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 UNITED STATES DEPARTMENT OF AGRICULTURE

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 NATIONAL ORGANIC STANDARDS BOARD

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 FALL 2018 PUBLIC COMMENT WEBINAR

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 TUESDAY,

OCTOBER 16, 2018

 The webinar was held via telephone at

1:00 p.m., Tom Chapman, NOSB Chair, presiding. 

BOARD MEMBERS PRESENT 

TOM CHAPMAN, Chair

HARRIET BEHAR, Vice Chair

SCOTT RICE, Secretary

JESSE BUIE 

SUE BAIRD 

ASA BRADMAN 

A-DAE ROMERO-BRIONES 

LISA DE LIMA 

STEVE ELA 

JAMES "RICK" GREENWOOD 

DAVE MORTENSEN 

EMILY OAKLEY 

DAN SEITZ 

ASHLEY SWAFFAR 

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STAFF PRESENT 

DR. PAUL LEWIS, Ph.D., Director, Standards

 Division, National Organic Program 

MICHELLE ARSENAULT, Advisory Board Specialist, 

National Organic Program 

DEVON PATTILLO, Materials Specialist, Standards 

Division, National Organic Program 

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P-R-O-C-E-E-D-I-N-G-S 

1:00 p.m. 

 MS. ARSENAULT: Hi, everyone, welcome. 

This is Michelle from NOP. My clock says 1:00 

straight up, so I think we'll get started. 

We're going to -- a little bit of 

housekeeping at first. If you are on the line 

with us, you should see an instruction slide. 

Hopefully, everyone can see that. It says 

welcome, and it talks a little bit about 

ReadyTalk and how do dial in on the phone versus 

using your headset. 

If you're on your headset, just make 

sure your mic is muted. We -- it's -- the reason 

we get feedback on the line is when you're --

your mic is live and your speakers are on and you 

can tell that I'm not technologically savvy 

enough to explain that to you guys. If we get 

feedback, we'll make an announcement and have 

everyone check their lines there. 

So noise is our biggest challenge. 

It's much easier if we can have you guys selfNeal R. Gross and Co., Inc. 

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mute than if we have to mute and unmute the whole 

group. So we'll ask that you do self-mute 

yourself on the phone. 

If you have -- you're on a phone that 

doesn't have a mute button, you can hit star-6 to 

mute yourself and star-7 to unmute. 

All right, so as a participant on the 

call, you should be able to -- you have some 

limited functionality. You should see a chat box 

and a raise your hand box. 

We're asking people not to raise their 

hand. If you are signed up to speak, then you'll 

be called on when it's your turn, and we won't be 

responding to any raised hands that aren't board 

members. 

So Tom is going to run through some 

logistics with regard to the timer, but we are 

using a timer to limit people's comments to three 

minutes, and we'll demonstrate that for you in a 

little bit so everyone can hear what it sounds 

like on the phone. 

And if you're having any technical 

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problems, ReadyTalk has a really good customer 

service line. If you go to readytalk.com, you'll 

see a phone number, you can call them, and 

they're usually really quick about getting you 

fixed up. 

All right, I'm going to turn it over 

to Paul Lewis now to actually officially open the 

October 2018 NOSB meeting public comment webinar. 

DIRECTOR LEWIS: Thank you, Michelle, 

and good afternoon. I am Paul Lewis, Director of 

Standards Division of the National Organic 

Program. 

I want to welcome NOSB members and the 

public to today's National Organic Standards 

Board Public Comment Webinar, and I appreciate 

the NOSB members' participation in this call and 

for all your work serving on the Board. 

This webinar provides the opportunity 

for the public to provide comments to the Board 

as part of the upcoming face-to-face public 

meeting scheduled for October 24th through 26th 

in St. Paul, Minnesota. Please consult the NOP 

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website for further information about the faceto-face meeting. 

The meeting that we're having today, 

just like the meeting we'll be having later on 

this week is another public comment webinar, and 

the meeting next week in St. Paul all operate 

under the provisions of the Federal Advisory 

Committee Act. 

And I am looking forward to hearing 

comments from the public today and Thursday and 

at our meeting next week to assist the Board in 

preparing their recommendations to USDA in 

response to National Organic Standards Board 

board agenda items. 

I also want to personally thank my 

colleagues here in the NOP Standards Division for 

their help behind the scenes to bring you today's 

teleconference. 

I'd like to close now by turning to 

Chair, Mr. Tom Chapman, Chair of the NOSB. Tom, 

thank you for leading this webinar today. 

CHAIRPERSON CHAPMAN: Thank you, Paul, 

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and thanks to the NOP staff, particularly 

Michelle and Deb, for helping accommodate this 

webinar. 

On behalf of the Board, I'd like to 

welcome everyone to the public comment webinar 

prior to our fall meeting. Public comment is a 

vital part of the NOSB process, and I appreciate 

all folks who have spent their time getting us 

their thoughts. 

Michelle, if you'd be so kind to take 

roll of the -- a roll call of the Board members 

present? 

MS. ARSENAULT: Thanks, Tom. 

Tom Chapman? 

CHAIRPERSON CHAPMAN: Present. 

MS. ARSENAULT: Harriet Behar? 

MEMBER BEHAR: Present. 

MS. ARSENAULT: Great. Scott Rice? 

MEMBER RICE: Present. 

MS. ARSENAULT: Thank you, sir. Jesse 

Buie? 

MEMBER BUIE: Present. 

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 MS. ARSENAULT: Thanks, Jesse. 

Sue Baird? Sue, if you're talking, 

you're on mute. I see you on the line. 

MEMBER BAIRD: Present. 

MS. ARSENAULT: Okay, thanks, got it, 

thank you. Asa Bradman? 

MEMBER BRADMAN: Present, I may leave 

about two minutes early to go to a class. 

MS. ARSENAULT: Thanks, Asa. 

Lisa de Lima? 

MEMBER DE LIMA: Here. 

MS. ARSENAULT: Hi, Lisa, thank you. 

Steve Ela? 

MEMBER ELA: Present. 

MS. ARSENAULT: Great. I'm going to 

interrupt myself here and ask that if you are not 

speaking to please mute yourself, we're getting 

some beeping noises. 

Dave Mortensen? 

MEMBER MORTENSEN: Present. 

MS. ARSENAULT: Hi, Dave. 

Emily Oakley? 

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 MEMBER OAKLEY: Present. 

MS. ARSENAULT: Hi, Emily. 

A-dae Briones? A-dae, did you --

MEMBER ROMERO-BRIONES: Present. 

MS. ARSENAULT: Excellent, you were 

able to join. Thank you. 

Eric Schwartz? 

MEMBER SCHWARTZ: Present, Michelle. 

MS. ARSENAULT: Thank you. 

And Ashley Swaffar? 

MEMBER SWAFFAR: I'm here. 

MS. ARSENAULT: Hello there. 

And I'm just going to check, Dan 

Seitz, were you able to join? 

Okay, Dan, is going to join us a 

little bit late today. And Rick Greenwood is not 

able to be with us today, so he won't be on the 

call. So we have 13 of the 15 Board members with 

us on the call at the moment. All right. 

CHAIRPERSON CHAPMAN: Thank you, 

Michelle. 

MS. ARSENAULT: Thanks, Tom. 

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 CHAIRPERSON CHAPMAN: There are 13 of 

15, that's a quorum, and we'll look to have Dan 

join us a little bit later. So, next, I have 

some logistical items to go over and then we'll 

get into the public comment time. 

First off, like Michelle has mentioned 

already, please keep yourself on mute. If folks 

individually mute themselves, it's usually easier 

than muting across the board. We often get some 

background noise if people are using a speaker 

phone or their computer. So please keep that in 

mind as well. 

Star-6 to mute, star-7 to unmute. 

We'll start public comments in the 

order of the list that Michelle has provided for 

the commenters. If a commenter is not present at 

the time we call upon them, we'll skip them but 

come back to them at the end as time permits. 

We will call on the next speaker -- I 

will call out the name of the next speaker who is 

up as well as the next one or two names on deck. 

The program and I try to ID the 

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commenters via the phone number you've provided 

prior to make sure the speaker is present. If I 

cannot ID a phone number, you might hear me ask 

you to comment into the staff so that we can find 

your phone number. 

When called upon to speak, we ask the 

speaker to give their name and relevant 

affiliation for the record. We ask that you 

disclose all relevant affiliations pertaining to 

matters of business before the Board. If members 

of the NOSB want further clarification, I 

encourage you to ask questions after the public 

commenter has finished their comments. 

Comment time will be three minutes per 

commenter. After that three minutes, a buzzer 

will go off. 

Michelle, are you able to play an 

example of that buzzer? 

MS. ARSENAULT: Indeed, here we go. 

CHAIRPERSON CHAPMAN: There you go. 

MS. ARSENAULT: Is that okay? 

CHAIRPERSON CHAPMAN: -- the buzzer, 

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out of respect for the Board and other 

commenters, I ask that you try to finish as close 

to that three minute mark as possible or when you 

hear the buzzer. 

I will then facilitate questions at 

that point from the Board, if there's any of 

them. And then after that's completed, we'll 

move to the next commenter. 

We don't take questions from the 

public for other public commenters, only 

questions from the Board. Board members, if you 

have a question, either speak up when I ask if 

you have questions or message me via the message 

box. 

Keep public -- all public commenters 

are allotted only one time slot either in person 

or at the webinars. And there will be a 

transcript of these calls after the entire 

meeting bundled together with the meeting 

transcripts. 

Michelle, did I miss anything? 

MS. ARSENAULT: No, I think you 

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covered everything, Tom, thanks. 

CHAIRPERSON CHAPMAN: Okay. We are 

still getting a lot of feedback from folks, so, 

again, if people could self-mute, that would 

great. 

And we'll get started. So first up we 

have Amalie Lipstreu followed by Harold Austin 

and then Percy Hawkes. 

Amalie, are you on the line with us? 

MS. LIPSTREU: Yes, I am. Can you 

hear me okay? 

CHAIRPERSON CHAPMAN: Yes, we can. If 

you'd start with your name and affiliation for 

the record and then proceed with your comment? 

MS. LIPSTREU: Good afternoon, this is 

Amalie Lipstreu. I'm the Policy Coordinator for 

the Ohio Ecological Food and Farm Association. 

Thank you for the opportunity to share our input 

in an open forum. 

OEFFA has provided oral and written 

comments on energy infrastructure impacts to 

organic farms for several years. 

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To be perfectly clear, we are talking 

about prohibited substances being used during 

construction and operation of energy 

infrastructure. Many farmers and certifiers 

aren't aware of the use of prohibited substances 

and processes that can put certified organic 

production in jeopardy. 

OEFFA approaches this subject with 

abundance of caution as we hold the integrity of 

the National Organics program paramount. 

The NOSB and the NOP have the choice 

of being proactive or reactive on this issue. 

But the reality is these impacts will make 

themselves known when farms being decertified, 

noncompliance is a media story. 

Please add a study of energy system 

infrastructure on organic farms to the NOSB work 

agenda. 

Regarding the proposal on genetic 

integrity transparency of food grown on organic 

land, we appreciate the efforts of the Board to 

begin looking at levels of contamination starting 

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with organic corn seed. We heard from many 

producers that will no longer grow food grade 

organic corn due to the difficulties in 

maintaining purity of products from seed to 

delivery. An ability to maintain organic 

integrity to ensure next production and supply 

should not be a limiting factor. 

Also, with regard to testing, the 

equivalence of in-house and PCR testing is not 

certain. Many of our growers that have used nonPCR tests have had loads rejected, and companies 

that use PCR find levels of contamination that 

are higher than the on-farm testing indicated. 

The issue of GE contamination at many 

levels has been longstanding, and our farmers are 

looking for solutions. But as the proposal moves 

forward, please consider the feasibility of 

what's being asked of organic producers. 

The social, financial and 

environmental challenges, especially for organic 

grain farmers, many of whom are an island within 

a sea of conventional agriculture, are 

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considerable, and we must take great pains to 

ensure that we do not add an inordinate burden 

and responsibility on them. 

Thank you. 

CHAIRPERSON CHAPMAN: Thank you. Any 

questions from the Board? 

MEMBER BEHAR: Yes, this is Harriet. 

CHAIRPERSON CHAPMAN: Go ahead, 

Harriet. 

MEMBER BEHAR: Hi, Amalie. I'm 

wondering, so do you feel that the proposal on 

genetic integrity is implementable as written? 

MS. LIPSTREU: We feel very strongly 

that it should move forward because it has been 

such a longstanding issue. We do hope that some 

of the matters are addressed just as I have spoke 

to the equivalence of testing, some of the 

financial burden, and training for conducting 

those tests be considered as the proposal does 

move forward. 

MEMBER BEHAR: Okay, I think at the in 

person meeting, I'll be able to answer some of 

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those questions. 

MS. LIPSTREU: Great, thank you. 

MEMBER BEHAR: And then on the 

infrastructure -- Tom, can I ask another 

question? 

CHAIRPERSON CHAPMAN: Yes. 

MEMBER BEHAR: So I am just wondering, 

in the work plan, to help us figure out how this 

would work, would this also include some sort of 

testing protocol for inputs, water and the 

contaminates those might have, as well as the 

mitigation plan, which I know you've spoken 

about? Are you looking at kind of a two-pronged 

effort here? 

MS. LIPSTREU: Sure, thanks for the 

question, Harriet. And, no, I would not project 

about testing of water or anything of the like at 

this point. We really feel what would be best 

would be to start with a discussion document, 

invite a panel of experts to break down the issue 

and develop a better understanding of what the 

most burning issues are and what issues really 

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are within the scope of the Board to be able to 

address and then move forward from there. 

And I would say that this mitigation 

plan, as I've said previously, it has been 

implemented successfully with not just the 

producers we work with, but with the Federal 

Energy Regulatory Commission, as well as some of 

the pipeline companies. 

So it really is a tool that's worth 

taking a look at and considering how that might 

be used proactively. Does that answer your 

question? 

MEMBER BEHAR: Yes, thank you. 

MS. LIPSTREU: Thank you. 

CHAIRPERSON CHAPMAN: Any other 

questions? 

MEMBER RICE: -- Scott. 

CHAIRPERSON CHAPMAN: Yes, Scott. 

MEMBER RICE: Hi, Amalie, thanks for 

your comments, and we, as you know, have been 

discussing the impacts of the extraction 

activities. I just wonder, back to sort of 

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scoping what a work plan item or product would 

look like, you mentioned, you know, a discussion 

document and the panel of experts. 

But do you -- what is your -- what 

would you see as your ideal result of that work? 

What would the end product from NOSB look like? 

MS. LIPSTREU: Thank you, again. 

Well, I think, ideally, we would see some kind of 

guidance or instruction developed by the NOP that 

would provide some resources that could be shared 

with certifiers who could also share those 

resources with producers. 

One of the things that we've come to 

realize over the past several years of working on 

this issue is the critical nature of everyone 

having as complete information as possible as 

early on in the process as possible so that, you 

know, as many mitigation measures can be put in 

place that protect farmers and their resource 

base they depend on. 

MEMBER RICE: Thank you. 

MS. LIPSTREU: Thank you. 

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CHAIRPERSON CHAPMAN: Any other 

questions? 

Hearing none, thank you for your time, 

and we'll go on to the next commenter, Harold 

Austin, followed by Percy and then Ted Auch. Ted 

Auch, if you're on the line please comment in 

because we haven't identified your phone number 

yet. 

Harold, if you can start with your 

name and affiliation please? 

MR. AUSTIN: Thank you, Tom. Harold 

Austin, past member of the NOSB, an organic 

consumer, and the current Chair of the Northwest 

Hort Council's Organic Subcommittee. 

Good day. First, I'd like to thank 

all of the members of the NOSB for your service 

on behalf on our organic community and the 

various stakeholders that each of you represent. 

This can be very time consuming, so I truly 

appreciate all that you do on our behalf. 

I support the sunset materials 

currently under review and up for vote as 

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presented by the Crop Subcommittee. Please see 

my written comments for specific detail. 

I also support the position of the 

Crop Subcommittee on the proposals with the 

exception of allyl isothiocyanate. I think 

adding this material to the National List would 

be of assistance to organic growers for coming 

into compliance with federal and state 

phytosanitary requirements for nursery stock 

which currently can only be accomplished by the 

use of substances not currently allowed for use 

in organic crop production. 

In reading other public comments, I 

fully support the comments on this material that 

were submitted by the Organic Produce Wholesalers 

Coalition. They framed this very well. 

As a past Chair of the Handling 

Subcommittee, I support all of the sunset 

materials currently under review and up to the 

subsequent vote as presented by the Handling 

Subcommittee. 

These are materials that I've been 

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involved with for previous sunset reviews, and I 

see absolutely no reason why they should not 

continue to be allowed as currently listed on the 

National List because the majority of them are 

still quite necessary for organic handlers. 

I especially want to thank and comment 

and let you know how much I appreciate the hard 

work of this Subcommittee. 

Materials Subcommittee, a couple 

things to mention. First, regarding the marine 

materials discussion document, this is a complex 

subject, and I appreciate the hard work put in to 

it thus far by the Subcommittee. However, this 

is in no way ready for prime time nor do I think 

it will be any time in the near future. 

As an organic community, we must find 

a way to farm in a true sustainable fashion while 

at the same time protecting and/or enhancing the 

environment and our natural resources each and 

every day. This document, while it frames some 

of the concerns, I feel it creates more questions 

than provides answers. 

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And, thus, I urge caution as you try 

to move this very complex issue forward. I would 

support the formation of a working group to look 

at this issue. I also question if the NOP is 

actually the appropriate governmental agency to 

provide oversight for such a process. I would 

ask the NOP and the USDA to weigh in on that. 

Secondly, I question the need for the 

proposed work agenda item for sanitizers. I do 

not see a valid rationale for this to be included 

in the Subcommittee work plan as an action item. 

Each material is currently listed for a specific 

use for each of the appropriate Subcommittees. 

The need, the use, the necessity will 

vary for each material. And if they're lumped 

into a single category, seems pointless, 

especially when there are so many other things 

that you, the members of the NOSB, could be 

spending your time on. 

No one on any of the Subcommittees 

will be able to truly frame all of the variables 

that an organic handler or producer must take 

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into consideration. 

Thank you. 

CHAIRPERSON CHAPMAN: Thank you. Any 

questions for Harold? 

(Simultaneous speaking.) 

MEMBER ELA: Tom, I have one -- go 

ahead, Emily. 

MEMBER OAKLEY: Sorry. 

Thank you, Harold, for your comments. 

And I wanted to ask you specifically in regards 

to marine materials, we found a very difficult 

time in identifying an internationally recognized 

and agreed-upon definition of sustainability or 

something similar in terms of harvest of marine 

materials. And I was wondering if you had any 

specific suggestions or knew of any other avenues 

that you would -- that we pursue as we try to 

address environmental concerns of those 

materials? Thank you. 

MR. AUSTIN: Thanks, Emily. You know, 

that's a difficult question that you're trying to 

take and figure out the scope of. As you know, 

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while I was still on the Board, we looked at the 

marine materials and the classifications and 

sustainability. 

And, likewise, what you're now 

encountering, we also encountered at that time, 

the extreme difficulty by nature of what this 

encompasses. And that's why I question how to 

move it forward. It's going to be an extremely 

complex process, and this is a difficult topic. 

And we know there's environmental 

concerns. We also know that there's concerns by 

the organic stakeholders that rely on these 

materials. And how do we frame that? What does 

that look like? 

That's where I think stepping back, 

forming a committee, a working group to look at 

all of the specifics, to analyze and to go out 

and research that very -- the scope of what you 

just posed I think makes the best sense. 

Take the time, make sure that, as you 

take the approach to it, that we're looking at 

environmental concerns. We're also looking at 

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the feasibility of this and also the impact on 

the organic stakeholders as well. I hope that 

helps. 

MEMBER OAKLEY: Yes, thank you. Is it 

okay to do a quick follow up, Tom? 

CHAIRPERSON CHAPMAN: Yes. 

MEMBER OAKLEY: Do you feel that using 

the wildcraft standard for organic certification 

would not adequately address environmental 

concerns? Or what is your concern about applying 

that standard to address the environmental 

issues? And that's my last question. Sorry, 

thanks. 

MR. AUSTIN: You know, I don't know if 

I can give you a full answer on that, Emily. I 

think that's where having a working group really 

look at having that apply to this. 

What are the impacts? What does it 

cover well? What doesn't it cover well? What 

are the other issues that that might take and 

bring into play? 

