Project Point Status Target Meeting 

Person 

Letter for other FACA 

boards 

Zea Discussion document? spring 2012 

Get feedback from 

other committees on 

All 

committee 

In progress Spring 2012? 

framework document members 

topics 

 

 

 

 

Note: Committee notes may include preliminary discussions regarding substances considered 

for addition to or removal from the National List. They do not represent official National Organic 

Program (NOP) policy or regulations. Please see the NOP website for official NOP policy, 

regulations, and status of substances used in organic production and handling. 

National Organic Standards Board (NOSB) 

GMO ad-hoc Committee 

Wednesday, February 29, 2012, 3 pm ET 

Attending: Zea Sonnabend (Chairperson), Jay Feldman, Jennifer Taylor, Colehour Bondera 

and Joe Dickson 

Absent: Mac Stone and Calvin Walker 

NOP Staff: Lorraine Coke and Miles McEvoy 

Agenda: 

-get organized – determine call schedule, select vice chair (?), previous/outstanding issues, etc. 

-review/discuss documents 

-create timeline and work plan 

-assign tasks to committee members 

Discussion: 

Possible work plan for May meeting 

-give a short presentation at the spring 2012 meeting to explain to public that they are meeting 

on it 

-write letters to other FACA committees relating to this (AC21 Committee and Genetic 

Resources Advisory Committee) 

Have committee members (representing other committees) take information on framework back 

to their individual 

Suggestion to create charter or mission statement for group to help guide/focus 

-important to understand perspective and why Board is spending time on this 

-agreement on focus/mission among committee members 

Is there resistance on this among the committee/Board? 

-a more comprehensive and strategic approach may help this process 

Any additions to the framework? 

-under CACC, how GMO testing fits into the residue testing protocol, follow-up action, “tolerance 

levels” or the meaning of the results (i.e. how certifiers utilize GMO testing to verify compliance 

with the NOP regulations) 

-Board proposal about communicating directly with Secretary of Agriculture (maybe under 

section regarding letters to other FACA Boards and the public) – was not put on here before 

because it didn’t go anywhere, the Secretary is aware of the NOP/NOSB work  have to think 
 

 

 

 

 

 

about what the best avenue is to get the message heard 

-recent news about APHIS trying to approve GMO varieties in a more expedient manner (could 

be another topic for a letter) 

-both sides must be able to articulate their views and present them in a way that is constructive 

Process question: 

-how to draft a letter and receive public comment – list on agenda, develop proposal, open for 

public comments, vote (just like the process for any other proposal) 

-difference between “sense of the Board” and letter asking for policy change? 

Ask for time slot on EC call to get agenda spot and present proposal(s) during spring 2012 

meeting 

Meeting schedule: 

Wednesday – 1pm EST (March 7) 

Wednesday – 3pm EST (March 21) 

Next Calls: 

March 7, 2012 – present draft of mission statement for committee 

March 21, 2012 – 

Milestone Deadline 

Spring 2012 Agenda Finalized Friday, March 23, 2012 

Committee Proposals Due Monday, April 2, 2012 

Spring 2012 NOSB Meeting May 21 – 24, 2012 
 

 

 

 

 

 

 

 

 

 

 

Note: Committee notes may include preliminary discussions regarding substances considered 

for addition to or removal from the National List. They do not represent official National Organic 

Program (NOP) policy or regulations. Please see the NOP website for official NOP policy, 

regulations, and status of substances used in organic production and handling. 

National Organic Standards Board (NOSB) 

GMO ad-hoc Committee 

Wednesday, March 7, 2012, 1 pm ET 

Attending: Zea Sonnabend (Chairperson), Jay Feldman, and Colehour Bondera 

Absent: Mac Stone, Joe Dickson, Jennifer Taylor and Calvin Walker 

NOP Staff: Lorraine Coke and Miles McEvoy 

Project Point 

Person 

Status Target Meeting 

Letter; to other FACA 

boards, AC21, or 

Secretary Vilsack 

Zea Discussion document? spring 2012 

Get feedback from 

other committees on 

framework document 

topics 

All 

committee 

members 

In progress Spring 2012? 

Agenda: 

• Approve minutes from last call 

• Mission Statement: since we agreed to discuss this I am proposing the following 

paragraph for consideration: 

“The National Organic Standards Board believes that genetically modified organisms 

(GMOs) must be kept out of organic food and accepts responsibility for making 

recommendations on policies that can strengthen the rule's approach to "excluded 

methods". The NOSB ad hoc GMO committee will undertake examination of all the 

areas where GMO contamination poses a threat to organics and will attempt to provide 

leadership in clarifying what excluded methods actually are, and how compliance to the 

provisions of the rule can be monitored”. 

• "Sense of the Board" letter - Colehour (already circulated) 

• AC 21 letter/proposal - Zea (I have been communicating with several organic reps to this 

board and they will send me some language tonight that I will try to circulate as soon as I 

can) 

• Planning for presentation at next meeting and longer-term work. 

Discussion: 

• Review of draft mission statement 

use of the word “strengthen” could be edited, maybe to a more neutral word 

-use of “strengthen” gives the assumption that you are starting from a position that it 

needs to strengthened. This word could be replaced with “pertains” 

-question about what “GMO contamination” means and how it is measured/defined 

-a little long for a purpose/mission statement, but it is very inclusive 

-could stop after “excluded methods” in the 2nd sentence, but some committee members 

like the 2nd sentence 

-maybe some outside factors, which are outside a producers’ control, 

-belief that 1st statement/sentence is important too 
 

 

 

 

 

 

 

new draft as discussed: 

The National Organic Standards Board believes that genetically modified organisms 

(GMOs) must be kept out of organic food. We accept responsibility for making 

recommendations on policies that pertain to the rule's approach to "excluded methods". 

The NOSB ad hoc GMO committee will undertake examination of all the areas where 

GMO contamination poses a threat to organics and will attempt to provide leadership in 

clarifying excluded methods, with a focus on implementation. 

-some reservations on the use of the word “contamination” – how does this include the 

“use” of GMO products/methods? How do you keep GMOs out of organic production? 

