

278:12 286:1 288:6 

312:10 336:1,15 

346:22 375:17 402:3 

427:19 434:19 444:8 

helped 272:1 318:15 

432:2 

helpful 88:9 106:21 

109:18 122:15 155:21 

182:13 273:9 297:14 

378:11 

helping 40:16 43:20 

52:13 204:16 205:3 

280:19 282:2 432:5 

helps 52:12 246:4 

heme 167:19,21 

hemoglobin 176:8,15 

176:16 177:2,6 

hemp 435:13,17 

hen 206:19 207:5,20 

212:16,16 418:9 

hens 207:8 213:15,18 

220:15 221:1 231:3,8 

233:11,12 418:18 

herbal 226:22 227:12 

228:2 229:2 

herbally-based 227:1 

herbicidal 298:13 

herbicide 301:1 407:4 

449:8,9 

herbicides 273:17,20 

303:1 

herbs 227:4,17,19 

herds 379:7 

hey 74:5 93:14 289:9 

411:15 

hi 12:8 91:4 247:6,7 

250:3 254:2 335:7 

363:7 365:17 378:16 

382:1 408:4 426:1 

hide 364:4 

high 15:11 24:17 27:13 

53:8,13 89:14 129:16 

140:14 144:4,10 

146:13 149:7,17 

152:12 169:5 176:8 

177:9 185:7 188:1 

190:21 192:8 209:18 

210:5 214:10 215:4 

215:13,15,19,20 

216:5,6,7 217:15 

222:12 224:10,22 

225:15 226:14 228:18 

233:16 247:14,14 

249:6,10 261:10 

274:5 279:11 281:2,6 

302:22 385:16 

high-nitrate 148:15 

high-producing 131:22 

high-risk 53:20 

higher 51:5,6 74:10 

113:18 132:19 133:18 

134:7 140:20 175:9 

189:18 209:6 216:21 

228:7 365:14 425:14 

highest 129:7 134:4 

highlight 37:17 49:7 

106:8 134:19 403:12 

highlighted 23:14 

highlights 98:8 105:19 

148:3 

highly 58:6 243:4 324:5 

hire 42:13 43:8 

hiring 42:10 

historical 145:14 178:8 

207:22 

historically 352:12 

histories 79:10 305:16 

306:1 

history 79:12 89:21 

90:12 208:11 319:18 

381:6 430:22 434:12 

434:15 435:2 

hit 61:17 239:4 418:4 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
474 

hitting 61:22 128:21 

449:22 

hobgoblin 415:12 

hold 9:16 15:11 24:16 

53:10 92:2 114:19 

212:2 242:1 265:8 

303:1 365:13 383:12 

431:1 

holder 285:18 

holding 15:15 361:5 

373:5 

holds 5:15 118:13 

119:18 

hole 428:18 429:20,21 

holiday 44:3 

holistic 260:9 

holistically 121:7 

home 92:5 243:19 

268:17 269:4 324:14 

331:8 

homeowners 268:9 

honest 52:21 247:21 

301:3 

honestly 87:21 88:3 

425:17 

honey 359:21 408:7 

409:19 410:16,17 

honor 15:12 21:14 29:4 

honored 19:18 405:13 

hood 429:14 

hoop 451:21 

hope 19:2 21:8 95:4 

99:20 106:14 108:13 

197:1 282:9 290:22 

292:15 316:13 317:14 

320:13 327:17 388:18 

406:8,10,12,13,17 

427:17 

hoped 436:21 

hopeful 246:14 

hopefully 123:11 

143:13 194:12 310:3 

356:9 400:13 428:5 

hopes 377:10 

hoping 80:8 199:21 

409:14 

horizon 262:21,22 

324:1 325:3,5,6 

horse 416:16 

host 83:7 

hosting 21:1 

hot 139:17 274:22 

Hotchkiss 11:10 

Hotel 1:12 

hottest 375:17 

hour 314:20 349:2,13 

hours 69:11 127:22 

house 329:3 390:14 

409:5,6,8,8 

House's 5:11 

housekeeping 283:17 

286:4 

houses 451:21 

hovers 89:16 

Hub 10:7 

Hubbard 243:9,14,15 

247:2,7,19 249:7 

250:11 252:9 253:3 

huge 6:12 134:1 172:2 

204:6 233:8,10 

268:10 284:5 316:7,7 

317:11 

human 165:15 169:16 

170:6 171:10,20 

172:8 174:12 176:15 

177:6 202:6 219:12 

266:21 274:19 388:16 

humans 177:9 219:14 

hundred 323:13 326:10 

420:5,15 

hundreds 27:21 44:15 

202:4 235:19 

hung 284:3 

hurdle 141:22 

hurdles 139:20 385:5 

hurry 419:15 

hurtful 176:3 

hydro 397:17 404:15 

hydroponic 24:3 25:11 

34:13 36:6 74:20 75:5 

79:5 82:15 83:1 

283:21 284:13 285:1 

285:10,12 286:1,4,16 

287:10 288:4 289:12 

290:1,5 333:15 

355:17 356:12 361:12 

371:3 379:13 393:22 

394:2,4,13 397:11,21 

399:2 400:21 405:19 

405:21 408:14 414:22 

433:17 436:17,20 

hydroponic- 393:17 

hydroponically-prod...

358:16 

hydroponics 33:1,20 

35:10,22 36:1 75:9,15 

75:21 82:18 283:17 

283:19 284:16 287:1 

287:7 289:19 333:9 

333:19 362:2,21 

371:8 390:21 393:20 

396:18 397:15 405:1 

408:5 451:7 

hypothetical 33:5 

304:10 305:4,6 

398:18 399:3 400:22 

hypotheticals 80:19,20 

80:21 81:4,9 94:13 

288:11 306:10 307:10 

I

IARC 169:21 

ice 420:8 

Idaho 427:19 428:13 

idea 18:9,10 20:2 64:6 

178:3 251:9 256:18 

258:8 278:20 287:16 

299:21 302:7 315:12 

341:15 382:18,21 

399:10 416:8,11 

439:8,10 447:11 

ideal 143:21 149:16 

351:18 408:1 

ideas 238:19 252:1 

254:7 308:7 436:10 

438:19 

identified 8:14 46:21 

47:2 142:1 162:1 

169:6 225:18 226:6 

396:10 

identifies 274:9 393:2 

identify 56:2 131:21 

141:20 160:14 287:9 

450:18 

identifying 141:6 

248:17 281:17 389:18 

390:16 

idle 340:9 

ignorance 253:15 

ignorant 170:19 

ignored 360:8 

Illinois 118:16 119:20 

illustrate 7:20 

illustration 55:3 139:13 

imagine 17:22 178:2 

230:19 231:13,18 

284:1 415:6 

immediate 23:16 

137:12 192:3,4 

356:18 384:1 397:10 

397:16 406:20 452:20 

immediately 78:17 95:5 

385:8 397:2 399:12 

immune 171:16 

immunity 174:12 

impact 54:13 61:5 

113:5 118:4 140:22 

141:1 145:7 149:3,18 

191:21 225:16 276:14 

313:5 317:12 393:5 

415:3 

impacted 60:4 61:3 

impacting 138:11 

impacts 131:15 149:14 

163:20 195:18 259:8 

280:19 308:12 309:15 

309:19 313:20 372:7 

372:9,10 380:5 382:4 

382:9 

impart 151:7 

imparting 135:22 

imperative 281:4 

implement 39:9 250:6 

280:17 282:11 326:6 

389:10 397:13 402:21 

438:8 

implementation 25:4 

27:13 348:8 397:21 

implemented 294:15 

324:3 326:14 328:7 

330:1,12 346:13 

409:22 

implementing 246:1,3 

implicated 385:10 

import 46:15 47:7,8,20 

49:3 50:8,14 68:2 

383:19 396:15 

importance 105:10 

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important 26:1 43:2 

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76:18 87:6 95:6,18 

115:21 125:3,22 

139:6 140:16 142:19 

143:22 168:5,13 

172:20,21 184:8 

194:20 195:1,4 204:6 

204:6 215:3 244:19 

258:9 267:19 293:9 

313:3 314:1,13 

315:11,13,20 321:5,8 

321:14,18 322:19 

328:20 345:20 362:19 

363:18 365:13 372:11 

376:16 389:7 404:11 

405:20 417:7 433:10 

433:22 443:2 451:4 

importantly 217:10 

309:10 

imported 385:11 

importer 54:21 56:3,11 

importers 56:2 

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54:18 373:8 384:5 

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386:7,8 

impression 234:16 

236:3 322:10 

impressionistic 361:15 

impressive 327:20 

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improve 29:3 34:18 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
475 

285:13 370:17 403:1 

improved 92:18 282:13 

improvement 45:1 

72:20 74:12 255:9 

282:16 388:8 424:2 

436:9 

improvements 255:21 

423:20 

improving 22:16 23:7 

102:4 280:18 

impugn 242:8 

in- 361:8 

in-between 160:6 

in-field 161:4 

in-kind 122:20 

in-person 205:17 

322:18 439:3 

in-soil 75:11 

inactive 369:11,14 

inadvertently 193:12 

incentive 182:16 

255:14 

inch 145:18,19 

include 25:7 65:8,11 

99:21 102:14,17 

219:7 314:11 316:9 

352:4 364:8,20 

367:10 368:8 369:9 

372:6 

included 47:16 55:8,12 

55:19 68:12 100:1 

101:12 112:4 314:7 

314:14 363:17 403:10 

includes 34:15 48:1 

381:14 453:10 

including 19:14 25:19 

34:12 42:16 78:14 

83:11 118:2 157:20 

202:6 246:6 248:5 

292:4 311:21 315:8 

373:7 381:6 

inclusion 71:10 363:12 

367:16 

income 107:15 108:14 

108:15 193:6 418:20 

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414:21 

inconsistency 413:2 

415:6,12,14 

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151:19 201:5 403:22 

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316:18 404:12 

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280:9 

incorporates 330:18 

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187:1 213:6 344:20 

344:21 348:5 

increased 22:6 40:15 

54:21 64:4 74:3 87:3 

108:7 124:4 130:20 

144:2 219:10 344:8 

354:17 

increases 85:22 187:17 

281:11 

increasing 37:4 102:1 

109:7 131:11 160:22 

187:12 246:18 360:3 

420:13 421:19 

increasingly 167:14 

359:7 

incredible 360:14 

incredibly 43:11 399:7 

incremental 50:4 

255:21 262:6 263:8 

incumbent 83:13 285:4 

incur 252:5 

independent 207:8 

209:9 210:9 362:16 

389:17 418:12 

independently 232:5 

267:8 451:6 

Indiana 216:11 

indicated 170:8 344:8 

374:18 

indigenous 12:5 

individual 34:21 56:7 

66:10 67:15 213:16 

242:5,9 268:19 

324:20 351:17 353:17 

359:9 

individualized 67:13 

individually 66:14 

391:4 

individuals 67:12 206:9 

242:6 

induced 380:13 381:6 

industrial 361:12 

industries 143:16 

156:22 162:17 

industry 38:12 85:20 

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130:13 140:7 149:22 

150:13 155:16 156:13 

158:22 162:18 164:13 

164:14 183:5 192:4 

192:17 194:22 195:2 

196:10 199:19 204:7 

208:13 209:3 285:4 

285:11 288:17 301:5 

328:5 341:5,18,21 

342:6 344:4,13,19 

345:13,19 346:6 

369:5 376:4 417:21 

417:21 426:13 427:9 

427:9,18 428:19 

442:2,22 447:21 

448:20 

industry's 84:21 85:21 

inefficient 285:18 

inerts 25:8 390:7 

inevitable 96:5 

inevitably 174:8 

infancy 26:8 

infant 390:9 

infants 176:7 

infiltration 359:18 

449:21 

influence 126:11 

133:20 222:1 

influenced 132:9 

influences 131:6,12 

influencing 19:21 

133:21 

inform 91:11 109:11 

250:20 380:11 450:19 

information 41:5 48:20 

52:4,11 56:18 65:22 

66:7 67:10 71:11 72:2 

75:18 76:1 88:6 91:5 

91:13,20 92:1 97:19 

98:21 100:1 108:15 

110:20 169:16 188:22 

201:21 210:12 229:20 

230:5 237:19 245:9 

248:6 249:18 253:1 

253:14 266:6 267:4 

267:10,13 292:11 

295:17 296:3 298:1,7 

299:2,6 306:16 

322:12,22 351:16 

352:9,11,13,16 

371:17 378:10 399:20 

399:22 414:6 415:17 

431:11 445:11 447:10 

448:8 450:15 

informative 74:18 

informed 286:9 370:13 

infrastructure 380:5 

ingest 234:9 

ingested 171:22 

ingredient 10:3 120:1 

130:5 155:5,8 180:8 

180:14 187:20 193:7 

202:22 210:3 224:15 

225:18 274:4 364:3 

365:11 366:6 425:9 

430:18 

ingredients 128:2 

157:19 180:5,6 

182:16 198:3 215:10 

218:8 220:3,8 222:8,9 

222:12 224:7,9 225:1 

226:15 227:3 228:7 

228:11 229:2 363:13 

363:15 364:2,4,7,19 

365:1,7,10,18 366:13 

369:11,14 381:12 

425:12 

inherently 158:2 

inhibiting 175:13 

inhibitor 147:22 

inhibitors 191:3 

inhibitory 174:7 

initial 123:15 124:8 

126:4 131:16,17 

137:4 194:10 

initially 81:17 122:12 

179:8 183:9 

initiated 291:21 292:19 

initiative 5:12 57:1 

122:14 123:4 125:18 

442:2 

initiatives 54:3 119:2 

441:21 

innate 174:12 

innocuous 177:7 

Innovation 182:21 

innovations 404:2 

innovative 415:20 

input 19:21 238:17 

278:19 309:20 315:7 

322:3 341:1 380:17 

406:22 446:12 

inputs 45:12 134:6 

285:3 290:8 308:9,12 

309:13 312:5 313:5 

314:9 394:4 403:14 

407:4,7 

inquiry 440:3 

insect 215:17 223:18 

230:11,17 277:11 

278:13 389:1 

insects 224:2,6 229:17 

232:8 285:15 

insert 268:10 

inside 22:6 235:7 301:3 

420:12 

Insider 42:8,9 63:19 

insist 264:10 

inspected 88:19 

inspecting 253:6 376:2 

inspection 46:20 51:2 

57:18 67:22 112:13 

inspections 54:8 68:15 

88:15 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
476 

inspector 12:21 49:12 

57:17 69:9 112:14 

295:22 298:5,21 

334:12 376:2 423:1 

inspectors 60:12 65:5 

66:8 70:1 337:4,19 

instance 176:6 402:19 

Institute 12:4 120:10 

383:18 

institutional 345:5 

instruction 310:1 

400:22 434:6 436:16 

452:21 

instructions 67:4 

433:15 434:9,18 

438:10 439:21 450:10 

450:20 

insufficient 225:14 

intake 222:15 

integrated 46:7 

integrating 46:11 

integrity 14:11 19:15 

20:10 29:7,8 36:14,20 

37:8,21,22 45:6,12,20 

60:14 63:22 64:13,14 

64:18 70:7,11,19 71:3 

71:6 96:11 101:6 

103:5 104:2,13,21 

161:11 244:11,15 

247:3 249:13 251:1 

251:18 282:21 293:11 

336:16,21 358:6 

373:8 378:20 396:3 

396:17 398:1,6 

427:15 428:2 431:20 

439:1 444:3 445:6 

intended 257:18 

intense 28:6 

intent 15:5 24:11 

259:14 260:3 367:16 

368:14 386:3 

intention 163:14 

inter-agency 63:12 

interact 103:8 

interaction 103:19 

403:21 

interest 6:5 38:5 87:8 

155:2 193:2 215:17 

237:20 238:5,6,7,9 

261:2 330:11 389:15 

interested 43:20,20 

65:9 85:15 111:13 

229:12 312:19 370:5 

interesting 74:8 106:8 

109:1 130:2 134:15 

138:8 145:9 152:14 

165:17 229:13 267:12 

269:8 312:12 

interestingly 131:7 

134:3 

interests 391:20 

interface 357:11 360:16 

interfere 225:2 

Interim 366:21 

internally 249:12 

international 17:2 

53:16 169:21 

internationally 32:12 

254:6 

interpret 336:20 434:9 

434:19 

interpretation 24:15 

119:9 439:20 440:2 

interpretations 440:8 

interpretative 439:11 

interpreting 436:16 

interrupt 242:10 

intersection 388:16 

intervene 184:2 

interviews 124:8 

intestinal 176:21 

intimate 407:9 

introduce 9:1,14 13:22 

96:17 115:8 

introduced 41:9 368:11 

introducing 4:15 14:3 

117:2,16 

introduction 67:19 

120:15 303:6 

introductions 3:2 6:11 

introductory 333:6 

invest 74:6 282:7 

invested 376:6 

investigate 35:6 150:5 

200:14 359:9 400:5 

445:12 

investigated 225:10 

399:15 

investigating 51:11 

53:3,4 94:8 

investigation 54:5 

160:7,8 385:9 434:3 

447:11 

investigations 41:4 

47:12 49:15,16 51:13 

51:22 52:1 53:1,14 

62:2,13 68:16 434:8 

446:4,5 

investigative 40:18 

89:9 93:2 

investing 71:5 439:5 

investment 45:15 69:19 

70:17 73:11 125:16 

193:5,16 360:14 

389:6 

investments 194:16 

246:17 280:22 

invisible 70:14 

invitation 208:16 

invite 30:3 

invited 6:4 

invites 396:13 

invoices 55:14 423:2 

invoicing 284:8 

involve 60:19 414:2 

involved 33:3 57:5,17 

139:15 169:4 171:15 

195:16 196:17 244:6 

251:22 302:18 318:13 

433:9 451:12 

involvement 392:2 

involves 76:16 148:9 

involving 33:1 

IOAS 53:16 

iodine 338:17,19 

ion 166:6 

Iowa 206:15,17 216:11 

395:13 418:5 

iron 167:8,9,19,21 

189:14 348:14 

irrigating 127:17 

isothiocyanate 20:3 

issue 35:20 77:3 82:2 

82:15 94:15 95:4,6 

116:18 122:8 178:22 

182:10 194:15,20,20 

195:4 204:6 215:8 

225:6 227:22 232:7 

244:15 267:2 270:22 

290:19 318:13 333:19 

372:4 377:11 380:9 

389:18 393:2,22 

397:3,10,11 412:5 

420:13 423:22 427:19 

427:21 438:3 439:21 

440:13 451:7 

issued 90:14 93:11 

170:4 

issues 25:2 26:16 77:16 

83:7 89:3 90:13 104:8 

148:19,20 151:17 

163:1 200:15 204:19 

214:2,8,11,13 217:7 

217:11 224:21 225:14 

225:16 227:14 277:16 

277:19 293:8 311:11 

313:14 314:1 333:15 

333:20 334:19 350:6 

358:5 359:1,14,15 

360:15 362:15 371:14 

379:10 390:16 396:15 

420:18 421:20 437:3 

439:4 444:2 450:4 

451:19 

item 72:1 332:20 333:3 

373:9 451:16 

items 25:17 103:6 

238:10 284:12,13 

J

Jacksonville 82:16 

289:10 

January 5:5 39:6 55:16 

60:3 272:14 325:16 

326:3 

Jay 386:17 387:15,20 

387:21 391:9,9 

393:16 395:5 

Jeanne 45:9,19 

Jeanne's 45:14 

Jeff 124:14 136:13 

Jennifer 2:6,14 3:8 4:7 

26:21 31:1 118:13 

128:18 157:5 161:11 

180:20 

Jennifer's 135:14 

Jenny 9:3 13:22 74:17 

78:6 82:11 84:4,19 

87:17 88:14 91:4 

95:10 96:14 97:10 

283:12 304:5,6 305:7 

336:3 340:2,22 

343:12 345:11 348:20 

349:5,15,17 399:5 

406:8 411:21 437:18 

440:11,19 

Jesse 1:16 11:19 

111:10 112:10 259:11 

259:11 260:13 275:10 

Jesse's 263:20 276:19 

Joan 44:14,17 45:19 

job 39:2 42:6 92:8 

101:10 311:20 329:1 

360:5 401:22 

jobs 17:18 342:17 

John 387:11 

join 6:4 21:8 

joining 14:16 237:10 

340:7 

journal 206:22 

judgment 33:16 

judgments 77:16 

juice 147:3 174:5 184:6 

186:3 187:20 196:14 

juiced 127:21 

juicer 141:7 142:9 

196:2 

juicers 142:1 185:3 

juicing 124:20 130:11 

130:19 141:6,11 

184:9 

July 138:1 340:7 347:22 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
477 

420:10 

jump 296:6 406:4 423:6 

450:3 

June 125:20 

justifications 59:10,17 

justify 160:3 163:9 

381:11 

K

Kate 387:18 392:7 

395:6,11 400:11 

401:12 

keep 18:22,22 27:12 

28:22 41:3 62:4 93:13 

102:19 141:1 178:16 

200:3 205:6 285:20 

293:9 307:5 324:6,19 

336:20 337:1 348:18 

360:20,20 363:11 

390:18 416:22 429:9 

436:10 

keeping 52:21 104:10 

131:10 248:16 296:10 

keeps 253:17 

kelp 416:1,2 

kept 24:9 

Kerry 2:14 118:19 

122:21 128:2 142:12 

144:12 146:19 148:13 

150:13 158:8 196:3 

key 34:9 36:11 103:16 

104:9 118:22 122:17 

126:7 163:21 343:18 

354:9 379:4 393:2,11 

kickoff 47:2 

kids 329:2 

Kiki 243:9,15 247:6 

253:21 297:10 

Kiki's 293:18 

kill 236:20 

kilogram 173:2 

kinds 86:13,18 182:15 

305:19 344:10 346:9 

346:14,15 394:19 

451:11 

knew 126:11 171:5 

knowing 125:9 128:8 

145:22 247:13 284:5 

362:18 441:2 

knowledge 122:9 

158:13 166:10 170:12 

179:5 183:8 197:11 

199:22 287:17 336:13 

known 23:12 202:9 

219:17 284:14,16 

knows 268:8 

knuckle 264:1 

kosher 364:10 

Kraft 120:5 

Kristjan 2:8 206:11 

Kristjian 3:17 

kudos 101:7 

Kyla 363:6 366:19,21 

369:20 

L

L 3:14 

lab 207:12 

label 29:8 55:8,12,18 

83:6,19 118:20 180:5 

180:15 199:3,7 

249:13 282:21 287:8 

288:16,20 289:1,12 

294:17 356:7 357:18 

359:8,22 362:20 

363:18 366:6 371:18 

388:11 390:4 396:4,8 

424:15 

labeled 283:19 286:5 

350:17 362:3 363:15 

364:6,18 366:10 

368:22 371:9 384:4 

labeling 120:3 287:19 

287:20 288:6 289:2 

290:19 364:15 370:10 

371:3,12 390:21 

labels 287:22 359:6 

364:3 365:10,11 

366:18 

labor 70:14,20 113:18 

375:15,19,20 

laborious 375:17 

Labs 73:8 

lack 24:5 83:8,9 348:7 

378:21 379:12,21 

390:2,5 397:20 398:2 

398:12 419:6 

laid 441:7 

land 17:20 18:7 78:13 

79:3,9,12 80:14 94:16 

94:21 126:20,21 

127:6 213:21 214:14 

305:15 306:1,3 

313:10 411:9 434:12 

434:15 435:2 449:6 

landfills 302:14 

landlord 301:16 

landscape 122:15 

449:18 

language 24:13 46:12 

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281:15,20 282:14 

292:5 367:19 368:14 

392:14 429:12 

languishes 160:6 

large 35:5 59:3 89:13 

89:16 94:6 116:5 

140:11 156:22 160:15 

164:10 183:20 189:10 

224:16 231:10 333:18 

348:5,9 442:22 

453:11 

largely 161:4 285:3 

403:16 

larger 109:13 123:2 

137:1 139:9 162:20 

209:10 234:18 348:9 

largest 119:12 172:4 

209:11 232:2,3 

357:14 

LaRocca 291:12 300:9 

300:12,15,16,16 

304:2,4,16,20 305:5 

305:13 306:11,18,22 

307:2,7,11,13 

larvae 225:8 

larvaes 215:19 

laser-leveled 449:7 

lastly 29:10 149:20 

242:6 285:20 

late 17:8 127:18 131:17 

179:9 190:14 239:18 

419:16 

latest 169:16 280:14 

Latin 229:5 

latitude 17:10 

Laughter 237:16 247:1 

257:9 286:11 288:14 

291:9 300:11 323:19 

326:20 353:10 387:12 

launch 37:20 63:22 

68:3 69:17 272:2 

launched 40:13 118:9 

439:2 

launching 60:13 

Laura 426:5 430:9 

432:16 436:7 441:19 

law 5:16 94:17 287:12 

324:3 326:14 379:1 

381:19 383:13,13 

389:21,22 394:18 

layers 209:5 210:19 

231:18,19,20,22 

233:3 

laying 206:19 207:5,7 

207:20 212:15,16 

220:15 221:1 233:11 

233:12 418:8,9 

lead 36:16 58:13 63:17 

64:11 66:11 67:8 

218:21 228:4 246:19 

280:22 311:8 342:5 

leader 271:22 

leaders 66:18 

leadership 16:6 41:8 

85:12 343:19 388:6 

442:1 

leading 16:13 42:17 

375:22 

leads 14:9 16:8 118:20 

214:8 225:14,15 

444:20 

leaf 315:22 318:7 

375:11 

learn 34:3 52:14 76:20 

80:22 83:21 84:2 

447:18 

learned 34:1 58:16 69:7 

120:19,21 136:10 

399:14 

learning 37:21 60:14 

64:1,6,14 65:2 67:13 

70:5 244:8 312:20 

404:8 439:1 

learnings 139:3 

leased 301:15 

leave 161:14 175:6 

216:13 329:5 434:1 

leaves 185:5,6 210:1 

285:22 368:17 401:11 

leaving 207:2 239:20 

lecturer 207:12 

led 16:1 125:20 395:17 

402:11 442:19 

left 6:22 50:12 67:18 

165:6 292:22 325:2 

325:10 359:9 

legal 75:17 279:13 

288:13 306:9 346:2,9 

424:19 

legally 24:8 

legislation 14:14 

legislature 16:1 

length 38:11 206:2 

lengths 61:3 

lengthy 309:17 

lesions 214:9 219:10 

Leslie 369:21 373:13,17 

378:9 

lesson 69:2 

let's 6:16 8:20 31:4,20 

36:10 38:2 45:20,22 

48:5 54:6 62:17 67:17 

70:10 72:19 73:5,9 

96:14 164:20 211:3 

216:12 251:16 262:18 

262:19 295:10 302:6 

303:9,11 321:3 

373:12 429:9 

letter 433:1,6,13 453:9 

letters 38:6 63:5 88:3,5 

338:9 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
478 

level 17:22 31:21 36:22 

53:21 62:3,3 72:1 

78:2 91:17 97:1 

130:20 132:19 156:2 

173:14 175:13 182:1 

182:3 198:17 207:1 

217:4 223:1 247:14 

250:17 261:10 327:9 

327:13 345:5 379:1 

384:10 421:19 422:9 

446:13 

leveling 327:10 

levels 132:9 134:1,4,7 

138:4,5 140:14,15,20 

141:17 144:4,11 

145:4,8,9,13,16,21 

146:10,13 147:13 

149:12,17 152:7 

164:12 167:2 172:19 

175:1 181:19 182:5 

185:7 189:19 199:14 

214:18 224:22 233:15 

245:6 249:22 252:13 

leverage 448:8 

levied 62:15 

Lewis 2:3 4:17 204:13 

279:19 283:8,11,12 

286:17 289:6,16 

290:11 291:7,10 

liability 192:7 

licensing 265:15 

lie 64:8 

lies 155:2 

life 23:6 29:12,19 120:3 

141:13,14,21 177:4 

398:5 412:13 419:2 

421:1 

lifestyle 22:19 

lifetime 226:4 

lifetimes 174:16 

lift 444:11 

lifting 443:1 

light 131:11 241:14 

287:3 

lights 241:2 

Lima 1:17 12:8,8 

365:17 

limit 117:9 239:5 

241:11 247:11 253:19 

259:16 260:3 421:16 

421:17 

limited 24:20 103:18 

110:7 142:2 159:21 

225:5 230:2 239:7 

241:17 245:19 275:17 

375:19 381:17 385:14 

limiting 157:4 212:7,11 

limits 191:15 217:5 

line 181:7 220:13 285:5 

334:6 422:4 

lines 163:6 350:4 

link 282:22 388:13 

linked 196:5 

linking 109:3 

linseed 215:11 

liquid 184:13,18 185:13 

186:8 187:16,17,22 

313:8 314:11 382:6 

liquor 390:10 

Lisa 1:17 12:8 365:16 

list 2:4 4:19 23:19 39:1 

39:2 62:20 63:6,7 

67:18 74:5,9 115:15 

191:20 195:17 202:22 

224:8 227:18 239:5 

256:7,20 264:13 

270:3 274:4 275:9 

299:22 351:18,20 

374:5,8,12 377:12 

381:3,13 389:11 

394:5,17 403:10,17 

404:6 430:16 431:8 

listed 115:18 160:11 

165:15 

listen 20:8 238:19 

241:17 

listening 96:12 234:20 

235:17 

listeria 168:14 

listing 256:13 412:14 

418:22 435:7 

literally 27:20 56:5 

361:21 

literature 131:4,8 

210:15 216:2,3 218:8 

220:12 227:13 

litter 214:5 420:13 

little 7:5 13:13 16:10 

17:12 18:12,14 29:18 

29:19 63:6 70:9 87:13 

90:11 95:16,19 

106:14 110:19 111:20 

115:9 121:16 165:11 

175:2 196:21 204:1 

208:9,11 209:6 

211:10 216:20,21 

218:5,11 220:8,10 

228:14,15 233:5 

235:13 240:15 258:1 

275:14 278:11,19 

284:3 285:22 292:4 

293:14 302:16 314:7 

352:22 371:15 382:17 

386:16 422:12 423:8 

431:10 437:10 439:8 

439:10 443:4 452:14 

live 10:11 12:7,10 28:11 

64:19 67:6 171:14 

lived 206:12 

livelihoods 271:14 

377:13 

lives 28:3 329:2 353:9 

livestock 13:17 22:20 

24:1,2 38:4,9 42:10 

42:19 57:8,11 62:16 

71:10 84:21 85:13 

100:18 101:9,15 

102:12 103:3 104:1 

104:20 105:14 205:19 

258:19 312:6 328:7 

329:8 330:1,7 334:2 

336:4 338:2 340:19 

341:6 343:22 351:9 

358:9 379:7,8 390:9 

397:1 402:8 423:21 

427:14,21 428:14 

429:1,7 

livestocks 336:9 

living 13:20 212:15 

296:22 404:7 

load 70:2 

loaded 218:4 

loam 127:9 

lobster 307:15 

local 22:20 100:4 114:1 

269:21 359:21 391:18 

392:1 

locally 272:4,4 

locate 230:3 

located 418:4 

location 78:10 141:7 

locations 102:21 

lockstep 109:21 

Lodi 12:7 

Logan 2:12 3:13 119:3 

196:3,12 198:8 

Logan's 164:9 182:14 

195:18 

login 67:10,11 

logistics 130:13 136:19 

294:8 

logos 284:7 

long 23:19 56:19 102:4 

103:7 108:12 116:22 

221:20 239:19 250:17 

287:19 288:1 311:13 

319:18 325:15 344:14 

346:3 381:3,6 385:22 

428:3 

long-term 69:18 255:6 

longer 233:13 234:2,12 

273:22 297:3,4 

318:16 348:7 

longer-term 263:2 

longest 101:1 

Longmont 12:4 

longtime 336:10 

look 8:17 13:18 31:20 

43:19 45:22 51:1 54:6 

57:4 60:11 70:4,10 

71:1 72:3 83:14 91:8 

93:10,14,16 98:5 

108:5 130:13 132:4 

136:17,18 138:9 

153:16 162:17 172:8 

174:21 180:11 193:18 

194:3 195:14 202:19 

203:15 204:20 212:17 

227:12 229:6 257:5 

293:22 321:13 335:22 

337:5 344:12 346:6 

360:4 366:18 411:22 

425:11 434:22 439:16 

443:9 447:8 452:14 

452:22 453:8 

looked 79:21 84:6 

126:10 131:3,15 

145:14 148:10 153:6 

162:1 200:15 203:19 

210:1 218:9 220:11 

221:22 222:6 223:19 

224:8 278:18 446:15 

448:19 

looking 25:10 51:17 

59:6 61:20 71:8 76:12 

85:18 94:12 95:21 

96:12 103:16 121:9 

121:13,21 126:16,17 

128:18 129:5 131:4,9 

131:11 134:20 136:3 

138:10 149:10 150:20 

157:16 158:3,4 182:6 

183:22 211:21 220:5 

220:12 257:20 258:15 

263:1 279:1 289:10 

320:18 399:21 400:3 

421:13,17 422:3,21 

423:1,22 425:13 

435:5 

looks 177:11 205:14 

226:8 227:3 236:22 

291:22 453:18 

loophole 26:5 

loopholes 23:15 384:3 

loops 194:5 

lose 247:4 316:4 329:1 

329:3 331:8 335:17 

335:18 340:13 348:4 

losing 18:6 141:16 

329:6 

loss 181:6 219:1 316:6 

328:13 356:4 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
479 

lost 19:8 54:10 101:2 

325:8 328:13,16 

331:15 339:15 404:5 

lots 60:7 68:11 142:6 

166:18 249:9 354:21 

354:22 

loud 241:7 

loudly 412:6 

love 19:9 93:4 209:13 

312:1 347:8,9 

loved 273:17 

low 130:7 131:10 

149:18 164:12 175:12 

189:17 216:22 217:13 

222:16 223:3,9,20 

224:1,2,20 226:13 

228:21 274:16 339:16 

421:19 422:6 

low-hanging 251:10 

lower 152:8 172:19 

182:3 221:12,14,14 

230:18 233:6,15,19 

233:20 285:13 354:18 

375:22 376:1 

lowered 171:3 191:4 

lowering 131:8 222:1 

lowest 212:2,6,8 

lubricants 83:8 

lucky 325:2 

Luddites 285:16 

lunch 196:22 205:6 

Lynn 243:9,10 253:22 

254:2 257:10,12 

263:19 269:5 

lysine 214:20,22 215:6 

215:14,21 216:6 

226:14 228:20 

M

MacDonald 109:16 

machine 444:9 

macro 425:12 

macroeconomic 18:2 

Madam 13:6 269:12,13 

Madison 1:12 2:12,13 

117:21 120:9 121:2 

125:21 126:21 127:22 

133:12 146:21 

magic 285:19 

mail 268:7 

main 36:10 151:10 

227:15 262:18 350:8 

352:19 

Maine 401:20,21 452:2 

mainland 12:6 

maintain 34:18 161:9 

285:6 286:6 328:5 

402:22 

maintaining 45:11 

231:17 396:3 

major 162:1 315:8 

419:15 443:1 

majority 28:16 77:18 

90:6 92:11 125:15 

131:7 140:11 147:5 

236:8 

makeup 153:17 

making 4:13 19:21 

44:20 96:8 123:17 

154:9 166:5 190:3 

237:11 255:21 324:5 

347:1 348:9 427:10 

man 284:18 

manage 64:22 66:16 

335:16 403:3 

managed 127:1 235:21 

236:4 368:4 

management 38:17 

59:20 65:2 70:13,15 

86:17 99:3 118:5 

126:14 132:2 133:4 

195:10 197:14 207:6 

306:3 344:11 345:1 

350:19 367:12,21 

368:7,9,15 402:20 

403:7 446:1 

manager 2:4 4:19 16:15 

41:20,22 42:1 97:4 

managers 43:12 

managing 16:13 

mandatory 71:21 102:3 

102:16 105:2 371:12 

438:21 439:6 445:8 

448:22 

Mandel 366:19 369:21 

370:1 373:10 

manner 222:5 434:21 

manual 237:22 

manufacture 274:15 

manufacturer 430:14 

manufacturers 309:20 

352:14 381:11 431:5 

manure 127:11 133:1 

134:11 219:9 223:16 

231:6 

map 51:15 

maple 402:8 

March 40:14 55:5 

marginal 217:6 

marginally 222:3 

margins 397:6 

marijuana 321:17 

Marin 72:18 

marine 29:18 308:2,8 

308:17 309:4,12,17 

309:20 310:7 313:13 

390:17 392:11 416:14 

mark 195:9 

marker 436:1 

market 12:12 16:22 

17:11 22:11 36:19 

86:1,3,4,13 88:8 

125:8 130:6,8 139:10 

143:16 144:15 148:6 

151:14 156:20 158:4 

160:16 164:10 185:5 

244:21 247:17 251:12 

253:13 272:3 282:3 

326:5 339:9 376:20 

385:3 388:9 396:6 

418:9 431:20 435:17 

436:2 

market's 86:21 87:2 

market-driven 160:6 

marketing 4:10,22 

100:2,12 402:2 433:4 

marketplace 21:19 

28:14 29:7 245:12 

246:16 248:14 249:11 

253:20 255:17 357:10 

392:2 435:13 439:15 

444:4 

markets 17:2 23:14,18 

357:8 376:18 

Maryland 12:10 207:14 

mass 68:9 181:1,5 

190:8 

Massachusetts 10:12 

massage 24:12 

massive 328:8 

master's 14:19 118:15 

207:15 230:5 

match 385:20 

material 40:1 68:17 

115:11,14 116:4,12 

153:12 161:10 177:21 

187:18 190:8 244:18 

244:22 261:1,2,13 

265:17 271:4 274:8 

275:9,17 277:3,21 

313:19 317:7,8,17 

318:14 319:14,17,22 

320:5 367:5,14 

369:13 373:22 

materials 2:5 21:19 

24:3 39:20 115:22 

116:7 153:1 244:1,14 

245:6 250:13 254:11 

254:14 256:12 257:6 

260:4 270:8,12 

272:12 273:1 294:18 

308:1,2,8,17 309:12 

310:7 313:4,13 317:1 

332:5 377:18 389:18 

390:18 392:11 393:22 

394:2,7 403:5 416:14 

Mathews 2:4 4:19 117:1 

117:15 120:14 121:1 

137:10 138:16 150:22 

154:7 161:15 164:16 

164:22 175:18 195:8 

matrix 296:22 

matter 8:14 114:21 

127:8 170:8 184:18 

186:14 193:21 205:10 

212:9 228:19 337:15 

345:1 349:9 354:22 

354:22 355:9,11 

453:21 

matters 214:20 337:11 

358:17 362:4 389:4 

maturation 145:2 146:1 

146:10 

maturity 131:14 

maximize 61:7 

maximum 181:17 

189:22 200:11 

Mayer 120:4 

McCluskey 269:10 

279:19,20,21 283:7 

McDaniel 2:9 207:13 

McEvoy 16:7 

McGee 335:5 340:1,3,4 

McReynolds 254:1 

269:8,12,15 274:6 

275:15,20 276:2,7,12 

276:22 277:4,7,17 

278:8 279:3,16 

319:11 

McRoberts 383:10 

386:17,18 387:3 

meal 212:18 213:7,10 

213:19,21 215:11,11 

215:12,18 224:10,20 

225:3,5 228:13,15,15 

228:22 232:10,17 

310:22,22 314:12 

425:13,13 

mean 76:8 82:2 88:18 

88:22 107:16,16 

138:6 152:7 157:1 

179:10 186:1,3 

192:17 195:12 197:15 

200:5,9 229:5 232:3 

241:2 275:16 276:13 

296:9,20 297:15 

305:17 310:22 313:7 

319:5 330:9 345:17 

361:19,21 377:17,18 

382:20 398:12 412:9 

413:15 448:21 

meaning 28:2 170:1 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
480 

315:9 

meaningful 313:16 

354:14 386:2 

means 7:2 19:1 32:4 

63:12 105:3 129:12 

140:22 146:12 296:6 

332:1 341:16 351:8 

359:8 407:7,8 417:6 

meant 198:4 367:17 

measurable 281:11 

measure 145:3 161:10 

337:7,8 

measured 145:2 

measurement 120:3 

measurements 337:18 

measuring 186:2 

meat 116:8 120:8 

124:20 136:1 139:16 

140:6,18,19 142:20 

142:20,22 143:21 

148:8 149:2,13,19,21 

151:9,14,21 152:4 

154:20 155:1,12,14 

155:15,16,19 162:18 

166:5,9,15 167:4 

168:2 169:4,10,11 

178:8,11,12,15,20 

179:13,16 181:16 

182:9,11 186:6,18 

187:18 188:21 190:1 

192:6 200:8 201:1,4 

203:13,21 220:20 

224:22 

meat-based 220:2 

meathead 166:4 

meats 115:12 141:3 

151:15 156:4 165:22 

166:12 168:15 169:17 

169:22 170:5 171:9 

172:12,15 177:22 

178:2,5 180:11,12 

193:6 197:6 198:13 

198:21 200:9 203:18 

mechanical 427:11 

mechanism 170:14 

183:5 380:2 

mechanisms 223:12 

mediated 163:20 

medical 10:13 177:5 

medium 348:4,10 

meet 17:19 24:4 61:14 

73:15,20 136:21 

140:5 143:6,11 

158:21 162:11 181:22 

212:21 213:5 248:13 

249:14 265:16 268:12 

272:16 274:11 280:20 

336:19 368:12 375:9 

402:3 409:3,15 

449:15 

meeting 1:7 4:6,12,18 

6:7,14 8:20,21,22 9:5 

13:8,15 15:6 21:12 

25:18 33:13 40:9 

74:21 81:22 84:7 85:7 

85:11,11 92:6 96:13 

100:6 116:18 205:17 

226:2 237:22 238:1 

238:11,17 239:1,3,8 

254:18 255:19 266:1 

270:15 272:13,20 

282:10 289:11 292:2 

301:11 304:10 305:7 

305:9 306:9 308:22 

311:7 332:17 333:7 

343:19 380:8 383:21 

405:9 409:17 426:8 

433:7 436:8 437:17 

meetings 5:7 13:3 22:5 

206:1 321:1 333:13 

403:16 404:22 438:16 

meets 275:8 410:10 

Megan 443:4 

member 10:10 22:4 

116:11 119:16 120:9 

241:21 291:15 310:20 

325:17 361:6 362:14 

363:10 370:6 387:14 

390:7 

member-owned 357:14 

members 6:21 7:3,6,9 

9:13 13:9 21:15 28:21 

29:17 30:5 46:21 

116:16 117:2,6 

137:11 151:1 175:19 

195:9 205:14 232:6 

238:3,8 240:1,3 242:4 

269:13 283:12 314:16 

350:8 351:3 357:15 

359:14 378:18 391:2 

391:13 395:8,20 

433:8 

membership 382:13 

391:10,17 392:1,6 

396:12 433:8,14 

memberships 391:18 

Memorandum 47:13 

memory 171:16 

Mendenhall 387:19 

392:8 395:8,11 

398:15 400:8,12 

401:10,13 

Mensonides 323:10 

327:17,19,19 329:18 

330:20 

mention 155:10 160:19 

315:19 

mentioned 25:17 40:9 

68:6 84:5 94:15 99:9 

104:7 105:16 125:16 

136:7 144:18 150:2 

157:8 162:22 200:5 

217:3 236:2 376:10 

382:18 442:7 451:19 

mentioning 79:11 

message 85:14 293:5 

343:18 345:4 

messages 225:13 

messaging 286:2 

messing 369:22 

messy 420:14 

met 1:11 64:3 74:10 

77:1 84:14 182:1 

211:5 235:2 339:5 

metabolic 171:1 

metabolism 218:12 

metals 83:8 

meter 337:9 

Methiomax 226:20 

227:9 

methionine 2:14 3:16 

7:19 29:22 205:7,18 

205:21 206:3,10 

207:19 208:2,3,22 

209:18 210:3,6 212:8 

212:12,14,20,22 

213:1,7,8,14,14,22 

214:15,17,18 215:4,5 

215:13,20 216:5,8,13 

216:17 217:1,3,4,6,8 

217:13,16,19,22 

218:10,14 222:5,10 

223:2 225:14,20 

226:2,14 227:5,12 

228:2,7,17 231:9 

232:13,17 233:21 

234:10 236:12 390:11 

390:12 419:4,6 

420:18,22 422:12 

424:7,12,13 425:15 

425:19 

methionine- 216:18 

methionine-deficient

222:3 

methionine/lysine

225:7 

method 187:2 380:18 

381:2 394:10 

methodology 102:20 

methods 177:21 178:4 

225:19 244:2 255:12 

291:16 292:18 305:16 

338:3,6,12 351:11 

352:1,8 380:13 381:5 

389:14 402:18 403:13 

403:19 

methyl 263:15 

metrics 337:5,6,18 

Mexico 73:3 410:7 

Miami 56:12,19 

mic's 287:2 

Michael 19:4 20:18 

Michelle 2:1 6:12,15 

209:1 240:13 242:15 

242:18 260:19 348:13 

433:1 

micro 107:17 

microbes 285:21 

microbial 152:18 188:3 

microbiologically

178:17 

microbiology 118:14 

micrococcus 154:4 

mics 243:4 

mid- 294:18 

mid-1980s 171:6 

Mid-America 10:6,7 

mid-March 48:8 

mid-May 41:12 419:17 

mid-scale 270:18 

middle 9:10 113:11 

420:10 452:17 

Midwest 58:11 90:17 

118:11 162:3 188:7 

212:18 

Mike 255:4 257:15 

265:8 

mildly 243:4 

miles 16:7 323:13,13 

milestone 282:18 

milk 209:17 224:18 

323:13 325:1 326:2,4 

328:6,11,19 336:18 

339:21,22 342:5 

428:8,11 

milking 397:8 

Milkowski 2:11 3:14 

119:18,22 120:7 

165:1,3 175:19,21 

176:7 178:6 179:15 

189:8 197:22 198:7 

198:10,14 201:17 

milks 323:12 

mill 228:16 417:13,16 

milled 272:4 

millennia 178:3,12 

milligram 173:2 

milligrams 172:10,14 

172:16,17 

million 156:3,6,9 

166:15 180:21 184:4 

184:5,6,7,16,17 189:1 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
481 

189:5,16,22 190:9,16 

190:18 203:1 210:19 

316:9 

millions 157:1,1 

milliseconds 167:17 

mills 207:9 

mind 22:21 28:22 62:4 

75:12 102:19 156:18 

253:18 326:2,3 

mindful 143:18 

minds 156:17 415:13 

mine 309:14 329:9 

mineralization 138:12 

minerals 309:14 381:8 

425:14 

minimal 137:4 191:8 

minimize 253:14 403:2 

minimum 61:17 84:7 

134:22 181:17 

mining 107:5 

Minnesota 118:15 

418:5 

minor 170:5 230:14 

minute 137:11 195:9 

241:10 325:10 342:18 

minutes 114:18 151:2 

204:3 211:5 233:10 

240:13 242:3 325:9 

348:19 349:7 

missed 201:11 428:8 

missing 218:19,20 

284:7 

mission 35:9 49:22 

412:2 

mission-driven 243:17 

280:1 

Mississippi 11:20 

283:14 

Missouri 10:6 

mistake 306:8 

mistakes 104:9 

misunderstood 304:21 

305:2 

mitigate 354:7 

mitigating 353:22 

354:10,15 355:5 

356:10 

mix 256:17 

mixed 192:15 193:9 

mixture 166:16 

mode 74:22 75:19 

266:11 267:18 274:11 

modern 170:12 

modes 266:16 

modest 15:13 

modified 296:20 

module 47:7 

MOFGA 402:5 404:14 

405:18 410:15 412:15 

413:13 414:14 

moisture 219:9 223:1 

232:11 

molecule 167:13 

MOM's 12:12 

moment 14:8 444:17 

money 28:1 47:5 70:14 

385:21 

monitor 146:10 

monitored 145:5 

monitoring 191:11 

244:17 

monocytogenes

168:14 

month 146:1 385:14 

months 49:14,16 69:1 

69:15 93:11 177:4 

188:9 223:15 230:18 

342:20 350:19 367:14 

368:5 421:5 

moratorium 356:18 

379:15 382:18 397:10 

397:16 404:14 405:1 

405:12 408:5,7 409:1 

409:12 414:21 415:4 

416:11,19 417:3 

morning 4:3 6:10 7:12 

10:9,15 15:7 31:3 

42:12 44:22 80:18 

154:11 284:2,19 

323:16 341:9 345:12 

401:18 437:19 444:14 

445:8,20 453:20 

mortality 214:12 

Mortensen 1:19 10:15 

10:16 82:11 108:22 

110:10,13,21 111:3,5 

180:17 182:12 234:15 

235:16 237:8 243:3 

263:19 264:8,20 

265:3 278:15 291:3 

296:16 297:3,8 

321:22 323:5 347:15 

347:18 378:5,8 

382:16 383:7 

MOSA 127:4 

moss 309:14 313:4,11 

mother 176:12 

motivate 193:9,12 

motley 44:5 

mouth 173:11,13 

mouths 393:4 

mouthwash 175:12 

move 62:17 85:6 95:8 

115:3 126:3 137:13 

138:17 156:12 160:17 

164:21 167:14 175:21 

177:17 199:13 237:13 

237:18 238:14,16 

243:6 251:20 255:3 

291:2,6,20 314:3 

315:12 317:13 330:9 

343:20 345:22 380:15 

380:22 397:2 405:21 

408:1 409:7 410:22 

437:8 441:2 444:8 

451:5 452:7,13 453:7 

453:15 

moveable 409:8 

moved 10:16 229:22 

261:11 315:6 347:22 

415:22 436:22 453:2 

movement 15:20 122:7 

363:21 388:6 396:6 

moves 437:11 

moving 38:21 39:2 41:4 

112:19 142:11 165:10 

248:7 251:9 314:10 

314:17 330:11 346:2 

416:22 436:10 445:6 

much-needed 251:5 

mulberry 210:1 

mulch 8:11 302:10 

multi 58:3 

multiple 43:8 69:3 

89:20 97:1 101:20 

102:5,21,22 104:7 

256:13 409:8 

multiplier 113:12 

multiply 211:1 

multitude 6:20 

municipal 265:19 266:4 

267:2,9 

muscle 171:4 190:6 

202:12 233:17 

mushrooms 408:9 

412:19,20 

mutagenesis 293:7 

380:14 381:7 

myoglobin 167:5,8,9 

mysterious 171:5 

N

N 127:13 

name 4:7 9:15 10:9 

90:10 154:17 239:14 

241:19 243:11,14 

254:2 269:15 279:21 

283:9 304:11 307:17 

307:21 325:7 331:13 

335:7 338:15 340:3 

353:15 357:6 363:8 

366:20 373:13,16,20 

383:11 395:10 401:18 

417:14 430:12 

names 133:10 229:5 

NAS 103:7 

NASS 2:10 3:9 98:9 

99:2 101:3,12,17 

102:10,20 103:3 

105:3,5,16 344:5 

nation 42:22 

national 1:5 2:2,3,4,4,5 

2:6,9 4:6,8,19 6:2,17 

9:4 13:3 21:13,21 

25:20 27:15 28:15 

31:5 32:19 33:20 

34:11 35:1,17 39:1,2 

44:2,6,13 46:4 55:6 

77:18 92:6 95:11 

96:20 97:1 100:8 

115:15 116:19 156:2 

191:20 208:20 237:19 

256:20 270:2 331:20 

334:7 351:18,20 

359:8 374:5,8,11 

377:12 378:17 379:21 

381:13 389:11 394:5 

394:17 395:9,16 

396:1,5,21 398:22 

402:11,12 403:10,17 

404:6 411:2 412:11 

424:5 430:16 431:7 

433:11 435:7 439:4 

440:5 442:8 443:12 

443:22 

nationally 243:18 280:2 

411:1 

Nations 12:3 

nationwide 58:2 398:1 

native 310:17,17,18 

natural 23:1 34:18 

59:20 76:15 124:17 

136:5,13 152:20 

172:3 182:15 283:12 

320:1 356:8 359:20 

363:12,14 364:2,7,19 

365:1,10,18,20,22,22 

366:5,8 371:14,16 

404:7,12 405:4 416:8 

424:18 435:4 

naturally 219:15 222:9 

naturals 311:4,9 

nature 16:15 90:4 109:8 

Naturopathic 10:13 

NC 271:2 

near 59:4 

nearly 155:14 431:14 

necessarily 94:12 

136:1 146:5,7 159:5 

160:15 163:9 196:13 

228:8 235:8 248:22 

263:9 298:7 413:3 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
482 

necessary 53:9 245:12 

294:7 295:8 341:5 

354:7 384:18 442:5 

necessity 260:5 278:2 

needed 7:7,9 23:21 

59:16 82:8 85:3 

127:17 140:14 141:21 

146:4,13 147:20 

149:17 214:14 236:4 

246:17 254:14 258:20 

258:20 261:22 343:4 

343:17 352:12 354:1 

378:10 384:16 

needs 8:2 24:6,13 

25:22 37:7 58:17,20 

58:21 77:2 100:9 

131:20 141:10,16,22 

143:8 164:13 186:6 

217:1 220:17,22 

226:2 246:8 248:6 

255:15 271:1 286:5 

290:18 293:15 331:5 

375:9 448:19 

neem 229:3,10 

negate 413:3 

negative 149:3 309:15 

neglect 452:10 

neighborhood 113:22 

419:21 

neighbors 292:13 

neither 196:14 290:2 

Nell 300:13 307:17,19 

307:21 310:10 311:12 

311:15 312:22 314:4 

nematode 260:22 261:3 

nematodes 255:13 

260:16,19 261:22 

263:13 

net 108:15 448:5 

network 161:2 391:16 

418:11 

never 82:19 273:17 

287:11 290:4 299:5 

361:11 400:14 403:20 

424:14 431:2 

new 7:1,3 8:1 9:11 

10:19,19 18:17 19:11 

26:14 32:4,9,10 40:10 

40:13 41:8,10 43:7 

51:15 54:7 69:1 70:2 

73:3 75:22 84:22 

87:19 92:20 97:13 

163:10 174:16 192:6 

194:3 240:22 246:22 

267:10 285:17 341:17 

341:22 342:11 347:21 

354:6 368:11 379:16 

397:10,17 401:2 

404:15 410:7 415:1 

419:9 420:22 438:9 

439:14 440:4 442:7 

445:22 446:10 447:12 

newborn 176:7,18 

newer 201:21 

news 63:21 440:19 

NGO 119:7 

nice 217:9 

nicely 350:4 

night 9:11 

nine 188:9 340:6 

nitrate/nitrite 200:4 

nitrates 129:7 146:3 

148:19 151:12 169:17 

201:12 203:12,17 

nitric 167:11,16 171:7 

171:12,21 173:1,21 

202:5,11,16 

nitrite 142:16 147:7 

152:1 153:9 157:7 

165:9,18 166:5,20 

167:7 168:16 169:4 

170:6,11,14 171:22 

172:3,10,13,17,19 

173:4,15,17,19,20 

174:6 175:10,12,15 

176:16,22 177:2,8 

179:4,6,11,12,17,21 

180:1,9,12 181:14 

182:3 184:14,17,20 

189:16 190:1,17 

191:3 198:1,10 199:9 

201:19 202:5,7,11 

203:5 390:10 

nitrites 115:13 142:22 

151:12 169:17 201:13 

nitrogen 124:4 125:1 

127:12 128:9 129:12 

131:13 132:6,8,14 

144:3 147:13 160:21 

163:17 164:2 165:16 

170:20 171:20 174:3 

189:14 214:7 354:12 

354:19 

nitroglycerine 202:9 

nitrosamine 190:13 

191:3,11 

nitrosamines 190:22 

191:9,12,15 

nitrosohemochrome

167:22 171:8 

nitty- 451:14 

no-brainer 435:20 

NO2 167:12 

NO3 167:12 

NOC 74:21 301:11 

305:6,9 331:14 

332:17 333:7 378:21 

380:4 381:9 382:3,6 

noise 241:7 

nomination 48:6,22 

nominations 7:4 37:13 

48:1,6 

non- 56:7 271:3 281:14 

281:21 282:6 350:14 

350:20 

non-certified 92:12 

non-compliance 62:4 

62:10 

non-compliances 62:8 

90:14 

non-disclosure 251:7 

non-methionine 209:21 

non-optional 288:20 

non-organic 23:13 

106:5,11 165:20 

295:1 305:17 350:11 

359:19 367:13,21 

368:1 381:12,16 

non-organically 115:18 

non-processed 165:22 

non-synthetic 374:13 

375:8 

nonagricultural 430:17 

nonsensical 428:13 

nonsynthetic 308:12 

309:13 430:18 

NOP 3:8 6:10 7:16,21 

8:13 24:10,20 25:3,14 

25:22 26:19 28:10 

31:1 36:11 41:8 46:19 

55:16 56:15 57:6 

64:20 65:17 74:14 

101:5,7,20 102:16,22 

103:18 105:3,5 204:9 

238:5 272:21 280:16 

282:11 301:9,12 

304:1,18 309:21 

314:22 315:6 316:13 

317:2 333:12,14,14 

340:12,17 350:10 

354:1 355:13 356:17 

358:8,12 360:7,11 

377:4,7 380:1,3 384:1 

384:2,17,19 385:4 

386:6 389:10 396:16 

397:1,3,9,13 398:7 

407:13 410:9 428:22 

429:2,3,11 436:8 

437:22 438:4,7 

439:20 442:13 445:22 

448:7 

NOP's 5:4 

NOP-compliant 431:12 

norm 26:7 27:8 

normal 141:17 176:15 

north 169:7 269:20 

270:17 272:2 316:21 

Northeast 452:3 

Northern 197:6 

Northwest 9:7 21:3,7 

90:19 264:5 325:18 

395:13 

NOSB 2:1 3:6 5:6 7:15 

7:22 8:13 9:12 10:10 

21:11 25:1,1,4 28:10 

28:14 39:9,13 40:5 

44:10 47:22 48:21,22 

75:12 116:20 205:17 

209:16 238:18 239:8 

254:7 282:9,14 

291:15 308:3,11 

309:1,8,10,16 314:15 

315:8 332:16 333:8 

340:12,17 354:1 

355:13 356:11 361:6 

377:8,10 378:18 

379:9 380:4,8,11,19 

381:15 382:13 383:21 

388:5 389:10 390:7 

391:2 393:10 397:12 

397:14 409:21 413:9 

426:8 430:15 436:20 

437:8 442:13 443:19 

451:6,16 

NOSB's 38:4 308:7,20 

not-replicated 134:13 

notable 202:8 

note 63:1 73:22 98:14 

103:6 129:2,13 

135:18 170:4 202:18 

225:9 257:2 259:3 

266:6 302:16 360:7 

noted 25:7 106:9 

277:11 375:20 376:2 

notes 13:7 134:9 

331:22 411:21 

notice 39:21 55:15 

112:12 227:15 

noticing 283:6 

notified 55:6 

noting 170:5 

novel 75:9,14 77:8 

NPEs 338:18,19 

nuance 405:13 

nuances 33:8 

number 7:7 46:3,6 

49:13 56:8 62:21 

69:16 71:1 74:4 100:7 

102:9,14 105:20,22 

107:13 108:3,4 109:9 

139:14 140:10 148:17 

153:7 160:10,20 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
483 

169:2,4 170:18 174:4 

174:7 182:15 193:12 

198:2 199:2,4 201:18 

248:20 253:8 260:19 

285:17 287:21 305:11 

305:14 306:4 315:16 

319:14 325:14 329:11 

344:20 348:5 358:5 

364:14 396:16,16,17 

396:19,19 397:3,9 

443:15 

numbers 31:21 94:6 

97:16,17 102:7,7 

106:16 107:12 328:12 

344:22 

numerous 27:4 157:3 

374:12 

nurseries 255:14 

nursery 255:10,22 

256:1,4 261:6,11 

262:7,15 263:3,7 

nut 216:4 224:10 

368:17 

nutrient 354:20 381:8 

381:17 402:20 403:7 

nutrients 147:14 223:6 

313:10 403:3,9,9 

nutrition 2:8 10:18 

206:14,17,18,19 

207:2,5,6,17,18 

nutritional 120:3 225:2 

236:17 

nutritionist 207:4 

nuts 128:5 210:4 

O

Oakley 1:19 11:15,15 

78:6 80:3 81:6 93:21 

106:19 138:3 229:16 

252:20 259:12 273:6 

303:17 304:3,6 310:6 

310:11 311:13 312:8 

319:9 329:21 334:15 

372:16,20 392:10 

398:11 404:21 406:3 

406:7 413:12,22 

423:18 

Oaks 11:15 

Obama 429:9 

obligation 437:7 

obnoxious 241:3 

obscuring 23:10 

observations 59:21 

obtain 125:17 127:20 

352:13 

obtainable 352:16 

obtained 135:12 

obtaining 194:10 

obvious 27:11 103:16 

obviously 107:13 143:3 

146:17 152:7 235:6 

311:1 312:4 322:8 

418:14 421:5 447:1 

occasions 103:10 

occupation 106:10 

occupational 318:20 

occupy 357:9 

occurred 58:2 422:22 

occurring 91:17,17 

318:15 

ocean-based 314:9 

October 13:7 100:14 

396:22 

odds 360:10 

OFA 397:12 

Off-microphone 30:12 

30:17,20 

offense 269:11 

offer 20:14 148:14 

244:4 332:21 336:10 

336:13 

offered 272:14 

offering 362:9 

offers 64:15 129:4 

office 5:11 12:5 14:16 

34:6 38:17 44:15 

46:16 49:12 57:16 

86:17 243:19 344:11 

345:1 447:7 

official 2:7 4:12 51:17 

officially 4:5 

OFPA 78:11,20 81:12 

264:17,19 276:3 

311:7 355:20 359:4 

360:10 

OIG 434:3 

oil 54:14 375:7 382:2,3 

oils 375:3,10 

Oklahoma 11:16 

old 127:17 144:19 

284:2 318:9 

older 18:5 210:21 

421:20 

Ole 11:20 

OMB 38:9 

OMC 154:22 157:13 

omnivorous 219:15 

on-farm 133:8 

on-the-ground 400:3 

onboard 340:9 

once 67:2 82:17 141:20 

149:1 242:2 375:10 

423:11 429:1,11 

one's 197:1 

One-Cert 73:6 

onerous 19:7 

ones 24:4 86:18 87:22 

93:10 156:17 232:10 

261:16,20 266:1,12 

347:4 426:19 

ongoing 53:1 62:2 

252:17 416:6 

online 60:6 64:15 

onward 137:13 

op 325:18 

opacity 448:15,16 

open 7:4 31:8 35:17 

42:5 48:6 163:6 

177:12,15 330:8 

332:1,8 

opened 332:11 

opening 4:5 63:17 

379:17 

openly 26:22 

openness 87:10 

operate 48:14 141:18 

232:4 249:20 389:12 

operated 209:9 232:5 

operates 48:12,16 

196:10 

operating 438:15 

operation 24:14 33:3 

33:12,19 34:19,21 

48:13,15 58:5 62:3,16 

76:16 81:12 89:15 

94:21 102:16,22 

259:5 288:2 304:12 

361:12 367:22 368:1 

390:3 394:13,14 

399:2,14 401:2 407:9 

418:17 

operations 16:5,18 

24:3 31:10,22 32:14 

34:12,13 36:5 53:4 

54:9,9,12 58:18 59:17 

60:12,17 61:10 65:8 

74:20 75:5,15 76:14 

76:17 78:10 80:1 82:1 

84:6 89:1,13,13,20 

90:7,21 93:8 96:21 

102:10,12,15,17 

103:1 105:22 109:12 

259:9 305:18 342:14 

367:1 374:10,16,20 

376:7 379:2,16 

385:10,18 386:3 

397:6,11,17 404:16 

410:9 412:15 415:3 

420:4 452:2 

operators 28:17 

opinion 191:18 236:3 

326:8 338:20 356:12 

356:14 429:5 448:19 

opportunities 22:8 72:4 

77:11 117:6 121:10 

251:10 337:17 441:21 

opportunity 77:21 

83:21 120:16 129:5 

138:19 154:13 160:15 

256:14 269:14 333:8 

346:7 353:14 357:6 

363:8 369:16 374:3 

395:10 398:8 430:21 

434:5 435:15 441:22 

442:13 446:2 

opposed 164:14 180:9 

200:18 252:10 264:2 

opposes 381:9 

opposing 85:19 

opposite 411:18 

opt-in 287:19 288:5,16 

289:2 437:10 

optimization 129:5 

optimize 121:12 163:15 

optimizing 130:22 

option 351:17,22 352:3 

352:5 431:12 

options 38:18 245:20 

245:20 248:14 253:19 

281:6 

OPWC 254:10,16 255:6 

256:13 265:22 

oral 175:14 203:4 

270:14 

orchard 119:5 

order 3:2 56:17 62:11 

70:20 76:1 117:17 

139:15 140:8 143:9 

166:11 258:10 367:14 

369:1 409:13 434:8 

ordering 99:22 281:10 

orders 93:10 

Oregon 261:17 268:20 

353:16 

OREI 122:13 182:19 

183:11 197:8 

organic's 354:2 355:4 

organically 115:22 

116:2 128:12 148:5 

225:4 289:22 326:4 

350:21 351:1 368:4 

427:8 

organics 11:20 17:13 

19:6 23:7 126:2 

183:10 363:19 364:1 

371:18 384:20 428:3 

430:20 

organism 310:16,17 

organization 44:21 

60:8 66:12,18 88:10 

158:7 183:13 243:17 

269:19 280:2 344:11 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
484 

391:11 

organizations 66:19 

72:12 119:8 391:19 

organized 121:19 

organoleptic 141:2 

149:18 182:10 

oriented 36:14 37:6 

255:15 

origin 23:22 38:3,8 

84:20 85:13 324:4 

326:14 328:7 329:7 

330:1,7 334:2 336:4,9 

340:19 341:6 343:22 

358:9 379:7 390:8 

397:1 427:14,20 

428:14,22 429:7 

original 19:4 369:3 

originally 148:9 416:2 

OSA 243:22 244:13 

248:20 280:7 

Oscar 120:4 

OSP 59:8 

OTA 155:18 442:1 

OTA's 441:20 

ought 385:8 

ounces 159:16 

outcome 137:22 230:1 

257:18 

outcomes 57:3,3 58:14 

61:9 370:20 437:15 

437:21 438:1,20 

outdoor 24:1 209:21 

379:5 420:1 

outdoors 390:15 

outlet 143:10,22 

outlined 245:3 248:20 

412:11 

outpacing 328:11 

329:13 

outpocketing 223:22 

outreach 66:2 95:19 

279:22 

outset 292:22 295:9 

outside 235:5,6,8,14,15 

236:1,10,11 240:3 

246:2 266:3 

outweigh 334:8 386:5 

outweighed 267:1 

overall 21:17 108:18 

110:2 133:18 234:8 

245:17 247:3 323:3 

overarching 359:1 

overcome 137:6 139:20 

141:22 

overfeeding 419:19 

overlap 218:5 

overlooked 403:14 

overnight 221:19 

oversee 36:5 53:7 

overseeing 53:5 

oversight 24:6 27:3 

37:16 46:16 47:17 

49:3,4 50:9,14 53:1 

68:2 397:5 448:6 

oversupply 325:1 

328:19 

overview 3:2 7:10 

37:10,12 

owe 444:14 

owned 154:17 232:5 

owner 300:16 

owner- 28:16 

ownership 51:20 

429:10 

owns 48:12,16 154:19 

oxide 165:16 167:11,16 

170:20 171:7,12,20 

171:21 173:2,21 

202:5,11,16 

oxides 174:3 

oxidoreductive 167:6 

oxygen 176:10,11,12 

P

P-R-O-C-E-E-D-I-N-G-S

4:1 

p.m 205:11,12 349:10 

349:11 453:22 

Pacific 9:7 90:19 264:5 

325:18 

pack 210:17 

packaged 188:2 

packaging 25:12 372:1 

390:9 

packet 203:20 

packets 211:6 

packing 339:12 

pads 175:4 

page 93:15 434:20 

pages 93:13,17 

paid 391:16 

painful 390:5 

palatability 222:12,20 

224:21 

palatable 275:14 

panacea 263:6 

panda 432:13,16 

panel 3:11 7:19 8:10 

115:4 116:10,16,21 

117:2,5 157:14 

203:16 204:4,16,18 

237:10 308:21 312:17 

312:20 380:7,10 

439:11 

panelist 117:16 137:9 

panelists 117:17 

120:11 139:3 154:12 

160:21 226:8 

paper 16:9 103:13 

104:14 258:22 

papered 56:8 

papers 227:14,22 

paperwork 51:18 

parameters 125:7 

446:3 

paramount 296:10 

396:3 

parasite 224:5 

parcels 305:20 

Pardon 319:3 

park 428:22 429:3,5,16 

429:22 

parked 429:2 

part 4:9 26:17 35:10 

57:19 60:19 76:12 

84:11,13 88:17 99:11 

116:11 124:7 136:12 

143:7 151:8 152:13 

159:17,18 171:15 

195:2 205:2 209:12 

212:4,14 229:13 

236:13 237:4 238:18 

245:5 252:10 265:18 

278:21 332:13 350:3 

350:10 362:12 363:1 

363:19 372:13 375:18 

392:21 394:12 407:10 

408:13 410:21 418:16 

434:14 

participant 119:1 287:4 

325:11 

participants 86:2 

participate 142:13 

396:14 

participation 102:1 

438:21 439:6 

participatory 122:6 

411:13 

particular 33:9,17 

46:14 111:12 127:6 

144:22 155:5 178:13 

198:15 244:7 248:1 

252:10 281:7 304:14 

306:7 333:3 365:7 

394:8,9,9,10 412:4 

particularly 53:2 57:8 

89:14 313:13 433:8 

435:14 

partly 361:9 

partner 150:13 

partnering 199:15 

partners 183:6 195:6 

partnership 5:19 54:21 

437:6 

parts 60:20 132:15 

166:15 180:21 184:4 

184:4,6,6,16,16 189:1 

189:5,15,22 190:9,16 

190:18 203:1 292:6 

405:17 

party 44:8 

pass 30:4 137:8 208:5 

237:19 282:10 351:19 

passage 292:1 

passed 46:1,10 252:4 

260:11 334:2 383:21 

passing 16:2 292:16 

316:20 

passion 27:11 

passionate 303:7 

357:16 362:13 

password 67:10 

passwords 67:11 

pasture 23:22 58:19 

61:1,4,19 220:7 

222:14,15,18,22 

223:6,10,14,15 226:1 

229:21,22 230:10,13 

231:5 232:8 234:19 

235:11 237:3 337:8 

339:18 340:18 342:21 

390:8 396:19 420:2,4 

420:7 

pastured 209:8 232:3 

232:22 236:18 

pastures 229:18 420:10 

patchwork 359:5 

path 246:15 262:9 

452:18 

pathogen 166:13 

pathogens 174:8 

Pathology 117:20 

paths 182:19 

pathway 167:15 171:9 

174:2 177:7 179:4 

pattern 394:8,20 

patterns 40:16 51:20 

52:14 92:21 394:17 

Pattillo 2:5 4:21 

Paul 2:3 4:16 13:8 88:4 

204:11 347:4 

pause 416:12,19 

pay 18:12 196:7 252:7 

328:15 335:15,16 

379:19 389:5 

pays 271:9 

PCC 357:7,13 359:18 

360:2,13,16 363:10 

PCO 366:22 368:19 

peat 309:14 313:4,10 

peck 217:20 

pecking 219:2 419:5 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
485 

peer 25:13 379:20 

380:2 437:18 

peer-reviewed 206:22 

pelletized 127:11 133:1 

penalized 295:16 385:7 

penalties 385:19 386:9 

penalty 62:15 

Penn 230:6 

Pennsylvania 207:16 

347:22 366:22 

people 18:6,22 32:8 

36:16 43:3 48:14 60:7 

69:7 81:17 87:4 90:9 

94:12 173:18 193:4 

196:4,11 201:18 

204:21 209:11,13 

237:6 239:5,20 

240:21 270:6 273:17 

276:20 284:9 286:1 

288:6 293:15 294:10 

297:22 298:13 302:11 

310:11 311:21 312:13 

321:16 324:10,18 

331:18 346:21 364:4 

364:10,12 365:6 

384:12 391:16 400:4 

406:15 408:12 409:15 

409:17 417:19 419:20 

420:3,18 421:7,12,20 

422:2 423:6,12 424:6 

424:9,21 429:15 

people's 260:3 

pepper 56:2,6 

peppers 55:7 56:4 

284:14 

percent 17:3 32:2 50:15 

54:9,17,19 61:18,22 

89:17 105:22 106:1,9 

106:11 107:22 127:8 

127:13 143:5 147:15 

155:14 159:13 166:21 

173:10,16 181:21 

182:2 186:9,11 203:1 

209:5 213:13,13 

222:17 223:21 229:4 

229:4,18 236:17 

296:22 328:4,10,13 

328:15 337:14 344:9 

355:9,10 357:20 

397:7 418:2 419:14 

426:20 

percentage 181:20 

186:17 224:1 422:5 

423:14 

Perdue 289:17 

perennial 350:15 

367:13,21 368:1,2,7 

368:16 

perfect 261:12 

perform 295:20 

perfringens 168:8,10 

perfusion 202:13 

period 48:6 80:10 81:19 

82:1 84:9 117:9 

174:21 191:13 234:12 

303:3 307:1 309:17 

309:18 332:6 377:4,8 

377:21 398:13 401:1 

406:10 

periods 420:6 

Perishable 428:12 

peritonitis 214:12 

permitted 363:16 

394:18 

perpetual 332:5 

persistent 170:16 

person 45:10,16 48:15 

96:5,7 103:11 113:15 

116:13 239:7,9 

242:12,13,14 298:9 

307:19 324:17 

personal 359:21 363:9 

365:3 

personally 322:2 325:1 

328:12 363:16 

persons 239:2 

perspective 74:19 88:7 

161:5,8 166:4 208:1 

266:18 

perspectives 199:17 

pertaining 374:4 

pesticide 298:12 

pesticides 355:21 

387:22 391:11 392:13 

393:8 

Pet 25:15 

Pete 426:5 430:8 

Peter 300:13 307:17,21 

310:5 314:19 430:13 

Peterman 2:12 3:13 

119:3,10,14 154:8,9 

161:15,22 162:15 

183:7 192:2 

Peterson 401:16 

417:11,14,15 421:2 

422:16 423:4 424:3 

425:11,17 426:2 

petition 266:5 270:1,7,8 

270:12 272:13 273:2 

274:8 275:16 315:7 

316:11,18 320:7,8,13 

374:4,11 377:9 

383:22 431:1,3 432:3 

petition's 256:20 

petitioned 319:18 

petitioner 315:3 

petitioner's 265:12 

petitions 436:3 

Ph.D 2:3,4,6,11,13 

206:14 207:15 

phase 371:18 

phase-in 309:17,18 

PhD 119:20 

Phil 291:11 300:6,7,15 

303:15 307:14 

Philadelphia 55:5,11 

photographic 56:1 

photographs 55:13,18 

240:8 

photosynthesis 355:2 

phrase 367:11 

physical 118:5 403:1 

physiological 171:13 

physiology 165:16 

170:7,21 171:20 

phytosanitary 255:19 

256:2 260:20 261:9 

261:14 262:12 263:1 

268:13,20 

pick 202:19 261:15 

408:13 

picking 375:8 405:16 

408:17 

picture 73:12,15,18 

139:10 247:4 253:17 

361:11 

pictures 73:19 361:10 

piece 72:1 110:9 184:8 

301:2 302:2 307:7 

359:12 411:9 

pieces 195:5 218:21 

219:7 221:5 409:12 

416:18 

pigment 168:1 171:8 

pilot 183:10 245:5 

246:2 248:8 293:18 

294:12,15 295:7,10 

296:12 

pink 178:18 

pipeline 39:16 41:3 

Pittsburgh 380:8 

placard 284:19 285:8 

place 19:19 21:2 90:18 

191:5 195:6 273:14 

326:7,15 365:10 

383:3 405:6 406:11 

406:19 416:4 421:9 

435:19 439:18 442:4 

447:22 

places 341:7 445:17,18 

450:11 

plan 87:22 122:10 

250:5,6,7,9 317:16 

352:17 380:21 421:9 

421:10 423:10 440:6 

planet 23:2 29:13 

planned 137:20 

planning 122:14 124:8 

125:19 126:4 183:11 

183:14 

plans 51:2 110:17 

112:17 

plant 46:19 57:18 

117:20 126:18 131:14 

132:15 134:8 141:18 

145:13 146:2,11 

184:5,11,12 185:1,3,8 

185:12,15 222:20 

227:20 244:11 281:1 

283:2 295:19 310:18 

315:20 354:22 356:16 

375:11 380:19,21 

403:5,8 412:13 

plant- 169:18 

plant-based 135:15 

219:16 

planted 127:16 291:17 

451:22 

planting 255:8,13 

282:16 292:5,6 

350:11,14,16,17,22 

367:13,18,21 368:1,3 

368:3,8,13,16 

plants 124:5 131:10 

132:19,22 144:3 

271:7 275:1 277:18 

355:14,16 368:1 

403:21 412:18 413:13 

plasma 173:9 

plastic 83:9,11 301:2 

302:2,3,7,10,13,15 

303:12 306:14 307:8 

399:12 434:16 435:4 

435:7 440:15 441:6 

449:9 450:6 

plastics 83:8 

plate 337:9 

play 33:8 82:19 83:15 

264:18 281:16 443:21 

played 329:15 

players 57:5 122:17 

124:9 

playing 27:2 36:22 

327:9,13 379:1 

384:10 427:22 

please 9:15 31:15 42:7 

42:7,7,18,19 43:4,18 

43:19,21 66:12 67:14 

72:7,12 73:15 81:20 

205:14 240:2,4,9 

241:15 242:1 243:11 

283:9 307:17 349:12 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
486 

353:7 372:4 373:13 

401:8,8 429:9 

pleased 31:6 37:20 

42:2 63:21 67:6 70:6 

115:7 280:8 

pleasure 14:3 15:9 

pledged 357:21 

plot 127:6,16 144:13 

plots 129:9,12 163:13 

plow 18:18 

plus 167:9,22 218:14 

296:22 426:22 

pockets 385:21 

podium 240:22 442:20 

point 38:16 77:13 93:22 

94:7 105:18 107:12 

108:4,6 133:3 137:19 

144:20 146:4 148:3 

161:8 162:15 164:9 

177:14 183:7,16 

188:15 189:17 191:6 

192:20 200:11 216:21 

242:18 258:22 260:10 

263:20 283:14 294:3 

324:4 326:14 335:20 

341:10 393:17 400:16 

403:16 405:11,12 

406:20 415:13 440:3 

450:10 

pointed 149:5 161:12 

266:1 292:9 

points 34:9 117:11 

254:19 255:1 286:3 

344:10 379:22 

poison 318:21 

polar 354:3 

policies 237:21 

policy 4:22 14:13,15 

19:22 33:7,18 42:15 

57:3 58:14 75:17,22 

76:2,19 77:4,4,8,16 

77:17 79:8,20 81:2 

82:6 98:4 237:21 

282:20 304:13,18 

305:11,12,15 306:5 

344:1 353:18 383:17 

395:19,20 396:10 

438:4 

polite 426:16 

political 5:16 444:9 

ponic 75:15 

ponics 356:2 

pool 162:20 325:22,22 

326:1,11 

poor 217:14 296:21 

poorly 200:8 

populated 230:17 

population 230:17 

pork 156:1,2 

Port 55:5 243:19 

portfolio 192:14 

portion 185:13,13 

204:7 238:16 

ports 56:19 

posed 308:6 

position 42:3,11 265:20 

266:9 360:10 363:14 

365:9 406:16 414:20 

445:1,4 

positions 395:19 

positive 22:9 267:21 

289:3 317:12 384:14 

423:19 448:6 453:15 

possibilities 256:3 

344:18 

possibility 229:12 

362:9 414:22 

possible 6:15 18:21 

26:6 43:22 50:3 94:16 

272:6 330:14,15 

352:21 371:20 404:16 

406:3,20 415:18 

possibly 81:18 

post 93:7,9,10 

post- 132:2 

post-doc 206:15 

post-harvest 130:16,16 

130:17 

posted 48:21 93:6 

99:13 

poster 230:9 

posting 331:21 

pot 453:4 

potassium 178:14 

190:1 202:22 

potato 209:17 225:1 

272:1 

potent 191:2 

potential 162:20,21 

168:7 193:19 207:19 

224:4 246:5 255:20 

278:13 284:11 306:9 

310:12 358:20 372:4 

potentially 126:11 

201:6 284:12 442:9 

pots 440:15 

poultry 24:1 57:8 

127:11 133:1 134:11 

206:6,17 207:4,17 

211:9 212:9,12 

218:15,16 219:14,18 

220:15 221:1 223:5 

223:13 225:21 226:5 

379:5 390:13 

pound 354:18 

pound-per-pound

425:9 

pounds 127:12 146:12 

159:16 210:20,22 

212:20 213:11 216:16 

419:4 421:1 

powder 3:11 7:19 115:4 

115:9,10 120:20 

122:4 124:6,10,20 

125:14 126:9 135:7 

136:5 137:7 138:22 

139:9,16 140:5,9 

143:14 144:4 146:16 

148:13 150:10 151:8 

155:2,4,4 156:2,5,11 

157:17 159:8 161:20 

162:7,19 165:9,21 

168:17,19 169:1 

177:22 179:14 180:7 

180:13 181:12,13,14 

191:19 192:1 199:3,6 

199:8 200:7,22 216:4 

powders 167:1 224:18 

power 119:1 

powerful 385:2 

PowerPoint 242:21,22 

ppm 128:19 169:7 

181:4,11,11,16,19 

186:7,16 201:7 

practical 27:19 224:15 

228:12 255:12 258:11 

practice 48:4 304:3 

318:16,16 332:4 

356:16 375:3 398:20 

432:6 433:16 439:13 

practiced 367:19 

practices 22:18 34:18 

82:17 83:6,15 100:2 

100:12 109:19 127:1 

127:2,3,19 129:21 

133:14 140:13 161:4 

196:1 251:22 285:3 

290:7 327:10 350:5 

355:16 356:19 388:20 

402:22 404:1 407:19 

407:21,22 442:3 

452:8 

praise 308:3 

pre-converted 151:13 

151:20 

pre-NOSB 332:17 

precedent 248:16 

309:11 310:13 

preceding 78:17 

precious 23:2 

preclude 452:20 

predicament 334:20 

predominant 162:3 

prefer 60:6 80:21 

288:16 320:22 

pregnant 176:4 

preliminary 122:22 

123:1 248:4 

premium 389:6 

prepared 274:7 320:6 

392:18 

presence 244:17 

256:19 

present 1:14 2:1,8 

138:21 169:17 225:11 

254:12 255:20 263:14 

presentation 32:17 

36:11 117:9,12 

120:12 138:17 139:6 

150:12 164:21 204:5 

232:9 242:22 250:4 

255:3 366:3 388:2 

413:2 

presentations 117:5 

177:16 180:18 208:9 

242:21 

presented 140:12 

188:22 230:8 245:4 

267:4 285:11 

presenter 164:18 

presenters 277:11 

presenting 123:14 

180:21 254:3 

presents 155:11 

preservatives 118:21 

preserved 178:20 

preserving 178:11,15 

president 11:19 12:12 

340:4 

presiding 1:13 

pressing 360:21 

pressure 171:3,16 

332:18 

pretty 33:2 59:13 87:2 

90:22 177:7 183:20 

192:8 205:15 215:12 

216:6 233:4 234:14 

267:12,19 327:20 

342:16 412:5 432:11 

453:11 

prevent 223:16 258:10 

318:15 346:12 384:20 

440:1 

preventative 442:3 

prevention 442:17 

previous 101:17 248:21 

250:11,13 366:2 

390:6 404:22 406:4 

previously 5:7 14:13 

80:6 104:8 287:1,7 

328:18 

price 99:4 112:1,8 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
487 

113:18 114:5 303:5 

328:15 339:16 

prices 113:9 389:6 

pride 32:8 

primary 65:17,20 

106:10 136:4 138:7 

138:15 155:1 378:22 

383:18 

Primus 73:8,8 

principal 354:5 

principle 265:4 415:9 

principles 19:14 20:1 

83:18 246:21 363:22 

388:3 

print 69:9 

prior 97:3 144:9 176:13 

237:22 239:3 255:3 

274:8 374:10 

priorities 37:6,7 333:12 

334:8,8 396:10 

prioritization 444:16 

prioritize 370:9 

priority 36:11,18 92:15 

333:16,20 334:3 

396:15 397:12 

private 100:20 119:7 

443:2 

privilege 44:3 

proactive 27:7 439:22 

440:7 

proactively 446:6 

probability 274:14 

probably 82:22 108:9 

138:1 146:3 154:16 

160:13 170:13 175:12 

185:11 192:5 195:14 

206:3 209:11 216:9 

230:18 234:5,9 

341:16 412:14 425:16 

447:18 

probe 109:6 

probing 110:16 

problem 51:10 77:2 

160:12 162:10 177:4 

245:10,14 248:18 

249:12 250:20,22 

263:3 302:14 359:2 

360:8 362:10 400:17 

419:15 429:10 

problematic 24:18 

356:5 

problems 26:8,20 27:8 

28:20 95:22 162:6 

168:11 169:11 231:8 

231:10 244:21 262:9 

263:6 277:11 278:7 

284:5 346:17 348:6 

380:1 390:20 419:18 

420:3 451:3 

procedures 237:22 

process 19:7 22:7 

35:18 48:22 57:2 62:5 

66:3 68:4 85:8 88:2 

88:17 92:17 93:3 

139:19,22 141:6 

143:9 147:4 148:4 

150:9 151:6,11 152:4 

152:8,11,22 157:2 

159:18 163:19 175:3 

179:18 181:10 185:17 

210:7 303:9 308:14 

319:16 320:4,15 

322:1,6 325:6 330:22 

332:13 341:17 349:21 

368:20 369:13 380:1 

385:5 389:8 392:3,21 

403:20 416:13 424:1 

434:11 436:22 437:14 

processed 141:16 

166:12 168:15 169:17 

169:22 402:8 

processes 36:17 

322:20 356:9 402:2 

404:12 437:12 

processing 102:15 

115:19 140:7 142:7 

151:18 181:3,7 

258:18 

processor 158:19 

159:3 

processors 23:5 27:21 

28:17 102:18 142:21 

148:8 151:14,21 

158:17 159:20 

produce 124:5 126:8 

129:6 134:7,18 140:4 

144:3 160:2 163:2 

168:18 179:19 187:19 

217:8 248:13 249:4 

254:4,5,15 261:6 

283:15 327:7 350:12 

350:15,22 356:8 

357:20 410:18 417:6 

433:9 

produced 78:13 94:19 

115:18,22 128:12 

135:7 140:17 148:12 

149:21 179:16 180:11 

180:12 187:19 233:12 

246:20 318:21 350:21 

351:1 352:7 354:18 

393:18 

producer 98:9,11 

100:16 102:10 106:4 

235:10 338:2 394:3 

402:21 403:3 

producers 12:6 15:21 

17:1 32:7 207:9 

209:10 210:9 213:16 

231:3,7,8,10 232:3 

236:7 237:6 245:18 

249:3 259:17 282:9 

309:19 325:19 326:1 

327:7 351:21 357:11 

375:2,15,20 377:1,5 

395:17 406:8 410:17 

419:8 421:3 423:4 

453:11 

Producers' 15:22 

produces 371:7 

producing 116:8 

120:19 129:16 163:5 

192:1 233:18 

product 71:9 96:6 

115:19 120:2 121:14 

125:7 126:12,15 

133:7 136:1 140:17 

142:20 143:1,2,4 

148:8 151:13,20,22 

152:2 157:3 159:4,9 

160:17 163:10 166:5 

168:9 169:10,11 

181:12 182:3,9 186:6 

186:9,12,14 190:3,6 

190:11,12 191:7,16 

193:5,14 201:8 

226:20 227:9 272:9 

287:9 288:7 304:22 

339:8 357:7 376:1 

385:17 424:21 428:6 

428:11 

productions 27:22 

productive 111:16 

products 16:2 48:18 

56:20 78:18 113:7 

116:8 118:22 124:17 

135:6 140:19 148:18 

155:14 156:1 157:21 

160:10,14 163:3,5 

166:9,14 180:16 

188:4,21 189:20,21 

191:4 192:6,13 

198:14,16 203:21 

224:20,22 227:8 

313:8 369:11 378:1 

382:7,11 385:12,15 

393:18 394:2 402:8 

404:6 414:3 435:14 

447:15 

profession 18:6 

professional 64:16 

professionals 45:18 

64:8,17 65:7 

Professionals' 44:9,11 

professor 12:15 117:20 

120:7 121:3 124:15 

206:17 

profiles 135:22 

profit 160:2 328:17 

profitability 376:15 

profitable 139:11 150:9 

profound 171:13 

program's 450:14 

programs 57:9 182:20 

255:19 256:2,5 

260:20 261:9 262:12 

263:1 268:19,21 

269:1 451:21 

progress 69:13 123:17 

125:12 136:22 146:14 

150:19 280:13 356:10 

384:11 

progression 405:4 

prohibit 309:5 436:20 

prohibited 34:16 78:14 

80:13 374:6 376:22 

398:3,14 399:1 

400:14,20 401:3 

407:17 449:10 

prohibiting 396:18 

prohibition 376:9 

433:12 

project 37:18 42:17 

45:17 47:20 51:15 

53:15 56:22 57:5,22 

58:6,16 64:2 84:5 

97:4 105:4 120:21 

121:18 137:2 139:8 

164:14 188:16 245:5 

245:8 246:2,3 248:8 

295:7 434:2 

projects 36:12 49:4 

50:8,9 194:18 207:17 

promise 73:17 225:10 

promising 358:19 

promote 285:12 

promptly 377:11 

pronounce 432:6 

propagated 255:10 

proper 150:16 407:21 

properly 166:11 

properties 118:6 141:2 

151:7 

property 301:19 303:10 

329:2 

proportion 33:15 

proposal 123:6,10,11 

136:8,12 174:11 

244:3 245:3 249:19 

252:11 280:6,8 281:8 

282:10 284:9 350:1,3 

350:9 352:18 353:5 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
488 

367:4,9 380:4 451:14 

proposals 238:1 309:9 

332:8 347:5 

proposed 19:15 37:19 

38:9,12,13 39:10 40:2 

40:4,6 56:16 62:18 

69:21 71:19 72:2 

84:22 86:1,22 87:5,19 

91:9 102:2 250:6,9 

292:3 293:6 308:22 

330:16 343:21 344:6 

344:13,15 346:1,3,18 

346:20 367:10 368:10 

368:14 427:13 

pros 371:8 

protect 45:20 64:17 

339:8 372:12 378:19 

388:7 

protected 298:15 

protecting 36:14 70:11 

92:15 96:2,10,10 

446:4 447:4 

protection 41:13 46:19 

47:6 48:10 118:18 

255:12 388:17 

protects 385:3 388:22 

protein 209:17 211:11 

211:13,15 213:12 

214:1,2,4,7,13 215:1 

215:6,8,16 216:4,13 

218:18 219:4 225:1 

225:15 228:19 232:12 

419:3,10,19 420:13 

420:16,16 

protein-rich 222:8 

proteins 208:19 219:17 

219:21 220:20,20 

233:19 

protocol 191:12,15 

245:11 

protocols 251:22 

proud 16:16,21 28:5 

300:18 370:6 

proven 321:20 

proves 19:7 

provide 7:16 15:12 

27:14 94:22 97:19,21 

98:8,20 99:16,20 

101:16 105:14 115:9 

139:19 226:1 239:2 

244:1 251:6 252:13 

253:1 254:8 255:11 

262:7 263:12 280:15 

312:10 344:3 352:11 

353:2,14 374:4 388:5 

442:11 445:11 447:20 

provided 59:14 99:15 

100:22 101:5,20 

103:4 133:11 254:10 

358:11 

provides 151:20 172:15 

207:6 271:4 281:19 

395:15 446:20 

providing 18:22 22:18 

40:17 56:10 98:3 

219:19 223:4 233:20 

240:6 242:6 

provision 352:4 

provisions 46:3,6 76:7 

76:10,13 384:13 

proxies 239:12 

proximity 141:11 

prudent 287:16 

Pryor 349:6,16 353:11 

353:15 356:20 

psychology 203:6 

public 3:20 5:8 8:5,6 

10:10 11:1 12:7,16 

14:20 19:22 21:12 

22:5 25:6,22 29:16 

49:20 63:17 66:9 72:3 

85:7,22 86:6,10 87:10 

87:12,15 91:11 92:1 

92:22 160:7 188:20 

205:8 226:19 229:14 

237:18 238:7,16,17 

238:21 239:2 240:1,4 

241:20 242:6,8 

243:13 255:4 265:12 

267:4 280:9 293:3 

298:3,6 299:1,5 

322:17 326:17 330:17 

331:19 335:21 341:1 

345:17 346:5 358:11 

360:17 370:19 371:21 

388:10 389:3,5 392:3 

445:9,12 447:21 

448:22 

public's 330:18 

public-private 437:6 

publically 9:4 

publication 63:9 330:13 

332:7 369:3 

publications 198:18 

publicly 110:22 124:13 

352:9,9 397:22 

publish 39:21 40:6 

230:8 

published 39:4 71:20 

109:17 332:5 

publishing 210:13 

Puget 370:6 

pull 347:4 

pulled 121:17,18 

332:20 333:10 

pulling 217:20 284:3 

pullulan 430:16 431:7 

431:18 432:6 

pumps 83:8 

puppets 29:20 

purchase 96:8 268:17 

282:1 328:6 378:1 

pure 166:20 179:11,12 

purified 168:17 

purity 294:9 

purpose 151:10 220:17 

purposes 392:15 

pursue 47:12 81:2 

161:9 182:18 193:7 

push 137:2 194:13 

371:11 372:4 416:5 

pushing 27:12 372:6 

439:9 448:20 

put 18:18 22:1 24:21 

81:8 121:17 138:14 

147:4 149:1,13 

151:22 157:5 158:14 

175:4 194:18 200:22 

209:3 211:11 212:20 

213:2,11 214:18,22 

215:1,8 216:12,20 

239:5 246:11,11 

257:16 280:11 288:20 

295:9 297:3 301:2 

303:1,11 306:14 

314:5 329:3 339:7 

343:13 351:13 379:10 

393:3 397:16 399:11 

429:11 431:1 436:1 

438:12 440:5 441:9 

442:3 445:4 

puts 324:21 

putting 140:16 151:15 

182:8 233:17 271:13 

333:4 440:15,15 

puzzle 218:19,21 219:6 

219:7 221:4,5 

Q

Q&A 164:17 

QCS 369:22 374:1,1,6,9 

374:15 376:2 377:3 

377:10 

QCS-certified 374:14 

qualified 42:18 64:7 

qualifying 148:22 

quality 6:6 37:22 41:21 

42:1 45:3,5 61:1 

65:11 70:7,19 71:5,7 

71:14 73:11 74:3 97:8 

120:2 121:13 127:20 

157:20 169:11 281:2 

281:6,9 315:22 317:9 

373:22 376:1 

quantification 230:11 

quantities 431:20 

quantity 71:7 100:11 

quarter 181:5 

question 34:2 75:6,17 

79:6 82:12 110:22 

111:11 113:1 114:4 

124:2,11 125:11 

135:5,11 140:3 144:6 

152:16,18 155:3 

161:22 165:13,20 

166:1 168:18,21 

169:14 177:19 181:8 

182:13 185:20 188:12 

191:18 192:2 197:7 

197:19 198:15 201:9 

202:1 203:11,16 

223:19 226:18 229:17 

231:1 232:20 233:1 

234:16 241:22 242:1 

249:17 253:3 255:18 

257:13,14 258:1 

268:6 276:11 286:22 

287:1,7,19 288:13 

294:15 297:12 306:12 

310:8,8 311:14,16 

312:9,15 317:22 

320:20 321:7 332:18 

334:15 338:1,17 

351:6 360:1 366:1 

372:16 382:2 387:9 

392:10 393:20 398:6 

398:16 399:4 400:19 

407:3 413:21 423:17 

425:1,3,5,6 438:6 

440:17 445:19 

question-and-answer

174:20 

questionable 24:2 

questionnaire 99:19 

414:2 

quick 7:10 21:4 73:17 

73:18 152:17 188:19 

208:9,10,17 211:2 

233:4 266:20 290:15 

313:2 353:4 416:5 

441:22 

quickly 85:20 95:8 

210:14 220:5 233:7 

234:14 333:14 411:11 

412:5 438:4 

quiet 50:6 

quirk 17:10 

quite 42:2 85:2 123:16 

185:22 197:6 213:7 

222:16 229:10 289:13 

293:4 299:3 303:6 

407:6 424:11 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
489 

quiz 69:3 

quo 388:7 

quote 19:3 367:11 

368:11 415:11 452:17 

quote- 285:19 

R

Raging 386:19 387:14 

rails 83:16 

rain 285:15 449:22 

451:19,22 452:4 

rainfall 138:5,15 145:12 

145:16,18 

raise 81:3 360:5 424:12 

raised 34:5 75:22 79:7 

82:7 85:13 117:12 

434:6 

raises 317:9 

raising 416:1 

Ranchers 2:14 208:4 

ranches 301:14 

range 116:7 183:17 

189:2 224:9 258:16 

ranked 396:14 

rapidly 54:2 

rare 43:11 

rate 158:20 

rates 157:6 221:15 

233:6 419:1 

ratio 215:2,21 216:6 

221:3 225:7 

ration 209:21 419:3,4 

422:15,19 423:8 

425:10 

rations 236:13 425:19 

rattling 154:21 

raw 141:12 153:1 174:9 

187:18 

RD&A 118:17 

re-emphasize 94:1 

reach 35:21 241:10 

reaching 291:22 

react 167:18 

reacted 192:9 

reacting 167:5 

reaction 441:13 

read 19:3 63:15 175:5 

228:6 231:2 266:5 

293:3 316:17 328:1 

readily 221:16 

reading 19:3 62:20 

117:2 

ready 165:2 387:15 

441:16,18,18 

reaffirm 38:20 396:22 

436:19 

reaffirms 34:11 

real 44:20 54:13 112:14 

193:9 208:9 211:2 

244:21 438:17 

realities 400:4 

reality 70:15 76:3 

193:20,22 194:5 

228:14 

realization 195:3 

realize 292:20 

realized 149:2 171:19 

264:1 

realizing 154:22 

realm 445:7 

reason 140:15 181:15 

190:20 199:18 274:3 

312:1 372:2 385:16 

reasonable 322:3 

439:18 

reasons 80:18 84:16 

170:19 285:12 312:6 

322:16 415:21 

reassurance 332:22 

reassured 299:14 333:1 

reassuring 91:6 

receive 62:10 98:15 

125:22 187:15 188:4 

359:17 361:22 362:1 

received 32:10 40:15 

55:11 64:5 188:19 

268:6 270:13 271:1 

271:17 275:7 315:7 

377:3 

receives 273:2 

receiving 65:21 114:7 

128:1 

reception 21:1 

recess 205:6 

reclaim 19:10 

recognition 194:19 

383:1 442:16 

recognizable 180:6 

recognize 72:11 133:9 

157:14 178:19 180:8 

360:15 397:15 409:4 

416:7 442:17 

recognized 168:13 

411:1 

recognizes 377:10 

recommend 191:19 

292:1 309:1,16 

recommendation 7:8 

35:12,13 40:5 159:11 

226:3 256:7,11 257:7 

272:21 282:2 377:9 

397:14 409:22 410:13 

413:9 436:20 

recommendations

24:22 25:5 35:22 

39:10,13 40:3 124:19 

124:22 125:10 129:11 

158:10,11 244:4 

251:20 254:18 280:17 

282:12 309:9 360:9 

370:21 390:8 437:8 

446:11 453:1 

recommended 315:10 

407:17,22 

recommends 377:11 

431:7 

reconditioned 56:3,13 

reconditioning 56:11 

record 104:10 114:22 

205:11 349:10 453:22 

recorded 337:10 

records 50:16 

recruiting 7:2 42:21 

43:12,16 

recycle 174:2 

recycled 172:1 173:5 

173:12 

recycling 172:22 

201:14 

red 240:17 241:13 

redirecting 249:9 

reduce 143:22 176:21 

193:13 278:12 285:17 

reduced 145:13 219:2 

354:16 

reduces 150:7 277:19 

354:11 

reducing 193:5 263:13 

354:6 

reductase 147:19 

153:18,21 173:14 

200:18 

reduction 54:14 171:11 

175:15 180:1 

reemphasize 372:1 

reevaluate 336:6 

refer 184:15 

reference 7:6 102:13 

112:11 341:4 425:8 

referenced 366:2 

408:12 409:16 

references 13:16 

referencing 229:19 

409:18 410:4 

referred 440:5 

refinanced 331:1 

refinancing 428:16 

refined 179:9 

refining 309:22 

reflect 37:7 172:7 

reflects 73:10 

refrain 241:15 242:7,11 

reg 26:5,7 

regard 366:12 

regarded 365:2 

regarding 206:6 309:11 

350:1 365:14 367:8 

397:1 428:14,22 

433:4 

regardless 78:10 84:8 

123:13 125:2 161:10 

166:6 277:20 379:2 

regime 448:14 

region 50:18 51:10 53:2 

54:10,15 271:22 

316:9 376:5,16 380:9 

447:7 

regional 5:13 51:6 59:2 

59:6 157:11 269:20 

453:12 

regionally 22:15 

regions 88:21 121:11 

162:1 

register 39:21 48:8 

60:16 64:21 65:3 

66:20 67:14 99:13 

registered 66:2 266:8 

registration 67:10 

regretfully 266:15 

regs 23:15 84:16 85:18 

regular 71:9 209:15 

regularly 93:16 136:21 

regulate 74:19 259:6 

regulated 27:17 102:17 

189:19 366:9 

regulating 24:10 90:9 

regulation 76:18 

191:11 400:1 429:4 

regulations 16:19 

21:20 24:21 26:12 

27:18 34:14 35:2,7 

36:4 57:15 59:13,13 

59:18 60:21 61:8 

65:10,14 76:6,8 77:14 

79:1,3 84:11 89:19 

179:5 181:17 198:17 

199:1 203:18 287:13 

288:21 336:19 385:7 

386:8 399:18 402:4 

427:13 429:12 438:9 

450:17 

regulators 385:7 

regulatory 24:13 34:5 

38:10 46:9 255:7 

280:20 282:14 288:22 

330:8 351:15 367:19 

384:3 385:19 392:15 

437:12 443:14 

reinforced 433:21 

Reinforcement 46:8 

reinforces 165:17 

reinstatements 68:1 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
490 

reinstating 331:21 

reiterate 94:10 95:12 

313:22 345:11 356:12 

reiterating 346:18,20 

rejected 381:15 

relabeled 55:2 

relate 50:10 

related 46:4 47:22 50:8 

59:21 69:22 76:8,13 

116:5 138:5 177:16 

177:17 178:9 189:9 

305:15,16 306:3 

350:6 382:4 436:8 

relates 38:22 39:13 

162:16 167:4 437:15 

relationship 7:21 407:9 

437:21 448:7 

relationships 49:11 

51:16,21 

relatively 116:14 

relaxation 171:2 

relaxed 171:3 

relaxes 202:12 

release 100:14 202:15 

released 98:6 105:17 

relevant 86:12 189:6,7 

313:7 407:14 436:14 

reliable 98:4 104:16,19 

359:22 375:16 

reliably 248:12 

reliance 255:7 374:17 

reliant 339:11 

relied 272:8 

relies 354:20 444:4 

449:16 

relisting 381:9 382:3,6 

rely 103:20 328:21 

357:17 358:3 403:18 

relying 450:5 

remain 245:2 246:1 

346:18 

remaining 54:12 

remains 284:22 381:2 

remarkable 222:5 

444:14 

remarks 204:14 

remember 107:12 

108:12 234:1 241:1 

265:22 339:4 390:10 

404:9,22 438:13 

remind 20:22 251:18 

264:16 

reminded 348:14 

reminder 21:5,6 164:16 

remiss 444:17 

remote 43:6 

removal 191:19 

removals 40:2 

remove 56:13 188:14 

191:19 

removed 56:5 180:15 

195:19 277:15 355:1 

355:12 

removing 56:5 187:11 

195:17 354:6 355:6 

356:2 403:21 

Renaissance 1:12 

renewal 39:20 

renewing 352:15 

repeat 92:10 

repeated 332:9 

repeatedly 333:13 

437:3 

replace 118:21 225:19 

226:15 

replaced 56:7 176:14 

180:15 329:10 387:11 

replacements 218:10 

replications 127:15 

reply 343:12 

report 3:3,6 13:5,18 

21:11 55:11 56:21 

74:18 84:5 92:22 

101:14,19 170:3 

256:9 274:7 298:6 

337:19 352:17 446:7 

reported 51:5 102:11 

103:15,21,21 105:6 

155:18 161:1 169:6 

reporting 51:8 68:21 

71:21 72:1 92:18 

101:8,21 102:3,17 

104:3 105:2 109:5 

245:11 337:6 438:7 

445:8 448:22 

reports 40:18 51:3 

55:20 69:8 101:20 

437:17 

represent 21:16 102:8 

102:11 155:14 160:15 

209:4,8 282:18 315:2 

417:15 

representative 72:12 

430:13 

representatives 65:12 

represented 54:16,18 

350:17 368:22 392:4 

representing 88:10 

92:13 119:13 270:7 

331:14 340:6 

represents 22:14 28:5 

245:16 349:19 355:11 

request 148:16 245:6 

319:20 332:10 422:14 

requested 384:2 

requesting 122:10 

270:9,15 

requests 14:15 66:10 

282:6 368:19 422:17 

require 245:4 252:5,11 

253:11 261:10 282:15 

288:19,20,22 294:16 

295:2 367:12 368:15 

368:18 390:13 394:1 

394:6,11,19 443:13 

446:7 

required 48:2 72:1 82:1 

124:5 144:3 148:7 

247:18 288:18 295:12 

297:16,18 309:18 

311:9 355:20 364:18 

365:2 381:19 

requirement 61:14 

189:9 190:15 253:2 

280:20 294:6 352:20 

421:14,22 422:1,11 

423:14 

requirements 69:21 

79:3 140:6 143:6 

155:9 189:5 212:21 

213:5 221:13 275:8 

350:7 422:6 

requires 47:13 70:11 

104:7 235:11 244:8 

375:14 379:14 399:4 

421:18 447:12 

requiring 34:17 295:8 

308:8,16 392:16 

437:22 438:3,21 

rereduction 167:8 

research 8:15 10:22 

51:15,19 77:22 

100:22 109:17 112:1 

117:22 119:4,8,11,22 

120:10,17 122:10,11 

122:13 123:2,3,14 

125:18 141:5 142:14 

146:7,21 147:18 

160:7 164:13,15 

169:21 182:21 193:3 

193:15,16 199:11 

201:11 206:20 218:7 

225:21 230:20 251:5 

255:20 256:3 262:5 

271:3 280:3 316:22 

353:6 358:19 361:17 

361:20 371:15 

researched 209:14 

researching 164:8 

reservations 332:19 

resides 14:8 

residual 172:18 176:8 

residue 54:8 302:4 

residues 355:1 

resistance 347:10 

resolution 290:18 

396:22 

resolutions 379:11 

resolve 82:2 267:2 

332:15 421:21 

resolved 26:18 439:4 

resolving 191:22 

resonates 18:11 19:17 

resource 48:11 59:20 

416:9 

resources 34:19 76:15 

101:2 103:8,19 

352:10 435:4 

respect 89:12,19 168:6 

respectfully 256:6 

respiratory 214:11 

respond 54:2 165:11 

249:18 314:4 400:8 

400:10 411:6 

respondents 374:18 

responder 165:13 

responding 422:13,17 

440:20 

response 5:22 13:11 

14:17 171:17 192:4 

238:12 255:18 411:7 

440:18 

responses 104:5 

responsibility 27:9 

28:11 248:17 383:18 

responsible 34:20 

45:11 65:13 66:1 

132:5 360:17 

responsive 47:1 279:5 

rest 8:4 96:13 97:11 

286:9 326:5 384:15 

445:1,15 448:1 

restate 417:2 

restaurant 236:19 

386:22 

restaurants 387:6 

restrict 265:19 296:8 

restricted 422:9 

restricting 338:19 

restriction 422:7,8,10 

result 40:14 54:7 183:2 

resulting 281:18 

results 64:4 100:14 

105:17 131:18 151:19 

440:3 447:3 

resumed 114:22 205:11 

349:10 

retail 48:16 114:5 285:4 

retailer 289:20 357:19 

360:16 

retailer's 12:9 

retailers 336:17,22 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
491 

357:9,12 359:7 

retired 120:5 

return 18:15 397:11 

returns 18:22 

reveal 51:17 

revenue 17:17 155:15 

156:1 

review 25:13 37:13 40:3 

46:5 50:16 59:9 63:13 

68:17 97:17 103:15 

103:20 115:16,17 

116:11,15 205:2 

210:15 220:12 259:14 

259:21 270:2 274:5 

275:6 308:14 321:12 

322:6 336:11 369:13 

373:22 379:20 380:2 

390:7 430:21 437:18 

439:11 

reviewed 256:9 320:2 

369:12 381:15 

reviewers 65:6 70:1 

reviewing 82:6 369:14 

reviews 123:7 190:13 

194:18 218:8 227:13 

revise 316:17 

revised 280:8 315:6 

316:11,18 

revision 351:4 368:19 

revocation 447:6 

revocations 93:8 

rewards 386:4 

reworked 293:15 

rice 1:20 3:4 11:3,3 

13:6,12 14:1 15:15 

20:17,21 84:4,17 

203:19 205:20,22 

226:7 229:15 230:22 

232:18 234:13 237:9 

302:20,21,21 411:6 

436:7 440:18 441:11 

rich 15:18 

richer 232:14 

Rick 1:18 12:13 111:10 

152:15 

rid 214:6 

rigorous 389:11 

ripple 114:1 

rising 337:9 

risk 89:14,18 90:15 

99:3 144:1 150:7 

158:2,5,16,19 159:2,4 

159:4 160:3,18 162:9 

190:13,22 191:8 

195:21 196:4,6,19 

224:5 267:20 271:11 

271:14 279:6 309:4 

336:17 346:2 385:16 

386:5 424:17 

risk-based 37:16 49:4 

89:11 397:4 446:20 

447:1 

risk-benefit 264:18 

risks 53:21 169:16 

274:19 

risky 33:6 80:20 

RMA 99:3 

road 301:19 302:5 

roads 18:19 301:17 

robust 36:21 91:17 

139:22 150:6 354:21 

411:14 437:1 

Roland 253:22 269:7,11 

269:15 273:4 278:15 

279:15 

role 7:1 10:17 16:17 

50:13 281:16 385:1 

396:1,2 

roll 72:7 387:15 

ROMERO-BRIONES

1:20 12:1 

roof 79:15,16 

room 5:2 21:3,6,7 65:16 

72:11 154:10 239:15 

324:18 342:15 345:7 

384:12 

root 442:4 

roots 15:19 122:6 

355:22 356:16 

Ross 378:15 383:10,11 

383:12 386:14 

rotate 231:3 408:17 

rotated 229:22 230:13 

258:10,11 

rotation 127:2,7 223:15 

271:21 276:16 279:10 

279:12 316:5 409:3,9 

rotational 236:1 

rotations 59:20 271:13 

403:4 

roughly 13:15 173:15 

round 8:20 31:16 71:13 

87:12 96:14 183:22 

378:11 442:21 

route 56:12 

row 17:1 74:2 107:19 

271:11 302:8 

RPMs 429:15 

ruin 196:22 

rule 35:14 37:19 38:7,9 

38:12,14,14,21 39:4,8 

39:10 40:2,4,6 46:8 

46:11,13 58:19,19 

62:18 63:8,11,15 

69:21 71:19 72:2 

84:22 85:3,6,16,19 

86:1 87:1,5,9,20 91:9 

102:2 302:10 306:12 

326:7 328:6,8 329:7 

330:9,11,12,13,16,18 

334:2 341:6,17 342:1 

342:11 343:2,21,21 

344:6,13,15,15,19 

345:18 346:1,1,2,3,12 

346:18,20 347:2,8,13 

348:8 358:9,14 

368:10,18 384:14 

396:19 397:2,7 398:4 

402:11,13,17 403:6 

405:17 407:19 408:13 

410:10 413:9 449:15 

rulemaking 23:20 35:16 

38:5 46:8 62:22 

341:22 358:13 443:16 

rules 19:15 29:3 33:21 

34:22 36:17 39:2,14 

39:15 48:4 75:4,4,10 

75:13 76:21 77:1 

94:14 95:16 208:20 

347:12,13 390:1 

400:6 408:18 410:12 

427:22 428:4 434:19 

435:8 

ruminant 231:4 

ruminants 23:22 

223:10 

rumors 61:15 

run 12:4 50:11 152:11 

239:19,21 323:15 

421:5 

runs 212:11 217:3 

449:22 

rural 5:13 335:13 

375:19 

Russian 428:10 

Ryan 323:9 327:16 

335:14 

S

sacrificing 146:12 

safe 143:1 148:8 191:16 

201:7 365:3 

safer 274:16 

safety 14:5,9,11 120:4 

140:6 152:2 155:9 

166:13 168:14 170:12 

189:8 274:20 318:13 

365:4 

safir 130:1 

Saint 13:8 

salads 187:13 

sale 23:13 384:18,19 

385:2 

sales 105:21 106:1 

107:10,21 113:7 

155:19 156:1,3 

328:11 

saliva 172:2,21 173:5,8 

173:17 

salivary 173:8 174:22 

salt 178:13,13 199:9 

salted 178:15 

salting 178:11 

saltpeter 178:14 

Sam 73:7 

sample 134:16 

sampled 223:22 

samples 127:21 128:1 

128:1,7,20 133:11 

145:3 146:20 148:16 

sampling 68:19 133:8 

359:16 

San 12:17 

sanitizer 257:14 266:11 

267:18 

sanitizers 255:1 257:21 

258:5,9,19 259:2,3,7 

259:15 266:16 367:6 

369:8 390:17 

satisfied 274:10 

satisfy 81:13 431:14 

sausage 156:4 178:9 

save 117:12 440:10 

saw 59:1 73:6 132:18 

133:1 157:12 227:14 

236:16 296:13 300:22 

338:17 344:21 408:14 

412:5 426:11 

saying 87:11 94:8 

188:14 250:4 262:1 

264:3,3 275:22 276:6 

276:9 278:20 296:18 

300:22 306:12 307:6 

319:12 327:17 331:19 

416:10 

says 201:21 284:20 

306:13 350:11,20 

364:19 366:4 

SBIR 183:8,18 193:18 

scale 162:16 175:5 

209:10 224:16 231:3 

231:10 234:17 

scales 290:6 

scarce 178:22 

scenario 32:22 33:2 

401:7 449:5 

scenarios 390:3 450:13 

450:19,19 

schedule 197:1 239:17 

239:21 

scheduled 114:17 

301:7 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
492 

scheme 26:4 

Schilter 314:19 323:9 

323:11,20 325:12 

327:2,11,13,15 

school 11:1 12:15 

170:22 285:16 

schools 18:20 

Schwartz 6:22 

science 5:16 118:15 

119:15 120:8 124:15 

179:1 244:6 313:15 

362:7,18 389:17 

scientific 166:10 202:2 

206:22 246:10 

scientist 10:20 

scientists 131:5 

scope 79:2 183:21 

259:4 

Scott 1:20 3:4 11:3 13:4 

15:14 84:3 205:20 

411:4 436:6,13 438:2 

440:11 

Scott's 15:16 

scraped 449:7 

scratch 197:12 297:5 

screen 289:20 

scrutiny 54:12 95:18 

446:21 

SDC 265:7 266:10,17 

se 366:13 

sea 50:18 53:2 54:10,15 

414:1,14,16 444:19 

seal 96:11 286:5,7 

289:19 290:9 427:16 

search 48:21 350:6 

searches 281:9 

season 59:2,7,10,11 

61:2,3,4,13,19 194:3 

252:8 321:7 339:18 

342:21 377:19 378:2 

420:8 

seasonal 157:13 

158:13 237:2 

seasons 59:5 

seat 9:16,20 10:4 11:4 

11:12,17,21 12:7,9,14 

12:20 15:15 29:11 

65:1 334:21 361:5 

396:7 

seat-belted 429:15 

seats 64:22 205:14 

349:13 

Seattle 1:12,12 4:14 9:8 

31:12 386:19 

second 36:18 38:8,13 

38:22 51:14 55:10 

86:1,22 87:5 133:15 

176:17 182:13 191:17 

197:7,20 226:18 

227:9 237:1 265:18 

330:16 341:5 343:21 

346:1 358:16 369:7 

385:6 386:22 

secondary 65:17,20 

67:9 

secondly 244:13 258:7 

seconds 286:10 

secretary 1:20 11:8 

44:13 87:20 289:17 

391:3,5 

secretary's 3:3 13:5 

secreted 173:7,16 

secrets 285:3 

section 31:9 78:12 

88:20 89:4 96:18 

99:21 110:4 314:7 

367:10 402:17 

sector 15:19 27:17 

108:19 119:6 254:15 

415:5 443:2 

sectors 27:6 

Securing 122:18 

seed 54:14 128:13 

158:22 162:22 225:5 

243:16,19 244:12,16 

244:18,22 245:7,19 

246:6,16,17,18,20 

247:10 248:4,11,13 

249:3,4,8,9,9,11,18 

250:12,17 251:13,18 

252:12,13,22 253:19 

280:1,4,7,18,22 281:1 

281:9,10,12 282:4,14 

282:16,19 283:1 

291:17,18,19 293:11 

293:20,22 294:9,16 

294:17,21 295:1,4,14 

295:20 297:17,17,19 

299:9,13 350:2,6 

367:5,8 369:4 380:20 

seeding 131:16,17 

seedlings 144:19 

seeds 281:6 350:21 

367:18 

seeing 54:20 91:8 

107:18 131:4 134:2 

135:3 238:13 258:14 

334:13 348:16 437:3 

447:2,3 

seen 46:2 63:7 71:12 

147:5 149:14 153:10 

158:22 163:1 228:3 

328:9 361:11 389:13 

451:20 452:1 

sees 325:7 

segment 288:17 418:1 

segments 7:20 

Seitz 1:21 10:9,10 

74:17 177:20 179:10 

231:1,20 286:21 

287:5 288:8,12,15 

327:5,12 361:5 

393:16 394:21 414:18 

select 36:12 88:16 

222:9 402:21 

selected 57:16 

selection 89:6 99:5 

118:3 126:13 

self- 60:6 64:20 102:10 

self-guided 60:13 

sell 17:21 249:5 283:15 

324:11 326:4 368:2 

368:16 376:20 418:14 

424:20 

selling 228:1 

sells 289:21 326:2 

send 7:7 66:6 103:13 

339:11 347:3 

sending 47:5 88:3 

344:2 

sense 18:1 149:6 297:9 

312:4,7 331:4 343:1 

415:7 

sensible 67:20 

sensitive 176:16 177:1 

202:21 251:12 253:13 

sensory 120:1 157:14 

sent 128:2 134:17 

433:2,6 

sentence 241:15 

sentiments 335:2 

separate 13:15 76:18 

305:20 355:16 

separately 196:11 

separating 185:12 

305:16 

September 127:18 

septic 267:7 

sequencing 200:16 

sequester 355:18 

sequestering 355:6 

sequestration 355:15 

series 117:5 

serious 334:20 379:22 

388:4 400:17 

seriously 101:9 346:11 

346:12 

seriousness 286:3 

288:22 

serve 4:11 11:7,12 12:5 

60:7 282:6,8 

served 14:13 206:16 

387:5 

serves 118:11 119:10 

119:16 208:3 

service 2:10 4:10 6:3 

46:20 65:2 96:20 

100:22 109:17 283:3 

369:15 383:15 386:10 

391:7 411:2 447:20 

services 14:5,10 57:19 

374:1 401:21 433:4 

442:20 

serving 10:8 418:6 

sesame 364:14,16,20 

session 115:8 164:17 

175:22 205:16 230:9 

sessions 238:22 

set 109:4,6 114:11 

134:14 309:11 453:5 

setback 148:3 

sets 248:15 

setting 310:13 396:7 

settings 257:2 

settlement 93:9 

seven 211:1 221:11 

250:14 254:4 319:15 

325:19 326:1 329:4 

severely 380:9 

shade 59:22 

shape 322:13 347:7 

shapes 16:18 

share 15:17 45:1 52:3 

89:10 91:22 92:1 

139:2,12 161:4 

242:16 244:19 340:20 

435:17 436:11 443:8 

443:18 448:8 

shared 45:9,14 56:11 

146:17,20 306:4 

sharing 33:7 56:18 91:5 

91:20 93:1 

sharp 447:9 

shelf 120:2 141:13,14 

141:21 325:8 

shelves 357:21 

ship 52:19 268:9 

418:10,13 

ship-specific 52:8,9 

shipment 55:7,8 56:12 

shipments 55:1 

shipped 269:1 

shipping 324:1 

shocked 301:4 

shoot 197:2 

shoots 368:17 

short 37:9 42:1 43:17 

105:13 141:12,14 

151:5 197:4 268:5 

325:15 379:4 420:6,8 

shorten 196:22 

shortened 332:6 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
493 

shorter 39:15 

shoulders 248:19 

show 70:21 101:22 

108:1 201:12 212:12 

217:4 254:13 410:9 

438:15 

showed 228:13 235:20 

showing 130:10 147:1 

358:20 

shown 212:22 

shrinking 375:18 

shutdown 60:4 

shutting 87:3,4 444:18 

shy 192:12 

sickness 275:2 

side 11:10 67:18 146:18 

146:19 186:21 197:9 

197:13,17 202:17 

267:21 302:16 370:22 

371:21 

side-dressed 132:22 

sidebar 90:11 

sides 219:13 389:17 

sight 247:4 340:13 

sign 66:3,13 67:5 239:2 

sign-up 158:9 

signal 52:16 66:19 

signature 386:21 

signed 239:21 270:7 

signers 433:13 453:9 

significant 17:15 48:17 

57:1 62:15 63:11 

145:7,12,16,20 

147:15 148:2 222:19 

223:4 282:20 372:3 

375:14 

significantly 71:15 

133:2,6 163:17 

silence 240:4 

silk 215:18 

silkworms 210:2 

silt 127:9 

Silva 2:13 3:12 117:19 

118:11 120:13,14 

137:10,12,19 138:6 

157:8 161:1 163:11 

193:15 199:15 

Silva's 117:21 

similar 56:12 98:13 

99:7 183:12,12 230:4 

231:1 297:16 

simple 99:21 

simply 105:9 179:22 

321:13 363:22 364:22 

365:8 369:9 388:6 

434:17 

Simpson 353:12 357:3 

357:5,6 361:19 363:4 

Simultaneous 372:22 

Sindelar 124:14 136:13 

sing 386:20 

Singing 387:2,7 

single 56:6,6 58:3 

102:21 108:5 210:3 

225:17 226:15 230:19 

259:5 261:13,14 

sir 75:19 

sit 9:19 10:4 11:3,12,17 

11:21 12:8,14,20 

29:10 242:14 262:8 

331:7 334:18 352:2 

site 394:9 

site-specific 34:22 

sites 195:6 394:7 

sits 334:21 

sitting 300:7 

situation 24:19 80:5,8 

81:9,14 310:16 311:3 

312:1 313:17 325:20 

379:17 415:16 448:2 

situations 34:22 219:14 

258:12,18 415:17 

six 50:7,11 54:3 69:1 

171:11 177:4 179:20 

250:14 

sixth 53:15 98:11 

size 78:11 108:2,9 

109:7,9,18,20 146:11 

218:19 219:6 220:17 

231:17 379:2 

sized 348:4,11 

sizes 16:18 88:21 

skew 108:4 

skid 192:10 

skip 211:3 

skirt 95:16 

SKUs 357:21 

slew 224:8 

slide 52:5 63:2 98:22 

150:18 185:10 195:13 

236:16 

slides 165:2 

Sligh 19:4 20:18 

slight 133:2 

slightly 220:21 230:6 

233:15 

slippery 383:3 

slope 383:4 

slots 239:3 

slow 85:5 118:5 375:2 

376:4 420:11 

slow-growing 233:6 

slower-growing 221:8 

slowing 354:15 

sludge 267:7,11 

small 9:22 16:16,22 

35:5 89:2,16 144:13 

159:10,17 172:13 

182:21 209:9 210:9 

231:3 232:5 235:18 

237:6 245:17 285:18 

292:15 348:4 391:4 

409:4 415:13 

small-scale 420:17 

smaller 107:16 156:7 

183:2 348:10 415:4 

418:15 420:4 

Smith 363:6 366:19,20 

366:21 369:19 

smoke 429:13 

smooth 171:4 

smoothly 22:2 

snapshot 62:20 

snow 237:4 285:16 

so-called 363:12 

societies 178:21 

sociological 202:1 

203:7 

sodium 179:21 180:9 

180:11 190:1,17,17 

190:18,20 197:5 

198:5,12 199:9 202:7 

203:12,20 390:10 

soil 76:8,9,11,13 82:15 

127:8,9 134:6 138:10 

138:10 144:20 224:6 

256:16,16 271:12 

284:1,15,21 285:15 

285:20,21 354:21 

355:7,15,17,19,20,22 

356:16 358:17 362:3 

371:6 401:2 402:19 

403:2,3,8,22 404:13 

449:11,22 451:20 

452:1,5 

soil-based 24:4 33:19 

35:5,6 36:6 76:5,9,14 

285:18 288:5 388:20 

451:20 

soil-building 271:13 

soils 355:8,10 356:4,9 

372:11 

sold 18:16 55:2 350:16 

367:15 368:22 

soldier 210:10,20 

215:18 225:8 

sole 165:13 

solicit 254:11 

solid 184:5 185:12 

312:3 450:6 

solids 152:12 

solution 122:2 150:16 

195:5 446:16 

solutions 28:22 118:21 

351:15 362:10 390:19 

solve 245:15 263:2 

427:20 451:3 

solving 26:20 

somebody 43:4 59:7 

288:3,19 302:6 

324:11,12 346:4 

399:17 429:1 

somebody's 89:22 

someday 387:14 

something's 226:13 

somewhat 113:18 

161:7 197:3,4,10 

296:14 449:19 

song 386:21 

songs 386:21 

Sonnabend 283:10 

290:12 291:11,13,14 

295:3,6 297:2,7,15 

298:17 299:8,11,13 

299:17,20 300:2,5 

Sonny 289:17 

sons 427:11 

soon 26:6 43:21 81:22 

208:10 303:5 330:12 

356:9 357:16 

sooner 26:13 

soonest 138:1 

sophisticated 104:12 

sorely 23:20 

sorry 30:21 78:16,19 

80:17 81:7 93:21 

111:9 153:15 164:4 

289:8 290:17 301:10 

302:2 304:20 314:6 

348:20 378:7 392:8,9 

392:10 394:13 407:17 

412:8 417:1 

sort 60:20 66:3 76:5 

79:6,7 80:4 113:19 

183:1,2 192:10 

193:12 221:19 260:6 

264:10 309:2 345:5 

346:17 373:4 405:3 

411:8 436:18 438:1 

439:9 443:5 446:18 

447:8 450:9 

sorts 109:10 

sought 402:13 

soul 19:6,8 

sound 67:20 127:1 

133:13 

sounded 319:12 

Sounds 21:9 366:16 

soups 130:5 

source 124:5 126:18 

129:20 130:14 135:2 

136:4 161:9 166:7,17 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
494 

166:19 168:17 170:6 

170:8 172:20,21 

193:19 210:1,2 223:4 

227:20 228:5 350:15 

366:11 

sourced 116:1 255:8 

364:9 

sources 59:22 98:1 

102:6 116:9 148:15 

169:5,19 172:1 173:6 

185:11 223:3 224:18 

364:8 

sourcing 10:3 196:14 

245:7 280:18,21 

282:16 

south 269:20 323:13,14 

Southern 418:4,5 

soy 213:2 214:19 

soybean 212:18 213:7 

213:10,19,20 216:16 

228:13,22 425:13 

space 91:7 357:9,12 

390:13 

span 341:19 

spatial 441:8 

speak 7:16 8:14 97:12 

106:13 116:22 120:16 

218:2 239:9,17 269:2 

269:14,22 277:10 

291:16 307:3 330:6 

361:16 370:2 395:10 

404:3 427:14 437:19 

speaker 13:22 240:10 

240:12 241:22 242:5 

242:10,13 426:6 

430:9 432:17,22 

speaker's 242:2 

speakers 240:6,8 

241:17 371:4,13 

speaking 117:17 239:3 

248:22 310:7 326:17 

326:22 370:5 372:22 

speaks 306:3 

spec 158:21 162:11 

422:18,19 

special 7:13 8:19 26:10 

98:16,19 99:2,8 

190:11 

specialist 2:2,5 4:22 

6:13 373:22 

specialists 42:11,19 

57:7 

specialized 57:12 

specializing 207:17 

specialty 207:4 

species 201:18 222:20 

309:4,5 

specific 33:2,3,4,22 

34:5 35:22 50:7,17,17 

51:16 55:3 58:22 

59:14 63:10 76:5 

80:22 84:12 88:16 

117:11,11 124:18 

133:4 152:22 153:2 

186:7 191:13 200:17 

224:13 252:20 256:15 

258:3 309:5 343:15 

351:19 390:2 392:14 

394:19 395:1 399:9 

399:13,17 400:3 

401:8 441:1 

specifically 81:1 

124:21 195:15 255:15 

317:1 322:20 367:9 

367:20 380:14 437:15 

specification 158:15 

specifics 125:9 

speculating 306:8 

speculative 161:5 

163:22 

speech 242:9 

speechless 285:22 

speed 437:11 

spend 50:1 125:12 

134:5 165:14 169:15 

446:17 

spent 22:4 90:9 112:16 

164:7 207:3 

sphere 49:20 

spices 190:4 

spirit 327:8 

split 127:15 132:8 

133:5 305:18 

spoiling 178:16 

spoke 181:8 239:8 

247:20 303:21 

spoken 278:17 

sponsoring 116:20 

spontaneously 405:5 

spores 168:10 

spot 81:21 107:2 

146:11 343:14 424:1 

441:10 

spray 80:13 277:15 

301:17 399:1 401:3 

sprayers 318:10 

spraying 440:14,21 

441:13 

spread 43:21 255:12 

spreadsheet 66:6 

103:13 238:1 

spring 1:7 4:5 39:13 

239:1 314:6,6 

Springs 11:16 

spur 194:15 

squeeze 17:5 

stab 427:10 

stability 187:17 

stable 164:1 168:6 

Stacy 101:9 

staff 2:1 26:20 41:9 

66:2,2,9 107:4 443:22 

staffing 41:8 

stage 352:18 

stains 153:19 

stake 19:6 377:13 

stakeholder 38:5 

333:17,18 334:4 

405:3 

stakeholders 100:7,8 

101:11 248:5 308:6 

332:18 380:17 392:4 

392:5 

stakes 155:10 

stance 379:10 

stand 4:20 31:16 72:10 

72:13 73:1 445:22 

standard 16:6 24:4,17 

128:14 129:10 152:18 

340:18 351:6 367:19 

409:3,14,18 410:16 

410:18,20 411:1 

412:22 413:18 433:16 

437:10 439:13,17 

440:4 450:11 452:10 

452:22 

standardized 53:19 

140:5 142:19,20 

147:13 168:19 

standards 1:5 2:3 4:6 

4:17 6:18 9:4 13:3 

19:5 21:13 25:10,15 

27:13 36:8 37:3 57:12 

78:8 237:20 255:11 

290:21 302:10 303:11 

308:17 358:2 359:6 

359:10 360:12,18,22 

365:14 379:12 383:3 

389:9,13 395:9 396:2 

396:20,21 397:20 

402:13 404:17 405:15 

405:20 408:6,8,22 

409:17,20 412:4,10 

412:12 413:4,14 

415:8 417:5 434:4,10 

435:19 436:16 437:1 

440:6 451:9,12,17 

452:11 453:14 

standing 52:16 72:16 

73:2 

standpoint 155:11 

215:15 287:16 

stands 154:22 156:13 

388:14 

staphylococcus 154:4 

star 339:6 

starches 209:18 

Stark 268:7 269:2 

start 4:15 32:16 38:2 

47:19 68:3 71:7 98:5 

98:9 102:9 121:15 

139:12 141:16 142:3 

147:14 157:16 182:10 

189:18 205:18 217:19 

241:18 325:22 331:19 

348:20 384:16 421:10 

423:13 

started 4:4 5:3 31:4 

40:10 44:10 51:15 

58:8 64:3 68:22 

157:14 180:7 326:3 

421:12 

starter 151:16 201:2 

starting 9:17 117:15 

197:12 205:15 258:21 

283:14 291:19 294:4 

341:15 401:2 420:10 

421:2,18 422:3,6 

439:14 

starts 41:12 241:11,14 

402:18 

state 2:10 7:14 9:15 

11:6,11 14:21 15:8 

16:1,4,5,20 17:6 

31:13,15 94:14 113:1 

119:7 122:9 126:6 

167:9,22 206:15,18 

207:16 230:6 243:11 

268:18 271:2 273:20 

283:9 293:16 307:17 

316:21 365:9 399:7 

406:17 426:19,21 

428:10,13 

state's 14:12 

stated 25:22 289:13,18 

293:13 339:14 342:2 

385:13 

statement 33:18 56:16 

80:18 233:14 256:22 

304:18 311:8 333:21 

387:10 

statements 288:7 

states 1:1 32:6 119:14 

209:6 221:17 254:6 

270:6 274:18 279:14 

283:13 364:17 395:21 

438:15 444:22 

stating 256:18 

station 126:21 134:3 

146:22 

statistically 132:17 

statistician 97:4 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
495 

statistics 2:10 6:2 51:7 

96:20 113:21 119:4 

328:2 

stats 101:22 328:20 

status 372:17 373:3 

388:7 

statutory 385:5 391:2 

stave 211:21,22 212:3,8 

staves 389:1 

stay 72:16 73:2 239:20 

240:10 272:18 

stayed 232:11 325:4 

staying 349:14 

steep 244:8 390:10 

steer 192:10 429:1,2 

stem 359:1 

step 139:7 142:11,18 

193:13 196:17 263:8 

282:20 380:11 383:5 

396:5 437:2 450:9 

steps 18:8 53:9 67:17 

84:1 104:22 105:12 

139:14,18 195:19 

197:18 262:6,14 

384:18 

stereoisomer 190:20 

sterile 176:19 

sterilize 153:1 

Steve 1:18 2:10 3:5 

7:13 11:9 14:4,9,17 

14:19,22 20:16,17,21 

78:4 88:13 107:8 

162:5 184:4 196:20 

200:2 275:10 276:17 

345:10 377:15 436:6 

440:9 

Stewardship 269:17 

sticker 56:6,8 

stickers 56:7 

stipulated 253:2 

stock 152:19 255:8,10 

255:13,22 256:2,4 

261:7,11 262:8,15 

263:4,7 292:5,6 

350:11,14,16,17,22 

367:13,19,22 368:2,3 

368:4,8,13,16 

stocks 282:17 

stoichiometric 189:13 

stole 41:13 

stomach 173:20 223:12 

stood 383:22 

stop 68:6 174:19 247:9 

247:16 294:2 326:16 

384:18,19,22 385:2 

stopped 343:5 

store 96:5 180:10 188:6 

202:18 284:20 361:10 

366:17 

stored 188:2,9 

stores 113:8 283:13 

357:15 418:12,13 

stories 91:15 334:17 

story 44:18 52:4 323:20 

325:15 330:5 

straight 87:20 228:22 

411:10 

strain 142:15 147:7 

153:2 

strains 153:7,11,17 

200:16,21 221:8 

strategies 126:14 132:7 

132:12 134:11 140:4 

168:18 218:9 220:7 

221:22 

strategy 132:22 140:8 

146:9 225:18 391:19 

Straus 331:12 335:5,7,8 

335:8 338:7,14,21 

339:3,13 340:4 

strawberries 302:9 

stream 384:21 

street 1:12 42:6 

strengthen 247:3 280:6 

336:15 

strengthening 37:18 

46:7 62:17 244:5 

350:2 367:4 

strengthens 389:20 

strengths 70:21 

stress 391:18 

strict 27:19 

strictly 108:17 

strikes 95:1 

strip 236:19 

strips 175:2,4 

strive 415:15 

strong 5:12,12 6:5 

36:15 63:16 64:8,10 

75:3 136:11,20 149:3 

150:13 228:4 326:18 

343:20,20 356:1 

388:12 395:15 

stronger 282:22 

strongest 360:22 

strongly 176:11 374:6 

386:6 

structure 101:15 

289:22 348:3 

structured 58:15 

struggle 345:14 

struggled 362:11 

struggles 384:9 

struggling 113:4 

student 230:5 

students 174:13 

studied 221:9 

studies 53:18 60:20 

99:2,8 137:17 174:5 

202:4 224:11 228:6 

229:19 

study 33:14 98:16,19 

144:14 197:21 207:18 

209:18 210:8,11,15 

210:17 222:7 230:3,4 

230:7,13,20 

stuff 216:12 257:16 

427:2 447:17 448:12 

stymied 262:22 

subcommittee 11:14 

21:22 115:6 205:19 

238:15 250:14 280:6 

280:11,16 281:8 

316:12 331:21 350:1 

351:10,13 372:20 

393:1 431:3,6 432:11 

subcommittee's 244:1 

244:7,14,20 256:7,10 

257:7 280:7 308:1 

367:4,6 

subcommittees 8:8 

254:16 332:9 

subdivisions 155:20 

subject 8:14 256:2 

257:4 261:9 274:22 

350:12 

submission 21:20 

137:22 

submittals 71:3 

submitted 123:5 315:5 

366:1 431:1 

submitting 123:10 

136:7 

subscription 65:1 

subsequent 23:12 

197:8 

subsequently 201:7 

316:12 320:6 

subset 391:5 

subsidiary 154:20 

subsist 420:7 

substance 80:14 

256:21 398:3,14 

399:1 400:14,20 

401:4 449:10 

substances 34:16 

78:14 308:12,14 

374:6,13 403:11 

substantiated 345:19 

substantive 292:7 

substitute 263:10 

substitution 407:1 

substrate 184:22 

subtract 190:2 

suburb 12:11 

succeed 98:3 

success 52:4 143:9 

204:21 252:17 281:5 

374:19 

successes 41:1 54:7 

successful 58:7 194:10 

successfully 147:6 

sucker 270:3,21 271:5 

272:7,22 278:1,5 

315:20 374:15 375:22 

suckering 271:7 278:3 

318:4 375:3,13 

suckers 277:14 278:6 

375:2 

sucking 277:12 

sudden 448:14 

Sue 1:15 10:5 250:2 

252:2 294:13 298:8 

suffice 431:20 

sufficiency 292:14 

sufficient 265:16 431:3 

sufficiently 375:21 

sugar 190:4 

suggest 174:22 188:21 

suggested 352:10 

suggesting 392:13 

suggestion 183:21 

193:18 450:9 452:17 

suggestions 238:20 

252:21 280:15 297:14 

343:5 

suit 326:18 

suitable 135:21 136:2 

143:14,15 

suite 82:17 83:15 

sulfur 149:7 

sulphidal 167:19 

summary 13:7 109:2 

172:6 

summation 292:1 

summer 39:22 60:15 

137:17,21 229:8 

230:16 274:22 375:18 

sun 274:22 285:15 

sunflower 215:11 225:5 

228:14 

sunlight 138:10 

sunset 39:20 40:1 

115:16,17 116:11,14 

177:17 203:20 205:2 

254:11 264:4 308:14 

sunshine 23:11 

super 70:2 95:18 

superior 17:12 

supervisor 16:10 

supplement 174:6 

287:8 418:19 420:15 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
496 

supplementing 231:14 

supplements 235:2 

236:4 

supplier 252:12 

suppliers 142:12 144:8 

148:14 185:12 251:13 

281:22 282:4,7 

342:10 

supplies 377:6 

supply 14:12 36:20 

50:20,20 51:14,16 

52:13 55:13 136:19 

139:15 150:6 188:10 

195:12 244:16 254:9 

271:18,20 315:2 

417:15 433:9 

supplying 251:12 

253:13 

support 15:13 16:21 

35:14,16,18 37:3 50:3 

51:21 54:5 99:4 105:8 

149:21 231:16 251:19 

269:22 270:8 281:20 

287:19 288:5 289:2 

289:14,15 308:15,20 

308:21 347:5 350:3 

351:14 352:5,20 

362:2,15 382:3 

388:22 389:3,5 

393:14 408:6 417:21 

418:22 424:4 431:6 

436:19 

supported 17:21 35:17 

35:19 52:10,22 62:1 

256:11 315:5 316:19 

382:6 

supporting 4:18 194:21 

204:10 289:12 315:8 

316:21 

supportive 52:5 244:3 

252:16 

supports 8:2 36:19 

51:12 64:15 246:15 

256:13,18 280:7 

374:7 380:4 396:1 

404:14 

supposed 326:8 432:18 

supposedly 324:16 

Supreme 428:10 

surplus 326:9 

Surprise 310:6 

surprised 142:14 145:6 

175:7 303:18 

surprising 147:9 

surprisingly 94:6 

340:18 

surrender 333:22 

surveillance 52:8,10,20 

58:16 

survey 3:9 96:19 97:20 

98:10,11 99:10 100:5 

100:10 102:13 104:6 

110:15 126:6 

surveyed 374:16 

surveys 6:6,9 97:1,8,22 

98:10,12,12 99:4 

100:16,17 102:5,10 

111:21 

suspect 145:22 

suspensions 93:7 

suspicious 201:19 

sustainability 118:7 

357:7 382:5,10 

sustainable 118:1 

121:3 139:10,22 

150:8 269:19 

Swaffar 1:22 9:18,18 

84:19 87:16 232:19 

234:7 257:12 337:22 

338:11,16 408:4,11 

408:20 409:16 413:8 

425:1,5,8,15,21 

swallow 173:18 174:9 

203:2 

swallowed 173:11 

203:3 

Swartwood 101:10 

sweater 44:3 

sweet 17:4 146:11 

272:1 

swiftly 282:11 

swine 219:15 223:9 

Swiss 149:13 

sync 104:12 

synthesis 173:1 

synthesized 171:21 

synthetic 78:14 115:13 

124:4 144:2 160:21 

164:2 169:18 207:19 

208:21 218:10 220:2 

225:20 226:16 236:12 

270:3 271:4 274:4 

308:13 320:5 374:7 

381:11,16 390:12 

403:11 418:22 424:7 

syrup 402:8 

system 23:8 24:6 25:11 

25:14 39:3 40:13 47:8 

47:9,17,19 51:2 62:10 

64:19 65:2,3 67:5,20 

68:4,22 70:3 78:11 

83:17 110:13 118:8 

163:15 164:1 168:6 

168:14 176:9 194:1 

199:2 219:9 246:13 

246:22 257:18 267:9 

272:10 301:22 313:19 

314:10 315:17 317:11 

370:11 371:7 372:12 

379:3 388:22 406:13 

421:10 430:20 439:15 

445:5,22 446:19 

447:12 448:18 449:16 

450:2 451:3 

systematic 121:22 

246:9 

systematically 123:21 

systems 10:18 22:17 

23:1 26:1 36:6,7,7,16 

40:11 41:11 64:9,11 

76:11,13 78:7 79:5 

80:22 104:12 118:1 

121:4 223:12 245:22 

255:16 259:3 265:20 

266:4 269:20 281:7 

290:22 379:13 415:1 

433:17,18,19 446:10 

systems-based 407:5 

T

T 158:12 

table 21:6 67:1 240:11 

242:16 

tablets 430:18 

tags 423:2 

take-home 225:9,13 

takeaway 106:3 

taken 25:2 33:14 49:12 

69:10 147:3 164:3 

267:8 269:12 304:9 

342:10 360:9 361:7 

379:9 437:2 442:2 

takes 70:16,16 146:2 

158:19 210:19 

talk 6:9 7:5 34:8 37:14 

37:18 40:22 48:5 49:2 

49:17 50:7,12 57:2 

67:17 89:5 97:7 

111:15 120:18 135:14 

136:21 198:19 209:13 

211:8 218:11 240:2 

292:12 302:13 371:4 

399:20 424:8,11 

430:15,15 443:4 

talked 50:19 60:5 184:8 

203:11 218:22 219:5 

221:6 226:20 231:2 

233:2 260:16 314:8 

343:3 371:13 399:10 

399:15 407:20 436:7 

440:12 

talking 29:22 105:9 

128:17 149:4 166:20 

166:22 184:16,22 

188:20 199:22 204:21 

212:14 226:22 234:20 

261:5 276:5 283:16 

293:14 295:7,8 305:3 

344:4,18 365:19,19 

366:12 371:6 409:13 

410:21 435:15 436:15 

tall 129:16 243:5 307:19 

tandem 393:13 

tank 267:7 

tanked 302:21 

tap 283:10 387:16 

395:6 

tapes 240:11 

target 65:7 181:20 

182:5 

targeted 202:15 

targeting 182:22 

targets 181:21 

task 2:15 35:18 206:10 

208:2,3 209:2 210:5 

232:6 250:17 251:3 

294:9 375:17 442:22 

444:16,19 

taskforce 309:2 312:11 

312:15 314:15 

tasty 222:11 

taught 171:1 206:18 

taxonomy 71:10 

TBD 381:3 

teach 59:9 

teaches 118:7 

team 4:16 5:18 14:18 

16:14,17 41:19 45:7 

118:20 136:12,20 

team's 39:1 

technical 204:19 256:9 

259:14,21 265:9 

266:19 268:1 274:7 

275:6 442:20 

techniques 51:20 68:8 

68:12 89:9 93:3 

technologies 285:17 

technology 47:4 120:1 

teeth 202:21 

tell 16:11 42:7 44:18 

55:3 85:12 89:6 93:4 

156:10 166:3 170:18 

174:13 202:2 229:1 

268:2 278:18 284:8 

284:18 295:22,22 

298:21 299:2 324:8 

334:11 384:9,10 

391:5,10 425:18 

telling 348:1 

temperature 138:10 

151:18 256:16 

temperatures 190:21 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
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template 453:13 

temporary 84:10,15 

270:9 272:21 377:22 

ten 7:9 113:14 115:15 

126:22 189:5 207:3 

218:14 272:2,9 

300:21 328:4 348:18 

349:6 364:17 426:20 

428:18,20,21 434:2 

ten-year 429:20 

tenacious 26:15 

tend 88:11 134:6 

277:14 

tenets 363:21 

Tennessee 316:10 

tenth 340:7 

tenure 101:1 

TER 274:16 

term 56:4 258:7 368:11 

381:3 

terminology 292:18 

terms 49:15 54:20 

107:2,4 120:19 

123:16,17 124:16 

126:8 128:20 130:12 

130:19,22 132:2,6 

134:9 135:19,21 

149:12 157:6 163:15 

166:13 168:5 192:19 

194:9,13 195:6 

199:17 200:21 204:17 

204:18,21 219:1 

258:5 276:14 310:15 

372:10 382:9 391:16 

391:21 392:3,14 

409:14 435:3 437:1,7 

440:20 442:1 443:19 

448:6 

Terry 45:8,14 

test 115:20 153:11 

174:22 175:2,4 

249:10 250:8 

tested 148:13,17 169:9 

332:15 

testified 337:16 

testimony 322:18 

testing 54:8 68:19 

99:19 128:3 191:12 

244:16 249:8 251:7 

251:22 252:6,12 

295:20 

text-only 55:20 

textbook 207:2 

thanked 44:13 

thanks 14:1 15:1 20:17 

20:21 75:16 84:4,17 

84:19 111:6 180:17 

182:12 226:7 232:19 

237:8,9 254:16 

257:12 268:4 269:5,6 

287:18 323:5 369:19 

378:11 384:11 432:3 

442:15 

theoretical 288:9,12 

theoretically 441:8 

thereof 206:4 

they'd 231:15 

things 20:7 26:4 60:11 

93:4 94:1,2,3 108:3 

109:10,14 129:2 

130:12 158:12 182:22 

190:2 197:15 202:8 

206:10 218:9 221:15 

223:5 225:9 236:6 

258:16,17 264:13,22 

279:1 284:13 285:10 

292:15,21,22 294:2 

314:12 315:16,20 

318:11 324:1 336:12 

336:14 340:12 341:3 

346:14 364:6 371:1 

371:22 389:21 402:16 

407:13 408:14 410:22 

416:12,20 431:9 

435:18 440:13 443:8 

443:21 444:6 445:3 

445:12 446:4 447:5 

450:1 

third 21:3,7 36:21 52:1 

123:11 125:11 136:8 

155:13 182:1 324:13 

385:19 412:14 427:9 

third-party 314:10 

this'll 152:16 

thorough 321:12 

392:12 

thoroughly 316:18 

thought 78:4 81:15 

96:16 127:19 145:11 

257:12 267:12 325:9 

369:3 410:6 427:4 

thoughtful 63:4 88:6 

308:4 

thoughtfully 38:7 

thoughts 33:7 300:20 

308:7 443:18 

thousand 391:17 397:7 

thousands 27:20 166:8 

271:16 

threads 445:14 

three 7:11 11:16 42:13 

46:14 50:16,17 51:9 

74:1,1 78:15,17 79:11 

79:15 80:9 81:18,22 

94:6 105:12 114:18 

127:15 153:7 162:1 

179:19 189:15 195:15 

195:18 206:9 209:11 

210:6 220:10 227:4 

232:2,22 237:4 

240:12,16 241:10 

242:3 250:8 254:20 

284:10 285:17 301:13 

303:2,2,4 319:21 

325:9 328:17 330:22 

331:2 341:16 342:3 

342:17,20 351:14 

352:3 361:21 376:3 

390:16 396:17 397:9 

401:17 409:2 

three-year 398:2,13 

406:9 

threshold 128:18,21,22 

129:1 134:20,22 

248:11 250:16 274:5 

388:14 

thrilled 268:17 

throw 232:1 

Thursday 136:7 

tied 299:9,10 334:19 

tight 151:19 

tighten 27:3 

till 118:3 300:21 

tillage 354:17 402:22 

Tilth 15:21,22 20:22 

timeframe 142:2 368:9 

timeframes 103:8 

timely 26:2 29:4 70:12 

104:17,20 281:10 

434:21 

timer 240:22 

times 25:18 51:9 97:16 

123:6 197:14 233:13 

304:11 332:14 398:16 

444:9 

tiny 235:18 

tissue 190:8 202:15 

tissues 167:17 

title 139:5 

tobacco 270:4,6,11,14 

271:5,7,9,15,19,22 

272:14,15 273:1 

275:2,13,17 276:10 

276:21 277:2 279:10 

279:13 315:4,15,21 

316:3 318:5,7,22 

321:13 374:9,14,16 

374:20 375:12 376:3 

376:11,14,17 377:1 

today 16:8 31:6 42:9 

65:22 67:11 72:21 

73:5 93:15 97:7,12 

115:8 117:18 123:14 

139:4 144:9 178:22 

196:9 211:8 239:17 

239:17,21,22 242:22 

243:22 254:20 269:15 

269:22 270:19 284:10 

291:16 307:22 333:7 

333:13 343:2 353:14 

353:20 359:15 390:2 

391:6 395:10 398:9 

398:16 403:12 404:4 

404:9 426:10 427:5 

429:18 430:11 431:11 

433:21 444:11 

today's 242:20 

told 45:7 320:10 333:2 

333:8 426:16 429:1 

tolerate 415:5 

Tom 1:17 10:1 91:3 

95:12 184:3 185:18 

203:10 263:18 265:6 

289:8 307:18 314:18 

321:22 323:9 366:7 

381:21 387:8 411:5 

412:7 414:13 441:16 

442:15 445:20 

tomato 298:19 432:9,9 

tomatoes 284:13 

408:16 409:4,6 

tomorrow 8:6 21:1 

65:22 323:16 426:10 

442:21 453:20 

ton 213:11 419:4 

421:16 

tongue 285:9 

tonight 323:16 

tons 213:19,20 355:11 

Tony 314:19 323:9 

Tony's 329:9 

tool 107:1 262:12 

263:13 

tools 39:16 49:10 260:3 

262:7 

toothpaste 202:19,20 

top 92:15 185:6 253:4 

272:2 277:21 301:2 

318:8 338:22 364:17 

396:10,15 397:12 

441:7 

topic 35:12 70:6 77:12 

164:8 233:8,10 255:4 

256:3 309:9 351:10 

351:13 369:10 380:12 

436:18 441:19 

topics 37:10 85:13 

243:22 373:6 

topping 277:18 278:1 

318:5 

total 107:10 110:7 

181:1 215:1 234:4 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
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344:22 

totally 81:7 137:17 

168:20 170:19 174:15 

300:20 450:7 

touch 232:9 243:21 

280:5 301:19 411:8 

touched 171:15 233:7 

318:9 

tough 266:2 

Touzeau 369:21 373:14 

373:16,17,21 377:20 

378:12 

Townsend 243:20 

toxic 177:8 178:21 

toxicity 274:11 

TR 255:3 256:18,22 

260:16 262:3 

trace 15:19 425:14 

traceability 36:19 50:20 

50:21 68:8,12 

traceback 68:10 

tracing 69:6 

track 67:12 

tracked 69:4 

tracking 40:17,18 

tract 176:18,21 

traction 160:16 

trade 41:11 47:10 48:17 

52:17 56:1 121:20 

251:19 285:3 432:2 

436:19 446:18 447:12 

trading 233:20 

tradition 15:18 

traditional 211:20 

traditionally 178:1,5 

traffic 83:11 

train 60:9 325:9 337:3 

trained 64:7 337:5 

training 57:12 58:12,17 

58:21 59:16,19 60:1,3 

60:7,14,17,19 64:15 

68:13,15 69:20,22 

70:3 84:14 118:10 

336:11,15 397:4 

439:5 

trainings 438:21 439:3 

439:7 

transcripts 13:14 

transfer 313:9 

transfers 176:12 

transformed 181:14 

transition 79:16,18 

80:9 81:19 82:1 94:7 

101:8 109:5 110:6 

325:21 376:12 398:2 

398:13 399:3 401:1 

406:9 434:12 

transitioning 80:7 

407:2 441:19 

transmission 429:16 

429:22 

transparency 19:16 

20:10 37:5 87:11 

238:8 244:15 246:15 

251:14 284:22 287:16 

363:20 365:15 370:10 

370:22 389:8 445:5 

445:11,14,16 446:6 

446:13 448:2,10 

transparent 35:18 78:3 

359:10 388:11 389:14 

transparently 27:1 

transplant 144:19 

transplants 127:17 

treat 202:6,10 386:16 

treated 267:8,9 

treating 449:11 

treatment 144:16 

267:11 

tree 216:4 268:9 

trees 224:14 268:9,11 

268:11,16 269:4 

tremendous 15:9,16 

444:11 

tremendously 105:11 

trend 107:18 132:18 

147:9 200:3 

trends 130:17 134:15 

trial 210:6 264:11 

292:11,14 

trials 209:15 281:16,18 

292:10,14 316:22 

tried 111:22 226:12 

227:8 310:14 

trigger 284:15,17 385:9 

triggers 284:10,11 

trimester 324:14 

trip 4:13 

trouble 18:5 81:3 

truck 83:11 

trucks 283:20 418:6 

true 390:1 

truly 21:16 45:16 

431:18 434:13 

Trump 429:9 

trust 28:11 92:2 95:13 

102:7 192:11 284:21 

388:10 389:8 

trusted 36:16 97:17 

Trustees 119:17 

trusting 19:1 

truth 235:3 

truthful 287:20 288:2,7 

try 17:19 110:14,15,19 

139:21 149:8 153:3 

195:19 218:6 222:2,9 

239:15,16 245:8 

258:15 259:16 260:3 

263:9 347:6 408:1 

409:7 414:6 419:14 

420:15 451:2,5 

trying 8:1 75:1 113:11 

127:19 157:9 168:9 

181:19,22 188:18 

194:14 200:14 226:15 

236:5 245:14,15 

247:17 258:4 259:1 

259:13,21 261:6 

262:7 263:2 421:7 

422:9 423:2,13 441:2 

441:9 442:2 

tube 202:20 

Tucker 2:6 3:8 4:3,7 6:1 

26:22 31:1,3 72:16 

75:16 78:19 80:17 

82:4 83:20 84:10 

85:10 87:21 89:5 92:4 

95:7 96:1 287:18 

288:10,19 304:8,17 

305:3,8,14 306:15,19 

307:1,4,9 312:19 

330:4 333:2 343:15 

345:21 373:3 399:6 

401:6 

Tucson 383:21 

tulsi 229:3,5 

turkey 54:15 209:13 

turkeys 209:12 220:15 

turn 8:7,22 13:21 66:1 

115:5 117:1 143:1 

205:19 342:13 376:19 

440:11 

turned 178:18 

turning 385:18 449:12 

tweaks 292:4 

twentieth 166:10 

twice 221:20 331:1 

two 19:9 42:13 48:13 

51:9 53:6,17 63:20 

74:2 83:2 85:18 

107:11 110:4 128:16 

132:11,12 133:14 

148:22 151:1 167:9 

167:12,22 180:18 

183:6 188:17 193:10 

197:4 198:2 200:4 

207:1 208:9 210:10 

211:5 212:20 215:2 

222:16 226:10 229:6 

232:21 235:17 236:6 

236:16 238:21 243:21 

245:9 250:8 263:22 

270:15 285:16 289:17 

290:8 325:11 328:14 

330:22 337:22 341:4 

341:16 342:3,17,20 

351:22 371:1 382:11 

383:16 384:6 390:5 

396:16 397:3 409:2 

409:17 419:4 420:9 

443:21 

two-pounds 421:16 

two-way 66:3 

type 56:17 109:10 

114:11 134:6 196:8 

223:16 229:20 231:9 

239:1 242:9 248:8 

256:16 268:19 

types 79:20 126:13 

167:1 171:17 195:15 

253:7 256:13 258:17 

262:19 

typical 130:8 221:11 

typically 131:9 167:18 

212:17 328:4 364:18 

418:8 

U

U.S 19:5 32:7 199:1,5 

206:12 245:18 367:1 

384:5,7 396:13 

UC 11:2 

UC-Davis 210:10,15 

UCLA 12:15 14:20 

ultimately 64:12 139:21 

157:22 195:18 281:2 

347:6 384:21 388:12 

umbrella 16:21 

unable 334:1 

unacceptable 398:4 

unachievable 23:3 

unanimous 375:4 

unannounced 54:8 

57:22 58:1,8 

uncertainty 164:3 

383:6 

uncertified 90:7 

uncharged 167:13 

unclear 258:7 293:5,12 

367:17 440:3 

undergraduate 5:15 

underlying 355:17 

undermining 397:22 

underscore 244:9 

understand 26:12 

28:20 41:16 75:1 

79:21 80:4 81:7 84:21 

94:2,3,5 97:15 113:11 

113:21 122:15,16,17 

129:19 131:1,5 135:2 

137:5 141:13 147:19 

157:10 203:6 245:10 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
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245:14 246:4 250:19 

251:21 258:16 259:2 

273:18 277:13 279:11 

288:15 306:22 334:12 

372:3 380:18 387:3 

389:6 392:13 393:16 

402:3 406:16 409:20 

413:11 432:5 443:22 

understanding 22:7 

65:9 88:8 123:17 

124:18 128:17 197:13 

199:13 203:17 

understood 273:16 

278:5 287:11 

underway 49:18 54:4 

63:8 384:15 

undisclosed 285:2 

290:1 

unequivocally 155:6 

289:18 

unfair 342:13 

unfeasible 271:8 

unfertilized 132:19 

unfortunately 23:19 

55:15 60:1 70:13 73:4 

123:8 124:10 148:18 

159:1 

unhelpful 271:8 

unification 359:5 

427:17 

unified 395:15 426:13 

uniform 389:13 397:20 

uniformly 435:9 

unintended 246:5 

248:9 

unintentional 147:21 

Union 198:2 390:11 

unique 7:21 80:5 88:6 

139:20 310:15 311:22 

357:9,13 439:13 

uniquely 354:8 

uniqueness 258:5,8,15 

311:3 

unit 163:10 

United 1:1 32:5 209:6 

221:17 254:6 270:6 

279:14 364:17 438:15 

444:22 

universally 6:5 

universe 296:5 

universities 122:1 

197:16 

university 2:11,13 

10:19 14:22 117:21 

118:14,16 119:20,21 

120:8,9 121:2 136:15 

199:10,16,21 206:15 

206:16,18 207:16 

271:2 316:21 

unjust 17:10 

unknown 174:15 

unknowns 253:11 

unlabeled 284:7 285:2 

unnecessary 256:21 

unqualified 168:20 

unquote 285:20 

unrelated 180:18 

unstable 167:14 

unsure 359:8 

untreated 245:20 

350:21 

unusual 27:16 344:14 

344:16 

unwilling 161:3 

upcoming 39:19 42:4 

47:3 97:19 98:10 

update 3:8,16 6:10 7:15 

7:16,19 31:2,5 37:10 

38:3 40:7 63:1 74:14 

96:12 205:8,18,21 

206:9 208:1,18 

updated 172:6 

updates 37:11 38:3,22 

41:7 63:20,21 71:9,17 

209:15 438:9 

updating 84:20 

upholding 78:20,22 

80:1 360:17 

upped 71:4 

upper 90:17 118:10 

162:2 

upward 422:7 

urban 79:13 

urbanization 18:7 

urea 144:16 

urge 255:22 257:5 

293:2,7 371:11,18 

377:7 379:14,19 

380:6 386:6 396:21 

urgency 78:1 82:5 

297:9 331:5 343:1 

345:6 377:11 397:16 

urgent 334:19 348:2 

433:15 

urging 397:1 

urinary 219:9 

usage 164:12 198:17 

265:19 

USDA 2:9 3:8 4:16 5:9 

5:11 6:11 16:18 26:4 

38:17 46:20 76:7 79:1 

86:16 91:5 98:1 100:7 

105:13 122:1,13 

182:20 189:20 251:3 

334:6 374:2 396:3 

428:22 433:18 437:7 

USDA's 4:9,11 6:8 

96:19 97:8 106:13 

USDA-accredited

349:19 

use 36:4 55:22 56:4 

71:9 76:11 79:9 88:11 

91:2 124:4 125:1 

135:9 152:20,20,21 

156:1 160:21 175:11 

179:7,13,21 181:18 

188:20 190:16,18 

197:20 198:16 200:22 

201:4 202:4 208:19 

212:19 214:1,15,16 

215:4 216:17 227:6 

234:5 236:12 237:7 

244:18 255:7 257:19 

257:20 258:11 259:2 

261:7 262:11 266:3 

270:3,10 273:20 

274:15 275:17 281:12 

289:19 294:21 297:16 

305:15 306:1 309:5 

313:18 315:3 318:2 

318:17 319:19 320:14 

332:1 350:11 354:12 

374:15,17 381:6 

390:12 394:8,17,20 

398:3,13 407:21 

410:12 411:9 416:6 

424:19,20 434:12,15 

435:2,4 443:13 

453:17 

use-up 377:4,7,16,17 

useful 72:3 88:4 282:6 

user 394:3 

users 104:18 

uses 24:2 162:19 266:8 

302:9 

usually 188:4 213:15 

214:8 418:15 419:9 

420:4 

Utah 129:16 

utilized 159:5 

utilizing 443:15 

uttered 206:3 

UW 125:21 126:20 

127:22 

V

vacancies 48:9 

vacancy 6:22 

vaccinations 338:4,12 

vaccine 352:1 

vaccines 338:3 351:10 

351:17,20 352:7 

vacuum 260:8 

valid 427:5 

validation 105:4 

Valley 2:14 119:12 

154:15,17 183:14 

208:4 209:16 226:19 

229:14 

Valley's 126:1 

Valley/CROPP 2:12 

Valleys 122:19 

valuable 18:7 204:8 

value 20:4,11 54:17 

105:21 106:1 107:20 

110:7 111:17 272:2 

279:12 281:18 443:19 

444:21 

value-added 339:8 

values 61:5,21 87:14 

100:11 

variability 129:14 

133:17 134:1 135:2 

152:5 183:19 192:8 

260:15,22 

variable 260:17 

variables 61:7 126:10 

variation 129:20 138:4 

157:12 158:13 206:4 

419:12 

varied 128:20 

varies 104:10 

varietal 157:7 158:10 

varieties 128:13,14 

130:1,9 133:21 

134:10 142:17 147:2 

147:10 197:13 245:21 

246:7 255:14 262:20 

268:16 281:2,17 

282:1,4 296:8 

variety 29:14,19 118:3 

118:22 126:12 128:7 

129:4,6,16 130:3,4,6 

130:18 131:12,19,22 

132:1,2 141:15 

144:14 163:20 195:22 

247:13 248:1 281:16 

292:10,11,14,14 

298:20,22 299:22 

351:2 415:22 

various 24:2 25:2,4,18 

228:11 260:16 261:22 

276:21 410:11,12 

vary 135:9 

vast 28:16 77:18 94:4 

131:7 260:21 415:16 

vastly 290:6 

vegetable 9:22 121:5 

124:3 125:8 127:6 

129:10 140:18 148:15 

148:21 149:7,16,16 

161:12 169:5 195:21 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
500 

375:3,7,10 376:19 

414:2,14 

vegetables 131:6 

139:11 142:3,6 

146:19 149:9 151:15 

172:5 175:8 257:3 

298:18 376:20 414:16 

418:17 

vegetarian 219:22 

431:12,16 

vegetarians 364:10 

vegetation 83:9,12 

vegetative 292:5 

350:18 351:7 367:11 

367:14,17 368:11 

vendors 328:21 

verbiage 427:13 429:4 

verification 314:10 

verify 322:12 337:19 

338:7 

Vermont 405:10 

versa 103:1 

version 280:10,14 

versus 82:15 89:2 

111:18,22 125:7 

129:17 130:6 131:10 

131:16 133:19 184:18 

220:20 277:12 318:10 

viable 187:2 273:19,21 

276:16 316:3 446:18 

Viagra 202:15 

vibrant 9:8 

vice 1:18 11:13,21 

12:11 103:1 

video 242:20 329:6,15 

view 60:17 82:21 90:22 

245:12 261:12 282:19 

330:18 341:10 

views 276:21 

vigor 18:17 

Vineyards 300:16 

violates 83:18 

violations 62:7 385:20 

violators 40:19 

virtually 176:19 

visibility 438:17,18 

visible 41:3 70:21 

vision 402:14 412:2 

visit 23:5 

visited 27:19 32:20 

61:10,13,21 90:17 

103:10 

visits 57:21 58:1,8 

vital 50:21 

vitality 21:18 

vitamin 190:19 

vitamins 381:8 

voice 333:22 392:6 

393:10 395:16 

voices 254:8 

volume 307:20 

volumes 189:10 448:16 

voluntarily 293:20 

voluntary 101:22 104:3 

104:6 437:9 

volunteering 116:17 

vote 20:9 82:14 238:10 

317:17 321:2 

voted 82:14,15 

votes 7:7,9 451:11 

voting 48:4 453:2 

VP 442:19 

W

wait 194:2,6 218:4 

239:5 342:4 348:7 

408:11 

walked 361:10 

wanted 20:21 82:11 

108:22 132:7 160:19 

247:13 259:22 273:7 

277:8 278:10,16 

294:9 330:2 331:15 

340:22 370:8 373:20 

378:5 406:7,17 411:7 

411:19 

wanting 264:21 

wants 41:14,15 368:2 

441:17 

warehouses 18:19 

warrant 415:3 

warrants 155:10 

Washington 1:12 2:10 

7:13 9:8 11:6 12:11 

15:8 16:2 17:6,13 

31:15 42:14 43:9 

243:20 426:15,19,21 

428:14 

Washington's 15:19 

Wasieleski 2:14 118:13 

118:19 138:17,18 

151:1,10 152:10,21 

153:6,15 154:3,6 

164:4 180:2 181:15 

184:15 185:2 186:5 

186:19 187:3,8 

195:11 198:20 200:12 

wasn't 61:16 94:18 

145:7,15 174:3 181:9 

184:10 188:12 216:10 

239:12 246:20 305:5 

305:11 445:2 

waste 267:2 358:13 

watching 22:5 52:18 

376:4 

water 59:22 172:18,18 

172:19,20 176:3 

187:4,11 188:1,15 

189:4,9 190:4 212:2 

214:6 256:16 265:19 

283:21 372:10 403:8 

449:21 

water- 257:1 

watered-down 428:5 

wave 4:20 5:3 

way 8:2,3 17:9,13 18:21 

26:2 29:2,4 39:18 

64:21 65:4,15 78:3 

81:15 86:5 101:11 

102:4 103:14 109:2 

113:20 120:22 121:22 

151:6 159:6 161:12 

169:10 171:18 178:19 

187:1 188:2 192:9 

193:1 194:7 199:11 

211:20 215:16 216:7 

224:9 235:21 236:2,5 

240:9 246:10 249:20 

253:17 268:12 279:2 

291:4 292:10 294:1 

301:18 316:10 318:10 

322:13 332:4,14 

342:13 364:22 365:4 

365:8 371:7 389:5 

393:9 402:17 410:16 

413:15 415:4 416:5,9 

416:10 419:16 437:6 

438:6 440:7 445:15 

447:3 

ways 6:20 27:3 49:20 

69:6 83:11 88:16 

115:11 116:4 249:20 

252:16,21 253:9 

339:8 415:2 417:6 

444:7 

weak 385:19 

weakest 388:12 

weaknesses 70:22 

weather 133:20 138:8 

145:15 

web 51:19 

webinar 63:4 238:22 

239:9 273:8 277:9 

279:9 347:20 

webinars 267:5 317:5 

website 48:21 49:20 

92:19 93:6 341:7 

WEDNESDAY 1:9 

weeds 301:16 

week 58:9 83:2 123:10 

127:17 384:7 433:3,7 

440:21 

weeks 17:8 47:3 49:15 

209:22 210:16 221:10 

221:11 235:17 420:9 

weight 86:14 159:14 

173:3 217:9 219:2,3 

326:10 

weights 419:13 

welcome 3:5 4:5 9:3 

14:22 15:5 19:18 

20:12 31:18 207:9,21 

243:20 357:2 

welfare 25:10 212:4 

217:12,22 315:15 

316:16 317:11 318:3 

318:12 390:7 

well-established

224:13 

went 103:10,11 107:13 

107:21,21 114:22 

202:3 205:11 209:22 

222:11 233:3 277:11 

320:7 324:1 325:3 

349:10 410:16 441:12 

453:22 

weren't 86:3 453:5 

west 126:21 146:21 

283:14 294:19 325:4 

western 11:10 90:17 

353:16 

Westminster 207:14 

wet 175:3 186:2 214:5 

223:2 236:10 

whey 209:17 

whim 339:11 

white 5:11 126:17 

Wholesalers 254:4 

wholly-owned 154:19 

wide 118:22 

wide-ranging 95:10 

383:9 

widely 258:12 

widely-held 448:4 

wider 396:11 

widespread 334:3 

wife 327:22 329:3 

wild 308:16 310:17,18 

313:8 413:14 414:16 

wildlife 285:15 

wildly 415:1 

willing 18:12 29:1 

196:18 296:3 

willingness 26:22 

wind 285:15 

wind-up 29:21 

winds 173:3,11 

winner 73:14 

winners 38:1 45:2 70:8 

72:7,9 73:13,19 74:1 

74:4,10,11 

winter 223:15 230:18 

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396:14 428:8 

Wisconsin 2:11,13 

113:1,2 117:21 

118:11,19 119:5,21 

120:8,9 121:2 229:11 

279:10 417:16 418:4 

418:5 

wise 253:11 

wish 266:15 341:2 

wishing 239:2 

woman 284:18 

women 176:4 

won 74:1 

wonder 174:1 297:5 

wonderful 5:17 41:18 

344:1 

wondering 78:9 183:17 

197:16 226:16,21 

227:6 231:7 274:2 

287:14 382:16 392:15 

405:6 

woohoo 41:21 

word 19:10 43:2,21 

49:21 56:9 60:8 67:7 

93:17 178:8 411:8 

wording 24:11 99:21 

292:4 395:1 

words 19:11 20:20 

206:3 254:13 318:3 

345:15 

worked 27:14 55:4 97:3 

119:6 121:4 144:12 

179:1 197:17 232:21 

322:1,6 383:16 

447:14 

worker 274:20 

workers 219:12 271:9 

315:15 318:6 

working 14:14 22:22 

26:20 44:1 46:18 

47:14 49:4 53:16 

54:22 64:17 67:6 69:8 

75:13 91:7 104:4,13 

119:1 121:19 138:22 

150:21 154:14 156:19 

162:2 196:13 204:15 

204:17 205:3 265:4 

269:19 293:9 309:2 

314:15 321:19 336:2 

388:15 417:18 420:21 

421:8,12 422:14 

works 207:8 243:17 

256:15 264:4 280:2 

423:15 

world 32:2 37:8 43:16 

82:9 113:14 174:1 

285:1 306:17 314:2 

339:6 445:2,10,16 

448:2,22 

worldwide 31:21 36:19 

worm 215:18 223:18 

worms 229:17 

worried 259:19 

worry 190:7 201:22 

202:17 

worst 91:16 

worth 128:16 183:21 

264:15 328:17 416:19 

worthwhile 409:11 

wouldn't 86:22 112:2 

231:15 259:20 263:10 

299:7 321:17 441:4,9 

447:2 452:9 

wound 171:17 

woven 449:20 

wow 246:21 

wrap 204:2 234:13 

wrap-around 287:21 

wrapping 203:10 

wrestle 20:6 

writes 59:7 

writing 87:22 238:5 

written 58:20 94:17 

226:19 239:10 244:4 

254:19 266:14 270:13 

273:8 280:14 292:3 

308:4 312:11 350:4 

358:4 385:13 402:17 

421:9 427:2 

wrong 30:22 258:22 

300:8 301:9,10 

323:18 366:11 

wrote 227:16 311:18 

382:3 431:5 

WSDA 2:11 20:22 

WSDA's 14:17 

Wyard 442:19 

X

Y

year 7:1 16:10,12 17:8 

17:11 23:9 32:10 

40:15 44:4,7,16 50:4 

57:1 58:13,14,15 64:5 

71:6,13 72:9 74:4,8 

74:10,11 79:15 80:9 

81:19,22 90:21 94:6 

100:14,15 102:13 

110:19 127:14 129:14 

129:14 156:19 188:7 

210:9,10 213:19 

237:4 262:21,22 

282:15 300:18 303:3 

320:12 324:9,9 

328:16 329:10,13 

330:22 331:7,16 

335:10 341:17 377:17 

377:19,22 438:10 

year's 45:2 

year-old 269:18 

year-round 187:19,20 

year-to-year 157:12 

years 5:9 16:1 22:4 

49:14 70:18 74:2 

78:16,17 79:11 97:6 

99:1 101:3 115:15 

120:6,18 121:5 

126:22 132:11 133:15 

133:21 135:4 138:4 

148:13 155:17 166:8 

168:12 169:3 170:10 

170:20 174:15 201:12 

206:13 207:4 210:7 

229:9 250:8,8,15 

251:7 263:22 272:9 

280:12 284:2 285:11 

289:17 302:4,17 

303:2,4 319:14 325:2 

328:14 329:4 331:2 

339:4 342:3,17 346:6 

346:22 376:3 383:16 

384:6 402:11 417:17 

417:19 428:18,20,21 

429:8 431:19 434:2 

435:16 445:3 

years' 128:16 328:17 

yellow 126:17 240:17 

yeses 348:17 

yesterday 42:8 43:6 

74:21 92:6 301:11 

304:5,21 305:6,9 

306:5 330:6 333:7 

426:9,12 427:4 436:7 

436:12 437:17 

yesterday's 333:12 

yield 50:13 51:7 53:8 

286:9 

yields 51:5,5 53:13 

354:17 375:22 

young 26:3 68:21 

189:11 210:21 284:18 

Youngblood 373:19 

378:15,16,17 382:12 

382:20 

younger 18:5 106:4 

175:8 340:7 

Z

Zambetti 426:5 430:8 

430:10,13 432:8,13 

Zea 283:10 290:12 

291:11,14 294:14 

296:19 300:4 

Zea's 381:4 

zone 9:11 

0

0.01 166:21 

0.02 166:21 

0.4 159:13 

0.7 172:13 

0.9 159:13 

07 209:2 

1

1-1/2 130:15 

1,000 32:4,9 357:21 

418:7 

1,300 16:17 

1,400 31:13 

1,600 367:1,2 

1,848 344:7 

1,900 326:11 

1.1 155:19 

1.2 182:2 

1:45 205:7 

1:47 205:12 

10:27 114:22 

10:45 114:20 

10:48 115:1 

100 50:15 54:9 143:4 

159:16 186:10 213:19 

213:20,21 418:1 

100-fold 167:1 

100-percent 427:5 

1000 169:7 

11 357:15 377:3 

119 156:6 

12 211:14,15 221:10 

286:9 350:18 367:13 

368:4 

12-month 368:8,15 

12,000 128:19 

12:25 205:11 

120 3:12 61:11,17 84:7 

84:14 88:20 89:17 

127:12 190:16 

1200-ppm 134:20 

125 127:11 

13 3:3 355:9 

14 6:21 7:6 210:19 

254:11 421:5 

140 329:12 

145 131:16 

15 3:5 5:9 7:9 97:6 

101:4 121:5 357:16 

15,500 32:13 

150-some 283:13 

150,000 328:16 

154 3:13 

156 189:22 

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16 39:12 213:8 134:16 147:2,5,22 28th 99:14 54 206:2 270:17 

165 3:14 274:8 328:3 344:7 29 120:6 55 9:6 13:3 

169 270:7 395:14 29th 99:14 550 190:18 

17 35:16 58:13 

17-percent 419:3 

2017 32:3,6 39:9 98:7 

98:20 99:11 101:20 3

55th 9:3 205:16 

57 106:1 

171 131:17 105:17 111:2 112:2 3.5 127:8 57.5 106:7 

18 213:12 284:2 128:17 129:17,22 61:18,22 82:22 89:16 570 216:16 

18-percent 419:10 132:21 133:16,19 170:10,19 174:15 58 349:19 

18.5 419:13 

1860's 202:10 

147:3,8,22 152:7 

153:12 155:18 181:4 

201:12 229:4 328

417:17 449:18 

:10 

6

19 13:15 283:13 418:12 200:8 333:9 374:10 30- 397:6 6 172:15,16 

19- 419:13 442:10 451:11 300 323:12 6:00 21:2 

1920's 179:8 2017-2018 344:21 31 3:8 6:14 453:22 

1937 428:12 2018 13:7 31:21 32:7 32 156:3 60 54:9 

1970's 179:9 190:14 39:13 40:5 54:18 33 328:15 606 115:18 116:1 

1970s 15:20 402:6 332:17 382:5 384:13 39:5 160:11 435:22 436:4 

1980-81 190:14 396:22 431:2,4 442:7 350 55:8 64 106:9 

1985 16:3 442:10 36 119:14 65 209:22 210:16 

1987 16:6 2019 1:7,9 3:9 4:6 38:9 38 344:8 6518(m) 274:10 

1989 427:8 39:7,20 40:1 48:7 39 105:22 66,000 357:15 

1992 100:19 

1995 100:21 

1997 19:3 101:1 

58:7 63:9,17 69:17 

71:7 97:19 98:10,19 

99:9 110:15 128:6 

4

4 3:2 168:18 181:21 

67,000 210:16 

7

1998 296:21 239:1 272:13 377:3 369:2 7.1 107:11 

1st 325:16 326:3 396:9 397:2 4.1.6 367:10 7.2 106:1 107:20 

2020 377:19 378:2 4:15 349:10 70 337:13 

2 2021 254:11 4:25 349:7,8,11 700 32:13 

2,000 119:13 181:11 2022 341:20 357:22 169:3 170:10,20 75 31:11 43:3 145:10,17 

236:8 419:22 2023 341:20 229:4 269:18 417:19 172:14 301:6 

2,300 326:10 

2,560 344:9 

205.202 79:4 306:2 

205.203 402:19 404:1 

449:18 

400 181:4,11 8

2.7 182:2 

20 7:4 48:7 155:17 

205.204(a)(1) 350:13,20 

351:4 368:6 369:1 

401 107:21,22 

416 350:10 

8 130:16 

8,000 418:8 

168:12 173:15 211:14 

211:16 262:21,22 

205.204(a)(4) 367:20 

205.601 374:8 

42 106:10 223:20 

229:18 

8:00 21:2 

8:30 1:12 453:20 

268:15 417:18 449:18 205.605 430:17 43,000 31:22 8:32 4:2 

20,000 213:15,18 20th 179:5 43,004 32:1 80 166:14 210:16 

235:19 21 3:6 54:18 191:14 301:6 81 145:10,17,18 

200 67:2 166:15 189:1 355:11 453 3:22 84 107:22 

190:9 

2002 324:4 

2105(2) 78:12 

211 3:17 

45th 300:18 

48 328:13 395:21 

85 209:5 353:16 

2004 427:8 430:22 218 3:18 107:21 9

2006 120:5 22 206:22 5 9 181:21 189:20 

2007 207:15 323:21 

2008 98:17 

22-1/2 213:13 

220 172:10 270:5 

5 130:16 172:16 

5,000-bird 419:22 

9,000 429:15 

90 17:3 144:21 296:22 

2010 35:11 334:1 23 316:9 5:30 284:2,18 328:21 428:8,9 

356:12 397:13 436:20 237 3:20 5:37 432:19 910,000 210:19 

2011 101:1 238,000 210:22 5:51 432:18 95 144:22 145:18 

2012 105:21 207:15 24 1:9 127:22 54:17 127:13 186:8 357:19 428:9 

2014 98:18 101:3 25 155:14 173:10 236:7 323:12 374:9 96 145:5 

2015 35:16 100:4 206:13 268:15 328:10 395:21 97 3:9 145:5 

121:18 124:1 125:12 250 213:11 323:13 50,000 183:15 203:1 

146:14 164:7 323:21 25th 335:10 391:16 

333:9 343:2 344:6 26 270:13 339:4 500 284:3 

405:10 263 156:8 500,000 328:14 

2016 54:16 125:19 27 39:5 326:12 5029 350:10 

128:17 129:17,21 27,500 32:7 51.3 106:7 

132:12 133:15,18 28 326:12 374:18 515 1:12 

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C E R T I F I C A T E 

This is to certify that the foregoing transcript 

In the matter of: National Organic Standards Board

Spring 2019 Meeting

Before: USDA

Date: 04-24-19

Place: Seattle, WA

was duly recorded and accurately transcribed under 

my direction; further, that said transcript is a 

true and accurate record of the proceedings. 

