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Town Hall 

Strengthening Organic Enforcement 

USDA Agricultural Marketing Service (AMS)

National Organic Program (NOP)

Jennifer Tucker, Ph.D., Deputy Administrator

Matthew Pavone, Policy Analyst 

July 17, 2018

3
NOP Regulatory Pathways Forward 

1 Strong Organic 

Control Systems 

Trusted People, 

Processes, and Rules

2 Farm to Market 

Traceability 

Worldwide Supply 

Chain Integrity 

3 Robust

Enforcement 

A Level Playing 

Field for All 
NOP Webinar Format 

Overview of potential topics - two at a time.

Display 2-3 questions for response. 

5-minute pause to ‘chat’ responses to the

questions.
How do I ‘Chat’ My Input? 

• Go to your chat box located in your lower left corner.

• Enter the question number followed by your input.

• For example, typing “2” followed by input shows us 

you’re addressing question #2.

“2 Your Input...”
Rule Making Topics

7

Areas of Focus

• Federated Organic Certificates

• Satellite Offices
Rule Making Questions

8

Questions 

Q1: What challenges would Certifiers face if 

required to use a federated organic certificate? Is 

there an alternative you would suggest? 

Q2: What should NOP consider with respect to 

accrediting satellite offices? 
Rule Making Topics

9

Areas of Focus

• Inspectors: Qualifications, Training 

and Field Evaluations

• Certification of Grower Groups
Rule Making Questions

10

Questions 

Q3: What should the minimum qualification and 

training requirements be for organic inspectors?

Q4: What specific practices might NOP consider for 

Grower Groups that are not already addressed by the 

2002 and 2008 NOSB recommendations? 
Rule Making Topics

11

Areas of Focus

• Operations excluded from organic 

certification 

• Increased reporting to the organic 

INTEGRITY database
Rule Making Questions

12

Questions 

Q5: Which types of excluded operations 

should be required to be certified and why?

Q6: Should any of the current exclusions in the 

USDA organic regulations remain in place?
Rule Making Topics

13

Areas of Focus

• Import Certificates

• Update regulatory requirements

for equivalency arrangements
Rule Making Questions

14

Questions 

Q7: How might the rule address full supply chain 

traceability from farm to table?

Q8: How can the rule address the integrity of 

organic products imported to the United States?

Q9: What should NOP consider about existing or 

future trade arrangements?
Rule Making Topics

15

Areas of Focus

• Unannounced Inspections 

• Updates to noncompliance and 

appeals process
Rule Making Questions

16

Questions 

Q10: What should NOP consider about the 

costs of unannounced inspections?

Q11: Which parts of the noncompliance 

and appeal processes might NOP need to 

further clarify? 
Next Steps 

• Ongoing Engagement

– Meetings

– NOP.guidance@ams.usda.gov

• National Organic

Standards Board Fall

Meeting

• Spring 2019 Proposed

Rule

• Feedback

17
Tell Us How We Did!

How did you find 

this Town Hall?

What might we do differently 

next time? 
Strengthening Organic Enforcement 

USDA Agricultural Marketing Service (AMS)

National Organic Program (NOP)

THANK YOU

19
Strengthening Organic Enforcement Town Hall Chat, July 17, 2018

USDA Agricultural Marketing Service, National Organic Program 

Sender Message

letis letis hello!

Kelly Abbott Kelly Abbott-ICS yes!

Westley Baker Wes Paramount Coffee yes

Colette Piper Colette, Oregon Tilth. Yes! I can hear you.

veronica reyes Veronica

Beth Unger Beth Unger Organic Valley, yes

ellis collier Ellis Collier- National Ag Law Center. Yes

Elise George Elise George, OEFFA Certification - yes

Megan Megan Megan Hoveland, Ciranda. Yes

letis letis Matias Dortona - LETIS yes!

Richard Bertrand Hello Ventura Foods

Rebekah Ritson Rebekah Ritson, Grain Millers Inc. Yes

Megan McDonald Megan. Food & Beverage Consulting Group. Yes ma'am!

Lynn Coody Lynn Coody, Organic Agsystems Consulting. Yes, I hear you.

Irazu Lopez Yes, Irazu Lopez CERTIMEX

Yutaka Yokote Yutaka Yokote -Yamasa USA- Yes.

Mary Capehart Mary Capehart CROPP

Shelby French yes

Val Schmale NOP CE yes i can hear you

George Kalogridis George C Kalogridis ECOCERT

Susan Halsted Susan - Allen Flavors - I can hear you

Annette Semper Greetings from Organic Partners

Marni Karlin Marni Karlin, Karlin Strategic Consulting

Marisol Oviedo Marisol Oviedo, Northwest Horticultural Council

Gretchen Zimmer Gretchen Zimmer, Only Natural/Bio Nutrition

Jared Clark Jared Clark, Oregon Tilth

Shelby French Bill Wolf - WD+A -- yes

Brittny Bauer Brittny Bauer - Everbest Organics, Inc.

Dimitris Sotiropoulos Dimitris Sotiropoulos: Agronomist - DS CONSULTING, Consultant for 

Organic Control Systems, Greece

Peter Nell Peter Nell, California Certified Organic Farmers (CCOF)

Joan Avila I can hear you!

Jackie DeMinter Jackie DeMinter - MOSA Certification Policy Manager

Joan Avila Secretary, NOP

Bob Bob Bob Turner GrainCorp can hear you

Rebekah Finn Rebekah Finn True Organic Products, I can hear you
Johanna Mirenda Johanna Mirenda, OMRI

Ali Hudson Ali Hudson - Oregon Tilth Certification Officer

Cindy Elder Cindy Elder, OCIA

Leslie Fernandez Leslie Fernandez - CDFA

Elizabeth Tigan Elizabeth Tigan - NICS! Thank you

Feliciana Puig Feliciana Puig - MOSA

Max Max Max Goldberg - Organic Insider

Leslie Fernandez If you can't hear, use a different browser.

Kelly Monaghan Kelly Monaghan, Ash Street Organics, Toronto

Justina vasquez Justina Vasquez, Bloomberg News, yes can hear

Michael Menes Mike Menes - True Organic Products. we can hear you :)

Sandia Martin Sandia Martin of TAB AG GROUP

Darice Wraspir Darice Wraspir - Pacific Foods (Campbell's Soup Company)

Allison Burke I can hear you

Beth Rota Beth Rota - Quality Certification Services (QCS)

Daniel Burkard Daniel Burkard, Holland & Knight

Kyla Smith Kyla Smith, PCO

Neil Millman Neil -- I Love Produce

Alexis Russell Alexis Russell, Ayrshire Farm in Upperville, VA

Paul Schockman Paul and Isaac, we don't have audio yet

Julie Paillat Canadian Horticultural Council

Leslie Fernandez If you can't hear, use a different browser.

Bob Puruleski Bob Puruleski - Big Dutchman (Cage Free Poultry Equipment)

Genevieve Albers no audio, trying a 3rd browser option...

Gibbs Wilson Gibbs Wilson, Valent USA in Georgia

Brittany Jordan i have audio but its very muted

Val Schmale google chrome or firefox work best

Alexis Russell Couldn't hear on Safari, but switched to Chrome and got sound

Gwendolyn Wyard Gwendolyn Wyard, Organic Trade Association

Leslie Fernandez chrome works best

Anna Maria Gottmann Anna Maria Gottmann @Jean Niel

meredith smith Hello, Meredith Smith from ED&F Man, here

Richard Siegel Richard Siegel, Richard D. Siegel Law Offices

roger griess Roger Griess Ag Tec Resources

Terry Smith Terry Smith, Nature's Way Dairy

mike crotser Mike Crotser - Certification Manager Organic Valley/CROPP 

Cooperative

Randy krieg Randy Krieg Sacramento Ag Dept. CA

Stacy Swartwood For audio: You can also try clicking the settings gear icon and select 

"Join with our Flash version at the bottom of the window" that 

appears
Özlem Emirler Özsan Hi, Özlem from ETKO

Glenn Kern Glenn Kern, Carolina Farm Stewardship Association

Rebeca Rabago Wholesum Harvest

Ann Gaitan Hello, Ann Marie Gaitan and Laurie Hale from Diversey, Inc.

Jeff Jeff Jeff Yorzyk - Green Chef Organic-certified company in meal kit home 

delivery

Shannon Brubaker Oregon Dept. of Ag

Brittany Jordan egg innovations

Ashley Vulin Davis Wright Tremaine

Michelle O'Brien Michelle O'Brien - Wegmans Food Markets

Arturo Gonzalez Arturo Gonzalez - Ground-Fresh International here

LUIS LOPEZ Luis López, CCOF

Jacob Neufeld Sunrise Foods International

Elizabeth Figueredo Liz Figueredo - Technical Quality Manager, QAI, Inc.

Madison Kempner Maddie Kempner, Northeast Organic Farming Association of Vermont 

(NOFA-VT)

Paul Schockman Paul and Isaac Naturefresh

Sam Welsch Sam Welsch - OneCert, Inc.

Cydnee Pletcher Cydnee Pletcher - Progressive Agricultural Management

Marcus Caswell Marcus Caswell- Wish Farms

Jessica Walden Jessica Walden - QAI

Jodi Snyder Jodi Snyder: Global Organic Alliance

Nicole Dehne Vermont Organic Farmers

ANDRES ARMSTRONG Chilean Blueberry Committee

Bill Wolf Wolf, DiMatteo + Associates

Genevieve Albers Traditional Medicinals

Ann Marie Hourigan Whole Foods Market

Michael Corbett Sunrise Foods International

Gianfranco Santaliz-Rogers Hello, Is there a call in number?

Rhonda Pudwill Has the webinar started yet?

Leslie Fernandez yes

miraj patel what is prior university graduation year that got the snap work 

registration or tanf work registration

miraj patel how does usda intervene

Erica Lundquist No Audio for me

Leslie Fernandez If you can't hear, use a different browser.

Stacy Swartwood For audio: You can also try clicking the settings gear icon and select 

"Join with our Flash version at the bottom of the window" that 

appears

miraj patel during prior 4 years, people are waiting for usda intervention. they 

explained they are the snap work registration personnel.
Marty Dagoberto pre-test said it was configured correctly, but I'm not getting audio... 

will you be sending out a recording?

Chairperson Thanks so much for joining us today! 

miraj patel fruits, vegetables, grains, oats, coffees, teas

Melissa Elkins Sustainability Coordinator, Community Food Co-op, Bellingham, WA

Chairperson Yes, there will be a recording. 

Chairperson Your Chairperson is NOP. 

Thais Agostini Is there a phone number to call?

Valeria Frances can not hear a thing and my headphones are working

Stacy Swartwood If the audio is still not working, try using a different browser. Chrome 

and Firefox are recommended by other participants.

Amalie Lipstreu Amalie Lipstreu-Ohio Ecological Food and Farm Association

Marty Dagoberto yeah call in number would solve this audio problem..

miraj patel i rather be able to earn my wages for my breakfast oatmeal and tea

JAIME GARCIA Jaime Garcia - Kingdom Fresh Produce

JAIME GARCIA Steve Garza - Kingdom Fresh Produce

Erin Heitkamp I cannot hear the audio despite electing to use the Flash Player

Tessa Tripp Tessa Tripp, International Certification Services, Inc.

miraj patel i paid for my lunch at lasalle bank abnamro 540 madison chicago 

illinois december 2007 to may 2009, prior to 99 weeks 

unemployment insurance claim. i remember the usda salad bar at my 

first employer

Chairperson As new folks are joining, please type in your name and affiliation. All 

chats and this webinar are being recorded. 

Miles Miles Miles McEvoy, Lacewing Auditing and Consulting

Erin Heitkamp Erin Heitkamp - Pipeline Foods

Jody Kenworthy Jody Kenworthy, Maryland Farm Service Agency

Karlin Warner Karlin Warner - OneCert, Inc.

Colleen O'Brien Colleen O'Brien, WSDA Organic Program

Marty Dagoberto Northeast Organic Farming Association, Massachusetts Chapter

Rudy Amador Rudy Amador - Dole Fresh Fruit

Leona Propson Leona Propson, Briess Malt & Ingredients Company.

Jessie Jessie Jessie Bovay, Mercaris

Melinda DeNobrega Melinda DeNobrega -

Andy Hupp OEFFA Certification

Allison Dermond WSDA Organic Program

lila Haddouche Lila Haddouche - Quality

Daniel Gagnon Daniel Gagnon: Herbs, Etc., Inc.

Erica Lundquist Erica Lundquist, NRCS No Audio, flash player not available, installed 

Chrome yesterday and had all green arrows.

Chairperson Thanks for joining, all! Pease introduce yourself as you join. 
hande kemerli Hande Kemerli , Control Union

Ann Gaitan Can you minimize the chat? It is very distracting.

Mayze Fowler-Riggs Mayze Fowler-Riggs, California State Organic Program

Brad Johnson Brad Johnson-Kalmbach Feeds, Inc.

Sarah Reed Sarah Reed - CCOF Certification Services

Gisele Atkinson Gisele Atkinson, Council for Responsible Nutrition

Cynthia Troetschler Cynthia Troetschler: CytoSport Inc.

Chris Grigsby Chris Grigsby: MOFGA Certification Services

Kara Nagel Kara Nagel, NOW Foods

Angela Anegon Angela Anegon - WSDA Organic Program

Britt Britt Britt Lundgren, Stonyfield

Mike Chansilp Mike Chansilp/Vanessa Dyckman - Hain Celestial

Martina Melapie SRS Certification

Annie Berical Annie Berical, OCIA International

Chairperson If you cannot hear, we will post a recording. 

Ignacio Guntin Ignacio Guntin from OIA

yasmin cedamanos Yasmin Cedamanos, CUC

Monique Salhab Monique Salhab, Community Development La Montanita Cooperative

SOPHIE MONTEIRO Sophie Monteiro: Flavor Producers

miraj patel how would usda offer explanation of the usda approach with lasalle 

bank abnamro 540 madison chicago illinois cafetaria novemebr 2007 

to may 2009 ? how did usda select the choices there, with the 

coffees, smoothies, salads, paninis, pizza toaster ovens ?

Ryan Koory Ryan Koory with Mercaris

Brittany Jordan ok thank you

Jennifer Robinson I cannot hear.