-some may argue that “Contamination” has an acceptable level 

-original mission statement tried to include “contamination” and “leadership” to try to 

address these concerns from the public 

another possible draft: 

The National Organic Standards Board believes that genetically modified organisms 

(GMOs) must be kept out of organic food. We accept responsibility for making 

recommendations that pertain to "excluded methods" to ensure that GMOs are 

prohibited in organic production and handling and don’t contaminate organic agricultural 

products. The NOSB ad hoc GMO committee will examine all the areas where GMO 

contamination poses a threat to organics and will provide leadership in clarifying what 

excluded methods actually are, and how compliance to the provisions of the rule can be 

monitored. 

• “Sense of the Board” letter: 

-this committee should be communicating/advising the secretary of agriculture on these 

issues – one committee member expressed that this is important and could be done 

fairly easily 

-the longer letter , which was sent by email, is similar to shorter letter(?) – either one 

could be used, depending on what the committee decides 

-if committee were to decide that one is preferable to the other, then could go with 

revising/editing only that draft 

-first issue, should we have a letter (if yes, who should it go to?)? second issue - what 

should it say? 

-the first letter seemed to have come out as a “reaction” to the deregulation of sugar 

beets, interest in broadening the letter 

-sending this letter to AC21 may be the best approach because they are dealing with 

some of these issues 

-feeling from several committee members that a letter is the most feasible product to 

present at the spring meeting, some members also suggested a discussion document 

-suggestion to create a separate letter to the secretary – this may be best to propose to 

the group 

-consider the fact that the letter will be published on the NOP website 

moving forward – starting with a short letter (to the secretary?), including mission 

statement, rewording to make the letter more focused, need to convey the importance of 

the public comments (this meeting was unique – number of comments and types of 

comments) 

• AC 21 letter/proposal: 

-AC21 had meeting on March 6 

-concern from some members – a primary concern/topic is seed purity (this could be 
 

 

 

 

 

 

 

 

 

appropriate for Crops committee – maybe a discussion document for spring 2012?) 

-general feeling that the organic interests group is a minority on this committee 

-specific issues include contamination, fairness, indemnification, and representation 

if writing a letter to the AC21, then need to focus on the important issues (like 

indemnification) 

-concern that a compensation program doesn’t focus on preventative practices 

-this “involuntary exposure” or “pollution” of GMOs to organic producers should be 

responsibility of manufacturer? Producers who use it? Combination? Others? 

-how will the GMO committee support this effort and/or select a topic to write this letter? 

-the issue of seed purity is a serious concern, especially in areas where soy and corn 

are widely grown/produced 

-establishing a threshold on “background” vs. “contamination” – have to be clear about 

how we define these 

-would be helpful to have more data on levels of contamination – this could be 

addressed in a discussion document 

Next steps: 

-take bullet points/discussion and shape them into a letter, have draft ready for review on 

next call 

Future Calls: 

March 21, 2012 (3pm EST) – finish/finalize mission statement, review/edit drafts of letters, 

prepare items for agenda for spring meeting 

March 28, 2012 (2pm EST) -

Milestone Deadline 

Spring 2012 Agenda Finalized Friday, March 23, 2012 

Committee Proposals Due Monday, April 2, 2012 

Spring 2012 NOSB Meeting May 21 – 24, 2012 
 

 

 

 

 

 

 

 

Note: Committee notes may include preliminary discussions regarding substances considered 

for addition to or removal from the National List. They do not represent official National Organic 

Program (NOP) policy or regulations. Please see the NOP website for official NOP policy, 

regulations, and status of substances used in organic production and handling. 

National Organic Standards Board (NOSB) 

GMO ad-hoc Committee 

Wednesday, March 21, 2012, 3:00pm ET 

Attending: Zea Sonnabend (Chairperson), Jay Feldman, and Colehour Bondera, Jennifer 

Taylor, Mark Lipson, Mac Stone, Calvin Walker 

Absent: Joe Dickson 

NOP Staff: Lorraine Coke, Michelle Arsenault, and Miles McEvoy 

Workplan 

Project Point 

Person 

Status Target Meeting 

Letter; to other FACA 

boards, AC21, or 

Secretary Vilsack 

Zea Discussion document? spring 2012 

Get feedback from 

other committees on 

framework document 

topics 

All 

committee 

members 

In progress Spring 2012? 

Agenda: 

• Finish/finalize mission statement 

• Review/edit drafts of letters to Secretary Vilsack and USDA, Letter in support of AC 21 

• Discussion paper on seed purity standard 

• Prepare items for agenda for spring meeting 

Discussion: 

Minutes from March 7- Approved 

• Finish/finalize mission statement 

Mission Statement: Chair proposes the following paragraph for consideration: 

The National Organic Standards Board believes that genetically modified organisms 

(GMOs) must be kept out of organic food. We accept responsibility for making 

recommendations that pertain to "excluded methods" to ensure that GMOs are 

prohibited in organic production and handling and don’t contaminate organic agricultural 

products. The NOSB ad hoc GMO committee will examine all the areas where GMO 

contamination poses a threat to organics and will provide leadership in clarifying what 

excluded methods actually are, and how compliance to the provisions of the rule can be 

monitored. 

Suggestion: Eliminate first sentence, start paragraph with second sentence, and keep 

the rest. 

Chair will send out revision with minutes for review by the members. 

• Review/edit drafts of letter to Secretary Vilsack (USDA) 

Draft Letter to encourage USDA to strengthen their role in preventing contamination from 

GMOs was sent around. The first sentence of the letter needs to be revised based on 

the conversation about the mission statement. 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Question as to whether or not this letter should be sent as open letter to Secretary 

Vilsack 

Letter should include intended outcomes. Right now it is not clear what the goal is, and 

what action the secretary should take. Members will include suggested language to 

make the letter stronger and include a way to open the door for further discussion. One 

member suggested softening the language about “the rest of the USDA...”, and 

changing the language in the sentence pertaining to stakeholders “conferring since 

2011”. A question arose about the difference between GE and GMO. Members agreed 

there should be more consistency in language and to use one or the other. Change 

second sentence of last paragraph to read, organic farmers must no longer be held 

“soley” responsible. Draft letter will be posted for public comment prior to the Spring 

Meeting. 

