National Organic Program

1400 Independence Avenue, SW

Room 2642-South, STOP 0268

Washington, DC 20250-0268

Page 1 of 2

July 2, 2021

MEMORANDUM TO THE NATIONAL ORGANIC STANDARDS BOARD

FROM: Jennifer Tucker, Ph.D.

Deputy Administrator

National Organic Program (NOP)

SUBJECT: Response to National Organic Standards Board Recommendations (Spring 2021

Meeting)

Background

This memorandum responds to recommendations the National Organic Standards Board (NOSB) 

made to the U.S. Department of Agriculture (USDA), Agricultural Marketing Service (AMS), 

National Organic Program (NOP) at its virtual meeting, which took place April 28-30, 2021.

Summary of Recommendations and AMS Responses

• Petitioned Substances

The NOSB recommended one amendment to the National List of Allowed and Prohibited 

Substances (National List) based on its review of a petition. The National List is a section of 

the USDA organic regulations that includes synthetic substances allowed in organic crop and 

livestock production, nonsynthetic substances prohibited in organic crop and livestock 

production, and non-organic substances allowed in organic handling.

Substance Section of Organic 

Regulations

NOSB Recommendation

Paper (Plant Pots and 

Other Crop Production 

Aids)

Crops

§ 205.601

Classified as a synthetic substance; 

recommended for addition to the 

National List supported by a 

recommendation to add a definition 

of “Paper-based crop planting aid” to 

§ 205.2

AMS Response: AMS regularly publishes National List rules to implement NOSB 

recommendations. AMS is drafting a proposed rule to address the NOSB’s recommendation 

for paper-based crop planting aids.
• Ion Exchange Filtration

The NOSB voted to request assistance from the NOP to determine, by legal opinion or 

conference with the Food and Drug Administration, whether ion exchange resins are 

secondary direct food additives or food contact substances.

AMS Response: AMS thanks the Board for their work on this topic. AMS has discussed this 

topic with FDA since the meeting and is working on a separate response to the Board. AMS 

recognizes ion exchange remains a source of inconsistency among certifiers. In the 

meantime, certifiers may continue their ongoing practices, as no noncompliances have been 

identified related to the use of this material.

• Human Capital: Strategy for Recruitment and Talent Management

The NOSB recommended that NOP further explore and support the recruitment and retention 

of qualified organic inspectors and reviewers. The NOSB recommended the following 

avenues to accomplish this: encouraging consistency in contracting and employment by 

certifiers, exploring access to pooled insurance purchase opportunities, opportunities to 

reduce the amount of travel, building a consistent mentorship program, and encouraging 

standardized inspector pay rates across certifiers.

AMS Response: AMS thanks the NOSB for the ongoing work with this complex topic. 

AMS has issued a request for proposals to address this recommendation and looks forward to 

working with the Board further on this topic.

Summary

AMS acknowledges and sincerely appreciates the many hours NOSB provided in developing its 

recommendations. AMS supports NOSB’s vital role in representing the diversity of the organic 

community and ensuring organic integrity.

AMS thanks Steve Ela for his continued service as NOSB Chair and thanks Nate Powell-Pam 

and Mindee Jeffery for their service as part of the NOSB leadership team.

AMS welcomes five NOSB members whose terms started in January 2021: Amy Bruch, Brian 

Caldwell, Carolyn Dimitri, Logan Petrey, and Kyla Smith. The program appreciates their 

commitment and congratulates them on their first meeting as NOSB members.