This is a work product of the National Organic Standards Board (NOSB). It does not represent official 

National Organic Program (NOP) positions or policy.

National Organic Standards Board

Policy Development Subcommittee

Proposal

Public Communications 

January 22, 2013

I. Introduction

The National Organic Standards Board (NOSB) recognizes that members have been 

specifically appointed to NOSB to provide advice and counsel to the Secretary

concerning policies related to the development of organic standards and the creation 

and amendments to the National List (NOSB Policy and Procedures Manual, pg. 9). A 

part of the NOSB’s responsibility is to communicate with the organic community 

pertaining to the implementation of Organic Foods Production Act (OFPA); the NOSB

must receive and review information from USDA’s National Organic Program (NOP) and 

other sources during its deliberations. The input from the organic community is valuable 

in the deliberations of NOSB, the NOP, and the community decision-making process. 

NOSB recommends that the NOP establish a year-around online communication 

mechanism(s) for stakeholders to communicate with NOSB and the NOP on matters of 

interest and concern.

II. Background

The Federal Advisory Committee Act (FACA) regulations on “Meeting Obligations to the 

Public” (41 CFR 102-3.140) states that, “Any member of the public is permitted to file a 

written statement with the advisory committee during meetings.” A written statement 

received during the comment period for scheduled NOSB meetings has been the 

primary method by which the public communicates with the Board.

Nevertheless, NOSB members also receive public communications outside of the 

designated public comment period. These communications include verbal and written 

information. In response to a previous public communications proposal, the NOSB 

received public comments that overwhelmingly supported the establishment of a 

mechanism that would provide for a central location for all public communications to the 

NOSB and NOP, enable transparency in public communications, and provide access to 

information from the organic community.

III. Discussion

The NOSB through its Policy and Procedures Manual establishes procedures for its 

activities. The manual “is designed to assist NOSB in its responsibilities” (PPM, p4) and 

establish procedures for carrying out its responsibilities in accordance with its advisory 

mission.

As a part of its responsibility to communicate with the organic community pertaining to 

the implementation of OFPA, the Board must receive and review information from the 
NOP and other sources during its deliberations. As a stakeholder Board, the input from 

the organic community is valuable in the deliberations of the Board, the NOP, and the 

community decision-making process. The procedures of the Board and NOP should 

facilitate public communication to inform these deliberations. 

Providing an online mechanism that allows the public to share information between 

official comment periods will help to facilitate public communication that informs the 

Board’s and NOP’s deliberations in several ways. The online system is intended to:

1. Inform discussions early in the materials or policy review process through the 

collection of complete background and perspectives; 

2. Reduce the amount of new information coming to the Board and NOP late in its 

deliberations on an issue without adequate time to verify or fully assess it;

3. Increase transparency for the NOSB, NOP, and the public itself to ensure that 

everyone has access to the same information in a timely fashion; 

4. Help the Board and NOP to become aware of issues that may not be on the work 

plan or may not have been generated internal to the NOP and NOSB process, but 

are important based on the experience and expertise of those in the organic 

community.

Thus, an online public communication mechanism can help board members to 

discharge their “Duty of Care,” which “calls upon a member to participate in the 

decisions of the Board and to be informed as to the data relevant to such decisions.”

(PPM, p. 6)

IV. Recommendation

1. The NOSB proposes amending PPM Section VI, Miscellaneous Policies (page 

27) to add a new subcategory (in italics).

Policy for Public Communication between NOSB Meetings.

The NOSB and NOP seek public communication outside of Board biannual meetings 

and public comment periods to inform the NOSB and NOP of stakeholders’ interests, 

and to comment on the NOSB’s and NOP’s work activities year around.

PPM Section II (page 13) adds a phrase to the Role of an Advisory Board Specialist to 

include the following language (in italics): 

With support from NOP, identify, implement, administer and maintain a year-round 

public communication mechanism (Internet and other means) by which public feedback 

can be received, posted, and archived online for viewing by the NOSB, the NOP, and 

the public. 

V. Committee Vote

Moved: Jay Feldman Second: Jennifer Taylor

Yes: 6 No: 0 Abstain: 0 Absent: 2 Recuse: 0