 ----------------------- Court Reporter 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 
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 UNITED STATES DEPARTMENT OF AGRICULTURE

 + + + + +

 NATIONAL ORGANIC STANDARDS BOARD

 + + + + +

 SPRING 2019 MEETING

 + + + + +

 THURSDAY,

 APRIL 25, 2019

 The Board met in the Courtyard Ballroom at

the Renaissance Seattle Hotel, 515 Madison

Street, Seattle, Washington at 8:30 a.m., Harriet

Behar, Chair, presiding. 

PRESENT: 

HARRIET BEHAR, Chair

STEVE ELA, Vice Chair

SCOTT RICE, Secretary

SUE BAIRD 

ASA BRADMAN 

JESSE BUIE 

TOM CHAPMAN 

LISA DE LIMA 

RICK GREENWOOD 

DAVE MORTENSEN 

EMILY OAKLEY 

A-DAE ROMERO-BRIONES 

DAN SEITZ 

ASHLEY SWAFFAR 

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STAFF PRESENT: 

MICHELLE ARSENAULT, NOSB Advisory Board 

 Specialist, National Organic Program 

DAVID GLASGOW, Associate Deputy Administrator, 

 National Organic Program 

DR. PAUL LEWIS, Ph.D., Director, Standards 

 Division, National Organic Program 

CLARISSA MATHEWS, Ph.D., National List Manager 

DEVON PATTILLO, Materials Specialist, National 

 Organic Program 

DR. JENNIFER TUCKER, Ph.D., Deputy 

 Administrator, National Organic Program; 

 Designated Federal Official 

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 CONTENTS 

Public Comments. . . . . . . . . . . . . . . . . . 7 

Materials Subcommittee 

Topics:

Proposal: Excluded methods determinations

 April 2019 . . . . . . . . . . . . . . . . 306

Discussion document: Excluded methods: induced

 mutagenesis and embryo transfer. . . . . . 314

Discussion document: Marine materials in organic

 crop production. . . . . . . . . . . . . . 320

Discussion document: Genetic integrity

 transparency of seed grown on

 organic land . . . . . . . . . . . . . . . 339

Discussion document: Assessing cleaning and

 sanitation materials used in organic crop,

 livestock and handling . . . . . . . . . . 353 

Compliance, Accreditation and Certification

Subcommittee 

Topics: Discussion document: Oversight

improvements to deter fraud - Summary. . . . . . 376 

Livestock Subcommittee 

Topics: Proposal: Oxalic acid. . . . . . . . . . 401

Discussion document: Use of excluded method 

vaccines in organic livestock production . . . . 419 

2021 Sunset substances review:

 Atropine . . . . . . . . . . . . . . . . . 433

 Hydrogen peroxide. . . . . . . . . . . . . 437

 Iodine . . . . . . . . . . . . . . . . . . 438 

Adjourn. . . . . . . . . . . . . . . . . . . . . 448 

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 P-R-O-C-E-E-D-I-N-G-S

 8:32 a.m.

 CHAIR BEHAR: Okay. Thank you 

everyone. Good morning and welcome to the second 

day of the 55th public NOSB meeting, and we are 

going to start with public comment today, and 

then in the afternoon we will move to 

Subcommittee reports, our Materials Subcommittee, 

Compliance, Accreditation and Certification 

Subcommittee and Livestock Subcommittee are on 

the agenda. 

 So before we start, I just want to 

give you some ground rules for giving public 

comment. Public input is an important part of 

the NOSB decision-making, and be assured we do 

listen and depend upon your ideas and 

suggestions.

 All persons wishing to give public 

comment sign up prior to the meeting, and 

speaking slots are served on a first-come basis. 

When we hit our limit, we put people on a wait 

list in case there are cancellations. 

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 Comments are limited to one per person 

for each NOSB meeting, and if you spoke at the 

webinar or yesterday, you cannot speak again in 

person at this meeting. Proxies are not allowed.

 If we call your name and you're not in 

the room, we'll try to come back to you if time 

allows. We're going to try to have everyone 

who's on our schedule get through today, so 

hopefully we won't get too far behind. 

 I ask that members of the public 

please try to take any side conversations 

outside, and members of the public as well as 

members of the Board, please mute your phones and 

your computers so that we can clearly hear the 

speakers who are providing comment. 

 You are allowed to take photographs, 

but please do not distract either the Board or 

the speaker during that activity. Each speaker 

has three minutes and is Michelle there. 

Michelle, do you want to go over the way the 

timer works?

 MS. ARSENAULT: Yes. So there's a 

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clock now on the podium and it will start at 

three minutes and count down to zero, and it 

gives you one beep when you have one minute left. 

 Don't be alarmed by that, and then it 

will beep incessantly when your time is up, and 

I'll stop the timer at that point. Otherwise, it 

will start counting back up again to show you how 

much time you've gone over your three minutes.

 There's also a slide advancer on the 

podium. For those of you who have PowerPoint 

presentations, you can advance your own slides 

and then I can show you. There's two buttons on 

it, so you can go back or forward. Thanks. 

 CHAIR BEHAR: Thank you, Michelle. 

Commenters have three minutes, and once that's 

completed, I will then ask the Board members if 

there are any questions for that specific 

speaker. 

 Lastly, individuals providing public 

comment to the Board are asked to refrain from 

personal attacks that might impugn the character 

of any individual, and if I hear that type of 

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speech I will interrupt the speaker and ask them 

to refrain from that activity.

 So I will call on the person who is 

next to speak and also announce the person on 

deck. The area on deck is right next to 

Michelle, and feel free to grab an animal or a 

marine animal or whatever you see over there as a 

souvenir or just my gift to you for sharing 

biodiversity on the planet.

 So first up is Mike Dill, and after 

Mike is Michael Crotser, and I should know how to 

say his name because I know him. Thank you, 

Mike. Please state your name and affiliation.

 MR. DILL: All right, good morning. 

My name is Mike Dill, and I'm the Food Safety and 

Compliance Manager for Organically Grown Company. 

I'm also the coordinator for Organic Produce 

Wholesalers Coalition and of course would like to 

thank the NOSB for their time and dedication to 

organic integrity.

 Please note that today my comments 

represent both OPWC and OGC. OPWC members are 

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required to comply with FDA's preventative 

control rule for human food and foreign supplier 

verification program, FDA's Bioterrorism Act and 

good manufacturing practices. We have to comply 

with third party audits, customer audits and 

we're also subject to FDA's mandatory recall 

authority.

 I just want to state on the record how 

important sanitizers are to our operations, 

because preventing the adulteration of food is 

essential to our organic businesses, and in fact 

is essential to every food business. NOSB 

members have stated now that the intent of this 

comprehensive review is not to remove any 

sanitizers from the National List, but we remain 

unconvinced because the logical outcome of 

evaluating for uniqueness would seem to eliminate 

all but one unique material in each category.

 We submitted detailed comments on 

sanitizers expressing our concerns that one, 

moving forward with a technical report before 

stakeholders were able to provide input was 

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premature and not transparent, two, the concept 

of uniqueness, the idea that there can only be 

one sanitizer per use or function is not 

supported by OFPA, and does not address the wellknown need to rotate sanitizers to avoid 

resistance problems, and three, developing new 

evaluation criteria specifically for sanitizers 

may not comply with OFPA.

 The OFPA criteria and current 

evaluation process is sufficient and is working. 

If you look the petition for SDC, you'll see that 

the evaluation process is working just fine 

without using criteria other than those in OFPA. 

In this scenario, a new sanitizer was petitioned. 

It's promising because of its alternative mode of 

action, but we are still evaluating it against 

the environmental and human health criteria from 

OFPA because new information continues to be 

presented by stakeholders and public comment. It 

appears that we're still in the discovery phase 

and we're not ready to make a decision yet.

 When new information comes out, we 

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deserve the time to review, research and respond. 

In order for the evaluation process to 

effectively apply the OFPA criteria, especially 

for products that present information that is new 

to most of the members of the organic community, 

we must allow for an iterative process that 

includes the petitioner, NOSB members, technical 

experts, affected parties and other organic 

stakeholders to interact over time.

 Applying the OFPA criteria is a 

process that requires careful consideration, open 

minds and creative outlooks to balance elements 

of a complex system which at times may conflict 

with each other. We do not need additional 

criteria, but rather the patience and 

perseverance to apply the OFPA criteria, which 

serves for evaluation of all other types of 

materials. Thank you.

 CHAIR BEHAR: Any questions from the 

Board? Mike, I have one. So are you thinking 

that if we do a TR on understanding the mode of 

action of various active ingredients in 

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sanitizers, that we will no longer review 

products as they come to us as petitioned, and 

just do it internally and not in front of the 

public? Is that your concern?

 Because you mentioned that you wanted 

the sanitizers to be reviewed in the public eye. 

So I just want to make sure that you understand 

that we will still do that. 

 MR. DILL: Yes. I'm not sure if 

that's what I said.

 CHAIR BEHAR: Okay.

 MR. DILL: I was asking that we have 

a deliberative process with everyone involved, 

where we still review the materials against OFPA 

criteria. So I'm not suggesting a change to any 

process. Did I answer that correctly? 

 CHAIR BEHAR: Okay, Ashley? Okay. 

Ashley.

 MS. SWAFFAR: Yeah. So you have 

concerns over uniqueness. Can you talk about the 

rotational use of sanitizers in your operation, 

and why maybe just one sanitizer for an 

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application wouldn't work?

 MR. DILL: Sure. So we would like to 

rotate more than we're able to. Unfortunately, 

we have some pieces of equipment where -- that we 

lease from manufacturers, so they don't allow us 

to. They say you have to use this material, 

because otherwise to use one over the other it 

might be corrosive, it might damage the 

equipment.

 So but we do, and we do it more for 

environmental sanitation. I will just state that 

in our operation, we don't use any direct contact 

sanitizers. We're not applying, we don't use 

water in our operation. So we're not 

disinfecting water, we're not -- we don't have 

water baths.

 So it's more important for our 

suppliers than it is for us, because they are --

they have many more uses. We're sanitizing table 

tops, you know. So but we do. We use our 

hypochlorous acid, which we generate on site, 

electrolyzed water, and we use that on our table 

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tops daily and in between our repacks. So we do 

repacks throughout the day.

 So we might do -- we might sanitize a 

table 50 times throughout the day. But at the 

end of the week, we use our peracetic acid and 

we'll do a full clean up, clean down, wash down 

of the equipment. So we would love to have more 

options in terms of sanitizers, especially with 

different modes of action, and that's why SDC is 

appealing to us and it was from the very 

beginning. 

 We were in support of it until we saw 

the environmental, the potential environmental 

impacts of using it outside of municipal systems. 

I think that's been addressed. However now, you 

know, with some new information that came to 

light about the potential use of silver in wounds 

and dressings, and that's a little outside of, 

you know, my expertise and our expertise.

 So we're hoping that we can now look 

at that information, take that into 

consideration, potentially postpone a vote and, 

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you know, evaluate it against the new information 

that came to light, and kind of get into this 

iterative process where we can, you know, 

actually take the time to research all the 

aspects of the material so we can come to a fair 

and proper decision.

 CHAIR BEHAR: Tom.

 MR. CHAPMAN: I have two questions for 

you. You've answered my SDC question I was going 

to toss at you. Can you, can you spend a little 

time talking about the difference between 

cleaning and sanitizing?

 MR. DILL: I can. So cleaning, I mean 

these are actually terms that are defined, and 

when I went to Oregon State University for Food 

Science, which is what I got my degree in, our 

very first class was food sanitation. And the 

very first chapter of the book we had was 

explaining the difference between cleaning and 

sanitizing.

 Cleaning is defined, I'm going to 

paraphrase, as the removal of dirt and residues 

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from the surface of the -- from the surface, and 

then sanitation is the actual like destruction of 

cells or -- I mean they define it more in terms 

of what the reduction of bacteria is. 

 So if you have a 5-log reduction, then 

you've actually sanitized the surface. So one, 

you can't sanitize a surface that hasn't been 

cleaned first, and that's why the standard 

operating procedure in any restaurant and retail 

operation anywhere you go is clean, rinse, 

sanitize.

 So you clean off all the debris so 

that you can go through and sanitize and get that 

kill step.

 MR. CHAPMAN: And then my second 

question is you talked a bit about your use of 

sanitizers is mostly environmentally based in 

your operation, and we've had comments or 

questions earlier about good agricultural 

practices and whether or not, you know, a high 

level of good agricultural practices would 

eliminate the need for sanitizers or negate the 

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need perhaps. Can you, can you speak a little 

bit to that?

 MR. DILL: I could, and that's a 

conversation I love having and I wish we had, you 

know, hours to talk about this. But good 

agricultural practices will help reduce the 

contamination of produce out in the field. It 

covers personal hygiene as well. So it does have 

some preventative practices.

 FSMA's the same, the same kind of 

process, is that they're trying to prevent as 

much as possible. However, there's so much out 

there in the environment that you can't account 

for everything. If you remember, we grow produce 

in the dirt outside with animals, with all the 

environmental factors out there, and we're, you 

know, so we're subject to a lot.

 But the -- in my opinion and the 

research I've done is that the biggest concern is 

the post-harvest handling. So I think a good 

example is there might be a single head of 

lettuce that comes in with some contamination. 

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Maybe an animal dropped by, you know, and visited 

that lettuce.

 If you put that in water with another 

1,000 pounds of lettuce, you can contaminate that 

whole 1,000 pounds. So it's that post-harvest 

processing that can really make a small incident 

into a large one. 

 And so we can't just rely on good 

agricultural practices and say that, you know, if 

they're following their GAAP practices, best 

practices, that there's not going to be any 

contamination. The potential's still going to 

exist.

 And there's other items out there too, 

you know. I'm not familiar with what 

certifications are out there for livestock or 

meat, poultry. I don't, you know, that's not my 

area so I can't speak to that. But GAAPs aren't 

going to solve the problem. They're helpful but 

it's not a failsafe.

 CHAIR BEHAR: Rick.

 MR. GREENWOOD: Yeah, quick question 

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for you. Have you seen any resistance from the 

sanitation agents that you've used? I assume 

you do follow-up cultures? Have you found 

resistance. A lot of people talk about 

resistance, but in fact I wonder if you've ever 

seen it?

 MR. DILL: I have not seen it and I 

don't want to see it. So what we're trying to do 

is be as preventative as possible. I think 

that's a concern and one of those that we don't 

really want to take a chance with. Developing 

some kind of an anti-microbial resistance in any 

pathogen would, I mean that could be devastating.

 MR. GREENWOOD: No, I get that. But 

the question is when you use the sanitizer that's 

that strong, the odds are you probably won't have 

resistance. I think the issue with microbial 

resistance to antibiotics, which I think is what 

people are referring to, is low levels of an 

antibiotic. 

 The sanitizers are high levels, and 

it's very hard for things to live through that. 

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So I just wonder if this is truly a real issue. 

 MR. DILL: I don't have an exact 

answer for you. I haven't done a ton of 

research. We use our sanitizers at as low a 

concentration as we can. We're relying on the 

whole process, so the cleaning, the rinsing and 

the sanitation. 

 We just try to follow best practices, 

and I'll admit I'm not an expert in sanitation. 

I mean I manage food safety and like most of the 

folks in this room that have facilities, we have 

questions, we look to our sanitation reps and 

we're consulting with them. That's kind of what 

we pay them for.

 So I know how we use it and why we use 

it. But when it comes to all the technical 

expertise, those folks aren't here in the room. 

I mean I'm not sure. I know PURE Bioscience has 

some folks here, and they would probably be more 

able to answer specific questions like that. I 

just don't have the time to --

 MR. GREENWOOD: Okay. Well it's just 

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it's been used a lot when we talk about 

sanitizers about resistance, and if used properly 

I don't know, you know. Not many things can get 

away from chlorine. And so I just wonder if it's 

a real issue or something where people are 

thinking about anti-microbial agents like 

antibiotics at low level. Anyhow, that's my 

question. Thank you.

 CHAIR BEHAR: Okay. Thank you, Mike. 

Sorry, Emily.

 MS. OAKLEY: Just a quick one. I just 

wanted to help clarify some of the questions 

about process for this document, which is -- so 

the intent is, you know, to get a technical 

review and we would never come out with like a 

proposal as a direct result of that. It would 

then be a discussion document and potential 

multiple discussion documents to engage 

stakeholders.

 It's also -- I don't think we're 

looking to do a proposal for this. I think we're 

looking for information. I think it's a little 

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bit similar maybe to the process that took place 

with marine materials, because this topic came 

out of many meetings and public comments asking 

for this sanitizer review.

 So it's not something, you know, that 

came from the NOSB directly. It came out of 

public comments. So I do think that, you know, 

in that materials process they came to some 

issues in the 2015 sunset review, did a technical 

review, came out with a discussion document.

 I mean that then led to proposals, 

which I don't think is necessarily the intent of 

this. I just want to clarify that the intent is 

not to get a technical review and then come out 

with proposals to remove materials. 

 MR. DILL: Sure. No, and thank you. 

That's why in our comments, I mean I think we 

submitted 18 pages on this. So if we're going to 

proceed, you know, that's what our comments 

reflect. 

 What we're talking about today is kind 

of more of the, you know, developing a 

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deliberative, step by step process to make sure 

that we have the right people in the room, and we 

give folks the chance they deserve to get the 

information in front of us.

 Sometimes when you have, you know, one 

meeting, you hear something. You don't get to 

comment or the public doesn't see anything until 

the next meeting. Then we have 20 days to try to 

do as much research as we can. So it just, it 

makes it tough. So that's kind of what we were 

focusing on today.

 And then I just if I can, I just have 

one more kind of request, and that is to -- to 

see if we can align more with industry in the way 

that we use certain terms. Like I don't know how 

ancillary ingredients is used in this, in this 

discussion document.

 I look for any reference of ancillary 

ingredients and sanitizers and it doesn't exist. 

So I would just suggest that we stick with terms 

that are used in the industry, such as inerts or 

non-active ingredients, so that we're -- it just 

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makes it a lot easier to understand.

 So and the same with the uniqueness, 

you know. If the intent isn't to have a one of a 

kind material, then we should probably use a term 

other than uniqueness, because if you look at the 

definition for uniqueness it's one of a kind. So 

that's how we came to that conclusion, that the 

intent is to get to one material per use. So 

that's just my request.

 MS. OAKLEY: Yeah. Thanks for those 

clarifications.

 CHAIR BEHAR: Thank you. Mike, I 

think you're up next. Thank you Mike. Mike and 

Mike, Michael, Mike and Michael. Please state 

your name and your affiliation, and next up is 

Rebecca Willows on deck.

 MR. CROTSER: I'm Michael Crotser, the 

certification manager at CROPP Cooperative. 

Thank you for the opportunity to speak today. We 

support the relisting of celery powder on 

205.606. 

 Over 25 percent of the organic meat 

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company sales are products that contain celery 

powder. This includes hot dogs, meat sticks, 

sland yager (phonetic), meat bars, jerky, deli 

ham, summer sausage, pepperoni, bacon and spiral 

hams.

 In 2018, these sales represented $9 

million and over one million pounds of product. 

We are exploring organic celery powder production 

research strategies with Dr. Erin Silva at the 

University of Wisconsin. However, variety, 

selection and production strategies did not 

provide consistent and reliable results.

 CROPP Cooperative is committed to this 

project through continued FAFO funding. Several 

plant species have been identified by Dr. Jeff 

Sindelar at the University of Wisconsin-Madison. 

Potential substitutes include charred yellow 

beets, spinach and other leafy vegetables.

 However, these alternatives have low 

nitrate conversions when compared to celery 

powder. There are no alternatives at this time, 

so we ask that you re-list celery powder to 

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prevent disruption in organic commerce. 

 My second comment is to support 

relisting of fish oil and gelatin on 205.606. 

CROPP Cooperative uses gelatin encapsulated fish 

oil for omega-3 supplemented milk SKUs. In 2018, 

we sold over one million gallons of fortified 

milk, which equates to $7.8 million in sales and 

roughly nine million pounds of farm milk.

 Removal of fish oil would result in 

discontinuation of this product line. When 

researchers polled consumers on what nutrients 

they believe their diets lacked, omega-3 was at 

the top of their response. Voluntary standards 

exist for purity and contaminants. This includes 

Global Organization for EPA and DHA Omega-3, GOED 

and the COAC standard for fish oils. 

 Health Canada is a federal program 

which also establishes legal limits. Our 

supplier participates in the GOED program. Our 

fish oil is the secondary product of fish meal 

production utilizing sustainable fish standards 

that are established by the Marine Stewardship 

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Council of Fisheries, Friends of the Sea and a 

responsible supply of fish meal and fish oil will 

verify that production maintains or improves 

aquatic ecosystems.

 We also support relisting of gelatin. 

Gelatin has a function in the fish oil. It's 

sourced from tilapia skins, from commercial 

harvests. The function of gelatin is to 

encapsulate the fish oil to reduce the fish smell 

and ease the handling of the powder. Thank you 

for your time for me to comment this morning.

 CHAIR BEHAR: Any comments. Lisa?

 MS. DE LIMA: So can you just clarify? 

So when you're purchasing the fish oil that you 

use in the milk, it actually comes through with a 

certification from the MSC, showing that it meets 

-- did you say MSC?

 MR. CROTSER: Yes.

 MS. DE LIMA: Marine Stewardship 

Council. Were you just giving general examples 

of how fish oil can be sourced, or can you 

specifically trace back on the lots that you get 

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that they're certified MSC?

 MR. CROTSER: Yeah. Our supplier is 

certified. I believe it's by the Marine 

Stewardship Council of Fisheries. I think that 

would be in their comments, and we can secure a 

certificate for that to verify. They also have 

additional environmental statements and other 

things that we look at when we choose a supplier.

 CHAIR BEHAR: Any other comments? I 

have a question. I don't know if you have the 

answer. In your -- in the Organic Valley public 

comments you talk about a material called 

Methiomax that is being looked at. I did talk 

with David Bruce. That is some kind of 

methionine enhancer, and I thought sure I know 

the ingredients. 

 I don't know the manufacturing process 

or anything like that and it comes from Belgium, 

I believe. I believe Organic Valley trying to 

see if the FDA will allow it for chicken feed. 

But I'm just wondering if you have any 

information on how much, if that's being fed with 

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the methionine, what type of lowering of 

methionine would we be able to accomplish, or is 

it just to kind of enhance what's already there? 

 I don't understand how the product 

works, but it was in your public comment.

 MR. CROTSER: Yeah. David Bruce put 

that together for the Coop. My understanding of 

that Methiomax, it's an herbal product or a 

plant-based product that increases availability 

of methionine in a feed ration. I don't know 

exactly or specifically how that does, so I don't 

want to misspeak on that. I would suggest that 

connecting with David Bruce on that would be best 

for a proper answer.

 CHAIR BEHAR: Can Organic Valley get 

us some information before we do our vote in the 

fall?

 MR. CROTSER: Yes, we certainly can do 

that for you.

 CHAIR BEHAR: Thank you. Anyone else? 

Okay. Next up is Rebecca Willows, with Johanna 

Mirenda on deck. Hello Rebecca. Please state 

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your name and affiliation.

 MS. WILLOWS: Hi. My name is Rebecca 

Willows, and I'm the senior compliance specialist 

at Organically Grown Company, with over 30 years 

of experience in the organic produce industry. I 

manage organic certificates from over 800 

certified operations, ranging from simple crop 

farms to more complex wholesale distributors, 

grower groups and uncertified handlers.

 I participated on OTA's Global Organic 

Supply Chain Integrity Project, and OGC is now an 

active member of OTA's Organic Fraud Prevention 

Solution Program. We are also an associate 

member of the Accredited Certifiers Association, 

and I participated in many of their working 

groups, including several best practice documents 

and the standardization of certificates.

 I support the NOSB's move to require 

certification for all operations that buy, sell 

or handle organic products. There are many 

instances of handlers who take advantage of the 

exclusion and are buying and selling organic 

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products without regard to transparency, or 

managing documentation that provides a vital link 

from the grower or handling operation to the 

products they sell.

 Without certification of the full 

supply chain, certified handling operations bear 

the burden of performing verification activities, 

who must then trace the documentation back to the 

last certified operation, which can be difficult 

and time-consuming.

 To enhance transparency, I support a 

rule change to require a clear linkage between 

package labeling and the information on the 

certificate and shipping documents. This clear 

correlation would not only dramatically reduce 

the risk for fraud, it would also increase the 

efficiency of the supply chain by decreasing the 

amount of time needed to verify product as it 

moves through the marketplace.

 The rules regarding non-retail 

containers of organic products used to ship or 

store raw or processed agricultural products 

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which may be labeled as containing organic 

ingredients should be changed to require the 

identification of the product as organic, and to 

list the name and contact information of the 

final handler of the product, and include the 

name and contact information of the certifier and 

the final handler.

 I ask the NOSB to support rule changes 

related to product labeling and documentation 

that are detailed in OPWC's written comments. I 

applaud the move to require certifiers to input 

data into the NOPs, since in practice some 

certifiers are not actively updating the NOP OID 

until a complaint is filed.

 The contents of the NOP OID are 

basically unreliable and are mostly not current. 

In addition, the taxonomy of certified products 

does not necessarily correctly identify the 

product. For example, avocado is often listed 

broadly as fruit. 

 I support and have joined the ACA's 

working group focused on creating a consistent 

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taxonomy and urge the NOSB to support a 

conversion, the mandated conversion of the NOP's 

OID to a real time database. Thank you, and I 

welcome your questions if you have any.

 CHAIR BEHAR: Any questions from the 

Board? Thank you, Rebecca. 

 MS. WILLOWS: Thanks.

 CHAIR BEHAR: Thank you for the time. 

Johanna Mirenda is next, with Dean Wesen on deck.

 MS. MIRENDA: Okay. Good morning. I'm 

Johanna Mirenda, the Organic Trade Association's 

Farm Policy Director. So my job is to develop 

policy strategy through producer engagement in 

the interest of our mission and our members. 

Here we are at another NOSB meeting, another 

massive 200 page meeting packet, and another 

wimpy 22 day comment period.

 That's just 16 business days to 

address ten proposals, seven discussion documents 

and 51 sunset materials. In this amount of time, 

it's impossible to carry out an effective comment 

development process. At the trade association, 

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we represent over 9,000 businesses, so we have 

this incredible ability to reach thousands of 

certified organic operators of all sizes and 

scopes across the whole value chain, and collect 

thoughtful and representative feedback on the 

issues before you.

 But with only 22 days, we miss out on 

that valuable opportunity. It's a huge 

disappointment to the public stakeholders and a 

disservice to your hard work of the Subcommittees 

to develop the meeting materials. We urge the 

Board and members of the organic community to 

voice this concern to the USDA.

 Something is fundamentally broken and 

needs to be fixed so that we can make the most of 

the NOSB's work and this important process of 

shaping the organic standards through stakeholder 

input. So on that note, we weren't able to fully 

engage on a couple of the topics such as marine 

materials. We support the Board's ongoing work 

on this topic.

 Seaweeds are widely used and put on 

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organic farms, and there's a lot of information 

and implications to consider. But we ask the 

Board to keep working on this topic, and to keep 

the current discussion document open through to 

the fall meeting, which will give us time to 

establish a member task force, and deeply engage 

and respond to the discussion questions.

 And on the issue of vaccines, due to 

the time constraints we weren't able to endorse 

any one of the specific options. But in general, 

we think all the options are going in the right 

direction, which is to carve out a very narrow --

a very narrow and discrete allowance for the use 

of excluded methods vaccines as in alignment with 

the current regulations.

 And while OTA does not promote the use 

of GMO vaccines, we also see that its 

unacceptable to move forward with any 

recommendations that prohibit the use of vaccines 

from excluded methods when there's no 

alternatives. 

 So we want to thank the Board and the 

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previous Livestock Subcommittee members that have 

put a tremendous amount of work into the topic of 

vaccines over the past decade. We've come a long 

way since the 2009 recommendation, and also 

thanks to the Materials Subcommittee, which has 

done work on excluded methods terminology, which 

has really helped this topic move forward.

 Both the vaccines issue and the marine 

materials issue have brought forward really 

comprehensive discussion documents, and that 

speaks to the importance for an appropriate 

public comment period so that we as stakeholders 

can give it a fair shot and deeply engage with 

that important information. So I'm happy to 

respond to any questions you may have.

 CHAIR BEHAR: Thank you, Johanna. 

Okay. Sue, Steve and Emily. Go ahead, Sue.

 MS. BAIRD: Johanna, you're the Farm 

Policy Director for OTA, so you must have a lot 

of dairy farmers in your membership. So I want 

to ask you a question, and if you'll bear with me 

I want to read the rule. 205.236, Origin of 

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Livestock. We've known for all the years of the 

rules, we've got a problem with A.

 A discusses -- 205.236(a) discusses 

the origin of transitioning or the origin of 

livestock, including the dairy. So we go through 

that. We know we've got this ambiguous, entire 

distinct herd thing, which has caused some 

consternation over time.

 We get that solved and we say oh, take 

a breath. Oh now B. B says the following are 

prohibited. (1) Livestock or edible livestock 

products, I would think that would be milk, that 

are removed from an organic operation and 

subsequently managed on a non-organic operation 

may not be sold, labeled or represented as 

organically produced.

 I thought hmm, that's pretty specific, 

but maybe there's some problems here because I'm 

hearing -- have you heard from your livestock 

dairy operations that we're allowing baby calves 

be born, obviously brought onto the organic farm, 

fed in the hut, whatever, and they take it out 

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and then brought back in? Have you heard that 

from your farmers, because I've heard that here 

and it amazes me.

 MS. MIRENDA: We unfortunately have 

heard that practice. We wholeheartedly disagree 

with that practice and do not believe it's 

compliant with the regulations. 

 To demonstrate our disagreement, we 

galvanized our membership last fall and voiced 

our concern to actually this Board, which 

resulted in a resolution being passed to close 

that loophole and get the final origin of 

livestock rule published.

 We've also communicated directly with 

the USDA on this specific topic and had a number 

of our dairy producer members sign onto a letter 

to publicly demonstrate that they also disagree 

with that practice.

 MS. BAIRD: Thank you. I actually 

took time last night to go into the preamble, 

because sometimes preamble -- well, preamble is 

the intent of the law. 

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 MS. MIRENDA: Yeah, love the preamble.

 MS. BAIRD: I do too. Page five says 

-- of 31 in the preamble says "Should an animal 

be brought into an organic operation pursuant to 

this section and subsequently moved to a nonorganic operation, neither that animal nor any 

products derived from that animal may be sold, 

labeled or represented as organic." 

 So I appreciate you taking a stance 

against it, so I guess I would address NOP, how 

do you perceive this? 

 DR. TUCKER: Okay. First good morning 

everybody. So we agree. We agree there is 

inconsistent implementation of origin of 

livestock. There has been a very unified message 

coming from the community, your unified 

communication to the Department and to the 

program. About this as a priority for the 

community has helped us in moving along this 

rule. 

 And so we are grateful for that 

feedback. Origin of livestock has been an area 

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of contention for many, many years. And so there 

is a proposed rule out from 2015. We hope to 

move as fast as possible, working through a legal 

process to gain clarity on this issue.

 CHAIR BEHAR: Thank you. Steve.

 MR. ELA: Suggestions from you of how 

we can improve the -- I mean we continuously hear 

the short comment period, you know. We get 

caught between the rock and the hard spot of 

having Subcommittees have time to work on things 

and get things to NOP and the reality is it takes 

them a while to vet everything that we send to 

them.

 Do you have thoughts of how we could, 

I mean short of just us having to get materials 

to the program earlier so they can get it out 

earlier, but that means we can work on less? Do 

you have any other ideas?

 MS. MIRENDA: It may be worth looking 

at, you know, after the Subcommittees submit your 

information, what is the time between the program 

or the USDA reviewing it, so that the 

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Subcommittee meeting materials can get out to the 

public. What's happening between, like what's 

happening in that window between when you finish 

your work and we see it on our end?

 From what I've heard, maybe that 

period is too long. Are there possibilities that 

the agency or the program can work with you all 

to make that process a little bit smoother and 

maximize the amount of time that you all have to 

do your work, and that we have to do our work to 

respond.

 DR. TUCKER: So I agree with the 

comments made about we have to give the 

Subcommittee time to work. This is a document 

that has a whole lot of information in it that's 

posted on the USDA website. And so there is a 

process of both us reviewing the documents and 

then explaining internally what these documents 

are, why they are important in getting the 

clearance through.

 I actually think that that process is 

by government standards quite quick, that it 

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takes time to explain what are all of these 

documents? What do they mean? What are the 

implications of them? What is the Board process? 

When we have new people in the review process, 

sometimes that takes a little bit longer to walk 

them through.

 Okay, this is what the Board is, this 

is what the Board does, this is how they proceed 

with their work. We see that actually as a great 

education opportunity, to teach people about the 

Board and the importance of its work. It does 

sometimes add a few days here and there to the 

time line.

 We are doing the best we can to move 

that clearance process through. I think we have 

gotten it as short as we -- as we probably can. 

I just want to be clear on what's possible here. 

But before something goes up on a government 

website, you know, a lot of people need to 

understand what it is, and that's part of the 

process.

 MS. MIRENDA: Fully understood, and 

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thank you for your work on that. We want to make 

sure that this process of the NOSB development of 

materials and the stakeholder feedback is really 

operating to its fullest extent, because we 

defend this process on a daily basis. This is a 

critical part of the organic world that we live 

in, so we want to make sure its functioning to 

its best ability and continuously improving.

 CHAIR BEHAR: Emily.

 MS. OAKLEY: Thank you for your 

comments on marine materials and the suggestion 

to keep the current discussion document on the 

open docket through the summer and into the fall, 

which would hopefully then tie into an expert 

panel. I like the idea, of course, of soliciting 

feedback from your members for a task force.

 I'm wondering if you have any sense of 

what some of those outcomes might be, what some 

of the questions that might be asked and the time 

frame for delivering that information to the NOSB 

on the open docket?

 MS. MIRENDA: Yeah, thank you Emily. 

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So the establishment of a member task force is 

the mechanism by which the trade association 

develops policy positions. We don't operate as 

staff in a vacuum. We really fully engage with 

our membership. So that takes time. We have a 

broad reach.

 In terms of the outcomes, we would 

want to look at the specific discussion questions 

that are being posed, along with some of the 

unanswered questions that we started to touch on 

in our comments last comment period and this one 

again around the feasibility of organic 

certification option, the impacts of a supply 

chain, the other options presented in the 

discussion document and implications of those, 

all under the understanding of this is a 

conversation we want to have.

 We want to move towards more 

sustainable sourcing of inputs, but doing it in a 

thoughtful way. So by keeping the discussion 

document open, we know exactly what we're 

responding to. We've got the questions. We're 

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not, you know, like some of us sitting at our 

computers waiting for the meeting materials to 

post and then rushing to get our membership 

engaged. We'll know exactly what we're 

responding to.

 CHAIR BEHAR: Dave and then Ashley, 

and we are 25 minutes behind right now. So just 

I ask both the Board and the speakers to try to 

have the answers and the questions be succinct. 

Thank you.

 MR. MORTENSEN: Yeah just quickly, and 

it's really more maybe for the Board and the NOP 

folks. It seems to me that one solution to the 

turnaround time would be to push the meeting 

later, and somehow give folks, I don't know. It 

does seem to me that when you think about it, 

you're reviewing things. You're going to ask 

your folks that you work with to engage.

 It seems to me that it's probably more 

like a two month, realistically a two month 

turnaround, not a 20 day one. Like where I work 

at the University, any place at work you give 

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them two or three weeks to review a dissertation. 

That's one person going through a 200 page 

document.

 Here, there's a process of iterative 

feedback from your clientele. It seems to me 

it's a couple of months, I would think, to do due 

diligence. 

 MS. MIRENDA: Yeah. Sixty days would 

be ideal.

 CHAIR BEHAR: Ashley.

 MS. SWAFFAR: Just an easy question 

here. So we heard a lot or a few people talk 

about the concern over the sanitizer discussion 

document. Do you feel that NOSB has existing 

tools in our toolbox to conduct consistent 

reviews of sanitizers, without having to do this 

new project?

 MS. MIRENDA: Yes. I think that what 

we were missing and seeing in the discussion 

document is acknowledgment of those existing 

tools. We were looking for how does this new 

concept fit into the existing framework of OFPA 

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criteria, petition process, technical report 

process. So I think that using the existing 

tools of obtaining technical reports for new 

materials, using your authority to ask for 

additional focus areas in addition to that 

technical report template is a good option.

 Asking for technical reports to 

compare similar materials so that you can 

directly compare, for example, the gums TR from 

last year looked at seven different gums, 

comparing and contrasting specific modes of 

action and other characteristics. 

 Another concern we had with that 

discussion document was the fact that a technical 

report was requested before this concept was 

fully fleshed out. We don't understand how the 

evaluation criteria and the discussion document 

fit into the existing OFPA criteria and NOP 

requirements for review.

 So we need to have more clarity on 

that. I think it will serve the Board better to 

get more clarity on what the goals of the 

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discussion document are, and then go to a 

technical report if needed with a very clear 

scope of work, and it would probably result in a 

better end document. 

 CHAIR BEHAR: Thank you, Johanna. 

Next up is Dean Wesen, with Marie Burcham on 

deck. Please state your name and affiliation. 

All right. You chose a baby chick.

 MR. WESEN: Hello. My name is Dean 

Wesen. I'm a dairy farmer. I live about a hour 

and a half north of here. I drove down here on 

this beautiful day and I don't know why I'm here 

but I'm here anyway. Sue put it very nicely for 

us. She explained why I'm here.

 I'm talking about the origin of 

livestock. Dr. Tucker knows all about it, and 

every time we come to these meetings we hear that 

the NOP is working on it. But it takes time, but 

how much time? They used to say it took money, 

but now I'm under the impression that the NOP has 

a lot more money.

 So last night I was at a track meet. 

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Kids like track because the rules are clear and 

they're out in the open. My son throws a shot 

put. There's a five or six foot circle. You 

stay inside the shot put. You have this 12 pound 

ball. You do whatever you want inside that 

circle, throw the ball. Whoever gets it the 

farthest wins.

 Each kid doesn't get to bring their 

own referee with them. They all have the same 

referee. Everyone follows the same rules. There 

isn't anyone there saying well, my kid weighs 

less so he should get a ten pound ball. My kid 

is not as good or whatever. Everyone plays by 

the same rules. That's why kids love track.

 I appreciate the Board. I saw that 

you guys passed that resolution last meeting. I 

would just like to thank you for that and read 

the last paragraph. 

 "Therefore, be it resolved by 

unanimous vote, the National Organic Standard 

Board at USDA's Federal Advisory Board on Organic 

Issues and representing organic farmers, 

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ranchers, processors, retailers and consumers, 

urge the Secretary to directly issue a final rule 

for the origin of livestock."

 Every month farmers have to try to 

make ends meet, and the longer this drags out, 

we're losing farmers every month. I just wish 

that something could get done. Thank you for 

your time.

 CHAIR BEHAR: Any questions from the 

Board? I have one question. Do you think that 

the calves that you raise on your farm from birth 

and then at six months they go out on pasture as 

their rumens develop, do you think that they are 

healthier cows and more ready to be pasture-based 

than cows that might be raised in confinement on 

grain during that same time period, and then come 

back and have to then learn how to graze?

 MR. WESEN: I think all cows love to 

graze, even the conventional cows that are locked 

in a barn. They look up outside and see the 

grass and they'd love to go out in the grass. I 

think it's bred into them. 

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 But your question of do they do better 

later on in life? I would say yes, as long as 

they don't get worms or any other problems that 

could develop when they are out there at that 

young age. But beef cattle do it all the time.

 But beef, you know, beef is bred 

different than dairy and dairy is -- part of the 

dairy problem is that the animals have been bred 

for generations to stand behind the feed gate and 

stand there and eat and make a lot of milk. So 

it's a little bit of transitioning there.

 CHAIR BEHAR: Thank you. 

 MR. WESEN: Thank you for your time.

 CHAIR BEHAR: Okay. Marie Burcham is 

next. Please state your name and affiliation, 

with Marisol Oviedo on deck.

 MS. BURCHAM: Good morning. I'm Marie 

Burcham.

 (Off-microphone comments.)

 MS. BURCHAM: All right. Sorry about 

that. Can you hear me now? I'm Marie Burcham, 

the Director of Domestic Policy for the 

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Cornucopia Institute. I am also an attorney with 

a background on animal and environmental law. We 

stand by the fact that the organic label isn't 

just about the substitution of inputs. The rules 

and the regulations make that clear.

 But the industry has moved away from 

holistic practice. We urge the NOSB to continue 

the hard work required to uphold organic 

integrity. Organic is about fostering soil 

health, having the livestock outdoors, on land 

managed to improve, not degrade its quality. 

 It's about supporting native 

ecosystems and improving local communities, all 

while providing the food that is both nutritious 

and safe for families. When the organic 

livestock and poultry practices rule was 

discarded, it was clear to many stakeholders that 

the NOP was rubber-stamping industrial poultry 

practices. Confinement-based poultry businesses 

are breaking the current organic rules because on 

a basic level every bird does not have access to 

the outdoors. 

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 The loss of the OLPP signified an 

absolute breakdown of public process. The 

majority of commenters and the public input was 

in favor of some kind of regulation. You've also 

heard from family scale dairies. Cornucopia 

hears from farmers and our members all the time 

echoing these concerns.

 They are losing their farms and their 

homes due to a perceived loophole in the rules. 

When farms are like these are lost, many 

consumers will lose their trust in the organic 

label. If consumers lose all trust in the 

organic label, the organic label is lost.

 Big and small farms will be at risk. 

The difference is the industrial-scale producers 

can go back to conventional marketplace. That 

will not be an option for most family scale 

farms. There is a theme among these problems, a 

lack of consistency in how the rules are applied. 

For many in the industry, there now appear to be 

two organic labels.

 We urge the NOSB to aggressively push 

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for these issues with the NOP. We need 

clarification about the three year land 

transition period. It is disturbing that what is 

apparently clear language in the soil fertility 

and nutrient standard is being muddied.

 We need accredited certifiers to 

enforce current and future rules consistently. 

If we need new rules to provide that consistency, 

then we need them now. We urge the NOSB to act 

to the extent they have authority. Your work and 

recommendations represent the voice of the 

organic stakeholders for the USDA.

 If your efforts are fine tuned to 

support real organic farmers, you can help save 

the organic label. Thank you for your time and 

hard work on all these issues.

 CHAIR BEHAR: Any questions or 

comments from the Board? Thank you, Marie. 

Marisol Oviedo is next, with Kelly Pepper on 

deck.

 MS. OVIEDO: Good morning and thank 

you for the opportunity to comment today. My 

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name is Marisol Oviedo, and I am with the 

Northwest Horticultural Council located in 

Yakima, Washington. The Northwest Horticultural 

Council or NHC represents growers, packers and 

shippers of apples, pears and cherries in Oregon, 

Idaho and Washington, on federal and 

international policy and regulatory issues.

 While the NHC submitted written 

comments on a number of invaluable tools for 

organic tree fruit growers, today I will focus my 

oral comments on the need to allow the continued 

use of hydrogen peroxide, horticultural oils and 

pheromones in the National Organic Program.

 In many ways, the Pacific Northwest is 

the epicenter for organic palm fruit and cherry 

production in the U.S. Washington state is the 

national leader in the production of organic 

apples, pears and cherries. Over 18 million 

boxes of organic apples are now harvested from 

more than 28,000 acres, amounting to over 90 

percent of the entire organic apple crop in the 

U.S. There is also a significant amount of 

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organic pears and cherries.

 Hydrogen peroxide is used in the cropsetting as an effective anti-microbial pesticide 

in orchards to sanitize picking bags, pruning 

shears as well as for plant disease control for 

pathogens like fire blight and powdery mildew. 

It is also used in the packing house setting to 

disinfect belts and brushes for food safety 

purposes. Hydrogen peroxide is used by almost 

all organic tree fruit growers. 

 Horticulture oils are used as part of 

growers' integrated pest management strategies, 

to control mites, pear psylla, leaf hoppers, 

codling moth and apple aphids. These pests cause 

significant damage to tree fruit. 100 percent of 

all organic growers use this product.

 Pheromones are also of great 

importance to organic tree fruit production, used 

for meeting disruption of pests which include 

codling moth and leafrollers. They're essential 

to the control of these pests. Pheromones are 

used by 100 percent of organic tree fruit 

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growers, and loss of this material would be 

catastrophic.

 The NHC also understands that the NOSB 

will be considering a discussion document on 

sanitizers. We emphasize the critical need for 

organic growers, packers and processors to have 

access to multiple effective sanitizers, both now 

and in the future. The number of food-borne 

pathogen outbreaks related to fresh produce has 

increased in recent years, and crosscontamination of produce from food contact 

surfaces has often been identified as a primary 

contributor.

 Access to effective sanitizers is 

vital to preventing food-borne pathogens from 

becoming established in packing houses. The 

ability to rotate sanitizers as well as to use 

different sanitizers on orchard tools versus 

packing house food contact surfaces is necessary 

to prevent developing resistance.

 In addition, with the implementation 

of FSMA that are now in effect, growers, packers 

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and processors are required by law to adequately 

sanitize food contact surfaces. On behalf of the 

growers and packers we represent, the NHC 

strongly supports the continued use of these 

vital tools for insect control. Thank you.

 CHAIR BEHAR: Steve.

 MR. ELA: With regard to pheromones, 

I know the interpretation has been generally that 

like can applied misters, but sprayable 

formulations are not allowed. But we don't have 

that annotated per se. Do you know of any 

growers using sprayable formulations that would 

actually contact the fruit and its pheromones?

 MS. OVIEDO: I don't know of any. I 

know that we use a lot of the twisty ties so --

 MR. ELA: Yes, which would be noncontact.

 MS. OVIEDO: Right.

 MR. ELA: Do you think there's any 

issue with us needing to annotate that or is it 

-- does the system work fine?

 MS. OVIEDO: That is something that we 

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would probably have to vet through our 

stakeholders so --

 CHAIR BEHAR: Any other questions? 

Thank you, Marisol. 

 MS. OVIEDO: All right, thank you. 

Thank you for the chicken.

 CHAIR BEHAR: Next up is Kelly Pepper 

with Alexander Strauch, DVM on deck.

 MR. PEPPER: I am Kelly Pepper with 

Texas Organic Cotton Marketing Coop of Lubbock, 

Texas. Our members have historically produced a 

large majority of the organic cotton grown in the 

U.S. I'm here today on behalf of these farmers 

to urge you to renew the inclusion of hydrogen 

chloride for delinting cotton planting seed on 

the National List. 

 In respect for your time I will not 

repeat many of the details in the written 

comments. In light of the major issues that are 

being discussed at this meeting, which are 

drastically affecting so many organic farmers, I 

feel apologetic taking time on an issue that 

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involves so few. However, an inability to plant 

seed delinted with hydrogen chloride would have 

similar devastating results for our farmers.

 I will summarize our comment on 

hydrogen peroxide and then briefly address some 

seed issues. At the last sunset of this product, 

we were hopeful that a mechanical delinting 

process that was under development might be in 

commercial use by now.

 Unfortunately, this has not happened 

and we have detailed the current status of that 

research in our written comments. So what 

remains essential for the cotton industry in the 

U.S. I am so sorry. Can we proceed from where I 

was?

 CHAIR BEHAR: Okay. Please speak into 

the mic. Like lift it up if you talk -- yeah, 

much better. Thank you.

 MR. PEPPER: I'm sorry. At the last 

sunset of this product, we were hopeful that a 

mechanical delinting process that was under 

development might be in commercial use by now. 

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Unfortunately, this has not happened and we've 

detailed the current status of that research in 

our written comments.

 So it remains essential for the 

organic cotton industry in the U.S. that hydrogen 

chloride continue to be allowed for delinting 

cotton planting seed until an approved, 

alternative process is perfected and in use by 

seed companies.

 In my opinion, one of the reasons that 

an alternative to acid delinting of cotton 

planting seed for organic production has not 

become available is the fact that the acreage of 

organic cotton is so limited. There's just not 

enough volume to make it worthwhile for seed 

companies to pursue.

 In a similar vein, I'm concerned that 

this volume issue has potential parallels in the 

strengthening the organic seed guidance proposal 

and in the genetic integrity transparency of seed 

discussion document. While we agree that both 

are addressing important issues, our farmers and 

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perhaps growers of some other small acreage crops 

are dealing with very fragile seed supplies. We 

would ask that this be kept in mind as these 

proposals move forward.

 Regarding GMO testing of planting 

seed, let me say that GMO contamination is a huge 

issue for us, and I appreciate the Board tackling 

with very difficult issue. In the cotton world, 

seed breeders struggle to keep GMO contamination 

under two percent in their breeding programs. 

 So it's only natural that commercial 

non-GMO varieties often have even higher levels. 

I would note that in my understanding from 

conversations within biologic personnel, that the 

fairly economical and detailed testing methods 

that are available for corn are not available for 

cotton at this time.

 In closing, I want to thank you for 

the sacrifices in your personal and business 

lives that serving on this Board entails.

 CHAIR BEHAR: Any comments from the 

Board? I want to thank you. I visited, I 

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believe, your family's farm outside of Lubbock, 

at IOIA organic cotton training.

 MR. PEPPER: Well, I'm sure your 

connection with my sister-in-law --

 CHAIR BEHAR: Yes, LaRhea, yes. So 

thank you and growing cotton is a very unique 

crop.

 MR. PEPPER: Thank you.

 CHAIR BEHAR: Okay. Next up is Dean 

Wesen -- I'm sorry. Alexander Strauch and then 

Bjarne Pedersen is on deck. I'm sure I messed 

that one up.

 DR. STRAUCH: I have a PowerPoint. 

Wonderful, thank you. 

 (Pause.)

 DR. STRAUCH: All right. I will be 

assisted by your technical team. Thanks for 

letting me stall. Good morning everybody. My 

name is Dr. Alex Strauch. I am a poultry 

veterinarian from Michigan and I'm trying to 

impart some Midwestern friendliness to Seattle, 

but it's really hard to break through. I'm 

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outside.

 I'm here to speak to you today 

regarding methionine supplementation in 

organically raised laying hens. Please proceed. 

I don't want to take up too much of your time 

with my bio, so I'll be brief. I'm a licensed 

veterinary doctor. I work in Michigan and 

Indiana, and I am a city kid originally from 

Metro Detroit. 

 I did not grow up next to birds, hogs, 

pigs or horses, but I consciously spent 11 years 

researching, studying and working in the 

agricultural sector due to my conscious effort to 

enter agriculture and have a voice in the food 

system and animal welfare.

 My bachelor's degree is in Zoology and 

my Veterinary Medicine degree is in -- was 

concentrated in agriculture. I hope this gives 

me a balance view of the big picture that we try 

to work within. 

 To use some choice words here, I am 

not brainwashed or desensitized to livestock 

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practices that have been used over generations, 

and we have an opportunity here to ensure animal 

health, animal welfare, food safety and 

environmental stewardship through this meeting. 

Again, thank you.

 The Methionine Task Force yesterday 

did a great job laying down this framework, so I 

won't take too much time again. But the due 

diligence is methionine is not only an amino 

acid, a building block for a protein, it is an 

essential amino acid and in addition it is the 

limiting essential amino acid for poultry. This 

is species-specific for poultry.

 What that means in short is this is a 

rate-limiting factor for normal biological 

functions, as in we cannot pass go and collect 

200 if we do not have enough methionine for these 

birds to function.

 Proceed. This ties into -- oh, I've 

got to hurry up -- the negative impacts of 

intentional or unintentional methionine 

deficiency as listed yesterday are retardation of 

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growth, a hindered immune system, agitation, 

which leads to pecking, feather-eating, feather 

loss, cannibalism, which is very much tied into 

stress and pain.

 We can proceed to the next slide. 

Decreased ag production and retardation of growth 

then in turn become an environmentally hostile 

practice. I aim to look at this problem or 

opportunity as holistically as possible. With a 

less efficient bird, we then consume more 

resources to produce less eggs. This 

irresponsible utilization of resources will 

result in a higher environmental footprint. 

 Proceed. I welcome, the U.S. should 

welcome and the Board should welcome advances in 

these alternative methionine supplies to support 

our organic market. I'm excited to hear our talk 

about them yesterday, today and in the future. 

We should also look at genetic selection for 

laying hen breeds that will require less 

methionine through traditional breeding 

practices. 

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 As it states today, currently we do 

not have a commercially available alternative. 

Thus, please allow me to keep supplying my hens 

with the necessary essential limiting amino acid 

that they need. Thank you guys.

 CHAIR BEHAR: Thank you. Any 

comments, questions from the Board? Ashley, I'm 

looking over at you.

 DR. STRAUCH: Hi.

 MS. SWAFFAR: Hi. Yeah, so one of the 

alternatives that we've heard a little bit about 

is fish products. Can you talk a little bit 

about using those in your diets and maybe some 

issues or what you see with using fish products?

 DR. STRAUCH: Understood. The 

question was fish meal as an alternative for 

methionine supplementation instead of synthetic 

DL methionine. Fish meal, other than not 

currently being allowed through no animal 

byproduct regulations, has some cons that I can 

think of right off the top of my head. 

 One, it's very short shelf life. Two, 

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that gives me a salmonella risk, which would have 

to be dealt with through internal measures. It 

is dealt with through internal measures at other 

operations but that is additional risk and three, 

it has a very unintended consequence of making 

your egg product fishy, which is a problem for 

those who do not like fish. Sir.

 CHAIR BEHAR: I believe Scott's next, 

then Dave and Sue.

 MR. RICE: Hi. Your last bullet there 

talks about selecting for breeds that require 

less methionine, but I believe in the 

presentation yesterday, Dr. Burley had said that 

there were no breeds. Are you talking about 

future development and looking for how that can 

happen?

 DR. STRAUCH: Yes sir, we're on the 

same page. That would be looking towards the 

future, which I would welcome with open arms. 

The current, how do I say, turnover time for 

genetic selection at the major genetics 

companies, and then effects seen at market level, 

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which would be me, is about four years is the 

rule of thumb when we have major characteristic 

changes done on a genotypical level before we see 

them phenotypically. So patience is a virtue.

 CHAIR BEHAR: Dave. Oops, I'm sorry. 

Dave.

 MR. MORTENSEN: Alexander, you said 

that you take a holistic approach to the problem. 

I was curious about how the size of flocks that 

are being managed constrains the holistic 

solution set of management, or does it?

 DR. STRAUCH: Understood. This sounds 

similar to the discussion that was done 

yesterday. Yeah, okay. With the -- the question 

was regarding size of operations and whether that 

impacts the holistic management of organic 

flocks, as it specifically relates to methionine 

supplementation. Okay, thank you.

 So pros and cons is the short answer. 

The cons of having smaller flocks that are 

pasture-raised to have this .42 percent access to 

insects and worms and possibly a frog here and 

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there, are that you then have higher parasite 

load. I really value the ability of choice, and 

as I see time and time again, I actually have 

managed a couple of million birds at this point, 

and provided them veterinary care.

 When given the choice, the bird 

chooses to possibly poke its head outside and 

then return inside. The ancestor of the 

commercial chicken today was the red jungle fowl 

out of Africa. This is a jungle-dwelling 

organism that thrives with canopy cover and not 

direct sunlight. 

 The birds are curious, and mental 

stimulation is important. But I see time and 

time again birds look outside, turn around and 

then go back in. Maybe it's a sense of security, 

but the access to pasture and the smaller 

operations is not the one-size-fits-all or silver 

bullet. 

 CHAIR BEHAR: Sue. 

 MR. MORTENSEN: Thanks.

 MS. BAIRD: We know that chickens are 

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dinosaurs. Therefore are --

 DR. STRAUCH: They're velociraptors, 

yes.

 MS. BAIRD: Yes absolutely, yes. So 

explain to those who don't know what is the 

source of natural methionine that would make it 

to be limiting, and why do we need a synthetic 

methionine?

 DR. STRAUCH: Great age-old question. 

Yes, the chicken is a modern hand-held 

velociraptor, you're absolutely correct. These 

chickens that we have are what I consider Olympic 

athletes, and as such, we do not give Olympic 

athletes the same supplementation or food or diet 

that we give to my Uncle Rick who's in a 

recreational bowling league.

 He requires a very different diet to 

prosper and thrive than does the, you know, 

Jamaican 100 meter dashers. We have gotten so 

precise and so scientific with the best way to 

most efficiently nutritionally support these 

animals that we are giving them the Olympic 

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treatment when it comes to their diet, and not 

the backyard barbeque that fuels every bowling 

league that I know. Yes ma'am.

 (Laughter.)

 CHAIR BEHAR: Go ahead, Sue.

 MS. BAIRD: I suppose the point I was 

hoping you would make is that methionine comes 

from meat and bone meal, and they are required 

because they are dinosaurs to eat meat. They're 

omnivores. I just wanted to make that point. 

And so if we can't give them meat and bone, then 

we have to find methionine from some other 

source. Is that correct?

 DR. STRAUCH: Yes. So if given the 

opportunity, a chicken is omnivorous, so they are 

opportunistic omnivores, if I can say that. The 

pros and cons of then giving them the options for 

bug or insect supplementation or meat and bone 

meal supplementation is in the basis of food 

safety.

 I can have a more confident view of my 

feed inputs if I leave out wild bugs. Wild bugs 

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or how do I say, yeah or black soldier fly 

larvae, which is talked about here and there. 

That is regards to salmonella, E. coli, 

campylobacter and listera monocytogenes. Those 

are my risk factors that again, pros and cons 

seems to be the common theme to my responses.

 CHAIR BEHAR: Okay. I have one quick 

question.

 DR. STRAUCH: Yes.

 CHAIR BEHAR: I think one of the 

reasons that methionine each time brings up a lot 

of comment is that it is a synthetic, and we 

would prefer that humans and animals would be 

getting most of their nutrition from the 

agricultural products that they are consuming. 

 So I'm just wondering if you know 

anything about Methiomax and that herbal 

supplement that would at least lessen, as I 

understand it, the need for the synthetic. It 

wouldn't get rid of it, but it would enhance the 

absorption I believe.

 Now again, I don't know as much as 

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what I'm trying to hear, but on the Internet it 

did show that it's even consumed by humans in 

like muscle-building drinks and that sort of 

thing. I'm familiar with all three of the herbs. 

They're all typically consumed by humans or used. 

So do you know anything about that product?

 DR. STRAUCH: Great. Thank you for 

mentioning it yesterday as it piqued my interest, 

and between yesterday and today I've been able to 

do a limited amount of Googling regarding this 

product, and that constitutes the basis of my 

knowledge of Methiomax. Regarding Methiomax --

 CHAIR BEHAR: Mine too.

 DR. STRAUCH: Yes. Other than the 

online forums of people who I can't pronounce 

their names, some are over in the Far East, I 

cannot find the same structured peer reviewed 

journal articles that I would hold similar 

supplements to currently available, due to my 

limited Googling yesterday. I am a very openminded person. 

 I will pursue Methiomax for research 

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purposes internally when I go ahead and manage 

flocks in the future. But then I need to also 

think about commercial availability and that is 

my next follow-up question and homework to do 

over this next year, is Methiomax commercially 

available and is it a legitimate product.

 CHAIR BEHAR: Well, I believe Organic 

Value is working with FDA to try to get it 

approved, and any information that you find out 

about it, we would really love to hear about it.

 DR. STRAUCH: Yep, independent review. 

I will definitely share with anyone that would 

like to hear it. 

 CHAIR BEHAR: Okay. Thank you very 

much.

 DR. STRAUCH: Asa?

 CHAIR BEHAR: Asa's got a question.

 DR. STRAUCH: Oh sorry.

 MR. BRADMAN: I just want to 

understand the differences between European 

organic standards and U.S., and how they're 

dealing with DL methionine, and whether that 

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there's any information that are applicable here. 

 DR. STRAUCH: Okay. Thank you for the 

question. For the rest of the room, he would 

like to know how Europe is dealing with DLmethionine supplementation compared to how we are 

dealing with it. 

 I am licensed in the United States. 

There were some background documents before this 

meeting that came out regarding how Europe deals 

with that. So I will defer the answering to 

somebody who knows the answer that's possibly on 

the Board.

 CHAIR BEHAR: Okay, thank you. All 

right. We're going to move on to the next 

person.

 DR. STRAUCH: I'm sorry. I don't know 

how Europe deals with it.

 CHAIR BEHAR: Yeah. Okay, thank you 

Alex. Next up is -- all right I'm going to say 

Bjarne Pedersen, or do you say the B?

 MR. PEDERSEN: Yeah. It's Bjarne 

Pedersen. 

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 CHAIR BEHAR: All right. Well, I 

really got that one wrong.

 MR. PEDERSEN: It's a Danish name.

 CHAIR BEHAR: Thank you, and then up 

on deck is Jay Kurtz.

 MR. PEDERSEN: Right, thank you. I'm 

Bjarne Pedersen, and I'm going to comment on 

paper pots. I'm a consultant working for the 

Danish company Ellepot, selling a paper pot 

system. Ellepot is testing the materials and the 

paper and I'm pleased to share some of the 

results. I also shared some of them in the 

written comment.

 We're testing fibers and paper 

degradation. The first samples here are testing 

plastic fiber and wood fibers to compare them as 

a sample of polyester, which is used in many 

hygiene products and also in some papers. I 

compare it to cellulose, and as you can see even 

after eight days I have some discoloration on the 

cellulose.

 After 35 days, the cellulose is almost 

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completely gone, and as expected nothing has 

happened to the polyester and looking in a 

microscope, I couldn't even find any fungus 

hyphae or anything else growing on it. I also 

looked up some research on soil burial testing 

comparing cellulose and some bioplastics, in this 

case PLA, and after 200 days the PLA, which is 

the blue square on the bottom is the same and the 

cellulose on the top is almost gone.

 And then I'll show you a few results 

from some papers that I've been testing. The 

first one is a coffee filter that I took from the 

company canteen. After 35 days, it's actually 

completely gone. I could find a few things in 

the microscope after 30 days.

 Secondly, Ellepot developed a paper 

which is approved for organic in the United 

Kingdom and in Denmark, and after 35 days most of 

it is gone. Finally, I also took newspaper, the 

local newspaper in the canteen and I must say 

much to my surprise almost nothing happened 

during the period of 35 days. 

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 I'm going to look into that a little 

more. What I've learned so far from one of the 

paper mills that I'm working with is that the 

newspapers are challenged financially and one way 

of lowering the cost is lowering the number of 

cellulose fibers, because it's an expensive 

product, and they can add in more glue and some 

coating to make it printable.

 This probably causes this well, bad 

degradation. I hope papers over here are doing 

better. Anyway, we're testing a lot on materials 

on degradation because Ellepot wants to make sure 

that the product does go away when left in the 

soil. So that concludes my comments and I'm open 

for any questions.

 CHAIR BEHAR: Steve, Emily.

 MR. ELA: Would you -- so as we're 

talking about synthetic materials and paper 

production aids, let's say, my understanding is 

you're moving to rayon, which is a cellulosebased product versus -- I mean Rand's probably 

classified it as a synthetic because of the 

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chemical process. 

 But that's going to be behave 

differently in the soil from what you've seen 

than say a polyester, some other plastic fiber, 

other synthetic fiber?

 MR. PEDERSEN: Yeah. I compared the 

three main types of cellulose fibers, the 

standard cellulose from some wood and then the 

two modified ones, rayon as you mentioned and 

also the lyocell fibers. These three seem to 

degrade almost simultaneously. The variation is 

too insignificant. 

 So within one or two months, it will 

have degraded completely, depending on 

conditions. The soil burial test probably has a 

very lower level of oxygen present that will 

prolong this time of degradation. But compared 

to plastic fibers like polyester, I mean the 

plastic will stay there for I don't know how 

long.

 And also we've been looking a lot into 

bioplastic fibers, because some of them 

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certifiable as composable. But we've learned 

over the years that for instance PLA, that's why 

I took it up here, it doesn't work in soil. 

We've had products buried for seven to ten years 

and nothing really happened.

 I know that Ellepot really have a hard 

time recommending it for growth, using it for 

plant out because it's going to stay there, and 

Ellepot doesn't really want to leave that impact.

 MR. ELA: So if -- I mean we're 

struggling with synthetic fiber content in a 

paper pot. Would there -- would you be able to 

give us any guidance on what percent of synthetic 

fibers? I mean I'm hearing if it's rayon, we 

really need no other synthetic plastic fibers in 

a product to make it useable. 

 Do you think we should -- as the 

Subcommittee struggles with how much to allow in 

a paper product what -- do you have a percentage 

of fibers that would maybe across the industry 

might keep a pot, make a pot useful but also let 

it break down, or can you give any insight on 

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that?

 MR. PEDERSEN: Well, I think I kind of 

wish to look at it a little differently, because 

at Ellepot, they try to work with sort of the 

paper materials and the plastic materials as two 

groups of materials, and the paper materials 

could be any kind of plant fiber. Even the 

modified rayon and lyocell fibers because they 

are degrading in the same manner as the cellulose 

fiber.

 On the plastic side, that doesn't 

really matter that it's oil-based or bio-based. 

It's a different matter, and they really don't 

want to put that into the paper that is going to 

be used, especially in the organic sector but 

also many other sectors because it's going to 

stay there for maybe a thousand years, I don't 

know.

 I know that the lyocell and the rayon 

would be considered synthetic. But still their 

way of acting when they're put in soil is similar 

to the cellulose fiber, and that is the view of 

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Ellepot, that they consider that to be the same. 

The percentages of this is somehow also used to 

design the product's life span for the user.

 Right now, without anything else in 

it, 35 days this organic grade that I showed you, 

is too short. For many growers, the paper need 

to sustain a certain strength for handling at 

plant out situation, and most cultures are not 

ready within 15 to 20 days. 

 So we are really looking for solutions 

to prolong the life for at least two to three 

months. Then most of the young plant cultures 

would be stepped up or planted out into the 

field.

 CHAIR BEHAR: Emily.

 MS. OAKLEY: Thank you. This was 

really helpful and informative, and I was 

wondering if the newspaper that you showed from 

your coffee break room trial was a glossy 

newspaper or a non-glossy newspapers, and 

depending upon your answer I'll have to follow 

up. 

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 MR. PEDERSEN: It was a non-glossy, 

and that is also why it quite surprised me that I 

didn't really see -- I saw some -- on one of the 

samples I had two vials going. One of the 

samples I saw some fungus trying to a foot in, 

but after a week or so it sort of stopped. 

 I'm actually over here collecting a 

few newspapers to bring home, just to see, 

testing more newspapers just to learn are there 

differences in the market and why are the 

differences together with the paper supplies.

 They are making the analysis of the 

products to understand what is in them, and we 

can learn how do they degrade. I guess for this 

local one I wouldn't recommend anyone wrapping 

their fish and chips in it, certainly not.

 MS. OAKLEY: So yeah, just to follow 

up. I find that very interesting, and I think as 

we struggle in the CS, we're certainly not 

wanting to create an annotation for paper as a 

planting aid. That would be more strict than the 

current annotation that we have right now. 

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 But our supplemental TR for 

newspapers, while thorough in many areas, can't 

be totally comprehensive, and I think this photo 

that you show demonstrates some of the complexity 

of this issue and knowing what's already allowed 

in terms of synthetic fibers and adhesives, and 

how that may compare with a product or a material 

that could be used as a planting aid.

 CHAIR BEHAR: I have just a quick 

question. Have you tried either hemp or flax 

linen as natural fibers? Those do tend to break 

down more slowly in the development of your pots 

along with the cellulose?

 MR. PEDERSEN: We have. We had this 

first test that I showed you part of here was 

quite huge in range. I'm sorry I'm not able to 

disclose all of the things. I have some nondisclosure agreements with some of the suppliers. 

But yes, we have tested several fibers and we're 

bringing in more products to test, because 

designing new papers for the future is viable for 

Ellepot as the new single use directive in Europe 

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rules out plastics.

 Being bio-based or oil-based doesn't 

really matter, and paper pots being single use 

products maybe are first in line for the 

directive to date. But it is coming, and they 

need to find solutions to rid out all the plastic 

contents. 

 CHAIR BEHAR: Thank you. Thank you 

very much.

 MR. PEDERSEN: You're welcome.

 CHAIR BEHAR: Okay. Next up is Jay 

Kurtz with Harry Rice on deck. Jay, your name 

and affiliation please?

 MR. KURTZ: Good morning. My name is 

Jay Kurtz, and I'm speaking today on behalf of 

Devro. Devro is a maker of collagen gels for the 

food industry, primarily used as the skin in the 

making of sausages. I do appreciate the 

opportunity to speak in today's session, to 

follow our petition through the entire process.

 I'd like to thank the Board and the 

Handling Subcommittee for consideration of 

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Devro's petition, to include collagen gel on 

205.606. We appreciate the level of research and 

discussion put forth by this group, resulting in 

a fair and accurate overview of collagen gel.

 Today in the United States, 

approximately 50 percent of the fully cooked 

sausage category has transitioned from 

traditional intestine casing and cellulose casing 

in favor of collagen gel. The food safety of the 

sausages made using collagen gel as the casing is 

unparalleled, and the quality of the products is 

of the highest standard.

 As the market continues to evolve, the 

ability to meet consumer demands for skin on 

organic sausages is limited to intestine casings, 

which is a significant barrier to organic growth. 

If the Board accepts the Subcommittee's 

recommendation to add collagen gel to 205.606, it 

is our hope that the ability for organic products 

will be more available for consumers, shifting 

toward the now widely-accepted co-extruded 

sausages. 

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 I'm aware that there were questions 

raised by Board member Asa Bradman to Jim Paskind 

of Salm Partners in the recent webinar on April 

the 18th, in relation to adequate supply of raw 

material to make an organic gel. Currently due 

to the absence of an identify preservation system 

in place and the low population of organic 

options that meet required specification, there 

is not a position to take presently to make 

organic collagen co-extrusion gels.

 As the availability of potentially 

organic skins grow, the ability to make a gel 

from organic-sourced skins should grow as well. 

At this time, growth assumptions enabling a 

market large enough to make a certified organic 

gel are unknown and premature, but growth in this 

category could certainly be a leading indicator.

 However, I do want to point out it is 

important to reiterate that it's not merely the 

critical mass that we need to exist; it's the 

right mass that can meet the right specification 

to make a functional gel. Thank you for your 

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time this morning and for consideration of this 

amended petition.

 CHAIR BEHAR: Any questions from the 

Board?

 MR. BRADMAN: Yes.

 CHAIR BEHAR: Okay, Asa.

 MR. BRADMAN: I just want to follow up 

on your comments and just kind of put this in the 

context of larger discussions in the organic 

community and on the Board related to 606, you 

know. And of course there's the requirement in 

606 to source organic materials if they're 

available, and the long term goal and hopefully 

not so long for many materials on that is that 

ultimately there can be an organic source.

 I think it would be, you know, I 

understand the limitations you describe in terms 

of availability. But it would also be I think 

important to consider the future in how to 

actively develop that source. 

 So there may be a business opportunity 

there as well. If you heard the discussions 

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around celery powder yesterday, similar issues 

there, and a commitment to find organic materials 

down the road would be valuable.

 MR. KURTZ: And I think our -- the 

answer to that would be a yes, you know. We're 

rookies to this process. We started about two, 

two and a half years ago. But that in our 

opinion would be the next step in the process, is 

having that identity preservation and having that 

critical mass. 

 So I guess you could say it's the 

classic chicken or the egg scenario. Is there 

going to be the market demand? Is there going to 

be that critical mass? We don't know yet, but 

that would be for us to identify as we go down 

the weeks, the months, the years and say okay, 

can we get the value chain to preserve these 

skins in the right fashion, to have them organic 

all the way through?

 CHAIR BEHAR: Steve.

 MR. BRADMAN: Thank you. Just one 

general comment or response. The egg came first. 

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 MR. KURTZ: I'll make note of that.

 (Laughter.)

 CHAIR BEHAR: Steve has a question.

 MR. ELA: I guess the question followup on Asa's, I mean one of our wonderments I mean 

obviously yes, it is an egg and then a chicken. 

But how -- if we approve this material, will that 

actually inhibit, I mean because there won't be 

as much incentive out of -- I guess I can say for 

lack of a better word desperation for a product. 

There won't be as much incentive to develop that 

organic product line.

 So how can we ensure that what you 

just said, you know, if we approve it it provides 

the bridge, so to speak, to an organic product or 

an intervening time period. But we don't want to 

delay the development of that organic product 

either.

 MR. KURTZ: I think that's a fair 

question, and I think the answer to that is what 

we have learned in working with our customers, 

they do believe in transparency to the consumers 

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and their customers. So is this an in-perpetuity 

listing? We certainly would not hope so. We 

believe that our customers would take this and 

use it as hopefully a stop gap to a better end 

game of an organic gel that would be certified 

organic, and to be not on 205.606 in perpetuity 

or to before the sunset reviews per se.

 CHAIR BEHAR: Thank you.

 MR. KURTZ: Thank you.

 CHAIR BEHAR: Next up is Harry Rice 

with Gwendolyn Wyard on deck.

 MR. RICE: Hello. My name is Harry 

Rice and I am with a Global Organization for EPA 

and DHA Omega-3s, which represents the worldwide 

industry for EPA and DHA, the primary long chain 

omega-3s found in fish oil. Our membership is 

built on a quality standard unparalleled in the 

market, and our mission is to increase 

consumption of EPA and DHA, and to ensure that 

our members produce quality products that 

consumers can trust.

 GOED understands you will be 

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discussing fish oil as part of the 2021 sunset 

review, so I'm here to address the relisting of 

fish oil on the National List. As mentioned in 

our written comments, GOED continues to support 

the inclusion of fish oil on the list of nonorganically produced agriculture products allowed 

as ingredients in or on processed products 

labeled as organic. 

 Consumers who prefers organic products 

should have access to products made with nonorganically produced fish oil, since organic fish 

oil does not currently exist and won't exist 

until such time that the National Organic Program 

adopts program standards for aquaculture. 

 With respect to sustainability, which 

historically seems to be one of the most 

contentious issues regarding the inclusion of 

fish oil on the National List, GOED believes that 

protecting our oceans and natural resources is 

paramount. It is not only good environmental 

stewardship, but also ensures sustainable growth 

for the omega-3 industry as a whole. 

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 Fortunately, most of the fisheries 

from which fish oils are sourced have either been 

certified or are currently pursuing certification 

for sustainability. While GOED supports 

sustainable fishing practices, it's important to 

note there's no fish species in the world that is 

caught primarily for fish oil production.

 Fish oil is always a value-added 

byproduct of fish meal or seafood production, 

because the protein's value is much greater than 

that of the oil. With respect to the 2015 fish 

oil technical report being relied upon by the 

Handling Subcommittee, GOED provided extensive 

written comments on what we view as incorrect or 

misleading information.

 Due to time constraints, I refer you 

to GOED's written comments for those specifics. 

But I can't reiterate enough GOED's concern about 

the quality of the technical report. With 

respect to the annotation for fish oil, the 

Handling Subcommittee has asked how the fish oil 

annotation can be modified to control for the 

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noted conservation concerns.

 In its written comments, GOED 

suggested the following addition to the present 

annotation. "From fish originating from 

fisheries that are not classified as overexploited according to FAO guidelines," it has 

been brought to GOED's attention that its 

suggestion left a potential loophole, which I 

assure you was not purposeful and I would like to 

correct the recommendation. 

 In addition to fish not originating 

from over-exploited fisheries, fish should not 

originate from depleted or recovering fisheries. 

Since GOED submitted its written comments and 

other suggestions, I have discussed with a GOED 

member who sells fish oil for use in products 

labeled organic, is the addition of the following 

to the annotation:

 "Fish oil must be sourced as an 

industry byproduct and not as the result of 

direct fishing. Where regulatory definitions of 

byproduct and direct fishing are not known to 

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GOED, we would consider a fishing byproduct to be 

an incidental or secondary product made from 

processing fish and fish products.

 "In addition, we would consider direct 

fishing to be the activities leading to and 

resulting in the capture and harvesting of wild 

fish." In conclusion, GOED encourages the NOSB 

to retain fish oil on the National List. 

 Please do not ever hesitate to contact 

GOED with any questions related to fish oil or 

any other EPA/DHA product. We're always happy to 

share our knowledge and experience. Thank you 

for your time.

 CHAIR BEHAR: Thank you. Any 

questions from the Board? Tom.

 MR. CHAPMAN: So oftentimes we 

struggle to get answers to get answers to our 

questions, so thank you for answering the 

questions that we posed. I really appreciate 

that. If you could also send those 

recommendations in writing potentially to 

Michelle, that would also be helpful, about the 

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wording.

 MR. RICE: Yeah, absolutely.

 MR. CHAPMAN: Do you have a sense --

now to my question. Do you have a sense of or 

are you able to speak to what percent of the fish 

oil industry are GOED members or that comply with 

GOED voluntary monograph?

 MR. RICE: Yeah. We've estimated this 

to be between 85 percent and 90 percent. We have 

170 members throughout the supply chain, and so 

that's our estimate at this time.

 MR. CHAPMAN: Thank you.

 CHAIR BEHAR: Asa. That's it? 

 MR. BRADMAN: Tom covered it.

 CHAIR BEHAR: Tom covered it. Okay, 

thank you. Thank you, very much Harry.

 CHAIR BEHAR: Okay. Next up is 

Gwendolyn Wyard with Megan DeBates on deck. I 

hope you took an animal. 

 MS. WYARD: All right, good morning. 

My name is Gwendolyn Wyard. I'm the Vice 

President of Regulatory and Technical Affairs for 

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the Organic Trade Association, and I'm sporting 

squid. Today I'll be highlighting some top line 

messages from our comments on three agenda 

topics.

 The first one is pullulan. The 

Organic Trade Association is the petitioner of 

pullulan, and it should be noted that we rarely 

petition materials, and in the rare instances 

that we have, it's been to further restrict or 

remove materials from the National List.

 In this case, although our petition is 

to add a material to the National List it really 

should be viewed as a move to further restrict 

its use because pullulan has been allowed and 

made with products in that 30 percent non-organic 

portion for many years.

 A full board recommendation to add 

pullulan to the National List is our preference 

because it will codify and restrict its allowance 

to the made with category only for encapsulated 

supplement products, and it will bring it under 

your review every five years via the sunset 

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process. 

 Meanwhile any other product, any USDA 

organic product will require the use of certified 

organic pullulan, which is unavailable at this 

time but development is well underway, and we're 

strongly advocating for organic pullulan.

 Number two, genetic integrity 

transparency of seed grown on organic land. 

Respectfully, this proposal needs more work, 

perhaps starting with the title of the document. 

We agree with the comments of Kiki Hubbard, and 

our Organic Seed Task Force has been working 

collaboratively with the Organic Seed Alliance on 

this topic as well as on the organic seed 

guidance proposal that we think should be passed 

at this meeting.

 On seed purity, we've long advocated 

for first identifying the problem before 

developing the solution. We called for the 

formation of a USDA-appointed Seed Task Force, 

and we requested the data collection to inform a 

baseline. We've requested that that happen 

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outside of the certification system.

 For our comments this round, we'd like 

to draw your attention to our request for a very 

related and we think actionable work plan item, 

which is a recommendation to NOP to develop 

guidance for certifiers and industry on GE 

testing. We currently don't have that guidance.

 Topic number three, celery powder. 

You heard the excellent panel yesterday on our 

ongoing efforts to develop organic celery powder. 

It's hard to imagine what more I could add. I 

was hoping to perhaps report out on the nitrate 

content of my saliva, but I can't find those 

strip tests.

 But I will say in terms of commercial 

availability, this clause in the organic 

regulation continues to present challenges, 

because really is it at odds with the law of 

supply and demand. So how do we incentivize the 

development of organic alternatives, and how do 

we make the system work the way it was intended 

to? 

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 Number one, the demand absolutely 

needs to be there. Number two, the supply chain 

needs to be built, and that takes time and 

resources as was explained yesterday. It's very 

complicated. Number three, it takes more than 

all of us just coming to NOSB meetings. 

 We're working really hard on the 

supply chain part, and I hope through our 

comments and yesterday's expert panel it's clear 

that we are committed to and taking very 

proactive and innovative steps to not only 

develop organic celery powder, but also 

developing a model that can be applied to other 

materials on the National List. 

 So this graphic that most people 

probably can't see, I can't see without my 

glasses, we have a write-up on this model that 

we've developed, the time it takes and the 

various phases for developing organic and natural 

alternatives to the National List. 

 This has really come out of our 

National List Innovation Working Group, our 

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Celery Powder Working Group, and we hope that 

this can help us in our process. Thank you very 

much. 

 CHAIR BEHAR: Thank you, Gwen. 

Questions?

 MR. BRADMAN: I'd like to comment.

 CHAIR BEHAR: Okay, Asa. Raise your 

hand so that I know.

 MR. BRADMAN: Sorry. Just in response 

to your comments now and the panel yesterday, you 

know, I think one of the benefits of the organic 

system is that we have a public and private 

partnership. 

 One of the things that struck me 

yesterday was that there's been an investment on 

the private side, and some on the public side 

too, to address this issue. 

 But clearly there's a need for more 

work, and I just want to kind of encourage more 

effort to develop that partnership, and for the 

-- on the public side, to really support the 

research that we need to move this ahead. 

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 MS. WYARD: Yeah. Thank you Asa, and 

that's exactly what our National List Innovation 

Working Group was formed. Celery Powder is the 

first subgroup of that effort, but it is set up 

for our industry to our members to financially 

invest into the development of alternatives. 

 And then as you'll see in the model, 

of course, you know working with universities and 

looking for funding because, you know, we want to 

pull obviously from all the sources and resources 

that we can. So we're really excited about the 

work that we're doing and what this can mean for 

the future. So thank you very much.

 CHAIR BEHAR: Thank you. Next up is 

Megan DeBates, with Steve Walker on deck.

 MS. DeBATES: Hi. I am Megan DeBates, 

Director of Legislative Affairs and Coalitions 

for the Organic Trade Association. Everyone here 

is committed to maintaining the integrity of 

organic, and we are very appreciative of the 

collective efforts on improving oversight of the 

organic supply chain. 

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 You've read our comments and should be 

familiar with our private sector initiative and 

launch of the Organic Fraud Prevention Program 

that organic businesses may voluntarily enroll 

in. We have additional materials out on the 

table if you would like to learn more. I will be 

focusing on our legislative efforts to prevent 

organic fraud, namely our work on the Farm Bill.

 For the last two years, OTA and many 

stakeholders in this room worked on solutions to 

increase oversight of the organic supply chain in 

the Farm Bill, which was signed into law this 

past December. The 2018 Farm Bill provided 

support and necessary funding for NOP to keep 

pace with industry growth, and to carry out 

compliance and enforcement actions in the U.S. 

and abroad.

 It strengthened the emphasis on NOP's 

authority and capacity to conduct investigations, 

and granted them the flexibility to conduct a 

risk-based approach to oversight. We thank the 

NOSB for your work on developing recommendations 

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to NOP on import fraud. 

 As NOP moves forward in implementing 

the Farm Bill, the Board as well as the industry 

will play a critical role in preventing fraud and 

utilizing the new tools and authorities granted 

in the Farm Bill.

 One area I would like to highlight in 

particular is that the Farm Bill provides $5 

million for NOP to invest in technology and 

access to data, to improve tracking of 

international organic trade and prevent fraud. 

The Farm Bill language does not specify how the 

funds should be used, which gives NOP flexibility 

in exploring technology-based solutions.

 We think it would be helpful for the 

Board to put together some recommendations for 

NOP, and how those funds could be best utilized, 

and would encourage you to include that as you 

work on your discussion document.

 I also want to mention livestock 

issues, another area where we have all been 

united in the need for robust and consistent 

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standards. Thank you for passing a resolution 

urging NOP to issue a final rule on the origin of 

livestock standards. We agree with you and feel 

very that a new proposed rule is not a real path 

forward.

 Nothing about this issue has changed 

to necessitate a new rulemaking, which would take 

years. The current standards are not being 

enforced or applied appropriately, and this has 

gone on for far too long. I want to draw your 

attention to the letter OTA's dairy sector 

council sent to USDA requesting a final rule.

 The companies and farms on that letter 

collectively represent over 90 percent of the 

organic dairy market. 

 Lastly, we want to thank all the 

former and current NOSB members that signed on as 

declarants to OTA's lawsuit on the organic 

livestock and poultry practices rule. We must 

use all the tools we have at our disposal to 

fight for the integrity of the organic standards.

 Thank you for the opportunity to 

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provide comments.

 CHAIR BEHAR: Any comments from the 

Board? Thank you very much, Megan. Okay, next 

up is Steve Walker with Alexis Randolph on deck.

 MR. WALKER: Good morning. I'm Steve 

Walker, Operations Manager at MOSA. I've been 

involved in certification since pre-NOP. Early 

on, many new certification questions exercised my 

reason and passion. Through the years, weighing 

letter and intents against many real cases, we've 

defined boundaries and worked out a lot of bugs.

 But innovation moves faster than 

development of regs. New twists and sometimes 

new sectors still require our best discernment as 

to how our standards and values apply. 

Navigating the gray in between regulatory lines 

raises passion and hazards. It's best to travel 

with friends.

 So when we find something new, we seek 

counsel, consensus or precedent from other 

certifiers and from NOP. I appreciate guidance 

and NOP's sensible take on regulatory discretion. 

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I used to be frustrated by answers like we don't 

have a policy on that. 

 Then a few years ago, at certifier 

training in Savannah, Jenny Tucker explained that 

when there's no specific published policy 

regarding an unforeseen practice, then ACAs are 

empowered and expected to make reasoned, and I'll 

add ethical, certification decisions.

 We're skilled navigators on a changing 

landscape. We tend to standards, organic values 

and forward thinking. I value certifiers' 

autonomy and ability to align, define boundaries 

and improve. We're currently collaborating on 

best practices for container production requiring 

nutrient cycling, biological activity, 

biodiversity enhancement and natural resources 

improvement.

 Organic choices in these systems must 

meaningfully serve our ailing planet. But we 

need NOP and NOSB to help develop applicable 

regulations. This part of our house is still on 

fire. We need action. Let's get this back on 

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NOSB work plans and consider requirements for the 

farm system beyond the container.

 Out here on the front lines defending 

organic integrity, we see a lot of good work 

inspiring hope. But there's also despair and 

frustration. It's hard to maintain faith in 

organic as a solution to global crises. 

 Some perspective. MOSA certifies 600-

some dairy farms averaging 64 cows per herd. 

Failure to move forward vetted, agreed upon rules 

hurts our farm families, rural economies and our 

seal. Stagnation also disables the resolve 

needed to heal our planet. Let's move forth the 

origin of livestock final rule this year. 

 Certifiers navigate the gray and draw 

boundaries every day. We're good, but today as 

our community is threatened at its core, we need 

clear guidance and teeth. Thanks.

 CHAIR BEHAR: Comments or questions? 

I have one. Oh Sue, you have something? No.

 MS. BAIRD: Just a comment. Thank you 

Steve, and you're right. You guys are good. You 

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do it every day. Appreciate it.

 MR. WALKER: Thanks.

 CHAIR BEHAR: And I want to thank you 

for the request for container standards review. 

Thank you very much for that.

 MR. WALKER: You're welcome. Thanks 

for all you do.

 CHAIR BEHAR: Okay. Next up is Alexis 

Randolph, and after her is Nate Lewis on deck.

 MS. RANDOLPH: Hi good morning. My 

name is Alexis Randolph and I am with QAI, an 

organic certification agency based in San Diego, 

California. 

 My comments are going to be very 

brief. I'm here today just to provide the Board 

with an appendix to our written public comment, 

that identifies how many QAI handling operators 

are using materials up for sunset review. 

 Please review the document Michelle is 

circulating at your convenience. I only have one 

material statistic for the Livestock Committee at 

this time. Peracetic acid is widely used by 

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poultry operations to clean out water lines. It 

is more difficult for us to provide statistics on 

crop materials and in some cases livestock 

materials because our operators rely heavily on 

OMRI-approved products that are a blend of 

generic materials, and therefore more difficult 

to isolate in our own material approval system.

 Before the fall vote, we will continue 

to work with our crop and livestock clients to 

try to get better data for NOSB on some of the 

important questions you have asked regarding this 

year's sunset materials. 

 We hope that there will be some type 

of open docket system in which we can submit this 

information, and if there's not, I would like 

advice on how to get this information to you. 

Thank you.

 CHAIR BEHAR: Thank you, and just the 

Board members. I believe it is all in your email 

inbox that Alexis sent. Any comments or 

questions? Emily.

 MS. OAKLEY: Yeah. Just a 

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clarification, that I think absolutely please use 

the open docket to continue to submit comments on 

any of the sunset materials that you might need 

more time to develop feedback on. 

 MS. RANDOLPH: Thank you.

 CHAIR BEHAR: Okay, thank you, Alexis. 

Next up is Nate Lewis, and then Rebekah Ritson, 

and after that we will take our scheduled break. 

We're about 20 minutes behind.

 MR. LEWIS: Good morning, everybody. 

My name is Nate Lewis. I'm here on behalf of my 

own farm, Oyster Bay Farm. I also sit on the 

Washington State Department of Ag's Organic 

Advisory Board. I was elected to the Poultry 

Committee at the Organic Farmers Association, and 

I serve on OTA's Farmers Advisory Council.

 These comments are my own, as I would 

think this is the first time I'm unaffiliated and 

speaking to you all.

 So first I wanted to introduce you to 

Peggy. She's my caged porch chicken, and the 

irony I had to share with you, she's confined on 

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205.239(b)(5). She had an injury. She's going 

to get better. She's going back to the flock in 

a couple of days. But I mostly wanted to talk to 

you all about the state of Washington, this great 

state that we're all getting to participate in 

this meeting in.

 Washington is extremely unique. If 

you go 100 miles to the west, you're in rain 

forest with over 100 inches of rain per year. If 

you go 100 miles to the east, you're in desert 

with under 10 inches of rain. It's in this 

desert that Washington State's organic production 

is thriving.

 We grow about 85 percent of United 

States' domestic production of organic apples, 

worth $300 million a year. We grow about half of 

the nation's organic blueberries. In 2016, on 

1,600 acres we produced 19 million pounds of 

blueberries. That's gone up by about 1,000 acres 

over the last two years.

 So I think if anyone's concerned about 

a flood of blueberries drowning out the market, 

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they should be giving us the credit because we 

are -- our berries are bumping. 

 I kind of wanted to bring these up 

because our eastern Washington production is in 

large part due to the ingenuity and the 

dedication of our growers. But they have a lot 

of help with the natural environment.

 As I mentioned, it's a desert and the 

desert means that fungal diseases, fungal and 

other diseases are not as big of an issue. They 

also are blessed with a tremendous amount of 

irrigation. In order to kind of tell the story 

about the development of this agricultural lands, 

we have to go back about 12,000 years, when 

Seattle was under about 2,000 feet of ice.

 As those glaciers receded, you can see 

the western part of Montana filled up with this 

giant lake backed up by a ice stand. When that 

ice stand broke, it flooded the entire Eastern 

Washington, sending a 500 foot wall of water down 

the Columbia Gorge, scouring everything in its 

path. 

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 But it also left behind these gigantic 

coolies, which were used afterwards under the New 

Deal and the resources from the federal 

government to create the Columbia Basin 

Irrigation Project, which still remains in my 

understanding the single largest infrastructure 

spending project in the history of the United 

States. 

 It irrigates 670,000 acres. It's got 

331 miles of canals with 1,300 miles of lateral 

canals, and it has brought rain to the desert 

where organic crops can flourish. 

 So I just wanted to use these three 

minutes of your captive attention to showcase how 

wonderful this state is, how diverse it is and 

while we think a lot about Seattle and the trees, 

there's this whole other aspect of the state 

which is what's pushing forward our organic 

production. So thank you all for your service.

 CHAIR BEHAR: Thank you, Nate. Any 

questions? Okay, thank you, and next up is 

Rebekah Ritson, and after that we will take a 

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break.

 MS. RITSON: All right. Since I'm 

standing between everybody and break, good 

morning. I am Rebekah Ritson. I'm the Organic 

Regulatory Specialist for Grain Millers. Thank 

you for the opportunity to provide public comment 

today. Grain Millers is a whole food ingredient 

manufacturer and merchandiser, and we'd like to 

offer comment on the oversight improvements to 

deter fraud discussion document.

 I'm going to dive right into some of 

the points that we really wanted to emphasize. 

Point 8 suggests use of transaction import 

certificates tied to an importer's commodity 

databases. We fully appreciate the risk inherent 

to importing organic ingredients, and we 

voluntarily require transaction certificates for 

all imports except Canadian.

 That said, current verification 

measures across certification agencies are 

inconsistent and insufficient. If we're going to 

rely on transactionary import certificates, but 

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they're not regularly compared to an operations 

production volume historic product inventory, 

they're meaningless.

 Such assessments could easily be 

incorporated into existing audit trail exercises, 

but in our experience these are not routine or a 

significant portion of inspections. 

 Therefore, we believe success in any 

development of this type of program is also going 

to be reliant on a concurrent development of 

guidance document for certifiers, outlining 

requirements for transaction certificate 

validation, and then an NOP focus on following 

this guidance at accreditation audits.

 We also have concerns about the 

practicality, implementation and objectivity of 

an organic industry alert system based on 

biorejection of products as outlined in Point 9. 

A reporting system based on rejection of 

unverified -- due to unverified sampling methods 

and test results or minor correctable paper work 

issues, could cause irreversible damage to both 

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individual businesses and entire supply chains.

 So, instead, we would really like to 

support Point 10, the immediate creation of a 

positive pesticide residue test database, or 

alternatively a comprehensive pesticide test 

residue base -- residue test database, sorry. 

This database would be a repository of validated 

pesticide residue test results from certification 

bodies.

 These already exist. They're just not 

available to the organic sector as a whole. So 

access to these data would permit certified 

operations to make more informed decisions about 

our suppliers, and it would also provide 

certifiers with a better basis for risk-based 

sampling, testing, and unannounced inspections.

 Then, the NOP could use this database 

to rigorously analyze the data, and that would 

serve as a foundation for an effective alert 

system when transfer-specific commodities or 

regions are identified. 

 Regarding Point 7 and the reporting 

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crop acreages and yields in the OID and 

confidentiality issues, the majority of our grain 

is purchased directly from the grower. Many of 

our farmer-suppliers have voiced concerns that 

disclosure of detailed crop and acreage 

information could create an unfavorable marketing 

environment and result in price fixing. We don't 

really consider this to be an immediate risk, but 

we don't wish to dismiss this concern in the long 

run.

 We're very concerned to see voluntary 

acreage reporting, and we'd like this to 

continue. And we'd suggest, to help protect the 

suppliers, that we make the disclosure of an at 

minimum the organic acreage per operation, and 

that would allow us to do some calculations, come 

up with basically a maximum production range, and 

that would be more than we have to go on right 

now.

 CHAIR BEHAR: Tom. 

 MR. CHAPMAN: Can you talk in more 

detail about the price fixing concern? 

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 MS. RITSON: So that is a concern that 

we've heard a lot more from our producers up in 

Canada, where they don't do any amount of sharing 

of crop or farm acreages, and basically there's a 

perception that companies could take all of that 

data and use it to determine how much corn is 

going to be out there in the winter, spring and 

then just decide amongst ourselves or 

independently to only pay so much based on what's 

available.

 So they're very concerned it's going 

to limit their income and marketing 

opportunities.

 MR. CHAPMAN: So they're concerned 

about price fixing, even though similar -- in the 

organic even though similar data is available on 

the conventional side?

 MS. RITSON: Yep. That is what we're 

hearing.

 MR. CHAPMAN: Okay.

 CHAIR BEHAR: Sue, Dave.

 MS. BAIRD: Thank you for your 

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comments, and we all agree that this is a huge 

issue, including we're thankful that NOP does. 

We've had a lot of written comments on this fraud 

documentation, and I did a quantification, and it 

appears that the number one person was that they 

wanted a stop sale authority be given to NOP. 

How do you feel about that?

 MS. RITSON: Based on my experience 

with grain millers, we haven't ever seen stop 

sale authority exercised just in general.

 (Off-microphone comment.)

 MS. RITSON: Right. Well, not just 

for organic but for conventional product as well. 

So I think it's going to take longer than we 

would like. I don't think it's something that we 

should totally ignore. But to get the stop sale 

authority, it could take a while to get set up. 

It will also require a lot of collaboration with 

state governments, I think, to effectively 

execute.

 So that will require a lot of training 

and outreach to state governments that don't have 

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organic programs.

 (Off-microphone comment.)

 MS. BAIRD: Yes, and I would agree. 

I know that I back many hundred years ago, I've 

managed feed and seed programs for the Missouri 

Department of Agriculture, and they do, state 

agencies under the Feed and Seed Act, have stop 

sale authority. So I'm wondering, and I do agree 

that any time you implement change, it's a huge 

issue. 

 But if the states have that authority, 

why we cannot implement that under the federal 

authority.

 MS. RITSON: I mean if we can. I 

think the collaboration is going to be effective 

to actually exercise the stop sale authority. So 

I think the states are going to need to be 

involved, even if it's a federal authorization.

 MS. BAIRD: Yeah, and I would agree. 

I just was making that comment. It was the 

number one comment.

 CHAIR BEHAR: Dave. 

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 MR. MORTENSEN: Rebekah, the fellow 

that presented the NASS data, were you here 

yesterday?

 MS. RITSON: Yep.

 MR. MORTENSEN: Yeah. There's an 

additional data set out there that his shop and 

others use, researchers use, where you can 

actually get down to the field level and 

calculate acreages by crop type. It's called the 

Crop Land Cover data set. So you can link it 

with the data that -- I think Adam was his name 

was. 

 So I want -- the question is as we go 

forward, I think talking with farmers who I 

totally get how concerned they are about 

revealing privately-held information about their 

farms, more of this data about at least crop type 

and acreage is quite available if various people 

wanted to take the step with that.

 So it would be interesting to be 

talking with farmers about how, you know, the 

fact that some data are available might help 

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inform their thinking about what they would share 

and what they would be less willing to share. 

Just a thought.

 MS. RITSON: I appreciate that, and 

I will keep it in mind during field visits this 

summer.

 CHAIR BEHAR: Rick.

 MR. GREENWOOD: Yeah. Just a source 

of information for you. I was on the Hass 

Avocado Board, and we up a grower database with 

numbers of potential crops for each year. You 

might check with them because they went through 

the process and so far I haven't heard of any 

price fixing or anything else. That's part of 

AMS. So just a good reference for you.

 MS. RITSON: Can I respond to that?

 MR. GREENWOOD: Sure.

 MS. RITSON: We are not particularly 

concerned about the price fixing, but we do work 

with so many suppliers that I felt given the 

number of times that I've heard that concern, 

that I should use my time to make that public 

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record. 

 MR. GREENWOOD: All right, thank you.

 CHAIR BEHAR: Okay. Yes, Jenny?

 DR. TUCKER: I appreciate the 

comments. I do want to clarify that the acreage 

data gathering is incredibly helpful for 

compliance and investigation purposes. What we 

would publish would be much more aggregate data 

set. So we'll be under this -- we're under the 

same sort of privacy laws that NASS and other 

federal agencies are under in terms of reporting 

aggregate data from the database.

 I'm not sure I've said that as much or 

as loudly as I thought I should in terms of that 

data that is summarized and reported to the 

public is at an aggregate level. I know that 

that doesn't address all the concerns that you're 

raising, but I do want to just highlight that 

this is an area that we're very aware of and 

concerned about in terms of balancing data 

availability for investigations versus data 

reporting and protecting confidential business 

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information, which is critical.

 MS. RITSON: Thank you.

 DR. TUCKER: Thank you.

 CHAIR BEHAR: Thank you. All right. 

With that, we will take a break. I'm going to 

say ten minutes, so we try to maybe catch up a 

little bit, and everyone come back at 10:45.

 (Whereupon, the above-entitled matter 

went off the record at 10:36 a.m. and resumed at 

10:50 a.m.) 

 CHAIR BEHAR: Okay. Thank you 

everyone. We have Howard Whitney on next, with 

David Hiltz on deck. So hopefully, and if 

somebody could just tell the people in the 

hallway that we're starting, that would be 

appreciated.

 Thank you, you may begin. Your name 

and affiliation please. 

 Oh and one more thing. Please speak 

into the mic. I know you're a little tall, so 

you might have to kind of get --

 MR. WHITNEY: Well, I've got it 

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pointing right at me. How's this?

 CHAIR BEHAR: Oh that's pretty good.

 MR. WHITNEY: Okay.

 CHAIR BEHAR: And just so speak up. 

Thank you very much.

 MR. WHITNEY: I'll try not to move my 

head too much. I'd like to thank the NOSB 

members, NOP staff and the organic professionals 

that are assembled here today. My name is Howard 

Whitney. I am the principal scientist of Steen 

Research. Steen Research specializes in air and 

water pollution control, and environmental 

remediation.

 We have developed a pollution control 

process that removes ammonium nitrogen pollution 

from animal waste. We stabilize it in a nonsynthetic organic acid including citric acid. We 

are now in the final stage of obtaining an 

organic input material label from California 

Department of Food and Agriculture.

 Because of the pending label for a 

non-synthetic, ammonium citrate clear liquid 

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fertilizer, we oppose the petition to list 

synthetic ammonium citrate. Synthetic ammonia 

production is responsible for three percent of 

global carbon dioxide emissions. Livestock 

operations are responsible for nearly 80 percent 

of ammonia pollution, producing nearly two 

million metric tons of ammonia per year in the 

U.S. alone.

 This constitutes more than ten times 

the current U.S. organic fertilizer needs. 

Preliminary studies indicate we can produce 

ammonium citrate for a wholesale price similar to 

fish emulsion on a nitrogen basis. We conclude 

that by early 2020, a non-synthetic ammonium 

citrate organic input material will be available 

in large supplies and at reasonable cost.

 We ask NOSB to reject the synthetic 

ammonium citrate petition because it would 

effectively kill our non-synthetic product by use 

of a cheap synthetic. Thank you.

 CHAIR BEHAR: Okay, thank you. Are 

there any questions? Excuse me, want to come 

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back? We do have a question for you from Steve.

 MR. WHITNEY: Sure.

 MR. ELA: Would that be able to be 

used as a foliar application, your -- what you're 

developing as well as the soil application?

 MR. WHITNEY: Yes, absolutely.

 MR. ELA: Great. I appreciate that 

information. That's very helpful. 

 CHAIR BEHAR: Okay, anyone else? Asa.

 MR. BRADMAN: I think Emily was next.

 CHAIR BEHAR: Oh, I'm sorry. 

 MS. OAKLEY: This may be an ignorant 

question, but I'm curious how you came to know 

that the ammonium citrate petition was before the 

NOSB, and I appreciate you being here today.

 MR. WHITNEY: Well thank you. Yeah, 

I've attended -- this is my third meeting in a 

row that I've attended. So I've been tracking 

the agendas. Last summer I met with NOP staff 

regarding our process, and they provided help to 

the state of California to provide a framework 

for them to process our application and other 

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applications similar to ours. 

 So I've been on an education process 

for the last year and a half in organic, and I 

really appreciate everyone's input to this. It's 

been very helpful to me.

 CHAIR BEHAR: Asa.

 MR. BRADMAN: Could you describe a 

little bit more the process for production and 

kind of the source of the ammonium in nitrogen?

 MR. WHITNEY: The source is from waste 

products developed in all the forms of livestock 

agriculture, and the process is proprietary and 

patented, and so I really -- I can tell you that 

we've made a very good case that our production 

results in a non-synthetic product.

 MR. BRADMAN: So this is being derived 

from animal manures from potentially --

 MR. WHITNEY: Anything you can think 

of having to do with animal agriculture as a 

source of ammonia pollution.

 MR. BRADMAN: Okay. So it could be 

poultry, it could be --

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 MR. WHITNEY: Yes, everything, 

everything.

 MR. BRADMAN: Okay, okay. So 

potentially even from a CAFO type operation or a 

large concentrated animal feeding operation? Is 

there like a scale that you need to derive the 

material?

 MR. WHITNEY: Yes and, you know, we've 

targeted a specific industry to get this thing 

launched, and so we're going to start there. But 

we would like to apply it more broadly. But we 

hope that this will be a game-changing product 

that I know there's been a lot of concern about 

the fish emulsion, and we believe our product 

could replace that without having to remove it 

from the toolbox, but we could do it 

competitively.

 MR. BRADMAN: Okay, great. Thank you.

 CHAIR BEHAR: Okay, and Rick has a 

question.

 MR. GREENWOOD: Yeah. Just to follow 

up on Asa's question, you mentioned this process 

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is patented?

 MR. WHITNEY: Well, the patent is 

pending right now.

 MR. GREENWOOD: Okay, because I was 

going to say if it was patented, it's in the 

public domain and you should be able to talk 

about the process.

 MR. WHITNEY: Right. No, it's 

pending.

 MR. GREENWOOD: Okay.

 MR. WHITNEY: Yeah, we're fighting 

with the lawyers right now at the Patent Office. 

It's a very complicated process to get through 

that.

 MR. GREENWOOD: Okay, no. Thank you.

 CHAIR BEHAR: One more question. So 

are you saying that the state of California will 

look at this as an approved for organic 

production material?

 MR. WHITNEY: Well, we've submitted an 

application to the state of California, and we've 

been through a long review process with them. 

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We've provided them additional information. 

 We understand they have contracted to 

conduct a peer review of our application and the 

chemistry behind it, and we have -- we are now in 

the process of doing, getting ready to do the 

final inspection and testing for CDFA.

 CHAIR BEHAR: Thank you. 

 MR. WHITNEY: Thanks.

 CHAIR BEHAR: Okay. Next up is David 

Hiltz, and on deck is John Hendrickson.

 MR. HILTZ: Good morning. My name is 

David Hiltz. I'm the Director of Regulatory 

Affairs at Acadian Seaplants. Acadian is a 

global producer of marine plant products based in 

Nova Scotia, Canada. We thank the NOSB and the 

NOP for their ongoing efforts to refine organic 

regulations, and we appreciate the opportunity to 

once again comment on the topic of marine 

materials.

 Acadian Seaplants continues to be 

committed to ensuring that our marine plant 

harvesting activities are performed in a 

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sustainable manner, and that we do not have 

negative impacts on the marine environment. 

 We continue to have our resource 

science team engage with collaboration with other 

stakeholders and groups like the Maine Seaweed 

Council and the New Brunswick Rockweed Advisory 

Group, to provide industry perspectives and 

scientific info to these group as they develop 

new regulations and policies.

 As outlined in our written submission, 

Acadian Seaplants is not necessarily opposed to 

the suggestion that marine plants used in the 

manufacture of crop inputs be certified in some 

way. But we do wonder what precedent this may 

invite for future evaluation of crop input 

materials.

 The Board may want to consider if they 

have the -- or if they wish to use their limited 

resources for future examination of the 

environmental impacts of procuring raw materials 

for other approved crop inputs. 

 One concern industry will certainly 

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have with whichever standard may be chosen or 

drafted is that it be clear and achievable, 

especially with respect to the statement such as, 

quote, having no significant impact on the 

biodiversity of the aquatic environment, quote. 

While one group may be confident that their 

research and history demonstrate that their 

harvesting activities are sustainable and show no 

evidence of environmental harm, other 

stakeholders may not accept this position and 

demand more studies be done.

 Therefore, a defined level of scrutiny 

must be clearly identified in the advance to 

avoid the unrealistic expectation that it is 

somehow possible to evaluate every possible 

ecological outcome of an industrial activity. 

 Finally, Acadian wishes to again 

address the suggestion that ascophyllum nodosum, 

commonly known as rockweed, is being wildly overharvested and should be individually prohibited. 

Rockweed harvesting is done in a manner where the 

upper portions of the plant are removed, leaving 

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the hold fast and the lower portion of the plant 

intact, so it can regenerate. 

 In many jurisdictions, there are 

government-enforced regulations that limit the 

amount of resource that can be removed. To be 

clear, industry only harvests a low amount of 

estimated total biomass of rockweed. In Maine, 

Iceland and Norway for example, the annual 

rockweed harvest removes about two to three 

percent of the estimated amount on the entire 

coastline.

 In Nova Scotia, where rockweed 

harvesting is well-regulated and has been 

occurring for more than 40 years, approximately 

ten percent of the estimated biomass is removed 

annually by harvesting, and many scientific and 

government publications has shown this harvest to 

be sustainable.

 For these reasons, Acadian Seaplants 

would dispute the suggestion that ascophyllum 

nodosum is being over-harvested and should be 

prohibited, as a review of the facts would 

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suggest otherwise. Thank you. 

 CHAIR BEHAR: Any questions or 

comments? I imagine Emily has one.

 MS. OAKLEY: Thank you so much for 

always coming in providing testimony. So I won't 

try to ask too many questions, but I do want to 

address the issue of precedent-setting, because 

it's been raised multiple times and by different 

commenters. And I understand that concern and 

the intention of this discussion document is not 

to create a precedent, but it's to look at the 

very unique nature of the fact that we're 

harvesting a living organism, a plant, from a 

wild native ecosystem.

 We don't have too many natural inputs 

that meet that criteria, and to address your 

question in terms of do we want to be focusing 

our limited resources to the scrutiny of 

naturals. I mean, you have to -- I'm sure you 

understand that any natural material that's 

allowed in organic production should also meet 

the same criteria for no harm to human health or 

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the environment.

 Do we have the time to sort through 

every single one? No, we don't. But this is a 

topic that has just come before the Board 

repeatedly. So we have an obligation, I think, 

to examine it based on stakeholder comments and 

feedback.

 And then this is just a question. I 

thought you mentioned that about ten percent of 

the rockweed in Nova Scotia was harvested, and I 

thought I remembered from the webinar a commenter 

stating that the harvesting in Nova Scotia was 

limited to hand means rather than mechanical. Do 

you think that that is partially attributable, 

that ten percent number would be attributable to 

the fact that it's hand-harvested rather than 

mechanically? 

 MR. HILTZ: Okay. Let's see if I can 

-- so just back to your first comment. Emily, we 

appreciate all the work you've done on this. It 

obviously is a huge issue to pull that document 

together, and while I understand your perspective 

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that this is a unique situation, I would 

respectfully maybe disagree with that, in the 

fact that the whole issue around looking at the 

harvest of rockweed is the ascertation that 

somehow this is damaging the environment. 

 And if that is going to be a 

consideration, I would argue that that same 

consideration could be used for the mining of 

leonardite, which is used to produce humic acid. 

What is the environmental impact of that, you 

know, the catching of fish to produce liquid fish 

products.

 I really don't see how the Board could 

go in this direction and not have that same 

criteria applied to other crop inputs.

 Regarding your second question yes, in 

Nova Scotia we do harvest all of our material by 

hand at the moment. I don't know that that's so 

much an issue of mechanical versus handharvesting. It really gets down to the 

government regulations that are imposed in Nova 

Scotia and New Brunswick, and as we expand around 

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the world, we try to bring those same types of 

regulations to other areas where again, we go in 

and establish, establish resource-based studies 

to find out how much material is in a certain 

sector, working with the Department of Fisheries, 

to establish how much ascophyllum is there.

 And then we apply the model that we've 

used successfully in Nova Scotia for almost 40 

years now, to make sure that we limit that 

harvest. Certainly by doing it by hand, it gives 

us a bit more control. But I would equally argue 

that, you know, investigation of new mechanical 

technologies do not necessarily mean that 

mechanical harvesting is any more destructive 

than hand-harvesting if it's done in a proper 

manner.

 MS. OAKLEY: Can I just do a quick 

follow-up, sorry.

 CHAIR BEHAR: Yeah.

 MS. OAKLEY: We've had a difficult 

time hearing from other harvesters of other 

marine algae ingredients, especially globally. 

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Do you by any chance have a way to reach out to 

other harvesters, to try to get them to comment 

on this process as well?

 MR. HILTZ: Certainly, and you have 

seen some comments from companies like Ocean 

Organics, for example, in Maine I know has 

submitted comments to the Board. 

 MS. OAKLEY: Thorvin.

 MR. HILTZ: Thorvin as well has 

submitted comments. Some of our other large 

marine plant companies probably have not, because 

I find a lot of them are not aware of the 

discussion around this, and it's something that 

I've tried to promote it a bit within our 

industry organizations, where we try to raise the 

attention that's been given to this, to say you 

know, you really need to come and talk about the 

same things that we've been coming and talking 

about to the Board since 2003.

 I think as you get more information 

from some of the companies on exactly what 

they're doing, hopefully they're doing as good of 

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a job as we are, in my opinion, and can provide 

you with the information that we are able to 

provide.

 MS. OAKLEY: Well, any help you can 

give us in getting the word out would be great.

 MR. HILTZ: Yeah, absolutely. 

 MS. OAKLEY: Thank you.

 MR. HILTZ: Again, I'll continue to 

raise that with my peers at some of the industry 

organizations.

 CHAIR BEHAR: Okay, Steve.

 MR. ELA: I guess that kind of falls, 

I mean that kind of leads into my question. I 

hear and believe that you're doing a great job 

and maybe your peer companies. But I guess, you 

know, one of my concerns would be those people 

that aren't you, and worldwide given that we have 

agreements and certified people outside your 

immediate area.

 So I mean to me, having you know, 

oops, excuse me, the proposal covers then makes 

it a fair playing field for everybody, so that 

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somebody doesn't come in and doesn't view it the 

way you do it and spend the money and apply the 

model and whatever, that they don't come in and 

undercut you just by stripping something.

 So I guess how do we, without some 

standard or guideline, how do we prevent that?

 MR. HILTZ: I guess, and well, what we 

hope for as a company is that the areas in which 

those operations are harvesting, impose the same 

government regulations like that we encounter as 

we work around the world. 

 In Nova Scotia and New Brunswick, as 

I said, this is a highly regulated industry 

there, where we've worked extensively with the 

Department of Fisheries and Oceans in those 

provinces to make sure that what we're doing is 

sustainable and is in accordance with what 

they're looking for from us.

 As we move into other areas around the 

world, we try to take that model elsewhere, and 

we try to work with local governments and some of 

the advisory boards in those areas to try to 

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again put safeguards in place to exactly what you 

described doesn't happen. Because it's in the 

interest of no one, it's not in our interest to 

destroy the resource that we're depending on for 

our company.

 So it's important that we and others 

all do a good job harvesting this material, 

because it's the future of the growth of our 

company. So we want to make sure that we and 

others take this seriously, and that's where we 

again try to go and promote the model that our 

resource science team has developed in Acadian 

globally.

 CHAIR BEHAR: Okay. I have one quick 

question. As one of the environmentalists on the 

Board, when you talk about sustainable harvest, 

are you only looking at the regeneration of the 

rockweed, or is there also some oversight and 

review of the other plant and animal life that 

depends upon that rockweed that has been 

harvested? Is that also under review?

 MR. HILTZ: Sure, that's a great 

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question, Harriet. I mean for sure, the majority 

of the work that Acadian has done has focused on 

the majority or focused on studying the 

regeneration of the rockweed. But in accordance 

with that, we have worked with other groups and 

you've heard from some of them in some of the 

comments over the past years, where we worked 

with some of the scientists in Maine to look at 

some of the bycatch, and we've worked with again, 

industry, with government association in Nova 

Scotia as well to understand what possible 

implications there could be, you know, on other 

areas of the fisheries.

 That's where -- that's one of my 

comments that I have given this morning. As I 

said, we are happy to try to meet any criteria 

that's put forward. But it has to be --

something has to be well-defined, where you can't 

just say well, that's not enough. We need you to 

go study this.

 I mean okay, you've done that. But 

that's not enough. We need you to go study this. 

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You will drive industry completely into the 

background if you keep demanding more and more of 

that. So as long as the terms are well-defined 

and are reasonable, I don't think that we or any 

other company should have any problem with 

meeting those. But it has to be well defined and 

it can't just be an ongoing --

 Certainly, we're going to continue to 

do science, but we can't be held to some waiting 

until we have all of the science out there.

 CHAIR BEHAR: Thank you. Sue.

 MS. BAIRD: I'm wondering if you have, 

and I'm sure you do, so I should not even phrase 

that by saying I'm wondering, a matrix for how a 

percentage that you can harvest at that time? 

 MR. HILTZ: So just to give you a 

brief overview of the system that we use, and as 

I mentioned, we will go out and we will use 

things like aerial photography, satellite mapping 

to estimate amounts of ascophyllum. We then have 

our resource science team go out and study those 

areas, where they'll actually do trans-sects 

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across the beach to understand, you know, based 

on the photography we estimate there's 1,000 tons 

in this sector. Is there really a 1,000 tons 

there based on plant density?

 We will then work with the local 

authorities to look at the harvest, at the 

harvest limitations. So for example in New 

Brunswick, if there was 1,000 tons of ascophyllum 

in a given sector, under the rule there we could 

harvest only 170 tons of that. The exploitation 

rate is 17 percent.

 In Nova Scotia, that rate is a little 

higher. I believe it's 21 percent I think in 

Nova Scotia. I should know that, but I'm not 

sure of that. 

 MS. BAIRD: Sure, sure.

 MR. HILTZ: But that's what we will 

do, and then we will monitor the landings that 

our harvesters are bringing in and watch what 

comes out of that sector of the beach. Once we 

hit that landing number, we will then shift our 

harvesters to a different area. 

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 Even while we're harvesting, we're 

making sure that when the guys are out there, 

they're not just going to one corner of a beach 

area and taking all of it from there, because 

that again defeats the purpose of the idea of the 

exploitation rate.

 MS. BAIRD: So what I'm understanding 

you to say is that it's already a well-defined, 

regulated amount percentage of the colony that 

you can harvest?

 MR. HILTZ: It is in some areas. New 

Brunswick and Nova Scotia, again especially Nova 

Scotia. The industry has been -- where our 

company is based, the industry has been working 

there for a long time. So there was a lot of 

back and forth initially with the Department of 

Fisheries and Oceans to establish an exploitation 

rate.

 As we moved, or you know I'm just 

thinking, talking only of our company, but as we 

moved into New Brunswick for example, when we 

worked with the government there, they were very 

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cautious. That's fine. You know, we probably 

should be. Even though we had years in data in 

Nova Scotia, they were a little more cautious. 

 So they established a slightly lower 

exploitation rate there, and we've been working 

at that rate for years. We have asked the 

government to, you know, to look at the 

possibility of increasing that to match what we 

do in Nova Scotia.

 When we expanded into Maine a number 

of years ago, that was the same type of a system 

that we tried to bring to regulation in Maine. 

Again, we've worked extensively with the Maine 

Seaweed Council to again try to bring that, that 

I guess exploitation rate or that harvest limit 

in place there as well.

 It hasn't been fully implemented in 

Maine. There is one area of the state of Maine, 

I believe Cobscook Bay is under an exploitation 

limit like that. The rest of the state is not, 

and then with the lawsuit that just occurred 

there, the whole harvesting application in Maine 

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is a little bit up in the air right now.

 CHAIR BEHAR: So it would appear that 

we --

 MS. OAKLEY: I have Dan next.

 MS. BAIRD: I'm sorry? 

 CHAIR BEHAR: Are you still asking 

questions?

 MS. BAIRD: You're right, I'm sorry. 

I should have asked if I could follow up.

 CHAIR BEHAR: Go ahead.

 MS. BAIRD: No, that's fine.

 DR. SEITZ: What happens if you have 

multiple companies exploiting the same area? How 

do they share the exploitation rate?

 MR. HILTZ: That's a good question, 

Dan. That's why in the written comments you will 

notice that one of the things that we had 

suggested that really makes the effect of the 

system work well is not to have that system. So 

in Nova Scotia, for example, the sectors that 

have been awarded to Arcadian Seaplants for 

harvest, no one else harvests it. 

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 There are other sectors, like the 

coastline is divided into sectors, and there are 

other companies that harvest there. But they 

don't harvest in the same sector that we do. So 

it's impossible to have that type of an overlap. 

In Maine, that's again where there in some areas 

there is no licensing per se, that becomes 

challenging. 

 That's why we as a company, as we go 

worldwide, we try to promote the idea of 

licensing of the areas of the shoreline to 

individual companies, or at least a collective 

where, you know, sectors are distributed to 

companies and only in that way can you really 

carefully control what's being taken out of a 

given area of the beach.

 CHAIR BEHAR: Okay. Emily has a 

question. 

 MS. OAKLEY: No, just a quick followup. One of the other commenters presented that 

it's 25 percent in Nova Scotia. But also I like 

that suggestion, of course. I think that makes a 

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lot of sense, but it's so far beyond the purview 

of anything that we could suggest or implement 

regulate, and that's up to local and regional 

governments and authorities. But it does speak 

to the broader problem.

 I mean that is where I think you 

address the issue. There are some things that 

are beyond the purview of a review like this, and 

that unfortunately is probably one of them, 

simply because we don't have that authority.

 MR. HILTZ: I will say, just to point 

out one last thing, is again look at the overall 

number of how much resource is being taken out of 

the environment. In Maine, for example, where a 

lot of the opposition to rockweed harvesting 

comes from, we removed two percent of the 

standing stock. Not we, all of the harvest 

removes about two percent of the standing stock 

of ascophyllum a year, and that's using a very 

conservative estimate of the amount of 

ascophyllum.

 I think some people envision this that 

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we're out mowing down the entire coastline. That 

is absolutely not the case.

 CHAIR BEHAR: Okay. I just have one 

very quick question. Is it typical that that the 

harvesters all work for one company, or are 

people individuals and they harvest and sell to 

many different companies?

 MR. HILTZ: That's a little bit 

depending on the area, to be honest, Harriet. In 

Nova Scotia, our harvesters work exclusively for 

us. In other areas, in Maine, I believe our 

harvesters are all associated with individual 

companies as well.

 In some of our operations that we're 

starting in Europe, we're finding there that the 

harvesters are more independent and because 

again, there's no licensing, they can go to the 

seashore and harvest and sell to any one of a 

number of producers.

 CHAIR BEHAR: Okay, thank you. I'm 

going to move on to the next speaker.

 MR. HILTZ: Thank you all for your 

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work on this.

 CHAIR BEHAR: It was very good to have 

your expertise here. Thank you very much. John 

Hendrickson is next, with Doug Currier on deck.

 MR. HENDRICKSON: Is this good? 

Great. John Hendrickson, organic farmer, Stone 

Circle Farm and owner of Small Farm Works, a 

business dedicated to providing innovative tools 

for small farms, including the paper chain pot 

transplanting system. I'm commenting today on 

paper pots. 

 I first want to thank the Committee 

for the action they all took at the fall 2018 

meeting, and thank the NOP for their decision to 

allow the use of paper pots on organic farms, 

while the complicated issue of paper as a 

production aid is reviewed and researched and 

voted on by the NOSB.

 In thanking you, I speak for many, 

many farmers who rely on paper pots as an 

integral part of their business and their effort 

to farm in a sustainable manner. With the 

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possible exceptions of community-supported 

agriculture, hoop houses and the current 

microgreen craze, few innovations have had the 

impact of paper chain pots on small and mediumscale vegetable farms in terms of profitability 

and viability.

 The economic viability is all organic 

farms is heavily dependent on efficiency, 

precision and successful conversion of seeds to 

marketable crops. The paper pot transplanting 

system dramatically increases the success rate 

for many crops that are suitable for planting 

paper chain pots.

 As the many public comments 

demonstrate, the paper chain pot transplanting 

system is not just a super-cool tool. It has 

direct and indirect environmental benefits 

including, but not limited to, reducing or 

eliminating the use of disposable or limited use 

plastics, reducing the use of fossil fuels as a 

hand-pulled implement, reduced soil disturbance 

from weed cultivation as compared to the same 

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crops being direct seeded, enhanced productivity 

allowing farmers to grow and sell more food off 

fewer cultivated acres, and keeping small, 

diversified operations in business through 

reduced labor costs and reduced back-breaking 

labor.

 The petition I submitted last year 

addressing the issue of paper pots has prompted 

the NOSB to take a broader look at paper products 

used as production aids in organic agriculture. 

I applaud this effort because the existing NOP 

rule does not address the many uses or potential 

uses of paper-based products on organic farms.

 While I am glad this happening, I hope 

this broader examination does not delay a vote 

and new rulemaking. A technical review has been 

requested to investigate an array of potential 

paper ingredients. The company that makes the 

paper chain pot system that I sell is committed 

to developing a product that is in compliance 

with organic standards. 

 They just need to know to what 

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standard they need to work. Hence, my desire to 

see a vote happen at the fall 2019 meeting. The 

manufacturer of the paper chain pot system has 

been actively working to develop new types of 

paper pots that use natural fibers rather than 

any of the synthetic fibers that are currently 

the subject of the technical review.

 It is my sincere hope that we will 

have clear guidance on what ingredients are 

allowed and not allowed in paper products 

following the fall meeting, in order for us to 

develop and offer products to organic farmers as 

quickly as possible. Thank you very much for 

your work and opportunity to comment.

 CHAIR BEHAR: Steve, Emily, Dave.

 MR. ELA: So I think this comes back 

to the egg and the chicken debate. You're asking 

for clear guidance on fibers that can be used and 

we're asking for clear thoughts on what fibers 

must be used and what are needed. 

 I don't know how -- I guess, you know, 

I would turn the question back to you. What is 

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the minimum amount of synthetic fibers and what 

are those fibers composed of, that are needed for 

the -- for example, for the paper pots. I mean 

we heard from Ellepot, you know. They're using 

rayon cellulose-based materials that while 

synthetic, probably are fairly breakdown very 

similar to newspaper. I would ask that same 

question for the paper chain pots as well. 

 MR. HENDRICKSON: Sure.

 MR. ELA: Do we need plastics, or can 

we use a rayon material or where can we go? We 

need that information. You want us to give 

guidance, but we need to know what's necessary to 

start with.

 MR. HENDRICKSON: Yeah. Well, I think 

I've been clear that the company that I represent 

is committed to develop a paper pot without any 

of those synthetics. They are pursuing hemp and 

other natural fibers to achieve a commercially 

viable product. So that is -- our hope is that 

we won't have to deal with the synthetic fibers 

at all. 

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 MR. ELA: Can I follow up, Harriet?

 CHAIR BEHAR: Sure.

 MR. ELA: But you also told us that 

the hemp pot wasn't commercially available yet --

 MR. HENDRICKSON: No, it's under 

development.

 MR. ELA: So --

 MR. HENDRICKSON: They're trying to 

determine how much hemp fiber is needed to 

achieve the same quality product. 

 MR. ELA: So it still hasn't answered 

my question. If you want us to vote on something 

in the fall, what are we -- what do we have to 

include in terms of --

 MR. HENDRICKSON: I'm not asking you 

to include any of the synthetic fibers. 

 MR. ELA: Okay. So even though you 

don't have that product, you're fine with us 

saying no synthetic fibers? 

 MR. HENDRICKSON: The company that I 

represent is committed to developing a product 

using all natural fibers. 

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 MR. ELA: Okay.

 CHAIR BEHAR: Emily.

 MS. OAKLEY: Okay, that's interesting. 

But I also think we have to be clear that we 

can't create a double standard within these 

standards in terms of the newspaper allowance 

that's already there. I don't think there's any 

interest in creating an imitation or a new 

listing for paper as a planting aid that is more 

strict than the existing listing, because I don't 

think we're at all able to go into what synthetic 

fibers are in all of those paper materials, what 

adhesives and start coming up with percentages or 

restricted materials.

 And if we want to do that, that's a 

whole other discussion and that supplemental TR 

definitely gave a lot of us pause for concern. 

But that's a whole other issue. Hopefully that 

wasn't too convoluted but --

 MR. HENDRICKSON: Was there a question 

in that, or was that a comment?

 MS. OAKLEY: That was a comment. I 

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just don't think -- 

 MR. HENDRICKSON: Okay, I thought so. 

I just wanted to make sure.

 MS. OAKLEY: I don't think we are --

that's okay, yes. I don't think we are looking 

for this TR to give us standards that we would 

then put out to the industry, simply because 

unless we do that for the other paper listing, 

you would be creating a double standard within 

the standards.

 CHAIR BEHAR: Okay, and Dave. Okay. 

I just have one question. Do you think the 

development with the hemp will be completed 

sometime in mid-summer, or I mean, when will we 

have an idea if the hemp actually seems like a 

viable option? I think at one point you did say 

that there was some concern about enough in the 

supply chain to the manufacturer to actually make 

a product that they could produce.

 MR. HENDRICKSON: Yeah. That's why 

I'm encouraged by the current booming interest in 

hemp production and expansion of farmers and 

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states being allowed to grow hemp, because that 

will hopefully increase the supply of hemp fiber 

internationally.

 We tested the first samples of paper 

pots using hemp fiber last summer. It was not 

successful, but a new batch of paper pots are 

apparently coming my way this summer for testing 

again. 

 So you know, the R&D process 

continues. I can't tell you exactly when I will 

-- when the company will be satisfied that 

they've come up with a product that meets their 

standards in terms of it being a commercially 

viable product for farmers to use.

 CHAIR BEHAR: Okay, thank you very 

much.

 MR. HENDRICKSON: Thank you.

 CHAIR BEHAR: Next up is Doug Currier, 

with Kanaga Sabapathy on deck. I hope I said 

that right, Kanaga Sabapathy. Thank you, Doug.

 MR. CURRIER: Okay. Thanks, Harriet. 

Thanks to the Board. My name is Doug Currier. 

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I'm with the Organic Materials and Review 

Institute, and I'm here today to discuss the 

marine materials discussion document and the 

discussion document on paper and other crop 

production aids.

 First, OMRI continues to monitor the 

work of the Materials Subcommittee on the use of 

marine materials in organic crop production. The 

current recommendation from the Subcommittee is 

for NOP to amend annotation language at 205.601 

and 602, so that marine materials used as crop 

inputs must be certified organic.

 As included in the discussion 

document, OFPA includes a provision that inputs 

substances must not be harmful to the 

environment. Amending the National List and 

requiring organic certification of marine 

ingredients in order to address the OFPA 

provision may be appropriate for this specific 

agricultural ingredient.

 However, as discussed today and 

yesterday during public comments, there are many 

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other substances where that approach would not 

work. For example, mine minerals and liquid fish 

products are two examples of substances whose 

procurement methods may violate that specific 

OFPA provision that natural materials not be 

harmful to the environment, but which currently 

fall outside of NOP's scope in regards to organic 

certification.

 It is unclear whether using multiple 

approaches to address that specific OFPA criteria 

is required, or whether a singular approach could 

be used to address both agricultural and nonagricultural substances. Also in preparation for 

the meeting, a survey of the OMRI list was 

conducted, and a limited number of marine algae 

substances were identified as certified organic.

 This includes both final products on 

our list that are certified, and products on our 

list that formulate with products that are 

certified. For comparison, there are products 

and six livestock feed additive products 

currently listed that OMRI considers marine algae 

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products.

 With that said, hundreds of other 

blended fertilizers and soil products could 

formulate with marine algae ingredients. 

 Okay. On to paper. The Crop 

Subcommittee discussion document on paper asks 

whether there were other paper-based production 

aids not mentioned in the discussion document 

beyond mulch, compost feedstocks, pots, seed 

tape, hot capture collars.

 In our review of brand name products, 

OMRI has allowed the recycled paper as a 

component of potting mixes and as a top dressing 

for soil. OMRI currently approves newspaper and 

other recycled paper for these purposes under the 

205.601(c) allowance for the material as a 

compost feedstock.

 The rationale for doing that is that 

when applied to the soil, it will degrade and 

therefore it's in line with the spirit of the 

205.601(c) compost feedstock allowance. Thank 

you to the Board. I welcome any questions if 

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there are any.

 CHAIR BEHAR: Any questions? At some 

point, I do want to talk to you about coconut 

coir and the possible use of calcium nitrate as a 

buffering agent. But that's not on our docket, 

so, but maybe we can find some time later.

 MR. CURRIER: Sure.

 CHAIR BEHAR: Okay. Oh, Emily, go 

ahead.

 MS. OAKLEY: Sorry. One quick 

question.

 MR. CURRIER: Yeah.

 MS. OAKLEY: So should ultimately it 

be determined that organic certification for the 

marine algae ingredient was a viable option, can 

you explain how a certifier or a farmer would be 

able to use the organic certificate as a 

verification means? 

 Like using the Organic Integrity 

Database or that ingredient being listed as 

certified organic, but clearly there's no purview 

or ability to list the product itself as organic. 

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 MR. CURRIER: So, marine algae is 

interesting because it is so commonly used as a 

crop input. But it is also certifiable and is 

certified for human use. And so I guess from an 

input material review perspective, we would 

accept an organic certificate as proof of 

compliance as a crop input. 

 And so we have ways of verifying an 

organic's status in our reviews. So yeah, I 

think from an input material review perspective, 

that's how we would look at it. Okay, thanks.

 (Off-microphone comments.)

 CHAIR BEHAR: Kanaga Sabapathy? Okay. 

Next up is Julie Weisman with Anne Bikle on deck.

 MS. WEISMAN: Good morning. My name 

is Julie Weisman. I thank the program and the 

NOSB for the opportunity to provide comment 

today. The two companies I represent, Elan Mill 

and Flavorganics have been developing and 

bringing to market organic flavor ingredients for 

use by organic food companies and organic 

consumers for over 20 years. 

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 I served on the NOSB from 2005 to 2010 

in the handling position, during which time 

commercial availability was my passion. 

Developing a market for a certified organic minor 

ingredient in the absence of a regulation that 

required its use has been a continuing challenge.

 By my rough estimate, only about half 

of organic products that use flavors are 

currently using certified organic flavors. The 

remaining products have been instead relying on 

what conventional flavor industry refers to as 

NOP-compliant natural flavors, and many have 

built businesses around that.

 Anyway, so I want to thank the NOP for 

the fact that this December, the use of a natural 

flavor will only be permitted in organic product 

when a certified organic flavor is not 

commercially available. Yay.

 Converting that other half, though, is 

not going to happen magically at the stroke of 

midnight on December 27th, and likely not without 

the attention of ACA and perhaps additional 

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guidance from the front of this room.

 Why do I say that? The needle will 

not move at all until companies using natural 

flavors in their certified organic products are 

made aware that the bar has been raised, but 

certainly by their certifier and hopefully by 

their trade associations or even their flavor 

supplier.

 And there will be many products for 

which an effective case will be made that there 

is no organic X say strawberry flavor that tastes 

quite like the NOP-compliant flavor that we're 

currently using. I don't mean me. And I can 

share thoughts on ways to address this, but I am 

most concerned that a significant portion of 

flavor ingredients could fall through the cracks 

because they are often not called flavor. They 

may be referred to as extract or concentrate 

because they conform to a specific legal standard 

of identity, and sound better in a clean labeling 

environment.

 It's very important that we understand 

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that these part -- these are part of flavors nonsynthetic listed on 605(a), and they are also now 

subject to the commercial availability 

requirements. This is where I think additional 

guidance might be helpful. 

 It is not my intention to rain on this 

parade. To be sure this rule change is a success 

I celebrate it. I thank the OTA for filing this 

petition. I thank the NOSB for working on it and 

passing the petition, and the NOP for making it a 

final rule.

 It is a step forward in the continuing 

improvement of organic integrity. I welcome the 

opportunities that it opens up for companies like 

mine, and like everything else in organic, the 

product will not be realized without vigilance, 

and with the same clear understanding of what is 

to be regulated, that the NOP and the NOSB can 

provide. Thank you all for your service.

 CHAIR BEHAR: Any questions from the 

Board? Dan.

 DR. SEITZ: Yesterday there was a 

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consumer who testified, who asked the question, 

why is it that you even allow natural flavors in 

organic foods, and I'm just curious from just a 

naive standpoint. If you have other substances 

that are organic, why is this category necessary 

for organic foods?

 MS. WEISMAN: Because when the 

regulations were originally crafted, that's 

getting to be back in ancient history now. But 

when we were originally, I was -- when that was 

originally being crafted, there were no certified 

-- there were no organic flavors, and there was a 

great desire to be able to make food products 

beyond raw vegetables and that consumers would 

recognize as analogous to other things that they 

were already using. 

 And so we were actually the first 

company to offer a certified organic, any kind of 

flavor, and that took a while to develop. That's 

a -- it's continuing a whole other discussion, 

but so -- and they were placed on the list. It 

was assumed that natural flavors for the most 

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part were not what anyone would consider 

agricultural products. 

 So they couldn't be -- and also 606 at 

the time wasn't -- this was pre-Harvey. So 606 

wasn't even being used. It was assumed that any 

agricultural product could be used. It didn't 

need to be on the list. That's where things were 

at then. So have I -- so there was on 605(a), 

there is no commercial availability requirement. 

 So we've been pushing organic flavors 

for the last 20 years to people who say but a 

non-organic flavor is cheaper. I'd rather use 

that. There was no, there was no requirement. 

Now there is. Now certifiers are going to have 

to ask like well, did you -- what other suppliers 

have you checked with? Have you tasted these out 

against the other ones?

 CHAIR BEHAR: Okay, thank you Julie, 

an alumni of the NOSB. Okay. Anne Bikle and 

then Robert Mensonides is on deck. Thank you, 

Anne. Oh, we have pictures.

 MS. BIKLE: Thank you. Hello. My 

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name is Anne Bikle, and by way of introduction, 

I'm a science writer as well as an organic 

gardener. I'm also the co-author of this book, 

The Hidden Half of Nature, which I wrote with my 

husband, David Montgomery. The book in part is 

the basis for my comments today.

 It explores the burgeoning new field 

of microbioscience and the implications for 

agriculture and medicine. I was peripherally but 

not fully aware of the range of soil stewardship 

practices allowed under the NOP. However a 

recent event where I was speaking prompted me to 

look into the matter, and what I discovered 

troubles me.

 These images are from an organic 

blueberry farm that includes a social media video 

stating, you'll notice we have tunnels. We grow 

in black pots. We have black ground cover. 

Indeed, I can see that as I think everybody else 

can. And this is a bird's eye view of same 

organic blueberry farm from a magazine article, 

noting that the blueberry plants are grown in 

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virgin soil media and why that practice is 

advantageous.

 Now, my intent is not to pick on this 

farm, as there are others with the same practices 

and more coming. The crux of the issue I believe 

is this. These practices are wholly inconsistent 

with at least five sections of the OFPA and NOP 

that pertains to soil. Here are just two 

examples. 

 Section 651(3)(b)(i) of the OFPA 

states in part, an organic plant shall contain 

provisions designed to foster soil fertility. 

And Section 205.205 of the NOP states in part, 

the producer must implement a crop rotation to 

maintain or improve soil organic matter content.

 I find it farfetched that covering 

soil with semi-permanent plastic fabrics could do 

anything to foster soil fertility. These 

practices suffocate and starve the soil 

microbiome, which in turn cripples the nutrient 

cycling that creates and maintains soil fertility 

and plant health. 

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 Deadened soils are the chief outcome 

of conventional agriculture. Why are some 

organic farms now headed in the same direction? 

In addition, how is confining crops to pots 

filled with soil-less media that is routinely 

thrown away after production, along with the 

pots, the plants and the plastic sheeting, doing 

anything to productively manage soil organic 

matter through crop rotations? I find this 

implausible, as well as a planetary calamity.

 In closing, I believe there's a high 

level of cognitive dissonance between what the 

OFPA and the NOP rules state, and what is 

happening on some organic farms. Shall and must 

as quoted above are not words with a gray or 

vague meaning. These words mean required. And 

so is it too much to ask that required practices 

needed to safeguard soil be implemented?

 I don't think so, and that's why I'm 

asking this body, the NOP and certifiers to more 

effectively address the issue of long-term soil 

health. Thank you. 

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 CHAIR BEHAR: Thank you, Anne. Any 

comments, questions? I have -- I'm not sure. 

Did you say how many acres this operation is that 

we're looking at? Do you know?

 MS. BIKLE: No, that information is --

I believe this is 20 acres, but that information 

was in the magazine article.

 CHAIR BEHAR: Okay, and sorry for not 

pronouncing your name right.

 MS. BIKLE: That's okay, it happens.

 CHAIR BEHAR: Thank you very much.

 MS. BIKLE: Uh-huh.

 CHAIR BEHAR: Okay. Next up is Robert 

Mensonides with Mary Chramiec on deck. Okay, 

Robert are you -- no, there's going to be a 

change. We have a little switcheroo here. Oh, I 

know who he is. Richard Mathews will be 

speaking. Okay, you may start. Whoops, you may 

start.

 MR. MENSONIDES: Can you hear me? 

Thank you for letting us to come to you this 

afternoon, and my name is Rob Mensonides. I'm 

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the new executive director for WODPA, and I live 

here in Washington state, in Eastern Washington. 

I'm also an organic farmer that is directly 

affected by the organic dairy producers.

 Richard has a long history of dealing 

with what we're going to talk about, so I'm going 

to let him hit on some points here, and then 

we'll be here to answer questions.

 MR. MATHEWS: Richard Mathews of 

WODPA. Thank you to Abbie Youngblood, National 

Organic Coalition, Kate Mendenhall, the Organic 

Farmers Association, Laura Batcha, Megan DeBates, 

Johanna Mirenda, Organic Trade Association for 

your support in calling for publication of the 

origin of livestock final rule.

 Thank you to the NOSB Board for your 

St. Paul origin of livestock resolution. I now 

see a ray of sunlight penetrating the dark clouds 

over the organic sector. Thank you Dr. Tucker 

for your words of support for organic dairy 

families. It is now time for USDA to completely 

drive away the dark clouds by completing the 

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origin of livestock rulemaking.

 The proposed rule was published four 

years ago. The final rule could have and should 

have been published three years ago. Andrew, 

B.J., Ryan, Tony, you heard them yesterday. They 

are not here today and will not be in organic 

dairy much longer if USDA does not complete the 

final rule soon.

 There is no need for a new import 

analysis. The plain language of the preamble is 

clear. Once a herd has been converted to organic 

animals -- or once a herd has been converted to 

organic, all future animals must be last third of 

gestation. Unfortunately, through a structural 

error in the reg text created by the -- which 

created the two track system.

 And now due to the lack of 

enforcement, this two track system has morphed 

into a multi-track system that allows clear 

violations of the regulations. Think antibiotics 

followed by one year transition. Think removing 

organic calves from the organic operation for 

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conventional grazing, and conversion back to 

organic.

 The origin of livestock rulemaking is 

intended to make the regulation consistent with 

the clear intent of the preamble. That is your 

justification for moving directly to the long, 

painfully long overdue final rule. 

 CHAIR BEHAR: Okay. Are there any 

questions from the Board? Ashley.

 MS. SWAFFAR: Thank you for your 

passion on this. I know it's you guys' 

livelihood, but I actually have questions about 

materials, sorry. 

 MR. MATHEWS: Okay. 

 MS. SWAFFAR: Not going to get away 

with that. So on the vaccine document, you had 

said, I think you had went with what we had said 

Option 1, just to list or to have vaccines 

available, regardless of if they're excluded --

made from excluded methods or not. So just 

wanted to clarify that.

 MR. MATHEWS: Yes. 

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 MS. SWAFFAR: And then on the iodine, 

we're hearing some folks kind of wanting to 

annotate that with no MPEs. Do you guys see an 

issue if we were to annotate that?

 MR. MATHEWS: I believe that you would 

probably eliminate most of the iodines.

 MS. SWAFFAR: We were -- we saw in 

some public comment that some of the dairy, the 

people that they supply milk to are requesting 

that they use iodine that don't have MPEs in 

them. 

 MR. MATHEWS: Yeah.

 MS. SWAFFAR: So that's kind of where 

that was coming from. But you're saying it would 

-- you don't see an iodine source available?

 MR. MATHEWS: That was the concern 

that I didn't want to raise, because I'm afraid 

of the extent of the impact and the future 

availability of iodine.

 MS. SWAFFAR: Okay, thank you. 

 CHAIR BEHAR: Did Dave have a 

question? 

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 MR. MATHEWS: If you all don't change 

the rule, it really won't matter for some of 

these producers.

 CHAIR BEHAR: Dave.

 MR. MORTENSEN: I think mine is just 

in an assertion and an observation. I just 

wanted to thank you and your colleagues today and 

yesterday for being here. I sense that when we 

have this kind of -- I mean how could we not hear 

it? That this will drive a tipping point that I 

have to believe will happen almost immediately.

 I think some of us on the Board, maybe 

many of us on the Board are wondering about some 

of the other things that we could be doing. 

Being a newcomer to this process, it is 

enormously and I know that I speak for the Board, 

enormously frustrating when we work on things 

together, and pass things that you work on for 

years together and then they're not implemented, 

it just doesn't make any sense.

 And when we hear about how it's 

impacting folks, it's heartbreaking. So we will 

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do whatever we can to be sure that the message of 

the Minneapolis meeting is as clearly heard in 

Washington, D.C. as it can be. So thank you for 

coming.

 MR. MATHEWS: Yeah, and the two track 

system that we ended up with, it was a structural 

problem to the regulation. It's very clear in 

the preamble what the intent was, and what it did 

was you had an exemption for the dairy animals, 

and those people that had only used that first 

exemption, they were allowed to continuously 

transition because of the structure.

 Because when you move into the second 

exemption, that is the exemption for feed. So 

the people who take advantage of either the 

80/20, the old 80/20 that's now gone as of 2007, 

or those who are taking advantage of the third 

year, feeding of third year transitional crops 

and pasture, they -- all of them are confined to 

last third of gestation.

 It's because the requirement for the 

last third of gestation was thrown into that as 

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triple I of that second exemption. It should 

have been its own stand-alone issue, applicable 

to those who did just the first exemption and to 

those who did both. 

 What we've seen in recent times is that that 

two track system, which is clear enough, the 

Department has been saying for 17 years they were 

going to fix it. I remember working on a 

proposed rule in 2007 that went nowhere. Then we 

finally got one out in 2015, and the Department 

dropped the ball.

 Nobody wants this. But it's killing 

the small and medium-sized dairy farmers. It 

really is, and we need that final rule today. 

 CHAIR BEHAR: Okay. I just want to go 

back to the vaccines. Would it be acceptable to 

have the vaccines if we had a commercially 

available list, to do it that way, or you just 

want to completely remove any annotation that's 

currently present in the rule, which says that 

vaccines have to currently be on the National 

List in an individual way? 

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 But just kind of basically approve 

vaccines as a class that are from excluded 

methods. Which way would you prefer?

 MR. MATHEWS: Well, in reality --

 CHAIR BEHAR: Or could you live with 

both?

 MR. MATHEWS: Probably could live with 

both, as long as the farmer still had the tools 

they needed to meet federal requirements and to 

make sure that their animals are healthy. That's 

the issue for us.

 CHAIR BEHAR: The Subcommittee has no 

intention of taking vaccines away from livestock 

production. Okay, thank you. Next up is --

 MR. MATHEWS: Thank you.

 CHAIR BEHAR: Mary Charmiec. Maybe 

you'll say your name for me and --

 MS. CHARMIEC: Charmiec.

 CHAIR BEHAR: On deck is Dain Craver.

 MS. CHARMIEC: Do I need to -- okay. 

My name is Mary Charmiec. I am a senior 

certification specialist at CCOF or California 

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Certified Organic Farmers. Today I will be 

commenting on the sunset review of nutrient 

vitamins and minerals, and also on the National 

List petition for pullulan. Pullulan. Okay, I 

got it. I'll just say it once.

 25 CCOF certified operations currently 

use nutrient vitamins and minerals within their 

organic system plan. These vitamins and minerals 

are used in a wide variety of organic products. 

CCOF supports the continued listing of nutrient 

vitamins and minerals.

 However, we feel that the annotation 

should be revised. The winding history of this 

listing has brought forth an often confusing 

playing field for all parties involved. CCOF 

supports Option 2 with proposed Annotation 4 from 

the 2016 Handling Subcommittee discussion 

document, which reads:

 "205.605(b), Vitamins and Minerals, 

Synthetic, for food, minerals including trace 

elements and vitamins identified as essential in 

21 C.F.R. 101.9. For infant formula, vitamins 

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and minerals as required by 21 C.F.R. 107.100, 

or/and 107.10 are allowed for use in agricultural 

products labeled organic and made with organicspecified food ingredients or food groups."

 Option 2 provides succinct and clear 

standards that are critical for ensuring long 

term compliance. Furthermore, Option 2 best 

aligns with the 2012 NOP proposed rule, and is 

the strongest basis for moving forward on this 

issue. 

 It is the most likely to be 

consistently enforced because certifiers --

because it clearly cites where to find the 

allowed list of essential nutrients. Consistent 

application and enforcement are of course key. 

 Switching gears to pullulan briefly, 

10 CCOF certified operations currently use 

pullulan capsules within their organic system 

plans, to manufacture vegetarian dietary 

supplements. CCOF supports the additional of 

pullulan to the National List at 205.605(b) as 

non-agricultural non-synthetic substance. 

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 We encourage the NOSB to add an 

annotation restricting the use of pullulan to 

dietary supplements, supplement products labeled 

"made with organic." The addition of pullulan to 

the National List will support the continued 

allowance of pullulan capsules, as well as help 

ensure consistent application and enforcement. 

Thank you for your time, service and 

consideration.

 CHAIR BEHAR: Any questions? Thank 

you very much.

 MS. CHARMIEC: Thank you.

 CHAIR BEHAR: Next up is Dain Craver, 

and then Paul Vandenberg on deck, and I believe 

he is a fermented beverage man.

 MR. CRAVER: Okay. Well, I would like 

to thank you guys. I know how hard it is to be 

on a Board and Commission. You guys have a lot 

on your plate and you have to go through a lot of 

things. I'm a really passionate organic grower 

and I have been for over 26 years. 

 Today, I'd like to talk about 

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something that we've already heard a little bit 

about, but it's a major component in growing 

fruit, and that pheromones. A lot of people ask 

what are pheromones. Well pheromones are just 

basically this. This is a plastic pheromone that 

we hang on the top of the tree. And the way 

pheromone works is a lot like if you've ever seen 

a female dog in heat, how the male's kind of 

attract around her?

 Well, the same thing happens in the 

insect world. Codling moth go through four 

stages. They overwinter as a pupae. The pupae 

drops to the ground in the spring, about this 

time, right, when we're starting to get blooms in 

our trees.

 And the male codling moth, of course, 

smells her out and goes and mates. She then lays 

eggs on the leaves or on the front, and the worms 

will go through in the second part of their life 

cycle inside the fruit. They'll pupae it out and 

this can happen three or four times.

 The first time that I was ever 

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involved with mating disrupter was with Dr. Jay 

Brunner. I was leasing a WSU research orchard in 

Othello, and mating disruption was just coming 

out. This had a really bad codling moth problem, 

and they were spraying a lot of different things.

 Well what happened is when we used 

this mating disruption, all of the sudden we had 

predators and parasitoid wasp. A lot of bugs I 

had never even seen before, and that really 

inspired me that there was a way to do it without 

spraying. When we used these mating disruptors, 

we're not going up and down our rows 10 or 15 

times spraying with things that don't work very 

well.

 Ryania was the stuff that we used to 

use before we got the pheromones in. Because of 

the pheromones, I get a lot more of these, 

ladybugs, and it's just -- it's a great way to 

control it. Is it 100 percent effective? No. 

What happens is that sometimes we'll get hot 

spots or moths will mate outside of our orchard 

and come into it, and there we then we use 

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viruses which are certified.