Cali Alexander Cali Alexander, H. O. NOFA-NJ Bd. Member

Aubrey Lopatin Aubrey Lopatin, Arbor Teas

Lindsay Jacob AgroThrive, Organic fertilizer

Bhagya Kaja Bhagya Kaja, Tastepoint by IFF

Katriana Garcia Katriana Garcia, Bayer

Juan Guzman Juan Guzman - Bard Valley Date Growers Association

Fatima McClain Fatima McClain, Clover Stornetta Farms

Cynthia Morphet Cynthia Morphet: Global Organics, LTd.

miraj patel what are we learning now week to week with usda approach to these 

government efforts. when we are at local grocery stores, usda is very 

very very silent

Thais Agostini Is there a phone number to call in?

Erica Lundquist Will listen to recording. Try another platform next time!

Clara Ordoñez Clara Ordoñez, OIA
Lee Frankel Lee Frankel - CSO

Cameron Harsh Cameron Harsh, Center for Food Safety

miraj patel usda simply ignores the webinars at the grocery store

Lynn Johansen Lynn Johansen Natures International NICS

Chairperson No phone, listen through your computer. 

Emily Brown Rosen Emily Brown Rosen, Organic Research Associates

Jim Sattelberg Jim Sattelberg: Everbest Organics

miraj patel the salad bar at jewel osco indicate be silent about the faming rules 

in progress

martin Lichty Martin Lichty Farm Service Agency

Gwendolyn Wyard Will be able to provide answers to the questions after the webinar?

James Cook James Cook, SGS

Lori Kenyon NOFA-NY Certified Organic

Jodi Snyder No sound.

miraj patel whats really occurring at usda offices

Jerry Combs Jerry Combs from Crosset Company, a produce distributor

miraj patel what do the usda staff really know

miraj patel how much information does usda staff know about usda's approach

Chairperson Most folks report being able to hear - if you cannot, try a different 

browser, turn up speakers. If that doesn't fix it, call support. 

marissa pyle marissa pyle & jen berkebile - pennsylvania certified organic

miraj patel how would usda staff think about agriculture economics tasks

miraj patel pricing of food items

miraj patel new food items available in usa after 2000

Valeria Frances Google chrome worked

Sherine Kanagasunderam Sherine Kanagasunderam - QTrade Teas

Mark Rokala Mark Rokala, Organic Farmers Association

miraj patel new food items available in usa in 1990s, in 2000s, after 2010

Marty Dagoberto Every other webinar I've ever been a part of had a call-in option for 

audio.

Stacy Swartwood For audio: You can also try clicking the settings gear icon and select 

"Join with our Flash version at the bottom of the window" that 

appears

miraj patel usda approach state to state

miraj patel usda's knowledge on jeanne kitchens grocery store credit

Chairperson We anticipated a lot of interest, that's why we are using computer 

option. The phone option has a ceiling on users. 

Chairperson Q1 and Q2 

miraj patel how does employment network staff think this is town hall
Sam Welsch 1. The problem with certificates is not the validity of the certificate, it 

is the easy availability of certificates that are being used by persons 

who are not authorized to use it. This is the basis for much fraudulent 

activity.

Chairperson Reminder - Start your answer with the number of the Q

miraj patel how many weeks more does usda think social security is requiring 

this sacrifice

miraj patel how does usda determine how to set up farms

Sam Welsch 1. There is no need to required a federated certificate. It would be 

sufficient to require a link to the Integrity database on a certificate.

Cynthia Morphet 1 - How do address equivalencies (e.g. EU and COR)

Rudy Amador 1. How would a federated organic certificate system deal with 

international organic farming ops that export to US?

Richard Mathews Q1 WODPA supports.

Alexis Russell Q1 : As a company that has to source organic ingredients and keep 

certificates current it would be much easier having a uniform 

certificate across all certifiers so I don't have to guess when the 

certificate expires

Richard Mathews Q2 WODPA supports

miraj patel what at jewel osco you are going to remember about your question

JAIME GARCIA 1. Federate organic certificate will need to cover international 

productions

miraj patel at meijer what are people going to remember

Cynthia Morphet 1 - challenges foreign certifiers may face with language/translation 

issues

Juan Guzman Q1 - A Challende would be to reconcile all of the current certifying 

agencies with a Federated Organic Certificate.

Megan Megan Q1: How would a federated organic cert work with EU traces system? 

How would it impact equivalency?

Sam Welsch 2. That is a good idea. OneCert has already applied for separate 

accreditation of our satellite office.

Annie Berical 2: Accreditation audits should visit and review the practices of all 

satellite offices. If satellite offices are being accredited under the 

umbrella of the "home" office, they MUST be part of the 

accreditation audit and their practices and procedures should reflect 

those of the "home" office.

SOPHIE MONTEIRO #2 I support this action

Jerry Combs Q1 What is wrong with current accreditation and NOP certificates, 

and why are you wanting to change it?

Cali Alexander 2. Does/Will equivalency confer regulatory authority, fully?
Elise George Q1: The ability to tailor certificates to the certifier's policies and the 

operation's specific products is essential.

Erin Heitkamp 1- Pipeline Foods supports the idea of a federated organic certificate 

and believes it would go a long way toward efficiently bolstering 

transparency and traceability.

Devin Dowell (WSDA) 1 - Issuing a federated certificate would require everyone to conform 

to the same taxonomy, which would not be a feasible endeavor to 

take on at this point. For most certifiers this would mean using 2 

databases, their own db to manage inspections, workload, and 

processes, as well as the OID for the sole purpose of generating 

certificates.

miraj patel youa re at the meijer produce section, jewel-osco produce section, 

costco wholesale usda produce section, what specifically will be 

remember here. when can people purchase their own groceries 

under usda organic webinars this extent

Kimberly Bousquet 1 - uniformity might make it easier for certifiers to ensure their 

customers they are a valid entity.

Mike Chansilp 1. We support the proposal but with an option to link to Organic 

integrity DB.

Kyla Smith 1: duplicating work. i.e. how to integrate with existing database data

JAIME GARCIA 1. FSVP will need to be involved being that some of these items will 

come from foreign countries

Sarah Reed 1. As long as we can produce it using our own database system, no 

significant burden for CCOF. If it's through Integrity, it would have a 

huge impact on our effectiveness and efficiency and therefore cost of 

certification.

miraj patel what is the federal certificate. you dont learn this certificate at 

marianos, meijer, jewel osco

Synthia Morales Q2 - Synthia Morales Biolatina - respect to accrediting satellite 

offices, we think it would perhaps increase the cost of accreditations 

because if we have many offices then we must pay a fee for each one 

that may be audited at the same time during external audit?

Richard Mathews Richard Mathews - WODPA

Mike Chansilp 1. How would this capture international certifiers?

Nicole Dehne Q1 Certifiers would need to be able to update certificates at any time 

during the year. In addition, we would need to decide on exactly 

what categories of products are listed on certificates- for example 

organic tomatoes vs. organic brandywine tomatoes. Or at least need 

the ability to tailor the products to whatever we might need.
Lori Kenyon Q1. support if level of detail is present and not as general as current 

NOP certificate program.

miraj patel dominicks grocery store used to work in my building at lasalle bank 

and i think they are asking usda for the mediation and connection of 

events from march 2009 staged to march 2001 time.

Rudy Amador 1. Could this system include transaction certificates (such as used for 

exports to EU) in addition to site certification information?

Andy Hupp 1 - It is not clear what problem federated certificates would solve. 

NOP 2603 should be edited and straightened if additional elements 

are necessary to ensure organic integrity. Challenges include 

technology, loss of unique certifier value, and loss of flexibility in 

adapting to the needs of operations.

Lori Kenyon Q2. Support

Richard Siegel Q2 I support accreditation of satellite offices. I just learned yesterday 

that In India, there is recognition agreement with NOP. Operations in 

India certified by certifiers in India are not listed on Integrity 

Database. This is a gap in the database. These operations should be 

on the Integrity Database. As for satellite offices, some of the 

certifiers in India are satellites of certifiers who have NOP 

accreditation. Those clients in India should be on the Integrity 

Database.

Juan Guzman Q1 - Another challenge would be the timing, in order to get a 

certificate as a grower, you need to be audited during harvest; if we 

only harvest once a year this means there could be a gap without 

coverage.

Devin Dowell (WSDA) 1 - (continued) Additionally a federated certificate would not have a 

measurable impact of fraud. Any certificate that is transmitted 

electronically would be able to vulnerable to editing.

Arturo Gonzalez 2 NOP should consider sattelite offices comply to the program the 

same as HQ

Kyla Smith 2: need to have clear definition of what a satellite office is. want to 

ensure remote work would necessitate additional accreditations

Judy Baldwin 1. It would delay the process of certifying the organic certification 

and make the transaction take longer.

miraj patel how many times have i worked with dominicks grocery store, that 

worked at lasalle bank building, in illinois, on the mediation 

clearances. usda apricot scrub approach

Sam Welsch 1. The QR code on the certificate is not useful or necessary. The link 

to the Integrity database is sufficient.

Lee Frankel Q2. How are satellite offices not already covered during the USDA 

process of reviewing the operations of the main office?
Kimberly Bousquet 2 - whether false certificates normally originate from satellite offices. 

Is there really a problem here?

Beth Rota Q2. If they maintain their own procedures and policies, staff training, 

and make certification decisions accreditation may be appropriate. If 

not, satellite offices should not need their own accreditation.

megan fierst Q1- This would add more leadtime from a business prespective. It 

already takes a long time frame to get a label approval. Would this 

add more cost to what we already incur from the certifying agency. 

Would USDA charge a fee for this cert?

Alexis Randolph Q1 it is important that a certificate include brand names of products 

to ensure the exact product and label (ingredients) have been 

approved. However, disclosing brand names on a public website 

discloses confidential supply chain information. Time would be 

needed to integrate certifier and NOP databases.

Michael Menes Q1- if federated organic certificates are made public, this may 

indicate volume information that could be considered private by 

company. consider overall numbers but keeping company name 

confidential.

miraj patel where is it . dominicks rebranded as marianos, however dominicks 

staff that worked at lasalle bank building have not gotten resolution 

yet

Sarah Reed 2. Devil is in the details. What constitutes a satellite office given 

technological connections to centralized offices. What is and is not a 

satellite office, how is training of satellite office conducted, how are 

they managed, what is the oversight.

miraj patel the fda salads approach with 1999 sams club

Melissa Elkins 1 and 2 - would need to have translation services

Neil Millman Q1 -- What options exist for digital certificates? Digital offers security, 

validation, searchability....

Aubrey Lopatin Q2: NOP needs to consider cultural differences in satellite offices 

abroad

Kimberly Bousquet 2 -- maybe not separately certified, but some higher level of oversight 

-- maybe increased frequency of inspection

miraj patel how is usda organic thinking usa citizens are thinking about usda 

organic outside usa

Annie Berical 2. I doubt that separately accrediting satellite offices would be 

affordable for most certifiers.
Devin Dowell (WSDA) 1 - (continued) a more effective but still difficult task would be to 

require that all valid organic certificates are publicly available online. 

Then a physical or electronically certificate would be moot and 

instead they would need to access the certificates from a specifically 

approved office--but this would take a substantial amount of effort 

and maintenance from certifiers to keep this up to date.

meredith smith Q2 - I do not believe that the satellite office should be SEPARATELY 

accredited. If they have a main office and follow all same 

procedures, I believe that a multi-site audit should be used and 

rotate which office gets the audit each year.

Nicole Dehne Q1 I would like to better understand how a federated certificate 

prevents fraud. Also, many certifiers have invested heavily in our own 

database systems, we would like to be able to generate certificates 

from these systems for a more seamless system for our staff.

Sarah Reed 1. The products and fields profile is highly variable and integrity does 

not contain sufficient info to meet market needs, e.g. brands, 

acreage. We would not support federating this portion.

Kate Mendenhall Q2. Would only international (located in a seperate country from 

main office) need seperate accreditation?

Kyla Smith 2: clarification... I meant to say would NOT necessiate additional 

accrediations

JAIME GARCIA 2. Satellite offices should be regulated and checked frecuently so the 

standars will be the same ones

Arturo Gonzalez 2 why do satellite offices are often under a different name?

miraj patel inventory

miraj patel coffees

miraj patel teas

miraj patel mangos

Yutaka Yokote #1 The challenge is the related with other country regulation. How to 

handle with that.There are so many language.

Sam Welsch 1. A major challenge of using a federated certificate is the need to 

include information in a format that is not available on the federated 

version.

miraj patel cereals

miraj patel oatmeals

Ed Treacy Q1. Fraud is a challenge. Has there been consideration for using 

Trellis, the framework (www.trellisframework.org) for securely 

sharing audit and certificate data data that would prevent fraud?

Kimberly Bousquet 2 -- satellite offices should be clearly tied to their home office

miraj patel uscis field office explains what about usda
Beth Rota Q1 Alternative - linking to certificate on the OID to allow for 

verification and reduce altering certificates

Erin Heitkamp 2- I think it is more important to think about sub-contracted 

offices/inspectors. If the individuals are not employees of the 

certifying body, they should be separately accredited.

Rudy Amador 2. Separate accreditation for satellite offices would not be necessary 

if accredited entities oversight system is robust and adequately 

reviewed by NOP.

Juan Guzman Q2- Accredited offices should be required to meet a timeline of how 

long it would take to certify or validate a certification, this means that 

if the do not meet the timeline, the could lose their status.

Judy Baldwin Q2. what determines where the satellite offices are placed? If they 

hinder the process, why use them?

Alvaro Martinez Q1: Maintain the CBs database to issue the Federated Certificates. 

Take into consideration if the Certificates will be only issued if the 

product arrives into the US or should be used for each transaction of 

organic NOP certified product. For complete traceability it should be 

for each transaction.

Alexis Randolph Q2 - Satellite offices that do not make any certification decisions 

should not need accreditation. I would define the satellite office 

based on steps of certification and responsibility from sales to cert 

decision and what activities are under the control of central office 

versus satellite office from a quality management stand point.

James Cook the clear procedures for accreditation must be outline and ample 

time to comment on.

Stephen Walker Q1 - concern about inconsistency between expiration dates and 

fluidity of annual certification process.

Annie Berical 2. What problem is separately accrediting satellite offices meant to 

address if they are already visited by accreditors?

Andy Hupp 2-Satellite offices should be subject to the same oversight as main 

offices. If that requires additional audit time, then the time should be 

taken. If policies and procedures differ substantially from the main 

office, an additional annual report may be appropriate. Separate 

accreditation may have the unintended side effect of different 

compliance issues being dealt with for separate offices of the same 

certifier.

Kyla Smith 1: additional training would likely be needed as ACAs have distinct 

and different ways we approach issue certificates to operations with 

additional locations under one legal entity and likely different ways 

we are using the taxonomy.