Group recommends that we add the letter to the Spring agenda 

• Letter in support of AC 21 

Members of AC21 suggested the letter, and the chair would like to put it on the agenda 

for the Spring Meeting. One member didn’t think it was ready, but the AC21 only has a 

one year charge so if the committee delays it will not get to them before they disband. 

An alternative could be to copy the AC21 on the letter that will be addressed to the 

Secretary of USDA. Potentially the AC21 could be extended. A question arose as to the 

committee makeup: 23 members, mixed with regard to organic and non-organic 

supporters. Farmers, industry, agribusiness, academics. Heavier on production industry 

(seeds and crops). Does not include processers. 

• Discussion paper on seed purity standard 

AC21 Members prepared this initial doc and the Chair of GMO committee edited it. Will 

start discussion for future efforts regarding GMOs. Mmbrs need to agree whether or not 

this should be on the agenda for the Spring meeting, and we can edit the questions on 

the next call. Not sure that this fits with the mission of the NOSB. There is confusion 

between process standards and outcome standards. Would like feedback about genetic 

drift 

• Prepare items for agenda for spring meeting 

Future Calls: 

March 28, 2012 (2pm EST) -

Milestone Deadline 

Spring 2012 Agenda Finalized Friday, March 23, 2012 

Committee Proposals Due Monday, April 2, 2012 

Spring 2012 NOSB Meeting May 21 – 24, 2012 
 

 

 

 

 

 

 

Note: Committee notes may include preliminary discussions regarding substances considered 

for addition to or removal from the National List. They do not represent official National Organic 

Program (NOP) policy or regulations. Please see the NOP website for official NOP policy, 

regulations, and status of substances used in organic production and handling. 

National Organic Standards Board (NOSB) 

GMO ad-hoc Committee Meeting Notes 

Wednesday, March 28, 2012, 2:00pm ET 

Attending: Zea Sonnabend (ZS) (Chairperson), Jay Feldman (JFe), and Colehour Bondera 

(CoB), Mac Stone (MS), Calvin Walker (CW), Joe Dickson (JD), Mark Bradley (NOP), Mark 

Lipson (OSEC) 

Absent: Jennifer Taylor (JT) 

NOP Staff: Michelle Arsenault (MA) 

Work Plan 

Project Point Status Target Meeting 

Person 

Letter; to other FACA 

boards, Secretary 

Vilsac 

ZS Discussion document spring 2012 

Get feedback from 

other committees on 

framework document 

topics 

All 

committee 

members 

In progress spring 2012? 

Agenda: 

• Approve minutes 

• Vote on Mission Statement. From last meeting: 

The National Organic Standards Board accepts responsibility for making 

recommendations that pertain to "excluded methods" to ensure that Genetically Modified 

Organisms (GMOs) are prohibited in organic production and handling and don’t 

contaminate organic agricultural products. The NOSB ad hoc GMO committee will 

examine all the areas where GMO contamination poses a threat to organics and will 

provide leadership in clarifying what excluded methods actually are, and how 

compliance to the provisions of the rule can be monitored. 

• Vote on revised Sense of the Board letter. 

• Brief discussion of content of committee’s presentation at the spring NOSB meeting 

• Schedule another call to continue to discuss #4. 

Discussion: 

• Minutes from March 21- Approved 

• Vote on Mission Statement: 

“The National Organic Standards Board accepts responsibility for making 

recommendations that pertain to "excluded methods" to ensure that GMOs are 

prohibited in organic production and handling and don’t contaminate organic agricultural 

products. The NOSB ad hoc GMO committee will examine all the areas where GMO 

contamination poses a threat to organics and will provide leadership in clarifying what 

excluded methods actually are, and how compliance to the provisions of the rule can be 
 

 

 

 

 

 

 

 

 

 

 

 

 

monitored.” Motion to approve statement: CoB, seconded by JFe. Yes: 5 No: 0 

Abstain: 0 Absent: 2 Recuse: 0 

• Revised “Sense of the Board letter” 

Chair made some edits to document, and opened floor for discussion. Committee did 

some editing with regard to introductory sentence, closing sentence, the uniform use of 

the terms GMO vs GE, etc. “Equal burden” is bothersome terminology and some 

members would like to alter it. Perhaps “share the burden” is better? CoB made motion 

to accept this letter as a recommendation to be sent to Secretary Vilsak. Seconded by 

MS. Yes: 6 No: 0 Abstain: 0 Absent: 1 Recuse: 0 ZS will rename letter-“Proposed 

NOSB letter to Secretary Vilsack regarding GMOs” and send via email to NOP office. 

MA will add return address, and NOP will forward letter to Secretary. 

• Presentation Content at the spring NOSB meeting 

What should be in presentation? Perhaps inputs from GMO material. Committee should 

look at Organic Materials Review Institute OMRI decision tree to use for information. ZS 

may use some of the questions from the decision tree during presentation. 

A member stressed that each of the standing committees should be updating and 

coordinating with each other, to eliminate redundancy at the Spring meeting. 

Organic dairy with GMOs is something the group agreed it would like to take up in future. 

Future Calls: 

April 11 (2:00pm EDT): Continue discussion about NOSB Spring meeting presentation. 

May 2 (2:00pm EDT 

Milestone Deadline 

Public Comment Period April 9 - May 3, 2012 

Spring 2012 NOSB Meeting May 21 – 24, 2012 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Note: Committee notes may include preliminary discussions regarding substances considered 

for addition to or removal from the National List. They do not represent official National Organic 

Program (NOP) policy or regulations. Please see the NOP website for official NOP policy, 

regulations, and status of substances used in organic production and handling. 

National Organic Standards Board (NOSB)

GMO Ad-hoc Committee Meeting Notes 

Wednesday, April 25, 2012, 2:00pm ET 

Attending: Zea Sonnabend (ZS) (Chairperson), Jay Feldman (JFe), Colehour Bondera (CoB), 

Barry Flamm (BF) 

Absent: Mac Stone (MS), Mark Lipson (OSEC), Calvin Walker (CW), Joe Dickson (JD), 

Jennifer Taylor (JT), Miles McEvoy (MM) 

NOP Staff: Michelle Arsenault (MA), Mark Bradley (NOP) 

Work Plan 

Project Point Status Target Meeting 

Person 

Letter to Secretary 

Vilsack 

ZS Discussion document spring 2012 

Get feedback from 

other committees on 

framework document 

topics 

All 

committee 

members 

In progress spring 2012? 