 What we've seen happening in Europe is 

that these viruses, the insects are getting 

resistance to them. So they're going to a higher 

potency. We've already seen this a little bit in 

our state, and so we're using that. And probably 

a third one you could use, which I don't like to 

use at all is Entrust.

 I know it's certified organic, but it 

really kinks on my predators and I just feel like 

it gets everything out of whack. And so I do use 

it in my cherries, but I don't like to use it in 

my apples. I hope that you'll consider to keep 

these in use. I heard the question earlier about 

was -- are they sprayed on the trees? No, 

they're not.

 We do, however, have misters. I don't 

personally use any, but a couple of my growers do 

and they actually just spurt out the pheromone at 

the certain time. There's only about an hour 

time when the moths fly. So I hope you guys will 

take into consideration and keep it alive for us 

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organic growers. Thanks.

 CHAIR BEHAR: Any questions? Steve.

 MR. ELA: I'll just ask the one. I 

mean are there any sprayable formulations out on 

the market now?

 MR. CRAVER: For? Can you repeat?

 MR. ELA: For pheromones.

 MR. CRAVER: For conventional, they 

are. They've been working on some. Our Shuford 

Research Commission (phonetic), they're adding it 

with their conventional products, and the 

organics, there's nothing that we're using right 

now. There's just a lot of add me to the tank 

and let's see if it works stuff Steve.

 MR. ELA: Yeah. I mean that's --

yeah. You and I know that. I just wanted to get 

it on the record, so thanks.

 MR. CRAVER: Okay.

 CHAIR BEHAR: Okay, thank you. 

 MR. CRAVER: Right, thanks. 

 CHAIR BEHAR: Next up is Paul 

Vandenberg, and on deck is Jackie DeMinter. 

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 MR. VANDENBERG: Good morning. I'm 

Paul Vandenberg, wine grower and chief scientist 

for Paradisos del Sol. We are an estate winery 

and certified organic vineyard. My primary 

reason for coming today was to thank you for the 

rather challenging tasks you all take on in 

helping us figure this out, and to encourage you 

to keep the standards high.

 Some of the things previous speakers 

spoke about blueberries. I often look at 

blueberries in my neighborhood and wonder how 

that can possibly be certified organic. Confined 

animal feed operations, that shouldn't even be in 

your arena in my view. You should send that back 

to the Secretary of Agriculture.

 One of the things being discussed, 

hydroponics. Absolutely contrary to the 

fundamental basis of organic. We are supposed to 

be building our soils. That's something we feel 

like we've done quite successfully. We have just 

completed six years of the zero use of any inputs 

on our farm other than labor, water and manure, 

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no pesticides of any sort.

 Vitis vinifera, the wine grape, has a 

natural problem in the world today, and that is 

originated in Eurasia, where there was no powdery 

mildew. Powdery mildew is native to the 

Americas. We believe we are the only commercial 

vineyard on earth who is not using chemical 

treatments for the prevention of powdery mildew.

 So these things are possible if people 

really pursue them. So I'm going to encourage 

you to continue maintaining the high standards, 

and to try and avoid some of the pressures from 

the large corporate farms who are trying to 

pursue organic as a profit thing and want to use 

things that perhaps they shouldn't, and are not 

required to provide proof of soil building and 

increased biodiversity on their farm.

 I don't have an insect problem because 

I have today five species of flowering plants in 

bloom in my vineyards, providing a pollen and 

nectar source for a lot of the important 

predatory insects. They control the pests in my 

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vineyard. You cannot find leafhoppers in my 

vineyard. You cannot find grape mealybug in my 

vineyard. 

 Sprays may not be necessary. So 

anyway, thank you for your work. I appreciate 

your efforts on our behalf, and please continue 

to keep the standards high.

 CHAIR BEHAR: Rick.

 MR. GREENWOOD: Thanks. So tell me 

how you control the powdery mildew?

 MR. VANDENBERG: Most vineyards use a 

trellis system that in my view has been obsolete 

since 1975. There is this area we call canopy 

management. Powdery mildew theoretically will 

not survive in strong, direct, ultraviolet light, 

which is something we have in Yakima Valley.

 I'm not finding that entirely true. 

There are some varieties, some cultivars we have 

that it's not working so well. So I have a 

couple of cultivars we're starting this year. 

We're going to try and control powdery mildew 

with a single application of stylet oil at bloom. 

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But I have a number varieties, angelasian 

semillon (phonetic) that have not a problem with 

it, as long as we keep the canopy and wellexposed to sunlight, which also makes better 

wine.

 MR. GREENWOOD: I have a small 

vineyard, and the leaves sometimes get together 

and there's shade between them and moisture, and 

where you still don't get --

 MR. VANDENBERG: Labor is a really big 

input for us. There's these things called shoot 

thinning and leaf pulling.

 MR. GREENWOOD: Okay.

 MR. VANDENBERG: Thank you. 

 CHAIR BEHAR: Sue, Steve and Asa. No, 

no. We're not done with you. Sue, Steve and 

Asa.

 MS. BAIRD: What is your average 

humidity, because in Missouri, we just cannot 

grow organic grapes. I'm sorry.

 MR. VANDENBERG: Well you know, the 

fundamental rule as proposed by Sir Howard in 

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Rodale way back when I was a child reading 

organic gardening magazine in 1960, is you first 

have to choose the right thing to grow in the 

right place. So I chose the farm I'm on 

specifically because I thought it was possible to 

grow grapes without these inputs.

 It's taken me a while to get there. 

I had a lot to learn. But yeah. In our 

neighborhood, if the thermometer hits 95 degrees, 

the humidity is below 20 percent and the heat 

index is 92 or 93.

 MS. BAIRD: Yeah, and absolutely in 

Missouri if it hits 95 we've also got 85 percent 

humidity.

 MR. VANDENBERG: Well, there's a lot 

of work being done at Cornell at other places on 

cross-breeding the Native American species with 

resistance to powdery mildew with the European 

Vitis vinifera. What's going to happen east of 

the Rockies in the next few decades is going to 

be really amazing.

 There are -- there's a lot of work 

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being done in France, where a third of all the 

pesticides in France are believed to be used on 

the three percent of the farmland that's 

vineyards.

 CHAIR BEHAR: I'd just ask the Board 

that if you're looking to the speaker as a crop 

consultant, maybe you can do that afterwards. 

But if you're specifically asking questions about 

what's before us on the docket, that would be 

okay. So next I have Steve, then Asa and Emily.

 MR. ELA: Just you're not done yet. 

I just want to say there are unsprayed orchards 

in Colorado. So I don't want you to be the only 

one but --

 MR. VANDENBERG: Vineyards or 

orchards?

 MR. ELA: Vineyards, I'm sorry.

 MR. VANDENBERG: Oh, yes. We've been 

hesitant about making the claim. I've been 

saying the world's first zero pesticide vineyard, 

in the hopes that there would be others. And 

yes, Colorado should be able to do it all the 

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time.

 MR. ELA: Similar, similar climates, 

so yeah.

 MR. VANDENBERG: Right.

 CHAIR BEHAR: Okay, Asa.

 MR. BRADMAN: So just to confirm, you 

aren't using sulfur or --

 MR. VANDENBERG: Sulfur is a 

pesticide.

 MR. BRADMAN: Right. So you're not 

using it?

 MR. VANDENBERG: Our only inputs for 

six years is labor, water and manure.

 MR. BRADMAN: Thank you.

 CHAIR BEHAR: Emily.

 MS. OAKLEY: So we have this petition 

before us hopefully for body alcohols, and one of 

the points that has been raised is that it's 

necessary because there's a tremendous amount of 

labor in desuckering the tobacco, and I'm 

wondering based on your comments on the amount of 

labor that it takes to do shoot thinning and 

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pulling, what your thoughts are on materials like 

that one.

 MR. VANDENBERG: I think as we stand 

now, people tell me what I do is totally 

impractical and it probably is, because we do --

it's my labor primarily. We're a small vineyard. 

I do believe, however, that things are changing, 

just as the apple growers are all preparing for 

robotic picking.

 I think the technologies that are 

coming down the line for thing like mechanized 

shoot thinning, a machine that can shoot thin the 

way I do. Right now there are mechanical ones 

that just knock out a certain percentage, whereas 

we remove very selectively for shoot thinning and 

leaf pulling.

 I actually wish I had one of the leaf 

blasting machines I call them that uses air to 

disintegrate leaves in the fruit zone, because we 

spend a lot of time doing that by hand. But 

there's not one of those machines in my 

neighborhood; otherwise, I would very happily 

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rent that.

 So what I do right now is not 

practical I think for a large-scale commercial 

operation, because labor just doesn't work. But 

I think in a few years that robotic pruning and 

robotic shoot thinning can make it possible. So 

yeah. I don't think everybody can get away from 

using spray materials for powdery mildew. I 

don't think it's possible on some varieties.

 Don't grow tempranillo, don't grow 

chardonnay if you want to avoid powdery mildew. 

Those will probably need something, until we 

create some genetic alternatives to those.

 CHAIR BEHAR: Okay. I have just one 

comment. I've often said when people have 

problems with insects and diseases on their 

organic farms that we're the ones with the big 

brains, and so we should be trying to figure it 

out. So I applaud you for the elegant system 

that it sounds like you have on your farm.

 MR. VANDENBERG: Thank you.

 CHAIR BEHAR: Now we're finally done 

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with you.

 MR. VANDENBERG: Sure, because I've 

got to go back to farming. 

 CHAIR BEHAR: Jackie DeMinter is next, 

with Winston Rost on deck. Hello Jackie. 

 MS. DeMINTER: Good morning. My name 

is Jackie DeMinter. I am the Certification 

Policy Manager at MOSA. We certify about 2,150 

organic operations through the United States. I 

will be commenting on vaccines, seed guidance and 

paper pots. 

 Of the 870 livestock operations 

certified by MOSA, approximately 500 use 

vaccines. MOSA has categorically allowed the use 

of vaccines and because of this, we only have 

about 50 different products recorded in our 

materials database. 

 If verification of non-GMO status is 

to become a requirement, we'd appreciate a 

resource to reference for quick answers, and a 

phase-in period to gather all of the necessary 

information from farmers and to enable us to 

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approve the products in use, or to redirect them 

to allowed products, if any are found to be 

unacceptable.

 We do not want to see a disruption of 

the tools organic farmers have come to rely on. 

There are at least a couple of paths the NOSB 

could take in making a recommendation to achieve 

the goal of minimizing the use of vaccines 

produced using excluded methods.

 MOSA could align with a direction to 

continue business as usual, but with attention 

toward addition of any concerning vaccines as 

prohibited to the National List, or we could 

align with a more thorough review process with 

established resources to ensure consistency in 

decision-making.

 Seed guidance. MOSA certifies 1,875 

operations for crops. We encourage you to pass 

the proposal at this meeting, to enable the NOP 

to take up revision suggestions and enable 

additional public comment. We support the 

majority of the new and revised updates for 

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strengthening the seed guidance.

 Additional clarification is needed, 

write this down, on additions to 4.1.6, 

4.2.1(b)(3) and (b)(6) and in Section 4.4.4, we 

think you should remove the reference to 

transplants and minor edits are also needed in 

(a). Our written comments detail our requests 

for clarification. 

 Paper pots. MOSA certifies 

approximately 500 vegetable and transplant 

growers. While we support the inclusion of paper 

pots to the National List for use as a crop 

production aid, we also think the NOSB process is 

sound, and are looking forward to seeing the 

results of the technical review on the fibers.

 In the meantime, we'd like clear 

guidance regarding the approval of new products, 

but similar to those that we are currently 

allowing. I'll end by stating our continued 

support for NOSB process and the work you do, and 

to the program we'll add our voice, which is 

representative of several hundred small family 

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dairy farms to the many comments you've already 

received. Please move forward with a final rule 

on origin of livestock.

 Sue, MOSA does not allow organic dairy 

animals to be removed from organic production and 

then later returned to the organic herd. Thank 

you. I'm happy to answer any questions you have.

 CHAIR BEHAR: Thank you. Any 

questions from the Board? As usual, MOSA is very 

complete and thorough I've noticed in the 

comments. 

 MS. DeMINTER: Thank you.

 CHAIR BEHAR: Okay. Next up is 

Winston Rost.

 MR. ROST: Rost, yeah.

 CHAIR BEHAR: And Kyla Bedard is on 

deck.

 MR. ROST: My name is Winston Rost. 

I'm a certification specialist for Vermont 

Organic Farmers, the USDA accredited certifier 

owned by the Northeast Organic Farmers 

Association of Vermont. We certify over 700 

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organic producers in Vermont. 200 of those are 

maple producers. Washington does apples; we do 

maple syrup.

 I would like to thank the Board for 

all of its hard work and for the opportunity to 

give comment today on two agenda items. We 

support -- number one, we support the 

Subcommittee's work toward genetic integrity 

transparency of seed grown on organic land.

 We appreciate that the Subcommittee 

has expressed the tolerance levels for seed 

contamination will not be created at this time. 

This proposal will be most successful if used as 

a tool for collecting information and determining 

levels of contamination, as opposed to being a 

means to determine compliance.

 We do not feel that this proposal, if 

implemented, would be a burden to organic 

producers in Vermont. However, we do not have a 

significant group of producers who grow organic 

corn. In addition, the suppliers of organic corn 

seed in the state have multiple varieties of 

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organic feed corn available to producers.

 Number two, we appreciate the NOSB 

starting the process of developing specific 

criteria and questions for assessing cleaning and 

sanitation materials used in organic production. 

Cleaning and sanitation materials are an 

important tool for organic processors, crop and 

livestock producers.

 We also support the Subcommittee's 

request for a technical review of cleaners and 

sanitizers. At the same time, it is essential 

that certifiers and producers have guidance about 

how to review and use these materials. We 

support the ACA's practical comments and feel 

their suggestions will help to improve the 

discussion document. Thank you.

 CHAIR BEHAR: Thank you. Any comments 

from the Board? All right, thank you very much. 

Next up is Kyla Bedard with David Moore on deck.

 MS. BEDARD: All right. My name is 

Kyla Bedard. I'm a certification specialist for 

dairy for also Vermont Organic Farmers or VOF. 

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I'd like to thank the NOSB for all of your hard 

work and opportunity today to comment on paper 

pots and use of excluded method vaccines. 

 We appreciate the NOSB adding paper 

pots to their work agenda in a timely manner. 

VOF continues to stress the importance of this 

product to small-scale vegetable producers in 

Vermont. We request that the NOSB reviews this 

material that virgin paper be included as part of 

that review.

 This may mean requesting that the 

technical review includes virgin paper as well as 

recycled paper. If additives such as synthetic 

fibers are concerned, then allowing virgin paper 

may offer better control over what additives the 

paper contains.

 In addition, we ask that the NOSB take 

a practical approach to reviewing this material, 

understanding that paper is already widely used 

in organic systems such as mulch and pots. 

 We agree with the Subcommittee's 

emphasis on the importance of vaccines to organic 

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livestock producers. Vaccines play a critical 

role in preventing disease. We believe that the 

current regulations prohibit the use of vaccines 

produced with excluded methods, unless they are 

on the National List.

 Currently, VOF reviews all the 

vaccines used by our producers to determine if 

those vaccines have been produced with excluded 

methods. We have not found that the livestock 

producers we certify, primarily dairy and smallscale beef, pork and poultry operations, have 

needed a vaccine produced with excluded methods.

 However, we do not certify large 

poultry or pork operations and we understand that 

there may be vaccines needed by livestock 

producers in other parts of the country that are 

not needed in Vermont. Therefore, we support the 

change proposed by the Subcommittee that would 

allow producers to use vaccines made from 

excluded methods when alternatives are not 

commercially available.

 For clarity, we suggest using a 

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definition of commercial availability that is 

similar to seeds and planting stock, quality, 

quantity and specific to a disease or health 

issue. Documentation of commercial availability 

could include statements from a vet and 

statements from suppliers of vaccines.

 To close, since we have Dr. Tucker's 

ear, VOF would like to stress the importance of 

implementing the final rule of origin of 

livestock. We cannot delay on this and further 

negatively impact our small dairy farmers. I 

hear of changes in the industry. If anything, 

the biggest change has been this drastic growth 

in western dairies enabled by the NOP's inaction 

to publish the final rule. 

 We greatly appreciate the opportunity 

to express our concerns, and thank you all for 

your time. Any questions?

 CHAIR BEHAR: Any questions? Ashley, 

Dave. Okay, Ashley.

 MS. SWAFFAR: So since you've been 

kind of doing the ground work of asking on 

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vaccines, are you seeing them as difficult for 

producers to gather that information if vaccines 

are available? Or if vaccines are made from 

excluded methods or --

 MS. BEDARD: We actually -- well, our 

materials -- I don't do the materials review, but 

we do have a staff person dedicated to that, and 

they're actually doing all the reviewing. We 

don't require the producer to do that. If there 

is a vaccine that we have not approved, then they 

can -- and they'd like to use it, then they are 

allowed to request us to review it. Does that 

answer it? Go ahead.

 MS. SWAFFAR: So your staff inspector 

or your staff reviewer is making the 

determination if the vaccine is genetically 

modified or made from excluded methods or not?

 MS. BEDARD: Yeah.

 MS. SWAFFAR: What information do they 

use?

 MS. BEDARD: That's a good question, 

and I'm not the person to answer that. But I can 

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have them be in touch.

 MS. SWAFFAR: Please do.

 MS. BEDARD: Yeah.

 CHAIR BEHAR: Okay. Next is Dave.

 MR. MORTENSEN: Yeah. Kayla, I just 

wanted to thank you for your directing some 

comments at the regional diversity across the 

country, you know. It's really striking when we 

look at some of these things for a certain region 

or a certain scale of operation. It's helpful to 

put the comments into context and that was 

helpful in your written comments and in what you 

said. So thanks.

 MS. BEDARD: Yeah. 

 CHAIR BEHAR: Thank you. 

 MS. BEDARD: Thank you.

 CHAIR BEHAR: Next up is David Moore, 

with Dolana Blount on deck. And remember there 

are animals over there on the table.

 MR. MOORE: Good afternoon. Thank you 

for this opportunity. I'm Dave Moore. I'm a 

California licensed agricultural pest control 

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advisor and qualified applicator. I work for 

Neudorff, and I'm here today to encourage you to 

vote for the continued listing of ferric 

phosphate as a molluscicide on the National List.

 Your votes are simply yes or no on a 

simple question, does ferric phosphate continue 

to meet all the required criteria for continued 

listing? Simple question, simple answer, it's 

yes. You're not voting on the NOP-compliant, 

OMNI list of finished product or any other 

individual ingredient.

 Ferric phosphate continues to meet all 

the required criteria for inclusion, and no new 

information has emerged since the last sunset 

review to the contrary. Therefore, there is no 

reason under the law or the regulations to vote 

to delist. 

 The Crops Committee raised four 

specific questions in their request for comment. 

Our detailed answers are posted in posting of 

4/3/2019. Here again, no new information. The 

unfounded and unattributed assertion that ferric 

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phosphate is somehow more toxic than previously 

known is untrue. No citation or verification is 

offered and the Committee notes the request for 

comment on either document.

 This assertion is further refuted by 

EPA required toxicity testing of all pesticide 

products. The LD50 of Sluggo is in excess of 

5,000 milligrams per kilogram, has always carried 

a caution signal word on the EPA label. Of 872 

comments posted, only 15 contained the word 

"ferric." None of those came from unaffiliated 

members of the public.

 They came from accredited certifiers, 

growers and grower groups and trade associations, 

plus Neudorff. Four stakeholders took no 

position. Of eight that did, seven plus Neudorff 

were in support. There was a single comment in 

opposition from the advocacy group Beyond 

Pesticides. It cited discredited arguments that 

had been before this Board for review and 

rejection three times in the last decade.

 Further, Beyond Pesticides in their 

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own paperwork attributed zero categories of harm 

to ferric phosphate use in organic agriculture. 

Ferric phosphate continues to meet all the 

required criteria for inclusion on the National 

List. Please vote accordingly.

 I'm David Moore. I work for Neudorff, 

and I appreciate your time and attention. Thank 

you very much.

 CHAIR BEHAR: Any comments from the 

Board? All right, thank you.

 MR. MOORE: Thank you.

 CHAIR BEHAR: Next up is Dolana 

Blount, with Brian Baker on deck.

 MS. BLOUNT: Thank you. My name is 

Dolana Blount and I'm with PURE Bioscience. 

Thank you for the opportunity to again present 

the Board with comments supporting the addition 

of silver dihydrogen citrate, referred to as SDC, 

to the National List.

 I defer to the written comments 

submitted by PURE Bioscience earlier this month 

and other comments during the webinars to support 

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our position that SDC is not nanotechnology, that 

the concerns over anti-microbial resistance do 

not outweigh the benefits from SDC's use, and 

that the concerns over environmental impact have 

been addressed by the EPA and FDA in their 

reviews of SDC. 

 I want to focus on the essentiality of 

SDC in organic processing. Including SDC for use 

as an optional anti-microbial intervention will 

support processors and effectively reduce the 

pathogen populations on inanimate and food 

surfaces, and can help mitigate the potential for 

resistance through rotation practices and 

alternative intervention steps.

 PURE is aware of many processors who 

are eagerly anticipating the ability to use SDC 

in organic processing. For a variety of reasons, 

many of these processors are unable to comment 

publicly, but their desire to have SDC allowed 

for use is strong.

 One major produce processor has been 

investigating the use of SDC on non-organic fresh 

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cut leafy greens during processing. The results 

demonstrate that SDC effectively yields nondetectable pathogen concentrations on treated, 

processed produce. These results currently are 

being validated in studies coordinated with the 

U.S. government.

 This level of pathogen reduction is 

not common in fresh cut produce, and represents a 

significant advancement in food safety. Another 

processor struggling with the negative effects of 

acidified chlorine on strawberries was planning 

to discontinue strawberry processing, in order to 

protect their brand reputation.

 Using SDC as an alternative to 

acidified chlorine, this processor observed twice 

the pathogen reduction and was able to use half 

the amount of chemistry to achieve the result. 

 In regard to surface sanitation, we 

are frequently contacted by organic processors 

who want alternatives to PAA and chlorine 

compounds, citing worker safety concerns due to 

off-gassing and employee complaints as their 

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greatest concern, followed closely by the damage 

and deterioration to their equipment from these 

chemistries.

 SDC is odorless, does not off-gas and 

is less corrosive. Moreover, unlike other hard 

surface sanitizers, SDC meets the advocacy 

performance standards for disinfection and 

sanitization at the same use level. Processors 

currently using SDC for surface sanitizing on 

their non-organic lines wish to get the same 

benefit on the organic lines and have a cohesive 

process in their sanitation and FSMA compliance 

plans.

 It's important that this level of 

protection is available to both organic and 

traditional processors. We remain confident that 

SDC is an essential tool to supporting organic 

processors in meeting food safety goals, and will 

be a valuable addition to the National List.

 I encourage the Board to approve the 

addition of SDC to the National List as an 

allowed substance at this meeting without further 

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delay. Thank you for your time and all of your 

dedication to this program. 

 CHAIR BEHAR: Thank you. Questions, 

comments from the Board? Emily.

 MS. OAKLEY: Hi. Can you help me 

understand whether some processors who hesitate 

to comment on this material, because I find that 

confusing?

 MS. BLOUNT: I do too, because when 

they contact us and when do you have organic and 

are you working on it, we give them the 

opportunity and they have corporate policies 

against making public comments that could 

potentially seem as though they were endorsing 

one thing over another.

 Contrary to what they want, but that's 

their corporate policies. That's what they're 

sharing with us.

 CHAIR BEHAR: Anyone else? Tom, 

Ashley.

 MR. CHAPMAN: Thank you for your 

detailed public comments and for addressing items 

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specifically raised in our proposal. I know you 

didn't plan to comment on it in here and other 

folks commented on the webinars. But can you 

talk a little bit about concerns raised about 

anti-microbial resistance and why you don't think 

that's a concern that should prevent this 

listing?

 Also, I want to know if you in the 

approval or in the application or manufacturing 

of this process, in your sale or manufacturing of 

this, has it been -- or the development of it, 

have you ever been contacted by CDC, World Health 

Organization, American Medical Association or any 

other medical community that's, you know, 

struggling with the challenge of anti-microbial, 

antibiotic resistance, and have any concerns 

about your application of this material been 

raised?

 MS. BLOUNT: I've got both of your 

questions. I'll start with the last one. So 

anti-microbial resistance that's been raised in 

the comments recently and just the literature 

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that's out there, it's stemming from treatments 

through wounds, persistent wounds that are 

treated with silver-impregnated bandages and 

topical applications.

 These applications are designed to 

release very small amounts of silver over time. 

But that is also not a controlled release. For 

bandage as an example, the wound juices, for lack 

of a non-technical term, will interact with the 

bandage and then release silver ions. But it 

could release a couple of PPM, it could release 

more, it could release less.

 These are where there have been some 

clinical isolates of resistance. But what 

They've also found in research is that it's 

transient resistance, and when silver is removed, 

they don't continue to express those genes. No, 

I have not been, the company has not been 

contacted about resistance or concerns with 

resistance whatsoever in regard to SDC.

 The beauty of SDC is that yes, silver 

ion is the primary active ingredient, but it is 

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coupled with citric acid, and the citric acid is 

a food source. It's almost blinding the silver 

when it's applied, and so organisms will bring it 

in.

 So while silver has multiple modes of 

action, resistance is difficult for organisms to 

obtain and maintain, but the citric acid as a 

side component also helps reduce that potential 

for development.

 MR. CHAPMAN: And then on the 

nanomaterial front, you know, we have a previous 

recommendations that hasn't been adopted formally 

or it will not be adopted formally given the 

NOP's response to it, stating our concerns with 

nanomaterials, engineered nanomaterials being 

used in organic applications.

 This has been codified in several 

international organic standards to an extent that 

it hasn't happened here domestically. Is there, 

is there language you could recommend if this 

material went back that -- because you claim this 

is not a nanomaterial that could help mitigate 

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the concerns of the community that this isn't a 

nanomaterial, that nanomaterials would be 

prohibited, you know. 

 We attempted that in the language the 

first time that we were told would not allow this 

material. So is there some other compromise 

language that PURE Bioscience could recommend to 

mitigate that concern?

 MS. BLOUNT: So yeah. The challenge 

with what you proposed, and I appreciate what you 

are trying to do, is that you assigned a particle 

size constraint to a technology that has no 

particles. And so you can't prove a negative, 

and so then there's a challenge for certifiers to 

say that folks that are using it fall within that 

limitation.

 You could say that it contains no 

particles, you know, that silver dihydrogen 

citrate, which only my company makes. So we 

could say that that makes no, contains no 

particles whatsoever. The challenge then would 

be and I would ask you, the Board and, you know, 

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certifiers in the room, what would then be 

acceptable proof to a certifier so that a 

processor could use that and show that it doesn't 

contain particles?

 We've shown you that. I have given 

you imaging and I've given you dynamic light 

scattering and if that data is sufficient for the 

product as a whole. But having to run those 

tests on every batch every time is not -- that's 

prohibitive.

 MR. CHAPMAN: The general practice for 

determining compliance, the annotation 

requirements on National List items is an 

affidavit from the seller or the manufacturer of 

the item --

 MS. BLOUNT: Perfect.

 MR. CHAPMAN: That states compliance 

with, with what's been required.

 MS. BLOUNT: So I think some sort of 

annotation that it is not nanotechnology and 

contains no particles is acceptable.

 MR. CHAPMAN: Okay. That would be 

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something you'd be willing to work with us on if 

this material is brought back in?

 MS. BLOUNT: Certainly, absolutely. 

Great. Thank you all.

 CHAIR BEHAR: Oh, sorry. Next up is 

Brian Baker, with Beth Unger on deck, and then 

after that we will take our lunch break and we'll 

see how long that will be, depending on what 

happens to the next two speakers.

 MR. BAKER: Thank you. The National 

Organic Program, members of the NOSB, Madam 

Chair, thank you for the opportunity to provide 

public comment to the National Organic Standards 

Board. I'm Brian Baker, president of IFO North 

America. IFO Organics International is the 

organic agent of change for true sustainability 

in agriculture value chains and consumption.

 We are working on behalf of its 

membership, the global organic movement in over 

120 companies, countries sorry. IFO North 

America is a regional body of its members in the 

United States, Canada and the English-speaking 

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Caribbean. Our purpose is to educate the public, 

serve as a forum to exchange ideas, engage in 

activities to advance organic agriculture and its 

principles.

 IFO North America wants to speak to 

you on three topics today, fraud in international 

trade, harmonization of international standards 

and organic 3.0. IFO has been engaged in 

protecting organic integrity for over 40 years. 

Fraud is a global issue. It's nothing new. It's 

been around for as long as there's been organic.

 International cooperation through 

public-private partnerships are essential to 

protect organic integrity. We're pleased to hear 

the USDA is working with the International 

Organic Accreditation Service on country 

commodity studies and organic supply chains.

 IFO offers help in providing greater 

transparency in international supply chains and 

data sharing. In making recommendations and 

setting standards, the NOSB and NOP should be 

aware how our trading partner standards compare 

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to the U.S. Harmonization is important to avoid 

trade distortions. 

 The organic market provides many 

opportunities for small holders in developing 

countries. Some of them are trading with both 

the -- or having products shipped both to the 

U.S. and Europe. Farmers are required to comply 

with all standards. The international reputation 

of USDA is undermined when it falls short of 

international norms.

 No other standard permits hydroponic 

production. IFO's standards require terrestrial 

plants to be grown in soil, explicitly prohibits 

hydroponic systems. There's a global consensus 

that organic animals are born and raised on 

organic farms and managed organically from birth.

 IFO has published a position paper on 

compatibility of new genetic techniques. We 

advise precaution. The NOSB plays a crucial role 

in protecting organic integrity. However, you 

can't do it all and you can't do it alone. Thank 

you. 

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 CHAIR BEHAR: Questions from the 

Board? Thank you very much, Brian. Next up is 

Beth Unger.

 MS. UNGER: Where's your cow? It's 

appropriate. Thank you and I'm not going to keep 

you from lunch for very long. But I do have a 

few things I want to say, not too much about 

what's on the agenda so far are two things. 

 First of all, I want to approach the 

NOP with our sincere appreciation for your 

efforts in the dairy compliance project. I think 

that's a critical project. We need to find a 

clear path to clear and consistent application of 

the final rule. 

 I don't believe that we're there, and 

it's creating a lot of difficulties within the 

entire community, much of which you've heard over 

the last two days. So one of the areas about --

that really excites me is I believe that you're 

setting a great path to ensure that certifiers 

are perfectly clear on what it takes to verify 

compliance with the pasture rule for all 

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certified operations, you know.

 This is an area that is very important 

to us. Also, I'm going to echo the same 

sentiment you've heard over and over and over 

again, and that is the importance of getting a 

final rule on the origin of livestock out there. 

It's one of those very inconsistent areas which 

really isn't a part of you doing a compliance 

project but --

 And staying on that same theme of this 

clear and consistent application of the rule, 

it's really disheartening to see things like the 

organic livestock and poultry practices final 

rule withdrawn. That said, I am so happy that 

the Accredited Certifiers Association took this 

up and took it in their own hands to create a 

best practices guide that really was more or less 

an implementation of that.

 It was not a new regulation. It was 

never intended to be a new regulation. It was 

only clarified the existing regulation and never 

should have been withdrawn. So I applaud the ACA 

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for doing that work because this is the industry 

saying we want this to be equal across all areas.

 About your agenda items, our opinion 

is iodine does not need MPE. I believe the 

conventional dairy industry has moved away from 

iodine with MPEs, and they have MPEs puts organic 

products that was at risk because those do show 

up in tests when you're exporting dairy products. 

So yes, they have to get rid of the MPEs, and 

that's all I have. Let's go to lunch.

 CHAIR BEHAR: Ashley, Tom.

 MS. SWAFFAR: Following up on that, we 

heard earlier that if we were to annotate it, 

there would be a little bit of concern of supply 

of iodine without MPEs. Do you see that being an 

issue.

 MS. UNGER: I do not.

 MS. SWAFFAR: Thank you.

 CHAIR BEHAR: Tom.

 MR. CHAPMAN: Once I see that fish oil 

before, we all have some fish for lunch. You 

guys commented in support of fish oil, noting 

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that it supports nine million pounds of milk 

sales?

 MS. UNGER: Uh-huh.

 MR. CHAPMAN: Do you have an idea of 

what that equates to in terms of farms supported?

 MS. UNGER: Well, it depends upon the 

size of the farm. But --

 MR. CHAPMAN: Average, bigger?

 MS. UNGER: You know, that's an 

interesting question. I cannot give you an 

answer to that, and I, you know, kind of push 

back on you to say that yeah, it supports some 

level of milk supply that, you know, is in dire 

straits right now. So you don't want to take 

products off of the shelf that are, you know, 

utilizing organic milk.

 And also you don't want to take away 

the choice of consumers who want to purchase, you 

know, a product that has this addition to it. 

And it is on 606, which has the commercial 

availability clause, and since we have no 

aquaculture standards, you can't find it 

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organically.

 MR. CHAPMAN: So you hit my second of 

three questions, which is that you don't think 

it's -- given what's coming on the dairy market 

right now, given what we've heard these last few 

days, it's not the right time to take dairy 

products out of the marketplace?

 MS. UNGER: Yes.

 MR. CHAPMAN: And then is -- in your 

products that contain fish oil, how are they 

labeled? Is it clearly labeled? Does the 

consumer know what they're buying?

 MS. UNGER: Absolutely.

 MR. CHAPMAN: Thank you.

 CHAIR BEHAR: Anyone else? Okay. So 

we will take a break for lunch, but I first want 

to say that Amy van Saun, Dave Carter, Nathan 

Frizzell and Marshall Talbot will be all on deck 

in that order. So you think about, you know, how 

close you are going for lunch, so you can be back 

in time. We will get back at 1:45 p.m.

 MALE PARTICIPANT: And a reminder to 

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everybody. We've got a reception from WSTA and 

Tilth Alliance tonight on the -- I forgot my crib 

sheet -- fourth floor in the Northwest room. 

There's flyers out front to remind you of that. 

Thank you. 

 CHAIR BEHAR: Fourth floor reception 

tonight.

 MALE PARTICIPANT: In this building, 

yes.

 (Whereupon, the above-entitled matter 

went off the record at 12:36 p.m. and resumed at 

1:47 p.m.) CHAIR BEHAR: So I do want 

everyone to know that we are actually right on 

time at this moment. So if we all behave, that's 

the caveat, we can pretty much stay on time. 

There are a few people on the waiting list, and 

I'm hoping to get to them. So that's why I want 

to start on time. 

 Looks like we have enough Board 

members present to start the public comment. So 

first up is Amy van Saun with Dave Carter on 

deck. 

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 (Pause.)

 CHAIR BEHAR: Amy went somewhere for 

lunch and didn't get back. I did see Dave 

Carter. Dave? Oh. Are you ready go, and then 

we'll come back for Amy later.

 MR. CARTER: Madam Chair, members of 

the Board and Dr. Tucker, I don't see her here 

yet but --

 CHAIR BEHAR: Not yet.

 MR. CARTER: My name is Dave Carter. 

I wear a number of hats literally and 

figuratively. I'm Director of the National Bison 

Association. I am a bison rancher. I am the 

principal in Crystal Springs Consulting Company 

and a NOSB survivor. I'm here today as a 

consultant on behalf of Merck Animal Health. But 

before I get into their comments, I want to say 

two things from a principal standpoint. 

 A is to thank you for all of your 

work. Been there, done that, know this is a 

tremendous investment of time and energy, and I 

appreciate all that you do on behalf of the 

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organic community. I also was pleased to hear 

the words "pet food regulations" uttered at the 

beginning of this meeting. 

 Unfortunately, they were uttered in 

connection with unfinished business, and it's 

only been 15 years since the Secretary of 

Agriculture said that there ought to be pet food 

regulations, and those have been written and they 

need to get over the finish line. 

 Now on behalf of Merck, Merck are the 

folks that brought us fenbendazole, which we were 

pleased was put on the National List in 2012. We 

think it needs to stay on the National List. 

It's a much better tool, much more eco-friendly 

to earthworms and dung beetles than what was on 

the list at the outset.

 It's interesting to note though in 

your Board packet on page 68, when there are the 

comments, the report from the Subcommittee, I 

just want to read. It says "Parasiticism may be 

the weakest link in the organic livestock 

production. Outbreaks of disease due to nematode 

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parasites can happen even in well-managed 

flocks."

 It's interesting the use of the word 

"flocks" when parasiticides are allowed in dairy 

stock and fiber animals. And as one of the 

previous commenters said this morning in response 

to a question about scale in poultry production, 

he said one of the biggest barriers to getting 

birds out on pasture is the parasite load.

 Well, I just want to do a little 

foreshadowing that Merck has a product, 

fenbendazole product that is made for poultry, 

and we are in the process of preparing a petition 

that will be coming before the program and before 

you to allow fenbendazole as an emergency 

treatment in organic laying flocks.

 So we want to provide those pasture 

producers with another resource. Again thank you 

very much, and I'm here to answer any questions, 

and I'm a little disappointed though. I don't 

see a bison over there so --

 CHAIR BEHAR: I was just about to 

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apologize, yeah. And by the way, sheep are in 

flocks. 

 MR. CARTER: Okay.

 CHAIR BEHAR: Okay. Any comments or 

questions from the Board for Dave Carter? Always 

wonderful to see you Dave. 

 MR. CARTER: Thank you.

 CHAIR BEHAR: Okay. Is Amy van Saun 

here yet? Okay. Nathan Frizzell? I see 

somebody walking, and then up on deck is Marshall 

Talbot.

 MR. FRIZZELL: Good afternoon. My 

name is Nathan Frizzell, the Director of 

Operations for our family owned calcium 

supplement and sun shade product manufacturing 

company, Full Measure Industries. 

 We manufacture two products, Full 

Measure Cow, which is a ground applied calcium 

supplement, and Reflections, which is a calciumbased foliar applied shade product and field 

temperature regulator.

 Calcium is widely used in agriculture, 

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and is considered the number four production 

ingredient behind N, K and P. Calcium is an 

essential building block for cellular growth and 

for cellular development. It's also important in 

absorbing and the availability of other minerals 

and nutrients into plants. 

 I'd like to respectfully request that 

calcium acetate be added to the National List of 

approved substances for organic production under 

vitamins and minerals and as a production aid. 

Calcium acetate is naturally occurring in nature, 

and although it's been discussed as being listed 

as a synthetic, it is not artificial and I'd 

remind you that there is -- there are no perfect 

materials.

 The formulation of calcium acetate in 

nature is a process whereby non-soluble calcium 

becomes available and soluble through microbial 

activity and through the introduction of acidic 

materials. The EPA has placed calcium acetate on 

the safer chemical ingredient list for processing 

aids and additives, as a safer replacement for 

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traditional ingredients.

 EPA has verified calcium acetate to be 

of no concern based on experimental and model 

data. EPA has also identified no toxic end 

points for birds, plants, aquatic or soil 

organisms. The joint FAO/WHO Export Committee on 

Food Additives has authorized calcium acetate for 

human consumption without limitation.

 The FDA has also granted calcium 

acetate GRAS status as a sequestrant and direct 

food substance. Other calcium options that are 

approved for organic production have limitations. 

Calcium chloride is toxic to plants and animals 

in small quantities. Calcium nitrate is a good 

way to provide calcium and nitrogen plants, but 

it's not recommended for finishing crops as the 

calcium promotes growth which is not desirable.

 I have some independent research 

supporting calcium acetate uptake and some Full 

Measure industry-sponsored research supporting 

the efficacy of both Full Measure Cow and 

Reflections calcium acetate as a shade product 

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and as a field temperature regulator.

 It's to benefit for organic growers as 

pruning and shade gloss have their limitations. 

I thank you for the opportunity and welcome any 

questions.

 CHAIR BEHAR: Steve.

 MR. ELA: So obviously in the write-up 

on calcium acetate, I was the lead on that. I 

mean it's obviously a pretty benign product, no 

dispute on that. 

 MR. FRIZZELL: Sure.

 MR. ELA: I think the biggest issue I 

see is we have not heard from a single grower in 

the public comments. I think there were only 

three public comments in total on the material in 

this docket. It's really hard to document 

essentiality that growers need and want this when 

we don't hear from any growers, and we've had 

other petitions before us that we voted down 

based on that.

 So that's a tough one for me, and I 

guess would you like to comment on that? 

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 MR. FRIZELL: Sure. Well, we've got 

some organic watermelon growers who have 

requested an organic product, and I can get you 

some statements from them. But like I said, 

we're a relatively small company. We're just 

getting started so --

 MR. ELA: Yeah. I think our -- I mean 

and they may be out there, but we haven't heard 

of them. So that, I mean that like say for me, 

that makes it just really hard to say people 

really want this when there's just nothing in the 

docket that shows that. So I just want to give 

you that heads up.

 CHAIR BEHAR: Anyone else on the board 

have a comment or question? Thank you very much.

 MR. FRIZZELL: Thank you.

 CHAIR BEHAR: Okay. We'll try Amy van 

Saun again. Okay. Marshall Talbot is up, with 

Sandra Mays on deck.

 MR. TALBOT: Well thank you for the 

opportunity to talk today. My name is Marshall 

Talbot. I'm a field man for McDougall and Sons, 

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an apple, cherry and pear grower-packer- shipper 

in Wenatchee, Washington. I'm also a third 

generation farmer. Under my management, my 

family's apple orchard went organic in 2009.

 Growing organic is fun and 

challenging, and some of the tools organic 

growers have are some of the same as conventional 

growers, like these loppers I brought here today. 

And everyone seems to use them a little 

differently, but it gets the job done. 

 But overall, organic growers just 

don't have as much or as full of a tool box as 

some conventional growers, and that's why I'm 

here today, is that some of our important 

integrated pest management tools are on the 

sunset list. 

 So the first one is calcium chloride, 

you know. It's an efficient product. I've kind 

of gone back and forth a little bit on it. But 

recently I found some research that it has 

benefits for post-harvest decay, and that's been 

done by Dr. Sugar, and it's used by most growers. 

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 Another product on the list is 

pheromones. I brought a NoMate CM Spiral that 

was used a couple of years ago. It's a pretty 

small little product. It's used organically and 

conventionally, and you know, darnit if this 

doesn't just really work well. 

 It reduces the amount of sprays that 

are needed for codling moth protection on apples 

and pears, and you know, on the high density 

plantings, you only put one of these guys in the 

top third of the tree every four trees. So 

there's about -- there's not a lot of them per 

acre. They don't affect but beneficial insects, 

but they confuse codling moth, one of the primary 

pests of apples and pears.

 In my opinion, this is a home run tool 

and it would be disappointing if we lost this 

product. Another one is horticultural oil. It's 

a huge part of organic IPM programs for apples, 

cherries and pears. A dormant application of 

this oil is one of our number one things for 

aphid control. 

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 Potassium bicarbonate is used for 

powder mildew control, and that's primarily on 

organic cherries and dang it, growing organic 

cherries is hard, so we need to keep this 

product. Peracetic acid is used in the McDougall 

and Sons packing facility, and it's an important 

tool in the toolbox for a process where we just 

don't have enough tools right to lose a product 

like this.

 I'd like to thank you again for the 

opportunity to talk, and kind of end with a final 

story. Just yesterday my wife and three of my 

kids were out for a drive, and my four year-old 

daughter was looking out the window, and she said 

hey daddy, look at the pear trees. I looked out 

the window and sure enough those were pear trees. 

So fourth generation, here we come so --

 CHAIR BEHAR: Okay, thank you. Any 

comments or questions from the Board? Steve.

 MR. ELA: I'll just comment it's great 

to have -- a number of you have come. I mean I 

used pheromones. I use oils, all the same 

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things, and yeah they're critical. It's really 

helpful. Even though I don't think there's much 

question about the necessity and that they're --

I mean I can't speak for the Board, but they're 

probably going to be relisted without much 

problem.

 But this kind of comment really helps 

with that process because it shows us, I mean 

just like my comment to the last speaker, it 

shows us yes, these are important. We need to 

continue to have these in our toolbox. So thank 

you for taking the time to come and tell us that. 

That does help.

 CHAIR BEHAR: And put it on the public 

record. That's really important, so those in the 

future can see that yes, there was support for 

these materials.

 MR. ELA: And our process says this is 

a review meeting. Fall meeting this is going to 

come up again for a vote. So I know it's a pain 

to comment twice, but please put those comments 

into the fall again, because that's when the vote 

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comes up. I mean we take these into account too, 

and I know fall's not too busy, but you know, 

positive comments and industry's done a really 

good job on that on these materials. So thank 

you.

 CHAIR BEHAR: Okay, thank you. Next 

up is Sandra Mays with Miles McEvoy on deck.

 MS. MAYS: Good afternoon. I'm Sandy 

Mays. I'm with --

 CHAIR BEHAR: Can you please put the 

microphone closer.

 MS. MAYS: Sure. I'm Sandy Mays. I'm 

a senior associate and partner with Wolf DiMatteo 

and Associates. Wolf DiMatteo and Associates 

serves many clients that use cleaning and 

sanitation materials as required by law to ensure 

food safety. We applaud the Materials 

Subcommittee for lending their support to all 

NOSB Subcommittees in reviewing substances.

 However, we're confused as to the 

necessity and purpose of this discussion 

document. Why question that these substances are 

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essential? Why request technical reviews before 

new or alternative substances are petitioned or 

current materials undergo sunset reviews? Why 

create a new system and framework for reviewing 

substances for the National List when there are 

required evaluation criteria and processes 

already in place, and why introduce the EPA's 

Safer Choice List?

 The evaluation criteria suggested, 

toxicity, persistence, compatibility, ancillary 

ingredients are typical of any National List 

review. The criteria of application and use does 

not apply to other material reviews, and would 

introduce inconsistency to the process. How do 

these criteria relate to the principles of 

organic and the requirements of OFPA and the NOP?

 EPA's Safer Choice List includes brand 

name products used in households and offices, not 

commercial manufacturing and handling operations, 

livestock operations or crop production. The 

formulas are held confidential, which is 

inconsistent with the NOSB petition process. 

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NOSB experience with EPA on the inert ingredients 

list should be considered before relying on 

cooperation with the EPA now.

 Cleaning and sanitation materials are 

constantly changing in this business. Certifiers 

take note in organic system plants for these 

materials, and then review these materials 

whether or not they're on the National List. 

Materials not on the list must be thoroughly 

reviewed. Some tested to zero parts PPM when 

used, with the results recorded, and do not have 

contact with the final product. The system isn't 

broken. We recommend that the Materials 

Subcommittee not continue with this initiative. 

 On another note, we urge you to 

approve the use of pullulan in made with organic 

products. Adding pullulan to the National List 

as a non-agricultural substance allowed for use 

in products labeled made with organic allows the 

existing market established before the 

reclassification of pullulan to continue, and 

brings a substance under the review by the NOSB 

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and the National List sunset process. 

 Last, thank you for volunteering your 

time and hard work.

 CHAIR BEHAR: Any questions from the 

Board? Thank you.

 MS. MAYS: Thank you.

 CHAIR BEHAR: Next up is Miles McEvoy 

and Jessica Walden is on deck.

 MR. McEVOY: Hello. I'm Miles McEvoy. 

It's really fun to be on this side of the table. 

Thank you for all the work that you do, amazing 

work that you do. A lot of people I don't think 

understand the depth of work that goes into all 

your deliberations between meetings, all the 

countless conference calls and deliberations that 

you have. So really quite a testament to the 

organic community and you guys are doing great.

 So I'm Miles McEvoy, former Deputy 

Administrator of the National Organic Program. I 

have a consulting business called Lacewing 

Auditing and Consulting. What I do is do 

internal audits of certifiers in different 

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places. I do training and do assessment of 

supply chains.

 So a lot of fun work. It's great to 

be working in this community and helping to 

improve the systems. I want to -- I have a few 

different comments. One is I want to praise the 

National Organic Program and Jenny Tucker in 

particular for all the work that they've done. 

They've done amazing stuff over the last few 

years.

 If you look at the enforcement stuff 

that NOP is doing, oversight of certifiers, the 

new training system that is being launched, 

really, really important stuff. The Organic 

Integrity Database continues to get better. So 

there's a lot of really great things that 

happening. Always room for improvement, but I 

really think that the National Organic Program 

and Jenny Tucker at the lead really deserves a 

lot of praise for that work.

 I think we forget how lucky we are 

here in the United States compared to other 

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countries in regards to the robustness of the 

National Organic Program and what USDA does to 

protect organic integrity, the amount of audits 

that occur, the enforcement.

 If you compare it to what happens in 

the EU or Canada, we're way, way ahead of those 

control systems. So we have to keep that in 

mind. But we also want to not forget that NOP 

has very limited ability to amend standards. So 

my comments that I submitted to the public record 

have to do with the concept of moving standards 

out of USDA, to form some kind of independent 

commission.

 It could be through the American 

National Standards Institute. You could form 

something like Canada has, the Canada Organic 

Standards Boards which actually has control over 

the standards rather than just an advisory 

committee. You look at all the standards that 

have not been implemented. Pet food was just 

mentioned. Aquaculture, apiculture. A lot of 

things have been written, but there's stuck by 

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USDA's political process.

 So recommend that NOSB should 

recommend an independent standard-setting 

authority that you guys can write a letter, make 

a recommendation to explore that concept to move 

standards forward, because they're pretty stuck. 

They have been for quite a while. 15 years for 

pet food and many years for other things as well. 

So thank you very much.

 CHAIR BEHAR: You're a popular guy. 

Sue, Asa, Steve, Emily.

 MS. BAIRD: Thanks Miles.

 MR. McEVOY: Sure.

 MS. BAIRD: And thank you for putting 

me on and then you leaving. 

 MR. McEVOY: Yeah. That was the 

Secretary, not me.

 MS. BAIRD: Yeah, yeah. I wanted to 

know, I really am fascinated with this idea, this 

concept that you put forth and think it has a lot 

of merit. What would be our step as NOSB to 

implement that or to help that happen. 

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 MR. McEVOY: Well, it would have to be 

changed to OFPA, because these standards are set 

through the organic, or the authorization to USDA 

is through the Organic Food Production Act. So 

it would have to be Congress that would make that 

change.

 So the NOSB has very little ability to 

make that happen, but a recommendation from the 

Board could start the community to think about 

it. I mean there's a lot of work that would have 

to go into it of what makes the most sense, and 

this is a long term concept that should be 

discussed by the community and come to consensus 

of how do we create standards that represent the 

interests of the community five, ten, fifteen 

years in the future, because there's a lot of 

things that haven't happened.

 CHAIR BEHAR: Okay. Next is Asa.

 MR. BRADMAN: Just related comments. 

I'm thinking of like the ASHRAE standards for 

building ventilation or there's any number of 

organizations that set standards for operating 

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systems.

 MR. McEVOY: Exactly.

 MR. BRADMAN: But I'm always concerned 

with those about accountability and who gets to 

make the decisions, and how would they be able --

how would it function independent of the 

political system we have, and could we end up 

with the same situation? So again like Sue, this 

is a very interesting idea, but I'm wondering how 

it would -- how would it move forward or how 

would there be accountability?

 MR. McEVOY: Yeah. Well, I think you 

would need to explore a couple of different 

models. One would be to have a federal organic 

commission that had the regulatory authority to 

set standards. 

 The other would be through more of a 

private standard-setting body like the American 

National Standards Institute that is in the 

business of setting standards with stakeholder 

involvement.

 There would still be politics 

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involved. There would still -- you'd still have 

to figure out the whole governance of who gets to 

decide what the standards are. So that wouldn't 

go away, but at least you'd be able to -- to be 

able to establish standards that the community 

wants, and not have them repealed like your 

organic welfare standards or just stop completely 

like origin of livestock, or have standards 

written and not implemented like pet food and 

apiculture and aquaculture.

 CHAIR BEHAR: Steve.

 MR. ELA: Miles, somebody asked me 

earlier and actually I've already asked you this 

question privately. But I just -- again from the 

record, they said what are other examples of 

groups that would have federal rulemaking, I mean 

kind of rulemaking capability and federal 

enforcement, but not direct residing within the 

agency and in that political structure? Are 

there other examples in government of groups like 

that?

 MR. McEVOY: Yeah. I think that's 

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where there's research -- study that needs to 

happen. The Federal Trade Commission would be 

something to look at because they enforce 

standards that are not -- for consumer protection 

that are not necessarily codified as much. 

 The NOP did do some work with the FTC 

for organic enforcement of non-agriculture 

products. Well, for textiles and products like 

that. So there are some concepts that could be 

explored. So I haven't done the research to be 

able to answer that question in any depth, but I 

think it's worthwhile looking at what those 

options are and whether there is a model that 

would serve the community better than the current 

system. 

 CHAIR BEHAR: Okay, Emily.

 MS. OAKLEY: I found your letter very 

interesting as well, and have had some thoughts 

as well about the difficulty of housing a 

standards body within a government system. But I 

was curious to note that you thought that 

enforcement should stay with USDA, and you also 

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said that in your verbal comments as well.

 I'm curious if you think there's ever 

a conflict in terms of interpreting the standards 

within USDA and then enforcing them, or if you 

think there might be room for that to also move 

with the standard board as well.

 MR. McEVOY: Yeah. Well, I think 

looking at the Canadian model would be a very 

good thing to do, because they have the Canadian 

Organic Standards Board, which is a lot larger. 

I think it's about 40 members. It represents 

different sectors as well as different parts of 

Canada that serve on the board.

 But then they also have a standards 

interpretation committee that's not -- that's 

part of the Trade and Community more and not -- I 

think there is government representatives on the 

standards interpretation committee, but it's not 

governed by CFIA.

 So that could be a model for the 

interpretations and the standards, that they're 

kind of linked together. And then the government 

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in Canada is the one that's responsible for 

enforcement and oversight of certifiers. Now the 

Canadian model is not good on the enforcement 

side because they don't do much on the 

enforcement side, so that would not be a good 

part to look at. 

 But the standard-setting part is maybe 

a model that could be looked at. I would think 

that the interpretation of the standards should 

be welded with the standards-setting body, and 

not with the body that does the enforcement. 

It's very common for auditors to have a standard 

that they audit to, and so that inspection 

auditing can be a separate regulatory body that's 

expert at doing auditing and inspections and 

sampling and seeing whether or not the standard 

is being met. So I don't think that's -- that's 

not much of a stretch.

 CHAIR BEHAR: Okay, Rick.

 MR. GREENWOOD: How would you think 

this could be funded? Would it be the industry 

funding the group or would it be through federal 

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funding?

 MR. McEVOY: Yeah, it would be through 

federal funding. So for instance, the Federal 

Trade Commission is federal funded. The 

International Trade Commission's federal funded. 

There's like there's a bunch of different small 

federal commissions.

 There's like a marine transport 

commission, and they get, you know, like 50 to 

100 million dollars a year. So it's a sizeable 

amount that they -- the NOP's budget currently is 

15 million. So it's not unreasonable to think 

about a smaller standard-setting body having 

enough money to keep the board functioning.

 That is one of the problems that 

Canada has, is that Canada has not funded the 

Canadian Organics Standards Board, and so they 

haven't been able to meet as regularly as they 

would like. But I would definitely see this as a 

federally funded standard-setting body.

 CHAIR BEHAR: Okay. I have a 

question. I'm wondering if because we're really 

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basically a pretty young program within the USDA, 

if part of that is some of the reason that we're 

playing catch up on so many of our standards, you 

know. When it was first written, pet food, 

apiculture, mushrooms, and a lot of these were 

not necessarily thought of when the rule first 

came out. 

 And as of course as the organic 

industry grows, then we have need for more 

standards. So I'm just kind of wondering if at 

some point we might not need as much standardmaking as we do now, and I'm a little bit 

concerned about the Canadian model. Of course, 

we can always model it however we want because 

there's not a lot of public input into that 

model, or not like this at least.

 MR. McEVOY: Yeah.

 CHAIR BEHAR: So there's some concern 

that I have there. But I'm just kind of 

wondering, going into the future, is this a model 

that works for the future as well as the present?

 MR. McEVOY: Well, I'm not sure 

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exactly what the model is. I think it's a 

discussion about how do you form standards in the 

future when recommendations from this body from 

15 years ago have still not been implemented into 

standards? So definitely there's a problem here, 

right?

 You're making recommendations on 

practice standards, nothing happens. Or they get 

repealed. So you've got to -- I think we start, 

we have to start thinking about a different model 

of creating those standards that are so important 

to the future of the earth, and all our 

livelihoods. 

 So we can't make progress through the 

regulatory process at USDA because of internal 

politics or, you know, they're too busy or 

there's lots of reasons why it doesn't work at 

USDA, but it hasn't been working. So let's think 

about some other models.

 CHAIR BEHAR: Yeah. I think you're 

expressing a lot of the frustration that the vast 

majority of people in the community feel. 

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 MR. McEVOY: Yeah.

 CHAIR BEHAR: I mean I think the 

program is quite responsive on materials.

 MR. McEVOY: Right, exactly.

 CHAIR BEHAR: But in practice 

standards, there's some areas where we're 

suffering because of the lack of implementation. 

Any other questions? Tom.

 MR. CHAPMAN: I just wanted to take 

the opportunity since you resigned your post 

while I was chair and then didn't show up again 

until right now, I'd feel remiss if we didn't 

thank you for your service, your eight years, 

tilting at windmills, trying to move this 

community forward in the USDA. Thank you Miles.

 MR. McEVOY: Thanks Tom.

 MR. CHAPMAN: Thank you very much.

 (Applause.)

 CHAIR BEHAR: Next up is Jessica 

Walden and Garth Kahl is on deck.

 MS. WALDEN: How do you follow that?

 CHAIR BEHAR: You're an NOP alumni. 

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 MS. WALDEN: I chose an ass. I need 

one. I'm Jessica Walden. I work with QAI. I'm 

an organic certifier. Today I'll discuss the 

handler sunset materials, L-malic acid and 

nutrient vitamins and minerals.

 With regards to L-malic acid, I just 

want to stress the importance of the NOSB taking 

the National List materials through the NOP's 

classification of materials decision trees when 

you're doing your sunset reviews. The reason is 

because we certifiers need to know that there's a 

consistent way to use those decision trees. Lmalic acid, several certifiers as well as 

material review organizations, we took malic acid 

through that decision tree. 

 And it's -- the second part of it 

created through defermentation, but it actually 

sort of originates from a synthetic source, the 

one that's commercially available anyway, that's 

used by everybody. So I just -- we just 

recommend that it is looked at again and 

recommend you add it to the National List in 

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605(b) as a synthetic allowed.

 It's the one that was allowed 

initially and the one that was reviewed 

initially, but it's just not from a non-synthetic 

source. 

 With regard to nutrient vitamins and 

minerals, this is a very complex topic. On the 

one hand because of the interim rule published in 

September 2012, organic manufacturers of products 

like infant formulas are currently able to 

provide organic options that are nutritionally 

equivalent to non-organic products, and consumers 

are able to purchase organic product that meets 

the nutritional needs.

 On the other hand, there's 

inconsistent interpretation and application of 

the use of nutrient vitamins and minerals in 

organic products. This causes consumer confusion 

and can weaken the confidence in the organic 

label. 

 Implementing the January 2012 proposed 

rule citing 21 C.F.R. 101.9 and 107.100 and 

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107.10 for infant formula would give the industry 

a specific list of nutrients to reference. 

However, the restriction of only using those 

nutrients listed in 107 for infant formulas that 

are in those CFRs, other than those recommended 

by industry experts, puts organic products in a 

competitive and nutritional disadvantage to nonorganic products.

 The FDA essentially allows anything 

that's GRAS into infant formulas that is backed 

up by scientific research, and the FDA has 

sponsored studies as well to determine the 

nutrient levels found in human breast milk and 

it's changing all of the time. So one way to 

resolve the issues might be to implement the 

January 2012 rule, and in addition create a 

subcategory as a part of the nutrient annotation 

for optional ingredients used in infant formulas 

or products that are unique foods that are often 

the sole source of nutrition for an infant or 

toddler.

 So it's a sub-ingredient on the 

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National List only for infant formulas. Those 

nutrients would have to be repetitioned. 

 CHAIR BEHAR: Okay. Any questions? 

Tom.

 MR. CHAPMAN: Can you finish your 

sentence and then I'll ask the question.

 MS. WALDEN: Sure, I'm going to do a 

run-on sentence, and a task force could be 

developed. There would need to be changes to 600 

as well in terms of evaluation criteria. It's 

much like the pet food proposed rule, whereby 

it's a specific food type. We've got a specific 

consumer base that needs a required nutrient.

 CHAIR BEHAR: Steve.

 MR. ELA: You brought it up, but I 

think a number of public comments noted that, you 

know, we have these fairly useful decision trees 

now, which I certainly use, but that the 

fermentation side of things is, you know. 

 As we've worked through some of these 

other synthetic/non-synthetic, agriculture or 

whatever, suddenly fermentation falls somewhere 

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in between and we keep getting some confusing 

classifications based on that. So I'm assuming 

you would support working on it, on a 

fermentation decision tree. 

 MS. WALDEN: Well, I think the problem 

with some of these materials is that there's 

several -- there's maybe a source material or two 

source materials that come together. Then after 

that there might be fermentation or further 

processes that happen.

 So it's a long, drawn-out process 

that's using a lot of different materials to 

create one at the end of the day. So it's really 

just understanding exactly the source material 

and how that source material is made to begin 

with, and are we starting off with a synthetic 

already.

 Fermentation is probably okay. In the 

decision tree, it's considered biological. So 

it's considered to create something that's nonsynthetic. But you have to look at sort of the 

full chain all the way back to the starting 

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point.

 CHAIR BEHAR: Tom.

 MR. CHAPMAN: Two questions. One, you 

noted -- you're talking foods for sole source of 

nutrition, but you noted infants and toddlers. I 

assume that that could also be extended to 

enteral feeding for adults, medical foods that 

people can't eat?

 MS. WALDEN: Yeah. I mean I would --

I would that possibly, you know, that that's the 

sort of thing that could be looked at if this was 

delved into a little bit deeper. I mean 

something has to happen with this whole nutrient 

vitamins and minerals.

 But I think that those are good, you 

know. That would probably be lumped into the 

sole source feeding.

 MR. CHAPMAN: And as a follow-up, so 

you talk about a need to repetition materials, 

because I guess the chicken and the egg question 

for you, what should happen first. Should we --

should we incur it to the adoption of the 2012 

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proposed rule, or should the materials be 

repetitioned first?

 MS. WALDEN: I think that probably the 

adoption of the 2012 rule as a first -- I think 

that would be a good idea, just at least to get 

the right references for us, because we're 

talking about like the whole organic industry, 

all of the products that are produced. It would 

be great to have the true reference point.

 And then in addition to that, you 

know, sort of -- I suppose I wouldn't, you know, 

we wouldn't -- there would be no enforcement 

action against those that are creating these sole 

source products. But they would have the 

opportunity to petition, to be a grandfathering 

in sort of thing, kind of like what happened with 

sodium lactate and potassium lactate. 

 CHAIR BEHAR: Okay. Thank you, 

Jessica. Next up is Garth Kahl, and then we are 

going to move into the waiting list folks, and we 

are four minutes early. 

 MR. KAHL: So thank you. My name is 

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Garth Kahl. I brought the branching coral this 

afternoon to remind us that synthetic nitrogen is 

a major source of greenhouse gases. It acidifies 

the oceans and hurts coral and causes dead zones 

in the Gulf of Mexico.

 I've been an organic farmer for over 

30 years and an organic inspector for over 22. I 

want to thank sincerely all the members of the 

Board for the sacrifices and daunting commitment 

of time that you make, and I'd also like to thank 

the members of the NOP who are here.

 I think the recent government shutdown 

should make us all aware of how much work you do 

for us, and I hope you got your garden built 

Michelle. 

 So you have my -- already received my 

written comments, and other than making a quick 

plug to list oxalic acid, please vote to list 

oxalic acid, those items, I don't really want to 

talk about those. I want to talk about fraud. 

 As members of the Board consider 

laudable, proposed changes to the NOP rule, I 

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would ask that you please review and reaffirm the 

concept of sound and sensible, while at the same 

time remembering that every National List change 

or additional requirement, no matter how 

laudable, adds significant time to the workload 

of inspectors, reviewers and of course organic 

operators.

 Right now there is a massive supertanker sized threat bearing down on the organic 

movement. That supertanker is named the SS 

Fraud. Fraud is the threat to organic integrity 

that risks swamping our little boat and drowning 

everything we have been working to build since 

the days of Sir Albert Howard, William Albrecht 

and Lady Eve Balfour.

 It is important to remember that the 

amount of time spent on inspection and review of 

organic operations is limited, and it's basically 

a zero sum game. All the hours spent on 

addressing relatively minor issues equate to less 

hours that can be spent performing additional 

mass balance, traceback and feed audits, and 

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cross-checking with other CBs, i.e. activities 

that stand a chance of detecting potential fraud.

 One of my favorite quotes comes from 

the organic revolutionary and pioneer Masanobu 

Fukuoka, author of the book One Straw Revolution. 

He famously said most farmers ask what I need to 

do. I ask what can I avoid doing? I submit that 

the NOSB and the NOP need to ask themselves the 

same questions.

 Where can our allies in government and 

other movements take the lead on things like 

over-harvesting marine organisms and the 

mandatory labeling of GMO vaccines, both for 

human and veterinary use. When I train and 

mentor organic inspectors, they will often hear 

me ask where is the real threat to organic 

integrity here?

 So I would submit that we in the 

organic policy community need to stop and ask 

ourselves where is the real threat to organic 

integrity, and then act accordingly. Thank you.

 CHAIR BEHAR: Comments. Sue? 

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 MS. BAIRD: Thanks Garth. So I'm 

turning that question back on you. Where is our 

realest, most risk factor. 

 MR. KAHL: So I think -- so yeah. I 

think the biggest, the biggest risk is fraud. I 

think the program has come up with some good 

steps to address fraud. I think that intercollaboration between CBs in a real time manner 

to assess sales, to assess volumes, particularly 

large volumes, particularly imports.

 The certification of non-certified 

handlers and elements of the supply chain is 

critical. We need to move forward on those 

issues. Training is obviously important, but I 

think that that's the biggest, that's the biggest 

thing. We can talk about all these laudable 

things all we want, and if we have fraud pouring 

in, our brand, our trademark, our movement is 

swamped. 

 So those are the things I would -- you 

know, if I were -- if I were sacrificing like you 

are, and in your position those are the things I 

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would be highlighting more than, more than other 

laudable things. 

 CHAIR BEHAR: Thanks. Scott.

 MR. RICE: Thanks Garth. You spoke 

very forcefully about oxalic acid being a useful 

tool, and I can appreciate that. But there's 

been a lot of conversation also this week about 

materials with a lack of standards or production 

methods being certified in the absence of 

standards.

 So I wonder if you had any thoughts on 

listing a material for which there's no 

standards. We have a recommendation of course, 

but not a rule.

 MR. KAHL: Right. Well, we have 

guidance of course, which is better than some 

practices and materials that are being certified. 

But I would say that the global situation is that 

there are multiple other international standards 

that certify honey. So the default standard 

worldwide, since most honey is grown in 

Argentina, Mexico and Brazil, organic honey, it's 

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the EU standard.

 So most of the world's honey is 

produced under the EU standard, which permits 

oxalic acid. So we actually currently have, you 

know, a conflict between standards. You have a 

lot of honey that is coming into the U.S., that's 

basically certified under those standards, and 

then there's a de facto equivalency that's taking 

place, and in many cases oxalic acid is a 

stumbling block, because they're using oxalic 

acid because it's allowed under those standards.

 I think that yes, we need to have --

we need to have apiculture standards created. 

But in the absence of that, we need to accept 

that there are very strong apiculture standards 

both in the EU, which we have equivalency 

agreements with, and in the Mexican organic 

standard, which we're moving towards equivalency 

with.

 So by de facto it exists and it is 

coming into the country and it's being labeled by 

the USDA, and the listing of oxalic acid might 

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actually serve to create an impulse to create a 

domestic apiculture, you know, production. 

Because right now, foralmite's (phonetic) the 

single biggest issue for domestic and 

international producers.

 CHAIR BEHAR: Ashley.

 MS. SWAFFAR: So you're saying we 

should list a product to create a group of people 

that will now produce honey to a standard that we 

do not have?

 MR. KAHL: Well again, we have 

guidance that says we can use our existing 

standard. I would absolutely admit that, you 

know, we don't have clear standards. But at the 

same time you can -- again, you can look at the 

existing livestock standard and we have, we have 

guidance that directs us to it. We have guidance 

that directs CBs to prevent contamination and 

there's a lot of evidence, you know.

 A producer can submit an OSP that 

says here's how I'm going to prevent 

contamination. I mean I'm a pre-NOP person, so I 

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believe that you can certify things in the 

absence of a huge standard. We did it prior to 

NOP, and you can think outside the box.

 We have a standard that says they're 

livestock, we can certify livestock. We have a 

standard that says the producer needs to present 

an OSP that clearly delineates how they're going 

to prevent contamination. So they present that 

OSP together with the, you know, the appropriate 

science and there's a lot of science and 

obviously Harriet's aware of this in terms of, 

you know, the area, the forage area for beef.

 So an operator submits an OSP. They 

say here's how I'm going to do this. I mean 

we've done this with a myriad of materials like 

soaps, like, I mean go down the line. We don't 

have specific standards for health and beauty, 

and yet we have shelves full of product that is 

certified NOP to health and beauty.

 I think it's possible to certify 

things using the existing standards, but you have 

to be -- you have to trust that CBs are going to 

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do so in good faith and are going to keep organic 

integrity in mind. And I actually trust CBs. I 

think there's good people working for CBs, and we 

don't have to have a standard for every little 

thing.

 CHAIR BEHAR: Emily.

 MS. OAKLEY: Just to the point of how 

the NOSB spends its time, because you're right, 

there is a limited amount of time. But we're 

also a very diverse organic community, and the 

priorities that we all see are very different. 

But I think one of the cornerstones for organics 

is continuous improvement.

 Now how we all interpret that, of 

course, is very different. But I just want to 

put it out there that I think we're all working 

towards that goal of continuous improvement. How 

that gets interpreted might be differently. But 

I think the NOSB, as it allocates its time on 

various different topics, is working towards that 

goal.

 MR. KAHL: No, and if I can respond to 

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that. I totally agree with you and I think that 

the concept of continuous improvement is key, and 

you all do just amazing yeoman work and it's 

great. We need to have those wider-ranging 

policy discussions. I just would argue that 

right now, we need an all hands on deck alert to 

focus on fraud, and maybe we need to prioritize, 

you know, put aside the other more lofty things 

and basically really focus on fraud.

 Because for the next two or three 

years, until we get this under control, like the 

whole, the whole thing is under attack. 

 MS. OAKLEY: Just a quick response. 

I don't disagree with you. I just think because 

we're so diverse, a livestock producer and a 

dairy producer might say well, the most urgent 

thing right now is origin of livestock. There 

are just so many different entities here that 

it's -- that I don't want us to forget the bigger 

picture.

 MR. KAHL: I agree, and I would say 

that yeah, origin of livestock is right up there 

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with fraud too, and we've heard it this week.

 CHAIR BEHAR: Okay, Dan.

 DR. SEITZ: I can't resist asking this 

question, since you made the sweeping statement 

about whether we need standards in areas that are 

not yet fully regulated. There seem to be very 

diverse potential practices out there around 

hydroponics, and there's a real split in the 

community obviously, or at least on the Board, 

between those who think it's appropriate or not.

 But given that it is a very different 

production system, wouldn't that be one area 

where you would need pretty extensive work on 

standards to define what that actually means in 

practice, for someone in your position who's out 

there potentially certifying these?

 MR. KAHL: Well yeah absolutely, and 

I think that that's -- that's a practice that's 

really run ahead of itself. It's a practice 

where people took the 2010 NOSB recommendation 

and ran with it. And you know, maybe we do need 

at this point some standards to rein it in. 

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 I mean I would just throw out there we 

have equivalency with Canada. Canada has some 

very detailed container growing standards, you 

know. Just throw it out there. A quick 

solution, yeah we'll accept Canada. I mean 

again, there may be reasons why we wouldn't want 

to do that. 

 But there is -- there's a good 

starting place. Well, let's adopt Canada's 

standards on container growing. Would that help 

to salve the wounds of this split? I don't know. 

But it would be a potential starting point.

 CHAIR BEHAR: Okay. Thank you, Garth. 

Amy van Saun? Has she showed up yet. Okay. 

With that, we're going to move to the waiting 

list. We are going to go a little over time, so 

let's try to, you know, stay a little short maybe 

on the questions here. It's Tina Ellor first. 

Lee Frankel will be on deck. Gabriel Flores is 

third, and then there's two more after that.

 MS. ELLOR: I seriously didn't think 

I'd get a chance to address this group. So thank 

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you very much for what you do and this 

opportunity. I don't have any written comments, 

but I would like to say that through working with 

certifiers and the NOP through the years, the 

crop standards are working really well for 

mushrooms. Some day we can have a mushroom 

standard, but there's no urgency there. 

 I want to speak to hydrogen peroxide. 

It's one of the few things that we use, that we 

depend on on our farm. We try not to use 

anything at all, but that's one thing that we do 

find that we need to use to control some diseases 

in our mushroom crops.

 I was going to talk about soil, but 

I'm not going to. I'm going to pass this on to 

the next commenter.

 CHAIR BEHAR: Any questions for Tina? 

Another NOSB alum. Okay, thank you. Lee Frankel 

is here. Thank you.

 MR. FRANKEL: Thanks Harriet. My name 

is Lee Frankel. I'm the executive director of 

the Coalition for Sustainable Organics, and I 

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guess I wanted to share some observations and 

comment on some of the things that I've heard at 

this meeting. They have not been vetted by my 

board or my membership, so they're my opinions, 

but so I do appreciate the time.

 As I enjoyed the analogy to the shot 

put at the high school track meet, and I think 

the container issue is, you know, somebody has 

now come up with Fosbury Flop in the high jump 

and it's something very different the western 

role and the scissors approach.

 And so, you know, it is something 

that's so follows the same rules. It's solely 

kind of human powered, but it's something that 

looks different than what's come before. So you 

know, I am pleasantly surprised at the number of 

people that were actively against containers in 

general are now supporting kind of work to get to 

a rule or a guidance document or some common set 

of language and regulations that we could have, 

to make things clearer.

 I did want to just kind of bring to 

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everybody's attention some of what I saw are 

maybe the problems the last time we attempted to 

address this, particularly just kind of feel like 

the hydroponic and aquaponic task forces maybe 

shortchanged a little bit by kind of not letting 

them get to the point where there could be a 

common set of definitions between the Section 1 

and Section 2 people, and then just even giving 

them a chance to kind of make sure there's 

internal editing consistency within the sections.

 The other portion is a number of the 

proposals the last time around were, in essence, 

kind of de facto bans on the production systems, 

even though they were kind of couched in a way to 

make it seem like a standard. 

 So hopefully we can find a way to get 

some more public input and dialogue, so that 

there's a chance actually to address those items. 

Let's see. I guess I did also want to kind of 

follow up with the -- what was brought up by MOSA 

in terms of kind of the farm system.

 You know, we kind of got into some 

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hypotheticals. But I think if we take things 

back to the farm system, that we're not kind of 

going practice by practice but we're looking at 

just different ways growers can demonstrate that 

they are meeting, you know, conservation of 

resources, cycling of nutrients and doing things 

and taking into account enhancing your 

environment and habitat where those operations 

are located. 

 So I look forward to working with 

Board and answering any questions.

 CHAIR BEHAR: Any questions from the 

Board? Asa.

 MR. BRADMAN: I just have a comment, 

and I communicated this when the discussions were 

going on a couple of years ago and I said it 

earlier today. I think it would be really useful 

to see some written proposals for specific 

standards. We've heard concerns today which I 

share about, you know, covering ground with 

plastic, runoff, soil ventilation, things like 

that. 

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 You know, we grow organic strawberries 

and we seal the ground with black plastic. It's 

not like, you know, there's in-soil methods that, 

you know, are full of these materials too and 

really seal off the soil, at least for much of 

the year. 

 But I think some of the issues that 

have been raised are really legitimate, and it 

would be nice to see some concrete proposals on, 

you know, container systems, hydroponic systems 

that kind of address the concerns that are being 

raised. In my mind, you know, I don't think that 

a container system is wrong, you know, for going 

into a city lot in Oakland that has high lead in 

the soil or, you know, you can't really use that 

soil.

 I don't think they should be denied 

the opportunity to have some sort of organic 

production. At the same time, when we look at 

the goals of the Organic Foods Production Act and 

I think in the heart of people involved in 

organic, it is a little disturbing to me when I 

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see pictures of, you know, acres of ground 

covered in plastic.

 For me, that's also true for 

strawberries in the soil, as much as it is for, 

you know, containers sitting on landscape cloth. 

But it would be interesting to me and I think to 

others to see kind of some really detailed, 

written proposals that -- I think that would 

further the discussion.

 MR. FRANKEL: And I think what could 

really help with that discussion is if we kind of 

flip it around or start it, the first principles 

to say -- and I guess using some, getting into 

some of the hypothetical examples. We talked 

about the herd, and we don't like people leveling 

their land or what the other one, where we have 

to certify the entire operation and, you know, 

just be aware.

 I live in the winter, mean winter 

production area for broccoli and leafy greens, 

and you know, other commodities. It would be 

irresponsible for the organic growers to not make 

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sure it has the exact right grade to use their 

flood irrigation systems so that water is being 

consistently applied across the whole lot.

 I'm excited to see more acres get 

certified each year in the valley where I live, 

but those growers have very large non-organic 

acres as well and they, kind of as the market 

grows and they can develop the market, they 

switch more acreage into organics.

 And so I think, you know, if we kind 

go back to saying well, what are you trying to 

address. Is it, you know, what's your farm 

system, how do you -- where are you inputs coming 

from? Are you taking kind of waste materials out 

of kind of the fish processing and other meal and 

blood meal and giving it a new and higher use 

through finding a home for that in organic 

container production systems?

 And so I know what you're looking for, 

but I think kind of chicken and the egg. If you 

guys can say these are the principles that are 

really important to us, that you don't think are 

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being addressed by certifiers, then we can try 

and come up with other examples that help growers 

say how they're meeting those principles, or 

different guidelines.

 So hopefully there's some way to get 

that established, so we know kind of what's even 

-- what we're trying to address.

 CHAIR BEHAR: Steve.

 MR. ELA: We've heard a lot of public 

comments about the three year transition period 

that all soil growers have to go through, and you 

know, three years of non-use of prohibited 

substances. I mean do you have -- I guess that 

to me is important. Is that a level playing 

field for land that containers or others might go 

on, to go through that same transition period?

 MR. FRANKEL: Yeah. I know we're 

quick on time, so I won't give a bunch of 

stories. I'm going to try to get right to the 

point. But I think if we go back to some of the, 

again kind of the first principles of why do we 

have the three year transition period, and it's 

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to give the vast majority of synthetic chemicals 

that have a half-life where they can break down 

in that three year period, and that contamination 

won't be present.

 But the other portion is, you know, 

there's a conversion of the biology in the 

systems. If you're using synthetic sources of 

nitrogen and have readily available nitrates, 

then that's a different biology that takes a few 

years to get reestablished. 

 So if you eliminate the contamination 

and you are -- have that correct organic biology 

to begin with, you know, are the ultimate needs 

being addressed and does it just seem unfair? So 

for example like a vulture producer that has a 

healthy population of hawks and eagles in their 

area needs to put up, you know, some kind of 

productive netting to keep the birds safe.

 But maybe a grower in a less healthy 

habitat doesn't have to do it. But should every 

grower have to put up that protective netting in 

the outside space for the poultry, to avoid 

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predators? Do we want to impose the cross on 

everybody, even though we're addressing an issue 

that's already kind of been addressed with the 

production approach? 

 So I don't know the answer. I just 

wanted to -- again, if we can draw up first 

principles, we can lay the arguments on the table 

and the community can evaluate what makes sense 

and what doesn't.

 CHAIR BEHAR: Okay, Emily. Short 

please.

 MS. OAKLEY: Sorry, I was a little 

confused. So are you saying that maybe that 

through your transition period wouldn't be 

necessary if the objectives of a three year 

transition period is supposed to be meeting, 

could be met in a shorter period of time? I 

don't know. I might have misunderstood.

 MR. FRANKEL: Yeah. 

 MS. OAKLEY: I'm sorry. I was just 

not clear on what you were saying.

 MR. FRANKEL: Yeah. I'm trying, I 

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guess I'm trying to study and understand why do 

we have the three year transition period? Is it 

to punish growers or is it to accomplish certain 

organic objectives? So I'm saying if those 

objectives are being accomplished through a 

selection of the growing medium, the growing 

material, and through finding a clean 

environment that hasn't been contaminated in the 

past and those objectives are being met.

 So maybe there's others I'm not 

seeing, but I just want to make sure we're 

dealing with the same set of facts, and then 

again the community can make some final decisions 

one way or the other. So I'm saying that I don't 

see -- I see container producers can meet the 

objectives of what's trying to be accomplished by 

the three year transition period in soil faster. 

 CHAIR BEHAR: Okay, thank you. 

 MR. FRANKEL: You're welcome. Thanks 

for your time. 

 CHAIR BEHAR: So we have Gabriel 

Flores next, Ed Brown and David Will, and that 

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will be the end of the public comment. 

 MR. FLORES: Well first of all thank 

you for working late tonight. My name is Gabriel 

Flores. I'm the Director of Sales and Marketing 

for Westmar Company. We are a food safety 

company. We approach food safety through 

chemistry, training and consultation. We are a 

PURE Bioscience distributor. We've actually 

helped introduce the PURE Bioscience product Hard 

Surface Sanitizer into the Pacific Northwest. 

 We're a Pacific Northwest-based 

company. We're a family company. We have 14 

representatives in the entire Pacific Northwest, 

more than all our competitors combined. I'm here 

to basically plead with you. Our customers, 

which is about 30 percent of our base, does 

organic and they have been asking for the last 

six months for the PURE Bioscience ASDC product 

to be organic certified.

 It is one of the only products, so it 

is essential to the Pacific Northwest, to food 

safety, that the PURE Bioscience product be 

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approved. It is a ready to use product. It is a 

-- it sanitizes on a disinfectant level, which 

does not have to be rinsed. It is non-corrosive, 

and again it is unavailable to about 30 percent 

of our market. 

 That is unlike the current products 

that are approved for organics, which is chlorine 

bleach, which comes in at about 20, 12.5 percent. 

Degrades almost immediately once upon opened to 

10.5 percent. It can be used up to 100 parts per 

million, 200 parts per million. It is dependent 

upon a workforce which is -- the cleaning and 

sanitizing industry relies on a workforce which 

is high school level or less. 

 We are dependent upon them to actually 

mix the products, to validate the products and 

then use these products to sanitize. Chlorine 

dioxide is the other product which needs to be 

generated through a process of mixing chlorine 

and the acid together, and then we have PAA.

 Any chlorine-based product is 

corrosive, and I think what's ironic about these 

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chlorine-based products that are corrosive is 

that it actually starts degrading the surface of 

these food processing facilities, and it actually 

creates another problem, which is it begins --

because it begins degrading the surface which 

PURE Bioscience products does not, it creates 

harborage for other and for more bacteria and 

pathogens.

 CHAIR BEHAR: That's your time.

 MR. FLORES: That's my time, okay. 

Any questions?

 CHAIR BEHAR: Asa.

 MR. BRADMAN: I just have a couple of 

questions and a comment. Some of the proposed 

uses for SDC are for equipment and surface 

sanitizing, and then also product rinses. When 

you say people are begging for it, could you 

clarify what purposes and, you know, it's 

described as a no rinse material, but I'm curious 

about how that would work for equipment versus 

fresh cut --

 MR. FLORES: These are food contact 

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surfaces. So they make direct contact with the 

food. So if you're disinfecting with any of the 

other products, they have to be rinsed.

 MR. BRADMAN: So you're saying the SDC 

is a no-rinse product?

 MR. FLORES: It disinfects and does 

not need to be rinsed.

 MR. BRADMAN: Okay. So it's not wiped 

off or anything? 

 MR. FLORES: No.

 MR. BRADMAN: If you put it on the 

surface or --

 MR. FLORES: It is, correct.

 MR. BRADMAN: Okay, and I just want to 

also go back to your point about just chlorine 

compounds. I know in my experience with working 

with farm workers and food processors, the 

interactions we've had, you know. They complain 

bitterly about chlorine compounds and, you know, 

the sanitizing field is a challenging one. Even 

hydrogen peroxide has its own issues, although I 

think it's one of the least toxic, certainly 

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environmentally, of the materials.

 But the chlorine compounds are 

definitely a challenge here. In some of the 

comments, you know, there's an assertion that 

really on acute basis this is probably less toxic 

than the chlorine compounds. Can you talk more 

about that?

 MR. FLORES: It's in -- I'll talk 

about the safety part of it. We do training, and 

most of our training is on chemical safety, and 

most of the chemical safety is on chlorine-based 

products. Most of the complaints we get from the 

companies is how do we get the perception of the 

smell from PAA and a chlorine-based product?

 Employees complain of headaches, and 

a lot of times they're calling us in to lower the 

amounts to the lower end of the scale. For 

example, PAA runs from 90 parts per million to 

500 parts per million on a sanitation level. We 

are asked or being asked to actually lower it 

down to the lower end of it. 

 So my question is, just out of 

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curiosity, is since we're going all the way down 

from 500 to 90, what are we -- what are we 

sacrificing? How, why are we -- why are we being 

required because of the smell to lower the 

sanitation level that much?

 In the case of PURE product, it is 

odorless, it is colorless and it is noncorrosive, as opposed to a chlorine product which 

is corrosive. In a chemical cage, you have 

almost up to 20 products. You have acids and 

chlorine. You have to have them by rule on 

opposite ends of the cage.

 But the cage is maybe 10 by 10, 20 by 

20. Any of those chemicals that spill from 

dilution, hand to hand dilution on the surface of 

and go into any cage and you'll see it on the 

ground, a drop. They drop chlorine, they drop a 

mixture of a chlorine-based product on that 

surface. You now create a gas, you know. 

 Any chlorine-based product mixed with 

an acid is, becomes immediately gases and it 

becomes toxic and you have to evacuate that room. 

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 CHAIR BEHAR: I'm going to cut you 

off. So we're about a half an hour beyond time, 

and we have two more speakers. Is that okay? 

 MR. FLORES: I'm done, okay.

 CHAIR BEHAR: Okay. Thank you very 

much. Edward Brown, David Will and that will be 

it, and hello Edward.

 MR. BROWN: Hello, Madam Secretary. 

Deputy Tucker, NOSB members and NOP members, I 

want to thank each and every one of you for the 

hard work that you do. I know at times it's got 

to be a thankless job, and I do appreciate it. 

I've been in this community for 45 years. I've 

done every position from being a migrant worker, 

wholesaler, retailer, production.

 Currently, I'm the executive vice 

president for Pilgrim's Market in Coeur d'Alene, 

Idaho and it's going to be basically some general 

comments. I want to first of all thank you for 

the Organic Integrity Database. 

 I think that is an excellent tool for 

retailers to look at, for retailers and consumers 

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to look at the organic community as a whole. I 

see that as a unique database that's open to the 

public, and I do appreciate that work greatly. 

 I also have a concern about the origin 

of livestock rule. I just see -- I've been --

I'm from Madison, Wisconsin, the livestock state 

for dairy, and I would sure like to encourage the 

AMS or the NOP and the NOSB members, to just 

encourage the AMS to adopt this as a final rule, 

to accept the final rule and they do pass that.

 I believe that we are in need. I 

think there's been a lot of comment on that, and 

I believe it's time to pass that. Another --

when using the Organic Integrity Database, I do a 

lot of private labeling at the store, and looking 

at the integrity of that is a key.

 But I'm noticing more and more stores 

are using private labeling, and since retail 

stores are exempt from the certification, I mean 

from the certification if they sell it in their 

own brick and mortar stores. So I'm a little 

concerned about fraud here. 

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 I actually developed an organic 

systems plan, called a lot of the certifiers 

checking on it, and almost all of them said you 

know what? No retailers do this, and so it gave 

me some concern for fraud there. 

 The other thing I have is that with 

OFPA, when I was at the Wedge Food Co-op, I was 

there for quite a few years, and we were crying 

for the Organic Food Production Act in 1990. My 

understanding was that the USDA NOP was the 

accreditor and the certifiers were accredited by 

the USDA. 

 And so that, my understanding was that 

they actually set the rule, and they accredit 

these certifiers to that rule. So my confusion 

here is that how did the expansion of the OFPA, 

which is in the hydroponics, how they can expand 

it some 15 years ago and the organic community 

never really understand it?

 Doesn't the USDA accredit the 

certifiers, and shouldn't we, the organic 

community, know about this ahead of time? Those 

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are my general comments. I thank you for taking 

these comments. I appreciate that.

 CHAIR BEHAR: Any questions? Thank 

you, Edward. David, you're next.

 MR. WILL: Thank you Madam Chairperson 

for allowing me to speak. Michelle, would you do 

me a favor and please put Miles McEvoy as one 

more person I don't want to follow ever to speak, 

okay? It's a list of three.

 I'd like to thank you all very much 

for your time and dedication. I want you to know 

it was not missed on me at all and the audience, 

noticing that in your discussions and you 

constantly mentioned the egg, I've realized, 

which doesn't surprise me I guess, that all of 

you are evolutionists versus creationists. So I 

think that speaks well for us as an industry and 

a board and a group. So I appreciate that very 

much.

 My name is David Will. I'm general 

manager of Chino Valley Ranchers. We're an 

organic or cage-free egg marketer in California. 

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I'm also the chair of the California Shell Egg 

Board Committee. I sit on the California Organic 

Program. Since they're here, yea California, and 

I am the chair of the Methionine Task Force, and 

that's what my quick comments are going to be 

based on.

 Yesterday, I didn't get to give you 

quite the update I wanted to for our 2019-2020 

plans. We currently, like I said, we just funded 

and finished the UC Davis study. 

 We've been looking at having some 

small, very small field trials on high methionine 

corn in the Midwest that one of our producers has 

used for years. So we're hopefully going to 

gather his flock records at the end of this year 

and his yield records from the corn, and have 

those available for you.

 We're also going to do an in depth 

dive literature review through Penn State 

University, and also having them do a quick check 

through European uses in the law, so that we're 

actually clear what's going on in Europe with the 

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change now as of the first of the year, and they 

no longer have the five percent exemption.

 Just to let you know, we are an 

industry-funded group. We have about 25 members 

that actually are on the Methionine Board. But 

those members either source through or represent 

about 12 million laying hens of the 14 million 

that the USDA says are active in the United 

States currently, and we have three broiler 

people on there too. No turkeys. So if you know 

anybody that does turkey, we're looking for some 

turkey people.

 We are very small. We have farms that 

represent anywhere from 1,000 birds all the way 

out to some of the larger, bigger, complex farm 

people. Our goals for 2021, we're going to look 

at funding some more research. I think it became 

very apparent to you yesterday, in listening to 

Heather's comments, that we probably need to do 

some what's available on pasture areas as far as 

insects and the feeding and the selection. 

 Again, we thank you very much for your 

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work. We will definitely take a look into 

Methiomax as well. Unfortunately, we've seen 

some other things of this. There's been a few 

other things out of India that have come, that 

are just about guaranteed to cure everything.

 In fact, if you go to the NOP or the 

National Organic Program show and you go to the 

upper floor, they pretty much have a pill there 

that will cure everything. Somebody left their 

coral behind, I don't know who that was. But I 

thank you all for your hard work, and if there's 

anything else that we can answer, we'd be happy 

to.

 CHAIR BEHAR: Any questions? Thank 

you very much, and I hope you got your chicken. 

 MR. WILL: I can't take one back 

because we're in D&D quarantine. 

 CHAIR BEHAR: Oh Emily. Oh, oh, okay.

 MR. WILL: Oh no, it's not funny.

 CHAIR BEHAR: Thank you.

 MR. WILL: Okay.

 CHAIR BEHAR: Okay. Well, we're not 

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ready for the Materials Subcommittee yet.

 MS. OAKLEY: Can I ask a question, 

like a point of clarification on your question?

 CHAIR BEHAR: Okay.

 MS. OAKLEY: Is it ever possible to 

call a public speaker back if you have a question 

that you didn't answer or ask at that time? 

Okay.

 CHAIR BEHAR: Okay next, I'm going to 

call on Paul Lewis to give us -- Oh, okay. Thank 

you all.

 (Applause.)

 CHAIR BEHAR: Thank you for still 

being in the audience.

 DR. LEWIS: Let me just echo that. I 

appreciate the public commenters being here the 

past day and a half, and all your work preparing 

for the meeting today. 

 We're now going to the next part of 

the meeting as we're moving toward the NOSB 

Subcommittee work. And I'm pleased to announce 

the upcoming publication of another National List 

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rule.

 We just learned from the Office of the 

Federal Register that sometime next week, the 

final rule, the National List rule responding to 

the fall of 2017 recommendations from the NOSB 

will be published next week. And this addresses 

two materials. One, you may recall, adding 

sulfur to organic livestock, and then 

reclassifying potassium acid tartrate.

 And I just want to spend a moment 

talking about this. This is, again, part of our 

ongoing activity of being responsive and timely 

to NOSB recommendations. I want to again thank 

the Board for all your work with that. But I'd 

be remiss in terms of not thanking my colleagues 

around the table with the National Organic 

Program Materials Team, Clarissa Mathews, Devon 

Pattillo and others with our Standards Materials 

team, that have really put together this effort 

of being responsive to the Board in 18 months, 

preparing a proposed rule, reviewing the 

comments, preparing a final rule. Let's give 

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them all a round of applause.

 (Applause.)

 CHAIR BEHAR: Okay, with that Emily, 

I'm going to turn this over to the Materials 

Subcommittee and Emily Oakley, chair.

 MS. OAKLEY: Thanks Harriet, but I 

will obviously be turning it quickly back over to 

you. So we have five documents. I'm going to 

look at the time, because we have an hour and 

we're going to take an hour.

 So we have one proposal. We have four 

discussion documents, and Harriet, I'll turn it 

back over to you for the proposal on Excluded 

Methods Determinations, April 2019.

 CHAIR BEHAR: Okay. So this is a 

continuing document. It's kind of like a soap 

opera saga. I don't know if we'll ever be done 

with it, but we are working through a list of 

methods to determine if they should be excluded 

or not, using criteria and evaluation points to 

determine if they should become excluded. Okay, 

thank you Michelle. 

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 So based on the public comment, there 

was a lot of public comment that supported this 

proposal, that transposons developed via use of 

in vitro nucleic acid techniques, are not -- the 

transposon itself is not a method, and that we 

need to be clear that it's via use of in vitro 

nucleic acid techniques. That is the method. 

 So all we did was just make it clear 

in the box that the method is transposons 

developed via use of in vitro nucleic acid 

techniques. Then there was, you know, some 

concern that perhaps, you know, we didn't quite 

have this one right, that transposons that were 

developed through environmental stress such as 

heat, drought or cold, were we being clear enough 

on that.

 So we're just going to remove that and 

put it off to the future, the next time we look 

at transposons again. And so that is the change 

to that. When we didn't change this, there was a 

lot of good public comment that supported it, and 

so that was a pretty short and sweet little 

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proposal there.

 Let's see here. There was also a 

suggestion to change the wording on transposons 

activated or directed through in vitro 

techniques, but it seemed that the word developed 

covered both of those words and more better, so 

that's why we chose that wording.

 So the actually in the -- what the 

Committee actually voted on was that wording, 

transposons developed via in vitro. So I'm not 

100 percent sure. We of course can have a 

comment, but I'm not sure if we need to have a 

motion for -- probably for removing the other 

one, and putting that wording into that box.

 I mean there was a change there, as 

you saw, so I will go back to that so everyone 

can see it, because you don't need to look at the 

things we didn't change. You need to look at the 

things that we did change. So that's really the 

main change right there. 

 So I just moved from the notes, and I 

moved it into the method, the red. Has everybody 

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got that? So the red is what got changed. 

Before, it just said transposons, and now it 

includes the words developed via use of in vitro 

nucleic acid techniques, basically just moving 

over the language from the notes section, so it's 

clear that it's that method of producing the 

transposon.

 So I guess with that, I will open it 

up for discussion, and then we'll -- and then we 

can decide if we were ready to go to a vote to 

approve this change. You want to go to the next 

slide. 

 MS. OAKLEY: Can I jump in Harriet?

 CHAIR BEHAR: Yep.

 MS. OAKLEY: So this was in response 

to public comment, saying that these were natural 

processes. They were not -- it was not a method. 

 CHAIR BEHAR: Just trying get it right 

in here.

 MS. OAKLEY: Are there any questions 

or comments for Harriet?

 MR. MORTENSEN: I would -- I would 

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just say that I think it's also done a good job 

of capturing the points that were raised multiple 

times, that transposons do arise naturally under 

stressful conditions of the kind that were in 

there, and now that's been removed. I think the 

document's ready to go.

 MS. OAKLEY: Any other comments or 

questions? Looks of confusion? No, we're good? 

Asa.

 MR. BRADMAN: I would move that we 

accept the change, the amendment that the 

transposons arising from environmental stress 

such as heat, drought or cold be removed, struck 

from the document before we vote on it. So 

that's a motion.

 MS. OAKLEY: There's a motion from 

Dave to accept the wording change.

 CHAIR BEHAR: Can I do a friendly 

amendment --

 MS. OAKLEY: Okay.

 CHAIR BEHAR: --that we also add the 

wording in the Methods box, developed via use of 

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in vitro nucleic acid?

 MR. MORTENSEN: Yep, certainly.

 CHAIR BEHAR: Is that okay?

 MR. MORTENSEN: Yep.

 CHAIR BEHAR: So then all the change 

is in one motion.

 MS. OAKLEY: So there's a motion to 

move the wording from the notes section to the 

transposons method and synonym section of the 

box, and then to remove the section describing 

transposons developed through environmental 

stress such as heat, drought or cold. Is there a 

second for that motion? 

 DR. SEITZ: Second.

 MS. OAKLEY: Dan will second that. 

Any further discussion? 

 (No response.)

 MS. OAKLEY: All right. So we should 

start the vote.

 CHAIR BEHAR: I believe I take over 

from here.

 MS. OAKLEY: I believe you do. 

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 CHAIR BEHAR: Okay, so we'll see. 

Scott, are you ready?

 MR. RICE: I'm good to go, I think.

 CHAIR BEHAR: Okay. We will start --

wait a minute. I'm on the wrong page. Get the 

page right. There we go. So the motion is to 

accept the changes and we will start with Ashley.

 MS. SWAFFAR: Yes.

 MR. CHAPMAN: Yes.

 MS. BAIRD: Yes.

 DR. SEITZ: Yes.

 MR. MORTENSEN: Yes.

 MR. BRADMAN: Yes.

 MR. RICE: Yes.

 MR. ELA: Yes.

 MS. OAKLEY: Yes.

 MR. BUIE: Yes.

 MS. ROMERO-BRIONES: Yes.

 MS. DE LIMA: Yes.

 MR. GREENWOOD: Yes.

 CHAIR BEHAR: And the chair votes yes. 

So I have a unanimous vote that's 14 yes, 0 no, 

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no abstentions, no absence. Does that sound good 

to you Scott?

 MR. RICE: You read it.

 MS. OAKLEY: All right. So now we 

have a motion to accept the proposal on Excluded 

Methods Determinations, April 2019. Motion in 

the Subcommittee was by Harriet, seconded by 

Dave. Is there any further discussion? Harriet.

 CHAIR BEHAR: I'm just happy to keep 

pecking away at the list, and I hope as future 

NOSB Board members get on, that we continue to 

work on the list. So thank you for being patient 

and going through this fairly scientific 

determination.

 MS. OAKLEY: Thank you for your work 

on this. Any further discussion? 

 (No response.)

 MS. OAKLEY: Okay. Then I think we're 

ready to move to a vote. 

 CHAIR BEHAR: Okay. We will start 

with Tom.

 MR. CHAPMAN: Yes. 

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 MS. BAIRD: Yes.

 DR. SEITZ: Yes.

 MR. MORTENSEN: Yes.

 MR. BRADMAN: Yes.

 MR. RICE: Yes.

 MR. ELA: Yes.

 MS. OAKLEY: Yes.

 MR. BUIE: Yes.

 MS. ROMERO-BRIONES: Yes.

 MS. DE LIMA: Yes.

 MR. GREENWOOD: Yes.

 MS. SWAFFAR: Yes.

 CHAIR BEHAR: And the chair votes yes. 

I have 14 yes, 0 no's, 0 absent, 0 abstentions, 0 

recusals. How many of you have transposons? So 

it passes. 

 MS. OAKLEY: Great, thank you. So we 

did really well on our time. Our next item is 

also with Harriet. It is a discussion document, 

Induced Mutagenesis and Embryo Transfer in 

Livestock. Harriet.

 CHAIR BEHAR: Okay. So there was some 

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discussion and public comment. I really 

appreciate the expertise in the organic community 

on this somewhat confusing and detailed issue. 

There was excellent comment, especially since 

there's so many methods of induced Mutagenesis, 

and that there are some seeds currently used in 

organic agriculture that originated from some of 

these methods that caused induced mutagenesis.

 The Materials Subcommittee will 

continue to research this issue and work to 

clearly define which method or methods might be 

considered to be excluded, with careful research 

to not remove access to important seeds. This 

may or may not be done in the fall. It's hard to 

know, because it is fairly complicated. But we 

will work on it and hopefully we can have a 

proposal by then. If not, we will give you an 

update.

 Then on the embryo transfer. Many 

certifiers weighed in on this method. I did not 

see a single grower, however, weigh in. I 

believe WODPA might have weighed in on this. 

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With most considering the use of hormones only in 

the donor animal for the embryo allowable, but 

not in the recipient animal.

 The possibility of narrowing the gene 

pool if this method becomes more used was not 

considered to be an issue by most commenters, 

especially since this is already occurring with 

artificial insemination when farmers choose 

specific genetics to improve their herds.

 And so you have, you could have many 

different herds in a neighborhood all using the 

same semen from the same bull. There was some 

feeling that farmers should have access to this 

as a tool, to improve their herds not only from 

the male side but from the female side, and there 

are times when there is a cow who cannot 

conceive, and so then they use her for embryo 

transfer.

 There was not much comment on the 

possible effect of the use of the hormones on the 

young animals born from these embryos, with more 

research needed on the small amount of 

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information that I have seen, that both the 

original young animal and subsequent generations 

could be negatively affected by the hormones 

given to the donor cow.

 And of course this would be for sheep 

and goats and any mammal, but I've only seen it 

used mostly in dairy animals. This method is not 

used regularly within organic agriculture, both 

due to its cost and the lack of need for this 

expensive procedure.

 This method does not technically meet 

our criteria for genetic engineering, since there 

is no compromise of the nucleus through in vitro 

manipulation. However, the use of prohibited 

hormones led the Materials Subcommittee to look 

at this material, and a future proposal might or 

might not continue to keep this method within 

this excluded method's framework, or provided as 

a separate issue because it doesn't really seem 

to be, to fit within the criteria.

 Except for the fact that with some of 

the research that I saw and heard from others, 

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that some of the -- there is a genetic pass-down, 

okay. So the super-ovulation hormones given to 

the mother do change some of the genetics of that 

embryo, and then it is passed down through the 

generations.

 And so in a way, that is a type of 

genetic engineering. So we just have to see 

where that all fits, and if it's significant 

enough to consider it a problem or not. And so I 

reach out to the public to continue giving us 

information, to help us through this issue.

 And again like I said, I didn't hear 

from a lot or really from any individual farmers 

that this was an important tool that they either 

used now and many certifiers do allow it, or one 

that they feel is important for the future. 

That's it.

 MS. OAKLEY: Is there any discussion 

or question, questions for Harriet? 

 (No response.)

 MS. OAKLEY: I have a question. As 

you near the end of your term, which is superNeal R. Gross and Co., Inc. 

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sad, I think it's important that members of the 

Materials Subcommittee start helping you with 

these documents in more detail over the course of 

the summer and the fall, so that everyone is 

prepared to help take on many of the tasks that 

you're working on now.

 And I'm wondering if you feel that 

listening to public comment, this is something 

that should come out as a proposal in the fall, 

or if it's something that you feel needs more 

time and more development before going forward?

 CHAIR BEHAR: I think the embryo 

transfer livestock we could go forward on. But I 

need to look a little bit closer with the 

Subcommittee, if it really fits under the heading 

of an excluded method document that might go 

somewhere else, because it's really somewhat of a 

prohibited material use that then might affect 

genetics, you know, into the future generations, 

which is somewhat complicated.

 MS. OAKLEY: Any other questions or 

comments for Harriet, or any volunteers to take 

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this on? All right.

 CHAIR BEHAR: I like to look at Dave

 MS. OAKLEY: I was looking right at 

Dave too. I think that's a natural progression. 

All right. We continue to do well on time, so we 

will move into the next discussion document, 

which is Marine Materials and Organic Crop 

Production, which I was the lead on.

 So at our administrative meeting as a 

Board a few days ago, we talked about the benefit 

of having dialogue amongst ourselves about 

topics. So in that spirit, I want to not go 

through an exhaustive list of the public 

comments, which I can do in more detail in the 

future or my response to them.

 I'd rather have a dialogue amongst 

ourselves and open this up to conversation, 

because we're tackling or at least looking at, 

you know, a very challenging issue. It's very 

helpful for the Subcommittee to hear the full 

Board's thoughts on these topics, because we are 

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a much smaller subset of the full Board.

 So I will give a very brief sort of 

overview and kind of road map for how we might 

discuss this over the next 10 to 12 minutes, and 

then I hope we can just kind of open up and I'd 

love to hear people's thoughts. So just a quick 

summary of some of the comments that I think 

should be taken to heart is that I do think and I 

hope we will be able to have a fall expert panel 

on this topic. 

 It was requested that we keep this 

document on the open docket throughout the 

summer, to allow for additional comments and I 

think that that is a good idea. There is not 

enough consensus within the community about how 

to move forward to come forward with any sort of 

proposal this fall.

 So I look forward, all the 

stakeholders that are out there that said they 

wanted more time, to hearing more comments, and 

especially if those comments can be targeted 

towards the most consensus-building path forward 

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that we can achieve, that would be ideal.

 There was a lot of comment, as I 

mentioned before, that was sort of spontaneous 

from different stakeholders about their request 

for a task force, largely because this is such a 

complicated issue. It's beyond the purview of 

many of us in terms of our, you know, 

professional expertise, and even beyond the 

purview of the professional expertise of many, I 

think, at the NOP, and that a task force may be 

best suited to try to flesh out some of the 

issues and how we might sort of address 

environmental harm, especially if we were to look 

towards guidance or any sort of standards.

 So that's all I'm going to say about 

the public comments. To just frame the 

conversation, I would say that, you know, the 

goal and the reason this came before the Board 

was the question of whether or not we're meeting 

this criteria of avoiding environmental harm with 

this material.

 So that's sort of our overarching 

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goal, and then the question is what's the best 

way of addressing that? I think there are 

basically two options, maintaining the status 

quo, which some people might favor. They might 

feel that the status quo does adequately address 

environmental issues.

 And then there are those that 

obviously don't think that it does. So then 

creating a means of defining, measuring and 

verifying the extent to which that's possible, 

and trying to find out which method would be the 

best means of ensuring that no environmental harm 

or limited environmental harm was being created.

 So some of the concerns are the issue 

of precedent-setting, which we have heard from 

commenters. I think the discussion document, as 

I've said, tries to address that issue, but I 

don't think that's going to resolve everyone's 

concerns on that topic. 

 So is there a way that we can frame 

this as a wild crop material, that might help 

assuage or some of those precedent-setting 

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concerns and not create such a precedent? And 

then there's the concern about the ability to 

apply certification to this marine material. 

 That sort of spans a spectrum from 

those who say that certification wouldn't be 

strong enough to achieve the goal of environment, 

of no environmental harm, to those who say that 

certifiers don't have the expertise to carry out 

certification, although we do know that it is 

happening now.

 So I guess my question for the Board 

is how can we meet this goal? Are we meeting it 

currently and what are the best ways that Board 

members see of addressing these concerns? So I 

know that's a very broad discussion point, but I 

know we don't have a lot of time. 

 But I think it's really important for 

the Materials Subcommittee as we determine our 

next steps. So anybody feel like the excited 

person to open up their thoughts on this topic? 

Dave?

 MR. MORTENSEN: I first would like to 

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thank you, as a number of people have, for the 

amount of time that's been put into this 

document. 

 We've read the drafts, but you've put 

an enormous amount of time into this, as actually 

also having sat in on a number of breakfasts over 

the last number of years since I've been on the 

Board, have many folks in the community that have 

been helping provide information and data.

 I think that when we have a panel of 

experts speaking to the Board, and this kind of 

goes without saying, but I think some of them 

have been better than others in my opinion in 

terms of really helping us. I thought the second 

integrity panel was excellent, and really helped 

us to see where some of the problems lie.

 I think that it would be really 

helpful to be very, very deliberate about how we 

decide who we would decide could help us to see 

this problem more clearly, and do that by 

committee maybe, so that we could have some 

pretty rigorous discussion about how we set such 

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a panel up.

 I, for example, would be really 

interested in understanding better how some of 

the certification processes that are in place 

now, Emily, that you know more about, how those 

are working. I also think that we have a 

tendency here, when folks like -- and I thought 

David, I have always thought that David Hiltz's, 

presentations have been very helpful. 

 But we don't usually hear from the 

marine folks that are concerned about fishery 

depletions in the Northern Atlantic, for example, 

speaking to the Board about how changes in 

habitat alter the sustainability of the fisheries 

of the Northeast, for example. But that's just 

one example.

 So that's, those are my thoughts on a 

panel. I think it's a great idea, and I 

definitely think we need to keep working on this, 

because I think it's a very, very important 

issue.

 MS. OAKLEY: Lisa. 

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 MS. DE LIMA: So one thought I have is 

before we try to move forward with a task force 

or a panel, try to narrow the scope a little 

bit. So a couple of certifiers, this time and 

past times, have brought up the concern about 

whether it's -- if we put something forward, 

that it's not legally enforceable for OFPA.

 So I think narrowing in on some of 

those comments and figuring out the validity of 

those and what's behind that before we go to task 

force, so that we don't have them going down a 

path which then we can't actually pursue. So I 

don't really have any answers, just questions.

 MS. OAKLEY: Either of you guys? 

Scott.

 MR. RICE: In terms of panels, I 

agree. I think we've had some good successes and 

agree with Dave that, you know, with a sort of 

more curated panel we can definitely have more 

success. I reiterated an idea I had of just even 

splitting the panel in two, of having -- which 

might also speak to some of Lisa's concerns of 

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one looking at sort of the regulatory kind of 

certification angles that we're interested in 

learning, and then another looking at the ecology 

and environment questions that are concerning us, 

and maybe that would help guide further work.

 You could even potentially do that at 

the same meeting, and just kind of be -- a lot of 

information, but I think you could do it well and 

help shape the discussion further.

 (Off-microphone comment.)

 MR. RICE: A panel of regulatory and 

certification angles and topics, and one of kind 

of ecology and environment.

 MS. OAKLEY: Steve.

 MR. ELA: I'm trying to catch that 

thought, because otherwise I'll be in a very 

short memory. I agree with what's been said, 

that you know, this is a very complex topic and I 

remember when I came on the Board and the various 

marine materials documents were floating around.

 I was kind of like oh my goodness. 

That may not have been the exact words, but I 

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mean incredibly complex. And yet, I mean I think 

one of the issues we struggle with on this Board 

is, you know, somebody said we do really well 

with materials because that's very concrete, and 

it's concrete for a reason and the more complex 

issues, which really are why we are organic 

growers, we deal with complex systems, are much 

harder to nail down and find consensus on.

 So I don't want to let it go. I don't 

want to take it on. I want somebody else to take 

it on. But I see real needs, you know. In 

hearing the public comments, I think there are 

some very good things happening out there by 

companies, and with protocols. 

 I still have a real worry that the bad 

actors, you know, the regulations don't go after 

the good people, they go after the bad people. I 

worry, especially with climate change and other 

issues, that bad actors out there that may not, 

you know, take the system into account, I don't 

want to be using those materials accidentally. I 

want to support the good people. 

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 But it's hard to know as a grower I 

can't do that research. So I feel somewhat 

compelled as a Board to keep following up on 

this. I really thought, you know, your document, 

you know, it became clear to me we shouldn't, you 

know, certifying somebody else's protocol like 

the Maine standards, probably not a good idea 

because we don't have control over that.

 Plagiarizing that maybe, with 

permission. I guess that's not plagiarism, but 

you know maybe, you know, in starting that may be 

a good starting point. But I think we, you know, 

reading the initial documents on all the seaweeds 

and all the materials around the world and those 

beds, it was fascinating, and I had no clue. But 

it also, you know, it did show the fragility of 

that system.

 So I agree with what Scott said. I 

think, you know, a panel with two sets, I think 

that was a really good, really good suggestion, 

and maybe that's the starting point. I'm not 

sure about a task force yet, but I thought your 

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document was really, really good, laid out the 

questions and still the wild harvesting thing, I 

think I could still be in favor of it.

 MS. OAKLEY: Harriet and then Rick.

 CHAIR BEHAR: So I think we got here 

because in our rule, it does state that we have 

to, you know, protect the natural resources, and 

it doesn't -- so I think there was this feeling 

too that, you know, well wild kelp is used in 

conventional agriculture too, that organic 

farmers care more widely about the greater 

environment and, you know, we talked about carbon 

sequestration.

 That's not just for the rainfall on 

our own farms; it's around the planet. So I 

think there was a little bit of concern about 

like a black eye for organic if what we are 

requiring on our farms is actually despoiling the 

seas and causing species to go extinct, and 

that's not something we want to see.

 But on the other side, we have to be 

somewhat practical in how far can we really save 

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the planet. I mean we'd like to think we could, 

but you know, I'm wondering with some kind of 

annotation, you know, like -- but organic 

certification is going to require some ramping 

up.

 But that said, you know, there could 

be a phase-in period or whatever, and that's why 

I think it's a good idea what Scott said, to have 

the regulators talk about it and then get some 

background. I was asking the question about do 

the harvesters mostly work for one company, 

because I kind of was thinking about having them 

be like a grower group, because between Arcadian 

Seaplants and Ocean Organics I believe that's 

their system, where they have protocols that they 

even check up on.

 So they already have kind of a grower 

group internal control system in place for the 

harvest of kelp, which means that not everyone 

who's got a boat going out there would have to be 

certified, and that would be somewhat helpful as 

far as what kind of cost, right, having the kelp 

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become certified. Would it add to the cost? It 

would be a lot more addition if every boat had to 

have an inspector versus, you know, dealing with 

it like a grower group.

 I know that the NOP is looking at 

grower groups, so we'll see what comes out of 

that and that will maybe inform our future 

discussion.

 MS. OAKLEY: Rick.

 MR. GREENWOOD: Yeah. I also like the 

idea of splitting the two panels, and I think the 

area that I'm least comfortable with and where 

I'd like more information is obviously the ocean 

ecology. I think we can't set standards until we 

understand what's going on.

 We heard some numbers today, where we 

only harvest ten percent. Well I don't know if 

ten percent is a good number. I mean maybe over 

time ten percent destroys things. Not initially, 

but maybe 15 years later. So we really need some 

expertise. 

 I don't know that. I think I had 

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mentioned at the last meeting I helped build a 

reef as a mitigation and it's really hard, and 

it's got to be followed for 30 years by federal 

law, to see if it actually works.

 So we need, we need real information. 

Then we can get to the certification, what we do. 

Otherwise, we're measuring to a standard that may 

not be of any value at all.

 MS. OAKLEY: Dave, then Asa.

 MR. MORTENSEN: Right, and I was also 

struck by something that David Hiltz said this 

morning, that just reveals the fact that how this 

plays out is quite context-specific, where he was 

talking about, you know, zones of the oceanfront 

that were, you know, this group can work in that 

area, that the Canadian government is managing.

 I just moved into Hampshire and I was 

thinking about what he was saying, that that's 

largely unregulated in Maine. It seems to me 

that how that plays out, how it's managed, how 

it's overseen and when we have a panel therefore. 

Let's get to the point of the panel. It would be 

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helpful to have somebody that knows something 

about regulating what goes on in the intertidal 

zone along the coast, west and east coast and 

maybe even other places around the world.

 Because clearly if you have a 

carefully managed process in Canada and an 

unregulated process largely, in at least in New 

England, that's a very different set of concerns 

I think.

 MS. OAKLEY: Asa.

 MR. BRADMAN: Excuse me. David 

actually just said some of the things I was 

thinking. But just to reemphasize, I think this 

is a very important issue, and from what I can 

see the status quo is not acceptable at this 

point, or at least we really need to have a lot 

of discussion before we can even consider that as 

an option.

 It sounded like today in Canada they 

actually have pretty good rules. But in some 

cases there's probably not; in other cases, the 

government agencies really may be promoting 

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economic activity and potentially at the expense 

of the environment. This is a very unique 

situation, where we're taking nutrients from 

essentially a native ecosystem and then 

transferring them as really a pure input into, 

you know, an agricultural ecosystem for people.

 I think that just -- you know, there's 

a special kind of responsibility to support that 

activity.

 MS. OAKLEY: Thank you. Are there any 

further questions or comments? Tom.

 MR. CHAPMAN: So I share Lisa's 

thoughts that we should clarify what authorities 

we could potentially utilize with standard-making 

before we go down that road. I've been somewhat 

reticent to comment on this because I think you 

should come with solutions, and unfortunately I 

don't have solutions.

 I have a lot of concerns around 

certifying inputs and the precedent-setting on 

there, and precedents can be set no matter how 

many disclaimers you place on something. On the 

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flip side, I don't like referring to third party 

standards. And so, you know, that's not a 

solution I'm particularly drawn to, and you know, 

but I think something needs to be done.

 So I'm not bringing solutions, which 

I don't, you know, like X against me on that one. 

I'm sorry. But so far I also have concerns about 

some of the solutions that have been proposed. I 

do think -- this is also where I'm going to be 

somewhat speaking out of both sides of my mouth.

 I do think that a panel is probably 

the best way to do it, but I struggle with the 

priority of this item over some of the other 

items that we have before us. I agree heavily 

with the comments that Garth had made about how 

fraud is really the big issue before us, and you 

know, there are limited resources.

 And so in the absence of looking at 

limited resources, this seems like a great panel 

to proceed to in the fall. But if you look at it 

as a tradeoff decision amongst all the other 

various panels we could potentially bring in on 

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integrity, on international recognition and 

conformance agreements, on seeds, on livestock 

practices and what's going on in the marketplace 

there, like there's a ton of issues that seem 

more pressing than this one, which also I am 

struggling with because I know I can't ask for 

ten panels. That's just not realistic.

 So we only have so much time. Is this 

the one we want to use in the fall? At the same 

time Emily, I know you put a ton of work in this, 

and this goes on prior to your time. It goes, 

you know, traces back to Jean. She put a ton of 

work into this, so I have respect for that. I'm 

just, you know, I'm pulled in a lot of different 

directions on this.

 MS. OAKLEY: Yeah. So in the interest 

of time, unless there are other pressing 

comments, I'll close it there and thank you Tom 

for that last point, because I do want to say 

that this is -- so many other Board members put 

in so much more work, so just a small thing.

 But this did come from others who had 

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done much, a lot of work. I want to just thank 

all the stakeholders who have put in a ton of 

time on this, and for your really helpful 

comments because each of them really does help 

improve the process.

 So with that, we will move on to the 

next discussion document. Harriet.

 CHAIR BEHAR: I'm here.

 MS. OAKLEY: Which is genetic 

integrity, transparency of seeds grown on organic 

land.

 CHAIR BEHAR: Okay. So I guess I want 

to somewhat apologize. I put out this discussion 

document kind of as a second to the one that was 

out at the last meeting, and didn't -- in the 

interest of just not throwing more paper at 

everyone, I should have probably included the 

other one with this. I did get some comments 

like where is this coming from? Don't expect us 

to look at the previous thing, and it's okay.

 So I didn't do that, so apologize, you 

know. I guess we'll just think about that again 

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for the future. So it does refer to the previous 

one though about what the public comment was. To 

give some background, this came from -- seed 

purity was the original name for it.

 There's been a call for a task force 

to try to understand about the genetic 

contamination of seed used on organic land, and a 

lot of discussion about thresholds, more 

tolerance or whatever and just -- and of course 

there was no agreement across the organic 

community on that.

 And so when I took it over from Zia, 

I kind of thought about what are we really trying 

to get to here, and what I saw in my neck of the 

woods in the upper Midwest was the fact that 

there were farmers who were, through no fault of 

their own, having crop rejected and not knowing 

if it started at the seed, if it was their own 

problem with genetic contamination.

 But this is a significant loss, and 

especially in the past few years when the corn 

price was a little bit higher, they would be 

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expecting to get $14 a bushel for their organic 

corn. They would ship it two or three hours and 

it would arrive and it would be rejected, and all 

of the sudden it gets sent off to the 

conventional mill or elevator, you know, and it 

was $3.50 a bushel.

 You can do your math on that. Very 

significant, and these are not new farmers who 

are growing, you know. These are farmers who 

have not had that problem before and are starting 

to see that occur. Long time farmers, good 

organic farmers. 

 And so I thought well really what we 

need to know is what is the integrity of that 

seed, and on the genetic level that's grown on 

organic land. So that's where I took it. It 

actually also came from going to the Organic Seed 

Alliance conference and discussing this with seed 

producers, who said they were already doing quite 

a bit of testing and that they were happy to be 

transparent.

 But of course as this moved along, you 

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know, the organic seed is more than just the 

Pacific Northwest and the Upper Midwest. It's 

the whole country, and actually our rule is 

international. So there are complications to 

trying to set some kind of program together, 

where we try to provide the information to the 

farmers.

 With that, I have been speaking with 

Kiki Hubbard and the Organic Seed Alliance, and 

they will be doing some reaching out, as Kiki did 

say in her public comment, to organic and nonorganic seed producers that typically sell to 

organic producers, to determine if this type of 

genetic transparency program and the accompanying 

testing is practical, doable, you know, legally, 

although I think we've taken care of that 

question, and that it is legal to test final 

product that may not be legal, to test foundation 

seed that hybrid seed is made from. 

 But any seed that a farmer would buy 

to grow a crop. It is legal at this time to test 

for genetic contamination. What are the type of 

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costs? What's the availability of the testing, 

and to determine if there's any other unintended 

negative consequences if a pilot project does 

move forward.

 We look forward to their research, 

which hopefully will be completed so we can move 

ahead with some sort of proposal this fall. 

Let's see. There were quite a few public 

comments on the previous document about, you 

know, how do we put this together. 

 There was quite a few comments that it 

wasn't clear which entity had to do what thing of 

the 18 items in the list. So I have that in my 

head and would put that together, you know, if we 

did move forward with a proposal. 

 So make sure that, you know, I will 

have a list and then I will clearly somehow, 

either in a table or whatever, and point out this 

is what's expected of the organic seed producer. 

This is what's expected of the organic farmer. 

This is what's expected of the organic certifier, 

and this is what's expected or could be asked of 

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the non-organic seed producer.

 Because I truly do not feel it's fair 

to only ask organic seed producers to have the 

burden of testing on them. We really need that 

if there's non-organic seed being planted on 

organic land, that there is some background 

information. You know, perhaps this could be a 

way to push organic producers more towards using 

organic seed, although there is not quite enough 

out there for them to use.

 But again, we should be working with 

organic seed. That's what the rule says, and I 

don't think it's necessarily fair to the organic 

producers when a non-organic seed supplier is not 

transparent about what's in their seed, and it 

could end up then causing a great monetary loss 

to the organic producer, by not knowing what 

they're starting out with.

 So why is that happening? That's 

because the marketplace has -- does have 

thresholds on GMO contamination, and many times 

the farmer either signs a contract or is aware 

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that they need to bring, you know, no more than 

.9 percent. So if they don't know if their seed 

has 1.1 percent genetic contamination, they can't 

meet their contract, and they don't even know if 

there's no transparency.

 Okay. So numerous comments were put 

forward to remove the collection of the data from 

the proposal, and also to make the testing of the 

seed strictly voluntary, with no collection of 

data that then would go into a large database, 

all the way to we should just require no 

detectable levels of GE in any seed planted on 

organic land.

 So we had all and everything in 

between pretty much. Most commenters, though, 

were positive about the need to move ahead with 

some sort of system to aid farmers in knowing 

what the unintended genetic engineering 

contamination levels their seed may contain, and 

the public generally does not want us to move 

forward until we have more information from the 

seed producers and farmers. 

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 There's concern about the GE 

contamination that's occurring, that disrupts the 

supply chain, resulting in lower prices to the 

farmers, but also to the processors. This is 

stressful for the processors when they're 

expecting to process something and to then be 

able to sell it on, and then all of the sudden 

they have three semi loads of corn that they 

can't use, and they have to then scramble to go 

find other product.

 I did speak with the Organic 

Ecological Food Farming Association's Grain 

Farmer Group on a conference call, as well as the 

O Farm Board, twice in person and once on a call. 

They were generally supportive. They did not 

want to see a lot of financial burden, but they 

really wanted the information.

 One thing that they -- that stuck with 

me is that they felt that they should be really 

protecting the organic integrity of the crops 

that they are growing, and having this 

information would help them do that. 

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 The discussion document brought 

forward the comment that the NOSB and the NOP 

should aid certifiers with clear guidelines on 

what type and number of testing they should do to 

determine unintended genetic engineering presence 

in seed and final crop, as part of the 

comprehensive guidance on this subject, that 

there's kind of a gap there that some certifiers 

are testing for genetic contamination, others are 

not, and there's no clear guidance on who's doing 

what and what should be done so that it is 

consistent across all certifiers.

 For those that were positive on this 

issue, they stated that they want the pilot 

project to be practical and cost effective, and 

they also see this as a way for the marketplace 

to incentivize seed producers themselves, to 

lower the GE contamination, because if there's 

sunshine on what the contamination is, then 

there's thought and hope that the seed producers 

will try to lower the GE contamination, when 

nobody knows there's just not that incentive. 

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 The farmers want to see us raise the 

bar, because there's concern that without 

transparency, many producers will continue to 

lose access to markets due to this genetic 

contamination that's no fault of their own. 

There were some very good comments given on 

building a practical pilot program.

 I know I went on pretty long, but 

there were a lot of comments, so I thank you for 

that.

 MS. OAKLEY: Thank you, Harriet. 

There were a lot of comments. Are there any 

comments or questions for Harriet from the Board? 

Dave.

 MR. MORTENSEN: I have a couple of 

thoughts. One of those is several people at the 

-- well, lots of the written comments and then at 

the NOC meeting I was sitting in the background 

quietly listening while you and Kiki and others 

were talking thoughtfully about this subject.

 It seems to me, so I'm going to just 

reveal my bias here, and pardon if I upset anyone 

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in the audience or on the Board. I get the sense 

we're afraid to know what the state of the seed 

supply is. That's my opinion. I think we need 

to know the state of the seed supply, period. 

 I thought there were some very helpful 

suggestions made by folks about how we answer 

that question. What is the state of the seed 

supply with regard to purity, and one of those 

suggestions that was made repeatedly by several 

different folks and groups was that we have some 

sort of group of individuals that would conduct a 

study, where people were very sensitive to not 

smearing anybody in the process, that this would 

be some sort of autonomous but pointed set of, 

you know, look and see how are we doing with 

maize, corn.

 The fellow from Texas today was 

talking about cotton is a big problem, and we all 

know that any GMO crop that is either bee 

pollinated or wind pollinated when it's grown in 

a matrix that is overwhelmingly GMO transformed, 

there's a risk of that happening. 

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 Whether you're a breeder or you --

unless you're going to do your breeding in a 

country or an island where GMO crops of that 

species are not grown. So I liked the suggestion 

that some sort of group, and I don't want to call 

it a task force, a group of folks working 

collaboratively would actually set out to 

determine the state of the seed supply with 

regard to purity.

 And then it could be shared with this 

group, this community and then discussed with the 

idea, which I think is totally the intent of this 

document, this part of it is in my reading of it 

and my discussions with the Subcommittee. We 

could then be looking at what are the problems 

that give rise to hot spots of impurity by, you 

know, asking those kind of questions of the data.

 So that's one thought. Should it 

remain in a discussion document. I don't know if 

it should remain in a discussion document or 

handled outside of a discussion document format. 

I do think that our farmers deserve to know what 

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they're dealing with on the front end, because 

most all of our farmers, organic farmers are 

concerned about genetic modification 

contamination of their seed, those that grow 

crops that are crops at risk.

 So that's just a thought I have coming 

away from listening to more of the discussion, 

and looking at the document and discussing this 

with the Subcommittee.

 MS. OAKLEY: Yes, Tom.

 MR. CHAPMAN: I just had a question 

for Harriet's summary. You mentioned O Farm was 

supportive of this? But then I also -- I thought 

I read a letter that they sent on saying that 

they had some strong concerns, and so can you 

clarify that?

 CHAIR BEHAR: Yeah. They stated that 

they did not want it to cost them a lot more. 

But the last sentence was we are supportive of 

this, that I saw.

 MR. CHAPMAN: I think that was the 

Crops. Are you confusing the Crops piece with 

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this piece?

 CHAIR BEHAR: No.

 MR. CHAPMAN: Okay, because they said

 CHAIR BEHAR: I can look that up. 

 MR. CHAPMAN: Yeah.

 CHAIR BEHAR: But no, they were 

supportive of having the information, and they 

were supportive if they could get the information 

from their seed suppliers up front before they 

even purchased the seed. 

 They didn't particularly like the part 

where if they couldn't get the information from 

their seed supplier, that they had to go out and 

do the test, because of the cost. If somebody 

else would pay for the test, then they would be 

fine with that.

 MR. CHAPMAN: Yeah.

 CHAIR BEHAR: There was concern about 

saving seed, which I did address and took that 

out, made that more of a best practice instead of 

a mandate. I know that there were a few 

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certifiers that wish that farmers would save 

their seed, but got a lot of pushback from that 

so that was pulled out.

 MR. CHAPMAN: Yeah. I mean I had read 

the letter from NOC. I just, it didn't seem like 

the summary coincided with what I had read in the 

comments. But maybe I misread it myself, so just 

let's make sure that we're -- if you could follow 

up on that before we move forward.

 CHAIR BEHAR: Okay.

 MR. CHAPMAN: Yeah.

 MS. OAKLEY: Just noting the time, 

we're closing in on our hour. Are there any more 

comments on this before we move to the sanitizers 

discussion document? 

 (No response.)

 MS. OAKLEY: All right. Well then our 

final item is assessing and cleaning sanitation 

materials used in organic crop, livestock and 

handling discussion document. Harriet.

 CHAIR BEHAR: Okay. So sorry Tom, I 

can't search the -- busy. Okay. So while the 

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Subcommittee clearly stated that our goal was not 

to limit sanitizer use in organic agriculture, 

but instead the NOSB really feels it needs a 

reference to aid them in current -- for the 

current NOSB and for future NOSBs, to better 

evaluate the petitions as they come to us, to see 

where the sanitizers that we are receiving 

petitions for fit in the constellation of 

sanitizers.

 Not to change the OFPA criteria. We 

will still get TRs for individual sanitizers. 

But we don't always understand how they work 

with, you know. What is the difference between 

this one and that one, and this active ingredient 

and that active ingredient? 

 It seems there's still a concern that 

the work on this topic is somehow secretly being 

done, to remove the use of needed and in some 

places legally mandated sanitizers. So as the 

lead on this document, I just want to make it 

clear that I am an approved Produce Safety 

Alliance trainer, helping produce growers meet 

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FSMA requirements.

 I have taken both basic and advanced 

trainings. I have written numerous articles and 

fact sheets. I have given many trainings to 

growers, and I do not hate sanitizers, okay. So 

everybody, you just need to know that. I 

understand about biofilms and pathogens and where 

they hide and how hard they are to get rid of and 

how they can grow, and exponentially and cause a 

food safety crisis.

 So please, I am not lying to you. I 

am not secretly trying to do something else. So 

I hope that's clear. You can go on the Produce 

Safety Alliance website, see my name there. I 

want you all to know too that the NOSB struggles 

with the review of these direct contact materials 

to decide what is truly needed and what is not.

 Sanitizers by definition kill 

biological life, and can have a wide range of 

negative consequences. We are hoping that this 

TR will provide that reference to us and to the 

public, to determine what sanitizers, what active 

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ingredients in sanitizers best meet the OFPA 

criteria, and that that reference to the safer 

choice was really to kind of show there is 

something out there already that kind of gives 

maybe not the food processing industry, but has 

an overview of these sanitizers choosing certain 

ones that meet a criteria.

 We agree that this should only be 

limited now to those that have direct contact, 

but many of the sanitizer active ingredients are 

also used in cleansers. So that's partially why 

the word cleanser was put in there, not that we 

were going to review items that are washed off. 

We're only going to review those with direct 

contact, but they are also found in cleansers. 

So we didn't want to ignore the fact that they 

would be there too.

 There was some public comment about 

asking for clarity on the use of these materials 

that have contact with organic food in postharvest handling, since there's no consistency 

between certifiers on this issue. Some do not 

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allow the 100 percent organic label if there's no 

rinse after an approved National List sanitizer, 

and others do allow the 100 percent organic 

label.

 So I don't know if that's something to 

discuss with the NOP, but it's really kind of 

beyond the purview of this TR and issue. But it 

was brought up and I think it is a good question.

 On the question of uniqueness, that 

uniqueness was meant to discuss the activity or 

mode of action of the product, not the product 

itself. So there could be numerous products that 

have the same unique quality in its mode of 

action. 

 So we're not -- and we're not saying 

that if numerous products have that mode of 

action, that we will only accept one. But we 

want to know what is that unique activity of that 

product through the TR. 

 We did discuss the need for rotation 

of products in the document, which shows that we 

understood that there could be more than one 

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sanitizer used in a situation, and that we -- it 

is our intention to provide these options. But 

many times, we are not given that information, 

and we really feel that this TR will give us some 

reference to be able to assess that.

 The NOP has used the word ancillary 

ingredients in the past for materials that are 

either not inert or excipients. So I know there 

was some question about the use of ancillary 

ingredients, and that I suppose we could have 

defined better. But it's basically everything 

except the active ingredient in the product, and 

maybe we should look for another word.

 So we are hoping that the TR will give 

us some basic information. If the Materials 

Subcommittee feels that a discussion document or 

a proposal would help others access this 

information in an easier way, including 

manufacturers and users of sanitizers, to 

identify and petition new materials for the 

National List, we would do something besides the 

TR. 

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 We don't know what the TR looks like. 

Depending what that looks like, we may come out 

with a discussion document or something else that 

makes it a little bit more accessible to the 

public, to then use for helping us find the gaps. 

With that, I am done.

 MS. OAKLEY: Okay, thank you Harriet. 

I just want to note that we have met our hour 

allotment and slightly exceeded it. So if you 

want to open it up for questions we can. Are 

there any questions or comments for Harriet? 

Ashley, are you nodding your head yes. 

 CHAIR BEHAR: Steve was first.

 MS. OAKLEY: Okay.

 MR. ELA: I find it interesting that 

for the whole time I've been on the Board, our 

stakeholders have asked us to figure out a 

comprehensive review of sanitizers so that we 

don't just willy-nilly put them on the list, 

knowing that we all need them.

 And then -- and then we propose this 

and suddenly it seems like, you know, OFPA 

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criteria are perfect. And that's not -- it's a 

little bit of a frustration. It's just a note. 

I think it's a complex topic that, you know, none 

of us want to lose tools. We all want more 

tools, but yet kind of fundamentally the 

sanitizers go against OFPA in that they're 

widespread biologics. 

 For anything else, we might kick that 

out. And so I think we really do need to 

continue to figure out classes of chemistries 

that are active so that we have rotation against 

resistance, and I have no problem with multiple 

compounds within a class. 

 But in the insecticide world, there 

are the neonics and there are the 

organophosphates and there are the biologicals, 

and we have multiple materials in those. Each 

one may have a specific use, even though they 

fall in a single class.

 So I think we need to keep moving 

forward on it. I personally have some 

reservations if we do have -- know what to ask 

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for in a TR at this point, in terms of getting 

something that's really valuable. So I'm kind of 

tempted to take this process slowly. But I also 

don't know how to move forward to resolving what 

we might want to ask. It's a -- I chase my own 

tail on this one.

 MS. OAKLEY: Why don't you come join 

us on our Subcommittee calls?

 MR. ELA: Oh, I'm busy. 

 MS. OAKLEY: You are? Ashley.

 MS. SWAFFAR: So that person that asks 

all the time in their public comments for that 

comprehensive review of sanitizers, also in their 

public comments really ask us to remove a whole 

lot of sanitizers. That's my concern with this 

document, is you know that potential. I think we 

heard from so many of the growers and packers 

that sanitizers are critical and they feel like 

they don't even have enough.

 So that's where my reservations are on 

the whole like whittling down and uniqueness of 

certain things. I would like to see us have 

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options for especially the produce industry. So 

I hope that this document can do that, and I 

think there could be some really good ground work 

on adding new substances, you know.

 That's where I think this could really 

help us, not looking at taking things off the 

list. So I hope that the TR can focus in that 

area specifically. Thank you.

 MS. OAKLEY: You too are welcome on 

our calls. Tom.

 MS. SWAFFAR: I'm a senior. I'm not 

accepting new committees.

 MR. CHAPMAN: I have a couple of 

questions and then maybe a statement or two. So 

the first one, has the TR gone out? Has it been 

contracted?

 DR. LEWIS: No, it is not. It's still 

in development in terms of understanding the 

scope of the TR in that case. So we've been in 

conversations with Emily and Harriet in terms to 

finding the scope of the TR and in terms of the 

boundaries we should be --

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 MR. CHAPMAN: So I'm under the 

assumption the Subcommittee is open to taking the 

feedback from this meeting and incorporating that 

into the TR as well? Is that fair? I see head 

nodding, so I'm going to say yes.

 MS. OAKLEY: Yes, yes. We will look 

at that at our next meeting, which is in a couple 

of weeks.

 MR. CHAPMAN: Great, getting right 

back into it. I share some of Steve's concerns 

around whether or not right now is the right 

timing for a TR, and I guess the concept that 

would be in my mind is potentially a technical 

panel, that would be able to explore what we're 

looking for here, mostly made up of various types 

of food safety experts, that could then help us 

flush out what we could expect to find in 

research out there, to help answer the questions 

we may have.

 But I don't think we right now know 

the questions even maybe to ask, to get the most 

that we could get out of a technical review. So 

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maybe working in a more collaborative environment 

first, with the intention of moving to a 

technical review after that might get some more 

results.

 I also want to speak to the -- we did 

hear from stakeholders asking for this review. 

We also heard over the years stakeholders asking 

us or stating that they didn't think this was 

necessary, sharing the concerns that people have 

that this is an attempt to remove sanitizers.

 So I just want to make sure that 

people realize that while we did hear from some 

stakeholders supporting this concept, we also 

heard from stakeholders not supporting the 

concept. So that then doesn't surprise me when 

we hear then when the, it goes forward, you're 

hearing from people that are now resistant to the 

idea speaking up a little bit more.

 I also think the Subcommittee needs to 

consider ancillary substances in a lot more 

detail, and I refer you back to the peracetic 

acid sunset from the San Diego meeting, so spring 

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2015, where we actually -- the NOSB in that 

proposal noted that inert ingredients in a 

sanitizer are not ancillary substances subject to 

review.

 So there's a conflict now from what 

was just said versus what was done previously by 

the NOSB. So that's an issue I think probably 

that we should dive into too before we send out 

the TR and go into those details.

 MS. OAKLEY: Harriet, sorry.

 CHAIR BEHAR: I thought I said that we 

were not going to look at ancillary substances. 

Did I say we were?

 MR. CHAPMAN: I think there was a 

comment that they overlap with other substances. 

So inerts are completely out, not at all looked 

at.

 CHAIR BEHAR: Correct.

 MR. CHAPMAN: Okay. Well inerts and 

ancillary substances?

 CHAIR BEHAR: Yes.

 MR. CHAPMAN: Because we said the 

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ancillary substances were everything else that's 

in the product?

 CHAIR BEHAR: No, I was defining them. 

I wasn't saying -- I was -- the question was 

what do we mean by ancillary substances?

 MR. CHAPMAN: And inerts are not 

ancillary substances.

 CHAIR BEHAR: Then I said well, we 

have categories of inerts. We have categories of 

excipients, and then we had a category of 

ancillary substances like used in handling 

products, and perhaps that was the wrong word. 

But this was basically everything else besides 

the active ingredient. 

 That's what I was referring to in the 

document, but that we were not going to look at 

those ancillary substances, or should I say all 

the other things besides the active ingredients.

 MR. CHAPMAN: Yeah, probably all the 

other things, just because we previously noted 

that there's -- in handling, there's inerts and 

ancillaries. 

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 CHAIR BEHAR: Right, right. So I'm 

sorry if you didn't understand that. But no, I 

was just trying to define what ancillary meant in 

this context, and then it meant everything but 

the active ingredient, and that we were not going 

to be looking at those in the TR.

 MS. OAKLEY: Sue, anybody else? And 

Asa. Okay. Sue, then Asa, oh and Jenny. Okay, 

sorry Jenny. Sue, Asa.

 DR. TUCKER: Oh, I just wanted to 

follow up briefly on what Paul said about the TR, 

because that follows immediately on what Tom just 

said. To do a TR contract, we really need to 

have a very clear scope, because a consultant has 

to take that statement of work and determine how 

many hours it's going to take to answer the 

questions, to do that work in order to come up 

with a fixed price.

 So I hate to get mundane about 

contracting, but that's why we keep on 

emphasizing the importance of a very clear, 

specific defined scope for that technical report. 

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 So I would encourage the Board to make 

sure you know what you really want a contractor 

to do before we spend money to get a contractor 

to do it, because we don't want a contractor for 

a technical report come back and say well, we 

wish we would have asked all these other things, 

because then we have to do another contract, and 

the price of those -- this is worthwhile 

expenditures, but the better we can define it up 

front, the more cost effective it will be. I 

just want to make that point.

 MS. OAKLEY: So I'm just going to 

interject myself really quickly and say that yes, 

we have been in that discussion with members of 

the NOP staff during our Subcommittee calls and 

through emails, and we will continue that 

process, especially when we come back with the 

public comments and make any changes that we 

would be making. So yes, thank you for that. 

Sue, Asa, Tom.

 MS. BAIRD: Yes. Thank you for this 

work, and I do appreciate it. I think Jenny did 

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address something that I was going to say. But 

there is another concern, observation, and I 

appreciate Harriet's, all of her vast stuff that 

she has going on in her life, including the fact 

that she is a FSMA trainer.

 But I have heard the concern from some 

of the stakeholders that says, you know, I'm 

afraid that you're going to say this uniqueness 

will now limit us, or you're going to use this as 

a criteria to prevent -- either to take things 

off or prevent new materials being put on. There 

has been precedent I've heard in even the short 

time I've been on board, for using that very 

criteria.

 Well, we've already got one like this; 

why do we need to add another one? Got the same 

mode. So just as a caution, let's don't go down 

that way.

 MS. OAKLEY: Asa.

 MR. BRADMAN: Just in terms of the 

more mundane, you know, I think there is value 

here, and if nothing else given how important 

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sanitizing and food safety is, just having kind 

of a matrix of allowed materials, potential 

materials, stuff under review.

 I think having an organized system to 

categorize that information and evaluate it would 

be valuable. That's where I see this functioning 

here. I would add to the evaluation criteria 

comparative toxicity. So if you have a new 

material, comparing it to the other ones and 

also, you know, what the end points are.

 I mean I can picture kind of a table 

that would have different checkoffs there, so 

there could be a quick summary. So just a detail 

here, but I think this could be really valuable 

and useful.

 MS. OAKLEY: Thank you. Tom.

 MR. CHAPMAN: Sorry to continue to 

belabor the point on ancillaries, but I see that 

that was in the technical review request, and so 

I know you're telling me the ancillaries are out, 

but I see that it's in.

 MS. OAKLEY: I'm going to interrupt 

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you and say that that is something that got 

removed before or after this was already 

submitted, because we heard from the program on 

that in particular saying that it was too broad, 

and that it would expand the cost of a technical 

review beyond something that was feasible.

 So although it's in this document 

before the public, it is not in the document that 

would go forward as a technical review request.

 MR. CHAPMAN: Okay. So it was the 

intent of the Subcommittee to review it. They 

just, the finances prevented it from being --

 MS. OAKLEY: Harriet.

 CHAIR BEHAR: This was something that 

had been brought forward by the public, to look 

at the ancillaries, and so we put it in there. 

And then in the discussion with the NOP, we came 

to a consensus that really we wanted to focus on 

the actives. 

 It was really kind of a timing thing. 

But yes, this was -- it was removed. But you 

know how it is? I mean how many weeks has it 

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been since we submitted the materials, and we did 

not stop working on it.

 (Simultaneous speaking.)

 MS. OAKLEY: Okay, yeah. Speaking of 

timing, we're, you know I'm that person. So we 

are late, but I'll let Dave have the final 

comment, since you raised your hand, and then 

we'll end the discussion on this.

 MR. MORTENSEN: Yeah. I guess I just 

would like to reiterate that it was never the 

intention that this was going to be used to -- I 

completely agree with the point that Harriet made 

at the very outset and has, I think said at least 

ten times during the course of the last three 

days: It was not intended ever to be eliminating 

things. 

 To me after listening to the food 

safety -- the excellent presentations that our 

commenters made on the importance of food safety, 

it seems to me it's all the more important that 

we have a more systems-oriented approach to 

evaluating some new things. Where does it fit, 

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under what circumstances would it be used, and I 

think the point that Asa just made is an 

excellent one.

 So I think this strengthens our 

capacity to evaluate the fit of new things, and 

the fit of old things as we go forward with 

sunset and new petition materials. So I, that is 

clearly the spirit of this, and that's what I 

think we want to try to accomplish with it, and I 

think I'll finish there.

 MS. OAKLEY: Paul.

 DR. LEWIS: Just one additional 

comment, and we're looking at the 16 evaluation 

criteria that's listed here. In terms of the 

conversation by the Board here, I'm looking 

forward to kind of working again with the 

Subcommittee in terms of refining. That's what 

we've been saying all along in terms of looking 

at the scope of having a TR and what will the TR 

look like. So again, looking forward to working 

with the committee in this case.

 MS. OAKLEY: Harriet, do you have any 

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concluding remarks?

 CHAIR BEHAR: Yes, I do. So we have 

already worked with Clarissa and Devon on this 

and cut it back quite a bit actually, kind of 

lumped some of them together. The reason really 

why the Materials Subcommittee came to this is 

that we felt frustrated in trying to evaluate 

sanitation materials.

 We felt that we needed a reference and 

we felt if we needed a reference, future NOSBs 

also needed a reference. So I know there has 

been discussion about having a panel, but we felt 

that a panel would not be something that would be 

present for future people to use as a reference 

to help them through, unless they wanted to sit 

and read the transcript.

 So that's why we wanted to do a TR, 

and have that information there, and that also 

makes it more available to the public, to see are 

there any gaps. Where do we see that, oh, here's 

a specific mode of action that we don't have 

anything on the National List that has this mode 

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of action. 

 So that's what that was all about, and 

I think Livestock Subcommittee, are we frustrated 

when we get, you know, a teat dip every, you 

know. Of course there's nothing this time 

around, but you know --

 But we've looked at a lot and we're 

lost, and we were like we wish we understood how 

it all works, and how each of those active 

ingredients work within a system and what's 

useful in which way. So that's why there's that 

long list, right, what works in rotation, all of 

those things. 

 MS. OAKLEY: Thank you everyone for a 

very robust discussion. I knew we needed more 

than an hour, that's all I'm saying. I do just 

want to add before we conclude the Materials 

Subcommittee that there was one comment from 

public comment to add to our work plan the 

development of criteria for evaluating products 

of fermentation processes.

 So we can go back and discuss that 

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later in Subcommittee, but thanks everyone for 

the discussion and that concludes the Materials 

Subcommittee. 

 CHAIR BEHAR: So there was some 

thought that maybe we should take a break now. 

Yes. Everybody is saying yes, and then come 

back. No more than 15 minutes. So it is right 

now 4:27. Let's go until 4:45. So you get 18 

minutes.

 (Whereupon, the above-entitled matter 

went off the record at 4:27 p.m. and resumed at 

4:47 p.m.) 

 CHAIR BEHAR: Okay. So we are back, 

and we are now on the Compliance, Accreditation 

and Certification Subcommittee. Sue Baird is the 

chair.

 MS. BAIRD: Yes, hi. The CAC 

Subcommittee has compiled a summation document 

from the past two panel discussions that has 

taken place, both in '17 and '18, and so that was 

compiled by Harriet Behar. We've had a lot of 

public comment asking for us to address organic 

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agriculture impact of energy infrastructures.

 We're cognizant that there are a lot 

of subcategories to the impacts from energy 

infrastructures that could come. It impacts 

water quality and which would transfer into 

several different governmental agencies. It 

could impact soil quality.

 So we've been asked, it's been 

requested that there would be a panel compiled to 

determine what all of the impacts are to the 

organic agriculture. We've asked NOP if this 

could be put on our working agenda, and they are 

considering it at this point. So with nothing 

more to say, Harriet would you want to discuss 

your summation document?

 CHAIR BEHAR: Thank you. I've been a 

little busy bee. Okay. So this Compliance 

Accreditation Subcommittee oversight of 

improvements to deter fraud discussion document 

basically was a way to put in writing a summary 

of the excellent import fraud panel that we had, 

as well as the many public comments that we 

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received during that meeting, where we really 

focused on this really important issue.

 There was a lot of approval for the 

direction and items listed in this document, with 

numerous responses to the questions on which 

items should be prioritized. I encourage the NOP 

and I actually have already done that directly 

with NOP staff, to review the excellent comments 

received on this topic, since they are currently 

involved in rulemaking on this issue.

 These public comments could then aid 

them in targeting the issues that certifiers and 

the trade see on the ground as really needing the 

most attention. The community is very interested 

in having rulemaking that will be as effective as 

possible, with a strong focus on items that can 

make the most difference.

 There was expansion of tariff codes 

mentioned, which I don't believe is something 

that NOP would put into rulemaking. But I 

encourage NOP, and Jenny can speak to that after 

I'm done, and hopefully the NOP can facilitate 

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that activity.

 Specifically, and I actually offered 

to help the program with this, OTA, OFARM, Food 

and Water Watch, Oregon Tilth and Organic Produce 

Wholesalers Coalition had especially good 

comments on this subject. Some of the public 

comment that we received verbally also I took 

some notes on.

 There was a request for better product 

labeling that correlates to the information on 

the certificate, including the certifier, the 

actual name of the product and that's sort of 

documentation that a lot of times it's hard to 

verify that what you have in your hand is 

actually being certified by the certificate in 

your other hand.

 And as well, the Organic Integrity 

Database should also then be integrated with that 

as well. So there's real clear nomenclature and 

semantics, and it's just -- it's not like you're 

playing, you know, find the needle in the 

haystack. 

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 A lot of times that it's almost like 

you are being a detective when you're trying to 

figure out is this product really certifies, and 

is this really the product being represented by 

the certificate I've just been handed?

 Another point that was made was that 

import certificates need to be tied to the 

production capabilities and stock on hand, 

similar to the transaction certificate system 

that we actually did have in the past, where 

certifiers kind of got in the middle of the 

trade.

 And when someone wanted to sell 

something, they went to the certifier and asked 

for a certificate on that transaction, known 

officially and fondly as the TC. There are some 

certifiers that are still doing this, but then 

they would look at what the producer had in 

stock, what they said they were going to produce, 

and then they could subtract the amount that had 

been sold and keep track of it that way.

 So there's some kind of system like 

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that that was suggested by a public commenter. 

There was also discussion of a pesticide residue 

testing database. Since testing is already done 

but it's not collated and available to others or 

the general public, I'm not sure where that would 

all go.

 And that there really was a strong 

push for having acreage per operation as a way to 

estimate the amount an operation could produce. 

I believe that most certifiers do collect that 

acreage information, and a lot of them also put 

it directly on the certificate, but it doesn't 

end up in the Organic Integrity Database.

 There was some concern that stop sale 

authority might take too long for the NOP to do, 

but a general encouragement that they should 

start working on it so it could occur, and that 

we do need collaboration between certifier, 

states and federal authorities in that stop 

authority, I mean stop sale authority.

 I'll just give a short personal. I 

went to -- I did an organic inspection, it was 

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many years ago, where I found fraud and there was 

product about to be sold. I knew it was 

fraudulent and the farmer knew that I knew it was 

fraudulent. I contacted the certifier and I 

contacted the state it was in who had an organic 

certification program, not a state organic 

program with enforcement capabilities. But that 

state also had a certification.

 I called both certifiers and informed 

them of what I found, and neither of them could 

stop that sale. I didn't, I don't know if the 

certifier I told who the sale was going to go to, 

but there are times when we really do need that 

authority to get in there when we see something.

 Now, you know, we're not talking about 

a boatload, but it was a couple of semi loads of 

grain that was -- had been grown using prohibited 

substances. So with that, I am done.

 MS. BAIRD: Any discussions? Please. 

No, that's not what I'm supposed to say? Oh Jen? 

Yes, please.

 DR. TUCKER: First, I want to thank 

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everybody that submitted public comments on this 

issue. I know we've been hearing for the last 

couple of days that most of the groups 

represented here today do have fraud and import 

oversight as their top priority. So I do 

appreciate when that -- I appreciate the 

investment and comments that people have made. 

This has been an ongoing work and discussion has 

been enormously helpful to hear from the 

community.

 An awful lot of what is being 

discussed here will be reflected in some way in 

the proposed rule. So when those comments come 

in, again I encourage folks to really read them 

and respond. On the tariff codes, that will be 

something that we wouldn't do through rulemaking. 

So that was correct.

 However, we have recently updated our 

memorandum of agreement with CBP, Customs and 

Border Protection, to fundamentally rework how an 

AMS, our agency overall, accesses information in 

the automated commercial environment, so that 

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it's not tied, it doesn't have to be tied to a 

very specific code.

 We get to look at cross-code 

categories rather than specific codes. That will 

down the road make an enormous difference for us. 

Once we have more visibility into organic 

imports, I have a feeling that this tariff code 

issue will every time you solve a problem, new 

problems emerge and it will become much more 

clear how badly these are needed. So I think 

that will be a work in progress.

 My final comment was on sort of stop 

sale. I just want to be really clear that this 

is not something that the NOP would have the 

authority to do on its own. So this is not an 

NOP project that we could even take on. This 

would be something that would have to be a change 

in the Organic Foods Production Act.

 It is something that has been 

discussed in the past. There are lots of 

intricacies about it. But I just want to be up 

front in terms of what the limitation would be of 

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that. We've had a few comments on notification 

systems. 

 NOP is currently working on building 

out our accreditation system, to allow alerts 

more easily to certifiers. So that when 

something does happen, for example with the 

change of the certification or accreditation 

status of a certifier, all the certifiers would 

get an alert in their dashboard. 

 So that's an immediate step we're 

doing to communicate with certifiers. We'll then 

figure out how to expand notifications as 

appropriate and with respect to due process to 

trade. So wonderful, thoughtful comments and 

feedback. I appreciate so much the Subcommittee 

continuing this dialogue. So thank you. 

 MS. BAIRD: Thank you. Tom.

 MR. CHAPMAN: I had a question for 

Jenny and then a question for the Subcommittee. 

Jenny, you just talked about changing the MOU to 

be able to cross-codes. I'm not sure if I'm 

following what you meant by that. Is that like 

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you're trying to embed organic status outside of 

the HS coding, or are you trying to be able to 

get multiple codes all related to organic at the 

same time, or am I completely interpreting what 

you said wrong?

 DR. TUCKER: Let me try again, because 

it's actually -- it's complicated, and so maybe 

if I explain it again I'll get it right. So 

right now, it has to do with how AMS accesses 

data. And so right now, at the former MOU of how 

AMS as an agency accesses data was at a very 

specific code level.

 Instead, we now are organizing it by 

categories. So instead of having to identify 

every single code that we might be able to see 

related to organic, we get to see the entire 

category, which means it doesn't have to have an 

organic code in the tariff code for us to be able 

to see it.

 Once we have -- and that doesn't --

honestly, that's useful now kind of, but it will 

be really useful once we have import 

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certificates. So once we have import 

certificates and we can look across categories, 

it will just -- so much more data will be 

available to us than otherwise.

 So I think this is work that's going 

to take a long time, but putting this kind of 

infrastructure in place will help us once we have 

the electronic import certificate. So it's a 

huge domino game, but we're trying to set up the 

dominos appropriately, while also stopping the 

bad guys in the meantime. And so it's a 

balancing of projects.

 MR. CHAPMAN: Okay, question and then 

probably a statement after that. The question is 

what's next for the Subcommittee? What's the 

next areas of work that they should be focusing 

on on the subject matter, and you know, the 

question to Jenny as well, you have depending at 

this point, but also to the Subcommittee or other 

members.

 MS. BAIRD: I'm new to this committee, 

so it's hard for me. It would seem logical to me 

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that there are many different facets to fraud. 

We've heard, we've heard domestic fraud. We've 

heard import fraud. We've heard fraud in 

livestock. We've seen fraud in vegetable 

production.

 And perhaps we might take bites at a 

time. I think that we can't address all of them 

at one time. It's just not time. There's just 

too much time constraint. I know, I feel like 

that NOP's doing an incredible job of 

implementing procedures for imports.

 I would make a comment, Jenny, and 

I'll get to you. I'm not ignoring you. But you 

have MOUs for some things and you said you don't 

have stop sale authority, and we understand that. 

We know that is absolutely true. But would it be 

possible to do a MOU to another agency that does 

have stop sale authority such as grain agency, 

grain -- what's the title of the grains? I've 

lost their agencies.

 But they do have stop sale authority. 

So perhaps that might be something to at least 

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look at.

 DR. TUCKER: Do you want me to 

respond?

 MS. BAIRD: Yeah, sure, sure.

 DR. TUCKER: You know, we're having 

that conversation with APHIS right now. You 

know, APHIS has its own set of regulations. You 

know, how we could have APHIS do some of our 

enforcement. It really does come down to the 

authorities that they have their regs.

 I do think in working with the CBP 

working group, we're going to get a much better 

of, you know, how far their authorities can come, 

how far our authorities come, and how we could 

leverage some of their authorities differently. 

That's why I'm really -- I'm excited about the 

work group of ways of raising possibilities we 

don't even really know about yet. So that's a 

point very well taken and I agree with.

 MS. BAIRD: Thank you. Harriet.

 CHAIR BEHAR: I'm just wondering since 

they're working on some pretty robust rulemaking 

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to come out in the fall, if we should wait and 

see what they've done and then continue work 

where we feel that there's the next steps to 

take. 

 MS. BAIRD: Emily.

 MS. OAKLEY: Yeah. I mean I think 

what helped us last year was having Jenny on our 

calls and getting some guidance about where it 

was most useful for the Committee to focus its 

attention. So I think inviting her back to our 

next call or, you know soon so we can be prepared 

for the fall would probably be helpful.

 MS. BAIRD: Dave.

 MR. MORTENSEN: In response to Tom's 

question, which was to the broader board what are 

some of the next steps, I first should have said 

yesterday, I think it was, that I was really 

impressed with the integrity presentation that 

Jenny made at the morning of the first day, 

whatever day that was, yesterday. Sorry.'

 Really, given where we were only a 

year ago or a year and a half ago. So thank you 

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for that team. One of the things that I was 

thinking about after the presentation is that it 

would be helpful, I think, for the Board to get a 

little bit deeper into the weeds of what are the 

data telling us about how well we're doing.

 I think you presented some encouraging 

signs, and I'm sure you made it clear, Jenny, 

that some of that data can't be revealed because 

it would reveal how the risk analysis and all of 

that helps identify problem spots. 

 But it would be some of the things 

that I think got us concerned about this in the 

first place a couple of years ago, were that 

fraud was undercutting the price of grain. 

 We were losing confidence in our 

ability to know that we were catching the problem 

entries of grain, that we were concerned about 

even knowing what country the grain was coming 

from, were some of the things people were arguing 

and presenting to us.

 It would be really interesting if we 

could maybe at the next meeting, or maybe during 

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phone calls, as Emily was saying, if we could get 

into some of the, you know, sort of outcomes of 

the early phases of the data dive that you're 

doing. That would be something I would like to 

have a greater sense for.

 MS. BAIRD: Tom.

 MR. CHAPMAN: I think I had three 

areas that I would suggest to the Subcommittee as 

well. Let's hope I can remember all three right 

now. The first one is, you know, a quarter of 

enforcement activities, roughly at least that's a 

stat I heard at one time from the USDA, is 

handled by the California State Organic Program, 

and we haven't heard from them about enforcement 

challenges and opportunities, what's working for 

them, what's not.

 The different party that's going 

through the same thing with the USDA is I think 

they would -- I think it would be great to bring 

them in and give them some time to talk about how 

they manage it, what they're going after, what 

the challenges they face, what tools could 

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potentially help them to be more effective.

 That's an area we haven't explored. 

So I would encourage reaching out to the 

California state organic program. -- I knew I 

wasn't going to remember all three, but like you 

stirred them all up and I'm pulling that.

 The second one, and this is -- I was 

going to save this one for the last, because this 

is the one I care the most about, is the Organic 

Integrity Database is an amazing tool. As the 

sourcing manager who leads a lot of the antifraud initiative work that Clif Bar does, that's 

an amazing tool to use.

 Now its biggest shortcoming is 

operations that are not in it. I know we've 

raised this up in the past and it's part of other 

things. But I think understanding potentially 

the items aren't in it are recognition agreements 

and equivalency agreements. I understand the 

challenges to putting those into the OID, or at 

least the equivalency agreements into the OID.

 But I think further exploration on 

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that could be helpful, both understanding what 

goes into a recognition anti-equivalency 

agreements and what opportunities that are --

could potentially add criteria over time to 

those, to encourage our international partners to 

become more robust in tracking their own 

certified entities. 

 And particularly challenging on 

recognition agreements who are certifying to NOP 

standards, to have those in the OID. I don't 

fully understand the challenges there, and I 

think that's maybe a closer install potentially, 

but something that could be explored by the 

Subcommittee is how do you sew up those gaps in 

the OID system, because if I'm looking at a 

supply chain domestically, it's amazing. And 

then I go across the board to Canada and it 

becomes a black hole.

 Or I'm exploring a supply chain in 

Southeast Asia and it's amazing, and then I end 

up in India and it's a black hole. And so right 

now it's biggest constraint is not having other 

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opportunity areas. And so I think that's -- we'd 

be remiss to not continue to explore 

opportunities and constraints and what could be 

done next in that area. I guess I'm going to 

stop at two, because I took up a ton of time.

 MS. BAIRD: You don't know what three 

is anyway, do you? Okay, Emily.

 MS. OAKLEY: Yeah, I just wanted to 

echo that, and I thought that was one of the very 

helpful things that came out of public comments 

as well, and obviously this is not an area of my 

expertise. But it's something that I immediately 

honed in on as a potential area that could be 

improved.

 So I don't know Jenny. It looked like 

you were trying to maybe raise your hand right 

before I talked. So did you -- 

 DR. TUCKER: I get so excited by the 

technology stuff. You know, I think this would 

be -- it would be really cool for the 

Subcommittee to talk about a more -- one of the 

things -- so there was a public comment about the 

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Subcommittee getting involved in this 

incremental, the Farm Bill funding and 

understanding what that is.

 So one of the things we've been kind 

of considering is you have all these countries. 

It was mentioned yesterday that don't have any 

kind of public registry and they are -- we've 

started to have conversations with them. Okay, 

what would it take for you to get a registry?

 I think sometimes we underestimate the 

technology infrastructure that we have and are 

able to deploy. One of the things we have been 

looking at is how -- we have the integrity 

database. 

 How could we create an open source 

organic integrity database that other countries 

could either have -- they could deploy in their 

own environment or we could have in a U.N. cloud 

or something like that, where these countries 

could use an open source version of the integrity 

database to load their own data in.

 The main reason -- the difficulty 

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with, you know, the equivalency arrangements and 

the recognition is I don't want Stacey Swartwood 

to become an international help desk. I mean 

honestly it really comes down to that. She 

spends a lot of time on the phone with certifiers 

helping them get their data into the system, and 

so it's really how do we manage that kind of --

it's hard enough with certifiers whose first 

language is English, right, and trying to explain 

how to do all of this.

 So that is a challenge. But if we 

were able to deploy a system that they could then 

use, if it were a version of our database, it 

would already be mapped technologically, which 

would then immediately allow some data exchanges, 

all the way into import-export systems. So just 

looking down the road.

 So I think it would be really exciting 

as a board to talk about these kinds of 

possibilities, of where is the biggest bang for 

the buck in terms of protecting all of the 

integrity, not only in the U.S. but around the 

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world, a global system. I get really worked up, 

so I'm going to stop now.

 MS. BAIRD: I did want to commend you. 

Quite a few of the commenters were saying, you 

know, we just need more training for our 

inspectors and certifiers. So I think you've 

addressed that well. 

 Just some anecdotal and not wanting to 

take time up, but I've had a lot of certified 

entities when you go and inspect will say well, 

I've never had this kind of audit. Why are you 

trying to audit all this stuff?

 And that I think is a key, although 

I'm not sure if someone is truly intent on 

cooking the books if any true, any inspector can 

find that. I say that because I was one of the 

inspectors for one who just got busted, and in 

fact FBI would actually did it. They didn't find 

it either.

 So I'm not sure, but I do think the 

training is critical and thank you for that. Tom 

had his hand up. He's remembered his third 

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point.

 MR. CHAPMAN: Fresh produce supply 

chains. They're unique, they're different. We 

got a lot of public comment on those. I imagine 

some of the rulemaking touches that area, so 

there could be reason to pause on that one. But 

it's so unique and it's so diverse, and I think 

there's a lot of opportunity to go deeper in that 

realm as well.

 MS. BAIRD: Scott.

 MR. RICE: Thanks. There was also 

some good suggestions in the comments from the 

certification community about the desire to have 

more training on, and kind of best practices on 

communicating between certifiers on confidential 

information and feeling comfortable doing so, and 

how to have parameters around how to do that and 

do it efficiently and responsibly.

 Especially I think with some of our 

international partners is where, to Tom's point, 

that kind of breaks down on our side of things as 

well. And just to an overall work plan, I think 

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I do see this Subcommittee having a big role once 

that proposed rule comes out, and I think we'll 

really be able to sink into areas that we can 

build recommendations and move from there, and 

kind of help in that process.

 MS. BAIRD: Did you have your hand up 

Steve?

 MR. ELA: I just want to say this is 

most animated I've seen Jenny the whole meeting, 

which is cool. I mean thank goodness you're 

working and this excites you, because I mean it 

really does have such meaning to our community 

and to our price structure, and to our consumers.