So I think really taking and having a 

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working group that can really dig into the weeds 

on this, so to speak, I think behooves us all to 

take a step back, be a little bit cautious about 

it, because this is going to have an impact. We 

definitely want something that's sustainable. We 

want something that's going to protect the 

environment. 

But I think putting together a working 

group of the various different perspectives, 

different agencies, different, you know, 

consumers, environmentals, organic stakeholders 

that use these materials, looking at all the 

impact that this is going to have. Because this 

covers such a tremendous scope, I just urge 

caution as you move forward with it. 

CHAIRPERSON CHAPMAN: Other questions 

for Harold? 

MEMBER ELA: Tom, this is Steve, I had 

a question. 

CHAIRPERSON CHAPMAN: Steve, go ahead. 

MEMBER ELA: Harold, just wanted to 

follow up on your comments on AITC and your 

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recommendation that we move forward with that. 

Could you expand a little more on 

that? Because we're certainly wrestling with its 

application, I mean, not being all that different 

from other broad spectrum fumigants and such 

versus, you know, it's not -- it's a little more 

specific and a little more potentially 

appropriate for organic. 

So I'd like to hear a little more 

detailed thoughts on that from you. 

MR. AUSTIN: Cool, yes, Steve. I 

think compared to the other materials that we 

have on a conventional side, which we know, I 

mean, essentially, we're coming in and we're 

fumigating, you're sterilizing the soil, you 

know, for the planting stocks. 

But there are phytosanitary 

requirements that we have to meet in order to 

take and provide -- be able to provide those 

planting stocks to the grower. 

Organically, you know, pretty much, we 

have to take and look aggressively at 

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conventional stock rather than organic supplied 

stock, especially when we're dealing with like --

crops -- tree fruits, specifically. 

I think utilizing this material, we 

could take it and give something that's very 

close to the natural sources, but we can use it 

in a more confined, more defined application 

technique. You know, we've all dealt with, a lot 

of us, with the mustard seeds, the natural, the 

mustard plants, working them in. That 

encompasses broad spectrum. 

Where on this specific, we could 

utilize this material because it hits site 

specific so that we're minimizing the impact that 

it might be having on a broad spectrum. So I 

think there's a lot more benefit if we have this 

material, especially when we're dealing with 

planting stock, wood stock, for phytosanitary --

to meet the phytosanitary requirements that we're 

trying to accomplish. 

I think it give the organic community 

a tool that they could use, and we could provide 

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-- and we could begin to provide those planting 

stocks from an organic source rather than a 

conventional source. 

MEMBER ELA: As a follow up to that, 

Harold, would you then be in favor of an 

annotation that would restrict it to planting 

stock versus other more widespread use? 

MR. AUSTIN: I wouldn't be opposed to 

that at all. 

MEMBER ELA: Thank you. 

MR. AUSTIN: Thanks, Steve. 

CHAIRPERSON CHAPMAN: Other questions 

for Harold? 

Okay, thank you, Harold. 

Up next, we have Percy followed by 

Ted. Ted, we still haven't located your phone 

number, so please comment in if you're here. And 

after Ted, Julia Barton, you're on deck. 

Percy, if you could start with your 

name and affiliation? 

MR. HAWKES: Yes, can you hear me? 

CHAIRPERSON CHAPMAN: Yes, we can. 

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MR. HAWKES: Okay, yes, this is Percy 

Hawkes, and I'm the Regulatory Affairs Specialist 

for Protena International, and we are petitioning 

that sodium citrate be included on the list of 

synthetic substances allowed for use in organic 

crop production. 

Sodium citrate is commonly used as an 

anticoagulant to facilitate the processing and 

handling of blood collected in slaughterhouses. 

And it acts as a chelating agent in fresh blood, 

the citric ion binding with and removing calcium 

ions which are needed to coagulate blood. 

Sodium citrate is the anticoagulant of 

choice for the following seven reasons. First, 

it is made from citric acid which is easy to 

manufacture resulting from the fermentation of 

organic starch components and the addition of 

sodium hydroxide or sodium monohydrate. 

Second, sodium citrate and its 

precursor, citric acid, are widely used in the 

food industry with many uses already approved in 

the production of organic food products. 

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Third, sodium citrate is one of the 

three USDA-approved anticoagulants for processing 

slaughterhouse blood. The other two are citric 

acid and sodium tripolyphosphate. 

Fourth, sodium citrate is the most 

readily available anticoagulant for handling 

slaughterhouse blood. 

Fifth, food grade sodium citrate is 

not known to have any negative effects on the 

environment nor on human or animal health. It is 

rapidly degraded in the soil and is free of heavy 

metals. 

Sixth, sodium citrate used as an 

anticoagulant produces a more uniform and quality 

product than the alternative method of mixing the 

blood with agitators. Agitators or mixers cause 

hemolysis of the red blood cells and the 

formation of fibrin residue, ruling out its use 

in further processing blood byproducts. 

And, seventh, citric acid is already 

approved as a processing aid to lower the pH of 

liquid fish organic fertilizer. And by lowering 

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the pH, it forms citrate salts. 

Therefore, sodium citrate becomes one 

of the ingredients in organic liquid fish 

fertilizer resulting from the use of citric acid 

to adjust the pH. We believe that sodium citrate 

should be approved as a processing aid, 

anticoagulant for organic blood derivative 

fertilizers. Thank you. 

CHAIRPERSON CHAPMAN: Thank you. Any 

questions for Percy? 

MEMBER BEHAR: Tom, this is Harriet. 

CHAIRPERSON CHAPMAN: Yes, go ahead. 

MEMBER BEHAR: Would you say that the 

vast majority of dried blood meal is -- has 

sodium citrate in it now? 

MR. HAWKES: Yes, that is the 

anticoagulant of choice that basically all 

slaughterhouses that process blood use. 

MEMBER BEHAR: And one other question. 

Did you have a certifier tell you that blood meal 

would not be allowed if you had used the sodium 

citrate as the anticoagulant? Is that what 

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precipitated this petition? 

MR. HAWKES: Yes, we assumed that we 

had to get sodium citrate approved as an 

ingredient just as it has to be approved by other 

countries. Does that answer your question, or am 

I missing the question? 

MEMBER BEHAR: I know that blood meal 

has been allowed without that review of the 

processing aid of sodium citrate in the past, so 

I was just wondering if you had a certifier tell 

you that they would no longer allow blood meal as 

a natural product because of the presence of the 

sodium citrate, the small amount of residual. 

MR. HAWKES: Well, some blood meal is 

just processed from raw blood directly. And 

other -- other plants that process plasma and 

hemoglobin use the hemoglobin portion as a blood 

derivative organic fertilizer. 

So I guess my previous answer, you 

asked if all blood meal has sodium citrate, if 

they process plasma, yes, it will have sodium 

citrate in the hemoglobin portion as well as the 

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plasma portion. 

If they don't -- if they just use raw 

blood that is not -- does not have -- does not 

need to have anticoagulant because they don't 

process plasma, then it wouldn't have the sodium 

citrate. Does that answer the question? 

MEMBER BEHAR: Yes. You did mention 

that overseas that you've been asked to have this 

approved by other governmental organic oversight 

agencies, is that correct? 

MR. HAWKES: Yes, we are not aware 

that it's approved. 

MEMBER BEHAR: Okay. 

MR. HAWKES: Could you give me the --

I guess I need the reference of what you're 

referring to. I mean, we know blood meal is 

approved, but is blood meal that contains sodium 

citrate approved? We were told that it was not, 

that it would have to be approved, and that's 

part of the process that we had to go through at 

your request. 

MEMBER BEHAR: Okay, thank you. 

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CHAIRPERSON CHAPMAN: Any other 

questions for Percy? 

All right, thank you, Percy. 

Up next, we have Ted Auch followed by 

Julia Barton and Doug Raubenolt. 

Ted, are you here? 

MR. AUCH: Can you hear me? 

CHAIRPERSON CHAPMAN: Yes, you're a 

little light, Ted, but we can hear you. If you 

could start with your name and affiliation for 

the record? 

MR. AUCH: Sure, my name is Ted Auch. 

I work with a nonprofit called The FracTracker 

Alliance -- work in Cleveland, Ohio and I also 

teach adjunct -- environmental science -- and the 

reason that I'm on this phone call is, well, I'm 

a recovering soil scientist, that's what I have 

my PhD in, but it's been a while since I've got 

my hands dirty in the soil science profession. 

But, at the nonprofit that I work at, 

FracTracker, we do a lot of work analyzing and 

looking at the impacts of unconventional oil and 

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gas production processing and transport and that 

kind of thing. 

And, we do a lot of mapping of this 

industry, the unconventional oil and gas industry 

with respect to their water impact, their waste 

impact and their land use impact. 

And I was talking to Amalie Lipstreu 

at Ohio Ecological Food and Farm, and she 

suggested I get on this call, and the only thing 

that I'd really like to add to this phone call is 

I've talked to a lot of people, a lot of organic 

farmers, whether it's Tony Driac up in Jackson 

County, Wisconsin or some other folks who I've 

met here in Ohio. 

And what I'd like to stress on this 

phone call is that this -- your organization, 

it's critical that you pay attention to and 

really get a sense for the magnitude of 

unconventional oil and gas development in the 

United States and really broaden what -- how you 

define that and its impact on your constituents. 

Because, what the oil and gas industry 

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has been really good at doing in my six years of 

looking at them is constraining how we define 

fracking, what we define as fracking to the well 

pads in North Dakota, Pennsylvania and Ohio. 

But this is an organism spread out 

across the United States, and it's having a 

dramatic impact on the landscape, on watershed --

on surface water, subsurface waters, hydrologic 

cycles, and it has everything from there's --

it's having impacts whether it's the sand mines 

up in Wisconsin and their impacts on dairy 

farmers and beet farmers, or it's an injection 

well in Ashtabula County, Ohio, which is having 

an incredible impact on small farmers in that 

county and everything in between. 

I think that -- I think it's important 

-- it's just critical that everyone understands 

that fracking includes a tremendous amount of 

infrastructure, a tremendous amount of transport 

of stuff, whether it's brine hauling or sand 

movement or whatever the case may be. And all of 

that is going to trickle back down into the 

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people that are on this phone call. 

And we've mapped that impact, the 

potential impact of these -- the full 

exploitation of these shale plates across the 

United States, and you can find that at our 

website, www.fracktracker.org. 

 We've worked on that project, mapping 

the potential impact on the agricultural sector 

in the United States, organic and otherwise. 

So I just wanted to kind of give my 

two cents as to what I've seen on this topic and 

just convey to the audience on this call that 

fracking is having a quiet and a very loud impact 

on farming when we really understand that this is 

not just a well pad, there's all sorts of other 

stuff going on. 

So that's all I kind of have to 

contribute. 

CHAIRPERSON CHAPMAN: Thank you, Ted. 

MR. AUCH: Sure. 

CHAIRPERSON CHAPMAN: Any questions 

for Ted from the Board? 

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All right, Ted, I'm not seeing any 

questions or hearing any. Thank you for your 

time today. 

MR. AUCH: Sure. 

CHAIRPERSON CHAPMAN: Up next we have 

Julia Barton, followed by Doug and then Jo Ann 

Baumgartner. 

Julia, if you could start with your 

name and affiliation for the record? 

MS. BARTON: Yes, can you hear me? 

CHAIRPERSON CHAPMAN: Yes, I can. 

MS. BARTON: Okay, thank you. 

Good afternoon, my name is Julia 

Barton with the Ohio Ecological Food and Farm 

Association. Thank you to the Board for your 

service, to the program for your work, and for 

the opportunity to offer public comment over the 

phone. 

You heard just now from my colleagues 

Amalie Lipstreu, Ted Auch and from 32 

organizations in a group letter submitted to the 

docket regarding our ongoing request to the Board 

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and the program to please add the topic of energy 

infrastructure development on organic farms to 

the work agenda. 

It sounds like from your questions to 

Amalie that you may be considering how to scope 

such an agenda item. To fuel that conversation, 

we have several real-life examples, some of which 

we've shared over time of organic farmers 

impacted by this development. 

This development, we know, is not 

going away, so we think it's important to work 

together to add consistency and transparency to 

the way we understand and address this issue in 

the organic realm. 

As an example, from a certifier 

perspective, we at OEFFA have identified some 

prohibited substances that are commonly used in 

pipeline construction, foam breakers which are 

used as soil bands in the trench to hold up and 

stabilize the pipes and are buried in the trench 

right along with the pipe when construction is 

finished, are one example of a prohibited 

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substance. 

Similarly, foam balls consisting of 

prohibited materials are used on sloping land to 

prevent gullies which could destabilize the 

pipes. Another commonly used material called 

Black Magic is a sand which sounds innocuous 

enough, in the sand blasting guns. It contains, 

however, acrylic and recycled glass material. 

This material is used because the pipes come off 

the pipe yard with paint on them and the 

contractors have to blast that coating off to 

then weld and put a latex rubberized coating over 

the pipes to connect the pipes together to move 

the gas around. 

OEFFA requires that the welding area 

must be blanketed in order to prevent the 

material from contaminating the soil. The 

application of these prohibited materials would 

require an OEFFA certified farm to retransition 

which leads us to the experience of the producer. 

If, say, the producer did not engage 

in an ag impact mitigation plan, I should note 

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ahead of construction or if, say, that plan was 

not followed, then they're in a situation of decertification and the need for retransitioning. 

So the producer is then left to figure 

out how to, for example, meet dry matter demand 

or manage a pasture rotation requiring them to 

repeatedly cross a pipeline strip that's 100 feet 

wide that's in transition and make sure the cows 

don't eat anything out of that strip that's being 

retransitioned while they're moving back and 

forth. 

Maybe they need to get to the parlor 

or access water or shade that's not accessible in 

the pasture that they're grazing that day as part 

of a rotational grazing system. So this gets 

complicated from producer perspectives, too, 

which is another reason we're requesting the 

Board's help. 

Finally, the inspectors are being 

forced to handle these situations differently 

according to the policies or lack thereof of 

various certifiers. This is an untenable 

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position for inspectors, and you'll be hearing 

from one of OEFFA's best inspectors, and most 

experienced in this arena, here in just a moment. 

Thank you for your time. 

CHAIRPERSON CHAPMAN: Thank you, 

Julia. Any questions for Julia? 

I'm hearing and seeing none, so we'll 

move along. Thank you, Julia, for your time. 

MS. BARTON: Thank you. 

CHAIRPERSON CHAPMAN: Up next is Doug, 

followed by Jo Ann Baumgartner and then Corellia 

Johnson. 

Doug, are you on the line with us? 

Doug, are you there? If you're speaking, you are 

on mute. 

MS. ARSENAULT: I just unmuted him, 

Tom. So, Doug, can you hear us? Can you talk? 

Say something so we know you're unmuted. 

MR. RAUBENOLT: Yes, I'm here now. 

Can you hear me now? 

CHAIRPERSON CHAPMAN: Okay, Doug, we 

hear you. 

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MR. RAUBENOLT: Okay. 

CHAIRPERSON CHAPMAN: If you could 

start with your name and affiliation for the 

record? 

MR. RAUBENOLT: Yes, my name is Doug 

Raubenolt. I'm an IOIA-accredited inspector from 

Ohio. I've been an organic inspector for 13 

years and have performed inspections in 24 states 

for six different certifiers. 

Most everybody knows that Eastern Ohio 

and Western Pennsylvania are in the middle of an 

oil and natural gas boom which has now led to 

huge pipeline construction projects dissecting 

both states, and many organic farms are located 

in their pathway. 

Organic farmers have been given the 

option through mitigation agreements to have all 

pipeline construction activities monitored by an 

on-site IOIA-accredited organic inspector to 

ensure their farm's organic status remains 

intact. I have served in this capacity for four 

different pipelines, and three of those have just 

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occurred in the last 12 months. 

Prohibited inputs in normal pipeline 

construction include the use of polyurethane and 

polyphenylene foam products used for pipe 

stabilization and water breakers, sand blasting 

materials using recycled ingredients, welding and 

grinding residue, paint, contaminated dozer and 

trackhoe tracks, buckets, and blades from 

conventional farms, and boring fluids for 

construction under roads and streams. 

Alternative plans have been agreed 

upon by pipeline companies for most of these 

activities, however, the NOP regulations are 

unclear on the following four issues. Number 

one, top soil replacement. Pipes settle and 

erosion events occur which result in the need to 

bring in off-farm topsoil to fill these voids, 

always confused as an inspector whether it needs 

to be organic or whether prior land use 

documentation suffices. 

Number two, rock formations, they 

require drilling and blasting by the companies 

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using dynamite and nitroglycerine, and our 

question has always been, once this substance is 

exploded, is it still prohibited? 

Is there a -- number three, is there 

a depth where a prohibited input is not going to 

take a -- for instance, polystyrene pillows are 

formed and lay under pipes at about 15-foot deep 

to be used as rock shields. 

And, number four, if an organic farmer 

voluntarily pulls his right-of-way strip from 

certification exchange for a three-years crop 

compensation from the pipeline company, they've 

got a lot of money, they don't care, they'll 

write big checks, would the toxic products used 

during normal construction be an issue in 

granting -- certification after 36 months? 

Some certifiers are really scared to 

death about these foam products and are not sure 

whether that can ever be recertified again, all -

- a concern for me, as an inspector. 

 So there's one thing I hear in common 

from all pipeline companies, we ain't seen 

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nothing yet. The pipelines, there's going to be 

lots of them coming through here. The pipeline 

sites -- involved in only represent about 20 

percent of what they're got tapped. 

Thank you very much for hearing me 

out, and those are the concerns that I have as an 

inspector. Thank you. 

CHAIRPERSON CHAPMAN: Thank you, Doug. 

Any questions for Doug? 

MEMBER BEHAR: This is Harriet. I 

just want to say thank you for those four points 

there at the end. 

CHAIRPERSON CHAPMAN: Okay, Doug, not 

seeing any questions. Thank you very much for 

your testimony and your time today. 

Up next, we have Jo Ann Baumgartner 

followed by Corellia Johnson and then Steve Etka. 

Jo Ann, are you on the line with us? 

MS. BAUMGARTNER: Yes, can you hear 

me? 

CHAIRPERSON CHAPMAN: Yes, I can. And 

can you start with your name and affiliation? 

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MS. BAUMGARTNER: Okay, thanks. I'm 

Jo Ann Baumgartner with the Wild Farm Alliance. 

We promote a healthy, viable agriculture that 

protects and restores wild nature. 

Thank you, again, to NOSB for passing 

the proposed rule to eliminate the incentive to 

convert native ecosystems to organic production. 

Over 1,200 organic consumer comments supported 

that proposal. The NOP should now begin moving 

this recommendation forward to rulemaking. 

With the help of organic and 

conservation experts, we are putting together a 

draft guidance for this rule that can be used by 

the NOSB or the NOP as a starting point. It will 

help operators and certifiers -- information 

needed to determine whether or not a native 

ecosystem has been converted. 

Specifically, there are examples of 

organic systems and questions that can be asked 

from the desk and from the field and will also 

provide other examples of land that has not 

recovered enough to become a native system. 

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Now, for marine materials, any seaweed 

that is used in organic production should adhere 

to the wild caught standard that ensures no 

destruction to the environment. All certifiers 

should require documentation from operators for 

monitoring efforts that show they are protecting 

the environment. 

Last year, we conducted a survey of 42 

to 48 OSP new site certifiers in the U.S. The 

majority allow visual assessment for the NOP 

monitoring requirement. There were some 

certifiers that required photographs or written 

documentation because they felt like that was the 

only way that they could really verify what the 

operator was doing as they say they are. This 

should be the norm. 

Visual assessment alone is not enough. 

Documentation should occur before and after each 

marine vegetation harvest for all biodiversity. 

But, the seaweed itself, the by catch from the 

harvest and the wildlife that uses seaweed as 

purchase for hunting and cover for predators. 

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 For seaweed, documentation of the 

three dimensional structure in the seaweed bed 

against the height and bio mass should be 

conducted. For bio catch, they can take a photo 

of what's left in their boats. The wildlife 

documentation should include a survey of birds 

and marine mammals using seaweed. 

We are in support of establishment of 

a working group whose members include marine 

biologists and other conservationists, land 

owners who are impacted by seaweed harvest, 

companies that harvest the seaweed, the producers 

that use the seaweed, and consumers. 

The creation of a wild marine 

vegetation harvest guidance is critical for 

uniform compliance. Thank you for listening to 

my thoughts today. 

CHAIRPERSON CHAPMAN: Thank you, Jo 

Ann. Any questions for Jo Ann? 

