Formal Recommendation 

From: The National Organic Standards Board (NOSB)

To: The National Organic Program (NOP)

Date: April 28, 2022

Subject: Policy and Procedures Manual (PPM) Revision 

NOSB Chair: Nate Powell-Palm

The NOSB hereby recommends to the NOP the following:

Other: X

Statement of the Recommendation: 

The NOSB recommends minor clerical changes for clarity to the Policy and Procedures Manual (PPM). A

sentence requiring written commenters to refrain from personal attacks was added for consistency with 

parameters for oral comments. A redundant header “Oral Comments” was also removed.

Rationale Supporting Recommendation:

The NOSB’s Policy and Procedures Manual (PPM) was established to assist the NOSB in the 

implementation of its duties under the Organic Foods Production Act (OFPA) and the Federal Advisory 

Committee Act (FACA). The PPM contains operating procedures and policies for the NOSB, along with a 

framework for public comments.

Public commenters supported the update to the PPM, and provided some additional feedback about 

terminology that the PDS will consider for a future update. Commenters reflected in their written 

statements that discourse is powerful, and it may be difficult to offer rebuttal without direct reference 

to previous statements by other commentors. They went on to note that respectful dissent is allowed 

and appreciated in public comments.

NOSB Vote: 

Motion to accept the proposal on the PPM update to the public comment process 

Motion by: Mindee Jeffery

Seconded by: Jerry D’Amore 

Yes: 15 No: 0 Abstain: 0 Absent: 0 Recuse: 0

Motion Passed
National Organic Standards Board 

Policy Development Subcommittee Proposal

Policy and Procedures Manual (PPM) Revision

January 19, 2022

Introduction and Background 

The Policy and Procedures Manual (PPM) was established to assist the National Organic Standards Board 

(NOSB) in the implementation of its duties under OFPA. It contains operating procedures and policies 

for the NOSB. During the period since the last revision (October 2019), the Policy Development 

Subcommittee has been compiling a list of minor revisions and suggested changes. The PDS has 

reviewed these suggested changes and proposes the following as listed in the table below. 

Summary Table of Changes 

Section/Page Changes (red highlight indicates additions, strikethrough indicates deletions)

VIII. E Page 33

Made minor clerical changes for clarity.

Added a sentence requiring written commenters to refrain from personal attacks.

Removed a redundant header “Oral Comments”.

E. PUBLIC COMMENT 

The NOP and NOSB encourage public comment and work collaboratively to increase 

opportunities for greater participation by a broad range of people, employing various modes of 

communication and modern technology whenever possible. Individuals may present oral 

comment at either a pre- meeting electronic webinar or at the in-person NOSB meeting.

Individuals are encouraged to submit written comments and may also present oral comment at 

either a pre-meeting electronic webinar or at the in-person NOSB meeting. 

Comments Before Public Meetings:

Written comment: 

All members of the public are encouraged to submit public comment in writing according to the 

Federal Register Notice. Written submissions allow NOSB members the opportunity to read 

comments in advance, eliminate or decrease the need for paper copies to be distributed during 

the meeting, and allow each NOSB member to review and analyze data and information well 

ahead of the public meeting and possible voting. 

 Commenters shall refrain from including personal attacks or remarks that might impugn the 

 character of any individual. 

Oral Comments 

Oral comments: Individuals may present oral comment at either a pre-meeting electronic 

webinar or at the in-person NOSB meeting. May be received via a virtual meeting/webinar. 

Public notice of such electronic meetings will be included in the Federal Register notice 

announcing the public meeting. Such electronic pre-meetings may allow individuals more time 
to present their data or information, reduce the need to attend the public meeting in person, 

reduce our carbon footprint, and give the NOSB more time to absorb the information. Such 

electronic meetings shall be recorded and made available to the public and to NOSB members.

Motion to accept the proposal on the PPM update to the public comment process 

Motion by: Mindee Jeffery

Seconded by: Jerry D’Amore 

Yes: 3 No: 0 Abstain: 0 Absent: 0 Recuse: 0