Rudy Amador 3. Agree that it would be good to include minimum requirements and 

annual training for inspectors.
Sandia Martin Q2: I don't think satellite offices should be run by non-government 

companies and then certified by the government. They should be 

RUN by the government and gov employees. This would hopefully 

create consistency throughout the country.

Mark Kastel The NOP is breaking with decades of precedent in bypassing the 

NOSB in creating rulemaking and industry-why dialogue on important 

issues.

Yutaka Yokote #2 The satellite office might have different sight from main office. It 

need to have easy general rule for that.

JAIME GARCIA cant hear any more

Ashley Buhler 2: Satellite office may only have 1 person in each satellite office 

throughout a large state that make some certification decisions, but 

not all of them so they may not be able to meet all accreditation 

requirements, but certification costs would be too high if all people 

who make certification decisions and inspect had to work out of a 

home office.

Chairperson Q3 and Q4

Angela Echols Q3 - PCQI 3rd Party Trained

Heather Ganske Q3 Completion of the IOIA training course.

Kimberly Bousquet 3 -- third party training certification similar to Produce Safety Rule, or 

other FSMA training requirements

Allison Burke Generating a standardized system of training and knowledge base 

would only strengthen Organic Program.

JAIME GARCIA Q3. PCQI trained as well as FSVP trained if inspecting abroad

LUIS LOPEZ 3 IOIA training and shadow inspections with a mentor

Sam Welsch 4. More specificity is required for improving consistency on how 

many members must be inspected. The specificity should be sound 

and sensible.

Kate Mendenhall Q3: At a minimum IOIA accreditation. There should also be some 

sort of proven academic or practical background/experience 

requirement for each scope. For organic inspectors to be qualified 

to inspect high-risk operations, they should have some level of 

advanced qualifications in that subject/production area.

Beth Rota Q4 - Observation of a grower group's internal control system site 

visit/control visit to at least one grower group member

Sarah Reed 3. Should require 10-16 hours of continuing education every 2 years, 

CCOF requires 16.

Chelsey Lenczyk Q3 - Inspectors should be familiar with organic seed availability and 

varietal equivalency

Cynthia Morphet 3 - Should establish an approved training program with minimum 

requirements. ( Need to address qualifications for inspecting 

growers, processors, distributors, and warehouses.
Gwendolyn Wyard Third-party training by a trainer that is ISO accredited and approved if 

not accredited by USDA.

Jerry Combs Q3 Before training requirements are made the NOP should eliminate 

the clause that allows certifying bodies to make it up as they go. Set it 

up like SQF Code.

Beth Unger 3 - need to include continuing education requirement

Cydnee Pletcher Q3- Standardize a system of training for inspectors

Johanna Mirenda Q4 - is group certification only limited to crop products or will 

livestock producer groups be eligible?

Sam Welsch 4. It should be clear that GG certification is only for crop production. 

It is not applicable to livestock certification.

Yutaka Yokote #3 At least the inspectors had better have PCQI, HACCP, some 3rd 

Pary Audit Cer. training.

Juan Guzman Q3 - A proper Certification Program should be developed. Organic 

Inspectors should be required to be certified. This Certification 

Program should also be evaluated and updated on a consistent basis, 

to keep up with new regulations, pesticides, etc.

Cali Alexander Bachelors degree in science or math,..... expanded schools for 

certification

Marty Mesh Q3 test

Kyla Smith 4: define which scopes are eligible - are livestock operations (e.g. 

poultry) eligible? there have been mixed responses on this topic over 

the years

Alvaro Martinez Q2: More than satellite offices being accredited independently, it 

should be better to implement other forms of improve the evaluation 

of the CB.

Alesia Bock Q3 - standardized third party testing for consistency

Beth Rota Q4 - guidance for determining what percentage of sub-units to 

inspect (specific risk criteria to assess and appropriate percentages 

depending on the overall risk).

Kate Mendenhall Q4: Perhaps Certifiers must be accredited to certify Grower Groups, 

which would require a more focused look at the regulations around 

Grower Group certification. It is important to find a way to continue 

this option for very small farmers around the world.

Neil Millman Q4 Scientific lab testing of soil or crop samples of each member.

Andy Hupp 3 - See ACA best practices on inspector qualifications. NOP assistance 

in providing training content could go a long way toward raising the 

bar and encouraging consistency.

Jerry Combs Q4 Set it up like Group GAP audits
Kelly Monaghan Q3 - As a bseline - IOIA basic training for areas which are being 

inspected (crops, livestock or processing) and then advanced training 

for more complex operations. I agree with Kate Mendenhall's 

comments on this - IOIA accreditation would be the ideal

Sarah Reed 3. Field evaluation based on risk level tiers (based on number of 

inspections) have been successful. All inspectors no less than every 

three years.

Kimberly Bousquet 3 -- required certification with a mandatory test, test repeated every 

2 or so years

Synthia Morales Q4 1. MInimum information about minimum traces allowed in 

restricted substances 2. Handlers certification scope

veronica reyes Where can I get the training for organic inspector?

Mark Kastel Unlike past rulemaking the NOSB did not just gather feedback it was 

charged by the NOP to create tangible rule recommendations. That is 

being bypassed now.

Richard Mathews Q1 Has been an issue since 2002. NOP should implement the federal 

certificate regardless of push back by certifiers. The Federal 

Certificate program needs to address the issue of certificates being 

fraudulently used to represent nonorganic livestock and products as 

organic. this is a current problem.

Nicole Dehne Q3 Organic Inspectors should have a B.A./B.S degree in agriculture, 

environmental science, food technology, food science or related field 

or equivalent work experience. Minimum 5 years of related field or 

equivalent work experience. They should have a strong background in 

the production area that they inspect. For example, an inspector that 

inspects vegetable operations should have a minimum of 2 years 

working on a vegetable operation.

Lori Kenyon Q3. IOIA full week course per scope inspecting, mentorship program, 

& continued training recommend required # of hours

Rudy Amador 4. The key aspect for grower groups is the control system of 

members. Rule should establish requirements for this control system.

Sam Welsch 3. The early guidance from the NOP was that inspectors should have 

at least two of experince, education, or training.

Alexis Russell Q3 : All inspectors should be required to know both the livestock and 

crop standards to an equal degree. We have a mixed system that 

skews largely to the livestock side and it's hard to find inspectors who 

is comfortable with livestock operations

Mary Hand I am only able to chat here,with presenter, not in the participant 

feedback section
Gwendolyn Wyard A key here is to place more emphasis on the qualifications of the 

trainer. Accreditation, consistency.

Erin Heitkamp 3- Inspectors should be required to pass/perform well on a test of 

what are considered to be best inspection and certification practices. 

Inspectors should be required to pass the current test on a period 

basis like a board exam i.e. every three to five years.

megan fierst Q3- USDA should define requirments and training for inspectors with 

a certification program. USDA should take a look at how FDA 

initiated FSMA QI training.

Kyla Smith 3: lots of resources already out there: ACA best practices, IOIA 

contract

Chris Grigsby Q3 - use ACA Best Practices recommendation for inspector 

qualifications. Presented last year.

Sarah Reed 3. MInimum qualifications can create challenges for multi-scope 

inspections. COuld result in dairies having 2 inspectors, for example.

Judy Baldwin Q3 Minimum qualifications should be soil and crop knowledge, basic 

agronomy knowledge, knowledge of organic rules and regulations. 

formalized consistent training across the board for all inspectors.

Arturo Gonzalez 4 very important to follow up on new growers added to those groups, 

sometimes it is not clear when new member are added.

meredith smith Q3 - Min 3 years experience in the industry or related industry to 

what they are auditing. (Have had auditors who knew very little 

about my industry and that lends to confusion of acceptable practices 

for that commodity, etc. Dont' send someone with only farm 

experience to audit a manufacturing facility and vice versa)

Sam Welsch 3. It is difficult to establish a minimum in one of those areas when an 

inspector may be very strong in the other two.

Synthia Morales Q5 1. Minimum sample allowed for new farmers to be inspected

Michael Roberson Q3: In addition to minimum qualifications to enter the field organic 

inspection, I support formal training and education to help make the 

organic inspection process as robust as possible. Similar to the Safe 

Quality Food (SQF) standard under the Global Food Safety Initiative 

(GFSI), USDA should consider specific industry focus areas for the 

minimum qualifications. Examples might include on the farm 

practices for fruits and vegetables; on the farm practices for animal 

herds; and various food processing industries such as dairy 

processing; meat processing; and other food types. USDA should 

consider ISO Audit Guide 65 as they develop the standard as a 

minimum quality standard for auditing.
Annie Berical 3: Inspector training program should be completed. That program 

may be administered by IOIA or an accredited certifying agency. A 

minimum requirement should also be a 4 year degree, simple 

because inspectors need to have acceptable writing and reading 

comprehension skills in order to be effective inspectors. Further 

background in ag or processing industry would also be desirable.

Cali Alexander Q4- Social justice, fair practices

Alvaro Martinez Q4: include risk assessment evaluations guidance for 

auditors/Certifiers

Jim Sattelberg 4 Grower groups can get too large to manage. Growers should be 

certified separately.

Mike Chansilp 3 - standardized training and testing to avoid inconsistent evaluations 

during onsite audits

Lianne Nunes 3 - Minimum qualifications should be a 3rd party training as well as 

detailed training by the CB employing said inspector. Inspector 

should also have background knowledge of scope that they are 

inspecting in addition to training (i.e. education and/or job 

experience in respective scope).

Cullen Carns-Hilliker 3. IOIA training; Knowledge of farming/processing; Knowledge of the 

NOS Standards; Auditing training and/or experience; Residue testing 

training; Personable and non-judgmental.

Danny Hernandez Q3 - certifying body should have an detailed checklist for inspectors 

to follow and provide training for inspecting. Also, having an 

educational background in biological/chemical sciences to aid in 

answering questions.

Beth Rota Q3 - Inspector training from the NOP would be helpful

Melissa Elkins Q3 - we are a OG certified retailer and every year our business ends 

up having to train a new inspector on how retail establishments do 

recordkeeping while simultaneously participating in our audit. It 

takes a lot of our businesses time to do this and then we have to wait 

for months and months before we get any feedback on the audit, 

which complicates recordkeeping as we have to haul boxes of 

invoices in and out of storage. It would be helpful to have dedicated 

inspectors for each sector so we don't have to retrain them on our 

dime every year.

Allison Burke 3, Ability to reference NOP guidelines, understand and convey 

information to others.

Kimberly Bousquet 4 -- limits on the size or number of participants in grower groups

Sarah Reed 4. NOP should be ready to apply grower groups in US if allowed in 

other places. Many grower groups are not in fact a single legal entity.
Sam Welsch 3. Most important would be the development of a standard training 

curriculum that must be used by any ACA or other organization 

provding training.

Nicole Dehne Q3 We currently require IOIA training within the first year of hiring an 

inspector and 12 annual hours of professional development there 

after.

James Cook If not IOIA training then must establsih a specific training program 

and make availabel online and in class.

Erin Heitkamp 3- Inspectors should be required to serve in an internship/residency 

with oversight by an experience inspector for say three years prior to 

being allowed to practice independently.

Tina Sohal 3 - the requirements should be consistent for everyone. A good 

understanding of the organic program and how it will apply to 

different operations.

Mary Hand Q3 Agree that inspectors should have proven experience in areas 

they audit

Alexis Randolph Q3 please see our comments to the NOSB. QAI can also provide NOP 

with our specific criteria for on-boarding inspectors.

Dimitris Sotiropoulos 3 scope related academic background - 1 year minimum field

working experience before working as an inspector - inspector 

training (NOP - ISO 19011/17065) - observation audits with senior 

inspectors - witnessed by senior inspector

Allison Burke 4 - Inspect grower groups annually

Stephen Walker Q4 - Regarding vertically integrated livestock production in the US... 

Even assuming all sites are inspected, it's a challenge to know how 

best to identify who is certified (company, site managers) when 

issuing certificates. Certificates need to be adequately transparent. 

Dovetails with NOP 2603 and 4009.

Michael Menes Q3 - organic inspectors should understand the impact of organic 

inputs in growing practices. understand the potential for fraud in 

fertilizers when growing organically. this is sometimes understated 

but furthermore there is no accepted method to detect or test for 

fraud in organic fertility.

Lianne Nunes 3 - Continued training: monitored by CB employing inspector through 

shadowing at least once a year as well as a yearly calibration for all 

employees.

Cullen Carns-Hilliker 3. Field training with experienced inspector - 3-5 inspections; 

Monitoring of initial inspection reports.

Brennen Herbruck 3 - Standardized. Have formal training and a minimum experience 

requirement in the field they are inspecting.
Lori Kenyon Q4: inspection requirements based on size of group. Inspection 

volume increases as size increases.

Beth Unger 3 require a minimum amount of shadow inspections with an 

experienced inspector

Aubrey Lopatin Q3: FSMA and PCQI training, specific training in the type of 

organization (producer/handler/etc) that s/he is inspecting

Juan Guzman Q4. Its is important that Grower Groups are properly identified based 

on their needs among state lines. There are different practices and 

needs based on the growing region for example for citrus growers in 

Florida than the ones in California.

Richard Mathews Q3 inspectors need to be trained in the field for which they will be 

performing inspections. they need to be tested. they need to attend 

the NOP certified training.

Alexis Russell Q4 : How large does a system have to be to be considered a "grower 

group"? Should there be different requirements for domestic vs 

international groups?

Sarah Reed 4. Specific hard thresholds for sample audit failure, if you only inspect 

20%, what is the threshold for failure?

Jessica Walden Q3: IOIA training, ACA Best practices, ongoing individual certifier 

trainings, qualifications and effectiveness of trainers

Tina Sohal 4- the growers should be audited regularly - atleast annually

Mark Kastel These are important and complex questions on an issue vital to the 

future value of the organic seal. The dialogue is being highlycontrolled by USDA bureaucrats. If you sincerely wanted substantive 

input from the public why couldn?t you brief us on the scope of the 

questions in advance. Now we are all just shooting from the hip.

Yutaka Yokote #4 Much more often inspection.

Sam Welsch 4. It should be clear that any member of a GG with more than $5000 

in annual sales must be inspected annually.

Kate Mendenhall Q3: I do think this needs to expand BEYOND just the inspectors. File 

reviewers in the office should also have some sort of 

training/expertice requirements. File reviewers must have an 

educational or experiencial background in the scope they are 

reviewing.

Alyssa Mack We can't access the chat/participant feedback-Q&A. Any thoughts?