MEMBER BEHAR: So this is Harriet. 

Hello, Jo Ann. 

I was wondering if you had heard 

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anything from certifiers or inspectors or anyone 

about the protecting the native ecosystem 

proposal that we passed? Either concerns or, you 

know, pleasure that it was passed and looking 

forward to implementation? Have you heard 

anything? 

MS. BAUMGARTNER: Well, we have not 

specifically outreached to them. We're still 

working internally with this -- draft guidance. 

So I will just say that, you know, there was a 

lot of really good comments submitted in your 

last meeting, if you'll recall, from certifiers 

in support. 

CHAIRPERSON CHAPMAN: Any other 

questions? 

Hearing none, thank you, Jo Ann. 

MS. BAUMGARTNER: Thank you. 

CHAIRPERSON CHAPMAN: Up next is 

Corellia Johnson followed by Steve Etka and then 

Ari Davis. Ari, we have not found you on the 

line, so if you're on the line, if you could 

comment in to the Chairperson, that would be 

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appreciated. 

Corellia, are you on the line with us? 

Corellia, if you're speaking, we can't hear you. 

MS. ARSENAULT: I don't see her name 

on the line, Tom, but there was someone from the 

same area code, but I guess it's not her. 

Thanks. 

CHAIRPERSON CHAPMAN: Yes. All right, 

Corellia, not hearing you on the line. Give you 

one more shot, otherwise, we'll skip over you and 

move on to Steve Etka. So, Steve, are you there? 

MR. ETKA: I am. Can you hear me? 

CHAIRPERSON CHAPMAN: I can, hold on 

one sec, Steve. 

So after Steve is Ari. Ari, we 

haven't found you, so please comment in if you're 

here, Ari Davis. And then after Ari is Nathan 

Brown. 

Steve, if you could start with your 

name and affiliation? 

MR. ETKA: Sure, my name is Steve 

Etka, and I'm Policy Director for the National 

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Organic Coalition. The Board's work is important 

to the integrity of organics, so it's important 

that you all be aware of the latest news in the 

larger organic policy arena as well. 

In that context, NOC is pushing hard 

for Congress to pass a new Farm Bill. The 2014 

Farm Bill and funding for key organic programs 

officially expired on September 30th without any 

action by Congress to finalize a new Farm Bill or 

pass a short term extension of the old one. 

Both House and Senate versions of the 

Farm Bill include positive organic provisions and 

bad ones. From our perspective, the bad 

provisions include inappropriate statutory 

changes to the NOSB authorities which NOC 

strongly opposes. 

We're pushing for a new Farm Bill that 

keeps the good organic provisions and gets rid of 

the bad. Fortunately, both versions of the Farm 

Bill improve organic import fraud enforcement. 

Related to enforcement, we are 

concerned about the lack of reliable USDA organic 

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data collection, particularly for organic acreage 

data. USDA's Economic Research Service and 

National Agricultural Statistics Service used to 

collect organic acreage data through the Organic 

Certifier Survey. And we no longer have this 

data because in 2017 the responsibility for 

collecting organic acreage data from certifiers 

was transferred to the AMS without the 

appropriate infrastructure to collect meaningful 

and complete data. 

And, as a result, there will be a 

multi-year gap in meaningful organic acreage data 

as well as other -- organic data stretching from 

2015 until the procedures for collecting and 

inputting data via the NOP's organic integrity 

database are strengthened. These gaps greatly 

impede the organic community's ability to deter 

fraud, especially through the use of mass balance 

audits. 

NOC believes that NOP should make 

product and acreage reporting mandatory for 

certifiers through the organic enforcement 

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rulemaking in spring of 2019, but should also 

adopt a sound and sensible approach to ensure 

that for certifiers working with small 

diversified producers that it can be captured in 

a reasonable way. We're also urging AMS to hire 

some qualified statisticians to maintain and 

analyze the data. 

I also want to address the 606 

exemption approval process. It should not be 

enough for a petitioner, in our view, to show 

that they are unable to source an organic farm of 

an ingredient. Petitioners should have to show 

that they have exhausted efforts to work with 

farmers and suppliers to have the ingredient 

produced organically. 

Too many times, the 606 exemptions 

become an impediment to farmers who want to 

produce an organic product but have no market for 

the product because buyers have a 606 exemption. 

The organic industry has grown enough 

that we should be able to produce most things 

organically. Thanks for this opportunity to 

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provide testimony. 

CHAIRPERSON CHAPMAN: Thank you, 

Steve. Any questions for Steve? 

MEMBER BEHAR: This is Harriet. Thank 

you for bringing that up about 606. I think that 

is something that we, NOSB members, do get a 

little frustrated with. So we're going to see if 

we can deal with that somehow in an up-front 

petition question as well as maybe a checklist 

that we can look at. Thank you. 

MEMBER GREENWOOD: Tom, I had a 

question. 

CHAIRPERSON CHAPMAN: Go ahead, Rick. 

MEMBER GREENWOOD: Steve, could you 

just clarify what data had been collected prior 

to 2015 that is no longer being collected? 

MR. ETKA: So prior to that time, 

originally, the USDA's Economic Research Service 

did an Organic Certifier Survey. That 

transferred over to NASS, the National 

Agricultural Statistic Service at USDA, a number 

of years later. 

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And that survey was done in a way 

where USDA employees actually, when needed, would 

go out and work individually with each certifier 

to get the data, and as a result of that process, 

they had near-universal compliance with providing 

that data. 

But what we have seen is now that AMS 

has taken over that function, and it's supposed 

to be part of the Organic Integrity Database, 

that process has been slow to get started, and 

the complexity of what certifiers are supposed to 

be providing has meant that there has not been 

good compliance with providing that data. 

And as a result, we just don't really 

even know how much organic acreage we have 

anymore. The last -- we have was back in 2015. 

So it really causes a lot of problems. 

We can't track production trends. It makes it 

harder for putting together risk management 

tools. It makes it very difficult to do mass 

balance auditing as part of the effort to crack 

down on particularly import fraud, but also 

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domestically. 

So it's a problem in a number of 

different areas. And we like the fact that the 

Organic Integrity Database has been -- is realtime, but there's some problems with it that need 

to be addressed so that we can get back on track 

in getting the data. 

MEMBER GREENWOOD: Thank you, Steve. 

CHAIRPERSON CHAPMAN: Any other 

questions for Steve? 

Steve, you said that small producers 

-- acreage data about small producers should be 

captured in a reasonable way. What -- how would 

you -- what would you suggest as reasonable? 

MR. ETKA: Well, one example we laid 

out in our written comments would be for 

certifiers working with producers would grow on 

small acreage and have like mixed -- diversified 

vegetable operations, for instance. 

You know, they may have a number of 

hundred foot rows and, in certain cases where 

you're dealing with a small producer, it may be 

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sufficient to capture the data as mixed 

vegetables on 2.5 acres, for instance, as opposed 

to having to list, you know, seven or eight 

different tiny amounts of individual vegetables. 

You know, in other areas where you 

have certain high risk crops like where we've 

seen some of the fraud like corn and other 

things, it may be really important to gather that 

data, but for small, diversified operations there 

may be some sound and sensible way to do that 

that would discourage the inputting of that data. 

CHAIRPERSON CHAPMAN: Thank you. And 

then on the 606 issue and your comments about 

farmers not being able to find a market for some 

606 items because of the exemption. 

I mean, we've seen several examples of 

items coming off that list with operations, you 

know, developing in organic farming and 

petitioning the Board to have it removed. 

So it's worked in some cases and not 

-- and I'm taking from your comments that you're 

thinking it's not working in other cases. What's 

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causing that difference? Why does it work 

sometimes and not the rest of it? 

MR. ETKA: You know, I'm thinking back 

a number of years to the hops example where there 

was kind of a big fight about whether or not that 

could come off the 606 list. And what we're 

hearing from producers is that they really felt 

like they could and wanted to produce hops 

organically. 

But because of the complexity of the 

crop, often it's done under contract, and because 

buyers didn't need to use organic forms, it just 

dried up that market. 

So it's not only the question of 

whether it comes off, it's also the question of 

whether it goes on and whether there's the due 

diligence up front by a petitioner to not just 

determine that it's not available right now, but 

also to see if there's a way that could work with 

suppliers and farmers to make it available before 

they go through the 606 or have to go through the 

606 process. 

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I mean, we're certainly aware that 

time is of the essence for many buyers, but I 

guess we also wanted to point out that the 606 

process is not a fast process either, as you all 

know. It's sort of -- the NOSB process, but then 

it has to go through the USDA rulemaking process 

which is quite timely and cumbersome in many 

ways. 

It would just be easier for a buyer to 

be kind of proactive in the market in trying to 

work with farmers and ingredient manufacturers to 

have it provided organically. 

CHAIRPERSON CHAPMAN: Okay, thank you, 

Steve. Any other last questions for Steve? 

MEMBER SWAFFAR: Hey, Ashley here. I 

just want to say one comment. Steve, I think you 

are spot on on your comments about the data 

collection for small farmers. 

It's my experience that those people 

don't care to let you take the time to figure 

that out. They always call me in the most random 

times and never have that data available. So I 

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like that of a mixed vegetable idea. Good idea. 

MR. ETKA: Thanks. 

CHAIRPERSON CHAPMAN: Okay, thank you, 

Steve. Up next we have Ari Davis followed by 

Nathan Brown and Jessica Shade. 

Ari, are you here? Not sure if we've 

been able to identify your phone number yet. 

Ari, if you're speaking, we can't hear 

you. Ari, going once, going twice. 

Okay, we'll move on down the list. Up 

next is Nathan Brown. Nathan, are you here? 

MR. BROWN: Yes, I'm here. 

CHAIRPERSON CHAPMAN: Okay, Nathan, we 

can hear you. Hold on one second, Nathan. 

Up after Nathan will be Jessica Shade 

followed by Jaydee Hanson. 

Nathan, if you'd start with your name 

and affiliation? 

MR. BROWN: My name is Nathan Brown, 

and my family has Amaltheia Organic Dairy. I've 

been past Chair of the Montana Organic 

Association and on the Farmer Advisory Council 

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for the Organic Trade Association. 

I'm commenting today on the paper pot 

transplanter, and I'd make a recommendation from 

the NOSB to extend the December 2018 deadlines 

for its use until the NOSB has a chance to review 

the material and vote on the petition. 

I've used this paper pot transplanter 

for one year. I got it about a year ago to do 

winter greenhouse growing. And, it's totally 

changed my farm. I can now do crops like lettuce 

mix. I've transplanted beets, all of the onions 

and shallots, bok choy using one person this year 

did all of my seeding and all of my 

transplanting. 

A typical 250-sub-bed took about an 

hour where it would take four to five people 

probably three hours before to transplant that 

bed. It's just been remarkably efficient for us. 

And, it has obviously affected the 

quality of my produce as well. All of my onions 

and shallots are more uniform than they've ever 

been. It also almost doubled my yield in the 

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same growing area from previously doing onions. 

It has also -- we can reuse the trays. 

We can use less potting soil and I think all of 

these obviously impact small farms like myself. 

One of the things I guess I'm most, I 

guess, proud of and the biggest impact I would 

say is we've been able to pay employees more 

because we've been able to increase our income 

because we're not having to pay employees to do 

basically back breaking transplanting on our 

small farm. 

We're too small for a water wheel 

transplanter. And so, I guess, years past, the 

highest I've paid is $13 an hour and this year, 

I'm paying two of our experienced employees $15 

an hour. 

And, I'm in Bozeman, Montana which is 

a fast growing, very expensive place to live. 

And, it has been harder and harder for us to find 

candidates for employment, so this has really 

helped out as well. 

Thank you for your time. 

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 CHAIRPERSON CHAPMAN: Thank you, 

Nathan. Thank you for your comments. 

Any questions for Nathan? 

MEMBER OAKLEY: This is Emily. I just 

wanted to let people know that we've discussed 

this quite extensively across the Committee. 

And, I wondered if Steve and or Paul 

might want to share a little bit about our most 

recent conversation and especially in terms of 

the possible extension of the December 2018 

deadline. 

Do either of you want to comment on 

that? 

MEMBER ELA: This is Steve, I can jump 

in. I was actually going to ask a question. 

And, again, the NOP, I think is going 

to talk about this at the meeting in St. Paul as 

well. But, one of the big issues, there's not 

really much debate, I think, on this, on the 

efficacy of paper pots and what they -- the time 

and labor savings and all those things. 

I think the real the problem we're 

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having is that since they used virgin paper --

well, there are a number of issues, but one of 

them is that the virgin paper and virgin -- and 

the current guidelines are recycled paper such as 

news print. 

And then, also, the issue of the 

uncertainty of the adhesive use. 

And then, that puts the Board and the 

NOP in a real quandary of recognizing that this 

is a really valuable item, but also of not -- as 

how do we extend a deadline for something that is 

potentially synthetic without prior approval of 

that? 

And so, that's the quandary that we're 

in at this point. We certainly I think that the 

Crops Committee is really sensitive to what 

you're saying on the plight of these growers 

using the paper pots. 

And, it's also kind of a Catch-22 not 

wanting to set precedent, but we're going to have 

to -- but if something's petitioned, we're just 

going to allow it to be used without complete 

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review. 

So, that's kind of the cliff notes of 

some of our dilemma at this point. But, Paul, if 

you want to add anything, go ahead. 

CHAIRPERSON CHAPMAN: Paul or Devon? 

MS. ARSENAULT: Paul may have dropped 

off the call, sorry. 

CHAIRPERSON CHAPMAN: All right. 

MEMBER ELA: So, Tom, maybe I'll just 

ask a question of the commenter. 

Given that, what would be -- I mean, 

we're, of course, we're trying to deal with the 

OFPA criteria and not allowing the use of 

synthetic on a farm until it's actually formally 

petitioned or approved. 

Given that problem (inaudible due to 

telephone interference)-- how we address that 

issue? 

(TELEPHONE INTERFERENCE) 

MR. BROWN: Sorry, I guess I'm 

(inaudible due to telephone interference) 

MS. ARSENAULT: So, I just muted 

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Steve, but it did not stop that noise. I'm not 

sure where we're getting the feedback from. 

DIRECTOR LEWIS: Michelle, can you 

hear me? 

MS. ARSENAULT: I can hear you, yes. 

Who is this? 

DIRECTOR LEWIS: Great, this is Paul. 

So --

MS. ARSENAULT: Hey, Paul. 

DIRECTOR LEWIS: Yes, I was on. 

So, let me try to add some commentary 

to this. Yes, so, just to paraphrase what Emily 

spoke about, we had extensive conversations, 

obviously, at the subcommittee level and also at 

the exec committee. 

Dr. Tucker, the Deputy Administrator, 

will be talking about this in more detail, Emily, 

at the NOSB meeting next week and really 

outlining the issue that Steve spoke about in 

terms of the issue of paper and the 

classification of paper. 

And then, obviously, the other issue 

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in terms of the use of adhesives and paper pots. 

So, she'll be talking about that in more detail 

at next week's meeting. 

CHAIRPERSON CHAPMAN: Okay. Steve, 

did you have a question that you wanted to 

repeat? I don't think it was heard. 

Thank you, Paul. 

MEMBER ELA: Sure. I was just going 

to ask the commenter how he would prefer we deal 

with -- I mean, the Crops Committee, obviously, 

is very sensitive to this. But, given the issues 

of virgin paper and adhesives and the potential 

use of a synthetic on organic farms before it's 

fully approved or added to the national list, how 

we should handle that? 

MR. BROWN: Well, I guess from what 

everybody has told me that there is the -- the 

glue is in other paper products, cardboard and 

compost ingredients that people can use right now 

in organic production. It's the same 

ingredients. 

And, I've not heard anybody say that 

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there was a synthetic in the ingredients list. 

That, I've not ever heard. If there was, I would 

definitely take a different tone. 

But, I would say, you need to figure 

out exactly what's in the ingredients and if it's 

the same ingredients that we're already able to 

use in compost making, that goes right into the 

soil as well. 

I've had no issues with them breaking 

down in our soil at all. When we harvested the 

onions, there wasn't hardly any paper left when 

we harvested. 

(Simultaneous speaking.) 

MEMBER ELA: Yes, I think the issue is 

that the -- oh, I was just going to follow up, 

Emily, real quick. 

The issue is that the --

MEMBER OAKLEY: Yes, Steve. 

MEMBER ELA: -- adhesives themselves 

are synthetics and they or may not be used in 

paper already. 

And then, the current listings for 

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recycled papers, not virgin paper. So, and those 

two issues are kind of key to the problem we're 

facing. 

MR. BROWN: Yes, I understand that. 

I think they just need time to come up with an 

alternative is the other big issue. I know 

they're working on it, they just need time to 

implement it. 

And, I guess I've also -- yes, it's 

the first -- I'm going to call it the first I've 

heard that it is a prohibited substance in the 

ingredients list. 

CHAIRPERSON CHAPMAN: Emily, do you 

want to say one last thing or a question and then 

we'll need to move along? 

MEMBER OAKLEY: Yeah, no, it's 

basically what Steve said. I mean, there are 

several adhesives that bind the paper together. 

And, they are synthetic adhesives, but at least 

one of them is in newspaper and at least one of 

them, we're having a hard time determining if it 

currently is in newspaper or cardboard or other 

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current allowed recycled materials. 

So, I completely empathize with and 

understand your perspective. But, we just want 

to let know that I think probably, I mean, 

personally, that the current situation revolves 

around the adhesive. 

But, we will discuss at the meeting 

any possible options for extension of that 

deadline and look forward to hearing from Dr. 

Tucker about that. 

Thank you. 

CHAIRPERSON CHAPMAN: Al right, thank 

you Board members and thank you, Nathan, for your 

comments on this item. Clearly, it's an item 

that is important to a lot of farmers and a lot 

of Board members. 

Up next, we have Jessica Shade, 

followed by Jaydee Hanson and then Amber Pool. 

Jessica, are you on the line with us? 

MS. SHADE: Yes, I'm on the line. 

CHAIRPERSON CHAPMAN: Hi, Jessica, if 

you'd start with your name and affiliation? 

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 MS. SHADE: Hi, I'm Dr. Jessica Shade, 

the Director of Science Programs for the Organic 

Center. We're a nonprofit that communicates 

research of interest to organic stakeholders and 

then we also collaborate with government and 

academic institutions to conduct research when we 

find gaps in our knowledge. 

So, first, I want to say, we really 

appreciate the time that the Material 

Subcommittee spent on its recommendation on 

research priorities. We really like the creation 

of the research priority framework and the 

efforts of each Subcommittee to set their 

research priorities for 2018. 

And so, I just have a few comments on 

them. So, first, I want to say that we're 

especially happy to see that you included organic 

no-till practices, plant disease management, 

strategies for controlling invasive insects and 

production of celery for celery powder yield in 

nitrate sufficient for cured meat. 

Because, we're actively involved in 

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conducting and communicating research on those 

topics. And, we think that the NOSB prioritizing 

them will really help us secure funding to 

continue the work. 

So, for example, on the organic notill practices, the organic is collaborating with 

Dr. Kate Tully at the University of Maryland to 

look at practices that improve soil health on 

organic farms. 

And, one of the areas that we included 

was the comparison of no and low till in organic 

production versus standard tillage in organic 

production. 

And, overall, the surface level for 

organic carbon levels are higher in reduced 

tillage plots comparted to standard tillage plots 

for organic. 

But, we also found that reduced 

tillage in organic was associated with 

significant reductions in yield. 

So, basically, while organic farmers 

could improve carbon sequestration by reducing 

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tillage, we really need to have more research to 

support farmers that want to use conservation 

tillage to make sure that it's a viable and 

economically feasible option for a wider variety 

of crops. 

So, we're really thankful that the NOC 

included that because it'll help encourage 

research and provide really needed tools to help 

organic farmers realize the benefits of reduced 

tillage without threatening their yield. 

We've also been working on several 

aspects of plant disease management that are 

directly called out in the 2018 research 

priorities. 

So, for example, we addressed the 

research priority alternative to antibiotics for 

fire blight in a project we did a couple years 

ago with the University of Washington. 

We worked on -- we're currently 

working on integrative pest management strategies 

for organic rice. We're also working on a 

project that looks at organic solutions to 

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citrus screening. 

But, before I use all my time talking 

about projects that we're currently doing, I also 

wanted to touch on additional research needs. 

So, one thing we're continually doing is 

collecting information on research needs and we 

think that --

CHAIRPERSON CHAPMAN: Jessica, that's 

your time, but --

MS. SHADE: Yes. 