 MS. BAIRD: No, it's great. I think 

it's wonderful that you're so animated about 

protecting organic integrity, so thank you. Any 

other comments? No, okay. Back to you.

 CHAIR BEHAR: So with that, thank you 

Sue. We're not having another break, forget it. 

But so we go to the Livestock Subcommittee. 

Scott, you are the chair. So take it over.

 MR. RICE: Thank you. Got my notes up 

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here. We have got one proposal today on oxalic 

acid, which was petitioned to us and a number of 

-- excuse me, and one discussion document, and a 

number of sunset items.

 I think what we're proposing to do 

today is just move through those sunset items 

without our usual kind of formal presentation of 

describing each of them and move into each of our 

respective assigned materials, and offer a roundup of comments and use in brief, to try and keep 

us a little closer to schedule. 

 So just as a heads up to folks as we 

move forward. But our first item is, as I noted, 

oxalic acid, and I will turn that over to the 

lead who is Harriet.

 CHAIR BEHAR: Harriet again. Okay, so 

it was kind of a no brainer that I take this 

material since I'm the beekeeper, right, and we 

did not receive very many comments. But I'm 

looking at Garth, who gave really very important 

comments to this. 

 There were comments that echoed the 

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information in the proposal, that there was no 

NOP apiculture standards, and then felt that 

adding materials to the National List should not 

be done if there's not an overall standard to 

oversee this.

 However, in response to that, we are 

in a place where there are organic honey 

producers, a few of them being domestic. I know 

there are a few in the Upper Midwest. There's 

quite a few I think in Hawaii in comparison to 

other places. 

 I believe there's somebody in North 

Dakota and I don't know all the honey producers. 

I did not research the Organic Integrity 

Database. But in Garth's very good comments, he 

did note that there are foreign producers. So I 

just want to read a little bit of what he said, 

if you didn't have your chance. 

 This material is allowed under the EC 

or the European Union, since the largest 

consumers of organic honey in the world are EU 

member states. Most of the organic honey 

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projects in South America are already certified 

to this standard, with NOP certification coming 

to them as an added overlay.

 Because of the lack of harmony between 

the EU and the NOP standards with respect to 

synthetic materials allowed in apiculture, there 

exists much confusion on the part of the 

producers and managers regarding allowed 

materials for the control of varroa mites.

 He says that he's seen several 

projects fail to obtain NOP certification due to 

the confusion over what materials are allowed or 

not. He also recently taught a course to organic 

inspectors on organic apiculture, and the lack of 

harmony between the two standards was a major 

topic of conversation.

 In his experience, and I know he is a 

beekeeper as well as myself, beekeepers tend to 

prefer oxalic acid over formic because it is less 

irritating to both the bees and the beekeepers. 

In addition, the ability to vaporize the oxalic 

acid in the hive without opening up the hive 

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bodies is particularly attractive to beekeepers, 

and for those of you that are not beekeepers, you 

probably would not want to open up a hive.

 And especially in the cooler climates 

where opening the hives especially in early 

spring could chill the brood and even the queen, 

and that is not a preferred activity. The point 

that I made in the proposal too was that it can 

be used in a sugar syrup and drizzled over 

packaged bees, and that is a great need.

 I personally have received packaged 

bees that arrive full of mites, and I don't have 

a tool to deal with that, and then I put them in 

my hive and then I'm just -- they just explode. 

So the fact that -- and formic does not have that 

mode of action. So this is a special and needed 

activity.

 As far as not having a standard, I 

feel -- this is my personal view -- I am not an 

organic beekeeper. I don't get my hives 

certified, but I do manage them organically, so 

I've never used oxalic acid. That because there 

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is not a standard, I don't think that we should 

punish the organic beekeepers and not give them a 

material that they need. That's it.

 MR. RICE: We can open it up to 

discussion. Comments, questions for Harriet? 

 MR. MORTENSEN: Harriet, I was 

wondering if you could just give us -- the vote 

was, there was one against and five in support in 

the Subcommittee. Could you just give us just a 

thumbnail sketch of the thinking that underpinned 

the vote?

 CHAIR BEHAR: Yes, and that was 

mentioned in the proposal. That was because 

there were no apiculture standards. That was the 

reason that the person mentioned that they would 

not vote for this, because without standards 

there should not be materials. I think you --

okay, okay. Ashley.

 MR. RICE: Ashley.

 MS. SWAFFAR: Okay, good. Yeah. So 

I was the no vote on this one, just based on that 

whole no standards. I understand that bees are 

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classified as livestock, but I do question kind 

of how some folks are producing -- if anybody 

really is producing organic honey in the U.S.

 Just a few folks I think are. I 

really don't have any objection to this material, 

but that's just kind of the basis of where I was 

on that no vote.

 MR. RICE: Emily.

 MS. OAKLEY: Yeah. So oddly enough, 

I find myself conflicted as well, just because 

I'm not clear about why there aren't apiculture 

standards. I'm not clear why there aren't more 

organic honey producers, and I was just hoping 

Harriet could expand on that.

 Like if there are only a few 

producers, why is that? Why is it that people if 

they're technically allowed to certify to the 

existing standards not doing so?

 CHAIR BEHAR: Okay. So there are no 

standards specifically to apiculture, but the 

NOSB did pass an apiculture standard twice. The 

first one went through and then it was redone, 

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and actually I and Garth and some other people in 

the audience were on the task force under the 

Accredited Certifiers Association and actually 

pretty much handed the standard to the NOSB. I 

think they changed two words from our 

recommendation.

 Honey is concentrated flour nectar, 

and so we felt quite strongly that the honey 

needed to come from land that had not been 

treated with prohibited substances. And so we 

have a 1.8 circular diameter forage zone, 1.8 

miles, with an extension going out to four miles 

of what we called a review zone or something, 

where like -- 

 MALE PARTICIPANT: Observation zone.

 CHAIR BEHAR: Observation zone, yeah. 

So we couldn't, there wouldn't be like dumps or 

golf courses or something that was highly 

attractive to the bees. Most bees will stay 

within the 1.8 miles. Those that go further, 

many times they don't make it home, so they're 

not even bringing back nectar to the hive or 

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pollen.

 So that has been one of the areas. So 

and if you're in an agricultural area, try to 

find 1.8 mile diameter where you don't have any 

prohibited substances in the United States. But 

there are places out west where there's 

rangeland. What I know of is up in the Upper 

Peninsula of Michigan.

 There are places actually. There is 

a place near my house where I could produce 

organic honey. The owner of Land's End before he 

sold it to Sears has a large tract of land, and I 

could put my hives there. He doesn't use any 

prohibited substances. But I mean so there are 

places you could find, okay, if you're 

interested.

 They also have quite a bit on 

materials in there and about the wax in the hive 

and all that. Now as for why the NOP did not 

move forward with the apiculture standards, I do 

know that I did receive quite a few phone calls 

from NOP staff within the two years after those 

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standards were presented by the, as a 

recommendation for the NOSB, and then it all when 

dark.

 And no more. I mean when Miles was 

there he did mention that it was in process, in 

process, and then now I have heard from the NOP 

that it's not a priority, perhaps because there's 

not a lot of domestic production. I don't know 

if there is. 

 It is an important industry in Hawaii, 

organic honey. So that is still a state in the 

union, and actually on the mainland we do get 

organic honey from Hawaii. So I can't speak to 

that. I don't know if Jenny wants to say 

anything. She has mentioned in the past that it 

was not a priority and so it was not moving 

forward. If you want to say more, go ahead.

 DR. TUCKER: Yeah, I would say yeah, 

our priorities are very much strengthening 

organic enforcement, the fraud, import oversight 

and dairy compliance. Those are our top 

priorities right now. Origin of livestock 

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clearly a high priority moving forward. So 

that's, those are the priorities where we're 

really focusing on at this time.

 CHAIR BEHAR: However, there are 

numerous accredited certifiers here in the U.S. 

that are certifying organic honey. There is 

organic honey carrying the USDA seal in the 

marketplace, and this material would be very 

useful in perhaps growing that domestic market, 

because varroa mites are one of the main parasite 

issues. This invasive pest has been devastating 

to the vitality of honey bees overall and to the 

bee colonies.

 MR. RICE: Okay. I've got Tom and 

Emily.

 MR. CHAPMAN: So while there is some 

limited domestic production, there is a sizeable 

amount of foreign production of this product, 

particularly in areas that have tropical rain 

forests that allow for a wide, certified 

controlled wild forage areas for bees. If you 

look, honey is one of those rare commodities that 

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actually have an organic tariff code so it's 

imports are tracked.

 In 2018, there was 23, over 23,000 

thousand metric tons imported into the U.S., with 

90 percent of that coming from Brazil. So 

fortunately I hear there's other origins like 

India, but India is a black hole, so it's a 

little hard to find certified operators out 

there.

 But it is a big commodity, and there's 

hundreds of people on the Organic Integrity 

Database that are certified for honey bees and 

livestock and crop scopes. The other thing to 

keep in mind, I did another search in the OID for 

just the word honey for people who have a 

handling scope, and there were 609 operations. 

 This isn't a count of products, but 

this is a count of operations that use honey in 

some form. My company is a company that uses 

honey in some form. It's a natural sweetener, 

it's great, organic honey.

 And just if you take that out of the 

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total of certified organic handlers, there's 

1,800. That's 3.3 percent of certified handlers 

have a honey product that they market. So it is 

a large market that enables the sale of other 

organic goods. Just because this isn't a wide 

production item in the U.S. doesn't mean it's not 

an item that organic consumers should have access 

to.

 MR. RICE: Emily.

 MS. OAKLEY: So Harriet, that came 

super-close to fully answering my question. But 

are you saying that the main reason that there is 

not U.S. organic honey is because certifiers 

would follow the NOSB standard, even though it 

wasn't passed as a rule, and therefore growers 

don't have access to enough -- okay sorry, Tom. 

 You're both shaking your head. So I 

still don't understand why there isn't a robust 

U.S. production when people can find those 

regions.

 CHAIR BEHAR: I believe it's the 

forage zone, but truly varroa mites are an issue, 

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and so there's, you know, it's not that easy. I 

mean myself as a beekeeper, I do a lot of 

cultural activities. I'm in my hives once a week 

if not twice a week during the warmer months. I 

mean, and when people come to me and I mentor 

people as beekeepers, I say you have to be in 

your hives every week. 

 They're like oh, you know, I don't 

live up here and whatever. No, you cannot --

it's not like the old days when we didn't have 

mites. You have to be in those hives. So it's a 

lot more labor to not use chemical controls for 

the varroa mites, and I say also the forage zone 

is an issue why there's not.

 But there are organic. There are 

certifiers who are certifying to their own 

standard. Many of them rely on the 

recommendation that was passed but not 

implemented by the NOP. I don't know what every 

certifier's honey standard is. But I know that 

there are beekeepers who would welcome oxalic 

acid. 

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 MR. CHAPMAN: And it's economics. So 

in Brazil, you plop them down in one spot in a 

single forage area, and they can forage 365 days 

a year for tropical flowers. You plop them down 

somewhere in the U.S. and the forage zone allows 

them to forage while flowers are in bloom.

 But when they're not, they need to 

move. So the honey industry in the U.S. moves 

around, which would mean you'd need multiple 

forage zones year-round. So that kind of just 

knocks you out in the U.S. If you notice they 

move a lot. I didn't notice, but the honey 

industry in the U.S. has mobile honey bees that 

move from crop to crop and that --

 You know, each of those forage zones 

you move to and those economics are don't meet 

the needs, then you're going to have a more 

expensive or limited production environment, and 

it just kind of makes you uncompetitive with 

international honey bees from tropical areas.

 MR. RICE: And I think it just 

generally gets down to that, that large forage 

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zone that's required, forage and observation. 

It's just such an extensive area that it 

effectively makes it impractical. Harriet.

 CHAIR BEHAR: For the honey producers 

that sell regionally or direct to consumer don't 

typically move their hives. It's just the larger

 MR. CHAPMAN: Exactly, yeah. That's 

why you don't see a more robust, because it's 

kind of limited to that --

 CHAIR BEHAR: Yep. To regional, yes.

 MR. RICE: Okay Ashley, and then I 

think we're going to need to wrap it up here.

 MS. SWAFFAR: So sorry. So yeah. I'm 

going to hold fast on my no vote on this, just 

because we did not hear from producers. The only 

person we really heard from that had a positive 

on this was Garth, I'm sorry. 

 But we did hear from NOC and Beyond 

Pesticides that, you know, echoed my sentiment of 

we should not be voting on petitions for items 

that don't have standards, and so I am going to 

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hold fast on my no vote on this one. Thank you.

 MR. RICE: Tom.

 MR. CHAPMAN: Just one. I mean the 

one thing I want to say is deep in the Amazon, I 

don't know how well the NOP docket penetrates, to 

get the comment that you want to have on the 

needs for some of these items.

 MR. RICE: Are we ready to move this 

forward? All right. This comes to us as a --

get my document open -- a motion. We need to go 

with a classification motion. This was coming 

from committee from Harriet, seconded by Ashley, 

and our vote begins with -- and again this is 

classification, with Dan or Sue.

 CHAIR BEHAR: No Sue.

 MR. RICE: Sue.

 CHAIR BEHAR: We're voting on the 

classification.

 MR. RICE: This is classification.

 MS. BAIRD: Yes.

 MR. RICE: As a synthetic, excuse me.

 MR. CHAPMAN: Can I ask for a quick 

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point of order? Can we read clearly what the 

motions are and who made it and seconds before 

the votes?

 MR. RICE: Yes we may.

 MR. CHAPMAN: Okay.

 MR. RICE: The first motion is for --

to add, excuse me, I'm having trouble with Excel 

cells here, to classify oxalic acid as synthetic.

 CHAIR BEHAR: You might want to say 

the full thing, oxalic acid dihydrate.

 MR. RICE: Very well. 

 MS. BAIRD: Yes.

 DR. SEITZ: Yes.

 MR. MORTENSEN: Yes.

 MR. BRADMAN: Yes.

 MR. RICE: Yes.

 MR. ELA: Yes.

 MS. OAKLEY: Abstain.

 MR. BUIE: Yes.

 MS. ROMERO-BRIONES: Yes.

 MS. DE LIMA: Yes.

 MR. GREENWOOD: Yes. 

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 CHAIR BEHAR: The chair votes yes.

 MS. SWAFFAR: Sorry Harriet, I was 

next.

 CHAIR BEHAR: Oh, I'm sorry.

 MS. SWAFFAR: Yes.

 MR. CHAPMAN: Yes.

 MR. RICE: There was --

 MS. OAKLEY: Could I change my vote? 

My brain was in the wrong place. That wasn't 

abstain on this. That was yes.

 MR. RICE: Okay. I'm glad this is 

going so swimmingly. Okay, 14 yes. Let's hope 

the next one's smoother. 

 The next motion is to add oxalic acid 

dihydrate to 205.603(b) as topical treatment, 

external parasiticide or local anesthetic as 

applicable, with the annotation, excuse me, the 

annotation for use as a pesticide solely for 

apiculture. This motion was -- it was a motion 

from Harriet, seconded by Ashley in Subcommittee. 

Voting starts with Dan.

 DR. SEITZ: Yes. 

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 MR. MORTENSEN: Yes.

 MR. BRADMAN: Yes.

 MR. RICE: Yes.

 MR. ELA: Yes.

 MS. OAKLEY: Abstain.

 MR. BUIE: Yes.

 MS. ROMERO-BRIONES: Yes.

 MS. DE LIMA: Yes.

 MR. GREENWOOD: Yes.

 MS. SWAFFAR: I like that abstain. 

Yeah, abstain.

 MR. CHAPMAN: Yes.

 MS. BAIRD: I would love to say 

sustain because I have -- but I'm going to say 

yes.

 CHAIR BEHAR: Chair votes yes.

 MR. RICE: That was 12 yes, 2 abstain, 

no recusals, no absence. The motion passes. 

Okay. Next is a discussion document on the use 

of excluded method vaccines on organic livestock 

production. This goes back to Harriet, and just 

a time check. We are at 5:37 and let's keep our 

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discussions relevant and on track here.

 CHAIR BEHAR: Okay. This subject did 

have numerous comments. There were three options 

presented to the public for how to deal with this 

issue, with the inconsistency in implementation 

and even within the rule, because there's various 

places where vaccines are mentioned, excluded or 

not.

 So the first one was to follow the 

current rule entirely as it's written and start 

reviewing known excluded method vaccines for 

individual placement on the National List. 

Approval of vaccines produced through excluded 

methods as a class of vaccines, and place this 

class of vaccines on the National List. Or, yes. 

And then lastly to change 205.105(e) to state 

that excluded methods except for vaccines are 

prohibited, provided there are no commercially 

available vaccines that are not produced through 

excluded methods to prevent that specific animal 

disease or health problem.

 Then we also asked about what type of 

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documentation and how hard would it be to do the 

commercial availability. Option 1 was not very 

popular. Option, okay. Option 3, the commercial 

availability, seemed to have the most people who 

approved it. Most people approved Option 3 or 

liked it.

 However, they did say that they needed 

more help in finding the commercial, you know, 

what is commercially available as non-GMO to 

serve that same disease if they are currently or 

intend to use a GMO one. They really wanted an 

easy way for themselves and their producers to 

find it. There was some discussion of the narrow 

and discrete allowance of vaccines from excluded 

methods was something we need to do, but they 

really didn't want to do that full class of 

allowing just all of them. 

 Many noted that they need this 

resource to find the non-genetically modified 

vaccines or vaccines from excluded methods, and 

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excluded method vaccines to some sort of 

maturity, to handle that determination.

 There were a few certifiers who did 

like this, the commercial availability and 

specifically said that the quantity, quality and 

function that's typically used in commercial 

availability would work for this type of product. 

So that's it. 

 MR. RICE: Thank you, Harriet. 

Opening up to discussion, questions, comments for 

Harriet? All right. Ashley.

 MS. SWAFFAR: Yeah, sorry. Yeah. 

This is a very tricky subject because in the 

vaccine community, I don't even think some of 

them realize what, if their vaccine is kind of 

made from excluded methods, because I've been 

trying to nail one of them down and they keep 

telling me that it's not. 

 But I really believe that it is. So 

I think that's really a huge challenge for us if 

go to Option No. 3, which is the middle ground 

of, you know, of requiring a commercial 

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availability search. I just wonder, you know, 

what those vaccines manufacturers, if they were 

to sign off. 

 I know one certifier showed me a thing 

that they have their clients talk to the vaccine 

manufacturer to sign off on, and I just really 

question like what if that vaccine manufacturer 

signs off oh, we don't make our vaccines from 

excluded methods but they really do. 

 So I think that's a real challenge in 

going forward with Option 3. I myself like 

Option 2, to just allow them as a class honestly, 

because I think this is a huge issue and it's 

opening a big can of worms. There are vaccines 

in the poultry industry that we are required to 

use, federally mandated by the FDA for some of 

the salmonella vaccines, and those are the ones 

that are made from excluded methods.

 So it's not like we have a choice in 

using those vaccines. So there's lots of other 

agency issues, I think, if you were to not allow 

vaccines made from excluded methods. So it's a 

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conundrum. But I do think that it's really 

important that we do figure this out, to make it 

fair across all certifiers, because I do hear 

some certifiers do not allow vaccines made from 

excluded methods to be used, period.

 And then there are a lot of certifiers 

that allow people to just use vaccines as a 

class. So I think it's very important that we do 

make a recommendation to kind of even the playing 

field.

 MR. RICE: Harriet.

 CHAIR BEHAR: I just want to ask 

Ashley. So the vaccines that are mandated, are 

there any non-excluded method vaccines available 

for that or not?

 MS. SWAFFAR: That's the one where 

that one vaccine manufacturer doesn't really 

think that they make it from excluded methods, 

but I think they do.

 CHAIR BEHAR: But is there a nonexcluded --

 MS. SWAFFAR: No. 

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 CHAIR BEHAR: So then there's --

 MS. SWAFFAR: There's two options for 

a salmonella vaccination made by two different 

companies. One definitely is made from an 

excluded method; the other one I really believe 

it's made from excluded methods, but they say 

it's not. But their competitor also says that it 

is.

 CHAIR BEHAR: Right. So that would be 

my next question. So you're thinking that 

perhaps this other vaccine maker who is not 

saying it's excluded might be trying to grab the 

organic market by being the one that's not 

excluded, and that commercial availability would 

come into play?

 MS. SWAFFAR: Yeah. But I think it is 

made from excluded methods. That's the thing. I 

think there trying to say it's not. I pulled up 

-- I want to say it's also transposons too, so 

that might throw them out if that terminology 

gets through.

 CHAIR BEHAR: Well, if it's in vitro. 

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 MS. SWAFFAR: Yeah. Let me finish.

 MR. RICE: Any other comments? Paul.

 DR. LEWIS: Scott, so a question I 

have. In the discussion for this discussion 

document, you're looking at the issue of animal 

health. So you're looking at the organic 

regulations. Was there a discussion in other 

areas of animal health about the use of vaccines? 

Or was only the conversation focusing on 

vaccines, or was it a broader issue of animal 

health? So that's, that's the first question I 

have.

 CHAIR BEHAR: I believe it does say in 

the document that we very much respect the place 

that vaccines have in promoting animal health as 

a prevention.

 DR. LEWIS: Okay.

 CHAIR BEHAR: And so we --

 DR. LEWIS: So you were looking at the 

broader issue of animal heath, yeah.

 CHAIR BEHAR: Yes. This really came 

from the inconsistent implementation of the rule, 

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with some saying the rule as written, when you 

read the whole rule, says that individual 

excluded method vaccines have to be placed on the 

National List individually. So meaning that it 

would have gone through a review, whereas on the 

actual National List it says vaccines allowed, 

right? Biologics are allowed. It doesn't talk 

about the excluded part.

 But in the other part of the rule, 

where it talks about excluded methods, it has 

that caveat specifically for vaccines. So some 

certifiers are choosing to only look at the 

National List, some are looking at both and it's 

very confusing. And so I, you know, I really 

don't have -- I prefer the commercial 

availability, you know. You'd think that Harriet 

would have an opinion.

 But I just really want it to be clear, 

and I want it to be consistent. I don't want 

farmers in Maryland to not have access to the 

vaccines they need, when farmers in Missouri do.

 DR. LEWIS: But under the broader 

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context of looking at the animal health issue?

 CHAIR BEHAR: Absolutely. We 

understand that vaccines -- we want to make 

vaccines acceptable and clarifying the 

inconsistency in implementation will do that.

 DR. LEWIS: Okay, thanks.

 MR. RICE: Ashley.

 MS. SWAFFAR: Yeah. Paul, I just want 

to clarify again, that animal health is critical 

and important for the Livestock Committee. This 

is no way wanting to take away any vaccine 

whatsoever. It is clarification among 

certifiers. 

 But I will say I didn't touch on 

Option 1. I don't think Option 1 is a great 

option because we would have to list vaccines by 

brand name under the National List, and we do not 

have anything as a brand name. We have generic 

substances. So I don't think that's an option.

 We alluded to that in this document. 

So really it's between two and three on this.

 CHAIR BEHAR: No one supported Option 

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1. But that is the way the rule is written.

 MR. RICE: Tom.

 MR. CHAPMAN: I hear some of the 

concerns about Option 3, but I don't -- I 

struggle with why it's still not the best middle 

path put forward. I think it accommodates both 

ways. The wording could potentially be adjusted 

a bit to deal with the inability to find out 

information, and then that would be also, you 

know, considered an acceptable reason to continue 

to use a substance, the vaccine. But it just 

seems like a viable middle path. 

 The other thing I wanted to just point 

out is, you know, the handling world lives in a 

sea of affidavits that we get, and it is quite 

common for us to get an affidavit answered by a 

company for a decade one way, and then suddenly 

that same item I'm buying the staff changed, and 

I get an affidavit and it's got a different 

answer that's not a good answer.

 And you know, so like that's an issue 

that exists already, but it's a technicality. I 

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think it works en masse generally, and when it's 

discovered it gets fixed. That's what the 

process is built upon. So I don't know if the 

fact that it can be difficult at times is enough 

reason to not move forward with this option, 

because I do think it's still allows for all the 

protections you have today.

 MR. RICE: Ashley, and then Sue.

 MS. SWAFFAR: So on that too, I do 

think a lot of these vaccine manufacturers will 

list confidentiality in their manufacturing 

process. So I think that adds another layer to 

it for concern. Yeah, I mean you do have that. 

But I just want to point that out, that there is 

a level of confidentiality in how they make their 

vaccinations to some degree. But they do give 

that information to APHIS.

 MR. RICE: Sue.

 MS. BAIRD: Yeah. I've as a past 

certifier approved both by I would say two and/or 

three, depending on which certifier I worked for. 

Inherently number two is always going to be the 

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easiest, you know. You just say okay, vaccines 

are allowed.

 But I think that, and I'd love to just 

go with number two. But I think if we do number 

two, just say all class vaccines are allowed, 

it's against the inherent intent of the law, 

which is no genetically modified engineered 

products are allowed.

 Number three will be a little tougher, 

I agree. It's going to be hard for those 

vaccination manufacturers to give up that 

information. It's going to have to be building 

trust with the certifier. They're not going to 

give it to producers and they don't have to. But 

they can give it to the certifier just as Tom 

says, the handlers do and it could be reviewed. 

 Or they can give it to OMRI or whoever 

and it can be reviewed under confidentiality, and 

have that list available. I think it's 

incredibly important that that list would be 

available, of which ones are approved and which 

ones are not because a producer does not have the 

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ability or the credibility to get that 

information from the manufacturer himself.

 MR. RICE: Okay. Are we ready to move 

on there? Okay. What? One moment. We have 11 

sunsets to review here, and there's some 

discussion of waiting until we're bright and 

early or we're bright and fresh. Okay, here we 

go.

 MR. CHAPMAN: Are we doing it? Yeah. 

 (Off-microphone comments.)

 MR. CHAPMAN: Point of personal 

privilege, that is -- 

 MR. RICE: Do I have a motion to 

delay?

 MR. CHAPMAN: That is the thing. It 

doesn't need to be seconded, it doesn't need to 

be recognized. I mean do we not have time to 

delay this until tomorrow? We do.

 CHAIR BEHAR: We have a lot on the 

agenda tomorrow, and we have the Crop 

Subcommittee chair has to leave, you know. He's 

got a flight. 

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 MR. CHAPMAN: We can make it do.

 CHAIR BEHAR: So I really feel like we 

need to get that. I mean I'm just -- we just --

how about if we just do a few?

 MS. OAKLEY: How about a compromise 

and we do half?

 CHAIR BEHAR: Yeah. That's where we 

were just discussing.

 MR. CHAPMAN: Let's do it.

 MR. RICE: All right. The crowd has 

spoken. We're going to move on, and 2021 sunset 

substances review. This is our first opportunity 

at this. We are not voting on these at this 

meeting. We are just first reviewing them, and 

we are going to start with atropine, which the 

lead is Dan.

 DR. SEITZ: And Scott, I wasn't clear 

on your direction. Did you want to do a very 

quick summary of the, like a 30 second summary of 

the material?

 MR. RICE: Yeah. I think our usual, 

just brief round-up and take into consideration 

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any highlighted public comment.

 DR. SEITZ: Okay. So atropine is 

approved under 205.603(a). It's a synthetic 

substance allowed for use in organic livestock 

production as disinfectant, sanitizer and medical 

treatments. Atropine may be used under the 

lawful written order of a licensed veterinarian, 

and there's a meat withdrawal period of at least 

56 days after administering the substance, and a 

milk discard period of at least 12 days after 

administering the substance to dairy animals.

 Atropine is an anticholinergic derived 

from atropa belladonna, otherwise known as deadly 

nightshade. It's isolated through synthetic 

extraction. It's a highly controlled substance. 

Its primary use is as an antidote for 

organophosphate poisoning, which most commonly 

occurs through ingestion of pesticides. It does 

have a couple of other medical uses. 

 It's allowed also under the Canadian 

standards, but it's not a substance that is 

allowed -- well, it's not referenced under Codex, 

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the European Economic Community Council 

regulations, the Japanese standards or the IFOAM 

standards. In terms of environmental 

contamination, it's seen as being unlikely that 

it causes much environmental contamination, 

because it's used in very small amounts.

 It can have an adverse effect on human 

health. It is a powerful drug, so if misused of 

course it can cause toxicological concerns. 

There was a, in the latest technical report from 

2019, there was one other substance mentioned as 

a potential natural alternative, magnesium 

sulfate, but this has not been really tested or 

used.

 And so there's currently no substance 

that's considered to be a replacement for this. 

This has been allowed for many years now, I think 

since before 2002 or around that time. It was 

also last renewed in 2017. There were only 

several comments, four or five comments in favor 

of continuing listing. 

 No one opposed the removal of it. It 

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does not appear to be widely used, but it is 

nonetheless considered essential for the rare 

times that it is needed.

 MR. RICE: Thank you, Dan. Any 

questions for Dan? Dave.

 MR. MORTENSEN: Just really quickly. 

I mean organophosphates are a very nasty class of 

insecticides, and so I'm just trying to imagine 

when this would be used by an organic animal 

person. I know if you had a split operation. In 

any case, it strikes me as odd that it's 

something that we need.

 DR. SEITZ: Yeah, and nothing I read 

addressed that. But I imagine that if a fence 

broke and your cow wandered into your neighbor's 

farm where there were pesticides or whatever, 

that would be the sort of circumstance.

 MR. RICE: And I think we can focus on 

the -- more closely on the comments that we 

received. These are -- the Board has had an 

opportunity to review these, as has the public, 

of course, and given our time, I think we can 

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keep it even briefer. Emily.

 MS. OAKLEY: Super brief, but I just 

echo Dave's comments. It seems like a weird need 

to have.

 DR. SEITZ: In the interest of time, 

I'm going to withdraw half of my summary. Let 

the record reflect that. Okay. Moving on to 

hydrogen peroxide. This is a material belonging 

to Jesse.

 MR. BUIE: Hydrogen peroxide, 205.603, 

synthetic substances, allowed for use in organic 

livestock production. Hydrogen peroxide is used 

as a readily available disinfectant and broad 

spectrum germicide. It's an important cleaning 

agent for use on contact surfaces such as 

equipment, calf pails, bottles and utensils. 

 It's been around since 1977, where the 

EPA approved it. It's a -- hydrogen peroxide is 

very simple molecule which basically consists of 

H2O2. Environmental contamination is not 

expected when purified forms of hydrogen peroxide 

are released to the environment following normal 

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use.

 Typical pesticide concentration, 

hydrogen peroxide is expected to rapidly degrade 

to oxygen gas and water. There were a few 

comments, but as you noticed they were in person 

here. We had some on the webinar had comments, 

and they were overwhelmingly in favor of keeping, 

of relisting hydrogen peroxide.

 Hydrogen peroxide is recommended for 

relisting based on the available technical 

advisory panel October 1995, the technical review 

of October 2015, the unanimous NOSB 2017 support 

of this material, and no new scientific or 

meritorious information. Are there any 

questions?

 MR. RICE: Thank you, Jesse. Seeing 

no questions, we'll move to iodine, which is 

Ashley.

 MS. SWAFFAR: So there's two listings. 

I'm going to do both of them together in the 

interest of time, if that's all right with 

everyone. So iodine is widely used as a teat dip 

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in the dairy industry; also used to clean wounds 

and combat infections, and we heard from 

commenters that iodine's anti-microbial qualities 

make it a vital product for treating and 

preventing health care issues.

 I will note that we did hear from 

several commenters that we should annotate the 

iodine listing to exclude MPEs. I would like to 

hear just a little more from the public on this, 

since we did hear from a couple of different 

commenters, one saying there was concern with 

supply issues, one saying there was not. 

 So that's something I think we'll take 

back to the committee and talk about, so we may 

be bringing an annotation forward on that. Any 

questions?

 MR. BRADMAN: Just a comment. From 

the COOP Cooperative, you know, they supported 

relisting iodine. They agree that MPEs must go, 

quote-unquote. It sounds like they have access 

to iodine teat dips without MPEs, and just in 

general MPEs are -- I mean they're kind of 

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controversial.

 They're nonylphenol, how do they 

pronounce it, nonylphenol polyethylene glycol 

ether. So it's an ethoxylated surfactant. In 

California, in the -- there's a safer chemical 

program right now, and MPEs are actually on their 

list to get taken out of laundry detergents and 

things like that. There's a lot of issues with 

this material environmentally too.

 It's relatively small use probably 

with teat dips, but something to discuss in the 

committee is at least this CROPP statement and 

perhaps others too, that there are available 

formulations without MPEs, and I think that would 

be a worthy goal.

 MS. SWAFFAR: Yep, that's what I said. 

We're going to get back to committee, because we 

heard from them that it is available. But we 

also heard from another commenter that he was 

concerned about supply issues. So I just want to 

flesh that out. 

 MS. OAKLEY: So would you be looking 

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for an annotation this fall, if you found the 

correct information that you needed this summer?

 MS. SWAFFAR: We can't, we can't do 

it. We can't annotate at sunset.

 MS. OAKLEY: We can't bring a separate 

proposal at the same time?

 MS. SWAFFAR: I don't think so, Tom?

 MR. CHAPMAN: I mean it would need to 

be an item approved, a separate item. You have 

to go through all that with NOP, but if they 

approved it and you had a proposal.

 MS. OAKLEY: Right. It doesn't -- oh 

it doesn't seem like it would necessarily 

necessitate that much work, right? I mean I 

don't know. I was just wondering if you would 

try to get that, if you found the information 

that you needed.

 MS. SWAFFAR: We'll discuss it in 

Subcommittee, yeah. Sorry, we can't talk -- I 

can't talk for the whole subcommittee. 

 MR. RICE: Okay. We are going to move 

ahead a little bit and cover methionine, since 

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we've got, as I understand it, some stakeholders 

that are leaving today. 

 CHAIR BEHAR: Okay, that's me. 

Producers and certifiers spoke in favor of 

continued listing. Other groups felt that the 

reliance on synthetic methionine did not 

encourage producers to provide methionine through 

pasture and a more systems-based approach.

 We heard from the Methionine Task 

Force panel of the continued need for DLmethionine, and how difficult it is to blend 

organic agricultural plant-based products and 

come up with a healthy ration with the right 

balance of methionine with other amino acids.

 We also heard from them that it is 

extremely difficult, if not impossible, to get 

enough methionine from pasture alone, in order to 

maintain a healthy bird. Organic Valley mentioned 

in their comments about an enhancer called 

Methiomax. I seem to be like stuck on this thing.

 Made from herbs and that's probably 

why, because I grow these herbs. Andrographis 

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tulsi and I don't grow neem. And I currently 

have them growing in my greenhouse. So that's 

why it's interesting. 

 This product is made in Belgium and 

Organic Valley is working to get approval from 

the FDA for use as a feed supplement for poultry, 

and my interest in this is that if it does work, 

which is questionable and we, you know, and it's 

natural then it could be used right away. 

 I don't know any manufacturing process 

or anything else yet. But the ingredients stated 

100 percent herbs. So all we have is that. But 

if it truly would make it so the birds did not 

need as much methionine from a synthetic source, 

that it might open the door for agricultural 

products, because one of the problems with the 

synthetic methionine now, trying to replace it 

with agricultural products is that you need so 

much of it that it then throws the whole ration 

off balance because of the other amino acids in 

the agricultural products. 

 So if we needed less, it might open 

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the door for using some agricultural products in 

place. So I'm going to obviously keep up on this 

one. Maybe I'll start feeding my birds tulsi, 

see what happens, and that's it.

 MR. RICE: Questions or comments for 

Harriet?

 CHAIR BEHAR: I just wowed them.

 MR. RICE: Okay, go ahead Steve.

 MR. ELA: Being a non-livestock person 

and I mean this is one I've seen lurking, and 

it's got, you know, I turned to all of you 

livestock people for advice. I thought this was 

really valuable. 

 The panel informed me as they -- I 

mean really a lay novice person, and it made it 

pretty clear to me what the choice was. So that 

was really helpful. So my kudos to the Livestock 

Committee and Harriet and Ashley and all for 

helping inform those of us are not necessarily 

very educated. So thank you.

 MR. RICE: Thanks, Steve. I think with 

that material -- oh, I couldn't see a hand. 

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Emily.

 MS. OAKLEY: Sorry, just a quick one, 

that I checked in with a couple of pastured 

poultry producers that I know that also use this 

material, certified organic.

 MR. RICE: Ashley.

 MS. SWAFFAR: Okay. So Harriet, I've 

never seen to many chicken people Google one 

thing in my life as that Methiomax. India's going 

crazy. They think they have a hot new thing. 

 I just want to touch on -- there was 

one comment that kind of stuck out to me. It's 

the need for synthetic methionine is the result 

of choices regarding management of organic 

poultry and flocks in this country, choices 

regarding breeds, stocking rates and outdoor 

access.

 I've been in the poultry industry my 

entire career, and the majority of that has been 

working for companies that truly are committed to 

putting birds on pasture. We do -- I've done 

pasteurized production for like nine or ten years 

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now, and that's 108.9 square foot per bird 

outside in the south, where like birds really 

probably should be out on pasture, not in cold 

climate areas.

 But, you know, we still see issues, 

because our pastures go dormant in the winter 

time. In the summer, we don't have bugs. Like 

the bugs are smart. They know. They are outside 

of the fence, because the chickens want to eat 

them and chase them out. So you know we don't 

-- you know, there's not this like great bugs.

 But you know I spend so much time 

trying to get birds to go outside, and creating 

amazing environments for birds. I get really 

passionate about that, and you know, it's still 

really difficult to get every bird outside every 

day. I'm talking from managed flocks from 800 to 

20,000. There's a little bit of difference 

between flock size, but it's really hard to get 

them to go outside and, you know. 

 Like I say, I've created environments 

for them, planting different shrubs and bushes 

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and things, and there's just a lot of chickens 

that just don't want to go outside. So you know, 

it's really hard if we were to lose this material 

to get, you know, to make it up outside.

 And then I just want to point out on 

the breeds, you know, there's no commercial 

available laying hen or broiler in this country 

right now that we could change breeds to. You 

know, we're a very small segment of the industry 

is the poultry industry.

 You know, 14 million organic layers 

sound like a lot, but that's not very many in the 

real grand scheme of things. We're an 

afterthought that they don't really cater just to 

us. So you know, there's some issues and I'm 

very proud of the work that the Methionine Task 

Force has done. 

 I think that's a -- them and the 

celery powder folks have really looked at what 

this Board has said in the past and realized that 

they need to work on finding alternatives. That 

is completely industry funded. They're spending 

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money on research to find alternatives. So I 

think that's a really great thing that they've 

done. So sorry I went so long. I'm very 

passionate.

 MR. RICE: That's great, thank you. 

Any other comments? Questions? Okay. Now I 

think we are ready to pause on the sunset review 

for today, and we will pick this up in the 

morning. 

 I would invite all of you to the third 

floor, the Northwest Room, where we are honoring 

Washington's David Granatstein for all of his 

contributions over the years with some organic 

beverages and food, so please join us. 

 Our program will start at 6:30. Brief 

words. So you have a minute to run upstairs, but 

keep that in mind. Thank you. 

 CHAIR BEHAR: Okay everyone. We'll 

see you tomorrow and don't forget to get your 

animal. Less for me to carry home in my suitcase.

 (Whereupon, the above-entitled matter 

went off the record at 6:11 p.m.) 

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a.m 1:9 4:2 125:9,10 

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118:5,12,15 122:18 

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122:9 

acres 54:20 112:18,19 

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384:18 

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134:16 236:19 305:12 

336:1,9 357:10,18 

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427:6 

acute 295:5 

Adam 122:11 

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97:12,17 99:11 107:8 

186:1 190:13 202:21 

261:22 310:21 333:1 

369:16 370:7 375:17 

375:19 394:4 417:7 

418:14 

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246:17 305:7 362:4 

402:3 

addition 31:17 46:5 

56:21 64:11 94:3,11 

94:17 95:4 174:4 

186:4 201:12 204:21 

206:17 213:17 216:19 

216:21 229:19 263:16 

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46:5 67:4 103:5 122:6 

132:1 167:22 169:4 

185:20 201:21 202:2 

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373:12 

additions 202:3 

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271:7 279:22 282:3 

282:18 284:11 286:12 

287:7 322:12 323:5 

323:17 352:20 369:1 

376:22 388:7 

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287:1 288:14 289:3 

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247:19 

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224:3 

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181:15,17 

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advisor 211:1 

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142:22 249:18 438:11 

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advocated 98:17 

advocating 98:6 

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120:1 121:3,8,19 

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327:17,18 328:17 

330:18 337:14 356:8 

372:12 389:19 431:10 

439:19 

agreed 108:10 

agreement 340:10 

383:19 

agreements 84:18 

141:18 273:17 338:2 

393:18,19,21 394:3,9 

agricultural 15:19,21 

16:6 17:9 30:22 63:13 

72:15 113:13 162:20 

163:12,13 171:2,6 

185:2 210:22 336:6 

408:3 442:12 443:15 

443:18,21 444:1 

agriculture 1:1 63:14 

63:18 92:6 121:6 

126:20 129:12,19 

154:2 155:10 172:9 

174:2 191:15 213:2 

223:17 224:3 233:7 

235:22 264:21 315:7 

317:8 331:10 354:2 

377:1,11 

ahead 35:17 71:5 74:1 

101:22 149:10 165:9 

209:13 249:6 278:19 

299:22 343:7 345:16 

409:17 441:22 444:8 

aid 83:21 84:8 153:17 

159:9 202:13 236:10 

345:17 347:3 354:4 

378:11 

aids 78:19 155:10 162:5 

164:8 236:22 

ailing 107:19 

aim 65:8 

air 126:11 149:1 198:18 

alarmed 6:4 

Albert 269:14 

Albrecht 269:14 

alcohols 197:17 

alert 116:17 117:19 

277:6 385:9 

alerts 385:4 

Alex 62:19 75:19 

Alexander 58:8 62:10 

68:7 

Alexis 106:4 109:8,11 

110:20 111:6 

algae 139:22 163:15,22 

164:4 165:15 166:1 

align 22:14 107:12 

201:10,14 

alignment 34:14 

aligns 185:8 

alive 189:22 

Alliance 98:13 231:2 

341:18 342:9 354:22 

355:14 

allies 270:10 

allocates 276:19 

allotment 359:9 

allow 10:6 12:5 27:20 

54:11 66:3 80:18 

118:16 153:15 170:2 

203:4 207:19 221:5 

234:15 318:15 321:13 

357:1,3 385:4 397:15 

410:20 423:12,21 

424:4,7 

allowable 316:2 

allowance 34:13 97:19 

159:6 164:16,21 

186:6 421:14 

allowed 5:4,16 57:10 

60:6 66:19 84:5 92:6 

97:14 136:21 156:10 

156:10 161:1 164:12 

172:11 181:11 185:2 

185:14 200:14 201:2 

209:12 214:19 216:22 

234:4 246:18 262:1,2 

273:11 370:2 402:19 

403:6,8,12 406:17 

427:6,7 431:2,5,8 

434:4,20,22 435:17 

437:11 

allowing 36:20 155:2 

202:19 206:14 300:6 

421:17 

allows 5:7 177:19 

246:19 263:9 414:5 

430:6 

alluded 428:20 

alter 326:14 

alternative 9:15 60:8,11 

65:16 66:2,16 214:14 

215:14 245:2 435:12 

alternatively 117:5 

alternatives 24:19,21 

34:21 66:11 99:20 

100:20 102:6 199:13 

207:20 215:20 447:21 

448:1 

alum 280:18 

alumni 171:19 260:22 

amazes 37:3 

amazing 195:21 247:11 

248:9 277:3 393:10 

393:13 394:16,20 

446:14 

Amazon 416:4 

ambiguous 36:6 

amend 162:10 249:9 

amended 88:2 

Amending 162:16 

amendment 310:11,19 

America 223:15,21 

224:5 403:1 

American 195:17 

218:13 249:14 252:18 

Americas 192:6 

amino 64:9,11,12 66:4 

442:14 443:20 

ammonia 127:2,6,7 

129:20 

ammonium 126:15,22 

127:2,12,14,18 

128:14 129:9 

amount 30:18 32:20 

35:2 40:9 54:22 73:10 

113:11 119:3 135:5,6 

135:10 147:9 151:20 

157:1 197:19,21 

215:17 241:7 249:3 

257:11 269:17 276:9 

316:22 325:2,5 

380:20 381:9 410:18 

amounting 54:20 

amounts 145:20 219:6 

295:17 435:6 

AMS 123:15 298:8,9 

383:21 386:9,11 

Amy 230:17 231:21 

232:2,5 235:8 239:17 

279:14 

analogous 170:15 

analogy 281:6 

analysis 83:12 177:10 

391:9 

analyze 117:18 

ancestor 69:8 

ancient 170:9 

ancillaries 366:22 

370:18,20 371:16 

ancillary 22:16,18 

245:10 358:6,9 

364:20 365:3,12,20 

366:1,5,7,11,17 367:3 

and/or 430:20 

Andrew 177:4 

Andrographis 442:22 

anecdotal 398:8 

anesthetic 418:16 

angelasian 194:1 

angles 328:2,12 

animal 7:6,7 17:1 38:3 

38:6,7 51:2 63:15 

64:2,3 66:19 96:19 

126:16 129:17,19 

130:5 143:19 191:13 

232:16 316:2,3 317:2 

420:20 426:5,8,10,15 

426:20 428:1,9 436:9 

448:20 

animals 16:15 50:8 

70:22 72:13 177:12 

177:13 181:9 183:10 

203:5 210:19 225:15 

234:5 237:13 316:21 

317:7 434:11 

animated 400:9,15 

Anne 166:14 171:19,21 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
451 

172:1 175:1 

annotate 57:20 179:3,4 

228:13 439:7 441:4 

annotated 57:11 

annotation 83:20,22 

93:20,22 94:4,18 

162:10 182:19 184:12 

184:16 186:2 222:12 

222:20 263:17 332:3 

418:17,18 439:15 

441:1 

announce 7:4 304:21 

annual 135:8 

annually 135:16 

answer 11:16 19:3,20 

27:11 28:14 68:19 

75:11 82:21 89:5 

90:20 176:8 203:7 

209:13,22 211:8 

229:11 234:19 254:11 

289:5 303:12 304:7 

349:6 363:18 367:16 

429:20,20 

answered 14:9 158:11 

429:16 

answering 75:10 95:18 

283:11 412:11 

answers 44:9 95:17,17 

107:1 200:20 211:20 

327:13 

anti- 393:11 

anti-equivalency 394:2 

anti-microbial 18:12 

20:6 55:3 214:2,9 

218:5,15,21 439:3 

antibiotic 18:20 218:16 

antibiotics 18:18 20:7 

177:20 

anticholinergic 434:12 

anticipating 214:16 

antidote 434:16 

anybody 302:11 324:19 

349:13 367:7 406:2 

anyone's 112:21 

anyway 47:13 78:11 

167:14 193:5 261:19 

395:7 

aphid 241:22 

aphids 55:14 

APHIS 389:6,7,8 430:17 

apiculture 249:21 

253:10 258:5 273:13 

273:15 274:2 402:2 

403:6,14 405:14 

406:11,20,21 408:20 

418:19 

apologetic 58:22 

apologize 235:1 339:13 

339:21 

apparent 302:18 

apparently 53:4 161:7 

appealing 13:10 

appear 52:20 149:2 

436:1 

appears 9:20 120:5 

appendix 109:16 

applaud 31:11 155:11 

199:19 227:22 244:17 

applause 260:18 

304:12 306:1,2 

apple 54:21 55:14 

198:8 240:1,4 

apples 54:5,18,19 

112:15 189:13 204:2 

241:8,15,19 

applicable 75:1 107:20 

182:2 418:17 

application 12:1 128:4 

128:5,22 131:21 

132:3 148:22 185:15 

186:7 193:22 218:9 

218:17 226:13 227:11 

241:20 245:12 262:16 

applications 129:1 

219:4,5 220:16 

applicator 211:1 

applied 52:19 57:9 

100:13 105:9 138:15 

164:19 220:3 235:18 

235:20 286:3 

apply 10:3,16 106:15 

130:11 139:7 142:2 

245:13 324:3 

applying 10:10 12:13 

appreciate 38:9 48:15 

61:7 85:18 86:2 95:19 

106:21 109:1 115:15 

123:4 124:4 128:7,15 

129:4 132:17 137:20 

193:5 200:19 204:10 

205:2 206:4 208:16 

213:7 221:10 232:22 

272:6 281:5 297:12 

298:3 300:2,18 

304:16 315:2 368:22 

369:3 383:6,6 385:15 

appreciated 125:16 

appreciation 226:10 

appreciative 102:20 

approach 68:8 103:21 

163:1,11 206:18 

226:9 281:11 289:4 

291:6 372:21 442:8 

approaches 163:10 

appropriate 35:11 

162:19 226:5 275:9 

278:10 385:13 

appropriately 105:9 

387:10 

approval 110:7 202:17 

218:9 378:3 420:13 

443:5 

approve 90:7,14 183:1 

201:1 216:20 246:16 

309:11 

approved 60:7 74:9 

77:17 131:18 133:21 

209:10 236:9 237:12 

292:1,7 354:21 357:2 

421:5,5 430:20 

431:21 434:3 437:18 

441:9,11 

approves 164:14 

approximately 86:6 

135:14 200:13 202:10 

April 1:7 3:5 87:3 

306:14 313:6 

aquaculture 92:14 

229:22 249:21 253:10 

aquaponic 282:4 

aquatic 26:4 134:5 

237:5 

Arcadian 149:21 

332:13 

area 7:5 17:18 38:22 

104:7,21 124:19 

141:19 146:22 147:4 

148:18 149:13 150:16 

152:9 193:13 227:2 

275:12,12 278:12 

285:20 288:17 333:12 

334:16 362:8 393:2 

395:4,11,13 399:5 

408:3 414:3 415:2 

areas 46:5 84:2 139:2 

142:8,19,22 144:13 

145:22 147:11 150:6 

150:11 152:11 226:18 

227:7 228:2 260:6 

278:5 302:20 387:16 

392:8 395:1 400:3 

408:2 410:19,21 

414:20 426:8 446:4 

arena 191:14 

Argentina 272:22 

argue 138:7 139:11 

277:5 

arguing 391:19 

arguments 212:19 

289:7 

arising 310:12 

arms 67:19 

arrangements 397:1 

array 155:17 

arrive 341:3 404:12 

ARSENAULT 2:7 5:22 

article 172:21 175:7 

articles 73:18 355:3 

artificial 236:13 316:8 

Asa 1:14 74:16 87:2 

88:6 96:13 101:7 

102:1 128:9 129:6 

194:15,17 196:10 

197:5 250:11 251:18 

283:13 293:12 310:9 

334:9 335:10 367:8,8 

367:9 368:20 369:19 

373:2 

Asa's 74:17 90:5 

130:22 

ascertation 138:4 

ascophyllum 134:18 

135:20 139:6 145:20 

146:8 151:19,21 

ASDC 291:18 

Ashley 1:20 11:17,18 

44:6 45:10 66:7 178:9 

208:19,20 217:20 

228:11 274:6 312:7 

359:12 361:10 405:18 

405:19 415:12 416:12 

418:20 422:11 424:13 

428:7 430:8 438:18 

444:18 445:6 

ASHRAE 251:20 

Asia 394:20 

aside 277:8 

asked 6:20 42:19 93:21 

110:11 148:6 149:9 

170:1 253:12,13 

295:20,20 343:22 

359:17 368:6 377:8 

377:11 380:14 420:22 

asking 11:12 21:3 46:7 

149:6 156:17,19 

158:15 174:20 196:8 

208:22 278:3 291:17 

332:10 350:17 356:19 

364:6,7 376:22 

asks 164:6 361:11 

aspect 114:17 

aspects 14:5 

ass 261:1 

assembled 126:9 

assertion 180:6 211:22 

212:5 295:4 

assess 271:9,9 358:5 

assessing 3:9 205:4 

353:18 

assessment 248:1 

assessments 116:4 

assigned 221:11 401:9 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
452 

assisted 62:17 

associate 2:9 29:13 

244:13 

associated 152:12 

Associates 244:14,14 

association 29:14 

32:22 43:2 97:1,6 

102:18 111:15 144:10 

176:12,13 203:22 

218:13 227:15 232:13 

407:3 

Association's 32:11 

346:12 

associations 168:7 

212:14 

assuage 323:22 

assume 18:2 266:6 

assumed 170:22 171:5 

assuming 265:2 

assumption 363:2 

assumptions 87:14 

assure 94:9 

assured 4:15 

athletes 70:13,14 

Atlantic 326:12 

atropa 434:13 

atropine 3:17 433:15 

434:2,6,12 

attack 277:12 

attacks 6:21 

attempt 364:10 

attempted 221:4 282:2 

attended 128:17,18 

attention 94:7 99:3 

105:11 114:14 140:16 

167:22 201:11 213:7 

282:1 378:14 390:10 

attorney 51:1 

attract 187:9 

attractive 404:1 407:19 

attributable 137:14,15 

attributed 213:1 

audience 300:12 

304:14 349:1 407:2 

audit 116:5 256:13 

398:11,12 

auditing 247:21 256:14 

256:15 

auditors 256:12 

audits 8:5,5 116:14 

247:22 249:3 269:22 

author 270:5 

authorities 104:5 146:6 

151:4 336:13 381:19 

389:10,13,14,15 

authority 8:7 46:4 

53:10 103:19 120:6 

120:10,17 121:8,11 

121:13,16 151:10 

250:4 252:15 381:15 

381:20,20 382:14 

384:15 388:15,18,21 

authorization 121:18 

251:3 

authorized 237:7 

automated 383:22 

autonomous 349:14 

autonomy 107:12 

availability 28:9 74:3 

87:11 88:18 99:16 

124:21 167:3 169:3 

171:9 179:19 208:1,4 

229:21 236:5 343:1 

421:2,4 422:4,7 423:1 

425:14 427:16 

available 60:13 61:16 

61:16 66:2 73:19 74:6 

86:20 88:13 117:11 

119:10,16 122:18,22 

127:15 158:4 167:18 

178:19 179:15 182:18 

205:1 207:21 209:3 

216:15 236:18 261:19 

288:8 301:17 302:20 

374:19 381:4 387:4 

420:19 421:9,22 

424:14 431:19,21 

437:13 438:10 440:13 

440:18 447:7 

average 194:18 229:8 

averaging 108:9 

avocado 31:19 123:10 

avoid 9:5 134:14 

192:12 199:11 225:1 

270:7 288:22 

avoiding 322:20 

awarded 149:21 

aware 87:1 124:19 

140:12 168:5 172:10 

214:15 224:22 268:13 

275:11 285:18 344:22 

awful 383:11 

B

b 36:10,10 75:20 202:4 

B.J 177:5 

baby 36:20 47:8 

bachelor's 63:16 

back 5:6 6:7,13 26:22 

30:8 37:1 49:17 52:16 

69:16 107:22 112:2 

113:14 121:4 125:7 

128:1 137:19 147:16 

156:16,22 170:9 

178:1 182:16 191:14 

195:1 200:3 220:21 

223:2 229:12 230:20 

230:21 232:3,5 

240:19 265:22 271:2 

283:2 286:11 287:20 

294:15 303:16 304:6 

306:7,13 308:16 

338:12 363:10 364:21 

368:5,17 374:4 

375:22 376:7,13 

390:10 400:17 407:22 

419:21 439:14 440:17 

back-breaking 155:5 

backed 113:18 263:10 

background 51:2 75:8 

145:2 332:10 340:3 

344:6 348:18 

backyard 71:2 

bacon 24:4 

bacteria 15:4 293:7 

bad 78:9 188:4 329:15 

329:17,19 387:11 

badly 384:10 

bags 55:4 

Baird 1:13 35:18 37:19 

38:2 69:22 70:4 71:6 

108:21 119:22 121:3 

121:19 145:12 146:16 

147:7 149:5,8,11 

194:18 195:12 250:12 

250:14,18 271:1 

312:10 314:1 368:21 

376:15,17 382:19 

385:17 387:21 389:4 

389:20 390:5,13 

392:6 395:6 398:3 

399:10 400:6,14 

416:20 417:12 419:13 

430:19 

Baker 213:13 223:6,10 

223:14 

balance 10:12 63:19 

269:22 442:14 443:20 

balancing 124:20 

387:12 

Balfour 269:15 

ball 48:5,6,12 182:11 

Ballroom 1:8 

bandage 219:8,10 

bandages 219:3 

bang 397:20 

bans 282:13 

bar 168:5 348:2 393:12 

barbeque 71:2 

barn 49:20 

barrier 86:16 

barriers 234:8 

bars 24:3 

base 117:6 264:13 

291:16 

based 15:17 78:21 

109:12 116:17,19 

119:9 120:8 132:14 

137:6 146:1,4 147:14 

197:21 235:20 237:3 

238:20 265:2 301:6 

307:1 405:21 438:10 

baseline 98:22 

basic 51:21 355:2 

358:15 

basically 31:16 118:17 

119:4 183:1 187:5 

258:1 269:18 273:7 

277:9 291:15 297:18 

309:4 323:3 358:11 

366:13 377:20 437:19 

Basin 114:4 

basis 4:20 42:5 71:19 

73:11 117:15 127:13 

172:6 185:9 191:18 

295:5 406:6 

batch 161:6 222:9 

Batcha 176:12 

baths 12:16 

Bay 111:12 148:19 

beach 146:1,20 147:3 

150:16 

bear 30:6 35:21 

bearing 269:9 

beautiful 47:12 

beauty 219:21 275:17 

275:19 

becoming 56:16 

Bedard 203:16 205:19 

205:20,21 209:5,18 

209:21 210:3,14,16 

beds 330:15 

bee 349:19 377:17 

410:13 

beef 50:5,6,6 207:11 

275:12 

beekeeper 401:18 

403:18 404:20 413:2 

beekeepers 403:18,20 

404:1,2 405:2 413:6 

413:21 

beep 6:3,5 

bees 403:20 404:10,12 

405:22 407:19,19 

410:12,21 411:12 

414:13,20 

beetles 233:15 

beets 24:18 

begging 293:17 

beginning 13:11 233:3 

begins 293:4,5 416:13 

behalf 57:2 58:13 85:15 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
453 

111:11 193:6 223:18 

232:16,22 233:10 

behave 79:2 231:14 

belabor 370:18 

Belgium 27:18 443:4 

believe 25:12 27:3,19 

27:19 37:6 62:1 67:8 

67:12 72:21 74:7 

90:22 91:3 110:19 

116:8 130:14 141:14 

146:13 148:19 152:11 

173:5 174:11 175:6 

179:5 180:11 186:14 

192:6 198:7 207:2 

226:15,19 228:4 

275:1 298:11,13 

311:20,22 315:22 

332:14 378:19 381:10 

402:12 412:21 422:19 

425:5 426:13 

believed 196:2 

believes 92:18 

belladonna 434:13 

belonging 437:8 

belts 55:8 

beneficial 241:13 

benefit 216:11 238:2 

320:11 

benefits 101:11 154:17 

214:3 240:21 

benign 238:9 

berries 113:2 

best 17:10 19:8 28:13 

29:16 41:14 42:8 

70:20 104:17 106:14 

106:17 107:14 185:7 

227:17 322:11 323:1 

323:12 324:13 337:12 

352:21 356:1 399:14 

429:5 

Beth 223:6 226:3 

better 46:21 47:4 50:1 

59:18 78:11 90:10 

91:4 110:10 112:2 

117:15 168:20 194:4 

206:15 233:14 248:15 

254:14 272:16 308:6 

325:13 326:3 354:5 

358:11 368:9 379:9 

389:12 

beverage 186:15 

beverages 448:14 

beyond 108:2 151:1,8 

164:9 170:14 212:18 

212:22 297:2 322:6,8 

357:7 371:6 415:19 

bias 348:22 

bicarbonate 242:1 

big 52:14 63:19 113:10 

194:10 199:17 337:16 

349:18 400:1 411:10 

423:14 

bigger 229:8 277:19 

302:15 

biggest 16:19 208:13 

234:8 238:12 271:5,5 

271:15,15 274:4 

393:14 394:22 397:20 

Bikle 166:14 171:19,22 

172:1 175:5,10,12 

Bill 103:8,12,13 104:3,6 

104:8,12 396:2 

bio 63:6 

bio-based 81:12 85:2 

biodiversity 7:9 107:16 

134:5 192:17 

biofilms 355:7 

biologic 61:14 

biological 64:15 107:15 

265:19 355:19 

biologicals 360:16 

biologics 360:7 427:7 

biology 288:6,9,12 

biomass 135:7,15 

bioplastic 79:22 

bioplastics 77:6 

biorejection 116:18 

Bioscience 19:18 

213:15,21 221:7 

291:8,9,18,22 293:6 

Bioterrorism 8:3 

bird 51:21 65:10 69:6 

442:18 446:1,16 

bird's 172:20 

birds 63:10 64:18 69:4 

69:13,15 234:9 237:5 

288:18 302:14 443:13 

444:3 445:21 446:2 

446:13,14 

birth 49:11 225:16 

bison 232:12,13 234:21 

bit 15:16 16:2 21:1 40:8 

41:5 50:11 66:11,12 

125:7 129:8 139:11 

140:14 149:1 152:8 

187:1 189:5 218:4 

228:14 240:19 258:12 

266:12 282:5 319:14 

327:4 331:16 340:22 

341:20 359:4 360:2 

364:18 374:4 391:4 

402:17 408:17 429:8 

441:22 446:18 

bites 388:6 

bitterly 294:19 

Bjarne 62:11 75:20,21 

76:7 

black 72:1 172:18,18 

284:2 331:17 394:18 

394:21 411:7 

blasting 198:18 

bleach 292:8 

blend 110:5 442:11 

blended 164:3 

blessed 113:11 

blight 55:6 

blinding 220:2 

block 64:10 236:3 

273:10 

blood 286:16 

bloom 192:20 193:22 

414:6 

blooms 187:14 

Blount 210:18 213:13 

213:14,15 217:9 

218:19 221:9 222:16 

222:19 223:3 

blue 77:8 

blueberries 112:17,19 

112:22 191:10,11 

blueberry 172:16,21,22 

Board's 33:20 320:22 

boards 142:22 249:17 

boat 269:12 332:20 

333:2 

boatload 382:16 

bodies 117:9 404:1 

body 174:20 197:17 

223:21 252:18 254:20 

256:10,11,14 257:13 

257:20 259:3 

bone 71:8,11,18 

book 14:18 172:3,5 

270:5 

books 398:15 

booming 160:21 

Border 383:20 

born 36:21 225:15 

316:21 

bottles 437:16 

bottom 77:8 

boundaries 106:11 

107:12 108:16 362:22 

bowling 70:16 71:2 

box 240:12 275:3 307:9 

308:14 310:22 311:10 

boxes 54:19 

Bradman 1:14 74:19 

87:2 88:5,7 89:21 

96:14 101:6,9 128:10 

129:7,16,21 130:3,18 

197:6,10,14 251:19 

252:3 283:14 293:13 

294:4,8,11,14 310:10 

312:13 314:4 335:11 

369:20 417:15 419:2 

439:17 

brain 418:9 

brainer 401:17 

brains 199:18 

brainwashed 63:22 

branching 268:1 

brand 164:11 215:13 

245:17 271:18 428:17 

428:18 

Brazil 272:22 411:5 

414:2 

break 62:22 80:22 

82:19 84:11 111:8 

115:1,3 125:5 223:7 

230:16 288:2 376:5 

400:19 

breakdown 52:2 157:6 

breakfasts 325:6 

breaking 51:20 

breaks 399:21 

breast 263:13 

breath 36:10 

bred 49:22 50:6,8 

breeder 350:1 

breeders 61:9 

breeding 61:10 65:21 

350:2 

breeds 65:20 67:11,14 

445:16 447:6,8 

Brian 213:13 223:6,14 

226:2 

brick 298:21 

bridge 90:15 

brief 63:6 109:15 

145:17 321:2 401:10 

433:22 437:2 448:15 

briefer 437:1 

briefly 59:5 185:16 

367:11 

bright 432:6,7 

bring 48:8 83:8 97:21 

113:3 139:1 148:12 

148:14 220:3 281:22 

337:22 345:1 392:19 

421:21 441:5 

bringing 84:20 146:19 

166:20 337:5 407:22 

439:15 

brings 72:11 246:22 

broad 43:6 324:15 

371:4 437:13 

broader 151:5 155:9,15 

390:15 426:10,20 

427:22 

broadly 31:20 130:11 

broccoli 285:20 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
454 

broiler 302:9 447:7 

broke 113:19 436:15 

broken 33:14 246:13 

brood 404:6 

brought 35:9 36:21 

37:1 38:4 94:7 114:11 

184:14 223:2 233:11 

240:8 241:2 264:15 

268:1 282:20 327:5 

347:1 357:8 371:15 

Brown 290:22 297:6,8 

Bruce 27:14 28:6,13 

Brunner 188:2 

Brunswick 133:6 

138:22 142:12 146:8 

147:12,21 

brushes 55:8 

buck 397:21 

budget 257:11 

buffering 165:5 

bug 71:18 

bugs 71:22,22 106:11 

188:8 446:7,8,11 

BUIE 1:14 312:17 314:8 

417:19 419:6 437:10 

build 269:13 334:1 

400:4 

building 64:10 191:19 

192:16 231:8 236:3 

251:21 348:7 385:3 

431:12 

built 91:17 100:3 

167:13 268:14 430:3 

bull 316:12 

bullet 67:10 69:19 

bumping 113:2 

bunch 257:6 287:18 

Burcham 47:6 50:14,17 

50:18,20,21 

burden 30:7 204:18 

344:4 346:16 

burgeoning 172:7 

burial 77:5 79:15 

buried 80:4 

Burley 67:13 

bushel 341:1,6 

bushes 446:22 

business 8:12 32:18 

61:19 88:21 124:22 

153:8,21 155:4 

201:11 233:5 246:5 

247:20 252:20 

businesses 8:11 33:1 

51:19 103:4 117:1 

167:13 

busted 398:17 

busy 244:2 259:16 

353:22 361:9 377:17 

buttons 6:12 

buy 29:19 342:20 

buying 29:22 230:12 

429:18 

bycatch 144:9 

byproduct 66:20 93:9 

94:20,22 95:1 

C

C.F.R 184:22 185:1 

262:22 

CAC 376:17 

CAFO 130:4 

cage 296:9,12,13,16 

cage-free 300:22 

caged 111:21 

calamity 174:10 

calcium 165:4 235:14 

235:18,22 236:2,8,11 

236:16,17,20 237:2,7 

237:9,11,13,14,15,17 

237:19,22 238:8 

240:17 

calcium- 235:19 

calculate 122:9 

calculations 118:16 

calf 437:16 

California 109:13 

126:19 128:21 131:17 

131:21 183:22 210:22 

300:22 301:1,2,3 

392:13 393:4 440:5 

call 5:5 7:3 193:13 

198:18 304:6,10 

340:5 346:13,14 

350:5 390:11 

called 27:12 98:19 

122:9 168:17 194:11 

247:20 299:2 382:9 

407:13 442:19 

calling 176:14 295:16 

calls 247:15 361:8 

362:10 368:15 390:8 

392:1 408:21 

calves 36:20 49:11 

177:22 

campylobacter 72:4 

Canada 25:17 119:3 

132:15 223:22 249:6 

249:16,16 255:13 

256:1 257:16,16 

279:2,2,5 335:6,19 

394:17 

Canada's 279:9 

Canadian 115:18 255:8 

255:9 256:3 257:17 

258:13 334:16 434:20 

canals 114:10,11 

cancellations 4:22 

cannibalism 65:3 

canopy 69:11 193:13 

194:3 

canteen 77:13,20 

capabilities 380:8 

382:7 

capability 253:17 

capacity 103:19 373:5 

capsules 185:18 186:6 

captive 114:14 

capture 95:6 164:10 

capturing 310:2 

carbon 127:4 331:12 

care 69:5 331:11 

342:16 393:9 439:5 

career 445:19 

careful 10:11 315:12 

carefully 150:15 335:6 

Caribbean 224:1 

carried 212:8 

carry 32:21 103:15 

324:8 448:20 

carrying 410:7 

Carter 230:17 231:21 

232:4,6,10,10 235:3,5 

235:7 

carve 34:12 

case 4:22 77:7 97:11 

129:14 152:2 168:10 

296:6 362:19 373:21 

436:11 

cases 106:10 110:3 

273:9 335:21,21 

casing 86:8,8,10 

casings 86:15 

catastrophic 56:2 

catch 125:6 258:3 

328:15 

catching 138:11 391:16 

categorically 200:14 

categories 213:1 366:9 

366:9 384:4 386:14 

387:2 

categorize 370:5 

category 8:18 86:7 

87:17 97:20 170:5 

366:10 386:17 

cater 447:14 

cattle 50:5 

caught 39:9 93:7 

cause 55:14 116:22 

355:9 435:9 

caused 36:7 315:8 

causes 78:9 262:18 

268:4 435:5 

causing 331:19 344:16 

caution 212:9 369:17 

cautious 148:1,3 

caveat 231:15 427:11 

CBP 383:19 389:11 

CBs 270:1 271:8 274:18 

275:22 276:2,3 

CCOF 183:22 184:6,10 

184:15 185:17,20 

CDC 218:12 

CDFA 132:6 

celebrate 169:8 

celery 23:20 24:1,8,20 

24:22 89:1 99:8,10 

100:12 101:1 102:3 

447:19 

cells 15:3 417:8 

cellular 236:3,4 

cellulose 76:19,21,22 

77:6,9 78:6 79:7,8 

81:9,22 84:13 86:8 

cellulose- 78:20 

cellulose-based 157:5 

certain 22:15 82:7 

139:4 189:20 198:14 

210:9,10 290:3 356:6 

361:22 

certainly 28:18 83:16 

83:19 87:17 91:2 

133:22 139:10 140:4 

145:8 168:6 223:3 

264:18 294:22 311:2 

certifiable 80:1 166:3 

certificate 27:6 30:14 

116:12 165:17 166:6 

379:11,15 380:5,9,15 

381:12 387:8 

certificates 29:6,17 

115:14,17,22 380:7 

387:1,2 

certification 3:11 4:9 

23:18 26:16 29:19 

30:5 43:13 93:3 99:1 

106:7,8 107:8 109:12 

115:20 117:8 162:17 

163:8 165:14 183:22 

200:7 203:19 205:21 

271:11 298:19,20 

324:3,5,9 326:4 328:2 

328:12 332:4 334:6 

376:15 382:6,8 385:7 

399:13 403:2,11 

certifications 17:16 

certified 27:1,3 29:7 

30:6,9 31:17 33:3 

87:15 91:5 93:3 98:3 

117:12 133:13 141:18 

162:12 163:16,18,20 

165:21 166:4 167:4,9 

167:17 168:4 170:11 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
455 

170:18 184:1,6 

185:17 189:1,9 191:4 

191:12 200:13 227:1 

272:9,17 273:7 

275:19 286:5 291:19 

332:21 333:1 379:15 

394:7 398:9 403:1 

404:21 410:20 411:8 

411:12 412:1,2 445:5 

certifier 31:6 107:3 

165:16 168:6 203:20 

222:2 261:3 343:21 

379:11 380:14 381:18 

382:4,12 385:8 423:4 

430:20,21 431:13,15 

certifier's 413:20 

certifiers 29:14 31:11 

31:13 53:6 99:6 

106:21 108:15 116:11 

117:15 171:14 174:20 

185:12 205:12 212:13 

221:14 222:1 226:20 

227:15 246:5 247:22 

248:12 256:2 261:11 

261:13 280:4 287:1 

299:2,11,15,21 

315:20 318:15 324:8 

327:4 347:3,8,12 

353:1 356:22 378:12 

380:11,17 381:10 

382:9 385:5,8,11 

397:5,8 398:6 399:15 

407:3 410:5 412:13 

413:16 422:3 424:3,4 

424:6 427:12 428:13 

442:4 

certifiers' 107:11 

certifies 108:8 201:17 

202:9 380:3 

certify 200:8 203:22 

207:10,13 272:20 

275:1,5,20 285:17 

406:17 

certifying 278:16 330:6 

336:20 394:9 410:6 

413:16 

CFIA 255:19 

CFRs 263:5 

chain 29:11 30:6,17 

33:4 43:14 89:17 

91:15 96:10 100:2,8 

102:22 103:11 153:9 

154:4,13,15 155:19 

156:3 157:8 160:18 

265:22 271:12 346:3 

394:16,19 

chains 117:1 223:17 

224:17,19 248:2 

399:3 

Chairperson 300:5 

challenge 167:6 218:15 

221:9,14,21 295:3 

397:11 422:20 423:10 

challenged 78:4 

challenges 99:17 

392:15,22 393:20 

394:11 

challenging 150:8 

191:6 240:6 294:20 

320:20 394:8 

chance 18:11 22:3 

140:1 270:2 279:22 

282:9,18 402:18 

change 11:15 30:12 

121:9 169:7 175:16 

180:1 207:18 208:13 

223:16 251:6 269:3 

302:1 307:19,20 

308:3,15,18,19,20 

309:11 310:11,17 

311:5 318:3 329:18 

354:10 384:17 385:7 

418:8 420:16 447:8 

changed 31:2 105:6 

251:2 309:1 407:5 

429:18 

changes 31:8 68:3 

208:12 264:9 268:22 

312:7 326:13 368:18 

changing 107:9 198:7 

246:5 263:14 385:20 

CHAPMAN 1:15 14:8 

15:15 95:16 96:3,12 

118:21 119:14,20 

217:21 220:10 222:11 

222:17,22 228:20 

229:4,8 230:2,9,14 

260:9,17 264:5 266:3 

266:18 312:9 313:22 

336:12 351:11,21 

352:3,6,18 353:4,11 

362:13 363:1,9 

365:14,19,22 366:6 

366:19 370:17 371:10 

385:18 387:13 392:7 

399:2 410:16 414:1 

415:8 416:3,22 417:5 

418:6 419:12 429:3 

432:9,11,15 433:1,9 

441:8 

chapter 14:18 

character 6:21 

characteristic 68:2 

characteristics 46:12 

chardonnay 199:11 

Charmiec 183:16,18,18 

183:20,21 186:12 

charred 24:17 

chase 361:5 446:10 

cheap 127:20 

cheaper 171:12 

check 123:12 301:20 

332:16 419:22 

checked 171:16 445:3 

checking 299:3 

checkoffs 370:12 

chemical 79:1 192:7 

236:21 295:10,11 

296:9 413:12 440:5 

chemicals 288:1 

296:14 

chemistries 216:3 

360:10 

chemistry 132:4 215:17 

291:7 

cherries 54:5,18 55:1 

189:12 241:20 242:3 

242:4 

cherry 54:15 240:1 

chick 47:8 

chicken 27:20 58:6 

69:9 70:10 71:15 

89:12 90:6 111:21 

156:17 266:20 286:20 

303:15 445:8 

chickens 69:22 70:12 

446:9 447:1 

chief 174:1 191:2 

child 195:1 

chill 404:6 

Chino 300:21 

chips 83:16 

chloride 58:15 59:2 

60:6 237:13 240:17 

chlorine 20:4 215:11,15 

215:20 292:7,17,19 

294:15,19 295:2,6 

296:8,11,17 

chlorine-based 292:21 

293:1 295:11,14 

296:18,20 

choice 63:21 69:2,6 

229:18 245:8,17 

356:3 423:19 444:16 

choices 107:18 445:14 

445:15 

choose 27:8 195:3 

316:8 

chooses 69:7 

choosing 356:6 427:12 

chose 47:8 195:4 261:1 

308:7 

chosen 134:1 

Chramiec 175:14 

circle 48:3,6 153:7 

circular 407:11 

circulating 109:20 

circumstance 436:17 

circumstances 373:1 

citation 212:2 

cited 212:19 

cites 185:13 

citing 215:21 262:22 

citrate 126:22 127:2,12 

127:15,18 128:14 

213:18 221:19 

citric 126:17 220:1,1,7 

city 63:8 284:14 

claim 196:19 220:21 

clarification 53:2 111:1 

202:2,8 304:3 428:12 

clarifications 23:11 

clarified 227:21 

clarify 20:12 21:13 

26:13 124:5 178:21 

293:18 336:13 351:16 

428:9 

clarifying 428:4 

Clarissa 2:13 305:17 

374:3 

clarity 39:4 46:20,22 

207:22 356:19 

class 14:17 183:2 

360:13,19 420:14,15 

421:16 423:12 424:8 

431:5 436:7 

classes 360:10 

classic 89:12 

classification 261:9 

416:11,14,18,19 

classifications 265:2 

classified 78:22 94:5 

406:1 

classify 417:8 

clause 99:16 229:21 

clean 13:6,6 15:10,12 

110:1 168:20 290:7 

439:1 

cleaned 15:8 

cleaners 205:10 

cleaning 3:9 14:12,13 

14:19,21 19:6 205:4,6 

244:15 246:4 292:12 

353:18 437:14 

cleanser 356:12 

cleansers 356:11,15 

clear 30:12,14 41:17 

47:2 48:1 51:5,17 

53:4 100:9 108:18 

126:22 134:2 135:6 

156:9,18,19 157:16 

159:4 169:17 177:11 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
456 

177:19 178:5 181:7 

182:6 185:5 202:16 

226:13,13,21 227:11 

274:14 289:21 301:22 

307:6,8,15 309:6 

330:5 343:12 347:3 

347:10 354:21 355:13 

367:14,21 379:19 

384:10,13 391:7 

406:11,12 427:18 

433:17 444:16 

clearance 40:20 41:15 

clearer 281:21 

clearly 5:14 101:18 

134:13 165:21 181:2 

185:13 230:11 275:7 

315:11 325:20 335:5 

343:17 354:1 373:8 

410:1 417:1 

clientele 45:5 

clients 110:9 244:15 

423:5 

Clif 393:12 

climate 329:18 446:4 

climates 197:2 404:4 

clinical 219:14 

clock 6:1 

close 37:11 208:7 

230:20 338:18 

closely 216:1 436:19 

closer 244:11 319:14 

394:12 401:11 

closing 61:18 174:11 

353:13 

cloth 285:5 

cloud 396:18 

clouds 176:18,22 

clue 330:15 

CM 241:2 

co-author 172:3 

co-extruded 86:21 

co-extrusion 87:10 

Co-op 299:7 

COAC 25:16 

Coalition 7:18 176:11 

280:22 379:5 

Coalitions 102:17 

coast 335:3,3 

coastline 135:11 150:2 

152:1 

coating 78:8 

Cobscook 148:19 

coconut 165:3 

code 384:2,7 386:12,15 

386:18,18 411:1 

codes 378:18 383:15 

384:4 386:3 

Codex 434:22 

codified 220:17 254:5 

codify 97:19 

coding 386:2 

codling 55:14,20 

187:11,16 188:4 

241:8,14 

Coeur 297:17 

coffee 77:12 82:19 

cognitive 174:12 

cognizant 377:2 

cohesive 216:11 

coincided 353:6 

coir 165:4 

cold 307:15 310:13 

311:12 446:3 

coli 72:3 

collaborating 107:13 

collaboration 120:18 

121:15 133:4 271:8 

381:18 

collaborative 364:1 

collaboratively 98:13 

350:7 

collagen 85:16 86:1,4,9 

86:10,18 87:10 

collars 164:10 

collated 381:4 

colleagues 180:7 

305:15 

collect 33:4 64:16 

381:10 

collecting 83:7 204:14 

collection 98:21 345:7 

345:9 

collective 102:21 

150:12 

collectively 105:14 

colonies 410:13 

colony 147:9 

Colorado 196:13,22 

colorless 296:7 

Columbia 113:21 114:4 

combat 439:2 

combined 291:14 

come 5:6 11:2 14:5 

20:15 21:14 35:3 

47:17 49:16 100:21 

118:16 125:7 127:22 

137:4 140:17 142:1,3 

161:12 175:21 188:22 

201:5 232:5 242:17 

242:21 243:12,20 

251:13 265:8 271:6 

281:9,15 287:2 303:4 

319:9 321:16 336:17 

338:22 354:6 359:2 

361:7 367:17 368:5 

368:17 376:6 377:4 

383:13 389:9,13,14 

390:1 407:9 413:5 

425:15 442:13 

comes 9:22 16:22 

19:16 26:15 27:18 

71:1,7 146:20 151:16 

156:16 244:1 270:3 

292:8 333:6 397:4 

400:2 416:9 

comfortable 333:12 

399:16 

coming 38:16 85:5 

100:6 136:5 140:18 

159:13 161:7 173:5 

179:14 181:4 188:3 

191:5 198:11 230:4 

234:14 273:6,21 

286:13 339:19 351:6 

391:18 403:2 411:5 

416:11 

commend 398:3 

comment 4:6,14,19 

5:15 6:20 9:19 22:7 

25:2 26:11 28:5 32:17 

32:21 35:12 39:8 

43:11 53:22 59:4 

72:12 76:7,13 89:22 

101:6 108:21 109:16 

115:6,9 120:11 121:2 

121:20,21 132:18 

137:19 140:2 156:14 

159:21,22 166:17 

179:8 199:15 201:21 

204:6 206:2 211:19 

212:4,17 214:18 

217:7 218:2 223:13 

231:20 238:22 239:15 

242:20 243:7,9,21 

281:2 283:14 291:1 

293:14 298:12 307:1 

307:2,21 308:12 

309:16 315:1,4 

316:19 319:8 322:2 

328:10 336:16 340:2 

342:11 347:2 356:18 

365:15 372:7 373:13 

375:18,19 376:22 

379:7 384:12 388:12 

395:22 399:4 416:6 

434:1 439:17 445:12 

commented 218:3 

228:22 

commenter 137:11 

280:16 381:1 440:19 

commenters 6:15 52:3 

136:9 150:20 234:6 

304:16 316:6 323:16 

345:15 372:19 398:4 

439:3,7,11 

commenting 153:10 

184:2 200:10 

commerce 25:1 

commercial 26:7 59:9 

59:22 61:11 69:9 74:3 

99:15 167:3 169:3 

171:9 192:6 199:3 

208:1,4 229:20 

245:19 383:22 421:2 

421:3,8 422:4,6,22 

425:14 427:15 447:6 

commercially 66:2 74:5 

157:19 158:4 161:13 

167:18 182:17 207:21 

261:19 420:18 421:9 

421:22 

commission 186:18 

190:10 249:13 252:15 

254:2 257:4,9 

Commission's 257:5 

commissions 257:7 

commitment 89:2 

268:9 

committed 24:13 

100:10 102:19 132:21 

155:19 157:17 158:21 

445:20 

committee 109:21 

111:15 153:12 211:18 

212:3 237:6 249:19 

255:15,18 301:2 

308:9 325:21 373:21 

387:21 390:9 416:12 

428:10 439:14 440:12 

440:17 444:18 

committees 362:12 

commodities 117:20 

285:21 410:22 

commodity 115:14 

224:17 411:10 

common 72:6 215:8 

256:12 281:19 282:7 

429:16 

commonly 134:19 

166:2 434:17 

communicate 385:11 

communicated 37:14 

283:15 

communicating 399:15 

communication 38:17 

communities 51:13 

community 10:5 33:12 

38:16,19 88:10 

108:17 218:14 221:1 

226:17 233:1 247:17 

248:4 251:9,13,15 

253:5 254:14 255:16 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
457 

259:22 260:15 270:19 

276:10 278:9 289:8 

290:13 297:13 298:1 

299:18,22 315:2 

321:15 325:8 340:11 

350:11 378:14 383:10 

399:13 400:12 422:14 

435:1 

community-supported

154:1 

companies 60:9,16 

67:22 105:13 119:5 

140:5,11,21 141:15 

149:13 150:3,12,14 

152:7,13 166:18,21 

168:3 169:14 223:20 

295:13 329:14 425:4 

445:20 

company 7:16 24:1 

29:4 76:9 77:13 142:8 

143:5,9 145:5 147:14 

147:20 150:9 152:5 

155:18 157:16 158:20 

161:11 170:18 219:18 

221:19 232:14 235:16 

239:5 291:5,6,12,12 

332:11 411:19,19 

429:17 

comparative 370:8 

compare 46:8,9 76:16 

76:19 84:7 224:22 

249:5 

compared 24:20 75:5 

79:6,17 116:1 154:22 

248:22 

comparing 46:11 77:6 

370:9 

comparison 163:20 

402:10 

compatibility 225:18 

245:10 

compelled 330:3 

competitive 263:7 

competitively 130:17 

competitor 425:7 

competitors 291:14 

compiled 376:18,21 

377:9 

complain 294:18 

295:15 

complaint 31:14 

complaints 215:22 

295:12 

complete 177:7 203:10 

completed 6:16 160:13 

191:21 343:6 

completely 77:1,14 

79:14 145:1 176:21 

182:19 253:7 365:16 

372:12 386:4 447:22 

completing 176:22 

complex 10:13 29:8 

262:7 302:15 328:18 

329:1,5,7 360:3 

complexity 84:4 

compliance 3:11 4:9 

7:16 29:3 103:16 

124:7 155:20 166:7 

185:7 204:16 216:12 

222:12,17 226:11,22 

227:8 376:14 377:17 

409:21 

compliant 37:7 

complicated 100:5 

131:13 153:16 315:15 

319:20 322:6 386:7 

complications 342:4 

comply 8:1,4 9:8 96:6 

225:7 

component 164:13 

187:2 220:8 

composable 80:1 

composed 157:2 

compost 164:9,17,21 

compounds 215:21 

294:16,19 295:2,6 

360:13 

comprehensive 8:14 

35:10 84:3 117:5 

347:7 359:18 361:13 

compromise 221:6 

317:13 433:5 

computers 5:14 44:2 

conceive 316:17 

concentrate 168:18 

concentrated 63:18 

130:5 407:7 

concentration 19:5 

438:2 

concentrations 215:3 

concept 9:1 45:22 

46:15 249:11 250:5 

250:20 251:12 269:2 

277:2 363:12 364:13 

364:15 

concepts 254:9 

concern 11:4 16:19 

18:10 33:13 37:10 

45:13 46:13 93:18 

118:9,22 119:1 

123:21 130:13 133:22 

136:9 159:17 160:17 

179:16 216:1 218:6 

221:8 228:14 237:3 

258:18 298:4 299:5 

307:12 324:2 327:5 

331:16 346:1 348:2 

352:19 354:16 361:15 

369:2,6 381:14 

430:13 439:11 

concerned 60:17 

112:21 118:11 119:11 

119:14 122:15 123:19 

124:20 168:15 206:14 

252:3 258:13 298:22 

326:11 351:3 391:12 

391:17 440:20 

concerning 201:12 

328:4 

concerns 8:20 11:20 

52:7 94:1 116:15 

118:4 124:17 141:16 

208:17 214:2,4 

215:21 218:4,16 

219:19 220:14 221:1 

283:19 284:11 323:14 

323:19 324:1,14 

327:22 335:8 336:19 

337:7 351:15 363:10 

364:9 429:4 435:9 

conclude 127:13 

375:17 

concludes 78:14 376:2 

concluding 374:1 

conclusion 23:7 95:7 

concrete 284:9 329:4,5 

concurrent 116:10 

conditions 79:15 310:4 

conduct 45:15 103:19 

103:20 132:3 349:11 

conducted 163:15 

conference 247:15 

341:18 346:13 

confidence 262:19 

391:15 

confident 71:21 134:6 

216:16 

confidential 124:22 

245:21 399:15 

confidentiality 118:2 

430:11,15 431:18 

confined 111:22 181:19 

191:12 

confinement 49:15 

Confinement-based

51:19 

confining 174:4 

confirm 197:6 

conflict 10:13 255:3 

273:5 365:5 

conflicted 406:10 

conform 168:19 

conformance 338:2 

confuse 241:14 

confused 244:20 

289:13 

confusing 184:14 217:8 

265:1 315:3 351:22 

427:14 

confusion 262:18 

299:15 310:8 403:7 

403:12 

Congress 251:5 

connecting 28:13 

connection 62:4 233:5 

cons 66:20 68:19,20 

71:17 72:5 

conscious 63:13 

consciously 63:11 

consensus 106:20 

225:14 251:13 321:15 

329:8 371:18 

consensus-building

321:22 

consequence 67:5 

consequences 343:3 

355:20 

conservation 94:1 

283:5 

conservative 151:20 

consider 34:2 70:12 

82:1 88:19 95:1,4 

108:1 118:8 133:17 

171:1 189:13 268:21 

318:9 335:17 364:20 

consideration 10:11 

13:22 85:22 88:1 

138:7,8 186:9 189:22 

433:22 

considered 81:20 236:1 

246:2 265:19,20 

315:12 316:6 429:10 

435:16 436:2 

considering 56:4 316:1 

377:13 396:5 

considers 163:22 

consistency 52:19 53:8 

201:15 282:10 356:21 

consistent 24:12 31:22 

45:15 104:22 178:4 

185:14 186:7 226:13 

227:11 261:12 347:12 

427:19 

consistently 53:7 

185:12 286:3 

consists 437:19 

constantly 246:5 

300:14 

constellation 354:8 

consternation 36:8 

constitutes 73:11 127:9 

constrains 68:10 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
458 

constraint 221:12 

388:9 394:22 

constraints 34:9 93:16 

395:3 

consultant 76:8 196:7 

232:16 367:14 

consultation 291:7 

consulting 19:13 

232:14 247:20,21 

consume 65:10 

consumed 73:2,5 

consumer 86:14 170:1 

230:12 254:4 262:18 

264:13 415:5 

consumers 25:11 49:1 

52:11,12 86:20 90:22 

91:21 92:9 166:22 

170:14 229:18 262:12 

297:22 400:13 402:21 

412:7 

consuming 72:15 

consumption 91:19 

223:17 237:8 

contact 12:12 31:4,6 

56:11,19 57:2,13,17 

95:9 217:10 246:12 

293:22 294:1 355:16 

356:9,15,20 437:15 

contacted 215:19 

218:12 219:19 382:4 

382:5 

contain 24:1 173:11 

222:4 230:10 345:19 

contained 212:10 

container 107:14 108:2 

109:4 279:3,10 281:8 

284:10,13 286:18 

290:15 

containers 30:21 

281:17 285:5 287:15 

containing 31:1 

contains 206:16 221:17 

221:20 222:21 

contaminants 25:14 

contaminate 17:4 

contaminated 290:8 

contamination 16:7,22 

17:12 56:11 61:6,9 

204:12,15 274:18,22 

275:8 288:3,11 340:7 

340:19 342:22 344:21 

345:3,19 346:2 347:9 

347:18,19,21 348:5 

351:4 435:4,5 437:20 

content 80:11 99:13 

173:15 

contention 39:1 

contentious 92:17 

contents 3:1 31:15 85:7 

context 88:9 210:11 

367:4 428:1 

context-specific

334:13 

continue 51:7 60:6 

110:8 111:2 118:13 

133:3 141:8 145:8 

192:11 193:6 201:11 

211:6 219:17 243:11 

246:14,21 313:11 

315:10 317:17 318:10 

320:6 348:3 360:10 

368:16 370:17 390:2 

395:2 429:10 

continued 24:14 54:11 

57:4 184:10 186:5 

202:19 211:3,7 442:5 

442:10 

continues 9:18 86:13 

92:4 99:17 132:20 

161:10 162:6 206:6 

211:12 213:3 248:15 

continuing 167:6 

169:12 170:20 306:16 

385:16 435:21 

continuous 276:13,17 

277:2 

continuously 39:7 42:8 

181:11 

contract 344:22 345:4 

367:13 368:7 

contracted 132:2 

362:16 

contracting 367:20 

contractor 368:2,3,4 

contrary 191:17 211:15 

217:16 

contrasting 46:11 

contributions 448:13 

contributor 56:13 

control 8:2 55:5,13,21 

57:5 93:22 126:12,14 

139:11 150:15 188:19 

192:22 193:10,21 

206:15 210:22 241:22 

242:2 249:7,17 

277:11 280:12 330:8 

332:18 403:9 

controlled 219:7 

410:21 434:15 

controls 413:12 

controversial 440:1 

conundrum 424:1 

convenience 109:20 

conventional 49:19 

52:16 119:17 120:13 

167:11 174:2 178:1 

190:8,11 228:5 240:7 

240:13 331:10 341:5 

conventionally 241:5 

conversation 16:4 

43:17 272:7 320:18 

322:17 373:15 389:6 

403:16 426:9 

conversations 5:11 

61:14 362:20 396:8 

conversion 32:2,2 

154:9 178:1 288:6 

conversions 24:20 

converted 177:11,12 

Converting 167:19 

convoluted 159:19 

cooked 86:6 

cooking 398:15 

cool 395:20 400:10 

cooler 404:4 

coolies 114:2 

Coop 28:7 58:10 439:18 

cooperation 224:12 

246:3 

Cooperative 23:18 

24:13 25:4 439:18 

coordinated 215:5 

coordinator 7:17 

coral 268:1,4 303:10 

core 108:17 

corn 61:16 119:6 

204:21,21 205:1 

301:13,16 340:21 

341:2 346:8 349:16 

Cornell 195:16 

corner 147:3 

cornerstones 276:12 

Cornucopia 51:1 52:5 

corporate 192:13 

217:12,17 

correct 70:11 71:13 

94:10 288:12 294:13 

365:18 383:17 441:2 

correctable 116:21 

correctly 11:16 31:18 

correlates 379:10 

correlation 30:15 

corrosive 12:8 216:5 

292:22 293:1 296:8,9 

cost 78:5 127:16 317:9 

332:22 333:1 347:15 

351:18 352:15 368:10 

371:5 

costs 155:5 343:1 

cotton 58:10,12,15 

59:13 60:5,7,11,14 

61:8,17 62:2,6 349:18 

couched 282:14 

council 26:1,20 27:4 

54:2,4 105:12 111:16 

133:6 148:14 435:1 

counsel 106:20 

count 6:2 411:17,18 

counting 6:7 

countless 247:15 

countries 223:20 225:5 

249:1 396:5,16,19 

country 207:16 210:8 

224:16 273:21 342:3 

350:3 391:18 445:15 

447:7 

couple 33:19 45:6 69:4 

112:3 189:18 193:20 

201:6 219:11 241:3 

252:13 283:16 293:13 

327:4 348:15 362:13 

363:7 382:16 383:3 

391:13 434:19 439:10 

445:3 

coupled 220:1 

course 7:18 42:15 

88:11 102:8 150:22 

185:15 187:16 258:8 

258:13 269:6 272:13 

272:16 276:15 308:11 

317:5 319:3 340:9 

341:22 372:14 375:5 

403:13 435:9 436:22 

courses 407:18 

Courtyard 1:8 

cover 69:11 122:10 

172:18 441:22 

covered 96:14,15 285:2 

308:6 

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covers 16:8 141:21 

cow 226:4 235:18 

237:21 316:16 317:4 

436:15 

cows 49:14,15,18,19 

108:9 

cracks 168:16 

crafted 170:8,11 

Craver 183:19 186:13 

186:16 190:6,8,18,20 

craze 154:3 

crazy 445:10 

create 83:20 114:4 

118:6 136:11 159:5 

199:13 227:16 245:4 

251:14 263:16 265:13 

265:20 274:1,1,8 

296:19 324:1 396:15 

created 177:15,16 

204:12 261:17 273:13 

323:13 446:21 

creates 173:21 293:4,6 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
459 

creating 31:22 159:8 

160:9 226:16 259:11 

267:13 323:9 446:13 

creation 117:3 

creationists 300:16 

creative 10:12 

credibility 432:1 

credit 113:1 

crib 231:2 

cripples 173:20 

crises 108:7 

crisis 355:10 

criteria 9:7,9,13,17 10:3 

10:10,15,16 11:15 

46:1,17,18 136:16,22 

138:15 144:16 163:10 

205:4 211:7,13 213:4 

245:6,9,12,15 264:10 

306:20 317:12,20 

322:20 354:10 356:2 

356:7 360:1 369:10 

369:14 370:7 373:14 

375:20 394:4 

critical 42:6 56:5 87:20 

89:10,14 104:4 125:1 

185:6 207:1 226:12 

243:1 271:13 361:18 

398:21 428:9 

crop 3:7,9 29:7 54:21 

62:7 110:3,9 118:1,5 

119:4 122:9,10,17 

133:13,15,21 138:15 

162:4,8,11 164:5 

166:3,7 173:14 174:9 

196:6 202:12 205:7 

245:20 280:5 320:8 

323:21 340:17 342:21 

347:6 349:19 353:19 

411:13 414:14,14 

432:20 

crop- 55:2 

CROPP 23:18 24:13 

25:4 440:12 

crops 61:1 114:12 

123:11 154:10,12 

155:1 174:4 181:18 

201:18 211:18 237:16 

280:13 346:20 350:3 

351:5,5,22,22 

cross 289:1 

cross- 56:10 

cross-breeding 195:17 

cross-checking 270:1 

cross-code 384:3 

cross-codes 385:21 

Crotser 7:11 23:17,17 

26:18 27:2 28:6,18 

crowd 433:10 

crucial 225:19 

crux 173:5 

crying 299:8 

Crystal 232:14 

CS 83:19 

cultivars 193:18,20 

cultivated 155:3 

cultivation 154:22 

cultural 413:3 

cultures 18:3 82:8,12 

curated 327:19 

cure 303:5,9 

curiosity 296:1 

curious 68:9 69:13 

128:13 170:3 254:21 

255:2 293:19 

current 9:9 31:16 34:4 

34:15 42:12 51:20 

53:7 59:11 60:2 67:20 

83:22 105:8,17 

115:19 127:10 154:2 

160:21 162:9 207:3 

245:3 254:14 292:6 

354:4,5 420:10 

currently 66:1,19 73:19 

87:5 92:12 93:3 99:7 

107:13 156:6 163:6 

163:22 164:14 167:9 

168:13 182:20,21 

184:6 185:17 202:18 

207:6 215:4 216:9 

257:11 262:10 273:4 

297:16 301:9 302:9 

315:6 324:13 378:9 

385:3 421:10 435:15 

443:1 

Currier 153:4 161:18,21 

161:22 165:7,12 

166:1 

customer 8:5 

customers 90:21 91:1,3 

291:15 

Customs 383:19 

cut 215:1,8 293:21 

297:1 374:4 

cycle 187:20 

cycling 107:15 173:21 

283:6 

D

d'Alene 297:17 

D&D 303:17 

D.C 181:3 

daddy 242:15 

daily 13:1 42:5 

Dain 183:19 186:13 

dairies 52:5 208:14 

dairy 35:20 36:5,20 

37:16 47:10 50:7,7,8 

105:11,15 108:9 

176:4,20 177:7 179:8 

181:9 182:13 203:1,4 

205:22 207:10 208:11 

226:11 228:5,8 230:4 

230:6 234:4 277:16 

298:7 317:7 409:21 

434:11 439:1 

Dakota 402:13 

damage 12:8 55:15 

116:22 216:1 

damaging 138:5 

Dan 1:19 149:4,16 

169:21 278:2 311:15 

416:14 418:21 433:16 

436:4,5 

dang 242:3 

Danish 76:3,9 

dark 176:18,22 409:3 

darnit 241:5 

dashboard 385:9 

dashers 70:19 

data 31:12 98:21 

104:10 110:10 117:12 

117:18 119:6,16 

122:2,6,10,11,17,22 

124:6,8,12,15,20,21 

148:2 222:7 224:20 

237:4 325:9 345:7,10 

350:17 386:10,11 

387:3 391:5,8 392:3 

396:21 397:6,15 

database 32:3 117:4,6 

117:7,17 123:10 

124:12 165:20 200:17 

248:15 297:20 298:2 

298:14 345:10 379:18 

381:3,13 393:10 

396:14,16,21 397:13 

402:15 411:12 

databases 115:15 

date 85:5 

daughter 242:14 

daunting 268:9 

Dave 1:16 44:6 67:9 

68:5,6 119:21 121:22 

156:15 160:11 179:21 

180:4 208:20 210:4 

210:21 230:17 231:21 

232:3,4,10 235:5,6 

310:17 313:8 320:2,5 

324:21 327:18 334:9 

348:14 372:6 390:13 

436:5 

Dave's 437:3 

David 2:9 27:14 28:6,13 

125:13 132:9,12 

172:5 205:19 210:17 

213:6 290:22 297:6 

300:4,20 326:8,8 

334:11 335:11 448:12 

Davis 301:10 

day 4:5 13:2,4 32:17 

44:21 47:12 108:16 

109:1 265:13 280:6 

304:17 390:19,20 

446:17 

days 22:8 32:18 33:7 

41:12 45:8 76:20,22 

77:7,13,15,18,22 82:5 

82:9 112:3 226:18 

230:6 269:14 320:11 

372:15 383:3 413:10 

414:3 434:9,10 

de 1:15 26:13,19 273:8 

273:20 282:13 312:19 

314:10 327:1 417:21 

419:8 

dead 268:4 

Deadened 174:1 

deadly 434:13 

deal 114:3 157:21 329:7 

404:13 420:4 429:8 

dealing 61:2 74:22 75:4 

75:6 176:5 290:12 

333:3 351:1 

deals 75:9,17 

dealt 67:2,3 

Dean 32:9 47:6,9 62:9 

debate 156:17 

DeBates 96:18 102:15 

102:16,16 176:12 

debris 15:12 

decade 35:3 212:21 

429:17 

decades 195:20 

decay 240:21 

December 103:13 

167:15,21 

decide 119:8 253:3 

309:10 325:19,19 

355:17 

decision 9:21 14:6 

153:14 261:9,12,15 

264:17 265:4,19 

337:21 

decision-making 4:15 

201:16 

decisions 107:8 117:13 

252:5 290:13 

deck 7:5,5 23:16 28:22 

32:9 47:7 50:16 53:20 

58:8 62:11 76:5 85:12 

91:11 96:18 102:15 

106:4 109:9 125:13 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
460 

132:10 153:4 161:19 

166:14 171:20 175:14 

183:19 186:14 190:22 

200:5 203:17 205:19 

210:18 213:13 223:6 

230:18 231:22 235:10 

239:19 244:7 247:8 

260:20 277:6 279:19 

declarants 105:18 

Decreased 65:6 

decreasing 30:17 

dedicated 153:8 209:7 

dedication 7:19 113:6 

217:2 300:11 

deep 416:4 

deeper 266:12 391:4 

399:8 

deeply 34:6 35:13 

default 272:20 

defeats 147:5 

defend 42:5 

defending 108:3 

defer 75:10 213:20 

defermentation 261:17 

deficiency 64:22 

define 15:3 107:12 

278:14 315:11 367:3 

368:9 

defined 14:14,21 

106:11 134:12 145:6 

358:11 367:22 

defining 323:9 366:3 

definitely 74:12 159:17 

257:19 259:5 295:3 

303:1 326:19 327:19 

425:4 

definition 23:6 208:1 

355:18 

definitions 94:21 282:7 

degradation 76:15 

78:10,12 79:17 

degrade 51:11 79:11 

83:14 164:19 438:3 

degraded 79:14 

Degrades 292:9 

degrading 81:9 293:2,5 

degree 14:16 63:16,17 

430:16 

degrees 195:9 

del 191:3 

delay 90:17 155:15 

208:10 217:1 432:14 

432:18 

deli 24:3 

deliberate 325:18 

deliberations 247:14 

247:15 

deliberative 11:13 22:1 

delineates 275:7 

delinted 59:2 

delinting 58:15 59:7,21 

60:6,11 

delist 211:17 

delivering 42:20 

delved 266:12 

demand 89:13 99:19 

100:1 134:11 

demanding 145:2 

demands 86:14 

DeMinter 190:22 200:4 

200:6,7 203:12 

demonstrate 37:8,17 

134:7 154:15 215:2 

283:4 

demonstrates 84:4 

denied 284:17 

Denmark 77:18 

density 146:4 241:9 

Department 1:1 38:17 

111:13 121:6 126:20 

139:5 142:15 147:16 

182:7,10 

depend 4:16 280:10 

dependent 154:8 

292:11,15 

depending 79:14 82:21 

143:4 152:9 223:8 

359:2 387:18 430:21 

depends 143:20 229:6 

depleted 94:13 

depletions 326:12 

deploy 396:12,17 

397:12 

depth 247:13 254:11 

301:18 

Deputy 2:9,16 247:18 

297:9 

derive 130:6 

derived 38:7 129:16 

434:12 

describe 88:17 129:7 

described 143:2 293:19 

describing 311:10 

401:8 

desensitized 63:22 

desert 112:10,12 113:8 

113:9 114:11 

deserve 10:1 22:3 

350:22 

deserves 248:19 

design 82:3 

Designated 2:18 

designed 173:12 219:5 

designing 84:21 

desirable 237:17 

desire 156:1 170:13 

214:19 399:13 

desk 397:3 

despair 108:5 

desperation 90:10 

despoiling 331:18 

destroy 143:4 

destroys 333:19 

destruction 15:2 

destructive 139:14 

desuckering 197:20 

detail 118:22 202:7 

319:3 320:15 364:21 

370:13 

detailed 8:19 31:10 

59:11 60:2 61:15 

118:5 211:20 217:22 

279:3 285:7 315:3 

details 58:18 365:9 

detectable 215:3 

345:12 

detecting 270:2 

detective 380:2 

deter 3:13 115:10 

377:19 

detergents 440:7 

deterioration 216:2 

determination 209:16 

313:14 422:2 

determinations 3:4 

306:14 313:6 

determine 119:6 158:9 

204:16 207:7 263:12 

306:19,21 324:18 

342:13 343:2 347:5 

350:8 355:22 367:15 

377:10 

determined 165:14 

determining 204:14 

222:12 

Detroit 63:9 

devastating 18:13 59:3 

410:11 

develop 32:12 33:11 

49:13 50:4 88:20 

90:11 99:5,10 100:12 

101:20 107:20 111:4 

133:8 156:4,12 

157:17 170:19 286:8 

developed 77:16 

100:18 126:14 129:11 

143:12 264:9 299:1 

307:3,10,14 308:5,10 

309:3 310:22 311:11 

developing 9:6 18:11 

21:22 56:20 98:19 

100:13,19 103:22 

128:5 155:20 158:21 

166:19 167:4 205:3 

225:4 

development 32:22 

42:2 59:8,22 67:15 

84:12 90:17 98:5 

99:20 102:6 106:13 

113:13 116:9,10 

158:6 160:13 218:11 

220:9 236:4 319:11 

362:18 375:20 

develops 43:3 

Devon 2:14 305:17 

374:3 

Devro 85:16,16 

Devro's 86:1 

DHA 25:15 91:14,15,19 

dialogue 282:17 320:12 

320:17 385:16 

diameter 407:11 408:4 

Diego 109:12 364:22 

diet 70:14,17 71:1 

dietary 185:19 186:3 

diets 25:12 66:13 

difference 14:11,19 

52:15 354:13 378:17 

384:5 446:18 

differences 74:20 83:10 

83:11 

different 13:9 46:10 

50:7 56:18 70:17 

81:13 136:8 146:22 

152:7 188:5 200:16 

247:22 248:6 252:13 

255:12,12 257:6 

259:10 265:12 276:11 

276:15,20 277:18 

278:11 281:10,15 

283:4 287:4 288:9 

316:11 322:4 335:8 

338:14 349:10 370:12 

377:6 388:1 392:17 

399:3 425:3 429:19 

439:10 446:22 

differently 79:3 81:3 

240:10 276:18 389:15 

difficult 30:9 61:8 110:2 

110:6 139:20 209:1 

220:6 430:4 442:11 

442:16 446:16 

difficulties 226:16 

difficulty 254:19 396:22 

dihydrate 417:10 

418:15 

dihydrogen 213:18 

221:18 

diligence 45:7 64:9 

Dill 7:10,14,15 11:9,12 

12:2 14:13 16:3 18:7 

19:2 21:16 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
461 

dilution 296:15,15 

DiMatteo 244:13,14 

dinosaurs 70:1 71:9 

dioxide 127:4 292:18 

dip 375:4 438:22 

dips 439:21 440:11 

dire 229:13 

direct 12:12 20:16 

69:12 94:21,22 95:4 

154:17 155:1 193:15 

237:10 253:18 294:1 

355:16 356:9,14 

415:5 

directed 308:4 

directing 210:6 

direction 34:12 138:14 

174:3 201:10 378:4 

433:18 

directions 338:15 

directive 84:22 85:5 

directly 21:6 37:14 46:9 

49:2 118:3 176:3 

178:6 378:7 381:12 

director 2:11 32:12 

35:19 50:22 102:17 

132:12 176:1 232:12 

235:13 280:21 291:4 

directs 274:17,18 

dirt 14:22 16:15 

disables 108:12 

disadvantage 263:7 

disagree 37:5,17 138:2 

277:14 

disagreement 37:8 

disappointed 234:20 

disappointing 241:17 

disappointment 33:9 

discard 434:10 

discarded 51:17 

discernment 106:14 

disclaimers 336:22 

disclose 84:17 

disclosure 84:18 118:5 

118:14 

discoloration 76:20 

discontinuation 25:10 

discontinue 215:12 

discovered 172:13 

430:2 

discovery 9:20 

discredited 212:19 

discrete 34:13 421:14 

discretion 106:22 

discuss 162:2 261:3 

321:4 357:6,10,20 

375:22 377:14 440:11 

441:18 

discussed 58:20 94:15 

162:21 191:16 236:12 

251:13 350:11 383:12 

384:20 

discusses 36:3,3 

discussing 92:1 341:18 

351:8 433:8 

discussion 3:5,6,7,9,12 

3:15 20:17,18 21:10 

22:17 32:19 34:4,7 

35:10 42:12 43:8,15 

43:20 45:13,19 46:14 

46:17 47:1 56:4 60:21 

68:13 86:3 104:19 

115:10 136:10 140:13 

159:16 162:3,4,13 

164:6,8 170:20 

184:17 205:16 244:21 

259:2 285:9,11 

306:12 309:9 311:16 

313:8,16 314:19 

315:1 318:18 320:7 

323:16 324:15 325:22 

328:9 333:8 335:17 

339:7,13 340:8 347:1 

350:19,20,21 351:7 

353:15,20 358:16 

359:3 368:14 371:17 

372:8 374:12 375:15 

376:2 377:19 381:2 

383:8 401:3 405:5 

419:19 421:13 422:10 

426:4,4,7 432:6 

discussions 88:9,22 

277:5 283:15 300:13 

350:14 376:19 382:19 

420:1 

disease 55:5 207:2 

208:3 233:22 420:21 

421:10 

diseases 113:9,10 

199:16 280:12 

disheartening 227:12 

disinfect 55:8 

disinfectant 292:2 

434:5 437:13 

disinfecting 12:15 

294:2 

disinfection 216:7 

disinfects 294:6 

disintegrate 198:19 

dismiss 118:9 

disposable 154:19 

disposal 105:20 

dispute 135:20 238:10 

disrupter 188:1 

disruption 25:1 55:19 

188:3,7 201:4 

disruptors 188:11 

disrupts 346:2 

dissertation 45:1 

disservice 33:10 

dissonance 174:12 

distinct 36:7 

distortions 225:2 

distract 5:17 

distributed 150:13 

distributor 291:8 

distributors 29:8 

disturbance 154:21 

disturbing 53:3 284:22 

dive 115:11 301:19 

365:8 392:3 

diverse 114:15 276:10 

277:15 278:7 399:7 

diversified 155:4 

diversity 210:7 

divided 150:2 

Division 2:12 

DL 66:18 74:22 

DL- 75:4 442:10 

doable 342:15 

docket 42:13,21 110:14 

111:2 165:5 196:9 

238:16 239:12 321:12 

416:5 

doctor 63:7 

document 3:5,6,7,9,12 

3:15 20:13,17 21:10 

22:17 34:4 40:14 

42:12 43:15,21 45:3 

45:14,20 46:14,17 

47:1,4 56:4 60:21 

98:10 104:19 109:19 

115:10 116:11 136:10 

137:21 162:3,4,14 

164:6,8 178:16 

184:18 205:16 212:4 

238:16 244:22 281:19 

306:16 310:14 314:19 

319:16 320:7 321:12 

323:16 325:3 330:4 

331:1 339:7,14 343:9 

347:1 350:13,19,20 

350:21 351:8 353:15 

353:20 354:20 357:21 

358:16 359:3 361:16 

362:2 366:16 371:7,8 

376:18 377:15,19 

378:4 401:3 416:10 

419:19 426:5,14 

428:20 

document's 310:6 

documentation 30:2,8 

31:9 120:4 208:4 

379:13 421:1 

documents 20:18 29:16 

30:14 32:19 35:10 

40:17,18 41:2 75:8 

306:8,12 319:3 

328:20 330:13 

dog 187:8 

dogs 24:2 

doing 41:14 43:19 

78:10 102:12 132:5 

139:10 140:22,22 

141:14 142:16 164:18 

174:7 180:14 198:20 

208:22 209:8 227:8 

228:1 247:17 248:12 

256:15 261:10 270:7 

283:6 341:19 342:10 

347:10 349:15 380:17 

385:11 388:10 391:5 

392:4 399:16 406:18 

432:9 

Dolana 210:18 213:12 

213:15 

dollars 257:10 

domain 131:6 

domestic 50:22 112:15 

274:2,4 388:2 402:8 

409:8 410:9,17 

domestically 220:19 

394:16 

domino 387:9 

dominos 387:10 

donor 316:2 317:4 

door 443:15 444:1 

dormant 241:20 446:6 

double 159:5 160:9 

Doug 153:4 161:18,20 

161:22 

Dr 2:11,16 24:9,15 

38:12 40:12 47:16 

62:13,16,19 66:9,15 

67:13,17 68:12 70:2,9 

71:14 72:9 73:7,14 

74:11,16,18 75:2,16 

124:4 125:3 149:12 

169:22 176:19 188:1 

208:7 232:7 240:22 

278:3 304:15 311:14 

312:11 314:2 362:17 

367:10 373:12 382:22 

386:6 389:2,5 395:18 

409:18 417:13 418:22 

426:3,17,19 427:22 

428:6 433:17 434:2 

436:13 437:5 

drafted 134:2 

drafts 325:4 

drags 49:5 

dramatically 30:15 

154:11 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
462 

drastic 208:13 

drastically 58:21 

draw 99:3 105:10 

108:15 289:6 

drawn 337:3 

drawn-out 265:11 

dressing 164:13 

dressings 13:18 

drinks 73:3 

drive 145:1 176:22 

180:10 242:13 

drizzled 404:9 

drop 296:17,17,17 

dropped 17:1 182:11 

drops 187:13 

drought 307:15 310:13 

311:12 

drove 47:11 

drowning 112:22 

269:12 

drug 435:8 

due 34:8 45:6 52:9 

63:13 64:8 73:19 87:5 

93:16 113:5 116:20 

177:17 215:21 233:22 

317:9 348:4 385:13 

403:11 

dumps 407:17 

dung 233:15 

DVM 58:8 

dynamic 222:6 

E

E 72:3 

eagerly 214:16 

eagles 288:16 

ear 208:8 

earlier 15:19 39:16,17 

189:14 213:21 228:13 

253:13 283:17 

early 106:7 127:14 

267:21 392:3 404:5 

432:7 

earth 192:7 259:12 

earthworms 233:15 

ease 26:10 

easier 23:1 358:18 

easiest 431:1 

easily 116:4 385:5 

east 73:16 112:10 

195:19 335:3 

eastern 113:4,19 176:2 

easy 45:11 413:1 

421:12 

eat 50:10 71:9 266:8 

446:9 

EC 402:19 

echo 227:3 304:15 

395:9 437:3 

echoed 401:22 415:20 

echoing 52:7 

eco-friendly 233:14 

ecological 134:16 

346:12 

ecology 328:3,13 

333:14 

economic 154:7 336:1 

435:1 

economical 61:15 

economics 414:1,16 

economies 108:11 

ecosystem 136:14 

336:4,6 

ecosystems 26:4 51:13 

Ed 290:22 

edible 36:11 

editing 282:10 

edits 202:6 

educate 224:1 

educated 444:20 

education 41:10 129:2 

Edward 297:6,7 300:4 

effect 56:22 149:18 

316:20 435:7 

effective 32:21 55:3 

56:7,14 117:19 

121:15 168:10 188:19 

347:15 368:10 378:15 

393:1 

effectively 10:3 120:19 

127:19 174:21 214:10 

215:2 415:3 

effects 67:22 215:10 

efficacy 237:21 

efficiency 30:17 154:8 

efficient 65:10 240:18 

efficiently 70:21 399:18 

effort 63:13 101:20 

102:4 153:21 155:11 

305:19 

efforts 53:13 99:10 

102:21 103:7 132:16 

193:6 226:11 

egg 67:6 89:12,22 90:6 

156:17 266:20 286:20 

300:14,22 301:1 

eggs 65:11 187:18 

eight 76:20 212:16 

260:13 

either 5:17 84:10 90:18 

93:2 181:15 212:4 

302:6 318:14 327:14 

343:18 344:22 349:19 

358:8 369:10 396:17 

398:19 

ELA 1:12 39:6 57:7,16 

57:19 78:17 80:10 

90:4 128:3,7 141:12 

156:16 157:10 158:1 

158:3,7,11,17 159:1 

190:3,7,15 196:11,17 

197:2 238:7,12 239:7 

242:20 243:18 253:12 

264:15 287:9 312:15 

314:6 328:15 359:15 

361:9 400:8 417:17 

419:4 444:9 

Elan 166:18 

elected 111:14 

electrolyzed 12:22 

electronic 387:8 

elegant 199:19 

elements 10:12 184:21 

271:12 

elevator 341:5 

eliminate 8:17 15:22 

179:6 288:11 

eliminating 154:19 

372:15 

Ellepot 76:9,10 77:16 

78:12 80:6,9 81:4 

82:1 84:22 157:4 

Ellor 279:18,21 

else's 330:6 

email 110:19 

emails 368:16 

embed 386:1 

embryo 3:6 314:20 

315:19 316:2,17 

318:4 319:12 

embryos 316:21 

emerge 384:9 

emerged 211:14 

emergency 234:15 

Emily 1:17 20:10 35:17 

42:9,22 78:16 82:15 

110:21 128:10 136:3 

137:19 150:17 156:15 

159:2 165:8 196:10 

197:15 217:4 250:11 

254:16 276:6 289:10 

303:18 306:3,5 326:5 

338:10 362:20 390:5 

392:1 395:7 406:8 

410:15 412:9 437:1 

445:1 

emissions 127:4 

emphasis 103:18 

206:22 

emphasize 56:5 115:12 

emphasizing 367:21 

employee 215:22 

Employees 295:15 

empowered 107:7 

emulsion 127:13 

130:14 

en 430:1 

enable 200:22 201:19 

201:20 

enabled 208:14 

enables 412:4 

enabling 87:14 

encapsulate 26:9 

encapsulated 25:4 

97:20 

encounter 142:10 

encourage 101:19 

104:18 186:1 191:7 

192:10 201:18 211:2 

216:20 298:7,9 368:1 

378:6,21 383:14 

393:3 394:5 442:7 

encouraged 160:21 

encouragement 381:16 

encourages 95:7 

encouraging 391:6 

ended 181:6 

endorse 34:9 

endorsing 217:14 

ends 49:5 296:12 

energy 232:21 377:1,3 

enforce 53:7 254:3 

enforceable 327:7 

enforced 105:9 185:12 

enforcement 103:16 

177:18 185:15 186:7 

248:11 249:4 253:18 

254:7,22 256:2,3,5,11 

267:12 382:7 389:9 

392:11,14 409:20 

enforcing 255:4 

engage 20:18 33:19 

34:6 35:13 43:4 44:18 

133:4 224:2 

engaged 44:4 224:8 

engagement 32:13 

engineered 220:15 

431:7 

engineering 317:12 

318:7 345:18 347:5 

England 335:8 

English 397:9 

English-speaking

223:22 

enhance 28:3 30:11 

72:20 

enhanced 155:1 

enhancement 107:16 

enhancer 27:15 442:19 

enhancing 283:7 

enjoyed 281:6 

enormous 325:5 384:5 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
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383:9 

enroll 103:4 

ensure 64:2 90:13 

91:19 186:7 201:15 

226:20 244:16 

ensures 92:21 

ensuring 132:21 185:6 

323:12 

entails 61:20 

enter 63:14 

enteral 266:7 

entire 36:6 54:21 85:20 

113:19 117:1 135:10 

152:1 226:17 285:17 

291:13 386:16 445:19 

entirely 193:17 420:10 

entities 277:18 394:7 

398:10 

entity 343:12 

entries 391:17 

Entrust 189:8 

environment 16:13 

113:7 118:7 133:2 

134:5 137:1 138:5 

151:14 162:16 163:6 

168:21 283:8 290:8 

324:6 328:4,13 

331:12 336:2 364:1 

383:22 396:18 414:18 

437:22 

environmental 9:17 

12:11 13:13,13 16:16 

27:7 51:2 64:4 65:13 

92:20 126:12 133:20 

134:9 138:10 154:17 

214:4 307:14 310:12 

311:11 322:13,20 

323:6,12,13 324:7 

435:3,5 437:20 

environmentalists

143:15 

environmentally 15:17 

65:7 295:1 440:9 

environments 446:14 

446:21 

envision 151:22 

EPA 25:15 91:13,15,19 

212:6,9 214:5 236:20 

237:2,4 246:1,3 

437:18 

EPA's 245:7,17 

EPA/DHA 95:11 

epicenter 54:15 

equal 228:2 

equally 139:11 

equate 269:20 

equates 25:7 229:5 

equipment 12:4,9 13:7 

216:2 293:15,20 

437:16 

equivalency 273:8,16 

273:18 279:2 393:19 

393:21 397:1 

equivalent 262:12 

Erin 24:9 

error 177:15 

especially 10:3 13:8 

81:15 134:3 139:22 

147:12 315:4 316:7 

321:21 322:13 329:18 

340:21 362:1 368:17 

379:5 399:19 404:4,5 

essence 282:12 

essential 8:11,12 55:20 

59:13 60:4 64:11,12 

66:4 184:21 185:14 

205:11 216:17 224:13 

236:3 245:1 291:21 

436:2 

essentiality 214:7 

238:17 

essentially 263:9 336:4 

establish 34:6 139:3,3 

139:6 147:17 253:5 

established 25:22 

56:16 148:4 201:15 

246:20 287:6 

establishes 25:18 

establishment 43:1 

estate 191:3 

estimate 96:11 145:20 

146:2 151:20 167:7 

381:9 

estimated 96:8 135:7 

135:10,15 

ether 440:4 

ethical 107:8 

ethoxylated 440:4 

EU 249:6 273:1,3,16 

402:21 403:5 

Eurasia 192:4 

Europe 75:4,9,17 84:22 

152:15 189:2 225:7 

301:22 

European 74:20 195:18 

301:21 402:20 435:1 

evacuate 296:22 

evaluate 14:1 134:15 

289:8 354:6 370:5 

373:5 374:7 

evaluating 8:17 9:16 

372:22 375:20 

evaluation 9:7,10,12 

10:2,17 46:17 133:15 

245:6,9 264:10 

306:20 370:7 373:13 

Eve 269:15 

event 172:12 

everybody 38:13 62:18 

111:10 115:3 141:22 

172:19 199:7 231:1 

261:20 289:2 308:22 

355:6 376:6 383:1 

everybody's 282:1 

everyone's 129:4 

323:18 

evidence 134:9 274:19 

evolutionists 300:16 

evolve 86:13 

exact 19:2 286:1 328:22 

exactly 28:11 43:21 

44:4 102:2 140:21 

143:1 161:10 252:2 

259:1 260:4 265:14 

415:8 

examination 133:19 

155:15 

examine 137:6 

example 16:21 31:19 

46:9 135:8 140:6 

146:7 147:21 149:20 

151:14 157:3 163:2 

219:8 288:15 295:18 

326:2,12,15,16 385:6 

examples 26:20 163:3 

173:9 253:15,20 

285:14 287:2 

exceeded 359:9 

Excel 417:7 

excellent 99:9 297:21 

315:4 325:15 372:18 

373:3 377:21 378:8 

exceptions 154:1 

excess 212:7 

exchange 224:2 

exchanges 397:15 

excipients 358:8 

366:10 

excited 65:17 102:11 

286:4 324:19 389:16 

395:18 

excites 226:19 400:11 

exciting 397:18 

exclude 439:8 

excluded 3:4,5,15 

34:14,20 35:6 178:19 

178:20 183:2 201:9 

206:3 207:4,8,12,20 

209:4,17 306:13,19 

306:21 313:5 315:12 

317:18 319:16 419:20 

420:7,11,13,17,20 

421:14,20 422:1,16 

423:9,18,22 424:5,18 

424:21 425:5,6,12,14 

425:17 427:3,8,10 

exclusion 29:22 

exclusively 152:10 

excuse 127:22 141:21 

335:11 401:3 416:21 

417:7 418:17 

execute 120:20 

executive 176:1 280:21 

297:16 

exempt 298:19 

exemption 181:9,11,14 

181:14 182:1,3 302:2 

exercise 121:16 

exercised 106:8 120:10 

exercises 116:5 

exhaustive 320:14 

exist 17:13 22:19 25:14 

87:20 92:12,12 

117:10 

existing 45:14,20,22 

46:2,18 116:5 155:11 

159:10 227:21 246:20 

274:12,16 275:21 

406:18 

exists 273:20 403:7 

429:22 

expand 138:22 299:17 

371:5 385:12 406:14 

expanded 148:10 

expansion 160:22 

299:16 378:18 

expect 339:19 363:17 

expectation 134:14 

expected 77:1 107:7 

343:19,20,21,22 

437:21 438:3 

expecting 341:1 346:6 

expenditures 368:9 

expense 336:1 

expensive 78:6 317:10 

414:18 

experience 29:5 95:12 

116:6 120:8 246:1 

294:16 403:17 

experimental 237:3 

expert 19:9 42:14 100:9 

256:15 321:9 

expertise 13:19,19 

19:17 153:3 315:2 

322:8,9 324:8 333:21 

395:12 

experts 10:8 263:6 

325:11 363:16 

explain 41:1 70:5 

165:16 386:8 397:9 

explained 47:14 100:4 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
464 

107:4 

explaining 14:19 40:18 

explicitly 225:13 

explode 404:14 

exploitation 146:10 

147:6,17 148:5,15,19 

149:14 

exploited 94:6 

exploiting 149:13 

exploration 393:22 

explore 250:5 252:13 

363:14 395:2 

explored 254:10 393:2 

394:13 

explores 172:7 

exploring 24:8 104:14 

394:19 

exponentially 355:9 

Export 237:6 

exporting 228:8 

exposed 194:4 

express 208:17 219:17 

expressed 204:11 

expressing 8:20 259:21 

extended 266:6 

extension 407:12 

extensive 93:13 278:13 

415:2 

extensively 142:14 

148:13 

extent 42:4 53:10 

179:18 220:18 323:10 

external 418:16 

extinct 331:19 

extract 168:18 

extraction 434:15 

extremely 112:7 442:16 

eye 11:6 172:20 331:17 

F

fabrics 173:17 

face 392:22 

facets 388:1 

facilitate 378:22 

facilities 19:11 293:3 

facility 242:6 

fact 8:11 18:5 46:14 

51:3 60:13 122:22 

136:12 137:16 138:3 

167:15 303:6 317:21 

334:12 340:15 355:4 

356:16 369:4 398:18 

404:15 430:4 

facto 273:8,20 282:13 

factor 64:15 271:3 

factors 16:16 72:5 

facts 135:22 290:12 

FAFO 24:14 

fail 403:11 

failsafe 17:20 

Failure 108:10 

fair 14:5 35:13 86:4 

90:19 141:22 344:2 

344:13 363:4 424:3 

fairly 61:15 157:6 

264:17 313:13 315:15 

faith 108:6 276:1 

fall 28:17 34:5 37:9 

42:13 110:8 153:13 

156:2,11 158:13 

163:7 168:16 221:15 

243:19,22 305:5 

315:14 319:4,9 321:9 

321:17 337:20 338:9 

343:7 360:19 390:1 

390:12 441:1 

fall's 244:2 

falls 141:12 225:9 

264:22 

familiar 17:15 73:4 

103:2 

families 51:15 108:11 

176:21 

family 52:5,17 202:22 

235:14 291:12 

family's 62:1 240:4 

famously 270:6 

FAO 94:6 

FAO/WHO 237:6 

far 5:9 73:16 78:2 

105:10 123:13 151:1 

226:8 302:20 331:22 

332:22 337:7 389:13 

389:14 404:18 

farfetched 173:16 

farm 25:8 32:12 35:18 

36:21 49:11 62:1 

103:8,12,13 104:3,6,8 

104:12 108:2,11 

111:12,12 119:4 

153:7,7,22 172:16,21 

173:4 191:22 192:17 

195:4 199:20 229:7 

280:10 282:21 283:2 

286:12 294:17 302:15 

346:14 351:12 396:2 

436:16 

farmer 47:10 153:6 

165:16 176:3 183:8 

240:3 268:6 342:20 

343:20 344:22 346:13 

382:3 

farmer-suppliers 118:4 

farmers 35:20 37:2 

48:22 49:4,6 52:6 

53:14 58:13,21 59:3 

60:22 111:15,16 

122:14,21 153:20 

155:2 156:12 160:22 

161:14 176:12 182:13 

184:1 200:22 201:5 

203:20,21 205:22 

208:11 225:7 270:6 

316:8,13 318:13 

331:11 340:16 341:8 

341:9,11,12 342:7 

345:17,22 346:4 

348:1 350:22 351:2,2 

353:1 427:20,21 

farming 200:3 346:12 

farmland 196:3 

farms 29:8 34:1 52:8,10 

52:14,18 105:13 

108:9 122:17 153:9 

153:15 154:5,8 

155:13 174:3,14 

192:13 199:17 203:1 

225:16 229:5 302:13 

331:15,18 

farthest 48:7 

fascinated 250:19 

fascinating 330:15 

fashion 89:18 

fast 39:3 135:1 415:15 

416:1 

faster 106:12 290:17 

fault 340:16 348:5 

favor 52:4 86:9 300:7 

323:4 331:3 435:20 

438:7 442:4 

favorite 270:3 

FBI 398:18 

FDA 27:20 74:8 214:5 

237:9 263:9,11 

423:16 443:6 

FDA's 8:1,3,6 

feasibility 43:12 

feasible 371:6 

feather 65:2 

feather-eating 65:2 

fed 27:22 36:22 

federal 2:18 25:17 

48:21 54:6 114:3 

121:12,18 124:11 

183:9 252:14 253:16 

253:17 254:2 256:22 

257:3,3,4,5,7 305:3 

334:3 381:19 

federally 257:20 423:16 

feed 27:20 28:10 50:9 

71:22 121:5,7 163:21 

181:14 191:13 205:1 

269:22 443:6 

feedback 33:5 38:22 

42:3,16 45:5 111:4 

137:7 363:3 385:15 

feeding 130:5 181:18 

266:7,17 302:21 

444:3 

feedstock 164:17,21 

feedstocks 164:9 

feel 7:6 45:14 58:22 

105:3 120:7 184:12 

189:10 191:19 204:17 

205:14 259:22 260:12 

282:3 318:16 319:7 

319:10 323:5 324:19 

330:2 344:2 358:4 

361:18 388:9 390:3 

404:19 433:2 

feeling 316:13 331:8 

384:7 399:16 

feels 354:3 358:16 

feet 113:15 

fellow 122:1 349:17 

felt 123:20 346:19 

374:7,9,10,12 402:2 

407:8 442:5 

female 187:8 316:15 

fenbendazole 233:11 

234:12,15 

fence 436:14 446:9 

fermentation 264:19,22 

265:4,9,18 375:21 

fermented 186:15 

ferric 211:3,6,12,22 

212:11 213:2,3 

fertility 53:4 173:12,18 

173:21 

fertilizer 127:1,10 

fertilizers 164:3 

fewer 155:3 

fiber 76:16 79:4,5 80:11 

81:7,10,22 158:9 

161:2,5 234:5 

fibers 76:14,16 78:6 

79:7,10,18,22 80:14 

80:15,20 81:8 84:6,11 

84:19 156:5,6,18,19 

157:1,2,19,21 158:16 

158:19,22 159:12 

202:15 206:14 

field 16:7 82:14 122:8 

123:5 141:22 172:7 

184:15 235:20 238:1 

239:22 287:15 294:20 

301:12 424:10 

fifteen 251:15 

fight 105:21 

fighting 131:11 

figuratively 232:12 

figure 191:7 199:18 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
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253:2 359:17 360:10 

380:3 385:12 424:2 

figuring 327:9 

filed 31:14 

filing 169:8 

filled 113:17 174:5 

filter 77:12 

final 31:5,7 37:12 49:2 

105:2,12 108:14 

126:18 132:6 163:17 

169:11 176:15 177:3 

177:8 178:7 182:14 

203:2 208:9,15 

226:14 227:6,13 

242:11 246:12 290:13 

298:9,10 305:4,22 

342:17 347:6 353:18 

372:6 384:12 

finally 77:19 134:17 

182:10 199:22 

finances 371:12 

financial 346:16 

financially 78:4 102:5 

find 71:12 73:17 74:9 

77:3,14 83:18 85:6 

89:2 99:13 106:19 

139:4 140:12 165:6 

173:16 174:9 185:13 

193:1,2 217:7 226:12 

229:22 280:12 282:16 

323:11 329:8 346:10 

359:5,15 363:17 

379:21 398:16,18 

406:10 408:4,15 

411:8 412:19 421:13 

421:19 429:8 448:1 

finding 152:15 193:17 

286:17 290:7 362:21 

421:8,22 447:21 

fine 9:12 53:13 57:21 

148:1 149:11 158:18 

352:17 

finish 40:3 233:9 264:5 

373:10 426:1 

finished 211:10 301:10 

finishing 237:16 

fire 55:6 107:22 

first 7:10 14:17,18 15:8 

38:12 76:15 77:12 

84:15 85:4 89:22 97:5 

98:18 102:4 111:18 

111:20 137:19 153:12 

161:4 162:6 170:17 

181:10 182:3 187:22 

195:2 196:20 221:5 

226:9 230:16 231:21 

240:17 258:4,6 

266:21 267:2,4 

279:18 285:12 287:21 

289:6 291:2 297:19 

302:1 324:22 359:13 

362:15 364:2 382:22 

390:16,19 391:13 

392:10 397:8 401:13 

406:22 417:6 420:9 

426:11 433:12,14 

first-come 4:20 

fish 25:3,4,9,16,20,20 

25:21 26:2,2,6,9,9,14 

26:21 66:12,14,16,18 

67:7 83:16 91:16 92:1 

92:3,5,11,11,18 93:2 

93:6,7,8,9,11,20,21 

94:4,11,12,16,19 95:3 

95:3,7,8,10 96:5 

127:13 130:14 138:11 

138:11 163:2 228:20 

228:21,22 230:10 

286:15 

fisheries 26:1 27:4 93:1 

94:5,12,13 139:5 

142:15 144:13 147:17 

326:14 

fishery 326:11 

fishing 93:5 94:21,22 

95:1,5 

fishy 67:6 

fit 45:22 46:18 317:20 

354:8 372:22 373:5,6 

fits 318:8 319:15 

five 38:2 48:3 97:22 

173:7 192:19 251:15 

302:2 306:8 405:8 

435:20 

fix 182:8 

fixed 33:15 367:18 

430:2 

fixing 118:7,22 119:15 

123:14,19 

flavor 166:20 167:11,16 

167:17 168:7,11,12 

168:16,17 170:19 

171:12 

Flavorganics 166:19 

flavors 167:8,9,12 

168:4 169:1 170:2,12 

170:22 171:10 

flax 84:10 

flesh 322:11 440:21 

fleshed 46:16 

flexibility 103:20 

104:13 

flight 432:22 

flip 285:12 337:1 

floating 328:20 

flock 112:2 301:15 

446:19 

flocks 68:9,17,20 74:2 

234:2,4,16 235:2 

445:15 446:17 

flood 112:22 286:2 

flooded 113:19 

floor 231:3,6 303:8 

448:11 

Flop 281:9 

Flores 279:19 290:22 

291:2,4 293:10,22 

294:6,10,13 295:8 

297:4 

flour 407:7 

flourish 114:12 

flowering 192:19 

flowers 414:4,6 

flush 363:17 

fly 72:1 189:21 

flyers 231:4 

focus 46:5 54:10 

116:13 214:7 277:7,9 

362:7 371:18 378:16 

390:9 436:18 

focused 31:22 144:2,3 

378:2 

focusing 22:11 103:7 

136:17 387:16 410:3 

426:9 

foliar 128:4 235:20 

folks 19:11,17,19 22:3 

44:13,15,18 179:2 

180:22 218:3 221:15 

233:11 267:20 325:8 

326:7,11 349:6,10 

350:6 383:14 401:12 

406:2,4 447:19 

follow 19:8 82:21 83:17 

85:20 88:7 130:21 

149:9 158:1 260:21 

282:20 300:8 353:8 

367:11 412:14 420:9 

follow- 90:4 150:19 

follow-up 18:3 74:4 

139:18 266:18 

followed 177:21 216:1 

334:3 

following 17:10 36:10 

94:3,17 116:13 

156:11 228:12 330:3 

385:22 437:22 

follows 48:10 281:13 

367:12 

fondly 380:16 

food 7:15 8:2,10,12 

14:15,17 19:10 51:14 

55:8 56:11,19 57:2 

63:14 64:3 70:14 

71:19 85:17 86:9 

115:7 126:20 155:2 

166:21 170:13 184:20 

185:4,4 214:11 215:9 

216:18 220:2 233:2,7 

237:7,11 244:17 

249:20 250:8 251:4 

253:9 258:4 264:11 

264:12 291:5,6,21 

293:3,22 294:2,17 

299:7,9 346:12 

355:10 356:5,20 

363:16 370:1 372:17 

372:19 379:3 448:14 

food-borne 56:8,15 

foods 170:3,6 263:19 

266:4,7 284:20 

384:18 

foot 48:3 83:5 113:20 

446:1 

footprint 65:13 

forage 275:12 407:11 

410:21 412:22 413:13 

414:3,3,5,6,10,15,22 

415:1 

foralmite's 274:3 

force 34:6 42:16 43:1 

64:6 98:12,20 264:8 

301:4 322:5,10 327:2 

327:11 330:22 340:5 

350:6 407:2 442:10 

447:17 

forcefully 272:5 

forces 282:4 

foreign 8:2 402:16 

410:18 

foreshadowing 234:11 

forest 112:9 

forests 410:20 

forget 248:21 249:8 

277:19 400:19 448:19 

forgot 231:2 

form 249:12,15 259:2 

411:19,20 

formal 401:7 

formally 220:12,13 

format 350:21 

formation 98:20 

formed 102:3 

former 105:17 247:18 

386:10 

formic 403:19 404:15 

forms 129:11 437:21 

formula 184:22 263:1 

formulas 245:21 262:10 

263:4,10,18 264:1 

formulate 163:19 164:4 

formulation 236:16 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
466 

formulations 57:10,12 

190:4 440:14 

forth 86:3 108:13 

147:16 184:14 240:19 

250:20 

fortified 25:6 

fortunately 93:1 411:6 

forum 224:2 

forums 73:15 

forward 6:13 8:21 34:18 

35:7,9 61:4 104:2 

105:5 107:11 108:10 

114:18 122:14 144:17 

169:12 185:9 202:14 

203:2 250:6 252:10 

260:15 271:13 283:10 

319:11,13 321:16,16 

321:18,22 327:2,6 

343:4,5,15 345:7,21 

347:2 353:9 360:21 

361:4 364:16 371:9 

371:15 373:6,16,20 

401:13 408:20 409:17 

410:1 416:9 423:11 

429:6 430:5 439:15 

Fosbury 281:9 

fossil 154:20 

foster 173:12,18 

fostering 51:9 

found 18:3 91:16 201:2 

207:9 219:15 240:20 

254:17 263:13 356:15 

382:1,10 441:1,16 

foundation 117:19 

342:18 

four 68:1 177:2 187:11 

187:21 211:18 212:15 

236:1 241:11 242:13 

267:21 306:11 407:12 

435:20 

fourth 231:3,6 242:17 

fowl 69:9 

fragile 61:2 

fragility 330:16 

frame 42:20 322:16 

323:20 

framework 45:22 64:7 

128:21 245:4 317:18 

France 196:1,2 

Frankel 279:19 280:18 

280:20,21 285:10 

287:17 289:19,22 

290:19 

fraud 3:13 29:12 30:16 

103:3,8 104:1,4,11 

115:10 120:3 224:6 

224:10 268:20 269:11 

269:11 270:2 271:5,7 

271:17 277:7,9 278:1 

298:22 299:5 337:16 

377:19,21 382:1 

383:4 388:1,2,3,3,4 

391:14 393:12 409:20 

fraudulent 382:3,4 

free 7:6 

frequently 215:19 

fresh 56:9 214:22 215:8 

293:21 399:2 432:7 

friendliness 62:21 

friendly 310:18 

friends 26:1 106:18 

FRIZELL 239:1 

Frizzell 230:18 235:9,12 

235:13 238:11 239:16 

frog 68:22 

front 11:3 22:4 108:3 

168:1 187:18 220:11 

231:4 351:1 352:10 

368:10 384:22 

fruit 31:20 54:10,15 

55:10,15,18,22 57:13 

187:3,20 198:19 

frustrated 107:1 374:7 

375:3 

frustrating 180:17 

frustration 108:6 

259:21 360:2 

FSMA 56:22 216:12 

355:1 369:5 

FSMA's 16:10 

FTC 254:6 

fuels 71:2 154:20 

Fukuoka 270:5 

full 13:6 30:5 97:17 

235:16,17 237:19,21 

240:12 265:22 275:18 

284:4 320:21 321:1 

404:12 417:10 421:16 

fullest 42:4 

fully 33:18 41:22 43:4 

46:16 86:6 115:15 

148:17 172:10 278:6 

394:11 412:11 

fun 240:5 247:10 248:3 

function 9:3 26:6,8 

64:18 252:6 422:6 

functional 87:22 

functioning 42:7 

257:14 370:6 

functions 64:16 

fundamental 191:18 

194:22 

fundamentally 33:14 

360:5 383:20 

funded 256:21 257:4,5 

257:16,20 301:9 

447:22 

funding 24:14 102:9 

103:14 256:22 257:1 

257:3 302:17 396:2 

funds 104:13,17 

fungal 113:9,9 

fungus 77:3 83:5 

funny 303:19 

further 97:9,13 208:10 

212:5,22 216:22 

265:9 285:9 311:16 

313:8,16 328:5,9 

336:11 393:22 407:20 

Furthermore 185:7 

future 53:7 56:8 65:18 

67:15,19 74:2 84:21 

88:19 102:13 133:15 

133:19 143:8 177:13 

179:18 243:16 251:16 

258:20,21 259:3,12 

307:18 313:10 317:16 

318:16 319:19 320:16 

333:7 340:1 354:5 

374:10,14 

G

GAAP 17:10 

GAAPs 17:18 

Gabriel 279:19 290:21 

291:3 

gain 39:4 

gallons 25:6 

galvanized 37:9 

game 91:5 269:19 

387:9 

game-changing 130:12 

gap 91:4 347:8 

gaps 359:5 374:20 

394:14 

garden 268:14 

gardener 172:3 

gardening 195:2 

Garth 260:20 267:19 

268:1 271:1 272:4 

279:13 337:15 401:20 

407:1 415:18 

Garth's 402:15 

gas 296:19 438:4 

gases 268:3 296:21 

gate 50:9 

gather 200:21 209:2 

301:15 

gathering 124:6 

GE 99:6 345:12 346:1 

347:18,21 

gears 185:16 

gel 86:1,4,9,10,18 87:5 

87:12,16,22 91:5 

gelatin 25:3,4 26:5,6,8 

gels 85:16 87:10 

gene 316:4 

general 26:20 34:10 

89:22 120:10 222:11 

281:18 297:18 300:1 

300:20 381:5,16 

439:22 

generally 57:8 345:20 

346:15 414:22 430:1 

generate 12:21 

generated 292:19 

generation 240:3 

242:17 

generations 50:9 64:1 

317:2 318:5 319:19 

generic 110:6 428:18 

genes 219:17 

genetic 3:7 60:20 65:19 

67:21 98:7 199:13 

204:8 225:18 317:12 

318:1,7 339:9 340:6 

340:19 341:15 342:14 

342:22 345:3,18 

347:5,9 348:4 351:3 

genetically 209:16 

431:7 

genetics 67:21 316:9 

318:3 319:19 

genotypical 68:3 

germicide 437:14 

gestation 177:14 

181:20,22 

getting 40:19 72:14 

112:5 132:5 141:5 

170:9 189:3 227:5 

234:8 239:6 265:1 

285:13 361:1 363:9 

390:8 396:1 

giant 113:18 

gift 7:8 

gigantic 114:1 

give 4:13,18 22:3 34:5 

35:13 40:13 44:15,22 

70:13,15 71:11 80:13 

80:22 141:5 145:16 

157:12 160:6 204:6 

217:11 229:10 239:12 

263:1 287:18 288:1 

301:7 304:10 305:22 

315:17 321:2 340:3 

350:16 358:4,14 

381:21 392:20 405:2 

405:7,9 430:16 

431:11,14,15,17 

given 69:6 71:14 120:6 

123:20 140:16 141:17 

144:15 146:9 150:16 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
467 

220:13 222:5,6 230:4 

230:5 278:11 317:4 

318:2 348:6 355:4 

358:3 369:22 390:21 

436:22 

gives 6:3 63:18 67:1 

104:13 139:10 356:4 

giving 4:13 26:20 70:22 

71:17 113:1 282:8 

286:16 318:10 

glaciers 113:16 

glad 155:14 418:11 

GLASGOW 2:9 

glasses 100:17 

global 25:15 29:10 

91:13 108:7 127:4 

132:14 223:19 224:10 

225:14 272:18 398:1 

globally 139:22 143:13 

gloss 238:3 

glossy 82:19 

glue 78:7 

glycol 440:3 

GMO 34:17 61:5,6,9 

270:13 344:21 349:19 

349:21 350:3 421:11 

goal 88:13 201:8 

276:17,21 322:18 

323:1 324:6,12 354:1 

440:15 

goals 46:22 216:18 

284:20 302:16 

goats 317:6 

GOED 25:15,19 91:22 

92:4,18 93:4,13 94:2 

94:14,15 95:1,7,10 

96:6,7 

GOED's 93:17,18 94:7 

golf 407:18 

goodness 328:21 

400:10 

goods 412:5 

Google 445:8 

Googling 73:10,20 

Gorge 113:21 

gotten 41:16 70:19 

governance 253:2 

governed 255:19 

government 40:22 

41:18 114:4 135:17 

138:21 142:10 144:10 

147:22 148:7 215:6 

253:20 254:20 255:17 

255:22 268:12 270:10 

334:16 335:22 

government-enforced

135:4 

governmental 377:6 

governments 120:19 

120:22 142:21 151:4 

grab 7:6 425:12 

grade 82:5 286:1 

grain 49:16 115:5,7 

118:2 120:9 346:12 

382:17 388:18,19 

391:14,17,18 

grains 388:19 

Granatstein 448:12 

grand 447:13 

grandfathering 267:15 

granted 103:20 104:5 

237:9 

grape 192:2 193:2 

grapes 194:20 195:6 

graphic 100:15 

GRAS 237:10 263:10 

grass 49:21,21 

grateful 38:21 

gray 106:16 108:15 

174:15 

graze 49:17,19 

grazing 178:1 

greater 93:10 224:18 

331:11 392:5 

greatest 216:1 

greatly 208:16 298:3 

greenhouse 268:3 

443:2 

greens 215:1 285:20 

GREENWOOD 1:16 

17:22 18:14 19:22 

123:8,17 124:2 

130:21 131:4,10,15 

193:9 194:6,13 

256:20 312:20 314:11 

333:10 417:22 419:9 

ground 4:13 172:18 

187:13 208:22 235:18 

283:20 284:2 285:1 

296:17 362:3 378:13 

422:21 

group 31:22 86:3 

100:22 101:1 102:3 

133:7,8 134:6 204:20 

212:18 256:22 274:8 

279:22 300:18 302:4 

332:13,18 333:4 

334:15 346:13 349:11 

350:5,6,11 389:12,17 

groups 29:9,16 81:6 

133:5 144:5 185:4 

212:14 253:16,20 

333:6 349:10 383:3 

442:5 

grow 16:14 63:10 87:12 

87:13 112:14,16 

155:2 161:1 172:17 

194:20 195:3,6 

199:10,10 204:20 

284:1 342:21 351:4 

355:9 442:22 443:1 

grower 29:9 30:3 118:3 

123:10 186:20 191:2 

212:14 238:13 288:19 

288:21 315:21 330:1 

332:13,17 333:4,6 

grower-packer- 240:1 

growers 54:4,10 55:10 

55:16 56:1,6,22 57:3 

57:12 61:1 82:6 113:6 

189:18 190:1 198:8 

202:11 212:14 238:2 

238:17,18 239:2 

240:7,8,11,13,22 

283:4 285:22 286:6 

287:2,11 290:3 329:7 

354:22 355:5 361:17 

412:15 

growers' 55:12 

growing 62:6 77:4 

187:2 240:5 242:3 

279:3,10 290:6,6 

341:9 346:21 410:9 

443:2 

grown 3:8 7:16 29:4 

58:12 98:8 172:22 

204:9 225:13 272:21 

339:10 341:15 349:20 

350:4 382:17 

grows 258:9 286:8 

growth 65:1,6 80:7 

86:16 87:14,16 92:21 

103:15 143:8 208:13 

236:3 237:17 

guaranteed 303:5 

guess 38:10 83:14 

89:11 90:4,9 141:12 

141:15 142:5,7 

148:15 156:21 166:4 

238:22 266:20 281:1 

282:19 285:13 287:13 

290:1 300:15 309:8 

324:11 330:10 339:12 

339:22 363:12 372:9 

395:4 

guidance 60:19 80:13 

98:15 99:6,7 106:21 

108:18 116:11,14 

156:9,18 157:13 

168:1 169:5 200:10 

201:17 202:1,17 

205:12 272:16 274:12 

274:17,17 281:19 

322:14 347:7,10 

390:8 

guide 227:17 328:5 

guideline 142:6 

guidelines 94:6 287:4 

347:3 

Gulf 268:5 

gums 46:9,10 

guys' 178:11 

Gwen 101:4 

Gwendolyn 91:11 

96:18,21 

H

H2O2 437:20 

habitat 283:8 288:20 

326:14 

half 47:11 89:7 112:16 

129:3 167:7,19 172:4 

215:16 297:2 304:17 

390:22 433:6 437:6 

half-life 288:2 

hallway 125:15 

ham 24:4 

Hampshire 334:17 

hams 24:5 

hand 101:8 137:13 

138:18 139:10 198:20 

262:8,15 296:15,15 

372:7 379:14,16 

380:8 395:16 398:22 

400:6 444:22 

hand- 138:19 

hand-harvested 137:16 

hand-harvesting

139:15 

hand-held 70:10 

hand-pulled 154:21 

handed 380:5 407:4 

handle 29:20 422:2 

handled 350:21 392:13 

handler 31:5,7 261:4 

handlers 29:9,21 

271:12 412:1,2 

431:16 

handling 3:10 16:20 

26:10 30:3,6 82:7 

85:22 93:13,21 

109:17 167:2 184:17 

245:19 353:20 356:21 

366:11,21 411:16 

429:14 

hands 227:16 277:6 

hang 187:6 

happen 67:16 98:22 

143:2 156:2 167:20 

180:11 187:21 195:19 

234:1 250:22 251:8 

254:2 265:10 266:13 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
468 

266:21 385:6 

happened 59:10 60:1 

77:2,21 80:5 188:6 

220:19 251:17 267:16 

happening 40:2,3 

155:14 174:14 189:2 

248:17 324:10 329:13 

344:19 349:22 

happens 149:12 175:10 

187:10 188:20 223:9 

249:5 259:8 444:4 

happily 198:22 

happy 35:14 95:11 

144:16 203:7 227:14 

303:12 313:9 341:20 

harborage 293:7 

hard 18:22 33:10 39:9 

51:8 53:16 62:22 80:6 

99:11 100:7 108:6 

186:17 204:5 206:1 

216:5 238:16 239:10 

242:4 247:3 291:9 

297:11 303:11 315:14 

330:1 334:2 355:8 

379:13 387:22 397:8 

411:8 421:1 431:10 

446:19 447:3 

harder 329:8 

harm 134:9 136:22 

213:1 322:13,20 

323:12,13 324:7 

harmful 162:15 163:6 

harmonization 224:7 

225:1 

harmony 403:4,15 

Harriet 1:9,12 144:1 

152:9 158:1 161:21 

280:20 306:6,12 

309:13,21 313:7,8 

314:19,21 318:19 

319:22 331:4 339:7 

348:11,13 353:20 

359:7,11 362:20 

365:10 371:13 372:12 

373:22 376:21 377:14 

389:20 401:15,16 

405:5,6 406:14 

412:10 415:3 416:12 

418:2,20 419:21 

422:9,11 424:11 

427:16 444:6,18 

445:7 

Harriet's 275:11 351:12 

369:3 

Harry 85:12 91:10,12 

96:16 

harvest 135:9,17 138:4 

138:17 139:10 143:16 

145:15 146:6,7,10 

147:10 148:15 149:22 

150:3,4 151:17 152:6 

152:18 332:19 333:17 

356:21 

harvested 54:19 134:20 

137:10 143:21 

harvesters 139:21 

140:2 146:19,22 

152:5,10,12,16 

332:11 

harvesting 95:6 132:22 

134:8,21 135:13,16 

136:13 137:12 138:20 

139:14 142:9 143:7 

147:1 148:22 151:15 

331:2 

harvests 26:8 135:6 

149:22 

Hass 123:9 

hate 355:5 367:19 

hats 232:11 

Hawaii 402:10 409:10 

409:13 

hawks 288:16 

haystack 379:22 

hazards 106:17 

head 16:21 66:21 69:7 

126:7 343:14 359:12 

363:4 412:17 

headaches 295:15 

headed 174:3 

heading 319:15 

heads 239:13 401:12 

heal 108:13 

health 9:17 25:17 51:10 

64:3 136:22 173:22 

174:22 208:3 218:12 

232:16 275:17,19 

420:21 426:6,8,11,15 

428:1,9 435:8 439:5 

healthier 49:14 

healthy 183:10 288:16 

288:19 442:13,18 

hear 5:14 6:22 22:6 

39:7 47:17 50:21 

65:17 73:1 74:10,13 

141:14 175:20 180:9 

180:21 208:12 224:14 

233:1 238:18 270:15 

318:12 320:21 321:6 

326:10 364:6,12,16 

383:9 411:6 415:16 

415:19 424:3 429:3 

439:6,9,10 

heard 36:19 37:1,2,5 

40:5 45:12 52:5 66:11 

88:22 99:9 119:2 

123:13,21 144:6 

157:4 177:5 181:2 

187:1 189:14 226:17 

227:4 228:13 230:5 

238:13 239:8 278:1 

281:2 283:19 287:9 

317:22 323:15 333:16 

361:17 364:7,14 

369:6,12 371:3 388:2 

388:2,3,3 392:12,14 

409:6 415:17 439:2 

440:18,19 442:9,15 

hearing 36:19 80:14 

119:19 139:21 179:2 

321:20 329:12 364:17 

383:2 

hears 52:6 

heart 284:21 321:8 

heartbreaking 180:22 

heat 187:8 195:10 

307:15 310:13 311:12 

heath 426:20 

Heather's 302:19 

heavily 110:4 154:8 

337:14 

held 145:9 245:21 

hello 28:22 47:9 91:12 

171:22 200:5 247:9 

297:7,8 

help 16:6 20:12 53:14 

101:2 107:20 113:7 

118:13 122:22 128:20 

141:4 186:6 205:15 

214:12 217:5 220:22 

224:18 243:13 250:22 

279:10 285:11 287:2 

318:11 319:5 323:21 

325:19 328:5,9 339:4 

346:22 358:17 362:6 

363:16,18 374:15 

379:3 387:7 393:1 

397:3 400:5 421:8 

helped 35:7 38:19 

291:9 325:15 334:1 

390:7 

helpful 17:19 82:17 

95:22 104:15 124:6 

128:8 129:5 169:5 

210:10,12 243:2 

320:21 325:18 326:9 

332:21 335:1 339:3 

349:5 383:9 390:12 

391:3 394:1 395:10 

444:17 

helping 191:7 248:4 

319:2 325:9,14 

354:22 359:5 397:6 

444:19 

helps 220:8 243:7 

391:10 

hemp 84:10 157:18 

158:4,9 160:13,15,22 

161:1,2,5 

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Hendrickson 132:10 

153:4,5,6 157:9,15 

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herd 36:7 108:9 177:11 

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376:17 

Hidden 172:4 

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Hiltz 125:13 132:10,11 

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hindered 65:1 

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Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
469 

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423:12 

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418:12 

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184:21 237:4 

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391:10 

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428:5 

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413:19 

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442:16 

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276:17 277:2 

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Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
470 

347:22 

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55:19 86:1 104:18 

158:14,16 208:5 

included 162:13 206:9 

339:17 

includes 10:7 24:2 

25:14 162:14 163:17 

172:16 206:12 245:17 

309:3 

including 29:16 36:5 

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431:20 

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427:4 

individuals 6:19 152:6 

349:11 

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315:5,8 

industrial 51:18 134:16 

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Industries 235:16 

industry 22:14,21 29:5 

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102:5 103:15 104:3 

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133:22 135:6 140:15 

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228:1,5 256:21 258:9 

263:1,6 267:7 292:13 

300:17 356:5 362:1 

409:10 414:8,13 

423:15 439:1 445:18 

447:9,10,22 

industry's 244:3 

industry-funded 302:4 

industry-sponsored

237:20 

inert 246:1 358:8 365:2 

inerts 22:21 365:16,19 

366:6,9,21 

infant 184:22 262:10 

263:1,4,10,18,20 

264:1 

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333:7 444:19 

information 9:18,22 

10:4 13:16,21 14:1 

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28:16 30:13 31:4,6 

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93:15 110:15,16 

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125:1 128:8 132:1 

140:20 141:2 157:12 

175:5,6 200:22 

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211:14,21 317:1 

318:11 325:9 328:8 

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344:7 345:21 346:17 

346:22 352:8,9,13 

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374:18 379:10 381:11 

383:21 399:16 402:1 

429:9 430:17 431:12 

432:2 438:14 441:2 

441:16 

informative 82:17 

informed 117:13 382:9 

444:14 

infrastructure 114:6 

387:7 396:11 

infrastructures 377:1,4 

ingenuity 113:5 

ingestion 434:18 

ingredient 115:7 

162:20 165:15,20 

167:5 211:11 219:22 

236:2,21 354:14,15 

358:12 366:14 367:5 

ingredients 10:22 

22:16,19,22 27:16 

31:2 92:7 115:16 

139:22 155:18 156:9 

162:18 164:4 166:20 

168:16 185:4 237:1 

245:11 246:1 263:18 

356:1,10 358:7,10 

365:2 366:18 375:10 

443:11 

inherent 115:15 431:6 

Inherently 430:22 

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initial 330:13 

initially 147:16 262:3,4 

333:19 

initiative 103:2 246:14 

393:12 

injury 112:1 

innovation 100:22 

102:2 106:12 

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153:8 

input 4:14 8:22 31:11 

33:18 52:3 126:19 

127:15 129:4 133:15 

166:3,5,7,10 194:11 

258:15 282:17 336:5 

inputs 43:19 51:4 71:22 

133:13,21 136:15 

138:15 162:12,14 

191:21 195:6 197:12 

286:13 336:20 

insect 57:5 71:18 

187:11 192:18 

insecticide 360:14 

insecticides 436:8 

insects 68:22 189:3 

192:22 199:16 241:13 

302:21 

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inside 48:4,5 69:8 

187:20 

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256:13 269:17 381:22 

inspections 116:7 

117:16 256:15 

inspector 209:14 268:7 

333:3 398:15 

inspectors 269:6 

270:15 398:6,17 

403:14 

inspired 188:10 

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install 394:12 

instance 80:2 257:3 

instances 29:21 97:8 

Institute 51:1 162:2 

249:15 252:19 

insufficient 115:21 

intact 135:2 

integral 153:21 

integrated 55:12 

240:15 379:18 

integrity 3:7 7:20 29:11 

51:9 60:20 98:7 

102:19 105:21 108:4 

165:19 169:13 204:8 

224:9,14 225:20 

248:15 249:3 269:11 

270:17,21 276:2 

297:20 298:14,16 

325:15 338:1 339:10 

341:14 346:20 379:17 

381:13 390:18 393:10 

396:13,16,20 397:22 

400:16 402:14 411:11 

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227:20 372:15 

intent 8:13 20:14 21:12 

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350:12 371:11 398:14 

431:6 

intention 136:10 169:6 

183:13 358:2 364:2 

372:11 

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Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
471 