Agenda: 

• Approve minutes from March 28, 2012 call 

• Report progress from other committees re: GMO issues to work on. 

• Presentation outline for NOSB meeting. 

• Discuss public comments 

Discussion: 

• Minutes from March 28, 2012 not yet approved. Made minor edits 

• Report progress from other committees re: GMO issues to work on. 

o Crops Committee (CC) will have heavy workload with seed purity. Topic is 

complicated 

o Policy Development Committee (PDC). PDC felt that the general public 

comments re: GMOs would fall under their purview but aren’t sure how they 

would address them. ZS felt that they would fall under the GMO ad hoc 

committee. Perhaps after spring meeting we can find guidance about joint 

committees. As for GMO ad hoc committee, the language was included 2 years 

ago. 

o Handling committee is discussing this 

o Materials Committee will discuss at next meeting 

o Livestock Committee is discussing this 

• Presentation outline for NOSB meeting. 

o 10 minute-long presentation for NOSB Spring Meeting, composed of 5 or 6 

slides. 

o 4 examples for presentation: 
 

 

 

 

 

 

 Seed purity (CC) 

 Dairy feed (LC and CACC) 

 Plant breeding (CC, MC) 

 GMO affidavit: (CACC, HC) 

o (JFe) With regard to # 3 on ZSs outline. (plant breeding?). Public views organic 

as no GMOS and JFe wants to be receptive to that. Seems public comment is 

more concerned with general GMO use so keeping it more general seems like a 

good idea. JFe feels we should make it clear that even though we are looking at 

specific issues, we are generally talking about GMO 

o ZS will change language to include general content about keeping GMOs out 

of... (UREC?) 

o Fear that the public will interpret gene contamination as something that is 

unavoidable and acceptable. Committee agreed that “acceptable and tolerable” 

will not be words used in conjunction with GMOs. Statement by NOP: GMOs are 

excluded by process 

• Public comments 

o No discussion at this point as there aren’t many comments yet. 

• CoB will lead discussion at the NOSB spring meeting about the letter to 

Secretary Vilsack. 

Future Calls: 

May 2 (2:00pm EDT) - same agenda. 

Milestone Deadline 

Public Comment Period April 9 - May 3, 2012 

Spring 2012 NOSB Meeting May 21 – 24, 2012 
 

 

 

 

 

 

 

 

 

 

 

 

 

Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling. 

National Organic Standards Board (NOSB) 

GMO ad-hoc Subcommittee Meeting Notes 

Wednesday, May 1 2012, 2:00pm ET 

Attending: Zea Sonnabend (ZS) (Chairperson), Jay Feldman (JFe), Colehour Bondera (CoB), Barry Flamm 

(BF), Joe Dickson (JD), Jennifer Taylor (JT) 

Absent: Mac Stone (MS), Calvin Walker (CW), 

NOP Staff: Michelle Arsenault (MA), Miles McEvoy (MM) 

Work Plan 

Project Point Person Status Target Meeting 

Letter; to other FACA 

boards, Secretary Vilsack 

ZS Discussion document spring 2012 

Get feedback from other 

Subcommittees on 

framework document 

topics 

All 

Subcommittee 

members 

In progress spring 2012? 

Agenda: 

• Approve minutes from March 28, 2012 

• Approve minutes from April 25, 2012 

• Report about GMO issues. 

• Presentation outline for NOSB meeting 

• Discuss comments received about our letter to the Secretary. 

• Workplan 

Discussion: 

• Minutes from March 28, 2012 approved 

• Minutes from April 25, 2012 approved 

• Report from other subcommittees about GMO issues. 

o The Livestock Subcommittee has identified several potential GMO issues: GMO vaccines, 

feed, biotech animals (currently aren’t any, but there is the eventuality that there might 

be - for example bees.), cloning could potentially be an issue. 

o CACC: JD will put together a few bullets in place of MS. 

o CC: discussed two issues - seed purity and plant breeding, which could be put forth as 

either discussion documents or proposals. Also discussed process to solicit public input. 

• Presentation outline for NOSB meeting: Ties together with workplan, but illustrates a longer, 5-

year plan. Subcommittee made minor edits and chair will create Powerpoint slides 

• Public comments received so far have not addressed the letter to the Secretary Vilsack 

specifically. 
 

 

 

 

 

 

 

 

 

 

 

• Workplan – 

o NOP would like NOSB input for OIG report regarding the analysis of GE testing on 

organic feed and forage. NOP will report back to NOSB about the plan, perhaps at 

Albuquerque meeting. Chair asked if this item should be on the Subcommittee workplan 

and what the deadline was. NOP indicated that the target date would be the fall 

meeting. 

o A member asked whether this should be a joint recommendation from GMO, LC, and 

CACC. GMO ad hoc Subcommittee should be the umbrella Subcommittee and serve as 

POC. 

o JT suggested the Subcommittee review the public comments about GMOs and compile 

them into a discussion document and add it as a place holder on workplan. NOP asked 

for clarification about this discussion document and its purpose. Public comments so far 

have been general, but a discussion document would be a way to clarify the complex 

nature of the terminology of “excluded methods” and “GMO”. Chair offered to flesh 

out idea a bit more. 

Future Calls: 

Will reevaluate time and date to eliminate scheduling conflicts. 

ZS will speak with JT, and MA will poll members based on JT’s availability 

Milestone Deadline 

Public Comment Period April 9 - May 3, 2012 

Spring 2012 NOSB Meeting May 21 – 24, 2012 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling. 

National Organic Standards Board (NOSB) 

GMO ad-hoc Subcommittee Meeting Notes 

Thursday, June 14 2012, 2:00pm ET 

Attending: Zea Sonnabend (ZS) (Chairperson), Jay Feldman (JFe), Colehour Bondera (CoB) 

Absent: Joe Dickson (JD), Jennifer Taylor (JT), Mac Stone (MS), Calvin Walker (CW) 

NOP Staff: Michelle Arsenault (MA), Melissa Bailey (MB) 

OSEC Staff: Mark Lipson (ML) 

Work Plan 

Project Point Person Status Notes Target Meeting 

Seed Purity Discussion doc Joint w/Crops fall 2012 

Residue Testing (GM 

materials) 

Discussion doc Joint w/CACS? fall 2012? 