Stacy Swartwood There is a blue chat icon in the lower left corner of your screen.

Elizabeth Tigan Q3: Inspectors need to have experience in the scope, education in 

the field is not necessary. Ability to convey ideas is sufficient. A test 

for all would be valuable. A requirement got mandatory training is 

not necessary.

Kate Mendenhall Q3. File review staff should also be required to be 

accredited/complete consistent training/curriculum.
James Cook Q4. - Risk assessment to determine if increase inspection will be 

needed.

mike crotser Q4 - Animal welfare evaluation, body conditioning score, 

understanding of rations, pasture quality management, pasture 

evaluation - quality vs. quantity

Chairperson Q5 and Q6 

Jessica Walden Q4: more clarification on how to determine percentage of growers to 

inspect and transition procedures (eg, adding new growers)

Cynthia Morphet 5 - Should not be any exclusions other than retailers and 

transporters. Everyone else should be required to be certified. 

Exclusions leave vulnerability to fraud and compromise traceability.

Sam Welsch 5. I agree that all types of handlers should be certified, except for 

transportation.

Judy Baldwin Q5 There should be NO excluded operations.

SOPHIE MONTEIRO Q5 Brokers and Distributors should be certified

Nicole Dehne Q5 Any operation that takes ownership of an organic product should 

be required to be certified.

Rebeca Rabago Q3: Wearehouses

Kimberly Bousquet 1 -- importers esp b/c of fumigation of organic foods at ports of entry

Erin Heitkamp 5- Any and all handlers taking possession and/or brokering certified 

organic products should be required to be certified.

Beth Unger 6 transportation from one certified entity to another certified entity 

such as milk transport or animal transport to slaughter

Chris Grigsby Q5 - excluded operations that should be required to be certified: 

brokers, distributors, handlers. Agree that retail and restaurants 

remain exempt.

Alesia Bock Q5 - brokers and warehouses should be required to be certified

Brittny Bauer we agree any operation that takes ownership of an organic product 

should be required to be certified.

Kate Mendenhall Q5. All types of handlers should be certified, with exception of 

domestic transportation.

Chris Fanta Q5: All operations should be certified with the exception of 

transportation.

Neil Millman Q5: Looking at this incorrectly. Require organic certificate number of 

producer/ gr/ processor on the package to simplify traceability.

Sam Welsch 5. It is already required for any trans-loading site to be certified, but 

there is still many uncertified traders using uncertified facilities to 

load grain.

Jerry Combs Q5 all should be certified including restaurants and retailers

Erin Heitkamp 6- No
Megan Megan Q5 - support that all brokers and distributors should be certified

Genevieve Albers Q5: the excluded operations should be allowed to continue with an 

affidavit and/or declaration as long as the material is not handled or 

in permeable packaging

James Cook Wild caught seafood products should still be excluded but 

aquacultural seafood should be included

Kimberly Bousquet 5 --importers esp b/c of fumigation at the ports (misidentified as resp 

to question 1 earlier)

Nicole Dehne Operations that just transport product should not be required to be 

certified.

Cali Alexander Q5 Brokers and distributors shoudl be certified; whatever entitiy 

owns title to the product, better traceability

Chris Grigsby Q6 - retailers and restaurants remain exempt.

SOPHIE MONTEIRO Q6 Grocers should still remain excluded.

Jackie DeMinter Q:5 Brokers and wholesalers; to close the gap in the supply chain

Sarah Reed 5. Importers should be required to be certified as the number of risks 

are higher, even higher than domestic brokers. Overall brokers, 

traders, distributors, and wholesalers increase risk to supply chain 

transparency and should likely be required to be certified.

Lianne Nunes 5 - ALL operations excluding retail establishments and transporters 

should be certified.

Alexis Russell Q5: If a handler has a physical location and holds any inventory they 

should be required to be certified since they should follow the same 

pest management/separation between organic/non-organic 

standards

Beth Unger 5 any unpackaged product including brokers and handlers should 

require certification

Elise George Q6: transporters and retail food establishments should remain 

excluded.

Synthia Morales Q5 brokers and distributors must be certified because there is many 

operators demand and its necessary to review this part of operations

Melissa Elkins Q5 - any supplier that stores both organic and conventional produce 

(or other unpackaged products) should be required to have OG 

certification.

Mike Dill Q5- All operations that physically handle (store, pack, process, label, 

etc.) organic products that are not enclosed in a sealed package 

should be certified.

Allison Burke 5 - support proposal, brokers, importers, traders, distributors be 

certified - no to restaurants and grocery stores
megan fierst Q5- Brokers and distributors should NOT be excluded due to 

potential gaps of traceability.

Mike Chansilp 5 - Warehouses/Distribution Centers that handle only 

sealed/packaged finished goods should be exempt from certification

Emily Brown Rosen 5- agree All operations should be certified except retail and transport, 

this is long overdue. This will require more definition of what is 

considered excluded transport.

Aubrey Lopatin Q5: Brokers, distributors and warehouses should NOT be excluded to 

more easily maintain a chain of custody

Alesia Bock Q6 - only small growers, transporters, and retailers should be 

excluded

Michelle O'Brien 5 brokers, distributors and warehouses should be be required to be 

certified. 

Jessie Jessie Q5/Q6: There are a number of organizations that do not take 

ownership, or handle organic products, but do provide a service in 

enabling the marketing of organic products, including bulk 

commodities, and ingredients. As an organization who enables 

buyers and sellers to connect directly and do business via an on-line 

platform, Mercaris helps to increase transparency in the sector. 

However, our on-line platform is not currently certified under the 

USDA NOP. We think there are both upsides and downsides to 

requiring all operations in the supply chain to be certified. More 

certifications will lead to more knowledgeable people within the 

supply chain but will also create barriers to entry within the space. 

We think it is important to work with uncertified organizations across 

the supply chain to understand their particular role and what impact 

they play on the supply chain. If the NOSB decides to require 

certification?it is crucial to have input from currently uncertified 

organizations to craft regulations that allow to continued growth in 

the organic markets. Last but not least, certification should precisely 

identify risks for compliance, and specific certification tailored to ecommerce platforms should be crafted to address the risks identified. 

That is, we would expect USDA certifications for brokers to be 

different than that of certified handlers, and, certification for on-line 

platforms to vary from that of traditional brokers.
Annie Berical 5. Agree that all handlers excluding those mentioned need to be 

certified. Uncertified brokers, in particular, cause a lot of traceability 

problems and chain-of-custody breaks. Storage entities who are 

uncertified are a point where contamination via pest 

control/fumigation may easily occur without the knowledge of the 

owner of the certified organic product.

Andy Hupp 4 - Certification should be required for all brokers and distributors 

that market, sell, and trade organic products.

Tina Sohal 5 Warehouses and importers.

Rudy Amador 5. Agree that all key supply chain operators should have a "chain of 

custody" type organic certification to improve traceability. Key 

operators would include the importer and the wholesaler/distributor. 

Companies of same group/management that undertake several 

functions in the supply chain should not be required to have multiple 

handling certifications.

Jim Sattelberg Anyone handling or taking ownership of products should be certified

Danny Hernandez Q5 - Since brokers and distributors store organic products, they 

should NOT be excluded. The only groups who should be excluded 

are the end users such as retailers.

Mary Hand Q5 While I certainly understand and agree with requiring 

certification, documentation throughout the supply chain can be 

extremely difficult to secure. Am excited to see coordination with 

CBP on enforcement.

Nicole Dehne Q5 Retailers and Restaurants should remain exempt.

Elizabeth Tigan Q5: Brokers and Distributors should be certified. Anyone who takes

responsibility or possession of a product should be certified.

Marty Dagoberto Q5: Restaurants which make claims of "organic" should be certified, 

as they are directly benefiting from the organic market demand.

Jessica Walden Q5: please see QAI comments to this question in the survey.

Juan Guzman Q5 - Brokers and Selling Organizations SHOULD be required. The 

Industry is already requiring suppliers to be certified. This would just 

mean that you are catching up with Industry standards

Andy Hupp 5 - Certification should be required for all brokers and distributors 

that market, sell, and trade organic products.
Michael Roberson Q6: Relative to grocery retailers, the Food Marketing Institute (FMI) 

has previously worked with the USDA to develop guidance for 

grocery retailers to operate, relative to the USDA National Organic 

Plan. Over the last decade, this standard has been widely adopted by 

the multitude of retail grocers across the nation. Based on the 

industry standards that have been set forth by the Food Marketing 

Institute, vetted by the USDA, and implemented throughout the retail 

grocery industry and company-owned warehouses, I support retail 

grocers and company-owned warehouse to remain excluded in the 

USDA organic regulations. 

Gwendolyn Wyard Q5 - Definitions will be extremely important, specifically to define the 

various players in the supply chain (transporter vs. transportation, 

etc.) We agree that transporters and retailers may be excluded, but 

clear guidance on the activities that require certification will be 

imperative.

Lori Kenyon Q5: Brokers and distributors should be certified organic.

Cynthia Morphet 5 - Operations that are excluded (such as transporters) should still be 

required to sign an affidavit that they will comply with

commingling/handling requirements to maintain organic integrity 

and traceability

Alesia Bock Q6 - restaurants should remain exempt

Sam Welsch 5. If retailers continue to be excluded, there should be more 

enforcement by NOP, including on-site inspections, to assure that 

they are only selling organic products as organic.

yasmin cedamanos Q5 all operations should be certified to have control of traceability, 

only transportation should be excluded

Aubrey Lopatin Q6: transport should be excluded

Beth Rota Q6 - Retail establishments

Jerry Combs Q6 Exclusions don't really matter as CBs are allow to make you show 

certs on exclusions.

Sarah Reed 6. Restaurants and retailers should remain excluded as the 

marketplace may not be ready. However CCOF successfully certifies 

restaurants and retailers and there is value in certification; increased 

integrity and oversight of organic claims and labels.

Annette Semper Q5 support traders, brokers to be certified

Cali Alexander Q6 Small farm operations,small grower groups....

Kimberly Bousquet 5. all entities that touch organic produce/commodities should have 

some level of certification. Maybe a lower standard for transporters, 

etc..., but they still must have a basic understanding of how the 

organic products they are transporting, etc... must be maintained.
jake lewin Q6, mainly only for trucking for very limited defiintion of true 

brokering. not taking of title/ownership etc.

Alesia Bock Q5 - chain of custody from brokers/suppliers to handlers would be 

helpful

James Cook very small operators must not be excluded to assure integrity of 

program.

Andy Hupp 5 - Certification should be required for operations that mix livestock 

minerals intended for use in organic livestock production.

Dimitris Sotiropoulos 5 Brokers/Distributors should be certified in order not to create 

certification "gaps" in the supply chain (room for fraud) and because 

by being certified they will also take more responsibility about their 

procurers/transactions (they will be more engaged in the Organic 

control system)

rebecca willows 5 Traders, Exporters, Importers, Brokers, large Retailers with off-site 

Distribution Centers who handle produce should be certified

Mike Dill Q5- Retailers that have their own distribution centers need to be held 

to the same rules as other distributors. Just because they are a 

"Retailer" should not exclude them from certification. A distribution 

center is a distribution regardless of whether it is owned/operated by 

a retailer or a private company.

JAIME GARCIA Q5. All facilities where the organic items are loaded/unloaded should 

be regulated and validated, but not facilities that are only related in 

an administrative way and has no direct handle with the product.

Deborah Deborah Q6 - no need to change exclusions. Organic processor should be 

responsible for their supply chain and therefore substantiation of 

sourcing from warehouses, handlers, holding facilities, etc. This 

would be a unwise use of limited resources.

George Kalogridis 5 Every entity in the chain of custody must be certified, otherwise 

there is uncertainty.

Alexis Russell Q5: Livestock transporters should absolutely be certified, there are 

humane standards that need to be upheld for livestock during 

transportation so having a certified transportation company would 

assure that livestock are being treated up to the standards without 

having to train every new transporter you work with

Melissa Elkins 5 - Retailers that sell organic produce that want to label it as such 

should also be required to have certification, unless they are under a 

certain size (farmer's markets, small single proprietor retailers, etc. 

exempt). This should be a requirement for all national retailers at the 

very least.
Marty Dagoberto Q5: Brokers/distributors should be certified, as this is an obvious 

point for fraud

jake lewin Q5. Importers woudl be very helpful to the marketplace, and anyone 

mid-supply chain that takes ownership.

Sam Welsch 6. Any excluded operations that request certification should be 

expected to be certified to the same regulations as those that are 

required to be certified.

Synthia Morales Q6 transportation must remain being excluded

Kyla Smith 5: Yes, agree with Gwendolyn (OTA). definitely need definitions for 

certain types of operations - broker, importer, distributor, etc

meredith smith Full disclosure: I am an excluded operator (distributer) #5) I believe 

that excluded warehouses should have better oversight. Currently an 

affadavit is used, but either strengthen the affadavit or make some 

type of very easy audit that shows that these warehouses follow 

basic procedures (in order to prevent fraud and commingling with 

conventional products.) I believe that traders/distributers should 

remain excluded.

Annie Berical 6. Continuing to exclude packaged ready to eat foods, even when 

they use the term "organic" on the packaging is very confusing to 

consumers. This exclusion should remain in place, but should perhaps 

be amended to indicate that "organic" cannot be used on packaged 

ready to eat product.

Kimberly Bousquet 5. with most organic fraud being related to imports, that supports 

certification of the entire supply chain

Beth Rota Q5 - brokers, handlers of bulk products, exporters

Yutaka Yokote #5 The foods scientifically cannot be segregated or detected products 

from normal products. Due to no evidence. #6 No

Arturo Gonzalez Q5- imported product should required warehouse where product is 

received should be certified because they do handle the product, not 

the importer nor broker unless they do handle it themselves.

Kris Stewart Q6 should not include temp holding facilities-buying station, truckers,

Stephen Walker Q6 - restaurants. Some retail exemptions make sense, but we need to 

know scope of exclusion within the retail setting.

Tina Sohal 5- agree with definitions.

Deborah Deborah q6 - leave those existing in place

Drew Afton Q5 Warehouse pesticides can cause detectable contamination by 

pesticides not approved for use in organics.

Richard Siegel When will you have question on increasing reporting on INTEGRITY 

database?
Mike Dill Q5- brokers, traders, marketers, private-label "owners" should be 

certified so that their purchases, handling practices and sales are 

audited.

yasmin cedamanos q1 limitations for foreign operators, speed to update certificates 

during year

Sam Welsch 6. The NOP should immediately implement a robust traceability 

auditing system that can trace products from source to final package.