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438:21 443:7 

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interesting 83:18 

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359:15 391:21 443:3 

interests 251:15 

interim 262:8 

interject 368:13 

internal 67:2,3 247:22 

259:15 282:10 332:18 

internally 11:3 40:18 

74:1 

international 54:7 

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224:6,7,12,15,19 

225:8,10 257:5 

272:19 274:5 338:1 

342:4 394:5 397:3 

399:20 414:20 

internationally 161:3 

Internet 73:1 

interpret 276:14 

interpretation 57:8 

255:15,18 256:9 

262:16 

interpretations 255:21 

interpreted 276:18 

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386:4 

interrupt 7:1 370:22 

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245:14 291:9 

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236:19 

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139:12 

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124:21 

investment 101:15 

232:21 383:7 

invite 133:15 448:10 

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253:1 284:21 378:10 

396:1 

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iodine 3:18 179:1,10,15 

179:19 228:4,6,15 

438:17,22 439:8,19 

439:21 

iodine's 439:3 

iodines 179:6 

IOIA 62:2 

ion 219:22 

ions 219:10 

IPM 241:19 

ironic 292:22 

irony 111:22 

irresponsible 65:12 

285:22 

irreversible 116:22 

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irrigation 113:12 114:5 

286:2 

irritating 403:20 

island 350:3 

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issue 18:17 19:1 20:5 

34:8 35:8,9 39:4 49:2 

57:20 58:22 60:18 

61:7,8 84:5 101:17 

105:2,6 113:10 120:2 

121:10 136:7 137:21 

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153:16 155:8 159:18 

173:5 174:21 179:4 

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238:12 274:4 281:8 

289:2 315:3,10 316:6 

317:19 318:11 320:20 

322:6 323:14,17 

326:21 335:14 337:16 

347:14 356:22 357:7 

365:7 378:2,10 383:2 

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426:10,20 428:1 

429:21 

issues 21:9 33:6 48:22 

53:1,16 54:7 58:19 

59:6 60:22 66:14 89:1 

92:17 104:21 116:22 

118:2 263:15 269:20 

271:14 284:7 294:21 

322:12 323:6 329:2,6 

329:19 338:4 378:12 

410:11 423:21 439:5 

439:12 440:8,20 

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item 99:4 222:15 

314:18 337:13 353:18 

401:13 412:6,7 

429:18 441:9,9 

items 17:14 204:6 

217:22 222:13 228:3 

268:19 282:18 337:14 

343:13 356:13 378:4 

378:6,16 393:18 

401:4,6 415:21 416:7 

iterative 10:6 14:3 45:4 

J

Jackie 190:22 200:4,5,7 

Jamaican 70:19 

January 262:21 263:16 

Japanese 435:2 

Jay 76:5 85:11,12,15 

188:1 

Jean 338:12 

Jeff 24:15 

Jen 382:20 

JENNIFER 2:16 

Jenny 107:4 124:3 

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368:22 378:21 385:19 

385:20 387:18 388:12 

390:7,19 391:7 

395:15 400:9 409:14 

jerky 24:3 

Jesse 1:14 437:9 

438:16 

Jessica 247:8 260:19 

261:2 267:19 

Jim 87:2 

job 32:12 64:7 141:1,14 

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297:12 310:1 388:10 

Johanna 28:21 32:9,11 

35:16,18 47:5 176:13 

John 132:10 153:3,6 

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Julie 166:14,16 171:18 

jump 281:9 309:13 

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jungle-dwelling 69:10 

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justification 178:6 

K

K 236:2 

Kahl 260:20 267:19,22 

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274:11 276:22 277:21 

278:17 

Kanaga 161:19,20 

166:13 

Kate 176:11 

Kayla 210:5 

keep 34:3,3 42:12 61:9 

66:3 80:21 103:14 

123:5 145:2 189:13 

189:22 191:8 193:7 

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380:21 401:10 411:14 

419:22 422:17 437:1 

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keeping 43:20 155:3 

438:7 

Kelly 53:19 58:7,9 

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key 185:15 277:2 

298:16 398:13 

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391:18 

knowledge 73:12 95:12 

known 9:5 36:1 94:22 

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420:11 434:13 

knows 47:16 75:11 

335:1 347:22 

kudos 444:17 

Kurtz 76:5 85:12,14,15 

89:4 90:1,19 91:9 

Kyla 203:16 205:19,21 

L

L- 261:12 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
472 

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392:9 418:12 419:22 

433:9 

letter 37:16 105:11,13 

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351:14 353:5 

letting 62:18 175:21 

282:5 

lettuce 16:22 17:2,4 

level 15:21 20:7 51:21 

67:22 68:3 79:16 86:2 

122:8 124:16 134:12 

174:12 215:7 216:8 

216:14 229:13 287:14 

292:2,14 295:19 

296:5 341:15 386:12 

430:15 

leveling 285:15 

levels 18:19,21 61:12 

204:11,15 263:13 

345:12,19 

leverage 389:15 

Lewis 2:11 109:9 111:7 

111:10,11 304:10,15 

362:17 373:12 426:3 

426:17,19 427:22 

428:6 

licensed 63:6 75:7 

210:22 434:7 

licensing 150:7,11 

152:17 

lie 325:16 

life 50:2 66:22 82:3,11 

143:19 187:19 355:19 

369:4 445:9 

lift 59:17 

light 13:17 14:2 58:19 

193:15 222:6 

liked 350:4 421:6 

LIMA 1:15 26:13,19 

312:19 314:10 327:1 

417:21 419:8 

limit 4:21 119:12 135:4 

139:9 148:15,20 

354:2 369:9 

limitation 221:16 237:8 

384:22 

limitations 88:17 146:7 

237:12 238:3 

limited 5:1 60:14 73:10 

73:20 86:15 133:18 

136:18 137:13 154:18 

154:19 163:15 249:9 

269:18 276:9 323:13 

337:17,19 356:9 

410:17 414:18 415:10 

limiting 64:12 66:4 70:7 

limits 25:18 

line 25:10 41:13 85:4 

90:12 97:2 164:20 

198:11 233:9 275:16 

linen 84:11 

lines 106:16 108:3 

110:1 216:10,11 

link 30:2 122:10 233:21 

linkage 30:12 

linked 255:22 

liquid 126:22 138:11 

163:2 

Lisa 1:15 26:12 326:22 

Lisa's 327:22 336:12 

list 2:13 4:22 8:15 31:4 

58:16 92:3,5,18 95:8 

97:10,12,18 100:14 

100:20,22 102:2 

127:1 162:16 163:14 

163:18,19 165:22 

170:21 171:7 178:18 

182:18,22 184:4 

185:14,21 186:5 

201:13 202:12 207:5 

211:4,10 213:5,19 

216:19,21 222:13 

231:16 233:12,13,16 

236:8,21 240:16 

241:1 245:5,8,11,17 

246:2,8,9,17 247:1 

261:8,22 263:2 264:1 

267:20 268:18,18 

269:3 274:8 279:16 

300:9 304:22 305:4 

306:18 313:10,12 

320:14 343:13,17 

357:2 358:21 359:19 

362:7 374:22 375:12 

402:3 420:12,15 

427:4,6,13 428:16,17 

430:11 431:19,20 

440:7 

listed 31:19 64:22 

163:22 165:20 169:2 

236:12 263:4 373:14 

378:4 

listen 4:16 

listening 302:18 319:8 

348:19 351:7 372:17 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
473 

listera 72:4 

listing 91:2 159:9,10 

160:8 184:10,14 

211:3,8 218:7 272:12 

273:22 435:21 439:8 

442:5 

listings 438:19 

literally 232:11 

literature 218:22 

301:19 

little 13:18 14:10 16:1 

20:22 40:8 41:5 50:11 

66:11,12 78:1 81:3 

125:7,20 129:8 

146:12 148:3 149:1 

152:8 175:16 187:1 

189:5 218:4 228:14 

234:10,20 240:9,19 

241:4 251:7 258:12 

266:12 269:12 276:4 

279:16,17 282:5 

284:22 289:12 298:21 

307:22 319:14 327:3 

331:16 340:22 359:4 

360:2 364:18 377:17 

391:4 401:11 402:17 

411:8 431:9 439:9 

441:22 446:18 

live 18:22 42:6 47:10 

176:1 183:5,7 285:19 

286:5 413:9 

livelihood 178:12 

livelihoods 259:13 

lives 61:20 429:14 

livestock 3:10,14,16 

4:10 17:16 35:1 36:1 

36:5,11,11,19 37:13 

38:15,22 47:16 49:3 

51:10,16 63:22 

104:20 105:3,19 

108:14 109:21 110:3 

110:9 127:4 129:11 

163:21 176:15,17 

177:1 178:3 183:13 

200:12 203:3 205:8 

207:1,9,15 208:10 

227:6,13 233:21 

245:20 253:8 274:16 

275:5,5 277:15,17,22 

298:5,6 305:8 314:21 

319:13 338:2 353:19 

375:3 388:4 400:20 

406:1 409:22 411:13 

419:20 428:10 434:4 

437:12 444:12,17 

living 136:13 

load 69:2 234:9 396:21 

loads 346:8 382:16 

local 51:13 77:20 83:15 

142:21 146:5 151:3 

418:16 

located 54:2 283:9 

locked 49:19 

lofty 277:8 

logical 8:16 387:22 

long 35:3 40:6 50:2 

79:20 88:13,14 91:15 

98:17 105:10 118:9 

131:22 145:3 147:15 

176:5 178:6,7 183:8 

185:6 194:3 223:8 

224:11 226:6 251:12 

265:11 341:11 348:8 

375:12 381:15 387:6 

448:3 

long-term 174:21 

longer 11:1 41:5 49:5 

120:14 177:7 302:2 

look 9:11 13:20 19:12 

22:18 23:5 27:8 43:8 

49:20 65:8,19 69:15 

78:1 81:3 131:18 

136:11 144:8 146:6 

148:7 151:12 155:9 

166:11 172:13 191:10 

210:9 242:15 248:11 

249:19 254:3 256:6 

265:21 274:15 283:10 

284:19 297:22 298:1 

302:16 303:1 306:9 

307:18 308:17,18 

317:15 319:14 320:2 

321:18 322:13 337:20 

339:20 343:5 349:15 

352:5 358:13 363:6 

365:12 366:16 371:15 

373:20 380:18 384:3 

387:2 389:1 410:22 

427:12 

looked 27:13 46:10 

77:5 242:15 256:8 

261:21 266:11 365:16 

375:7 395:15 447:19 

looking 20:21,22 39:19 

45:21 66:8 67:15,18 

77:2 79:21 82:10 

102:9 138:3 142:18 

143:17 160:5 175:4 

196:6 202:14 242:14 

254:12 255:8 283:3 

286:19 298:15 301:11 

302:11 320:4,19 

328:1,3 333:5 337:18 

350:15 351:8 362:6 

363:15 367:6 373:13 

373:15,18,20 394:15 

396:13 397:17 401:20 

426:5,6,19 427:13 

428:1 440:22 

looks 231:19 281:15 

310:8 359:1,2 

loophole 37:12 52:9 

94:8 

loppers 240:8 

lose 52:11,12 242:8 

348:4 360:4 447:3 

losing 49:6 52:8 391:15 

loss 52:1 56:1 65:3 

340:20 344:16 

lost 52:10,13 241:17 

375:8 388:20 

lots 26:22 259:17 

348:17 384:20 423:20 

loudly 124:14 

love 13:7 16:4 38:1 

48:14 49:18,21 74:10 

321:6 419:13 431:3 

low 18:19 19:4 20:7 

24:19 87:7 135:6 

lower 79:16 135:1 

148:4 295:16,17,20 

295:21 296:4 346:3 

347:18,21 

lowering 28:1 78:5,5 

Lubbock 58:10 62:1 

lucky 248:21 

lumped 266:16 374:5 

lunch 223:7 226:6 

228:10,21 230:16,20 

232:3 

lurking 444:10 

lying 355:11 

lyocell 79:10 81:8,19 

M

ma'am 71:3 

machine 198:12 

machines 198:18,21 

Madam 223:11 232:6 

297:8 300:5 

Madison 1:9 298:6 

magazine 172:21 175:7 

195:2 

magically 167:20 

magnesium 435:12 

main 79:7 308:20 

396:22 410:10 412:12 

Maine 133:5 135:7 

140:6 144:8 148:10 

148:12,13,18,18,22 

150:6 151:14 152:11 

330:7 334:19 

mainland 409:12 

maintain 108:6 173:15 

220:7 442:18 

maintaining 102:19 

192:11 323:3 

maintains 26:3 173:21 

maize 349:16 

major 58:19 67:21 68:2 

187:2 214:21 268:3 

403:15 

majority 52:3 58:12 

118:2 144:1,3 201:22 

259:22 288:1 445:19 

maker 85:16 425:11 

making 67:5 83:12 

85:18 121:20 147:2 

169:10 196:19 201:7 

209:15 217:13 224:20 

258:12 259:7 268:17 

368:19 

male 187:16 230:22 

231:8 316:15 407:15 

male's 187:8 

malic 261:13,14 

mammal 317:6 

man 186:15 239:22 

manage 19:10 29:6 

74:1 174:8 392:21 

397:7 404:21 

managed 36:14 51:11 

68:10 69:4 121:5 

225:16 334:20 335:6 

446:17 

management 55:12 

68:11,16 193:14 

240:3,15 445:14 

manager 2:13 7:16 

23:18 106:6 200:8 

300:21 393:11 

managers 403:8 

managing 30:2 334:16 

mandate 352:22 

mandated 32:2 354:19 

423:16 424:13 

mandatory 8:6 270:13 

manipulation 317:14 

manner 81:9 133:1 

134:21 139:16 153:22 

206:5 271:8 

manufacture 133:13 

185:19 235:17 

manufacturer 115:8 

156:3 160:18 222:14 

423:6,7 424:17 432:2 

manufacturers 12:5 

262:9 358:19 423:2 

430:10 431:11 

manufacturing 8:4 

27:17 218:9,10 

235:15 245:19 430:11 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
474 

443:10 

manure 191:22 197:13 

manures 129:17 

map 321:3 

maple 204:2,3 

mapped 397:14 

mapping 145:19 

Marie 47:6 50:14,17,21 

53:18 

marine 3:6 7:7 21:2 

25:22 26:19 27:3 

33:19 35:8 42:11 

132:14,18,21 133:2 

133:12 139:22 140:11 

162:3,8,11,17 163:15 

163:22 164:4 165:15 

166:1 257:8 270:12 

320:8 324:3 326:11 

328:20 

Marisol 50:16 53:19 

54:1 58:4 

market 65:17 67:22 

83:10 86:13 87:15 

89:13 91:18 105:15 

112:22 166:20 167:4 

190:5 225:3 230:4 

246:20 286:7,8 292:5 

297:17 410:9 412:3,4 

425:13 

marketable 154:10 

marketer 300:22 

marketing 58:10 118:6 

119:12 291:4 

marketplace 30:19 

52:16 230:7 338:3 

344:20 347:16 410:8 

markets 348:4 

Marshall 230:18 235:10 

239:18,21 

Mary 175:14 183:16,21 

Maryland 427:20 

Masanobu 270:4 

mass 87:20,21 89:10,14 

269:22 

masse 430:1 

massive 32:16 269:8 

match 148:8 

mate 188:21 

material 8:18 12:6 14:5 

23:4,8 27:12 56:1 

84:7 87:5 90:7 97:12 

109:21 110:7 126:19 

127:15 130:7 131:19 

136:20 138:17 139:4 

143:7 157:11 164:16 

166:5,10 206:9,18 

217:7 218:17 220:21 

221:6 223:2 238:15 

245:13 261:14 265:7 

265:14,15 272:12 

290:7 293:19 317:16 

319:18 322:21 323:21 

324:3 370:9 401:18 

402:19 405:3 406:5 

410:8 433:20 437:8 

438:13 440:9 444:22 

445:5 447:3 

mates 187:17 

math 341:7 

Mathews 2:13 175:17 

176:9,9 178:14,22 

179:5,12,16 180:1 

181:5 183:4,7,15 

305:17 

mating 188:1,3,7,11 

matrix 145:14 349:21 

370:2 

matter 81:12,13 85:3 

125:8 172:13 173:15 

174:9 180:2 231:10 

269:4 336:21 376:10 

387:17 448:21 

maturity 422:2 

maximize 40:9 

maximum 118:17 

Mays 239:19 244:7,8,9 

244:12,12 247:6 

McDougall 239:22 

242:5 

McEvoy 244:7 247:7,9 

247:9,18 250:13,16 

251:1 252:2,12 

253:22 255:7 257:2 

258:17,22 260:1,4,16 

300:7 

meal 25:20 26:2 66:16 

66:18 71:8,19 93:9 

286:15,16 

mealybug 193:2 

mean 14:13 15:3 18:13 

19:10,18 21:11,17 

39:7,15 41:2 78:21 

79:18 80:10,14 90:5,5 

90:8 102:12 121:14 

136:19 139:13 141:13 

141:20 144:1,21 

151:6 157:3 160:14 

168:13 174:16 180:9 

190:4,15 206:11 

238:9 239:7,9 242:21 

243:4,8 244:1 251:10 

253:16 260:2 266:9 

266:12 274:22 275:14 

275:16 279:1,5 

285:19 287:13 298:19 

308:15 329:1,1 332:1 

333:18 353:4 366:5 

370:11 371:22 381:20 

390:6 397:3 400:10 

400:11 408:14 409:4 

412:6 413:2,5 414:9 

416:3 430:13 432:17 

433:3 436:7 439:22 

441:8,14 444:10,15 

meaning 174:16 400:12 

427:4 

meaningfully 107:19 

meaningless 116:3 

means 39:17 64:14 

113:9 137:13 165:18 

204:16 278:14 323:9 

323:12 332:19 386:17 

meant 357:10 367:3,4 

385:22 

Measure 235:16,18 

237:20,21 

measures 67:2,3 

115:20 

measuring 323:9 334:7 

meat 17:17 23:22 24:2 

24:3 71:8,9,11,18 

434:8 

mechanical 59:7,21 

137:13 138:19 139:12 

139:14 198:13 

mechanically 137:17 

mechanism 43:2 

mechanized 198:11 

media 172:16 173:1 

174:5 

medical 218:13,14 

266:7 434:5,19 

medicine 63:17 172:9 

medium 290:6 

medium- 154:4 

medium-sized 182:13 

meet 47:22 49:5 86:14 

87:8,21 136:16,21 

144:16 183:9 211:7 

211:12 213:3 257:18 

281:7 290:15 317:11 

324:12 345:4 354:22 

356:1,7 414:16 

meeting 1:5 4:5,19 5:2 

5:4 22:6,8 32:15,16 

33:11 34:5 40:1 44:2 

44:14 48:16 55:19 

58:20 64:4 75:9 98:16 

112:6 128:17 145:6 

153:14 156:2,11 

163:14 181:2 201:19 

216:18,22 233:3 

243:19,19 281:3 

283:5 287:3 289:16 

304:18,20 320:10 

322:19 324:12 328:7 

334:1 339:15 348:18 

363:3,7 364:22 378:1 

391:22 400:9 433:14 

meetings 21:3 47:17 

100:6 247:14 

meets 26:16 161:12 

216:6 262:13 

Megan 96:18 102:15,16 

106:3 176:12 

member 29:12,14 34:6 

43:1 87:2 94:16 

402:22 

members 5:10,12,13 

6:16 7:22 8:13 10:5,7 

32:14 33:12 35:1 

37:16 42:16 52:6 

58:11 91:20 96:6,10 

102:5 105:17 110:19 

126:8 212:12 223:11 

223:21 231:20 232:6 

255:11 268:8,11,21 

297:9,9 298:8 302:4,6 

313:11 319:1 324:14 

338:20 368:14 387:20 

membership 35:20 

37:9 43:5 44:3 91:16 

223:19 281:4 

memorandum 383:19 

memory 328:17 

Mendenhall 176:11 

Mensonides 171:20 

175:14,20,22 

mental 69:13 

mention 104:20 409:5 

mentioned 11:5 79:9 

92:3 113:8 130:22 

137:9 145:18 164:8 

249:21 300:14 322:3 

334:1 351:12 378:19 

396:6 405:13,15 

409:15 420:7 435:11 

442:18 

mentioning 73:8 

mentor 270:15 413:5 

merchandiser 115:8 

Merck 232:16 233:10 

233:10 234:11 

merely 87:19 

merit 250:21 

meritorious 438:14 

message 38:15 181:1 

messages 97:3 

messed 62:11 

met 1:8 128:19 256:17 

289:17 290:9 359:8 

meter 70:19 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
475 

Methiomax 27:13 28:8 

72:17 73:12,12,22 

74:5 303:2 442:20 

445:9 

methionine 27:15 28:1 

28:2,10 63:3 64:6,9 

64:17,21 65:16,21 

66:17,18 67:12 68:17 

70:6,8 71:7,12 72:11 

74:22 75:5 301:4,12 

302:5 441:22 442:6,7 

442:9,11,14,17 

443:14,17 445:13 

447:16 

method 3:15 206:3 

307:5,7,9 308:22 

309:6,17 311:9 

315:11,20 316:5 

317:7,11,17 319:16 

323:11 419:20 420:11 

422:1 424:14 425:5 

427:3 

method's 317:18 

methods 3:4,5 34:14,20 

35:6 61:15 116:20 

163:4 178:20 183:3 

201:9 207:4,9,12,20 

209:4,17 272:9 284:3 

306:14,19 310:22 

313:6 315:5,8,11 

420:14,17,20 421:15 

421:20 422:16 423:9 

423:18,22 424:5,18 

425:6,17 427:10 

metric 127:7 411:4 

Metro 63:9 

Mexican 273:17 

Mexico 268:5 272:22 

mic 59:17 125:20 

Michael 7:11 23:14,14 

23:17 

Michelle 2:7 5:19,20 

6:14 7:6 95:22 109:19 

268:15 300:6 306:22 

Michigan 62:20 63:7 

408:8 

microbial 18:17 236:18 

microbiome 173:20 

microbioscience 172:8 

microgreen 154:3 

microphone 244:11 

microscope 77:3,15 

mid-summer 160:14 

middle 380:11 422:21 

429:5,12 

midnight 167:21 

Midwest 301:13 340:15 

342:2 402:9 

Midwestern 62:21 

migrant 297:14 

Mike 7:10,11,13,15 

10:20 20:9 23:12,13 

23:13,14,14 

mildew 55:6 192:5,5,8 

193:10,14,21 195:18 

199:8,11 242:2 

mile 408:4 

miles 112:8,10 114:10 

114:10 244:7 247:7,9 

247:18 250:12 253:12 

260:15 300:7 407:12 

407:12,20 409:4 

milk 25:5,7,8 26:15 

36:12 50:10 179:9 

229:1,13,16 263:13 

434:10 

mill 166:18 341:5 

millers 115:5,7 120:9 

milligrams 212:8 

million 24:7,7 25:6,7,8 

54:18 69:4 104:9 

112:16,18 127:7 

229:1 257:10,12 

292:11,11 295:18,19 

302:7,7 447:11 

mills 78:3 

mind 61:3 123:5 249:8 

276:2 284:12 363:13 

411:14 448:17 

minded 73:21 

minds 10:12 

mine 73:13 163:2 

169:15 180:5 

minerals 163:2 184:3,7 

184:8,11,19,20 185:1 

236:5,10 261:5 262:7 

262:17 266:14 

minimizing 201:8 

minimum 118:15 157:1 

mining 138:8 

Minneapolis 181:2 

minor 116:21 167:4 

202:6 269:20 

minute 6:3 312:5 

448:16 

minutes 5:19 6:2,8,15 

44:7 111:9 114:14 

125:6 267:21 321:4 

376:7,9 

Mirenda 28:22 32:9,10 

32:11 37:4 38:1 39:19 

41:22 42:22 45:8,18 

176:13 

misleading 93:15 

misread 353:7 

missed 300:12 

missing 45:19 

mission 32:14 91:18 

Missouri 121:5 194:19 

195:13 427:21 

misspeak 28:12 

misters 57:9 189:17 

misunderstood 289:18 

misused 435:8 

mites 55:13 403:9 

404:12 410:10 412:22 

413:11,13 

mitigate 214:12 220:22 

221:8 

mitigation 334:2 

mix 292:16 

mixed 296:20 

mixes 164:13 

mixing 292:19 

mixture 296:18 

mobile 414:13 

mode 9:15 10:21 

357:11,13,16 369:17 

374:21,22 404:16 

model 100:13,17 102:7 

139:7 142:3,20 

143:11 237:3 254:13 

255:8,20 256:3,8 

258:13,14,16,20 

259:1,10 

models 252:14 259:19 

modern 70:10 

modes 13:9 46:11 

220:5 

modification 351:3 

modified 79:9 81:8 

93:22 209:17 421:19 

431:7 

moisture 194:8 

molecule 437:19 

molluscicide 211:4 

moment 138:18 231:14 

305:10 432:4 

monetary 344:16 

money 47:19,21 142:2 

257:14 368:3 448:1 

monitor 146:18 162:6 

monocytogenes 72:4 

monograph 96:7 

Montana 113:17 

Montgomery 172:5 

month 44:20,20 49:4,6 

213:21 

months 45:6 49:12 

79:13 82:12 89:16 

291:18 305:20 413:4 

Moore 205:19 210:17 

210:20,21 213:6,11 

morning 4:4 7:14 26:11 

32:10 38:12 50:17 

53:21 62:18 85:14 

88:1 96:20 106:5 

109:10 111:10 115:4 

132:11 144:15 166:15 

191:1 200:6 234:6 

334:12 390:19 448:9 

morphed 177:18 

mortar 298:21 

MORTENSEN 1:16 

44:11 68:7 69:21 

122:1,5 180:5 210:5 

309:22 311:2,4 

312:12 314:3 324:22 

334:10 348:15 372:9 

390:14 405:6 417:14 

419:1 436:6 

MOSA 106:6 108:8 

200:8,13,14 201:10 

201:17 202:9 203:4,9 

282:20 

moth 55:14,20 187:11 

187:16 188:4 241:8 

241:14 

mother 318:3 

moths 188:21 189:21 

motion 308:13 310:15 

310:16 311:6,7,13 

312:6 313:5,6 416:10 

416:11 417:6 418:14 

418:19,19 419:18 

432:13 

motions 417:2 

MOU 385:20 386:10 

388:17 

MOUs 388:14 

mouth 337:10 

move 4:7 29:18 31:11 

34:18 35:7 39:3 41:14 

43:18 61:4 75:14 

97:13 101:22 108:10 

108:13 126:6 142:19 

152:21 168:3 181:13 

203:2 250:5 252:10 

255:5 260:14 267:20 

271:13 279:15 310:10 

311:8 313:19 320:7 

321:16 327:2 339:6 

343:4,6,15 345:16,20 

353:9,14 361:4 400:4 

401:6,8,13 408:20 

414:8,12,14,16 415:6 

416:8 430:5 432:3 

433:11 438:17 441:21 

moved 38:5 51:6 

147:19,21 228:5 

308:21,22 334:17 

341:22 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
476 

movement 223:19 

269:10 271:18 

movements 270:11 

moves 30:19 104:2 

106:12 414:8 

moving 8:21 38:19 

78:20 178:6 185:9 

249:11 273:18 304:20 

309:4 360:20 364:2 

409:16 410:1 437:7 

mowing 152:1 

MPE 228:4 

MPEs 179:3,10 228:6,6 

228:9,15 439:8,19,21 

439:22 440:6,14 

MSC 26:16,17 27:1 

muddied 53:5 

mulch 164:9 206:20 

multi-track 177:19 

multiple 20:18 56:7 

136:8 149:13 163:9 

204:22 220:5 272:19 

310:2 360:12,17 

386:3 414:9 

mundane 367:19 

369:21 

municipal 13:14 

muscle-building 73:3 

mushroom 280:6,13 

mushrooms 258:5 

280:6 

mutagenesis 3:6 

314:20 315:5,8 

mute 5:13 

myriad 275:15 

N

N 236:2 

nail 329:8 422:17 

naive 170:4 

name 5:5 7:12,13,15 

23:15 29:1,2 31:4,6 

47:7,9 50:15 54:1 

62:19 76:3 85:12,14 

91:12 96:21 109:11 

111:11 122:11 125:17 

126:9 132:11 161:22 

164:11 166:15 172:1 

175:9,22 183:17,21 

200:6 203:18 205:20 

213:14 232:10 235:13 

239:21 245:18 267:22 

280:20 291:3 300:20 

340:4 355:14 379:12 

428:17,18 

named 269:10 

names 73:16 

nanomaterial 220:11 

220:22 221:2 

nanomaterials 220:15 

220:15 221:2 

nanotechnology 214:1 

222:20 

narrow 34:12,13 327:3 

421:13 

narrowing 316:4 327:8 

NASS 122:2 124:10 

nasty 436:7 

Nate 109:9 111:7,11 

114:20 

Nathan 230:17 235:9,13 

nation's 112:17 

national 1:3 2:8,10,12 

2:13,14,17 8:15 48:20 

54:13,17 58:16 92:3 

92:13,18 95:8 97:10 

97:12,18 100:14,20 

100:22 102:2 162:16 

176:10 182:21 184:3 

185:21 186:5 201:13 

202:12 207:5 211:4 

213:4,19 216:19,21 

222:13 223:10,13 

232:12 233:12,13 

236:8 245:5,11 246:8 

246:17 247:1,19 

248:7,18 249:2,15 

252:19 261:8,22 

264:1 269:3 303:7 

304:22 305:4,16 

357:2 358:21 374:22 

402:3 420:12,15 

427:4,6,13 428:17 

native 51:12 136:14 

192:5 195:17 336:4 

natural 61:11 70:6 

84:11 92:19 100:19 

107:16 113:7 136:15 

136:20 156:5 157:19 

158:22 163:5 167:12 

167:15 168:3 170:2 

170:22 192:3 309:16 

320:5 331:7 411:20 

435:12 443:9 

naturally 236:11 310:3 

naturals 136:19 

nature 136:12 172:4 

236:11,17 

navigate 108:15 

Navigating 106:16 

navigators 107:9 

near 318:22 408:10 

nearly 127:5,6 

necessarily 21:12 

31:18 133:11 139:13 

254:5 258:6 344:13 

441:13 444:19 

necessary 56:19 66:4 

103:14 157:13 170:5 

193:4 197:19 200:21 

289:15 364:9 

necessitate 105:7 

441:14 

necessity 243:3 244:21 

neck 340:14 

nectar 192:21 407:7,22 

needed 30:18 47:2 

108:13 156:20 157:2 

158:9 174:18 183:9 

202:2,6 207:12,15,17 

241:8 316:22 354:18 

355:17 374:9,10,11 

375:15 384:10 404:16 

407:9 421:7 436:3 

441:2,17 443:22 

needing 57:20 378:13 

needle 168:2 379:21 

needs 33:15 98:9 100:2 

100:3 127:10 233:13 

254:1 262:14 264:13 

275:6 288:13,17 

292:18 319:10 329:11 

337:4 354:3 364:19 

414:17 416:7 

neem 443:1 

negate 15:22 

negative 64:20 133:2 

215:10 221:13 343:3 

355:20 

negatively 208:11 

317:3 

neighbor's 436:15 

neighborhood 191:11 

195:9 198:22 316:11 

neither 38:6 382:10 

nematode 233:22 

neonics 360:15 

netting 288:18,21 

Neudorff 211:2 212:15 

212:16 213:6 

never 20:15 188:9 

227:20,21 299:19 

372:10 398:11 404:22 

445:8 

new 9:6,14,18,22 10:4 

13:16 14:1 41:4 45:17 

45:21 46:3 53:8 84:21 

84:22 104:5 105:4,7 

106:8,13,14,19 114:2 

133:6,9 138:22 

139:12 142:12 146:7 

147:11,21 155:16 

156:4 159:8 161:6 

172:7 176:1 177:9 

201:22 202:17 211:13 

211:21 224:10 225:18 

227:19,20 245:2,4 

248:13 286:16 335:7 

341:8 358:20 362:4 

362:12 369:11 370:8 

372:22 373:5,7 384:8 

387:21 438:13 445:10 

newcomer 180:15 

newspaper 77:19,20 

82:18,20 157:7 159:6 

164:14 

newspapers 78:4 82:20 

83:8,9 84:2 

NHC 54:4,8 56:3 57:3 

nice 284:9 

nicely 47:13 

night 37:20 47:22 

nightshade 434:14 

nine 25:8 229:1 445:22 

nitrate 24:20 99:12 

165:4 237:14 

nitrates 288:8 

nitrogen 126:15 127:13 

129:9 237:15 268:2 

288:8 

no's 314:14 

no-rinse 294:5 

NOC 348:18 353:5 

415:19 

nodding 359:12 363:5 

nodosum 134:18 

135:21 

NoMate 241:2 

nomenclature 379:19 

non- 38:5 57:16 84:17 

92:5,10 126:16 

163:12 169:1 215:2 

263:7 265:20 296:7 

342:11 421:22 424:20 

non-active 22:22 

non-agricultural

185:22 246:18 

non-agriculture 254:7 

non-certified 271:11 

non-corrosive 292:3 

non-excluded 424:14 

non-genetically 421:19 

non-glossy 82:20 83:1 

non-GMO 61:12 200:18 

421:9 

non-livestock 444:9 

non-organic 36:14 

97:15 171:12 214:22 

216:10 262:12 286:6 

344:1,5,14 

non-retail 30:20 

non-soluble 236:17 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
477 

non-synthetic 126:22 

127:14,19 129:15 

185:22 262:4 

non-technical 219:9 

non-use 287:12 

nonylphenol 440:2,3 

NOP 31:13,15 38:10 

39:11 44:12 46:18 

47:18,20 51:18 53:1 

99:5 103:14 104:1,2,9 

104:13,17 105:2 

106:21 107:20 116:13 

117:17 120:2,6 126:8 

128:19 132:16 153:14 

155:11 162:10 167:14 

169:10,18 172:11 

173:7,13 174:13,20 

185:8 201:19 224:21 

226:10 245:16 248:12 

249:8 254:6 260:22 

268:11,22 270:8 

275:3,19 280:4 297:9 

298:8 299:10 303:6 

322:10 333:5 347:2 

357:6 358:6 368:15 

371:17 377:11 378:6 

378:8,20,21,22 

381:15 384:14,16 

385:3 394:9 402:2 

403:2,5,11 408:19,22 

409:6 413:19 416:5 

441:10 

NOP's 32:2 103:18 

106:22 163:7 208:14 

220:14 257:11 261:8 

388:10 

NOP-compliant 167:12 

168:12 211:9 

NOPs 31:12 

normal 64:15 437:22 

norms 225:10 

north 47:11 223:14,20 

224:5 402:12 

Northeast 203:21 

326:15 

Northern 326:12 

Northwest 54:2,3,14 

231:3 291:10,13,21 

342:2 448:11 

Northwest-based

291:11 

Norway 135:8 

NOSB 2:7 4:5,15 5:2 

7:19 8:12 10:7 21:6 

31:8 32:1,15 42:2,20 

45:14 51:7 52:22 53:9 

56:3 95:7 100:6 

103:22 105:17 107:20 

108:1 110:10 126:7 

127:17 128:15 132:15 

153:18 155:9 166:17 

167:1 169:9,18 

171:19 176:16 186:1 

201:6 202:13,20 

205:2 206:1,4,8,17 

223:11 224:21 225:19 

232:15 244:19 245:22 

246:1,22 250:2,21 

251:7 261:7 270:8 

276:8,19 278:20 

280:18 297:9 298:8 

304:20 305:5,13 

313:11 347:2 354:3,5 

355:15 365:1,7 

406:21 407:4 409:2 

412:14 438:12 

NOSB's 29:18 33:16 

NOSBs 354:5 374:10 

note 7:21 33:18 61:13 

90:1 93:6 233:17 

246:6,15 254:21 

359:8 360:2 402:16 

439:6 

noted 94:1 97:7 264:16 

266:4,5 365:2 366:20 

401:13 421:18 

notes 212:3 308:21 

309:5 311:8 379:8 

400:22 

notice 149:17 172:17 

414:11,12 

noticed 203:10 438:5 

noticing 298:17 300:13 

notification 385:1 

notifications 385:12 

noting 172:22 228:22 

353:12 

Nova 132:15 135:12 

137:10,12 138:17,21 

139:8 142:12 144:10 

146:12,14 147:12,12 

148:3,9 149:20 

150:21 152:10 

novice 444:15 

nucleic 307:4,7,10 

309:4 311:1 

nucleus 317:13 

number 37:15 54:9 56:8 

78:5 98:7 99:8 100:1 

100:2,5 120:5 121:21 

123:21 137:15 146:21 

148:10 151:13 152:19 

163:15 194:1 204:7 

205:2 232:11 236:1 

241:21 242:21 251:21 

264:16 281:16 282:11 

325:1,6,7 333:18 

347:4 401:2,4 430:22 

431:4,4,9 

numbers 123:11 333:16 

numerous 345:6 355:3 

357:12,16 378:5 

410:5 420:3 

nutrient 53:5 107:15 

173:20 184:2,7,10 

261:5 262:6,17 

263:13,17 264:13 

266:13 

nutrients 25:11 185:14 

236:6 263:2,4 264:2 

283:6 336:3 

nutrition 72:14 263:20 

266:5 

nutritional 262:14 

263:7 

nutritionally 70:21 

262:11 

nutritious 51:14 

O

O 346:14 351:12 

Oakland 284:14 

Oakley 1:17 20:11 

23:10 42:10 82:16 

83:17 110:22 128:12 

136:4 139:17,20 

140:8 141:4,7 149:4 

150:19 159:3,22 

160:4 165:10,13 

197:16 217:5 254:17 

276:7 277:13 289:12 

289:20 304:2,5 306:5 

306:6 309:13,15,20 

310:7,16,20 311:7,15 

311:18,22 312:16 

313:4,15,18 314:7,17 

318:18,21 319:21 

320:4 326:22 327:14 

328:14 331:4 333:9 

334:9 335:10 336:10 

338:16 339:9 348:11 

351:10 353:12,17 

359:7,14 361:7,10 

362:9 363:6 365:10 

367:7 368:12 369:19 

370:16,22 371:13 

372:4 373:11,22 

375:14 390:6 395:8 

406:9 412:10 417:18 

418:8 419:5 433:5 

437:2 440:22 441:5 

441:12 445:2 

objection 406:5 

objectives 289:15 

290:4,5,9,16 

objectivity 116:16 

obligation 137:5 

observation 180:6 

369:2 407:15,16 

415:1 

observations 281:1 

observed 215:15 

obsolete 193:12 

obtain 220:7 403:11 

obtaining 46:3 126:18 

obviously 36:21 90:6 

102:10 137:21 238:7 

238:9 271:14 275:11 

278:9 306:7 323:8 

333:13 395:11 444:2 

occur 249:4 341:11 

381:17 

occurred 148:21 

occurring 135:14 

236:11 316:7 346:2 

occurs 434:18 

ocean 140:5 332:14 

333:13 

oceanfront 334:14 

oceans 92:19 142:15 

147:17 268:4 

October 438:11,12 

odd 436:11 

oddly 406:9 

odds 18:16 99:18 

odorless 216:4 296:7 

OFARM 379:3 

off-gas 216:4 

off-gassing 215:22 

Off-microphone 50:19 

120:11 121:2 166:12 

328:10 432:10 

offer 115:9 156:12 

170:18 206:15 401:9 

offered 212:3 379:2 

offers 224:18 

Office 131:12 305:2 

offices 245:18 

Official 2:18 

officially 380:16 

OFPA 9:4,8,9,13,18 

10:3,10,16 11:14 

45:22 46:18 162:14 

162:18 163:5,10 

173:7,10 174:13 

245:16 251:2 299:7 

299:16 327:7 354:10 

356:1 359:22 360:6 

oftentimes 95:16 

OGC 7:22 29:11 

OID 31:13,15 32:3 

118:1 393:20,21 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
478 

394:10,15 411:14 

oil 25:3,5,9,20 26:2,6,9 

26:14,21 91:16 92:1,3 

92:5,11,12,18 93:7,8 

93:11,12,20,21 94:16 

94:19 95:8,10 96:6 

193:22 228:20,22 

230:10 241:18,21 

oil-based 81:12 85:2 

oils 25:16 54:12 55:11 

93:2 242:22 

old 181:16 373:6 

413:10 

OLPP 52:1 

Olympic 70:12,13,22 

omega-3 25:5,12,15 

92:22 

omega-3s 91:14,16 

OMNI 211:10 

omnivores 71:10,16 

omnivorous 71:15 

OMRI 162:6 163:14,22 

164:12,14 431:17 

OMRI-approved 110:5 

once 6:15 132:18 

146:20 177:11,12 

184:5 228:20 292:9 

346:14 384:6 386:20 

386:22 387:1,7 400:1 

413:3 

one's 418:13 

one-size-fits-all 69:18 

ones 79:9 171:17 

198:13 199:17 356:7 

370:9 423:17 431:21 

431:22 

ongoing 33:20 99:10 

132:16 145:7 305:12 

383:8 

online 73:15 

oops 68:5 141:21 

open 10:11 34:4 42:13 

42:21 43:21 48:2 

67:19 78:14 110:14 

111:2 298:2 309:8 

320:18 321:5,12 

324:20 359:10 363:2 

396:15,20 404:3 

405:4 416:10 443:15 

443:22 

open- 73:20 

opened 292:9 

opening 403:22 404:5 

422:10 423:14 

opens 169:14 

opera 306:17 

operate 43:3 

operating 15:9 42:4 

251:22 

operation 11:21 12:12 

12:14 15:10,18 30:3,9 

36:13,14 38:4,6 

118:15 130:4,5 175:3 

177:22 199:4 210:10 

285:17 381:8,9 

436:10 

operations 8:9 29:7,19 

30:6 36:20 67:4 68:15 

69:18 106:6 110:1 

116:1 117:13 127:5 

142:9 152:14 155:4 

184:6 185:17 191:13 

200:9,12 201:18 

207:11,14 227:1 

235:14 245:19,20 

269:18 283:8 393:15 

411:16,18 

operator 275:13 

operators 33:3 109:17 

110:4 269:7 411:8 

opinion 16:18 60:10 

89:8 141:1 228:3 

241:16 325:13 349:3 

427:17 

opinions 281:4 

opportunistic 71:16 

opportunities 119:13 

169:14 225:4 392:15 

394:3 395:3 

opportunity 23:19 33:8 

41:10 53:22 64:2 65:9 

71:15 85:19 88:21 

105:22 115:6 132:17 

156:14 166:17 204:5 

206:2 208:16 210:21 

213:16 217:12 223:12 

238:4 239:21 242:11 

260:10 267:15 280:2 

284:18 395:1 399:8 

433:12 436:21 

oppose 127:1 

opposed 133:11 204:15 

296:8 435:22 

opposite 296:12 

opposition 151:15 

212:18 

option 43:13 46:6 52:17 

160:16 165:15 178:18 

184:16 185:5,7 

335:18 421:2,3,3,5 

422:21 423:11,12 

428:15,15,16,19,22 

429:4 430:5 

optional 214:9 263:18 

options 13:8 34:10,11 

43:14 71:17 87:8 

237:11 254:13 262:11 

323:3 358:2 362:1 

420:3 425:2 

OPWC 7:22,22 

OPWC's 31:10 

or/and 185:2 

oral 54:11 

orchard 56:18 188:2,21 

240:4 

orchards 55:4 196:12 

196:16 

order 10:2 113:12 

156:11 162:18 215:12 

230:19 367:17 417:1 

434:7 442:17 

Oregon 14:15 54:5 

379:4 

organic's 166:9 

organic- 185:3 

organic-sourced 87:13 

organically 7:16 29:4 

36:16 63:4 92:6,11 

225:16 230:1 241:4 

404:21 

organics 140:6 190:12 

223:15 257:17 276:12 

280:22 286:9 292:7 

332:14 

organism 69:11 136:13 

organisms 220:3,6 

237:6 270:12 

Organization 25:15 

91:13 218:13 

organizations 140:15 

141:10 251:22 261:14 

organized 370:4 

organizing 386:13 

organophosphate

434:17 

organophosphates

360:16 436:7 

origin 35:22 36:4,4 

37:12 38:14,22 47:15 

49:3 105:2 108:14 

176:15,17 177:1 

178:3 203:3 208:9 

227:6 253:8 277:17 

277:22 298:4 409:22 

original 317:2 340:4 

originally 63:8 170:8,10 

170:11 

originate 94:13 

originated 192:4 315:7 

originates 261:18 

originating 94:4,11 

origins 411:6 

OSP 274:20 275:7,9,13 

OTA 34:16 35:19 103:9 

169:8 379:3 

OTA's 29:10,12 105:11 

105:18 111:16 

Othello 188:3 

ought 233:7 

outbreaks 56:9 233:22 

outcome 8:16 134:16 

174:1 

outcomes 42:18 43:7 

392:2 

outdoor 445:16 

outdoors 51:10,22 

outlined 116:18 133:10 

outlining 116:11 

outlooks 10:12 

outreach 120:22 

outset 233:16 372:13 

outside 5:12 13:14,18 

16:15 49:20 62:1 63:1 

69:7,15 99:1 141:18 

163:7 188:21 275:3 

288:22 350:21 386:1 

446:2,8,13,16,20 

447:2,4 

outweigh 214:3 

over- 94:5 134:19 

over-exploited 94:12 

over-harvested 135:21 

over-harvesting 270:12 

overall 151:12 240:11 

383:21 399:22 402:4 

410:12 

overarching 322:22 

overdue 178:7 

overlap 150:5 365:15 

overlay 403:3 

oversee 402:5 

overseen 334:21 

oversight 3:12 102:21 

103:11,21 115:9 

143:18 248:12 256:2 

377:18 383:5 409:20 

overview 86:4 145:17 

321:3 356:6 

overwhelmingly 349:21 

438:7 

overwinter 187:12 

Oviedo 50:16 53:19,21 

54:1 57:14,18,22 58:5 

owned 203:21 235:14 

owner 153:7 408:11 

oxalic 3:15 268:18,19 

272:5 273:4,9,10,22 

401:1,14 403:19,21 

404:22 413:21 417:8 

417:10 418:14 

oxygen 79:16 438:4 

Oyster 111:12 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
479 

P

P 236:2 

P-R-O-C-E-E-D-I-N-G-S

4:1 

p.m 230:21 231:11,12 

376:11,12 448:22 

PAA 215:20 292:20 

295:14,18 

pace 103:15 

Pacific 54:14 291:10,11 

291:13,21 342:2 

package 30:13 

packaged 404:10,11 

packers 54:4 56:6,22 

57:3 361:17 

packet 32:16 233:18 

packing 55:7 56:16,19 

242:6 

page 32:16 38:2 45:2 

67:18 233:18 312:5,6 

pages 21:18 

pails 437:16 

pain 65:4 243:20 

painfully 178:7 

palm 54:15 

panel 42:15 99:9 100:9 

101:10 321:9 325:10 

325:15 326:1,18 

327:3,19,21 328:11 

330:19 334:21,22 

337:11,19 363:14 

374:12,13 376:19 

377:9,21 438:11 

442:10 444:14 

panels 327:16 333:11 

337:22 338:7 

paper 76:8,9,11,14 

77:16 78:3,18 80:12 

80:19 81:5,6,14 82:6 

83:11,20 85:3 116:21 

153:9,11,15,16,20 

154:4,10,13,15 155:8 

155:9,18,19 156:3,5 

156:10 157:3,8,17 

159:9,12 160:8 161:4 

161:6 162:4 164:5,6 

164:12,15 200:11 

202:9,11 206:2,4,9,12 

206:13,14,16,19 

225:17 339:16 

paper-based 155:13 

164:7 

papers 76:18 77:11 

78:10 84:21 

paperwork 213:1 

parade 169:7 

Paradisos 191:3 

paragraph 48:18 

parallels 60:18 

parameters 399:17 

paramount 92:20 

paraphrase 14:22 

parasite 69:1 234:9 

410:10 

parasites 234:1 

parasiticide 418:16 

parasiticides 234:4 

Parasiticism 233:20 

parasitoid 188:8 

pardon 348:22 

part 4:14 41:20 42:6 

50:7 55:11 84:15 92:1 

100:8 107:21 113:5 

113:17 123:14 153:21 

169:1,1 171:1 172:5 

173:11,13 187:19 

206:9 227:8 241:19 

255:16 256:6,7 258:2 

261:16 263:17 295:9 

304:19 305:11 347:6 

350:13 352:12 393:16 

403:7 427:8,9 

partially 137:14 356:11 

PARTICIPANT 230:22 

231:8 407:15 

participate 112:5 

participated 29:10,15 

participates 25:19 

particle 221:11 

particles 221:13,18,21 

222:4,21 

particular 104:8 248:8 

371:4 

particularly 123:18 

271:9,10 282:3 337:3 

352:12 394:8 404:1 

410:19 

parties 10:8 184:15 

partner 224:22 244:13 

partners 87:3 394:5 

399:20 

partnership 101:13,20 

partnerships 224:13 

parts 207:16 246:10 

255:12 292:10,11 

295:18,19 

party 8:5 337:1 392:17 

Paskind 87:2 

pass 64:16 180:18 

201:18 280:15 298:10 

298:13 406:21 

pass-down 318:1 

passed 37:11 48:16 

98:15 318:4 412:15 

413:18 

passes 314:16 419:18 

passing 105:1 169:10 

passion 106:9,17 167:3 

178:11 

passionate 186:20 

446:15 448:4 

pasteurized 445:22 

pasture 49:12 69:17 

181:19 226:22 234:9 

234:17 302:20 442:8 

442:17 445:21 446:3 

pasture-based 49:14 

pasture-raised 68:21 

pastured 445:3 

pastures 446:6 

patent 131:2,12 

patented 129:13 131:1 

131:5 

path 105:4 113:22 

226:13,20 321:22 

327:12 429:6,12 

pathogen 18:13 56:9 

214:11 215:3,7,16 

pathogens 55:6 56:15 

293:8 355:7 

paths 201:6 

patience 10:15 68:4 

patient 313:12 

Pattillo 2:14 305:18 

Paul 2:11 176:17 

186:14 190:21 191:2 

304:10 367:11 373:11 

426:2 428:8 

pause 62:15 159:17 

232:1 399:6 448:7 

pay 19:14 119:9 352:16 

pear 55:13 240:1 

242:15,16 

pears 54:5,18 55:1 

241:9,15,20 

pecking 65:2 313:10 

Pedersen 62:11 75:20 

75:21,22 76:3,6,7 

79:6 81:2 83:1 84:14 

85:10 

peer 73:17 132:3 

141:15 

peers 141:9 

Peggy 111:21 

pending 126:21 131:3,9 

penetrates 416:5 

penetrating 176:18 

Peninsula 408:8 

Penn 301:19 

people 4:21 18:4,19 

20:5 22:2 41:4,10,19 

45:12 73:15 100:15 

122:18 125:14 141:16 

141:18 151:22 152:6 

171:11 179:9 181:10 

181:15 187:3 192:9 

198:4 199:15 231:16 

239:10 247:12 259:22 

266:8 274:8 276:3 

278:20 281:17 282:8 

284:21 285:15 293:17 

302:10,12,16 323:4 

325:1 329:17,17,22 

336:6 348:16 349:12 

364:9,12,17 374:14 

383:7 391:19 406:16 

407:1 411:11,15 

412:19 413:5,6 421:4 

421:5 424:7 444:12 

445:8 

people's 321:6 

Pepper 53:19 58:7,9,9 

59:19 62:3,8 

pepperoni 24:4 

peracetic 13:5 109:22 

242:5 364:21 

perceive 38:11 

perceived 52:9 

percent 23:22 54:21 

55:15,22 61:10 68:21 

80:13 86:6 96:5,9,9 

97:15 105:14 112:14 

127:3,5 135:10,15 

137:9,15 146:11,13 

150:21 151:16,18 

188:19 195:10,13 

196:3 291:16 292:4,8 

292:10 302:2 308:11 

333:17,18,19 345:2,3 

357:1,3 411:5 412:2 

443:12 

percentage 80:19 

145:15 147:9 198:14 

percentages 82:2 

159:13 

perception 119:5 

295:13 

perfect 222:16 236:14 

360:1 

perfected 60:8 

perfectly 226:21 

performance 216:7 

performed 132:22 

performing 30:7 269:21 

period 32:17 35:12 39:8 

40:6 43:11 49:16 53:3 

77:22 90:16 200:21 

287:10,16,22 288:3 

289:14,16,17 290:2 

290:17 332:7 349:4 

421:21 424:5 434:8 

434:10 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
480 

peripherally 172:9 

permission 330:10 

permit 117:12 

permits 225:11 273:3 

permitted 167:16 

peroxide 3:18 54:12 

55:2,9 59:5 280:8 

294:21 437:8,10,12 

437:18,21 438:3,8,9 

perpetuity 91:6 

perseverance 10:16 

persistence 245:10 

persistent 219:2 

person 5:1,4 7:3,4 45:2 

73:21 75:15 120:5 

209:7,22 274:22 

300:8 324:20 346:14 

361:11 372:5 405:15 

415:17 436:10 438:5 

444:9,15 

personal 6:21 16:8 

61:19 381:21 404:19 

432:11 

personally 189:18 

360:21 404:11 

personnel 61:14 

persons 4:18 

perspective 108:8 

137:22 166:5,10 

perspectives 133:7 

pertains 173:8 

pest 55:12 210:22 

240:15 410:11 

pesticide 55:3 117:4,5 

117:8 196:20 197:9 

212:6 381:2 418:18 

438:2 

pesticides 192:1 196:2 

212:19,22 415:20 

434:18 436:16 

pests 55:14,19,21 

192:22 241:15 

pet 233:2,7 249:20 

250:8 253:9 258:4 

264:11 

petition 9:11 46:1 85:20 

86:1 88:2 97:8,11 

127:1,18 128:14 

155:7 169:9,10 184:4 

197:16 234:13 245:22 

267:15 358:20 373:7 

petitioned 9:14 11:2 

245:2 401:2 

petitioner 10:7 97:6 

petitions 238:19 354:6 

354:8 415:21 

Ph.D 2:11,13,16 

phase 9:20 

phase-in 200:21 332:7 

421:21 

phases 100:19 392:3 

phenotypically 68:4 

pheromone 187:5,7 

189:19 

pheromones 54:13 

55:17,21 57:7,13 

187:3,4,4 188:16,17 

190:7 241:2 242:22 

phone 392:1 397:5 

408:21 

phones 5:13 

phonetic 24:3 190:10 

194:2 274:3 

phosphate 211:4,6,12 

212:1 213:2,3 

photo 84:3 

photographs 5:16 

photography 145:19 

146:2 

phrase 145:13 

pick 173:3 448:8 

picking 55:4 198:9 

picture 63:19 277:20 

370:11 

pictures 171:21 285:1 

piece 351:22 352:1 

pieces 12:4 

pigs 63:11 

Pilgrim's 297:17 

pill 303:8 

pilot 343:3 347:14 

348:7 

pioneer 270:4 

piqued 73:8 

PLA 77:7,7 80:2 

place 21:1 44:22 87:7 

143:1 148:16 195:4 

245:7 273:9 279:9 

326:4 332:18 336:22 

376:20 387:7 391:13 

402:7 408:10 418:9 

420:14 426:14 444:2 

placed 170:21 236:20 

427:3 

placement 420:12 

places 195:16 248:1 

335:4 354:19 402:11 

408:6,9,15 420:7 

plagiarism 330:10 

Plagiarizing 330:9 

plain 177:10 

plan 99:4 184:8 218:2 

299:2 375:19 399:22 

planet 7:9 107:19 

108:13 331:15 332:1 

planetary 174:10 

planning 215:11 

plans 108:1 185:19 

216:13 301:9 

plant 24:15 55:5 59:1 

80:8 81:7 82:8,12 

132:14,21 134:22 

135:1 136:13 140:11 

143:19 146:4 173:11 

173:22 

plant-based 28:9 

442:12 

planted 82:13 344:5 

345:12 

planting 58:15 60:7,12 

61:5 83:21 84:8 

154:12 159:9 208:2 

446:22 

plantings 241:10 

plants 133:12 172:22 

174:7 192:19 225:13 

236:6 237:5,13,15 

246:6 

plastic 76:16 79:4,18 

79:19 80:15 81:5,11 

85:6 173:17 174:7 

187:5 283:21 284:2 

285:2 

plastics 85:1 154:20 

157:10 

plate 186:19 

play 104:4 207:1 425:15 

playing 141:22 184:15 

258:3 287:14 379:21 

424:9 

plays 48:13 225:19 

334:13,20 

plead 291:15 

pleasantly 281:16 

please 5:11,13,17 7:13 

7:21 23:14 28:22 47:7 

50:15 59:16 63:4 66:3 

85:13 95:9 109:19 

111:1 125:18,19 

193:6 203:2 210:2 

213:5 243:21 244:10 

268:18 269:1 289:11 

300:7 355:11 382:19 

382:21 448:14 

pleased 76:11 224:14 

233:1,12 304:21 

plop 414:2,4 

plug 268:18 

plus 212:15,16 

podium 6:1,10 

point 6:6 69:4 71:6,10 

87:18 115:13 116:18 

117:3,22 151:11 

160:16 165:3 180:10 

258:11 266:1 267:9 

276:7 278:22 279:12 

282:6 287:20 294:15 

304:3 324:15 330:12 

330:21 334:22 335:16 

338:19 343:18 361:1 

368:11 370:18 372:12 

373:2 377:13 380:6 

387:19 389:19 399:1 

399:20 404:7 417:1 

429:13 430:14 432:11 

447:5 

pointed 349:14 

pointing 126:1 

points 115:12 176:7 

197:18 237:5 306:20 

310:2 370:10 

poisoning 434:17 

poke 69:7 

policies 133:9 217:12 

217:17 

policy 32:12,13 35:19 

43:3 50:22 54:7 107:2 

107:5 200:8 270:19 

277:5 

political 250:1 252:7 

253:19 

politics 252:22 259:16 

polled 25:11 

pollen 192:20 408:1 

pollinated 349:20,20 

pollution 126:12,14,15 

127:6 129:20 

polyester 76:17 77:2 

79:4,18 

polyethylene 440:3 

pool 316:5 

popular 250:10 421:3 

population 87:7 288:16 

populations 214:11 

porch 111:21 

pork 207:11,14 

portion 97:16 116:7 

135:1 168:15 282:11 

288:5 

portions 134:22 

posed 43:9 95:19 

position 87:9 134:10 

167:2 212:16 214:1 

225:17 271:22 278:15 

297:14 

positions 43:3 

positive 117:4 244:3 

345:16 347:13 415:17 

possibilities 40:6 

389:17 397:20 

possibility 148:8 316:4 

possible 16:12 18:9 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
481 

39:3 41:17 65:9 

134:15,15 144:11 

154:1 156:13 165:4 

192:9 195:5 199:6,9 

275:20 304:5 316:20 

323:10 378:16 388:17 

possibly 68:22 69:7 

75:11 191:12 266:10 

post 44:3 260:10 

post- 356:20 

post-harvest 16:20 

17:5 240:21 

posted 40:16 211:20 

212:10 

posting 211:20 

postpone 13:22 

pot 76:9 80:12,21,21 

153:9 154:10,15 

155:19 156:3 157:17 

158:4 

potassium 242:1 

267:17 305:9 

potency 189:5 

potential 13:13,17 

20:17 24:17 60:18 

94:8 123:11 155:12 

155:17 214:12 220:8 

270:2 278:7 279:12 

361:16 370:2 395:13 

435:12 

potential's 17:12 

potentially 13:22 87:11 

95:21 129:17 130:4 

217:14 278:16 328:6 

336:1,14 337:22 

363:13 393:1,17 

394:4,12 429:7 

pots 76:8 84:12 85:3 

153:11,15,20 154:4 

154:13 155:8 156:5 

157:3,8 161:5,6 164:9 

172:18 174:4,7 

200:11 202:9,12 

206:3,5,20 

potting 164:13 

poultry 17:17 51:16,18 

51:19 62:19 64:12,13 

105:19 110:1 111:14 

129:22 207:11,14 

227:13 234:7,12 

288:22 423:15 443:6 

445:4,15,18 447:10 

pound 48:4,12 

pounds 17:4,5 24:7 

25:8 112:18 229:1 

pouring 271:17 

powder 23:20 24:2,8,21 

24:22 26:10 89:1 99:8 

99:10 100:12 101:1 

102:3 242:2 447:19 

powdery 55:6 192:4,5,8 

193:10,14,21 195:18 

199:8,11 

powered 281:14 

powerful 435:8 

PowerPoint 6:10 62:13 

PPM 219:11 246:10 

practical 199:3 205:14 

206:18 331:22 342:15 

347:15 348:7 

practicality 116:16 

practice 29:16 31:12 

37:5,6,18 51:7 65:8 

107:6 173:1 222:11 

259:8 260:5 278:15 

278:18,19 283:3,3 

352:21 

practices 8:4 15:20,21 

16:6,9 17:9,10,11 

19:8 51:16,19 64:1 

65:22 93:5 105:19 

107:14 172:11 173:4 

173:6,19 174:17 

214:13 227:13,17 

272:17 278:7 338:3 

399:14 

praise 248:6,20 

pre-Harvey 171:4 

pre-NOP 106:7 274:22 

preamble 37:20,21,21 

38:1,3 177:10 178:5 

181:8 

precaution 225:19 

precedent 106:20 

133:14 136:11 324:1 

369:12 

precedent-setting

136:7 323:15,22 

336:20 

precedents 336:21 

precise 70:20 

precision 154:9 

predators 188:8 189:10 

289:1 

predatory 192:22 

prefer 72:13 183:3 

403:19 427:15 

preference 97:18 

preferred 404:7 

prefers 92:9 

Preliminary 127:11 

premature 9:1 87:16 

preparation 163:13 

prepared 319:5 390:11 

preparing 198:8 234:13 

304:17 305:21,22 

presence 347:5 

present 1:11 2:5 10:4 

79:16 94:3 99:17 

182:20 213:16 231:20 

258:21 275:6,8 288:4 

374:14 

presentation 67:13 

390:18 391:2 401:7 

presentations 6:11 

326:9 372:18 

presented 9:19 43:14 

122:2 150:20 391:6 

409:1 420:4 

presenting 391:20 

presently 87:9 

preservation 87:6 89:9 

preserve 89:17 

president 96:22 223:14 

297:17 

presiding 1:10 

pressing 338:5,17 

pressures 192:12 

pretty 36:17 126:2 

231:15 238:9 241:3 

250:6 258:1 278:13 

303:8 307:22 325:22 

335:20 345:15 348:8 

389:22 407:4 444:16 

prevent 16:11 25:1 

56:20 103:7 104:11 

142:6 218:6 274:18 

274:21 275:8 369:10 

369:11 420:20 

preventative 8:1 16:9 

18:9 

prevented 371:12 

preventing 8:10 56:15 

104:4 207:2 439:5 

prevention 29:12 103:3 

192:8 426:16 

previous 35:1 191:9 

220:11 234:6 339:20 

340:1 343:9 

previously 212:1 365:6 

366:20 

price 118:7,22 119:15 

123:14,19 127:12 

340:22 367:18 368:8 

391:14 400:13 

prices 346:3 

primarily 85:17 93:7 

198:6 207:10 242:2 

primary 56:12 91:15 

191:4 219:22 241:14 

434:16 

principal 126:10 232:14 

232:18 

principles 224:4 245:15 

285:12 286:21 287:3 

287:21 289:7 

printable 78:8 

prior 4:19 275:2 338:11 

priorities 276:11 

409:19,22 410:2 

prioritize 277:7 

prioritized 378:6 

priority 38:18 337:13 

383:5 409:7,16 410:1 

privacy 124:10 

private 101:12,16 103:2 

252:18 298:15,18 

privately 253:14 

privately-held 122:16 

privilege 432:12 

proactive 100:11 

probably 18:16 19:19 

23:4 41:16 44:19 47:3 

58:1 78:9,21 79:15 

100:16 140:11 148:1 

151:9 157:6 179:6 

183:7 189:6 198:5 

199:12 243:5 265:18 

266:16 267:3 295:5 

302:19 308:13 330:7 

335:21 337:11 339:17 

365:7 366:19 387:14 

390:12 404:3 440:10 

442:21 446:3 

problem 17:19 36:2 

50:8 65:8 67:6 68:8 

98:18 145:5 151:5 

181:7 188:4 192:3,18 

194:2 243:6 259:5 

265:5 293:4 318:9 

325:20 340:19 341:10 

349:18 360:12 384:8 

391:10,16 420:21 

problems 9:6 36:18 

50:3 52:18 199:16 

257:15 282:2 325:16 

350:15 384:9 443:16 

procedure 15:9 317:10 

procedures 388:11 

proceed 21:19 41:8 

59:14 63:4 64:19 65:5 

65:14 337:20 

process 9:10,12 10:2,6 

10:11 11:13,16 14:3 

16:11 19:6 20:13 21:1 

21:8 22:1 27:17 32:22 

33:16 39:4 40:8,17,21 

41:3,4,15,21 42:2,5 

45:4 46:1,2 52:2 59:8 

59:21 60:8 79:1 85:20 

89:6,8 98:1 101:2 

123:13 126:15 128:20 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
482 

128:22 129:2,8,12 

130:22 131:7,13,22 

132:5 140:3 161:9 

180:15 201:14 202:13 

202:20 205:3 216:12 

218:10 234:13 236:17 

242:7 243:8,18 

245:14,22 247:1 

250:1 259:15 265:11 

292:19 335:6,7 339:5 

346:6 349:13 361:3 

368:17 385:13 400:5 

409:5,6 430:3,12 

443:10 

processed 30:22 92:7 

215:4 

processes 245:6 

265:10 309:17 326:4 

375:21 

processing 17:6 95:3 

214:8,17 215:1,12 

236:21 286:15 293:3 

356:5 

processor 214:21 

215:10,15 222:3 

processors 49:1 56:6 

57:1 205:7 214:10,15 

214:18 215:19 216:8 

216:16,18 217:6 

294:17 346:4,5 

procurement 163:4 

procuring 133:20 

produce 7:17 16:7,14 

29:5 56:9,11 65:11 

91:20 127:11 138:9 

138:11 160:19 214:21 

215:4,8 274:9 354:21 

354:22 355:13 362:1 

379:4 380:19 381:9 

399:2 408:10 

produced 36:16 58:11 

92:6,11 112:18 201:9 

207:4,8,12 267:8 

273:3 420:13,19 

producer 32:13 37:16 

132:14 173:14 209:9 

274:20 275:6 277:15 

277:16 288:15 343:19 

344:1,17 380:18 

431:22 

producers 52:15 119:2 

152:19 176:4 180:3 

204:1,2,19,20 205:1,8 

205:12 206:7 207:1,7 

207:10,16,19 209:2 

234:18 274:5 290:15 

301:13 341:19 342:12 

342:13 344:3,8,14 

345:22 347:17,20 

348:3 402:8,13,16 

403:8 406:13,16 

415:4,16 421:12 

431:14 442:4,7 445:4 

producing 127:6 309:6 

406:2,3 

product's 82:3 

production 3:7,16 24:8 

24:11 25:21 26:3 

54:16,17 55:18 60:12 

65:6 78:19 93:7,9 

107:14 112:12,15 

113:4 114:19 116:2 

118:17 127:3 129:8 

129:14 131:19 136:21 

153:17 155:10 160:22 

162:5,8 164:7 174:6 

183:14 202:13 203:5 

205:5 225:12 233:22 

234:7 236:1,9,10 

237:12 245:20 251:4 

272:8 274:2 278:12 

282:13 284:19,20 

285:20 286:18 289:4 

297:15 299:9 320:9 

380:8 384:18 388:5 

409:8 410:17,18 

412:6,19 414:18 

419:21 434:5 437:12 

445:22 

productive 288:18 

productively 174:8 

productivity 155:1 

professional 322:8,9 

professionals 126:8 

profit 192:14 

profitability 154:5 

program 2:8,10,12,15 

2:17 8:3 25:17,19 

29:13 38:18 39:16,21 

40:7 54:13 92:13,14 

103:3 116:9 166:16 

202:21 217:2 223:11 

234:14 247:19 248:7 

248:18 249:2 258:1 

260:3 271:6 301:3 

303:7 305:17 342:5 

342:14 348:7 371:3 

379:3 382:6,7 392:13 

393:4 440:6 448:15 

programs 61:10 121:1 

121:5 241:19 

progress 259:14 

384:11 

progression 320:5 

prohibit 34:19 207:3 

prohibited 36:11 

134:20 135:22 201:13 

221:3 287:12 317:14 

319:18 382:17 407:10 

408:5,14 420:18 

prohibitive 222:10 

prohibits 225:13 

project 24:14 29:11 

45:17 114:5,7 226:11 

226:12 227:9 343:3 

347:15 384:16 

projects 387:12 403:1 

403:11 

prolong 79:17 82:11 

promising 9:15 

promote 34:16 140:14 

143:11 150:10 

promotes 237:17 

promoting 335:22 

426:15 

prompted 155:8 172:12 

pronounce 73:15 440:3 

pronouncing 175:9 

proof 166:6 192:16 

222:2 

proper 14:6 28:14 

139:15 

properly 20:2 

proposal 3:4,15 20:16 

20:21 60:19 98:9,15 

141:21 201:19 204:13 

204:17 218:1 306:11 

306:13 307:3 308:1 

313:5 315:17 317:16 

319:9 321:17 343:7 

343:15 345:8 358:17 

365:2 401:1 402:1 

404:8 405:13 441:6 

441:11 

proposals 21:11,15 

32:19 61:4 282:12 

283:18 284:9 285:8 

propose 359:21 

proposed 39:2 105:4 

177:2 182:9 184:16 

185:8 194:22 207:18 

221:10 262:21 264:11 

267:1 268:22 293:14 

305:21 337:8 383:13 

400:2 

proposing 401:5 

proprietary 129:12 

pros 68:19 71:17 72:5 

prosper 70:18 

protect 118:13 215:13 

224:14 249:3 331:7 

protecting 92:19 

124:22 224:9 225:20 

346:20 397:21 400:16 

protection 216:15 

241:8 254:4 383:20 

protections 430:7 

protective 288:21 

protein 64:10 

protein's 93:10 

protocol 330:6 

protocols 329:14 

332:15 

proud 447:16 

prove 221:13 

provide 8:22 24:12 53:8 

106:1 109:15 110:2 

115:6 117:14 128:21 

133:7 141:1,3 166:17 

169:19 192:16 223:12 

234:17 237:15 262:11 

325:9 342:6 355:21 

358:2 442:7 

provided 69:5 93:13 

103:13 128:20 132:1 

317:18 420:18 

provides 30:2 90:14 

104:8 185:5 225:3 

providing 5:15 6:19 

51:14 136:5 153:8 

192:20 224:18 

provinces 142:16 

provision 162:14,19 

163:5 

provisions 173:12 

Proxies 5:4 

pruning 55:4 199:5 

238:3 

psylla 55:13 

public 3:2 4:5,6,13,14 

4:18 5:10,12 6:19 

9:19 11:4,6 21:3,7 

22:7 27:11 28:5 33:9 

35:12 40:2 52:2,3 

101:12,16,21 109:16 

115:6 123:22 124:16 

131:6 154:14 162:22 

179:8 201:21 212:12 

217:13,22 223:13 

224:1 231:20 238:14 

238:15 243:14 249:10 

258:15 264:16 282:17 

287:9 291:1 298:3 

304:6,16 307:1,2,21 

309:16 315:1 318:10 

319:8 320:14 322:16 

329:12 340:2 342:11 

343:8 345:20 355:22 

356:18 359:5 361:12 

361:14 368:18 371:8 

371:15 374:19 375:19 

376:22 377:22 378:11 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
483 

379:6 381:1,5 383:1 

395:10,22 396:7 

399:4 420:4 434:1 

436:21 439:9 

public-private 224:13 

publication 176:14 

304:22 

publications 135:17 

publicly 37:17 214:19 

publish 124:8 208:15 

published 37:13 107:5 

177:2,4 225:17 262:8 

305:6 

pull 102:10 137:21 

pulled 338:14 353:3 

425:18 

pulling 194:12 198:1,16 

393:6 

pullulan 97:5,7,14,18 

98:4,6 184:4,4 185:16 

185:18,21 186:2,4,6 

246:16,17,21 

punish 290:3 405:2 

pupae 187:12,12,20 

purchase 229:18 

262:13 

purchased 118:3 

352:11 

purchasing 26:14 

pure 19:18 213:15,21 

214:15 221:7 291:8,9 

291:18,22 293:6 

296:6 336:5 

purified 437:21 

purity 25:14 98:17 

340:4 349:8 350:9 

purpose 147:5 224:1 

244:21 

purposeful 94:9 

purposes 55:9 74:1 

124:7 164:15 293:18 

pursuant 38:4 

pursue 60:16 73:22 

192:10,14 327:12 

pursuing 93:3 157:18 

purview 151:1,8 165:21 

322:6,9 357:7 

push 44:14 52:22 

229:11 344:8 381:8 

pushback 353:2 

pushing 114:18 171:10 

put 4:21 17:3 28:6 

33:22 35:2 47:13 48:3 

48:4 81:14,21 86:3 

88:8 104:16 143:1 

144:17 160:7 210:11 

233:12 241:10 243:14 

243:21 244:10 250:20 

276:16 277:8 281:7 

288:17,21 294:11 

300:7 305:19 307:18 

325:2,4 327:6 338:10 

338:12,20 339:2,13 

343:10,14 345:6 

356:12 359:19 369:11 

371:16 377:12,20 

378:20 381:11 404:13 

408:13 429:6 

puts 228:6 263:6 

putting 250:14 308:14 

387:6 393:20 445:21 

Q

QAI 109:11,17 261:2 

qualified 211:1 

qualities 439:3 

quality 51:11 86:11 

91:17,20 93:19 

158:10 208:2 357:13 

377:5,7 422:5 

quantification 120:4 

quantities 237:14 

quantity 208:3 422:5 

quarantine 303:17 

quarter 392:10 

queen 404:6 

question 14:9 15:16 

17:22 18:15 20:8 

27:10 35:21 45:11 

49:10 50:1 66:16 

68:14 70:9 72:8 74:4 

74:17 75:3 84:10 90:3 

90:4,20 96:4 122:13 

128:1,13 130:20,22 

131:16 136:17 137:8 

138:16 141:13 143:15 

144:1 149:15 150:18 

152:4 156:22 157:8 

158:12 159:20 160:12 

165:11 170:1 179:22 

189:14 209:21 211:6 

211:8 229:10 234:7 

239:15 243:3 244:22 

253:14 254:11 257:22 

264:6 266:20 271:2 

278:4 295:22 304:2,3 

304:6 318:19,21 

322:19 323:1 324:11 

332:10 342:17 349:7 

351:11 357:8,9 358:9 

366:4 385:18,19 

387:13,14,18 390:15 

406:1 412:11 423:7 

425:10 426:3,11 

questionable 443:8 

questions 6:17 10:19 

14:8 15:19 19:12,20 

20:12 32:4,5 34:7 

35:15 42:19 43:8,10 

43:22 44:9 49:9 53:17 

58:3 66:7 78:15 87:1 

88:3 95:10,15,18,19 

101:5 106:8 108:19 

110:11,21 114:21 

127:22 136:2,6 149:7 

164:22 165:2 169:20 

175:2 176:8 178:9,12 

186:10 190:2 196:8 

203:7,9 205:4 208:18 

208:19 211:19 217:3 

218:20 226:1 230:3 

234:19 235:5 238:5 

242:19 247:4 260:8 

264:3 266:3 270:9 

279:18 280:17 283:11 

283:12 293:11,14 

300:3 303:14 309:20 

310:8 318:19 319:21 

327:13 328:4 331:2 

336:11 348:13 350:17 

359:10,11 362:14 

363:18,21 367:17 

378:5 405:5 422:10 

436:5 438:15,17 

439:16 444:5 448:6 

quick 17:22 20:11 

40:22 72:7 84:9 

139:17 143:14 150:19 

152:4 165:10 200:20 

268:17 277:13 279:4 

287:18 301:5,20 

321:6 370:13 416:22 

433:19 445:2 

quickly 44:11 156:13 

306:7 368:13 436:6 

quietly 348:19 

quite 40:22 83:2 84:16 

122:18 168:12 191:20 

247:16 250:7 260:3 

299:8 301:8 307:12 

334:13 341:19 343:8 

343:11 344:9 374:4 

398:4 402:10 407:8 

408:17,21 429:15 

quo 323:4,5 335:15 

quote 134:4,5 

quote-unquote 439:20 

quoted 174:15 

quotes 270:3 

R

R&D 161:9 

rain 112:8,9,11 114:11 

169:6 410:19 

rainfall 331:14 

raise 49:11 101:7 

140:15 141:9 179:17 

348:1 395:16 

raised 49:15 63:4 87:2 

136:8 168:5 197:18 

211:18 218:1,4,18,21 

225:15 284:8,12 

310:2 372:7 393:16 

raises 106:17 

raising 124:18 389:17 

ramping 332:4 

ran 278:21 

rancher 232:13 

ranchers 49:1 300:21 

Rand's 78:21 

Randolph 106:4 109:9 

109:10,11 111:5 

range 84:16 118:17 

172:10 355:19 

rangeland 408:7 

ranging 29:7 

rapidly 438:3 

rare 97:8 410:22 436:2 

rarely 97:7 

rate 146:11,12 147:6,18 

148:5,6,15 149:14 

154:11 

rate-limiting 64:15 

rates 445:16 

ration 28:10 442:13 

443:19 

rationale 164:18 

raw 30:22 87:4 133:20 

170:14 

ray 176:18 

rayon 78:20 79:9 80:14 

81:8,19 157:5,11 

re-list 24:22 

reach 33:2 43:6 140:1 

318:10 

reaching 342:10 393:3 

read 35:22 48:17 103:1 

233:20 313:3 325:4 

351:14 353:4,6 

374:16 383:14 402:17 

417:1 427:2 436:13 

readily 288:8 437:13 

reading 195:1 330:13 

350:13 

reads 184:18 

ready 9:21 49:14 82:9 

132:5 232:4 292:1 

304:1 309:10 310:6 

312:2 313:19 416:8 

432:3 448:7 

reaffirm 269:1 

real 19:1 20:5 32:3 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
484 

53:14 105:4 106:10 

270:16,20 271:8 

278:8 329:11,15 

334:5 379:19 423:10 

447:13 

realest 271:3 

realistic 338:7 

realistically 44:20 

reality 39:11 183:4 

realize 364:12 422:15 

realized 169:16 300:14 

447:20 

realm 399:9 

reason 106:9 191:5 

211:16 258:2 261:10 

322:18 329:5 374:5 

396:22 399:6 405:15 

412:12 429:10 430:5 

reasonable 127:16 

145:4 

reasoned 107:7 

reasons 60:10 72:11 

135:19 214:17 259:17 

279:6 

Rebecca 23:16 28:21 

28:22 29:2 32:6 

Rebekah 111:7 114:22 

115:4 122:1 

recall 8:6 305:7 

receded 113:16 

receive 401:19 408:21 

received 203:2 268:16 

378:1,9 379:7 404:11 

436:20 

receiving 354:7 

reception 231:1,6 

recipient 316:3 

reclassification 246:21 

reclassifying 305:9 

recognition 338:1 

393:18 394:2,9 397:2 

recognize 170:15 

recognized 432:17 

recommend 83:15 

220:20 221:7 246:13 

250:2,3 261:21,22 

recommendation 35:4 

86:18 94:10 97:17 

99:5 162:9 201:7 

250:5 251:8 272:13 

278:20 407:6 409:2 

413:18 424:9 

recommendations

34:19 53:11 95:21 

103:22 104:16 220:12 

224:20 259:3,7 305:5 

305:13 400:4 

recommended 237:16 

263:5 438:9 

recommending 80:7 

record 8:8 124:1 125:9 

190:17 231:11 243:15 

249:10 253:15 376:11 

437:7 448:22 

recorded 200:16 

246:11 

records 301:15,16 

recovering 94:13 

recreational 70:16 

recusals 314:15 419:18 

recycled 164:12,15 

206:13 

red 69:9 308:22 309:1 

redirect 201:1 

redone 406:22 

reduce 16:6 26:9 30:15 

214:10 220:8 

reduced 154:21 155:5,5 

reduces 241:7 

reducing 154:18,20 

reduction 15:4,5 215:7 

215:16 

reef 334:2 

reemphasize 335:13 

reestablished 288:10 

refer 93:16 340:1 

364:21 

referee 48:9,10 

reference 22:18 123:15 

200:20 202:5 263:2 

267:9 354:4 355:21 

356:2 358:5 374:9,10 

374:11,14 

referenced 434:22 

references 267:6 

referred 168:18 213:18 

referring 18:19 337:1 

366:15 

refers 167:11 

refine 132:16 

refining 373:17 

reflect 21:20 437:7 

reflected 383:12 

Reflections 235:19 

237:22 

refrain 6:20 7:2 

refuted 212:5 

reg 177:15 

regard 30:1 57:7 215:18 

219:20 262:6 349:8 

350:9 

regarding 30:20 61:5 

63:3 68:15 73:10,12 

75:9 92:17 107:6 

110:11 117:22 128:20 

138:16 202:17 403:8 

445:14,16 

regardless 178:19 

regards 72:3 163:7 

249:1 261:6 

regenerate 135:2 

regeneration 143:17 

144:4 

region 210:9 

regional 151:3 210:7 

223:21 415:11 

regionally 415:5 

regions 117:21 412:20 

Register 305:3 

registry 396:7,9 

regs 106:13 389:10 

regularly 116:1 257:18 

317:8 

regulate 151:3 

regulated 142:13 147:9 

169:18 278:6 

regulating 335:2 

regulation 52:4 99:17 

148:12 167:5 178:4 

181:7 227:19,20,21 

regulations 34:15 37:7 

51:5 66:20 107:21 

132:17 133:9 135:4 

138:21 139:2 142:10 

170:8 177:20 207:3 

211:16 233:2,8 

281:20 329:16 389:7 

426:7 435:2 

regulator 235:21 238:1 

regulators 332:9 

regulatory 54:7 94:21 

96:22 106:16,22 

115:5 132:12 252:15 

256:14 259:15 328:1 

328:11 

rein 278:22 

reiterate 87:19 93:18 

372:10 

reiterated 327:20 

reject 127:17 

rejected 340:17 341:3 

rejection 116:19 212:21 

relate 245:15 

related 31:9 56:9 88:10 

95:10 99:4 251:19 

386:3,16 

relates 68:17 

relation 87:4 

relatively 239:5 269:20 

440:10 

release 219:6,7,10,11 

219:11,12 

released 437:22 

relevant 420:1 

reliable 24:12 

reliance 442:6 

reliant 116:10 

relied 93:12 

relies 292:13 

relisted 243:5 

relisting 23:20 25:3 

26:5 92:2 438:8,10 

439:19 

rely 17:8 110:4 115:22 

153:20 201:5 413:17 

relying 19:5 167:10 

246:2 

remain 8:15 216:16 

350:19,20 

remaining 167:10 

remains 59:13 60:4 

114:5 

remarks 374:1 

remediation 126:13 

remember 16:14 182:8 

210:18 269:16 328:19 

392:9 393:5 

remembered 137:11 

398:22 

remembering 269:3 

remind 231:4 236:14 

268:2 

reminder 230:22 

remiss 260:12 305:15 

395:2 

removal 14:22 25:9 

435:22 

remove 8:14 21:15 

97:10 130:15 182:19 

198:15 202:5 307:17 

311:10 315:13 345:7 

354:18 361:14 364:10 

removed 36:13 134:22 

135:5,15 151:16 

203:5 219:16 310:5 

310:13 371:2,21 

removes 126:15 135:9 

151:18 

removing 177:21 

308:13 

Renaissance 1:9 

renew 58:14 

renewed 435:19 

rent 199:1 

repacks 13:1,2 

repealed 253:6 259:9 

repeat 58:18 190:6 

repeatedly 137:5 349:9 

repetition 266:19 

repetitioned 264:2 

267:2 

replace 130:15 443:17 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
485 

replacement 236:22 

435:16 

report 8:21 46:1,6,15 

47:2 93:12,19 99:12 

233:19 367:22 368:5 

435:10 

reported 124:15 

reporting 116:19 

117:22 118:12 124:11 

124:22 

reports 4:8 46:3,7 

repository 117:7 

represent 7:22 33:1 

53:11 57:3 105:14 

157:16 158:21 166:18 

251:14 302:6,14 

representative 33:5 

202:22 

representatives 255:17 

291:13 

represented 24:6 36:15 

38:8 380:4 383:4 

representing 48:22 

represents 54:4 91:14 

215:8 255:11 

reps 19:12 

reputation 215:13 

225:8 

request 22:13 23:9 99:3 

109:4 205:10 206:8 

209:12 211:19 212:3 

236:7 245:1 322:4 

370:19 371:9 379:9 

requested 46:15 98:21 

98:22 155:17 239:3 

321:11 377:9 

requesting 105:12 

179:9 206:11 

requests 202:7 

require 29:18 30:12 

31:2,11 65:20 67:11 

98:3 106:14 115:17 

120:18,21 209:9 

225:12 332:4 345:11 

required 8:1 51:8 57:1 

71:8 87:8 163:11 

167:6 174:16,17 

185:1 192:16 211:7 

211:13 212:6 213:4 

222:18 225:7 244:16 

245:6 264:13 296:4 

415:1 423:15 

requirement 88:11 

171:9,13 181:21 

200:19 269:4 

requirements 46:19 

108:1 116:12 169:4 

183:9 222:13 245:16 

355:1 

requires 10:11 70:17 

requiring 107:14 

162:17 331:18 422:22 

research 10:1 14:4 

16:19 19:4 22:9 24:9 

59:12 60:2 73:22 77:5 

86:2 101:22 126:11 

126:11 134:7 188:2 

190:10 219:15 237:18 

237:20 240:20 254:1 

254:10 263:11 302:17 

315:10,12 316:22 

317:22 330:2 343:5 

363:18 402:14 448:1 

researched 153:17 

researchers 25:11 

122:7 

researching 63:12 

reservations 360:22 

361:20 

residing 253:18 

residue 117:4,6,6,8 

381:2 

residues 14:22 

resigned 260:10 

resist 278:3 

resistance 9:6 18:1,4,5 

18:12,17,18 20:2 

56:20 189:4 195:18 

214:2,13 218:5,16,21 

219:14,16,19,20 

220:6 360:12 

resistant 364:17 

resolution 37:11 48:16 

105:1 176:17 

resolve 108:12 263:15 

323:18 

resolved 48:19 

resolving 361:4 

resource 133:3 135:5 

143:4,12 145:21 

151:13 200:20 234:18 

421:19 

resource-based 139:3 

resources 65:11,12 

92:19 100:4 102:10 

107:16 114:3 133:19 

136:18 201:15 283:6 

331:7 337:17,19 

respect 58:17 92:15 

93:11,20 134:3 

338:13 385:13 403:5 

426:14 

respectfully 98:9 138:2 

236:7 

respective 401:9 

respond 10:1 34:7 

35:15 40:11 123:16 

276:22 383:15 389:3 

responding 43:22 44:5 

305:4 

response 25:13 89:22 

101:9 220:14 234:6 

277:13 309:15 311:17 

313:17 318:20 320:16 

353:16 390:14 402:6 

responses 72:6 378:5 

responsibility 336:8 

responsible 26:2 127:3 

127:5 256:1 

responsibly 399:18 

responsive 260:3 

305:12,20 

rest 75:3 148:20 

restaurant 15:9 

restrict 97:9,13,19 

restricted 159:14 

restricting 186:2 

restriction 263:3 

result 20:16 25:9 47:3 

65:13 94:20 118:7 

215:17 445:13 

resulted 37:11 

resulting 86:3 95:6 

346:3 

results 24:12 59:3 

76:12 77:10 116:21 

117:8 129:15 202:15 

215:1,4 246:11 364:4 

resumed 125:9 231:11 

376:11 

retail 15:9 298:18 

retailer 297:15 

retailers 49:1 297:22,22 

299:4 

retain 95:8 

retardation 64:22 65:6 

reticent 336:16 

return 69:8 

returned 203:6 

reveal 348:22 391:9 

revealed 391:8 

revealing 122:16 

reveals 334:12 

review 3:17 8:14 10:1 

11:1,14 20:15 21:4,9 

21:10,14 41:4 45:1 

46:19 74:11 92:2 

97:22 109:4,18,19 

131:22 132:3 135:22 

143:19,21 151:8 

155:16 156:7 162:1 

164:11 166:5,10 

184:2 201:14 202:15 

205:10,13 206:10,12 

209:6,12 211:15 

212:20 243:19 245:12 

246:7,22 261:14 

269:1,17 301:19 

355:16 356:13,14 

359:18 361:13 363:22 

364:3,6 365:4 370:3 

370:19 371:6,9,11 

378:8 407:13 427:5 

432:5 433:12 436:21 

438:11 448:7 

reviewed 11:6 73:17 

153:17 246:10 262:3 

431:16,18 

reviewer 209:15 

reviewers 269:6 

reviewing 39:22 40:17 

44:17 206:18 209:8 

244:19 245:4 305:21 

420:11 433:14 

reviews 45:16 91:7 

166:9 206:8 207:6 

214:6 245:1,3,13 

261:10 

revised 184:13 201:22 

revision 201:20 

Revolution 270:5 

revolutionary 270:4 

rework 383:20 

Rice 1:13 67:10 85:12 

91:10,12,13 96:2,8 

272:4 312:3,14 313:3 

314:5 327:16 328:11 

399:11 400:22 405:4 

405:19 406:8 410:14 

412:9 414:21 415:12 

416:2,8,16,19,21 

417:4,6,11,16 418:7 

418:11 419:3,17 

422:9 424:11 426:2 

428:7 429:2 430:8,18 

432:3,13 433:10,21 

436:4,18 438:16 

441:21 444:5,8,21 

445:6 448:5 

Richard 175:17 176:5,9 

Rick 1:16 17:21 70:15 

123:7 130:19 193:8 

256:19 331:4 333:9 

rid 72:20 85:6 228:9 

355:8 

rigorous 325:22 

rigorously 117:18 

rinse 15:10 293:19 

357:2 

rinsed 292:3 294:3,7 

rinses 293:16 

rinsing 19:6 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
486 

rise 350:16 

risk 30:16 52:14 67:1,4 

72:5 115:15 118:8 

228:7 271:3,5 349:22 

351:5 391:9 

risk-based 103:21 

117:15 

risks 269:12 

Ritson 111:7 114:22 

115:2,4 119:1,18 

120:8,12 121:14 

122:4 123:4,16,18 

125:2 

road 89:3 321:3 336:15 

384:5 397:17 

Rob 175:22 

Robert 171:20 175:13 

175:15 

robotic 198:9 199:5,6 

robust 104:22 375:15 

389:22 394:6 412:18 

415:9 

robustness 249:1 

rock 39:9 

Rockies 195:20 

rockweed 133:6 134:19 

134:21 135:7,9,12 

137:10 138:4 143:18 

143:20 144:4 151:15 

Rodale 195:1 

role 104:4 207:2 225:19 

281:11 400:1 

ROMERO-BRIONES

1:18 312:18 314:9 

417:20 419:7 

rookies 89:6 

room 5:6 19:11,17 22:2 

75:3 82:19 103:10 

168:1 222:1 231:3 

248:17 255:5 296:22 

448:11 

Rost 200:5 203:14,15 

203:15,18,18 

rotate 9:5 12:3 56:17 

rotation 173:14 214:13 

357:20 360:11 375:12 

rotational 11:21 

rotations 174:9 

rough 167:7 

roughly 25:8 392:11 

round 99:2 306:1 

round- 401:9 

round-up 433:22 

routine 116:6 

routinely 174:5 

row 128:18 

rows 188:12 

rubber-stamping 51:18 

rule 8:2 30:12 31:8 

35:22 37:13 38:20 

39:2 49:2 51:16 68:2 

105:2,4,12,19 108:14 

146:9 155:12 169:7 

169:11 176:15 177:2 

177:3,8 178:7 180:2 

182:9,14,20 185:8 

194:22 203:2 208:9 

208:15 226:14,22 

227:6,11,14 258:6 

262:8,22 263:16 

264:11 267:1,4 

268:22 272:14 281:19 

296:11 298:5,9,10 

299:14,15 305:1,4,4 

305:21,22 331:6 

342:3 344:12 383:13 

400:2 412:15 420:6 

420:10 426:22 427:1 

427:2,9 429:1 

rulemaking 105:7 

155:16 177:1 178:3 

253:16,17 378:10,15 

378:20 383:16 389:22 

399:5 

rules 4:13 30:20 36:2 

48:1,10,14 51:4,20 

52:9,19 53:7,8 85:1 

108:10 174:13 281:13 

335:20 

rumens 49:13 

run 118:10 222:8 

241:16 278:19 448:16 

run-on 264:8 

runoff 283:21 

runs 295:18 

rural 108:11 

rushing 44:3 

Ryan 177:5 

Ryania 188:15 

S

Sabapathy 161:19,20 

166:13 

sacrifices 61:19 268:9 

sacrificing 271:21 

296:3 

sad 319:1 

safe 51:15 288:18 

safeguard 174:18 

safeguards 143:1 

safer 236:21,22 245:8 

245:17 356:2 440:5 

safety 7:15 19:10 55:8 

64:3 71:20 86:9 215:9 

215:21 216:18 244:17 

291:5,6,22 295:9,10 

295:11 354:21 355:10 

355:14 363:16 370:1 

372:18,19 

saga 306:17 

sale 120:6,10,16 121:8 

121:16 218:10 381:14 

381:20 382:11,12 

384:13 388:15,18,21 

412:4 

sales 24:1,6 25:7 229:2 

271:9 291:4 

saliva 99:13 

Salm 87:3 

salmonella 67:1 72:3 

423:17 425:3 

salve 279:11 

sample 76:17 

samples 76:15 83:4,5 

161:4 

sampling 116:20 

117:16 256:16 

San 109:12 364:22 

Sandra 239:19 244:7 

Sandy 244:8,12 

sanitation 3:9 12:11 

14:17 15:2 18:2 19:7 

19:9,12 205:5,6 

215:18 216:12 244:16 

246:4 295:19 296:5 

353:18 374:8 

sanitization 216:8 

sanitize 13:3 15:7,11,13 

55:4 57:2 292:17 

sanitized 15:6 

sanitizer 9:3,14 11:22 

18:15 21:4 45:13 

291:10 354:2 356:10 

357:2 358:1 365:3 

434:5 

sanitizers 8:9,15,20 9:5 

9:7 11:1,6,21 12:13 

13:8 15:17,22 18:21 

19:4 20:2 22:19 45:16 

56:5,7,14,17,18 

205:11 216:6 353:14 

354:7,9,11,19 355:5 

355:18,22 356:1,6 

358:19 359:18 360:6 

361:13,15,18 364:10 

sanitizes 292:2 

sanitizing 12:19 14:12 

14:20 216:9 292:13 

293:16 294:20 370:1 

sat 325:6 

satellite 145:19 

satisfied 161:11 

Saun 230:17 231:21 

235:8 239:18 279:14 

sausage 24:4 86:7 

sausages 85:18 86:10 

86:15,22 

Savannah 107:4 

save 53:14 331:22 

353:1 393:8 

saving 352:20 

saw 13:12 48:15 83:3,5 

179:7 282:1 308:16 

317:22 340:14 351:20 

saying 48:11 131:17 

145:14 158:19 179:14 

182:7 196:20 228:2 

274:7 286:11 289:13 

289:21 290:4,14 

294:4 309:16 325:12 

334:18 351:14 357:15 

366:4 371:4 373:18 

375:16 376:6 392:1 

398:4 412:12 425:12 

427:1 439:11,12 

says 36:10 38:2,3 

182:20 233:20 243:18 

274:12,21 275:4,6 

302:8 344:12 369:7 

403:10 425:7 427:2,6 

431:16 

scale 52:5,17 130:6 

154:5 207:11 210:10 

234:7 295:17 

scattering 222:7 

scenario 9:14 89:12 

schedule 5:8 401:11 

scheduled 111:8 

scheme 447:13 

school 281:7 292:14 

science 14:16 133:4 

143:12 145:9,10,21 

172:2 275:10,10 

scientific 70:20 133:8 

135:16 263:11 313:13 

438:13 

scientist 126:10 191:2 

scientists 144:8 

scissors 281:11 

scope 47:3 163:7 327:3 

362:19,21 367:14,22 

373:19 411:16 

scopes 33:4 411:13 

Scotia 132:15 135:12 

137:10,12 138:17,22 

139:8 142:12 144:11 

146:12,14 147:12,13 

148:3,9 149:20 

150:21 152:10 

Scott 1:13 272:3 312:2 

313:2 327:15 330:18 

332:8 399:10 400:21 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
487 

426:3 433:17 

Scott's 67:8 

scouring 113:21 

scramble 346:9 

scrutiny 134:12 136:18 

SDC 9:11 13:9 14:9 

213:18 214:1,6,8,8,16 

214:19,22 215:2,14 

216:4,6,9,17,21 

219:20,21 293:15 

294:4 

SDC's 214:3 

se 57:11 91:7 150:7 

sea 26:1 429:15 

seafood 93:9 

seal 108:12 284:2,5 

410:7 

Seaplants 132:13,20 

133:11 135:19 149:21 

332:14 

search 353:22 411:14 

423:1 

Sears 408:12 

seas 331:19 

seashore 152:18 

Seattle 1:9,9 62:21 

113:15 114:16 

Seaweed 133:5 148:14 

seaweeds 33:22 330:13 

second 4:4 15:15 25:2 

138:16 181:13 182:1 

187:19 230:2 261:16 

311:13,14,15 325:14 

339:14 393:7 433:19 

secondary 25:20 95:2 

seconded 313:7 416:12 

418:20 432:16 

Secondly 77:16 

seconds 417:2 

Secretary 1:13 49:2 

191:15 233:6 250:17 

297:8 

secretly 354:17 355:12 

section 38:5 173:10,13 

202:4 282:7,8 309:5 

311:8,9,10 

sections 173:7 282:10 

sector 63:13 81:15 

103:2 105:11 117:11 

139:5 146:3,9,20 

150:4 176:19 

sectors 81:16 106:14 

149:20 150:1,2,13 

255:12 

secure 27:5 

security 69:16 

seed 3:8 58:15 59:2,6 

60:7,9,12,15,19,20 

61:2,6,9 98:8,12,13 

98:14,17,20 121:5,7 

164:9 200:10 201:17 

202:1 204:9,11,22 

340:3,7,18 341:15,17 

341:18 342:1,9,12,19 

342:19,20 343:19 

344:1,3,5,9,12,14,15 

345:2,9,12,19,22 

347:6,17,20 349:2,4,7 

350:8 351:4 352:10 

352:11,14,20 353:2 

seeded 155:1 

seeds 154:9 208:2 

315:6,13 338:2 

339:10 

seeing 45:19 202:14 

209:1 256:16 290:11 

438:16 

seek 106:19 

seen 18:1,6,7 67:22 

79:3 120:9 140:5 

182:5 187:7 188:9 

189:2,5 303:2 317:1,6 

388:4 400:9 403:10 

435:4 444:10 445:8 

segment 447:9 

SEITZ 1:19 149:12 

169:22 278:3 311:14 

312:11 314:2 417:13 

418:22 433:17 434:2 

436:13 437:5 

selecting 67:11 

selection 24:11 65:19 

67:21 290:6 302:21 

selectively 198:15 

sell 29:19 30:4 152:6,18 

155:2,19 298:20 

342:12 346:7 380:13 

415:5 

seller 222:14 

selling 29:22 76:9 

sells 94:16 

semantics 379:20 

semen 316:12 

semi 346:8 382:16 

semi-permanent

173:17 

semillon 194:2 

send 39:12 95:20 

191:14 365:8 

sending 113:20 

senior 29:3 183:21 

244:13 362:11 

sense 42:17 69:16 96:3 

96:4 151:1 180:8,20 

251:11 289:8 349:1 

392:5 

sensible 106:22 269:2 

sensitive 349:12 

sent 105:12 110:20 

341:4 351:14 

sentence 264:6,8 

351:19 

sentiment 227:4 415:20 

separate 256:14 317:19 

441:5,9 

September 262:9 

sequestrant 237:10 

sequestration 331:13 

seriously 143:10 

279:21 

serve 46:21 107:19 

111:16 117:19 224:2 

254:14 255:13 274:1 

421:10 

served 4:20 167:1 

serves 10:17 244:15 

service 114:19 169:19 

186:8 224:16 260:13 

serving 61:20 

session 85:19 

set 68:11 102:4 120:17 

122:6,10 124:9 251:2 

251:22 252:16 281:19 

282:7 290:12 299:14 

325:22 333:14 335:8 

336:21 342:5 349:14 

350:7 387:9 389:7 

sets 330:19 

setting 55:3,7 224:21 

226:20 252:20 

seven 32:19 46:10 80:4 

212:16 

sew 394:14 

shade 194:8 235:15,20 

237:22 238:3 

shaking 412:17 

shape 328:9 

shaping 33:17 

share 74:12 76:11 

95:12 111:22 123:1,2 

149:14 168:14 281:1 

283:20 336:12 363:10 

shared 76:12 350:10 

sharing 7:8 119:3 

217:18 224:20 364:9 

shears 55:5 

sheep 235:1 317:5 

sheet 231:3 

sheeting 174:7 

sheets 355:4 

shelf 66:22 229:15 

Shell 301:1 

shelves 275:18 

shift 146:21 

shifting 86:20 

ship 30:21 341:2 

shipped 225:6 

shipper 240:1 

shippers 54:5 

shipping 30:14 

shoot 194:11 197:22 

198:12,12,15 199:6 

shop 122:6 

shoreline 150:11 

short 39:8,15 41:16 

64:14 66:22 68:19 

82:6 225:9 279:17 

289:10 307:22 328:17 

369:12 381:21 

shortchanged 282:5 

shortcoming 393:14 

shorter 289:17 

shot 35:13 48:2,4 281:6 

show 6:7,12 73:2 77:10 

84:4 134:8 222:3 

228:7 260:11 303:7 

330:16 356:3 

showcase 114:14 

showed 82:5,18 84:15 

279:14 423:4 

showing 26:16 

shown 135:17 222:5 

shows 239:12 243:8,10 

357:21 

shrubs 446:22 

Shuford 190:9 

shutdown 268:12 

side 5:11 81:11 101:16 

101:16,21 119:17 

220:8 247:10 256:4,5 

264:19 316:15,15 

331:21 337:1 399:21 

sides 337:10 

sign 4:19 37:16 423:3,6 

signal 212:9 

signed 103:12 105:17 

significant 54:22 55:15 

86:16 116:7 134:4 

168:15 204:20 215:9 

269:5 318:8 340:20 

341:8 

signified 52:1 

signs 344:22 391:7 

423:8 

Silva 24:9 

silver 13:17 69:18 

213:18 219:6,10,16 

219:21 220:2,5 

221:18 

silver-impregnated

219:3 

similar 21:1 46:8 59:3 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
488 

60:17 68:13 73:18 

81:21 89:1 119:15,16 

127:12 129:1 157:7 

197:2,2 202:18 208:2 

380:9 

simple 29:7 211:6,8,8 

437:19 

simply 151:10 160:7 

211:5 

Simultaneous 372:3 

simultaneously 79:11 

sincere 156:8 226:10 

sincerely 268:8 

Sindelar 24:16 

single 16:21 84:22 85:3 

114:6 137:3 193:22 

212:17 238:13 274:4 

315:21 360:19 386:15 

414:3 

singular 163:11 

sink 400:3 

sir 67:7,17 194:22 

269:14 

sister-in-law 62:4 

sit 111:12 301:2 374:15 

site 12:21 

sitting 44:1 285:5 

348:18 

situation 82:8 138:1 

252:8 272:18 336:3 

358:1 

six 48:3 49:12 163:21 

191:21 197:13 291:18 

Sixty 45:8 

size 68:9,15 221:12 

229:7 446:19 

sizeable 257:10 410:17 

sized 269:9 

sizes 33:3 

sketch 405:10 

skilled 107:9 

skin 85:17 86:14 

skins 26:7 87:12,13 

89:18 

SKUs 25:5 

sland 24:3 

slide 6:9 65:5 309:12 

slides 6:11 

slightly 148:4 359:9 

slots 4:20 

slowly 84:12 361:3 

Sluggo 212:7 

small 17:6 52:14 61:1 

153:7,9 154:4 155:3 

182:13 194:6 198:6 

202:22 208:11 219:6 

225:4 237:14 239:5 

241:4 257:6 301:12 

301:12 302:13 316:22 

338:21 435:6 440:10 

447:9 

small- 207:10 

small-scale 206:7 

smaller 68:20 69:17 

257:13 321:1 

smart 446:8 

smearing 349:13 

smell 26:9 295:14 296:4 

smells 187:17 

smoother 40:8 418:13 

soap 306:16 

soaps 275:16 

social 172:16 

sodium 267:17 

soil 51:9 53:4 77:5 

78:14 79:3,15 80:3 

81:21 128:5 154:21 

164:3,14,19 172:10 

173:1,8,12,15,17,18 

173:19,21 174:8,18 

174:21 192:16 225:13 

237:5 280:14 283:21 

284:5,15,16 285:4 

287:11 290:17 377:7 

soil-less 174:5 

soils 174:1 191:19 

Sol 191:3 

sold 25:6 36:15 38:7 

380:21 382:2 408:12 

soldier 72:1 

sole 263:20 266:4,17 

267:13 

solely 281:13 418:18 

soliciting 42:15 

soluble 236:18 

solution 29:13 44:13 

68:11 98:19 108:7 

279:5 337:3 

solutions 82:10 85:6 

103:10 104:14 336:17 

336:18 337:5,8 

solve 17:19 384:8 

solved 36:9 

somebody 75:11 

125:14 142:1 235:10 

253:12 281:8 303:9 

329:3,10 330:6 335:1 

352:15 402:12 

somewhat 315:3 

319:17,20 330:2 

331:22 332:21 336:15 

337:10 339:13 

son 48:2 

Sons 239:22 242:6 

soon 177:8 390:11 

sorry 20:10 50:20 59:14 

59:19 62:10 68:5 

74:18 75:16 84:16 

101:9 117:6 128:11 

139:18 149:5,8 

165:10 175:8 178:13 

194:20 196:17 223:5 

223:20 289:12,20 

337:7 353:21 365:10 

367:2,9 370:17 

412:16 415:14,18 

418:2,4 422:12 

441:19 445:2 448:3 

Sorry.' 390:20 

sort 73:3 81:4 83:6 

124:10 137:2 192:1 

222:19 261:18 265:21 

266:11 267:11,16 

284:18 321:2,16 

322:3,12,14,22 324:4 

327:18 328:1 343:7 

345:17 349:11,14 

350:5 379:12 384:12 

392:2 422:1 436:17 

sound 168:20 202:14 

269:2 313:1 447:12 

sounded 335:19 

sounds 68:12 199:20 

439:20 

source 70:6 71:13 

88:12,15,20 123:8 

129:9,10,20 179:15 

192:21 220:2 261:18 

262:5 263:20 265:7,8 

265:14,15 266:4,17 

267:14 268:3 302:6 

396:15,20 443:14 

sourced 26:7,21 93:2 

94:19 

sources 102:10 288:7 

sourcing 43:19 393:11 

south 403:1 446:2 

Southeast 394:20 

souvenir 7:8 

space 288:22 

span 82:3 

spans 324:4 

speak 5:3 7:4 16:1 

17:18 23:19 59:16 

63:2 85:19 90:15 96:5 

125:19 126:4 151:4 

153:19 180:16 224:5 

243:4 280:8 300:6,8 

327:22 346:11 364:5 

378:21 409:13 

speaker 5:18,18 6:18 

7:1 152:21 196:6 

243:9 304:6 

speakers 5:15 44:8 

191:9 223:9 297:3 

speaking 4:20 85:15 

111:19 172:12 175:18 

325:11 326:13 337:10 

342:8 364:18 372:3,4 

speaks 35:11 300:17 

special 336:8 404:16 

specialist 2:8,14 29:3 

115:5 183:22 203:19 

205:21 

specializes 126:11 

species 24:15 93:6 

192:19 195:17 331:19 

350:4 

species-specific 64:13 

specific 6:17 19:20 

34:10 36:17 37:15 

43:8 46:11 107:5 

130:9 162:19 163:4 

163:10 168:19 205:3 

208:3 211:19 263:2 

264:12,12 275:17 

283:18 316:9 360:18 

367:22 374:21 384:2 

384:4 386:12 420:20 

specifically 9:7 26:22 

28:11 68:17 195:5 

196:8 218:1 362:8 

379:2 406:20 422:5 

427:11 

specification 87:8,21 

specifics 93:17 

specified 185:4 

specify 104:12 

spectrum 324:4 437:14 

speech 7:1 

spend 14:10 142:2 

198:20 305:10 368:3 

446:12 

spending 114:7 447:22 

spends 276:8 397:5 

spent 63:11 269:17,19 

269:21 

spill 296:14 

spinach 24:18 

spiral 24:4 241:2 

spirit 164:20 320:13 

373:8 

split 278:8 279:11 

436:10 

splitting 327:21 333:11 

spoke 5:2 191:10 272:4 

442:4 

spoken 433:11 

sponsored 263:12 

spontaneous 322:3 

sporting 97:1 

spot 39:9 414:2 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
489 

spots 188:21 350:16 

391:10 

spray 199:8 

sprayable 57:9,12 

190:4 

sprayed 189:15 

spraying 188:5,11,13 

sprays 193:4 241:7 

spring 1:5 119:7 187:13 

364:22 404:6 

Springs 232:14 

spurt 189:19 

square 77:8 446:1 

squid 97:2 

SS 269:10 

St 176:17 

stabilize 126:16 

Stacey 397:2 

staff 2:5 43:4 126:8 

128:19 209:7,14,15 

368:15 378:8 408:22 

429:18 

stage 126:18 

stages 187:12 

Stagnation 108:12 

stakeholder 33:17 42:3 

137:6 252:20 

stakeholders 8:22 9:19 

10:9 20:19 33:9 35:12 

51:17 53:12 58:2 

103:10 133:5 134:10 

212:15 321:19 322:4 

339:2 359:17 364:6,7 

364:13,14 369:7 

442:1 

stall 62:18 

stance 38:9 

stand 50:9,10 51:3 

113:18,19 198:3 

270:2 

stand-alone 182:2 

standard 15:8 25:16 

48:20 53:5 79:8 86:12 

91:17 134:1 142:6 

156:1 159:5 160:9 

168:19 225:11 255:6 

256:12,16 272:20 

273:1,3,18 274:9,13 

274:16 275:2,4,6 

276:4 280:7 282:15 

334:7 402:4 403:2 

404:18 405:1 406:21 

407:4 412:14 413:17 

413:20 

standard- 258:11 

standard-making

336:14 

standard-setting 250:3 

252:18 256:7 257:13 

257:20 

standardization 29:17 

standards-setting

256:10 

standing 115:3 151:17 

151:18 

standpoint 170:4 

232:18 

start 4:6,12 6:1,7 

130:10 157:14 159:13 

175:18,19 218:20 

231:18,20 251:9 

259:9,10 285:12 

311:19 312:4,7 

313:20 319:2 381:17 

420:10 433:15 444:3 

448:15 

started 43:10 89:6 

239:6 340:18 396:8 

starting 98:10 125:15 

152:15 187:14 193:20 

205:3 265:16,22 

279:9,12 330:11,12 

330:21 341:10 344:18 

starts 293:2 418:21 

starve 173:19 

stat 392:12 

state 7:13 8:8 12:11 

14:15 23:14 28:22 

47:7 50:15 54:16 

111:13 112:4,5 

114:15,17 120:19,22 

121:6 128:21 131:17 

131:21 148:18,20 

174:13 176:2 189:6 

204:22 298:6 301:19 

331:6 349:2,4,7 350:8 

382:5,6,8 392:13 

393:4 409:11 420:16 

State's 112:12 

stated 8:13 347:14 

351:17 354:1 443:11 

statement 134:3 278:4 

362:14 367:15 387:14 

440:12 

statements 27:7 208:5 

208:6 239:4 

states 1:1 66:1 75:7 

86:5 114:8 121:11,17 

161:1 173:11,13 

200:9 222:17 223:22 

248:22 302:9 381:19 

402:22 408:5 

States' 112:15 

stating 137:12 172:17 

202:19 220:14 364:8 

statistic 109:21 

statistics 110:2 

status 59:11 60:2 166:9 

200:18 237:10 323:3 

323:5 335:15 385:8 

386:1 

stay 48:4 79:19 80:8 

81:17 231:15 233:13 

254:22 279:17 407:19 

staying 227:10 

Steen 126:10,11 

stemming 219:1 

step 15:14 22:1,1 89:8 

122:19 169:12 250:21 

385:10 

stepped 82:13 

steps 100:11 214:14 

271:7 324:19 390:3 

390:16 

Steve 1:12 35:17 39:5 

57:6 78:16 89:20 90:3 

102:15 106:4,5 

108:22 128:1 141:11 

156:15 190:2,14 

194:15,16 196:10 

238:6 242:19 250:11 

253:11 264:14 287:8 

328:14 359:13 400:7 

444:8,21 

Steve's 363:10 

stewardship 25:22 

26:19 27:4 64:4 92:21 

172:10 

stick 22:20 

sticks 24:2 

stimulation 69:14 

stirred 393:6 

stock 151:17,18 208:2 

234:5 380:8,19 

stocking 445:16 

Stone 153:6 

stop 6:6 91:4 120:6,9 

120:16 121:7,16 

253:7 270:19 372:2 

381:14,19,20 382:11 

384:12 388:15,18,21 

395:5 398:2 

stopped 83:6 

stopping 387:10 

store 30:22 298:15 

stores 298:17,19,21 

stories 287:19 

story 113:12 242:12 

straits 229:14 

strategies 24:9,11 

55:12 

strategy 32:13 

Strauch 58:8 62:10,13 

62:16,19 66:9,15 

67:17 68:12 70:2,9 

71:14 72:9 73:7,14 

74:11,16,18 75:2,16 

Straw 270:5 

strawberries 215:11 

284:1 285:4 

strawberry 168:11 

215:12 

Street 1:9 

strength 82:7 

strengthened 103:18 

strengthening 60:19 

202:1 409:19 

strengthens 373:4 

stress 65:4 206:6 208:8 

261:7 307:14 310:12 

311:12 

stressful 310:4 346:5 

stretch 256:18 

strict 83:21 159:10 

strictly 345:9 

strikes 436:11 

striking 210:8 

strip 99:14 

stripping 142:4 

stroke 167:20 

strong 18:16 193:15 

214:20 273:15 324:6 

351:15 378:16 381:7 

strongest 185:9 

strongly 57:4 98:6 

407:8 

struck 101:14 310:13 

334:11 

structural 177:14 181:6 

structure 181:12 

253:19 400:13 

structured 73:17 

struggle 61:9 83:19 

95:17 329:2 337:12 

429:5 

struggles 80:18 355:15 

struggling 80:11 

215:10 218:15 338:6 

stuck 249:22 250:6 

346:18 442:20 445:12 

studies 127:11 134:11 

139:3 215:5 224:17 

263:12 

study 144:20,22 145:21 

254:1 290:1 301:10 

349:12 

studying 63:12 144:3 

stuff 188:15 190:14 

248:9,11,14 369:3 

370:3 395:19 398:12 

stumbling 273:10 

stylet 193:22 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
490 

sub-ingredient 263:22 

subcategories 377:3 

subcategory 263:17 

subcommittee 3:3,11 

3:14 4:8,8,10,10 35:1 

35:5 40:1,14 80:18 

85:22 93:13,21 162:7 

162:9 164:6 183:12 

184:17 204:10 207:18 

233:19 244:18 246:14 

304:1,21 306:5 313:7 

315:9 317:15 319:2 

319:15 320:21 324:18 

350:14 351:9 354:1 

358:16 361:8 363:2 

364:19 368:15 371:11 

373:17 374:6 375:3 

375:18 376:1,3,15,18 

377:18 385:15,19 

387:15,19 392:8 

394:14 395:21 396:1 

400:1,20 405:9 

418:20 432:21 441:19 

441:20 

Subcommittee's 86:17 

204:8 205:9 206:21 

Subcommittees 33:10 

39:10,20 244:19 

subgroup 102:4 

subject 8:6 16:17 156:7 

169:3 347:7 348:20 

365:3 379:6 387:17 

420:2 422:13 

submission 133:10 

submit 39:20 110:14 

111:2 270:7,18 

274:20 

submits 275:13 

submitted 8:19 21:18 

54:8 94:14 131:20 

140:7,10 155:7 

213:21 249:10 371:3 

372:1 383:1 

subsequent 317:2 

subsequently 36:14 

38:5 

subset 321:1 

substance 185:22 

216:22 237:11 246:18 

246:22 429:11 434:4 

434:9,11,15,21 

435:11,15 

substances 3:17 

162:15 163:1,3,13,16 

170:4 236:9 244:19 

244:22 245:2,5 

287:13 362:4 364:20 

365:3,12,15,20 366:1 

366:5,7,11,17 382:18 

407:10 408:5,14 

428:19 433:12 437:11 

substitutes 24:17 

substitution 51:4 

subtract 380:20 

success 116:8 154:11 

169:7 327:20 

successes 327:17 

successful 154:9 161:6 

204:13 

successfully 139:8 

191:20 

succinct 44:9 185:5 

sudden 188:7 341:4 

346:7 

suddenly 264:22 

359:22 429:17 

Sue 1:13 35:17,17 

47:13 67:9 69:20 71:5 

108:20 119:21 145:11 

194:15,16 203:4 

250:11 252:8 270:22 

367:7,8,9 368:20 

376:15 400:19 416:14 

416:15,16 430:8,18 

suffering 260:7 

sufficient 9:10 222:7 

suffocate 173:19 

sugar 240:22 404:9 

suggest 22:20 28:12 

118:13 136:1 151:2 

207:22 392:8 

suggested 94:3 149:18 

245:9 381:1 

suggesting 11:15 

suggestion 42:11 94:8 

133:12 134:18 135:20 

150:22 308:3 330:20 

350:4 

suggestions 4:17 39:6 

94:15 201:20 205:15 

349:6,9 399:12 

suggests 115:13 

suitable 154:12 

suitcase 448:20 

suited 322:11 

sulfate 435:13 

sulfur 197:7,8 305:8 

sum 269:19 

summarize 59:4 

summarized 124:15 

summary 3:13 321:7 

351:12 353:6 370:13 

377:20 433:19,19 

437:6 

summation 376:18 

377:15 

summer 24:4 42:13 

123:6 128:19 161:5,7 

319:4 321:13 441:2 

446:7 

sun 235:15 

sunlight 69:12 176:18 

194:4 

sunset 3:17 21:9 32:20 

59:6,20 91:7 92:1 

97:22 109:18 110:12 

111:3 184:2 211:14 

240:16 245:3 247:1 

261:4,10 364:22 

373:7 401:4,6 433:11 

441:4 448:7 

sunsets 432:5 

sunshine 347:19 

Super 437:2 

super- 269:8 318:22 

super-close 412:11 

super-cool 154:16 

super-ovulation 318:2 

supertanker 269:10 

supplement 72:18 

97:21 186:3 235:15 

235:19 443:6 

supplemental 84:1 

159:16 

supplementation 63:3 

66:17 68:18 70:14 

71:18,19 75:5 

supplemented 25:5 

supplements 73:19 

185:20 186:3 

supplier 8:2 25:19 27:2 

27:8 168:8 344:14 

352:14 

suppliers 12:18 84:18 

117:14 118:14 123:20 

171:15 204:21 208:6 

352:10 

supplies 61:2 65:16 

83:11 127:16 

supply 26:2 29:11 30:6 

30:17 43:13 87:4 

96:10 99:19 100:2,8 

102:22 103:11 117:1 

160:18 161:2 179:9 

224:17,19 228:14 

229:13 248:2 271:12 

346:3 349:3,4,8 350:8 

394:16,19 399:2 

439:12 440:20 

supplying 66:3 

support 13:12 23:20 

25:2 26:5 29:18 30:11 

31:8,21 32:1 33:20 

53:14 65:16 70:21 

92:4 101:21 103:14 

117:3 176:14,20 

186:5 201:21 202:11 

202:20 204:7,7 205:9 

205:14 207:17 212:17 

213:22 214:10 228:22 

243:16 244:18 265:3 

329:22 336:8 405:8 

438:12 

supported 9:4 229:5 

307:2,21 428:22 

439:18 

supporting 51:12 

213:17 216:17 237:19 

237:20 281:18 364:13 

364:14 

supportive 346:15 

351:13,19 352:8,9 

supports 57:4 93:4 

184:10,16 185:20 

229:1,12 

suppose 71:6 267:11 

358:10 

supposed 191:18 

289:16 382:20 

surface 15:1,1,6,7 

215:18 216:6,9 

291:10 293:2,5,15 

294:12 296:15,19 

surfaces 56:12,19 57:2 

214:12 294:1 437:15 

surfactant 440:4 

surprise 77:21 300:15 

364:15 

surprised 83:2 281:16 

survey 163:14 

survive 193:15 

survivor 232:15 

sustain 82:7 419:14 

sustainability 92:15 

93:4 223:16 326:14 

sustainable 25:21 

43:19 92:21 93:5 

133:1 134:8 135:18 

142:17 143:16 153:22 

280:22 

SWAFFAR 1:20 11:19 

45:11 66:10 178:10 

178:15 179:1,7,13,20 

208:21 209:14,19 

210:2 228:12,18 

274:7 312:8 314:12 

361:11 362:11 405:20 

415:14 418:2,5 

419:10 422:12 424:16 

424:22 425:2,16 

426:1 428:8 430:9 

438:19 440:16 441:3 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
491 

441:7,18 445:7 

swamped 271:19 

swamping 269:12 

Swartwood 397:2 

sweeping 278:4 

sweet 307:22 

sweetener 411:20 

swimmingly 418:12 

switch 286:9 

switcheroo 175:16 

Switching 185:16 

synonym 311:9 

synthetic 66:17 70:7 

72:12,19 78:18,22 

79:5 80:11,13,15 

81:20 84:6 126:17 

127:2,2,17,20 156:6 

157:1,6,21 158:16,19 

159:11 169:2 184:20 

206:13 236:13 261:18 

262:1 265:16,21 

268:2 288:1,7 403:6 

416:21 417:8 434:3 

434:14 437:11 442:6 

443:14,17 445:13 

synthetic/non-synthe...

264:21 

synthetics 157:18 

syrup 204:3 404:9 

system 10:13 57:21 

63:15 65:1 76:10 87:6 

99:1,21 101:12 108:2 

110:7,14 116:17,19 

117:20 145:17 148:11 

149:19,19 153:10 

154:11,16 155:19 

156:3 177:16,18,19 

181:6 182:6 184:8 

185:18 193:12 199:19 

245:4 246:6,12 

248:13 252:7 254:15 

254:20 278:12 282:21 

283:2 284:13 286:13 

329:20 330:17 332:15 

332:18 345:17 370:4 

375:10 380:9,22 

385:4 394:15 397:6 

397:12 398:1 421:22 

systems 13:14 107:18 

206:20 225:14 248:5 

249:7 252:1 282:13 

284:10,10 286:2,18 

288:7 299:2 329:7 

385:2 397:16 

systems-based 442:8 

systems-oriented

372:21 

T

table 12:19,22 13:4 

103:6 210:19 247:10 

289:7 305:16 343:18 

370:11 

tackling 61:7 320:19 

tail 361:6 

taken 150:15 151:13 

195:7 321:8 342:16 

355:2 376:20 389:19 

440:7 

takes 39:11 41:1,5 43:5 

47:18 100:3,5,18 

197:22 226:21 288:9 

Talbot 230:18 235:11 

239:18,20,22 

talk 11:20 16:5 18:4 

20:1 27:12,13 45:12 

59:17 65:17 66:12 

112:3 118:21 131:6 

140:17 143:16 165:3 

176:6 186:22 218:4 

239:21 242:11 266:19 

268:20,20 271:16 

280:14 295:6,8 332:9 

392:20 395:21 397:19 

423:5 427:7 439:14 

441:19,20 

talked 15:16 72:2 

285:14 320:11 331:12 

385:20 395:17 

talking 14:11 21:21 

47:15 67:14 78:18 

122:14,21 140:18 

147:20 266:4 267:7 

305:11 334:14 348:20 

349:18 382:15 446:17 

talks 67:11 427:10 

tall 125:20 

tank 190:13 

tanker 269:9 

tape 164:10 

targeted 130:9 321:21 

targeting 378:12 

tariff 378:18 383:15 

384:7 386:18 411:1 

tartrate 305:9 

task 34:6 42:16 43:1 

64:6 98:12,20 264:8 

282:4 301:4 322:5,10 

327:2,10 330:22 

340:5 350:6 407:2 

442:9 447:16 

tasks 191:6 319:5 

tasted 171:16 

tastes 168:11 

taught 403:13 

taxonomy 31:17 32:1 

TC 380:16 

teach 41:10 

team 62:17 133:4 

143:12 145:21 305:17 

305:19 391:1 

teat 375:4 438:22 

439:21 440:11 

technical 8:21 10:7 

19:16 20:14 21:9,14 

46:1,3,6,7,14 47:2 

62:17 93:12,19 96:22 

155:16 156:7 202:15 

205:10 206:12 245:1 

363:13,22 364:3 

367:22 368:5 370:19 

371:5,9 435:10 

438:10,11 

technicality 429:22 

technically 317:11 

406:17 

techniques 225:18 

307:4,7,11 308:5 

309:4 

technologically 397:14 

technologies 139:13 

198:10 

technology 104:9 

221:12 395:19 396:11 

technology-based

104:14 

teeth 108:18 

tell 113:12 125:14 

129:13 161:10 193:9 

198:4 243:12 

telling 370:20 391:5 

422:18 

temperature 235:21 

238:1 

template 46:6 

tempranillo 199:10 

tempted 361:3 

ten 32:19 48:12 80:4 

125:6 127:9 135:15 

137:9,15 251:15 

333:17,18,19 338:7 

372:14 445:22 

tend 84:11 107:10 

403:18 

tendency 326:7 

term 23:4 88:13 185:7 

219:9 251:12 318:22 

terminology 35:6 

425:20 

terms 13:8 14:14 15:3 

22:15,20 43:7 84:6 

88:17 99:15 124:11 

124:14,20 136:17 

145:3 154:5 158:14 

159:6 161:13 229:5 

255:3 264:10 275:11 

282:21 305:15 322:7 

325:14 327:16 361:1 

362:18,20,21 369:20 

373:14,17,18 384:22 

397:21 435:3 

terrestrial 225:12 

test 79:15 84:15,20 

116:21 117:4,5,6,8 

342:17,18,21 352:15 

352:16 

testament 247:16 

tested 84:19 161:4 

246:10 435:13 

testified 170:1 

testimony 136:5 

testing 61:5,15 76:10 

76:14,15 77:5,11 

78:11 83:9 99:7 

117:16 132:6 161:7 

212:6 341:20 342:15 

343:1 344:4 345:8 

347:4,9 381:3,3 

tests 99:14 222:9 228:8 

Texas 58:10,11 349:17 

text 177:15 

textiles 254:8 

thankful 120:2 

thanking 153:19 305:15 

thankless 297:12 

thanks 6:13 23:10 32:7 

35:5 62:17 69:21 

108:18 109:2,6 132:8 

161:21,22 166:11 

190:1,17,20 193:9 

210:13 250:12 260:16 

271:1 272:3,4 280:20 

290:19 306:6 376:1 

399:11 428:6 444:21 

theme 52:18 72:6 

227:10 

theoretically 193:14 

thermometer 195:9 

they'd 49:21 209:11 

thin 198:12 

things 18:22 20:3 27:8 

39:10,11 44:17 77:14 

84:17 101:14 140:18 

145:19 149:17 151:7 

170:15 171:7 180:14 

180:17,18 186:20 

188:5,13 191:9,16 

192:9,15 194:11 

198:7 210:9 226:7,8 

227:12 232:18 241:21 

243:1 248:16 249:22 

250:8 251:17 264:19 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
492 

270:11 271:17,20,22 

272:2 275:1,21 277:8 

280:9 281:2,21 283:1 

283:6,21 303:3,4 

308:18,19 329:13 

333:19 335:12 361:22 

362:6 366:18,20 

368:6 369:10 372:16 

372:22 373:5,6 

375:13 388:14 391:1 

391:11,19 393:17 

395:10,22 396:4,12 

399:21 440:8 447:1 

447:13 

thinning 194:12 197:22 

198:12,15 199:6 

third 8:5 128:17 177:13 

181:17,18,20,22 

189:7 196:1 240:2 

241:11 279:20 337:1 

398:22 448:10 

thorough 84:2 201:14 

203:10 

thoroughly 246:9 

Thorvin 140:8,9 

thought 27:15 36:17 

123:3 124:14 137:9 

137:11 160:2 195:5 

254:21 258:6 325:14 

326:7,8 327:1 328:16 

330:4,22 340:13 

341:13 347:20 349:5 

350:18 351:6,13 

365:11 376:5 395:9 

444:12 

thoughtful 33:5 43:20 

385:14 

thoughtfully 348:20 

thoughts 39:14 156:19 

168:14 198:1 254:18 

272:11 320:22 321:6 

324:20 326:17 336:13 

348:16 

thousand 81:17 411:4 

thousands 33:2 

threat 269:9,11 270:16 

270:20 

threatened 108:17 

three 5:19 6:2,8,15 9:6 

45:1 53:2 67:4 73:4 

79:7,10 82:11 97:3 

99:8 100:5 114:13 

127:3 135:9 177:4 

187:21 196:3 212:21 

224:6 230:3 238:15 

242:12 277:10 287:10 

287:12,22 288:3 

289:15 290:2,17 

300:9 302:9 341:2 

346:8 372:14 392:7,9 

393:5 395:6 420:3 

428:21 430:21 431:9 

thresholds 340:8 

344:21 

thrive 70:18 

thrives 69:11 

thriving 112:13 

throw 48:6 279:1,4 

425:20 

throwing 339:16 

thrown 174:6 181:22 

throws 48:2 443:19 

thumb 68:2 

thumbnail 405:10 

THURSDAY 1:7 

tie 42:14 

tied 65:3 115:14 380:7 

384:1,1 

ties 57:15 64:19 

tilapia 26:7 

Tilth 231:2 379:4 

tilting 260:14 

time-consuming 30:10 

timely 206:5 305:12 

timer 5:21 6:6 

times 10:13 13:4 

123:21 127:9 136:8 

182:5 187:21 188:13 

212:21 295:16 297:11 

310:3 316:16 327:5 

344:21 358:3 372:14 

379:13 380:1 382:13 

407:21 430:4 436:3 

timing 363:12 371:20 

372:5 

Tina 279:18 280:17 

tipping 180:10 

title 98:10 388:19 

tobacco 197:20 

today 4:6 5:8 7:21 

21:21 22:11 23:19 

53:22 54:10 58:13 

63:2 65:18 66:1 69:9 

73:9 85:15 86:5 97:2 

108:16 109:15 115:7 

126:9 128:15 153:10 

162:2,21 166:18 

172:6 177:6 180:7 

182:14 184:1 186:22 

191:5 192:3,19 204:6 

206:2 211:2 224:6 

232:15 239:21 240:8 

240:14 261:3 283:17 

283:19 304:18 333:16 

335:19 349:17 383:4 

401:1,6 430:7 442:2 

448:8 

today's 85:19 

toddler 263:21 

toddlers 266:5 

told 158:3 221:5 382:12 

tolerance 204:11 340:9 

Tom 1:15 14:7 95:15 

96:14,15 118:20 

217:19 228:11,19 

260:8,16 264:4 266:2 

313:21 336:11 338:18 

351:10 353:21 362:10 

367:12 368:20 370:16 

385:17 392:6 398:21 

410:14 412:16 416:2 

429:2 431:15 441:7 

Tom's 390:14 399:20 

tomorrow 432:18,20 

448:19 

ton 19:3 338:4,10,12 

339:2 395:5 

tonight 231:2,7 291:3 

tons 127:7 146:2,3,8,10 

411:4 

Tony 177:5 

tool 154:16 204:14 

205:7 216:17 233:14 

240:12 241:16 242:7 

272:6 297:21 316:14 

318:14 393:10,13 

404:13 

toolbox 45:15 130:16 

242:7 243:11 

tools 45:15,21 46:3 

54:9 56:18 57:5 104:5 

105:20 153:8 183:8 

201:5 240:6,15 242:8 

360:4,5 392:22 

top 25:13 66:21 77:9 

97:2 164:13 187:6 

241:11 383:5 409:21 

topic 21:2 33:21 34:3 

35:2,7 37:15 98:14 

99:8 132:18 137:4 

262:7 321:10 323:19 

324:20 328:18 354:17 

360:3 378:9 403:16 

topical 219:4 418:15 

topics 3:4,12,15 33:19 

97:4 224:6 276:20 

320:13,22 328:12 

tops 12:20 13:1 

toss 14:10 

total 135:7 238:15 

412:1 

totally 84:3 120:16 

122:15 198:4 277:1 

350:12 

touch 43:10 210:1 

428:14 445:11 

touches 399:5 

tough 22:10 238:21 

tougher 431:9 

toxic 212:1 237:4,13 

294:22 295:5 296:22 

toxicity 212:6 245:10 

370:8 

toxicological 435:9 

TR 10:21 46:9 84:1 

159:16 160:6 355:21 

357:7,19 358:4,14,22 

359:1 361:1 362:7,15 

362:19,21 363:4,12 

365:9 367:6,11,13 

373:19,19 374:17 

trace 26:22 30:8 184:20 

traceback 269:22 

traces 338:12 

track 47:22 48:1,14 

177:16,18 181:5 

182:6 281:7 380:21 

420:1 

tracked 411:2 

tracking 104:10 128:18 

394:6 

tract 408:12 

trade 32:11,22 43:2 

97:1,6 102:18 104:11 

168:7 176:13 212:14 

224:7 225:2 254:2 

255:16 257:4,5 

378:13 380:12 385:14 

trademark 271:18 

tradeoff 337:21 

trading 224:22 225:5 

traditional 65:21 86:8 

216:16 237:1 

trail 116:5 

train 270:14 

trainer 354:22 369:5 

training 62:2 107:4 

120:21 248:1,13 

271:14 291:7 295:9 

295:10 398:5,21 

399:14 

trainings 355:3,4 

trans-sects 145:22 

transaction 115:13,17 

116:12 380:9,15 

transactionary 115:22 

transcript 374:16 

transfer 3:6 314:20 

315:19 316:18 319:13 

377:5 

transfer-specific

117:20 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
493 

transferring 336:5 

transformed 349:21 

transient 219:16 

transition 53:3 177:21 

181:12 287:10,16,22 

289:14,16 290:2,17 

transitional 181:18 

transitioned 86:7 

transitioning 36:4 

50:11 

transparency 3:8 30:1 

30:11 60:20 90:22 

98:8 204:9 224:19 

339:10 342:14 345:5 

348:3 

transparent 9:1 341:21 

344:15 

transplant 202:10 

transplanting 153:10 

154:10,15 

transplants 202:6 

transport 257:8 

transposon 307:5 

309:7 

transposons 307:3,9 

307:13,19 308:3,10 

309:2 310:3,12 311:9 

311:11 314:15 425:19 

travel 106:17 

treated 215:3 219:3 

407:10 

treating 439:4 

treatment 71:1 234:16 

418:15 

treatments 192:8 219:1 

434:6 

tree 54:10 55:10,15,18 

55:22 187:6 241:11 

261:15 265:4,19 

trees 114:16 187:15 

189:15 241:11 242:15 

242:16 261:9,12 

264:17 

trellis 193:12 

tremendous 35:2 

113:11 197:19 232:21 

trial 82:19 

trials 301:12 

tricky 422:13 

tried 84:10 140:14 

148:12 

tries 323:17 

triple 182:1 

tropical 410:19 414:4 

414:20 

trouble 417:7 

troubles 172:14 

TRs 354:11 

true 193:17 223:16 

267:9 285:3 388:16 

398:15 

truly 19:1 344:2 355:17 

398:14 412:22 443:13 

445:20 

trust 52:11,12 91:21 

275:22 276:2 431:13 

try 5:6,7,11 19:8 22:8 

44:8 49:4 63:19 74:8 

81:4 110:10 125:6 

126:6 136:6 139:1 

140:2,15 142:20,21 

142:22 143:11 144:16 

148:14 150:10 192:12 

193:21 239:17 279:17 

280:10 287:1,19 

322:11 327:2,3 340:6 

342:6 347:21 373:9 

386:6 401:10 408:3 

441:16 

trying 16:11 18:8 27:19 

62:20 73:1 83:5 158:8 

192:13 199:18 221:11 

260:14 286:11 287:7 

289:22 290:1,16 

309:18 323:11 328:15 

340:13 342:5 355:12 

367:3 374:7 380:2 

386:1,2 387:9 395:16 

397:9 398:12 422:17 

425:12,18 436:8 

443:17 446:13 

Tucker 2:16 38:12 

40:12 47:16 107:4 

124:4 125:3 176:19 

232:7 248:7,19 297:9 

367:10 382:22 386:6 

389:2,5 395:18 

409:18 

Tucker's 208:7 

tulsi 443:1 444:3 

tuned 53:13 

tunnels 172:17 

turkey 302:11,12 

turkeys 302:10 

turn 65:7 69:15 156:22 

173:20 306:4,12 

401:14 

turnaround 44:14,21 

turned 444:11 

turning 271:2 306:7 

turnover 67:20 

twice 215:15 243:21 

346:14 406:21 413:4 

twists 106:13 

twisty 57:15 

two 6:12 9:1 14:8 44:20 

44:20 45:1 52:21 

61:10 66:22 79:9,13 

81:5 82:11 83:4 89:6 

89:7 98:7 100:2 103:9 

112:20 127:6 135:9 

151:16,18 163:3 

166:18 173:8 177:16 

177:18 181:5 182:6 

204:6 205:2 223:9 

226:8,18 232:18 

235:17 265:7 266:3 

277:10 279:20 297:3 

305:7 323:3 327:21 

330:19 333:11 341:2 

362:14 376:19 395:5 

403:15 407:5 408:22 

425:2,3 428:21 

430:20,22 431:4,5 

438:19 

type 6:22 28:1 110:13 

116:9 122:9,17 130:4 

148:11 150:5 264:12 

318:6 342:13,22 

347:4 420:22 422:7 

types 10:17 79:7 139:1 

156:4 363:15 

typical 152:4 245:11 

438:2 

typically 73:5 342:12 

415:6 422:6 

U

U.N 396:18 

U.S 54:16,22 58:13 

59:14 60:5 65:14 

74:21 103:16 127:8 

127:10 215:6 225:1,7 

273:6 397:22 406:3 

410:5 411:4 412:6,13 

412:19 414:5,8,11,13 

UC 301:10 

ultimate 288:13 

ultimately 88:15 165:13 

ultraviolet 193:15 

unable 214:18 

unacceptable 34:18 

201:3 

unaffiliated 111:18 

212:11 

unanimous 48:20 

312:22 438:12 

unannounced 117:16 

unanswered 43:10 

unattributed 211:22 

unavailable 98:4 292:4 

uncertified 29:9 

Uncle 70:15 

unclear 163:9 

uncompetitive 414:19 

unconvinced 8:16 

undercut 142:4 

undercutting 391:14 

underestimate 396:10 

undergo 245:3 

undermined 225:9 

underpinned 405:10 

understand 11:7 23:1 

28:4 41:20 46:16 

72:19 74:20 83:13 

88:17 132:2 136:9,20 

137:22 144:11 146:1 

168:22 207:14 217:6 

247:13 290:1 299:19 

333:15 340:6 354:12 

355:7 367:2 388:15 

393:19 394:11 405:22 

412:18 428:3 442:1 

understanding 10:21 

28:7 43:16 61:13 

78:19 114:6 147:7 

169:17 206:19 265:14 

299:10,13 326:3 

362:18 393:17 394:1 

396:3 

understands 56:3 

91:22 

understood 41:22 

66:15 68:12 357:22 

375:8 

underway 98:5 

unfair 288:14 

unfavorable 118:6 

unfinished 233:5 

unforeseen 107:6 

unfortunately 12:3 37:4 

59:10 60:1 151:9 

177:14 233:4 303:2 

336:17 

unfounded 211:22 

Unger 223:6 226:3,4 

228:17 229:3,6,9 

230:8,13 

unified 38:15,16 

unintended 67:5 343:2 

345:18 347:5 

unintentional 64:21 

union 402:20 409:12 

unique 8:18 62:6 112:7 

136:12 138:1 263:19 

298:2 336:2 357:13 

357:18 399:3,7 

uniqueness 8:17 9:2 

11:20 23:2,5,6 357:9 

357:10 361:21 369:8 

united 1:1 75:7 77:17 

86:5 104:22 112:14 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
494 

114:7 200:9 223:22 

248:22 302:8 408:5 

universities 102:8 

University 14:15 24:10 

24:16 44:22 301:20 

unknown 87:16 

unparalleled 86:11 

91:17 

unrealistic 134:14 

unreasonable 257:12 

unregulated 334:19 

335:7 

unreliable 31:16 

unsprayed 196:12 

untrue 212:2 

unverified 116:20,20 

upcoming 304:22 

update 301:8 315:18 

updated 383:18 

updates 201:22 

updating 31:13 

uphold 51:8 

upper 134:22 303:8 

340:15 342:2 402:9 

408:7 

upset 348:22 

upstairs 448:16 

uptake 237:19 

urge 32:1 33:11 49:2 

51:7 52:22 53:9 58:14 

246:15 

urgency 280:7 

urgent 277:16 

urging 105:2 

USDA 33:13 37:15 

39:22 40:16 53:12 

98:2 105:12 176:21 

177:7 203:20 224:15 

225:9 249:2,12 251:3 

254:22 255:4 258:1 

259:15,18 260:15 

273:22 299:10,12,20 

302:8 392:12,18 

410:7 

USDA's 48:21 250:1 

USDA-appointed 98:20 

useable 80:16 

useful 80:21 264:17 

272:5 283:17 370:15 

375:11 386:21,22 

390:9 410:9 

user 82:3 

users 358:19 

uses 12:19 25:4 155:12 

155:13 198:18 293:15 

301:21 411:19 434:19 

usual 201:11 203:9 

401:7 433:21 

usually 326:10 

utensils 437:16 

utilization 65:12 

utilize 336:14 

utilized 104:17 

utilizing 25:21 104:5 

229:16 

uttered 233:2,4 

V

vaccination 425:3 

431:11 

vaccinations 430:16 

vaccine 178:16 207:12 

209:10,16 422:14,15 

423:5,7 424:17 

425:11 428:11 429:11 

430:10 

vaccines 3:16 34:8,14 

34:17,19 35:3,8 

178:18 182:16,17,21 

183:2,13 200:10,14 

200:15 201:8,12 

206:3,22 207:1,3,7,8 

207:15,19 208:6 

209:1,2,3 270:13 

419:20 420:7,11,13 

420:14,15,17,19 

421:14,20,20 422:1 

423:2,8,14,17,20,22 

424:4,7,13,14 426:8 

426:10,15 427:3,6,11 

427:21 428:3,4,16 

431:1,5 

vacuum 43:4 

vague 174:16 

validate 292:16 

validated 117:7 215:5 

validation 116:13 

validity 327:9 

valley 27:11,19 28:15 

193:16 286:5 300:21 

442:18 443:5 

valuable 33:8 89:3 

216:19 361:2 370:6 

370:14 444:13 

value 33:4 69:2 74:8 

89:17 93:10 107:11 

223:17 334:8 369:21 

value-added 93:8 

values 106:15 107:10 

van 230:17 231:21 

235:8 239:17 279:14 

Vandenberg 186:14 

190:22 191:1,2 

193:11 194:10,14,21 

195:15 196:15,18 

197:4,8,12 198:3 

199:21 200:2 

vaporize 403:21 

variation 79:11 

varieties 61:12 193:18 

194:1 199:9 204:22 

variety 24:10 184:9 

214:17 

various 10:22 100:19 

122:18 276:20 328:19 

337:22 363:15 420:6 

varroa 403:9 410:10 

412:22 413:13 

vast 259:21 288:1 369:3 

vegetable 154:5 202:10 

206:7 388:4 

vegetables 24:18 

170:14 

vegetarian 185:19 

vein 60:17 

velociraptor 70:11 

velociraptors 70:2 

ventilation 251:21 

283:21 

verbal 255:1 

verbally 379:7 

verification 8:3 30:7 

115:19 165:18 200:18 

212:2 

verified 237:2 

verify 26:3 27:6 30:18 

226:21 379:14 

verifying 166:8 323:10 

Vermont 203:19,22 

204:1,19 205:22 

206:8 207:17 

version 396:20 397:13 

versus 56:18 78:21 

124:21 138:19 293:20 

300:16 333:3 365:6 

vet 39:12 58:1 208:5 

veterinarian 62:20 

434:7 

veterinary 63:7,17 69:5 

270:14 

vetted 108:10 281:3 

viability 154:6,7 

viable 84:21 157:20 

160:16 161:14 165:15 

429:12 

vials 83:4 

vice 1:12 96:21 297:16 

video 172:16 

view 63:19 71:21 81:22 

93:14 142:1 172:20 

191:14 193:12 404:19 

viewed 97:13 

vigilance 169:16 

vineyard 191:4 192:7 

193:1,2,3 194:7 

196:20 198:6 

vineyards 192:20 

193:11 196:4,15,17 

vinifera 192:2 195:19 

violate 163:4 

violations 177:20 

virgin 173:1 206:9,12 

206:14 

virtue 68:4 

viruses 189:1,3 

visibility 384:6 

visited 17:1 61:22 

visits 123:5 

vital 30:2 56:15 57:5 

439:4 

vitality 410:12 

vitamins 184:3,7,8,11 

184:19,21,22 236:10 

261:5 262:6,17 

266:14 

Vitis 192:2 195:19 

vitro 307:4,6,10 308:4 

308:10 309:3 311:1 

317:13 425:22 

VOF 205:22 206:6 

207:6 208:8 

voice 33:13 53:11 63:14 

202:21 

voiced 37:9 118:4 

volume 60:15,18 116:2 

volumes 271:9,10 

voluntarily 103:4 

115:17 

voluntary 25:13 96:7 

118:11 345:9 

volunteering 247:2 

volunteers 319:22 

vote 13:22 28:16 48:20 

110:8 155:15 156:2 

158:12 211:3,16 

213:5 243:20,22 

268:18 309:10 310:14 

311:19 312:22 313:19 

405:7,11,16,21 406:7 

415:15 416:1,13 

418:8 

voted 153:18 238:19 

308:9 

votes 211:5 312:21 

314:13 417:3 418:1 

419:16 

voting 211:9 415:21 

416:17 418:21 433:13 

vulture 288:15 

W

wait 4:21 312:5 390:1 

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495 

waiting 44:2 145:9 

231:16 267:20 279:15 

432:6 

Walden 247:8 260:20 

260:21 261:1,2 264:7 

265:5 266:9 267:3 

walk 41:5 

Walker 102:15 106:4,5 

106:6 109:2,6 

walking 235:10 

wall 113:20 

wandered 436:15 

wanted 11:5 20:12 

71:10 111:20 112:3 

113:3 114:13 115:12 

120:6 122:19 160:3 

178:21 180:7 190:16 

210:6 250:18 260:9 

281:1 289:6 301:8 

321:20 346:17 367:10 

371:18 374:15,17 

380:13 395:8 421:11 

429:13 

wanting 83:20 179:2 

398:8 428:11 

wants 78:12 182:12 

224:5 253:6 409:14 

warmer 413:4 

wash 13:6 

washed 356:13 

Washington 1:9 54:3,6 

54:16 111:13 112:4,7 

112:12 113:4,20 

176:2,2 181:3 204:2 

240:2 

Washington's 448:12 

wasn't 158:4 159:19 

171:4,5 343:12 366:4 

393:5 412:15 418:9 

433:17 

wasp 188:8 

waste 126:16 129:10 

286:14 

watch 146:19 379:4 

water 12:14,15,16,22 

17:3 110:1 113:20 

126:12 191:22 197:13 

286:2 377:5 379:4 

438:4 

watermelon 239:2 

wax 408:18 

way 5:20 22:14 35:4 

43:20 70:20 78:4 

81:21 89:19 99:21 

133:14 140:1 142:2 

150:14 161:7 172:1 

182:18,22 183:3 

187:6 188:10,18 

195:1 198:13 235:1 

237:15 249:6,6 

261:12 263:14 265:22 

282:14,16 287:5 

290:14 296:1 302:14 

318:6 323:2,20 

337:12 344:8 345:11 

347:16 358:18 369:18 

375:11 377:20 380:21 

381:8 383:12 397:16 

421:12 428:11 429:1 

429:17 

ways 54:14 166:8 

168:14 283:4 324:13 

389:17 429:7 

weaken 262:19 

weakest 233:21 

wear 232:11 

webinar 5:3 87:3 

137:11 438:6 

webinars 213:22 218:3 

website 40:16 41:19 

355:14 

Wedge 299:7 

weed 154:22 

weeds 391:4 

week 13:5 83:6 272:7 

278:1 305:3,6 413:3,4 

413:7 

weeks 45:1 89:16 363:8 

371:22 

weigh 315:21 

weighed 315:20,22 

weighing 106:9 

weighs 48:11 

weird 437:3 

Weisman 166:14,15,16 

170:7 

welcome 4:4 32:4 65:14 

65:15,15 67:19 85:10 

109:6 164:22 169:13 

238:4 290:19 362:9 

413:21 

welded 256:10 

welfare 63:15 64:3 

253:7 

well- 9:4 194:3 

well-defined 144:18 

145:3 147:8 

well-managed 234:1 

well-regulated 135:13 

Wenatchee 240:2 

went 14:15 123:12 

125:9 178:17 182:9 

220:21 231:11 232:2 

240:4 348:8 376:11 

380:14 381:22 406:22 

448:3,22 

weren't 33:18 34:9 

Wesen 32:9 47:6,9,10 

49:18 50:13 62:10 

west 112:8 335:3 408:6 

western 113:17 208:14 

281:10 

Westmar 291:5 

whack 189:11 

whatsoever 219:20 

221:21 428:12 

whichever 134:1 

Whitney 125:12,22 

126:3,6,10 128:2,6,16 

129:10,18 130:1,8 

131:2,8,11,20 132:8 

whittling 361:21 

wholeheartedly 37:5 

wholesale 29:8 127:12 

wholesaler 297:15 

Wholesalers 7:18 379:5 

wholly 173:6 

Whoops 175:18 

wide 184:9 355:19 

410:20 412:5 

widely 33:22 109:22 

206:19 235:22 331:11 

436:1 438:22 

widely-accepted 86:21 

wider-ranging 277:4 

widespread 360:7 

wife 242:12 

wild 71:22,22 95:6 

136:14 323:21 331:2 

331:9 410:21 

wildly 134:19 

William 269:14 

willing 123:2 223:1 

Willows 23:16 28:21 

29:2,3 32:7 

willy-nilly 359:19 

wimpy 32:17 

wind 349:20 

winding 184:13 

windmills 260:14 

window 40:3 242:14,16 

wine 191:2 192:2 194:5 

winery 191:3 

wins 48:7 

Winston 200:5 203:14 

203:18 

winter 119:7 285:19,19 

446:6 

wiped 294:8 

Wisconsin 24:10 298:6 

Wisconsin-Madison

24:16 

wish 16:4 49:6 81:3 

118:9 133:18 198:17 

216:10 353:1 368:6 

375:8 

wishes 134:17 

wishing 4:18 

withdraw 437:6 

withdrawal 434:8 

withdrawn 227:14,22 

WODPA 176:1,10 

315:22 

Wolf 244:13,14 

wonder 18:5 19:1 20:4 

133:14 191:11 272:11 

423:1 

wonderful 62:14 114:15 

235:6 385:14 400:15 

wondering 27:21 42:17 

72:16 82:18 121:8 

145:12,14 180:13 

197:21 252:9 257:22 

258:10,20 319:7 

332:2 389:21 405:7 

441:15 

wonderments 90:5 

wood 76:16 79:8 

woods 340:15 

word 90:10 141:5 212:9 

212:10 234:3 308:5 

356:12 358:6,13 

366:12 411:15 

wording 96:1 308:3,7,9 

308:14 310:17,22 

311:8 429:7 

words 63:21 174:15,16 

176:20 233:2 308:6 

309:3 328:22 407:5 

448:16 

worked 103:10 106:11 

142:14 144:5,7,9 

147:22 148:13 264:20 

374:3 398:1 430:21 

worker 215:21 297:14 

workers 294:17 

workforce 292:12,13 

working 9:10,12 29:15 

31:22 34:3 39:3 47:18 

63:12 74:8 76:8 78:3 

90:21 98:12 100:7,22 

101:1 102:3,8 139:5 

147:14 148:5 156:4 

169:9 182:8 190:9 

193:19 217:11 223:18 

224:15 248:4 259:18 

265:3 269:13 276:3 

276:16,20 280:3,5 

283:10 291:3 294:16 

306:18 319:6 326:6 

326:19 344:11 350:6 

364:1 372:2 373:16 

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373:20 377:12 381:17 

385:3 389:11,12,22 

392:15 400:11 443:5 

445:20 

workload 269:5 

works 5:21 28:5 153:7 

187:7 190:14 258:21 

334:4 375:9,12 430:1 

world 42:6 61:8 93:6 

139:1 142:11,20 

187:11 192:3 218:12 

330:14 335:4 360:14 

398:1 402:21 429:14 

world's 196:20 273:2 

worldwide 91:14 

141:17 150:10 272:21 

worms 50:3 68:22 

187:18 423:14 

worry 329:15,18 

worth 39:19 112:16 

worthwhile 60:15 

254:12 368:8 

worthy 440:15 

wouldn't 12:1 72:20 

83:15 253:3 267:11 

267:12 278:12 279:6 

289:14 324:5 383:16 

407:17 

wound 219:8 

wounds 13:17 219:2,2 

279:11 439:1 

wowed 444:7 

wrap 415:13 

wrapping 83:15 

write 202:3 250:4 

write-up 100:17 238:7 

writer 172:2 

writing 95:21 377:20 

written 31:10 54:8 

58:18 59:12 60:3 

76:13 92:4 93:14,17 

94:2,14 109:16 120:3 

133:10 149:16 202:7 

210:12 213:20 233:8 

249:22 253:9 258:4 

268:17 280:2 283:18 

285:8 348:17 355:3 

420:10 427:1 429:1 

434:7 

wrong 76:2 284:13 

312:5 366:12 386:5 

418:9 

wrote 172:4 

WSTA 231:1 

WSU 188:2 

Wyard 91:11 96:18,20 

96:21 102:1 

X

X 168:11 337:6 

Y

yager 24:3 

Yakima 54:3 193:16 

Yay 167:18 

yea 301:3 

year 46:10 53:2 74:5 

108:14 112:9,16 

123:11 127:7 129:3 

151:19 155:7 177:21 

181:18,18 193:20 

257:10 284:6 286:5 

287:10,22 288:3 

289:15 290:2,17 

301:15 302:1 390:7 

390:22,22 414:4 

year's 110:12 

year-old 242:13 

year-round 414:10 

years 29:4 36:1 39:1 

56:10 63:11 68:1 80:2 

80:4 81:17 89:7,16 

97:16,22 103:9 105:8 

106:9 107:3 112:20 

113:14 121:4 135:14 

139:9 144:7 148:2,6 

148:11 166:22 171:11 

177:3,4 180:19 182:7 

186:21 191:21 197:13 

199:5 224:9 233:6 

241:3 248:10 250:7,8 

251:16 259:4 260:13 

268:7 277:11 280:4 

283:16 287:12 288:10 

297:13 299:8,18 

301:14 325:7 333:20 

334:3 340:21 364:7 

382:1 391:13 408:22 

435:17 445:22 448:13 

yellow 24:17 

yeoman 277:3 

yesterday 5:3 64:6,22 

65:18 67:13 68:14 

73:8,9,20 89:1 99:9 

100:4 101:10,15 

122:3 162:22 169:22 

177:5 180:8 242:12 

301:7 302:18 390:17 

390:20 396:6 

yesterday's 100:9 

yield 301:16 

yields 118:1 215:2 

young 50:5 82:12 258:1 

316:21 317:2 

Youngblood 176:10 

Z

zero 6:2 191:21 196:20 

213:1 246:10 269:19 

Zia 340:12 

zone 198:19 335:3 

407:11,13,15,16 

412:22 413:13 414:5 

415:1 

zones 268:4 334:14 

414:10,15 

Zoology 63:16 

0

0 312:22 314:14,14,14 

314:14 

1

1,000 17:4,5 112:19 

146:2,3,8 302:14 

1,300 114:10 

1,600 112:18 

1,800 412:2 

1,875 201:17 

1.1 345:3 

1.8 407:11,11,20 408:4 

1:45 230:21 

1:47 231:12 

10 112:11 117:3 185:17 

188:12 296:13,13 

321:4 

10.5 292:10 

10:36 125:9 

10:45 125:7 

10:50 125:10 

100 55:15,22 70:19 

112:8,9,10 188:19 

257:10 292:10 308:11 

357:1,3 443:12 

101.9 184:22 262:22 

107 263:4 

107.10 185:2 263:1 

107.100 185:1 262:22 

108.9 446:1 

11 63:11 432:4 

12 48:4 302:7 321:4 

419:17 434:10 

12,000 113:14 

12.5 292:8 

12:36 231:11 

120 223:20 

14 291:12 302:7 312:22 

314:14 341:1 418:12 

447:11 

15 82:9 188:12 212:10 

233:6 250:7 257:12 

259:4 299:18 333:20 

376:7 

16 32:18 373:13 

17 146:11 182:7 376:20 

170 96:10 146:10 

18 21:18 54:18 305:20 

343:13 376:8,20 

18th 87:4 

19 112:18 

1960 195:2 

1975 193:13 

1977 437:17 

1990 299:9 

1995 438:11 

2

2 184:16 185:5,7 282:8 

419:17 423:12 

2,000 113:15 

2,150 200:8 

20 22:8 44:21 82:9 

111:9 166:22 171:11 

175:6 195:10 292:8 

296:10,13,14 

20,000 446:18 

200 32:16 45:2 64:17 

77:7 204:1 292:11 

2002 435:18 

2003 140:19 

2005 167:1 

2007 181:16 182:9 

2009 35:4 240:4 

2010 167:1 278:20 

2012 185:8 233:12 

262:9,21 263:16 

266:22 267:4 

2015 21:9 39:2 93:11 

182:10 365:1 438:12 

2016 112:17 184:17 

2017 305:5 435:19 

438:12 

2018 24:6 25:5 103:13 

153:13 411:3 

2019 1:5,7 3:5 156:2 

306:14 313:6 435:11 

2019-2020 301:8 

2020 127:14 

2021 3:17 92:1 302:16 

433:11 

205.105(e) 420:16 

205.205 173:13 

205.236 35:22 

205.236(a) 36:3 

205.239(b)(5) 112:1 

205.601 162:10 

205.601(c) 164:16,21 

205.603 437:10 

205.603(a) 434:3 

205.603(b) 418:15 

205.605(b) 184:19 

185:21 

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30

35

40

45

497 

205.606 23:21 25:3 86:2 

86:18 91:6 

21 146:13 184:22 185:1 

262:22 

22 32:17 33:7 268:7 

23 411:3 

23,000 411:3 

1:7 23:22 44:7 

150:21 184:6 302:4 

26 186:21 

27th 167:21 

28,000 54:20 

3

3 421:3,5 422:21 423:11 

429:4 

3.0 224:8 

3.3 412:2 

3.50 341:6 

29:4 77:15 97:15 

268:7 291:16 292:4 

334:3 433:19 

300 112:16 

306 3:5 

31 38:3 

314 3:6 

320 3:7 

331 114:10 

339 3:8 

76:22 77:13,18,22 

82:5 

353 3:10 

365 414:3 

376 3:13 

4

4 184:16 

4.1.6 202:3 

4.2.1(b)(3) 202:4 

4.4.4 202:4 

4/3/2019 211:21 

4:27 376:8,11 

4:45 376:8 

4:47 376:12 

135:14 139:8 224:9 

255:11 

401 3:15 

419 3:16 

42 68:21 

433 3:17 

437 3:18 

438 3:18 

448 3:19 

297:13 

5

5 104:8 

5-log 15:5 

5,000 212:8 

5:37 419:22 

50 13:4 86:6 200:16 

257:9 

500 113:20 200:13 

202:10 295:19 296:2 

51 32:20 

515 1:9 

55th 4:5 

56 434:9 

6

6 202:4 

6:11 448:22 

6:30 448:15 

600 264:9 

600- 108:8 

602 162:11 

605(a) 169:2 171:8 

605(b) 262:1 

606 88:10,12 171:3,4 

229:20 

609 411:16 

64 108:9 

651(3)(b)(i) 173:10 

670,000 114:9 

68 233:18 

7

7 3:2 117:22 

7.8 25:7 

700 203:22 

8

8 115:13 

8:30 1:9 

8:32 4:2 

80 127:5 

80/20 181:16,16 

800 29:6 446:17 

85 96:9 112:14 195:13 

870 200:12 

872 212:9 

9

9 24:6 116:18 345:2 

9,000 33:1 

90 54:20 96:9 105:14 

295:18 296:2 411:5 

92 195:11 

93 195:11 

95 195:9,13 

Neal R. Gross and Co., Inc. 

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498

C E R T I F I C A T E 

This is to certify that the foregoing transcript 

In the matter of: National Organic Standards Board

Spring 2019 Meeting

Before: USDA

Date: 04-25-19

Place: Seattle, WA

was duly recorded and accurately transcribed under 

my direction; further, that said transcript is a 

true and accurate record of the proceedings. 

 ----------------------- Court Reporter 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 
1

 UNITED STATES DEPARTMENT OF AGRICULTURE

 + + + + +

 NATIONAL ORGANIC STANDARDS BOARD

 + + + + +

 SPRING 2019 MEETING

 + + + + +

 FRIDAY, 

 APRIL 26, 2019

 The Board met in the Courtyard Ballroom at

the Renaissance Seattle Hotel, 515 Madison

Street, Seattle, Washington at 8:30 a.m., Harriet

Behar, Chair, presiding. 

PRESENT 

HARRIET BEHAR, Chair

STEVE ELA, Vice Chair

SCOTT RICE, Secretary

SUE BAIRD 

ASA BRADMAN 

JESSE BUIE 

TOM CHAPMAN 

LISA DE LIMA 

RICK GREENWOOD 

DAVE MORTENSEN 

EMILY OAKLEY 

A-DAE ROMERO-BRIONES 

DAN SEITZ 

ASHLEY SWAFFAR 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
2 

STAFF PRESENT 

MICHELLE ARSENAULT, NOSB Advisory Board 

 Specialist, National Organic Program

DAVID GLASGOW, Associate Deputy Administrator, 

 National Organic Program

DR. PAUL LEWIS, Ph.D., Director, Standards 

 Division, National Organic Program

CLARISSA MATHEWS, Ph.D., National List Manager

DEVON PATTILLO, Materials Specialist, National 

 Organic Program

DR. JENNIFER TUCKER, Ph.D., Deputy 

 Administrator, National Organic Program; 

 Designated Federal Official 

ALSO PRESENT 

MARKUS FLURY, PhD, Washington State University

RAMANI NARAYAN, PhD, Michigan State University 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
3

 CONTENTS 

Livestock Subcommittee 

Magnesium sulfate. . . . . . . . . . . . . . . . . 5

(Parasiticide) Fenbendazole. . . . . . . . . . . . 6

(Parasiticide) Moxidectin. . . . . . . . . . . . . 8

Peroxyacetic/Peracetic acid. . . . . . . . . . . .10

Xylazine . . . . . . . . . . . . . . . . . . . . .11

Trace minerals . . . . . . . . . . . . . . . . . .14 

Vitamins . . . . . . . . . . . . . . . . . . . . .18 

Handling Subcommittee

Topics:

Proposal: Silver dihydrogen citrate. . . . . . . .25

Proposal: Pullulan . . . . . . . . . . . . . . . .55

Proposal: Collagen gel (casing). . . . . . . . . .64 

2021 Sunset substances review:

 Acids, Citric. . . . . . . . . . . . . . . .98

 Acids, Lactic. . . . . . . . . . . . . . . 110

 Calcium chloride . . . . . . . . . . . . . 112

 Dairy cultures . . . . . . . . . . . . . . 114

 Enzymes. . . . . . . . . . . . . . . . . . 117

 L-Malic acid . . . . . . . . . . . . . . . 118

 Magnesium sulfate. . . . . . . . . . . . . 121

 Microorganisms . . . . . . . . . . . . . . 123

 Perlite. . . . . . . . . . . . . . . . . . 133

 Potassium iodide . . . . . . . . . . . . . 135

 Yeast. . . . . . . . . . . . . . . . . . . 136

 Acid, Alginic. . . . . . . . . . . . . . . 142

 Activated charcoal . . . . . . . . . . . . 145

 Ascorbic acid. . . . . . . . . . . . . . . 147

 Calcium citrate. . . . . . . . . . . . . . 155

 Ferrous sulfate. . . . . . . . . . . . . . 156

 Hydrogen peroxide. . . . . . . . . . . . . 206

 Nutrient vitamins and minerals . . . . . . 207

 Peracetic acid . . . . . . . . . . . . . . 209

 Potassium citrate. . . . . . . . . . . . . 211

 Potassium phosphate. . . . . . . . . . . . 212

 Sodium acid pyrophosphate. . . . . . . . . 215

 Sodium citrate . . . . . . . . . . . . . . 216

 Tocopherols. . . . . . . . . . . . . . . . 217 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
4 

Handling Subcommittee

2021 Sunset substances review:

 Celery powder. . . . . . . . . . . . . . . 221

 Fish oil . . . . . . . . . . . . . . . . . 226

 Gelatin. . . . . . . . . . . . . . . . . . 230

 Orange pulp, dried . . . . . . . . . . . . 233

 Seaweed, Pacific kombu . . . . . . . . . . 242

 Seaweed, Wakame. . . . . . . . . . . . . . 246 

Biodegradable mulch film

 - Update on research . . . . . . . . . . . 172

Dr. Markus Flury

Dr. Ramani Narayan 

Crops Subcommittee

Topics:

Proposal: Allyl isothiocyanate (AITC). . . . . . 247

Proposal: Ammonium citrate . . . . . . . . . . . 265

Proposal: Ammonium glycinate . . . . . . . . . . 266

Proposal: Calcium acetate. . . . . . . . . . . . 276

Proposal: Strengthening the organic seed

 guidance April 2019. . . . . . . . . . . . 285

Discussion document: Paper (Plant pots and

 other crop production aids). . . . . . . . 298 

2021 Sunset substances review:

 Hydrogen peroxide. . . . . . . . . . . . . 314

 Soaps, ammonium. . . . . . . . . . . . . . 316

 Oils, horticultural. . . . . . . . . . . . 317

 Pheromones . . . . . . . . . . . . . . . . 321

 Ferric phosphate . . . . . . . . . . . . . 324

 Potassium bicarbonate. . . . . . . . . . . 330

 Magnesium sulfate. . . . . . . . . . . . . 331

 Hydrogen chloride. . . . . . . . . . . . . 333

 Ash from manure burning. . . . . . . . . . 336

 Sodium fluoaluminate . . . . . . . . . . . 337 

Deferred proposals/Final votes . . . . . . . . . 348

NOSB work agenda/Materials update. . . . . . . . 360 

Other business and closing remarks . . . . . . . 365 

Adjourn. . . . . . . . . . . . . . . . . . . . . 368 

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 P-R-O-C-E-E-D-I-N-G-S

 8:34 a.m.

 CHAIR BEHAR: Thank you, everyone. We 

are on to Day 3 of the 55th NOSB meeting. If you 

haven't remembered that, you will now.

 I want to also encourage people, 

anyone who hasn't taken any animals or if you 

want to take a few more you can over there. To 

keep us in mind that we have more than just us 

humans to be thinking about on this planet.

 So we will continue from yesterday. 

We are a little bit behind. So we do have a full 

day ahead of us. 

 And with that I am going to turn over 

the running of the meeting to Scott, the 

Livestock Subcommittee chairperson.

 MR. RICE: Thanks, Harriet. We're 

taking up where we left off yesterday looking at 

sunset materials for the 2021 cycle.

 Our next to be reviewed is magnesium 

sulfate. And that is Ashley.

 MS. SWAFFAR: Magnesium sulfate or 

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better known as Epsom salt has lots of uses 

including used to treat grass tetany, used as a 

laxative, used to prevent hypoglycemia, used to 

draw out deep infected lesions. And farmers also 

use that to soak feet and things to reduce signs 

of inflammation.

 We heard from producers that this is 

important to the humane treatment of organic 

animals and we did not receive any comments 

opposing the listing.

 MR. RICE: Any comments or questions 

for Ashley on magnesium sulfate? All right.

 Seeing or hearing none we will move 

onto parasiticides, fenbendazole and moxidectin. 

We'll do those separately but those both belong 

to Sue.

 MS. BAIRD: Yes. Fenbendazole is a 

parasiticide. Most of us that have livestock 

understand the mode of action, but it is an 

anthelmintic drug that is used to evacuate 

internal parasites.

 Fenbendazole was received from NOSB in 

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2007 and has been on the list effective 2012. It 

was petitioned and NOSB made a proposed change in 

2018 because fiber animal producers were needing 

fenbendazole listed for it.

 And so there was a proposed rule 

change January 17, 2018 and our annotation change 

was made 12/27/2018.

 In your books that you received it was 

put originally for public comment on the Federal 

Register as saying fenbendazole milk or milk 

products from a treated animal cannot be labeled 

as provided for in Subpart D of this part for 2 

days following treatment of cattle, 36 days 

following treatment of goats, sheep and other 

dairy species.

 And you will notice up on the board it 

has actually been listed in the Federal Register 

not any change in intent, but wording is changed 

which says allowed for fiber-bearing animals when 

used a minimum of 36 days prior to harvesting of 

fleece or wool that is to be sold, labeled, or 

represented as organic. 

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 So a little bit different wording than 

what you had in your original book or your 

original literature that went out to be commented 

on, but no intent -- no change in intent. 

 So fenbendazole and do I go straight 

into --

 MR. RICE: Straight into the mike.

 MS. BAIRD: Straight into the mike, 

okay. So that's fenbendazole.

 MR. RICE: Okay. Thank you, Sue. 

Moving onto peroxyacetic/peracetic acid. That is

 MS. BAIRD: Any questions?

 MR. RICE: Excuse me. We've got 

moxidectin. Excuse me.

 MS. BAIRD: Moxidectin. Yes. 

Moxidectin was reviewed at the same time as 

fenbendazole, was put on the National List at the 

same time.

 Has a little bit different mode of 

action. It's used in rotation with livestock 

producers because it does have a different mode 

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of action.

 It does the same thing. It is an 

internal parasiticide that's used in animals. 

 Was reviewed all three including 

ivermectin which has since been taken off the 

list. Were reviewed in 2015 as one group because 

they all are used in rotation for the animals.

 Moxidectin does have a little bit 

different mode of action. Any comments that we 

heard from the public on all of these -- well, 

not all of these now, these two parasiticides 

were favorable.

 All livestock producers say they're 

almost critical to have. Otherwise we have 

parasiticide loads that the animal could cause 

death and does cause death in especially the 

fiber-bearing animals.

 The very same change was made that I 

just pointed out for the fenbendazole. It was 

listed on your public comments that says 36 days 

following treatment of sheep, goats and other 

dairy species which has now been just changed to 

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saying fiber animals.

 So same mode, same comments. People 

who said they wanted fenbendazole also say 

they've got to have the moxidectin.

 MR. RICE: Great. Thanks, Sue. And 

now peroxyacetic and peracetic acid to Jesse.

 MR. BUIE: Okay. Peracetic acid, 

205.603(a) is a disinfectant, sanitizer, medical 

treatment as applicable.

 According to the TR the peracetic acid 

is listed for use in organic livestock production 

as a -- for sanitizing facility and processing 

equipment.

 According to the TR the reason for the 

excellent and rapid microbial effect of peracetic 

acid is this specific capability to penetrate the 

cell membrane.

 Once inside the cell peracetic acid 

plays a role in denaturing protein, disrupting 

cell wall permeability and oxidizing sulfhydryl 

and sulfur bonds in enzymes and other proteins.

 On the environment the peracetic acid 

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is considered to be an environmentally friendly 

substance with very little potential to cause 

contamination due to its rapid breakdown into 

benign substances already present in the 

environment.

 There were very few comments, but they 

were all overwhelmingly in favor of re-listing 

peracetic acid.

 Peracetic acid is recommended for relisting based on the available 2000 TAP. The 

technical review from March 2016, unanimous NOSB 

2017 supported this material and there is no new 

scientific or meritorious information.

 The NOP has reviewed few materials for 

use in barns, stalls, stables, milking parlors 

leaving relatively few options for producers. 

Are there any questions? 

 MR. RICE: Comments or questions for 

Jesse? Thanks, Jesse.

 Moving onto xylazine we turn to Dan.

 DR. SEITZ: So xylazine is a substance 

that is allowed under 205.603(a) as a 

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disinfectant, sanitizer and medical treatments as 

applicable.