CHAIRPERSON CHAPMAN: -- there might 

be a question from the Board for you. 

MS. SHADE: Oh. 

CHAIRPERSON CHAPMAN: Any questions 

from the Board? 

MEMBER BRADMAN: Yes, this is Asa. 

CHAIRPERSON CHAPMAN: Go ahead, Asa. 

MS. SHADE: Hey there. 

MEMBER BRADMAN: Hi, Jessica, if you 

would just finish what you were going to say and 

tell us about the -- what you contend the needs 

are. 

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MS. SHADE: Sure. So, soil health, 

climate change and then pathogen protections for 

uses with with raw manure should be considered. 

Those are the three things that I think might be 

additionally beneficial for including in the 

research priorities. 

CHAIRPERSON CHAPMAN: So, I got 

climate change, the pathogen protection, what was 

the other one? 

MS. SHADE: Soil health. 

CHAIRPERSON CHAPMAN: Soil health. 

So, climate change, specifically, what would you 

want to be included there? 

MS. SHADE: So, there are two aspects 

of climate change that I think need a lot more 

research. 

One is mitigation, so best practices 

for mitigating climate change on farms. 

And then, also, adaptation because, 

regardless of how well we do with climate change 

adaptation, we are seeing much more frequency and 

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MS. ARSENAULT: Sorry, that was me, I 

accidentally muted Jessica. Sorry, Jessica, 

could you repeat your last couple words? 

MS. SHADE: Oh, I was saying 

increasing frequency and intensity of extreme 

weather, so how organic can adapt to those 

situations. 

CHAIRPERSON CHAPMAN: Okay, thank you, 

Jessica. 

Any other questions for Jessica? All 

right, thank you for your testimony. 

Up next, we have Jaydee Hanson 

followed by Amber Pool and then Ronald Gonzales. 

Ronald, we haven't been able to identify you, so 

if you're on the line, please message us. 

Jaydee, are you on with us? Jaydee, if 

you're talking, we can't hear you. 

MS. ARSENAULT: Tom, can I interrupt 

for just one second? We're getting a little 

background noise. So, if you could please mute 

yourself if you're not talking, I appreciate it. 

Thanks. 

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CHAIRPERSON CHAPMAN: Yes, Jaydee? Is 

Jaydee here? I know we've kind of missing you 

here. We see you on the web portion, but we're 

not hearing you. 

All right, Jaydee, we'll come back if 

you're just having a technical issue. 

Amber, are you on the line with us? 

MS. POOL: I'm here. 

CHAIRPERSON CHAPMAN: All right, 

Amber, you'll be up next, give me one second. 

After Amber is Ronald Gonzales. We 

haven't identified and then after that is Jamie 

Barron who we haven't identified. And, there's 

actually about another four or five names that we 

haven't identified the person on the line yet. 

So, if you're Ronald Gonzales, Jamie Barron, 

Timothy Opiela, Tonda Fernando, Harold Lyles or 

Jean Marie Gore Traore, please message in and let 

us know your phone number. 

I guess, and if you're after those 

names on the list, you might be coming up 

quickly. 

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So, Amber, if you could start with 

your name and affiliation for the record? 

MS. POOL: Hi, this is Amber Pool and 

I work for CCOF in the Farm Certification 

Department. 

I want to thank the Board for, once 

again, giving us this opportunity to speak and 

comment through the webinar. 

CCOF is a nonprofit organization 

governed by the people who grow and make food. 

Started in California more than 40 years ago, to 

be our roots, spread the breadth of North 

America. 

We are supported by an organic family 

of farmers, ranchers, crop dusters, retailers, 

consumers and policy makers. 

Together, we work to advance organic 

agriculture for a healthy world. 

After working with certified organic 

growers at CCOF for more than 12 years, I wanted 

to let the Board know that the color requirements 

for adding the USDA organic seal to packaging is 

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a financial hardship for farmers. 

In modifying Section 205 bringing 311 

in to allow the USDA organic seal to be used in 

any foreign color, not 5A, it improves the use of 

this seal when considering the cost of compliance 

for farmers. 

The current limitations to only black 

in terms of the one color printing is the USDA 

seal is not or cannot be used on plastic or a 

package that is not black. 

To place the seal, certified 

operations must upgrade to two colors. This 

limits the use of the USDA seal on many produce 

cartons and other boxes. 

The modification of 205.311 to allow 

any single color would reduce the cost in the 

production system in crops that meet the 

certification and represent a reduction in 

regulatory burden for farmers. 

Thank you and those are my comments. 

CHAIRPERSON CHAPMAN: Thank you, 

Amber. 

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 Any questions for Amber? Hearing none, 

thank you. 

Jaydee Hanson, have you been able to 

call back in yet? 

MR. HANSON: I have. 

CHAIRPERSON CHAPMAN: All right, 

Jaydee. Hold on one second, I'm going to run 

through the list again of folks after you, but we 

do have you on the line now. 

So, after Jaydee, I'm going to turn 

through a long list because we haven't confirmed 

about the next seven or so folks. So, will the 

next after Jaydee is Ronald Gonzales, then Jamie 

Barron, Timothy Opiela, Tonda Fernando, Harold 

Lyles, Jean Marie Gore Traore, Inita Patton. 

The next one, we have confirmed on the 

line, so just to give a heads up, Suzanne 

McMillan, just so you know, you might actually 

come up really quick. 

With that, Jaydee, can you start with 

your name and affiliation for the record? 

MR. HANSON: I'm Jaydee Hanson, Senior 

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Policy Analyst at the Center for Food Safety. 

You have extensive comments from us. 

I'm just going to focus on two parts. First, 

silver dihydrogen citrate. 

The Center for Food Safety urges NOSB 

to reject Pure Bioscience's petition to add 

silver dihydrogen citrate to the national list. 

Even with the recommended annotation, 

we have substantial concerns regarding 

nanoparticles as well as the environmental and 

human health impacts of the over use of silver 

antimicrobials in food and farming. 

We think that silver dihydrogen 

citrate is incompatible with the sustainable 

agriculture and should not be allowed. 

While the company states their 

specific product does not contain silver 

nanoparticles, we iterate our concern that 

citrate is typically used in combination with 

silver for the purpose of controlling the size 

and shape of silver nanoparticles which increase 

the efficacy of the silver ions into microbial 

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properties. 

In fact, just last week, I heard Dr. 

Timothy Duncan, an FDA research chemist raised 

this question on the effects of citrate in silver 

compounds at the national nanotechnology 

leadership meeting on environmental effects of 

nanoparticles. 

So, even if the particle size of the 

specific product is at that size that the company 

claims, we still think it's incompatible with our 

organics because of the way the citrate will 

interact with the ion silver. 

We provided in our April 2018 comments 

a longer discussion of this. 

Basically, silver nanoparticles work 

to slow the release of ionic silver and increase 

its efficacy, in effect, make it a more powerful 

pesticide. 

The potential discharge or spread of 

silver in the environment will negatively impact 

microbial life in waterways. Moreover, research 

at Duke University meets another thousands of 

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plants dosed with nano silver demonstrates that 

some plants are especially prone to damage from 

nano silver. 

So, basically for two reasons, we're 

urging the --

CHAIRPERSON CHAPMAN: Thank you, 

Jaydee, we're at the agreement. We'll see if we 

have any questions from the Board. 

Any questions for Jaydee? 

MEMBER BRADMAN: This is Asa. 

I had a couple questions about the --

is there any evidence or information perhaps in 

your review about contaminated soil and the 

activity in the tampering. 

And then, just to clarify, how much 

you have the information that you talked about 

now in more detail in the written comments? 

And, in the comments, do you talk 

about the same things in the written comments? 

MR. HANSON: Could you repeat the 

question? I'm on a cell phone now. 

MEMBER BRADMAN: I'm sorry, a two part 

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question. 

One, do you have information about 

soil contamination and then, two, are there any 

comments that you made just now verbally that are 

not in the written comments? 

MR. HANSON: Only the reference to 

conductors of the recent research. 

The one thing, though, that is not in 

there is, I'm the U.S. Co-chair of the 

Nanotechnology Committee for the Trans-Atlantic 

Consumers' Dialogue. 

And, in Europe, the European 

Parliament has modified the European Commission 

proposal on EU organic standards to clearly 

exclude nanomaterials. 

So, that's in our comments, but, yeah, 

I think it's important that we do what we can to 

maintain compatibility between EU and U.S. 

organic standards. 

CHAIRPERSON CHAPMAN: So, Jaydee, can 

you help me understand why the proposed 

annotation is not sufficient to mitigate your 

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nano, your specific nano concerns? 

MR. HANSON: Well, I mean, it's not 

sufficient because it's -- you're basically, if 

you will, expecting this material to stay as a 

silver ion by using citrate in the compound. 

If it ends up reducing to nano silver 

particles, which we would argue, should be 

excluded. 

CHAIRPERSON CHAPMAN: So, you're 

saying there's no form of this material that can 

be manufactured with citrate that would not 

contain nanoparticles? 

MR. HANSON: That would not reduce the 

nanoparticles, I don't believe so. There are, 

you know, a couple of references in our comments 

that would point you to the one backdrop and slam 

on the toxicity of silver ions and nano silver 

particles in colloidal silver. 

And, it's, you know, the silver is a 

very toxic substance when you mix it with 

citrate, you actually are making it more toxic. 

So, to answer your question, probably 

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no. 

CHAIRPERSON CHAPMAN: Okay. And then, 

I mean this petition for use as an antimicrobial 

in a sanitizer at some level, those will always 

have to have some level of toxicity to be 

effective in the application. 

So, I know you were --

MR. HANSON: Silver and --

CHAIRPERSON CHAPMAN: -- of that. So, 

what -- like, how do you suggest, you know, a few 

ways the needs of providing safe foods with the 

inherent incompatibility between any level of 

environmental and health issue with a different 

type of sanitizer? 

MR. HANSON: Well, you're going to 

have some different kinds of problems with 

metallic citrates or metallic oxides. You know, 

the problem environmentally is twofold. 

Yes, it is an excellent antimicrobial. 

Personally, I think it should be reserved for 

medical uses and not sprayed around farms or 

cutting boards or used in any farm uses. 

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There is a preliminary research 

showing, too, that certain plants are especially 

prone to uptake nano silver and silver ions. 

And so, if you then dump it out, which 

you basically do when you're using it for these 

antimicrobial uses, you're going to have it go 

into certain crops. So, it shouldn't be in food 

and it shouldn't be in waste water and certainly 

be used next to next to absorb it. 

CHAIRPERSON CHAPMAN: And, then, the 

-- I think there was in the EPA review the 

substance they did not find it would cause a 

contamination greater than what's already in the 

background would be far below the background 

levels of silver. And, that's insufficient for 

you, is that correct? 

MR. HANSON: Yes, well, you know, we 

have sued the EPA and actually won on the issue 

of nano silver. The EPA, frankly, has, in many 

cases, and the Judge in our last case agrees with 

me on this, the EPA has, in many cases related to 

nano silver, had a belief based, not a science 

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based policy. 

So, you know, again, there are other, 

you know, I would say to look at the work of 

Timothy Duncan, the FDA's research scientist 

actually looking at this kind of product. And, 

he comes to that conclusion. 

CHAIRPERSON CHAPMAN: And, these folks 

that you've cited, are they in your --

MR. HANSON: Yes. 

CHAIRPERSON CHAPMAN: -- written 

comments? Okay. 

MR. HANSON: Yes, except for the last 

paper on from Duncan and I can send that in. 

CHAIRPERSON CHAPMAN: Yes, could you 

send that to Michelle so we would have a chance 

to --

MR. HANSON: Yes. 

CHAIRPERSON CHAPMAN: -- review that 

as well? Appreciate it. And, I appreciate the 

detailed comments on this, both on the phone and, 

I imagine what's in the written comments. I 

haven't been -- haven't had a chance to get to 

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yours yet, but I definitely will between now and 

the full meeting. 

MR. HANSON: Yes, both this one and 

the longer comments from April. Thank you very 

much. You guys have a lot to go through. 

CHAIRPERSON CHAPMAN: Yes. Not hearing 

any or seeing any. So, Jaydee, thank you for 

your comments. 

MR. HANSON: Okay, thank you. 

CHAIRPERSON CHAPMAN: Okay. So, so 

far, we still haven't gotten any confirmations on 

anyone up until Suzanne McMillan. 

I will run through that list just to 

make sure they're not here, but Suzanne, just be 

prepared, we might be coming to you very quickly. 

So, Roland Gonzales, Roland, are you 

here? 

Roland, going once, going twice. Up next, Jamie 

Barron. Jamie, are you here? Jamie, going one, 

going twice. All right, next is Timothy Opiela. 

Timothy, are you here? Going once, going twice. 

All right, Tonda Fernando. Tonda, are you here? 

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Hearing none, next up is Harold Lyles. Harold, 

are you here? Hearing nothing, next is Jean Marie 

Gore Traore, are you here? 

All right, and then Inita Patton. 

Inita, are you here? All right, that was a huge 

list of folks. So, Suzanne, you were at 11:50, 

so we're about 12 minutes ahead of schedule right 

now. 

Suzanne, let me just check, you're 

here, is that correct? Suzanne, are you hear? 

Are you speaking? If you're speaking, you're on 

mute. 

MS. ARSENAULT: I see Suzanne on the 

line on the web portion. 

CHAIRPERSON CHAPMAN: Yes. 

MS. ARSENAULT: So maybe -- Suzanne, 

maybe it's your mic that's not working. Oh, no, 

I see you using a headset, yes. 

CHAIRPERSON CHAPMAN: Suzanne, are you 

muted? We're not hearing from you. 

PARTICIPANT: Hello? Hello? 

CHAIRPERSON CHAPMAN: Hello, Suzanne. 

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Suzanne, are you there? All right, Suzanne's not 

there. 

Next up would be Marie Burcham. 

Marie, are you there? 

MS. BURCHAM: Can you hear me? 

CHAIRPERSON CHAPMAN: I can, Marie. 

But, hold on, Marie, because now we're fairly 

ahead of schedule. 

And, I don't know if the next people 

are here, either. So, if the -- after Marie 

would be Heidy Lopez-Rodriguez. And after Heidy 

would be Joseph Similanick. 

Michelle, have you confirmed any of 

those folks being on the line? 

MS. ARSENAULT: I have not yet, Tom. 

So, I will do that. 

CHAIRPERSON CHAPMAN: Okay. Marie, 

you're up next if you're ready to go. We can 

start with your name and affiliation for the 

record. 

MS. BURCHAM: Yes, of course. Hello 

and good afternoon. My name is Marie Burcham and 

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I am the Livestock Policy Analyst for the 

Cornucopia Institute. I'm also an attorney with 

a background in natural resource and animal law. 

Members of the Board and the public, 

thank you for the opportunity to speak on the 

material petition of NOSB research priorities. 

Cornucopia supports the NOSB comments 

in their entirety and hopes the NOSB will 

consider beyond pesticide exclusion in this 

matter. 

We specifically oppose the listing of 

the petition substances silver dihydrogen 

citrate, allyl isothiocyanate, and natamycin. 

Cornucopia submitted written comments 

telling why we oppose the listing of these 

specific materials in more detail. 

But, I would like to speak a little 

bit about the livestock research priorities and 

discussion documents on the agenda. 

First, we strongly support evaluating 

the current uses of natamycin on organic farms 

with concerns that direct natamycin is used 

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principally as a production tool rather than a 

dietary supplement essential for animal welfare. 

If accurate, that would not be 

compatible to organic agriculture. 

Poultry get natamycin in their -- from 

their diets and poultry who are raised following 

the spirit and letter of organic law should be 

most, if not all, the natamycin from a varied 

diet supplemented by adequate foraging. 

We also urge -- concern about the use 

of fish meal and animal byproducts, fish meal in 

particular, and it's impacts on fish stock and 

ocean ecosystem health. 

We do support further research into 

parasite prevention measures. This research is 

particularly needed for organic sheep research, 

the biodiveristy of native invertebrates and 

micro organisms should be carefully considered 

during this research as it has applications for 

both human and animal health. 

We also support research into organic 

livestock breeding and we hope that the focus on 

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keeping breeds viable for grass based production 

and true outdoor production will be maintained. 

High production rates of both milk and 

meat should not be the focus of the research. 

The research focus should be on quality of the 

product and healthy livestock animals. 

Again, the agriculture is not premised 

on a price and conventional imports with organic 

imports and so it is preventative soil based 

farming methods that improve soil through 

holistic farming strategies. 

Livestock breed protection is a very 

important piece of the organic label. 

Finally, we are very happy to see even 

more discussions -- more material discussion 

documents but still more work needs to be done on 

this topic as it is not dealt with in the depth 

this topic needs. And, there is much more moving 

forward. 

We do support the wealth of comments 

on this issue. 

Thank you so much for listening to me 

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today and I hope you will consider our written 

comments on these topics as well. 

CHAIRPERSON CHAPMAN: Thank you, 

Marie. 

Any questions for Marie? Not hearing 

or seeing any, thank you for your comments. 

MS. BURCHAM: Thank you. 

CHAIRPERSON CHAPMAN: Suzanne, are you 

on the line with us now? 

MS. MCMILLAN: Yes, can you hear me? 

CHAIRPERSON CHAPMAN: Yes, and hold on 

one second, Suzanne. 

MS. MCMILLAN: Thanks. 

CHAIRPERSON CHAPMAN: So, I'm told 

that there's someone speaking that I may have 

skipped over before. We've got the name of one 

of the speakers that I read out. 

Ronald, Jamie, Timothy, Tonda, Harold, 

Jean Marie or Inita, any of these folks on the 

line now? 

Okay, not hearing any of those, so, 

after Marie, or sorry, after Suzanne, then I have 

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Heidy Lopez-Rodriguez, Joseph Similanick, Michael 

Forrest, Frankie Thorn and then Linley Dixon. 

I don't have any of those folks except 

Linley Dixon confirmed to be on the line. So, 

Linley, just a heads up that you might be coming 

to you quickly. 

And, if any of you folks that I 

skipped over are here, please message us so we 

can come back to you. 

Suzanne, you're up next, if you could 

start with your name and affiliation for the 

record? 

MS. MCMILLAN: Thank you. 

Hi, I'm Suzanne McMillan, Content 

Director for the ASPCA Farm Animal Welfare 

Program. 

Thank you for the opportunity to 

provide comments to the NOSB on behalf of the 

ASPCA and our millions of supporters nationwide. 

The written comments we submitted 

focused on NOSB's livestock research priority, 

particularly the goal of breeding animals adapted 

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to outdoor life and living vegetation. 

So, I'll just reiterate some of our 

points here today. 

We thank the NOSB for addressing the 

critical issue of livestock and poultry genetics, 

something we've urged through comments for a 

number of years now. 

Reforms to policies related to animal 

genetics are critical for ensuring adequate 

welfare for animals raised organically as well as 

consumer confidence in organic animal products. 

Genetics serve as the cornerstone to 

animal health and welfare. They inform immune 

function, the ability to manage environmental 

stressors and a wide range of physical abilities 

down to basic locomotion. 

The vast majority of U.S. farm animals 

are selectively bred for high yields of meat, 

milk and eggs. This brings welfare tradeoffs, 

some of which are detailed in our written 

comments. 

So, the point I want to make here 

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today is that none of this should be surprising. 

The scientific principle of resource allocation 

written about by Temple Grandin among others, 

dictates that animals have various biological 

functions, such as maintenance, growth, 

reproduction as well as general health and well 

being. 

The resources in animals has available 

to devote to all of these functions in total are 

finite. And so, their resources must get 

distributed across all of them. 

A healthy animal will naturally find 

this balance, but if breeding programs 

overemphasize only one or a few of these 

biological traits, as has happened in the U.S. 

with our excessive breeding of livestock and 

poultry for production traits such as milk volume 

and muscle mass, then the other functions must 

necessarily suffer as a result. 

Environmental stressors can further 

skew the scaled balance, draining resources from 

these critical areas. This is why we see animals 

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that may appear robust thanks to their ability to 

turn out large volumes of eggs or produce heavy 

cuts of meat, but they struggle to simply breathe 

or walk or to fight off infections and to deal 

with any stressors such as weather extremes and 

transport. 

These unbalanced genetics now dominate 

U.S. farm animal populations and it appears that 

a good number of animals raised organically are 

sourced from these same gene pools, leaving them 

vulnerable to identical problems. 

This is compounding by the organic 

programs lack of comprehensive animal welfare 

standards which could help mitigate environmental 

stressors and overall health and well being 

challenges. 

