Updated June 17, 2010

Formal Recommendation by the 

National Organic Standards Board (NOSB) 

to the National Organic Program (NOP)

Date: April 29, 2011

Subject: Review of NOSB Vice Chair and Policy Development Committee 

Job Descriptions 

Chair: Tracy Miedema

 

The NOSB hereby recommends to the NOP the following: 

Rulemaking Action 

Guidance Statement 

Other X

Statement of the Recommendation (Including Recount of Vote): 

The recommendation proposes a change to the NOSB Policy and Procedures 

Manual (PPM) to clarify the job descriptions of the NOSB Vice Chair and the 

Policy Development Committee with regard to the responsibility for maintaining 

the PPM. The NOSB voted unanimously to accept the recommendation. 

 

Rationale Supporting Recommendation (including consistency with 

OFPA and NOP): 

The Organic Foods Production Act of 1990, 7 USC 6518 (a), directed the 

Secretary of Agriculture to establish the National Organic Standards Board and 

described its composition, authority and duties. The NOSB Policy and

Procedures Manual govern the operations and policies of the board. 

Committee Vote:

Moved: Barry Flamm Second: Joe Dickson

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

Policy Development Committee 

Proposed Recommendation 

Review of NOSB Vice Chair and 

Policy Development Committee Job Descriptions 

April 29, 2011 

Introduction 

The Policy and Procedures Manual (PPM) of the NOSB represents the board policies 

on committee responsibilities, board procedures, and other matters of board operational 

policy. The language of PPM is currently unclear on who is responsible for the ongoing 

maintenance of the PPM, since the descriptions of the responsibilities of both the Policy 

Development Committee and the NOSB Vice Chair include direct responsibility for 

maintaining the PPM. This recommendation clarifies the respective roles of the PDC 

and NOSB Vice Chair with regard to the maintenance of the PPM. 

Background 

It was noted by members of the PDC and the board in Fall 2010 that the PPM is not 

clear as to whether the maintenance of the PPM is the ultimate responsibility of the 

PDC or the NOSB Vice Chair. 

Section II of the PPM describes the responsibilities of the NOSB Vice Chair: 

Vice Chair 

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

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

Section IV of the PPM describes the responsibilities of the Policy Development 

Committee: 

Policy Development Committee (PDC) 

The Policy Development Committee makes draft recommendations for consideration 

by the Board to provide guidance, clarification or proposed standards of Board 

operations, policies and procedures. The PDC maintains the content and updates to 

the NOSB Policy and Procedures Manual and New Member Guide. The PDC 

occasionally works with other committees to develop joint recommendations where 

policy issues are involved. 

These two sections assign responsibility for maintenance and upkeep of the PPM to 

both the VC and the PDC. 

 
Recommendation: Review of NOSB Vice Chair and 

Policy Development Committee Job Descriptions 

April 29, 2011

Page 2 of 3

Relevant Areas in the Rule 

The Organic Foods Production Act of 1990, 7 USC 6518 (a), directed the Secretary of 

Agriculture to establish the National Organic Standards Board and described its 

composition, authority and duties. 

Discussion 

The guidelines contained in the Policy and Procedures Manual directly impact the 

internal operation and policies of the NOSB, and each board member has a vested 

interest in the PPM’s content and integrity. The participation of the Vice Chair in the 

maintenance of the PPM serves the interests of the Executive Committee in the smooth 

and effective operation of the overall board. However, the PDC is charged with matters 

of internal board policy, and the PPM clearly also falls within this sphere. In 

consideration of these equally important interests in the maintenance of the PPM, the 

Policy Development Committee proposes that the responsibility be shared 

collaboratively between the PDC and the NOSB VC. It is essential that the work of the 

maintenance of the PPM occur within the PDC, so that proposed changes are subject to 

the standard procedures regarding committee recommendations, votes, and 

presentation to the overall board. 

The Vice Chair of the NOSB typically serves as a member of the PDC, because of the 

shared interest in board operations between the VC and the PDC described above. The 

committee recommends that the VC job description be updated to reflect that she or he 

should serve as a member of the PDC, and should work collaboratively with the 

members of the PDC to facilitate the ongoing maintenance of the PPM. The PDC 

description should be updated to reflect this collaborative relationship with the VC on 

the maintenance of the PPM. 

Recommendation 

The PDC recommends that Section II of the NOSB Policy and Procedures Manual be 

amended as follows: 

Vice Chair 

The Vice Chair shall act in the absence of the Chair. The Vice Chair shall serve as a 

member of the Policy Development Committee, and work collaboratively with the 

PDC’s members on the also be responsible for maintenance and upkeep of the 

Policy and Procedures Manual.

The PDC recommends that Section IV of the NOSB Policy and Procedures Manual be 

amended as follows: 

Policy Development Committee (PDC) 

The Policy Development Committee makes draft recommendations for consideration 

by the Board to provide guidance, clarification or proposed standards of Board 
Recommendation: Review of NOSB Vice Chair and 

Policy Development Committee Job Descriptions 

April 29, 2011

Page 3 of 3

operations, policies and procedures. The PDC maintains the content and updates to 

the NOSB Policy and Procedures Manual (in collaboration with the NOSB Vice 

Chair) and New Member Guide. The PDC occasionally works with other committees 

to develop joint recommendations where policy issues are involved. 

Committee Vote 

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

Motion by: Joe Dickson Second: Jay Feldman 

Yes: 5 No: 0 Abstain: 0 Absent: 0 Recuse: 0