 It must be used by a lawful written 

order of a licensed veterinarian. And there's a 

meat withdrawal period of at least eight days 

after administering the substance and a milk 

discard period of at least four days.

 It's been listed since the early two 

thousands. There was a 2002 TAP report and then 

a 2019 technical report on the substance.

 Xylazine is used as a sedative, 

analgesic and muscle relaxant in veterinary 

medicine as a medical treatment. It can be 

administered intravenously, intramuscularly, 

subcutaneously, or orally.

 It's allowed under the Canadian 

standards, but it's not mentioned under Codex, 

the European Economic Community, the Japanese 

Agricultural Standard for Organics, or the IFOAM 

standards.

 There are some environmental concerns 

associated with it, both its manufacture and also 

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its use. It can cause wastewater pollution in 

the case of improper use or disposal.

 Xylazine has a potent hypnotic and 

muscle relaxing property and is not allowed for 

human medical use.

 There were about a half dozen 

comments, brief comments in favor. It seemed to 

be not widely used, but nonetheless seems to be 

an essential substance in the uses when used.

 There were no commenters who 

recommended removal. Beyond Pesticides did note 

that in the 2002 TAP report it was stated that 

both xylazine and tolazoline, these are two 

substances used in common, was not approved by 

the FDA for use in food producing animals. So 

they just pointed out that there may be something 

of a disparity between FDA regulations and what 

is allowed under our standards.

 I did not see, however, that mentioned 

in the 2019 TR. Any questions?

 MR. RICE: Questions or comments for 

Dan? Seeing none, thanks, Dan. 

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 Moving onto trace minerals. This was 

mine. 

 Trace minerals, 205.603(d) as feed 

additives. Trace minerals used for enrichment or 

fortification when FDA approved.

 Trace minerals elements whether 

naturally occurring in the diet or provided in 

supplements important to the maintenance, growth 

and reproduction and healthy production of 

cattle, swine and poultry.

 Forages and grains are good sources of 

calcium and phosphorus. However, bioavailability 

of minerals in forage varies on the mineral 

content of the soil and level of pasture 

fertilization.

 Mineral premixes are therefore widely 

used in livestock feed fortification to ensure 

adequate intake.

 The NOP has issued a guidance document 

for the use of minerals in livestock feed which 

spells out in more detail which minerals are 

covered under this listing. 

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 Manufacture varies because it is quite 

a broad categorical listing. Individual mineral 

compounds are produced on an industrial scale 

through chemical synthesis and extraction from 

either natural or reclaimed sources.

 For a representative sample of common 

production methods the 2013 TR includes some 

specifics on that.

 The trace minerals are included by 

either direct reference or in feed additives in a 

number of other international regulations.

 NOSB has continually received comments 

from the organic community supporting the 

continued use of these noting their essentiality 

to livestock health and welfare and importance in 

offsetting seasonal variables in forage 

nutrition.

 I should note that we did get --

received a TR for trace minerals on April 16. 

That was too close to our meeting here to take a 

look at, but we'll be looking at that in the 

coming months. 

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 And a number of certifiers submitted 

comments noting wide use on the operations they 

certify. 

 Several producers noted as above and 

in past reviews the continued need and necessity 

to provide adequate nutrition.

 A couple of organizations noted 

organic production should not be dependent on 

synthetic nutrients noting the current annotation 

may not be restrictive enough to prevent reliance 

on synthetic materials and recommended adding an 

annotation that -- of when forage and available 

natural feeds are of poor quality can these trace 

minerals be used.

 We did not receive much response on 

our questions related to production through 

excluded methods so we'll continue to look for 

those moving forward. 

 Any questions or comments? All right. 

Hearing none. Oh, Dave.

 MR. MORTENSEN: Yes. I was just 

curious, Scott, how much in the way of efficacy 

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data is provided with something like this? 

 How much -- sorry if you didn't hear. 

How much in the way of efficacy data is provided 

with a compound like this? I'm just curious how 

it affects animal weight gain, performance, 

health, behavior. Just curious.

 MR. RICE: In comments or the TR? Or 

both?

 MR. MORTENSEN: Just that would 

underpin the review.

 MR. RICE: We'd certainly take a look. 

As I said I haven't had an opportunity to take a 

look at the TR. I wouldn't say the comments 

pointed to efficacy per se more than just a 

necessity in the absence of consistent pasture 

conditions. I'm not sure if that specifically 

answers what you were looking for.

 MR. MORTENSEN: I guess I was just --

I mean, to me that would require in order to 

assess the extent to which a pasture delivers 

enough you would have some sort of -- see data to 

compare it against. I was just curious. Maybe 

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it will be reviewed in a technical report review.

 MR. RICE: Yes. I'll keep that in 

mind as I take a look. Thanks.

 Okay. Moving on we've got lastly 

vitamins with Sue.

 MS. BAIRD: Thank you. Vitamins have 

been listed since the beginning of time. Has 

gone through several sunset recommendations, 

1995, 2005, 2010 with the latest in 2015.

 And NOP allows vitamins from 205.603 

which says synthetic substance allowed for use in 

organic livestock for enrichment or fortification 

when FDA approved.

 They are listed by AAFCO which is the 

American Feed Official -- I can't remember what 

AAFCO stands for. It's the controlling for all 

feed, livestock feeds.

 Vitamins are combined with your grain 

rations, your bean oils, your other meals that 

they use to provide the nutrients that the animal 

needs.

 There are 15 essential vitamins that 

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are currently allowed that has been noted by the 

National Research Council for the needs for an 

animal.

 So that was further clarified in 

238(a)(2) which says livestock feed rations must 

meet nutritional requirements including vitamins, 

minerals, proteins, other amino acids, fatty 

acids, mineral sources and fiber for ruminants.

 So it's pretty clear that we need the 

vitamins in our feed for livestock, for humans, 

for anybody.

 But as we've become more diligent I 

think perhaps it was determined that some 

vitamins are being made from a fermentation 

production which uses genetic modification. 

 And that had been in the past accepted 

just as if it's a vitamin, it's a vitamin.

 And the TR said that genetic 

modification was commonly used in productions of 

vitamin A, B2, B5, B6, C, E and B12.

 So accordingly NOP published a 

Guidance 5030 which was called Guidance 

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Evaluating Allowed Ingredients in Sources of 

Vitamins and Minerals for Organic Livestock Feed 

which instructed the certifiers to be diligent in 

reviewing the vitamins for the presence of those 

excluded methods.

 And specifically NOP wrote the USDA 

organic regulations also prohibit use of excluded 

methods at 205.105(e) and thus vitamins and 

minerals -- vitamins used for livestock feed 

should be reviewed for excluded methods.

 And then OMRI also acknowledged that 

vitamins may be produced using excluded methods 

in their generic list. And they published a 

decision tree for evaluating GMO inputs in 

organic livestock feed on page 85 of the generic 

listing. And you can find that on the OMRI 

website.

 So, there's not been any environmental 

issues that's been found for soil-dwelling 

organisms. As we said, health impacts, they're 

absolutely essential for those vitamins to be 

added into the livestock feed. So any questions? 

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 MR. RICE: Questions for Sue? 

Harriet.

 CHAIR BEHAR: I've heard some 

certifiers question the source of some of the 

vitamins that they might be from genetically 

modified sources or things like that. Was there 

any consideration of that? I don't know if true 

or not. I don't know. But I know there's been 

discussion.

 MS. BAIRD: Yes. I think that they 

would be questioning it. They're instructed by 

NOP to be questioning the sources.

 So we did ask to further question what 

documentation are the certifiers and material 

review organizations using that would document 

that they have done their search. And we didn't 

get any response to that. 

 But I think that is a valid question. 

And I've been a reviewer for certifiers and I do 

know that they are asking those questions, or the 

ones that I did reviews for were. They were 

cognizant of this issue. 

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 MR. RICE: I would offer, I think we 

did get one comment on requiring as often 

certifiers do for things like this a non-GMO 

affidavit.

 MS. BAIRD: You're right, I'm sorry, 

I forgot that. Thank you. 

 MR. RICE: Ashley?

 MS. SWAFFAR: And I'll point out that 

we did receive a comment that that language says 

that certifiers should verify, but it does not 

say that they must verify. So there's a very 

distinct difference in that language. 

 MS. BAIRD: There's a lot of 

difference in that language and I didn't catch 

that. Thank you.

 MR. RICE: Dave.

 MR. MORTENSEN: So just so that I'm 

clear the sentence that you read from, Sue, that 

says in the technical review in 2015 fermentation 

production using genetic modification is commonly 

being used in production of A, B2, B5, B6, C, E, 

B12. 

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 And then later, quote, it says the 

USDA organic regs should be -- should prohibit 

the use of excluded methods.

 I'm just actually not quite sure I'm 

following what that's saying. It reads as though 

they're all being produced, or those are being 

produced through genetic modification. And then 

below it says they should be reviewed to 

determine if they're being produced using 

excluded methods. 

 It seems internally inconsistent. 

Unless I'm just not following what the intent of 

that wording is.

 MS. BAIRD: I apologize for that. If 

I'm understanding you're saying that you think 

that because of this technical review that all A, 

B2, B5, B6, C, E and B12 are produced with 

genetically modified organisms.

 I think that they said they're 

commonly used. It doesn't say that they are all 

-- the fermentation method is always used. It 

does say that some are done by chemical changes, 

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chemical synthesis or partial synthesis.

 So, I really am not totally sure that 

all -- according to NOP's direction they're 

saying that you should be reviewing to that.

 So I'm assuming by that direction that 

there are A's and B's and all these things that 

could be done by chemical synthesis. And it's 

something that I will certainly do a little more 

follow-up for the fall before we vote on it. 

Thank you for bringing that to my attention.

 MR. RICE: Thanks, Sue. Any other 

comments? All right. That completes our initial 

review of the 2021 sunset substances for the 

Livestock Committee and brings the Livestock 

Committee to the end of its business for this 

meeting. I turn it back to Harriet.

 CHAIR BEHAR: Thank you. Okay, so we 

are going to move on to 8:30 in the morning of 

today to the Handling Subcommittee, Asa Bradman, 

chairperson.

 MR. BRADMAN: Thank you. We have a 

very full agenda this morning and I think we'll 

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just start right out with the proposals. 

 The first one to consider is the 

silver dihydrogen citrate and Steve, I believe 

you're the lead on that.

 MR. CHAPMAN: I thought we shared it. 

You didn't prepare?

 MR. BRADMAN: I was going back to the 

emails.

 MR. CHAPMAN: I guess I'll have to 

wing this one. I'm joking, I'm joking. You can 

strike that from the record.

 MR. BRADMAN: Sorry, Steve.

 MR. ELA: It's fine. I actually 

hadn't conferred with Tom. I assume he had it 

ready.

 MR. BRADMAN: There was an email 

history from before I took over as chair.

 MR. RICE: I'll treat Steve for his 

mild heart attack right now.

 MR. CHAPMAN: Does the program do any 

reading into the record? Sorry, senioritis here. 

I don't remember. No? I'm seeing program heads 

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shaking no.

 All right, then I will get started. 

Silver dihydrogen citrate is being petitioned by 

PURE Bioscience as an antimicrobial processing 

aid for poultry carcasses and fruits and 

vegetables excluding citrus and grapes for winemaking, as a disinfectant and sanitizer for food 

contact surfaces and for food processing 

equipment.

 So this would be a petition to the 

National List 7 CFR 205.605(b).

 The petition was received in January 

of 2017. It was amended twice in August of '17 

and June of 2018.

 And the technical review was received 

and found sufficient in May of 2018.

 We considered this proposal, this 

petition as a proposal in our fall 2018 meeting 

but ultimately voted to send it back to 

subcommittee for a further review after receiving 

substantial public comment. And we brought it 

again forward in 2019. 

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 The comment received this time was 

similar in nature, at least areas of concern as 

were raised in the fall of last year. And I'll 

just go into those major areas.

 The first one which I think is one 

that's the easiest to say is mitigated was the 

concerns around sodium lauryl sulfate in the 

formulations of these products.

 There was a question related to the 

patents about how this product is being used. Is 

it being used as a detergent or a stabilizer. We 

received comments from the petitioner and an 

argument that this is akin to inert materials 

used in formulated sanitizing products and that 

the board has used that justification before to 

not look at those substances in detail which is 

true.

 When you look at substances like 

peracetic acid and all the additional inert 

ingredients that are used to stabilize that. 

 So considering SLS as an inert 

ingredient it would not be part of this review at 

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this time.

 The next issue that was brought up was 

compatibility, particularly due to the use of 

engineered nanotechnology.

 This is an area, frankly, that the 

subcommittee struggled with, hearing arguments on 

both sides around whether this should be 

considered a material of nanotechnology or not. 

And we heard further comment this time in that 

area.

 It seems like this issue could be --

this issue revolves around the fact that this is 

an ionic form of this material and whether or not 

this ionic form counts as an engineered nano 

material. And it's not really clear from the 

previous NOSB recommendation whether or not that 

was included in that review and what impacts that 

interpretation would have on various other 

materials on the National List.

 Additionally, it seems like this is a 

concern that could potentially be mitigated via 

annotation if the board wanted to move forward 

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with this material.

 The subcommittee did not make an 

attempt at revising the previous annotation given 

at the time the subcommittee was not recommending 

this material for listing.

 So if that view has changed then I 

believe the subcommittee would take an attempt to 

again address the nanotechnology concerns via an 

annotation.

 Human health concerns were raised both 

related to the nanotechnology issues noted 

previously and then also into the use of silver 

in wound management and studies that have been 

released about the growing or potential growing 

resistance to silver in wound management.

 Information again was presented on 

both sides related to this issue and there was 

also some discussion here and on the webinar 

about differences between medical and food 

applications and what's going on in this area.

 The subcommittee did not particularly 

find the use in medical applications as violative 

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of the OFPA criteria for human health. 

 It also should be noted there are 

other substances approved as sanitizers also used 

in medical contexts.

 Most of those who cited this issue 

also cited the Centers for Disease Control 

calling out that pathogen resistance is one of 

the world's most pressing public concern issues.

 However, in doing research with CDC 

they maintain the National Antimicrobial 

Resistance Monitoring System database and in my 

searches I didn't find anything related to silver 

or silver resistance in that database.

 I also queried FDA, World Health 

Organization, American Medical Association, who 

also do similar -- raise similar concerns around 

the growing concern of antimicrobial resistance 

and similarly did not find anything related to 

silver in those areas.

 So this is an area that I think we 

have to consider, but I'm curious to know how 

other members feel in this regard, if this is a 

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concern related to the criteria.

 Environmental toxicity was another 

area that was raised, particularly about silver 

in the environment and impact on waste effluent 

systems.

 I don't feel like we received much new 

information about silver in the environment. 

It's really do you -- on an absolute basis do you 

support the potential addition of more silver 

into the environment through this application or 

do you look at it on the dilution basis that it's 

probably not raising on a diluted basis because 

it's being released at lower levels and 

background levels, silver in that environmental 

context.

 The concerns around various locations 

of use of silver dihydrogen citrate was responded 

to by the petitioner. And I'll read it here that 

the scopes of SDC's regulatory approvals are far 

narrower and would not cover these uses as 

identified. SDC is not currently approved for 

use in field or post-harvest handling 

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applications for raw agricultural commodities.

 Those applications are the ones that 

the Handling Subcommittee raised as a concern and 

SDC is approved for FDA, EPA on food contact 

applications only on hard, non-porous surface, 

sanitizing, disinfection, and by FDA only for use 

in facilities that process produce for poultry.

 So it seems like that issue is 

mitigated just by its own licensing currently 

although again it also could be further mitigated 

if we wanted to via an annotation on this 

material. If we wanted to move forward.

 The last area of concern that was 

raised was around essentiality. And I'm going to 

interpret that actually under the necessity 

because I don't know if essentiality applies to 

this material.

 But under necessity of whether this is 

actually a needed additional material and most 

commenters noted that they thought that the 

petitioner failed to make that argument around 

its necessity. 

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 We did receive comments from industry, 

particularly produce wholesalers on the west 

coast and a couple of other as well as some 

sanitation supply companies asking for -- or 

reviewing its use.

 We did receive one written comment 

from Organic Produce Trade Association which 

recommended against its use although in verbal 

conversations here at the board they also seem to 

think that it could use further consideration and 

be brought back to the subcommittee given some of 

the additional public comment that was received 

this round.

 Moving back to essentiality. So the 

essentiality piece did seem to also in a lot of 

comments obfuscate in my opinion -- this is 

opinion I guess at this point -- the difference 

between cleaning and sanitation in facilities.

 And several of these comments cited 

two different papers, one from the Food and 

Agriculture Organization of the United Nations 

and one, a USDA one both related to meat 

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processing stating that sanitation begins having 

a clean facility, and that clean facilities selfnegate the need for chemical sanitation.

 And while I think most people who have 

experience in this area would agree that cleaning 

is a necessary step prior to sanitation that they 

are two distinct separate steps with separate 

purposes.

 And if you go into detail on both of 

those papers cited both of them also go into 

detail about the importance of chemical 

sanitizers as well as the need for multiple 

chemical sanitizers.

 So, the subcommittee did not recommend 

listing this item this time, the three major 

concerns being location, use and the impact on 

the environment.

 That seems like it can be mitigated 

via potential annotation.

 Its compatibility with organic 

production given concerns around nanotechnology, 

also potentially mitigatable by annotation. 

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 And then the concerns around sodium 

lauryl sulfate which does not seem to be a valid 

concern at this time.

 So in light of this my opinion on this 

material has changed. I would like to have the 

subcommittee consider it further and see if via 

annotations if this could be acceptable for use 

in organic processing for some or all of the 

scopes that's been petitioned for.

 I've noted in the comments that 

particularly for hard surfaces that is what 

industry was looking for a sanitizer to use.

 And then I guess I would be somewhat 

-- I think most people on this board have 

realized that from the amount of discussion on 

this, but this does as a material its true 

interest to I think most processors is around its 

different mode of action, that it's a unique mode 

of action separate from the oxidative or acidic 

modes of action that we currently have as 

sanitizers on the National List.

 Steve, do you have anything to add? 

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 MR. ELA: No, I think that -- probably 

a pretty good summary. I mean, I think Tom and I 

-- it's probably good we kind of co-worked on 

this because there's a fence and we probably fall 

on each side of the fence just a little bit. 

 But I would say you gave a pretty good 

summary of the disposal. Still I mean the public 

comment gave about sewage disposal systems and 

pumping, that sludge goes into a treated 

facility.

 Living in a rural area I guess I think 

that's great in theory, but I'm not sure that all 

-- I think there's a considerable variation in 

quality of treatment systems across the nation 

especially in rural areas. So I am not totally 

satisfied that -- I understand on the surface 

answer, but I'm not totally convinced on it.

 Sodium lauryl sulfate, yes, you've 

answered that. The hard surfaces versus contact 

with actual produce or poultry, you've covered 

that pretty well.

 Mode of action certainly. And I know 

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there's been a lot of discussion in the 

committee. 

 I tend to come down -- you tend to go 

let's go back and annotate and I kind of come 

down there's still these continuous niggling 

questions that I'm not completely sure we can --

especially on the nanoparticle side.

 I get very clearly that it's ionic. 

I also could see where it could form 

nanoparticles as it precipitates. Because we're 

talking about a precipitating sewage sludge and 

other areas. So it's not always ionic.

 So I tend to fall a little bit on the 

side of with all these niggling questions I'm not 

quite as excited about it as I initially was. 

You've come down on the other side so I think 

that -- I suspect a lot of people on the board 

are that way, but I think it's -- I look forward 

to the discussion. Thanks for the summary.

 MR. BRADMAN: Emily.

 MS. OAKLEY: Are we open for questions 

now? 

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 MR. BRADMAN: Yes. Let's open this 

for discussion.

 MS. OAKLEY: So then maybe this is a 

question for everyone on the subcommittee. How 

do you grapple with varying public comments in 

terms of the nano material aspect and the fact 

that they're conflicting information?

 And I also would echo Steve's comment 

about rural areas. I don't think that has been 

adequately resolved.

 And I know it's not the petitioner's 

problem to deal with variations in rural versus 

urban areas, variations in regulations across 

states, but it does pose a problem in terms of 

what we can expect end users to know about the 

material.

 But my real question is how do you 

resolve conflicting public testimony about the 

nano material aspect.

 MR. ELA: I don't think there's a 

great answer for that. I mean, it is conflicting 

and I think that's -- I guess my side comes down 

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on precautionary.

 Once you start receiving conflicting 

things then I tend to err on the side of 

conservatism in saying I don't want to put it on 

the list. I think Tom falls on the side -- and 

you should speak for yourself, but I also 

recognize the view that we do need more modes of 

action and food safety is paramount.

 And risk to public health by 

environmental releases versus risk to food safety 

of an outbreak. We have to balance that.

 But I don't know there's a great way 

to resolve inherently there's conflicting public 

comment on it. And that's real. We have to try 

and sort that out ourselves. But I don't know 

there's a great process for that except our own 

knowledge base.

 MR. BRADMAN: Tom, do you want to 

respond and then Lisa?

 MR. CHAPMAN: Yes. I mean, I guess 

there's conflicting information. There's almost 

always conflicting information on almost anything 

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we ever deal with so that's -- I'm not sure if I 

like discount the precautionary principle.

 I think I look at the totality of the 

evidence and then try to weigh it out.

 My biggest concern with this is on a 

technical side this is just way above. This is 

way above my pay grade. My YouTube 

certifications don't qualify me for making these 

determinations.

 And so you have to rely on these 

experts. Unfortunately -- I mean, the ideal 

thing would be to have I guess a third party 

independent expert that we fully trusted that 

didn't have an agenda.

 But I don't think we're going to get 

that on a material that's manufactured by a 

single processor because you're pretty much going 

to have to rely on them. That's the reality of 

the world and we're not going to trust that 

information because it came from a petitioner 

that it's not biased or it's their opinion.

 So to the extent that I'm qualified or 

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at least I have the right to vote on this 

material. I've looked at the evidence as 

provided and I'm leaning towards the -- what the 

petitioner has provided because I think they've 

responded to most of the concerns.

 However, I -- I'm not an expert in 

this area.

 MR. BRADMAN: Lisa and then Rick.

 MS. DE LIMA: I think Tom and Steve 

pretty much covered it pretty well, but just so 

folks know where I fall I'm kind of in line with 

Steve with yes, there's the fence. The lines 

pretty -- could go either way.

 But in those cases I kind of feel the 

opposite of Tom. I'm not an expert and I don't 

feel comfortable voting yes. There's too many 

lingering questions for me.

 MR. BRADMAN: Rick.

 MR. GREENWOOD: Tom, when you looked 

at the databases for antimicrobial resistance one 

of the things that I'd caution about that is 

silver isn't used that much. And so not having 

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resistant organisms, there hasn't been 

environmental pressure on them where there would 

be if we start putting vast quantities. And I 

assume they'd end up being vast quantities of 

silver into the environment.

 The other issue that Steve talked 

about is sludge. We talked about that a little 

bit on the webinar, but sludge goes somewhere. I 

mean we talked about moving it from rural places, 

but eventually it gets into the environment and I 

think that's the other area that concerns me as I 

mentioned on the webinar is the bioaccumulation.

 There are papers about its toxic 

effect on some of the microorganisms, the onecell animals.

 MR. BRADMAN: Dave.

 MR. MORTENSEN: Yes. I also am on the 

side of being concerned about the environmental 

impacts. 

 I think there is evidence of 

bioaccumulation in the microbial community. And 

the issue of sludge management is definitely a 

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concern of mine as well as in the water. So 

that's how I am leaning.

 DR. SEITZ: I too believe that we 

should err on the side of conservatism. 

 But I also want to add to that that 

once a substance is on the list the fact that it 

takes a two-thirds vote to remove it from the 

list I think is an added reason why we need to be 

very cautious with a substance where there's so 

many ambiguities.

 The other thing that was mentioned by 

a couple of commenters is that we may want to 

revisit the question or the NOP may want to 

revisit the question of whether nanotechnology 

should be looked at as a class of things that we 

may want to prohibit.

 And I think that that may be a very 

good idea just because in a case like this where 

there really is some question that the chemistry 

involved with this points to nanotechnology 

issues, even if it's asserted that it's not being 

used. 

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 If we have to work through that every 

time and there's ambiguity again I would say it's 

incumbent upon us to be very cautious about 

approving anything where that may be an issue.

 MR. BRADMAN: Harriet.

 CHAIR BEHAR: I agree with the first 

part of what Dan said about there's so many 

issues. 

 And the thought of we need to annotate 

for this and we need to annotate for that. If we 

have to keep narrowing and narrowing and 

narrowing the use because we have a concern I 

think that there's more chance for abuse out 

there once it's on the list. 

 I've seen that, that people don't read 

the annotations as quickly and it's confusing to 

them. So I am not for this material.

 And also I thought there was some 

compelling information from Consumer Reports on 

the resistance issue.

 MR. BRADMAN: I just want to interject 

a point here. I'll call on myself and then Tom. 

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 I have concerns about this material 

too, particularly as petitioned. I think it's 

reflected in some of the discussion.

 One thing to also think about though 

too is that we have some very nasty materials 

that are currently on the list, particularly 

chlorine compounds.

 I've mentioned this before. In my 

experience with farm workers and people working 

in processing plants you hear just bitter, bitter 

complaints about chlorine compounds. 

 Chlorine compounds are osmogens, 

they're respiratory, ocular irritants. They 

produce materials that cause cancer.

 And I think actually from a worker 

point of view there might be some uses of this 

material that could prevent other kinds of 

exposures.

 I do have some concerns about the 

concept of a food contact material that's going 

to have essentially an unlabeled residue.

 So anyway, but I just want to throw in 

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the worker health piece.

 And certainly on an acute basis it's 

probably safer than some of the other materials 

that we currently allow.

 MR. CHAPMAN: And that was definitely 

echoed in comments from a large organic produce 

handler in the 2018 comments that noted that 

their sanitation workers on their conventional 

lines vastly prefer this material if you take 

them at their word which you know, I do because I 

don't expect sanitation workers are particularly 

reading the regulations.gov waiting to comment to 

us.

 That being said, it seems quite clear 

from the comments here today that we know the 

fate of the votes that we're about to have. So I 

don't want to belabor that point in the interest 

of time.

 However, I guess a question I do have 

to members of the board. The subcommittee noted 

concerns and then noted that there's potential 

with this material and invited -- when we voted 

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it down, invited the petitioner to potentially 

re-petition in the future state when these 

concerns could be mitigated.

 And I guess my question in the 

interest of providing accurate information, what 

if anything could the petitioner do to develop 

further evidence that would mitigate concerns 

that are preventing us from supporting this 

material now.

 MR. BRADMAN: Before we go to Emily, 

Scott had raised his hand.

 MR. RICE: Thanks. I guess to answer 

Tom's question first I would think having, you 

know, we struggle with the impartiality on the 

nanotechnology so somehow having impartial 

information on that if that's even possible would 

be helpful for me personally.

 But I also wanted to speak to the idea 

of annotations. I think annotations can be very 

helpful and they're very helpful to certifiers.

 I think if someone isn't reading the 

annotation carefully there's ways for certifiers 

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to deal with that. At the end of the day the 

annotation is there and that should be followed, 

but I struggle with this as well.

 I think some of these things, or at 

least the location use could be addressed by the 

annotation, but I kind of fall on that side of 

being cautious in this instance and would like to 

see the potential of this, but not there right 

now.

 MR. BRADMAN: Emily.

 MS. OAKLEY: I mean, I think that's a 

good question, Tom.

 I think what I struggle with with this 

petition and what I struggled with in the fall is 

just the vastly conflicting information, not just 

on nano particles but on human health as well.

 And not necessarily disposal. I don't 

think we've delved as deeply into that as we 

might have.

 I guess -- I don't quite know how to 

answer the question but impartial information is 

super important to me. 

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 It's not that I don't trust the 

petitioner per se, it's simply that they have a 

perspective that is inherently inclined towards 

wanting to see the material approved.

 So how you obtain impartial 

information on some of these questions as you 

pointed out is challenging and I'm not sure, but 

that's what I think would be necessary for me.

 And then I did just want to echo Asa's 

comment because one thing that has come up for me 

is is there a question of residue on products 

with this material, residual effects of it.

 MR. BRADMAN: Is there any more 

discussion? Jesse.

 MR. BUIE: Yes, the urban versus rural 

disposal is an issue with me. So I'm leaning 

against it for that reason.

 MR. BRADMAN: I don't see any more 

comments. Tom, I don't know if you wanted to --

 MR. CHAPMAN: I'm still going to try 

to make the motion. We'll see what happens.

 MR. BRADMAN: Okay. 

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 MR. CHAPMAN: So I move to refer 

sodium dihydrogen citrate back to the 

subcommittee.

 CHAIR BEHAR: Is there a second?

 MS. SWAFFAR: Second.

 CHAIR BEHAR: Ashley second.

 MR. BRADMAN: So any final discussion 

before we vote on that? I'm not sure where we 

start on the voting cycle.

 CHAIR BEHAR: Okay. I believe Dave.

 MR. MORTENSEN: No.

 MR. BRADMAN: Yes.

 MR. RICE: Yes.

 MR. ELA: No.

 MS. OAKLEY: I told you I would 

abstain but I'm going to say no. Sorry.

 MR. BUIE: No.

 MS. ROMERO-BRIONES: No.

 MS. DE LIMA: No.

 MR. GREENWOOD: No.

 MS. SWAFFAR: Yes.

 MR. CHAPMAN: Yes. 

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 MS. BAIRD: Coming from a meat 

processing background I am going to say yes.

 DR. SEITZ: No.

 CHAIR BEHAR: The chair votes no.

 MR. RICE: That was five yes, nine no. 

The motion fails.

 MR. CHAPMAN: I just have a quick 

point of order question. Did we classify this 

last time before we sent it back? Anyone? Maybe 

the former chair can answer the question. He 

can't. Maybe the former secretary can answer the 

question, keeper of the record.

 MR. RICE: I've got the -- I think 

these motions on my sheet are from subcommittee. 

So I'm not -- I'd have to look back.

 MR. CHAPMAN: Okay. So we'll classify 

again.

 CHAIR BEHAR: So we have a question if 

it was classified as a synthetic at the last --

 MR. RICE: Maybe the program can help 

us.

 MR. CHAPMAN: There's probably no harm 

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in just classifying it again. I assume we're 

going to vote the same way if we voted last time.

 CHAIR BEHAR: Well, if we've already 

voted to classify it as a synthetic we don't need 

to do it again.

 MR. CHAPMAN: I know. Yes. But if 

it's going to take us longer to figure out the 

answer than to vote again maybe we just vote 

again. Perfect, okay.

 MR. BRADMAN: So --

 DR. TUCKER: We would recommend revoting on this. It has gone through additional 

work so -- not just for convenience purposes, but 

for just the record.

 MR. CHAPMAN: Yes, we have two votes. 

The classification -- once we classify we 

generally don't re-touch that piece. And then we 

would vote on the proposal, the second piece 

always. So it's just the classification piece I 

was questioning. But it sounds like we didn't 

vote on it.

 MR. BRADMAN: Just for clarity let's 

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vote on the classification motion to classify 

silver dihydrogen citrate as synthetic.

 CHAIR BEHAR: Okay. Is there 

discussion anyone?

 MR. ELA: Just for the record that 

would have been Tom as the first and Lisa as the 

second. For the record. 

 MR. BRADMAN: I'm voting yes as a 

synthetic.

 MR. RICE: Yes.

 MR. ELA: Yes.

 MS. OAKLEY: Yes.

 MR. BUIE: Yes.

 MS. ROMERO-BRIONES: Yes.

 MS. DE LIMA: Yes.

 MR. GREENWOOD: Yes.

 MS. SWAFFAR: Yes.

 MR. CHAPMAN: Yes.

 MS. BAIRD: Yes.

 DR. SEITZ: Yes.

 MR. MORTENSEN: Yes.

 CHAIR BEHAR: Chair votes yes. 

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 MR. RICE: And that's 14 yes. The 

motion passes.

 MR. BRADMAN: So the next motion is to 

add silver dihydrogen citrate at 205.605(b) as 

petitioned. And I guess I'll make a motion to do 

that and we need a second.

 MR. CHAPMAN: The motion's there. It 

comes from the subcommittee. 

 MR. BRADMAN: Okay.

 MR. CHAPMAN: So it was made by me and 

seconded by Lisa as well.

 MR. BRADMAN: I have to get the points 

of order in order. Okay. I guess we can go 

ahead with the vote then.

 MR. CHAPMAN: Just as a point of 

discussion on this if we can I'm going to abstain 

from this item just because I don't think 

straight out adding it is appropriate. It would 

be better with annotations, but I guess we're not 

going to have the opportunity to annotate it. 

I'll be abstaining from this.

 CHAIR BEHAR: Any other discussion? 

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Okay, I think -- do we start with Scott?

 MR. RICE: No.

 MR. ELA: No.

 MS. OAKLEY: No.

 MR. BUIE: No.

 MS. ROMERO-BRIONES: No.

 MS. DE LIMA: No.

 MR. GREENWOOD: No.

 MS. SWAFFAR: No.

 MR. CHAPMAN: Abstain.

 MS. BAIRD: No.

 DR. SEITZ: No.

 MR. MORTENSEN: No.

 MR. BRADMAN: As petitioned, no.

 CHAIR BEHAR: Chair votes no.

 MR. RICE: That's 13 no, 1 abstention. 

The motion fails.

 MR. BRADMAN: So I think our next item 

for discussion is a proposal to add pullulan if 

I'm pronouncing that correctly. Pullulan.

 MR. RICE: I think we just need a 

recording of it so anytime we need to say it we 

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just press a button.

 MR. BRADMAN: Exactly. So Lisa, I 

think you're the lead on that.

 MS. DE LIMA: I'm the lucky person 

that gets to say this multiple times. 

 So a petition has been submitted to 

add pullulan to the National List at 205.605(a) 

as an allowed non-agricultural non-synthetic 

ingredient used in tablets and capsules for 

dietary supplements labeled made with organic.

 A petition was submitted to the OTA on 

behalf of its National List Innovation Working 

Group and the petition stated that the purpose of 

the petition was twofold, to continue the 

production and availability of USDA NOP certified 

dietary supplements and to support the commercial 

development of certified organic pullulan.

 So for dietary supplements the capsule 

is considered an ingredient and must either be 

certified organic or made up of ingredients 

compliant with NOP's National List.

 Since the early two thousands 

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certifying agents have classified pullulan as 

agricultural and it was allowed in encapsulated 

dietary supplements.

 And then once the NOP's classification 

of materials guidance came out in 2016 certifying 

agents came to a different decision, that 

pullulan should be classified as a nonagricultural and non-synthetic substance. So in 

that instance pullulan would need to be on the 

National List to be allowed to be used.

 There are no other NOP compliant 

vegetarian options available for producing an 

organic encapsulated supplement.

 Organic pullulan is not commercially 

available in the United States. And according to 

the petition Capsugel, the owner of the pullulan 

patent in the U.S., is in the process of 

developing organic pullulan. We heard the same 

thing in public comment on Tuesday.

 The only alternative practice for 

supplements manufacturers would be to use 

gelatin. Gelatin is listed on 205.606 of the 

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National List but this would be again problematic 

for consumers looking for a vegetarian, kosher or 

halal product.

 Based on the information in the TR 

pullulan appears to be of low risk to the 

environment and human health both in its use and 

its disposal.

 And the TR also pointed out that 

although pullulan is not allowed or included in 

international standards that's because unlike in 

the U.S. international standards don't consider 

dietary supplement capsules to be an ingredient.

 As far as public comment we've had two 

public comment periods for pullulan. We received 

a fair amount of public comment at the last 

meeting in favor of listing, mostly from 

manufacturers and some certifiers. 

 And then this time again we heard 

support from manufacturers, certifiers and 

interest groups in listing pullulan.

 We did hear a couple of different 

public comments asking that when we vote on the 

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material for the listing motion that we're 

specific as to its use. When we voted it out of 

subcommittee the listing motion was motion to add 

pullulan as petitioned so after our discussion we 

are going to make a motion to amend the 

classification -- sorry, not classification. To 

amend the listing motion with the specific 

language that I don't have in front of me but 

we'll get to that.

 That is pretty much it. So I open it 

up for questions and discussion.

 MR. BRADMAN: Harriet and then Emily. 

Harriet.

 CHAIR BEHAR: This seems like a pretty 

innocuous material. There is a demand for it and 

I don't see a problem with it. 

 I do agree to have a clear annotation 

on the vote.

 MS. OAKLEY: Yes, I also just am eager 

to see the organic form developed as soon as 

possible.

 MR. BRADMAN: Any more discussion or 

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comment? Tom.

 CHAIR BEHAR: So first it's the 

classification. Once we've done the discussion.

 MR. CHAPMAN: Well, do I need to make 

the amending motion?

 CHAIR BEHAR: -- classified first.

 MR. CHAPMAN: Okay, yes, all right. 

The amending motion is what's on the screen. 

There you go.

 MR. BRADMAN: So we're ready to vote. 

No more discussion. Okay. So let's first then 

go ahead with the classification motion. And I 

think we're ready to vote on that.

 CHAIR BEHAR: Start with Steve.

 MS. DE LIMA: Point of order. Are we 

going to read the classification motion?

 MR. CHAPMAN: Yes, please.

 MS. DE LIMA: Okay.

 MR. BRADMAN: Okay, thank you. 

Everyone just tell me what to do and I'll do it. 

Let's see. Classification motion. Motion to 

classify pullulan. I can't read that. As a nonNeal R. Gross and Co., Inc. 

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agricultural and non-synthetic. And it's a 

motion by Lisa. It's been seconded by Scott.

 MR. ELA: Yes.

 MS. OAKLEY: Yes.

 MR. BUIE: Yes.

 MS. ROMERO-BRIONES: Yes.

 MS. DE LIMA: Yes.

 MR. GREENWOOD: Yes.

 MS. SWAFFAR: Yes.

 MR. CHAPMAN: Yes.

 MS. BAIRD: Yes.

 DR. SEITZ: Yes.

 MR. MORTENSEN: Yes.

 MR. BRADMAN: Yes.

 MR. RICE: Yes.

 CHAIR BEHAR: Chair votes yes.

 MR. RICE: That's 14 yes. The motion 

passes. Excuse me, 14 yes, zero no. Motion 

passes.

 MR. BRADMAN: Okay. So now we'll do 

the -- hopefully I'll get it right this time.

 MR. CHAPMAN: So --

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 MR. BRADMAN: We have an amendment.

 DR. LEWIS: And you want to read that 

into the record.

 MR. BRADMAN: Okay. So we want to 

read into the record the amended --

 MS. OAKLEY: Can I make -- or can Tom 

make a motion first?

 MR. CHAPMAN: Can I make a motion? 

All right. I'm a little torn on this item 

personally because I support pullulan, but not 

pullulan. So I just don't know how I'm going to 

vote on this. I'm joking, all right.

 So there was some concern raised about 

the way the motion was written so for sake of 

clarity we're going to make a motion to amend the 

listing motion.

 So it already read motion to add 

pullulan as petitioned at 205.605(a). And I move 

to amend it to include the words for use only in 

tablets and capsules for dietary supplements 

labeled, parentheses, made with organic -- sorry, 

quotation marks, made with organic, parentheses, 

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specified ingredients or food groups, 

parentheses, parentheses, quotation marks.

 MS. OAKLEY: Second.

 CHAIR BEHAR: I'll second.

 MR. BRADMAN: Okay. So shall we now 

vote on the amendment?

 CHAIR BEHAR: Well, maybe -- any 

discussion?

 MR. BRADMAN: I think someday I'll be 

smooth at this. So any discussion related to 

this amendment?

 MR. RICE: I'm tempted to add to the 

amendment that we include the phonetic 

pronunciation of pullulan. But I'll hold off.

 MR. CHAPMAN: I think that might be a 

significant change.

 MR. ELA: I think we should annotate 

to change the name.

 MS. OAKLEY: Just for clarification 

was that a motion by Tom and a second by Ashley? 

Okay, thank you.

 CHAIR BEHAR: Oh, Ashley. Okay. 

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 MR. RICE: I believe the voting starts 

with Emily.

 MS. OAKLEY: Yes.

 MR. BUIE: Yes.

 MS. ROMERO-BRIONES: Yes.

 MS. DE LIMA: Yes.

 MR. GREENWOOD: Yes.

 MS. SWAFFAR: Yes.

 MR. CHAPMAN: Yes.

 MS. BAIRD: Yes.

 DR. SEITZ: Yes.

 MR. MORTENSEN: Yes.

 MR. BRADMAN: Yes.

 MR. RICE: Yes.

 MR. ELA: Yes.

 CHAIR BEHAR: Chair votes yes.

 MR. RICE: That's 14 yes, zero no. 

The motion passes.

 CHAIR BEHAR: Now we're on collagen 

gel.

 MR. CHAPMAN: No, we still --

 MR. BRADMAN: So, now we're going to 

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-- next step, last step, see if I can get this 

right. We're now going to vote on the motion to 

add pullulan as petitioned at 205.605(a) for use 

only in tablets and capsules for dietary 

supplement labeled made with organic specified 

ingredients or food groups. Close parentheses. 

The motion is by I guess myself.

 MR. CHAPMAN: No, go to the next 

slide.

 MR. BRADMAN: Okay. Is it by Lisa.

 MR. CHAPMAN: There you go.

 MR. BRADMAN: So, we're going to vote 

on the National List motion to add pullulan as 

petitioned at 205.605(a). The motion by -- I can 

stop there.

 MS. OAKLEY: I think you need to 

clarify, right, that the motion is by Lisa and 

was seconded by Scott in the committee. Is that 

correct? 

 MR. BRADMAN: I was just going to say 

that, motion by Lisa and seconded by Scott. Am I 

getting it right here? When I took this job I 

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wanted to be like a worker bee, not in charge of 

anything.

 MS. OAKLEY: I second that.

 MR. RICE: The voting -- I guess 

discussion.

 MR. BRADMAN: So any discussion before 

the final vote? I think we can move to the vote.

 CHAIR BEHAR: We'll start with Jesse.

 MR. BUIE: Yes.

 MS. ROMERO-BRIONES: Yes.

 MS. DE LIMA: Yes.

 MR. GREENWOOD: Yes.

 MS. SWAFFAR: Yes.

 MR. CHAPMAN: Yes.

 MS. BAIRD: Yes.

 DR. SEITZ: Yes.

 MR. MORTENSEN: Yes.

 MR. BRADMAN: Yes.

 MR. RICE: Yes.

 MR. ELA: Yes.

 MS. OAKLEY: Yes.

 CHAIR BEHAR: Chair votes yes. 

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 MR. RICE: The vote is 14 yes, zero 

no. The motion passes.

 MR. BRADMAN: So I think now we can 

move on to collagen gel. So, I think this is 

actually going to warrant quite a bit of 

discussion.

 So collagen gel has been petitioned by 

Devro, Inc., to be added to 205.606 as a nonorganically produced agricultural product allowed 

as ingredient in a processed product.

 Basically this proposal is for a 

collagen material to use as a substitute for 

intestinal casings for -- I like this term --

enrobing sausage products and providing an 

alternative to intestines.

 There's -- it's primarily made of 

collagen which is a protein derived primarily 

from animal skins, but it can come from a number 

of sources including mammals, fowl and also fish 

and other sources although probably the most 

common sources are warm-blooded animals.

 There's also cellulose powder as an 

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ingredient here. When we were evaluating this as 

a subcommittee we considered that to be more of 

an ancillary material. But we can go into some 

more discussion about that.

 Some advantages of this material is 

that it provides a mechanism to produce meats of 

uniform animal products. So in other words it 

allows for producing kosher and other sausage 

products more efficiently and it basically 

extends the market for organically produced 

material.

 Collagen itself is a protein. It's 

basically structurally similar to the gelatin 

that's already on the National List. 

 There's no real toxicity or other 

issues associated with this material.

 We had a lot of discussion on the 

committee about whether we should classify this 

as synthetic or not because of some of the 

processing steps. And we decided to list it at 

606 as non-synthetic because the primary core 

material is derived from an agricultural product. 

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But that's something that we kind of struggled 

with.

 Also by placing it on 606 there's the 

specification that -- a preference going forward 

for organically sourced material.

 If we -- I should mention too that the 

subcommittee voted unanimously to list this 

material.

 There's been fairly extensive public 

comment on it this time around. We had a very 

brief discussion document published at the last 

meeting. There was almost no comment on it at 

that point.

 And this time there's been some more 

extensive comments primarily from membership 

groups and others concerned about -- raising 

concerns about what they consider a violation of 

organic integrity.

 Some of the main concerns are, one, 

well perhaps cellulose should not be viewed as an 

ancillary material here, that it's part of the 

structure and that this shouldn't be under 606. 

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 Perhaps more importantly and we kind 

of touched on this in the review that we're 

talking about using collagen gel derived from 

animals that are potentially raised in CAFO or 

other kind of industrial agricultural settings 

and that as such this source material is tainted 

by that source.

 So that was a real concern in our 

discussions and that's something that's been kind 

of universally raised by public comments.

 In general the public comments are not 

in support of listing this because of the 

concerns I just raised, and also -- and this is 

something that's come up with celery powder and 

other discussions that 606 can stifle production 

of new organic crops. It kind of provides a 

stopgap that can go on for years and therefore 

prevent the development of organic source 

material for a product like this.

 I think in the committee we felt that 

given that gelatin is already on the list and the 

similarity of this material to existing materials 

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on the list in terms of gelatin and also 

intestinal casings which may also come from 

similar sources as the collagen gel, that kind of 

the opportunity here to expand the market for 

organic meat could therefore ultimately expand 

access to organic product.

 Also it's a processed material and if 

we're talking about 95 percent organic and 5 

percent not, or made with organic that this 

material kind of fits into that category of the 

small percentage of non-organic materials.

 So I think there's some rich 

discussion here and I don't think I really have 

anything more to add in terms of the summary of 

the material or public comments so I think we 

should open it up for discussion at this point. 

A-Dae.

 MS. ROMERO-BRIONES: Yes, I just want 

to note that we also have gelatin in the sunset 

review and that we had similar discussions about 

gelatin and collagen gel because they're 

essentially -- one is just further cooked than 

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the other. So they're very similar. 

 MR. BRADMAN: Lisa and then Harriet.

 MS. DE LIMA: I think it's another one 

of those -- I mean, I don't like where the 

material is sourced from, but then I think about 

that sort of chicken and egg problem of like what 

comes first. Do you wait for availability and is 

that even realistic that we're going to end up 

with an organic cellulose and then be able to 

produce a certified organic meat product, or do 

we allow this so that we can continue to build 

the certified organic meat market and take more 

of that share away from the CAFOs and then the 

material comes next. 

 MR. BRADMAN: Just to clarify, the egg 

came first. Harriet.

 CHAIR BEHAR: So, on the webinar we 

did speak with a manufacturer of collagen gel and 

we asked about what are the barriers to producing 

organic collagen gel. 

 And so I specifically asked can you 

save up enough of the organic in order to then 

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have enough to do a production run.

 And he said that while it does have a 

long shelf life under refrigeration, about six 

months, that still would probably not get enough 

for them to do a production run.

 And that if you freeze it you 

basically lose the structure of the collagen gel 

to have the technical effect that you want it to 

have in the enrobing.

 So I think though as we -- I was 

actually somewhat positive in the fact that at 

least there's a six-month refrigerated shelf 

life. That's better than something like whey 

which has eight hours.

 MR. BRADMAN: Tom.

 MR. CHAPMAN: I want to echo A-Dae's 

comment that this collagen material is a 

precursor to gelatin. So if -- all the concerns 

raised in that regard also apply to gelatin on 

this list, at least from animal products.

 I agree that while very strict reading 

of classification may place this material on 605 

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I think 606 is truly the right home for this.

 It's clear that synthetic and nonsynthetic based on production techniques and raw 

materials could potentially be certified organic 

products even though our decision tree may place 

them in synthetic. Glycerin is a classic example 

of this, that depending on the form of production 

it could be agricultural, it could be nonsynthetic, it could be synthetic. And then if 

you use organic inputs that synthetic version 

could potentially be certified organic. I know, 

confusing, right?

 So, you know, to encourage that at 

some point we have organic gelatin or organic 

collagen I think 606 is the right home for it.

 I also -- I disagree strongly with the 

argument that placing items on 606 dissuades the 

-- or slows down the creation of an organic 

industry that can support this.

 Personally, I mean once you put 

products out there and then you make organic 

collagen gel the only people you have to go to is 

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to the certifiers. Let them know that you've got 

organic collagen gel and all of their operations 

when they do their commercial availability 

assessment every year need to reach out to you 

and you're going to charge whatever you want. 

And it'll be great for a couple of years and then 

competition will bring in other folks and it will 

go back to how it was.

 But we've seen that happen time and 

time again with materials that have come off 606. 

606 is a shrinking list. There's not much left 

on it.

 And then in some cases there are true 

supply chain challenges as we saw with the celery 

powder, and I think that's applicable to this 

material as well.

 So I support it because I don't know 

how I can support gelatin and not support 

collagen gel given that they're produced the same 

way. And I think this is the first step in 

growing, continuing to grow the organic meat 

market and will be important to grow it to a 

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point that then maybe collagen gel could be 

available from animal skins, organic animal skins 

on a regular basis.

 The other thing I just really quickly 

want to point out is organic is value-added at 

the farm which means it starts getting more 

expensive at the farm. That's part of what makes 

organic great because it allows farmers to have a 

better livelihood.

 But that also means that byproducts 

produced further in the stream add 

disproportionately to the costs of those products 

to consumers. So products that have a higher 

fraction of byproducts, cheese for example, 

disproportionately become more expensive on the 

shelf. And there is a financial decision that 

consumers have to make on how expensive an 

organic product they can actually afford.

 So finding homes, value homes for 

byproducts is very important. And so in the meat 

industry finding homes for the scraps of meat 

that can't be sold as full products is very 

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important to keeping that entire product valuable 

while also maintaining that value-add addition at 

the farm.

 MR. BRADMAN: I just want to respond 

to one thing and then we'll go to Dan. 

 Another point you make about the 

comparison to celery and 606. There's a 

difference here with the material used to source 

for collagen gel is really a byproduct of another 

industry, livestock industry. It's not being 

produced for organic.

 And I think that's one of the unique 

issues with celery powder when we go forward. 

Here we're actually using a conventional method 

to produce a product for organic. So we're 

actually using field space.

 But separate from that I think this is 

a little different from the celery powder. Dan 

and then Sue.

 DR. SEITZ: I'd like to preface my 

comments first with a quote from Otto von 

Bismarck who said law and sausage are two things 

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you do not want to see being made. To retain 

respect for sausages and laws one must not watch 

them in the making. The making of laws like the 

making of sausages is not a pretty sight. And I 

never dreamed I'd be involved in a regulatory 

process on the making of sausages. But that's 

beside the point.

 So, I just have to say as a consumer 

member I am torn on this for a couple of reasons.

 One, the sourcing of the materials. 

I mean, I would think a consumer buying sausages 

would not dream that part of the substances that 

are necessary for the making of those sausages 

come from CAFO operations, come from operations 

where there are use of excluded methods. So I 

actually -- I feel that from a consumer 

standpoint there's a real question on this.

 I think also the question of whether 

we speed up the growth of the organic industry is 

an interesting philosophic one. At the beginning 

it certainly was seen as a slow build happening 

on the foundation of very reputable practices. 

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 So it's not always necessarily a good 

thing to speed up production if it means -- and 

use and market share if you're using an approach 

that has -- is suspect.

 On the other hand good point that we 

already approved gelatin.

 And I just want to say from the 

standpoint of my two boys who love sausages I see 

-- actually I'm not going to go there. 

 But just to say I think there are 

really some deep questions around whether it's 

useful bringing in materials that are so suspect 

in order to increase market share. So I'm not 

sure yet how I'm going to vote on this.

 MR. BRADMAN: Sue, Tom, Emily and 

Steve.

 MS. BAIRD: I agree with Tom that this 

should be on 606. And I would point out that 606 

actually says that you can only use it and you 

have to do a commercial availability search 

before you can use it, a non-organic form rather 

than using organic form. 

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 I think it's been fairly well 

established that at the moment at least we don't 

have a sufficient amount of organic form.

 But by putting it on 606 you limit the 

producer, final producer/processor to having to 

do a commercial search.

 I think instead of limiting a producer 

from using it as non-organic it actually -- I've 

seen in the past it actually builds that market 

for organic because they have to go through the 

process.

 So I like the fact that it's going to 

be moved to 606 other than the fact that I think 

physiologically it needs to be there.

 That's all. I just think putting it 

on 606, they have to go through that commercial 

availability search which inherently adds to the 

restricting. We've seen that in the past.

 The other point that I like that Tom 

made was I am the executive director of MidAmerica Missouri Organic Association and in 

Missouri, at least in our region we have a very 

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small but trying to grow organic meat producer 

group.

 And the one thing that stops those 

producers from being certified organic instead of 

just telling them it's grass-fed is the fact that 

there's a real market for the steak or the pork 

chop, but you can't ever get rid of the rest of 

the product.

 So by creating the ability through 606 

that the processor has to try to find commercial 

availability organic maybe we will help those 

small producers to find a market for the 

byproducts.

 I like this. I'm totally in favor of 

it.

 MR. BRADMAN: Tom, Emily and then 

Steve.

 MR. CHAPMAN: I hear the concerns 

about CAFO operations. I'm pretty certain that 

this is not a make or break for the CAFO 

industry, whether or not organic adds it doesn't 

really impact them one way or the other. 

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 But I guess I'd also be remiss in not 

pointing out that this is not -- while this is 

acute to this material here, you should also, you 

know, if that's the concern to block this 

material I think we should heavily look at adding 

manure to 205.602 if it comes from a CAFO 

operation because in farming practices manure is 

widely used in farming as a source of nitrogen 

and it can come from any sort of source. And 

CAFO operations are a big source of that right 

now.

 So this is -- that concern is not 

alone in a small additive used to find market 

homes for meat products. It also goes all the 

way back to the farm level for what I would 

easily say is thousands and thousands of organic 

farmers.

 MR. BRADMAN: Emily.

 MS. OAKLEY: That's true and we could 

add many other materials to that, bone meal, 

blood meal, et cetera.

 But I don't think that precludes the 

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importance of discussing where these materials 

come from. And I don't think that they may be 

sourced. I think it's absolutely certain that 

they are sourced from CAFOs. 

 I live in an area with a lot of CAFOs 

and it's a real issue.

 I would just say that I kind of echo 

some of Dan's comments in terms of consumer 

expectation. I think there's a slight difference 

in a handling product from a crop product in that 

we're talking about something in the actual food 

ingredient that someone is eating.

 That being said as a farmer seat even 

though I don't produce livestock I also want to 

see farmers have additional outlets for their 

products. I find this to be a very conflicting 

issue because you can't find like a very fine, 

easy line to fall down on in terms of an ethical 

choice.

 I think that Lisa's comments were also 

important in terms of growing the organic meat 

industry and taking some of that market share 

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away from the CAFO industry.

 But it is a very nuanced and 

complicated issue. And the fact that we have 

gelatin and other materials on the list that are 

sourced from CAFOs doesn't take away the nuance 

or complexity or difficulty in making a decision 

on something like this.

 MR. BRADMAN: Steve.

 MR. ELA: I also -- I agree with all 

that's been said. And we've talked about 

gelatin. But I mean, our whole discussion on 

casings which is the other holder -- what do you 

call it, enrobement for sausage is the same deal.

 So if sausages already are mostly 

encompassed in a conventional animal byproduct. 

Not that we like that. And I found that 

discussion of supply chain of how you take a 

somewhat perishable product, I mean collage 

sounds less perishable but still perishable and 

accumulate a critical mass in order to promote 

the industry has come up with orange pulp and 

various other things. 

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 And that supply chain is very 

compelling. It is difficult. I want to see it 

change. I want to see it be different. But in 

the interest of fairness across the board and 

like I said because sausages are already --

people are eating sausages that way I don't see 

this as a real change. So I'm going to be in 

favor of it just for those reasons.

 MR. BRADMAN: Is there any more 

discussion? A little discussion about some of 

the wording related to the petition and the 

motion.

 Harriet, in the meantime we're going 

to go ahead with the classification. 

 DR. LEWIS: Just wait a moment. We'll 

make sure it gets up on the screen. Thanks for 

your patience.

 CHAIR BEHAR: Okay, we can do the 

classification.

 MR. BRADMAN: Okay. Let's vote on the 

classification motion.

 DR. LEWIS: Can you read it into the 

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record?

 MR. BRADMAN: Yes. The motion to 

classify collagen gel as agricultural by myself 

and seconded by Harriet.

 DR. LEWIS: Thank you.

 MR. BRADMAN: So I think at this point 

we can vote. Is there any final discussion? 

 MR. RICE: Voting begins with A-Dae.

 MS. ROMERO-BRIONES: Yes.

 MR. RICE: This is classification 

vote.

 MS. DE LIMA: Yes.

 MR. GREENWOOD: Yes.

 MS. SWAFFAR: Yes.

 MR. CHAPMAN: Yes.

 MS. BAIRD: Yes.

 DR. SEITZ: Yes.

 MR. MORTENSEN: Yes.

 MR. BRADMAN: Yes.

 MR. RICE: Yes.

 MR. ELA: Yes.

 MS. OAKLEY: Yes. 

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 MR. BUIE: Yes.

 CHAIR BEHAR: Chair votes yes.

 MR. RICE: That's 14 yes, zero no. 

The motion passes.

 MR. BRADMAN: So now we're going to 

vote on the motion to add collagen gel. So 

there's a slight wording change in the motion. 

Do we need to vote on that change? Okay. I'm 

starting to get this.

 So we made a slight change to the 

motion to address specifically enrobement of meat 

products -- I don't think we want meat products 

that are disrobed. So we have a National List --

I shouldn't have said that -- a National List 

motion to add collagen gel for enrobement of meat 

products. 

 DR. TUCKER: Just remember transcripts 

are forever.

 MR. CHAPMAN: Pullulan.

 MR. BRADMAN: This is embarrassing.

 MR. RICE: We can pause for a moment.

 (Simultaneous speaking) 

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 MR. BRADMAN: Like a casing. I'm 

going to be remembered for this -- at 205.606. 

And Harriet.

 CHAIR BEHAR: Yes, so we just felt 

that -- Steve and I were talking, that the 

previous one instead of as petitioned, we want to 

know -- tell the program.

 And this is what we pulled from the 

petition. So I just want to make sure that 

you're happy like that. Like a casing was what 

the petition asked for and what was in the 

proposal.

 MR. BRADMAN: Yes.

 CHAIR BEHAR: So it actually did say 

sausage, but I think it could be used for hot 

dogs. And I didn't -- so I said of meat 

products. So I want everyone to be happy with 

that and we want to have a discussion. I'll make 

the motion to update this and then we can get a 

second and then we can discuss it.

 MS. OAKLEY: I'll second.

 MR. BRADMAN: Tom. 

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 MR. CHAPMAN: I guess I'm just curious 

why we need this annotation. What's the concern?

 MR. BRADMAN: Harriet, do you want to 

comment on that? I guess this was the language 

that was in the petition. 

 CHAIR BEHAR: This is what the 

petition asked for. I guess are we -- this is 

what we've talked about. I don't know if 

collagen gel would be added to other products or 

not, but we're talking about it and it was 

reviewed for this reason. So I guess without 

this if it's just collagen gel then we would be 

approving it as an ingredient in other foods I 

would imagine if someone came up with that. But 

this is all we've reviewed it for.

 MR. BRADMAN: Emily.

 MS. OAKLEY: So just a question. If 

we write as petitioned isn't that sufficient? 

Because isn't that -- I mean not to belabor the 

point. Going forward in all proposals should we 

be very clear and not say as petitioned but list 

the specific reason that it was petitioned? 

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 MR. BRADMAN: Harriet.

 CHAIR BEHAR: Yes. And we just did 

that with a previous item.

 I think it's better for us to be clear 

about what we are voting on rather than having 

the program consider it later what were they 

thinking of.

 DR. LEWIS: I want to add to that. I 

think it really helps in terms of the clarity 

that you can provide in terms of the review and 

also looking at what the petition is actually 

asking for would help us to review your work and 

to take appropriate rulemaking steps.

 MR. BRADMAN: Clarissa, do you want to 

add something?

 DR. MATHEWS: Thank you. Just to 

clarify, the petition does have a rather lengthy 

description of intended activities and uses. And 

perhaps that's why the subcommittee had listed it 

that way as petitioned.

 MR. BRADMAN: That is why. Tom.

 MR. CHAPMAN: I mean, I guess I'm fine 

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voting for this. I will vote for this if this is 

what needs to get support to put it on here.

 But I find this very different and a 

significant difference from what happened with 

the pullulan petition.

 The pullulan petition in the actual 

item they were petitioning asked for it to be 

restricted that way. In the petition which I 

have in front of me item A1, Devro, Inc., is 

petitioning the inclusion of collagen gel in 

section 7 CFR 606 non-organically produced 

agricultural products allowed as ingredients in 

processed products and labeled as organic.

 There's nothing in there restricting 

it to this application. I know that's the 

majority usage of this application and this is 

what we've majority reviewed. And if we had a 

reason why we wanted to specifically restrict it 

to this application I think that's fine and 

that's something we should have done, but we 

should have also allowed the public an 

opportunity to comment on that as opposed to just 

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doing this here at this meeting.

 That was there in and throughout the 

entire conversation of the pullulan one. I hope 

I'm saying that right. That was not here with 

this one. And so I see these as being very 

distinct.

 If that was necessary for us to list 

this then I was fine with that -- fine with that. 

I don't know of any collagen uses at 5 percent or 

less of a product that are out there besides meat 

products. I mean, I know it's used as a 

supplement but that's like the supplement. So 

it's 100 percent or 90 percent plus of that 

product. So a listing on 606 isn't going to help 

those people.

 I generally wouldn't be opposed to 

this, but I just don't like the process by which 

we're adding this in here on this item.

 MR. BRADMAN: Harriet.

 CHAIR BEHAR: Well, when Asa 

introduced it to us this is the way he introduced 

it. So I was just trying to have the clarity. 

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 And I put it up there and I said well, 

we need to -- we're discussing it. If we want to 

remove the rest of it.

 I just didn't want it to say as 

petitioned because I felt that that was not clear 

to the program what we were getting at. And then 

they would have to go searching through the 

petition and see what did we actually vote for.

 So I'm opening this up to -- if we 

want to remove the enrobement part and vote on 

that I'm okay with that. But I really don't like 

the as petitioned because I don't think that's 

clear enough for the program. And for us to say 

this is what we're voting for.

 MR. BRADMAN: Clarissa, you wanted to 

add something?

 DR. MATHEWS: Yes. In section B of 

the petition number four, intended activities and 

application rate the petition states collagen 

casings and gels are GRAS for use in sausages and 

meat products. 

 For Devro's purposes the collagen gel 

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will function as a coating casing in sausages, 

hot dogs and other meat products manufactured 

using coextrusion production systems. Casing 

coatings are vital to holding the form of the 

meat product. 

 MR. BRADMAN: Right. I mean, this 

discussion that's going on, the reason why I used 

the word as petitioned because I assume that by 

reference brings in the specific language of the 

petition. 

 And in terms of clarity to the program 

I think that clarity depends on the content of 

the petition. 

 I do understand the petition to focus 

on this use. So I'm kind of weighing it. I 

don't see the conflict quite as strongly perhaps 

as Tom does, but is this something that we would 

vote on as a group, this change, or -- Emily, you 

want to comment? 

 MS. OAKLEY: This is a question for 

Clarissa or the program as to what is most useful 

for them. Whoever wants to answer that. If we 

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were to say as petitioned or the new language.

 DR. MATHEWS: I think given that 

section four intended activities and applications 

is pretty clear either way would be fine. I 

think program would be fine with the original 

language in the motion that was shown originally.

 MR. BRADMAN: Harriet.

 CHAIR BEHAR: I'm not sure what the 

program would do in the actual listing when it 

goes on the National List. Would you write as 

petitioned? Or would you come up with wording?

 DR. TUCKER: Remember for anything 

that's petitioned it would go through a proposed 

rule process. The proposed rule would have the 

specific language that would be proposed for 

addition to the National List.

 Then that would be opened for public 

comment meaning that they could also comment on 

that particular language. 

 So it depends a little bit in this 

discussion on how specific you want to signal the 

program to make the proposed rule or whether 

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you're kind of leaving it to us to pull out of 

the petition for the proposed rule what you want 

in it. I would personally vote for more 

specificity myself.

 MR. BRADMAN: Okay. Dan and then Tom.

 DR. SEITZ: I like the greater 

specificity here. I think the shorthand in the 

wording reflects what the petition says.

 As petitioned means you have to go 

find the petition. People won't always 

necessarily even easily find the thing that is 

being referenced.

 And also if we don't have anything 

like as petitioned or our shorthand understanding 

of that as expressed in this wording then we 

potentially leave this open for uses that this 

group had never even had a chance to really 

discuss.

 MR. BRADMAN: Tom.

 MR. CHAPMAN: I think the answer to 

the question that Harriet posed, they wouldn't 

put as petitioned on the National List. They 

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would just put collagen gel. And so it is what 

Dan says, it's that last point, that it would 

just be on 606 as collagen gel like the other 

thousands and thousands of materials that appear 

on the National List without an annotation.

 Dan's point is the accurate one that 

without the annotation then it's potentially open 

to all uses. This annotation limits it to meat.

 I don't particularly have a problem 

with that. I have a problem with us not opening 

it up to the public.

 MR. BRADMAN: Emily.

 MS. OAKLEY: But do you think the 

public understood from the petition and from the 

proposal that that was the intended use?

 MR. CHAPMAN: That was clearly the 

majority of the reason why this -- that was the 

reason why this item was petitioned by Devro and 

that's how it's used I think in this application 

that we reviewed.

 It doesn't mean that's the only 

application. There are dozens and dozens of 

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examples of items that get petitioned to the 

National List by a single interested party that 

once it's on that list can be used in other 

applications.

 So someone who petitions for citric 

acid might be using it for acidification, and the 

next person might use it for -- ascorbic acid, 

might use it for acidification. The next person 

might use it for fortification. And we may have 

looked at primarily on the acidification route, 

not fortification. But if it's okay for use, 

it's okay for use unless we as a board thought 

about it and wanted to restrict it to a certain 

item. 

 But that thinking about it and wanting 

to restrict it, that should be part of the public 

process. 

 DR. LEWIS: Tom, based on your review 

of the public comments that have come in was 

there an understanding in terms of this 

description here?

 MR. CHAPMAN: The conversation was all 

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about meat. So yes, in that sense it's all about 

meat.

 But that also wasn't open to have a 

conversation about other applicable uses. So you 

know, it's like in the absence of bringing 

something up was it discussed. I don't know. I 

don't know if the public had an opportunity to 

look at it in other contexts because they didn't 

know we were going to propose restricting it to 

just meat.

 MR. BRADMAN: Emily, then Harriet.

 MS. OAKLEY: I think that because the 

motion was as petitioned they would then go back 

to the petition and they would see the reasons 

and the uses that Clarissa just read which 

clearly states that limitation.

 So I don't think that there was any 

confusion in the public comments as to other 

wider uses that this might be allowed for.

 MR. CHAPMAN: But I disagree with 

that. As petitioned, it was petitioned for a 

straight usage. It was not petitioned for that. 

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That was an intended use for this petitioner. 

That's not how they petitioned the item.

 MR. BRADMAN: Harriet.

 CHAIR BEHAR: Well, I'm not sure that 

I necessarily agree with that. I think that's 

what they wanted this to be used for. And this 

is all we discussed it for.

 So I guess I would feel better if we 

were going to just add collagen gel, if that's 

what we wanted to do, I feel like it should go 

back to subcommittee and we should look at other 

uses. 

 Because this is what we looked at. 

This is all we discussed for it. We didn't look 

at it for other uses. So I'm uncomfortable just 

putting it on the National List for possible 

other uses. This is what we discussed.

 So if we want to send it back and have 

it open to the public again for possible other 

uses.

 And I disagree. On other products we 

do know what the various uses of it. So citric 

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acid, we know the many uses of it before we had 

decided to put it on the National List.

 MR. BRADMAN: Tom.

 MR. CHAPMAN: I mean, if that's the 

case why do we get public comment every sunset 

round about how we added an item and didn't think 

about other uses for it. 

 We talk about firming agents for tofu 

that can be used in other applications and we get 

asked why we didn't restrict it further. This is 

numerous, numerous times this has come up again 

and again.

 MR. BRADMAN: So, I guess I want to 

see a way forward here. Steve, why don't you --

you have your comment. Let's talk about a way 

forward.

 MR. ELA: So Tom, I agree with what 

you're saying as a point of process in general. 

I 100 percent agree. I feel like I'm comfortable 

with this because this is as it was petitioned, 

as it was described in the petition, but I think 

in the future your point is I think we as 

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subcommittees need to be very clear as we put 

things forward for discussion to avoid this kind 

of error. We're bogged down.

 My personal feeling is that we should 

vote on it. People can vote their conscience 

either way and that's how we move forward.

 MR. BRADMAN: So I just want to say 

too I think process is important and the issues 

that Tom is raising is important.

 If we vote on it as it's written here 

which I think does reflect the petition use it 

doesn't preclude someone in the future 

petitioning for another use. And maybe we can 

deal with that at that time.

 Given our workload, our time today, 

our time going forward I think -- I do see as a 

way forward to perhaps deal with the narrowing 

here. But I think your points are well taken and 

going forward we should think about that. Tom.

 MR. CHAPMAN: For the most part it's 

a question of process for me. I mean, like I 

said I could be perfectly fine with this. I just 

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don't think we gave people the opportunity for 

it.

 The one inconsistency I would want to 

put out, the one that I would want input from the 

public from is when we look at the casings 

listing which was very similar product from 

similar origins we don't have the similar 

restriction on it. So why would we restrict it 

on this material and not on the casings material. 

 MR. BRADMAN: Harriet, then Emily.

 CHAIR BEHAR: So I think we need to be 

clear. I really don't like the word as 

petitioned. Because this could be what the NOP 

had come up with as an annotation if they would 

have looked at it. We don't know. So that's 

what I'm -- I really want to remove the as 

petitioned word for what we're passing so we're 

really clear about what we -- and for me I feel 

like this is all we really talked about.

 MR. CHAPMAN: Can I ask a question 

then? Would you support an amendment that just 

strikes the words as petitioned? 

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 CHAIR BEHAR: I'm a little bit 

uncomfortable because we never talked about other 

uses. But you're correct that that's all that's 

been asked for at this time.

 Maybe at sunset the next time we can 

look at it again and see if there's been other 

uses or not that we don't like.

 MR. CHAPMAN: But you can't look at it 

at sunset because you don't review annotations at 

sunset. So once we list it that's how it is. 

And there's not going to be other uses in organic 

production because we're restricting it here.

 MR. BRADMAN: Unless it was repetitioned.

 MR. CHAPMAN: Unless it was repetitioned.

 MR. BRADMAN: Emily.

 DR. LEWIS: So, a couple of things 

here. What we're doing -- I appreciate, Tom, 

what you're bringing up in terms of did the 

public have an opportunity to kind of be aware of 

the scope. 

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 I think also what is happening here, 

and again we always like to have clarity to help 

us, the program, with the work.

 If we're now going to be looking at 

the motions in the future instead of using the 

word as petitioned if we're going to be providing 

greater clarity that's a whole new precedent in 

terms of how the board is going to be doing some 

of its work.

 So, I want you to be thinking about 

it. We might want to also pause in terms of this 

action if we can at least kind of caucus during a 

break and talk about how best we want to pursue 

that and then come back and discuss this further.

 MR. BRADMAN: I think I'll defer to 

the chair on that decision.

 CHAIR BEHAR: I think maybe we could 

put it to later on today and come back to it.

 MR. CHAPMAN: I move to table this to 

deferred items.

 CHAIR BEHAR: I'll second.

 MR. BRADMAN: Do we need to vote on 

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that?

 MR. CHAPMAN: Or you could ask for 

acclimation. You can ask for unanimous consent. 

Does anyone object via unanimous consent?

 MR. BRADMAN: Does anyone object to 

deferring -- just to defer discussion on this? 

No objections. 

 So I think that then moves us into the 

sunset review discussions. Are those up on the 

screen? Yes, okay.

 So we're going to start with citric 

acid. And I think Lisa, you're on tap for that.

 MS. DE LIMA: So citric acid is 

produced through a fermentation --

 MR. BRADMAN: Am I missing something, 

Harriet? No, okay. You're on.

 CHAIR BEHAR: Should we take a break 

before we start the sunsets? I'm seeing some 

yeses. Okay. So it is 10:25. Let's do a 10-

minute. We're back at 10:35.

 (Whereupon, the above-entitled matter 

went off the record at 10:26 a.m. and resumed at 

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10:47 a.m.)

 CHAIR BEHAR: Okay, I'm going to call 

on Jenny Tucker.

 DR. TUCKER: Welcome back, everybody. 

A quick statement on the discussion which I 

thought was fruitful right before the break.

 I wanted to just on a broader scale 

talk about just briefly substantive changes. And 

so the public comment process to board proposals 

and discussion comments is very important in 

informing how the board votes at this meeting.

 If the comments or if the board 

discussion ends up yielding some kind of proposed 

modification to a listing that would change how 

the public would have commented on it that's 

considered a substantive change.

 So what we have to weigh is, okay, 

here's what the public got to look at. Here's 

what the board is now thinking based on what the 

public looked at.

 If that change is substantive meaning 

it might have led to different comments or 

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constrains the public in some way that the public 

didn't have an opportunity to comment on that 

would be considered a substantive change and we 

would send it generally back to subcommittee.

 So while non-substantive changes can 

happen in this setting substantive changes that 

the public didn't have a chance to weigh in on 

would be problematic.

 We haven't had that kind of refresher 

on what substantive change means in a little bit 

so I thought it was worthwhile to open this 

session with that.

 CHAIR BEHAR: Okay, we're back to Asa 

and the sunset materials.

 MR. BRADMAN: Okay. So, and that puts 

us then back with Lisa and citric acid.

 MS. DE LIMA: So, citric acid is 

produced through fermentation and is widely used 

in food processing.

 According to public comment we got 

this first round it's used to control pH as an 

acidulant, a buffer used in gel formation, it's 

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used to stabilize colors as an ingredient in 

dietary supplements.

 In the organic produce sector it's 

widely used in the formulation of disinfectants 

and sanitizers, allowed for use in direct contact 

with organic food without the need to rinse which 

is a practice that's essential for complying with 

FSMA requirements.

 It's also used for controlling pH in 

wash water used for post-harvest handling of 

fresh fruits and vegetables. And neutralizing 

the pH of wash water further reduces the amount 

of chlorine that needs to be added to the water 

in order to achieve the desired levels of free 

chlorine.

 So two commenters believed that citric 

acid should be classified as synthetic unless 

it's possible to define non-synthetic citric acid 

by annotation. And no new information was 

brought forward in terms of harm to human health 

or the environment. 

 The rest of public comment was 

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overwhelmingly supportive. Questions or 

discussion?

 MR. BRADMAN: No discussion? Okay. 

I guess then we can move on to lactic acid which 

is also in your court.

 MS. DE LIMA: So, lactic acid 

originally isolated from sour milk. Lactic acid 

today is produced through carbohydrate 

fermentation.

 Uses from public comment included as 

an acidulant, flavor enhancer, buffer, 

coagulating agent, pH control agent, carcass wash 

and as a processing aid in conjunction with 

celery powder.

 In the organic produce sector it's 

widely used in the formulation similar to citric 

acid, formulation of disinfectants and sanitizers 

allowed for use in direct contact with organic 

food without a need for rinse.

 And same concern from two commenters 

that believed that lactic acid should be 

classified as synthetic. And no new information 

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was brought forward in terms of human health or 

environmental concerns.

 MR. BRADMAN: Any comments? Harriet.

 CHAIR BEHAR: I guess just -- I've 

seen this used as a wash on meat products to 

mitigate E. coli. I think there's some 

inconsistency and somebody brought this up in 

public comment with sanitizers that if the use of 

that product makes it not 100 percent organic any 

longer.

 And I think some are saying yes and 

some are saying no. So I'm just putting it out 

there that there's an issue with the 100 percent 

label and the use.

 It doesn't affect re-listing this 

product, but I just wanted to have it on the 

record.

 MR. BRADMAN: Emily.

 MS. OAKLEY: Isn't that a question for 

the program then in terms of helping certifiers 

get clarity on how to interpret that?

 DR. LEWIS: I think it's fine the way 

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it's moving forward. It's fine the way it's 

moving forward. No further comment on that.

 CHAIR BEHAR: No comment from the 

program.

 DR. LEWIS: It's fine the way it's 

moving forward.

 MR. BRADMAN: Any other comments from 

the board? No? Okay. I think then we can move 

on to calcium chloride which, Tom, is in your 

court.

 MR. CHAPMAN: So calcium chloride is 

used in a wide variety of food processing 

applications. And the ones that we knew of going 

into this was use as a firming agent in tofu, cut 

fruit and canning applications, as a sodium 

replacement to adjust mineral content in water 

for brewing applications as well as a nutritional 

electrolyte application.

 In addition to that we received public 

comment from trade associations, certifiers and 

manufacturers who use this substance who also 

noted its use as a buffering agent in fruit 

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preps, in cheese-making, in olive packing, in 

dairy analogs, as a disinfectant when used in 

conjunction with chloride to mitigate effects on 

plant tissues from chlorine or chlorides, and 

then also as a tool in mitigating acrylamide in 

I'm assuming baked applications.

 We did receive a comment questioning 

the purity of calcium chloride given that the --

what the commenter said was 6 percent impurities 

are allowed in food grade materials that they 

researched. 

 I pulled up the USP FCC monograph for 

this or what I could find of the monograph. It's 

actually up to 7 percent impurities.

 However, the commenter didn't provide 

any context for why 6 percent was considered an 

inappropriate level of impurities. And given 

that the FCC has a monograph that sets it 

actually at 7 percent it's a strange range of 93 

to 100.5 percent. So I don't know how you get to 

105 percent. I imagine that's a testing thing.

 But that was the totality of the 

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public comment. I didn't really hear much in 

terms of requests to remove this item, just 

really investigating what was meant by those 

impurities.

 MR. BRADMAN: Any discussion on 

calcium chloride? Harriet.

 CHAIR BEHAR: It's used heavily in the 

cheese industry.

 MR. CHAPMAN: Yes, I mentioned cheese. 

Yes.

 MR. BRADMAN: Any other comments? I 

think then we can move on to dairy cultures. And 

Steve, I think you're onboard for that.

 MR. ELA: I think Tom was going to do 

it he said.

 Dairy cultures, pretty universal, used 

a lot. Most of the public comments supported relisting. It's pretty straightforward.

 There was one comment that dairy 

cultures especially as a liquid product might 

contain preservatives such as sodium benzoate 

that should be reviewed as ancillary substances. 

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That was something to pay attention to.

 And also the Food Additives Council 

submitted a number of ancillary substances that 

should be added to the list that I showed in the 

document and for the fall I will merge those in 

so that that includes the public comments that 

were given to us.

 Otherwise pretty much universal 

support.

 One of the questions that keeps coming 

up is whether dairy culture listing is redundant, 

whether it should be combined with the 

microorganism listing.

 Again, all the comments at this point 

said yes, they really are kind of one and the 

same. The ancillary substances are the same.

 I think Stonyfield noted that during 

previous comment periods we've urged the NOSB to 

retain dairy cultures as a separate listing. 

This was in large part because at the time the 

NOSB was just beginning to have a more thorough 

review of ancillary substances and we had some 

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questions about whether this would affect the 

listing for dairy cultures.

 We can now see that the discussion 

document for the two materials are the same and 

the ancillary substances are the same and that 

they would support -- now that there's more 

clarity on that point they would not object to 

combining the two listings.

 So, and if you'll notice the writeups 

are very similar. So with that I think that is a 

very quick review of dairy cultures. Questions?

 MR. BRADMAN: Lisa.

 MS. DE LIMA: Just want to point out 

that Organic Valley did -- wasn't in agreement, 

but they didn't give a reason why. They said 

retain them separately, but there was no reason 

so we'd have to maybe just look into that as a 

subcommittee.

 MR. ELA: Thanks.

 MR. BRADMAN: Harriet.

 CHAIR BEHAR: This material has been 

on the National List since the very beginning. 

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And so that's probably why there's a little bit 

of concern between manufacturers of -- because 

when it was put on it didn't go through the same 

vetting that it does now.

 MR. BRADMAN: Any other comments from 

the board? I think we can move on to enzymes.

 MR. ELA: Okay. Let me find my notes 

here. All right. Similarly enzymes are widely 

used. Most of the comments support re-listing.

 However, there was one comment that 

the review of enzymes as a class even with a few 

specific representatives is insufficient to 

address classification and all the OFPA criteria.

 The classification of all commercial 

enzymes as non-synthetic is questionable given 

that the TR notes that chemical changes involving 

reactions with synthetic chemicals are sometimes 

involved in the manufacture, extraction, or 

purification. 

 So the comment was enzymes should be 

classified as synthetic unless annotated to 

define those that have not undergone synthetic 

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changes.

 Other comments, again, ancillary 

substances. The Food Additives Council did 

provide a few other ancillary substances to add 

which just like in dairy cultures I will add in 

for the fall review. Otherwise fairly 

straightforward although I guess the question of 

synthetic/non-synthetic is a big one but that 

it's annotated as it is now and we would have to 

add that as a separate work agenda item to 

separate all those things out.

 MR. BRADMAN: Harriet.

 CHAIR BEHAR: As with dairy cultures 

and microorganisms as well the certifiers do 

review that they are not from the product of 

genetic engineering. Just so people know.

 MR. BRADMAN: Any other comments from 

the board? Okay, I think then we can move onto 

L-Malic acid with Scott.

 MR. RICE: Thanks. L-Malic acid at 

205.605. There are two forms of Malic acid, DMalic and L-Malic. D-Malic acid is not approved 

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on the National List because a non-synthetic 

viable alternative is not available.

 L-Malic is used as a flavor enhancer, 

flavoring agent and adjuvant and is a pH control 

agent in a variety of foods to inhibit bacterial 

growth. 

 Its natural form occurs in fruit such 

as apples and cherries produced by the 

fermentation of fumaric acid. Fumaric acid can 

be produced by fermentation from glucose.

 We did get a significant comment on 

this. I should first add we do have an updated 

TR that's been received. That was received on 

March 20th and we've not had an opportunity to 

review that. We'll certainly be doing that as 

part of the process before fall.

 And a number of certifiers noted this 

on OSPs, their certified operations, several 

certifiers encouraged the NOSB to consider 

reclassifying as synthetic and moving it to 

605(b) noting that while there have been nonsynthetic versions available in the past it's 

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unlikely that there are commercially available 

non-synthetic sources of this material now.

 Most if not all of those commercially 

available sources are produced with petroleum as 

the starting material. And even when supporting 

documentation for L-Malic has stated produced 

naturally via enzymatic fermentation certifiers 

have seen that that refers to only the second 

half of the process. 

 Applying the materials guidance to the 

full production would result in classifying it as 

a synthetic.

 In the short term certifiers noted 

that they have been verifying for L-Malic acid 

looking at the big three compliance, that it is 

L-Malic acid and not DL or D and that it is the 

form with the same CAS number as identified on 

the National List.

 A couple of organizations oppose relisting because the principal document initially 

supporting is a TAP of DL-Malic, the synthetic 

form. But again we've got an updated TR that 

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we'll be reviewing as part of the sunset review 

of this.

 Any questions? 

 MR. BRADMAN: Any comments from the 

board? Harriet.

 CHAIR BEHAR: Will the Handling 

Subcommittee be looking to put this on their work 

agenda to see about moving it to a different --

has there been any discussion?

 MR. RICE: I don't think we've had to 

my recollection discussion on that particularly 

yet, but we will be reviewing the TR so I'm sure 

that would be something that we'd consider.

 MR. BRADMAN: I think we can move onto 

magnesium sulfate also in Scott's court.

 MR. RICE: Thank you. Magnesium 

sulfate has a wide variety of uses in food 

processing and personal care products, used as a 

firming agent in the production of tofu, 

sometimes combined with other coagulators in the 

production of tofu.

 It is manufactured from several 

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mineral forms recovered from the ground generally 

found in nature in the hydrated form. Excuse me, 

I have my notes in two places here.

 This is another that we've got a new 

TR that was received in April. We seem to have 

all the new TRs landing on these. And that 

review will be forthcoming.

 There were a few certifiers reporting 

and others reporting this material in their 

system plans.

 Two companies weighed in on the 

importance of it to their operations. One 

organization noted that the material should be 

reclassified as synthetic as the last TR 

indicated the purification and dehydration 

processes deem it synthetic. 

 So again, to Harriet's question before 

I think we would be certainly looking at topics 

like that as we dive into the TR that we've just 

received.

 MR. BRADMAN: Any comments from the 

board? I think we can then move onto 

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microorganisms and Steve, that's in your court.

 MR. ELA: I get all the little bugs 

this time. Incorrect use of bugs but anyhow.

 So microorganisms, again similar to 

dairy cultures. Broader class. One public 

comment that we need a clear definition of the 

term microorganism. The definition is critical 

for microorganisms in use currently and can be 

used to determine whether additional organisms 

such as unicellular algae should be considered 

microorganisms. So obviously microorganisms is a 

very broad class.

 There are also some lack of clarity 

perhaps of whether other products that are made 

from microorganisms or with the assistance of 

microorganisms, and we certainly -- I guess 

fermentation is mostly yeast, but it's not clear 

whether the listing is intended to cover them.

 These include nutritional uses, 

spirulina, both cultural microorganisms that are 

no longer living. So just trying to tighten up 

that listing a little bit perhaps. 

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 And then if the listing is intended to 

cover the group of killed microbial products then 

the evaluation should include algae as well as 

other organisms addressed in the TR.

 Otherwise pretty broad support. Again 

the ancillary substances that I mentioned as part 

of dairy cultures are the same for microorganisms 

and I'll add that into the chart for 

microorganisms.

 Otherwise widely used, broad support, 

but just with a few details in exactly what we 

mean by them.

 MR. BRADMAN: Any comments from the 

board on microorganisms? 

 MR. ELA: Can I ask a question? This 

is not my particular specialty and I guess I'd 

look -- as we take this back to subcommittee are 

those comments about the needing to define 

microorganisms a little more, how far down that 

path do we want to go? I guess I'd appreciate 

feedback from the broader board besides just the 

subcommittee. Anybody have any thoughts on that? 

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Fair enough.

 MR. MORTENSEN: Steve, I just had a 

thought that I was pondering when I was reading 

this the other night. Certainly there are all 

sorts of cultures where transformed organisms are 

being used in a variety of many different ways, 

not necessarily in organic. I'm not saying that.

 I just wonder if there needs to be 

greater specificity with respect to excluded 

means by which a microbial community that's in a 

culture has come about. Is that something that 

was discussed or should be?

 MR. ELA: It was not discussed in 

public comments. I mean, the de facto is it's 

organic. It's used in organic production systems 

so no, it can't be. And I would hope -- I mean I 

guess I would leave that to the certifiers' 

response on that of probably checking for that.

 When I hear from the board there's not 

a lot of stomach for this in defining things more 

carefully, I mean that's another work agenda item 

as well. We'll probably kind of go forward as is 

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unless anybody sees any major problems with that.

 MR. BRADMAN: Emily.

 MS. OAKLEY: I really feel like not 

being on the Handling Subcommittee it's hard for 

me to comment because I'm not doing that work. 

So I feel like it in large measure is something 

that that subcommittee has to determine.

 MR. BRADMAN: Rick.

 MR. GREENWOOD: I think it probably is 

worth taking a look because of the things that 

are in that. I notice there's bacteriophage in 

there and there's other kinds of microorganisms.

 So it's probably worth some discussion 

time just to see if we need to go forward and 

clarify it.

 MR. BRADMAN: Tom.

 MR. CHAPMAN: I think it's important 

to note that there's an annotation on this item 

that requires food grade so just keep that in 

mind.

 And then in regards to Dave's question 

I was wondering if the certifier on the board 

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could clarify how certifiers go about dealing 

with that question.

 MR. RICE: Yes, that would be with as 

we noted earlier affidavits of clarifying that 

it's non-GMO sourced.

 MR. CHAPMAN: So there's a global 

prohibition on that through the excluded methods 

big three prohibition and that applies to the 

microorganisms listing.

 MR. RICE: Yes.

 MR. BRADMAN: I have a question on 

this. The role of ancillary materials and for 

example, there's sodium benzoate and sodium 

aspertate.

 I'm not sure how to think about the 

ancillary materials here and whether or not 

they're present. That's something I know I would 

like to -- at least I need to get more educated 

about these issues.

 MR. ELA: My understanding -- Tom, do 

you want to answer that before I dive in and make 

a fool of myself? 

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 MR. CHAPMAN: I'd love to see what 

your understanding is and if it aligns with mine.

 The last -- where I left it, this came 

up, this was under while I was chair of the board 

and the program was under different management so 

I don't know if anything has changed about that 

time.

 We have a proposal out there on how to 

handle ancillary substances, but the NOP has not 

acted yet on that. 

 We didn't particularly want to go 

through and start making additional 

recommendations about ancillary substances until 

we got feedback from the program as to whether or 

not the methodology we put forward was 

appropriate.

 At the same time we didn't want to not 

move forward at all either.

 So the compromise that was struck is 

in the interim while we wait for a response from 

the program we're going to document known 

ancillary substances. 

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 And there's a way in how we proposed 

it is how we would potentially prohibit ancillary 

substances that we did not like. Until we know 

that the program is onboard with that we weren't 

going to go through and take any of those actions 

at this time.

 So we're kind of in a wait -- a 

document and a wait. And as soon as they take 

action on it then we can go forward with any 

removals we need to specify.

 MR. ELA: That was better worded than 

what I was going to say, but that was my 

understanding as well, that it's really a 

documentation process at this point. And then if 

there is some movement forward then we have that 

information and we can go back and pull things 

out. But right now there's no action on them per 

se except to note that they're there.

 MR. BRADMAN: Harriet, and then Emily, 

and then maybe the program could comment on that 

too.

 CHAIR BEHAR: So, part of this when it 

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came forward was at least now we have a listing 

of the ancillaries so that it's a little clearer 

to the certifiers that not only did we approve 

kind of a generic, but we are aware of what's in 

there. So when we are voting that we are voting 

for all.

 But there is a process for some 

evaluation of the ancillaries. But that hasn't 

moved forward. 

 But at least at this point -- because 

some certifiers might say sodium benzoate, we're 

not going to allow that microorganism and another 

one would. So we were trying to have that --

bring some consistency. 

 MR. BRADMAN: I think Emily and then 

Lisa, did you want to say something? Okay, 

Emily.

 MS. OAKLEY: You did read my mind 

though because I don't know if I raised my hand 

but you read my mind.

 I just think that this points to the 

problem of not having NOSB recommendations passed 

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in such a wide range of areas. And I would just 

be remiss if I didn't state that because we spend 

so much time doing the work.

 And this board and this whole label 

cannot be subject to changes in policies and 

preferences. And we need to have a uniform 

application of how these standards are vetted 

through the government and then through 

rulemaking and applied. So I just felt the need 

to say that.

 MR. BRADMAN: Would the program care 

to respond to any of those comments?

 DR. LEWIS: In terms of ancillary 

substances, yes, we're aware in terms of the 

recommendation that had come forward. We're 

studying it right now.

 I think what Tom kind of addressed in 

terms of moving forward is continue that process 

at this time.

 I'm not sure if, Clarissa, you want to 

add anything to this.

 DR. MATHEWS: Sure. I think the 

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program continues to support the information 

gathering and documentation that's being done, 

but we would just remind the board that you're 

obliged to review generic materials at this 

point.

 And we do rely on certifying agents 

that would be responsible for reviewing ancillary 

substances.

 MR. BRADMAN: Any more discussion? 

 DR. LEWIS: Just a question again, 

Asa. We kind of went back to the original point, 

it's about the issue of other microorganisms.

 So, just to make sure I'm hearing 

correctly it's that there isn't any further 

discussion on other organisms.

 MR. ELA: I mean, I think we'll bring 

it up in subcommittee. I just was wanting to see 

if the broader board had any input before we 

discussed it.

 I mean, the listing is at is now. 

That is the sunset review. Public comment asked 

us to clarify that a little bit, but to me that 

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would be an additional work agenda item --

 DR. LEWIS: That's correct.

 MR. ELA: -- that's not part of the 

sunset. But I guess in the committee we can 

decide if we want to go down that path or not. 

That's why I wanted to hear from the full board 

if there was any burning desire to do that.

 I think we're cautious with our work 

agenda items. We have plenty to do. But we also 

want to respect public comment and take things 

into account. So we'll talk about it at the 

Handling Committee.

 MR. BRADMAN: Okay, I think we're done 

with the discussion on microorganisms. The next 

material we have is perlite. And let me check my 

notes here. I think, Scott, that's in your 

court.

 MR. RICE: It is. Perlite for use 

only as a filter aid in food processing. Perlite 

is used as a filtrate in food processing such as 

filtration of juices, beer, wine and vegetable 

oils. 

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 It's an amorphous volcanic glass 

naturally occurring and sourced primarily in the 

U.S., Greece, Turkey and China. The high water 

content causes it to expand many times its 

original volume when exposed to high 

temperatures.

 It is listed widely in international 

regulations. It's been consistently supported by 

NOSB and stakeholders. There's been some concern 

with the potential human health hazard of 

inhalation of fine silica dust when using this 

material, but personal protective equipment such 

as dust masks can minimize that.

 And a number of certifiers noted the 

use of this product by their operations and other 

commenters from the community supporting the relisting of it. So broad support.

 MR. BRADMAN: Harriet.

 CHAIR BEHAR: I don't believe there 

are, but are there any ancillary ingredients?

 MR. RICE: I don't believe so and none 

were noted. 

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 MR. BRADMAN: Any other comments 

related to this material? Okay, I think we can 

move on then to potassium iodide in Tom's court.

 MR. CHAPMAN: Potassium iodide is used 

as a form of iodine in trace mineral supplements. 

FDA allows its use as a food additive in three 

different ways, as a nutrient in table salt for 

iodine, as a dietary supplement for human 

consumption and as a sanitizing agent in food 

processing equipment.

 We received public comment on this 

mostly around its use in infant formula or as a 

dietary supplement in it looked like gummy 

candies.

 And we asked a question given its use 

as a nutrient if it was being used to sanitize. 

I did not see comments speaking to its use as a 

sanitizer in particular.

 We also asked if its listing was 

redundant with the broader listing of nutrient 

vitamins and minerals and we did receive a 

comment back from that directly from a certifier 

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saying yes, they did see it as redundant.

 Although in general related to our 

nutrient vitamins and minerals listing we 

received several comments asking for individual 

listings, not for a global listing, so you can 

take that as I guess people opposing removing 

this in the form of just lumping it under 

nutrient vitamins and minerals.

 We also received a comment that it 

should be annotated to state as a source of 

iodine when required by law.

 MR. BRADMAN: Any comments on this 

material? No? Okay. We can then move onto 

yeast. And that is in Steve's court.

 MR. ELA: Yeast, one of my favorite --

well, yeast makes lots of great things. Again, 

widely supported, widely used. 

 One of the questions was whether there 

is sufficient supply of organic yeast so that we 

don't need to continue this listing. And it was 

noted that organic yeasts are available but not 

always in the quantity needed and the quality can 

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vary, and that in certain -- in a number of uses 

organic yeasts have not yet met the functional 

qualities for specific flavors needed. So there 

are certainly organic yeasts available, but the 

question of quality, quantity and specific uses 

is still somewhat open. So there was argument 

for the continued listing of this at this point 

even though that marketplace may be slowly 

changing.

 Again, ancillary substances. Yeast is 

produced by fermentation. It's separated by 

physical methods from the culture. It meets the 

OFPA requirements but there are many ancillary 

substances that have not been reviewed some of 

which may be problematic.

 And I may have missed but I don't see 

any actual substances listed in the public 

comments. I need to go back and double-check 

that I didn't overlook something on that. But if 

there were I'll get those added in to what we 

already have. But otherwise again very critical 

to the handling community. 

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 MR. BRADMAN: Any comments on yeast? 

Dave.

 MR. MORTENSEN: Steve, this is a case 

where I was wondering about microorganisms and 

then we have a class, one genus in its own 

category.

 And so -- and I guess this is actually 

a genus that I know whether or not it's used in 

organic, but I actually have heard rumors so I'll 

just say it's a rumor. I haven't studied it to 

substantiate it that there are many transformed 

cell culture lines of yeast that are used in 

cheese-making and other uses.

 So I mainly just raise the question 

what's the logic from a structural organizational 

approach to having microorganisms writ large and 

yeast as its own category as opposed to a 

category that is microorganisms that are broken 

into subgroups or something which would make more 

sense to me.

 MR. ELA: That's a great question. I 

personally can't speak to knowledge of that since 

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this is a listing I've taken over. I'm assuming 

-- if there's other people that know. I'm going 

to guess that this was how they were petitioned 

or added to the list, probably added to the list 

originally and that's how they were broken up and 

so we have those remnant classifications.

 I think there was more -- I mean there 

certainly was more comment and questions on the 

organic availability around yeast than some of 

the other microorganisms. So maybe by breaking 

them up it could in the future mean we could 

remove a class from allowed substances that 

aren't organic to it's available, we need to use 

the organic forms.

 Whereas if we lump them all together 

that becomes a little bit more problematic. But 

I'm open to the program or anybody else giving 

insight on that because that's --

 MR. MORTENSEN: Just to respond to 

Steve's -- it seems to me just organizationally 

and I don't know, as far as tracking things, 

which are the organisms that we're looking at for 

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different uses in different food cultures and 

such that it would make sense to me that it might 

be time to rethink how we're doing that and put 

them into a broad category with subsections or 

have two or three classes that we follow.

 I actually think that the issue of 

purity of some of these will become increasingly 

challenging to track with all the advent of 

fermentation and other changes to organisms. 

That's in the works. So it might be a time to 

revisit how we follow this.

 DR. LEWIS: I think in this case it's 

similar to the conversation before about other 

microorganisms and is this something that 

requires further discussion. Thinking about the 

subcommittee, I think it's appropriate for a work 

agenda item.

 I mean, again we kind of spoke about 

it in terms of the long list of activities that 

you have to work on and is it something that you 

want to be thinking about. So kind of move 

forward in that way. 

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 MR. ELA: Do you have something, 

Harriet?

 CHAIR BEHAR: Just for the members of 

the NOSB that have not attended many meetings 

yeast was the central focus of many meetings as 

reflected in this very long annotation, the deep 

conversations we've had over yeast over the 

years.

 But not as deep on microorganisms or 

others.

 MR. BRADMAN: Emily.

 MS. OAKLEY: Yes, I was just going to 

say that this might be a good topic for Dave to 

take on, the work agenda item request that was 

made by one of the public stakeholders about 

products of fermentation. And since you're in 

the Materials Subcommittee it would just be a 

natural fit.

 So we can discuss that on our next 

call too.

 MR. ELA: Okay. And I guess Scott, do 

you have any -- from a certifier's standpoint any 

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perspective on -- I mean Dave keeps raising -- I 

mean, we know the GMO issue but as we --

certainly I mean we've talked about vaccines and 

there are more and more. 

 This is becoming a regularly used 

tool, manipulation for a lot of these 

microorganisms. I mean I know you had asked 

about that, but is there anything we as a board 

need to do to help narrow that -- not put all the 

burden on you guys?

 MR. RICE: Well, I think as you look 

with excluded methods definitions and things 

evolve I think we've been keeping that document 

current. 

 But beyond verification I can't think 

of an active role.

 MR. BRADMAN: Any other comments? I 

think we can then move on then. The next 

material is alginic acid and Lisa, that's in your 

court.

 MS. DE LIMA: Yes. Alginic acid is 

derived from brown cold water seaweeds. It's 

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manufactured through a chemical separation 

process.

 FDA allowed uses include as an 

emulsifier, formulation aid, stabilizer and 

thickener. And its use is limited to soups and 

soup mixes.

 We received no public comment from 

manufacturers using alginic acid and there were 

no reports from certifiers of it being included 

on any OSPs in the written comment.

 One interest group asked that the 

listing be reviewed within the broader context of 

marine materials and to consider adding an 

annotation related to harvest, and also riskbased testing for toxic materials.

 I'll say in response to that public 

comment the TR reported no residues of heavy 

metals in excess of FDA tolerances.

 Another commenter thought alginic acid 

should be de-listed due to lack of essentiality 

and environmental impacts from the seaweed 

cultivation. 

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 In regards to the seaweed harvesting 

the TR reported that the majority of brown 

seaweed species harvested for production of 

alginic acid are wild harvested.

 But then it did go on to say that in 

countries like China and Japan large-scale 

production could affect coastal waterways.

 So I just want to take this chance to 

encourage the community to get the word out and 

if there's folks out there that are using alginic 

acid that they submit comment to us before the 

fall meeting. That would be very helpful.

 The TR did point out possible 

alternatives like agar agar, carrageenan, gellan 

gum and xanthan gum. So again it would be 

helpful to hear if and why alginic acid is a 

preferred material.

 MR. BRADMAN: Emily.

 MS. OAKLEY: In the absence of public 

comments if you don't get any this fall do you 

have a sense of where you may be going with a 

recommendation for this material? 

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 MS. DE LIMA: No. We haven't really 

talked about it and I just got this material like 

a week ago. This was one of Eric's so I'm still 

learning.

 MR. BRADMAN: I think we can move on. 

But I look forward to discussing this in terms of 

marine materials and ecosystem impacts. I think 

that's going to be an important piece of this.

 I suspect the volume of material used 

is less, say, than for fertilizer or other 

inputs. 

 So that moves us to activated 

charcoal. And Scott's on that. Thank you.

 MR. RICE: Yes. Activated charcoal 

only from vegetative sources and for use only as 

a filtering aid.

 This is used in processing as 

mechanical filtration involving the separation of 

suspended solids from a liquid as it passes 

through a carbon porous media in a column or bed. 

Used to remove odor and used for purification in 

water and food. 

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 And has a very large surface area and 

pore volume that gives it that unique absorption 

capacity. 

 Of vegetative origin. It could be 

made from a large variety of resources, 

hardwoods, grain holes, corn cobs, nut shells.

 It goes through pyrolysis at a very 

high heat. They may be chemically activated 

using a variety of acids and bases including 

acetic acid, potassium hydroxide, sodium 

hydroxide as possible bases.

 May also be activated through exposure 

to oxygenated gas or steam.

 It is allowed across a number of 

international regulations. 

 A number of certifiers noted this 

appearing on numerous organic system plans. 

Trade organizations and individual companies 

commented in support of re-listing this material.

 One organization wrote wishing to see 

its use limited to filtration of water and 

requiring that activation to steam activation. 

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 Another in view of large -- the 

handful of number of chemicals used to activate 

or reactivate it, one of the TAP reviews 

suggested the annotation must meet food chemicals 

Codex purity requirements and manufactured from 

ag products by steam activation.

 And another comment supporting its use 

solely as a water filtering aid.

 But in wide use at this time and 

supported across the community with the exception 

of those comments I noted.

 MR. BRADMAN: Any comments on 

activated charcoal? No? Okay, I think we can 

move on then to ascorbic acid which I believe is 

also in your court.

 MR. RICE: Me again. One moment. 

Ascorbic acid, used as a dietary supplement and 

nutrient, flavor ingredient, used in meat and 

meat containing products, curating and pickling 

in flour to improve baking quality, as an 

antioxidant in fats and oils and a wide variety 

of other food processing uses. 

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 One of the most common sources of 

vitamin C. 

 The majority of industrial production 

of ascorbic acid is synthesized. Modern 

production processes use fermentation with 

additional biooxidation steps adding a 

biocatalyst which eliminates the need for the 

chemical steps.

 Synthetic ascorbic acid is identical 

in molecular structure and function to the 

natural.

 This is a vital nutrient necessary for 

humans and other primates. Humans cannot 

synthesize vitamin C and must rely on dietary 

intake. It is added to many foods to restore 

vitamin C lost during processing. Some FDA 

regulations require vitamin C fortification often 

achieved with the use of ascorbic acid.

 This was also one I picked up so my 

organization of it was a little bit different.

 A number of certifiers noted the 

presence of this material on OSPs. Manufacturers 

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noted its necessity in the organic product 

developer's toolbox of available food acids.

 One organization commented against its 

re-listing noting its used to fortify products to 

original pre-processing vitamin C levels noting 

it is a synthetic antioxidant preservative and 

should be removed, but in wide use now and an 

essential nutrient for human health.

 MR. BRADMAN: Any comments on that 

material? Steve?

 MR. ELA: Scott, with your additional 

information requested about biooxidation as an 

excluded method. It doesn't sound like you got 

any comments about that.

 But I think -- I mean I keep seeing 

and we've talked about fermentation in general. 

And to Dave's recent comments on yeast and the 

vaccine issue that we've so discussed it seems 

highly likely that we're going to run into more 

and more of these fermentation processes that are 

very likely to use excluded methods.

 I don't know how we can -- I don't 

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want to get backed in the corner like we are with 

vaccines where suddenly we have to allow this 

because there is no other choice, but yet given 

the small size of the organic industry I don't 

know how we help protect that system that doesn't 

use excluded methods.

 I don't expect you have any particular 

thoughts, but I just -- it's concerning because I 

can just see we're going to end up being 

railroaded into some of these things that we 

don't really want to be in. And I don't know if 

there's anything we can do to head them off at 

the pass.

 MR. RICE: Yes, I neglected to note 

that this also has a TR pending that we received 

on April 4th. So in addressing that particular 

question we may get some answers from that.

 In terms of your general question I 

think we'd like to be proactive and I think that 

our excluded methods work has helped in 

identifying those things. And I would say if 

that TR that's yet to be reviewed indicates 

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something that needs to be on our radar then that 

doesn't perhaps put us in a proactive position, 

but at least puts it on our radar as something to 

address. So no magic answer there.

 MR. BRADMAN: Steve.

 MR. ELA: Well, and I guess I hope 

that from the business community, and I think 

this comes back to I mean if we're talking about 

collagen and opportunities for businesses it 

would be as some of these things move to excluded 

methods.

 I mean obviously we can do it without 

them. It may not be as efficient. But I would 

hope that there are small businesses out there, 

whatever, that pick that up and say no, the big 

manufacturers might not be able to do it but 

we're going to provide a niche market. They know 

the processes are big and scalable and expensive, 

but I hope people pay attention to those 

opportunities in the organic community.

 MR. BRADMAN: Sue.

 MS. BAIRD: Yes, I think this is akin 

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as we did the livestock vitamins they noted in 

the TR that vitamin C was one of those vitamins 

that was commonly produced using genetic modified 

-- genetic engineering. So I think we may see 

the same thing in the human vitamins. They're 

all vitamins.

 MR. BRADMAN: Paul.

 DR. LEWIS: So this kind of brings up 

the issue, talking about yeast, ascorbic acid, 

vitamins and others. So it may be something to 

think about for the NOSB is that some of these 

materials that are important for organic 

production and the production of those materials 

that are using excluded methods and how best you 

want to kind of balance that and commercial 

availability of non.

 So it's something we can be talking 

about with you in terms of how you want to be 

thinking about that in the future.

 MR. BRADMAN: Any more comments on 

this material? 

 MR. MORTENSEN: I know we're running 

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long here. It seems to me that this would be an 

interesting case at some point to get some 

feedback from folks in terms of how retooled 

would you have to get in a synthesis chain to 

have two fermentation vessels. 

 So it seems to me that the cultures of 

the organisms that we're using and then the whole 

production line is going to have to -- if it was 

going to be something that we were going to try 

to segment it would be interesting just to 

understand how -- what that looks like if we 

wanted to encourage that. So it's just a 

thought. 

 I like what Steve is saying. I think 

it's something we need to unpack a little bit 

more and understand better as a group. I think 

it would be helpful.

 MR. BRADMAN: Sue.

 MS. BAIRD: In my past life as a 

coordinator of a feed and seed program for 

Missouri Department of Agriculture it was -- and 

that's been a lot of years ago. Maybe things 

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have changed. But most of these vitamins are 

manufactured overseas in China and those kinds of 

places and very few sources of them being 

manufactured.

 I think that if we go there we're 

going to have some real issues being able to 

source vitamins either for livestock or for 

humans. And that's been several years ago, but 

that was back then.

 MR. BRADMAN: Harriet.

 CHAIR BEHAR: This is just a time 

check. We are fairly far behind and we do have 

two speakers that are scheduled to start at 11:45 

on biodegradable mulch. 

 So I think we can maybe do a few more, 

but we should be aware that we do have two 

speakers here to present to us.

 MR. BRADMAN: Yes. I agree. Emily.

 MS. OAKLEY: Why don't we do one more 

and just in respect of their time schedules move 

into them.

 MR. BRADMAN: That sounds perfect. So 

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the next material is calcium citrate and Lisa is 

on deck for that.

 MS. DE LIMA: So, calcium citrate is 

the calcium salt of citric acid. It's prepared 

by neutralizing citric acid with calcium 

hydroxide or calcium carbonate and subsequent 

crystallization.

 Public comment was supportive and 

mentioned uses including fortifying nutritional 

supplements with calcium. It's also used in 

fruit fillings to thicken and stabilize gel 

structures and as a buffer in fruit and flavor 

preps.

 No new information was brought forward 

in terms of human health or environmental 

concerns.

 MR. BRADMAN: Any comments on that 

material? I think we can then pause.

 CHAIR BEHAR: Well, we can still do 

another one. We're not quite at time. 

 MR. BRADMAN: The next one will be 

easy. Ferrous sulfate is in Tom's court. 

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 MR. CHAPMAN: This one's going to take 

about 30 minutes. 

 Ferrous sulfate has an annotation on 

it for iron enrichment or fortification of foods 

as required by regulation or recommended in 

parentheses independent organization.

 Ferrous sulfate is commonly added to 

flours and cereal products to make an optional 

enriched claim and is often found in baked 

products or infant snacks. As a father to young 

children I often found it in those kind of first 

meal oat, or I guess it's generally oat kind of 

cereals were fortified with iron.

 Its use is pretty much solely as a 

nutritional additive to address population-based 

iron deficiency.

 We asked the question if it was 

necessary to continue the listing of this 

material given the broader nutrient vitamins and 

minerals listing.

 Same comments I said before apply 

here, that some comments were received supporting 

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its removal because nutrient vitamins and 

minerals listing incorporates this as well as 

other iron-based supplements.

 And we also received opposition to the 

holistic listing of nutrient vitamins and 

minerals.

 Specifically we received comment from 

industry about its use in infant formulas. And 

then we also got a comment from an interest group 

about ferrous sulfate itself and that it's 

potentially not the best form for iron 

supplementation and that it should be phased out 

and we should look for potentially an 

alternative, or that less processed foods and a 

whole food diet itself was sufficient to meet the 

iron deficiencies that are seen in populations.

 MR. BRADMAN: I don't know if there's 

any other questions. Was there any explanation 

of why this material -- I mean it's true that 

non-heme sources of iron are not absorbed as 

well, but any supplement in this form would be a 

non-heme source. 

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 MR. CHAPMAN: Like why other sources 

were better? It's not saying why other sources 

are better, but it's saying ferrous sulfate 

oxidizes fats and oils in vitamin E in the 

product which it occurs is to be avoided by using 

natural whole foods. When absolutely necessary a 

less destructive chemical should be used. But it 

doesn't really offer alternatives.

 MR. BRADMAN: Okay, thanks. In 

general I think diet should be the source of 

people's nutrients, but I think iron 

supplementation has been valuable from a public 

health point of view. And the iron deficiency 

has for example some of the same effects as lead 

exposure. It affects development in ways that I 

think we benefit from the supplementation here.

 CHAIR BEHAR: Okay.

 MR. BRADMAN: Any other comments? 

It's 11:46. Do we have the speakers here?

 CHAIR BEHAR: Yes.

 MR. BRADMAN: And are the 

presentations ready to set up? 

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 CHAIR BEHAR: Yes. So I invite the 

two speakers up and Steve can start discussing 

their bios. Steve as the chair of the Crops 

Subcommittee.

 MR. ELA: Just as a little bit of 

background before I introduce the two speakers we 

know over the past number of years we've had 

pretty extensive -- well, I shouldn't say 

extensive, but considerable public comment on the 

use of biodegradable mulches.

 We had a TR that we reviewed. We've 

also then in subcommittee in the sunset review 

process have discussed biodegradable mulches and 

it keeps coming back to the question of the way 

they are concurrently listed on the National List 

of having to essentially be 100 percent 

biodegradable.

 And that question if you look in the 

biodegradable mulch TR was left open as to what 

the fate of some of these biodegradable mulches 

are in the environment.

 We've specifically noted there were 

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several studies going on and that it was 

important for us to wait until we saw the results 

of those studies to be able to really assess how 

the board should proceed with the biodegradable 

mulch issue.

 Since we are meeting in Seattle and 

much of the research has been done by people out 

in this area it seemed like a very good 

opportunity to hear an update on some of this 

research to help inform the board.

 So with that I'd like to welcome our 

two speakers. Markus Flury is an associate full 

professor of soil physics and vadose zone 

hydrology at Washington State University. He's 

in the Department of Crop and Soil Sciences. 

 He in his past has been a visiting 

professor at the Chinese Academy of Science and a 

post doc at the University of California 

Riverside.

 He received his Ph.D. from the Swiss 

Federal Institute of Technology in Zurich. It's 

not often as getting to introduce somebody as a 

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soil physicist since that's what my own 

background is in and that he's editor of the 

Vadose Zone Journal. I'm sure that's something 

you all read, but yet that is the zone that 

affects us all.

 And so it's a pleasure to have you 

here, Dr. Flury.

 Dr. Ramani Narayan is a university 

distinguished professor at Michigan State 

University and that's the highest honor that MSU 

bestows on a faculty member.

 He's an elected fellow of the U.S. 

National Academy of Inventors and he's earned the 

Michigan Green Chemistry Governor's Award for 

developing biodegradable packaging and insulation 

foams.

 He is the scientific chair of the 

Biodegradable Products Institute and works on 

ISO, International Standards Organizations 

committees. And he's a technical advisor to many 

organizational groups in bioplastics.

 He is invited here as well and 

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hopefully will be able to provide some insight in 

addition to the current research that's going on.

 So I don't know who we'll start off 

with. I'm assuming Dr. Flury maybe if you're 

willing we'll start with you. Thank you for 

taking the time to come and really give us kind 

of an on the go update of something that we're 

very curious about.

 DR. FLURY: All right, thank you very 

much for having me here to talk and thank you for 

the introduction. 

 And I want to talk to you a little bit 

about biodegradable plastic mulches because we 

know that plastic is used in agriculture to a 

great extent.

 Most of the plastic that is used is 

polyethylene plastic which is not degradable in 

nature and it causes enormous pollution problems.

 So the idea is to replace polyethylene 

plastic with biodegradable plastic. There are a 

lot of questions then whether the biodegradable 

plastic is really useful and suitable for the 

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replacement of polyethylene.

 And so we had a -- SCRI is a USDA 

grant for four years now that we are looking at 

the sustainability of biodegradable plastic as a 

substitute for polyethylene.

 And what you see here, and I assume 

you can see that slide here on that screen here? 

Okay.

 So what you see here is the project 

team that we have. So it's a large team that 

comprises of many different scientists. I can 

advance the slide.

 So that research team comprises of 

soil scientists, plant scientists, material 

scientists, economists and sociologists. It's a 

large team where we look at the suitability of 

biodegradable plastics in agriculture.

 And what I want to talk to you about 

today and this is what you asked me to talk about 

is about the soil. So I'll talk about the soil 

ecology, more specifically how does biodegradable 

plastic affect soil, short-term and long-term. 

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 So what we did in this experiment is 

we set up two field experiments. One is in Mount 

Vernon in Washington. For those of you that are 

not from the state of Washington Mount Vernon is 

about two hours north of Seattle.

 And the other side is in Knoxville, 

Tennessee. And the idea behind this is that 

biodegradable degradation of course depends on 

the locality where you study biodegradation. So 

it depends whether the climate is warm, whether 

the climate is cold, depends on the soils.

 So we chose two sites. So one is a 

more cool Mediterranean site in Washington and 

then more a subtropical warm site in Knoxville in 

Tennessee. So the idea is to have two different 

climates to see how degradation really works in 

these two different locations.

 And what I want to show you here is 

the field site that we have. We have a pair of 

field sites. So one is in Washington, Mount 

Vernon. This is the one here in Mount Vernon.

 The same one we have in Tennessee as 

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well.

 What you see here is a replicated 

field trial where we look at different types of 

biodegradable plastics and then compare this with 

no plastic, with polyethylene plastic. And here 

is kind of the aerial view how that looks like. 

 So it's a replicated site with 

different types of treatments that we set up.

 And we have one treatment that we use 

is paper because paper is a treatment that we 

know is degrading very well. Paper is oftentimes 

used as a standard in tests of biodegradation. 

 So we see here is the paper is here on 

the left side and then you see this BDM. So BDM 

stands for biodegradable mulch, plastic mulch.

 So we have four different BDMs. We 

have a no-mulch treat of five different BDMs, a 

no-mulch treatment, and then polyethylene which 

is the current standard that we use.

 And so the idea then is to see how do 

those biodegradable plastics affect plant 

production, crop yield and horticultural aspect. 

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And then also particularly how does it affect 

soil.

 And in terms of the soil, and that's 

what I want to focus here in this presentation, 

we do very comprehensive assessments of soil 

health. So we measure soil physical, soil 

biological, soil chemical properties over time 

and compare this then to the paper, to the nomulch and the polyethylene. So this is the idea.

 And then we also measure the impact of 

those biodegradable plastics on soil organisms.

 So some of the questions that we are 

asking is does biodegradable plastic affect soil 

health. So that's an important question and we 

don't -- until recently didn't have good answer 

to that.

 Then the second one, does 

biodegradable plastic degrade completely in soil. 

So does it completely degrade. And Dr. Ramani 

will talk a little bit about the degree of 

degradation in his talk then as well.

 And then the third one, are residues 

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released when biodegradable plastic degrades, 

when the polymers degrade. So these are some of 

the questions that we try to answer in our 

research project.

 And I want to talk more about the 

first one of those. And this is the soil health 

aspect.

 And as I mentioned we measured very 

comprehensive soil health assessments. And what 

I want to show you here is just an example. I 

want to show you two examples. One is the 

physical parameters, aggregate stability, and the 

other one is the microbial community structures 

that are potentially affected by biodegradable 

mulches.

 And what you see here is a graph, and 

I'll see if I can use the pointer. Yes, I can 

use the pointer here. You probably can't see the 

pointer on your slide there.

 But you see Knoxville on the left side 

and Mount Vernon on the right side. And the 

different colors that you see on that figure are 

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different types of biodegradable mulches compared 

with no-mulch and polyethylene which the 

polyethylene is on the right side on the black 

bar.

 But what you can see here is a change 

of aggregate stability over time. And you will 

notice, and I think this is important for that 

meeting that these data have been assessed from 

2015 to 2017. So this is two years of 

information that we have.

 We are 2019 now so we are assessing 

now the fourth year of those measurements. And 

we are trying to do that for a longer term. And 

this is an important question, what are the longterm implications.

 But what you can see here for two 

years, there is very little change of 

biodegradable plastic compared with polyethylene 

and those are then compared to the no-mulch. So 

we see very little effect short-term within two 

years in terms of aggregate stability. This is 

the same for other physical parameters as well. 

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 Now, the next slide I want to show you 

is the microbial communities. And I can show you 

here two data sets. One is from Tennessee. The 

other one from Washington. Again, two years of 

data.

 And what you see in those graphs. So 

these are a little bit complicated to understand, 

but these are microbial community structure 

figures. So very typical what microbiologists 

usually do to classify microbial community 

structures in soils.

 And the different colors, what you see 

in the different colors are the different 

seasons. So we have spring 2015 and then all the 

way to fall 2017.

 And the different dots that you see, 

so these clouds of dots are the different 

treatments. So different biodegradable plastics, 

different no-mulches and the polyethylene. 

 And basically what you can see with a 

figure like this is that we see very little 

change of microbial community structures affected 

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by the treatment of plastics. So whether you 

have polyethylene, no-mulch, or you have 

biodegradable plastics. So there is very little 

change in the community structure.

 But you see a lot of change in 

seasons. So the microbial communities in soils, 

they change between fall and spring, and they 

also change over the year. So we see those type 

of effects, but very little in terms of the 

biodegradable plastics.

 And so the last slide that I have here 

is kind of summarizing some of those results that 

we have from our current project.

 So first of all we see very similar 

agronomic benefits. So in terms of crop 

production the biodegradable mulches behave very 

similarly to polyethylene. So it's a suitable 

substitute.

 And we see no short-term effects of 

the mulches on soil health. And I highlight here 

short-term in red as you can see because the 

important question is what are the long-term 

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effects. But short-term, so two years and very 

likely -- we are analyzing the data now for four 

years, there will be very little or no effects 

compared with our polyethylene or to the no-mulch 

treatments.

 Seasonal changes are much more 

pronounced in effects that we see based on 

treatments to plastic.

 And then the last thing, the fourth 

point is of course the long-term effects. So we 

have to be cautious of course because soil health 

and soil processes are slowly changing with time. 

So it is possible that things will show up when 

we do these experiments over longer periods of 

time.

 And then I want to also mention that 

actually our experiment is one of the only ones 

that we have now four-year long-term systematic 

evaluation of those biodegradable mulches and we 

hope we can continue this for a longer term 

study. That I think is really needed to look at 

the long-term effects. 

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 So this is kind of a short summary of 

our project and I'm happy to answer more specific 

questions should you have them later on.

 MR. ELA: I think like we did with our 

other panels we'll go ahead and Dr. Narayan can 

speak and then we'll open it up to discussion so 

that we can get both their inputs.

 DR. NARAYAN: Good afternoon. Let me 

get the slide up. Okay. So let me start with I 

think, Harriet, you posed six questions which I 

thought was perfect because for a professor to 

say tell us what you do, that would take the 

entire day and afternoon for you.

 And so I decided that I'll use your 

questions as the framing way in which I will 

address this presentation.

 So the first three questions which you 

had and which some was addressed was what is the 

overall effect of soil health, what is the 

cumulative effect of breakdown, what happens to 

these breakdown products. Those are the three 

important questions which you had. 

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 And to answer those I thought I will 

take the liberty of going back to fundamentals 

and take you back to school sort of. 

 So, as the question what does 

biodegradable really mean. What does everybody 

really think what biodegradability means.

 And in reality you're asking the 

question can microorganisms present in your 

disposal system, in this case it is soil, utilize 

this mulch film, this molecule as food for their 

life processes. And will they do it completely 

with no issues which is what was addressed 

earlier. So that's the fundamental question 

which we need to answer and evaluate and find 

out.

 Okay. So, here is a schematic. I 

have polymer molecules. These are carbon chain 

polymer molecules. I can make this breakdown. 

If you submit it to the environment, heat, light, 

they break down.

 You can enzymatically break it down. 

You can oxidate. There are a number of ways in 

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which I can break it down.

 When you break it down you get these 

fragments, these oligomer polymer fragments. And 

this is degradation. This is depolymerization, 

whatever you may call it. 

 And this is where some of the 

confusion starts. And this is your question was 

okay, it breaks down. Is this and that a 

problem? How do you know this is safe and all 

that?

 But the standard and what you have now 

in that NOP 1 does not allow you to stop at this 

stage. So biodegradability will be defined if 

and only if these fragments are completely 

utilized by the microorganisms present in soil in 

this particular case and in a defined time frame.

 And this is again the second part of 

the confusion. And I would like to say that this 

word biodegradable unfortunately has been the 

most misused abused term in our whole 

discussions.

 Everything is biodegradable. You are 

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biodegradable. And so we need to be more careful 

how we define this and how we use this.

 But in your system as you have defined 

it you are saying that it breaks down but that's 

not sufficient. Can you document and validate 

that the microorganisms will completely use these 

broken down fragments in a time frame and in a 

way in which I can measure it and quantify it. 

So that is where the standard which you have put 

in play in your document.

 So let's take this further. What's 

the fundamental basis. Dig deeper into this.

 First part is microorganisms utilize 

carbon as food. That's what you need to very 

clearly understand. They don't do it to clean up 

the environment for us. They don't do it to give 

us food. They are very selfish. They are going 

to have their food and thrive and grow. If they 

can't, they go dormant or they die.

 So microorganisms utilize carbon as 

food. They do so -- remember the large chains. 

That has to be small molecules and that has to be 

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transported into the cell. 

 If that food fragments don't go inside 

the cell it cannot utilize it. So one condition 

would be will they transport in.

 And once it goes in, what happens. 

Then the microbial process takes over. It is 

biologically oxidized to CO2. And the process of 

that oxidation results in energy being released, 

686 kilocals and forgive me if a professor sort 

of wanders into this deep science.

 But 686 kilocals of energy is released 

that is harnessed by the microorganisms for its 

life process. Just like you eat food and you 

break it down and utilize that energy for your 

life process. A very similar mechanism is 

operating.

 And that complex picture you see is 

that the energy released is harnessed by the 

microbial process in this ADP-ATP cycle. This is 

very similar to what happens in humans too.

 So, what is it that I'm communicating? 

I'm saying that if we have to document and 

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validate that microorganisms are truly utilizing 

this then we need to show that we feed these 

microorganisms these mulch films which have got 

the carbon molecules in there, measure the CO2 

coming out because that's what drives the 

biological process.

 And if I can document all of that 

carbon has evolved as CO2 then I can say that the 

microorganisms are utilizing. That is the 

fundamental basis for all these test 

methodologies.

 So this is a simple schematic. This 

is the actual basic standard that is followed 

across the world literally.

 You have soil. Don't give the soil 

microorganisms any other carbon food except your 

test specimen. If the microorganisms are capable 

of utilizing it you should see CO2 because that 

is the process by which microorganisms utilize 

carbon.

 Then you know how much CO2 is being 

evolved, how much carbon you have fed as food. 

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Don't give it any other food. Give it all the 

nutrients and all the other ingredients it needs 

and measure the CO2 evolved as a function of 

time.

 So now I have got a value for time. 

I've got a value for how much of the carbon is 

being utilized. And that is the basis for the 

standard ASTM 5988, ISO 756 soil biodegradability 

test method which is what you have referenced.

 Now, these are test methods. It 

doesn't have a specification. Doesn't put time 

period. But you have been good enough to put 

that time frame in which is two years.

 So this 100 percent complete removal 

has to happen within the two-year time frame.

 Now, there is an EN standard 17963 

which also is identical to what we are talking 

about except that it has that specification of 

two years built into it. It's more easier I 

think in Europe. They say you will do this and 

that's the end of it. Here we go through more 

discussion. 

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 So this is a test method and you have 

defined the standard. 

 So, I think you have the right 

methodology in play to ensure that materials 

which are claimed to be biodegradable mulch films 

can be validated and the data provided to prove 

that this is workable.

 And then I just want to caution. So 

if this is so simple and hopefully you understood 

what I'm saying why is there so much confusion in 

the marketplace? Why are you inundated with is 

this truly biodegradable? You have oxo, you have 

this and not.

 And the reason is people simply use 

the word biodegradable. So the caution is just 

because you see the word biodegradable or 

somebody comes and sells you a product 

biodegradable that's not acceptable. You need to 

prove it. And you need to prove it based on the 

standard and validate and certified by some third 

party. And then you will have it.

 And this is happening across the board 

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in all the other places as well.

 The last point I want to talk to you 

about is here is an example of green washing. 

You see this biodegradability on the y axis and 

then time.

 You see that curve, lower curve, it 

just flattens out. If I stop in the four days 

there is a straight line. And then I just simply 

extrapolate it and say don't worry, in five years 

everything will biodegrade.

 But the graph shows you that it will 

not. So these are the kinds of misleading 

documentation which comes.

 It happens even in scientific 

communications. This is a Chem Communication 

paper. They attach sugar to the backbone of a 

polyethylene molecule. They did the 

biodegradability, showed some biodegradation. 

And then the press says sugar turns plastics 

biodegradable. Bacteria make a meal of sweetened 

polyethylene and polypropylene. 

 So these are sort of I would call 

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noises and distractions which exist in this 

space, but there is validity and you should look 

at it.

 I will show you data now to validate 

this. This is a molecule -- I won't go into the 

details of this -- which is used in this 

biodegradable mulch film. One of your six 

questions was are there such products even 

available on the marketplace.

 So this is a product molecule which is 

available and provided by a number of providers. 

And you can see the names there.

 Now, this molecule, we want to prove 

it will be completely utilized by the 

microorganisms. So we label that aromatic carbon 

which is the most recalcitrant carbon by carbon 

14, radioactive carbon, and then measure where 

does that C14 end up in after we do the 

biodegradability.

 And what we show is that 90 percent 

plus of that carbon, radioactive carbon, ended up 

in CO2. Remember that CO2 comes only if the 

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microorganisms utilize it. Some of it goes into 

the cell biomass and some of it is unaccounted 

for which is a very small percentage.

 What I am submitting to this group is 

there is data and validity that these will truly 

completely biodegrade. But beware of the other 

stuff. But this is what is true.

 The last slide here was a recent study 

which was published in Science Advances. Again, 

the same molecule but this time it is labeled 

with carbon 13 which is a stable isotope 

molecule.

 And they showed that carbon from each 

monomer of that large molecule. So they have 

taken -- in this PBAT molecule there are three 

different monomers which form that long chain.

 Every one of the carbons from that 

chain went into CO2 and also was included into 

the cell biomass, into the lipids fraction.

 So, again I'm providing very solid 

data using isotope labeling that you can degrade 

or biodegrade. And you can see the data there. 

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 So this is very important for you to 

understand that biodegradable mulch films if 

designed appropriately, if validated 

appropriately in a test method and certified that 

they would be, and you follow on studies will 

certainly be a neat, correct approach to this 

whole area.

 The last part I should bring about is 

this biobased. You have in your document 

biobased as well as this end of life 

biodegradable.

 So biobased has nothing to do with end 

of life. It is simply asking the question where 

did that carbon in that molecule originate from. 

Did it come from plant biomass, or did it come 

from petroleum fossil resources.

 And of course the USDA Biopreferred 

Program is promoting the use of agricultural 

based feed stocks to make these biobased plastic. 

But it has nothing to do with end of life.

 And there is a move towards this. But 

you will be difficult to say I want a molecule 

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like what I showed you, perfectly designed so all 

the microorganisms will utilize it completely. 

And oh by the way, I want it all 100 percent from 

biobased feed stocks.

 That would happen, but to expect that 

would be difficult. So that's for you to 

consider, that the 100 percent biobased is a 

constraint which essentially will never allow 

this program to move forward.

 And absolutely there is value in that 

so I don't want to take away from the value. The 

benefits are that it will reduce carbon 

footprint, it is food security, creating value 

for agrarian, rural agrarian economy. It creates 

wealth for rural agriculture.

 But if you don't have these products 

in the marketplace providing the pool then all 

these values which agriculture and agrarian 

economies can benefit will not be realized. So I 

just want that to be in your thought process as 

we move along.

 I think I exceeded a lot more of my 

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time than I should have.

 MR. ELA: Well, I want to -- it would 

be good to have a little bit of discussion. We 

don't have lots of time, but I also want to honor 

that both these folks came. And it's a question 

that we have certainly struggled with.

 So Harriet, then Emily, Dan.

 CHAIR BEHAR: Hi. This is mostly for 

Markus, but maybe both of you could speak to 

this.

 In one of the documents that you sent 

us, you gave us a research paper on the making of 

the poly-based biodegradable mulches. And you 

did mention that there's some use of genetic 

engineering in order to fractionate or form that 

polymer and that you weren't sure if it was a 

bacteria or a yeast. Can you speak to that? 

That was mentioned in the research paper.

 DR. FLURY: Yes. I think some of the 

biodegradable plastics are made with genetically 

modified organisms.

 And I think Ramani, Dr. Narayan can 

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probably talk a little bit more about it.

 DR. NARAYAN: You can still call me 

Ramani, it's okay.

 I could address that. So, the final 

-- so yes. So as you know GMOs are used to do 

all sorts of processes. And so you can make 

these molecules using GMO, genetically modified. 

And you don't have to.

 Now, in the U.S. this is sort of --

it's an issue which all U.S. corn today is GMO if 

you want it at the price you want it.

 If you say no, I don't want GMO then 

you can create identity preserved corn and then 

therefore provide this high-value product. But 

then you are priced out of the marketplace.

 But the process of manufacturing which 

uses fermentation. For example, PLA is one such 

molecule. And that is made by standard 

fermentation process, but it uses the sugar from 

corn. And that corn is probably coming from a 

genetically modified species because all U.S. 

corn is that way. 

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 So unfortunately I'm not sure how to 

answer this, but to me that is problematic 

because then for making this we will have to buy 

sugar from potatoes from Europe, or sugar cane 

from Brazil, or somewhere else. And that's the 

dilemma which U.S. agriculture actually faces, 

where do you call the line.

 But if you take the final product 

there is no GMOs in them. There is no modified 

organism. It's a molecule which is free of 

anything.

 CHAIR BEHAR: Just a quick follow-up. 

I thought that it said that the -- not the 

substrate, but the actual organism that was kind 

of -- that's what it said I thought in the paper.

 DR. FLURY: Yes, I think there are 

some microorganisms that are used to create some 

of the polymers that are also GMOs. Yes.

 MR. ELA: We'll move onto Emily.

 MS. OAKLEY: I have two questions. 

One for Dr. Flury. You had two test or 

experiment locations, but both seem to be in 

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maybe cooler and wetter environments, or wetter 

and hotter environments. How about a hot and dry 

environment? Because I think that's where we 

would see the greatest or the least likelihood of 

degradation. So that's my question for you.

 And then my question for Dr. Narayan 

is in the spirit of taking us back to school 

what's present in the biobased mulch film that 

allows for or facilitates the biodegradation.

 DR. FLURY: All right, so I will 

answer the first question regarding the soil 

environment and climatic conditions where 

degradation occurs.

 And you are right, yes, we have two 

sites in the U.S. In a very hot and dry 

environment we probably would expect that there 

is less degradation.

 And we do see the effects of 

environment on degradation. So for instance, we 

see more degradation in Knoxville than in Mount 

Vernon and mainly because in Knoxville it's 

warmer and the chemical reactions are faster if 

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it's warmer if you have adequate moisture in the 

soils so the microorganisms can grow.

 So we see definitely differences, 

climatic differences. And you are right, in a 

hot and dry climate you would expect less 

degradation.

 So that's why we think it's very 

important to make those tests in many different 

regions in the world where you would expect the 

plastics to be used and long-term, to study that 

long-term.

 So one region for instance where 

actually plastic is -- that may not be of 

interest to you specifically here in the U.S., 

but where plastic is really used the most is 

China.

 And the plastic is actually used in 

hot and dry climates because plastic will prevent 

evaporation and allow you to produce in semi-arid 

regions. 

 So we are trying to set up experiments 

in those regions as well to exactly study that 

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question. But we expect that degradation will be 

potentially happening, but much slower.

 DR. NARAYAN: You're talking whether 

biobased helps in the end of biodegradation. The 

answer is no. Oh, that was not the question. 

Sorry.

 MS. OAKLEY: Sorry. Like what are the 

ingredients within or the materials within the 

product that help facilitate the biodegradation?

 DR. NARAYAN: What is in there, I 

won't put up slides, otherwise you'll get late.

 It has got to do with the structure. 

So for example, polyethylene. Polyethylene is a 

carbon carbon carbon polymer chain. This is the 

strongest bond synthetic people have developed 

and built. So that's not going to break down.

 Now, if I use the ester linkage, that 

is carbon oxygen in that chain, then this is 

susceptible to moisture, it's susceptible to 

microorganisms getting in and esterases, I'm sure 

you've heard of microbial esterases that can 

break that down. 

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 So, putting the right linkages into 

the backbone of a long polymer chain allows you 

to achieve that complete biodegradability.

 The challenge is that you need to do 

that while still giving you the mulch film to 

last for six months, one year, whatever it is. 

So this play between how strong I make it to how 

soon I can get rid of it, so now we are saying 

two years, so the strength of this is going to be 

much lower.

 And then that's something which people 

need to get used to, right. Because I'm so used 

to polyethylene, I can do whatever I want with 

it, it will last forever. That's where the 

challenge is. Did I answer the question now?

 MS. OAKLEY: Not really, no. I mean, 

I understand sort of the science that you're 

describing, but what is the actual ingredient or 

material within that plastic, the biobased 

biodegradable mulch film that is creating the 

conditions under which it's biodegrading.

 Because you have some biobased content 

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and you have some plastic-based content. But 

what is facilitating that degradation.

 I think there are other ingredients 

that are helping facilitate that.

 DR. NARAYAN: I see what you're 

getting at. So let's separate the two. The 

fundamental molecule that is biodegrading is --

we saw that molecule called PBAT. It's got a 

linkage. We know how it breaks down and that's 

what we've shown. Oh, thank you. 

 If you go back to that structure which 

you see there. Okay. You see that structure. 

That is what is breaking down. I can give you 

the actual mechanism which is simple. It breaks 

down into smaller molecules and then they go 

inside the cell. They are oxidized and this is 

well documented.

 I think your question is in order to 

make that film there are other additives and 

ingredients which are added into that, colors, 

pigments, things which is in small quantities but 

could affect soil health and productivity. 

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 And that is correct. But if you look 

at the certification schemes for this those 

additives will have to be GRAS or approved.

 So for example, they use talc or 

calcium magnesium silicate. And I was sitting 

through your previous discussions and I thought 

is calcium magnesium silicate approved as an 

organic and would you allow that or not. I'm not 

sure. I need to go back and check that.

 But I think those considerations which 

you have must be an integral part of it. But I 

don't think that is a showstopper, right, because 

that is the key, the structure which you see to 

show that.

 So, additives are needed just for 

essentially to make it usable. And they need to 

be approved as safe. If it is organic like this 

should be completely biodegradable. So even if I 

add 2 percent of it I need to demonstrate that 

that 2 percent of what I added is also 100 

percent biodegradable in that time frame.

 MR. ELA: Thank you. I want to 

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continue. So Dan.

 DR. NARAYAN: I'm willing to wait with 

you afterwards. I'm always looking for 

audiences.

 DR. SEITZ: So I'd actually like to 

bring us back to grade school with my question. 

It sounds as if you can make both biodegradable 

and non-biodegradable plastic mulch out of oil.

 It also sounds like you can make it 

out of biomass --

 DR. NARAYAN: Yes.

 DR. SEITZ: -- except that if you make 

it out of oil it sounds like you're further ahead 

in terms of getting the properties you want. Is 

that a fair statement?

 DR. NARAYAN: Today you can make both. 

It's a question of cost and availability. So if 

you look at that molecule again on the table 

today almost all of that components which go to 

form that molecule, the adipic acid, the diol can 

come from plant biomass. In fact fermentation 

gives you that. Adipic acid can be done. There 

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are plants which do that.

 But it's not in volume. Even 

terephthalic acid if you remember Coca-Cola 

announced 100 percent plant bottle. That's the 

molecule they needed. And they make it from 

sugar cane. So they are possible but it's not 

going to happen overnight and the volumes are not 

there to do it.

 So that molecule can be made from 

petroleum fossil resources, can be made from 

plant biomass resources.

 But you need that kind of a molecular 

structure for it to be utilized by microorganisms 

and be a fuel to them. Does that answer your 

question?

 DR. SEITZ: Yes, thank you.

 DR. FLURY: Maybe I could just add one 

more comment to that question. Because the 

question here whether you make a biodegradable 

plastic out of a biobased material like of corn 

for instance or whether you use oil to me is 

really not that relevant. 

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 And the reason is that if you use corn 

or any other bio product that bio product has to 

be made with fuel as well because you need 

fertilizer.

 So the resource to make a bio product 

is oil in the first place.

 MR. BRADMAN: I have a couple of 

questions. How or if was the plastics 

incorporated into the soil? In the pictures you 

showed it looked like these were like surface 

mulches. It wasn't clear to me whether they were 

disked in or allowed to degrade on the surface.

 And then you also mentioned the need 

for long-term studies. And that's something that 

we've grappled with as a board is what term do we 

need.

 I would turn that around with it and 

say why do we need that. For example, if you 

look at the mass of carbon. I looked at the 

density of the degradable mulches and if you look 

at that the mass of carbon relative to the soil, 

it's tiny. 

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 So what impacts would you expect on 

soil health that would be different from not 

using it, or perhaps using another organic mulch 

like paper, or a green manure, or something like 

that.

 DR. FLURY: Excellent question. So 

the first question relates to the incorporation 

of the mulch in soil.

 And the photos I showed you is the 

mulch applied to the soil surface. I mean, 

that's what it's supposed to work on in the first 

place.

 But then the idea of the biodegradable 

plastic is that after the growing season these 

plastics are not going to be removed. They are 

tilled in. Mainly we do rototilling now. So we 

rototill the plastic into the ground and then the 

idea is that the plastic will degrade in the 

soil. So that is what we are doing. So we are 

not taking the plastic away.

 Now the question then is what happens 

after you till the plastic into the ground. And 

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as Dr. Ramani said the microorganisms will come 

into play and start to chew up these polymers. 

But it takes a while to do that.

 And what will happen initially is that 

the plastic will get fragmented. So you'll get 

smaller and smaller pieces. 

 And then the second part of your 

question then is what happens with those pieces 

until they are completely degraded.

 So Dr. Ramani said these standard 

tests, and the European Union has now the first 

test in soil that says that you have to have 

degradation within two years.

 From our data we know that in soil it 

will not happen in two years. Very likely it 

will happen much longer.

 And if you go to dry and arid climates 

it may take I guess maybe 10 years for that 

plastic actually to degrade.

 Now, what happens with these plastic 

pieces is not certain because organisms, let's 

say for instance earthworms, they can eat them. 

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They can start to eat those up. Other soil 

organisms can chew them up.

 And we don't really know at this point 

what is the effect on these soil organisms. So 

there is a lot of research that has to be done to 

see whether there is any harmful effect. 

Although we know theoretically in the lab that 

they will degrade, but until they degrade they 

could still pose some problem.

 DR. NARAYAN: It's just a little 

added. This was your fifth or sixth question in 

terms of effect.

 This is the real world environment. 

And what I have talked about and shown and 

absolutely validate that this is going to happen 

in soil. 

 The soil which is in the test methods 

are from the best of conditions. The temperature 

is maintained at 25 degrees and then you see the 

two-year complete removal.

 But if the environment -- what to me 

was shocking was the two sites which they picked, 

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the rate at which this was degrading was not as 

safe. So there is going to be a time lag.

 And then in that time frame is there 

any impacts, or will there be anything. And so 

it is good that you learn what is happening, what 

is not happening and not after the fact find out 

that there is a problem.

 MR. BRADMAN: And would the impacts be 

-- are we concerned about a toxic effect of the 

chemical versus perhaps the physical effect of 

ingesting the plastic for larger organisms, say.

 And then it sounds like -- there might 

be a portion that takes longer to break down that 

that could also get into the air if there was 

dust, that sort of thing. It could move out of 

the area.

 DR. FLURY: So one concern of course 

is that you have soil erosion for instance and 

you have leaching that could actually potentially 

leach some of those plastic fragments into the 

ocean before they have completely degraded in 

soil. 

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 DR. NARAYAN: I would -- it depends on 

the little additives that you add which could go 

as volatile. But these molecules and the 

mechanism with which it breaks down is that it 

goes inside the cell. It's not going to get out. 

It's going to completely be utilized.

 And the rate at which it breaks down 

and gets in, that's a pretty tight time frame.

 The issue which is that sometimes the 

soil is dry, arid. For biology to happen water 

is essential. If you take that out of the 

picture or you reduce it then the rates are going 

to go down.

 So real world to validate the lab, 

I'll put it a different way. If your material 

does not even pass the lab test and cannot 

document it then we should not even be sitting 

here discussing what should be the next steps.

 So I -- not because he's sitting next 

to me, but his work is critical to validating 

that the lab-scale study because there's a time 

frame between completeness and what is there, 

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that there is no effect.

 And they will be not immediate. Like 

it's not going to be toxic, it's not going to 

kill anything, but it could be some biological 

effects like microbial population changes, or 

diversity and the things which soil scientists 

look very carefully at.

 MR. ELA: That's one of the things 

we're concerned about. Dave, we're really out of 

time -- very short?

 MR. MORTENSEN: Yes, very briefly. 

The lefthand side of that sketch is the building 

block for 95 percent of the synthetic herbicides 

used in conventional ag. Aromatic ring 

structures.

 And I guess the question that I have 

is when you think about the fate of the primary 

metabolites and the secondary metabolites of that 

long chain with an aromatic ring in it could 

impurities in the plastic synthesis or coingredients result in functional groups being 

attached to that aromatic ring that result in 

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compounds in the soil that shift microbial 

communities and the behavior of the soil life.

 DR. NARAYAN: To answer the first part 

in terms of -- this is why if you noticed all the 

studies which was done, the labeling was done on 

the recalcitrant aromatic carbon for the same 

reason that what if it is a primary metabolite. 

It just breaks down and releases these complex 

aromatic residues.

 That's why this study was critical. 

The radio labeling was done on the aromatic 

carbon and that all of that radio labeling came 

out as CO2. So it was completely utilized.

 So that should give us cause that 

that's what's happening.

 This was validated also by this recent 

study where they labeled each of the molecules 

including the aromatics. If you look at the 

third structure down. That was labeled -- all 

the aromatic ring carbons were labeled carbon 13.

 And they did show -- that red line 

shows you that that also evolved CO2 and it also 

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went into the lipids.

 So I think these studies give us proof 

that what the mechanisms are happening. It's the

 MR. MORTENSEN: I mean --

 DR. NARAYAN: -- effect which you 

bring out again to see whether that will go fast 

enough. But that's where the studies will 

document that.

 MR. ELA: I wish we had the whole 

afternoon because --

 DR. NARAYAN: I wish that too.

 MR. ELA: -- there is so much 

experience between you two that I think we have 

wrestled with, and to be able to pick your brains 

would be wonderful. Unfortunately we don't.

 Thank you very much for your time. 

We'll look forward to the new results. I think 

you did answer some of our questions in the sense 

of there are still questions which is not 

surprising.

 But thank you for your time and I'll 

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turn it back over to you, Harriet.

 (Applause)

 DR. FLURY: Thank you for having us.

 DR. NARAYAN: Thank you and thank you 

for these chickens. My two grandkids, they'll 

like it.

 CHAIR BEHAR: Oh good, I'm so happy 

you took them.

 Okay, we are at 12:36 so let's do an 

hour. Get back at 1:36. If you can get back a 

little sooner that would be good because we still 

have quite a bit. We still have to finish 

Handling and move to Crops.

 (Whereupon, the above-entitled matter 

went off the record at 12:37 p.m. and resumed at 

1:36 p.m.)

 CHAIR BEHAR: Okay, we're going to 

start on time here and not wait for anyone else 

to show up. I know that some of the board 

members were here so here they come. And we're 

back to Asa with the Handling Committee sunset 

materials. 

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 MR. BRADMAN: So the next material on 

our list is hydrogen peroxide. And I was the 

lead on that so I will comment.

 But before I do I just want to remind 

everyone that to expedite our time and use it 

efficiently we don't need to summarize everything 

that's in the sunset document. The goal here is 

just to bring up public comment and any 

discussion related to that. So we're behind 

schedule and we need to try to catch up here.

 Hydrogen peroxide. I will say it's 

a common sanitizer. Just very quickly I think we 

can get through this one fast. Hydrogen peroxide 

is a very commonly used sanitizer and 

disinfectant in higher levels.

 In terms of public comment everyone 

loves hydrogen peroxide basically. It's 

effective. It doesn't leave residues. It's 

relatively low on the toxicity frame at least at 

lower concentrations. It does have to be handled 

carefully at higher concentrations especially 

food grade levels up around 35 percent. 

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 But it's really I think an 

environmentally friendly material. 

 And just counting up the comments 

there's probably -- there was a couple of dozen 

comments. But then within the lists of 

certifiers that have members using them were in 

the hundreds. 

 And this is really a material that's 

used both among processors and growers and at 

different stages of handling and production. 

 So I don't think there's more to be 

said. Any comments? Harriet.

 CHAIR BEHAR: This is a material used 

across all the scopes, crops, livestock and 

handling.

 MR. BRADMAN: So, with no more comment 

on that one our next item is nutrient vitamins 

and minerals with Tom on deck.

 MR. CHAPMAN: Nutrient vitamins and 

minerals. We didn't hear much so I think we're 

good. I'm joking. Just out of a sense of 

urgency. 

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 Nutrient vitamins and minerals. 

They're used to recreate or add nutritional 

contents to food. It's a categorical listing so 

there's a lot of items listed there.

 There's a long history which I'm not 

going to summarize here, but leads to some of the 

questions we asked around synthetic and nonsynthetic versions and how to move forward in 

light of 2012 proposed rule and later 

rulemakings.

 The public comment was kind of divided 

amongst industry and trade associations that 

spoke to its need and demand in food, and a lot 

of comments from certifiers around its wide usage 

by several types of operations.

 And then other comments that objected 

to both the categorical listing of vitamins and 

minerals as well as their usage where not 

required by law.

 And there is various options proposed 

by people on how to move forward on this topic. 

The subcommittee will take those all into 

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detailed consideration as we review the sunset 

material and see if we need to take any further 

additional actions.

 I'm not going to go into like deep 

detail on this because we could literally spend 

the rest of our evening on it. So unless there's 

specific questions I think I'll hold it there.

 But we did get detailed specific 

comment from the public and it's really 

appreciated, especially responses to our four 

questions. So thank you.

 MR. BRADMAN: Harriet.

 CHAIR BEHAR: Will you be able to 

summarize that for the subcommittee, or at least 

direct us in the bundled comments to page numbers 

that we could go to to find the ones that you 

specifically thought were very useful?

 MR. CHAPMAN: Yes, definitely. 

Definitely.

 MR. BRADMAN: Okay, the next material 

that we're up for is peracetic acid. I'm the 

lead on that. 

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 In ways similar to hydrogen peroxide 

I think this is a well appreciated material 

that's used across different categories within 

the National Organic Program.

 It degrades rapidly, leaves little 

residues. Relatively harmless breakdown 

products. Acetic acid, vinegar type product, 

oxygen water.

 I should mention though acetic acid is 

a respiratory irritant at high levels. So any 

sanitizer, these things do need to be handled 

appropriately and carefully.

 One kind of interesting comment. 

There is some review historically and also in 

more updated information about stabilizers used 

in the peracetic acid. There's both HEDP and 

dipicolinic acid.

 And in our view we're considering that 

really as an inert material. Beyond Pesticides 

points out that it's a former list 3 inert and 

that it may not be allowed in formulations for 

organic use. 

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 And this is something I want to look 

more into and also perhaps something that OMRI 

could provide some input on.

 Related to this I also want to just 

give a shout out to Beyond Pesticides for a very 

impressive report that they submitted in public 

comments on inerts. I don't know if you're in 

the room, but I think all of us should look at 

that report and think carefully about it.

 And it helps guide perhaps some of the 

future work and also evaluation of some of these 

materials.

 So again though I think peracetic acid 

is really non-controversial and essential across 

many sectors. Any comments from the board? 

 Our next material is potassium -- I 

say citrate. I don't know if it's citrate. And 

going back to my notes is Lisa. You're on deck 

for potassium citrate.

 MS. DE LIMA: Potassium citrate. 

Public comment was supportive and mentioned uses 

including as a buffer in pH control agent, 

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acidity regulator in the wine-making process.

 The TR also states that it's used to 

wash processing equipment to remove off flavors. 

No real information was brought forward in terms 

of harm to human health or the environment.

 Questions or discussion?

 MR. BRADMAN: No more comments from 

the board? Okay. 

 DR. LEWIS: Mike.

 MR. BRADMAN: Our next material is 

potassium phosphate and that's in Tom's court.

 MR. CHAPMAN: So, potassium phosphate 

is annotated for use only in agricultural 

products labeled as made with organic 

ingredients, prohibited in agricultural products 

labeled as organic.

 Potassium phosphate can be used for pH 

control and buffering, and as a nutritional 

additive for potassium either for yeast or for 

also just food products.

 It's unclear to me whether potassium 

phosphate is restricted in its use as a nutrient 

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product because it would also fall under that 

global listing of nutrient vitamins and minerals. 

And so as it's used as a nutrient vitamins and 

minerals I'm curious to know if potassium would 

be allowed in that form or not.

 We received very little comment on 

potassium phosphate. We did have a certifier 

note that they had two folks using potassium 

phosphate as they add nutrient vitamin and 

mineral products.

 And then we received an extensive 

comment from a trade association that spoke to 

various uses, potassium phosphate items as well 

as addressing the long-term concern product about 

human health, accumulated human health risks of 

phosphate products in general.

 It was unclear from the comment from 

the trade association whether their comments were 

about usage of phosphates in food products, or 

usage of phosphates in organic food products.

 It looked like a lot of their uses may 

be for products that aren't typically to the made 

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with organic level so it seemed to me like they 

were talking mostly about food products and not 

about particular organic food products currently 

on the market. But I could be mistaken in that 

and we'll seek further clarification.

 MR. BRADMAN: Any comments from the 

board on this material? Questions? Emily, thank 

you.

 MS. OAKLEY: Did you get any clarity 

on your question about if it's redundant and 

should the listing be removed?

 MR. CHAPMAN: The only one that I saw 

that commented was that single certifier who 

agreed that the nutrient -- their application of 

it was under that nutrient vitamin and mineral 

listing. So it was -- out of all those questions 

this one was probably the one that we got the 

weakest response on.

 And then just to throw it out there, 

the contrary opinion that the categorical listing 

of nutrient vitamins and minerals several people 

objected to. So. 

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 MR. BRADMAN: Any more comments, 

questions? Let's move onto our next material, 

sodium acid pyrophosphate with Scott.

 MR. RICE: Sodium acid pyrophosphate. 

It's use limited to as a leavening agent.

 In terms of comments we had a number 

of certifiers noting the presence of this 

material on OSP's organic system plans.

 A number of companies weighed in 

noting it as the only chemical leaver available 

allowing for specific types of bread and baked 

goods.

 One organization opposed the relisting noting that the initial TAP review only 

covered its use in soy milk. Further commenting 

that a subsequent TR focused on proposed expanded 

use of sodium acid pyrophosphate and didn't 

address the current listed use.

 But the -- still in use and as I said 

relied on as the only chemical leavener on the 

list.

 MR. BRADMAN: Any comments or 

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questions? Harriet.

 CHAIR BEHAR: I just want to say when 

this was first put on the list there was concern 

that there would be like this multitude of 

phosphates added because there's so many 

phosphates that are used in very specific 

situations. 

 But we really haven't seen that 

happen. This is going back like 20 years. So it 

seems like the phosphates that we have have 

really been working for the manufacturers.

 I know that there was a lot of 

controversy about putting it on to begin with. 

And the petitioner tried to sweeten it by saying 

well, you can't have any cake doughnuts without 

this. And the people who were at the meeting are 

shaking their heads yes. So we now have organic 

cake doughnuts as well as other things.

 MR. BRADMAN: Any more comments? 

 MS. DE LIMA: Sodium citrate?

 MR. BRADMAN: Yes, sodium citrate with 

Lisa on deck. 

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 MS. DE LIMA: Sodium citrate. Public 

comment was generally supportive and mentioned 

uses including as an antioxidant, a stabilizing 

salt, buffer, and also when it's combined with 

citric acid the pair provides a tartness without 

a significant drop in pH which is important for 

confectionary products. 

 Also used for achieving a consistent 

pH for the gelling of pectin. It was also found, 

some certifiers mentioned it was found in OSPs 

used for meat processing as well as in the 

manufacturing of dietary supplements and personal 

care products.

 No new information was brought forward 

in terms of human health or the environment.

 MR. BRADMAN: Any questions or 

comments from the board? Okay. I keep turning 

it off instead of on. Excuse me.

 Our next material is tocopherols. I'm 

the lead on that.

 Tocopherols are used as an antioxidant 

and material to prevent rancidity. Right now 

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it's listed on 205.605(b). 

 There's been some question about 

whether there are non-synthetic sources that are 

as functional and whether it should be listed on 

205.605(a) or (a) and (b).

 We discussed some of this at the 2017 

meeting and at that point -- thank you, Tom, for 

reminding me -- that we basically decided to 

leave the listing as is.

 Overall there is support for keeping 

tocopherol -- in the public comments as being 

necessary for many processed food products.

 There's been some experimentation with 

non-synthetic sources. And there's definitely a 

feeling at least from the people who commented 

that there's not enough non-synthetic sources 

available and that in some cases they're not as 

functional as the current material.

 So, there's also kind of a long list 

of potential ancillary substances. And this 

table that's in the writeup is extracted from the 

technical report. 

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 You'll notice in a lot of categories 

there's just unknown listed there. So this kind 

of ties into the larger issue, another material 

that ties into the larger issue of ancillary and 

how to consider those.

 Any comments from the board? Dave.

 MR. MORTENSEN: Just a quick question. 

When there is a substance unknown how is that 

handled from a labeling point of view? Like when 

you look at the contents of a packaged thing.

 MR. BRADMAN: Tom.

 MR. CHAPMAN: Ancillary substances are 

a whole class of like processing aids and other 

precursor products that don't appear on a labeled 

product. 

 So for example, yeast is the easier 

one for me to speak to will be grown on a 

substrate. And when you add that to your product 

some of that substrate may or may not be there. 

 So I'm brewing beer and I buy 

commercial yeast. That yeast was fermented on 

something, probably other malt extracts or 

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something. Some of that malt extract may remain 

and may go into my product.

 I'm adding yeast. So yeast is what 

would appear on that label if beer was labeled, 

not the malt extract unless it was another 

ingredient in there. Does that make sense?

 So it doesn't show up on the label.

 MR. MORTENSEN: Okay, yes. I just 

asked because my wife has a number of pretty 

serious food allergies that relate to 

hydrogenated things. I'm just curious how often 

you might encounter something for someone that's 

sensitive where you don't even know that it's in 

the product.

 MR. CHAPMAN: Yes. I mean, there's a 

law under the FDA's authority for food allergen 

labeling. Food Allergen and Consumer Protection 

something. FALCPA. I'm butchering it, but.

 Which specifies those eight major 

allergens in the U.S. We had a public commenter 

speaking about sesame and sesame is not a major 

allergen in the U.S. so it may not be labeled. 

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 Some food companies go above and 

beyond and get that question from a lot of their 

people and provide that information. In a case 

of a product like this you would still seek to 

know what was in there and ask for those 

disclosures from those companies.

 But once you're outside of those big 

eight at least in the U.S. it's tough. It's 

tough to know.

 MR. MORTENSEN: Okay, thank you.

 MR. BRADMAN: Any other questions or 

comments? No? Okay, then our next material is 

celery powder. I think given the extensive 

discussions we had today and comments. We really 

have a lot of new information on that.

 Just to briefly summarize public 

comments I would say there was -- some of our 

speakers were actually -- their organizations 

were submitting comments. 

 There's definitely a feeling that this 

is an important material, an essential material 

and that there's a wish to get past it. 

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 Overall there was support for it. 

There was some -- I think Beyond Pesticides is 

one of our main commenters among others that 

really feel this should be taken off the market 

because it's not compatible with an organic 

system.

 And it is true that in contrast for 

example to the collagen gel we're actually 

growing a non-organic crop as an input to produce 

organic products.

 And I think that there is kind of a 

special burden on the system to try to get away 

from that.

 And just when we were looking at some 

of the graphs, looking at some of the slides we 

saw the other day. And the organic material was 

struggling to get up to 5 or over 1,200 parts per 

million in those plants.

 The conventional celery plants were 

fairly easily getting up to 2,000, even higher 

when they were younger. So there's kind of 

almost a factor of two difference between the 

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conventionally grown, or two or three between the 

conventionally grown and the organically grown.

 And I think as a community we do need 

to think carefully about this material and really 

support the work that's going forward. 

 I know there's some talk about funding 

and grants, and I think it's critical that this 

be a research item on our agenda and that as an 

institution that USDA should support work on this 

to move it ahead. Because it would be nice to 

get this off of 606.

 Any comments from the board? Emily, 

then Harriet.

 MS. OAKLEY: Yes, it seems that from 

that research data there is a lot to explore in 

terms of maturation of the harvested celery and 

the timing for when it's processed.

 I would think that sort of midrange 

and a smaller sized head would probably yield 

from what we've seen and just in terms of how we 

treat cover crops, for example. I think there's 

a similar logic there. Might be some 

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opportunities.

 MR. BRADMAN: Harriet.

 CHAIR BEHAR: Well, I just wish that 

we had a better handle on the conventional side 

of growing. I found that a little disturbing 

that it was difficult to find out what they're 

doing on the conventional side to bring up the 

level of nitrates in the celery.

 MR. BRADMAN: Yes. We had an explicit 

question about that and basically it's 

unanswered.

 MR. MORTENSEN: And I would just say 

that I think that's an excellent suggestion. 

That's where I would start.

 It seems to me that this is something 

I think could be resolved pretty quickly by 

talking with some folks that grow conventional 

celery.

 MR. BRADMAN: Harriet.

 CHAIR BEHAR: Erin Silva is a 

colleague of mine and she's tried. The problem 

is there's kind of a proprietary wall out there 

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and it hasn't been very forthcoming from the 

conventional side.

 But now that she's working with other 

universities who then work with those 

conventional celery producers hopefully we'll be 

able to knock down that wall and get some 

information.

 MR. BRADMAN: Paul.

 DR. LEWIS: So, as the board prepares 

its research priorities for the fall meeting one 

thing to think about is how you're characterizing 

research in this area.

 It was interesting in terms of the 

work that Erin shared the year to year difference 

was interesting.

 I know that other research she's 

published is that she looks at a very -- it's 

regionally. So what she sees in Wisconsin may 

not be applicable other celery production areas 

such as Florida. 

 So one thing to think about when 

you're developing your research priorities --

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what kind of questions do you want to be thinking 

about.

 MR. BRADMAN: Thank you. Any other 

comments related to celery powder? I think we 

spent enough time on that this week.

 So the next material is fish oil and 

Tom, you're on deck.

 MR. CHAPMAN: So fish oil is produced 

clearly from fish. It's primarily used as a 

source of omega-3 fatty acids, particularly EPA 

and DHA.

 And from what I can tell at least from 

the comments that we received it's primarily used 

in dairy products.

 We received support for this item from 

organic dairies that speak to the consumer demand 

for omega-3 enriched products and having an 

opportunity to compete with conventional products 

that market themselves similarly.

 On the other side opposition to this 

material really kind of fell into three buckets, 

first being environmental concerns around 

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harvesting of fish akin to the concerns we've 

been grappling with on marine materials and other 

items from wild harvesting.

 Another area of concern was human 

health, particularly accumulation of heavy 

metals.

 And then the last area of concern was 

essentiality and whether or not this is a product 

that should be added to foods in the first place.

 We also received extensive comment 

from a manufacturer of the product and a trade 

association that represents manufacturers of the 

product.

 We had posed four questions to the 

public being questions about dealing with the 

heavy metal accumulation and purity, questions 

about how the industry deals with those. 

Questions about standards related to those and 

then also noting that we have these environmental 

and conservation concerns. How can we address 

them.

 And there were several options posed 

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to us both in written comments and then during 

the webinar and in public. So we'll take those 

under consideration as we review this material 

and if renewed if we'd want to propose additional 

annotations to this we'll discuss that at the 

subcommittee level.

 MR. BRADMAN: Emily.

 MS. OAKLEY: I would highly encourage 

an annotation based on public comments because it 

seems highly feasible. And I don't know what the 

work agenda timeline is, but it doesn't seem like 

a heavy lift in terms of its workload. So if it 

could be quickly adopted as a work agenda item 

over the summer and passed as a proposal for the 

fall meeting it seems timely and feasible. But 

I'll let you guys figure that out.

 MR. CHAPMAN: Yes. I guess just back 

at that one. It seemed like there was a decent 

amount of support across the board for that. And 

there was some proposed items. And given the 

amount of time you've spent in this general area 

I'm curious to know if there was -- if you found 

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any of those wordings sufficient.

 MS. OAKLEY: I mean, I think as the 

Crops Subcommittee is looking to get its TR on 

fish harvested exclusively -- whole fish -- wild 

native whole fish from native ecosystems for use 

as fertilizer I think that those suggestions that 

came up as possible annotation wordings -- and I 

know some of those were going to come to you 

later through Michelle -- sounded absolutely 

feasible.

 And if I were someone adding fish oil 

to my products and that fish oil was MSD 

certified I would absolutely put that on the 

product.

 MR. BRADMAN: Dave.

 MR. MORTENSEN: Tom, I just was 

curious under the uses section of this draft if 

you have it there.

 The sentence that reads in addition to 

aquiculture estimated to use about 81 percent of 

fish oil produced. Is that a typo or is that 

accurate? 

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 MR. CHAPMAN: Can you cite me to?

 MR. MORTENSEN: The first sentence of 

the second paragraph under uses. 

 MR. CHAPMAN: That may or may not be 

a typo. What I think was being stated here was -

- well, I'd need to look at it in more detail, 

but I also just read this in the public comment 

from Beyond Pesticides I believe that the 

majority of fish oil production goes into feed 

applications, particularly in aquiculture 

settings.

 MR. MORTENSEN: Okay.

 MR. CHAPMAN: So that was what was 

meant to be said I believe by that sentence. I 

don't know if that is what was said by that 

sentence.

 MR. MORTENSEN: That's what it's 

saying I think. I didn't realize that. I 

thought the majority was human consumption. 

That's not the case.

 MR. BRADMAN: Any more comments or 

questions related to fish oils? Okay, our next 

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material is gelatin and A-Dae, I think you're up 

for that.

 MS. ROMERO-BRIONES: So, a lot of the 

discussion about gelatin is -- should be taken in 

relationship with our discussion about collagen 

gel because gelatin is derived from collagen and 

our TR was a combined TR with collagen gel and 

casings.

 So I won't go into detail about --

well, yes, let me do that then.

 Gelatin is used in a wide range of 

products as a clarification or refining agent in 

teas, juice and wine and as a stabilizer, 

texturalizer, thickener and in capsules.

 It's used in a wide variety of 

products from gummy bears to Jell-O to sour cream 

to ice cream to cosmetics. And fish gelatin is 

widely preferred for uses in kosher foods. 

 It comes from a variety of different 

sources, from cattle bones, hides, pig skins and 

fish are the principal commercial sources.

 We had several commenters. There are 

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several users of gelatin as it's listed. NOC 

suggested that we need more information about 

what is preventing the production of organic 

gelatin.

 We had one commenter offer 

alternatives to gelatin which was organic pea 

starch and other alternatives, namely pectin.

 Beyond Pesticides suggested that we 

needed to separate the listing for fish gelatin 

versus gelatin derived from other animal sources, 

and that we should consider of course as the same 

discussion was in collagen the conventional 

production of the sources of gelatin.