Millions of organic animals still 

contend daily with realities like crowding, poor 

ventilation, barren environments, lack of 

sunlight and lack of outdoor access. 

We look forward to working with the 

NOSB to identify meaningful standards for 

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stronger genetics that can support all animals 

raised organically. 

We appreciate your consideration. 

Thank you very much. 

CHAIRPERSON CHAPMAN: Thank you. 

Any questions for Suzanne? Again, 

thank you for your testimony here today. 

Roland, you're here, we're just having 

a hard time connecting with you. Can you try to 

talk again to see if you're unmuted? 

MS. ARSENAULT: Ronald, this is 

Michelle, we're still not hearing you. 

CHAIRPERSON CHAPMAN: I'm hearing the 

typing of numbers, are you typing -- hold on. 

MR. GONZALES: I'm trying. 

CHAIRPERSON CHAPMAN: We hear you. 

MS. ARSENAULT: We can hear you, 

you're a little faint. 

CHAIRPERSON CHAPMAN: You're a little 

faint, so you have to speak up. But, hold on one 

second, I'm going to go through the people who 

are on deck and then we'll come back to you. 

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So, if these folks are here, they'll 

be next, Heidy Lopez, Joseph Similanick, Michael 

Forrest, Frankie Thorn and then Linley Dixon. 

Ronald, if you can start with your 

name and affiliation and go into your comments. 

MR. GONZALES: I apologize for all the 

technical problems. I've been trying to connect 

for a while. 

Well, good afternoon, my name is 

Ronald Gonzales, I am the manager of the Resource 

Department of Dole Pineapple Division in Costa 

Rica. 

I truly appreciate the opportunity to 

address members of the Board. 

The direct issue that is of great 

importance for the organic pineapple producers 

that commercialize their fruit in the U.S. 

market. 

I would like to make a comment to 

support the use of ethylene gas to induce 

flowering in certified organic pineapple 

production. 

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First, I would like to refer to a 

practice in the use of ethylene gas is used for 

years in pineapples. 

We have not found any viable 

alternative in the nation. We have consulted 

specialists from companies that make products who 

are using safe bio organic pineapple production. 

And, we have not been advised of any 

alternative that we are now aware of to replace 

the use of ethylene gas. 

Recently, two --[AUDIO DIFFICULTIES, 

SPOKE ABOUT ETHYLENE FOR PRESERVING PINEAPPLES]--

- took place at University of Costa Rica National 

University --[AUDIO DIFFICULTIES, SPOKE ABOUT 

ETHYLENE FOR PRESERVING PINEAPPLES] -- Costa Rica 

have started to research work to experiments 

carried out by scientists in Taiwan, in France, 

looking for alternatives to the use of ethylene 

gas for flowering in organic pineapples. 

These studies have already become --

[AUDIO DIFFICULTIES, SPOKE ABOUT ETHYLENE FOR 

PRESERVING PINEAPPLES] -- of ethylene and 

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consequently causing floral depreciation by 

subjecting plants to stress for a short period of 

time followed by the application of high ethylene 

as well as the application of ice cubes. 

We hope that the very narrow resource 

of these --- [AUDIO DIFFICULTIES, SPOKE ABOUT 

ETHYLENE FOR PRESERVING PINEAPPLES] -- will be 

available for presentation to the board today. 

I have been informed that the 

application of ice water and ice cubes did not 

induce flowering in treating plants. And, if 

these results become available, understanding 

that they will be presented before you next week. 

On the other hand, I would like to 

turn to the possibility of cultivating pineapple 

varieties for which the use of ethylene gas to 

induce flowering is not necessary. 

In a categorical way, it can -- [AUDIO 

DIFFICULTIES, SPOKE ABOUT ETHYLENE FOR PRESERVING 

PINEAPPLES] -- of usage carried by Dole's genetic 

improvement tools, not a single variety has been 

obtained for which the use of ethylene is not 

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strictly necessary. 

Therefore, the organic people at Dole 

issued out --[AUDIO DIFFICULTIES, SPOKE ABOUT 

ETHYLENE FOR PRESERVING PINEAPPLES] -- pineapple 

for which they use the ethylene gas is not 

required to induce flowering ---[AUDIO 

DIFFICULTIES, SPOKE ABOUT ETHYLENE FOR PRESERVING 

PINEAPPLES]. 

Therefore, the company encourage the 

members of the NOSB Committee to maintain 

approved use of the ethylene gas as a floral 

inducer in the production of organic pineapples. 

The introduction of these inputs would 

have significant impacts on the ---[AUDIO 

DIFFICULTIES, SPOKE ABOUT ETHYLENE FOR PRESERVING 

PINEAPPLES]-- breeding in large climates with the 

CHAIRPERSON CHAPMAN: Ronald, we've 

reached the three minute mark, if you can wrap up 

your comments. 

MR. GONZALES: Okay. So, those would 

be the two comments I wanted to make. Thank you 

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so much for your time. 

CHAIRPERSON CHAPMAN: Thank you, 

Ronald. 

Any questions for Ronald from the 

Board? 

COURT REPORTER: I'm sorry to 

interrupt. Hello? This is the Court Reporter. 

CHAIRPERSON CHAPMAN: Hello? 

COURT REPORTER: Mr. Ronald Gonzales, 

his phone sounds to be on speaker. It won't be -

- it won't make a clear record. 

 MS. ARSENAULT: Okay, thanks. So, we 

can talk offline about that, thank you. 

CHAIRPERSON CHAPMAN: Yes, that's fine. 

Okay, Ronald, I'm not hearing any questions from 

the Board, so thank you for your time. 

So, I'm going to read those --

MR. GONZALES: Yes, so --

CHAIRPERSON CHAPMAN: Thank you very 

much. 

MR. GONZALES: -- much, I apologize, 

I was in the speaker. I hope you guys could hear 

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what I had to say. 

CHAIRPERSON CHAPMAN: Thank you. 

I'm going to go down the list of 

speakers who we still haven't been able to 

identify. 

So, Heidy Lopez-Rodriguez, are you 

here? 

Joseph Similanick, are you here? Michael Forrest? 

Frankie Thorn, are you here? All right, Linley 

Dixon, are you here? 

MS. DIXON: I am. 

CHAIRPERSON CHAPMAN: All right, 

Linley, hold on one second. 

After Linley is Brian Bates who we see 

is on the line as well. So you're up next. 

And then, after Brian is Miraj Patel 

and that is the end of our list. 

So, at that point, we'll run through 

the list again, but if no one's here, we will 

then be wrapping up this webinar. 

So, Linley, if you could start with 

your name and affiliation for the record? 

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MS. DIXON: I'm Linley Dixon, 

Associate Director of Real Organic Project. 

As many of you know, the Real Organic 

Project is a farmer driven effort to get organic 

standards back in line with the law. 

A few things have become painfully 

apparent to many in the organic community. 

First, there are major differences in 

how certifiers are interpreting the law, 

encouraging certifier shopping. 

Second, in some cases, the NOC process 

for continuous improvement is not functioning as 

it was intended. 

And, third, enforcement of the NOP's 

position, giving an unfair advantage to 

operations and ACAs that are following that. 

We should develop the creation of an 

add-on label. Farms that are qualified for the 

add-on of fostering soil fertility and pasture 

access including poultry. 

These are practices that we feel are 

inherent to the word organic and the integrity of 

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the label. 

As NOC members, we urge you to make 

the Real Organic Project obsolete by continuing 

to work to prohibit hydroponics and propose the 

still standing 24 recommendation and the 

requirement and access and soil fertility. 

We urge you to continue to advocate 

for strong animal welfare standards, to fight the 

rejection of the OICP or the SPA. 

Our standards are created by the 

gallant efforts of experts in the organic 

community and include much of what the organic 

community has been lobbying for for over a 

decade. 

We have standards reflecting soil 

fertility, origin of livestock and pasturing 

poultry. 

The standards are published on our 

website along with information on how to provide 

feedback and we welcome input. 

We visited over 50 organic farms this 

summer that wanted to participate in our pilot 

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project. Farmers not only provided us feedback 

on our standards, but they reinforced concrete 

needs to differentiate real organic practices 

under the seal. 

Most of these farms have had a 

significant shift from the organic wholesale 

marketplace. 

Our certified farms have the 

opportunity to tell others what organic farming 

is all about through the farmer interviews on 

their farm. 

Every operation showed a deep 

commitment to continuous improvement and the 

sustainability of all their farm systems. 

Farmers shared knowledge about how to 

generate fertility on the farm and reduce the 

need for unsustainably sourced off farm imports. 

Their voices are a striking contrast 

to the certified organic farms whose systems 

completely depend on imported grain or hydrolyzed 

protein or fish harvested from the sea. 

The willingness of farmers to be 

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completely open and transparent about the details 

of their practices is in line with the spirit of 

organic farming. 

Their practices are in line with the 

organic law as it is written. 

If you are a member of the organic 

community and refuse to sit back and watch as the 

majority of organic farms meeting the letter of 

the law struggle to complete against the tiny 

minority of operations that will, please join us. 

Thank you for listening and your 

volunteered time. 

CHAIRPERSON CHAPMAN: Thank you, 

Linley. 

Any questions for Linley? All right, 

hearing none, up next is Brian Bates. Brian, are 

you on the line with us? 

MR. BATES: I am, can you hear me? 

CHAIRPERSON CHAPMAN: Yes, I can. 

Brian, you're up and then up next is 

Miraj Patel. 

Brian, if you'd start with your name 

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and affiliation for the record? 

MR. BATES: Sure. My name is Brian 

Bates. I am the owner and primary operator of 

Bear Creek Organic Farm in Northern Michigan. 

And, I want to thank you for the 

opportunity to speak today. 

My comments pertain to the potential 

ban of the Japanese paper pot transplanter. 

We are a 100 percent USDA certified 

organic farm for the last six years. Prior to 

starting this farm, we studied organic 

agriculture at Penn State and helped author the 

organic crop production guide. 

Can you hear me? I'm hearing 

background noise. 

MS. ARSENAULT: Yes, can you -- people 

on the line -- can people who are not speaking 

please mute yourself, we're hearing the 

background conversation. Thanks. 

All right, go ahead. Thanks. Sorry 

about that. 

MR. BATES: That's okay. 

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And, one of the things that we've 

learned in trying to be committed to organic crop 

production since the get-go is trying to navigate 

the balance in our current agriculture between, 

you know, what is truly sustainable versus who 

just meets the bare minimum organic rule and, you 

know, what sort of embraces the true intent. 

And so, being schooled from the early 

pioneers of true organic agriculture, one of the 

reasons that we use the paper pot system is 

because all of the farms that we worked on after 

completing studies at Penn State extensively used 

black plastic mulch on their farms which was 100 

percent synthetic, annual use, making contact 

with the soil and with crops and would break down 

by the end of the seasons and was not organic in 

any way whatsoever. 

We then set out to start our own 

business that would not use any black plastic 

mulch, though it was completely allowed to try to 

farm more in harmony with nature and with what 

the founders of the organic movement would have 

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wanted. 

When we came across the Japanese paper 

pot system, it radically changed our operation 

from an ecological economic and labor standpoint. 

One of the things that the paper pot 

planter has done for us that's most important in 

our minds is it has allowed us to hire more 

skilled labor, spend less time doing menial tasks 

and maximize our efficiency, both in the 

greenhouse and in the field. 

Not only has it improved our labor 

savings, but doing so, it has allowed us to tap 

into organic market share that was previously 

unattainable. 

We've been able to lower the cost of 

our prices of our top products. And, within one 

year, every product that we grew with the paper 

pot transplanter became cash positive when it 

previously was not. 

Our concern is that we were given 

extremely short notice to stop using the paper 

pot planter which has been used for over a dozen 

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years, wholly certified in the United States. 

And, with not enough time for a proper 

review, which we completely support by the USDA 

and the Organic Materials Research Institute. 

We are forced to either face our first 

year of negative growth in 2019, layoff some of 

our staff in 2019 and forego several thousand 

dollars of inventory and materials for systems 

built around this tool. 

It is no joke that we have told our 

staff, if this tool is not approved, they will 

have to consider finding other work. 

I think I hear my beeper, maybe not. 

MS. ARSENAULT: It actually --

MR. BATES: And so --

MS. ARSENAULT: Sorry, Brian, it was 

the timer going off. Sorry. 

MR. BATES: Okay, all right, fine. 

Yes, no worries. 

CHAIRPERSON CHAPMAN: No, Brian, 

sorry. Let me -- because the NOSB interrupted 

you before, you have a couple left for comments, 

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go ahead. 

MR. BATES: That's fine. 

All I would like to say is that, we 

are committed to organic agriculture without a 

shadow of a doubt. We've help work with our 

certifiers on a number of issues. We've helped 

first-wave farmers in our area over a dozen 

become certified organic in the last five years. 

We are not trying to wiggle out of 

anything with a tool like this. But, we've seen 

farms where black plastic is totally permitted 

who never get all the plastic out of the field. 

And, when we use this biodegradable 

paper product, just because it's not recycled 

newsprint or cardboard, you can't see any 

evidence of it within months. 

So, we are firmly convinced that the 

net positive from this tool which has no moving 

parts and no engines and burns no fossil fuels 

far outweighs a number of other tools that are 

widely accepted. 

So, what we're hoping is for at least 

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a stay to pause the suspension of this tool so 

that there's more time to properly review it 

because we're confident that with the proper 

review, this would not be something that you 

would look to ban in the organic community. 

Thank you. 

CHAIRPERSON CHAPMAN: Thank you. 

Thank you, Brian. 

Any questions from the Board? 

MEMBER ELA: Tom, I have a question. 

CHAIRPERSON CHAPMAN: Sure, go ahead. 

MEMBER ELA: Brian, I would like to 

just thank you for calling in and particularly 

for your clear articulation of the adverse 

impacts of losing the paper pots on your 

operation. 

And, also juxtaposing the use of paper 

pots against the alternatives or one of the 

alternatives which is the use of plastics. I 

think it's a great point that you make. 

One of the things that the Board, I've 

found in discussing this with the NOP is that, 

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there's the perception that, you know, that 

they're not hearing a lot about the need for 

paper pots. So, your call has been helpful and 

if we can encourage some of your colleagues also 

to speak up about this, it could help sway the 

decision about the state of the paper pots in the 

near term. 

MR. BATES: I appreciate that 

feedback. This is probably the most vocal I've 

been on some kind of regulatory issue affecting 

our farm, second only to the Food Safety 

Modernization Act which we're widely in 

supportive and have helped other growers around 

us implement and get acclimated to over the last 

half dozen years. 

I think a lot of growers feel like 

they're too small and that the process is too big 

to stop. And, I refuse to believe that that's 

the case because I think one thing that is 

profoundly unique about the paper pot system is 

that it is only used by small farms and it only 

benefits small farms. 

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 Once you achieve a certain size, the 

tool is both irrelevant and not functional. 

So I think that's one of the unique 

challenges with this, is it's not widely 

scalable. We're seeing many conventional growers 

exploring plant tape based systems such as the 

ones that they're bringing over from Spain. 

But, I think in the grower community, 

banning something like the paper pots has felt 

like a particular attack on small growers. 

And, I guess I could see why that 

might be the case because this tool, other than 

something like a hoop house has been the most 

profound innovation on our farm since we've 

started. 

So, I really appreciate that feedback 

and this is definitely the first time I've 

actively engaged in this process, but it's 

something that I think the voice is strong, it's 

just so small, unfortunately. 

MEMBER ELA: Thank you, Brain. 

DIRECTOR LEWIS: Brian, this is Paul, 

Neal R. Gross and Co., Inc. 

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if you want to clarify one thing, and I do 

realize that, from your perspective, this is 

going to have an economic impact on you if it 

stands the way it is right now. 

And, I understand the prospective 

you're coming from. But, it is somewhat a 

logistical issue or a regulatory issue, it's not 

that we're looking to ban something, it's that 

potentially something was allowed that shouldn't 

have been allowed in the first place without 

going through the proper channels. 

I know that seems like a really small 

gray area, but when you expand that to the impact 

it could have on any operation due to the 

potential use for what would be a synthetic item, 

it could have some implications there. 

So, I know for your specific 

operation, that kind of regulatory speak probably 

doesn't give you much reassurance, but just so 

you know, we're not looking to ban this tool on 

small operators, rather it's just it didn't go 

through perhaps the proper channels to get 

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approved in the first place. 

MR. BATES: That sounded definitely 

clear and I appreciate you saying that. That's 

something that we actually stayed back on the 

sidelines for the first two years of its growing 

popularity concerned that it wasn't totally 

certifiable. 

But, it seemed to sort of start 

receiving unanimous approval for many certifiers 

and so we then did decide to take the plunge. 

But, I totally understand what you're 

articulating and I think most growers also 

understand that. 

I think it is the bureaucratic nature 

of this process that has made it challenging. 

And, I think the confusion on sort of virgin 

paper versus recycled paper has caused some 

consternation amongst growers who are able to use 

recycled paper all over the place, but then not, 

you know, virgin paper in a tool like this. 

DIRECTOR LEWIS: Yes, yes, fair enough 

and that's a good point. And, like I said, I 

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appreciate the impact that this has on your 

operation. That's not going unnoticed. 

CHAIRPERSON CHAPMAN: Any other 

questions from the Board? 

MEMBER OAKLEY: Yes, Tom, this is 

Emily. 

I just wanted to tell Brian that I 

really thank you for your comments and agree with 

Dave that you succinctly echoed a lot of what we 

discussed on the Crops Subcommittee calls. 

And, I had one question which is, when 

were you informed about the 2018 December 

deadline? 

MR. BATES: We were informed, I 

believe, it was I want to say March or April. We 

first heard about it on Facebook from another 

grower who was certified by another certifier. 

And then, it was included in our certifier's 

newsletter in, I'm going to say maybe April. 

Just ironically, about a month after 

we had just purchased $6,000 of new inventory for 

this tool system. But, so that's what makes me 

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think April because we've been drawing it prior 

to that. So, I would say April. 

MEMBER OAKLEY: Thank you. 

CHAIRPERSON CHAPMAN: Any other 

questions for Brian? All right, Brian, thank you 

for your comments here today. 

Thank you, up next is Miraj Patel. 

Miraj Patel here? Miraj, going once. Going 

twice. Okay, I sent out a broadcast to folks and 

we haven't heard any messages back. So, I'm 

going to run through the list of names and if 

someone's here, then we'll go to them. If not, 

then we'll be completed with this webinar. 

So, going down the list from the top, 

first is Corellia Johnson. Corellia, are you 

here? Hearing nothing, Ari Davis, are you here? 

Jamie Barron, are you here? Timothy Opiela, are 

you here? Tonda Fernando, are you here? Harold 

Lyles, are you here? Jean Marie Gore Traore, are 

you here? Inita Patton, are you here? 

Heidy Lopez-Rodriguez, are you here? 

Joseph Similanick, are you here? Michael Forrest, 

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are you here? Frankie Thorn, are you here? And, 

back to Miraj Patel? 

Okay, it looks like we have now 

completed all the commenters who are present for 

the Tuesday webinar before the fall meeting. 

We'll fall into recess and come back 

on Thursday for the second of the two public 

webinars and that will be at, what, Thursday at 

1:00 p.m. Eastern Time, is that right, Michelle? 

 MS. ARSENAULT: That's correct, 

thanks. 

CHAIRPERSON CHAPMAN: All right, thank 

you again for all the commenters for your time. 

It's been very valuable to the process and I 

appreciate the Board for their thoughtful 

consideration and questions. 

And, I look forward to talking to 

folks on Thursday. Take care. 

(Whereupon, the above-entitled matter 

went off the record at 3:15 p.m.) 