Gwendolyn Wyard Strongly agree that everyone in the supply chain should be certified. 

Consider a registration process for retailers and transporters that are 

handling organic products, if excluded. Increased oversight of 

excluded operations is greatly needed.

Melissa Elkins 5 - agree with those that commented about livestock transporters 

being certified, although livestock rules aren't even close to being 

stringent enough.

Sandia Martin Q 5 & 6: How about if you create a secondary type of certification. In 

the marijuana realm, you can get a license to be a grower OR a 

processor/handler. Could you do a secondary certification for 

transporters/handlers/importers, etc. ? Their certification and 

training would be much different than one for a grower.

Elise George Q6: I agree with Sam re: NOP review of retail food establishments 

records.

Feliciana Puig 5- brokers and wholesalers should be certified to close the gap in the 

supply chain

meredith smith Q6 - full disclosure, I am an excluded operator. I believe that traders 

should remain excluded as I do not believe that fraud will be 

prevented by having traders certified - especially traders that do not 

take physical possession of product.

hande kemerli Q5 trader , broker should be.

Dimitris Sotiropoulos Generally speaking, exclusions undermine the integrity of the control 

system and negatively challenge consumer confidence

Lianne Nunes 6 - Restaurants should remain excluded. Handlers that mix livestock 

minerals should be certified.

Richard Mathews Q5 Anyone who purchases an organic product for sale to someone 

else (excluding a consumer should be certified. For an example a hay 

broker who purchases hay from a hay producer for resale to an 

organic dairy, should be certified as a handler.

Deborah Deborah Definitions: definitions should be consistent with NOP and FSMA.

Sam Welsch 6. The NOP traceablity audit would help detect much of the 

fraudulent trading that is currently occuring.

Andy Hupp 6 - If exclusions are to remain in place, clarification is needed on what 

"packaged or otherwise enclosed in a container" means
Neil Millman Q? I didn't see a question # on input to the organic integrity database 

input. again, look at it differently. change the input process to ensure 

accurate info. check (click) boxes and dropdowns are the best way to 

assure consistent input integrity

Kimberly Bousquet 6. agree restaurants should still be excluded

Mary Hand Q5 Clarity on private branded industry handling would be greatly 

appreciated - for example, trader using a separate manufacturer for 

private label item

Juan Guzman Q6. The scope of the exclusions is to broad. There should be a 

minimum requirement for organic handlers to have some sort of 

certification. If a shipper, restaurant, retailer etc. are claiming a 

organic expertise, product etc, we need to make sure that they have 

a minimum training or knowledge.

jake lewin Missed Q#, increased frequencny, quality and completeness of data 

from certifiers should be a part of integrity. including not solely 

certified entity information. Reporting on who recieved 

samples/Unannounced isnpections and inspectors etc.could facilitate 

oversight. As a general rule certifier reporting is a neglible actual cost.

Sam Welsch 5. Integrity database must be updated immediately when an 

operation is suspended or surrenders certification. Regulations 

already require certifiers to immediately notify NOP when sending a 

Notice of Suspension.

Tina Sohal agree with Juan..a minimum or knowledge is required for who are 

handling organic products

Chairperson Q7, Q8, Q9 

Jerry Combs Q-7 Utilize Block Chain Technology

Kimberly Bousquet 7 -- require use of blockchain technology

Rudy Amador 8. Use of import certificates is a good idea to help avoid fraud. Key is 

a system that does not create unnecessary burden to trade 

participates. Consider using same electronic system (Traces) 

implemented by EU last year.
Andy Hupp 7 - The NOP should use high risk protocols and cross checking 

between accredited certifiers as part of the audit process. This is a 

current gap that could be exploited by unscrupulous entities. For 

instance, NOP could choose several large shipments of imported 

and/or high-risk products and, working with multiple certifiers, 

attempt to trace them through the supply chain. Such audit activities 

could be initiated through accreditation audits with follow-through 

by NOP staff from Washington. If discrepancies are uncovered, such 

activities may result in compliance and enforcement actions with the 

certifiers and/or operations involved in these transactions. This 

would undoubtedly be instructive and could be translated into 

further instruction, guidance, and training in the future.

Beth Rota Q7 - requiring organic certification for all handlers, brokers, importers 

and exporters

JAIME GARCIA 7. Import Certificates should come in with each inbound of produce, 

as well as validated by SAGARPA (in Mexico). This way 2 entities will 

validate the certificate and eliminate the produce that is not organic.

Sam Welsch 7. NOP should have dedicated staff who can audit the entire supply 

chain. It is not possible for ACA to investigate more than a small 

segment of the supply chain.

Deborah Deborah Q7 Organic processor should have a "supply chain/traceability" prerequisite program as part of their OSP.

Patty Lovera 8 - implement all of the Inspector General audit recommendations.

Sarah Reed 8. Require import certificates for all imports to US. This could be very 

challenging for over-land shipments from Mexico and Canada.

yasmin cedamanos q7: import certificates should be a requirement for imported 

products from any origin

rebecca willows 5 I agree with Sam NOP OID should be updated immediately 

Otherwise it is basically useless for the fast paced fresh produce 

business.

Michelle O'Brien 9 NOP should make sure that their organic practices are equal or 

above what US requires and should ensure that anytime they make a 

change to their policy's we are aware of the change to ensure it is still 

up to our standards

Alesia Bock Q7 - block chain technology may be helpful

Jessica Walden Q7: certification of the entire supply chain

Beth Unger 8 agree with import certificates

Sam Welsch 7. This would not require a rule change, just making it a focus.
Arturo Gonzalez Q5 Integrity Data Base is not updated regularly, we need that info as 

accurate as possible to prevent fraud.

Jessica Walden Q8: certification of importers

Synthia Morales Q7 all the supply chain must be certified, Producers, 

Handlers/processors , distributors, Importers in USA, also each one 

must be registered with a specific scope

Andy Hupp 7 - Certify all operations involved in organic commerce

Richard Siegel INTEGRITY DATABASE should include operations that are certified in 

other countries under Recognition Agreements: India, NZ, Israel.

Alexis Russell Q7 It is my understanding that farms across the EU have stricter 

traceability standards than we have in the US, so I wouldn't anticipate 

any issues with an equivalency with the EU system when it comes to 

farm to table audits

Jerry Combs Q-8 We import from other countries and require a NOP Organic Cert 

for the product. Therefore Import Certs are redundant and wasted 

cost.

Lee Frankel Q8. Consider value of FDA Foreign Supplier Verification Program that 

requires importer to show that he has oversight of production 

practices of foreign supplier.

Sam Welsch 8. Import certificates would help from all sources.

Aubrey Lopatin Q7/Q8: import certificates should be required for all imports

Michelle O'Brien 8 I feel that the certificate should accompany each time a product is 

imported to ensure that it infact is certified.

Kimberly Bousquet 7 -- agree that areas of high risk for fraud should be considered, but 

also increased investigation on the supply routes that are used to 

ship fraudulent organic food

mike crotser Q9 - maintain organic trade arrangements with Brittan whether they 

continue with the EU equivilency arrangment or not.

jake lewin Q7) Standardized import documentation would facilitate oversight in 

terms of visibility of trade changes and volumes. Per shipment 

documentation would be helpful and coudl be worked out but overland borders should be considered in any system. Import certificates 

or other visibility, such as trade registration, for all imports would 

greatly improve oversight and enforcement ability.

Beth Rota Q9 - Additional paperwork won't necessarily reduce fraud. A master 

system to look at volume control, similar to Europe's TRACES may be 

helpful.

Brenda Walker Would be great if the national data base of certified suppliers could 

be searched by County.

Sam Welsch 9. More robust oversight of foreign accreditation bodies.

Synthia Morales Certifiers from importers in USA must be registered too
Cali Alexander Q7 Full supply chain traceability should employ the same tech 

systems already in place in many other industries as international 

industries; as an example pharmaceuticals. Blockchain;

JAIME GARCIA 8. Labels on the packages and brands on the boxes should be register 

in a database

Kimberly Bousquet 7 -- each party along the supply chain must be certified organic and 

must certify that they maintained the integrity of the organic food

James Cook database from farm to fork using GSI/UPC/EAN information input at 

each point. Database can be as NOAA is taking on catch information.

Lori Kenyon Q7. Import certificate required on all organic imports.

Chris Grigsby Q7 - Full supply chain audit ability should fall to NOP. Very difficult for 

ACAs to do this on small scale. Difficulty sometimes working with 

other ACAs with investigations. How does ACA hold other ACA 

accountable in making determinations?

Jessie Jessie Q8: Organic tariff codes should be required for all imported 

shipments and failing to use an organic tariff code should negate the 

organic status of an imported product. Avoiding usage of a HTS code 

could contribute to underestimating true import levels and therefore 

supply and demand metrics. With a limited number of organic 

specific import codes; the industry needs the U.S. government to 

make a concerted effort to increase the number of organic specific 

codes. These changes would encourage shippers to accurately label 

shipments?increasing transparency in the import market.

Andy Hupp 8 - Training CBP, APHIS and related authorities on organic 

requirements and set up lines of communication for them to report 

observed issues

Lianne Nunes Integrity Database - More detailed information should be required, 

specifically for livestock/crop producers. Ex: acreage #'s, herd #'s, est. 

production yields.

Kyla Smith 8: certification of the entire supply chain will help

Elise George Q9: NOP should consider streamlining trade arrangements so that 

verifications, documentation, and labeling are more easily 

understood.

Cynthia Morphet 7 - Requiring import certificates would help. While specific 

technologies, like BlockChain would be helpful, it is not feasible to 

require it, particularly with small, foreign suppliers. FSVP will also 

help address full traceability.

Stephen Walker 9- import certificates' logistics are way diffferent for land transport 

(Mexico) than boats.
Alexis Russell Q9 I think the USDA should consider whether it is making it harder for 

domestic farmers to compete on pricing if we are encouraging 

imported organic products

Neil Millman Q7 Import certificates are an administrative time expense and does 

not enhance traceability. We're all spending too much time chasing 

after paper. Most importantly, import B/L's do NOT have any 

accommodation for organic information. So, get the current systems 

for shipping to accomodate organic record needs and requirements. 

It seems each "and" additional requirement only adds to the time 

and expense involved in chasing paperwork. Amend existing systems 

of the logistics companies to accomodate organic -- organic is the 

future and is not going away.

Annie Berical 7/8. The rule needs to get specific about what documents are 

required for imports. Requiring something like a TM-11 from the 

exporting party's cert agency would be helpful so that we have 

verification from that cert agency on the product. Additionally, 

making transaction certificates a more formally regulated document 

would also help. Standardizing TCs and requiring that they contain 

specific information (like certificates) would increase verification that 

a product.

Andy Hupp 9 - multilateral agreements

Patty Lovera 9 - include mechanism to communicate with countries US has 

equivalence agreement with so that NOP knows about enforcement 

action in those countries. These should be included in how NOP 

determines risk

Kris Stewart would like to see more consistency in understanding of the rules 

amoung the auditing companies

jake lewin q9) critical that other governments and accredited systems be able to 

meet the integrity database. NOP should be able to identify the 

number and scale of equivalent operations.

Alesia Bock Q8 - import certificates may help, but please be consistent. It's 

confusing to handlers when NOP requires Import certificates vs. T-C's. 

Equivalency agreements are also confusing as to whether a supplier 

organic certificate compliant to NOP standards is enough, or if a T-C 

or Import certificate is still required above and beyond that. It would 

be great to get a policy manual or guidance document for this to 

educate the industry.

Sam Welsch 8 & 9. Require all operations certified under equivalency 

arrangements to be listed in the Integrity database.
Michael Roberson Q7: USDA NOP should adopt a similar traceability standard to that of 

the US Food and Drug Administration (FDA) which is currently one-up 

and one-down, based on regulated establishment and carrier, 

especially as it relates to imported organic products into the United 

States. The records would need to be maintained in a manner 

consistent with the US FDA?s record keeping provisions with the FDA 

Bioterrorism Act. As the industry improves traceability solutions 

through GS1 US, Blockchain, and other solutions, the regulations 

should still adopt the minimum standard of one-up and one-down.

Q8: I would support USDA considering collaboration with the US 

Customs and Border Patrol (CBP) to have the organic customs 

documents uploaded with import certificates. Recently, this practice 

was adopted by the US Food and Drug Administration (FDA) as it 

relates to the Foreign Supplier Verification Program (FSVP). It may be 

possible for US CBP to update their database and provide codes that 

indicate if an organic certificate is valid, not valid, and/or missing at 

the time of importation.

Jessie Jessie Q7/ Q8/ Q9: Other countries operating under an equivalency 

agreement should be required to maintain the same information as 

US based operations. Additionally, they should be integrated into the 

Organic Integrity Database allowing the supply chain to have a one 

stop shop for information.

Cali Alexander Q8 Equivalancy certificates with other countries shoudl be expedited.

Richard Siegel Q7. We do not know who the operators are under Recognition 

Agreements in India, NZ and Israel, because certifiers in those 

countries do not report about their clients to the INTEGRITY 

Database. Thus there is not full supply chain traceability from farm to 

table.

James Cook Imports continue with USDA CB certiifcation of certification through 

those CBs in equivalent countries.

George Kalogridis 8 In overseas regions where there is very little data on organic farms 

/ acreage / hectares etc .Domestic certifies need to be able to trace 

crops back to the farm to verify the authenticity of the crops being 

offered to US organic companies

Kyla Smith 9: reporting data into OID or a portal of OID?

Jessica Walden Q7: better labeling on all non-retail packaging.

Stephen Walker 9- changes to EU regs

Dimitris Sotiropoulos 9 Trade arrangements should be further supported. Since the organic 

market is still on the rise, more resources are needed to guarantee 

integrity. As long as Countries Worldwide are cooperating, control of 

organic products will be more efficient.
meredith smith Q8,9 - I believe there is confusion on organic equivalency programs 

and what information is required to call products organic in the US 

that are certified in other countries. There is OK information 

available on the web related to US-Canada equivalency programs, but 

there needs to be a CONCISE, easy to understand summary 

somewhere to make it clear to traders and others what is required. 

(Also suggest a list of what must-have items need to be on each 

certificate - goes back to Q1 related to what might be on a Federated 

certficate.)

Allison Burke Agree with Jessie

Sarah Reed 9. Remove requirements for product to be processed/handled in the 

specific country that is part of the equivalency. If certified to NOP, 

considered equivalent even if processed outside US.

Chris Grigsby Q8 - Additional requirements for any ACA certifying products grown 

in other countries, especially where no equivalency arrangement is in 

place.