 We did try to address the animal 

sources whether from fish or from conventional 

animal sources in the TR. But the TR stated that 

marine sources are mainly in the research stage 

and so there wasn't too much information provided 

about the fish sources of gelatin.

 MR. BRADMAN: Tom, you look like you 

want to say something.

 MR. CHAPMAN: I just want to note that 

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the pea starch may have some functional 

replacements for gelatin, but I highly doubt it 

would function in all applications. 

 MR. BRADMAN: Any other comments 

related to gelatin? No? Okay, let's move onto 

our next material, orange pulp, dried. And 

that's also A-Dae.

 MS. ROMERO-BRIONES: So dried orange 

pulp is currently used as a moisture retention 

agent and fat substitute in baked goods, pastas, 

salad dressings, cheese spreads, frozen doughs, 

frozen meats.

 We had several commenters. It's also 

-- other names for dried orange pulp is citrus 

fiber and citrus flour.

 We had several commenters report that 

nobody reported using it. Some commenters 

reported using orange peel and orange pulp, but 

not in the dried form.

 We had several -- we had one commenter 

suggest de-listing because of the conventional 

sources of the dried orange pulp which may 

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include the use of pesticides to create the dried 

orange pulp. So we really didn't have too many -

- we didn't have any certifiers suggest the use 

of dried orange pulp in any of their listings.

 MR. BRADMAN: Emily, then Steve.

 MS. OAKLEY: So when we don't hear 

that a material is being used again where does 

that leave the subcommittee? I mean, I see it 

wasn't added all that long ago necessarily. So 

what's happened in the intervening years?

 MS. ROMERO-BRIONES: So, based on what 

-- from just researching it very quickly it seems 

like this material is primarily -- was primarily 

used by the petitioner for a specific trade 

product and they call it Citri-Fi 100. And 

that's really the only use that I found. So I 

would love more commenters to tell us if that is 

not the case.

 MR. BRADMAN: Steve, and then Lisa.

 MR. ELA: I think echoing Emily's 

comment these are the kind of things that there 

may be users out there, but we need to hear from 

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them because I have a hard time leaving it on the 

list if -- why have something there if it's just 

a placeholder. So I guess a note to the 

petitioner.

 MR. BRADMAN: Okay. Lisa, and then --

 MS. DE LIMA: I agree with Steve that 

we want to hear from folks, but also on the other 

side we know this is not a perfect process.

 So to answer Emily's question I think 

we still have to weigh -- I mean, there have been 

situations in the past with tragacanth gum where 

no one came forward and then someone came forward 

afterwards. 

 So it's one of those not clear spaces. 

But we do have to consider that everybody is not 

aware of this process by a long shot.

 MR. BRADMAN: Harriet, then Tom.

 CHAIR BEHAR: So I was in the room 

when this was petitioned and placed on the 

National List. 

 It was somewhat controversial because 

there were questions of the petitioner whether or 

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not -- why couldn't they get -- there was organic 

oranges. This is before citrus greening occurred 

and it was harder to grow organic oranges, 

especially in Florida.

 And they said well, you know, we own 

all of these orchards that surround our plant and 

none of them are organic. 

 And then we said well, why don't you 

transition them to organic then if you need them. 

And they said well, you know, we need more 

organic oranges, we know that. There's a big 

market. But we don't really want to do that.

 And so it was put on there. But I 

just wonder if we couldn't reach out to the 

original petitioner and see if they have any 

clients that are even buying this. That's where 

it would come from.

 Because I think it is just one 

manufacturer who's making this product. And so 

if we could find out if they have any customers 

then we would know if anyone was using it.

 MR. BRADMAN: Tom, then Ashley. 

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 MR. CHAPMAN: As far as I'm aware the 

Citri-Fi product is the only orange fiber product 

out there. And I think they may even have a 

patent on the process so they may be the only one 

that can manufacture it.

 They did come when we reviewed this in 

2017 and presented a fairly detailed similar to 

what we saw with the celery powder presentation 

about the supply chain challenges to produce it.

 It's a byproduct of the juicing side 

of the industry and has a very short shelf life 

and a very low yield.

 At one point I purchased this product 

for a product that we no longer sell. It was in 

the made with category so this listing was not 

particularly important to us.

 It is an alternative fiber that has 

some functional benefits especially in like fruit 

prep areas or extruded fruit prep areas.

 But I also have not -- I don't see it 

out there in usage in the organic side so I would 

love to hear from people if they're using it. 

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 On the flip side this is a 606 item. 

They have to search for it organically. I don't 

see it as propping up conventional business or 

preventing an organic business or preventing more 

oranges from going into organic.

 It's used at very minor levels and 

people would -- like it's probably a small 

business unit. Overall just in the fiber world 

this is not a major fiber that people are using 

in their foods.

 So, I just, I don't see it going 

organic anytime in the near future. I struggle 

with having items on there that aren't used. On 

the flip side I don't see the harm on a 606 item 

if it's not being used. But I get the argument.

 MR. BRADMAN: Ashley.

 MS. SWAFFAR: So, looking back through 

previous public comments when we reviewed this 

last time we did get a public comment that said 

dried orange pulp is produced under patent 

protected only by Fiberstar at their single 

facility in Florida. And therefore no other 

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processing operations worldwide can produce the 

dried orange pulp as a functional food 

ingredient. So I think that's an important 

thing.

 And I do remember them commenting that 

they said there's not enough organic raw 

material, fresh wet organic orange pulp on any 

given day within the proximity of their single 

Florida production facility to produce a minimum 

batch of dried orange pulp. So two issues there.

 But like Tom said, 606 item. But I 

think the patent pending kind of gets it on the -

-

 MR. BRADMAN: Steve.

 MR. ELA: So what I hear in that is we 

just listed a specific product.

 MR. CHAPMAN: Yes, I mean that's not 

always uncommon, but yes.

 MR. ELA: It can't be replicated. 

Kind of weird. I mean, we didn't just list it, 

but it was listed.

 MR. BRADMAN: Emily. 

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 MS. OAKLEY: I mean, when I hear that 

that's really not a compelling reason to keep it 

because they have no interest to change it to 

organic because they will have no competition in 

the industry to ever produce this in an organic 

method. So that's for me not a compelling reason 

to keep it, especially if we don't have many 

people using it and at this point since we 

haven't heard from people it would be great to 

get comments.

 And I think that suggestion from 

Harriet to contact the manufacturer would be 

excellent.

 MR. BRADMAN: Just to interject one 

thing. It's not that relevant, just coming from 

California there's lots of organic oranges in 

California.

 MR. CHAPMAN: Not for juice though I 

don't believe. I think it's mostly a fresh --

 MR. BRADMAN: That's true.

 DR. LEWIS: California is a special 

market. Florida is a juice market. 

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 MR. CHAPMAN: This is a byproduct of 

the juicing market.

 MR. BRADMAN: Tom.

 MR. CHAPMAN: Just so people know it's 

listed as orange pulp, dried I think because of 

the point you raised, Steve, which is a very 

weird listing.

 I actually think I voted to remove 

this last time because I don't think it's in use. 

But it's commonly called citrus fiber. So if you 

are looking for it out there citrus fiber is how 

it would be labeled. It wouldn't be labeled as 

orange pulp, dried. So.

 MR. BRADMAN: Any more comments, 

discussion? Let's move on. Our next material is 

seaweed, Pacific kombu.

 MS. ROMERO-BRIONES: So, Pacific kombu 

seaweed is used as an ingredient to make stock 

for Instant Miso Soup and Yuzu Ponzu. It's 

primarily used in Japanese traditional foods as 

stock.

 It is a seaweed and it is one of four 

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marine plants listed under 205.206. 

 There was one comment against relisting basically because of the process in which 

seaweed absorbs heavy metals and radioactivity, 

and also for consideration of over-harvesting and 

protecting the environment.

 In our TR it was a TR based on marine 

and algae so there was no specific absorption 

rates based on the type of seaweed. And so this 

lends itself to the discussion we have on marine 

and algae.

 No one listed as using it. And the 

petitioner is from Japan.

 MR. BRADMAN: Comments or question? 

I have one question. I'm not sure who to direct 

this to, but this issue of it potentially being a 

material that's prone to accumulating 

contaminants from the environment.

 It seems to me that's a very kind of 

vague statement in the sense that every plant or 

food accumulates stuff from the environment. We 

have DDT in our bodies. Probably everything we 

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eat does too from decades ago.

 So I don't know how to judge those 

kinds of statements. It seems to me if there's 

standards then does it measure up against a 

standard. 

 I would think any manufacturer would 

have to have some testing requirements if they're 

concerned about contamination and can deal with 

that. But I don't see how that could be used as 

a criteria to evaluate whether something should 

be listed or not.

 MS. ROMERO-BRIONES: And I would just 

say that that's my summary of the comments really 

quickly. The commenter Beyond Pesticides did go 

into detail particularly because this type of 

seaweed is collected around the Japan Fukushima 

radioactivity that is occurring. So there's a 

higher percentage probably of absorption of these 

types of heavy metals and toxics in that area. 

So again, that was just my general --

 MR. BRADMAN: No, I understand that. 

But I don't see the -- I understand there's an 

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issue with potential contamination and that 

should be addressed, but I don't see that as a 

listing issue. I don't know if we need to 

discuss that now. Emily.

 MS. OAKLEY: In the absence of 

requiring testing of an individual ingredient 

which we don't have it's hard to get any data 

like that or to require it.

 MR. BRADMAN: So any more comments? 

If not we'll move onto the next material, also 

seaweed and also in A-Dae's court.

 MS. ROMERO-BRIONES: So --

 MR. BRADMAN: I'm sorry, Tom, you had 

a comment?

 MR. CHAPMAN: I'm not quick enough 

with my OFPA. I always like to point out when 

people use the criteria correctly or incorrectly.

 I do believe an assessment of heavy 

metals content or something along that lines is 

part of the OFPA criteria that we're supposed to 

use.

 MR. BRADMAN: But everything can 

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accumulate it. And it's going to be sitespecific. 

 MR. CHAPMAN: If OFPA criteria was 

crystal clear there would be no need for the 15 

of us.

 MR. BRADMAN: Point taken.

 MR. RICE: Correction, 14.

 MR. BRADMAN: So let's shift over. 

Emily.

 MS. OAKLEY: I just want to make it 

clear that I'm not saying that I don't think we 

should be looking at heavy metal accumulation. I 

just don't see -- it would be very hard to obtain 

that data as this board.

 And if that data is out there I would 

highly encourage people to submit it for us in as 

much detail as possible.

 MR. CHAPMAN: Yes. My comment wasn't 

at all directed to you. It was directed to Asa's 

statement.

 MS. OAKLEY: I just wanted to make 

sure it didn't sound like I was saying we 

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shouldn't care about accumulation of heavy 

metals.

 MR. BRADMAN: So, the next material 

then to A-Dae again is Wakame seaweed.

 MS. ROMERO-BRIONES: So Wakame seaweed 

is a traditional component in miso soup in 

Japanese cuisine.

 Again, this is listed as one of the 

four marine plants listed under 205.206. With 

this commenters there was one commenter, one 

handler that commented that they do use it in 

their organic system plan, but the same 

discussions around Pacific kombu relate to 

Wakame. Very similar.

 MR. BRADMAN: Any comments related to 

this material from the board? Harriet.

 CHAIR BEHAR: I'm just wondering if 

there's anything within the FDA or the USDA that 

might have some information that we could 

reference. 

 MR. BRADMAN: Don't know. Okay. So 

I think then we're done with the sunset 

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substances review. And I think we decided to 

work on the collagen gel later on this afternoon. 

 So according to our schedule it would 

be time to have lunch again. But just a related 

message that we're that far behind. So turning 

it over back to Harriet.

 CHAIR BEHAR: Okay. So, I am going to 

turn it over to Steve Ela, the Crops Subcommittee 

chair.

 MR. ELA: Sounds good. We'll start 

right off with the allyl isothiocyanate petition. 

Jesse, that is yours.

 MR. BUIE: Okay. We received two 

petitions for allyl isothiocyanate which I'll 

just from this point AITC that have been 

submitted to the NOP. And both these petitions 

propose to add AITC as an allowed synthetic 

substance in organic production at 205.601 as a 

pre-plant fumigant.

 The original petition dated December 

2013 was received by the NOP January 24, 2014. 

 After review and discussion by the 

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Crops Committee the request to add AITC to 

205.601 was not recommended.

 The petitioner re-submitted a petition 

in 2016, asserted that AITC offers organic 

growers the only effective management tool for 

soil-borne diseases and pathogenic nematodes at 

levels that are commercially relevant and 

supports the phytosanitary certification process 

for organic fruit and vegetable nursery stock 

production.

 AITC, commonly referred to as oil of 

mustard was first registered by the U.S. EPA in 

1962 for use in pesticides and rodent control 

products.

 However, oil of mustard is a common 

food ingredient and has been listed on the U.S. 

Food and Drug Administration generally regarded 

as safe listing since 1975.

 Now, to facilitate the review of the 

re-petition dated 2016 the Crops Subcommittee 

requested a limited scope TR to address some 

outstanding issues. And I'm going to just 

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briefly summarize these outstanding issues that 

were dealt with in the February 2018 TR.

 The first one was provide a review of 

AITC as it pertains to the newly listed 

additional uses.

 The second, review proposed 

phytosanitary use of nursery stock and plants 

with deals with nursery stock certification.

 And the third one was provide a 

comprehensive look at both the short and longterm impacts of soil beneficial life forms 

compared to existing practices and the materials 

being used.

 So, on line 100 through 107 of the TR 

it states that AITC and AITC containing materials 

possess good potential to serve as an alternative 

nematocide that are safe and more environmentally 

benign than traditional synthetic fumigants.

 However, the effectiveness of AITC can 

be selective. In 2005 the study -- in a 2005 

study the nematocidal activity of AITC was 

evaluated using seven different species of 

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nematodes including six of the most important 

parasitic nematode species in agriculture 

worldwide.

 The study found that the 

susceptibility or tolerance of nematode species 

was highly variable. While AITC was found to be 

toxic and possess anti-hatching activity against 

all species of the study the required 

concentration of AITC for effective nematocidal 

activities was different across the species that 

was studied.

 Additionally, the TR notes that one of 

the degradation products of AITC is carbon 

disulfide, CDS. 

 There are concerns regarding the 

exposure of CDS because it is listed by the state 

of California on the Proposition 65 list as a 

developmental toxicant and is known to induce 

neuropathological changes and other toxic effects 

in rodents exposed through inhalation over the 

intermediate during less than a year. And this 

is referenced, the TR 491. 

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 And because CDS is a major degradant 

of AITC the human and environmental toxicity of 

CDS should be considered as part of the 

evaluation of AITC for use in organic production.

 Also, according to TR lines 210 and 

211 several international organizations and 

regulatory bodies do not permit the use of AITC 

in organic crop production.

 Additionally, the lines 993 to 994 

indicate that in addition to traditional crop 

rotation the available information suggests that 

the variety of available management techniques 

preclude the application of synthetic 

biofumigants such as AITC in organic production.

 For example, the TR indicates that 

some organic farmers including organic strawberry 

producers are adapting mustard seed meal as a 

natural option for soil pest control.

 Synthetic AITC as a broad spectrum --

synthetic AITC acts as a broad spectrum fumigant. 

This broad spectrum effect on both beneficial and 

pest species is not compatible with organic 

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production.

 Are there any questions? 

 MR. ELA: Harriet.

 CHAIR BEHAR: So we did have some 

public commenters who did like this material but 

with fairly narrow suggested -- kind of a narrow 

annotation.

 But it seemed like it was kind of hard 

to really narrow down exactly what we wanted to 

say in the annotation.

 And I originally was kind of open to 

like for the nursery stock. But then when I've 

seen really quite a growth on organic nursery 

stock available. 

 I know there might be some certain 

phytosanitary issues for shipping over state 

lines and that sort of thing.

 It's not an approved material now and 

it doesn't seem to me that -- we're seeing growth 

now in the nursery stock without its use. And so 

there are some questionable aspects to it that 

make us want to narrow it. 

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 So I'm not so sure that we really need 

it now. The last time we talked we were kind of 

open to the nursery stock side, but now I'm 

really wondering about that.

 MR. ELA: Tom, then we'll go Emily, 

Asa.

 MR. CHAPMAN: Can you speak to the 

scale of that nursery stock? Like how much out 

there comparative to the growth in organic 

industry, where is it being sold, what regions, 

what markets.

 CHAIR BEHAR: Well, I know there's 

quite a bit of strawberries that are available 

conventionally. I saw that note on the CCOF 

newsletter and I went to the website.

 MS. OAKLEY: You mean organic.

 MR. CHAPMAN: You mean organic.

 CHAIR BEHAR: Organic strawberry 

transplants for commercial use.

 MR. CHAPMAN: You said conventional 

but I get what you're saying.

 CHAIR BEHAR: I'm sorry. Organic --

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 MR. CHAPMAN: Like a lot doesn't give 

me a sense. Do you have a percentage?

 CHAIR BEHAR: No, I just saw it 

available when last year at this time I didn't 

see any available. So to me that seems like 

there's growth if I'm seeing it available. No, I 

didn't do research into it.

 But we know that there has not really 

been a significant amount of apple trees 

available organically. And then I see Stark 

Brothers sending out catalogs across the country. 

And I'm aware of a few other nurseries that are 

getting into organic production.

 And we haven't heard from them that 

they need this material.

 MR. CHAPMAN: I guess, I mean zero to 

half a percent is a thousand plus million 

infinite growth there. But it doesn't mean it's 

anywhere near what's needed to support the size 

of the organic market and the growth rates that 

we're seeing. 

 So I guess I'm just curious to hear 

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numbers associated with those statements.

 MR. ELA: I can -- do you mind if I 

address that first? I think your point's well 

taken. There is -- as a perennial grower there 

is essentially for a back yard gardener there is 

some availability on certain varieties and 

certain root stocks in very limited numbers.

 I mean, we plant three or four 

thousand trees a year. The Washington guys here 

plant 200, half a million trees a year. We're 

not even close.

 And I'll say some more things about my 

thoughts, but just in direct response to that. 

I'll go after the other people. Emily.

 MS. OAKLEY: There's so much to say 

here. In terms of the strawberry producer in 

California they've been around for a while and 

they've been increasing their production. 

 I think the potential in the next five 

years is pretty great for them to expand. Some 

of the limitations right now are when those root 

stocks and grounds are available. And depending 

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upon where you are in the country when you need 

to plant.

 But I think some of that's going to 

change very quickly. Because it's already 

changed pretty dramatically.

 In terms of planting stock for trees 

although I'm a small farm we do have trees. And 

I think the issue of root stock is really key. 

And where you are in the country has a huge 

impact on where you're going to buy your trees.

 And the chance that you're going to 

find someone with the root stock and the variety 

that you need that is going to actually go to the 

trouble to offer that organically is pretty slim.

 And I think the reason that we sent 

this back was a hope to see if there might be an 

encouragement in the organic nursery industry 

with this material. But we didn't hear from 

anyone with regards to that.

 And that's because it's going to take 

way more than AITC to probably boost the organic 

nursery stock industry. 

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 To that point my final comment would 

just be I don't think we want to adopt a broad 

spectrum fumigant in the hopes that maybe some 

year down the road this might be helpful.

 And the precedent that that sets I 

think is a very slippery slope even with an 

annotation which we of course didn't come forward 

with at this time.

 So I still remain convinced that the 

committee's decision was the right one.

 MR. ELA: Asa.

 MR. BRADMAN: I just kind of want to 

reiterate some of the comments that have come by. 

But also kind of understanding that -- I'm 

looking at the recommendations from the Organic 

Produce Wholesalers and this came up last fall.

 To me it wasn't a question about AITC, 

but it raises this larger issue. What are the 

phytosanitary needs to support nursery stock. 

This may or may not be the material for that.

 I don't think we should approve it for 

that purpose. It hasn't even been validated or 

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tested for specific diseases where we're talking 

about -- that may be of concern for interstate 

transportation.

 Their other point, add a topic to our 

research agenda to identify methods and materials 

to support production systems for organic 

planting stock. I think that's important.

 Just in discussions recently I've 

talked to prominent organic orchard growers and 

they're buying non-organic stock on a regular 

basis.

 In a way that's a little bit similar 

to the issue of converting a cow from non-organic 

to organic.

 I see some similarities. But we're 

using a conventional system to produce literally 

the root stocks of organic agriculture. It would 

be great if the roots could also be organic.

 MS. OAKLEY: Can I just quickly add 

that yes, I have that as a research priority for 

this year. I think that has clearly come up.

 MR. ELA: Tom. 

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 MR. CHAPMAN: Just as long as you 

plant that tree before the first third of 

gestation.

 Good points. I hear you. I also 

think this would be a good area for us to 

potentially have a panel on like we've had on the 

barriers to organic seed.

 We've always focused on seed. We 

haven't really spent the same amount of time at 

least in my duration here on planting stocks.

 MR. MORTENSEN: And if we go to that 

to me this is clearly a case -- I think the point 

that has been made by two speakers already that 

this has got to be a systems approach.

 I really do think we should hold the 

line on having efficacy. So I totally agree with 

Asa's point.

 This is a very active compound and 

just having it be a one-off as a part of a 

nursery stock management plan, it's totally 

incomplete and the data they gave us is not 

sufficient to support this request in my view. 

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 MR. ELA: Harriet, I apologize. I 

jumped over you.

 CHAIR BEHAR: That's all right. I 

just want to say that the fact that I'm starting 

to see more nursery stock gives me hope that 

there has been -- they've figured something out 

and that others will figure it out too and that 

we'll see a growth without a reliance on a 

somewhat questionable material.

 MR. ELA: I'll throw in -- there is a 

need for organic nursery stock. It's a very 

complex system just like it is in seeds, of 

varieties. If you have 60 varieties of lettuce, 

you have hundreds of varieties of apples as well.

 And each state has its own 

phytosanitary restrictions. So it's not a 

national phytosanitary list although there is 

that too.

 So it's a complex topic. I did a 

search as part of my organic certification to 

look for organic trees. I barely could find the 

variety let alone size, root stock, et cetera, et 

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cetera. So it's very rudimentary.

 I think the other thing is at least in 

perennials, and I can't speak for strawberries, 

but a nursery is a very intensive place. I mean 

just like it is for humans, or maybe even cows if 

you want to make that comparison.

 But you're trying to graft this root 

stock and grow a saleable tree in a year and 

there's not a lot of tolerance for mistakes and 

there's a huge amount of risk. And I think that 

probably really cuts to the chase of how do you 

grow a viable nursery tree that can get planted 

out in an orchard like mine or other people's in 

a year. It's an intensive process.

 I think that's going to be the tougher 

nut to crack. Either that or we're going to have 

to accept much lower quality nursery stock, or 

grow it for two years, or some other process.

 I'm not against that, but the cost is 

going to go way up. And cost isn't an issue, but 

from a nursery standpoint they have to be able to 

justify their production. So, Emily. 

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 MS. OAKLEY: Just in conclusion I feel 

that as a matter of process especially for 

someone who loves process I think that when we 

create exceptions it is a very murky territory. 

And it just creates the argument for increasing 

exceptions over time.

 And I think we kind of see that in 

some of the issues that we're facing as an 

organic community. And I feel that to Dave's 

comment about holding the line I feel like this 

is a broad spectrum soil fumigant and it is a 

synthetic. I don't think that is something that 

we want in organic agriculture and I don't think 

it's a place that we want to go.

 MR. ELA: Rick.

 MR. GREENWOOD: Yes, just one comment. 

If you look at the TR the impact on soil health 

is noted. And I think one of the big issues for 

us is soil health.

 So again, it just seems incompatible. 

That's sort of the fundamental of what we do. So 

I don't know if we need another broad spectrum. 

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 MR. ELA: It seems like we've kind of 

honed in on most of the comments. Are we okay to 

go to a vote? I'm hearing more agreement than 

disagreement. So why don't we go ahead and move 

forward. 

 We have a classification motion to 

classify allyl isothiocyanate, AITC, as 

synthetic. It was a motion by Jesse. It was 

seconded by Harriet. Looks like we're starting 

with Lisa I think.

 MS. DE LIMA: Yes.

 MR. GREENWOOD: Yes.

 MS. SWAFFAR: Yes.

 MR. CHAPMAN: Yes.

 MS. BAIRD: Yes.

 DR. SEITZ: Yes.

 MR. MORTENSEN: Yes.

 MR. BRADMAN: Yes.

 MR. RICE: Yes.

 MR. ELA: Yes.

 MS. OAKLEY: Yes.

 MR. BUIE: Yes. 

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 MS. ROMERO-BRIONES: Yes.

 CHAIR BEHAR: Chair votes yes.

 MR. ELA: All right.

 MR. RICE: It's 14 yes, zero no. 

Motion passes.

 MR. ELA: All right. We'll move on to 

the National List motion. The motion is to add 

allyl isothiocyanate, AITC, at 205.601. The 

motion is made by Jesse, seconded by Asa. The 

vote would start with Rick, I believe.

 MR. GREENWOOD: No.

 MS. SWAFFAR: No.

 MR. CHAPMAN: No.

 MS. BAIRD: No.

 DR. SEITZ: No.

 MR. MORTENSEN: No.

 MR. BRADMAN: No.

 MR. RICE: No.

 MR. ELA: No.

 MS. OAKLEY: No.

 MR. BUIE: No.

 MS. ROMERO-BRIONES: No. 

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 MS. DE LIMA: No.

 CHAIR BEHAR: Chair votes no.

 MR. RICE: That's zero yes, 14 no. 

Motion fails.

 MR. ELA: Okay. We'll move on to the 

next petition material. Dave's going to present 

both ammonium citrate and ammonium glycinate. 

Dave, I imagine you can kind of present them 

together but we'll have to vote on them as two 

separate materials. So feel free to distinguish 

or lump as you will but we'll go to the vote 

separately.

 MR. MORTENSEN: Will do, Steve. 

Thanks. So, a company by the name of Alpha 

Chelates has submitted for two compounds, 

ammonium citrate and ammonium glycinate.

 The intent of both of these compounds 

would be that they would serve as chelating 

agents that would -- their purpose would be to 

apply them to the soil and deliver micronutrients 

that would be complexed with the chelating agent 

ammonium citrate or ammonium glycinate. 

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 We have been working on this 

application and three addenda to this 

application. We've spent a lot of time looking 

at this.

 We kind of got going around. In 2016 

the board determined that this was not something 

that we would approve, the subcommittee did, 

based on the fact that chelating agents exist, 

alternatives exist and certainly cultural 

management practices exist that basically provide 

the service of delivering micronutrients to plant 

rhizospheres to the soil and the roots of plants 

in the field.

 The applicant Alpha Chelates 

challenged the board with respect to its 

understanding of the chemistry of chelating 

agents and the language. And we had a new 

technical review performed that we received 

sometime in 2018 that we went through very 

carefully together and discussed on many phone 

calls.

 And basically concluded that we --

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basically these are chelating agents, ammonium 

citrate and ammonium glycinate, that the company 

is interested in seeing if we would register as a 

petitioned material.

 These are synthetic compounds. 

They're a synthetic reaction vessel where citric 

acid is combined with ammonium hydroxide to form 

these chelating agents.

 We asked for additional -- well, we 

had this out and we got feedback. I would say we 

got mixed feedback in the public comment.

 There was some comments from the 

Organic Produce Wholesalers Coalition about 

adding another chelating agent would add to the 

toolbox of things that could be used while others 

felt that we have sufficient numbers of things 

and management practices to perform the purpose 

of the chelating agents.

 Another point that I've been harping 

on during the course of the last day or so is the 

issue of supporting data. And I will say that 

the supporting data is very weak in this 

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application.

 The company is in Australia and we 

have one data set from dryland wheat production 

that shows some marginal improvements. And they 

draw quite a few conclusions about the influence 

of soil chemistry, pH, et cetera that's quite a 

reach, some of the claims that are made in those 

statements.

 So, the subcommittee looked at this 

and the subcommittee was not supportive of us 

going forward with this petition. 

 And based on the mixed feedback and 

nothing compelling in the way of new data I think 

we're ready to vote on the proposal. I am not 

supportive of this going forward for all the 

reasons that I've stated already.

 We have alternatives. Cultural 

practices. And I'm not meaning in tiny little 

farms and fields. This is -- the cultural 

practices are scalable. I just think this is not 

needed at this time.

 MR. ELA: Discussion. Emily. 

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 MS. OAKLEY: I just want to add that 

the original reason that the petitioner gave for 

petitioning this material was that the Australian 

authorities defer to the U.S. authorities when 

examining chelates, chelating agents.

 And so they were sort of pressing us 

to help them set a precedent for their own 

national standards.

 They also were having concerns about 

nomenclature uses both within the NOSB and NOP 

applications. 

 So I would just hope if I could put 

Clarissa on the spot which I didn't tell you 

earlier I would do. Are you comfortable 

addressing some of what was covered in the 

technical report regarding that point?

 DR. MATHEWS: Yes. So the recent 

technical report did address several of the 

concerns that have been raised about nomenclature 

and also listing within our system on the 

National List in terms of chelating agents.

 And the recent technical report had 

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very detailed coverage, over a page of additional 

material addressing these points.

 MR. ELA: Other -- Harriet?

 CHAIR BEHAR: I'll just say that to 

put it on the public record that we did have many 

robust discussions. This was not done lightly. 

Dave's discussion and I think the feeling of the 

subcommittee.

 We did give it an open-minded review 

and we did not come to a positive decision in the 

subcommittee.

 MR. ELA: Emily.

 MS. OAKLEY: Yes, sorry. Clarissa 

just reminded me that we actually rejected the 

initial technical report and asked for additional 

clarification on the nomenclature issue and 

subsequently got that back.

 So this has not been a slow process. 

It has taken a great deal of deliberation. I 

think that therefore addresses this re-petition 

that came before us. So I think we consider this 

issue very much addressed. 

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 MR. ELA: I'll jump in with my own 

comments. First of all I want to thank Clarissa 

and Dave. This shows why we have a diverse board 

and having a scientist that can work through the 

chemistry and having a technical advisor that 

also works through that gave me much more 

comfort.

 I could have spent a lot of days and 

figured it out, but I didn't want to. And so 

knowing that you guys could look at it. And the 

TR too in conjunction. But it gives me much more 

confidence in the outcome on this so thank you on 

that because these are the ones where we are 

above our pay grade. But we have people that 

have experience so thank you.

 I just want to reiterate in our own 

world there are other chelates out there that are 

usable in organics. This is not the only choice 

and they're not all lignin-based and the other 

things. I really struggle with essentiality on 

it as well besides some of the other technical 

issues. That's my own two cents. 

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 Any other comments or should we move 

to a vote? Okay. 

 The motion is to classify ammonium 

citrate as synthetic. It was motioned by Dave 

Mortensen, seconded by Harriet. And who are we 

starting with? 

 MS. SWAFFAR: Start with me. Yes.

 MR. CHAPMAN: Yes.

 MS. BAIRD: Yes.

 DR. SEITZ: Yes.

 MR. MORTENSEN: Yes.

 MR. BRADMAN: Yes.

 MR. RICE: Yes.

 MR. ELA: Yes.

 MS. OAKLEY: Yes.

 MR. BUIE: Yes.

 MS. ROMERO-BRIONES: Yes.

 MS. DE LIMA: Yes.

 MR. GREENWOOD: Yes.

 CHAIR BEHAR: Chair votes yes.

 MR. RICE: That's 14 yes, zero no. 

The motion passes. 

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 MR. ELA: Okay. The listing motion is 

a motion to add ammonium citrate as petitioned at 

205.601. This is a motion by Dave, seconded by 

Emily. Looks like we start with Tom.

 MR. CHAPMAN: No.

 MS. BAIRD: No.

 DR. SEITZ: No.

 MR. MORTENSEN: No.

 MR. BRADMAN: No.

 MR. RICE: No.

 MR. ELA: No.

 MS. OAKLEY: No.

 MR. BUIE: No.

 MS. ROMERO-BRIONES: No.

 MS. DE LIMA: No.

 MR. GREENWOOD: No.

 MS. SWAFFAR: No.

 CHAIR BEHAR: Chair votes no.

 MR. RICE: That is zero yes, 14 no. 

The motion fails.

 MR. ELA: Okay. If we could have the 

next slide. Dave, are you ready to proceed to 

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the vote on the second one?

 MR. MORTENSEN: Yes. 

 MR. ELA: Do you have anything else to 

add?

 MR. MORTENSEN: Not really. I mean, 

just to say that they're two very, very similar 

salts. The processes, the reaction process is 

the same. It's a synthetic compound. The 

technical review from 2018 addressed both of them 

together and as Clarissa said and others have 

pointed out and I may have glossed over it was a 

deep dive on the chemistry of these things and 

basically affirmed our interpretation of the 

chemistry and the appropriateness by which we 

were evaluating the fit of these compounds. So I 

don't think there's anything else to add, Steve.

 MR. ELA: Anybody else have anything 

else to add? Move to the vote. 

 So the motion is to classify ammonium 

glycinate as synthetic. Motion by Dave, seconded 

by Harriet. Starting with Sue.

 MS. BAIRD: Yes. 

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 DR. SEITZ: Yes.

 MR. MORTENSEN: So this is synthetic, 

right?

 MR. ELA: Yes.

 MR. MORTENSEN: Sorry. Yes.

 MR. BRADMAN: Yes.

 MR. RICE: Yes.

 MR. ELA: Yes.

 MS. OAKLEY: Yes.

 MR. BUIE: Yes.

 MS. ROMERO-BRIONES: Yes.

 MS. DE LIMA: Yes.

 MR. GREENWOOD: Yes.

 MS. SWAFFAR: Yes.

 MR. CHAPMAN: Yes.

 CHAIR BEHAR: Chair votes yes.

 MR. RICE: That's 14 yes, zero no. 

The motion passes.

 MR. ELA: Okay. The listing motion, 

motion to add ammonium glycinate as petitioned at 

205.601. It was motioned by Dave, seconded by 

Dan. We will start with Dan. 

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 DR. SEITZ: No.

 MR. MORTENSEN: No.

 MR. BRADMAN: No.

 MR. RICE: No.

 MR. ELA: No.

 MS. OAKLEY: No.

 MR. BUIE: No.

 MS. ROMERO-BRIONES: No.

 MS. DE LIMA: No.

 MR. GREENWOOD: No.

 MS. SWAFFAR: No.

 MR. CHAPMAN: No.

 MS. BAIRD: No.

 CHAIR BEHAR: Chair votes no.

 MR. RICE: That's zero yes, 14 no. 

The motion fails.

 MR. ELA: All right. The next 

material is mine for calcium acetate. One second 

here.

 So calcium acetate is a calcium 

material that is treated to provide additional 

available calcium to the crop. It's basically 

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limestone that's acidified and that makes more 

available calcium.

 It was petitioned for two uses. One 

as a calcium product to add calcium to plants in 

either soil or foliar and then it was secondly 

petitioned as a sunscald protectant either to use 

directly on the plant and fruit or over plastic 

to help reduce temperature loading of those 

crops.

 As far as public comments went fairly 

limited number of public comments. We had one 

group in favor, other groups against. There were 

no comments from growers in the record. We did 

have a couple of comments from the petitioner. 

 We certainly know some of the comments 

were that calcium foliar sprays are necessary in 

growing seasons because there are calcium 

deficiencies even in high-calcium soils. And so 

that was a claim for it.

 However, then the claim is there are 

other calcium products on the market. Some may 

be available in a slower fashion, but there are 

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also some chelated calcium products as well that 

are already on the market.

 One group noted as far as the sunscald 

protection goes especially in terms of reducing 

temperature loading when plastic is used, 

especially black plastic, that we do not believe 

that the application of a synthetic material in 

order to overcome the problems inherent in the 

use of another synthetic material, in other words 

using calcium acetate to overcome overheating 

caused by plastic mulch is compatible with 

organic production.

 I have to say in general this is a 

very benign product. It's a calcium material. 

It is synthetic, or we determined to be 

synthetic, we'll vote on that, but it's not an 

extensive process.

 However, it is adding a synthetic to 

the list. So I at least had issues with 

essentiality and the need for it.

 And then also do we really -- where 

there are actually natural materials available do 

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we want to add another synthetic to the list.

 With that I will open it up for 

questions. Emily.

 MS. OAKLEY: Not that I want to be the 

first person so if somebody else wants to go they 

can. All right.

 I was just going to say that I think 

there are ample calcium products and methods to 

address calcium deficiency. Many vegetable and 

fruit farmers address this issue in a number of 

ways.

 There are both products that can be 

used and there are cultural methods that can also 

help with this.

 In terms of sunscald additionally 

there are many cultural methods that can be used 

in terms of plant spacing, trellising, many other 

options that can help address this. In tree 

fruit that's a bit different.

 But I don't think that that is an 

issue that warrants the use of a synthetic. I 

think that there are many opportunities for 

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addressing this with tools that are already 

available.

 MR. ELA: Tom.

 MR. CHAPMAN: I know the petitioner 

had asked for more time to get public comment to 

support this. I will say that it seems like this 

petition wasn't written somewhat on the same 

format. It doesn't speak to the petitioner and 

it leaves out that we did have this as a 

discussion document item in 2018.

 So there has been two meetings with 

the opportunity for public comment that have 

failed to materialize at this point outside of 

the comment from the produce trade association, 

the produce wholesalers trade association. So 

that's difficult. 

 But I think that's important to note 

is that they had two opportunities both of which 

-- and the first opportunity we asked those 

questions about need from the industry or need 

from farmers.

 MR. ELA: Yes. Thank you, Tom. 

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Ashley.

 MS. SWAFFAR: I just noticed there was 

an abstention in the subcommittee. Was there any 

detail about that in the vote? It said there was 

an abstention.

 MS. OAKLEY: I think I remember that. 

I think that was you, Steve.

 MR. ELA: Was it?

 MS. OAKLEY: I could be wrong.

 MR. ELA: It may have been a meeting 

I wasn't at. I can't remember.

 MS. OAKLEY: I thought you were 

waiting to sort of get more information. I could 

be wrong.

 MR. ELA: It's possible. I don't 

know. I can't give you a solid answer on that. 

It could have been me.

 MS. SWAFFAR: Just making sure there 

wasn't something underlying.

 MR. ELA: Oh actually, I know what it 

was. I better not say. I was thinking -- I was 

thinking it might have been a new member. 

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 MS. OAKLEY: You're right. Actually, 

I think you might be right. It might have been a 

new member who did not have enough time.

 MR. ELA: I think it's when Eric came 

on.

 MS. OAKLEY: You're right. Thank you.

 MR. ELA: So there was some -- didn't 

feel like they had adequate background to vote on 

it.

 MS. OAKLEY: That's right. Thank you.

 MR. ELA: Sorry not to be more clear 

on that.

 CHAIR BEHAR: Right. And he's no 

longer here to speak to it.

 MR. ELA: So, other discussion on 

this? Rick.

 MR. GREENWOOD: Yes. Emily mentioned 

trees. So when we stump our avocado trees 

they're susceptible to sunscald. 

 And there's plenty of products. We 

use a clay product to spray on the trunk. So 

nobody is crying for that in our industry 

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certainly. We stump thousands of trees.

 MR. ELA: Yes. I know the use of clay 

like on tree fruits, it can be difficult to wash 

off sometimes. People use coverings.

 You can make the claim of while you're 

using a lot of plastic for a covering you could 

use a fairly benign product. But I think it 

comes back we just didn't have testimony to 

justify it. 

 Anything else? All right, we'll move 

to the vote. Motion to classify calcium acetate 

as a synthetic. Motion was made by myself, 

Steve, seconded by Harriet. We are starting with 

Dave.

 MR. MORTENSEN: Yes.

 MR. BRADMAN: Yes.

 MR. RICE: Yes.

 MR. ELA: Yes.

 MS. OAKLEY: Yes.

 MR. BUIE: Yes.

 MS. ROMERO-BRIONES: Yes.

 MS. DE LIMA: Yes. 

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 MR. GREENWOOD: Yes.

 MS. SWAFFAR: Yes.

 MR. CHAPMAN: Yes.

 MS. BAIRD: Yes.

 DR. SEITZ: Yes.

 CHAIR BEHAR: Chair votes yes.

 MR. RICE: That's 14 yes, zero no. 

The motion passes.

 MR. ELA: Okay. We have the listing 

motion, motion to add calcium acetate at 205.601. 

Motion was made by myself, Steve, seconded by 

Emily. We will start with Asa.

 MR. BRADMAN: No.

 MR. RICE: No.

 MR. ELA: No.

 MS. OAKLEY: No.

 MR. BUIE: No.

 MS. ROMERO-BRIONES: No.

 MS. DE LIMA: No.

 MR. GREENWOOD: No.

 MS. SWAFFAR: No.

 MR. CHAPMAN: No. 

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 MS. BAIRD: No.

 DR. SEITZ: No.

 MR. MORTENSEN: No.

 CHAIR BEHAR: Chair votes no.

 MR. RICE: That's zero yes, 14 no. 

The motion fails.

 MR. ELA: Moving onwards we have the 

proposal strengthening the organic seed guidance 

April 2019. Harriet.

 CHAIR BEHAR: Okay. So, we did get 

quite a few comments. Okay. So we did have some 

really excellent comments. And I want to say 

that this one has taken quite awhile to get to 

the finish line. I really appreciate all the 

previous public comments in helping lead us to 

this path. And it was very gratifying I think 

for the public and for me to provide it for them 

to see some of their language in this finished 

proposal. So it truly is a collaboration between 

the organic community and the NOSB and hopefully 

the National Organic Program.

 So, I would say there were a few 

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little tweaks here and there, but basically 

people said well, that's really all right except 

for one area.

 And that was -- Michelle, do you have 

that? And this is on 4.1.6 where we talk about 

the -- whether or not there's plant -- I'm just 

trying to get that open so I'm looking at it. 

Sorry. It all went so fast I didn't catch up.

 So, I had a discussion. There was 

discussion that the rule allows for the sale of a 

crop from a non-organic planting stock. And the 

guidance had that if the same plant is the mother 

plant to a planting stock that it had to wait a 

year before it could be sold as organic, be 

managed organically for a year before it could be 

on the organic market.

 But if it was a crop, and I used the 

example of a rosemary plant, they could cut that 

rosemary plant immediately and sell that as 

organic.

 And so we looked at the rule and yes, 

the rule says that crop could be sold as organic. 

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So we have removed that from the item.

 However, it is in the proposal as 

another issue. I didn't want it to get lost and 

at some point someone else will maybe deal with 

this in the future for a rule change. But we 

felt that there was just -- it didn't necessarily 

make sense to be selling a crop just the minute 

that it came onto the farm from a conventional 

source as organic when you are making a planting 

stock wait a year.

 And so I think Steve's trying to help 

Michelle. You've got it, right. Sorry, 

Michelle, that I didn't warn you that it was 

coming. Okay. 

 So I tried to make it really easy. 

The areas that I removed are in red. The areas 

that are in the new issue section are in blue. 

And as soon as she can get it up everyone can see 

it.

 And that would be the only change to 

the item that's up as a proposal. 

 MS. OAKLEY: Harriet, in the meantime 

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do you mind reading it?

 CHAIR BEHAR: Well, it's fairly long 

because I took everything from the proposal and 

moved it. So it's about three paragraphs. So I 

don't know how helpful that would be if I read 

three paragraphs. Okay.

 So in the blue there in the cross-out 

is what was in the proposal to change from the 

original guidance 5029. So that all is removed 

including the public comment and subcommittee 

response which then moves down.

 So then you can keep scrolling so you 

can see all of that for that whole section 

referring to that got removed. Okay, you can 

keep scrolling.

 So I believe that's on page 6 and then 

page 11 is where the new -- where basically all 

that got moved to is page 11. There it is. 

What's in blue. So that's what you were asking 

me to read.

 So all of that came from the earlier. 

I just cut and pasted. I'm sorry. So all of 

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this came from the earlier section except just a 

little bit of wordsmithing.

 So as 4.1.6 and 2.5.2.4(a)(4) are 

currently written certifiers can allow sale of an 

organic crop for consumption from non-organic 

planting stock immediately after planting it and 

would not allow any cuttings from that planting 

stock to be sold as organic planting stock for at 

least one year. Which is what I just said.

 As an example an organic grower can 

purchase a non-organic rosemary plant, plant it 

in their organic field or leave it in its 

original container, cut it immediately and sell 

it as an organic crop.

 However, as written if they make a 

cutting, put it in water and root it they cannot 

sell that plant for a year as an organic planting 

stock.

 The allowance for a crop to be sold 

from non-organic planting stock that has not been 

under organic management for at least one year 

was to provide for the sale of fruit from nonNeal R. Gross and Co., Inc. 

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organic strawberry plants and other fruits within 

the first year of planting on organic land.

 Typically other perennial plants do 

not produce fruits, nuts, or other non-vegetative 

crops within the first year. 

 However, vegetative growth that would 

be sold from the non-organic planting stock would 

have been managed non-organically. It does not 

make sense to sell this vegetative crop as 

organic, but the allowance for fruit does fit 

better with the regulation's intent since fruit 

would not be present at the time of planting.

 Therefore the sale of this fruit as 

organic had been considered to be more in line 

with current regulations.

 So if you're selling fruit within a 

year of receiving planting stock that seemed to 

make more sense because you're not going to buy a 

strawberry plant full of strawberries, plant it 

and sell those strawberries off that plant 

immediately. Like you would something that was 

vegetative. 

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 So 4.1.6 states -- again this was all 

just moved from up above. And then I have if you 

keep scrolling a little bit I have an improvement 

to the guidance and possibly the regulation could 

be. And there is based upon public comment any 

vegetative harvest from that planting stock may 

be sold, labeled, or represented as organic only 

after 12 months of organic management.

 Scroll back up.

 MR. CHAPMAN: So what specifically was 

added or changed that wasn't in the?

 CHAIR BEHAR: The 4.1.6 change was 

completely removed.

 DR. LEWIS: So Harriet, just a point 

of order. So in other words the document that 

the board has seen and the public has seen, 

there's been a change.

 CHAIR BEHAR: By removal of one item 

that nobody liked.

 DR. LEWIS: And the example you had 

about rosemary, that's new.

 CHAIR BEHAR: No, that was always in 

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there.

 MR. ELA: Harriet, Scott would like to

 CHAIR BEHAR: Yes, go ahead, Scott.

 MR. RICE: Yes. As noted in the 

comments there was a lot of confusion around the 

language and as Harriet just mentioned around 

vegetative crop, or vegetative stock, or 

vegetative growth. And there was a number of 

alternatives offered.

 At the end of the day I think the 

intent of improving the guidance was to close 

something that seemed somewhat nonsensical in the 

regulation. However, that is what the regulation 

reads and that's how certification has 

interpreted it.

 So instead of trying to make a 

guidance dictate what a regulation does or says 

Harriet took the move to just take this portion 

of the suggested changes out, but highlight the 

need or the desire to perhaps revisit the 

regulation so that it is a little more consistent 

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in crop as it is with planting stock if that 

helps any.

 CHAIR BEHAR: Yes. So, I don't know 

that it's that much of a substantive change 

because we're still pointing out that this is an 

issue that needs addressing. But we're not 

asking you to take it as guidance at this time 

except to help us look at this in this 

inconsistency.

 Because if the rule already says that 

that crop can be sold within 12 months we can't 

have the guidance go against that rule. That 

would have to be a rule change. Go ahead, 

Ashley.

 MS. SWAFFAR: Yes, I think this is a 

substantial change. Honestly, I do. Because 

you're taking out -- basically from what I can 

follow from this, this is very difficult to 

follow what you're changing here, but I think it 

says you're removing or an organic vegetable 

crop. Is that right basically is what you're 

removing? You're removing that language. 

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 CHAIR BEHAR: Vegetative crop.

 MS. SWAFFAR: Vegetative, sorry. 

Vegetative crop. That's what you're removing? 

What you're changing, in the whole document 

you're basically removing those words.

 CHAIR BEHAR: So we're removing any 

change to 4.1.6.

 MS. SWAFFAR: You're removing 4.1.6 

altogether?

 CHAIR BEHAR: No, removing any change 

to the current 4.1.6 in the current guidance.

 MR. CHAPMAN: Can I?

 CHAIR BEHAR: Go ahead.

 MR. CHAPMAN: I don't know if this is 

a substantive change, I just don't know if I 

understand the change. That's what I'm trying to 

struggle with.

 So let me try to say what I think 

you're saying to me and see if I understand it. 

The bold sections in here were what you were 

suggesting change to 4.1.6 and you're removing 

this altogether. So you're no longer suggesting 

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a change to 4.1.6.

 In the other text that you added what 

has changed in that text?

 CHAIR BEHAR: It came both from the 

description above where there's discussion of the 

public comment and then the actual in the 

proposal was removed.

 MR. CHAPMAN: So word for word it's 

the same.

 CHAIR BEHAR: There was a little bit 

of wordsmithing just to make it flow well.

 MR. CHAPMAN: So just like changing a 

therefore and an and or something like that?

 CHAIR BEHAR: Yes. It was a cut and 

paste. And I had Scott and Steve look it over.

 MR. CHAPMAN: Okay.

 MR. RICE: Instead of changing 

anything because this was confusing and caused 

alarm it was removed.

 MR. CHAPMAN: We've made changes like 

these on these in the past. I don't think -- it 

doesn't sound like it's substantive, it's just it 

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was hard for me to follow what actually was 

changed.

 MR. RICE: Understood.

 CHAIR BEHAR: If you scroll up on page 

6. Keep going to page 6. 

 MR. ELA: So it's keeping -- instead 

of proposing to change to that section it's 

keeping it as it is, as it currently reads in 

guidance.

 CHAIR BEHAR: Right there. So it says 

no changes to 4.1.3, 4.1.4 and then I added 

4.1.6.

 MR. ELA: And then it moves it to the 

bottom to tell the NOP as a suggestion here's an 

inconsistency in the rule. We can't change the 

rule right now. This isn't about the rule, but 

this is something we should pay attention to so 

it will be preserved in the record rather than 

having it come back to transcripts. 

 So it's just taking that section 

saying we know it's in the wrong spot.

 CHAIR BEHAR: Yes. So since this is 

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a recommendation on updating a guidance and the 

guidance really cannot inform a rule change 

that's why it was moved.

 MR. CHAPMAN: Thank you. Thank you 

for helping me understand the change.

 CHAIR BEHAR: There's a lot of pages 

to it. And then we could then still keep the 

wording as a suggestion for future discussion or 

whatever. 

 There were no other changes except 

trying to make it clear that we've removed 4.1.6. 

The changes to, not entirely.

 MR. ELA: Okay, discussion? 

 CHAIR BEHAR: Ashley.

 MS. SWAFFAR: Can you send this to us 

so we can look at it? I feel like you've added 

and taken away in a few places and I would like 

to see this before we vote on this.

 CHAIR BEHAR: Michelle, can you send 

it to everyone?

 MR. ELA: Scott can. Michelle's got 

her hands full. 

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 So, in the interest of time can we --

could I have a motion to table this? We'll put 

it up with collagen so we can come back to it. 

We can proceed to sunsets while you guys look at 

that.

 MR. CHAPMAN: I move to table this to 

deferred items.

 MR. ELA: Okay, is there a second? 

Okay, so Tom and then Dave seconded. I believe 

we could use a unanimous consent. We are 

trainable, Tom. Anybody object to the unanimous 

consent? Okay, we'll table this and we'll come 

back to it. That will give us the break time to 

have a little time for everybody to catch up on 

that.

 With that we will move into discussion 

document on paper pots, well paper I'll just say. 

I should not say pots, just paper. Which is a 

petitioned material that is -- so this is just a 

discussion document. It will not be a vote so 

it's just an update.

 CHAIR BEHAR: Sorry, I'm just trying 

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to find. Oh, here we go.

 MR. ELA: So as we know at the last 

meeting this came up. It was a pretty hot topic. 

The committee decided not to ask for a TR. And 

then as we got into it we realized that the pots 

had more materials in them than we knew about so 

we did decide that we did need to ask for a TR. 

So that's been submitted. We're waiting for it. 

And we decided to proceed with a discussion 

document for this meeting to make sure the board 

knew where the subcommittee was at and what some 

of the issues might be. So Harriet.

 CHAIR BEHAR: Okay, I got it. Okay, 

so we found that there were numerous synthetic 

fibers being used in both the paper chain pots 

and in Ellepots and we haven't even dug deeply 

into some of the other papers used as production 

aids.

 But we did have numerous growers 

continue from the fall meeting to stress their 

need for the use of paper pots and specifically 

the products sold by the petitioner, the paper 

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chain pots.

 And as the petitioner stated yesterday 

the manufacturer of the paper chain pots is 

working towards removing the synthetic fibers 

from their current product, replacing it with 

hemp fibers with -- and unfortunately last year's 

experiments were not successful, but an updated 

sample will be received from that Japanese 

manufacturer of the paper chain pots this summer 

to test the paper with the hemp fibers to see if 

they're working.

 Ellepots, another manufacturer of nonchain paper pots provided the inclusion of 

numerous other synthetic fibers. Vinylon is the 

one in the paper chain pots. Ellepots discussed 

the use of polyester, rayon and tencel. Two of 

them being cellulosic fibers and polyester coming 

from fossil fuels.

 They prefer the synthetic fibers for 

the pots for plants that grow that are in those 

pots for longer time because they need to get to 

a bigger maturity. So if you're growing lettuce 

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versus growing a tomato plant they're in a pot a 

little bit longer.

 They do have a pot that is 100 percent 

paper and the same type of paper and adhesives 

that are found in newspaper, but this does not 

have a very long shelf life and they would like 

to be able to use their rayon and tencel, et 

cetera, and have those reviewed and possibly 

approved. They had really excellent public 

comment.

 We have asked the program for a 

technical review for the synthetic fibers for 

paper as a crop production aid.

 And then there was one question that 

pointed out that they felt that the review of hot 

caps should not be part of the crop as a -- paper 

as a production aid because they don't degrade 

into the soil.

 But we felt that this does come into 

contact with the soil and at times they could 

remain in the field as part of its disposal. You 

get heavy rain or whatever you're not going to be 

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hauling all your paper hot caps out of the field.

 So we're going to leave that in there 

as far as part of the review. And that's my 

summary.

 MR. ELA: Tom.

 MR. CHAPMAN: I have two questions. 

What's a hot cap?

 CHAIR BEHAR: You put that out in the 

fields. It's like a little hat, like a party 

hat, and it keeps the plant warmer, or after 

transplanting it will shade it. So then it 

doesn't go --

 MR. CHAPMAN: Like little beanies, 

little beanies for the plants?

 CHAIR BEHAR: Well, it looks more like 

party hat, actually. Or like a tepee or 

something.

 MR. ELA: It would be equivalent to 

sort of like your wall of water. Different 

material obviously. You're trying to protect the 

plant.

 MR. CHAPMAN: Yes. Okay. If I'm 

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reading -- I wonder if I'm reading this right 

that discovery of synthetic fibers is also 

applicable to newspaper. Is that correct? It's 

likely, do we think it is, is it?

 CHAIR BEHAR: You mean are there 

synthetic fibers like these in the newspapers?

 MR. CHAPMAN: Yes.

 CHAIR BEHAR: We didn't get as deep a 

review of that in the newspaper TR and that's why 

we thought -- and especially since the paper pot 

manufacturers were really asking us to very 

specifically allow these specific synthetic 

fibers that we should dig a little deeper there.

 MR. CHAPMAN: Okay. Is there 

potential overlap between these synthetic fibers 

potentially already in use in soil applications 

either in the paper pots out there right now in 

use or if it is in newspaper and newspaper is 

based on -- I know we had at least a public 

comment about glues and other things in 

newspapers to cheapen them.

 But if they're being -- is there a 

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similar in thinking about this as we're thinking 

about biodegradable biobased mulch that there's, 

you know, synthetic petroleum-based products 

being put into the soil to break down and be 

consumed by soil microbes? Am I connecting 

things wrong or am I connecting things right?

 CHAIR BEHAR: We were trying to use 

the newspaper TR as best we could in looking at 

paper as a crop production aid. But really there 

just was not enough.

 And really tencel and rayon are not 

petroleum products so there isn't the same issue 

there. The polyester is a fossil fuel-based 

polymer of some sort. Don't ask me the 

chemistry.

 MR. CHAPMAN: So it's breakdown would 

be akin to some of the stuff we --

 CHAIR BEHAR: Perhaps.

 MR. CHAPMAN: Perhaps.

 CHAIR BEHAR: Perhaps. We don't know 

the answer to that because it's a different 

polymer. 

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 MR. ELA: If I could jump in. We 

thought we had this made. Natural fibers, 

adhesives already used in paper, we're cool.

 And then it came back that their 

attempts to use hemp had not gone well and that 

they needed to add synthetic fibers to especially 

the paper pots to keep the chain because if the 

chain breaks the system doesn't work. 

 We've had a lot of contact with the 

Ellepots people as well as with this petitioner. 

Both of them are working very hard to get the 

synthetics out but they're not there yet. So we 

don't want to end up with the biodegradable mulch 

issue where we say yes, let's use something we 

can't do.

 But I've been educated on this. My 

organic chemistry was a long time ago and it 

wasn't my best class. 

 So rayon, for example, synthetic. 

It's cellulose-based. Is similar to adding 

cellulose to the soil. So even though it's 

synthetic we're not too far apart there. 

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 So relatively small percentages of 

rayon. And this is one of the reasons we asked 

the question whether it's less than 20 percent. 

I mean, one manufacturer told me 15 percent was 

quite doable. They're even saying maybe lower 

now. Paper pot people are saying maybe lower.

 So we're trying to really nick that 

down is how low can we go. We'll do the limbo 

with the paper pots. 

 And then the TR is should we even go 

down that route. It went from kind of a slam 

dunk to like oh, we have to really think about 

this. Emily.

 MS. OAKLEY: Okay, I highly encourage 

the entire board to look at the supplemental 

newspaper TR because there are adhesives and 

there are synthetic fibers in paper products 

already in use.

 The newspaper TR does a pretty good 

job of covering a vast array of areas, but it 

also and I think Joe used this term of meeting 

back. There's like the et cetera, et cetera, et 

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cetera. There's just a whole swath of unknown 

that is already allowed in the current paper 

listing.

 I probably feel a little differently 

from my other board members on this topic. I 

mean, while I'm concerned absolutely I don't want 

to have a product that's like 90 percent 

synthetic fiber and 10 percent paper.

 I certainly do not want us to create 

some sort of a listing that is more strict than 

what's already allowed because theoretically 

someone could go out and put cardboard all over 

their field. There's a tremendous amount of 

adhesives in cardboard and synthetic fibers and 

that would be perfectly allowed.

 And it would be a much greater 

quantity than these applications. 

 So, I don't want us to split too many 

hairs over this while at the same time I want us 

to get the needed information.

 MR. ELA: Harriet.

 CHAIR BEHAR: So, we did not ask for 

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a TR on adhesives because we felt that that 

newspaper TR really did cover it okay.

 But when we went looking for the 

synthetic fibers it was kind of like yes, there 

are many. And that didn't tell us very much. 

Like which ones. 

 And so we felt like we didn't have 

enough technical background to then just carte 

blanche allow them.

 And as Steve said too the annotation 

may include a limit. It may say synthetic fibers 

allowed, rayon, tencel, at no more than 20 

percent. I mean, but that's just off the top of 

my head. That's kind of what we're looking at.

 Because again we have learned from the 

biodegradable mulch which did not give a 

percentage of the biobased and then the NOP took 

it as 100 percent. So we wanted to make sure 

both that we were doing our due diligence in the 

review and that we would have something practical 

to offer to the community.

 MR. ELA: And I'll echo what Emily 

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said. I'm in her camp. We don't want to make 

something different than newspaper, what's 

already allowed.

 But we also don't want to just go 

whatever and have it explode in our face. So 

we're trying to --

 MR. CHAPMAN: Don't interpret my 

questions as meaning I'm thinking in that realm. 

I'm trying to understand what was written there 

and to be honest what is already out in the field 

via newspaper. It's more about that than what we 

were looking at and reviewing.

 A new substance that would be akin to 

or better than what's already out in the field is 

more on the newspaper side that are my questions.

 MR. ELA: Sue.

 MS. BAIRD: I just wanted to say I 

appreciate your diligence because I was in the 

beginning of this discussion when I was on the 

Crops. And so I really appreciate the fact that 

you delved a little deeper into it. I was 

concerned at the beginning if you remember about 

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the fact that.

 The people who tried the hemp, it's 

interesting that it's not holding up because I 

know they're using hemp even in hydroponics 

strictly in water and they're using straight hemp 

fibers for hydroponic in water.

 Was there any discussion on how the 

hemp was being incorporated?

 CHAIR BEHAR: I've only had one on one 

talks with the importer and he's expressed to me 

that it's a little bit difficult because there's 

a language barrier. The manufacturer is 

Japanese. 

 And the manufacturer doesn't really 

understand our process, how we're looking at it 

and trying to figure all this out. 

 So I don't even know if he knows 

exactly how much hemp was put in that paper or 

whatever.

 Truthfully hemp is kind of becoming 

more available. So it's kind of a newer product 

for the manufacturer to try to incorporate into 

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that paper.

 MR. ELA: One of -- in the discussions 

I've had with people is this is a first try. It 

didn't work like they thought. They're trying to 

do it in one shot. Research rarely works that 

way.

 I've had discussions with another 

manufacturer and they think in 15 years it will 

absolutely be all hemp, not an issue. But we're 

talking about some retooling.

 What's interesting I think even having 

this discussion we're seeing the manufacturers 

look at this and go oh, maybe we could go back 

and reformulate a little bit. So I think we've 

already changed the playing field just by the 

discussion which is really, I mean that's really 

cool. These manufacturers I think are really 

trying to work with us.

 But it's not necessarily simple. So 

Dave.

 MR. MORTENSEN: And I'm also thinking 

that, you know, the whole notion of continuous 

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improvement. 

 I thought two of the presentations 

made to us these last couple of days were really 

compelling. And that was that when we transplant 

with paper pots, or transplant period we're 

really helping with all sorts of other pest 

management that actually relies much more heavily 

on plastic, for example.

 So when we look at this in a systems 

context we have the potential to really minimize 

the impact of some of the system-level practices 

we're using where we could be precluding such 

heavy reliance on plastic just as an example. 

That is a really encouraging thought.

 MR. ELA: Other -- Emily.

 MS. OAKLEY: Sorry again. I just want 

to say that again please go look at that 

newspaper TR. It won't take you very long. It 

will take you five minutes at max.

 And it does list synthetic fibers 

commonly found in paper, but it's just commonly 

found. I mean just broad. 

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 So if we come up with some sort of 

percentage that's going to start getting a little 

tricky because is it going to force us to go back 

and start creating percentages in that current 

listing. So just a cautionary note.

 MR. ELA: All right. I think we'll 

probably end it there. There's your background. 

So when it comes up again you'll all be educated.

 Harriet, should we just proceed with 

sunsets? Do you want to take a break or 

anything?

 CHAIR BEHAR: Ready for a break?

 MR. CHAPMAN: Maybe we do sunsets and 

then break?

 MR. ELA: Okay. Fair enough. Okay, 

we'll move into sunsets. The first one is 

hydrogen peroxide. Jesse, this is your material.

 MR. BUIE: Okay. We have two hydrogen 

peroxides at 205.601.

 DR. LEWIS: I think the first one is 

ferric phosphate.

 MR. ELA: Not on my list. 

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 MR. CHAPMAN: My list says ferric 

phosphate.

 MR. ELA: We must have two different 

-- I'm in Crops.

 MR. CHAPMAN: The short printout has 

hydrogen peroxide first. The big packet has 

ferric phosphate first.

 MR. ELA: Sorry. Yes. I guess we 

have hydrogen peroxide up on the screen so we'll 

go with that. I'll use executive power. So go 

ahead, Jesse.

 And just as a reminder to all the 

sunset people just really summarize comments, 

public comments, high points that might be points 

of discussion.

 MR. BUIE: Okay. Hydrogen peroxide, 

205.601. Reference 205.601 as algicide, 

disinfectant, sanitizer including irrigation 

system cleaning systems and at reference 

205.601(i) as plant disease control.

 Hydrogen peroxide is widely used as a 

disinfectant and bleaching agent. As we 

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mentioned earlier it has a very simple molecular 

structure which is H2O2.

 Contamination is not expected when 

purified forms of hydrogen peroxide are released 

to the environment following normal use.

 At typical pesticide concentration 

hydrogen peroxide is expected to rapidly degrade 

to oxygen gas and water.

 While there are some alternatives on 

the National List for sanitizers and 

disinfectants as well as some essential oils and 

antiseptic properties the National List items are 

not necessarily any better or safer than hydrogen 

peroxide and the essential oils have not been 

studied to compare with hydrogen peroxide side by 

side to see if they are equally as effective and 

equally benign.

 We received few comments, but the 

comments from 2015 were overwhelmingly in support 

of hydrogen peroxide. It's widely used to clean 

equipment, in mushroom production as one speaker 

mentioned during this meeting and as an alternate 

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to other materials for resistance management.

 The NOSB found the material to meet 

OFPA criteria and there were no objections to 

continued listing.

 No significant new issues were raised 

by the public. Are there questions?

 MR. ELA: Any questions on hydrogen 

peroxide? Okay, seeing none we will move onto 

soaps, ammonium. Rick.

 MR. GREENWOOD: Okay. Ammonium soaps, 

205.601, synthetic substances. It's used as an 

animal repellant, for large animal repellant 

only. No contact with soil or edible portion of 

a crop.

 It's saponified fats and it is used 

again for large animal barriers.

 There are other things that can be 

used. Fencing is one that can be used. A couple 

of other things include coyote urine which I have 

used to keep rabbits away and is worthless but 

that's a personal opinion. I think it attracts 

them. 

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 I talked to CCOF who's my certifier 

and they have people have it on their system 

plan. 

 And we had one comment in the webinar 

saying that they'd like to keep it onboard. But 

otherwise low toxicity. There's no long-term 

studies because it degrades in the environment 

almost immediately.

 MR. ELA: Any questions on soaps? 

I'll just interject one. I think there is the 

question of effectiveness that kind of comes up.

 I mean, people keep saying it's there. 

Some people -- I thought it was interesting. 

Public comments, some people seemed to believe it 

was effective even though there's some anecdotal 

stuff and maybe for different species. But I 

just want to put that in that that still is a 

question on this material. 

 MR. GREENWOOD: Exactly.

 MR. ELA: Okay. Moving on. This is 

my own. So oils, horticultural (narrow range 

oils). It actually has two listings and I'm 

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going to lump them both together. One is for --

as an insecticide and I don't have the other one 

right in front of me.

 Basically public comment on oils, 

heavily used, widely used, multiple crops. 

Everybody is in favor of them. A very critical 

organic input.

 One of the questions, we received a 

new TR on this. And it was interesting because 

the TR did list a lot of alternative oils other 

than petroleum, plant-based oils. 

 And so we asked the question if those 

plant-based oils were actually viable 

alternatives. I'd say almost all the comments 

were no, they aren't which has been sort of what 

I've heard as well as a grower.

 I think Harold Austin in particular, 

he said you ask if there are other types of oils 

available. The answer is yes. Will they work in 

place of horticultural spray oils, the answer is 

no.

 Some of the alternative types of oils 

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such as fish oils, vegetable oils can be 

extremely hard on the plant and/or the crop. 

Most of the alternative oils can be phytotoxic to 

the foliage and the fruit itself. 

 They also tend to have compatibility 

issues with other materials used in organic 

production which then in turn can cause 

additional crop or plant injury.

 Another group noted that the listing 

for horticultural oils should be annotated in a 

way that protects workers from inhalation hazards 

and non-target arthropods from harm. If this is 

not possible they should be de-listed. 

 They suggest that the annotation read 

steps to meet worker protection standards must be 

documented in the organic system plan and they 

must not be used when predators, parasitoids, or 

pollinators are present.

 And I would just respond to those 

comments. The petroleum oils have become much 

more refined in recent years. There are several 

available to organic growers that become much 

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narrower spectrum and we're able to use them kind 

of throughout the season without injury. So I 

think they've become much more specialized. 

 I think that's one of the problems 

with some of vegetable oils is we don't have that 

same type of refinement yet.

 In terms of worker protection 

standards I don't believe in that annotation just 

because we all have to comply with worker 

protection standards. It's kind of like saying 

excluded methods for organic. We can't use GMOs. 

We can't use oils without meeting the worker 

protection standards legally so I don't see any 

reason to annotate that. That's sort of a given.

 And then as far as the may not be used 

when predators, parasitoids, or pollinators are 

present that would essentially say you would 

never be able to use them to be able to guarantee 

that. 

 I think a lot of the point of using 

oils is that they are fairly soft. They don't 

tend to disrupt those populations and there's 

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hundreds of years of experience that.

 Take those comments seriously. They 

need to be used thoughtfully and carefully, but 

they are used often specifically because they are 

gentle on predators.

 Any discussion on oils? 

 CHAIR BEHAR: It's always helpful to 

have someone who really knows the subject.

 MR. ELA: I was just putting them on 

earlier this week. Okay. Moving on, pheromones 

which is also my own.

 Used for insect management. Again, 

pheromones, widely accepted, widely used. Most 

organic growers in some way may use them whether 

it's for insect monitoring and traps or for 

mating disruption. Definitely it's something the 

organic growers helped kind of research and it 

moved quickly into the conventional industry.

 So basically the one question that I 

kind of had and it's generally been resolved by 

OMRI is that we just list them as pheromones. 

There have been attempts to make sprayable 

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pheromones on the market. To my knowledge none 

are being used at this point would have food 

contact. There might be some used in cotton but 

that's not a food. So the de facto use has been 

in non-food contact.

 We don't have that annotation. It 

makes me a little uncomfortable. I wish we 

actually had that tied up a little bit. But at 

this point I don't think it's a work agenda item 

just because it's not an issue. It is something 

I could see possibly coming down the line 

someday, but we're not there yet.

 And the questions we had are there any 

health or environmental effects noted. 

Essentially no major comments on that.

 Any formulations that might cause 

concern. That comes down to the sprayable 

formulations that would concern me. 

 And then are there any pheromones 

synthesized with excluded methods and we didn't 

get any comments on that. To my knowledge most 

of the pheromones that are used, for example, 

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codling moth pheromone is essentially a six or 

seven component material that's very selective 

and they found that we can use three and that 

does well enough. The extra three are very 

expensive to synthesize and to include. So we 

can keep the cost down by using three and it's 

still a very selective material.

 That pretty well covers pheromones. 

Does anybody have any questions on them? Moving 

on.

 MR. RICE: Just a comment. There's 

one -- I think we have one material that's 

sprayable that is on the market. Pheromones.

 MR. ELA: For -- do you know what use?

 MR. RICE: I'm trying to remember what 

the use was. I can get it back.

 MR. ELA: The one that somebody told 

me yesterday was for cotton.

 MR. RICE: No, we have it used in 

other applications too.

 MR. ELA: I'd be curious. I've tried 

asking around. I know if there were some, maybe 

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it's 10 years ago that they were really looking 

at and just couldn't -- didn't perfect them. At 

that point they weren't going to be used in 

organic anyhow.

 All right. Moving on, ferric 

phosphate. Dave.

 MR. MORTENSEN: Yes. So ferric 

phosphate is a compound that's used as a 

molluscicide for slugs and snails with an 

increased adoption of reduced tillage practices 

in vegetables and increased reliance on cover 

cropping.

 The organic matter on the surface is 

ideal habitat for slugs in particular, but also 

snails.

 We looked at this carefully and 

composed these four questions and we got some 

really helpful feedback about them from the 

Organic Produce Wholesaler's CCOF and the Vermont 

organic farmers about the formulations folks are 

using and about the fact that they rely on ferric 

phosphate for slug protection quite a bit 

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actually. So that feedback was very helpful.

 The one that had to do with quite an 

active series of discussions that we had about 

formulations and the potential for inhalation 

exposure to field workers and other things, and 

most all of the feedback has been that it's being 

used in a pelleted form which is helpful and 

comforting from a field worker exposure 

perspective.

 The one thing that we were concerned 

about and several people spoke to this sometimes 

-- well, spoke to it during some of the public 

comment was the fact that alone, ferric phosphate 

used alone is rather marginally effective at slug 

suppression.

 When used in combination with a 

chelating agent, EDT or EDDS, these are two 

compounds that behave quite similarly to the 

chelating agents I reviewed earlier the activity 

of the compound increases by orders of magnitude 

on slugs.

 And we have compelling efficacy data 

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to support that in the form of a number of 

studies.

 One unfortunate outcome of the 

increased efficacy on slugs is that when you add 

these chelating agents it increases their 

activity on earthworms and other organisms in the 

soil that are beneficial.

 So we took a very careful look at that 

data as well and that was one of the reasons that 

gave rise to the question about any additional 

information about the compound being used alone, 

ferric phosphate, or formulated with the 

chelating agent.

 The products that we're aware of are 

formulated with the chelating agent. That's not 

to say that we don't think ferric phosphate 

should be allowed to be used. It is to say that 

it's leading us to look at it more closely and 

more critically. 

 That's about where it is. We've 

gotten really helpful feedback and we'll continue 

to monitor that feedback as it comes in. But 

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people have been really good about speaking to 

the questions that we asked folks to respond to 

and we thank them for that.

 MR. ELA: Questions, responses? 

Ferric phosphate.

 I will add in what Dave referred to. 

We actually had a number of discussions with the 

program. 

 It comes back that the registered 

material ferric phosphate and even though there's 

fairly obvious effect of the ancillary -- we 

might not call it ancillary in crops, but the 

inert material that it's mixed with, we only 

reviewed ferric phosphate. So this is kind of a 

weird one that basically our review is on ferric 

phosphate and not on the extra materials added to 

it. So, Emily.

 MS. OAKLEY: I just want to complement 

that to let the stakeholders know that we spent a 

significant amount of time on this material in 

the Crops Subcommittee and take seriously these 

issues that Dave has laid out. 

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 MR. ELA: Good point. Yes, it was not 

-- Asa, sorry.

 MR. BRADMAN: I just want to reiterate 

this point too about reviewing ferric phosphate 

versus the actual formulation.

 I would say for me just like to vote 

on ferric phosphate for this use in this material 

it would be wrong in the absolute sense of right 

and wrong.

 If the material is used as a 

formulated product and it's only effective as a 

formulated product it seems to me that should be 

what we're reviewing.

 I know that raises a lot of cans of 

worms so to speak, but it just seems like the 

right thing to do.

 MR. ELA: That's what we went back and 

forth with the program on. The problem is we 

don't review products. So that's the issue.

 Your comment is well taken. It was an 

issue as you know for the committee in general. 

Anything else? Emily. 

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 MS. OAKLEY: Yes, but I mean I think 

Asa's point is well made because if we were just 

reviewing this without the inert then it's not 

effective. So, I have to talk about the chicken 

and the egg.

 MR. ELA: The worm and the slug.

 MR. MORTENSEN: I guess I would say 

that I don't know. I can't separate them. So 

when I vote on something like this if everyone is 

using the formulated product I can't separate 

those two things in my mind.

 I think in action it's being used that 

way and certainly we need to be cognizant I would 

say. I got the sense the subcommittee generally 

feels this way. We have to be cognizant of how 

it's being used.

 The environmental data are pretty 

strong to suggest a close look at it. And the 

efficacy is orders of magnitude higher. So, I 

don't know. But we have all that data in front 

of us and that's a great thing. So that helps 

inform our thinking about what we think of ferric 

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phosphate.

 MR. ELA: Anything else? And you get 

the joy of writing it up and then everybody will 

have a chance to vote next fall on their thoughts 

on that.

 Moving on we have potassium 

bicarbonate. Emily.

 MS. OAKLEY: Potassium bicarbonate is 

used as plant disease control. It's used on a 

variety of crops and a variety of diseases.

 We asked a couple of questions about 

are growers using any of the alternative 

materials that might be able to replace this on 

their farm and if they did could they tell us 

about the desired results. But we didn't really 

hear that.

 But what we did hear was pretty 

significant response to our second question, if 

this material was still needed.

 We got some specific diseases in 

crops, primarily powdery mildew, cucurbit, 

strawberries, tomatoes and high tunnels in 

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greenhouses. And then also tree fruits.

 It was kind of explained as something 

that might be used later in the season when 

alternatives could damage the crop.

 And it's being used to control fire 

blight in orchards so it's playing an impact role 

with the limited tools that might be available 

for that.

 There was a comment that it does not 

fit any OFPA categories of allowed synthetics. 

But by and large we did actually receive some 

nicely robust comments on this and I really 

appreciate it when we hear from so many people on 

a material. Any questions?

 MR. ELA: All right. We will move on 

to magnesium sulfate. Emily.

 MS. OAKLEY: Yes. So magnesium 

sulfate allowed with a documented soil 

deficiency.

 So definitely people who commented and 

wrote in were in support of maintaining that 

annotation saying that it's not used that often, 

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usually as a rescue treatment.

 We did ask about non-synthetic 

magnesium available in sufficient form and 

quantity because the 2011 TR did point to nonsynthetic dolomite as an alternative material.

 But the previous reviews of this 

material have shown that that might not be widely 

available or useful. 

 So we did get some comments on that 

and I also really appreciate that. We heard that 

the non-synthetic dolomite is expensive and not 

widely available, that mined magnesium sulfate 

does not work quickly enough and must be added in 

higher quantities.

 We also heard that dolomite creates 

problems in plugs drip irrigation. We also heard 

that dolomite cannot substitute in all cases 

because as a rock powder it's slow to become 

available, not good for high pH soils and can't 

be used in foliar applications.

 We did also hear that it should not 

take the place of soil-building practices. And 

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pretty widespread comments on this as well, a 

highly used product. 

 We were told that it's used by 100 

percent of fruit tree growers in the Pacific 

Northwest and especially the state that we're in.

 And again as I said it's really used 

I think as a rescue treatment and hopefully not 

widely used obviously without the documented 

deficiency. That it's useful in high pH soils 

with ample calcium where sulphur is needed but 

they don't want to increase the pH.

 Any comments or questions?

 MR. ELA: All right. We will move on 

to hydrogen chloride. And Asa, I believe this is 

yours.

 MR. BRADMAN: Thank you. So this is 

a really interesting compound. Hydrogen chloride 

is used to generate an acid environment to delint 

cotton seeds for planting. 

 Basically it's vaporized and sprayed 

into cotton seeds with some moisture and that can 

then generate a strong acid to remove the lint 

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and also helps with breaking dormancy. So it 

serves a couple of roles there for pre-treating 

cotton seed to grow it.

 In terms of public comment there's 

really no groups that are opposed to it. Both 

trade groups would like to see it re-listed and 

community -- National Organic Coalition, Beyond 

Pesticides even are in support of re-listing it.

 But there is concerns about using such 

a strong acid and material for accomplishing this 

in terms of both potential environmental and 

occupational exposures.

 And there's kind of a consensus that 

it would be great to move away from this, but 

also at least from the trade organization that 

there's really not a commercialized alternative 

to this material at this point.

 From 2014, five years ago there was a 

reference to work being done at a USDA station to 

generate a mechanical system. And according to 

the group that we heard from yesterday in their 

written comments there's been kind of a move from 

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a tabletop version to a drum scale version. And 

it's kind of at a threshold for a commercial 

company really now to take it on to see if it's 

commercially viable. Not within the scale of an 

academic lab.

 But one of the issues here is the 

scale of organic cotton in the U.S. is too small 

to support that industry which I think is also 

important and relevant.

 I think re-listing this is important 

to help support this domestic U.S. cotton 

production system.

 I know back in 1996 when Patagonia did 

their review of materials and really identified 

cotton as one of their major products and fibers 

that impacts on the environment. And they've 

really moved most of their -- as far as I 

understand most of their cotton production is in 

India.

 I think it would be great to continue 

to support domestic cotton production. And then 

also perhaps we can provide tools down the road 

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to help that expand.

 MR. ELA: Questions for Asa? Harriet.

 CHAIR BEHAR: Do we know what they're 

using in India? Do they use this material as 

well?

 MR. BRADMAN: I don't know. Good 

question. I'll follow up on that for the fall.

 MR. ELA: Any other discussion? All 

right. Next is ash from manure burning and this 

is switching to prohibited substances just as a 

note.

 CHAIR BEHAR: Okay. No one noted that 

this material was in use which is good because 

it's prohibited. 

 No one asked for it to be moved to the 

allowed list and many agreed that it should stay 

on the prohibited list.

 I just want to read something that 

just gives a little background that the Organic 

Produce Wholesalers Coalition gave us, some 

language from the preamble in December 2000 --

1997 that it was placed on the prohibited list 

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because burning these materials is not an 

appropriate method to use in order to recycle 

organic waste and would not be considered a 

proper method in a manuring program because 

burning removes the carbon from these wastes and 

therefore destroys the value of the materials for 

restoring soil organic content.

 Burning as a disposal method of these 

materials would therefore not be consistent with 

organic production. That's it.

 MR. ELA: All right. Any discussion 

on this? Okay, nobody wants to remove that one. 

Okay, last on the sunset review, and we'll have 

one other topic after we finish this so don't get 

too excited here. Sodium fluoaluminate. 

 DR. SEITZ: That's my substance.

 MR. ELA: Dan, thank you. I'm sorry.

 DR. SEITZ: Okay, so that also is a 

prohibited substance, non-synthetic substance 

under 205.602(g).

 DR. LEWIS: Speak into the mike, 

please. 

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 DR. SEITZ: Okay, sure. 

 DR. LEWIS: Thank you.

 DR. SEITZ: It's been prohibited since 

1996 due to environmental toxicity. It is used 

as an insecticide. 

 There were only a few comments and 

they all recommended continued listing as a 

prohibited substance. No one was in favor of 

removing it from the list. Any questions?

 MR. ELA: No questions. Okay. That 

is the Crops sunset review. Thank you to the 

committee for your hard work on these and lots 

more writeups to come for the fall.

 The last thing I just wanted to bring 

up because we did have public comment on it and 

just to recognize those commenters both publicly 

on the webinars and in the written comments are 

the fatty alcohols for use of desuckering in 

tobacco.

 Jesse, did you want to say anything 

about those comments?

 MR. BUIE: Thank you. Yes, we 

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received approximately 30 written comments on 

fatty alcohol.

 And the common theme that I noticed 

was that these were certified organic farmers who 

grow tobacco in rotation with other certified 

organic crops and vegetables.

 According to one of the public 

commenters controlling -- one of their concerns 

was controlling sucker growth improved tobacco 

quality and produces a significant increase in 

tobacco yield.

 And this statement that was made 

several times is documented in TR on line 121 and 

130.

 According to another public commenter 

this increase in crop yield has allowed certified 

organic farmers to expand their certified acreage 

which also has facilitated an increase in other 

certified organic crops in their crop rotation.

 And the crops that were mentioned by 

several of the farmers was organic sweet 

potatoes, soybeans and corn. 

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 Another common theme was also that 

controlling sucker growth allows for a reduction 

-- it produced a reduction in pests as well as 

more efficient use of fertilizers.

 And according to one of the commenters 

that this was a desirable outcome for their 

organic service plan, their OAS. 

 Also mentioned by a number of farmers 

was the fact that fatty alcohols reduce the 

exposure -- their risk for the green tobacco 

sickness which as you know is a nicotine -- is a 

form of nicotine poisoning which it puts them at 

greater risk of heat illness.

 The other common theme was a concern 

for the USDA's temporary allowance for fatty 

alcohols and would a decision come through before 

they run out of the supplies that they had 

already.

 And finally, another one was -- their 

concern was fatty alcohol being added to the 

National List.

 MR. ELA: Thank you, Jesse. I just 

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wanted to make sure we recognize those public 

comments came in.

 I will say the Crops Subcommittee 

attempted to get a discussion document out but we 

-- it was -- with the shutdown and such there 

were some -- we just ran out of time. There was 

some procedural things. So you did not see that.

 Jenny, do you have any comments on 

this petition? Emily, I'll come to you.

 DR. TUCKER: There has been some 

question as to sort of the scheduling and the 

steps for considering this particular item.

 It is listed for the fall meeting as 

a discussion document. If the board wanted to 

proceed to a proposal in the fall we would be 

supportive of that.

 MR. ELA: First of all Emily and then 

Harriet. Thank you, Jenny.

 MS. OAKLEY: I just wanted to say that 

it was very helpful to hear from the farmers on 

the webinar and in the written comments.

 But I also just want to note the 

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absence of other comments is probably just due to 

the fact that there was not a document for them 

to respond to.

 So I think while it's good to hear and 

note their concerns we should also anticipate 

that there will be many other comments as well 

and more nuanced and complicated ones as we come 

into the fall.

 MR. ELA: Good point. Harriet.

 CHAIR BEHAR: So we are a little 

constrained in what we do on the board. And 

really what we do is we look at a material. We 

don't necessarily look at what crop it might be 

facilitating and whether we like that crop or 

not.

 And tobacco is a legally grown crop in 

the United States. And fatty alcohols are being 

petitioned to facilitate the growing of that 

legally grown crop. Whether we like tobacco or 

not.

 MR. ELA: I think there were some 

concerns -- yes. There were concerns about the 

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type of crop, but we've pretty well resolved that 

that is not our bailiwick because otherwise we go 

down a deep hole of deciding what crops should be 

grown in the United States. And we don't want to 

do that. 

 Anything else on fatty alcohols? I 

just wanted to touch base. Asa?

 MR. BRADMAN: I just appreciate those 

comments. I have to consider them about crop 

versus material.

 I just want to say though out loud 

that tobacco is really a damaging crop to our 

country, to our youth, to our unborn children. 

It's really a serious addictive drug. 

 We're at a time when we have an 

explosion of addiction illnesses and disease 

emerging in the United States. We have a 

situation where it's really becoming -- it's a 

national emergency. And certainly tobacco is not 

associated with the opioids that are related to 

that, but it's still an addictive material.

 I think we should all acknowledge that 

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out loud. I have to as being involved in public 

health.

 MR. ELA: So yes. Thank you, Asa. 

Tom?

 MR. BRADMAN: I acknowledge that out 

loud. But that can also be said for the 

carbohydrates that we produce that then get 

fermented into alcoholic beverages. 

 And before I came here my son 

advocated for me to remove all items that support 

the growth of broccoli because he doesn't want to 

eat that. 

 There are ethical things. I say that 

to make light of this a little bit. But I hear 

what you're saying. But we also, we have a set 

of criteria and that criteria has to be what we 

use to evaluate substances.

 If we stray from that there's a 

million different reasons why we could move away 

from stuff. And while this one might be very 

valid for a lot of personal reasons and what's 

gone on with the history of tobacco, it still --

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it gets to a very slippery slope when we move 

away from criteria.

 MR. BRADMAN: Just to say I understand 

that and agree with that.

 MR. ELA: Sue.

 MS. BAIRD: I think Emily was before 

me. 

 MS. OAKLEY: I just want to say I 

understand all of these points, the health issue, 

the fact that we can't judge a crop.

 But I just want to add that there is 

an additional nuance to this which is tobacco 

dust is a prohibited natural on our list. So it 

does add another layer of complication as we 

discuss it.

 But I understand that we're evaluating 

the material itself, not the crop.

 MR. ELA: Okay, Sue.

 MS. BAIRD: I think that's very valid, 

Emily, but I've got to echo that we have to 

evaluate by the criteria.

 And there's no one that hates tobacco 

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smoking more than I do, or the disasters. I've 

got children who smoke and I can't figure that 

how that ever happened, but they do.

 And I guess maybe this doesn't have 

pertinence, but to me in my heart it does. These 

are fourth, fifth, sixth generation farmers that 

have always grown tobacco. We're talking about 

poor people in North Carolina, Virginia, that 

this is their livelihoods. 

 And they've made a point of saying 

that if we don't have the monies from this we 

can't continue doing all the other crops that we 

do organically. And I think that's got to be 

weighed as well.

 Perhaps it's not -- it's not by the 

criteria either so I'm contradicting myself.

 MR. ELA: Rick.

 MR. GREENWOOD: Obviously I'm against 

tobacco. I'm in a school of public health. 

 But the issue about selecting crops. 

I come from California and we've had real battles 

about what we can grow based on water. And 

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there's been tremendous, you know, you shouldn't 

grow almonds in California because they use a lot 

of water. 

 I think it's a dangerous precedent. 

And so if you're a farmer and you have land and 

you have water I think you should be able to grow 

what you can if it's a legal crop. And so I'd 

just like to mention that.

 MR. ELA: I'll just make one final 

comment. It's probably going to be grown. I 

would rather see that land be in organic 

production and taken care of with healthy soil 

and all those things than anything else and I 

think that's important to me too.

 I'd rather see those growers as part 

of our community than part of some other 

community.

 With that I'm going to close down this 

discussion. I think we might have a short -- or 

I'll turn it back to Harriet is what I'll do and 

then she can make the big decisions.

 CHAIR BEHAR: I just want everyone to 

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know that we actually are on time. 4:15 was 

deferred proposals. But I do think we all need a 

break. So let's try and be back by 4:25 and 

we'll continue.

 (Whereupon, the above-entitled matter 

went off the record at 4:14 p.m. and resumed at 

4:30 p.m.)

 CHAIR BEHAR: Okay, so we are on 

deferred proposals. And so I will talk about the 

organic seed guidance document will be returned 

to subcommittee. 

 There was significant concern by at 

least one member that the change was too 

significant for us to move forward. And so stay 

tuned. You're going to have another document to 

look at in the spring we think. We'll see about 

the -- I'm sorry, in the fall. We'll see if --

how much we're willing to be working on it. 

 But we hope we'll be able to pull 

something together for the fall for you to look 

at and maybe we'll be at a vote then.

 MR. ELA: Point of order. Do we need 

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a vote to return to the subcommittee?

 CHAIR BEHAR: Yes, probably. 

 MR. ELA: So I'll as Crops chair -- or 

do you want to handle the vote? I don't care.

 I would entertain a motion to send the 

seed proposal and just to be specific, 

Strengthening Organic Seed Guidance, April 2019 

back to committee. Is there a motion?

 MS. SWAFFAR: I'll make that motion.

 MR. ELA: Okay. Is there a second? 

Dave. So Ashley made the motion, Dave seconded 

it. Start with Asa. Is there any further 

discussion first? Emily, sorry.

 MS. OAKLEY: Just curious. Do you 

think that stakeholders would rather see us pass 

it as it is without any changes than send it 

back? Because I would entertain that. Not 

making any changes and just accepting it as it 

is.

 MR. ELA: Other discussion. 

 MS. DE LIMA: I wouldn't vote for 

that. But I was comfortable with the language 

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change and voting on it the way you guys rewrote 

it.

 MS. OAKLEY: I feel like the vast 

majority of public comments said don't delay. 

Like yes, we'd like some tweaks but we'd rather 

see you pass it and perhaps we could address some 

of these concerns in a cover letter.

 MS. DE LIMA: I don't know. My 

interpretation of the comments was they'd like to 

see it go forward if we addressed that section 

4.1.6. But I was okay with the way that Harriet 

and Scott and Steve had --

 MR. MORTENSEN: I was also okay with 

it.

 MR. ELA: Let's go one at a time. 

 MR. MORTENSEN: As it was revised.

 MR. ELA: Let me recognize people as 

we go around. So Tom.

 MR. CHAPMAN: I'm fine either way.

 MR. ELA: Anybody else? I mean, I 

guess -- I'm trying to think through my Robert's 

Rules here. 

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 MR. CHAPMAN: Is there a motion?

 MR. ELA: Time out. Time out. So I 

think we can vote -- if we don't send it back to 

committee then it will mean we vote on it and 

move it forward if I'm correct. Is that right?

 DR. SEITZ: Point of clarification. 

Do we vote on it with the changed language? In 

other words it might be that most of the board 

does not consider this to be a substantive change 

requiring it to be returned to the committee.

 (Simultaneous speaking)

 DR. SEITZ: Okay, gotcha.

 MR. ELA: So, the program thinks it's 

-- go ahead, Jenny.

 DR. TUCKER: Do you want me to read 

the definition of substantive change? Based on 

the definition that we've been training on for 

the last five years we believe this is a 

substantive change. And so I think the process 

is you are correct, you can either vote to send 

it back to committee, a subcommittee to make that 

change, or you can vote to advance it as it is. 

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But the change made wouldn't be voted on because 

it's a substantive change.

 MR. ELA: Fair enough. Okay, Harriet.

 CHAIR BEHAR: So if we vote it forward 

now in the cover letter I can make the note that 

this 4.1.6 is requesting a change to guidance 

that really informs the regulation and that 

that's not quite right, but we still are giving 

them what we feel that there is an inconsistency 

there.

 So they can do with it what they wish. 

Which is basically what the change did. It still 

kept the wording in there and said this is 

another issue.

 So we could give it to them as it sits 

with a cover letter saying we realize that you 

can't do anything with 4.1.6. But it still 

expresses our opinion that something needs to be 

done there.

 MR. ELA: Scott.

 MR. RICE: I would just reiterate I 

would be fine moving this forward versus back. I 

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think we've heard pretty clearly from the 

community that that would be the preference. 

 And then as Harriet noted she could 

address the issue in a cover.

 MR. ELA: Ashley.

 MS. SWAFFAR: Yes. So I'm the one 

that raised concerns over the additional 

language, but I would be fine voting on this as 

originally written.

 MR. ELA: I think that that becomes 

clear. Okay, we do have a motion on the floor. 

Is there any further discussion on that motion?

 MR. CHAPMAN: Does the motion maker 

want to remove the motion or are we going forward 

with the motion?

 DR. LEWIS: Point of order. Can you 

just reread the motion? So we know exactly for 

the record.

 MR. ELA: Sure. The motion is to send 

the Strengthening Organic Seed Guidance April 

2019 back to committee.

 MS. OAKLEY: I didn't hear what Tom 

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said, I'm sorry. Could you just repeat that?

 MR. CHAPMAN: Yes. I mean I guess my 

question is do we want to vote on this motion 

given the conversation that was just had. We 

could also have the motion withdrawn and proceed 

with the primary motion.

 MR. ELA: That is up to the motion 

maker.

 MR. CHAPMAN: I know. And the 

seconder.

 MS. OAKLEY: So who made the motion?

 MR. ELA: Ashley did.

 MS. SWAFFAR: I would like to move to 

withdraw my motion to send this back.

 MR. ELA: Is that okay with the 

second?

 MR. MORTENSEN: Yes, I support that.

 MR. ELA: So the record will show that 

the motion maker withdrew their motion and it was 

concurred with by the second.

 So, we now have on the floor the 

document, the Strengthening Organic Seed Guidance 

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as distributed and written in the packet. Is 

there any further discussion on that? Okay, if 

so we will move -- Emily.

 MS. OAKLEY: Just a final comment. 

Thank you for all the work that's been done on 

this over the many years and I'm excited to see 

us vote on it. Thank you.

 MR. ELA: Any other discussion? Okay. 

We said we are starting with Scott I believe. 

Tell me when you're ready. But you get to 

control it by being the first vote.

 MR. RICE: Multitasking. Yes.

 MR. ELA: Yes.

 MS. OAKLEY: Yes.

 MR. BUIE: Yes.

 MS. ROMERO-BRIONES: Yes.

 MS. DE LIMA: Yes.

 MR. GREENWOOD: Yes.

 MS. SWAFFAR: Yes.

 MR. CHAPMAN: Yes.

 MS. BAIRD: Yes.

 DR. SEITZ: Yes. 

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 MR. MORTENSEN: Yes.

 MR. BRADMAN: Yes.

 CHAIR BEHAR: Chair votes 

enthusiastically yes.

 MR. RICE: That is 14 yes, zero no. 

The motion passes.

 MR. ELA: With that the Crop Committee 

thankfully yields the floor to the chair.

 CHAIR BEHAR: Okay. So we have one 

more deferred proposal, collagen gel. Asa, do 

you want to take that?

 MR. BRADMAN: Yes. 

 CHAIR BEHAR: As the Handling 

Subcommittee chair and the lead on that material. 

I think it belongs in your lap.

 MR. BRADMAN: Yes. Okay. I thought 

I was going to turn it over to you.

 Given your involvement in the original 

proposal and all the discussions we had I think 

maybe you can summarize the discussions we had 

about how to address some of the confusion about 

how to move ahead on the language. 

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 CHAIR BEHAR: Okay. So, we did 

discuss about leaving the words as petitioned and 

then in a cover letter take directly from the 

petition that it's being only really petitioned 

for casings or the exact wording and also make 

note that that was the only use that we discussed 

in subcommittee based upon that petition.

 So we can vote on it as is with the 

words as petitioned but in the cover letter we'll 

make it clear that that was what we reviewed. 

And that's what the petition said.

 MR. ELA: Since I was the one that 

brought up the original issue, I'm sorry, but I 

think that's perfectly fine. 

 I just want to make sure that we 

inform the program as to the intent of the board 

and the committee. And I don't want to see it 

listed as just collagen. I would like to see it 

listed for what the petition actually stated. 

But I am comfortable with that.

 Can I ask a point of order?

 CHAIR BEHAR: Sure. 

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 MR. ELA: I think we had -- and this 

is where my Robert's Rules is a bit oxidized, but 

we had a motion to change the wording that was --

may have been seconded.

 MR. CHAPMAN: No, we never had the 

motion. We just started talking about it.

 (Simultaneous speaking)

 MS. SWAFFAR: I have it written down 

a motion by Harriet and a second by myself to 

amend it.

 MR. ELA: Correct. Yes. That's what 

I had too.

 CHAIR BEHAR: So I will withdraw that 

motion.

 MS. SWAFFAR: And as the seconder I 

would support that.

 MR. ELA: Okay. I just wanted to make 

sure we cleared that.

 CHAIR BEHAR: Thank you. Okay, so --

 MR. BRADMAN: So I think that clears 

the way then for me to go through the -- did we 

do the classification motion? We did. Okay, 

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thank you.

 So, then I want to put to vote the 

motion to add collagen gel as petitioned at 

205.606. The motion was by myself and seconded 

by Tom. So at this point any final discussion 

before we vote? Okay.

 MR. ELA: I vote yes.

 MS. OAKLEY: Abstain.

 MR. BUIE: Yes.

 MS. ROMERO-BRIONES: Abstain.

 MS. DE LIMA: Yes.

 MR. GREENWOOD: Yes.

 MS. SWAFFAR: Yes.

 MR. CHAPMAN: Yes.

 MS. BAIRD: Yes.

 DR. SEITZ: Abstain.

 MR. MORTENSEN: Yes.

 MR. BRADMAN: Yes.

 MR. RICE: Yes.

 CHAIR BEHAR: Chair votes yes.

 MR. RICE: I was tracking here.

 CHAIR BEHAR: Scott? 

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 MR. RICE: Yes, my vote was yes.

 CHAIR BEHAR: And chair votes yes.

 MR. RICE: Okay. Thanks for your 

patience. Eleven yes, three abstentions. The 

motion -- no nos. And the motion passes.

 CHAIR BEHAR: Okay. With that we move 

to the work agenda. And any new materials or 

whatever we might be looking at in the fall. So, 

this is the next part of the soap opera. We'll 

be moving to a fall meeting in Pittsburgh and 

this is what we'll be working on.

 DR. LEWIS: Just a moment to post it.

 CHAIR BEHAR: Okay. Am I presenting 

this part? I guess so.

 So, we are looking at possibly another 

discussion document for helping the NOP with more 

oversight improvements to deter fraud. Tom kind 

of gave us a little list there that I wrote down 

so I'll bring that to the Certification 

Subcommittee and we can discuss which items we 

are prepared and able to work on. Thank you, 

Tom. 

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 Paper pots. We will go to a vote. 

Then we -- I could just say vote, vote, vote, 

vote.

 The potassium hypochlorite material 

for crops. We will go to a vote. Fatty 

alcohols, material for crops will go to a vote. 

Liquid fish products, annotation. We will go to 

a vote in the fall.

 Biodegradable biobased mulch 

annotation change. I don't think we've done a 

vote -- we're not --

 MR. ELA: I'm going to say I think 

that's to be decided because it depends on 

several factors.

 CHAIR BEHAR: That's to be determined.

 MR. ELA: And can I just go back. 

Emily, do you think -- are liquid fish, are we?

 MS. OAKLEY: We don't even have the 

TR.

 MR. ELA: I think that's TBD, yes, 

because it depends on the timing of the TR. 

 CHAIR BEHAR: Okay. Then we're going 

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to sunset items for crops. Hydrogen peroxide, 

soaps, ammonium, oils, horticultural, oils that's 

narrow range. I guess it's in two places. 

Pheromones, again crops sunset vote. 

 Ferric phosphate, vote. Hydrogen 

peroxide, vote. Potassium bicarbonate, vote. 

Magnesium sulfate, vote. Hydrogen chloride, 

vote. Ash from manure burning, vote. Sodium 

fluoaluminate, vote. So everybody get their 

voting voices on.

 Celery powder is a sunset material for 

handling and that's vote. Fish oil, vote. 

Goodbye, Dave. Gelatin, vote. Orange pulp, 

dried, vote. Seaweed Pacific kombu and seaweed -

- I say Wakame both votes.

 Alginic acid, vote. Calcium chloride, 

vote. Citric acid, vote. We have a lot to do in 

Handling.

 Lactic acid, go to vote. Dairy 

cultures, enzymes, L-Malic acid, magnesium 

sulfate, microorganisms, perlite, potassium 

iodide all will be voted on as sunset. 

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 Okay, yeast, activated charcoal, 

ascorbic acid, calcium citrate, ferrous sulfate, 

hydrogen peroxide, nutrient vitamins and 

minerals, peracetic acid, potassium citrate, 

potassium phosphate, sodium acid pyrophosphate, 

sodium citrate, tocopherols, all in Handling, all 

going to a vote, all sunset materials.

 And on to Livestock for sunset 

materials. As parasiticide fenbendazole and 

moxidectin all up for a sunset vote. Atropine, 

hydrogen peroxide, magnesium sulfate, peracetic 

acid, xylazine, iodine in two uses, methionine, 

trace minerals, vitamins, all sunset materials 

that will be voted on in the fall in the 

Livestock Subcommittee.

 Use of excluded methods, vaccines in 

organic livestock production. I hope we go to a 

vote. We really haven't talked about it in 

subcommittee, if we felt that we had a good 

suggestion.

 Part of it has to do with a little 

research on the commercial availability and what 

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we can offer certifiers and producers to make 

that go easier because that seemed to be where 

most people felt it made sense.

 DR. LEWIS: Do you want to have that 

as vote or do you want to have it as a TBD?

 CHAIR BEHAR: Let's do a TBD.

 DR. LEWIS: Okay.

 CHAIR BEHAR: Just to make sure that 

I can get the information. I hope to.

 DR. LEWIS: This is the first time 

presented to the public and discussion group.

 CHAIR BEHAR: Right. So it's more 

just making sure that we could do the support for 

the community. 

 Marine materials will remain in 

discussion. We are hoping to perhaps do a panel. 

We're going to talk with the program about that.

 Genetic integrity transparency of seed 

grown on organic land. Let's say a TBD there. I 

am hoping to have a finished item, but let's do 

TBD depending on again the information the 

community gives us. 

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 Induced mutagenesis and embryo 

transfer in livestock. I think we'll be able to 

do the embryo transfer in livestock. I'm not 

sure about the induced mutagenesis part. So do a 

TBD on that. I think one part of it is yes and 

one part of it needs a little more research. 

 Sanitizers. That will be just a 

discussion. Research priorities, each of the 

subcommittees will be coming forward to the 

Materials Subcommittee and we'll be collating 

those for a vote by the full board.

 And then there will be, Rick, a policy 

and procedure manual update that we will probably 

vote on.

 And that's the end of our list. Good 

thing I didn't hold my breath during that list or 

I'd be blue. Okay.

 As far as other business and closing 

remarks I would just like to say that I really 

appreciate the work of my fellow board members 

and the very engaged discussion that we have.

 I think we all learn a lot. And I 

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think it's so valuable to have so many 

viewpoints. Sometimes we don't always agree but 

that's part of the situation we are -- neither 

does the public.

 But I think we do come to very good 

decisions in the end. So I greatly appreciate 

that. And I don't know if anyone else on the 

board has something to say to the public before I 

use the gavel that's been sitting here. 

 Oh, you want to say something too. 

Can I have the board first and then you can have 

the last word. Anyone from the board have 

something to say? Dan?

 DR. SEITZ: Just want to thank you, 

Harriet, for a nicely done meeting and also all 

of the subcommittee chairs because I know you put 

in a tremendous amount of work so thank you.

 CHAIR BEHAR: Asa.

 MR. BRADMAN: I'm just going to echo 

what Dan said.

 CHAIR BEHAR: Emily.

 MS. OAKLEY: Yes. And as the program 

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looks to be recruiting new members for the board 

we have one particular strong workhorse that 

you've seen at this meeting today and with a lot 

of historical knowledge. So if we can be sure to 

get someone on the board that has that historical 

knowledge and is a workhorse that would be great. 

Also livestock producers would be great.

 CHAIR BEHAR: Steve.

 MR. ELA: Yes, I would like to echo 

that. Looking forward I think livestock is -- I 

mean, we need everybody, but livestock probably 

would be a very nice addition. I know you only 

have the choices you have, but that would be the 

high priority in my book.

 CHAIR BEHAR: I know a few people have 

mentioned that I kind of followed in Zea's 

footsteps so I just want to mention that, that I 

had a good lead on how to be a workhorse.

 Okay. Thank you, Jenny.

 DR. TUCKER: Okay. And so from a 

program perspective we also want to thank you 

very, very much, Harriet, for running this 

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meeting as board chair.

 Thank you to the entire board and to 

NOP staff. The meeting process and outcome 

reflect an enormous investment of both time, 

energy and investment and care.

 As we all leave for home I also thank 

all of you in the public and all of the public 

commenters who came here this week. Your passion 

and dedication is truly inspiring. And so thank 

you very, very much for being here.

 We all look forward to seeing you in 

Pittsburgh this fall. Let's give everybody a 

hand.

 (Applause)

 CHAIR BEHAR: With that I want to 

announce that it's 4:51 so we're nine minutes 

early. And I am going to -- I know this thing's 

been sitting next to me. Adjourned.

 (Whereupon, the above-entitled matter 

went off the record at 4:51 p.m.) 

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A

A's 24:6 

A-Dae 1:20 71:17 86:8 

231:1 233:7 246:4 

A-Dae's 73:16 244:11 

a.m 1:9 5:2 106:22 

107:1 

A1 91:9 

AAFCO 18:14,16 

ability 81:9 

able 72:9 151:16 154:6 

160:3 162:1 204:15 

209:13 225:6 261:21 

301:7 320:1,18,18 

330:13 347:6 348:19 

360:21 365:2 

above-entitled 106:21 

205:14 348:5 368:19 

absence 17:15 99:5 

144:19 244:5 342:1 

absolute 31:8 328:8 

absolutely 20:21 83:3 

158:6 184:10 199:15 

229:9,13 307:6 311:9 

absorbed 157:20 

absorbs 242:4 

absorption 146:2 242:8 

243:18 

abstain 50:16 54:16 

55:10 359:8,10,16 

abstaining 54:21 

abstention 55:16 281:3 

281:5 

abstentions 360:4 

abuse 44:13 

abused 174:20 

academic 335:5 

Academy 160:17 

161:13 

accept 261:17 

acceptable 35:7 179:18 

accepted 19:16 321:13 

accepting 349:18 

access 71:6 

acclimation 106:3 

accomplishing 334:10 

account 133:11 

accumulate 84:20 

245:1 

accumulated 213:15 

accumulates 242:21 

accumulating 242:17 

accumulation 227:5,16 

245:12 246:1 

accurate 47:5 97:6 

229:22 

acetate 4:10 276:18,20 

278:10 283:11 284:10 

acetic 146:10 210:7,9 

achieve 109:14 191:3 

achieved 148:18 

achieving 217:8 

acid 3:4,12,15,16,19,20 

8:11 10:6,7,10,16,18 

10:22 11:8,9 27:19 

98:6,7 101:1 106:12 

106:13 108:16,17 

109:17,18 110:4,6,7 

110:17,21 118:19,20 

118:21,22 119:9,9 

120:14,16 142:19,21 

143:8,19 144:4,11,16 

146:10 147:14,17 

148:4,9,18 152:9 

155:4,5 194:20,22 

195:3 209:21 210:7,9 

210:16,17 211:13 

215:3,4,17 217:5 

267:7 333:18,22 

334:10 362:16,17,19 

362:20 363:2,4,5,12 

acidic 35:19 

acidification 98:6,8,10 

acidified 277:1 

acidity 212:1 

acids 3:10,10 19:7,8 

146:9 149:2 226:10 

acidulant 108:22 

110:11 

acknowledge 343:22 

344:5 

acknowledged 20:11 

acreage 339:17 

acrylamide 113:5 

acted 128:10 

action 6:19 8:21 9:1,9 

35:18,19,20 36:22 

39:8 105:12 129:9,17 

329:12 

actions 129:5 209:3 

activate 147:2 

activated 3:16 145:12 

145:14 146:8,12 

147:13 363:1 

activation 146:22,22 

147:6 

active 142:16 259:18 

325:3 

activities 90:18 93:18 

95:3 140:19 250:10 

activity 249:21 250:7 

325:19 326:6 

acts 251:20 

actual 36:20 83:11 91:6 

95:9 137:17 177:13 

187:14 191:18 192:14 

295:6 328:5 

acute 46:2 82:3 

adapting 251:17 

add 35:22 43:5 54:4 

55:19 56:7 59:3 62:17 

63:12 65:3,13 71:14 

76:11 82:20 87:6,15 

90:8,15 93:16 100:9 

118:4,5,10 119:12 

124:8 131:21 193:19 

195:17 201:2 208:2 

213:9 219:18 247:17 

248:1 258:4,19 264:7 

267:14 269:1 273:2 

274:4,16,18 275:20 

277:4 279:1 284:10 

305:6 326:4 327:6 

345:11,14 359:3 

added 20:22 43:8 67:8 

89:9 101:6 109:13 

115:4 137:20 139:4,4 

148:15 156:7 192:20 

193:20 199:11 216:5 

227:9 234:9 291:11 

295:2 296:11 297:16 

327:16 332:13 340:20 

addenda 266:2 

addiction 343:16 

addictive 343:14,21 

adding 16:11 54:18 

82:5 92:18 143:13 

148:6 220:3 229:11 

267:14 278:18 305:20 

addition 31:9 77:2 

95:16 112:19 162:2 

229:19 251:10 367:12 

additional 27:19 32:19 

33:12 52:12 83:15 

123:9 128:12 133:1 

148:6 149:11 209:3 

228:4 249:5 267:9 

270:1,15 276:21 

319:8 326:10 345:12 

353:7 

additionally 28:20 

250:12 251:9 279:15 

additive 82:13 135:6 

156:15 212:19 

additives 14:4 15:10 

115:2 118:3 192:19 

193:3,15 201:2 

address 29:8 87:11 

117:13 151:4 156:15 

172:16 186:4 215:18 

227:20 232:14 248:21 

255:3 269:18 279:9 

279:10,18 350:6 

353:4 356:21 

addressed 48:5 124:4 

131:17 172:18 173:12 

244:2 270:22 274:9 

350:10 

addresses 270:20 

addressing 150:16 

213:14 269:15 270:2 

280:1 293:6 

adds 80:17 81:21 

adequate 14:18 16:6 

189:1 282:8 

adequately 38:10 

adhesives 301:4 305:3 

306:16 307:14 308:1 

adipic 194:20,22 

Adjourn 4:22 

Adjourned 368:18 

adjust 112:16 

adjuvant 119:4 

administered 12:14 

administering 12:6 

Administration 248:17 

Administrator 2:3,7 

adopt 257:2 

adopted 228:13 

adoption 324:10 

ADP-ATP 176:19 

advance 163:12 351:22 

Advances 182:9 

advantages 68:5 

advent 140:8 

advisor 161:20 271:5 

Advisory 2:2 

advocated 344:10 

aerial 165:6 

affect 111:15 116:1 

144:7 163:22 165:21 

166:1,13 192:22 

affidavit 22:4 

affidavits 127:4 

affirmed 274:13 

afford 76:18 

afternoon 172:8,13 

204:11 247:2 

ag 147:6 202:14 

agar 144:14,14 

agenda 24:22 40:14 

118:10 121:8 125:21 

133:1,9 140:17 

141:14 223:8 228:11 

228:13 258:5 322:9 

360:7 

agenda/Materials 4:20 

agent 110:12,12 112:14 

112:22 119:4,5 

121:19 135:9 211:22 

215:5 231:12 233:10 

265:21 267:14 314:22 

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325:17 326:13,15 

agents 57:1,6 101:8 

132:6 265:19 266:8 

266:17 267:1,8,18 

269:5,21 325:19 

326:5 

aggregate 167:12 168:6 

168:21 

ago 145:3 153:22 154:8 

234:9 243:1 305:17 

324:1 334:18 

agrarian 184:14,14,18 

agree 34:5 44:6 59:17 

73:21 79:17 84:9 

100:5 101:17,19 

154:18 235:6 259:16 

345:4 366:2 

agreed 214:14 336:16 

agreement 116:14 

263:3 

agricultural 12:19 32:1 

57:2,8 61:1 67:9 

68:22 70:5 74:8 86:3 

91:12 183:18 212:13 

212:15 

agriculture 1:1 33:21 

153:21 162:14 163:17 

184:15,18 187:6 

250:2 258:17 262:13 

agronomic 170:15 

ahead 5:13 54:14 60:12 

85:14 172:5 194:13 

223:10 263:4 292:4 

293:13 294:13 314:11 

351:14 356:22 

aid 26:5 110:13 133:19 

143:4 145:16 147:8 

301:13,17 304:9 

aids 4:12 219:13 299:18 

air 200:14 

AITC 4:9 247:15,17 

248:1,4,11 249:4,15 

249:15,19,21 250:6,9 

250:13 251:2,4,7,14 

251:19,20 256:21 

257:17 263:7 264:8 

akin 27:13 151:22 227:1 

304:17 309:13 

alarm 295:19 

alcohol 339:2 340:20 

alcoholic 344:8 

alcohols 338:18 340:9 

340:16 342:17 343:6 

361:6 

algae 123:10 124:3 

242:8,11 

algicide 314:17 

alginic 3:15 142:19,21 

143:8,19 144:4,10,16 

362:16 

aligns 128:2 

allergen 220:16,17,22 

allergens 220:20 

allergies 220:10 

allow 46:4 72:11 130:12 

150:2 174:12 184:8 

189:19 193:8 289:4,7 

303:12 308:9 

allowance 289:19 

290:10 340:15 

allowed 7:19 11:22 

12:16 13:4,18 18:11 

19:1 20:1 56:8 57:2 

57:10 58:9 67:9 91:12 

91:21 99:19 109:5 

110:18 113:10 139:12 

143:3 146:14 196:12 

210:21 213:5 247:17 

307:2,11,15 308:12 

309:3 326:17 331:10 

331:18 336:16 339:16 

allowing 215:11 

allows 18:10 68:8 76:8 

135:6 188:9 191:2 

286:10 340:2 

allyl 4:9 247:11,14 

263:7 264:8 

almonds 347:2 

Alpha 265:14 266:14 

alternate 315:22 

alternative 57:20 67:15 

119:2 157:14 237:17 

249:16 318:10,22 

319:3 330:12 332:5 

334:16 

alternatives 144:14 

158:8 232:6,7 266:9 

268:17 292:10 315:9 

318:14 331:4 

altogether 294:9,22 

ambiguities 43:10 

ambiguity 44:2 

amend 59:5,7 62:15,19 

358:10 

amended 26:13 62:5 

amending 60:5,8 

amendment 62:1 63:6 

63:11,13 103:21 

America 80:21 

American 18:15 30:15 

amino 19:7 

ammonium 4:9,10,14 

265:7,7,16,16,22,22 

267:1,2,7 272:3 273:2 

274:19 275:20 316:9 

316:10 362:2 

amorphous 134:1 

amount 35:15 58:15 

80:3 109:12 228:19 

228:21 254:9 259:9 

261:10 307:13 327:20 

366:17 

ample 279:8 333:10 

analgesic 12:12 

analogs 113:2 

analyzing 171:2 

ancillaries 130:2,8 

ancillary 68:3 69:21 

114:22 115:3,16,22 

116:5 118:2,4 124:6 

127:12,16 128:9,13 

128:22 129:2 131:13 

132:7 134:20 137:10 

137:13 218:20 219:4 

219:12 327:11,12 

and/or 319:2 

anecdotal 317:15 

animal 7:3,11 9:15 17:5 

18:20 19:3 67:18 68:7 

73:20 76:2,2 84:15 

232:10,14,16 316:12 

316:12,16 

animals 5:7 6:9 7:19 

9:3,7,17 10:1 13:15 

42:15 67:21 70:4 

annotate 37:4 44:9,10 

54:20 63:17 320:14 

annotated 117:21 118:9 

136:10 212:13 319:10 

annotation 7:6 16:9,12 

28:22 29:3,9 32:11 

34:19,22 47:22 48:2,6 

59:17 89:2 97:5,7,8 

103:14 109:19 126:18 

141:6 143:14 147:4 

156:3 228:9 229:7 

252:7,10 257:7 

308:10 319:14 320:8 

322:6 331:22 361:7 

361:10 

annotations 35:7 44:16 

47:19,19 54:19 104:9 

228:5 

announce 368:16 

announced 195:4 

answer 36:17 38:21 

47:12 48:21 51:10,11 

52:8 94:22 96:20 

127:21 151:4 166:15 

167:3 172:2 173:1,14 

187:2 188:11 190:5 

191:15 195:14 203:3 

204:19 235:9 281:16 

304:21 318:19,20 

answered 36:19 

answers 17:17 150:17 

anthelmintic 6:20 

anti-hatching 250:7 

anticipate 342:5 

antimicrobial 26:4 

30:10,17 41:20 

antioxidant 147:21 

149:6 217:3,21 

antiseptic 315:12 

anybody 19:11 124:22 

126:1 139:17 274:17 

298:11 323:9 350:20 

anytime 55:22 238:12 

anyway 45:22 

apart 305:22 

apologize 23:14 260:1 

appear 97:4 219:14 

220:4 

appearing 146:17 

appears 58:5 

Applause 205:2 368:14 

apple 254:9 

apples 119:8 260:14 

applicable 10:9 12:2 

75:15 99:4 225:19 

303:3 

applicant 266:14 

application 31:10 91:15 

91:16,19 93:19 97:19 

97:22 112:18 131:7 

214:14 251:13 266:2 

266:3 268:1 278:7 

applications 29:20,22 

32:1,2,5 95:3 98:4 

101:9 112:13,15,17 

113:6 230:10 233:3 

269:11 303:16 307:17 

323:20 332:20 

applied 131:9 197:10 

applies 32:16 127:8 

apply 73:19 156:21 

265:20 

Applying 120:10 

appreciate 104:19 

124:20 285:14 309:18 

309:20 331:13 332:10 

343:8 365:20 366:6 

appreciated 209:10 

210:2 

approach 79:3 138:16 

183:6 259:14 

appropriate 54:18 

90:13 128:16 140:16 

337:2 

appropriately 183:3,4 

210:12 

appropriateness

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274:14 

approvals 31:19 

approve 130:3 257:21 

266:7 

approved 13:14 14:5 

18:13 30:3 31:21 32:4 

49:4 79:6 118:22 

193:3,7,17 252:18 

301:9 

approving 44:4 89:13 

approximately 339:1 

April 1:7 4:11 15:19 

122:5 150:16 285:9 

349:7 353:20 

aquiculture 229:20 

230:10 

area 28:5,10 29:20 

30:20 31:3 32:13 34:5 

36:11 41:7 42:11 83:5 

146:1 160:8 183:7 

200:16 225:12 227:4 

227:7 228:21 243:19 

259:5 286:3 

areas 27:2,4 30:19 

36:15 37:12 38:9,13 

131:1 225:19 237:19 

237:19 287:16,16 

306:20 

argument 27:13 32:21 

74:17 137:6 238:15 

262:5 

arguments 28:6 

arid 198:17 201:10 

aromatic 181:15 202:14 

202:19,22 203:6,9,11 

203:20 

aromatics 203:18 

array 306:20 

ARSENAULT 2:2 

arthropods 319:12 

Asa 1:14 24:19 92:20 

108:13 132:11 205:21 

253:6 257:11 264:9 

284:12 328:2 333:14 

336:2 343:7 344:3 

349:12 356:10 366:18 

Asa's 49:9 245:19 

259:17 329:2 

ascorbic 3:16 98:7 

147:14,17 148:4,9,18 

152:9 363:2 

ash 4:18 336:9 362:8 

Ashley 1:22 5:21 6:12 

22:7 50:6 63:20,22 

236:22 238:16 281:1 

293:14 297:14 349:11 

353:5 354:12 

asked 72:19,21 88:11 

89:7 91:7 101:10 

104:4 132:21 135:15 

135:19 142:7 143:11 

156:17 163:19 208:7 

220:9 267:9 270:15 

280:5,19 301:11 

306:2 318:12 327:2 

330:11 336:15 

asking 21:20 33:4 

58:22 90:12 136:4 

166:13 173:7 183:13 

288:19 293:7 303:11 

323:22 

aspect 38:6,19 165:22 

167:7 

aspects 252:21 

aspertate 127:14 

asserted 43:21 248:4 

assess 17:20 160:3 

assessed 168:8 

assessing 168:11 

assessment 75:4 

244:18 

assessments 166:5 

167:9 

assistance 123:15 

associate 2:3 160:12 

associated 12:22 68:16 

255:1 343:20 

association 30:15 33:7 

80:21 213:12,18 

227:12 280:14,15 

associations 112:20 

208:12 

assume 25:14 42:4 

52:1 94:8 163:6 

assuming 24:5 113:6 

139:1 162:4 

ASTM 178:8 

Atropine 363:10 

attach 180:16 

attached 202:22 

attack 25:19 

attempt 29:3,7 

attempted 341:4 

attempts 305:5 321:22 

attended 141:4 

attention 24:10 115:1 

151:19 296:17 

attracts 316:21 

audiences 194:4 

August 26:13 

Austin 318:17 

Australia 268:2 

Australian 269:3 

authorities 269:4,4 

authority 220:16 

availability 56:15 72:7 

75:3 79:20 80:17 

81:11 139:9 152:16 

194:17 255:6 363:22 

available 11:10 16:12 

57:12,15 76:2 119:2 

119:22 120:1,4 

136:21 137:4 139:13 

149:2 181:9,11 

215:10 218:17 251:11 

251:12 252:14 253:13 

254:4,5,6,10 255:22 

276:22 277:2,22 

278:22 280:2 310:21 

318:19 319:22 331:7 

332:3,8,12,19 

avocado 282:18 

avoid 102:2 

avoided 158:5 

Award 161:14 

aware 104:21 130:4 

131:14 154:16 235:16 

237:1 254:12 326:14 

awhile 285:13 

axis 180:4 

B

b 93:17 218:5 

B's 24:6 

B12 19:20 22:22 23:17 

B2 19:20 22:21 23:17 

B5 19:20 22:21 23:17 

B6 19:20 22:21 23:17 

back 24:16 25:7 26:19 

33:11,14 37:4 50:2 

51:9,15 75:8 82:15 

99:13 100:11,18 

105:14,18 106:20 

107:4 108:4,13,16 

124:17 129:16 132:11 

135:22 137:18 151:8 

154:9 159:14 173:2,3 

188:7 192:11 193:9 

194:6 205:1,10,10,21 

211:18 216:9 228:17 

238:17 247:6 255:5 

256:16 270:17 283:8 

291:9 296:19 298:3 

298:13 305:4 306:22 

311:13 313:3 323:16 

327:9 328:17 335:13 

347:20 348:3 349:8 

349:17 351:3,21 

352:22 353:21 354:14 

361:16 

backbone 180:16 191:2 

backed 150:1 

background 31:14 51:2 

159:6 161:2 282:8 

308:8 313:7 336:19 

bacteria 180:20 185:17 

bacterial 119:5 

bacteriophage 126:11 

bailiwick 343:2 

BAIRD 1:13 6:17 8:8,13 

8:16 18:6 21:10 22:5 

22:13 23:14 51:1 

53:19 55:11 61:11 

64:10 66:15 79:17 

86:16 151:22 153:19 

263:15 264:14 272:9 

273:6 274:22 276:13 

284:4 285:1 309:17 

345:6,19 355:21 

359:15 

baked 113:6 156:9 

215:11 233:10 

baking 147:20 

balance 39:11 152:15 

Ballroom 1:8 

bar 168:4 

barely 260:21 

barns 11:15 

barrier 310:12 

barriers 72:19 259:7 

316:16 

base 39:17 343:7 

based 11:10 58:4 74:3 

98:18 107:19 143:15 

171:7 179:19 183:19 

228:9 234:11 242:7,9 

266:8 268:12 291:5 

303:19 346:22 351:16 

357:7 

bases 146:9,11 

basic 177:13 

basically 67:11 68:9,13 

73:7 169:20 206:17 

218:8 224:10 242:3 

266:10,22 267:1 

274:13 276:22 286:1 

288:17 293:17,21 

294:5 318:4 321:19 

327:15 333:20 352:12 

basis 31:8,11,12 46:2 

76:3 175:12 177:10 

178:7 258:11 

batch 239:10 

battles 346:21 

BDM 165:14,14 

BDMs 165:16,17 

bean 18:19 

beanies 302:13,14 

bears 231:16 

becoming 142:5 310:20 

343:18 

bed 145:20 

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bee 66:1 

beer 133:21 219:20 

220:4 

beginning 18:7 78:20 

115:21 116:22 309:19 

309:22 

begins 34:1 86:8 

behalf 56:12 

behave 170:16 325:18 

behavior 17:6 203:2 

belabor 46:17 89:19 

believe 25:3 29:7 43:3 

50:10 64:1 134:19,21 

147:14 230:8,14 

240:19 244:18 264:10 

278:6 288:16 298:9 

317:14 320:8 333:14 

351:18 355:9 

believed 109:16 110:21 

belong 6:15 

belongs 356:15 

beneficial 249:11 

251:21 326:7 

benefit 158:16 184:19 

benefits 170:15 184:12 

237:18 

benign 11:4 249:18 

278:14 283:7 315:17 

benzoate 114:21 

127:13 130:11 

best 105:13 152:14 

157:11 199:18 304:8 

305:18 

bestows 161:11 

better 6:1 54:19 73:13 

76:9 90:4 100:8 

129:11 153:16 158:2 

158:3 224:4 281:21 

290:11 309:14 315:13 

beverages 344:8 

beware 182:6 

beyond 13:11 142:15 

210:19 211:5 221:2 

222:2 230:8 232:8 

243:14 334:7 

biased 40:21 

bicarbonate 4:16 330:7 

330:8 362:6 

big 82:10 118:8 120:15 

127:8 151:15,18 

221:7 236:11 262:18 

314:6 347:21 

bigger 300:22 

biggest 40:5 

bio 196:2,2,5 

bioaccumulation 42:12 

42:21 

bioavailability 14:12 

biobased 183:9,10,12 

183:19 184:4,7 188:8 

190:4 191:19,22 

195:20 304:2 308:17 

361:9 

biocatalyst 148:7 

biodegradability 173:6 

174:13 178:8 180:4 

180:18 181:19 191:3 

biodegradable 4:5 

154:14 159:10,13,17 

159:19,20 160:4 

161:15,18 162:13,20 

162:21 163:4,17,21 

164:8 165:4,15,21 

166:11,13,18 167:1 

167:14 168:1,18 

169:18 170:3,10,16 

171:19 173:5 174:19 

174:22 175:1 179:5 

179:12,15,16,18 

180:20 181:7 183:2 

183:11 185:13,20 

191:20 193:18,21 

194:7 195:19 197:13 

304:2 305:13 308:16 

361:9 

biodegradation 164:9 

165:12 180:18 188:9 

190:4,9 

biodegrade 180:10 

182:6,22 

biodegrading 191:21 

192:7 

biofumigants 251:14 

biological 166:7 177:6 

202:4 

biologically 176:7 

biology 201:10 

biomass 182:2,19 

183:15 194:10,21 

195:11 

biooxidation 148:6 

149:12 

bioplastics 161:21 

Biopreferred 183:17 

bios 159:3 

Bioscience 26:4 

Bismarck 77:22 

bit 5:12 8:1,20 9:8 36:5 

37:13 42:8 67:5 95:20 

104:1 108:10 117:1 

123:22 132:22 139:16 

148:20 153:15 159:5 

162:12 166:20 169:7 

185:3 186:1 205:12 

253:13 258:12 279:19 

289:2 291:3 295:10 

301:2 310:11 311:14 

322:8 324:22 344:14 

358:2 

bitter 45:10,10 

black 168:3 278:6 

blanche 308:9 

bleaching 314:22 

blight 331:6 

block 82:4 202:13 

blood 82:21 

blue 287:17 288:7,19 

365:17 

board 1:3,8 2:2 7:16 

27:15 28:22 33:9 

35:14 37:17 46:20 

85:4 98:12 105:8 

107:9,11,12,19 112:8 

117:6 118:18 121:5 

122:22 124:14,21 

125:19 126:22 128:4 

131:4 132:3,18 133:6 

142:8 160:4,10 

179:22 196:15 205:19 

211:15 212:8 214:7 

217:17 219:6 223:12 

225:9 228:19 245:14 

246:16 266:6,15 

271:3 291:16 299:10 

306:15 307:5 341:14 

342:11 351:8 357:16 

365:11,20 366:8,11 

366:12 367:1,5 368:1 

368:2 

bodies 242:22 251:7 

bogged 102:3 

bold 294:20 

bond 190:15 

bonds 10:21 

bone 82:20 

bones 231:20 

book 8:2 367:14 

books 7:8 

boost 256:21 

bottle 195:4 

bottom 296:14 

boys 79:8 

brains 204:15 

Brazil 187:5 

bread 215:11 

break 81:20 105:13 

106:17 107:6 173:20 

173:21 174:1,2 

176:14 190:16,22 

200:13 298:13 304:4 

313:10,12,14 348:3 

breakdown 11:3 172:20 

172:21 173:18 210:6 

304:16 

breaking 139:10 192:13 

334:1 

breaks 174:8 175:4 

192:9,14 201:4,7 

203:8 305:8 

breath 365:16 

brewing 112:17 219:20 

brief 13:7 69:11 

briefly 107:8 202:11 

221:16 249:1 

bring 75:7 130:14 

132:16 183:8 194:6 

204:7 206:8 224:7 

338:14 360:19 

bringing 24:10 79:12 

99:5 104:20 

brings 24:14 94:9 152:8 

broad 15:2 123:12 

124:5,10 134:17 

140:4 251:19,20,21 

257:2 262:11,22 

312:22 

broader 107:7 123:5 

124:21 132:18 135:20 

143:12 156:19 

broccoli 344:11 

broken 138:18 139:5 

175:7 

Brothers 254:11 

brought 26:21 28:2 

33:11 109:20 111:1,7 

155:14 212:4 217:14 

357:13 

brown 142:22 144:2 

buckets 226:21 

buffer 108:22 110:11 

155:12 211:22 217:4 

buffering 112:22 

212:18 

bugs 123:2,3 

BUIE 1:14 10:7 49:15 

50:17 53:13 55:5 61:5 

64:4 66:9 87:1 247:13 

263:22 264:21 272:16 

273:13 275:10 276:7 

283:20 284:17 313:18 

314:16 338:22 355:15 

359:9 

build 72:11 78:21 

building 202:12 

builds 80:9 

built 178:19 190:16 

bundled 209:15 

burden 142:10 222:12 

burning 4:18 133:7 

336:9 337:1,5,8 362:8 

business 4:21 24:15 

151:7 238:3,4,8 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
373 

365:18 

businesses 151:9,14 

butchering 220:18 

button 56:1 

buy 187:3 219:20 

256:10 290:18 

buying 78:11 236:16 

258:10 

byproduct 77:9 84:15 

237:10 241:1 

byproducts 76:10,14 

76:20 81:13 

C

C 19:20 22:21 23:17 

148:2,14,16,17 149:5 

152:2 

C14 181:18 

CAFO 70:4 78:14 81:19 

81:20 82:6,10 84:1 

CAFOs 72:13 83:4,5 

84:5 

cake 216:15,18 

calcium 3:11,17 4:10 

14:12 112:9,11 113:8 

114:6 155:1,3,4,5,6 

155:10 193:5,7 

276:18,20,20,22 

277:2,4,4,16,17,21 

278:1,10,14 279:8,9 

283:11 284:10 333:10 

362:16 363:2 

California 160:18 

240:16,17,21 250:17 

255:17 346:21 347:2 

call 44:22 84:13 107:2 

141:20 174:5 180:22 

186:2 187:7 234:15 

327:12 

called 19:22 192:8 

241:10 

calling 30:7 

calls 266:21 

camp 309:1 

Canadian 12:16 

cancer 45:14 

candies 135:14 

cane 187:4 195:6 

canning 112:15 

cans 328:14 

cap 302:7 

capability 10:16 

capable 177:17 

capacity 146:3 

caps 301:16 302:1 

Capsugel 57:16 

capsule 56:18 

capsules 56:9 58:12 

62:20 65:4 231:14 

carbohydrate 110:8 

carbohydrates 344:7 

carbon 145:20 173:17 

175:14,20 177:4,8,16 

177:20,22 178:6 

181:15,16,16,17,21 

181:21 182:11,13 

183:14 184:12 190:14 

190:14,14,18 196:19 

196:21 203:6,12,20 

250:13 337:5 

carbonate 155:6 

carbons 182:17 203:20 

carcass 110:12 

carcasses 26:5 

cardboard 307:12,14 

care 121:18 131:11 

217:13 246:1 347:12 

349:4 368:5 

careful 175:1 326:8 

carefully 47:22 125:21 

202:7 206:21 210:12 

211:9 223:4 266:20 

321:3 324:16 

Carolina 346:8 

carrageenan 144:14 

carte 308:8 

CAS 120:17 

case 13:2 43:18 101:5 

138:3 140:12 153:2 

173:9 174:16 221:3 

230:20 234:18 259:12 

cases 41:14 75:13 

218:17 332:17 

casing 3:8 88:1,10 94:1 

94:3 

casings 67:13 71:2 

84:12 93:20 103:5,9 

231:8 357:5 

catalogs 254:11 

catch 22:14 206:10 

286:8 298:14 

categorical 15:2 208:3 

208:17 214:20 

categories 210:3 219:1 

331:10 

category 71:10 138:6 

138:17,18 140:4 

237:15 

cattle 7:13 14:10 

231:20 

caucus 105:12 

cause 9:15,16 11:2 13:1 

45:14 203:14 319:7 

322:16 

caused 278:11 295:18 

causes 134:4 162:18 

caution 41:21 179:8,15 

cautionary 313:5 

cautious 43:9 44:3 48:7 

133:8 171:11 

CCOF 253:14 317:1 

324:19 

CDC 30:9 

CDS 250:14,16 251:1,3 

celery 4:2 70:14 75:14 

77:7,13,18 110:14 

221:13 222:19 223:16 

224:8,18 225:5,19 

226:4 237:8 362:11 

cell 10:17,18,20 42:15 

138:12 176:1,3 182:2 

182:19 192:16 201:5 

cellulose 67:22 69:20 

72:9 305:21 

cellulose-based 305:20 

cellulosic 300:17 

Centers 30:6 

central 141:5 

cents 271:22 

cereal 156:8 

cereals 156:13 

certain 81:19 83:3 

98:13 137:1 198:21 

252:15 255:6,7 

certainly 17:11 24:8 

36:22 46:2 78:21 

119:15 122:18 123:16 

125:4 137:4 139:8 

142:3 183:6 185:6 

266:9 277:15 283:1 

307:9 329:13 343:19 

certification 193:2 

248:8 249:8 260:20 

292:15 360:19 

certifications 40:8 

certified 56:15,17,20 

72:10,12 74:4,11 81:4 

119:18 179:20 183:4 

229:13 339:4,5,16,17 

339:19 

certifier 126:22 135:22 

213:7 214:13 317:1 

certifier's 141:22 

certifiers 16:1 20:3 21:4 

21:14,19 22:3,10 

47:20,22 58:17,19 

75:1 111:20 112:20 

118:14 119:17,19 

120:7,13 122:8 127:1 

130:3,11 134:14 

143:9 146:16 148:21 

207:6 208:14 215:7 

217:10 234:3 289:4 

364:1 

certifiers' 125:17 

certify 16:3 

certifying 57:1,5 132:6 

cetera 82:21 260:22 

261:1 268:6 301:8 

306:22,22 307:1 

CFR 26:11 91:11 

chain 75:14 84:17 85:1 

153:4 173:17 182:16 

182:18 190:14,18 

191:2 202:19 237:9 

299:15 300:1,3,9,13 

300:15 305:7,8 

chains 175:21 

chairperson 5:16 24:20 

chairs 366:16 

challenge 191:4,15 

challenged 266:15 

challenges 75:14 237:9 

challenging 49:7 140:8 

chance 44:13 96:17 

108:7 144:8 256:11 

330:4 

change 7:2,6,6,18 8:4 

9:18 63:16,18 85:3,7 

87:7,8,10 94:18 

107:14,16,21 108:3 

108:10 168:5,17 

169:22 170:4,5,7,8 

240:3 256:4 287:5,20 

288:8 291:12,17 

293:4,13,16 294:7,10 

294:15,16,21 295:1 

296:7,15 297:2,5 

348:13 350:1 351:9 

351:16,19,22 352:1,2 

352:6,12 358:3 

361:10 

changed 7:18 9:22 29:6 

35:5 128:6 154:1 

256:5 291:11 295:3 

296:2 311:15 351:7 

changes 23:22 107:8 

108:5,6 117:16 118:1 

131:5 140:9 171:6 

202:5 250:19 292:20 

295:20 296:11 297:10 

297:12 349:16,18 

changing 137:9 171:12 

293:19 294:4 295:12 

295:17 

characterizing 225:11 

charcoal 3:16 145:13 

145:14 147:13 363:1 

charge 66:1 75:5 

chart 124:8 

chase 261:11 

cheapen 303:21 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
374 

check 133:15 154:12 

193:9 

checking 125:18 

cheese 76:14 114:8,9 

233:11 

cheese-making 113:1 

138:13 

chelated 278:1 

chelates 265:15 266:14 

269:5 271:17 

chelating 265:18,21 

266:8,16 267:1,8,14 

267:18 269:5,21 

325:17,19 326:5,13 

326:15 

Chem 180:15 

chemical 15:4 23:22 

24:1,7 34:3,11,13 

117:16 143:1 148:8 

158:7 166:7 188:22 

200:10 215:10,20 

chemically 146:8 

chemicals 117:17 

147:2,4 

chemistry 43:19 161:14 

266:16 268:6 271:5 

274:12,14 304:15 

305:17 

cherries 119:8 

chew 198:2 199:2 

chicken 72:6 329:4 

chickens 205:5 

children 156:11 343:13 

346:2 

China 134:3 144:6 

154:2 189:16 

Chinese 160:17 

chloride 3:11 4:17 

112:9,11 113:3,8 

114:6 333:14,17 

362:7,16 

chlorides 113:4 

chlorine 45:7,11,12 

109:13,15 113:4 

choice 83:19 150:3 

271:18 

choices 367:13 

chop 81:7 

chose 164:12 

cite 230:1 

cited 30:5,6 33:19 

34:10 

citrate 3:7,17,19,21 4:9 

25:3 26:3 31:17 50:2 

53:2 54:4 155:1,3 

211:17,17,19,20 

216:20,21 217:1 

265:7,16,22 267:2 

272:4 273:2 363:2,4,6 

Citri-Fi 234:15 237:2 

citric 3:10 98:5 100:22 

106:11,13 108:16,17 

109:16,18 110:16 

155:4,5 217:5 267:6 

362:17 

citrus 26:6 233:14,15 

236:2 241:10,11 

claim 156:9 277:19,20 

283:5 

claimed 179:5 

claims 268:7 

clarification 63:19 

214:5 231:12 270:16 

351:6 

clarified 19:4 

clarify 65:17 72:15 

90:17 126:15 127:1 

132:22 

clarifying 127:4 

Clarissa 2:5 90:14 

93:15 94:21 99:15 

131:20 269:13 270:13 

271:2 274:10 

clarity 52:22 62:15 90:9 

92:22 94:11,12 105:2 

105:7 111:21 116:7 

123:13 214:9 

class 43:15 117:11 

123:5,12 138:5 

139:12 219:13 305:18 

classes 140:5 

classic 74:6 

classification 52:16,19 

53:1 57:4 59:6,6 60:3 

60:12,16,21 73:22 

85:14,19,21 86:10 

117:13,14 263:6 

358:22 

classifications 139:6 

classified 51:19 57:1,7 

60:6 109:17 110:22 

117:21 

classify 51:8,16 52:4,16 

53:1 60:22 68:18 86:3 

169:10 263:7 272:3 

274:19 283:11 

classifying 52:1 120:11 

clay 282:21 283:2 

clean 34:2,2 175:15 

315:20 

cleaning 33:18 34:5 

314:19 

clear 19:9 22:18 28:15 

46:14 59:17 74:2 

89:21 90:4 93:5,13 

95:4 102:1 103:12,18 

123:6,17 196:11 

235:14 245:4,11 

282:11 297:11 353:11 

357:10 

cleared 358:18 

clearer 130:2 

clearly 37:8 97:16 

99:16 175:15 226:9 

258:21 259:12 353:1 

clears 358:20 

clients 236:16 

climate 164:10,11 

189:5 

climates 164:16 189:18 

198:17 

climatic 188:12 189:4 

close 15:20 65:6 255:11 

292:12 329:18 347:18 

closely 326:18 

closing 4:21 365:18 

clouds 169:17 

co- 202:20 

co-worked 36:3 

CO2 176:7 177:4,8,18 

177:21 178:3 181:22 

181:22 182:18 203:13 

203:22 

coagulating 110:12 

coagulators 121:20 

Coalition 267:13 334:7 

336:20 

coast 33:3 

coastal 144:7 

coating 94:1 

coatings 94:4 

cobs 146:6 

Coca-Cola 195:3 

Codex 12:17 147:5 

codling 323:1 

coextrusion 94:3 

cognizant 21:22 329:13 

329:15 

cold 142:22 164:11 

coli 111:6 

collaboration 285:19 

collage 84:18 

collagen 3:8 64:19 67:4 

67:7,12,17 68:12 70:3 

71:3,21 72:18,20 73:7 

73:17 74:15,22 75:2 

75:19 76:1 77:9 86:3 

87:6,15 89:9,12 91:10 

92:9 93:19,22 97:1,3 

100:9 151:9 222:8 

231:5,6,7 232:12 

247:2 298:3 356:10 

357:18 359:3 

collating 365:10 

colleague 224:21 

collected 243:16 

colors 109:1 167:22 

169:12,13 192:20 

column 145:20 

combination 325:16 

combined 18:18 115:12 

121:20 217:4 231:7 

267:7 

combining 116:8 

come 37:3,4,16 49:10 

67:18 70:14 71:2 

75:10 78:14,14 82:9 

83:2 84:21 95:11 

98:19 101:11 103:14 

105:14,18 125:11 

131:15 162:6 183:15 

183:15 194:21 198:1 

205:20 229:8 236:17 

237:6 257:7,13 

258:21 270:10 296:19 

298:3,12 301:19 

313:1 338:13 340:16 

341:9 342:7 346:21 

366:5 

comes 38:22 54:8 72:7 

72:14 82:6 151:8 

179:17 180:13 181:22 

231:19 283:8 313:8 

317:11 322:17 326:22 

327:9 

comfort 271:7 

comfortable 41:16 

101:19 269:14 349:22 

357:20 

comforting 325:8 

coming 15:22 51:1 

115:10 159:14 177:5 

186:20 240:15 287:14 

300:17 322:11 365:9 

commented 8:3 107:15 

146:19 149:3 214:13 

218:15 246:11 331:20 

commenter 113:9,15 

143:19 220:20 232:5 

233:20 243:14 246:10 

339:15 

commenters 13:10 

32:20 43:12 109:16 

110:20 134:16 222:3 

231:22 233:13,16,17 

234:17 246:10 252:5 

338:16 339:8 340:5 

368:8 

commenting 215:15 

239:5 

commercial 56:16 75:3 

79:20 80:6,16 81:10 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
375 

117:14 152:15 219:21 

231:21 253:19 335:2 

363:22 

commercialized 334:16 

commercially 57:14 

120:1,3 248:7 335:4 

committee 24:14,15 

37:2 65:18 68:18 

70:20 133:4,12 

205:21 248:1 299:4 

328:21 338:12 349:8 

351:4,10,21 353:21 

356:7 357:17 

committee's 257:10 

committees 161:20 

commodities 32:1 

common 13:14 15:6 

67:21 148:1 206:12 

248:15 339:3 340:1 

340:14 

commonly 19:19 22:20 

23:20 152:3 156:7 

206:14 241:10 248:11 

312:21,21 

communicating 176:21 

Communication 180:15 

communications

180:15 

communities 169:2 

170:6 203:2 

community 12:18 15:13 

42:21 125:10 134:16 

137:22 144:9 147:10 

151:7,20 167:13 

169:8,10,22 170:4 

223:3 262:9 285:20 

308:21 334:7 347:16 

347:17 353:2 364:14 

364:22 

companies 33:4 122:11 

146:18 215:9 221:1,6 

company 265:14 267:2 

268:2 335:3 

comparative 253:9 

compare 17:22 165:4 

166:8 315:15 

compared 168:1,18,19 

171:4 249:12 

comparison 77:7 261:6 

compatibility 28:3 

34:20 319:5 

compatible 222:5 

251:22 278:11 

compelling 44:19 85:2 

240:2,6 268:13 312:4 

325:22 

compete 226:18 

competition 75:7 240:4 

complaints 45:11 

complement 327:18 

complete 178:14 191:3 

199:20 

completely 37:6 166:18 

166:19 173:11 174:14 

175:6 181:14 182:6 

184:2 193:18 198:9 

200:21 201:6 203:13 

291:13 

completeness 201:22 

completes 24:12 

complex 176:17 203:8 

260:12,19 

complexed 265:21 

complexity 84:6 

compliance 120:15 

compliant 56:21 57:11 

complicated 84:3 169:7 

342:7 

complication 345:14 

comply 320:9 

complying 109:7 

component 246:6 

323:2 

components 194:19 

composed 324:17 

compound 17:4 259:18 

274:8 324:8 325:20 

326:11 333:17 

compounds 15:3 45:7 

45:11,12 203:1 

265:15,17 267:5 

274:15 325:18 

comprehensive 166:5 

167:9 249:10 

comprises 163:11,13 

compromise 128:19 

concentration 250:9 

315:6 

concentrations 206:20 

206:21 

concept 45:20 

concern 27:2 28:21 

30:8,17 31:1 32:3,13 

35:3 40:5 43:1 44:12 

62:13 70:8 82:4,12 

89:2 110:20 117:2 

134:9 200:17 213:14 

216:3 227:4,7 258:2 

322:17,18 340:14,20 

348:12 

concerned 42:18 69:16 

200:9 202:9 243:8 

307:6 309:22 325:10 

concerning 150:8 

concerns 12:21 27:7 

29:8,10 30:16 31:16 

34:16,21 35:1 41:5 

42:11 45:1,19 46:21 

47:3,7 69:17,19 70:13 

73:18 81:18 111:2 

155:16 226:22 227:1 

227:20 250:15 269:9 

269:19 334:9 339:8 

342:5,22,22 350:7 

353:7 

concluded 266:22 

conclusion 262:1 

conclusions 268:5 

concurred 354:20 

concurrently 159:15 

condition 176:3 

conditions 17:16 

188:12 191:21 199:18 

confectionary 217:7 

conferred 25:14 

confidence 271:12 

conflict 94:16 

conflicting 38:7,18,21 

39:2,13,21,22 48:15 

83:16 

confusing 44:16 74:12 

295:18 

confusion 99:18 174:7 

174:18 179:10 292:6 

356:21 

conjunction 110:13 

113:3 271:11 

connecting 304:5,6 

conscience 102:5 

consensus 334:13 

consent 106:3,4 298:10 

298:12 

conservation 227:20 

conservatism 39:4 43:4 

consider 25:2 30:21 

35:6 58:11 69:17 90:6 

119:19 121:13 143:13 

184:7 219:5 232:11 

235:15 270:21 343:9 

351:9 

considerable 36:13 

159:9 

consideration 21:7 

33:10 209:1 228:3 

242:5 

considerations 193:10 

considered 11:1 26:17 

28:8 56:19 68:2 

107:16 108:3 113:16 

123:10 251:3 290:14 

337:3 

considering 27:21 

210:18 341:12 

consistency 130:14 

consistent 17:15 217:8 

292:22 337:9 

consistently 134:8 

constrained 342:11 

constrains 108:1 

constraint 184:8 

consumed 304:5 

consumer 44:19 78:8 

78:11,16 83:8 220:17 

226:16 

consumers 58:2 76:13 

76:17 

consumption 135:9 

230:19 289:5 

contact 26:8 32:4 36:19 

45:20 109:5 110:18 

240:12 301:20 305:9 

316:13 322:3,5 

contain 114:21 

container 289:13 

containing 147:19 

249:15 

contaminants 242:18 

contamination 11:3 

243:8 244:1 315:3 

content 14:14 94:12 

112:16 134:4 191:22 

192:1 244:19 337:7 

contents 3:1 208:3 

219:10 

context 31:15 113:16 

143:12 312:10 

contexts 30:4 99:8 

continually 15:12 

continue 5:11 16:17 

56:14 72:11 131:18 

136:20 156:18 171:20 

194:1 299:20 326:21 

335:20 346:12 348:4 

continued 15:14 16:5 

137:7 316:4 338:7 

continues 132:1 

continuing 75:21 

continuous 37:5 

311:22 

contradicting 346:16 

contrary 214:20 

contrast 222:7 

control 30:6 108:21 

110:12 119:4 211:22 

212:18 248:13 251:18 

314:20 330:9 331:5 

355:11 

controlling 18:16 109:9 

339:8,9 340:2 

controversial 235:21 

controversy 216:13 

convenience 52:13 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
376 

conventional 46:8 

77:14 84:15 202:14 

222:19 224:4,7,17 

225:2,5 226:18 

232:12,15 233:21 

238:3 253:20 258:16 

287:8 321:18 

conventionally 223:1,2 

253:14 

conversation 92:3 

98:22 99:4 140:13 

354:4 

conversations 33:9 

141:7 

converting 258:13 

convinced 36:17 257:9 

cooked 71:22 

cool 164:13 305:3 

311:17 

cooler 188:1 

coordinator 153:20 

core 68:21 

corn 146:6 186:10,13 

186:20,20,22 195:20 

196:1 339:22 

corner 150:1 

correct 65:19 104:3 

133:2 183:6 193:1 

303:3 351:5,20 

358:11 

Correction 245:7 

correctly 55:20 132:14 

244:17 

cosmetics 231:17 

cost 194:17 261:19,20 

323:6 

costs 76:12 

cotton 322:3 323:18 

333:19,21 334:3 

335:7,11,15,18,21 

Council 19:2 115:2 

118:3 

counting 207:3 

countries 144:6 

country 254:11 256:1,9 

343:13 

counts 28:14 

couple 16:7 33:3 43:12 

58:21 75:6 78:9 

104:18 120:19 196:7 

207:4 277:14 312:3 

316:18 330:11 334:2 

course 164:8 171:10,11 

183:17 200:17 232:11 

257:7 267:20 

court 110:5 112:10 

121:15 123:1 133:17 

135:3 136:14 142:20 

147:15 155:22 212:11 

244:11 

Courtyard 1:8 

cover 31:20 123:18 

124:2 223:21 308:2 

324:11 350:7 352:5 

352:16 353:4 357:3,9 

coverage 270:1 

covered 14:22 36:20 

41:10 215:15 269:15 

covering 283:6 306:20 

coverings 283:4 

covers 323:8 

cow 258:13 

cows 261:5 

coyote 316:19 

crack 261:16 

cream 231:16,17 

create 186:13 187:17 

234:1 262:4 307:9 

creates 184:14 262:5 

332:15 

creating 81:9 184:13 

191:20 313:4 

creation 74:18 

criteria 30:1 31:1 

117:13 243:10 244:17 

244:20 245:3 316:3 

344:16,16 345:2,21 

346:16 

critical 9:14 84:20 

123:7 137:21 201:20 

203:10 223:7 318:6 

critically 326:19 

crop 4:12 83:10 160:15 

165:22 170:15 222:9 

251:8,10 276:22 

286:11,17,22 287:7 

289:5,14,19 290:9 

292:8 293:1,11,21 

294:1,3 301:13,16 

304:9 316:14 319:2,8 

331:4 339:16,19 

342:13,14,16,19 

343:1,9,12 345:10,17 

347:7 356:7 

cropping 324:12 

crops 4:8 70:16 159:3 

205:13 207:14 223:21 

229:3 247:8 248:1,20 

277:9 290:5 309:20 

314:4 318:5 327:12 

327:21 330:10,21 

338:11 339:6,19,20 

341:3 343:3 346:12 

346:20 349:3 361:5,6 

362:1,4 

cross-out 288:7 

crying 282:22 

crystal 245:4 

crystallization 155:7 

cucurbit 330:21 

cuisine 246:7 

cultivation 143:22 

cultural 123:20 266:9 

268:17,19 279:13,16 

culture 115:11 125:11 

137:12 138:12 

cultures 3:11 114:12,16 

114:20 115:19 116:2 

116:11 118:5,13 

123:5 124:7 125:5 

140:1 153:6 362:20 

cumulative 172:20 

curating 147:19 

curious 16:22 17:4,6,22 

30:21 89:1 162:8 

213:4 220:11 228:22 

229:17 254:22 323:21 

349:14 

current 16:9 142:14 

162:2 165:19 170:13 

215:18 218:18 290:15 

294:11,11 300:5 

307:2 313:4 

currently 19:1 31:21 

32:9 35:20 45:6 46:4 

123:8 214:3 233:9 

289:4 296:8 

curve 180:6,6 

customers 236:20 

cut 112:14 286:18 

288:22 289:13 295:14 

cuts 261:11 

cutting 289:16 

cuttings 289:7 

cycle 5:19 50:9 176:19 

D

D 7:12 120:16 

D- 118:21 

D-Malic 118:22 

dairies 226:16 

dairy 3:11 7:15 9:22 

113:2 114:12,16,19 

115:11,19 116:2,11 

118:5,13 123:5 124:7 

226:14 362:19 

damage 331:4 

damaging 343:12 

Dan 1:21 11:20 13:22 

13:22 44:7 77:5,18 

96:5 97:2 185:7 194:1 

275:22,22 337:17 

366:13,20 

Dan's 83:8 97:6 

dangerous 347:4 

data 17:1,3,21 168:8 

169:3,5 171:2 179:6 

181:4 182:5,21,22 

198:14 223:15 244:7 

245:14,15 259:21 

267:21,22 268:3,13 

325:22 326:9 329:17 

329:20 

database 30:11,13 

databases 41:20 

dated 247:20 248:20 

Dave 1:18 16:20 22:16 

42:16 50:10 138:2 

141:13 142:1 202:9 

219:6 229:15 265:8 

271:3 272:4 273:3,22 

274:20 275:21 283:14 

298:9 311:20 324:6 

327:6,22 349:11,11 

362:13 

Dave's 126:21 149:17 

262:9 265:6 270:7 

DAVID 2:3 

day 5:4,13 48:1 172:13 

222:16 239:8 267:20 

292:11 

days 7:13,13,20 9:20 

12:5,7 180:7 271:8 

312:3 

DDT 242:22 

de 1:16 41:9 50:19 

53:15 55:7 56:4 60:15 

60:18 61:7 64:6 66:11 

72:3 86:12 106:13 

108:17 110:6 116:13 

125:14 142:21 145:1 

155:3 211:20 216:20 

217:1 235:6 263:11 

265:1 272:18 273:15 

275:12 276:9 283:22 

284:19 322:4 349:21 

350:8 355:17 359:11 

de-listed 143:20 319:13 

de-listing 233:21 

deal 38:12 40:1 48:1 

84:13 102:14,17 

243:8 270:19 287:4 

dealing 127:1 227:15 

deals 227:17 249:8 

dealt 249:2 

death 9:16,16 

decades 243:1 

December 247:20 

336:21 

decent 228:18 

decide 133:5 299:7 

decided 68:20 101:2 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
377 

172:14 218:8 247:1 

299:4,9 361:13 

deciding 343:3 

decision 20:14 57:6 

74:5 76:16 84:6 

105:16 257:10 270:10 

340:16 

decisions 347:21 366:6 

deck 155:2 207:18 

211:18 216:22 226:7 

dedication 368:9 

deem 122:16 

deep 6:4 79:11 141:6,9 

176:10 209:4 274:12 

303:8 343:3 

deeper 175:12 303:13 

309:21 

deeply 48:18 299:16 

defer 105:15 106:6 

269:4 

deferred 4:19 105:20 

298:7 348:2,9 356:10 

deferring 106:6 

deficiencies 157:16 

277:18 

deficiency 156:16 

158:13 279:9 331:19 

333:9 

define 109:18 117:22 

124:18 175:2 

defined 174:13,16 

175:3 179:2 

defining 125:20 

definitely 42:22 46:5 

189:3 209:18,19 

218:14 221:20 321:16 

331:20 

definition 123:6,7 

351:16,17 

definitions 142:12 

degradable 162:17 

196:20 

degradant 251:1 

degradation 164:8,16 

166:21 174:4 188:5 

188:13,17,19,20 

189:6 190:1 192:2 

198:13 250:13 

degrade 166:18,19 

167:2 182:21 196:12 

197:18 198:19 199:8 

199:8 301:17 315:7 

degraded 198:9 200:21 

degrades 167:1 210:5 

317:7 

degrading 165:11 

200:1 

degree 166:20 

degrees 199:19 

dehydration 122:15 

delay 350:4 

deliberation 270:19 

delint 333:18 

deliver 265:20 

delivering 266:11 

delivers 17:20 

delved 48:18 309:21 

demand 59:15 208:13 

226:16 

demonstrate 193:19 

denaturing 10:19 

density 196:20 

Department 1:1 153:21 

160:15 

dependent 16:8 

depending 74:7 255:22 

364:21 

depends 94:12 95:20 

164:8,10,11 201:1 

361:13,21 

depolymerization

174:4 

Deputy 2:3,6 

derived 67:17 68:22 

70:3 142:22 231:6 

232:10 

described 101:21 

describing 191:18 

description 90:18 

98:21 295:5 

Designated 2:7 

designed 183:3 184:1 

desirable 340:6 

desire 133:7 292:21 

desired 109:14 330:15 

destroys 337:6 

destructive 158:7 

desuckering 338:18 

detail 14:21 27:16 34:9 

34:11 209:5 230:6 

231:9 243:15 245:17 

281:4 

detailed 209:1,8 237:7 

270:1 

details 124:11 181:6 

deter 360:17 

detergent 27:11 

determinations 40:9 

determine 23:9 123:9 

126:7 

determined 19:13 

266:6 278:15 361:15 

develop 47:6 

developed 59:20 

190:15 

developer's 149:2 

developing 57:18 

161:15 225:22 

development 56:17 

70:18 158:15 

developmental 250:18 

DEVON 2:5 

Devro 67:8 91:9 97:18 

Devro's 93:22 

DHA 226:11 

dictate 292:18 

die 175:19 

diet 14:7 157:15 158:10 

dietary 56:10,16,18 

57:3 58:12 62:20 65:4 

109:2 135:8,13 

147:17 148:14 217:12 

difference 22:12,14 

33:17 77:8 83:9 91:4 

222:22 225:14 

differences 29:19 189:3 

189:4 

different 8:1,20,22 9:9 

33:20 35:18 57:6 

58:21 77:18 85:3 91:3 

107:22 121:8 125:6 

128:5 135:7 140:1,1 

148:20 163:11 164:15 

164:17 165:3,8,16,17 

167:22 168:1 169:12 

169:13,13,16,17,18 

169:19 182:16 189:8 

197:2 201:15 207:10 

210:3 231:19 249:22 

250:10 279:19 302:19 

304:21 309:2 314:3 

317:16 344:19 

differently 307:4 

difficult 85:2 183:22 

184:6 224:6 280:16 

283:3 293:18 310:11 

difficulty 84:6 

dig 175:12 303:13 

dihydrogen 3:7 25:3 

26:3 31:17 50:2 53:2 

54:4 

dilemma 187:6 

diligence 308:19 

309:18 

diligent 19:12 20:3 

diluted 31:12 

dilution 31:11 

diol 194:20 

dipicolinic 210:17 

direct 15:10 109:5 

110:18 209:15 242:15 

255:13 

directed 245:19,19 

direction 24:3,5 

directly 135:22 277:7 

357:3 

director 2:4 80:20 

disagree 74:16 99:20 

100:21 

disagreement 263:4 

disasters 346:1 

discard 12:7 

disclosures 221:6 

discount 40:2 

discovery 303:2 

discuss 88:20 96:18 

105:14 141:19 228:5 

244:4 345:15 357:2 

360:20 

discussed 99:6 100:7 

100:14,17 125:12,13 

132:19 149:18 159:13 

218:6 266:20 300:15 

357:6 

discussing 83:1 93:2 

145:6 159:2 201:18 

discussion 4:12 21:9 

29:18 35:15 37:1,19 

38:2 45:3 49:14 50:7 

53:4 54:16,22 55:19 

59:4,11,22 60:3,11 

63:8,10 66:5,6 67:6 

68:4,17 69:11 71:13 

71:16 84:11,17 85:10 

85:10 86:7 88:18 94:7 

95:21 102:2 106:6 

107:5,10,13 110:2,3 

114:5 116:3 121:9,11 

126:13 132:9,15 

133:14 140:15 172:6 

178:22 185:3 206:9 

212:6 231:4,5 232:12 

241:15 242:10 247:22 

268:22 270:7 280:10 

282:15 286:9,10 

295:5 297:8,13 

298:16,20 299:9 

309:19 310:7 311:12 

311:16 314:15 321:6 

336:8 337:11 341:4 

341:14 347:19 349:13 

349:20 353:12 355:2 

355:8 359:5 360:16 

364:11,16 365:8,21 

discussions 70:9,15 

71:20 106:9 174:21 

193:6 221:14 246:13 

258:8 270:6 311:2,7 

325:3 327:7 356:19 

356:20 

disease 30:6 314:20 

330:9 343:16 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
378 

diseases 248:6 258:1 

330:10,20 

disinfectant 10:8 12:1 

26:7 113:2 206:15 

314:18,22 

disinfectants 109:4 

110:17 315:11 

disinfection 32:6 

disked 196:12 

disparity 13:17 

disposal 13:2 36:7,8 

48:17 49:16 58:7 

173:9 301:21 337:8 

disproportionately

76:12,15 

disrobed 87:13 

disrupt 320:22 

disrupting 10:19 

disruption 321:16 

dissuades 74:17 

distinct 22:12 34:7 92:6 

distinguish 265:10 

distinguished 161:9 

distractions 181:1 

distributed 355:1 

disturbing 224:5 

disulfide 250:14 

dive 122:19 127:21 

274:12 

diverse 271:3 

diversity 202:6 

divided 208:11 

Division 2:4 

DL 120:16 

DL-Malic 120:21 

doable 306:5 

doc 160:18 

document 4:12 14:19 

21:15 69:11 115:5 

116:4 120:20 128:21 

129:8 142:13 175:5 

175:10 176:22 177:7 

183:9 201:17 204:9 

206:7 280:10 291:15 

294:4 298:17,20 

299:10 341:4,14 

342:2 348:10,15 

354:22 360:16 

documentation 21:14 

120:6 129:14 132:2 

180:13 

documented 192:17 

319:16 331:18 333:8 

339:13 

documents 185:11 

dogs 88:16 94:2 

doing 30:9 92:1 104:19 

105:8 119:15 126:5 

131:3 140:3 197:19 

224:7 308:19 346:12 

dolomite 332:5,11,15 

332:17 

domestic 335:11,21 

dormancy 334:1 

dormant 175:19 

dots 169:16,17 

double-check 137:18 

doubt 233:2 

doughnuts 216:15,18 

doughs 233:11 

dozen 13:6 207:4 

dozens 97:22,22 

draft 229:17 

dramatically 256:5 

draw 6:4 268:5 

dream 78:12 

dreamed 78:5 

dressings 233:11 

dried 4:3 233:6,8,14,19 

233:22 234:1,4 

238:20 239:2,10 

241:5,13 362:14 

drip 332:16 

drives 177:5 

drop 217:6 

drug 6:20 248:17 

343:14 

drum 335:1 

dry 188:2,15 189:5,18 

198:17 201:10 

dryland 268:3 

due 11:3 28:3 143:20 

308:19 338:4 342:1 

dug 299:16 

dunk 306:12 

duration 259:10 

dust 134:11,13 200:15 

345:13 

E

E 19:20 22:21 23:17 

111:6 158:4 

eager 59:19 

earlier 127:4 173:13 

269:14 288:21 289:1 

315:1 321:10 325:19 

early 12:8 56:22 368:17 

earned 161:13 

earthworms 198:22 

326:6 

easier 178:19 219:16 

364:2 

easiest 27:6 

easily 82:16 96:11 

222:20 

easy 83:18 155:22 

287:15 

eat 176:13 198:22 199:1 

243:1 344:12 

eating 83:12 85:6 

echo 38:8 49:9 73:16 

83:7 308:22 345:20 

366:19 367:9 

echoed 46:6 

echoing 234:20 

ecology 163:21 

Economic 12:18 

economies 184:19 

economists 163:15 

economy 184:14 

ecosystem 145:7 

ecosystems 229:5 

EDDS 325:17 

edible 316:13 

editor 161:2 

EDT 325:17 

educated 127:18 

305:16 313:8 

effect 10:15 42:14 73:8 

168:20 172:19,20 

199:4,6,12 200:9,10 

202:1 204:6 251:21 

327:11 

effective 7:1 206:18 

248:5 250:9 315:16 

317:15 325:14 328:11 

329:4 

effectiveness 249:19 

317:11 

effects 49:12 113:3 

158:14 170:9,19 

171:1,3,7,10,22 

188:18 202:5 250:19 

322:14 

efficacy 16:22 17:3,14 

259:16 325:22 326:4 

329:19 

efficient 151:13 340:4 

efficiently 68:9 206:6 

effluent 31:4 

egg 72:6,15 329:5 

eight 12:5 73:14 220:19 

221:8 

either 15:5,10 41:13 

56:19 95:4 102:6 

128:18 154:7 212:19 

261:16 277:5,6 

303:17 346:16 350:19 

351:20 

elected 161:12 

electrolyte 112:18 

elements 14:6 

Eleven 360:4 

eliminates 148:7 

Ellepots 299:16 300:12 

300:15 305:10 

email 25:16 

emails 25:8 

embarrassing 87:20 

embryo 365:1,3 

emergency 343:19 

emerging 343:17 

Emily 1:19 37:20 47:10 

48:10 59:12 64:2 

79:15 81:16 82:18 

89:16 94:18 97:12 

99:11 103:10 104:17 

111:18 126:2 129:19 

130:15,17 141:11 

144:18 154:18 185:7 

187:19 214:7 223:12 

228:7 234:5 239:22 

244:4 245:9 253:5 

255:14 261:22 268:22 

270:12 273:4 279:3 

282:17 284:12 306:13 

308:22 312:15 327:17 

328:22 330:7 331:16 

341:9,17 345:6,20 

349:13 355:3 361:17 

366:21 

Emily's 234:20 235:9 

emulsifier 143:4 

EN 178:16 

encapsulated 57:2,13 

encompassed 84:15 

encounter 220:12 

encourage 5:6 74:13 

144:9 153:12 228:8 

245:16 306:14 

encouraged 119:19 

encouragement 256:17 

encouraging 312:14 

ended 181:21 

ends 107:13 

energy 176:8,11,14,18 

368:5 

engaged 365:21 

engineered 28:4,14 

engineering 118:16 

152:4 185:15 

enhancer 110:11 119:3 

enormous 162:18 

368:4 

enriched 156:9 226:17 

enrichment 14:4 18:12 

156:4 

enrobement 84:13 

87:11,15 93:10 

enrobing 67:14 73:9 

ensure 14:17 179:4 

entertain 349:5,17 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
379 

enthusiastically 356:4 

entire 77:1 92:3 172:13 

306:15 368:2 

entirely 297:12 

environment 10:22 

11:5 31:4,7,10 34:17 

42:5,10 58:6 109:21 

159:21 173:19 175:16 

188:3,12,16,19 

199:13,21 212:5 

217:15 242:6,18,21 

315:5 317:7 333:18 

335:16 

environmental 12:21 

20:18 31:2,14 39:10 

42:2,18 111:2 143:21 

155:15 226:22 227:19 

251:2 322:14 329:17 

334:11 338:4 

environmentally 11:1 

207:2 249:17 

environments 188:1,2 

enzymatic 120:7 

enzymatically 173:21 

enzymes 3:12 10:21 

117:6,8,11,15,20 

362:20 

EPA 32:4 226:10 

248:12 

Epsom 6:1 

equally 315:16,17 

equipment 10:13 26:9 

134:12 135:10 212:3 

315:21 

equivalent 302:18 

Eric 282:4 

Eric's 145:3 

Erin 224:20 225:14 

erosion 200:18 

err 39:3 43:4 

error 102:3 

especially 9:16 36:15 

37:7 114:20 206:21 

209:10 236:4 237:18 

240:7 262:2 278:4,6 

303:10 305:6 333:5 

essential 13:9 18:22 

20:21 109:7 149:8 

201:11 211:14 221:21 

315:11,14 

essentiality 15:14 

32:14,16 33:14,15 

143:20 227:8 271:20 

278:20 

essentially 45:21 71:22 

159:16 184:8 193:16 

255:5 320:17 322:15 

323:1 

established 80:2 

ester 190:17 

esterases 190:20,21 

estimated 229:20 

et 82:21 260:22,22 

268:6 301:7 306:22 

306:22,22 

ethical 83:18 344:13 

Europe 178:20 187:4 

European 12:18 198:11 

evacuate 6:20 

evaluate 173:14 243:10 

344:17 345:21 

evaluated 249:22 

evaluating 20:1,14 68:1 

274:15 345:16 

evaluation 124:3 130:8 

171:19 211:11 251:4 

evaporation 189:19 

evening 209:6 

eventually 42:10 

everybody 107:4 173:5 

235:15 298:14 318:6 

330:3 362:9 367:11 

368:12 

evidence 40:4 41:2 

42:20 47:7 

evolve 142:13 

evolved 177:8,22 178:3 

203:22 

exact 357:5 

exactly 56:2 124:11 

189:22 252:9 310:18 

317:19 353:17 

examining 269:5 

example 74:6 76:14 

127:13 158:14 167:10 

180:3 186:17 190:13 

193:4 196:18 219:16 

222:8 223:21 251:15 

286:18 289:10 291:20 

305:19 312:8,13 

322:22 

examples 98:1 167:11 

exceeded 184:22 

excellent 10:15 197:6 

224:13 240:13 285:12 

301:9 

exception 147:10 

exceptions 262:4,6 

excess 143:18 

excited 37:15 337:15 

355:6 

excluded 16:17 20:5,7 

20:10,12 23:3,10 

78:15 125:9 127:7 

142:12 149:13,21 

150:6,20 151:10 

152:14 320:11 322:20 

363:16 

excluding 26:6 

exclusively 229:4 

Excuse 8:14,15 61:18 

122:2 217:18 

executive 80:20 314:10 

exist 181:1 266:8,9,10 

existing 70:22 249:12 

expand 71:4,5 134:4 

255:20 336:1 339:17 

expanded 215:16 

expect 38:15 46:11 

150:7 184:5 188:16 

189:5,9 190:1 197:1 

expectation 83:9 

expected 315:3,7 

expedite 206:5 

expensive 76:7,15,17 

151:18 323:5 332:11 

experience 34:5 45:9 

204:14 271:15 321:1 

experiment 164:1 

171:17 187:22 

experimentation

218:13 

experiments 164:2 

171:14 189:21 300:7 

expert 40:13 41:6,15 

experts 40:11 

explained 331:2 

explanation 157:18 

explicit 224:9 

explode 309:5 

explore 223:15 

explosion 343:16 

exposed 134:5 250:20 

exposure 146:12 

158:15 250:16 325:5 

325:8 340:10 

exposures 45:18 

334:12 

expressed 96:15 

310:10 

expresses 352:18 

extends 68:10 

extensive 69:9,15 

159:8,9 213:11 

221:13 227:10 278:17 

extent 17:20 40:22 

162:15 

extra 323:4 327:16 

extract 220:1,5 

extracted 218:21 

extraction 15:4 117:18 

extracts 219:22 

extrapolate 180:9 

extremely 319:2 

extruded 237:19 

F

face 309:5 

faces 187:6 

facilitate 190:9 192:4 

248:19 342:18 

facilitated 339:18 

facilitates 188:9 

facilitating 192:2 

342:14 

facilities 32:7 33:18 

34:2 

facility 10:12 34:2 

36:10 238:22 239:9 

facing 262:8 

fact 28:12 38:6 43:6 

73:11 80:12,13 81:5 

84:3 194:21 200:6 

260:4 266:8 309:20 

310:1 324:21 325:13 

340:9 342:2 345:10 

facto 125:14 322:4 

factor 222:22 

factors 361:14 

faculty 161:11 

failed 32:21 280:13 

fails 51:6 55:17 265:4 

273:20 276:16 285:6 

fair 58:15 125:1 194:15 

313:15 352:3 

fairly 69:9 80:1 118:6 

154:12 222:20 237:7 

252:6 277:10 283:7 

288:2 320:21 327:11 

fairness 85:4 

FALCPA 220:18 

fall 24:9 26:18 27:3 36:4 

37:13 41:11 48:6,14 

83:18 115:5 118:6 

119:16 144:12,20 

169:15 170:7 213:1 

225:10 228:15 257:16 

299:20 330:4 336:7 

338:13 341:13,15 

342:8 348:17,20 

360:8,10 361:8 

363:14 368:12 

falls 39:5 

far 31:19 58:13 124:19 

139:21 154:12 237:1 

247:5 277:10 278:3 

302:3 305:22 320:15 

335:17 365:18 

farm 45:9 76:6,7 77:3 

82:15 256:7 287:8 

330:14 

farmer 83:13 347:5 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
380 

farmers 6:4 76:8 82:17 

83:15 251:16 279:10 

280:21 324:20 339:4 

339:17,21 340:8 

341:20 346:6 

farming 82:7,8 

farms 268:19 

fashion 277:22 

fast 204:7 206:13 286:8 

faster 188:22 

fat 233:10 

fate 46:16 159:20 

202:17 

father 156:10 

fats 147:21 158:4 

316:15 

fatty 19:7 226:10 

338:18 339:2 340:9 

340:15,20 342:17 

343:6 361:5 

favor 11:7 13:7 58:16 

81:14 85:8 277:12 

318:6 338:8 

favorable 9:12 

favorite 136:15 

FCC 113:12,18 

FDA 13:15,17 14:5 

18:13 30:14 32:4,6 

135:6 143:3,18 

148:16 246:18 

FDA's 220:16 

feasible 228:10,15 

229:10 

February 249:2 

fed 177:22 

Federal 2:7 7:9,17 

160:21 

feed 14:3,17,20 15:10 

18:15,17 19:5,10 20:2 

20:9,15,22 153:20 

177:2 183:19 184:4 

230:9 

feedback 124:21 

128:14 153:3 267:10 

267:11 268:12 324:18 

325:1,6 326:21,22 

feeds 16:13 18:17 

feel 30:22 31:6 41:14,16 

78:16 100:8,10 

101:19 103:18 126:3 

126:6 222:4 262:1,9 

262:10 265:10 282:8 

297:16 307:4 350:3 

352:9 

feeling 102:4 218:15 

221:20 270:7 

feels 329:15 

feet 6:5 

fell 226:21 

fellow 161:12 365:20 

felt 70:20 88:4 93:5 

131:9 267:16 287:6 

301:15,19 308:1,7 

363:19 364:3 

fenbendazole 3:3 6:14 

6:17,22 7:4,10 8:5,9 

8:18 9:19 10:3 363:9 

fence 36:4,5 41:12 

Fencing 316:18 

fermentation 19:14 

22:19 23:21 106:14 

108:18 110:9 119:9 

119:10 120:7 123:17 

137:11 140:9 141:16 

148:5 149:16,20 

153:5 186:17,19 

194:21 

fermented 219:21 

344:8 

ferric 4:16 313:21 314:1 

314:7 324:5,7,21 

325:13 326:12,16 

327:5,10,14,15 328:4 

328:7 329:22 362:5 

ferrous 3:17 155:22 

156:3,7 157:10 158:3 

363:2 

fertilization 14:15 

fertilizer 145:10 196:4 

229:6 

fertilizers 340:4 

fiber 7:3 10:1 19:8 

233:15 237:2,17 

238:8,9 241:10,11 

307:8 

fiber-bearing 7:19 9:17 

fibers 299:15 300:4,6 

300:10,14,17,19 

301:12 303:2,6,13,15 

305:2,6 306:17 

307:14 308:4,11 

310:6 312:20 335:15 

Fiberstar 238:21 

field 31:22 77:16 164:2 

164:19,20 165:3 

266:13 289:12 301:21 

302:1 307:13 309:10 

309:14 311:15 325:5 

325:8 

fields 268:19 302:9 

fifth 199:11 346:6 

figure 52:7 167:22 

169:21 228:16 260:7 

310:16 346:2 

figured 260:6 271:9 

figures 169:9 

fillings 155:11 

film 4:5 173:10 181:7 

188:8 191:5,20 

192:19 

films 177:3 179:5 183:2 

filter 133:19 

filtering 145:16 147:8 

filtrate 133:20 

filtration 133:21 145:18 

146:21 

final 50:7 66:7 80:5 

86:7 186:4 187:8 

257:1 347:9 355:4 

359:5 

finally 340:19 

financial 76:16 

find 20:16 29:22 30:12 

30:18 81:10,12 82:13 

83:16,17 91:3 96:10 

96:11 113:13 117:7 

173:14 200:6 209:16 

224:6 236:20 256:12 

260:21 299:1 

finding 76:19,21 

fine 25:13 83:17 90:22 

91:19 92:8,8 95:4,5 

102:22 111:22 112:1 

112:5 134:11 350:19 

352:22 353:8 357:14 

finish 205:12 285:14 

337:14 

finished 285:18 364:20 

fire 331:5 

firming 101:8 112:14 

121:19 

first 25:2 27:5 44:6 

47:13 53:6 60:2,6,11 

62:7 72:7,16 75:20 

77:21 108:21 119:12 

156:11 167:6 170:14 

172:17 175:13 188:11 

196:6 197:7,11 

198:11 203:3 216:3 

226:22 227:9 230:2 

248:12 249:3 255:3 

259:2 271:2 279:5 

280:19 290:2,5 311:3 

313:16,20 314:6,7 

341:17 349:13 355:11 

364:10 366:11 

fish 4:2 67:19 226:6,8,9 

227:1 229:4,4,5,11,12 

229:21 230:9,22 

231:17,21 232:9,15 

232:19 319:1 361:7 

361:17 362:12 

fit 141:18 274:15 

290:10 331:10 

fits 71:10 

five 51:5 165:17 180:9 

255:19 312:19 334:18 

351:18 

flattens 180:7 

flavor 110:11 119:3 

147:18 155:12 

flavoring 119:4 

flavors 137:3 212:3 

fleece 7:21 

flip 238:1,14 

floor 353:11 354:21 

356:8 

Florida 225:20 236:4 

238:22 239:9 240:22 

flour 147:20 233:15 

flours 156:8 

flow 295:11 

fluoaluminate 4:18 

337:15 362:9 

Flury 2:9 4:6 160:12 

161:7 162:4,9 185:19 

187:16,21 188:10 

195:17 197:6 200:17 

205:3 

foams 161:16 

focus 94:14 141:5 

166:4 

focused 215:16 259:8 

foliage 319:4 

foliar 277:5,16 332:20 

folks 41:11 75:7 144:10 

153:3 185:5 213:8 

224:17 235:7 324:20 

327:2 

follow 140:5,11 183:5 

293:18,19 296:1 

336:7 

follow-up 24:9 187:12 

followed 48:2 177:13 

367:16 

following 7:13,14 9:21 

23:5,12 315:5 

food 13:15 26:7,8 29:19 

32:4 33:20 39:8,10 

45:20 63:1 65:6 83:11 

108:19 109:6 110:19 

112:12 113:10 115:2 

118:3 121:17 126:19 

133:19,20 135:6,9 

140:1 145:22 147:4 

147:22 149:2 157:15 

173:10 175:14,17,18 

175:21 176:2,13 

177:16,22 178:1 

184:13 206:22 208:3 

208:13 212:20 213:19 

213:20 214:2,3 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
381 

218:12 220:10,16,17 

221:1 239:2 242:21 

248:16,17 322:2,4 

foods 89:13 119:5 

148:15 156:4 157:14 

158:6 227:9 231:18 

238:10 241:20 

fool 127:22 

footprint 184:13 

footsteps 367:17 

forage 14:13 15:16 

16:12 

Forages 14:11 

force 313:3 

forever 87:18 191:14 

forgive 176:9 

forgot 22:6 

form 28:13,14 37:9 

59:20 74:7 79:21,22 

80:3 94:4 119:7 

120:17,22 122:2 

135:5 136:7 157:11 

157:21 182:16 185:15 

194:20 213:5 233:19 

267:7 325:7 326:1 

332:3 340:12 

format 280:8 

formation 108:22 

former 51:10,11 210:20 

forms 118:21 122:1 

139:14 249:11 315:4 

formula 135:12 

formulas 157:8 

formulated 27:14 

326:12,15 328:11,12 

329:10 

formulation 109:4 

110:16,17 143:4 

328:5 

formulations 27:8 

210:21 322:16,18 

324:20 325:4 

forth 328:18 

forthcoming 122:7 

225:1 

fortification 14:5,17 

18:12 98:9,11 148:17 

156:4 

fortified 156:13 

fortify 149:4 

fortifying 155:9 

forward 16:18 26:22 

28:22 32:12 37:18 

69:4 77:13 89:20 

101:14,16 102:2,6,16 

102:17,19 109:20 

111:1 112:1,2,6 

125:22 126:14 128:15 

128:18 129:9,15 

130:1,9 131:15,18 

140:22 145:6 155:14 

184:9 204:18 208:8 

208:21 212:4 217:14 

223:5 235:12,12 

257:7 263:5 268:11 

268:15 348:14 350:10 

351:5 352:4,22 

353:14 365:9 367:10 

368:11 

fossil 183:16 195:10 

300:18 304:13 

found 20:19 26:16 

84:16 122:2 156:9,11 

217:9,10 224:5 

228:22 234:16 250:4 

250:6 299:14 301:5 

312:21,22 316:2 

323:3 

foundation 78:22 

four 12:7 93:18 95:3 

163:3 165:16 171:2 

180:7 209:10 227:14 

241:22 246:9 255:8 

324:17 

four-year 171:18 

fourth 168:12 171:9 

346:6 

fowl 67:19 

fraction 76:14 182:19 

fractionate 185:15 

fragmented 198:5 

fragments 174:3,3,14 

175:7 176:2 200:20 

frame 174:16 175:7 

178:13,15 193:21 

200:3 201:8,22 

206:19 

framing 172:15 

frankly 28:5 

fraud 360:17 

free 109:14 187:10 

265:10 

freeze 73:6 

fresh 109:11 239:7 

240:19 

FRIDAY 1:7 

friendly 11:1 207:2 

front 59:8 91:9 318:3 

329:20 

frozen 233:11,12 

fruit 112:15,22 119:7 

155:11,12 237:18,19 

248:9 277:7 279:10 

279:19 289:22 290:10 

290:11,13,16 319:4 

333:4 

fruitful 107:6 

fruits 26:5 109:11 283:3 

290:1,4 331:1 

FSMA 109:8 

fuel 195:14 196:3 

fuel-based 304:13 

fuels 300:18 

Fukushima 243:16 

full 5:12 24:22 76:22 

120:11 133:6 160:12 

290:19 297:22 365:11 

fully 40:13 

fumaric 119:9,9 

fumigant 247:19 251:20 

257:3 262:11 

fumigants 249:18 

function 94:1 148:10 

178:3 233:3 

functional 137:2 202:21 

218:4,18 233:1 

237:18 239:2 

fundamental 173:13 

175:12 177:10 192:7 

262:21 

fundamentals 173:2 

funding 223:6 

further 19:4 21:13 

26:20 28:9 32:10 

33:10 35:6 47:7 71:22 

76:11 101:10 105:14 

109:12 112:2 132:14 

140:15 175:11 194:13 

209:2 214:5 215:15 

349:12 353:12 355:2 

future 47:2 101:22 

102:12 105:5 139:11 

152:19 211:11 238:12 

287:5 297:8 

G

gain 17:5 

gardener 255:5 

gas 146:13 315:8 

gathering 132:2 

gavel 366:9 

gel 3:8 64:20 67:4,7 

70:3 71:3,21 72:18,20 

73:7 74:22 75:2,19 

76:1 77:9 86:3 87:6 

87:15 89:9,12 91:10 

93:22 97:1,3 100:9 

108:22 155:11 222:8 

231:6,7 247:2 356:10 

359:3 

gelatin 4:3 57:22,22 

68:13 70:21 71:1,19 

71:21 73:18,19 74:14 

75:18 79:6 84:4,11 

231:1,4,6,11,17 232:1 

232:4,6,9,10,13,19 

233:2,5 362:13 

gellan 144:14 

gelling 217:9 

gels 93:20 

general 70:11 101:18 

136:2 149:16 150:18 

158:10 213:16 228:21 

243:20 278:13 328:21 

generally 52:17 92:16 

108:4 122:1 156:12 

217:2 248:17 321:20 

329:14 

generate 333:18,22 

334:20 

generation 346:6 

generic 20:13,15 130:4 

132:4 

genetic 19:15,18 22:20 

23:7 118:16 152:3,4 

185:14 364:18 

genetically 21:5 23:18 

185:20 186:7,21 

gentle 321:5 

genus 138:5,8 

gestation 259:3 

getting 65:22 76:6 93:6 

160:22 190:20 192:6 

194:14 222:20 254:13 

313:2 

give 116:15 162:6 

175:16 177:15 178:1 

178:1 192:13 203:14 

204:2 211:5 254:1 

270:9 281:16 298:13 

308:16 352:15 368:12 

given 29:3 33:11 34:21 

70:21 75:19 95:2 

102:15 113:8,17 

115:7 117:15 135:15 

150:3 156:19 221:13 

228:20 239:8 320:14 

354:4 356:18 

gives 146:2 194:22 

260:5 271:11 336:19 

364:22 

giving 139:17 191:5 

352:8 

GLASGOW 2:3 

glass 134:1 

global 127:6 136:5 

213:2 

glossed 274:11 

glucose 119:10 

glues 303:20 

Glycerin 74:6 

glycinate 4:10 265:7,16 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
382 