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choy 64:12 

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class 8:8 

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cliff 68:2 

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climates 107:16 

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Co-chair 87:9 

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Coalition 21:16 54:1 

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95:14 97:20 98:2,6 

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114:7 117:22 124:8 

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87:13 

commitment 112:13 

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community's 55:17 

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113:1 115:20 117:3 

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58:5,13 82:5 

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84:18 96:10 116:20 

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concerns 22:21 24:18 

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conclusion 91:6 

concrete 112:2 

conduct 74:6 

conducted 50:8 51:4 

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conductors 87:7 

confidence 100:11 

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confined 29:7 

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confirmed 83:11,16 

94:13 99:4 

confused 46:18 

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Congress 54:6,9 

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76:2 

conservationists 51:10 

consider 15:17 95:9 

98:1 117:12 

considerable 16:1 

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considered 16:19 78:3 

96:18 

considering 18:10 41:5 

82:5 

consistency 41:12 

consisting 42:2 

consternation 123:18 

constituents 37:21 

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construction 14:3 

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45:18 46:3,10 47:15 

consult 5:22 

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consumer 20:13 49:8 

100:11 

consumers 27:11 51:13 

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consuming 20:19 

contact 115:14 

contain 84:17 88:12 

contains 35:17 42:7 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
130 

contaminated 46:7 

86:13 

contaminates 17:11 

contaminating 42:17 

contamination 14:22 

15:12,14 87:3 90:13 

contend 77:21 102:18 

Content 99:14 

context 54:5 

continually 77:5 

continue 22:3 75:4 

111:7 

continuing 111:3 

continuous 110:12 

112:13 

contract 61:11 

contractors 42:11 

contrast 112:18 

contribute 39:18 

controlling 74:19 84:20 

conventional 15:22 

28:13 29:1 30:3 46:9 

97:8 121:5 

conversation 41:6 66:9 

114:19 

conversations 69:13 

convert 49:7 

converted 49:17 

convey 39:12 

convinced 118:17 

Cool 28:11 

Coordinator 13:16 

Corellia 44:11 48:17 

52:19 53:2,3,9 125:15 

125:15 

corn 15:1,3 60:7 

cornerstone 100:12 

Cornucopia 95:2,7,14 

correct 35:10 90:16 

93:10 126:10 

cost 82:5,16 116:15 

Costa 104:11 105:13,15 

Council 63:22 

Council's 20:14 

countries 34:5 

county 37:13 38:13,15 

couple 22:9 76:17 79:3 

86:11 88:15 117:22 

course 68:12 94:21 

Court 108:6,7,9 

cover 26:19,19 50:22 

covered 13:1 

covers 27:14 

cows 43:8 

crack 58:21 

created 111:10 

creates 22:21 

creation 51:14 74:11 

110:17 

Creek 114:4 

criteria 68:13 

critical 19:15 37:17 

38:17 51:15 100:5,9 

101:22 

crop 21:1,4,12 31:6 

47:11 61:11 81:15 

114:13 115:2 

crops 29:3 60:6 64:10 

67:16 70:10 76:5 

82:17 90:7 115:15 

124:10 

cross 43:7 

crowding 102:18 

cubes 106:4,10 

cultivating 106:15 

cumbersome 62:7 

cured 74:21 

current 20:13 67:4 

71:22 73:1,5 82:7 

95:21 115:4 

currently 20:22 21:10 

21:11,19 22:3 23:12 

72:22 76:19 77:3 

customer 5:1 

cuts 102:3 

cutting 89:22 

cycles 38:9 

D

daily 102:18 

dairy 38:11 63:20 

Dakota 38:4 

damage 86:2 

Dan 1:20 9:13,15 10:2 

data 55:1,2,4,6,7,10,12 

55:13,15 56:7 57:15 

58:4,6,13 59:7,12 

60:1,9,11 62:17,22 

database 55:16 58:9 

59:4 

Dave 1:18 8:19,21 

124:9 

Davis 52:20 53:17 63:4 

125:16 

day 20:15 22:20 43:14 

de 1:15 8:10,11 

de- 43:2 

deadline 66:11 67:11 

73:9 124:13 

deadlines 64:4 

deal 57:8 68:12 70:9 

102:4 

dealing 29:2,17 59:22 

dealt 29:8 97:17 

death 47:18 

Deb 7:2 

debate 66:19 

decade 111:14 

December 64:4 66:10 

124:12 

decertified 14:14 

decide 123:10 

decision 120:6 

deck 10:21 30:18 

103:22 

deep 47:7 112:12 

define 37:21 38:2,3 

defined 29:7 

definitely 27:5 71:3 

92:1 121:17 123:2 

definition 24:13 

degraded 32:11 

delivery 15:5 

demand 43:5 

demonstrate 4:19 

demonstrates 86:1 

Department 1:1 81:5 

104:11 

depend 19:20 112:20 

depreciation 106:1 

depth 47:5 97:17 

Deputy 69:16 

derivative 33:7 34:18 

desk 49:20 

destabilize 42:4 

destruction 50:4 

detail 21:2 69:17 70:2 

86:17 95:16 

detailed 28:10 91:20 

100:20 

details 113:1 

deter 55:17 

determine 49:16 61:18 

determining 72:21 

develop 17:21 110:17 

developed 19:9 

developing 60:18 

development 37:19 

41:2,9,10 

Devon 2:15 68:5 

devote 101:9 

dial 3:11 

Dialogue 87:11 

dictates 101:4 

diet 96:9 

dietary 96:2 

diets 96:6 

difference 61:1 

differences 110:8 

different 27:9,10,10 

28:4 45:9,22 59:3 

60:4 71:3 89:13,16 

differentiate 112:3 

differently 43:20 

difficult 24:11,21 25:9 

58:20 

difficulties 15:3 105:11 

105:14,21 106:6,19 

107:3,7,15 

difficulty 25:6 

dig 27:1 

dihydrogen 84:4,7,13 

95:12 

dilemma 68:3 

diligence 61:17 

dimensional 51:2 

direct 95:22 104:15 

directly 34:15 76:13 

Director 2:11 5:9,10 

53:22 69:3,7,10 74:2 

99:15 110:2 121:22 

123:21 

dirty 36:19 

discharge 85:19 

disclose 11:9 

discourage 60:11 

discuss 73:7 

discussed 66:5 124:10 

discussing 18:21 

119:22 

discussion 17:19 19:2 

22:11 85:14 95:19 

97:15 

discussions 97:15 

disease 74:18 76:12 

dissecting 45:13 

distributed 101:11 

diversified 56:4 59:18 

60:9 

Division 2:12,16 5:11 

6:16 104:11 

Dixon 99:2,4 104:3 

109:10,11 110:1,1 

docket 40:22 

document 17:19 19:3 

22:11,20 

documentation 46:20 

50:5,13,18 51:1,6 

documents 95:19 97:16 

doing 38:1 50:15 65:1 

77:3,5 116:8,12 

Dole 104:11 107:2 

Dole's 106:20 

dollars 117:8 

domestically 59:1 

dominate 102:7 

dosed 86:1 

doubled 64:22 

doubt 118:5 

Doug 36:5 40:6 44:10 

44:13,14,17,21 45:5 

48:8,9,13 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
131 

dozen 116:22 118:7 

120:15 

dozer 46:7 

Dr 2:11 69:16 73:9 74:1 

75:7 85:2 

draft 49:13 52:9 

draining 101:21 

dramatic 38:7 

drawing 125:1 

Driac 37:12 

dried 33:14 61:13 

drilling 46:22 

driven 110:4 

dropped 68:6 

dry 43:5 

due 15:3 61:16 68:16 

68:21 122:14 

Duke 85:22 

dump 90:4 

Duncan 85:3 91:4,13 

dusters 81:15 

dynamite 47:1 

E

early 8:8 19:17 115:8 

easier 3:22 10:8 62:9 

Eastern 45:10 126:9 

easy 31:15 

eat 43:9 

echoed 124:9 

ecological 13:17 37:8 

40:14 116:4 

economic 55:2 57:18 

116:4 122:3 

economically 76:4 

ecosystem 49:17 52:2 

96:13 

ecosystems 49:7 

effect 85:17 

effective 89:6 

effects 32:9 85:4,6 

efficacy 66:20 84:22 

85:17 

efficiency 116:9 

efficient 64:18 

effort 17:14 58:21 110:4 

efforts 14:21 50:6 56:13 

74:13 111:11 

eggs 100:19 102:2 

eight 60:3 

either 12:12,16 52:3 

62:4 66:12 94:10 

117:5 

Ela 1:16 8:13,14 24:6 

27:18,21 30:4,10 

66:14 68:9 70:8 71:14 

71:19 119:10,12 

121:21 

eliminate 49:6 

embraces 115:7 

Emily 1:19 8:22 9:2 

24:7,20 26:15 66:4 

69:12,17 71:16 72:13 

124:6 

empathize 73:2 

employees 58:2 65:7,9 

65:15 

employment 65:20 

encompasses 25:7 

29:11 

encountered 25:5 

encountering 25:5 

encourage 11:12 76:7 

107:9 120:4 

encouraging 110:10 

ends 88:6 

energy 13:21 14:3,16 

18:7 41:1 

enforcement 54:20,21 

55:22 110:14 

engage 42:21 

engaged 121:18 

engines 118:19 

enhancing 22:18 

ensure 15:6 16:2 45:20 

56:2 

ensures 50:3 

ensuring 100:9 

entire 12:18 

entirety 95:8 

environment 22:19 

27:7 32:10 50:4,7 

85:20 

environmental 15:20 

24:18 25:10,22 26:9 

26:11 36:15 84:10 

85:6 89:13 100:14 

101:20 102:14 

environmentally 89:18 

environmentals 27:11 

environments 102:19 

EPA 90:11,18,19,21 

equivalence 15:9 16:17 

Eric 9:7 

erosion 46:16 

especially 15:20 22:6 

23:17 29:2,17 55:18 

66:9 74:17 86:2 90:2 

essence 62:2 

essential 96:2 

essentially 28:14 

establishment 51:8 

ethylene 104:20 105:2 

105:10,12,15,18,21 

105:22 106:3,7,16,19 

106:22 107:4,5,7,11 

107:15 

Etka 48:17 52:19 53:11 

53:12,21,22 57:17 

59:15 61:3 63:2 

EU 87:14,18 

Europe 87:12 

European 87:12,13 

evaluating 95:20 

events 46:16 

everybody 45:10 70:17 

evidence 86:12 118:16 

exactly 71:5 

example 11:18 41:15 

41:22 43:5 59:15 61:4 

75:5 76:15 

examples 41:7 49:18 

49:21 60:16 

excellent 9:5 89:19 

exception 21:5 

excessive 101:16 

exchange 47:11 

exclude 87:15 

excluded 88:8 

exclusion 95:9 

exec 69:15 

exemption 56:9,19 

60:15 

exemptions 56:16 

exhausted 56:13 

expand 28:2 122:13 

expecting 88:4 

expensive 65:18 

experience 42:20 62:19 

experienced 44:3 65:15 

experiments 105:16 

experts 17:20 19:3 

49:12 111:11 

expired 54:8 

explain 3:18 

exploded 47:3 

exploitation 39:4 

exploring 121:6 

extend 64:4 67:11 

extension 54:10 66:10 

73:8 

extensive 69:13 84:2 

extensively 66:6 115:12 

extraction 18:21 

extreme 25:6 79:5 

extremely 25:8 116:21 

extremes 102:5 

F

face 117:5 

face- 6:1 

face-to-face 5:20 

Facebook 124:16 

facilitate 12:5 31:8 

facing 72:3 

fact 59:3 85:2 

factor 15:7 

faint 103:18,20 

fair 123:21 

fairly 94:7 

fall 1:5 7:6 126:5,6 

family 63:20 81:14 

far 22:13 90:14 92:11 

118:20 

farm 13:17 22:17 37:8 

40:14 42:19 49:2 54:6 

54:7,9,12,17,19 56:11 

64:10 65:11 68:14 

81:4 89:22 99:15 

100:17 102:8 112:11 

112:14,16,17 114:4 

114:10,11 115:21 

120:11 121:14 

farm's 45:20 

farmer 47:9 63:22 110:4 

112:10 

farmers 14:4 15:15,21 

19:19 37:12 38:12,12 

38:14 41:8 45:16 

56:14,17 60:14 61:20 

62:11,18 73:15 75:21 

76:2,9 81:15 82:1,6 

82:19 112:1,15,22 

118:7 

farming 39:14 60:18 

84:12 97:10,11 112:9 

113:3 

farms 13:22 14:14,17 

41:2 45:14 46:9 65:4 

70:13 75:9 78:18 

89:21 95:21 110:18 

111:21 112:5,8,19 

113:8 115:11,13 

118:11 120:21,22 

fashion 22:17 

fast 62:4 65:18 

favor 30:5 

FDA 85:3 

FDA's 91:4 

feasibility 15:17 26:1 

feasible 76:4 

federal 6:7 18:6 21:8 

feedback 3:15,19 13:3 

69:2 111:20 112:1 

120:9 121:16 

feel 16:11,13 17:18 

22:21 26:7 110:21 

120:16 

feet 43:7 

felt 50:13 61:7 121:9 

fermentation 31:16 

Fernando 80:17 83:14 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
132 

92:22 125:18 

fertility 110:19 111:6,16 

112:16 

fertilizer 32:22 33:4 

34:18 

fertilizers 33:8 

fibrin 32:18 

field 49:20 116:10 

118:12 

Fifth 32:8 

fight 61:5 102:4 111:8 

figure 17:8 24:22 43:4 

62:20 71:4 

fill 46:17 

finalize 54:9 

Finally 43:19 97:14 

financial 15:19 16:18 

82:1 

find 11:4 15:12 22:16 

39:5 60:14 65:19 74:7 

90:12 101:12 

finding 117:12 

fine 108:14 117:18 

118:2 

finish 12:2 77:20 

finished 11:13 41:22 

finite 101:10 

fire 76:17 

firmly 118:17 

first 3:7 10:6 13:6 20:15 

22:10 31:14 72:10,10 

74:8,16 84:3 95:20 

105:1 110:8 117:5 

121:17 122:10 123:1 

123:5 124:16 125:15 

first-wave 118:7 

fish 32:22 33:3 96:11 

96:11,12 112:21 

five 64:16 80:14 118:8 

fixed 5:5 

floral 106:1 107:11 

flowering 104:21 

105:19 106:11,17 

107:6 

fluids 46:9 

foam 41:18 42:2 46:4 

47:18 

focus 84:3 96:22 97:4,5 

focused 99:21 

folks 7:8 10:7 13:3 

37:13 83:8,12 91:7 

93:6 94:14 98:19 99:3 

99:7 104:1 125:9 

126:18 

follow 26:5 27:22 30:4 

71:15 

followed 13:7 20:5 

30:15 36:4 40:6 43:2 

44:11 48:17 52:19 

63:4,16 73:18 79:13 

106:3 

following 31:14 46:14 

96:6 110:16 

food 13:17 14:20 15:2 

31:21,22 32:8 37:8 

40:14 81:10 84:1,5,12 

90:7 120:11 

foods 89:11 

foot 59:21 

foraging 96:9 

forced 43:20 117:5 

forego 117:7 

foreign 82:4 

form 88:10 

formally 68:14 

formation 23:3 32:18 

formations 46:21 

formed 47:7 

forming 25:16 

forms 33:1 61:12 

Forrest 99:2 104:3 

109:8 125:22 

forth 43:11 

Fortunately 54:19 

forum 13:19 

forward 6:9 15:17 16:14 

16:20 18:2 23:2 25:8 

27:15 28:1 49:10 52:5 

73:9 97:19 102:21 

126:17 

fossil 118:19 

fostering 110:19 

found 24:11 52:20 

53:16 75:18 105:4 

119:22 

founders 115:22 

four 45:21 46:14 47:9 

48:11 64:16 80:14 

Fourth 32:5 

fracking 38:3,3,18 

39:13 

FracTracker 36:13,21 

frame 23:21 25:13 

framed 21:16 

frames 22:20 

framework 74:12 

France 105:17 

Frankie 99:2 104:3 

109:9 126:1 

frankly 90:19 

fraud 54:20 55:18 58:22 

60:7 

free 32:11 

frequency 78:21 79:5 

fresh 31:10 

front 61:17 

fruit 104:17 

fruits 29:3 

frustrated 57:7 

fuel 41:6 

fuels 118:19 

full 26:15 39:3 92:2 

fully 21:14 70:14 

fumigants 28:5 

fumigating 28:15 

function 58:8 100:14 

functional 121:2 

functionality 4:9 

functioning 110:12 

functions 101:5,9,18 

funding 54:7 75:3 

further 6:1 11:11 32:19 

96:14 101:20 

future 22:15 

G

gallant 111:11 

gap 55:12 

gaps 55:16 74:7 

gas 37:1,4,19,22 42:14 

45:12 104:20 105:2 

105:10,19 106:16 

107:5,11 

gather 60:8 

GE 15:14 

gene 102:10 

general 101:6 

generate 112:16 

genetic 14:19 16:12 

106:20 

genetics 100:5,9,12 

102:7 103:1 

get-go 115:3 

getting 5:4 7:8 8:17 

13:3 59:7 69:2 79:19 

give 11:7 26:15 29:5,21 

35:14 39:10 53:9 

80:10 83:17 122:19 

given 45:16 68:11,16 

70:11 116:20 

giving 81:7 110:15 

glass 42:8 

glue 70:18 

goal 99:22 

Gonzales 79:13 80:11 

80:16 83:13 92:16 

103:15 104:6,10 

107:21 108:9,18,21 

Gore 80:18 83:15 93:3 

125:19 

gotten 92:11 

governed 81:10 

government 74:5 

governmental 23:5 

35:9 

grade 15:2 32:8 

grain 15:21 112:20 

Grandin 101:3 

granting 47:16 

grass 97:1 

gray 122:13 

grazing 43:14,15 

greater 90:13 

greatly 55:16 

greenhouse 64:9 

116:10 

Greenwood 1:17 9:16 

57:11,14 59:8 

grew 116:17 

grinding 46:7 

group 4:2 23:3 25:16 

26:16 27:1,9 40:21 

51:9 

grow 15:2 59:17 81:10 

grower 28:20 121:8 

124:17 

growers 15:10 21:7 

67:17 81:20 120:13 

120:16 121:5,10 

123:12,18 

growing 64:9 65:1,18 

123:5 

grown 14:20 56:20 

growth 101:5 117:6 

guess 34:19 35:15 53:6 

62:3 65:5,6,13 68:20 

70:16 72:9 80:20 

121:11 

guidance 19:9 49:13 

51:15 52:9 

guide 114:13 

guidelines 67:4 

gullies 42:4 

guns 42:7 

H

half 120:15 

hand 4:10,12 106:14 

handle 43:20 70:15 

handler 23:22 

handlers 22:5 

handling 21:17,20 31:9 

32:6 

hands 4:14 36:19 

Hanson 63:16 73:18 

79:12 83:3,5,22,22 

86:20 87:6 88:2,13 

89:8,15 90:17 91:9,12 

91:17 92:3,9 

happened 101:15 

happy 74:17 97:14 

hard 22:7,12 54:5 72:21 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
133 