Plant Breeding Discussion doc Joint w/Crops fall 2012 

Agenda: 

• Approve minutes from May 1, 2012 

• Review workplan and discuss working on some topics with other committees 

• Select a vice-chair 

Discussion: 

• Approval of minutes from May 1, 2012 deferred due to lack of quorum 

• Workplan discussion 

o Seed purity - Chair would like to flesh out draft “Discussion Document” and discuss it in 

more depth on next call (July 12th). [Chair’s??] Goal is to narrow the number of questions. 

Comments from members included a possible need for the document to address critical 

differences between NOP policy and what’s happening in marketplace. For example, with 

regard to question # 4; would a seed purity standard increase, decrease, or have no impact 

on the impact of testing on farmers? If anonymity can be preserved, perhaps more seed 

companies would contribute information. A member inquired whether or not there was a 

government entity that could help with this. ML indicated that there is a well-established 

protocol for USDA’s Economic Research Service (ERS) to collect proprietary data, so that 

part of the problem can be solved. However, funding for this would probably be an obstacle. 

Chair asked if it was possible to get these data by the deadline for the fall 2012 meeting 

(August 20). ML indicated that this process could take a year, due to work plan lead-times. 

Subcommittee asked if the Organic Seed Alliance (OSA) could send out the questions, and 

ensure anonymity and collect the data, then forward it to NOSB. MB raised the issue that 

data collection on behalf of the NOSB could be considered a survey and could be subject to 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

OMB information collection requirements – this is referenced in the NOSB PPM. MB will 

check into this further prior to next call. 

o CBo asked who within the organic community could frame this to come up with answers. 

Feels this is outside NOSB’s scope. AC21 was told they should frame their questions about 

seed purity for the new National Germplasm Resources Advisory Council (NGRAC). ZS in in 

discussions with AC21 rep about collaborating, and will coordinate with NGRAC as well. 

A member suggested rewording Q # 6 for next meeting: Should a seed purity standard apply 

to both organic and non-organic seed? 

o CBo asked for clarification about question # 8: “What testing methods are appropriate to 

use in order to determine and label for seed purity and to verify compliance to a seed purity 

standard?” He suggested that this question seemed to get at the establishment of 

tolerances but that leads to many more questions such as who would set these tolerances 

and define them, and how does this relate to labeling. The chair indicated that this 

discussion doc was just a way to get the conversation started. The goal is to post it for 

comment for the fall 2012 meeting. Subcommittee feels that the organic community is very 

interested in this issue. JFe indicated that we might think about tolerance levels and ask the 

community about this up front before diving into this topic too deeply. 

o ZS has been working with AC 21, and would like to engage OMRI and OSA as well. JFe 

cautioned the use of outside groups prior to publishing, and that keeping questions general 

would be wise. Crops is working on this jointly with GMO. Will be collaborating over next 

few calls to get this done by fall 2012 deadline (August 20). 

CBo added that the process of testing needs clarification, and he would like to see a 

reference in the questions to how different sized seed companies and producers might be 

impacted. Chair asked that CBo work on language to that affect. 

o Periodic Residue Testing: Chair asked about status of Final Rule on Periodic Residue Testing. 

MB indicated that publication of Final Guidance is approaching and she will provide an 

update by July 12. 

o Plant breeding discussion doc: Subcommittee asked NOP status of plant breeding issues 

they are working on. MB indicated that NOP is working on issue of cell fusion, and was going 

to submit a memo to NOSB for targeted input, but NOP is now considering issuing 

information directly to certifiers. MB will inform the subcommittee if assistance from them 

on this topic becomes necessary. 

OMRI decision tree policy – Ad hoc committee needs to address the question, “how far back 

in food chain do we look (for source of unintended GMO presence)?” OMRI has done work 

on this topic, and subcommittee could use this to inform process. Would like to see if other 

groups such as Soil Association have similar docs. MB will follow up and report back to 

Subcommittee. 

o MB asked how GMO ad hoc subcommittee was coordinating with Livestock subcommittee 

on GMO vaccines. Chair noted that there are several reps from LS on the GMO ad hoc (JD, 

CW and CBo). CBo will discuss with others about how best to strategize. MB will coordinate 
 

 

 

 

with Scott Updike (LS) to keep flow of communication between both subcommittees up to 

date. 

• Select a vice-chair – CBo volunteered to serve as Vice Chair if no one else comes forward. No 

committee vote is necessary. 

Upcoming meetings and agenda items: 

2nd and 4th Thursdays at 2pm Eastern, 11am Pacific: 

Note: no call June 28, 2012 

July 12, 2012. Feedback from subcommittee on seed purity draft and NOP Update. 

July 26, 2012 

Aug 9, 2012 

Aug. 23, 2012 

Sept 13, 2012 

Sept 27, 2012 

Milestone Deadline 

NOP - “Finalize” tentative agenda August 13, 2012 

Fall 2012 proposals due to NOP August 20, 2012 

NOP - Post proposals, Publish FRN, Open public comment August 27, 2012 

Public comment closes September 24, 2012 

NOP - Send compiled public comments to NOSB October 1, 2012 

Fall 2012 NOSB Meeting – Providence, RI October 15-18, 2012 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling. 

National Organic Standards Board (NOSB) 

GMO ad-hoc Subcommittee Meeting Notes 

Thursday, July 12 2012, 2:00pm ET 

Attending: Zea Sonnabend (ZS) (Chairperson), Colehour Bondera (CoB), Jennifer Taylor (JT), Calvin 

Walker (CW), Joe Dickson (JD) 

Absent: Mac Stone (MS), Jay Feldman (JFe) 

NOP Staff: Michelle Arsenault (MA), Melissa Bailey (MB) 

OSEC Staff: Mark Lipson (ML) 

Work Plan 

Project Point Person Status Notes Target Meeting 

Seed Purity ZS Discussion doc Joint w/Crops fall 2012 

Residue Testing (GM 

materials) 

Discussion doc Joint w/CACS? fall 2012? 