Mary Hand q7 perhaps a standardized required set of documents that must 

accompany materials throughout the supply chain. suppliers would 

be audited for proof of compliance and users would be required to 

deny receipt of any material without the document set

Sherine Kanagasunderam Import Certificate is a wasted document because, the CB does not 

really check what's being imported. We can trace the products we 

purchase through purchase orders and lot numbers.

JAIME GARCIA 7. Adding to this question... FDA input with FSVP will have a lot of 

support to identify any information required by USDA regarding the 

status of the produce

Erin Heitkamp 7- Requiring federated certificates with QR codes, and acreage data 

submissions by certifiers to the organic integrity database, along with 

the requirement for transaction certificates that would also be 

captured in the Organic Integrity Database would allow for full 

traceability and facilitate mass balance reconciliation on both an 

individual farm and aggregate basis, as long as reciprocal programs 

are also required to report the data, conduct mass balance 

reconciliation, and issue TCs.

jake lewin Q9) require reporting into integrity at least annually or maintaining 

an equivalent system.

Cali Alexander Q9 Expedite them.

Cynthia Morphet 8 - Import certificates and being incorporated into the OID will help.
Deborah Deborah Q9 - Future Trade - equivalency of exporting organic processor should 

be evaluated periodically (every 2 yrs, etc.) and subject to NOP 

oversight. For example, similar to FSVP. FSVP should be addressing 

"organic" processing and compliance within their products for any 

food exported to US anyway. In other words, should be covered 

under FSVP - may not be a need to additionally have NOP 

certification body oversight for these exported products.

Kate Mendenhall Q9: Establish a system for communication with equivalency 

countries/regions so that if a shipment is turned away, it equivocaly is 

turned away anywhere there is equivalency & NOP should be notified 

& vice a versa.

Alexis Russell Q9 When consumers see the organic symbol, are they assuming 

they're getting a more local product compared to conventional? Is 

that something that should be addressed when it comes to 

certification of imported products?

Allison Burke Current and future trade arrangements exhibit increased 

transparency

Kimberly Bousquet 7 -- electronic capture of all transactions involving the organic food

James Cook Equivalency would have to adjust with the adjustmenet of this 

rulemaking.

Cali Alexander FDA foreign verification prgram is full of loopholes.

Juan Guzman Q8. Certificates can subject to falsification. En electronic database 

validation would be the best way to go on imports, if a importer or 

exporter would like to bring the product to the USA, they would need 

to register ahead of time and validate their organic certification via 

this database that can be reviewed confirmed at the point of entry 

into the country. This could be further developed with a Prior 

Notification Program/System that would allow importers to let the 

port of entry know that the product is coming in

Aubrey Lopatin Q9: Equivalency arrangements are very helpful for importing organic 

goods. However, Equivalency arrangements that still require 

additional notation on certs (such as US/CA equivalency) can create 

as much hassle as having no equivalency to begin with

Michelle O'Brien 7 have a standardized way of compiling the information at each stage 

gate and to link them together for an item so that you can follow it 

from start to finish

jake lewin q9) agreements should be based on demonstrated ability and track 

record of implementing an organic system not merely the creation of 

a standard or propping up an accreditor but without enforcement 

history.
mike crotser Q9 - Examine expanding equivlency arrangements with other trade 

partners such as China.

Richard Mathews Integrity Database - Farm name, First and Last names, Anniversary 

Date

Sarah Reed 7. NOP should do risk-based full supply chain audits as NOP is the 

only party with full authority to review a complete supply chain. 

Certifiers can only see one step forward and back so risks may be 

disguised.

Erin Heitkamp 9 - Reciprocal programs should be required to report acreage data to 

the OID, conduct mass balance reconciliations and issue TCs.

Annie Berical 9. One thing I've had trouble with regarding existing trade 

arrangements is getting verification from the certifying agencies of 

these countries. These agencies are not formally accredited by the 

USDA, so we cannot look up certified entities in the integrity DB. 

Often we look at an agencies website or email an agency to get 

confirmation of an entity's certification status, but their agency may 

not have a list of certified operations that is easily searchable or they 

may not respond to emails.

Melissa Elkins 9 - domestic product should always have priority over imported 

products - any trade agreements reached should not allow US 

farmers to lose sales opportunities.

yasmin cedamanos q9: difficulties that cause to some operator not included in the 

equivalence, p.e.us trader not handling, not covered by equivalence 

with eu and no possibilities to certify eu for that categogory.

hande kemerli Q 7 : each party have to certified - electronic ( as Traces ) certificates 

should be used.

Megan Megan Q7: Importers are required under FSVP to maintain records of 

traceability. Would recommend aligning requirements with FDA & 

FSVP Q9: there is an issue currently with TRACES where product that 

is not from the U.S. that is certified organic and equivalent, which is 

exported to the EU, is not allowed under TRACES since it is not 

originating from the U.S. These types of issues should be evaluated to 

align systems with other foreign countries

Sam Welsch 7. Traceability requires much more detailed auditing than typically 

occurs during inspections. This is essential for detecting fraud.

Arturo Gonzalez Q5- it often occurs that imported product is held at customs by USDA 

or FDA and many times offloaded insite, we have not knowledge of 

these facilities been organic handling capable.
jake lewin Q10) Unannounced inspections are great and a clear regulatory 

requirements for at least 5% should be the bare minimum. both for 

sampling and UAI's certifiers should have to report to NOP annually 

on their programs, success rate, and meeting the minimum 

threshold.

Richard Mathews Integrity Database - Farm name, First and Last names, Anniversary 

Date should be required NOT optional.

Melissa Elkins Q9 - require ethical sourcing for imported products

Chairperson Q 10 and Q11

Sam Welsch 10. NOP should cover the cost of unannounced inspections.

jake lewin Q10) very little to consider. these are already done and largely 

integrated into the cost structure.

rebecca willows 7 once again I agree with Sam inspections need to be much more 

rigorous.

Cali Alexander Q10 Cost is the same

Alesia Bock Q10 - NOP should cover the cost of unannounced inspections

Aubrey Lopatin Q10: NOP or the certifier should cover the costs of unannounced 

inspections

Angela Echols Q10 - costs of unannounced inspections may make organic certifiers 

not recertify and new potential organic certifiers no longer consider 

getting certified.

Marcus Caswell Q10- i love the idea of unannounced inspections. think that will go a 

long way to ensuring everyone is doing the right thing.

Cynthia Morphet 10 - Need to consider practicality of unannounced foreign 

inspections.

Andy Hupp 10 - the cost of unannounced inspections is already incorporated into 

certifier fee structures

Richard Siegel Q11. Appeals take too long to be decided - currently around 1 year. 

When appeal is denied, and appellant requests a hearing, this adds 

more years to the final outcome - all this time, the operator is still 

certified.

jake lewin Q11) NOP should allow correction of minor or administrative 

noncompliances during the adverse action process to suffice for 

closing the issue.

Cullen Carns-Hilliker 10. NOP should reimburse certification agencies for unannounced 

inspection costs.

Jerry Combs Q-10 normal costs IF the unannounced audit is allowed to count for 

the regular announced audit.

Sam Welsch 10. even for announced inspections, the competition among certifiers 

to be "low cost" results in superficial inspections and audits.
Sarah Reed 10. Certifiers should have criteria for risk-based unannounced 

inspections as part of the 5%. CCOF covers the cost of unannounced 

inspections unless certified operation was already informed that they 

would pay the cost, e.g. in a settlement agreement.

Judy Baldwin Q10 NOP should be responsible for the costs of unannounced 

inspections, particularly for fraud discovery of innocent parties.

Michael Roberson Q10: I support unannounced inspections, including a 60 to 90 day

window which the organic certification agency might conduct the 

inspection. The agency should consider an economic analysis to 

better understand the economic burden, if any, to the industry.

JAIME GARCIA Q10. Unannounced inspections costs should be covered by NOP

Allison Burke NOP should have a budget to share expense of annual unannounced 

inspection with grower or processor / handler.

Arturo Gonzalez Q10 NOP should cover the cost

Stephen Walker 11 - broken settlement agreements. No further option for mediation 

with certifier.

Nicole Dehne Q10 The costs of unannounced inspections should include the 

inspection costs themselves but also the staff time involved with 

preparing the unannounced inspection, evaluating the inspection 

report, and writing up the certification decision based on the 

unannounced.

James Cook Must establish a time perido to perform the announce audit in to 

reduce cost impact. 60 days is adequate.

hande kemerli Q10 - NOP should cover cost of unnannounced ins.

Kyla Smith 11: can corrections be accepted at the proposed stage? back and 

forth on this over the years

jake lewin Q11) Medition and settlement agreements for non-payment is 

counter productive and drives costs in the system uncessarily.

julio diaz julio diaz:who is qualified to perform an unannounced inspections

Alesia Bock Q10 - if cost of unannounced inspections is an issue, then make the 

inspections based on risks -- similar to how FDA does it -- to mitigate 

limited inspectors - go for higher risk first.

Alexis Russell Q10: Cost of unannounced inspections should not fall on the 

producers if there are no major violations found. Inspectors still need 

to be paid, but costs should be covered by NOP or certifier

Melinda DeNobrega 7-8: Don't believe Import certificates should be required - product 

arrives marked as organic and organic certificates outline specific 

products' equivalency due to an agreement. Supplier and buyer are 

audited as part of their or
Lori Kenyon Q11: Stages and timely of appeal process i.e. hearings. We have a 

producer in appeal now for over a year. Also, clearly define 

responsiblities of certifiers and producers during appeal. i.e 

submittal of apps, inspections,etc.

Alvaro Martinez Q10: Unannounced inspections should be charged because it is part 

of the certificatoin process in case of projects with higher risk. If a 

project has a higher risk and they receive an unannounced 

inspections, the client should pay for it.

Kate Mendenhall Q11. Issueing a non-compliance should somehow transfer to the 

next certifier, and or mark that producer on a high-risk operation 

probationary period that would give the next certifier a headsup that 

closer observation and inspection is necessary.

Cali Alexander Q11 Minor non complainces should allowed to be corrected on site 

and short term correction items.

Devin Dowell (WSDA) Q10 - The issue isn't so much with cost but ensuring that 

unannounced inspections are implemented unilaterally by all 

certifiers so that certifiers who do conduct unannounced inspections-

-and include provisions in their fee structures to cover this cost--are 

not less appealing to certified operations

Jerry Combs Q-11 As long as the NOP has clause for CB's to make it up as they go, 

how can you appeal that?

Alexis Randolph Q10 would like more information about why NOP thinks 5% may not 

be sufficient. We plan for 5% and add on additional based on 

complaint investigations as needed. We currently absorb the cost 

and do not charge operators. May need to change that approach if 

number increases significantly.

Kyla Smith 11: corrections for administrative (nonpayment, submitting annual 

updates) especially bog down the system

Beth Rota Q10 - Unannounced inspections increase the cost of certification to 

every operation because they must be incorporated into certification 

fees.

Neil Millman QQ10 -- compare the costs of unannounced inspections versus the 

information gained from scientific lab testing. yes, there are drift 

issues, however... the best way to know what is in a product is to lab 

test. additional inspections check paperwork, which can be doctored. 

chemicals in soil or product are where the true story lies. lab testing 

is economical, too. general comment -- add someone to the 

committee who is operationally/ efficiency oriented -- there are ways 

to enhance/ increase oversight and lessen costs / time spent. this 

should be a priority.

Cullen Carns-Hilliker 10. Is NOP is considering codifying the current unannounced 

inspection guidance into the NOS?
Synthia Morales Q10 The costs of unnanounced inspections must be covered by NOP 

and operations (50 / 50) in cases of fraud or finding of 

contaminations (sometimes the origin is not responsability of the 

operation)

Richard Siegel Q11. Certifiers who issue notices of suspension or revocation should 

be encouraged to resolve these cases by informal mediation - or 

settlement negotiations.

Annie Berical 11. The proposed suspension/mediation process has become quite 

onerous. We have operations that at this point have incurred 2 or 3 

settlement agreements, the terms of which we try to verify are being 

met each year. Do settlement agreement terms apply indefinitely, or 

should they expire at some point?

Gwendolyn Wyard When will the recording be available?

jake lewin Q11) NOP should further clarify and solidify the role of ACA-led 

informal mediation processes.

Elizabeth Figueredo Q11 Appeals process can take an incredibly long time especially when 

routed to a SOP. Meanwhile, the operation in proposed adverse 

action can still sell product as organic and maintain their certification. 

I understand we have to respect due process, but there should be a 

maximum amount of time established to finalize a decision by the 

Administrator.

Kimberly Bousquet 10 -- if companies know they will face (or have to conduct) a certain 

number of unannounced inspections each year, they can account for 

that in their yearly accounting.

Synthia Morales Q11 all clear of non compliance and appeal processes

Melissa Elkins Q10 - it is hard to have relevant paperwork on the premises when we 

are being inspected for activities that happened in the prior fiscal 

year; it costs us money to have files moved from storage on short 

notice, especially since we have to have ALL of our invoices from the 

previous year delivered to our office, plus on-site storage of said 30+ 

file boxes.

Sarah Reed 11. Define "written request for mediation" more broadly as any 

attempt to respond, e.g. payment of overdue fees or response to 

original issues that led to proposed suspension.
meredith smith Q10 - I think the proposed rule to have 5% of the annual inspections 

be unannounced is OK, but there are some audits (SQF or maybe it's 

BRC, I can't remember) requires that one audit every 3 or 5 years is 

unannounced, which makes sense. It also ensure that someone 

other than just the quality manager understand the requirements 

and makes sure that the processes and procedures are fully 

communicated. The auditor should indicate in what month they plan 

to come just so that vacations, etc, can be scheduled and not waste 

the auditors time if noone knowledgeable is available at the time of 

the audit. So to keep the costs of unannounced audits down, I 

believe a site should know in which year they will receive an 

unannounced audit and have some idea of what quarter or month 

the audit would occur in.

Alexis Randolph Q11 is a very large questions. Could this go to the NOSB for additional 

public comment? For example, settlement agreements (who when 

why).

Dimitris Sotiropoulos 10 the cost of unannounced inspections should be incorporated in 

the annual fees of the CBs, since it forms part of their service towards 

organic operators in general. It could be that operators with "positive 

background - with no non-compliances" may get discounts over the 

years.

Andy Hupp 11 - It is extremely difficult to get a motivated bad actor out of the 

system. Due process is important, but the tools we have as certifiers 

are very, very limited.