103:9 

harder 58:19 65:19,19 

hardship 82:1 

harmony 115:21 

Harold 13:7 20:4,9,11 

24:4,9 27:17,21 30:5 

30:13,14 80:17 83:14 

93:1,1 98:18 125:18 

Harriet 1:11 7:16 16:7,9 

17:16 33:11 48:10 

51:20 57:4 

harvest 24:14 50:19,21 

51:11,12,15 

harvested 71:10,12 

112:21 

hauling 38:20 

Hawkes 13:8 30:21 

31:1,2 33:16 34:2,14 

35:11,14 

heads 83:17 99:5 

headset 3:12,13 93:18 

health 32:10 75:8 78:1 

78:10,11 84:11 89:13 

96:13,20 100:13 

101:6 102:15 

healthy 49:3 81:18 97:6 

101:12 

hear 4:20 11:3 12:4 

13:11 28:9 30:21 36:7 

36:9 40:10 44:17,20 

44:22 47:21 48:19 

53:3,12 63:8,14 69:4 

69:5 79:17 93:10 94:5 

98:10 103:16,17 

108:22 113:18 114:14 

117:13 

heard 15:1 40:19 51:22 

52:5 70:6,22 71:2 

72:11 85:2 124:16 

125:10 

hearing 6:9 20:3 40:2 

44:1,7 48:5 52:16 

53:9 61:7 73:9 80:4 

83:1 92:6 93:1,2,20 

98:5,21 103:12,13 

108:15 113:16 114:14 

114:18 120:2 125:16 

heavy 32:11 102:2 

Heidy 94:11,11 99:1 

104:2 109:6 125:21 

height 51:3 

held 1:8 

Hello 9:12 51:21 93:21 

93:21,22 94:21 108:7 

108:8 

help 6:17 17:8 43:18 

49:11,15 75:3 76:7,8 

87:21 102:14 118:5 

120:5 

helped 65:21 114:12 

118:6 120:13 

helpful 120:3 

helping 7:2 

helps 26:3 

hemoglobin 34:17,17 

34:22 

hemolysis 32:17 

Hey 62:15 69:9 77:18 

Hi 3:3 8:12,21 9:2 16:10 

18:19 73:21 74:1 

77:19 81:3 99:14 

high 60:6 97:3 100:18 

106:3 

higher 15:13 75:15 

highest 65:14 

hire 56:5 116:7 

hit 4:5 

hits 29:13 

hold 14:9 41:19 53:13 

63:14 83:7 94:7 98:11 

103:14,20 109:13 

holistic 97:11 

hoop 121:13 

hope 16:15 26:2 96:22 

98:1 106:5 108:22 

Hopefully 3:9 

hopes 95:8 

hoping 118:22 

hops 61:4,8 

Hort 20:14 

hour 64:16 65:14,16 

hours 64:17 

house 54:11 121:13 

housekeeping 3:7 

huge 45:13 93:5 

human 32:10 84:11 

96:20 

hundred 59:21 

hunting 50:22 

hydrologic 38:8 

hydrolyzed 112:20 

hydroponics 111:4 

hydroxide 31:18 

I

ice 106:4,10,10 

ID 10:22 11:3 

idea 63:1,1 

ideal 19:5 

ideally 19:8 

identical 102:11 

identified 20:7 41:16 

80:12,13,15 

identify 63:7 79:14 

102:22 109:5 

identifying 24:12 

imagine 91:21 

immune 100:13 

impact 26:1 27:4,13 

29:14 37:5,6,6,21 

38:7,14 39:2,3,8,13 

42:22 65:4,6 85:20 

122:3,13 124:1 

impacted 41:9 51:11 

impacts 13:21 14:13 

18:21 26:18 36:22 

38:10,11 84:11 96:12 

107:14 119:15 

impede 55:17 

impediment 56:17 

implement 72:8 120:14 

implementable 16:12 

implementation 52:5 

implemented 18:5 

implications 122:16 

import 54:20 58:22 

importance 104:16 

important 38:16 41:11 

54:1,2 60:8 73:15 

87:17 97:13 116:6 

imported 112:20 

imports 97:8,9 112:17 

improve 54:20 75:8,22 

97:10 

improved 116:11 

improvement 106:21 

110:12 112:13 

improves 82:4 

in-house 15:9 

inappropriate 54:14 

incentive 49:6 

include 17:9 46:3 51:6 

51:9 54:12,14 111:12 

included 23:10 31:4 

74:17 75:10 76:7 

78:13 124:18 

includes 38:18 

including 78:5 110:20 

income 65:8 

incompatibility 89:12 

incompatible 84:14 

85:10 

increase 65:8 84:21 

85:16 

increasing 79:5 

incredible 38:14 

indicated 15:13 

individual 60:4 

individually 10:8 58:3 

induce 104:20 106:11 

106:17 107:6 

inducer 107:12 

industry 31:21 37:4,4 

37:22 56:20 

infections 102:4 

inform 100:13 

information 6:1 19:16 

49:15 77:6 86:12,16 

87:2 111:19 

informed 106:9 124:12 

124:14 

infrastructure 13:21 

14:4,17 17:4 38:19 

41:2 55:9 

ingredient 34:4 56:12 

56:14 62:11 

ingredients 33:3 46:6 

70:19,21 71:1,5,6 

72:12 

inherent 89:12 110:22 

Inita 83:15 93:4,5 98:19 

125:20 

injection 38:12 

innocuous 42:6 

innovation 121:14 

inordinate 16:2 

input 13:18 47:5 111:20 

inputs 17:10 46:2 

107:13 

inputting 55:15 60:11 

insects 74:19 

inspections 45:8 

inspector 45:6,7,19 

46:18 47:20 48:7 

inspectors 43:19 44:1,2 

52:1 

instance 47:6 59:19 

60:2 

Institute 95:2 117:4 

institutions 74:6 

instruction 3:8 19:9 

insufficient 90:15 

intact 45:21 

integrative 76:20 

integrity 14:9,20 15:6 

16:12 54:2 55:15 58:9 

59:4 110:22 

intended 110:13 

intensity 79:5 

intent 115:7 

interact 85:12 

interest 74:4 

interference 68:19,21 

interference)-- 68:17 

internally 52:9 

International 31:3 

internationally 24:12 

interpreting 110:9 

interrupt 8:16 79:18 

108:7 

interrupted 117:21 

interviews 112:10 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
134 

introduction 107:13 

invasive 74:19 

inventory 117:8 124:21 

invertebrates 96:17 

invite 17:20 

involved 22:1 48:3 

74:22 

IOIA-accredited 45:6 

45:19 

ion 31:11 85:12 88:5 

ionic 85:16 

ions 31:12 84:22 88:17 

90:3 

ironically 124:20 

irrelevant 121:2 

island 15:21 

isothiocyanate 21:5 

95:13 

issue 14:12 15:14 16:15 

17:20 19:15 23:2,4 

41:13 47:15 60:13 

67:6 68:18 69:19,20 

69:22 71:14,17 72:6 

80:6 89:13 90:18 

97:21 100:5 104:15 

120:10 122:7,7 

issued 107:3 

issues 17:22,22 26:12 

26:20 46:14 66:18 

67:2 70:11 71:9 72:2 

118:6 

it'll 76:7 

item 19:1 23:9,11 41:6 

67:10 73:14,14 

122:15 

items 6:14 10:4 60:15 

60:17 

iterate 84:18 

J

Jackson 37:12 

JAMES 1:17 

Jamie 80:12,16 83:13 

92:18,19,19 98:18 

125:17 

Japanese 114:8 116:2 

Jaydee 63:16 73:18 

79:12,16,16 80:1,2,5 

83:3,7,10,13,20,22 

86:7,9 87:20 92:7 

Jean 80:18 83:15 93:2 

98:19 125:19 

jeopardy 14:7 

Jesse 1:12 7:20 8:1 

Jessica 63:5,15 73:17 

73:19,21 74:1 77:8,19 

79:2,2,9,10 

Jo 40:6 44:11 48:16,18 

49:2 51:18,19,21 

52:16 

Johnson 44:12 48:17 

52:19 125:15 

join 9:6,14,15 10:3 

113:10 

joke 117:10 

Joseph 94:12 99:1 

104:2 109:8 125:22 

Judge 90:20 

Julia 30:18 36:5 40:6,8 

40:13 44:6,6,8 

jump 66:14 

juxtaposing 119:17 

K

Kate 75:7 

keep 10:7,11 12:15 

keeping 97:1 

keeps 54:18 

key 54:7 72:2 

kinds 89:16 

knew 24:16 

knowledge 74:7 112:15 

known 14:14 32:9 

knows 45:10 

L

label 97:13 110:18 

111:1 

labor 66:21 116:4,8,11 

lack 43:21 54:22 102:13 

102:19,20 

laid 59:15 

land 14:21 37:6 42:3 

46:19 49:21 51:10 

landscape 38:7 

large 102:2 107:16 

larger 54:4 

late 9:16 

latest 54:3 

latex 42:12 

law 95:3 96:7 110:5,9 

113:5,9 

lay 47:7 

layoff 117:6 

leadership 85:6 

leading 6:21 

leads 42:20 

learned 115:2 

leave 8:7 

leaving 102:10 

led 45:12 

left 43:4 51:5 71:11 

117:22 

letter 40:21 96:7 113:8 

lettuce 64:10 

level 69:14 75:14 89:4,5 

89:12 

levels 14:22 15:12,15 

75:15 90:15 

Lewis 2:11 5:7,9,10 

69:3,7,10 121:22 

123:21 

life 85:21 100:1 

light 36:9 

likewise 25:4 

Lima 1:15 8:10,11 

limit 4:18 

limitations 82:7 

limited 4:9 

limiting 15:7 

limits 82:13 

line 3:7,15 5:2 8:3 13:9 

20:6 44:13 48:18 

52:21,21 53:2,5,9 

73:19,20 79:15 80:7 

80:15 83:9,17 93:14 

94:14 98:9,20 99:4 

109:15 110:5 113:2,4 

113:17 114:17 

lines 3:20 

Linley 99:2,4,5 104:3 

109:9,13,14,21 110:1 

113:14,15 

Lipstreu 13:7,10,15,16 

16:13 17:2,15 18:14 

19:7,22 37:7 40:20 

liquid 32:22 33:3 

Lisa 1:15 8:10,12 

list 10:15 21:6 22:4 31:4 

60:3,17 61:6 63:10 

70:14 71:1 72:12 

80:21 83:8,11 84:7 

92:13 93:6 109:3,17 

109:19 125:11,14 

listed 22:3 23:12 

listening 51:16 97:22 

113:11 

listing 95:11,15 

listings 71:22 

little 3:6,10 4:20 9:16 

10:3 27:3 28:2,6,7,9 

36:9 57:7 66:8 79:19 

95:17 103:18,19 

live 3:16 65:18 

livestock 95:1,18 96:22 

97:6,12 99:21 100:5 

101:16 111:16 

living 100:1 

loads 15:11 

lobbying 111:13 

located 30:16 45:14 

locomotion 100:16 

logistical 10:4 122:7 

logistics 4:17 

long 83:11 

longer 15:2 34:11 55:5 

57:16 85:14 92:4 

longstanding 15:15 

16:15 

look 10:2 18:10 19:2,6 

23:3 25:14,16 26:17 

28:22 57:10 73:9 75:8 

91:3 102:21 119:5 

126:17 

looked 25:1 

looking 6:9 14:22 15:16 

17:13 25:21,22 27:12 

36:22 38:2 52:4 91:5 

105:18 122:8,20 

looks 76:22 126:3 

Lopez 104:2 

Lopez-Rodriguez 94:11 

99:1 109:6 125:21 

losing 119:15 

lot 13:3 29:8,16 36:21 

37:3,11,11 47:13 

52:11 58:17 73:15,15 

78:15 92:5 120:2,16 

124:9 

lots 48:2 

loud 39:13 

low 75:11 

lower 32:21 116:15 

lowering 32:22 

lumped 23:15 

Lyles 80:17 83:15 93:1 

125:19 

M

Magic 42:6 

magnitude 37:18 

maintain 15:5 56:6 

87:18 107:10 

maintained 97:2 

maintaining 15:4 

maintenance 101:5 

major 110:8 

majority 22:4 33:14 

50:10 100:17 113:8 

makers 81:16 

making 71:7 88:21 

115:14 

mammals 51:7 

manage 43:6 100:14 

management 58:19 

74:18 76:12,20 

manager 104:10 

mandatory 55:21 

manufacture 31:16 

manufactured 88:11 

manufacturers 62:11 

manure 78:3 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
135 

mapped 39:2 

mapping 37:3 39:7 

March 124:15 

Marie 80:18 83:15 93:2 

94:3,4,6,7,10,17,22 

98:4,5,19,22 125:19 

marine 22:10 24:11,14 

25:2 50:1,19 51:7,9 

51:14 

mark 12:3 107:19 

market 56:18 60:14 

61:13 62:10 104:18 

116:13 

marketplace 112:7 

Maryland 75:7 

mass 51:3 55:18 58:20 

101:18 

material 21:6,14 23:12 

23:15 29:4,13,17 42:5 

42:8,9,17 64:6 74:9 

88:4,10 95:6 97:15 

materials 2:15 20:21 

21:19,22 22:9,11 

24:11,15,19 25:2,13 

27:12 28:12 42:3,18 

46:6 50:1 73:1 95:16 

117:4,8 

matter 43:5 95:10 

126:19 

matters 11:10 16:16 

maximize 116:9 

McMillan 83:18 92:12 

98:10,13 99:13,14 

meal 33:14,20 34:7,11 

34:14,20 35:16,17 

96:11,11 

mean 28:4,14 35:16 

60:16 62:1 68:11 

70:10 72:17 73:4 88:2 

89:3 

meaningful 55:9,12 

102:22 

meant 58:12 

measures 19:18 96:15 

meat 74:21 97:4 100:18 

102:3 

media 14:15 

medical 89:21 

meet 28:18 29:19 43:5 

82:17 

meeting 5:8,21 6:2,3,4 

6:6,11 7:6 12:19,19 

16:22 52:12 66:17 

69:18 70:3 73:7 85:6 

92:2 113:8 126:5 

meets 85:22 115:6 

member 7:17,19,22 8:4 

8:7,11,14,20 9:1,4,8 

9:11 16:7,10,21 17:3 

17:7 18:13,17,19 

19:21 20:12 24:6,8 

26:4,7 27:18,21 30:4 

30:10 33:11,13,19 

34:7 35:7,13,22 48:10 

51:20 57:4,11,14 59:8 

62:15 66:4,14 68:9 

70:8 71:14,18,19 

72:16 77:16,19 86:10 

86:22 113:6 119:10 

119:12 121:21 124:5 

125:3 

members 1:10 4:15 

5:13 7:11 9:18 11:10 

12:11 20:16 23:18 

51:9 57:6 73:13,16 

95:4 104:14 107:10 

111:2 

members' 5:16 

menial 116:8 

mention 22:10 35:7 

mentioned 10:6 19:2 

message 12:13,13 

79:15 80:18 99:8 

messages 125:10 

met 37:14 

metallic 89:17,17 

metals 32:12 

method 32:15 

methods 97:10 

mic 3:14,16 93:17 

Michael 99:1 104:2 

109:8 125:22 

Michelle 2:13 3:4 5:9 

7:2,10 9:8,21 10:6,15 

11:17 12:21 69:3 

91:15 94:13 103:12 

126:9 

Michigan 114:4 

micro 96:18 

microbial 84:22 85:21 

middle 45:11 

milk 97:3 100:19 101:17 

millions 99:19 102:17 

mind 10:12 

minds 116:7 

mines 38:10 

minimizing 29:14 

minimum 115:6 

Minnesota 5:22 

minority 113:10 

minute 12:3 107:19 

minutes 4:19 8:8 11:14 

11:15 93:7 

Miraj 109:16 113:21 

125:7,8,8 126:2 

missing 34:6 80:2 

mitigate 87:22 102:14 

mitigating 78:18 

mitigation 17:12 18:3 

19:18 42:22 45:17 

78:17 

mix 64:11 88:20 

mixed 59:18 60:1 63:1 

mixers 32:16 

mixing 32:15 

Modernization 120:12 

modification 82:15 

modified 87:13 

modifying 82:2 

moment 9:19 44:3 

money 47:13 

monitored 45:18 

monitoring 50:6,11 

monohydrate 31:18 

Montana 63:21 65:17 

month 124:20 

months 46:1 47:16 

118:16 

Mortensen 1:18 8:19,20 

move 12:8 16:14,20 

18:2 23:2 25:8 27:15 

28:1 42:13 44:8 53:11 

63:10 72:15 

movement 38:21 

115:22 

moves 15:16 

moving 43:10 49:9 

97:18 118:18 

mulch 115:13,20 

multi-year 55:12 

muscle 101:18 

mustard 29:9,10 

mute 4:1,1,5,6 8:3,17 

10:7,8,13 44:15 79:20 

93:12 114:18 

muted 3:14 68:22 79:2 

93:20 

muting 10:9 

N

name 10:20 11:7 13:13 

20:10 30:20 36:10,12 

40:9,13 45:3,5 48:22 

53:4,20,21 63:17,19 

73:22 81:2 83:21 

94:19,22 98:16 99:11 

104:5,9 109:22 

113:22 114:2 

names 10:21 80:14,21 

125:11 

nano 86:1,3 88:1,1,6,17 

90:3,19,22 

nanomaterials 87:15 

nanoparticles 84:10,18 

84:21 85:7,15 88:12 

88:14 

nanotechnology 85:5 

87:10 

narrow 106:5 

NASS 57:20 

natamycin 95:13,21,22 

96:5,8 

Nathan 53:17 63:5,11 

63:11,13,14,15,17,19 

66:2,3 73:13 

nation 105:5 

national 1:3 2:12,14,16 

5:11,14 6:13 14:10 

21:6 22:4 53:22 55:3 

57:20 70:14 84:7 85:5 

105:13 

nationwide 99:19 

native 49:7,16,22 52:2 

96:17 

natural 22:19 29:6,9 

34:12 45:12 95:3 

naturally 101:12 

nature 19:15 25:6 49:4 

115:21 123:14 

navigate 115:3 

near 22:15 120:7 

near-universal 58:5 

necessarily 101:19 

necessary 22:5 106:17 

107:1 

necessity 23:14 

need 23:8,14 35:4,15 

43:3,12 46:16 59:5 

61:12 71:4 72:5,7,15 

76:1 78:15 112:17 

120:2 

needed 31:12 49:16 

58:2 76:8 96:16 

needs 46:18 77:4,6,21 

89:11 97:16,18 112:3 

negative 32:9 117:6 

negatively 85:20 

net 118:18 

never 62:22 118:12 

new 50:9 54:6,9,17 

124:21 

news 54:3 67:5 

newsletter 124:19 

newspaper 72:20,22 

newsprint 118:15 

nitrate 74:21 

nitroglycerine 47:1 

no- 75:5 

no-till 74:18 

NOC 54:5,15 55:20 76:6 

110:11 111:2 

noise 3:21 10:10 69:1 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
136 

79:20 114:15 

noises 8:18 

non- 15:10 

noncompliance 14:15 

nonprofit 36:13,20 74:3 

81:9 

NOP 3:4 5:22 6:16 7:1 

14:11 19:9 23:4,7 

46:13 49:9,14 50:10 

55:20 66:16 67:9 

119:22 

NOP's 55:15 110:14 

norm 50:16 

normal 46:2 47:15 

North 38:4 81:12 

Northern 114:4 

Northwest 20:13 

NOSB 1:9 5:8,13,16 

6:20 7:7 11:11 14:11 

14:17 19:6 20:12,16 

23:18 49:5,14 54:15 

57:6 62:5 64:4,5 

69:18 75:2 84:5 95:6 

95:7,8 99:18 100:4 

102:22 107:10 117:21 

NOSB's 99:21 

note 42:22 

notes 68:2 

notice 116:21 

number 5:3 11:1,3,5 

20:7 30:17 46:14,21 

47:4,9 57:21 59:2,20 

61:4 63:7 67:2 80:19 

100:7 102:9 118:6,20 

numbers 103:14 

nursery 21:9 

O

Oakley 1:19 8:22 9:1 

24:8 26:4,7 66:4 

71:18 72:16 124:5 

125:3 

obsolete 111:3 

obtained 106:22 

obviously 64:19 65:4 

69:14,22 70:10 

occur 46:16 50:18 

occurred 46:1 

ocean 96:13 

October 1:7 5:8,21 

OEFFA 13:20 14:8 

41:16 42:15,19 

OEFFA's 44:2 

off-farm 46:17 

offer 40:17 

officially 5:7 54:8 

offline 108:13 

OFPA 68:13 

Ohio 13:17 36:14 37:8 

37:14 38:4,13 40:14 

45:7,10 

OICP 111:9 

oil 36:22 37:4,19,22 

45:12 

old 54:10 

on-farm 15:13 

on-site 45:19 

once 47:2 63:9 81:6 

92:18,21 121:1 125:8 

one's 109:19 

ones 54:13 121:7 

ongoing 40:22 

onions 64:11,20 65:1 

71:11 

open 5:7 13:19 113:1 

operate 6:6 

operation 14:3 112:12 

116:3 119:16 122:14 

122:18 124:2 

operations 59:19 60:9 

60:17 82:12 110:16 

113:10 

operator 50:15 114:3 

operators 49:15 50:5 

122:21 

Opiela 80:17 83:14 

92:20 125:17 

opportunity 5:18 13:18 

40:17 56:22 81:7 95:5 

99:17 104:13 112:9 

114:6 

oppose 95:11,15 

opposed 30:8 60:2 

opposes 54:16 

option 45:17 76:4 

options 73:8 

oral 13:20 

order 10:15 28:18 42:16 

organically 28:21 56:15 

56:22 61:9 62:12 

100:10 102:9 103:2 

organics 14:10 54:2 

85:11 

organism 38:5 

organisms 96:18 

organization 37:16 