Plant Breeding ZS Discussion doc Joint w/Crops fall 2012 

Agenda: 

• Approve minutes from May 1 and June 14 

• Reports from other committees on GMO issues discussed (such as GMO vaccines for livestock, seed 

purity for crops....) 

• Seed Purity Discussion Doc - Please see Mark Lipson's revisions (attached) and summary (below) and 

we can discuss the points he raises. 

• Begin discussion of how to proceed with Decision Tree and other evaluation method comparison 

towards tracing GMO back in the input/ingredient chain. Refer to OMRI decision tree sent last time 

(June 14) and Melissa Bailey's recent email on international standards. 

Discussion: 

• Minutes from May 1 and June 14 approved with no changes 

• Reports from other committees on GMO issues 

o Crops-no update as JFe was not present. 

o Livestock - CW. MB indicated that she is in the process of creating a GM-vaccines working 

group (WG), which will include APHIS, as well as two NOSB members (NM and JR). The WG 

will hold a teleconference this month. The intention is to have an update at fall NOSB 

meeting 

o JT (Materials) – Interested in working with GMO ad hoc to consider excluded methods. JT 

will write an initial draft for the group to look at. MB stated that this is not currently on the 

workplan and NOP would need additional details. 

o CACS – Waiting for NOP guidance on the workplan item for residue testing - may not be on 

fall agenda, likely pushed to 2013. 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

• Seed Purity Discussion Doc 

o The group discussed suggestions from ML. ML explained his suggestion for reframing the 

discussion document in the context of compliance with NOP rules (i.e. excluded methods) 

rather than in the context of consumer expectations that the organic label is equivalent to a 

“GMO-free” claim. A member agreed that the comments by ML were appropriate, and 

would also like to see the language simplified and clarified. ZS will look at doc again, and 

discuss conceptually how the group might move forward. MB noted that the doc would be 

much more accessible if each issue was tied directly to pertinent sections of the USDA 

organic regulations. Currently, some of the discussion in the document involves an implied 

level of background knowledge. ZS would like to work with ML as she edits this doc to try to 

unify the two ideas. ZS’ thought is to put forth both contexts (NOP regs and consumer 

expectations) as drivers for the discussion. . CBo indicated that he would like to see an 

outline or short description to give more clarity about how a different approach would 

work. He noted concern that if the group takes a different approach they may run out of 

time to have this ready for the fall meeting. The chair noted that there is a new FACA 

committee (Genetic resources) and thought it would be useful for the GMO ad hoc to 

interface with them. MB sent doc with guidance about what the NOSB could or couldn’t ask 

for when attempting to collect info on testing seeds: cannot be official survey without going 

through OMB process. Question # 2 was discussed and MB will revise language and send it 

back to group. The GMO ad hoc will prepare doc and present it to the Crops Subcommittee 

before it is finalized. At fall meeting, GMO will take lead in presenting the discussion 

document. 

• Decision Tree and other evaluation method comparisons towards tracing GMO back in the 

input/ingredient chain. 

o Issues –composting, plant breeding chain, etc. ZS is collecting info to begin what will be a 

long term process. MB provided the group with an international perspective although she 

indicated she could not find actual decision trees. MB will look for information from other 

entities such as KRAV (Sweden) and BioGro and forward it to the group. ZS will continue to 

work on this for now, but would like someone to take over. Feels that this is a long term 

project. OMRI indicated that there are many items in their decision tree doc that needs to 

be updated. 

• Group requested an update from NOP on plant breeding. MB does not have any request for the 

GMO ad hoc to work on this issue at this time – will inform the GMO ad hoc if this changes. 

Upcoming meetings and agenda items: 

2nd and 4th Thursdays at 2:00pm Eastern, 11am Pacific: 

July 26, 2012 

Aug 9, 2012 

Aug. 23, 2012 

Sept 13, 2012 

Sept 27, 2012 
Milestone Deadline 

NOP - “Finalize” tentative agenda August 13, 2012 

Fall 2012 proposals due to NOP August 20, 2012 

NOP - Post proposals, Publish FRN, Open public comment August 27, 2012 

Public comment closes September 24, 2012 

NOP - Send compiled public comments to NOSB October 1, 2012 

Fall 2012 NOSB Meeting – Providence, RI October 15-18, 2012 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling. 

National Organic Standards Board (NOSB) 

GMO ad-hoc Subcommittee Meeting Notes 

Thursday, July 26 2012, 2:00pm EDT 

Attending: Zea Sonnabend (ZS) (Chairperson), Colehour Bondera (CoB), Calvin Walker (CW), Joe Dickson 

(JD), Mac Stone (MS), Jay Feldman (JFe), Jennifer Taylor (JT) 

Absent: 

NOP Staff: Michelle Arsenault (MA), Melissa Bailey (MB) 

OSEC Staff: Mark Lipson (ML) 

Work Plan 

Project Point Status Notes Vote Target Meeting 

Person 

Seed Purity ZS Discussion doc Joint w/Crops Fall 2012 

Residue Testing 

(GM materials) 

Discussion doc Joint w/CACS? Fall 2012? 

Plant Breeding ZS Discussion doc Joint w/Crops Fall 2012 

Agenda: 

• Approve minutes from July 12 

• Draft 2 of the Seed Purity Discussion Document 

• Future workplan item: GM prevention strategies. 

Discussion: 

• Minutes from July 12 approved with no changes. 

• Chair asked that MS, JD and CW (from Livestock Subcommittee) provide an update on GMO Vaccine 

Task Force at next GMO ad hoc meeting (August 9), and also asked that the Crops Subcommittee 

review the Seed Purity Discussion Doc. 

• Seed Purity Discussion Document: Group edited some language in document and suggested adding 

a glossary. ZS will incorporate changes and circulate the edited version (draft 3) to the members. 

Also asked group to reread the document and think about what terms would be useful in the 

glossary. 