Cali Alexander Q10 Simple protocols for unannounced inspections should be 

developed for consistent entry.

Stephen Walker 11- options for removing portions of operation from certification 

voluntarily. For example, because of drift from a neighbor - land is 

out for three years, but that may not require adverse action, and 

subsequent reinstatement process.

Deborah Deborah Q11 Appeals Process - there should be a clear process to get 

questions or descrepancies clarified. Often one certifying agent 

accepts a certificate for a product or acceptance of a product 

(sanitizer or cleaner) in an operation with removal event for example 

and then another certifying agent or when a processor changes 

certification bodies and they don't accept a certificate (product) and 

this is problematic. Maybe suggest setting up an askNOP similar to 

askFSIS where you can get feedback on a question, substance use, 

use, etc. 
Chris Grigsby Q10 - NOP should consider that currently unannounced inspections 

costs are born by the certifier, and any relief or cost sharing would be

helpful. Ultimately it is shifted to the certified operations through 

adjusted fee schedules. Rulemaking should include parameters 

around scope of unannounced mix per year to represent all 

production scopes, not just the easiest to hit 5%.

Elizabeth Tigan Q11: Agree with Jake about the Mediation process for payment and 

paperwork proposed suspensions. Too much time and money ? make 

the process not work the way it should, time and efforts can be 

better spent with real compliance work.

Beth Rota Q11 - the appeal process can be very lengthy. It makes it hard for 

certifiers to evaluate continued compliance while the operation is still 

certified while waiting on an appeal decision

Sam Welsch 11. NOP should conduct its own investigations when receiving 

complaints.

Alesia Bock Q11 - minor non-compliances for voluntary changes made by industry 

for label changes (which are considered "temporary label approvals" 

by FSIS, should not be considered "minor non-compliances" by NOP --

i.e. label runouts where there are minor ingredient line changes that 

do not affect consumer labeling or allergen risks, as long as it meets 

FDA and/or FSIS labeling.

Chris Fanta Q11: Clarify settlement agreements and their intention to the public. 

Don't force settlement agreements in adverse actions when it is 

something as simple as fees or paperwork updates that could be 

corrected.

Nicole Dehne Q11 The Agricultural Mediation Program should cover costs for 

mediation. Certifiers could avoid appeals by using the mediation 

process but currently certifiers charge farmers to mediate while the 

appeals process is free. NOP should make sure that mediation for 

organic certification is covered under the Agricultural Mediation 

Program. This would save the USDA money.

Devin Dowell (WSDA) Q11 - Maybe slightly off topic, but I would like clarification in the rule 

of when to pursue a Suspension instead of a Revocation

Cali Alexander Q10 "Right of Entry" authority should be legally researched.

Nicole Dehne Q11 https://www.agmediation.org/

Juan Guzman Q10. The process of certifying an entity or growing practices as 

Organic has a cost, CCOF for example does based on revenue, others 

have a fixed rate. A certain amount of this cost should be passed 

from the certifying bodies to the USDA, to covers some of the costs of 

unannounced inspections and other operating costs.
Kate Mendenhall Q11. How do you plan to handle very large clients & certifiers? 

Perhaps certifiers that handle client payments above a certain 

threshold must have a third-party certifier randomly identified by 

NOP conduct part of the review or provide a surprise inspection. The 

threat of losing a very large paying client to non-compliance could 

create bias and inconsistency.

jake lewin Q11) Rule should allow for correction of noncompliances during 

proposed adverse action. NOP should revise current reading of text 

of regulation.

Beth Rota Q11 agree that settlement agreements should not be needed for 

administrative noncompliances

Sam Welsch 12. Complaint investigation was not listed as an item for discussion, 

but too often complaints are dismissed too easily.

Andy Hupp 11 - ACAs are required to use the adverse action process 

unnecessarily for administrative issues, taking up valuable resources 

that could be used for investigations and other compliance work that 

has a greater impact on organic integrity.

marissa pyle i agree with jake and andy

Nicole Dehne Q11 Producers should be able to resolve proposed suspensions vs 

having to mediate and go into a settlement agreement.

Lori Kenyon Q10: Investigating complaints can be a costly expense to a certifier. 

Could federal funding support some cost due to ensuring integrity

Dimitris Sotiropoulos 11 non-compliances and appeals should not be left to be interpreted 

by CBs. NOP should at least categorize according to the severity and 

leave room to the CBs about the sanctions imposed. The frame 

should be unified horizontally for all CBs.

Alexis Randolph Q11 agree with Jake Lewin that NOP current reading of rule to 

prevent accepting noncompliance responses during adverse action is 

an interpretation that could be revisited

Jerry Combs Q-11 We were made to switch from Quat Strips to Nitrogen strips 

and the next year told to switch back. Eliminate the make it up as you 

go clause.

jake lewin Q10) UAIs strengthen the system and generate value. cost of 

inspections themselves is pretty minor overall.

Kimberly Bousquet Other item: certifies should have more accountability toward the 

AMS; not just toward their customers

Chris Grigsby Q11 - appeals are too time consuming and give the operation way 

too much time to continue as certified. Perhaps consider 

differentiating between administrative noncompliances and actual 

production/compliance related issues.

Kyla Smith agree with Lori (NOFA-NY) RE: cost for complaint unannounced
Cullen Carns-Hilliker 10. Support for rulemaking for unannounced inspections, similar to 

the current NOP guidance.

Andy Hupp Agree with Cullen re: adding unannounced inspections to the rule

Alexis Russell 12. It would be helpful for certificates to be attached to the integrity 

database so I don't have to call every supplier I have on my list to get 

updated certificates. If it's public information then why not have 

certifiers upload the actual certificate to the database as well?

Erin Heitkamp NOP's enforcement authority should include the retroactive recall of 

organic labeled products that have been proven to not be in 

compliance with the NOP.

Stephen Walker 11- mediation might not just occur in one "session," but can be a 

series of communications in varied forums.

Sarah Reed 11. Per Penalty Matrix, required Combined Notice of Noncompliance 

and proposed suspension for "accidental or otherwise un-willful 

application of a prohibited substance to land" results in adverse 

action process when operation simply needs/wants to surrender 

certification of the land. This is very burdensome for certifiers.

Tina Sohal unannounced audits for manufacturers too

jake lewin Really nice of NOP to give the entire public an opportunity to engage 

and share thinking. Strongly encourage NOP and department to 

continue to make rules and moving the system forward to ensure the 

massive value creation that comes from organic production, well in 

excess of theoretical "economic impact"

Erin Heitkamp 10 - Pipeline Foods supports unannounced inspections.

Arturo Gonzalez Totally agree with Alexis

Neil Millman General comment: Fertilizer-gate -- look at each new regulation with 

an eye towards this question: How would this new rule have 

identified / prevented fertilizergate? if it wouldn't have prevented / 

identified it... it's not worthwhile.

Lori Kenyon provide questions prior to town hall so can be more prepared.

meredith smith I really appreciate you requested feedback this early in the process -

thank you!!!!

Stephen Walker This was all pretty shoot from the hip and pretty quick. But, 

appreciated, for sure.

Kyla Smith i really appreciate the early engagement. questions in advance would 

be really helpful

Cynthia Morphet Appreciate the opportunity to provide comments/feedback at this 

stage of the process.

Kimberly Bousquet Thank you for this town hall opportunity. I'm subscribed to AMS 

updates, so found it there. I appreciated being able to see everybody 

else's response.
Kimberly Luce Nice to feel more like part of the process

Aubrey Lopatin Agree with Lori -- provide questions in advance to be more prepared

Allison Burke Find Town Hall - informed by our Organic Certifier

Jackie DeMinter Thank you for the engagement in the process early!

Nicole Dehne Let us know what the topics will be ahead of time so we can think 

about the issues in advance for better comments.

Amalie Lipstreu Appreciate your reaching out for advance input for the rulemaking 

process-thank you! Agree- with Kyla that questions in advance would 

be helpful

Gwendolyn Wyard This was extremely helpful and we support future Town Hall 

opportunities. Early input on a proposed rule is greatly appreciated. 

Nice use of technology. Thank you, more please!

Beth Unger I appreciate getting a sense of your direction. The chat box went so 

fast that it was very difficult to get a sense of the input. We look 

forward to seeing the posting to get a better sense. Thank you for 

setting this up.

Jerry Combs This is a great webinar and I appreciate your time and efforts in 

informing the Organic Community. Great Job))

Kate Mendenhall Really appreciate the opportunity to participate and provide 

feedback. Agree a list of questions ahead of time would be helpful.

Rebekah Finn It would have been nice to have the questions in advance so we had 

more time to gather thoughts and ideas in more time than 5 minutes

George Kalogridis Share questions prior to meeting

Alesia Bock I found this Town Hall via email this morning. Not sure I would have 

paid much attention. But I'm happy I found it and was able to 

participate. Next time, provide multiple reminders?

veronica reyes Thank you for information

Synthia Morales We are conform with this webinar, appreciate the oportunity to be 

part of the process

Richard Siegel Very pleased with Town Hall. Very efficient way to receive feedback 

from large group of people. Look forward to reading all the feedback 

on line.

Neil Millman How did you find this town hall? excellent. it gave folks voice. thank 

you!

Chris Fanta Thanks for allowing the recording to be published, as well.

Juan Guzman Q11. All processes must have a specified standard set deadline, in 

other words no more than 30 days, vs trying to complete the process 

based on the workload of the agency,

mike crotser What might we do differently next time? Why the new process 

instead of first funneling through the normal NOSB process?
Chris Grigsby Would have been good to get the questions and topics in advance for 

more prepared answers.

Michelle O'Brien Would be good to provide questions a head of time to be able to run 

by others to provide feedback if they are unable to attend a town hall

Emily Brown Rosen how you did: Good idea to give this opportunity, will help jumpstart 

community thinking at an earlier stage of rulemaking. Thanks.

Cali Alexander Have many of these along the process!

Cynthia Morphet Agree that seeing the questions in advance would allow for more 

thoughtful, inclusive feedback

Angela Echols Agree that list of questions ahead of time would help us be more 

prepared. Having more background on current regulations compared 

to how they are being proposed to change.

Cindy Elder The opportunity to provide comments so early is appreciated! It 

would be helpful to know the topics/questions in advance, so 

certifiers can be prepared by discussing with the various staff 

involved.

Elizabeth Tigan We would like to be better prepared in the future.

Andy Hupp Thanks for providing this opportunity for early feedback in addition to 

the public comment period where we have more time to prepare 

considered content.

Lianne Nunes Enjoyed and appreciated this town hall opportunity prior to rule 

making. Would like to be given questions prior to the webinar so 

answers can be more prepared.

JAIME GARCIA Sound was coming and going, probably need a better platform to 

have these webinars.

Dimitris Sotiropoulos it was a very positive and interactive experience. Thank you for the 

opportunity

Britt Britt Thanks for hosting this. It would be useful to be able to access the 

comments as a pdf, rather than just via watching a recording of the 

webinar. They move past pretty quickly as they are coming in. Agree 

would be great to get questions ahead too.

Nicole Dehne This was great. Thanks for attempting to get our input earlier.

Alexis Russell Giving some background information ahead of time so we can make 

more informed comments would be very helpful

Bill Wolf A healthy process, thank you. It would have been helpful if questions 

were posed in advance.

Randy krieg Send out questions in advance so answers are more complete

Alesia Bock I agree with questions ahead of time. that would be helpful.

Aubrey Lopatin Thank you for providing this opportunity to be included in the 

process without having to travel to a fall/spring meeting
Madison Kempner Appreciate the additional opportunity to provide feedback, and agree 

with others about circulating questions in advance.

Erin Heitkamp Thank you for sharing information on the regulatory changes NOP is 

currently considering and the opportunity to provide feedback. It 

would be of significant interest to see a summary of all the feedback 

you receive during the session. Opportunities to continue to engage 

in this format in the future would be appreciated.

James Cook Thank you

Melinda DeNobrega Agree with feedback that it would be nice to have questions ahead of 

time

Lianne Nunes Great Idea. Hope the NOP continues to do this with future rule 

making

Michael Menes Would like to see the questions prior to the meeting. very fast 

process.

Richard Mathews Q 10 - WODPA supports unannounced inspections. these inspections 

should be factored into the certifier's fee structure.

Kimberly Bousquet Agreed with advanced notice of topics! Thank you presenters.

Jessie Jessie We appreciate the opportunity to add our feedback and input to 

these questions around rule making.

Elise George Helpful and interesting format, thank you.

JAIME GARCIA The limited time to answer questions since the presentation 

continues makes it to be in a rush.

Sarah Reed Really great opportunity to provide feedback, thank you. Suggestion 

to improve - no talking during the "answer the question" moment as 

it is difficult to listen and type. Also hard to read others responses 

especially when they are long, unclear how visible they will be in the 

recording.

Jackie DeMinter We appreciate knowing the direction NOP is heading!

Gwendolyn Wyard Agree, a summary of the input would be greatly appreciated.

Chris Grigsby Any chance to push the OLPP forward again? Desperately needed!

Cullen Carns-Hilliker I agree with Jackie

George Kalogridis Thank you for reaching out to the greater organic community

Lynn Johansen narrower focus might be helpful to fine-tune the comments. Great 

though to be included early.

Richard Bertrand Thank you

Alexis Russell Agree with Sarah! It was hard to reason out my response while 

everyone was still talking

Juan Guzman Townhall was great, it would be great if we could receive the power 

point a couple of days ahead, so the contributions can be further 

researched and validated

Sarah Reed Agreed that more time for each question would be helpful.
Alesia Bock I wish your team luck in getting through all these awesome responses 

:)

Synthia Morales A summary is needed. Thank you

hande kemerli thNK YOU

jake lewin q-10) suggest NOP consdier the allowance for certifiers to also 

implement focused isnpections instead of annuals so they can do 

better more nuanced work on biodiversity, soil conservation, pasture 

etc.

Richard Mathews Q When wwill the slides from this webinar be available.

Dimitris Sotiropoulos It would be very helpful if you could "automatically" group the 

answers under the Questions somehow :-) (connect it to the 

Question number maybe?)

Genevieve Albers Thank you for this opportunity. Agree with comments regarding more 

advance notice of questions.

Ali Hudson Please provide the comments/feedback in a format that is easier to 

review than just the recording. Some comments were bumped off 

the chat too quickly. Thank you for the opportunity to provide 

feedback.

Arturo Gonzalez Thank you for the info, this should happen more often, its a great 

way to share and communicate information.

Julie Paillat thank-you. very smooth and got through a LOT of info. I am not able 

to feedback at this time but it gave me good insight which can be 

used as follow up, and for the formal opportunity.