265:22 267:2 274:20 

275:20 

GMO 20:14 142:2 186:7 

186:10,12 

GMOs 186:5 187:9,18 

320:11 

goal 206:7 

goats 7:14 9:21 

Goodbye 362:13 

goods 215:12 233:10 

gotcha 351:12 

gotten 326:21 

government 131:8 

Governor's 161:14 

grade 40:7 113:10 

126:19 194:6 206:22 

271:14 

graft 261:7 

grain 18:18 146:6 

grains 14:11 

grandkids 205:5 

grant 163:3 

grants 223:7 

grapes 26:6 

graph 167:16 180:11 

graphs 169:6 222:15 

grapple 38:5 

grappled 196:15 

grappling 227:2 

GRAS 93:20 193:3 

grass 6:2 

grass-fed 81:5 

gratifying 285:16 

greater 96:6 105:7 

125:9 307:16 340:13 

greatest 188:4 

greatly 366:6 

Greece 134:3 

green 161:14 180:3 

197:4 340:10 

greenhouses 331:1 

greening 236:2 

GREENWOOD 1:17 

41:19 50:20 53:16 

55:8 61:8 64:7 66:12 

86:13 126:9 262:16 

263:12 264:11 272:19 

273:16 275:13 276:10 

282:17 284:1,20 

316:10 317:19 346:18 

355:18 359:12 

ground 122:1 197:17 

197:22 

grounds 255:22 

group 9:6 56:13 81:2 

94:18 96:17 124:2 

143:11 153:16 157:9 

182:4 277:12 278:3 

319:9 334:21 364:11 

groups 58:20 63:1 65:6 

69:16 161:21 202:21 

277:12 334:5,6 

grow 75:21,22 81:1 

175:18 189:2 224:17 

236:3 261:8,12,18 

300:20 334:3 339:5 

346:22 347:2,6 

grower 255:4 289:10 

318:16 

growers 207:9 248:5 

258:9 277:13 299:19 

319:22 321:14,17 

330:12 333:4 347:15 

growing 29:14,14 30:17 

75:21 83:21 197:14 

222:9 224:5 277:17 

300:22 301:1 342:18 

grown 219:17 223:1,2,2 

342:16,19 343:4 

346:7 347:10 364:19 

growth 14:8 78:19 

119:6 252:13,19 

253:9 254:6,18,20 

260:8 290:6 292:9 

339:9 340:2 344:11 

guarantee 320:18 

guess 17:18 25:9 33:17 

35:13 36:11 38:22 

39:20 40:12 46:19 

47:4,12 48:20 54:5,13 

54:19 65:7 66:4 82:1 

89:1,4,7,11 90:22 

100:8 101:13 110:4 

111:4 118:7 123:16 

124:16,20 125:17 

133:4 136:6 138:7 

139:3 141:21 151:6 

156:12 198:18 202:16 

228:17 235:3 254:16 

254:22 314:8 329:7 

346:4 350:21 354:2 

360:14 362:3 

guidance 4:11 14:19 

19:22,22 57:5 120:10 

285:8 286:12 288:9 

291:4 292:12,18 

293:7,12 294:11 

296:9 297:1,2 348:10 

349:7 352:6 353:20 

354:22 

guide 211:10 

gum 144:15,15 235:11 

gummy 135:13 231:16 

H

H2O2 315:2 

habitat 324:14 

hairs 307:19 

halal 58:3 

half 13:6 120:9 254:17 

255:10 

hand 47:11 79:5 130:19 

368:13 

handful 147:2 

handle 128:9 224:4 

349:4 

handled 206:20 210:11 

219:9 

handler 46:7 246:11 

handling 3:6 4:1 24:19 

31:22 32:3 83:10 

109:10 121:6 126:4 

133:12 137:22 205:13 

205:21 207:10,15 

356:13 362:12,18 

363:6 

hands 297:22 

happen 75:9 108:6 

178:15 184:5 195:7 

198:4,15,16 199:15 

201:10 216:9 

happened 91:4 234:10 

346:3 

happening 78:21 105:1 

179:22 190:2 200:5,6 

203:15 204:3 

happens 49:21 172:20 

176:5,20 180:14 

197:21 198:8,20 

happy 88:10,17 172:2 

205:7 

hard 32:5 35:11 36:19 

126:4 235:1 244:7 

245:13 252:8 296:1 

305:11 319:2 338:12 

harder 236:3 

hardwoods 146:6 

harm 51:22 109:20 

212:5 238:14 319:12 

harmful 199:6 

harmless 210:6 

harnessed 176:12,18 

Harold 318:17 

harping 267:19 

Harriet 1:9,12 5:17 21:2 

24:16 44:5 59:12,13 

72:2,16 85:13 86:4 

88:3 89:3 90:1 92:19 

95:7 96:21 99:11 

100:3 103:10 106:16 

111:3 114:6 116:20 

118:12 121:5 129:19 

134:18 141:2 154:10 

172:10 185:7 205:1 

207:12 209:12 216:1 

223:13 224:2,19 

235:17 240:12 246:16 

247:6 252:3 260:1 

263:9 270:3 272:5 

274:21 283:13 285:9 

287:22 291:14 292:2 

292:7,19 299:12 

307:21 313:9 336:2 

341:18 342:9 347:20 

350:11 352:3 353:3 

358:9 366:15 367:22 

Harriet's 122:17 

harvest 143:14 291:6 

harvested 144:3,4 

223:16 229:4 

harvesting 7:20 144:1 

227:1,3 

hat 302:9,10,16 

hates 345:22 

hauling 302:1 

hazard 134:10 

hazards 319:11 

head 150:12 223:19 

308:14 

heads 25:22 216:17 

health 15:15 17:6 20:20 

29:10 30:1,14 39:9 

46:1 48:16 58:6 

109:20 111:1 134:10 

149:8 155:15 158:13 

166:6,14 167:6,9 

170:20 171:11 172:19 

192:22 197:2 212:5 

213:15,15 217:15 

227:5 262:17,19 

322:14 344:2 345:9 

346:19 

healthy 14:9 347:12 

hear 17:2 45:10 58:21 

81:18 114:1 125:19 

133:6 144:16 160:9 

207:20 234:6,22 

235:7 237:22 239:15 

240:1 254:22 256:18 

259:4 330:16,17 

331:13 332:21 341:20 

342:4 344:14 353:22 

heard 6:7 9:10 21:3 

28:9 57:18 58:18 

138:9 190:21 240:9 

254:14 318:16 332:10 

332:15,16 334:21 

353:1 

hearing 6:13 16:20 28:6 

132:13 263:3 

heart 25:19 346:5 

heat 146:8 173:19 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
383 

340:13 

heavily 82:5 114:7 

312:7 318:5 

heavy 143:17 227:5,16 

228:12 242:4 243:19 

244:18 245:12 246:1 

301:22 312:13 

HEDP 210:16 

help 51:20 81:11 90:12 

92:14 105:2 142:9 

150:5 160:10 190:9 

269:7 277:8 279:14 

279:18 287:11 293:8 

335:11 336:1 

helped 150:20 321:17 

helpful 47:17,20,20 

144:12,16 153:17 

257:4 288:5 321:7 

324:18 325:1,7 

326:21 341:20 

helping 111:20 192:4 

285:15 297:5 312:6 

360:16 

helps 90:9 190:4 

211:10 293:2 329:21 

334:1 

hemp 300:6,10 305:5 

310:2,4,5,8,18,20 

311:9 

herbicides 202:13 

Hi 185:8 

hides 231:20 

high 134:3,5 146:8 

210:10 314:14 330:22 

332:19 333:9 367:14 

high-calcium 277:18 

high-value 186:14 

higher 76:13 206:15,21 

222:20 243:18 329:19 

332:14 

highest 161:10 

highlight 170:20 292:20 

highly 149:19 228:8,10 

233:2 245:16 250:6 

306:14 333:2 

historical 367:4,5 

historically 210:14 

history 25:17 208:5 

344:22 

hold 63:14 209:7 

259:15 365:16 

holder 84:12 

holding 94:4 262:10 

310:3 

hole 343:3 

holes 146:6 

holistic 157:5 

home 74:1,15 368:6 

homes 76:19,19,21 

82:14 

honed 263:2 

honest 309:10 

Honestly 293:16 

honor 161:10 185:4 

hope 92:3 125:16 151:6 

151:14,19 171:20 

256:16 260:5 269:12 

348:19 363:17 364:9 

hopefully 61:21 162:1 

179:9 225:5 285:20 

333:7 

hopes 257:3 

hoping 364:16,20 

horticultural 4:15 

165:22 317:21 318:20 

319:10 362:2 

hot 88:15 94:2 188:2,15 

189:5,18 299:3 

301:15 302:1,7 

Hotel 1:9 

hotter 188:2 

hour 205:10 

hours 73:14 164:5 

huge 256:9 261:10 

human 13:5 29:10 30:1 

48:16 58:6 109:20 

111:1 134:10 135:8 

149:8 152:5 155:15 

212:5 213:15,15 

217:15 227:4 230:19 

251:2 

humane 6:8 

humans 5:10 19:10 

148:13,13 154:8 

176:20 261:5 

hundreds 207:7 260:14 

321:1 

hydrated 122:2 

hydrogen 3:18 4:14,17 

206:2,11,13,17 210:1 

313:17,18 314:6,9,16 

314:21 315:4,7,13,15 

315:20 316:7 333:14 

333:17 362:1,5,7 

363:3,11 

hydrogenated 220:11 

hydrology 160:14 

hydroponic 310:6 

hydroponics 310:4 

hydroxide 146:10,11 

155:6 267:7 

hypnotic 13:3 

hypochlorite 361:4 

hypoglycemia 6:3 

I

ice 231:17 

idea 43:18 47:18 162:19 

164:7,15 165:20 

166:9 197:13,18 

ideal 40:11 324:14 

identical 148:9 178:17 

identified 31:21 120:17 

335:14 

identify 258:5 

identifying 150:21 

identity 186:13 

IFOAM 12:19 

illness 340:13 

illnesses 343:16 

imagine 89:14 113:21 

265:8 

immediate 202:2 

immediately 286:19 

289:6,13 290:21 

317:8 

impact 31:4 34:16 

81:22 166:10 256:10 

262:17 312:11 331:6 

impacts 20:20 28:17 

42:19 143:21 145:7 

197:1 200:4,8 249:11 

335:16 

impartial 47:15 48:21 

49:5 

impartiality 47:14 

implications 168:15 

importance 15:15 

34:11 83:1 122:12 

important 6:8 14:8 

48:22 75:22 76:20 

77:1 83:21 102:8,9 

107:10 126:17 145:8 

152:12 160:2 166:14 

168:7,14 170:22 

172:22 183:1 189:8 

217:6 221:21 237:16 

239:3 250:1 258:7 

280:17 335:9,10 

347:14 

importantly 70:1 

importer 310:10 

impressive 211:6 

improper 13:2 

improve 147:20 

improved 339:9 

improvement 291:3 

312:1 

improvements 268:4 

360:17 

improving 292:12 

impurities 113:9,14,17 

114:4 202:20 

inappropriate 113:17 

inclined 49:3 

include 62:19 63:13 

123:19 124:3 143:3 

234:1 308:11 316:19 

323:5 

included 15:9 28:17 

58:9 110:10 143:9 

182:18 

includes 15:7 115:6 

including 6:2 9:4 19:6 

67:19 146:9 155:9 

203:18 211:22 217:3 

250:1 251:16 288:10 

314:18 

inclusion 91:10 300:13 

incompatible 262:20 

incomplete 259:21 

inconsistency 103:3 

111:7 293:9 296:15 

352:9 

inconsistent 23:11 

incorporate 310:22 

incorporated 196:9 

310:8 

incorporates 157:2 

incorporation 197:7 

Incorrect 123:3 

incorrectly 244:17 

increase 79:13 333:11 

339:10,16,18 

increased 324:10,11 

326:4 

increases 325:20 326:5 

increasing 255:18 

262:5 

increasingly 140:7 

incumbent 44:3 

independent 40:13 

156:6 

India 335:19 336:4 

indicate 251:10 

indicated 122:15 

indicates 150:22 

251:15 

individual 15:2 136:4 

146:18 244:6 

induce 250:18 

induced 365:1,4 

industrial 15:3 70:5 

148:3 

industry 33:1 35:12 

74:19 76:21 77:10,10 

78:19 81:21 83:22 

84:1,21 114:8 150:4 

157:8 208:12 227:17 

237:11 240:5 253:10 

256:17,22 280:20 

282:22 321:18 335:8 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
384 

inert 27:13,19,21 

210:19,20 327:13 

329:3 

inerts 211:7 

infant 135:12 156:10 

157:8 

infected 6:4 

infinite 254:18 

inflammation 6:6 

influence 268:5 

inform 160:10 297:2 

329:22 357:16 

information 11:13 

29:16 31:7 38:7 39:21 

39:22 40:20 44:19 

47:5,16 48:15,21 49:6 

58:4 109:19 110:22 

129:16 132:1 149:12 

155:14 168:10 210:15 

212:4 217:14 221:3 

221:15 225:7 232:2 

232:18 246:19 251:11 

281:13 307:20 326:11 

364:9,21 

informing 107:11 

informs 352:7 

ingesting 200:11 

ingredient 27:22 56:9 

56:19 58:12 67:10 

68:1 83:12 89:13 

109:1 147:18 191:18 

220:6 239:3 241:18 

244:6 248:16 

ingredients 20:1 27:20 

56:20 63:1 65:6 91:12 

134:20 178:2 190:8 

192:3,20 202:21 

212:15 

inhalation 134:11 

250:20 319:11 325:4 

inherent 278:8 

inherently 39:13 49:3 

80:17 

inhibit 119:5 

initial 24:12 215:14 

270:15 

initially 37:15 120:20 

198:4 

injury 319:8 320:2 

innocuous 59:15 

Innovation 56:12 

input 103:4 132:18 

211:3 222:9 318:7 

inputs 20:14 74:10 

145:11 172:7 

insect 321:12,15 

insecticide 318:2 338:5 

inside 10:18 176:2 

192:16 201:5 

insight 139:18 162:1 

inspiring 368:9 

instance 48:7 57:9 

188:19 189:12 195:21 

198:22 200:18 

Instant 241:19 

Institute 160:21 161:18 

institution 223:9 

instructed 20:3 21:11 

insufficient 117:12 

insulation 161:15 

intake 14:18 148:15 

integral 193:11 

integrity 69:18 364:18 

intended 90:18 93:18 

95:3 97:15 100:1 

123:18 124:1 

intensive 261:4,14 

intent 7:18 8:4,4 23:12 

265:17 290:11 292:12 

357:16 

interest 35:17 46:17 

47:5 58:20 85:4 

143:11 157:9 189:14 

240:3 298:1 

interested 98:2 267:3 

interesting 78:20 153:2 

153:10 210:13 225:13 

225:15 310:3 311:11 

317:13 318:9 333:17 

interim 128:20 

interject 44:21 240:14 

317:10 

intermediate 250:21 

internal 6:21 9:3 

internally 23:11 

international 15:11 

58:10,11 134:7 

146:15 161:19 251:6 

interpret 32:15 111:21 

309:7 

interpretation 28:18 

274:13 350:9 

interpreted 292:16 

interstate 258:2 

intervening 234:10 

intestinal 67:13 71:2 

intestines 67:15 

intramuscularly 12:14 

intravenously 12:14 

introduce 159:6 160:22 

introduced 92:21,21 

introduction 162:11 

inundated 179:11 

Inventors 161:13 

investigating 114:3 

investment 368:4,5 

invite 159:1 

invited 46:22 47:1 

161:22 

involved 43:20 78:5 

117:18 344:1 

involvement 356:18 

involving 117:16 

145:18 

iodide 3:14 135:3,4 

362:22 

iodine 135:5,8 136:11 

363:12 

ionic 28:13,14 37:8,12 

iron 156:4,13,16 157:11 

157:16,20 158:11,13 

iron-based 157:3 

irrigation 314:18 

332:16 

irritant 210:10 

irritants 45:13 

ISO 161:19 178:8 

isolated 110:7 

isothiocyanate 4:9 

247:11,14 263:7 

264:8 

isotope 182:11,21 

issue 21:22 28:2,11,12 

29:17 30:5 32:8 42:6 

42:22 44:4,20 49:16 

83:6,17 84:3 111:13 

132:12 140:6 142:2 

149:18 152:9 160:5 

186:10 201:9 219:3,4 

242:16 244:1,3 256:8 

257:18 258:13 261:20 

267:21 270:16,22 

279:10,21 287:3,17 

293:6 304:12 305:14 

311:9 322:10 328:19 

328:21 345:9 346:20 

352:14 353:4 357:13 

issued 14:19 

issues 20:19 29:11 30:8 

43:21 44:8 68:16 

77:13 102:8 127:19 

154:6 173:12 239:10 

248:22 249:1 252:16 

262:8,18 271:22 

278:19 299:12 316:5 

319:6 327:22 335:6 

it'll 75:6 

item 34:15 54:17 55:18 

62:9 90:3 91:7,9 

92:18 97:18 98:14 

100:2 101:6 114:2 

118:10 125:21 126:18 

133:1 140:17 141:14 

207:17 223:8 226:15 

228:13 238:1,14 

239:11 280:10 287:1 

287:21 291:18 322:9 

341:12 364:20 

items 74:17 98:1 

105:20 133:9 208:4 

213:13 227:3 228:20 

238:13 298:7 315:12 

344:10 360:20 362:1 

ivermectin 9:5 

J

January 7:6 26:12 

247:21 

Japan 144:6 242:13 

243:16 

Japanese 12:18 241:20 

246:7 300:8 310:13 

Jell-O 231:16 

JENNIFER 2:6 

Jenny 107:3 341:8,18 

351:14 367:19 

Jesse 1:14 10:6 11:19 

11:19 49:14 66:8 

247:12 263:8 264:9 

313:17 314:11 338:20 

340:22 

job 65:22 306:20 

Joe 306:21 

joking 25:10,10 62:12 

207:21 

Journal 161:3 

joy 330:3 

judge 243:2 345:10 

juice 231:13 240:18,22 

juices 133:21 

juicing 237:10 241:2 

jump 271:1 305:1 

jumped 260:2 

June 26:14 

justification 27:15 

justify 261:22 283:9 

K

keep 5:9 18:2 44:11 

126:19 149:15 217:17 

240:2,7 288:12,15 

291:3 296:5 297:7 

305:7 316:20 317:5 

317:12 323:6 

keeper 51:12 

keeping 77:1 142:13 

218:10 296:6,8 

keeps 115:10 142:1 

159:14 302:10 

kept 352:13 

key 193:13 256:8 

kill 202:4 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
385 

killed 124:2 

kilocals 176:9,11 

kinds 45:17 126:12 

154:2 180:12 243:3 

knew 112:13 299:6,11 

knock 225:6 

knowing 271:10 

knowledge 39:17 

138:22 322:1,21 

367:4,6 

known 6:1 128:21 

250:18 

knows 310:17 321:8 

Knoxville 164:6,14 

167:20 188:20,21 

kombu 4:4 241:16,17 

246:13 362:14 

kosher 58:2 68:8 

231:18 

L

L-Malic 3:12 118:19,20 

118:22 119:3 120:6 

120:14,16 362:20 

lab 199:7 201:14,16 

335:5 

lab-scale 201:21 

label 111:14 131:4 

181:15 220:4,7 

labeled 7:11,21 56:10 

62:21 65:5 91:13 

182:10 203:17,19,20 

212:14,16 219:14 

220:4,22 241:12,12 

291:7 

labeling 182:21 203:5 

203:11,12 219:9 

220:17 

lack 123:13 143:20 

lactic 3:10 110:4,6,7,21 

362:19 

lag 200:2 

laid 327:22 

land 290:2 347:5,11 

364:19 

landing 122:6 

language 22:9,12,14 

59:8 89:4 94:9 95:1,6 

95:15,19 266:17 

285:18 292:7 293:22 

310:12 336:21 349:22 

351:7 353:8 356:22 

lap 356:15 

large 46:6 115:20 126:6 

138:16 146:1,5 147:1 

163:10,16 175:21 

182:14 316:12,16 

331:11 

large-scale 144:6 

larger 200:11 219:3,4 

257:18 

lastly 18:4 

late 190:11 

latest 18:9 

lauryl 27:7 35:2 36:18 

law 77:22 136:11 

208:19 220:16 

lawful 12:3 

laws 78:2,3 

laxative 6:3 

layer 345:14 

leach 200:20 

leaching 200:19 

lead 25:4 56:3 158:14 

206:3 209:22 217:20 

285:15 356:14 367:18 

leading 326:18 

leads 208:6 

leaning 41:3 43:2 49:16 

learn 200:5 365:22 

learned 308:15 

learning 145:4 

leave 96:16 125:17 

206:18 218:9 234:8 

289:12 302:2 368:6 

leavener 215:20 

leavening 215:5 

leaver 215:10 

leaves 210:5 280:9 

leaving 11:16 96:1 

235:1 357:2 

led 107:22 

left 5:18 75:11 128:3 

159:19 165:14 167:20 

lefthand 202:12 

legal 347:7 

legally 320:13 342:16 

342:19 

lends 242:10 

lengthy 90:17 

lesions 6:4 

let's 37:4 38:1 52:22 

60:11,21 85:20 

101:15 106:19 175:11 

192:6 198:21 205:9 

215:2 233:5 241:15 

245:8 305:14 348:3 

350:15 364:6,19,20 

368:12 

letter 350:7 352:5,16 

357:3,9 

lettuce 260:13 300:22 

level 14:14 82:15 

113:17 214:1 224:8 

228:6 

levels 31:13,14 109:14 

149:5 206:15,22 

210:10 238:6 248:7 

LEWIS 2:4 62:2 85:15 

85:22 86:5 90:8 98:18 

104:18 111:22 112:5 

131:13 132:10 133:2 

140:12 152:8 212:9 

225:9 240:21 291:14 

291:20 313:20 337:21 

338:2 353:16 360:12 

364:4,7,10 

liberty 173:2 

licensed 12:4 

licensing 32:9 

life 73:3,13 153:19 

173:11 176:13,15 

183:10,13,20 203:2 

237:11 249:11 301:6 

lift 228:12 

light 35:4 173:19 208:9 

344:14 

lightly 270:6 

lignin-based 271:19 

liked 291:19 

likelihood 188:4 

LIMA 1:16 41:9 50:19 

53:15 55:7 56:4 60:15 

60:18 61:7 64:6 66:11 

72:3 86:12 106:13 

108:17 110:6 116:13 

142:21 145:1 155:3 

211:20 216:20 217:1 

235:6 263:11 265:1 

272:18 273:15 275:12 

276:9 283:22 284:19 

349:21 350:8 355:17 

359:11 

limbo 306:8 

limestone 277:1 

limit 80:4 308:11 

limitation 99:16 

limitations 255:21 

limited 143:5 146:21 

215:5 248:21 255:7 

277:11 331:7 

limiting 80:7 

limits 97:8 

line 41:11 83:18 153:8 

180:8 187:7 203:21 

249:14 259:16 262:10 

285:14 290:14 322:11 

339:13 

lines 41:12 46:9 138:12 

244:19 251:5,9 

252:17 

lingering 41:17 

linkage 190:17 192:9 

linkages 191:1 

lint 333:22 

lipids 182:19 204:1 

liquid 114:20 145:19 

361:7,17 

Lisa 1:16 39:19 41:8 

53:6 54:11 56:2 61:2 

65:10,17,21 72:2 

106:12 108:16 116:12 

130:16 142:19 155:1 

211:18 216:22 234:19 

235:5 263:10 

Lisa's 83:20 

list 2:5 7:1 8:18 9:6 

20:13 26:11 28:19 

35:21 39:5 43:6,8 

44:14 45:6 56:7,12,21 

57:10 58:1 65:13 

68:14,20 69:7 70:21 

71:1 73:20 75:11 84:4 

87:13,14 89:21 92:7 

95:10,16 96:22 97:5 

98:2,3 100:16 101:2 

104:10 115:4 116:22 

119:1 120:18 139:4,4 

140:19 159:15 206:2 

210:20 215:21 216:3 

218:19 235:2,20 

239:20 250:17 260:17 

264:7 269:21 278:19 

279:1 312:20 313:22 

314:1 315:10,12 

318:10 321:21 336:16 

336:17,22 338:9 

340:21 345:13 360:18 

365:15,16 

listed 7:4,17 9:20 10:11 

12:8 18:7,14 57:22 

90:19 134:7 137:17 

159:15 208:4 215:18 

218:1,4 219:2 232:1 

239:16,21 241:5 

242:1,12 243:11 

246:8,9 248:16 249:4 

250:16 341:13 357:18 

357:19 

listing 6:10 11:10 14:22 

15:2 20:16 29:5 34:15 

58:16,20 59:1,3,7 

62:16 70:12 92:14 

95:9 103:6 107:14 

114:18 115:11,13,19 

116:2 120:20 123:18 

123:22 124:1 127:9 

130:1 132:20 134:17 

135:19,20 136:3,5,20 

137:7 139:1 143:12 

156:18,20 157:2,5 

208:3,17 213:2 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
386 

214:11,16,20 215:14 

218:9 232:9 237:15 

241:7 242:3 244:3 

248:18 269:20 273:1 

275:19 284:9 307:3 

307:10 313:5 316:4 

319:9 338:7 

listings 116:8 136:5 

234:4 317:22 

lists 207:5 

literally 177:14 209:5 

258:16 

literature 8:3 

little 5:12 8:1,20 9:8 

11:2 24:8 36:5 37:13 

42:7 62:9 77:18 85:10 

95:20 104:1 108:10 

117:1 123:2,22 

124:19 130:2 132:22 

139:16 148:20 153:15 

159:5 162:12 166:20 

168:17,20 169:7,21 

170:3,9 171:3 185:3 

186:1 199:10 201:2 

205:11 210:5 213:6 

224:5 258:12 268:18 

286:1 289:2 291:3 

292:22 295:10 298:14 

301:2 302:9,13,14 

303:13 307:4 309:21 

310:11 311:14 313:2 

322:7,8 336:19 

342:10 344:14 360:18 

363:21 365:6 

live 83:5 

livelihood 76:9 

livelihoods 346:9 

livestock 3:2 5:16 6:18 

8:21 9:13 10:11 14:17 

14:20 15:15 18:12,17 

19:5,10 20:2,9,15,22 

24:14,14 77:10 83:14 

152:1 154:7 207:14 

363:8,15,17 365:2,3 

367:7,10,11 

living 36:11 123:21 

loading 277:8 278:5 

loads 9:15 

locality 164:9 

location 34:16 48:5 

locations 31:16 164:17 

187:22 

logic 138:15 223:22 

long 73:3 140:19 141:6 

153:1 182:16 191:2 

202:19 208:5 218:19 

234:9 235:16 259:1 

288:2 301:6 305:17 

312:18 

long- 168:14 249:10 

long-term 163:22 

170:22 171:10,18,22 

189:10,11 196:14 

213:14 317:6 

longer 52:7 111:10 

123:21 168:13 171:14 

171:20 198:16 200:13 

237:14 282:14 294:22 

300:21 301:2 

look 15:21 16:17 17:11 

17:13 18:3 27:16,18 

31:11 37:18 40:3 

51:15 82:5 99:8 

100:11,14 103:5 

104:6,8 107:18 

116:17 124:17 126:10 

142:11 145:6 157:13 

159:18 163:16 165:3 

171:21 181:2 193:1 

194:18 196:19,20 

202:7 203:18 204:18 

211:1,8 219:10 230:6 

232:20 249:10 260:21 

262:17 271:10 293:8 

295:15 297:16 298:4 

306:15 311:13 312:9 

312:17 326:8,18 

329:18 342:12,13 

348:16,20 368:11 

looked 41:2,19 43:15 

98:10 100:13 103:15 

107:20 135:13 196:10 

196:19 213:21 268:9 

286:21 324:16 

looking 5:18 15:21 

17:17 35:12 58:2 

90:11 105:4 120:15 

121:7 122:18 139:22 

163:3 194:3 222:14 

222:15 229:3 238:17 

241:11 245:12 257:15 

266:3 286:7 304:8 

308:3,14 309:12 

310:15 324:1 360:8 

360:15 367:10 

looks 153:11 165:6 

225:17 263:9 273:4 

302:15 367:1 

lose 73:7 

lost 148:16 287:3 

lot 22:13 33:15 37:1,17 

68:17 83:5 114:17 

125:20 142:6 153:22 

162:21 170:5 184:22 

199:5 208:4,13 

213:21 216:12 219:1 

221:2,15 223:15 

231:3 254:1 261:9 

266:3 271:8 283:6 

292:6 297:6 305:9 

318:10 320:20 328:14 

344:21 347:2 362:17 

365:22 367:3 

lots 6:1 136:16 185:4 

240:16 338:12 

loud 343:11 344:1,6 

love 79:8 128:1 234:17 

237:22 

loves 206:17 262:3 

low 58:5 206:19 237:12 

306:8 317:6 

lower 31:13 180:6 

191:10 206:20 261:17 

306:5,6 

lucky 56:4 

lump 139:15 265:11 

318:1 

lumping 136:7 

lunch 247:4 

M

Madison 1:9 

magic 151:4 

magnesium 3:2,13 4:17 

5:20,22 6:12 121:15 

121:16 193:5,7 

331:16,17 332:3,12 

362:7,20 363:11 

magnitude 325:20 

329:19 

main 69:19 222:3 

maintain 30:10 

maintained 199:19 

maintaining 77:2 

331:21 

maintenance 14:8 

major 27:4 34:15 126:1 

220:19,21 238:9 

251:1 322:15 335:15 

majority 91:16,17 97:17 

144:2 148:3 230:9,19 

350:4 

maker 353:13 354:8,19 

making 26:7 40:8 78:3 

78:3,4,6,13 84:6 

128:12 185:12 187:3 

236:19 281:18 287:9 

349:18 364:13 

Malic 118:21,22 

malt 219:22 220:1,5 

mammals 67:19 

managed 286:15 290:8 

management 29:13,15 

42:22 128:5 248:5 

251:12 259:20 266:10 

267:17 289:21 291:8 

312:7 316:1 321:12 

Manager 2:5 

manipulation 142:6 

manual 365:13 

manufacture 12:22 

15:1 117:18 237:5 

manufactured 40:16 

94:2 121:22 143:1 

147:5 154:2,4 

manufacturer 72:18 

227:11 236:19 240:12 

243:6 300:3,9,12 

306:4 310:12,14,22 

311:8 

manufacturers 57:21 

58:17,19 112:21 

117:2 143:8 148:22 

151:16 216:11 227:12 

303:11 311:12,17 

manufacturing 186:16 

217:12 

manure 4:18 82:6,7 

197:4 336:9 362:8 

manuring 337:4 

March 11:11 119:14 

marginal 268:4 

marginally 325:14 

marine 143:13 145:7 

227:2 232:17 242:1,7 

242:10 246:9 364:15 

market 68:10 71:4 

72:12 75:22 79:3,13 

80:9 81:6,12 82:13 

83:22 151:17 214:4 

222:4 226:19 236:12 

240:22,22 241:2 

254:20 277:21 278:2 

286:16 322:1 323:13 

marketplace 137:8 

179:11 181:9 184:17 

186:15 

markets 253:11 

marks 62:22 63:2 

Markus 2:9 4:6 160:12 

185:9 

masks 134:13 

mass 84:20 196:19,21 

materialize 280:13 

materials 2:5 5:19 

11:14 16:11 27:13 

28:19 45:5,14 46:3 

57:5 70:22 71:11 74:4 

75:10 78:10 79:12 

82:20 83:1 84:4 97:4 

108:14 113:10 116:4 

120:10 127:12,16 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
387 

132:4 141:17 143:13 

143:15 145:7 152:12 

152:13 179:4 190:8 

205:22 211:12 227:2 

249:12,15 258:5 

265:10 278:22 299:6 

316:1 319:6 327:16 

330:13 335:14 337:1 

337:6,9 360:7 363:7,9 

363:13 364:15 365:10 

MATHEWS 2:5 90:16 

93:17 95:2 131:22 

269:17 

mating 321:16 

matter 106:21 205:14 

262:2 324:13 348:5 

368:19 

maturation 223:16 

maturity 300:22 

max 312:19 

meal 82:20,21 156:12 

180:20 251:17 

meals 18:19 

mean 17:19 36:2,7 

38:21 39:20 40:11 

42:9 48:11 72:4 74:20 

78:11 84:11,18 89:19 

90:22 92:11 94:6 

97:21 101:4 102:21 

124:12 125:14,16,21 

132:16,20 139:7,11 

140:18 142:1,2,3,7 

149:15 151:8,12 

157:19 173:5 191:16 

197:10 204:5 220:15 

229:2 234:8 235:10 

239:17,20 240:1 

253:16,17 254:16,18 

255:8 261:4 274:5 

303:5 306:4 307:6 

308:13 311:16 312:22 

317:12 329:1 350:20 

351:4 354:2 367:11 

meaning 95:18 107:21 

268:18 309:8 

means 76:6,10 79:2 

96:9 108:10 125:10 

173:6 

meant 114:3 230:14 

measure 126:6 166:6 

166:10 175:8 177:4 

178:3 181:17 243:4 

measured 167:8 

measurements 168:12 

meat 12:5 33:22 51:1 

71:5 72:10,12 75:21 

76:20,21 81:1 82:14 

83:21 87:11,12,15 

88:16 92:10 93:21 

94:2,5 97:8 99:1,2,10 

111:5 147:18,19 

217:11 

meats 68:6 233:12 

mechanical 145:18 

334:20 

mechanism 68:6 

176:15 192:14 201:4 

mechanisms 204:3 

media 145:20 

medical 10:8 12:1,13 

13:5 29:19,22 30:4,15 

medicine 12:13 

Mediterranean 164:13 

meet 19:6 147:4 157:15 

316:2 319:15 

meeting 1:5 5:4,15 

15:20 24:16 26:18 

58:16 69:12 92:1 

107:11 144:12 160:6 

168:8 216:16 218:7 

225:10 228:15 281:10 

299:3,10,20 306:21 

315:22 320:12 341:13 

360:10 366:15 367:3 

368:1,3 

meetings 141:4,5 

280:11 

meets 137:12 

member 78:9 161:11 

281:22 282:3 348:13 

members 30:22 46:20 

141:3 205:20 207:6 

307:5 365:20 367:1 

membership 69:15 

membrane 10:17 

mention 69:6 171:16 

185:14 210:9 347:8 

367:17 

mentioned 12:17 13:19 

42:12 43:11 45:8 

114:9 124:6 155:9 

167:8 185:18 196:13 

211:21 217:2,10 

282:17 292:7 315:1 

315:22 339:20 340:8 

367:16 

merge 115:5 

meritorious 11:13 

message 247:5 

met 1:8 137:2 

metabolite 203:7 

metabolites 202:18,18 

metal 227:16 245:12 

metals 143:18 227:6 

242:4 243:19 244:19 

246:2 

methionine 363:12 

method 23:21 77:14 

149:13 178:9 179:1 

183:4 240:6 337:2,4,8 

methodologies 177:11 

methodology 128:15 

179:4 

methods 15:7 16:17 

20:5,8,10,12 23:3,10 

78:15 127:7 137:12 

142:12 149:21 150:6 

150:20 151:11 152:14 

178:10 199:17 258:5 

279:8,13,16 320:11 

322:20 363:16 

Michelle 2:2 229:9 

286:4 287:12,13 

297:19 

Michelle's 297:21 

Michigan 2:9 161:9,14 

microbes 304:5 

microbial 10:15 42:21 

124:2 125:10 167:13 

169:2,8,10,22 170:6 

176:6,19 190:21 

202:5 203:1 

microbiologists 169:9 

micronutrients 265:20 

266:11 

microorganism 115:13 

123:7 130:12 

microorganisms 3:13 

42:14 118:14 123:1,4 

123:8,11,11,15,16,20 

124:7,9,14,19 126:12 

127:9 132:12 133:14 

138:4,16,18 139:10 

140:14 141:9 142:7 

173:8 174:15 175:6 

175:13,20 176:12 

177:1,3,9,16,17,19 

181:15 182:1 184:2 

187:17 189:2 190:20 

195:13 198:1 362:21 

Mid- 80:20 

midrange 223:18 

mike 8:7,8 212:9 337:21 

mild 25:19 

mildew 330:21 

milk 7:10,10 12:6 110:7 

215:15 

milking 11:15 

million 222:18 254:17 

255:10 344:19 

mind 5:9 18:3 126:20 

130:18,20 255:2 

288:1 329:11 

mine 14:2 43:1 128:2 

224:21 261:13 276:18 

mined 332:12 

mineral 14:13,16 15:2 

19:8 112:16 122:1 

135:5 213:10 214:15 

minerals 3:5,18 14:1,3 

14:4,6,13,20,21 15:9 

15:19 16:14 19:7 20:2 

20:9 135:21 136:3,8 

156:20 157:2,6 

207:18,20 208:1,18 

213:2,4 214:21 363:4 

363:13 

minimize 134:13 

312:10 

minimum 7:20 239:9 

minor 238:6 

minute 106:20 287:7 

minutes 156:2 312:19 

368:16 

misleading 180:12 

miso 241:19 246:6 

missed 137:16 

missing 106:15 

Missouri 80:21,22 

153:21 

mistaken 214:4 

mistakes 261:9 

misused 174:20 

mitigatable 34:22 

mitigate 47:7 111:6 

113:3 

mitigated 27:6 28:21 

32:9,10 34:18 47:3 

mitigating 113:5 

mixed 267:11 268:12 

327:13 

mixes 143:6 

mode 6:19 8:20,22 9:9 

10:2 35:18,18 36:22 

Modern 148:4 

modes 35:20 39:7 

modification 19:15,19 

22:20 23:7 107:14 

modified 21:6 23:18 

152:3 185:21 186:7 

186:21 187:9 

moisture 189:1 190:19 

233:9 333:21 

molecular 148:10 

195:12 315:1 

molecule 173:10 

180:17 181:5,10,13 

182:10,12,14,15 

183:14,22 186:18 

187:10 192:7,8 

194:18,20 195:5,9 

molecules 173:17,18 

Neal R. Gross and Co., Inc. 

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175:22 177:4 186:7 

192:15 201:3 203:17 

molluscicide 324:9 

moment 80:2 85:15 

87:21 147:16 360:12 

monies 346:11 

monitor 326:22 

monitoring 30:11 

321:15 

monograph 113:12,13 

113:18 

monomer 182:14 

monomers 182:16 

months 15:22 73:4 

191:6 291:8 293:11 

morning 24:18,22 

Mortensen 1:18 16:21 

17:9,18 22:17 42:17 

50:11 53:21 55:13 

61:13 64:12 66:17 

86:18 125:2 138:3 

139:19 152:22 202:11 

204:5 219:7 220:8 

221:10 224:12 229:16 

230:2,12,17 259:11 

263:17 264:16 265:13 

272:5,11 273:8 274:2 

274:5 275:2,5 276:2 

283:15 285:3 311:21 

324:7 329:7 350:13 

350:16 354:17 356:1 

359:17 

moth 323:1 

mother 286:12 

motion's 54:7 

motioned 272:4 275:21 

motions 51:14 105:5 

Mount 164:2,4,20,21 

167:21 188:20 

move 6:13 24:18 28:22 

32:12 50:1 62:18 66:7 

67:4 102:6 105:19 

110:4 112:8 114:12 

117:6 118:18 121:14 

122:22 128:18 135:3 

136:13 140:21 142:18 

145:5 147:14 151:10 

154:20 183:21 184:9 

184:21 187:19 200:15 

205:13 208:8,21 

215:2 223:10 233:5 

241:15 244:10 263:4 

264:6 265:5 272:1 

274:18 283:10 292:19 

298:6,16 313:16 

316:8 331:15 333:13 

334:14,22 344:19 

345:1 348:14 351:5 

354:13 355:3 356:22 

360:6 

moved 80:13 130:9 

288:4,18 291:2 297:3 

321:18 335:17 336:15 

movement 129:15 

moves 106:8 145:12 

288:11 296:13 

moving 8:11 11:20 14:1 

16:18 18:4 33:14 42:9 

112:1,2,6 119:20 

121:8 131:18 285:7 

317:20 321:10 323:9 

324:5 330:6 352:22 

360:10 

moxidectin 3:3 6:14 

8:15,16,17 9:8 10:4 

363:10 

MSD 229:12 

MSU 161:10 

mulch 4:5 154:14 

159:19 160:5 165:15 

165:15 166:9 173:10 

177:3 179:5 181:7 

183:2 188:8 191:5,20 

194:8 197:3,8,10 

278:11 304:2 305:13 

308:16 361:9 

mulches 159:10,13,20 

162:13 167:15 168:1 

170:16,20 171:19 

185:13 196:11,20 

multiple 34:12 56:5 

318:5 

Multitasking 355:12 

multitude 216:4 

murky 262:4 

muscle 12:12 13:4 

mushroom 315:21 

mustard 248:12,15 

251:17 

mutagenesis 365:1,4 

N

name 63:18 265:14 

names 181:12 233:14 

nano 28:14 38:6,19 

48:16 

nanoparticle 37:7 

nanoparticles 37:10 

nanotechnology 28:4,8 

29:8,11 34:21 43:14 

43:20 47:15 

Narayan 2:9 4:7 161:8 

172:5,8 185:22 186:2 

188:6 190:3,10 192:5 

194:2,11,16 199:10 

201:1 203:3 204:6,12 

205:4 

narrow 142:9 252:6,6,9 

252:22 317:21 362:3 

narrower 31:20 320:1 

narrowing 44:11,11,12 

102:17 

nasty 45:5 

nation 36:14 

national 1:3 2:2,3,4,5,5 

2:7 8:18 19:2 26:11 

28:19 30:10 35:21 

56:7,12,21 57:10 58:1 

65:13 68:14 87:13,14 

95:10,16 96:22 97:5 

98:2 100:16 101:2 

116:22 119:1 120:18 

159:15 161:13 210:4 

235:20 260:17 264:7 

269:8,21 285:21 

315:10,12 334:7 

340:21 343:19 

Nations 33:21 

native 229:5,5 

natural 15:5 16:13 

119:7 141:18 148:11 

158:6 251:18 278:22 

305:2 345:13 

naturally 14:7 120:7 

134:2 

nature 27:2 122:2 

162:18 

near 238:12 254:19 

neat 183:6 

necessarily 48:17 79:1 

96:11 100:5 125:7 

234:9 287:6 311:19 

315:13 342:13 

necessary 34:6 49:8 

78:13 92:7 148:12 

156:18 158:6 218:12 

277:16 

necessity 16:5 17:15 

32:15,18,22 149:1 

need 16:5 19:9 34:3,12 

39:7 43:8 44:9,10 

52:4 54:6 55:21,22 

57:9 60:4 65:16 75:4 

87:8 89:2 93:2 102:1 

103:11 105:22 109:6 

110:19 123:6 126:14 

127:18 129:10 131:6 

131:9 136:20 137:18 

139:13 142:9 148:7 

153:15 173:14 175:1 

175:14 177:2 179:18 

179:19 191:4,12 

193:9,16,19 195:12 

196:3,13,16,18 206:6 

206:10 208:13 209:2 

210:11 223:3 230:6 

232:2 234:22 236:9 

236:10 244:3 245:4 

253:1 254:15 256:1 

256:13 260:11 262:22 

278:20 280:20,20 

292:21 299:7,21 

300:21 321:3 329:13 

348:2,22 367:11 

needed 32:19 136:22 

137:3 171:21 193:15 

195:5 232:9 254:19 

268:21 305:6 307:20 

330:19 333:10 

needing 7:3 124:18 

needs 18:21 19:2 80:14 

91:2 109:13 125:8 

151:1 178:2 257:19 

293:6 352:18 365:6 

negate 34:3 

neglected 150:14 

neither 366:3 

nematocidal 249:21 

250:9 

nematocide 249:17 

nematode 250:2,5 

nematodes 248:6 250:1 

neuropathological

250:19 

neutralizing 109:11 

155:5 

never 78:5 96:17 104:2 

184:8 320:18 358:5 

new 11:12 31:6 70:16 

95:1 105:7 109:19 

110:22 122:4,6 

155:14 204:18 217:14 

221:15 266:17 268:13 

281:22 282:3 287:17 

288:17 291:21 309:13 

316:5 318:9 360:7 

367:1 

newer 310:21 

newly 249:4 

newsletter 253:15 

newspaper 301:5 303:3 

303:9,18,18 304:8 

306:16,19 308:2 

309:2,11,15 312:18 

newspapers 303:6,21 

nice 223:10 367:12 

nicely 331:12 366:15 

niche 151:17 

nick 306:7 

nicotine 340:11,12 

niggling 37:5,14 

night 125:4 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
389 

nine 51:5 368:16 

nitrates 224:8 

nitrogen 82:8 

no- 166:8 

no-mulch 165:17,18 

168:2,19 170:2 171:4 

no-mulches 169:19 

NOC 232:1 

noises 181:1 

nomenclature 269:10 

269:19 270:16 

non 152:16 

non- 57:7 60:22 67:8 

74:2,8 119:21 208:7 

289:22 300:12 332:4 

non-agricultural 56:8 

non-biodegradable

194:8 

non-controversial

211:14 

non-food 322:5 

non-GMO 22:3 127:5 

non-heme 157:20,22 

non-organic 71:11 

79:21 80:8 222:9 

258:10,13 286:11 

289:5,11,20 290:7 

non-organically 91:11 

290:8 

non-porous 32:5 

non-substantive 108:5 

non-synthetic 56:8 

57:8 61:1 68:21 

109:18 117:15 119:1 

120:2 218:3,14,16 

332:2,11 337:19 

non-target 319:12 

non-vegetative 290:4 

nonsensical 292:13 

NOP 11:14 14:19 18:10 

19:21 20:6 21:12 

43:13 56:15 57:11 

103:13 128:9 174:12 

247:16,21 269:10 

296:14 308:17 360:16 

368:3 

NOP's 24:3 56:21 57:4 

normal 315:5 

north 164:5 346:8 

Northwest 333:5 

nos 360:5 

NOSB 2:2 4:20 5:4 6:22 

7:2 11:11 15:12 28:16 

115:18,21 119:19 

130:22 134:9 141:4 

152:11 269:10 285:20 

316:2 

note 13:11 15:18 71:19 

126:18 129:18 150:14 

213:8 232:22 235:3 

253:14 280:17 313:5 

336:11 341:22 342:5 

352:5 357:6 

noted 16:4,7 19:1 29:11 

30:2 32:20 35:10 46:7 

46:20,21 112:22 

115:17 119:17 120:13 

122:13 127:4 134:14 

134:22 136:21 146:16 

147:11 148:21 149:1 

152:1 159:22 262:18 

278:3 292:5 319:9 

322:14 336:12 353:3 

notes 117:7,16 122:3 

133:16 211:18 250:12 

notice 7:16 116:9 

126:11 168:7 219:1 

noticed 203:4 281:2 

339:3 

noting 15:14 16:2,9 

119:21 149:4,5 215:7 

215:10,14 227:19 

notion 311:22 

nuance 84:5 345:12 

nuanced 84:2 342:7 

number 15:11 16:1 

67:18 93:18 115:3 

119:17 120:17 134:14 

137:1 146:14,16 

147:2 148:21 159:7 

173:22 181:11 215:6 

215:9 220:9 277:11 

279:10 292:9 326:1 

327:7 340:8 

numbers 209:15 255:1 

255:7 267:16 

numerous 101:11,11 

146:17 299:14,19 

300:14 

nurseries 254:12 

nursery 248:9 249:7,8 

252:12,13,20 253:3,8 

256:17,22 257:19 

259:20 260:5,11 

261:4,12,17,21 

nut 146:6 261:16 

nutrient 3:18 135:7,16 

135:20 136:3,8 

147:18 148:12 149:8 

156:19 157:1,5 

207:17,19 208:1 

212:22 213:2,3,9 

214:14,15,21 363:3 

nutrients 16:9 18:20 

158:11 178:2 

nutrition 15:17 16:6 

nutritional 19:6 112:17 

123:19 155:9 156:15 

208:2 212:18 

nuts 290:4 

O

OAKLEY 1:19 37:21 

38:3 48:11 50:15 

53:12 55:4 59:19 61:4 

62:6 63:3,19 64:3 

65:16 66:3,21 82:19 

86:22 88:21 89:17 

94:20 97:13 99:12 

111:19 126:3 130:18 

141:12 144:19 154:19 

187:20 190:7 191:16 

214:9 223:14 228:8 

229:2 234:6 240:1 

244:5 245:10,21 

253:16 255:15 258:19 

262:1 263:21 264:20 

269:1 270:13 272:15 

273:12 275:9 276:6 

279:4 281:6,9,12 

282:1,6,10 283:19 

284:16 287:22 306:14 

312:16 327:18 329:1 

330:8 331:17 341:19 

345:8 349:14 350:3 

353:22 354:11 355:4 

355:14 359:8 361:18 

366:22 

OAS 340:7 

oat 156:12,12 

obfuscate 33:16 

object 106:4,5 116:7 

298:11 

objected 208:16 214:22 

objections 106:7 316:3 

obliged 132:4 

obtain 49:5 245:13 

obvious 327:11 

obviously 123:11 

151:12 302:20 333:8 

346:18 

occupational 334:12 

occurred 236:2 

occurring 14:7 134:2 

243:17 

occurs 119:7 158:5 

188:13 

ocean 200:21 

ocular 45:13 

odor 145:21 

offer 22:1 158:8 232:5 

256:14 308:21 364:1 

offered 292:10 

offers 248:4 

Official 2:7 18:15 

offsetting 15:16 

OFPA 30:1 117:13 

137:13 244:16,20 

245:3 316:3 331:10 

oftentimes 165:11 

oil 4:2 194:8,13 195:21 

196:6 226:6,8 229:11 

229:12,21 230:9 

248:11,15 362:12 

oils 4:15 18:19 133:22 

147:21 158:4 230:22 

315:11,14 317:21,22 

318:4,10,11,13,18,20 

318:22 319:1,1,3,10 

319:20 320:5,12,21 

321:6 362:2,2 

oligomer 174:3 

olive 113:1 

omega-3 226:10,17 

OMRI 20:11,16 211:2 

321:21 

onboard 114:13 129:4 

317:5 

once 10:18 39:2 43:6 

44:14 52:16 57:4 60:3 

74:20 98:3 104:10 

176:5 221:7 

one's 156:1 

one- 42:14 

one-off 259:19 

ones 21:21 32:2 112:13 

171:17 209:16 271:13 

308:6 342:7 

onwards 285:7 

open 37:21 38:1 59:10 

71:16 96:16 97:7 99:3 

100:19 108:11 137:6 

139:17 159:19 172:6 

252:11 253:3 279:2 

286:7 

open-minded 270:9 

opened 95:17 

opening 93:9 97:10 

opera 360:9 

operating 176:16 

operation 82:7 

operations 16:2 75:2 

78:14,14 81:19 82:10 

119:18 122:12 134:15 

208:15 239:1 

opinion 33:16,17 35:4 

40:21 214:20 316:21 

352:18 

opioids 343:20 

opportunities 151:9,20 

224:1 279:22 280:18 

opportunity 17:12 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
390 

54:20 71:4 91:22 99:7 

103:1 104:21 108:2 

119:14 160:9 226:18 

280:12,19 

oppose 120:19 

opposed 91:22 92:16 

138:17 215:13 334:5 

opposing 6:10 136:6 

opposite 41:15 

opposition 157:4 

226:20 

option 251:18 

optional 156:8 

options 11:16 57:12 

208:20 227:22 279:18 

orally 12:15 

orange 4:3 84:21 233:6 

233:8,14,18,18,22 

234:2,4 237:2 238:20 

239:2,7,10 241:5,13 

362:13 

oranges 236:2,3,11 

238:5 240:16 

orchard 258:9 261:13 

orchards 236:6 331:6 

order 12:4 17:19 51:8 

54:13,13 60:15 72:22 

79:13 84:20 109:14 

185:15 192:18 278:8 

291:15 337:2 348:22 

353:16 357:21 

orders 325:20 329:19 

organically 67:9 68:10 

69:5 223:2 238:2 

254:10 256:14 286:15 

346:13 

organics 12:19 271:18 

organism 187:10,14 

organisms 20:20 23:18 

42:1 123:9 124:4 

125:5 132:15 139:22 

140:9 153:7 166:11 

185:21 198:21 199:2 

199:4 200:11 326:6 

organization 30:15 

33:21 122:13 146:20 

148:20 149:3 156:6 

215:13 334:15 

organizational 138:15 

161:21 

organizationally

139:20 

organizations 16:7 

21:15 120:19 146:18 

161:19 221:18 251:6 

origin 146:4 

original 8:2,3 95:5 

132:11 134:5 149:5 

236:15 247:20 269:2 

288:9 289:13 356:18 

357:13 

originally 7:9 95:6 

110:7 139:5 252:11 

353:9 

originate 183:14 

origins 103:7 

osmogens 45:12 

OSP's 215:8 

OSPs 119:18 143:10 

148:22 217:10 

OTA 56:11 

Otto 77:21 

outbreak 39:11 

outcome 271:12 326:3 

340:6 368:3 

outlets 83:15 

outside 221:7 280:13 

outstanding 248:22 

249:1 

over-harvesting 242:5 

overall 172:19 218:10 

222:1 238:8 

overcome 278:8,10 

overheating 278:10 

overlap 303:15 

overlook 137:19 

overnight 195:7 

overseas 154:2 

oversight 360:17 

overwhelmingly 11:7 

110:1 315:19 

owner 57:16 

oxidate 173:22 

oxidation 176:8 

oxidative 35:19 

oxidized 176:7 192:16 

358:2 

oxidizes 158:4 

oxidizing 10:20 

oxo 179:12 

oxygen 190:18 210:8 

315:8 

oxygenated 146:13 

P

P-R-O-C-E-E-D-I-N-G-S

5:1 

p.m 205:15,16 348:6,7 

368:20 

Pacific 4:4 241:16,17 

246:13 333:4 362:14 

packaged 219:10 

packaging 161:15 

packet 314:6 355:1 

packing 113:1 

page 20:15 209:15 

270:1 288:16,17,18 

296:4,5 

pages 297:6 

pair 164:19 217:5 

panel 259:6 364:16 

panels 172:5 

paper 4:12 165:10,10 

165:11,13 166:8 

180:16 185:12,18 

187:15 197:4 298:17 

298:17,18 299:15,21 

299:22 300:3,9,10,13 

300:15 301:4,4,13,16 

302:1 303:10,17 

304:9 305:3,7 306:6,9 

306:17 307:2,8 

310:18 311:1 312:5 

312:21 361:1 

papers 33:20 34:10 

42:13 299:17 

paragraph 230:3 

paragraphs 288:4,6 

parameters 167:12 

168:22 

paramount 39:8 

parasites 6:21 

parasitic 250:2 

parasiticide 3:3,3 6:18 

9:3,15 363:9 

parasiticides 6:14 9:11 

parasitoids 319:17 

320:16 

parentheses 62:21,22 

63:2,2 65:6 156:6 

parlors 11:15 

part 7:12 27:22 44:7 

69:21 76:7 78:12 

93:10 98:16 102:20 

115:20 119:16 121:1 

124:6 129:22 133:3 

174:17 175:13 183:8 

193:11 198:7 203:3 

244:20 251:3 259:19 

260:20 301:16,21 

302:3 347:15,16 

360:9,14 363:21 

365:4,5,6 366:3 

partial 24:1 

particles 48:16 

particular 95:19 124:16 

135:18 150:7,16 

174:16 214:3 318:17 

324:14 341:12 367:2 

particularly 28:3 29:21 

31:3 33:2 35:11 45:2 

45:6 46:11 97:9 

121:11 128:11 166:1 

226:10 227:5 230:10 

237:16 243:15 

parts 222:17 

party 40:12 98:2 179:21 

302:9,16 

pass 150:13 201:16 

349:15 350:6 

passed 130:22 228:14 

passes 54:2 61:18,19 

64:18 67:2 87:4 

145:19 264:5 272:22 

275:18 284:8 356:6 

360:5 

passing 103:17 

passion 368:8 

pastas 233:10 

paste 295:15 

pasted 288:22 

pasture 14:14 17:15,20 

Patagonia 335:13 

patent 57:17 237:4 

238:20 239:12 

patents 27:10 

path 124:20 133:5 

285:16 

pathogen 30:7 

pathogenic 248:6 

patience 85:17 360:4 

PATTILLO 2:5 

Paul 2:4 152:7 225:8 

pause 87:21 105:11 

155:18 

pay 40:7 115:1 151:19 

271:14 296:17 

PBAT 182:15 192:8 

pea 232:6 233:1 

pectin 217:9 232:7 

peel 233:18 

pelleted 325:7 

pending 150:15 239:12 

penetrate 10:16 

people 5:6 10:2 34:4 

35:14 37:17 44:15 

45:9 74:22 85:6 92:15 

96:10 102:5 103:1 

118:16 136:6 139:2 

151:19 160:7 179:14 

190:15 191:11 208:21 

214:21 216:16 218:15 

221:3 237:22 238:7,9 

240:8,9 241:4 244:17 

245:16 255:14 271:14 

283:4 286:2 305:10 

306:6 310:2 311:3 

314:13 317:2,12,13 

317:14 325:11 327:1 

331:13,20 346:8 

350:17 364:3 367:15 

people's 158:11 261:13 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
391 

peracetic 3:19 10:6,7 

10:10,15,18,22 11:8,9 

27:19 209:21 210:16 

211:13 363:4,11 

percent 71:8,9 92:9,13 

92:13 101:19 111:9 

111:13 113:9,14,16 

113:19,20,21 159:16 

178:14 181:20 184:3 

184:7 193:19,20,21 

195:4 202:13 206:22 

229:20 254:17 301:3 

306:3,4 307:7,8 

308:13,18 333:4 

percentage 71:11 182:3 

243:18 254:2 308:17 

313:2 

percentages 306:1 

313:4 

perennial 255:4 290:3 

perennials 261:3 

perfect 52:9 154:22 

172:11 235:8 324:2 

perfectly 102:22 184:1 

307:15 357:14 

perform 267:17 

performance 17:5 

performed 266:18 

period 12:5,7 178:12 

312:5 

periods 58:14 115:18 

171:14 

perishable 84:18,19,19 

perlite 3:14 133:15,18 

133:19 362:21 

permeability 10:20 

permit 251:7 

peroxide 3:18 4:14 

206:2,11,13,17 210:1 

313:17 314:6,9,16,21 

315:4,7,14,15,20 

316:8 362:1,6 363:3 

363:11 

peroxides 313:19 

peroxyacetic 10:6 

peroxyacetic/peracetic

3:4 8:11 

person 56:4 98:7,8 

279:5 

personal 102:4 121:18 

134:12 217:12 316:21 

344:21 

personally 47:17 62:10 

74:20 96:3 138:22 

perspective 49:3 142:1 

325:9 367:21 

pertains 249:4 

pertinence 346:5 

pest 251:18,22 312:6 

pesticide 315:6 

pesticides 13:11 

210:19 211:5 222:2 

230:8 232:8 234:1 

243:14 248:13 334:8 

pests 340:3 

petition 26:10,12,18 

48:14 56:6,11,13,14 

57:16 85:11 88:9,11 

89:5,7 90:11,17 91:5 

91:6,8 93:8,18,19 

94:10,13,14 96:2,8,10 

97:14 99:14 101:21 

102:11 247:11,20 

248:3 265:6 268:11 

280:7 341:9 357:4,7 

357:11,19 

petitioned 7:2 26:3 35:9 

45:2 54:5 55:14 59:4 

62:18 65:3,14 67:7 

88:6 89:18,21,22 

90:20 93:5,12 94:8 

95:1,11,13 96:9,14,22 

97:18 98:1 99:13,21 

99:21,22 100:2 

101:20 103:13,17,22 

104:14,16 105:6 

139:3 235:19 267:4 

273:2 275:20 277:3,6 

298:19 342:18 357:2 

357:4,9 359:3 

petitioner 27:12 31:18 

32:21 40:20 41:4 47:1 

47:6 49:2 100:1 

216:14 234:14 235:4 

235:22 236:15 242:13 

248:3 269:2 277:14 

280:4,8 299:22 300:2 

305:10 

petitioner's 38:11 

petitioning 91:7,10 

102:13 269:3 

petitions 98:5 247:14 

247:16 

petroleum 120:4 

183:16 195:10 304:12 

318:11 319:20 

petroleum-based 304:3 

pH 108:21 109:9,12 

110:12 119:4 211:22 

212:17 217:6,9 268:6 

332:19 333:9,11 

Ph.D 2:4,5,6 160:20 

phased 157:12 

PhD 2:9,9 

pheromone 323:1 

pheromones 4:15 

321:10,13,21 322:1 

322:19,22 323:8,13 

362:4 

philosophic 78:20 

phone 266:20 

phonetic 63:13 

phosphate 3:20 4:16 

212:11,12,17,22 

213:7,9,13,16 313:21 

314:2,7 324:6,8,22 

325:13 326:12,16 

327:5,10,14,16 328:4 

328:7 330:1 362:5 

363:5 

phosphates 213:19,20 

216:5,6,10 

phosphorus 14:12 

photos 197:9 

physical 137:12 166:6 

167:12 168:22 200:10 

physicist 161:1 

physics 160:13 

physiologically 80:14 

phytosanitary 248:8 

249:7 252:16 257:19 

260:16,17 

phytotoxic 319:3 

pick 151:15 204:15 

picked 148:19 199:22 

pickling 147:19 

picture 176:17 201:12 

pictures 196:9 

piece 33:15 46:1 52:17 

52:18,19 145:8 

pieces 198:6,8,21 

pig 231:20 

pigments 192:21 

Pittsburgh 360:10 

368:12 

PLA 186:17 

place 73:22 74:5 196:6 

197:12 227:9 261:4 

262:14 318:20 332:22 

placed 235:19 336:22 

placeholder 235:3 

places 42:9 122:3 154:3 

180:1 297:17 362:3 

placing 69:3 74:17 

plan 246:12 259:20 

317:3 319:16 340:7 

planet 5:10 

plans 122:10 146:17 

215:8 

plant 4:12 113:4 163:14 

165:21 183:15 194:21 

195:4,11 236:6 

242:20 255:8,10 

256:2 259:2 266:11 

277:7 279:17 286:6 

286:12,13,18,19 

289:11,11,17 290:19 

290:19,20 301:1 

302:10,21 314:20 

319:2,8 330:9 

plant-based 318:11,13 

planted 261:12 

planting 256:6 258:7 

259:10 286:11,13 

287:9 289:6,6,7,8,17 

289:20 290:2,7,12,17 

291:6 293:1 333:19 

plants 45:10 195:1 

222:18,19 242:1 

246:9 249:7 266:12 

277:4 290:1,3 300:20 

302:14 

plastic 162:13,14,16,17 

162:20,20,22 163:4 

163:22 165:5,5,15 

166:13,18 167:1 

168:18 171:8 183:19 

189:13,15,17,18 

191:19 194:8 195:20 

197:14,17,18,20,22 

198:5,19,20 200:11 

200:20 202:20 277:7 

278:5,6,11 283:6 

312:8,13 

plastic-based 192:1 

plastics 163:17 165:4 

165:21 166:11 169:18 

170:1,3,10 180:19 

185:20 189:10 196:8 

197:15 

play 175:10 179:4 191:7 

198:2 

playing 311:15 331:6 

plays 10:19 

please 60:17 312:17 

337:22 

pleasure 161:6 

plenty 133:9 282:20 

plugs 332:16 

plus 92:13 181:21 

254:17 

point 22:8 33:17 44:22 

45:16 46:17 51:8 

54:15 60:15 69:13 

71:16 74:14 76:1,5 

77:6 78:7 79:5,18 

80:19 86:6 89:20 97:2 

97:6 101:18,22 

115:14 116:7,13 

129:14 130:10 132:5 

132:11 137:7 144:13 

153:2 158:13 171:10 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
392 

180:2 199:3 218:7 

219:9 237:13 240:8 

241:6 244:16 245:6 

247:15 257:1 258:4 

259:12,17 267:19 

269:16 280:13 287:4 

291:14 320:20 322:2 

322:9 324:3 328:1,4 

329:2 332:4 334:17 

342:9 346:10 348:22 

351:6 353:16 357:21 

359:5 

point's 255:3 

pointed 9:19 13:16 

17:14 49:7 58:8 

274:11 301:15 

pointer 167:17,18,19 

pointing 82:2 293:5 

points 43:20 54:12 

102:18 130:21 210:20 

259:4 270:2 314:14 

314:14 345:9 

poisoning 340:12 

policies 131:5 

policy 365:12 

pollinators 319:18 

320:16 

pollution 13:1 162:18 

poly-based 185:13 

polyester 300:16,17 

304:13 

polyethylene 162:17,19 

163:1,5 165:5,18 

166:9 168:2,3,18 

169:19 170:2,17 

171:4 180:17,21 

190:13,13 191:13 

polymer 173:17,18 

174:3 185:16 190:14 

191:2 304:14,22 

polymers 167:2 187:18 

198:2 

polypropylene 180:21 

pondering 125:3 

Ponzu 241:19 

pool 184:17 

poor 16:13 346:8 

population 202:5 

population-based

156:15 

populations 157:16 

320:22 

pore 146:2 

pork 81:6 

porous 145:20 

portion 200:13 292:19 

316:13 

pose 38:14 199:9 

posed 96:21 172:10 

227:14,22 

position 151:2 

positive 73:11 270:10 

possess 249:16 250:7 

possible 47:16 59:21 

100:16,19 109:18 

144:13 146:11 171:13 

195:6 229:7 245:17 

281:15 319:13 

possibly 291:4 301:8 

322:11 360:15 

post 160:18 360:12 

post-harvest 31:22 

109:10 

pot 301:1,3 303:10 

306:6 

potassium 3:14,19,20 

4:16 135:3,4 146:10 

211:16,19,20 212:11 

212:12,17,19,21 

213:4,7,8,13 330:6,8 

361:4 362:6,21 363:4 

363:5 

potatoes 187:4 339:22 

potent 13:3 

potential 11:2 29:14 

31:9 34:19 46:21 48:8 

134:10 218:20 244:1 

249:16 255:19 303:15 

312:10 325:4 334:11 

potentially 28:21 34:22 

47:1 70:4 74:4,11 

96:16 97:7 129:2 

157:11,13 167:14 

190:2 200:19 242:16 

259:6 303:16 

pots 4:12 298:17,18 

299:5,15,21 300:1,3,9 

300:13,15,20,21 

303:17 305:7 306:9 

312:5 361:1 

poultry 14:10 26:5 32:7 

36:20 

powder 4:2 67:22 70:14 

75:15 77:13,18 

110:14 221:13 226:4 

237:8 332:18 362:11 

powdery 330:21 

power 314:10 

practical 308:20 

practice 57:20 109:7 

practices 78:22 82:7 

249:12 266:10 267:17 

268:18,20 312:11 

324:10 332:22 

pre-plant 247:19 

pre-processing 149:5 

pre-treating 334:2 

preamble 336:21 

precautionary 39:1 

40:2 

precedent 105:7 257:5 

269:7 347:4 

precipitates 37:10 

precipitating 37:11 

preclude 102:12 251:13 

precludes 82:22 

precluding 312:12 

precursor 73:18 219:14 

predators 319:17 

320:16 321:5 

preface 77:20 

prefer 46:9 300:19 

preference 69:4 353:2 

preferences 131:6 

preferred 144:17 

231:18 

premixes 14:16 

prep 237:19,19 

prepare 25:6 

prepared 155:4 360:21 

prepares 225:9 

preps 113:1 155:13 

presence 20:4 148:22 

215:7 

present 1:11 2:1,8 11:4 

127:17 154:17 173:8 

174:15 188:8 265:6,8 

290:12 319:18 320:17 

presentation 166:4 

172:16 237:8 

presentations 158:22 

312:2 

presented 29:16 237:7 

364:11 

presenting 360:13 

preservative 149:6 

preservatives 114:21 

preserved 186:13 

296:18 

presiding 1:10 

press 56:1 180:19 

pressing 30:8 269:6 

pressure 42:2 

pretty 19:9 36:2,6,21 

40:17 41:10,10,13 

59:10,14 78:4 81:19 

95:4 114:16,18 115:8 

124:5 156:14 159:8 

201:8 220:9 224:16 

255:20 256:5,14 

299:3 306:19 323:8 

329:17 330:17 333:1 

343:1 353:1 

prevent 6:3 16:10 45:17 

70:18 189:18 217:22 

preventing 47:8 232:3 

238:4,4 

previous 28:16 29:3 

88:6 90:3 115:18 

193:6 238:18 285:15 

332:6 

previously 29:12 

price 186:11 

priced 186:15 

primarily 67:16,17 

69:15 98:10 134:2 

226:9,13 234:13,13 

241:20 330:21 

primary 68:21 202:17 

203:7 354:6 

primates 148:13 

principal 120:20 231:21 

principle 40:2 

printout 314:5 

prior 7:20 34:6 

priorities 225:10,22 

365:8 

priority 258:20 367:14 

proactive 150:19 151:2 

probably 31:12 36:1,3,4 

46:3 51:22 67:20 73:4 

117:1 125:18,22 

126:9,13 139:4 

167:18 186:1,20 

188:16 207:4 214:17 

219:22 223:19 238:7 

242:22 243:18 256:21 

261:11 307:4 313:7 

342:1 347:10 349:2 

365:13 367:11 

problem 38:12,14 59:16 

72:6 97:9,10 130:22 

174:9 199:9 200:7 

224:21 328:18 

problematic 58:1 108:8 

137:15 139:16 187:2 

problems 126:1 162:18 

278:8 320:4 332:16 

procedural 341:7 

procedure 365:13 

proceed 160:4 273:22 

298:4 299:9 313:9 

341:15 354:5 

process 32:7 39:16 

57:17 78:6 80:11 

92:17 95:14 98:17 

101:18 102:8,21 

107:9 119:16 120:9 

129:14 130:7 131:18 

143:2 159:13 176:6,7 

176:13,15,19 177:6 

177:19 184:20 186:16 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
393 

186:19 212:1 235:8 

235:16 237:4 242:3 

248:8 261:14,18 

262:2,3 270:18 274:7 

278:17 310:15 351:19 

368:3 

processed 67:10 71:7 

91:13 157:14 218:12 

223:17 

processes 122:16 

148:5 149:20 151:18 

171:12 173:11 186:6 

274:7 

processing 10:12 26:4 

26:8 34:1 35:8 45:10 

51:2 68:20 108:19 

110:13 112:12 121:18 

133:19,20 135:10 

145:17 147:22 148:16 

212:3 217:11 219:13 

239:1 

processor 40:17 81:10 

processors 35:17 

207:9 

produce 32:7 33:2,7 

36:20 45:14 46:6 68:6 

72:10 77:15 83:14 

109:3 110:15 189:19 

222:9 237:9 239:1,9 

240:5 257:16 258:16 

267:13 280:14,15 

290:4 324:19 336:20 

344:7 

produced 15:3 20:12 

23:6,7,9,17 67:9 

68:10 75:19 76:11 

77:11 91:11 106:14 

108:18 110:8 119:8 

119:10 120:4,6 

137:11 152:3 226:8 

229:21 238:20 340:3 

producer 80:5,7 81:1 

255:16 

producer/processor

80:5 

producers 6:7 7:3 8:22 

9:13 11:16 16:4 81:4 

81:12 225:5 251:17 

364:1 367:7 

produces 339:10 

producing 13:15 57:12 

68:8 72:19 

product 27:10 58:3 

67:9,10 68:22 70:19 

71:6 72:10 76:18 77:1 

77:15 81:8 83:10,10 

84:18 92:10,14 94:5 

103:6 111:9,16 

114:20 118:15 134:15 

149:1 158:5 179:17 

181:10 186:14 187:8 

190:9 196:2,2,5 210:7 

213:1,14 219:15,18 

220:2,14 221:4 227:8 

227:11,13 229:14 

234:15 236:19 237:2 

237:2,13,14 239:16 

277:4 278:14 282:21 

283:7 300:5 307:7 

310:21 328:11,12 

329:10 333:2 

production 4:12 10:11 

14:9 15:7 16:8,16 

19:15 22:20,21 34:21 

56:15 70:15 73:1,5 

74:3,7 79:2 94:3 

104:12 120:11 121:19 

121:21 125:15 144:3 

144:7 148:3,5 152:13 

152:13 153:8 165:22 

170:16 207:10 225:19 

230:9 232:3,13 239:9 

247:18 248:10 251:4 

251:8,14 252:1 

254:13 255:18 258:6 

261:22 268:3 278:12 

299:17 301:13,17 

304:9 315:21 319:7 

335:12,18,21 337:10 

347:12 363:17 

productions 19:19 

productivity 192:22 

products 7:11 27:8,14 

49:11 67:14 68:7,9 

73:20 74:5,21 76:12 

76:13,22 82:14 83:16 

87:12,12,16 88:17 

89:9 91:12,13 92:11 

93:21 94:2 100:21 

111:5 121:18 123:14 

124:2 141:16 147:6 

147:19 149:4 156:8 

156:10 161:18 172:21 

181:8 184:16 210:7 

212:14,15,20 213:10 

213:16,19,20,22 

214:2,3 217:7,13 

218:12 219:14 222:10 

226:14,17,18 229:12 

231:12,16 248:14 

250:13 277:21 278:1 

279:8,12 282:20 

299:22 304:3,12 

306:17 326:14 328:19 

335:15 361:7 

professor 160:13,17 

161:9 172:11 176:9 

program 2:2,3,4,6,7 

25:20,22 51:20 88:7 

90:6 93:6,13 94:11,21 

95:5,9,22 105:3 

111:20 112:4 128:5 

128:14,21 129:4,20 

131:11 132:1 139:17 

153:20 183:18 184:9 

210:4 285:21 301:11 

327:8 328:18 337:4 

351:13 357:16 364:17 

366:22 367:21 

prohibit 20:7 23:2 

43:16 129:2 

prohibited 212:15 

336:10,14,17,22 

337:19 338:3,8 

345:13 

prohibition 127:7,8 

project 163:9 167:4 

170:13 172:2 

prominent 258:9 

promote 84:20 

promoting 183:18 

prone 242:17 

pronounced 171:7 

pronouncing 55:20 

pronunciation 63:14 

proof 204:2 

proper 337:4 

properties 166:7 

194:14 315:12 

property 13:4 

proposal 3:7,8,8 4:9,9 

4:10,10,11 26:17,18 

52:18 55:19 67:11 

88:12 97:15 128:8 

228:14 268:14 285:8 

285:19 287:2,21 

288:3,8 295:7 341:15 

349:6 356:10,19 

proposals 25:1 89:20 

107:9 348:2,9 

proposals/Final 4:19 

propose 99:9 228:4 

247:17 

proposed 7:2,5 95:13 

95:14,15,22 96:2 

107:13 129:1 208:9 

208:20 215:16 228:20 

249:6 

proposing 296:7 

Proposition 250:17 

propping 238:3 

proprietary 224:22 

protect 150:5 302:20 

protectant 277:6 

protected 238:21 

protecting 242:6 

protection 220:17 

278:4 319:15 320:7 

320:10,13 324:22 

protective 134:12 

protects 319:11 

protein 10:19 67:17 

68:12 

proteins 10:21 19:7 

prove 179:6,19,19 

181:13 

provide 16:6 18:20 

90:10 113:15 118:4 

151:17 162:1 186:14 

211:3 221:3 249:3,9 

266:10 276:21 285:17 

289:22 335:22 

provided 7:12 14:7 17:1 

17:3 41:3,4 179:6 

181:11 232:18 300:13 

providers 181:11 

provides 68:6 70:16 

217:5 

providing 47:5 67:14 

105:6 182:20 184:17 

proximity 239:8 

publicly 338:16 

published 19:21 20:13 

69:11 182:9 225:17 

pull 96:1 129:16 348:19 

pulled 88:8 113:12 

pullulan 3:8 55:19,20 

56:7,17 57:1,7,9,14 

57:16,18 58:5,9,14,20 

59:4 60:22 62:10,11 

62:18 63:14 65:3,13 

87:19 91:5,6 92:3 

pulp 4:3 84:21 233:6,9 

233:14,18,22 234:2,4 

238:20 239:2,7,10 

241:5,13 362:13 

pumping 36:9 

purchase 289:11 

purchased 237:13 

PURE 26:4 

purification 117:19 

122:15 145:21 

purified 315:4 

purity 113:8 140:7 

147:5 227:16 

purpose 56:13 257:22 

265:19 267:17 

purposes 34:8 52:13 

93:22 

pursue 105:13 

put 7:9 8:18 39:4 74:20 

91:2 93:1 96:22 97:1 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
394 

101:2 102:1 103:4 

105:18 117:3 121:7 

128:15 140:3 142:9 

151:2 175:9 178:11 

178:12 190:11 201:15 

216:3 229:13 236:13 

269:12 270:5 289:16 

298:2 302:8 304:4 

307:12 310:18 317:17 

359:2 366:16 

puts 108:15 151:3 

340:12 

putting 42:3 80:4,15 

100:16 111:12 191:1 

216:13 321:9 

pyrolysis 146:7 

pyrophosphate 3:20 

215:3,4,17 363:5 

Q

qualified 40:22 

qualify 40:8 

qualities 137:3 

quality 16:13 36:14 

136:22 137:5 147:20 

261:17 339:10 

quantify 175:8 

quantities 42:3,4 

192:21 332:14 

quantity 136:22 137:5 

307:17 332:4 

queried 30:14 

question 21:4,13,18 

27:9 38:4,17 43:13,14 

43:19 46:19 47:4,13 

48:12,21 49:11 51:8 

51:10,12,18 78:17,18 

89:17 94:20 96:21 

102:21 103:20 111:19 

118:7 122:17 124:15 

126:21 127:2,11 

132:10 135:15 137:5 

138:14,21 150:17,18 

156:17 159:14,18 

166:14 168:14 170:22 

173:4,8,13 174:7 

183:13 185:5 188:5,6 

188:11 190:1,5 

191:15 192:18 194:6 

194:17 195:15,18,19 

197:6,7,21 198:8 

199:11 202:16 214:10 

218:2 219:7 221:2 

224:10 235:9 242:14 

242:15 257:17 301:14 

306:3 317:11,18 

318:12 321:19 326:10 

330:18 336:7 341:11 

354:3 

questionable 117:15 

252:21 260:9 

questioning 21:11,12 

52:20 113:7 

questions 6:11 8:13 

11:17,18 13:20,21 

16:16,19 20:22 21:1 

21:20 37:6,14,21 

41:17 49:6 59:11 

79:11 110:1 115:10 

116:1,11 121:3 

136:18 139:8 157:18 

162:21 166:12 167:3 

172:3,10,15,17,22 

181:8 187:20 196:8 

204:19,20 208:7 

209:7,11 212:6 214:7 

214:16 215:2 216:1 

217:16 221:11 226:1 

227:14,15,16,18 

230:22 235:22 252:2 

279:3 280:20 302:6 

309:8,15 316:6,7 

317:9 318:8 322:13 

323:9 324:17 327:2,4 

330:11 331:14 333:12 

336:2 338:9,10 

quick 51:7 107:5 

116:11 187:12 219:7 

244:15 

quickly 44:16 76:4 

206:12 224:16 228:13 

234:12 243:14 256:4 

258:19 321:18 332:13 

quite 15:1 23:4 37:15 

46:14 48:20 67:5 

94:16 155:20 205:12 

252:13 253:13 268:5 

268:6 285:11,13 

306:5 324:22 325:2 

325:18 352:8 

quotation 62:22 63:2 

quote 23:1 77:21 

R

rabbits 316:20 

radar 151:1,3 

radio 203:11,12 

radioactive 181:17,21 

radioactivity 242:4 

243:17 

railroaded 150:10 

rain 301:22 

raise 30:16 138:14 

raised 27:3 29:10 31:3 

32:3,14 47:11 62:13 

70:4,10,13 73:19 

130:19 241:6 269:19 

316:5 353:7 

raises 257:18 328:14 

raising 31:12 69:16 

102:9 142:1 

Ramani 2:9 4:7 161:8 

166:19 185:22 186:3 

198:1,10 

ran 341:6 

rancidity 217:22 

range 113:19 131:1 

231:11 317:21 362:3 

rapid 10:15 11:3 

rapidly 210:5 315:7 

rarely 311:5 

rate 93:19 200:1 201:7 

rates 201:12 242:9 

254:20 

rations 18:19 19:5 

raw 32:1 74:3 239:6 

rayon 300:16 301:7 

304:11 305:19 306:2 

308:12 

re- 11:9 52:11 104:13 

104:15 114:17 120:19 

134:16 215:13 242:2 

re-listed 334:6 

re-listing 11:7 111:15 

117:9 146:19 149:4 

334:8 335:10 

re-petition 47:2 248:20 

270:20 

re-submitted 248:3 

re-touch 52:17 

reach 75:4 236:14 

268:7 

reaction 267:6 274:7 

reactions 117:17 

188:22 

reactivate 147:3 

read 22:18 31:18 44:15 

60:16,22 62:2,5,17 

85:22 99:15 130:18 

130:20 161:4 230:7 

288:5,20 319:14 

336:18 351:15 

reading 25:21 46:12 

47:21 73:21 125:3 

288:1 303:1,1 

reads 23:5 229:19 

292:15 296:8 

ready 25:15 60:10,13 

158:22 268:14 273:22 

313:12 355:10 

real 38:17 39:14 68:15 

70:8 78:17 81:6 83:6 

85:7 154:6 199:13 

201:14 212:4 346:21 

realistic 72:8 

reality 40:18 173:7 

realize 230:18 352:16 

realized 35:15 184:19 

299:5 

realm 309:8 

reason 10:14 43:8 

49:17 89:11,22 91:18 

94:7 97:17,18 116:15 

116:16 179:14 196:1 

203:7 240:2,6 256:15 

269:2 320:14 

reasons 78:9 85:8 

99:14 268:16 306:2 

326:9 344:19,21 

recalcitrant 181:16 

203:6 

receive 6:9 16:15 22:9 

33:1,6 113:7 135:21 

331:11 

received 6:22 7:8 15:12 

15:19 26:12,15 27:1 

27:12 31:6 33:12 

58:14 112:19 119:13 

119:13 122:5,20 

135:11 136:4,9 143:7 

150:15 156:22 157:4 

157:7 160:20 213:6 

213:11 226:13,15 

227:10 247:13,21 

266:18 300:8 315:18 

318:8 339:1 

receiving 26:20 39:2 

290:17 

reclaimed 15:5 

reclassified 122:14 

reclassifying 119:20 

recognize 39:7 338:16 

341:1 350:17 

recollection 121:11 

recommend 34:14 

52:11 

recommendation 28:16 

131:15 144:22 297:1 

recommendations 18:8 

128:13 130:22 257:15 

recommended 11:9 

13:11 16:11 33:8 

156:5 248:2 338:7 

recommending 29:4 

record 25:11,21 51:12 

52:14 53:5,7 62:3,5 

86:1 106:22 111:17 

205:15 270:5 277:13 

296:18 348:6 353:18 

354:18 368:20 

recording 55:22 

recovered 122:1 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
395 

recreate 208:2 

recruiting 367:1 

recycle 337:2 

red 170:21 203:21 

287:16 

reduce 6:5 184:12 

201:12 277:8 340:9 

reduced 324:10 

reduces 109:12 

reducing 278:4 

reduction 340:2,3 

redundant 115:11 

135:20 136:1 214:10 

refer 50:1 

reference 15:10 94:9 

246:20 314:17,19 

334:19 

referenced 96:12 178:9 

250:22 

referred 248:11 327:6 

referring 288:14 

refers 120:8 

refined 319:21 

refinement 320:6 

refining 231:12 

reflect 102:11 368:4 

reflected 45:3 141:6 

reflects 96:8 

reformulate 311:14 

refresher 108:9 

refrigerated 73:12 

refrigeration 73:3 

regard 30:22 73:19 

regarded 248:17 

regarding 188:11 

250:15 269:16 

regards 126:21 144:1 

256:19 

region 80:22 189:12 

regionally 225:18 

regions 189:9,20,22 

253:10 

register 7:10,17 267:3 

registered 248:12 

327:9 

regs 23:2 

regular 76:3 258:10 

regularly 142:5 

regulation 156:5 291:4 

292:14,14,18,22 

352:7 

regulation's 290:11 

regulations 13:17 

15:11 20:7 38:13 

134:8 146:15 148:17 

290:15 

regulations.gov 46:12 

regulator 212:1 

regulatory 31:19 78:5 

251:7 

reiterate 257:13 271:16 

328:3 352:21 

rejected 270:14 

relate 220:10 246:13 

related 16:16 27:9 

29:11,17 30:12,18 

31:1 33:22 63:10 

85:11 135:2 136:2 

143:14 206:9 211:4 

226:4 227:18 230:22 

233:5 246:15 247:4 

343:20 

relates 197:7 

relationship 231:5 

relative 196:21 

relatively 11:16 206:19 

210:6 306:1 

relaxant 12:12 

relaxing 13:4 

released 29:14 31:13 

167:1 176:8,11,18 

315:4 

releases 39:10 203:8 

relevant 195:22 240:15 

248:7 335:9 

reliance 16:10 260:8 

312:13 324:11 

relied 215:20 

relies 312:7 

rely 40:10,18 132:6 

148:14 324:21 

remain 220:1 257:9 

301:21 364:15 

remarks 4:21 365:19 

remember 18:15 25:22 

87:17 95:12 175:21 

181:22 195:3 239:5 

281:6,11 309:22 

323:15 

remembered 5:5 88:2 

remind 132:3 206:4 

reminded 270:14 

reminder 314:12 

reminding 218:8 

remiss 82:1 131:2 

remnant 139:6 

removal 13:11 157:1 

178:14 199:20 291:18 

removals 129:10 

remove 43:7 93:3,10 

103:16 114:2 139:12 

145:21 212:3 241:8 

333:22 337:12 344:10 

353:14 

removed 149:7 197:15 

214:11 287:1,16 

288:9,14 291:13 

295:7,19 297:11 

removes 337:5 

removing 136:6 293:20 

293:22,22 294:3,5,6,8 

294:10,21 300:4 

338:9 

Renaissance 1:9 

renewed 228:4 

repeat 354:1 

repellant 316:12,12 

replace 162:19 330:13 

replacement 112:16 

163:1 

replacements 233:2 

replacing 300:5 

replicated 165:2,7 

239:19 

report 12:9,10 13:12 

18:1 211:6,9 218:22 

233:16 269:16,18,22 

270:15 

reported 143:17 144:2 

233:17,18 

reporting 122:8,9 

reports 44:19 143:9 

representative 15:6 

representatives 117:12 

represented 7:22 291:7 

represents 227:12 

reproduction 14:9 

reputable 78:22 

request 141:14 248:1 

259:22 

requested 149:12 

248:21 

requesting 352:6 

requests 114:2 

require 17:19 148:17 

244:8 

required 136:11 156:5 

208:19 250:8 

requirements 19:6 

109:8 137:13 147:5 

243:7 

requires 126:19 140:15 

requiring 22:2 146:22 

244:6 351:10 

reread 353:17 

rescue 332:1 333:7 

research 4:6 19:2 30:9 

160:7,10 162:2 

163:13 167:4 185:12 

185:18 199:5 223:8 

223:15 225:10,12,16 

225:22 232:17 254:7 

258:5,20 311:5 

321:17 363:22 365:6 

365:8 

researched 113:11 

researching 234:12 

residual 49:12 

residue 45:21 49:11 

residues 143:17 166:22 

203:9 206:18 210:6 

resistance 29:15 30:7 

30:11,13,17 41:20 

44:20 316:1 

resistant 42:1 

resolve 38:18 39:13 

resolved 38:10 224:16 

321:20 343:1 

resource 196:5 

resources 146:5 183:16 

195:10,11 

respect 78:2 125:9 

133:10 154:20 266:15 

respiratory 45:13 

210:10 

respond 39:19 77:4 

131:12 139:19 319:19 

327:2 342:3 

responded 31:17 41:5 

response 16:15 21:17 

125:18 128:20 143:16 

214:18 255:13 288:11 

330:18 

responses 209:10 

327:4 

responsible 132:7 

rest 81:7 93:3 109:22 

209:6 

restore 148:15 

restoring 337:7 

restrict 91:18 98:13,16 

101:10 103:8 

restricted 91:8 212:22 

restricting 80:18 91:14 

99:9 104:12 

restriction 103:8 

restrictions 260:16 

restrictive 16:10 

result 120:11 202:21,22 

results 160:2 170:12 

176:8 204:18 330:15 

resumed 106:22 205:15 

348:6 

retain 78:1 115:19 

116:16 

retention 233:9 

rethink 140:3 

retooled 153:3 

retooling 311:10 

return 349:1 

returned 348:10 351:10 

review 3:9 4:1,13 11:11 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
396 

17:10 18:1 21:15 

22:19 23:16 24:13 

26:15,20 27:22 28:17 

70:2 71:20 90:10,12 

98:18 104:9 106:9 

115:22 116:11 117:11 

118:6,15 119:15 

121:1 122:7 132:4,21 

159:12 209:1 210:14 

215:14 228:3 247:1 

247:22 248:19 249:3 

249:6 266:18 270:9 

274:9 301:12,15 

302:3 303:9 308:20 

327:15 328:19 335:14 

337:13 338:11 

reviewed 5:20 8:17 9:4 

9:6 11:14 18:1 20:10 

23:8 89:11,15 91:17 

97:20 114:22 137:14 

143:12 150:22 159:11 

237:6 238:18 301:8 

325:19 327:14 357:10 

reviewer 21:19 

reviewing 20:4 24:4 

33:5 121:1,12 132:7 

309:12 328:4,13 

329:3 

reviews 16:5 21:21 

147:3 332:6 

revised 350:16 

revising 29:3 

revisit 43:13,14 140:11 

292:21 

revolves 28:12 

rewrote 350:1 

rhizospheres 266:12 

RICE 1:13 5:17 6:11 8:7 

8:10,14 10:5 11:18 

13:21 17:7,11 18:2 

21:1 22:1,7,16 24:11 

25:18 47:12 50:13 

51:5,13,20 53:10 54:1 

55:2,16,21 61:15,17 

63:12 64:1,14,17 66:4 

66:19 67:1 86:8,10,20 

87:3,21 118:20 

121:10,16 127:3,10 

133:18 134:21 142:11 

145:14 147:16 150:14 

215:4 245:7 263:19 

264:4,18 265:3 

272:13,21 273:10,19 

275:7,17 276:4,15 

283:17 284:7,14 

285:5 292:5 295:17 

296:3 323:11,15,19 

352:21 355:12 356:5 

359:19,21 360:1,3 

rich 71:12 

Rick 1:17 41:8,18 126:8 

262:15 264:10 282:16 

316:9 346:17 365:12 

rid 81:7 191:8 

ring 202:14,19,22 

203:20 

rinse 109:6 110:19 

rise 326:10 

risk 39:9,10 58:5 

261:10 340:10,13 

risk- 143:14 

risks 213:15 

Riverside 160:19 

road 257:4 335:22 

Robert's 350:21 358:2 

robust 270:6 331:12 

rock 332:18 

rodent 248:13 

rodents 250:20 

role 10:19 127:12 

142:16 331:6 

roles 334:2 

ROMERO-BRIONES

1:20 50:18 53:14 55:6 

61:6 64:5 66:10 71:18 

86:9 231:3 233:8 

234:11 241:17 243:12 

244:12 246:5 264:1 

264:22 272:17 273:14 

275:11 276:8 283:21 

284:18 355:16 359:10 

room 211:8 235:18 

root 255:7,21 256:8,12 

258:17 260:22 261:7 

289:16 

roots 258:18 266:12 

rosemary 286:18,19 

289:11 291:21 

rotation 8:21 9:7 

251:11 339:5,19 

rototill 197:17 

rototilling 197:16 

round 33:13 101:6 

108:21 

route 98:10 306:11 

rudimentary 261:1 

rule 7:5 95:14,14,22 

96:2 208:9 286:10,21 

286:22 287:5 293:10 

293:12,13 296:15,16 

296:16 297:2 

rulemaking 90:13 131:9 

rulemakings 208:10 

Rules 350:22 358:2 

ruminants 19:8 

rumor 138:10 

rumors 138:9 

run 73:1,5 149:19 

340:17 

running 5:15 152:22 

367:22 

rural 36:11,15 38:9,12 

42:9 49:15 184:14,15 

S

safe 174:9 193:17 200:2 

248:18 249:17 

safer 46:3 315:13 

safety 39:8,10 

sake 62:14 

salad 233:11 

sale 286:10 289:4,22 

290:13 

saleable 261:8 

salt 6:1 135:7 155:4 

217:4 

salts 274:7 

sample 15:6 300:8 

sanitation 33:4,18 34:1 

34:3,6 46:8,11 

sanitize 135:16 

sanitizer 10:8 12:1 26:7 

35:12 135:18 206:12 

206:14 210:11 314:18 

sanitizers 30:3 34:12 

34:13 35:21 109:5 

110:17 111:8 315:10 

365:7 

sanitizing 10:12 27:14 

32:6 135:9 

saponified 316:15 

satisfied 36:16 

sausage 67:14 68:8 

77:22 84:13 88:15 

sausages 78:2,4,6,11 

78:13 79:8 84:14 85:5 

85:6 93:20 94:1 

save 72:22 

saw 75:14 160:2 192:8 

214:12 222:16 237:8 

253:14 254:3 

saying 7:10 10:1 23:5 

23:15 24:4 39:4 92:4 

101:18 111:11,12 

125:7 136:1 153:14 

158:2,3 175:4 176:22 

179:10 191:8 216:14 

230:18 245:11,22 

253:21 294:19 296:21 

306:5,6 317:5,12 

320:10 331:22 344:15 

346:10 352:16 

says 7:19 9:20 18:11 

19:5 22:9,19 23:1,8 

79:19 96:8 97:2 

180:19 198:12 286:22 

292:18 293:10,20 

296:10 314:1 

scalable 151:18 268:20 

scale 15:3 107:7 253:8 

335:1,4,7 

schedule 206:10 247:3 

scheduled 154:13 

schedules 154:20 

scheduling 341:11 

schematic 173:16 

177:12 

schemes 193:2 

school 173:3 188:7 

194:6 346:19 

science 160:17 176:10 

182:9 191:17 

Sciences 160:15 

scientific 11:13 161:17 

180:14 

scientist 271:4 

scientists 163:11,14,14 

163:15 202:6 

scope 104:22 248:21 

scopes 31:19 35:9 

207:14 

Scott 1:13 5:15 16:22 

47:11 55:1 61:2 65:18 

65:21 118:19 133:16 

141:21 149:11 215:3 

292:2,4 295:15 

297:21 350:12 352:20 

355:9 359:22 

Scott's 121:15 145:13 

scraps 76:21 

screen 60:8 85:16 

106:10 163:7 314:9 

SCRI 163:2 

scroll 291:9 296:4 

scrolling 288:12,15 

291:3 

SDC 31:21 32:4 

SDC's 31:19 

se 17:14 49:2 129:18 

search 21:16 79:20 

80:6,17 238:2 260:20 

searches 30:12 

searching 93:7 

season 197:14 320:2 

331:3 

seasonal 15:16 171:6 

seasons 169:14 170:6 

277:17 

seat 83:13 

Seattle 1:9,9 160:6 

164:5 

seaweed 4:4,4 143:21 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
397 

144:1,3 241:16,18,22 

242:4,9 243:16 

244:11 246:4,5 

362:14,14 

seaweeds 142:22 

second 50:4,5,6 52:18 

53:7 54:6 63:3,4,20 

66:3 88:20,21 105:21 

120:8 166:17 174:17 

198:7 230:3 249:6 

274:1 276:18 298:8 

330:18 349:10 354:16 

354:20 358:9 

secondary 202:18 

seconded 54:11 61:2 

65:18,21 86:4 263:9 

264:9 272:5 273:3 

274:20 275:21 283:13 

284:11 298:9 349:11 

358:4 359:4 

seconder 354:10 

358:15 

secondly 277:5 

secretary 1:13 51:11 

section 91:11 93:17 

95:3 229:17 287:17 

288:13 289:1 296:7 

296:20 350:10 

sections 294:20 

sector 109:3 110:15 

sectors 211:15 

security 184:13 

sedative 12:11 

seed 4:11 153:20 

251:17 259:7,8 285:8 

334:3 348:10 349:6,7 

353:20 354:22 364:18 

seeds 260:12 333:19,21 

seeing 6:13 13:22 

25:22 106:18 149:15 

252:19 254:6,21 

267:3 311:12 316:8 

368:11 

seek 214:5 221:4 

seen 44:15 75:9 78:21 

80:9,18 111:5 120:8 

157:16 216:8 223:20 

252:13 291:16,16 

367:3 

sees 126:1 225:18 

segment 153:10 

SEITZ 1:21 11:21 43:3 

51:3 53:20 55:12 

61:12 64:11 66:16 

77:20 86:17 96:6 

194:5,12 195:16 

263:16 264:15 272:10 

273:7 275:1 276:1 

284:5 285:2 337:16 

337:18 338:1,3 351:6 

351:12 355:22 359:16 

366:14 

selecting 346:20 

selective 249:20 323:2 

323:7 

self- 34:2 

selfish 175:17 

sell 237:14 286:19 

289:13,17 290:9,20 

selling 287:7 290:16 

sells 179:17 

semi-arid 189:19 

send 26:19 100:18 

108:4 297:15,19 

349:5,16 351:3,20 

353:19 354:14 

sending 254:11 

senioritis 25:21 

sense 99:1 138:20 

140:2 144:21 204:19 

207:21 220:6 242:20 

254:2 287:7 290:9,18 

328:8 329:14 364:3 

sensitive 220:13 

sent 51:9 185:11 

256:15 

sentence 22:18 229:19 

230:2,14,16 

separate 34:7,7 35:19 

77:17 115:19 118:10 

118:11 192:6 232:9 

265:10 329:8,10 

separated 137:11 

separately 6:15 116:16 

265:12 

separation 143:1 

145:18 

series 325:3 

serious 220:10 343:14 

seriously 321:2 327:21 

serve 249:16 265:18 

serves 334:2 

service 266:11 340:7 

sesame 220:21,21 

session 108:12 

set 158:22 164:2 165:8 

189:21 268:3 269:7 

344:15 

sets 113:18 169:3 257:5 

setting 108:6 

settings 70:5 230:11 

seven 249:22 323:2 

sewage 36:8 37:11 

shade 302:11 

shaking 26:1 216:17 

share 72:13 79:3,13 

83:22 

shared 25:5 225:14 

sheep 7:14 9:21 

sheet 51:14 

shelf 73:3,12 76:16 

237:11 301:6 

shells 146:6 

shift 203:1 245:8 

shipping 252:16 

shocking 199:22 

short 120:13 172:1 

202:10 237:11 249:10 

314:5 347:19 

short-term 163:22 

168:20 170:19,21 

171:1 

shorthand 96:7,14 

shot 235:16 311:5 

shout 211:5 

show 164:18 167:10,11 

169:1,2 171:13 177:2 

181:4,20 193:14 

203:21 205:19 220:7 

354:18 

showed 115:4 180:18 

182:13 184:1 196:10 

197:9 

shown 95:6 192:10 

199:14 332:7 

shows 180:11 203:22 

268:4 271:3 

showstopper 193:12 

shrinking 75:11 

shutdown 341:5 

sickness 340:11 

side 36:5 37:7,14,16 

38:22 39:3,5 40:6 

42:18 43:4 48:6 164:6 

165:14 167:20,21 

168:3 202:12 224:4,7 

225:2 226:20 235:8 

237:10,21 238:1,14 

253:3 309:15 315:15 

315:16 

sides 28:7 29:17 

sight 78:4 

signal 95:21 

significant 63:16 91:4 

119:11 217:6 254:9 

316:5 327:20 330:18 

339:10 348:12,14 

signs 6:5 

silica 134:11 

silicate 193:5,7 

Silva 224:20 

silver 3:7 25:3 26:3 

29:12,15 30:12,13,19 

31:3,7,9,14,17 41:22 

42:5 53:2 54:4 

similar 27:2 30:16,16 

68:13 71:3,20 72:1 

103:6,7,7 110:16 

116:10 123:4 140:13 

170:14 176:15,20 

210:1 223:22 237:7 

246:14 258:12 274:6 

304:1 305:20 

similarities 258:15 

similarity 70:22 

similarly 30:18 117:8 

170:17 226:19 325:18 

simple 177:12 179:9 

192:14 311:19 315:1 

simply 49:2 179:14 

180:8 183:13 

Simultaneous 87:22 

351:11 358:7 

single 40:17 98:2 

214:13 238:21 239:8 

site 164:13,14,19 165:7 

site- 245:1 

sites 164:12,20 188:15 

199:22 

sits 352:15 

sitting 193:5 201:17,19 

366:9 368:18 

situation 343:18 366:3 

situations 216:7 235:11 

six 73:3 172:10 181:7 

191:6 250:1 323:1 

six-month 73:12 

sixth 199:11 346:6 

size 150:4 254:19 

260:22 

sized 223:19 

sketch 202:12 

skins 67:18 76:2,2 

231:20 

slam 306:11 

slide 65:9 163:7,12 

167:19 169:1 170:11 

172:9 182:8 273:22 

slides 190:11 222:15 

slight 83:9 87:7,10 

slim 256:14 

slippery 257:6 345:1 

slope 257:6 345:1 

slow 78:21 270:18 

332:18 

slower 190:2 277:22 

slowly 137:8 171:12 

slows 74:18 

SLS 27:21 

sludge 36:9 37:11 42:7 

42:8,22 

slug 324:22 325:14 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
398 

329:6 

slugs 324:9,14 325:21 

326:4 

small 71:11 81:1,12 

82:13 150:4 151:14 

175:22 182:3 192:21 

238:7 256:7 306:1 

335:7 

smaller 192:15 198:6,6 

223:19 

smoke 346:2 

smoking 346:1 

smooth 63:10 

snacks 156:10 

snails 324:9,15 

soak 6:5 

soap 360:9 

soaps 4:14 316:9,10 

317:9 362:2 

sociologists 163:15 

sodium 3:20,21 4:18 

27:7 35:1 36:18 50:2 

112:15 114:21 127:13 

127:13 130:11 146:10 

215:3,4,17 216:20,21 

217:1 337:15 362:8 

363:5,6 

soft 320:21 

soil 14:14 160:13,15 

161:1 163:14,20,20 

163:22 166:2,3,5,6,6 

166:7,11,13,18 167:6 

167:9 170:20 171:11 

171:12 172:19 173:9 

174:15 177:15,15 

178:8 188:11 192:22 

196:9,21 197:2,8,10 

197:19 198:12,14 

199:1,4,16,17 200:18 

200:22 201:10 202:6 

203:1,2 249:11 

251:18 262:11,17,19 

265:20 266:12 268:6 

277:5 301:18,20 

303:16 304:4,5 

305:21 316:13 326:7 

331:18 337:7 347:12 

soil-borne 248:6 

soil-building 332:22 

soil-dwelling 20:19 

soils 164:11 169:11 

170:6 189:2 277:18 

332:19 333:9 

sold 7:21 76:22 253:10 

286:14,22 289:8,19 

290:7 291:7 293:11 

299:22 

solely 147:8 156:14 

solid 182:20 281:16 

solids 145:19 

somebody 111:7 

160:22 179:17 279:5 

323:17 

someday 63:9 322:12 

somewhat 35:13 73:11 

84:18 137:6 235:21 

260:9 280:7 292:13 

son 344:9 

soon 59:20 129:8 191:8 

287:18 

sooner 205:11 

sorry 17:2 22:5 25:12 

25:21 50:16 59:6 

62:21 190:6,7 244:13 

253:22 270:13 275:5 

282:11 286:8 287:12 

288:22 294:2 298:22 

312:16 314:8 328:2 

337:17 348:17 349:13 

354:1 357:13 

sort 17:21 39:15 72:6 

82:9 173:3 176:9 

180:22 186:9 191:17 

200:15 223:18 252:17 

262:21 269:6 281:13 

302:19 304:14 307:10 

313:1 318:15 320:14 

341:11 

sorts 125:5 186:6 312:6 

sound 149:13 245:22 

295:22 

sounded 229:9 

sounds 52:20 84:19 

154:22 194:7,9,13 

200:12 247:10 

soup 143:6 241:19 

246:6 

soups 143:5 

sour 110:7 231:16 

source 21:4 70:6,7,18 

77:8 82:8,9,10 136:10 

154:7 157:22 158:10 

226:10 287:9 

sourced 69:5 72:5 83:3 

83:4 84:5 127:5 134:2 

sources 14:11 15:5 

19:8 20:1 21:6,12 

67:19,20,21 71:3 

120:2,4 145:15 148:1 

154:3 157:20 158:1,2 

218:3,14,16 231:20 

231:21 232:10,13,15 

232:16,17,19 233:22 

sourcing 78:10 

soy 215:15 

soybeans 339:22 

space 77:16 181:2 

spaces 235:14 

spacing 279:17 

speak 39:6 47:18 72:18 

138:22 172:6 185:9 

185:17 219:17 226:16 

253:7 261:3 280:8 

282:14 328:15 337:21 

speaker 315:21 

speakers 154:13,17 

158:19 159:2,6 

160:12 221:18 259:13 

speaking 87:22 135:17 

220:21 327:1 351:11 

358:7 

special 222:12 240:21 

Specialist 2:2,5 

specialized 320:3 

specialty 124:16 

species 7:15 9:22 144:3 

186:21 249:22 250:2 

250:5,8,10 251:22 

317:16 

specific 10:16 59:2,7 

89:22 94:9 95:15,21 

117:12 137:3,5 172:2 

209:7,8 215:11 216:6 

234:14 239:16 242:8 

245:2 258:1 303:12 

330:20 349:6 

specifically 17:16 20:6 

72:21 87:11 91:18 

157:7 159:22 163:21 

189:14 209:17 291:10 

299:21 303:12 321:4 

specification 69:4 

178:11,18 

specificity 96:4,7 125:9 

specifics 15:8 

specified 63:1 65:5 

specifies 220:19 

specify 129:10 

specimen 177:17 

spectrum 251:19,20,21 

257:3 262:11,22 

320:1 

speed 78:19 79:2 

spells 14:21 

spend 131:2 209:5 

spent 226:5 228:21 

259:9 266:3 271:8 

327:19 

spirit 188:7 

spirulina 123:20 

split 307:18 

spoke 140:18 208:13 

213:12 325:11,12 

spot 269:13 296:21 

spray 282:21 318:20 

sprayable 321:22 

322:17 323:13 

sprayed 333:20 

sprays 277:16 

spreads 233:11 

spring 1:5 169:14 170:7 

348:16 

stability 167:12 168:6 

168:21 

stabilize 27:20 109:1 

155:11 

stabilizer 27:11 143:4 

231:13 

stabilizers 210:15 

stabilizing 217:3 

stable 182:11 

stables 11:15 

staff 2:1 368:3 

stage 174:13 232:17 

stages 207:10 

stakeholders 134:9 

141:15 327:19 349:15 

stalls 11:15 

standard 12:19 165:12 

165:19 174:11 175:9 

177:13 178:8,16 

179:2,20 186:18 

198:10 243:5 

standards 1:3 2:4 12:17 

12:20 13:18 58:10,11 

131:7 161:19 227:18 

243:4 269:8 319:15 

320:8,10,13 

standpoint 78:17 79:8 

141:22 261:21 

stands 18:16 165:15 

starch 232:7 233:1 

Stark 254:10 

start 25:1 39:2 42:3 

50:9 55:1 60:14 66:8 

106:11,18 128:12 

154:13 159:2 162:3,5 

172:9 198:2 199:1 

205:18 224:14 247:10 

264:10 272:7 273:4 

275:22 284:12 313:2 

313:4 349:12 

started 26:2 358:6 

starting 87:9 120:5 

260:4 263:9 272:6 

274:21 283:13 355:9 

starts 64:1 76:6 174:7 

state 2:9,9 47:2 131:2 

136:10 160:14 161:9 

164:4 250:16 252:16 

260:15 333:5 

stated 13:12 56:13 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
399 

120:6 230:5 232:16 

268:16 300:2 357:19 

statement 107:5 194:15 

242:20 245:20 339:12 

statements 243:3 255:1 

268:8 

states 1:1 38:14 57:15 

93:19 99:16 212:2 

249:15 291:1 342:17 

343:4,17 

stating 34:1 

station 334:19 

stay 336:16 348:14 

steak 81:6 

steam 146:13,22 147:6 

step 34:6 65:1,1 75:20 

steps 34:7 68:20 90:13 

148:6,8 201:18 

319:15 341:12 

Steve 1:12 25:3,12,18 

35:22 41:9,12 42:6 

60:14 79:16 81:17 

84:8 88:5 101:14 

114:13 123:1 125:2 

138:3 149:10 151:5 

153:14 159:2,3 234:5 

234:19 235:6 239:14 

241:6 247:8 265:13 

274:16 281:7 283:13 

284:11 295:15 308:10 

350:12 367:8 

Steve's 38:8 136:14 

139:20 287:11 

stifle 70:15 

stock 241:18,21 248:9 

249:7,8 252:12,14,20 

253:3,8 256:6,8,12,22 

257:19 258:7,10 

259:20 260:5,11,22 

261:8,17 286:11,13 

287:10 289:6,8,8,18 

289:20 290:7,17 

291:6 292:8 293:1 

stocks 183:19 184:4 

255:7,22 258:17 

259:10 

stomach 125:20 

Stonyfield 115:17 

stop 65:15 174:12 

180:7 

stopgap 70:17 

stops 81:3 

straight 8:5,7,8 54:18 

99:22 180:8 310:5 

straightforward 114:18 

118:7 

strange 113:19 

strawberries 253:13 

261:3 290:19,20 

330:22 

strawberry 251:16 

253:18 255:16 290:1 

290:19 

stray 344:18 

stream 76:11 

Street 1:9 

strength 191:9 

strengthening 4:11 

285:8 349:7 353:20 

354:22 

stress 299:20 

strict 73:21 307:10 

strictly 310:5 

strike 25:11 

strikes 103:22 

strong 191:7 329:18 

333:22 334:10 367:2 

strongest 190:15 

strongly 74:16 94:16 

struck 128:19 

structural 138:15 

structurally 68:13 

structure 69:22 73:7 

148:10 169:8 170:4 

190:12 192:11,12 

193:13 195:13 203:19 

315:2 

structures 155:12 

167:13 169:11,22 

202:15 

struggle 47:14 48:3,13 

238:12 271:20 294:17 

struggled 28:6 48:14 

69:1 185:6 

struggling 222:17 

studied 138:10 250:11 

315:15 

studies 29:13 160:1,3 

183:5 196:14 203:5 

204:2,8 317:7 326:2 

study 164:9 171:21 

182:8 189:10,22 

201:21 203:10,17 

249:20,21 250:4,8 

studying 131:16 

stuff 182:7 242:21 

304:17 317:16 344:20 

stump 282:18 283:1 

subcommittee 3:2,6 

4:1,8 5:16 24:19 

26:20 28:6 29:2,4,7 

29:21 32:3 33:11 

34:14 35:6 38:4 46:20 

50:3 51:14 54:8 59:3 

68:2 69:7 90:19 

100:11 108:4 116:18 

121:7 124:17,22 

126:4,7 132:17 

140:16 141:17 159:4 

159:12 208:22 209:14 

228:6 229:3 234:8 

247:8 248:20 266:7 

268:9,10 270:8,11 

281:3 288:10 299:11 

327:21 329:14 341:3 

348:11 349:1 351:21 

356:14 357:7 360:20 

363:15,19 365:10 

366:16 

subcommittees 102:1 

365:9 

subcutaneously 12:15 

subgroups 138:19 

subject 131:5 321:8 

submit 144:11 173:19 

245:16 

submitted 16:1 56:6,11 

115:3 211:6 247:16 

265:15 299:8 

submitting 182:4 

221:19 

Subpart 7:12 

subsections 140:4 

subsequent 155:6 

215:16 

subsequently 270:17 

substance 11:2,21 12:6 

12:10 13:9 18:11 43:6 

43:9 57:8 112:21 

219:8 247:18 309:13 

337:16,19,19 338:8 

substances 3:9 4:1,13 

11:4 13:14 24:13 

27:16,18 30:3 78:12 

114:22 115:3,16,22 

116:5 118:3,4 124:6 

128:9,13,22 129:3 

131:14 132:8 137:10 

137:14,17 139:12 

218:20 219:12 247:1 

316:11 336:10 344:17 

substantial 26:21 

293:16 

substantiate 138:11 

substantive 107:8,16 

107:21 108:3,6,10 

293:4 294:15 295:22 

351:9,16,19 352:2 

substitute 67:12 163:5 

170:18 233:10 332:17 

substrate 187:14 

219:18,19 

subtropical 164:14 

successful 300:7 

sucker 339:9 340:2 

suddenly 150:2 

Sue 1:13 6:16 8:10 10:5 

18:5 21:1 22:18 24:11 

77:19 79:15 151:21 

153:18 274:21 309:16 

345:5,18 

sufficient 26:16 80:3 

89:18 136:19 157:15 

175:5 229:1 259:22 

267:16 332:3 

sugar 180:16,19 186:19 

187:4,4 195:6 

suggest 233:21 234:3 

319:14 329:18 

suggested 147:4 232:2 

232:8 252:6 292:20 

suggesting 294:21,22 

suggestion 224:13 

240:11 296:14 297:8 

363:20 

suggestions 229:6 

suggests 251:11 

suitability 163:16 

suitable 162:22 170:17 

sulfate 3:2,13,17 4:17 

5:21,22 6:12 27:7 

35:2 36:18 121:15,17 

155:22 156:3,7 

157:10 158:3 331:16 

331:18 332:12 362:7 

362:21 363:2,11 

sulfhydryl 10:20 

sulfur 10:21 

sulphur 333:10 

summarize 206:6 208:6 

209:14 221:16 249:1 

314:13 356:20 

summarizing 170:12 

summary 36:2,7 37:19 

71:14 172:1 243:13 

302:4 

summer 228:14 300:9 

sunscald 277:6 278:3 

279:15 282:19 

sunset 3:9 4:1,13 5:19 

18:8 24:13 71:19 

101:5 104:5,9,10 

106:9 108:14 121:1 

132:21 133:4 159:12 

205:21 206:7 209:1 

246:22 314:13 337:13 

338:11 362:1,4,11,22 

363:7,8,10,13 

sunsets 106:18 298:4 

313:10,13,16 

super 48:22 

supplement 57:13 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
400 

58:12 65:5 92:12,12 

135:8,13 147:17 

157:21 

supplemental 306:15 

supplementation

157:12 158:12,16 

supplements 14:8 

56:10,16,18 57:3,21 

62:20 109:2 135:5 

155:10 157:3 217:12 

supplies 340:17 

supply 33:4 75:14 

84:17 85:1 136:19 

237:9 

support 31:9 56:16 

58:19 62:10 70:12 

74:19 75:17,18,18 

91:2 103:21 115:9 

116:6 117:9 124:5,10 

132:1 134:17 146:19 

218:10 222:1 223:5,9 

226:15 228:19 254:19 

257:19 258:6 259:22 

280:6 315:19 326:1 

331:21 334:8 335:8 

335:11,21 344:10 

354:17 358:16 364:13 

supported 11:12 

114:17 134:8 136:17 

147:10 

supporting 15:13 47:8 

120:5,21 134:16 

147:7 156:22 267:21 

267:22 

supportive 110:1 155:8 

211:21 217:2 268:10 

268:15 341:16 

supports 248:8 

supposed 197:11 

244:20 

suppression 325:15 

surface 32:5 36:16 

146:1 196:10,12 

197:10 324:13 

surfaces 26:8 35:11 

36:19 

surprising 204:21 

surround 236:6 

susceptibility 250:5 

susceptible 190:19,19 

282:19 

suspect 37:17 79:4,12 

145:9 

suspended 145:19 

sustainability 163:4 

SWAFFAR 1:22 5:22 

22:8 50:5,21 53:17 

55:9 61:9 64:8 66:13 

86:14 238:17 263:13 

264:12 272:7 273:17 

275:14 276:11 281:2 

281:18 284:2,21 

293:15 294:2,8 

297:15 349:9 353:6 

354:13 355:19 358:8 

358:15 359:13 

swath 307:1 

sweet 339:21 

sweeten 216:14 

sweetened 180:20 

swine 14:10 

Swiss 160:20 

switching 336:10 

synthesis 15:4 24:1,1,7 

153:4 202:20 

synthesize 148:14 

323:5 

synthesized 148:4 

322:20 

synthetic 16:9,11 18:11 

51:19 52:4 53:2,9 

68:19 74:2,3,6,9,9,10 

109:17 110:22 117:17 

117:21,22 119:20,22 

120:12,21 122:14,16 

148:9 149:6 190:15 

202:13 208:7,8 

247:17 249:18 251:13 

251:19,20 262:12 

263:8 267:5,6 272:4 

274:8,20 275:2 278:7 

278:9,15,16,18 279:1 

279:21 283:12 299:14 

300:4,14,19 301:12 

303:2,6,12,15 304:3 

305:6,19,22 306:17 

307:8,14 308:4,11 

312:20 316:11 332:5 

synthetic/non-synthe...

118:8 

synthetics 305:12 

331:10 

system 30:11 122:10 

146:17 150:5 173:9 

175:3 215:8 222:6,12 

246:12 258:16 260:12 

269:20 305:8 314:19 

317:2 319:16 334:20 

335:12 

system-level 312:11 

systematic 171:18 

systems 31:5 36:8,14 

94:3 125:15 258:6 

259:14 312:9 314:19 

T

table 105:19 135:7 

194:18 218:21 298:2 

298:6,12 

tabletop 335:1 

tablets 56:9 62:20 65:4 

tainted 70:6 

taken 5:7 9:5 102:18 

139:1 182:15 222:4 

231:4 245:6 255:4 

270:19 285:13 297:17 

328:20 347:12 

takes 43:7 176:6 198:3 

200:13 

talc 193:4 

talk 101:8,15 105:13 

107:8 133:11 162:10 

162:12 163:18,19,20 

166:20,21 167:5 

180:2 186:1 223:6 

286:5 329:4 348:9 

364:17 

talked 42:6,7,9 84:10 

89:8 103:19 104:2 

142:3 145:2 149:16 

199:14 253:2 258:9 

317:1 363:18 

talking 37:11 70:3 71:8 

83:11 88:5 89:10 

151:8 152:9,17 

178:17 190:3 214:2 

224:17 258:1 311:10 

346:7 358:6 

talks 310:10 

tap 11:10 12:9 13:12 

106:12 120:21 147:3 

215:14 

tartness 217:5 

TBD 361:20 364:5,6,19 

364:21 365:5 

team 163:10,10,13,16 

teas 231:13 

technical 11:11 12:10 

18:1 22:19 23:16 

26:15 40:6 73:8 

161:20 218:22 266:18 

269:16,18,22 270:15 

271:5,21 274:9 

301:12 308:8 

techniques 74:3 251:12 

Technology 160:21 

tell 60:20 88:7 172:12 

226:12 234:17 269:13 

296:14 308:5 330:14 

355:10 

telling 81:5 

temperature 199:18 

277:8 278:5 

temperatures 134:6 

temporary 340:15 

tempted 63:12 

tencel 300:16 301:7 

304:11 308:12 

tend 37:3,3,13 39:3 

319:5 320:22 

Tennessee 164:7,15,22 

169:3 

tepee 302:16 

terephthalic 195:3 

term 67:13 120:13 

123:7 168:13,15 

171:20 174:20 196:15 

249:11 306:21 

terms 38:6,14 71:1,14 

83:8,18,21 90:9,10 

94:11 98:20 104:20 

105:8,11 109:20 

111:1,20 114:2 

131:13,14,18 140:19 

145:6 150:18 152:18 

153:3 155:15 166:3 

168:21 170:9,15 

194:14 199:12 203:4 

206:16 212:4 215:6 

217:15 223:16,20 

225:13 228:12 255:16 

256:6 269:21 278:4 

279:15,17 320:7 

334:4,11 

territory 262:4 

test 177:10,17 178:9,10 

179:1 183:4 187:21 

198:12 199:17 201:16 

300:10 

tested 258:1 

testimony 38:18 283:8 

testing 113:21 143:15 

243:7 244:6 

tests 165:12 189:8 

198:11 

tetany 6:2 

text 295:2,3 

texturalizer 231:14 

thank 5:3 8:10 18:6 

22:6,15 24:10,17,21 

60:19 63:21 86:5 

90:16 121:16 145:13 

162:5,9,10 192:10 

193:22 195:16 204:17 

204:22 205:3,4,4 

209:11 214:7 218:7 

221:10 226:3 271:2 

271:12,15 280:22 

282:6,10 297:4,4 

327:3 333:16 337:17 

338:2,11,22 340:22 

341:18 344:3 355:5,7 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
401 

358:19 359:1 360:21 

366:14,17 367:19,21 

368:2,6,9 

thankfully 356:8 

thanks 5:17 10:5 11:19 

13:22 18:3 24:11 

37:19 47:12 85:16 

116:19 118:20 158:9 

265:14 360:3 

theme 339:3 340:1,14 

theoretically 199:7 

307:11 

theory 36:12 

they'd 42:4 317:5 350:9 

thicken 155:11 

thickener 143:5 231:14 

thing's 368:17 

things 6:5 21:6 22:3 

24:6 39:3 41:21 43:15 

48:4 77:22 84:22 

102:2 104:18 118:11 

125:20 126:10 129:16 

133:10 136:16 139:21 

142:12 150:10,21 

151:10 153:22 171:13 

192:21 202:6,8 

210:11 216:18 220:11 

234:21 255:12 267:15 

267:16 271:20 274:12 

303:20 304:6,6 

316:17,19 325:5 

329:11 341:7 344:13 

347:13 

thinks 351:13 

third 40:12 166:22 

179:20 203:19 249:9 

259:2 

thorough 115:21 

thought 25:5 32:20 

44:9,18 98:12 107:6 

108:11 125:3 143:19 

153:13 172:11 173:1 

184:20 187:13,15 

193:6 209:17 230:19 

281:12 303:10 305:2 

311:4 312:2,14 

317:13 356:16 

thoughtfully 321:3 

thoughts 124:22 150:8 

255:13 330:4 

thousand 254:17 255:9 

thousands 12:9 56:22 

82:16,16 97:4,4 283:1 

three 9:4 34:15 120:15 

127:8 135:6 140:5 

172:17,21 182:15 

223:1 226:21 255:8 

266:2 288:4,6 323:3,4 

323:6 360:4 

threshold 335:2 

thrive 175:18 

throw 45:22 214:19 

260:10 

tied 322:8 

ties 219:3,4 

tight 201:8 

tighten 123:21 

till 197:22 

tillage 324:10 

tilled 197:16 

timeline 228:11 

timely 228:15 

times 56:5 101:11 

134:4 301:20 339:13 

timing 223:17 361:21 

tiny 196:22 268:18 

tissues 113:4 

tobacco 338:19 339:5,9 

339:11 340:10 342:16 

342:19 343:12,19 

344:22 345:12,22 

346:7,19 

tocopherol 218:11 

tocopherols 3:21 

217:19,21 363:6 

today 24:19 46:15 

102:15 105:18 110:8 

163:19 186:10 194:16 

194:19 221:14 367:3 

tofu 101:8 112:14 

121:19,21 

tolazoline 13:13 

told 50:15 306:4 323:17 

333:3 

tolerance 250:5 261:9 

tolerances 143:18 

Tom 1:15 25:14 36:2 

39:5,18 41:9,15,19 

44:22 48:12 49:19 

53:6 60:1 62:6 63:20 

73:15 79:15,17 80:19 

81:16 88:22 90:21 

94:17 96:5,19 98:18 

101:3,17 102:9,19 

104:19 112:9 114:14 

126:16 127:20 131:17 

207:18 218:7 219:11 

226:7 229:16 232:20 

235:17 236:22 239:11 

241:3 244:13 253:5 

258:22 273:4 280:3 

280:22 298:9,11 

302:5 344:4 350:18 

353:22 359:5 360:17 

360:22 

Tom's 47:13 135:3 

155:22 212:11 

tomato 301:1 

tomatoes 330:22 

tool 113:5 142:6 248:5 

toolbox 149:2 267:15 

tools 280:1 331:7 

335:22 

top 308:13 

topic 141:13 208:21 

258:4 260:19 299:3 

307:5 337:14 

topics 3:7 4:8 122:18 

torn 62:9 78:9 

totality 40:3 113:22 

totally 24:2 36:15,17 

81:14 259:16,20 

touch 343:7 

touched 70:2 

tough 221:8,9 

tougher 261:15 

toxic 42:13 143:15 

200:9 202:3 250:7,19 

toxicant 250:18 

toxicity 31:2 68:15 

206:19 251:2 317:6 

338:4 

toxics 243:19 

TR 10:10,14 13:20 15:7 

15:19 17:7,13 19:18 

58:4,8 117:16 119:13 

120:22 121:12 122:5 

122:14,19 124:4 

143:17 144:2,13 

150:15,22 152:2 

159:11,19 212:2 

215:16 229:3 231:7,7 

232:16,16 242:7,7 

248:21 249:2,14 

250:12,22 251:5,15 

262:17 271:11 299:4 

299:7 303:9 304:8 

306:10,16,19 308:1,2 

312:18 318:9,10 

332:4 339:13 361:19 

361:21 

trace 3:5 14:1,3,4,6 

15:9,19 16:13 135:5 

363:13 

track 140:8 

tracking 139:21 359:21 

trade 33:7 112:20 

146:18 208:12 213:12 

213:18 227:11 234:14 

280:14,15 334:6,15 

traditional 241:20 

246:6 249:18 251:10 

tragacanth 235:11 

trainable 298:11 

training 351:17 

transcripts 87:17 

296:19 

transfer 365:2,3 

transformed 125:5 

138:11 

transition 236:9 

transparency 364:18 

transplant 312:4,5 

transplanting 302:11 

transplants 253:19 

transport 176:4 

transportation 258:3 

transported 176:1 

traps 321:15 

treat 6:2 25:18 165:17 

223:21 

treated 7:11 36:9 

276:21 

treatment 6:8 7:13,14 

9:21 10:9 12:13 36:14 

165:9,10,18 170:1 

332:1 333:7 

treatments 12:1 165:8 

169:18 171:5,8 

tree 20:14 74:5 259:2 

261:8,12 279:18 

283:3 331:1 333:4 

trees 254:9 255:9,10 

256:6,7,10 260:21 

282:18,18 283:1 

trellising 279:17 

tremendous 307:13 

347:1 366:17 

trial 165:3 

tricky 313:3 

tried 216:14 224:21 

287:15 310:2 323:21 

trouble 256:14 

TRs 122:6 

true 21:7 27:17 35:16 

75:13 82:19 157:19 

182:7 222:7 240:20 

truly 74:1 177:1 179:12 

182:5 285:19 368:9 

trunk 282:21 

trust 40:19 49:1 

trusted 40:13 

Truthfully 310:20 

try 39:14 40:4 49:20 

81:10 153:9 167:3 

206:10 222:12 232:14 

294:18 310:22 311:3 

348:3 

trying 81:1 92:22 

123:21 130:13 168:13 

189:21 261:7 286:7 

287:11 292:17 294:16 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
402 

297:11 298:22 302:20 

304:7 306:7 309:6,9 

310:16 311:4,18 

323:15 350:21 

Tucker 2:6 52:11 87:17 

95:12 107:3,4 341:10 

351:15 367:20 

Tuesday 57:19 

tuned 348:15 

tunnels 330:22 

Turkey 134:3 

turn 5:14 11:20 24:16 

196:17 205:1 247:8 

319:7 347:20 356:17 

turning 217:17 247:5 

turns 180:19 

tweaks 286:1 350:5 

twice 26:13 

two 9:11 12:8 13:13 

33:20 34:7 52:15 

56:22 58:13 77:22 

79:8 109:16 110:20 

116:4,8 118:21 122:3 

122:11 140:5 153:5 

154:13,16 159:2,6 

160:12 164:2,5,12,15 

164:17 167:11 168:9 

168:16,20 169:3,4 

171:1 178:13,19 

187:20,21 188:14 

191:9 192:6 198:13 

198:15 199:22 204:14 

205:5 213:8 222:22 

223:1 239:10 247:13 

259:13 261:18 265:9 

265:15 271:22 274:6 

277:3 280:11,18 

300:16 302:6 312:2 

313:18 314:3 317:22 

325:17 329:11 362:3 

363:12 

two-thirds 43:7 

two-year 178:15 199:20 

twofold 56:14 

type 170:8 210:7 242:9 

243:15 301:4 320:6 

343:1 

types 165:3,8 168:1 

208:15 215:11 243:19 

318:18,22 

typical 169:9 315:6 

typically 213:22 290:3 

typo 229:21 230:5 

U

U.S 57:17 58:11 134:3 

161:12 186:9,10,21 

187:6 188:15 189:14 

220:20,22 221:8 

248:12,16 269:4 

335:7,11 

ultimately 26:19 71:5 

unaccounted 182:2 

unanimous 11:11 106:3 

106:4 298:10,11 

unanimously 69:7 

unanswered 224:11 

unborn 343:13 

unclear 212:21 213:17 

uncomfortable 100:15 

104:2 322:7 

uncommon 239:18 

undergone 117:22 

underlying 281:19 

underpin 17:10 

understand 6:19 36:16 

94:14 153:11,16 

169:7 175:15 183:2 

191:17 243:21,22 

294:16,19 297:5 

309:9 310:15 335:18 

345:3,9,16 

understanding 23:15 

96:14 98:20 127:20 

128:2 129:13 257:14 

266:16 

understood 97:14 

179:9 296:3 

unfortunate 326:3 

unfortunately 40:11 

174:19 187:1 204:16 

300:6 

unicellular 123:10 

uniform 68:7 131:6 

Union 198:11 

unique 35:18 77:12 

146:2 

unit 238:8 

United 1:1 33:21 57:15 

342:17 343:4,17 

universal 114:16 115:8 

universally 70:10 

universities 225:4 

university 2:9,9 160:14 

160:18 161:8,10 

unknown 219:2,8 307:1 

unlabeled 45:21 

unpack 153:15 

update 4:6,20 88:19 

160:9 162:7 298:21 

365:13 

updated 119:12 120:22 

210:15 300:7 

updating 297:1 

urban 38:13 49:15 

urged 115:18 

urgency 207:22 

urine 316:19 

usable 193:16 271:18 

usage 91:16 99:22 

208:14,18 213:19,20 

237:21 

USDA 20:6 23:2 33:22 

56:15 163:2 183:17 

223:9 246:18 334:19 

USDA's 340:15 

useful 79:12 94:21 

162:22 209:17 332:8 

333:9 

users 38:15 232:1 

234:22 

uses 6:1 13:9 19:15 

31:20 45:16 90:18 

92:9 96:16 97:8 99:4 

99:15,19 100:12,15 

100:17,20,22 101:1,7 

104:3,7,11 110:10 

121:17 123:19 137:1 

137:5 138:13 140:1 

143:3 147:22 155:9 

186:17,19 211:21 

213:13,21 217:3 

229:17 230:3 231:18 

249:5 269:10 277:3 

363:12 

USP 113:12 

usually 169:10 332:1 

utilize 173:9 175:13,20 

176:3,14 177:19 

182:1 184:2 

utilized 174:15 178:7 

181:14 195:13 201:6 

203:13 

utilizing 177:1,9,18 

V

vaccine 149:18 

vaccines 142:3 150:2 

363:16 

vadose 160:13 161:3 

vague 242:20 

valid 21:18 35:2 344:21 

345:19 

validate 175:5 177:1 

179:20 181:4 199:15 

201:14 

validated 179:6 183:3 

203:16 257:22 

validating 201:20 

validity 181:2 182:5 

Valley 116:14 

valuable 77:1 158:12 

366:1 

value 76:19 178:5,6 

184:10,11,13 337:6 

value-add 77:2 

value-added 76:5 

values 184:18 

vaporized 333:20 

variable 250:6 

variables 15:16 

variation 36:13 

variations 38:12,13 

varies 14:13 15:1 

varieties 255:6 260:13 

260:13,14 

variety 112:12 119:5 

121:17 125:6 146:5,9 

147:21 231:15,19 

251:12 256:12 260:22 

330:10,10 

various 28:18 31:16 

84:22 100:22 208:20 

213:13 

vary 137:1 

varying 38:5 

vast 42:3,4 306:20 

350:3 

vastly 46:9 48:15 

vegetable 133:21 248:9 

279:9 293:20 319:1 

320:5 

vegetables 26:6 109:11 

324:11 339:6 

vegetarian 57:12 58:2 

vegetative 145:15 

146:4 290:6,9,22 

291:6 292:8,8,9 294:1 

294:2,3 

verbal 33:8 

verification 142:15 

verify 22:10,11 

verifying 120:14 

Vermont 324:19 

Vernon 164:3,4,21,21 

167:21 188:21 

version 74:10 335:1,1 

versions 119:22 208:8 

versus 36:19 38:12 

39:10 49:15 200:10 

232:10 301:1 328:5 

343:10 352:22 

vessel 267:6 

vessels 153:5 

veterinarian 12:4 

veterinary 12:12 

vetted 131:7 

vetting 117:4 

viable 119:2 261:12 

318:13 335:4 

Vice 1:12 

view 29:6 39:7 45:16 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
403 

147:1 158:13 165:6 

210:18 219:9 259:22 

viewed 69:20 

viewpoints 366:2 

vinegar 210:7 

Vinylon 300:14 

violation 69:17 

violative 29:22 

Virginia 346:8 

visiting 160:16 

vital 94:4 148:12 

vitamin 19:17,17,20 

148:2,14,16,17 149:5 

152:2 158:4 213:9 

214:15 

vitamins 3:5,18 18:5,6 

18:10,18,22 19:6,10 

19:14 20:2,4,8,9,12 

20:21 21:5 135:21 

136:3,8 152:1,2,5,6 

152:10 154:1,7 

156:19 157:1,5 

207:17,19 208:1,17 

213:2,3 214:21 363:3 

363:13 

voices 362:10 

volatile 201:3 

volcanic 134:1 

volume 134:5 145:9 

146:2 195:2 

volumes 195:7 

von 77:21 

voted 26:19 46:22 52:2 

52:4 59:2 69:7 241:8 

352:1 362:22 363:14 

votes 4:19 46:16 51:4 

52:15 53:22 55:15 

61:16 64:16 66:22 

87:2 107:11 264:2 

265:2 272:20 273:18 

275:16 276:14 284:6 

285:4 356:3 359:20 

360:2 362:15 

voting 41:16 50:9 52:12 

53:8 64:1 66:4 86:8 

90:5 91:1 93:14 130:5 

130:5 350:1 353:8 

362:10 

W

wait 72:7 85:15 128:20 

129:7,8 160:2 194:2 

205:18 286:13 287:10 

waiting 46:12 281:13 

299:8 

Wakame 4:4 246:4,5,14 

362:15 

wall 10:20 224:22 225:6 

302:19 

wanders 176:10 

wanted 10:3 28:22 

32:11,12 47:18 49:19 

66:1 91:18 93:15 

98:13 100:6,10 107:7 

111:16 133:6 153:12 

245:21 252:9 308:18 

309:17 338:14 341:1 

341:14,19 343:7 

358:17 

wanting 49:4 98:15 

132:17 

wants 94:22 279:5 

337:12 

warm 164:10,14 

warm-blooded 67:21 

warmer 188:22 189:1 

302:10 

warn 287:13 

warrant 67:5 

warrants 279:21 

wash 109:10,12 110:12 

111:5 212:3 283:3 

washing 180:3 

Washington 1:9 2:9 

160:14 164:3,4,13,20 

169:4 255:9 

wasn't 99:3 116:14 

196:11 232:18 234:9 

245:18 257:17 280:7 

281:11,19 291:11 

305:18 

waste 31:4 337:3 

wastes 337:5 

wastewater 13:1 

watch 78:2 

water 43:1 109:10,12 

109:13 112:16 134:3 

142:22 145:22 146:21 

147:8 201:10 210:8 

289:16 302:19 310:5 

310:6 315:8 346:22 

347:3,6 

waterways 144:7 

way 16:22 17:3 37:18 

39:12 40:6,7 41:13 

52:2 62:14 75:20 

81:22 82:15 85:6 

90:20 91:8 92:21 95:4 

101:14,15 102:6,17 

108:1 111:22 112:1,5 

129:1 140:22 159:14 

169:15 172:15 175:8 

184:3 186:22 201:15 

256:21 258:12 261:20 

268:13 311:6 319:11 

321:14 329:13,15 

350:1,11,19 358:21 

ways 47:22 125:6 135:7 

158:15 173:22 210:1 

279:11 

weak 267:22 

weakest 214:18 

wealth 184:15 

webinar 29:18 42:8,12 

72:17 228:2 317:4 

341:21 

webinars 338:17 

website 20:17 253:15 

week 145:3 226:5 

321:10 368:8 

weigh 40:4 107:17 

108:7 235:10 

weighed 122:11 215:9 

346:14 

weighing 94:15 

weight 17:5 

weird 239:20 241:7 

327:15 

welcome 107:4 160:11 

welfare 15:15 

went 8:3 106:22 132:11 

182:18 204:1 205:15 

253:15 266:19 277:10 

286:8 306:11 308:3 

328:17 348:6 368:20 

weren't 129:4 185:16 

324:3 

west 33:2 

wet 239:7 

wetter 188:1,1 

wheat 268:3 

whey 73:13 

Wholesaler's 324:19 

wholesalers 33:2 

257:16 267:13 280:15 

336:20 

wide 16:2 112:12 

121:17 131:1 147:9 

147:21 149:7 208:14 

231:11,15 

widely 13:8 14:16 82:8 

108:18 109:4 110:16 

117:8 124:10 134:7 

136:17,17 231:18 

314:21 315:20 318:5 

321:13,13 332:7,12 

333:8 

wider 99:19 

widespread 333:1 

wife 220:9 

wild 144:4 227:3 229:4 

willing 162:5 194:2 

348:18 

wine 133:21 231:13 

wine- 26:6 

wine-making 212:1 

wing 25:10 

Wisconsin 225:18 

wish 204:10,12 221:22 

224:3 322:7 352:11 

wishing 146:20 

withdraw 354:14 

358:13 

withdrawal 12:5 

withdrawn 354:5 

withdrew 354:19 

wonder 125:8 236:14 

303:1 

wonderful 204:16 

wondering 126:22 

138:4 246:17 253:4 

wool 7:21 

word 46:10 94:8 103:12 

103:17 105:6 144:9 

174:19 179:15,16 

295:8,8 366:12 

worded 129:11 

wording 7:18 8:1 23:13 

85:11 87:7 95:11 96:8 

96:15 297:8 352:13 

357:5 358:3 

wordings 229:1,7 

words 62:19 68:7 

103:22 278:9 291:15 

294:5 351:8 357:2,9 

wordsmithing 289:2 

295:11 

work 4:20 44:1 52:13 

90:12 105:3,9 118:10 

121:7 125:21 126:5 

131:3 133:1,8 140:16 

140:20 141:14 150:20 

197:11 201:20 211:11 

223:5,9 225:4,14 

228:11,13 247:2 

271:4 305:8 311:4,18 

318:19 322:9 332:13 

334:19 338:12 355:5 

360:7,21 365:20 

366:17 

workable 179:7 

worker 45:15 46:1 66:1 

319:15 320:7,9,12 

325:8 

workers 45:9 46:8,11 

319:11 325:5 

workhorse 367:2,6,18 

working 45:9 56:12 

216:11 225:3 266:1 

300:4,11 305:11 

348:18 360:11 

workload 102:15 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
404 

228:12 

works 140:10 161:18 

164:16 271:6 311:5 

world 30:14 40:19 

177:14 189:9 199:13 

201:14 238:8 271:17 

world's 30:8 

worldwide 239:1 250:3 

worm 329:6 

worms 328:15 

worry 180:9 

worth 126:10,13 

worthless 316:20 

worthwhile 108:11 

wouldn't 17:13 92:16 

96:21 241:12 349:21 

352:1 

wound 29:13,15 

wrestled 204:15 

writ 138:16 

write 89:18 95:10 

writeup 218:21 

writeups 116:9 338:13 

writing 330:3 

written 12:3 33:6 62:14 

102:10 143:10 228:1 

280:7 289:4,15 309:9 

334:22 338:17 339:1 

341:21 353:9 355:1 

358:8 

wrong 281:9,14 296:21 

304:6 328:8,9 

wrote 20:6 146:20 

331:21 360:18 

X

xanthan 144:15 

xylazine 3:4 11:20,21 

12:11 13:3,13 363:12 

Y

y 180:4 

yard 255:5 

year 27:3 75:4 168:12 

170:8 191:6 225:14 

225:14 250:21 254:4 

255:9,10 257:4 

258:21 261:8,14 

286:14,15 287:10 

289:9,17,21 290:2,5 

290:17 

year's 300:6 

years 70:17 75:6 141:8 

153:22 154:8 159:7 

163:3 168:9,17,21 

169:4 171:1,3 178:13 

178:19 180:9 191:9 

198:13,15,18 216:9 

234:10 255:20 261:18 

311:8 319:21 321:1 

324:1 334:18 351:18 

355:6 

yeast 3:15 123:17 

136:14,15,16,19 

137:10 138:1,12,17 

139:9 141:5,7 149:17 

152:9 185:17 212:19 

219:16,21,21 220:3,3 

363:1 

yeasts 136:21 137:2,4 

yeses 106:19 

yesterday 5:11,18 

300:2 323:18 334:21 

yield 165:22 223:19 

237:12 339:11,16 

yielding 107:13 

yields 356:8 

young 156:10 

younger 222:21 

youth 343:13 

YouTube 40:7 

Yuzu 241:19 

Z

Zea's 367:16 

zero 61:18 64:17 67:1 

87:3 254:16 264:4 

265:3 272:21 273:19 

275:17 276:15 284:7 

285:5 356:5 

zone 160:13 161:3,4 

Zurich 160:21 

0

1

1,200 222:17 

1:36 205:10,16 

10 3:4 198:18 307:8 

324:1 

10- 106:19 

10:25 106:19 

10:26 106:22 

10:35 106:20 

10:47 107:1 

100 92:13 101:19 111:9 

111:13 159:16 178:14 

184:3,7 193:20 195:4 

234:15 249:14 301:3 

308:18 333:3 

100.5 113:20 

105 113:21 

107 249:14 

11 3:4 288:17,18 

11:45 154:13 

11:46 158:19 

110 3:10 

112 3:11 

114 3:11 

117 3:12 

118 3:12 

12 291:8 293:11 

12/27/2018 7:7 

12:36 205:9 

12:37 205:15 

121 3:13 339:13 

123 3:13 

13 55:16 182:11 203:20 

130 339:14 

133 3:14 

135 3:14 

136 3:15 

14 3:5 54:1 61:17,18 

64:17 67:1 87:3 

181:17 245:7 264:4 

265:3 272:21 273:19 

275:17 276:15 284:7 

285:5 356:5 

142 3:15 

145 3:16 

147 3:16 

15 18:22 245:4 306:4 

311:8 

155 3:17 

156 3:17 

16 15:19 

17 7:6 26:13 

172 4:6 

17963 178:16 

18 3:5 

1962 248:13 

1975 248:18 

1995 18:9 

1996 335:13 338:4 

1997 336:22 

2

2 7:12 193:19,20 

2,000 222:20 

2.5.2.4(a)(4) 289:3 

20 216:9 306:3 308:12 

200 255:10 

2000 11:10 336:21 

2002 12:9 13:12 

2005 18:9 249:20,20 

2007 7:1 

2010 18:9 

2011 332:4 

2012 7:1 208:9 

2013 15:7 247:21 

2014 247:21 334:18 

2015 9:6 18:9 22:19 

168:9 169:14 315:19 

2016 11:11 57:5 248:4 

248:20 266:5 

2017 11:12 26:13 168:9 

169:15 218:6 237:7 

2018 7:3,6 26:14,16,18 

46:7 249:2 266:19 

274:9 280:10 

2019 1:5,7 4:11 12:10 

13:20 26:22 168:11 

285:9 349:7 353:21 

2021 3:9 4:1,13 5:19 

24:13 

205.105(e) 20:8 

205.206 242:1 246:9 

205.601 247:18 248:2 

264:8 273:3 275:21 

284:10 313:19 314:17 

314:17 316:11 

205.601(i) 314:20 

205.602 82:6 

205.602(g) 337:20 

205.603 18:10 

205.603(a) 10:8 11:22 

205.603(d) 14:3 

205.605 118:21 

205.605(a) 56:7 62:18 

65:3,14 218:5 

205.605(b) 26:11 54:4 

218:1 

205.606 57:22 67:8 88:2 

359:4 

206 3:18 

207 3:18 

209 3:19 

20th 119:14 

210 251:5 

211 3:19 251:6 

212 3:20 

215 3:20 

216 3:21 

217 3:21 

221 4:2 

226 4:2 

230 4:3 

233 4:3 

238(a)(2) 19:5 

24 247:21 

242 4:4 

246 4:4 

247 4:9 

25 3:7 199:19 

26 1:7 

265 4:9 

266 4:10 

276 4:10 

285 4:11 

298 4:12 

3

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
405 

3 5:4 210:20 

30 156:2 339:1 

314 4:14 

316 4:14 

317 4:15 

321 4:15 

324 4:16 

330 4:16 

331 4:17 

333 4:17 

336 4:18 

337 4:18 

348 4:19 

35 206:22 

36 7:13,20 9:20 

360 4:20 

365 4:21 

368 4:22 

4

4.1.3 296:11 

4.1.4 296:11 

4.1.6 286:5 289:3 291:1 

291:12 294:7,8,11,21 

295:1 296:12 297:11 

350:11 352:6,17 

4:14 348:6 

4:15 348:1 

4:25 348:3 

4:30 348:7 

4:51 368:16,20 

491 250:22 

4th 150:16 

5

5 3:2 71:8 92:9 222:17 

5029 288:9 

5030 19:22 

515 1:9 

55 3:8 

55th 5:4 

5988 178:8 

6

6 3:3 113:9,16 288:16 

296:5,5 

60 260:13 

605 73:22 

605(b) 119:21 

606 68:21 69:3,22 70:15 

74:1,15,17 75:10,11 

77:7 79:18,18 80:4,13 

80:16 81:9 91:11 

92:14 97:3 223:11 

238:1,14 239:11 

64 3:8 

65 250:17 

686 176:9,11 

7

7 26:11 91:11 113:14,19 

756 178:8 

8

8 3:3 

8:30 1:9 24:18 

8:34 5:2 

81 229:20 

85 20:15 

9

90 92:13 181:20 307:7 

93 113:19 

95 71:8 202:13 

98 3:10 

993 251:9 

994 251:9 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
 

406

C E R T I F I C A T E 

This is to certify that the foregoing transcript 

In the matter of: National Organic Standards Board

Spring 2019 Meeting

Before: USDA

Date: 04-26-19

Place: Seattle, WA

was duly recorded and accurately transcribed under 

my direction; further, that said transcript is a 

true and accurate record of the proceedings. 

 ----------------------- Court Reporter 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com