• Future workplan item: GM prevention strategies. Chair circulated doc to group about prevention 

strategies, which she feels is key to a process based system. The group discussed whether or not this 

document could be expanded to include handling, and chair asked if this was something the GMO 

ad hoc Subcommittee would like to include on a future workplan. NOP asked how the program 

would incorporate and use the information, to which ZS responded that it would not be sent forth 

for rulemaking, but would be intended as guidance. 
 

Upcoming meetings and agenda items: 

2nd and 4th Thursdays at 2:00pm Eastern, 11am Pacific: 

Aug 9, 2012 

Aug. 23, 2012 

Sept 13, 2012 

Sept 27, 2012 

Milestone Deadline 

NOP - “Finalize” tentative agenda August 10, 2012 

Fall 2012 proposals due to NOP August 20, 2012 

NOP - Post proposals, Publish FRN, Open public comment August 27, 2012 

Public comment closes September 24, 2012 

NOP - Send compiled public comments to NOSB October 1, 2012 

Fall 2012 NOSB Meeting – Providence, RI October 15-18, 2012 
 

 

 

 

 

 

 

 

 

 

 

 

 

Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling. 

National Organic Standards Board (NOSB) 

GMO ad-hoc Subcommittee Meeting Notes 

Thursday, August 9 2012, 2:00pm EDT 

Attending: Zea Sonnabend (ZS) (Chairperson), Colehour Bondera (CoB), Calvin Walker (CW), Mac Stone 

(MS), Jay Feldman (JFe), Jennifer Taylor (JT) 

Absent: Joe Dickson (JD) 

NOP Staff: Michelle Arsenault (MA), Melissa Bailey (MB) 

OSEC Staff: Mark Lipson (ML) 

Work Plan 

Project Point Status Notes Vote Target Meeting 

Person 

Seed Purity ZS Discussion doc Joint w/Crops Fall 2012 

Residue Testing 

(GM materials) 

Discussion doc Joint w/CACS? Spring 2013 

Plant Breeding ZS Discussion doc Joint w/Crops Spring 2013 

Agenda: 

• Approve minutes from July 26 

• Draft 3 of the Seed Purity Discussion Document 

• Report on the GMO Vaccine Task Force (CBo or CW) 

Discussion: 

• The minutes from the July 26th meeting were not approved as yet. 

• The Group discussed edits to the current draft of the seed purity discussion document. The chair 

will make the changes and recirculate the document ahead of the next call. 

Upcoming meetings and agenda items: 

2nd and 4th Thursdays at 2:00pm Eastern, 11am Pacific: 

Aug. 23, 2012 

Sept 13, 2012 

Sept 27, 2012 
Milestone Deadline 

NOP - “Finalize” tentative agenda August 10, 2012 

Fall 2012 proposals due to NOP August 20, 2012 

NOP - Post proposals, Publish FRN, Open public comment August 27, 2012 

Public comment closes September 24, 2012 

NOP - Send compiled public comments to NOSB October 1, 2012 

Fall 2012 NOSB Meeting – Providence, RI October 15-18, 2012 
 

 

 

 

 

 

 

 

Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling. 

National Organic Standards Board (NOSB) 

GMO ad-hoc Subcommittee Meeting Notes 

Thursday, August 17 2012, 2:00pm EDT 

Attending: Zea Sonnabend (ZS) (Chairperson), Colehour Bondera (CoB), Calvin Walker (CW), Jay Feldman 

(JFe), Jennifer Taylor (JT), Mac Stone (MS) 

Absent: Joe Dickson (JD) 

NOP Staff: Michelle Arsenault (MA), Melissa Bailey (MB) 

Work Plan 

Project Point Status Notes Vote Target Meeting 

Person 

Seed Purity ZS Discussion doc Joint w/Crops 08 17 12 Fall 2012 

Residue Testing 

(GM materials) 

Discussion doc Joint w/CACS? Spring 2013 

Plant Breeding ZS Discussion doc Joint w/Crops Spring 2013 

Agenda: 

• Approve minutes from July 26 

Discussion: 

• The minutes from July 26 were not discussed at this meeting. 

• The GMO ad hoc group made minor edits to the format of the seed purity document prior to 

voting. 

VOTE: Seed Purity discussion document. 

Motion to adopt the seed purity discussion document 

Motion by: ZS 

Seconded by: CW 

Yes: 6 No: 0 Absent: 1 Abstain: Recuse: 0 

Upcoming meetings and agenda items: 

2nd and 4th Thursdays at 2:00pm Eastern, 11am Pacific: 

Aug. 23, 2012. Cancelled 

Sept 13, 2012. Future work plan items 

Sept 27, 2012 
Milestone Deadline 

NOP - “Finalize” tentative agenda August 10, 2012 

Fall 2012 proposals due to NOP August 20, 2012 

NOP - Post proposals, Publish FRN, Open public comment August 27, 2012 

Public comment closes September 24, 2012 

NOP - Send compiled public comments to NOSB October 1, 2012 

Fall 2012 NOSB Meeting – Providence, RI October 15-18, 2012 
 

 

 

 

 

 

 

 

 

 

 

Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling. 

National Organic Standards Board (NOSB) 

GMO ad-hoc Subcommittee Meeting Notes 

Thursday, September 13 2012, 2:00pm EDT 

Attending: Zea Sonnabend (ZS) (Chairperson), Colehour Bondera (CoB), Calvin Walker (CW), Jay Feldman 

(JFe), Jennifer Taylor (JT), Mac Stone (MS), 

Absent: Joe Dickson (JD) 

NOP Staff: Michelle Arsenault (MA), Melissa Bailey (MB) 

Work Plan 

Project Point Status Notes Vote Target Meeting 

Person 

Seed Purity ZS Proposal Joint w/Crops 08 17 12 Spring 2013 

Residue Testing Discussion doc Joint w/CACS? Fall 2013? 