Judy Baldwin Topics could include from start to finish the certification process, and 

receiving your certification in a timely manner.

Rebekah Ritson Concur - especially with such a limited time to provide feedback, 

having the questions in advance would allow participants to provide 

well formulated and considered responses, which will ultimately be 

more valuable to the rulemaking process.

Angela Echols This was a nice way to feel open to providing feedback in a more 

informal setting. I feel you will get more comments this way then 

formally submitting.

Randy krieg This has been a very good forum.

Melissa Elkins There is way too much time between retailer audits and feedback on 

the audit and status of certification - we were audited last in March 

2018 and were told to have all of our 2016 invoices on site; when we 

were audited, they only asked for invoices from FY 2017, which 

ended up costing us money and time getting all of our 2016 files on 

site that ended up never being needed. We still haven't gotten any 

feedback on our audit and it's been four months. There needs to be a 

much better system and communication protocol on retail audits.

Rebekah Ritson whoops, sorry, wrong windo!
Cali Alexander Would love copy of everyones input!

JAIME GARCIA but definitely need more webinars and more information flowing 

through. Thanks for hosting this one!

Marisol Oviedo Jenny, when will this webinar info be available on the NOB website?

jake lewin Q10) cont'd. this could result in a decrease or maintenance of existing 

costs with better compliance outcomes in the most important areas 

of the rule.

Rebecca Frey More of these webinars should be done throughout the rule-making 

process,.

Juan Guzman A summary of the meeting and the answers would be great.

Juan Guzman Thank you for doing this and for all the participants.

Arturo Gonzalez Is it possible to send us a link by mail to go over the entire chat?

Daniel Burkard A transcript of the Q&A box would be helpful. Many of the answers 

vanished before being fully read.

Michael Menes Will there be a response from the NOP on the comments?

Dimitris Sotiropoulos Could we get all the comments in a txt file or word document?

Rudy Amador Great first virtual townhall. Consider keeping chat open for X time 

after the webinar so that participants have more time to answer 

questions fully.

Marty Mesh Look forward to opportunity to give input on these questions with 

ability to type slower

jake lewin q10) NOP should ensure the authority to require certain types or 

approaches to uannounced inspections so it is not solely up to ACAs, 

or at least to give NOP authority to require as directed.

julio diaz thanks for the info

Mark Kastel 45 minutes of organic stakeholders, shooting from the hip, on 

questions that were withheld prior to this session, does not remotely 

compare to the thoughtful engagement between industry 

participants and the NOSB which has proceeded rulemaking in the 

past.

Sam Welsch what is email to submit comment later?

Melissa Elkins Thanks for doing this - questions ahead of time would be great, but 

glad for the opportunity to submit our opinion.

Alexis Randolph Feedback - Great to have the opportunity to provide public 

comments direct to NOP. Many of these topics have been brought 

up during NOSB so not a surprise. However, some are new (e.g. 

changing adverse action process) which may require additional 

opportunity for feedback before going to rule making. To not risk the 

more vetted items from moving forward, I would encourage NOP 

consider keeping some items out of rule making until more public 

comment is received. Thanks you.
Juan Guzman Jenn, could you go back to the first slide

Jessica Walden thank you!

Kelly Monaghan Thanks very much

Richard Mathews I agree with Marty Mesh regarding having time to consider the 

questions and type slower.

Juan Guzman That shows your contact info as well as the other presenter?

Gwendolyn Wyard We appreciate that many of the questions are the same questions 

that NOSB asked in its spring 2018 Discussion Document. This 

provides another opportunity and reaches a larger audience.

Sarah Reed Consider allowing folks to send additional feedback after the 

presentation for those whose brains need a little more time to 

consider a thoughtful response. We acknowledge that there will 

provide draft comment.

jake lewin I felt prepared for this because of reading the documents NOP linked 

to in the invitation and the previous newsletters. none of the topic 

areas were a surprise.

Chairperson Thanks all for your comments! We will close chat in 1 min. Last call 

for feedback. 

Aubrey Lopatin Thank you again for providing this new format. Really helpful for 

smaller organizations. Hopefully, it reaches a broader audience and 

more stakeholders!

Chairperson We are closing the line now - thanks! END 
Strengthening Organic Enforcement Town Hall Participant List, July 17, 2018

USDA Agricultural Marketing Service, National Organic Program 

 Last Name, First Name

Abbott, Kelly

Adam, Warthesen

Adriainie, Adriainie

Aerin, Aerin

Afton, Drew

Agostini, Thais

Albers, Genevieve

Alexander, Cali

Amador, Rudy

Anderson, Alice

Anderson, Glenn

Anegon, Angela

Angel, Tracey

Anne, Anne

Armbrust, Heidi

Armstrong, Andres

Atkinson, Gisele

Avila, Joan

Bailey, Shane

Baker, Westley

Baldwin, Judy

Ballard, Tammie

Bascom, Crystal

Bauer, Brittny

Beausoleil, Km

Becker, Elizabeth

Benna, Sharon

Berical, Annie

Berkebile, Jen

Bertalmio, Genny

Bertrand, Marie-Eve

Bertrand, Richard

Bewersdorff, Daniel

Black, Jim

Bob, Bob

Bock, Alesia

Botto (Oia), Ariel

Bousquet, Kimberly

Britt, Britt

Brown, Beverly

Brown Rosen, Emily

Browner, Paul

Brubaker, Shannon

Buhler, Ashley

Burkard, Daniel

Burke, Allison

Burns, Susan

C, Jay

Capehart, Mary

Carlton, Kelly

Carmody, Daniela

Carns-Hilliker, Cullen

Carr, Jamie

Carrillo, Patricia

Casto, Lynnessa

Caswell, Marcus

Cedamanos, Yasmin

Cerci, Tugce

Chairperson, 

Chansilp, Mike

Charette, Jamie

Charles, Melissa

Chesnut, Dana

Clark, Jared

Clark, Megan

Claypool, Rebecca

Clemente, Cesarina

Cobianchi, Gina

Collier, Ellis

Combs, Jerry

Coody, Lynn

Cook, James

Cook, Justine

Corbett, Michael

Cori, Cori

Coulson, Michael

Courtney, Cheri

Cowell, Thomas

Criss, Jill

Crotser, Mike

Cruse, Jennifer

Dag, Dag

Dagoberto, Marty

Dai, Zi Ran

Dale, Kelli

David, David

Davidson, Amy

Davis, Graham

Davis, Katie

De Pedis, Laura

Debates, Megan

Deborah, Deborah

Dehne, Nicole

Delauter, Ashley

Deminter, 

Denobrega, Melinda

Dermond, Allison

Diandra, Diandra

Diaz, Julio

Dick, Mira

Dill, Mike

Dominique, Dominique

Donnel, Donnel

Doster, Elizabeth

Dowell (Wsda), Devin

Durand, Wendy

Durkin, David L.

Echols, Angela

Edwards, Suzette

Einstein-Curtis, Aerin

Elder, Cindy

Elkins, Melissa

Emirler Ã–Zsan, Ã–Zlem

Engle, Elvin

Etile, Maxime

Eustice, Amanda

Fanta, Chris
Farias, Brian

Farnsworth, A Stephen

Fernandez, Leslie

Ferris, William

Fields, Daniel

Fierst, Megan

Figueredo, Elizabeth

Finn, Rebekah

Fishback, Levi

Forbes, Stephen

Fowler-Riggs, Mayze

Frances, Valeria

Frankel, Lee

French, Karin

French, Shelby

Frey, Rebecca

Gagnon, Daniel

Gaitan, Ann

Gandolfo, Jana

Ganske, Heather

Garcia, Jaime

Garcia, Katriana

Gasinski, Aimee

Gehman, Rebecca

George, Elise

Gieseke, Beth

Gina, Gina

Godfrey, Evan

Gonzalez, Arturo

Gottmann, Anna Maria

Gracie, Josianne

Grasseschi, Christina

Greene, Kim

Griess, Roger

Grigsby, Chris

Guevara, Maki

Guntin, Ignacio

Guzman, Juan

H, C

Haddouche, Lila

Haines, Julia

Hake, Paige

Halsted, Susan

Hammergren, Chris

Hand, Mary

Hanks, Nathan

Harrington, Tawana

Harris, Chris

Harsh, Cameron

Heitkamp, Erin

Herbruck, Brennen

Hernandez, Danny

Hourigan, Ann Marie

Hubbart, Sarah

Hudson, Ali

Hudson, Ian

Hupp, Andy

Iglesias, Julio

Ingrid, Ingrid

Jacob, Lindsay

Jasmin, Jasmin

Jeff, Jeff

Jessica, Jessica

Jessica, Jessica

Jessie, Jessie

Jockel, Sam

Johansen, Lynn

Johnson, Brad

Johnson, Daniel

Jordan, Brittany

Kaja, Bhagya

Kalogridis, George

Kanagasunderam, Sherine

Kane, Patricia

Karlin, Marni

Kastel, Mark

Katherine, Katherine

Kelly, Kelly

Kemerli, Hande

Kempner, Madison

Kenworthy, Jody

Kenyon, Lori

Kern, Glenn

Kidwell, Christopher

Kieft, Janis

Kintz, Soline

Kissinger, Heath

Kline, Dusty

Koory, Ryan

Krieg, Randy

Kuljian, Nina

Kurple, C

Lacombe, Calem

Landa, Pedro

Landa, Sofia

Lanspa, Rachel

Lee, Danny

Lee, Juny

Lee, Megan

Lenczyk, Chelsey

Leticia, Leticia

Letis, Letis

Lewin, Jake

Lewis, Nate

Lichtner, Sarah

Lichty, Martin

Linder, Janet

Lindsay, Lindsay

Lindsey, Arianne

Lipstreu, Amalie

Lockman, Dave

Lopatin, Aubrey

Lopez, Irazu

Lopez, Luis

Love, Lucy

Lovera, Patty

Lucas, Kierra

Luce, Kimberly

Lundquist, Erica

Lydeen, Allison

Macias, Allison

Mack, Alyssa

Magallan, Daniel

Marenzi, Maria Ines

Markowski, Sarah

Marner, Paul

Martin, Andy

Martin, J

Martin, Mason
Martin, Sandia

Martinez, Alvaro

Mason, Jody

Mathews, Richard

Matthieu, Carri

Max, Max

Mayer, Yvonne

Mazurets, Natalie

Mcclain, Fatima

Mccormack, Amy

Mcdonald, Megan

Mcelroy, Bridget

Mcgovern, Dan

Mcguigan, Brian

Meadow, Scott

Megan, Fierst

Megan, Megan

Melapie, Martina

Menachem, Menachem

Mendenhall, Kate

Menes, Michael

Mesh, Marty

Meyer, Melody

Michel, Manuel

Michelson, Russell

Miles, Miles

Millman, Neil

Mirenda, Johanna

Monaghan, Kelly

Monteiro, Sophie

Morales, Synthia

Morphet, Cynthia

Morrell, Melody

Morrison, Sarah

Mudge, Courtney

Muley, Medha

Mulhall, Brian

Murga, Josã©

Nagel, Kara

Nell, Peter

Neufeld, Jacob

Newman, Alice

Noland, Henry

Nunes, Lianne

Nurse, Sandy

O'Brien, Colleen

O'Brien, Michelle

Ordoã±Ez, Clara

Oviedo, Marisol

Paciello, Stefania

Paillat, Julie

Parker, Courtney

Patel, Miraj

Paulsen, Wendy

Pedro, Pedro

Penn, Daniel

Pexton, Fiona

Phil, Phil

Piper, Colette

Pivonka, Lydia

Platt, Felicia

Pletcher, Cydnee

Pohle, Kimberly

Pope, Lauren

Prieto, Ricardo

Propson, Leona

Pudwill, Rhonda

Puig, Feliciana

Puruleski, Bob

Pyle, Marissa

Rabago, Rebeca

Randolph, Alexis

Reed, Sarah

Reyes, Veronica

Richards, Brandon

Richart, Sherri

Richer, Leonard

Ritson, Rebekah

Roberson, Michael

Robinson, Jennifer

Rodriguez, Pamela

Rokala, Mark

Romero, Eddy

Rosado, Robert

Ross, Anne

Rota, Beth

Russell, Alexis

Sachnoff, Lee

Salhab, Monique

Sally, Sally

Santaliz-Rogers, Gianfranco

Santucci, Ernest

Sarah, Sarah

Sartori, Paula

Sattelberg, Jim

Schaefer-Joel, Sam

Schmale, Val

Schockman, Paul

Scholtus, Lennart

Schortzmann, Brittney

Seggerman, Ingrid

Semper, Annette

Shattuck, Sharon

Sherri, Sherri

Shuler, Jennifer

Shurney, Denise

Siegel, Richard

Siemers, Joyce

Simsic, Derek

Siple, Susan

Skidgel, Skidgel

Small, Debra

Smith, Andrea

Smith, Kyla

Smith, Meredith

Smith, Terry

Smith, Thomas

Snyder, Jodi

Sohal, Tina

Sotiropoulos, Dimitris

Spycher, Bryce

Stewart, Caleb

Stewart, Kris

Stewart, Susan

Stolpestad, John

Swartwood, Stacy

Tajc, Mary Beth

Tanner, Ron

Tatro, Gordon
Tester, Wanda

Thomas, Adriainie

Tigan, Elizabeth

Tipton, Tra

Tram, Phan

Tripp, Tessa

Troetschler, Cynthia

Truong, Kim

Tsang, Nancy

Twombly, Jo

Unger, Beth

Vasquez, Justina

Velazquez, Emily

Ventrella, Matthew

Von, Jennifer

Voss, John

Vulin, Ashley

W, J

Wagner, Julie

Walden, Jessica

Walker, Brenda

Walker, Stephen

Wang, Charlene

Ward, Ellery

Warner, Karlin

Wasteneys, Carol

Watkins, Cindy

Watkins, Patricia

Waxman, Addie

Weida, Chad

Wert, Cody

West, Carrie

Westlake, Sarah

Westphal, Janin

Wheeler, Bonnie

Whitcher, Jason

Wilburn, Tammie

Wilcox, Brynne

Wilder, Karen

Willard, Anne

Willows, Rebecca

Wills, Maury Wills

Wilson, Gibbs

Winters, Monica

Withey, Katherine

Wojahn, Terri

Wolf, Bill

Wraspir, Darice

Wyard, Gwendolyn

Yang, Roert

Yokote, Yutaka

Youngblood, Abby

Zacharisen, Joni

Zimmer, Gretchen