(GM materials) 

Plant Breeding ZS Discussion doc Joint w/Crops Spring 2013 

Prevention JFe, TBD 

Strategy CBo 

Guidance for 

Excluded 

Methods in Crops 

and Handling 

Tracing GMOs in Discussion doc Fall 2013 

Input/Ingredient 

Chain 

Agenda: 

• Approve minutes for July 26, August 9 and August 17, 2012 

• Discuss Workplan for spring 2013 and beyond 

Potential Workplan Items: 

o Turn the Seed Purity discussion document into a Proposal 

o Plant Breeding: Clarifying definitions and practices that are considered a part of 

excluded methods as opposed to those that are not excluded. (Joint with crops but 

GMO ad hoc will take lead) 

o Residue testing for GM materials (GMO ad hoc input to NOP). (Joint with CACS, who will 

lead) 

o Prevention Strategy Guidance for excluded methods in crops and handling. (mentioned 

on call of 7/26) 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

o Tracing GMOs in Input/Ingredient chain with decision trees or other evaluation 

methods. Work of collecting examples from Material Review Organizations (MROs) and 

other countries has started, but further work could be done. 

o Considering excluded methods in context of sustainability. JT suggested this item and 

was going to write a first draft for the GMO subcommittee or the Materials 

subcommittee. 

o Interface with GMO Vaccine Task Force as necessary. 

o Start discussion of comments received on Seed Purity if there are some. 

Discussion: 

• Minutes from July 26, August 9 and August 17, 2012 approved with no changes. 

• Discuss Workplan for Spring 2013 and beyond 

Potential Workplan Items: 

o The group discussed the Seed Purity discussion document and decided to place it on the 

workplan as a proposal for spring 2013. Changes noted in table above. 

o Plant Breeding: Clarifying definitions and practices that are considered a part of 

Excluded methods and those that are not excluded. (Joint with Crops but GMO ad hoc 

will take lead). ZS asked if NOP’s cell fusion memo will be out in time inclusion in this 

document. MB indicated that the memo is in clearance and should be published in 

later this year. MB asked that there be more elucidation of the definitions. Item was 

added for spring 2013 - Changes noted in table above. 

o Residue testing for GM materials (GMO ad hoc input to NOP). (Joint with CACS, who will 

lead). MB indicated that NOP was working on an audit response, and that this item 

may not need to be on the spring workplan. Changes noted in table above. 

o Prevention strategy guidance for excluded methods in crops and handling. (Mentioned 

on July 26 call). A question was asked as to whether or not this seem like an item that 

can be folded into “other” ingredients, or if it should be an individual item. CBo 

suggested keeping it as a separate item. MB asked that the group expound on this by 

putting together bullet points so NOP knows what the intention is. Changes reflected in 

table above. 

o Tracing GMOs in Input/Ingredient Chain with decision trees or other evaluation 

methods. Work of collecting examples from MROs and other countries has started, but 

further work could be done. This is a key question, and the goal is to inform the other 

Subcommittees when they are doing material reviews. The group also feels that this 

could be incorporated into NOP policy memo. This could be a discussion document for 

fall 2013 

o Considering excluded methods in context of sustainability. JT suggested this item and is 

going to write a first draft for the GMO Subcommittee or the Materials Subcommittee. 

JT was not available to discuss this issue so group will ask her offline and have an 

update on Executive Subcommittee call. 

o Interface with GMO Vaccine working group as necessary. Not a workplan item, but 

group would like to keep it at the forefront. 

o Start discussion of public comments about Seed Purity, when those are received. 
 

 

Upcoming meetings and agenda items: 

2nd and 4th Thursdays at 2:00pm Eastern, 11am Pacific: 

Sept 13, 2012. Future work plan items 

Sept 27, 2012 

October 11, 2012 place holder 

Milestone Deadline 

NOP - “Finalize” tentative agenda August 10, 2012 

Fall 2012 proposals due to NOP August 20, 2012 

NOP - Post proposals, Publish FRN, Open public comment August 27, 2012 

Public comment closes September 24, 2012 

NOP - Send compiled public comments to NOSB October 1, 2012 

Fall 2012 NOSB Meeting – Providence, RI October 15-18, 2012 
 

 

 

 

 

 

Note: Subcommittee notes may include preliminary discussions regarding substances considered for 

addition to or removal from the National List. They do not represent official National Organic Program 

(NOP) policy or regulations. Please see the NOP website for official NOP policy, regulations, and status of 

substances used in organic production and handling. 

National Organic Standards Board (NOSB) 

GMO ad-hoc Subcommittee Meeting Notes 

Thursday, September 27 2012, 2:00pm EDT 

Attending: Zea Sonnabend (ZS) (Chairperson), Colehour Bondera (CoB), Mac Stone (MS), Joe Dickson 

(JD) 

Absent: Jay Feldman (JFe), Calvin Walker (CW), Jennifer Taylor (JT) 

NOP Staff: Michelle Arsenault (MA), Melissa Bailey (MB), Mark Lipson (ML) (USDA-OSEC) 

Work Plan 

Project Point Status Notes Vote Target Meeting 

Person 

Seed Purity ZS Proposal Joint w/Crops 08 17 12 Spring 2013 

Residue Testing 

(GM materials) 

NOP feels 

there are no 

issues for the 

GMO ad hoc to 

work on at this 

time 

Plant Breeding ZS Discussion doc Joint w/Crops Spring 2013 

Prevention 

Strategy 

Guidance for 

Excluded 

Methods in Crops 

and Handling 

JFe, 

CBo 

Beyond 2013 

Tracing GMOs in 

Input/Ingredient 

Chain 

Discussion doc Fall 2013 

Agenda: 

• Approve notes from last call (September 13) 

• Discuss comments received on Seed Purity 

• Set call if necessary 

Discussion: 

• Notes from last call September 13 approved with no changes 
 

• Group discussed briefly the public comments about the Seed Purity discussion document. In 

general, there was a divergence in opinion among the letters they received. 

Upcoming meetings and agenda items: 

2nd and 4th Thursdays at 2:00pm Eastern, 11am Pacific: 

Sept 13, 2012. Future work plan items 

Sept 27, 2012 

October 11, 2012 

Milestone Deadline 

NOP - “Finalize” tentative agenda August 10, 2012 

Fall 2012 proposals due to NOP August 20, 2012 

NOP - Post proposals, Publish FRN, Open public comment August 27, 2012 

Public comment closes September 24, 2012 

NOP - Send compiled public comments to NOSB October 1, 2012 

Fall 2012 NOSB Meeting – Providence, RI October 15-18, 2012