81:9 

organizations 40:21 

origin 111:16 

originally 57:18 

OSP 50:9 

outdoor 97:2 100:1 

102:20 

outlining 69:19 

outreached 52:8 

outweighs 118:20 

overall 75:14 102:15 

overemphasize 101:14 

overseas 35:8 

oversight 23:6 35:9 

owner 114:3 

owners 51:11 

oxides 89:17 

P

P-R-O-C-E-E-D-I-N-G-S

3:1 

p.m 1:9 3:2 126:9,20 

package 82:10 

packaging 81:22 

pad 39:15 

pads 38:4 

paid 65:14 

painfully 110:6 

pains 16:1 

paint 42:10 46:7 

panel 17:20 19:3 

paper 64:2,7 66:20 67:1 

67:3,4,18 69:20,21 

70:1,12,18 71:11,21 

72:1,18 91:13 114:8 

115:10 116:2,5,17,21 

118:14 119:15,17 

120:3,6,20 121:9 

123:17,17,19,20 

papers 72:1 

paramount 14:10 

paraphrase 69:12 

parasite 96:15 

Parliament 87:13 

parlor 43:12 

part 5:20 7:7 35:20 

43:14 58:9,21 86:22 

participant 4:7 93:21 

participate 111:22 

participation 5:16 

particle 85:8 

particles 88:7,18 

particular 96:12 121:10 

particularly 7:1 55:1 

58:22 96:16 99:22 

119:13 

parts 84:3 118:19 

pass 54:6,10 

passed 52:3,4 

passing 49:5 

pasture 43:6,14 110:19 

pasturing 111:16 

Patel 109:16 113:21 

125:7,8 126:2 

pathogen 78:2,8 

pathway 45:15 

PATTILLO 2:15 

Patton 83:15 93:4 

125:20 

Paul 2:11 5:7,10,22 6:6 

6:22 66:7,17 68:3,5,6 

69:7,9 70:7 121:22 

pause 119:1 

pay 37:17 65:7,9 

paying 65:15 

PCR 15:9,11,12 

Penn 114:12 115:12 

Pennsylvania 38:4 

45:11 

people 4:11 10:10 13:4 

37:11 39:1 62:19 

64:16 66:5 70:19 

81:10 94:9 103:21 

107:2 114:16,17 

people's 4:18 

percent 48:4 114:9 

115:14 

perception 120:1 

Percy 13:8 20:5 30:15 

30:19 31:1 33:10 36:2 

36:3 

perfectly 14:1 

performed 45:8 

period 106:2 

permits 10:18 

permitted 118:11 

person 12:16 16:22 

64:12 80:15 

personally 6:15 73:5 

89:20 

perspective 41:16 

54:13 73:3 122:2 

perspectives 27:9 

43:16 

pertain 114:7 

pertaining 11:9 

pest 76:20 

pesticide 85:18 95:9 

petition 34:1 57:9 64:6 

84:6 89:3 95:6,12 

petitioned 67:21 68:15 

petitioner 56:10 61:17 

Petitioners 56:12 

petitioning 31:3 60:19 

pH 32:21 33:1,5 

Ph.D 2:11 

PhD 36:18 

phone 3:11 4:3,4,21 5:3 

10:11 11:1,3,5 20:7 

30:16 36:16 37:10,16 

39:1 40:18 63:7 80:19 

86:21 91:20 108:10 

photo 51:4 

photographs 50:12 

physical 100:15 

phytosanitary 21:9 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
137 

28:17 29:18,19 

piece 97:13 

pillows 47:6 

pilot 111:22 

pineapple 104:11,16,21 

105:7 106:15 107:4 

pineapples 105:3,15,19 

105:22 106:7,20 

107:4,8,12 

PINEAPPLES]-- 105:12 

107:16 

pioneers 115:9 

pipe 41:21 42:10 46:4 

pipeline 18:8 41:18 

43:7 45:13,18 46:2,12 

47:12,22 48:2 

pipelines 45:22 48:1 

pipes 41:20 42:5,9,13 

42:13 46:15 47:7 

place 19:19 65:18 82:11 

105:13 122:10 123:1 

123:19 

plan 17:8,12 18:4 19:1 

23:11 42:22 43:1 

plans 46:11 

plant 74:18 76:12 121:6 

planter 116:6,22 

planting 28:16,20 29:18 

30:1,6 

plants 29:10 34:16 86:1 

86:2 90:2 106:2,11 

plasma 34:16,21 35:1,5 

plastic 82:9 115:13,19 

118:11,12 

plastics 119:19 

plates 39:4 

play 11:17 26:21 

please 5:22 8:17 10:7 

10:11 14:16 15:17 

20:6,10 21:1 30:17 

41:1 53:16 79:15,20 

80:18 99:8 113:10 

114:18 

pleasure 52:4 

plight 67:17 

plots 75:16,16 

plunge 123:10 

point 12:6 17:18 49:14 

62:3 67:15 68:3 88:16 

100:22 109:18 119:20 

123:22 

pointless 23:16 

points 48:11 100:3 

policies 43:21 100:8 

policy 13:16 53:22 54:4 

81:16 84:1 91:1 95:1 

polyphenylene 46:4 

polystyrene 47:6 

polyurethane 46:3 

Pool 73:18 79:13 80:8 

81:3,3 

pools 102:10 

poor 102:18 

popularity 123:6 

populations 102:8 

portion 34:17,22 35:1 

80:3 93:14 

posed 25:19 

position 21:3 44:1 

110:15 

positive 54:12 116:18 

118:18 

possibility 106:15 

possible 12:3 19:16,17 

66:10 73:8 

pot 64:2,7 114:8 115:10 

116:3,5,18,22 120:20 

potential 39:3,8 70:12 

85:19 114:7 122:15 

potentially 28:7 67:12 

122:9 

pots 66:20 67:18 70:1 

119:15,18 120:3,6 

121:9 

potting 65:3 

poultry 96:5,6 100:5 

101:17 110:20 111:17 

powder 74:20 

powerful 85:17 

practice 105:2 

practices 74:18 75:6,8 

78:17 110:21 112:3 

113:2,4 

precedent 67:20 

precipitated 34:1 

precursor 31:20 

predators 50:22 

prefer 70:9 

preliminary 90:1 

premised 97:7 

prepared 92:15 

preparing 6:12 

presence 34:12 

present 1:10 2:9 7:12 

7:15,17,19,22 8:4,7 

8:14,20 9:1,4,8 10:16 

11:2 126:4 

presentation 106:8 

presented 21:1,20 

106:13 

PRESERVING 105:12 

105:15,22 106:7,19 

107:4,7,15 

presiding 1:9 

pretty 28:21 

prevent 42:4,16 

preventative 97:9 

prevention 96:15 

previous 22:1 34:19 

previously 18:4 65:1 

116:13,19 

price 97:8 

prices 116:16 

primary 114:3 

prime 22:14 

principally 96:1 

principle 101:2 

print 67:5 

printing 82:8 

prior 7:6 11:2 46:19 

57:15,17 67:12 

114:10 125:1 

priorities 74:11,14 

76:14 78:6 95:6,18 

prioritizing 75:2 

priority 74:12 76:16 

99:21 

proactive 14:12 62:10 

proactively 18:11 

probably 64:17 73:4 

88:22 120:9 122:18 

problem 59:2 66:22 

68:16 72:2 89:18 

problems 5:1 58:17 

59:5 89:16 102:11 

104:7 

procedures 55:14 

proceed 13:14 

process 7:7 19:17 23:6 

25:9 33:18 34:16,21 

35:5,20 56:9 58:4,10 

61:22 62:4,4,5,6 

110:11 120:17 121:18 

123:15 126:14 

processed 34:15 

processes 14:6 

processing 31:8 32:2 

32:19,21 33:6 34:9 

37:1 

produce 21:15 56:18,21 

61:8 64:20 82:13 

102:2 

produced 56:15 

producer 23:22 42:20 

42:21 43:4,16 59:22 

producers 15:2,18 18:6 

19:12 51:12 56:4 

59:11,12,17 61:7 

104:16 

produces 32:14 

product 19:1,6 32:15 

34:12 55:21 56:18,19 

84:17 85:9 91:5 97:6 

116:17 118:14 

production 14:7 15:6 

21:12 31:6,22 37:1 

49:7 50:2 58:18 70:20 

74:20 75:12,13 82:17 

96:1 97:1,2,3 101:17 

104:22 105:7 107:12 

114:13 115:3 

products 15:4 31:22 

46:4 47:14,18 70:18 

100:11 105:6 116:16 

profession 36:19 

profound 121:14 

profoundly 120:20 

program 2:12,14,16 

5:12 10:22 14:10 

40:16 41:1 99:16 

programs 54:7 74:2 

101:13 102:13 

prohibit 111:4 

prohibited 14:2,5 41:17 

41:22 42:3,18 46:2 

47:3,5 72:11 

project 17:16 39:7 

76:17,22 110:2,4 

111:3 112:1 

projects 45:13 77:3 

promote 49:3 

prone 86:2 90:3 

proper 117:2 119:3 

122:11,22 

properly 119:2 

properties 85:1 

proposal 14:19 15:16 

16:11,19 49:9 52:3 

87:14 

proposals 21:4 

propose 111:4 

proposed 23:9 49:6 

87:21 

prospective 122:5 

protect 19:19 27:6 

protecting 22:18 50:6 

52:2 

protection 78:8 97:12 

protections 78:2 

protects 49:4 

protein 112:21 

Protena 31:3 

protocol 17:10 

proud 65:6 

provide 5:19 19:10 23:6 

28:19,19 29:22 30:1 

49:21 57:1 76:8 99:18 

111:19 

provided 10:15 11:1 

13:20 62:12 85:13 

112:1 

provides 5:18 22:22 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
138 

providing 58:5,12,13 

89:11 

provisions 6:7 54:12,14 

54:18 

public 1:5 5:8,14,15,19 

5:20 6:5,10 7:5,6 10:5 

10:14 11:12 12:10,10 

12:15,15 21:13 40:17 

95:4 126:7 

published 111:18 

pulls 47:10 

purchase 50:22 

purchased 124:21 

Pure 84:6 

purity 15:4 

purpose 84:20 

pursue 24:17 

pushing 54:5,17 

put 14:6 19:18 22:12 

42:12 

puts 67:8 

putting 27:8 49:12 

58:19 

Q

qualified 56:6 110:18 

quality 32:14 64:20 

97:5 

quandary 67:9,14 

question 12:12 17:5,16 

18:12 23:4,8 24:21 

25:7 26:12 27:19 

33:19 34:5,6 35:6 

47:2 57:9,12 61:14,15 

66:15 68:10 70:5 

72:14 77:12 85:4 

86:21 87:1 88:22 

119:10 124:11 

questions 11:12 12:5,9 

12:11,13 16:6 17:1 

18:16 20:2 22:21 24:4 

27:16 30:12 33:10 

36:2 39:21 40:2 41:4 

44:6 48:9,14 49:19 

51:19 52:15 57:3 

59:10 62:14 66:3 

77:14 79:10 83:1 86:8 

86:9,11 98:5 103:6 

108:4,15 113:15 

119:9 124:4 125:5 

126:16 

quick 5:4 26:5 71:16 

83:19 

quickly 80:22 92:15 

99:6 

quiet 39:13 

quite 22:5 62:7 66:6 

quorum 10:2 

R

radically 116:3 

raise 4:10,11 

raised 4:14 85:3 96:6 

100:10 102:9 103:2 

ranchers 81:15 

random 62:21 

range 100:15 

rapidly 32:11 

rates 97:3 

rationale 23:10 

Raubenolt 36:5 44:19 

45:1,5,6 

raw 34:15 35:2 78:3 

reached 107:19 

reactive 14:12 

read 98:17 108:17 

readily 32:6 

reading 21:13 

ready 22:14 94:18 

ReadyTalk 3:11 5:1 

readytalk.com 5:2 

real 66:22 67:9 71:16 

110:2,3 111:3 112:3 

real- 59:4 

real-life 41:7 

realities 102:18 

reality 14:13 

realize 19:14 76:9 122:2 

realm 41:14 

reason 3:14 22:2 36:16 

43:17 

reasonable 56:5 59:13 

59:14 

reasons 31:14 86:4 

115:10 

reassurance 122:19 

recall 52:12 

receiving 123:9 

recertified 47:19 

recess 126:6 

recognized 24:12 

recognizing 67:9 

recommendation 28:1 

49:10 64:3 74:10 

111:5 

recommendations 6:12 

recommended 84:8 

record 11:8 13:14 36:11 

40:9 45:4 81:2 83:21 

94:20 99:12 108:11 

109:22 114:1 126:20 

recovered 49:22 

recovering 36:17 

recycled 42:8 46:6 67:4 

72:1 73:1 118:14 

123:17,19 

red 32:17 

reduce 82:16 88:13 

112:16 

reduced 75:15,18 76:9 

reducing 75:22 88:6 

reduction 82:18 

reductions 75:20 

refer 105:1 

reference 35:15 87:6 

references 88:15 

referring 35:16 

reflecting 111:15 

Reforms 100:8 

refuse 113:7 120:18 

regard 4:17 15:8 

regarding 14:19 22:10 

40:22 84:9 

regardless 78:20 

regards 24:10 

regulations 46:13 

regulatory 18:7 31:2 

82:19 120:10 122:7 

122:18 

reinforced 112:2 

reiterate 100:2 

reject 84:6 

rejected 15:11 

rejection 111:9 

related 54:21 90:21 

100:8 

release 85:16 

relevant 11:7,9 

reliable 54:22 

rely 25:12 

remains 45:20 

remarkably 64:18 

removed 60:19 

removing 31:11 

repeat 70:6 79:3 86:20 

repeatedly 43:7 

replace 105:9 

replacement 46:15 

Reporter 108:6,7,9 

reporting 55:21 

represent 20:18 48:3 

82:18 

reproduction 101:6 

request 35:21 40:22 

requesting 43:17 

require 42:19 46:22 

50:5 

required 50:12 107:6 

requirement 50:11 

111:6 

requirements 21:9 

28:18 29:19 81:21 

requires 42:15 

requiring 43:6 

research 25:18 55:2 

57:18 74:4,6,11,12,14 

75:1 76:1,8,13,16 

77:4,6 78:6,16 85:3 

85:21 87:7 90:1 91:4 

95:6,18 96:14,15,16 

96:19,21 97:4,5 99:21 

105:16 117:4 

reserved 89:20 

residual 34:13 

residue 32:18 46:7 

resource 19:19 95:3 

101:2 104:10 106:5 

resources 19:10,12 

22:19 101:8,10,21 

respect 12:1 37:5 

responding 4:14 

response 6:13 

responsibility 16:3 

55:6 

rest 61:2 

restores 49:4 

restrict 30:6 

result 19:5 46:16 55:11 

58:4,14 101:19 

resulting 31:16 33:4 

results 106:12 

retailers 81:15 

retransition 42:19 

retransitioned 43:10 

retransitioning 43:3 

reuse 65:2 

review 20:22 21:19 34:8 

64:5 68:1 86:13 90:11 

91:18 117:3 119:2,4 

reviews 22:1 

revolves 73:5 

Rica 104:12 105:13,15 

rice 1:12 7:18,19 18:17 

18:19 19:21 76:21 

Rick 1:17 9:16 57:13 

rid 54:18 

right-of-way 47:10 

risk 58:19 60:6 

roads 46:10 

robust 102:1 

rock 46:21 47:8 

Roland 92:16,16,18 

103:8 

roll 7:11,11 

ROMERO-BRIONES

1:14 9:4 

Ronald 79:13,14 80:11 

80:16 83:13 98:18 

103:11 104:4,10 

107:18 108:3,4,9,15 

roots 81:12 

rotation 43:6 

rotational 43:15 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
139 

rows 59:21 

rubberized 42:12 

rule 49:6,13 115:6 

rulemaking 49:10 56:1 

62:6 

ruling 32:18 

run 4:16 83:7 92:13 

109:18 125:11 

S

safe 89:11 105:7 

Safety 84:1,5 120:11 

salts 33:1 

sand 38:10,20 42:6,7 

46:5 

sanitizer 89:4,14 

sanitizers 23:9 

savings 66:21 116:12 

savvy 3:17 

saying 67:17 79:4 

88:10 123:3 

says 3:4,9 

scalable 121:5 

scaled 101:21 

scared 47:17 

scenes 6:17 

schedule 93:7 94:8 

scheduled 5:21 

schooled 115:8 

Schwartz 9:7,8 

science 36:15,19 74:2 

90:22 

scientific 101:2 

scientist 36:17 91:4 

scientists 105:17 

scope 18:1 24:22 25:18 

27:14 41:5 

scoping 19:1 

Scott 1:12 7:18 18:17 

18:18 

screening 77:1 

sea 15:22 112:21 

seal 81:22 82:3,5,9,11 

82:13 112:4 

seasons 115:16 

seaweed 50:1,20,21 

51:1,2,7,11,12,13 

sec 53:14 

second 31:19 63:14 

79:19 80:10 83:7 

98:12 103:21 109:13 

110:11 120:11 126:7 

Secondly 23:8 

Secretary 1:12 

Section 82:2 

sector 39:8 

secure 75:3 

seed 15:1,4 

seeding 64:13 

seeds 29:9 

seeing 40:1 44:7 48:14 

78:21 92:7 98:6 121:5 

seen 39:11 47:22 58:7 

60:7,16 118:10 

Seitz 1:20 9:14 

selectively 100:18 

self- 3:22 

self-mute 4:2 13:4 

Senate 54:11 

send 91:13,15 

Senior 83:22 

sense 25:19 37:18 

sensible 56:2 60:10 

sensitive 67:16 70:11 

sent 125:9 

September 54:8 

sequestration 75:22 

serve 100:12 

served 45:21 

service 5:2 20:16 40:16 

55:2,3 57:18,21 

serving 5:17 

set 67:20 74:13 115:18 

settle 46:15 

seven 31:14 60:3 83:12 

seventh 32:20 

shade 43:13 63:5,15 

73:17,20 74:1,1 77:10 

77:13,18 78:1,10,14 

79:4 

shadow 118:5 

shale 39:4 

shallots 64:12,21 

shape 84:21 

share 13:18 19:11 66:8 

116:13 

shared 19:10 41:8 

112:15 

she'll 70:2 

sheep 96:16 

shields 47:8 

shift 112:6 

shopping 110:10 

short 54:10 106:2 

116:21 

shot 53:10 

show 50:6 56:10,12 

showed 112:12 

showing 90:2 

side 28:13 

sidelines 123:5 

signed 4:12 

significant 75:20 

107:14 112:6 

silver 84:4,7,11,13,17 

84:20,21,22 85:4,12 

85:15,16,20 86:1,3 

88:5,6,17,17,18,19 

89:8 90:3,3,15,19,22 

95:12 

Similanick 94:12 99:1 

104:2 109:8 125:22 

similar 24:14 

Similarly 42:2 

simply 102:3 

Simultaneous 24:5 

71:13 

single 23:16 82:16 

106:21 

sir 7:20 

sit 113:7 

site 29:13 50:9 

sites 48:3 

situation 43:2 73:5 

situations 43:20 79:7 

six 38:1 45:9 114:10 

Sixth 32:13 

size 84:20 85:8,9 121:1 

skew 101:21 

skilled 116:8 

skip 10:17 53:10 

skipped 98:16 99:8 

slam 88:16 

slaughterhouse 32:3,7 

slaughterhouses 31:9 

33:18 

slide 3:8 

sloping 42:3 

slot 12:16 

slow 58:10 85:16 

small 34:13 38:14 56:3 

59:11,12,18,22 60:9 

62:18 65:4,11,12 

120:17,21,22 121:10 

121:20 122:12,21 

social 15:19 

sodium 31:4,7,13,18,18 

31:19 32:1,4,5,8,13 

33:2,5,15,21 34:3,9 

34:13,20,21 35:5,17 

soil 28:15 32:11 36:17 

36:19 41:19 42:17 

46:15 65:3 71:8,10 

75:8 78:1,10,11 86:13 

87:3 97:9,10 110:19 

111:6,15 115:15 

solutions 15:16 76:22 

someone's 125:12 

something's 67:21 

somewhat 122:6 

sorry 24:8 26:12 68:7 

68:20 79:1,2 86:22 

98:22 108:6 114:20 

117:16,17,21 

sort 17:9 18:22 62:5 

115:7 123:8,16 

sorts 39:15 

sound 56:2 60:10 

sounded 123:2 

sounds 4:20 41:4 42:6 

108:10 

source 30:2,3 56:11 

sourced 102:10 112:17 

sources 29:6 

SPA 111:9 

Spain 121:7 

speak 4:12 11:6 12:12 

27:2 81:7 95:5,17 

103:20 114:6 120:5 

122:18 

speaker 10:10,19,20 

11:2,7 108:10,22 

speakers 3:16 98:17 

109:4 

speaking 8:17 24:5 

44:14 53:3 63:8 71:13 

93:11,11 98:15 

114:17 

Specialist 2:13,15 31:2 

specialists 105:6 

specific 21:2 23:12 

24:16 28:7 29:12,14 

84:17 85:9 88:1 95:16 

122:17 

specifically 24:10 29:3 

49:18 52:8 78:12 

95:11 

specifics 25:17 

spectrum 28:5 29:11,15 

spend 116:8 

spending 23:19 

spent 7:8 74:10 

spirit 96:7 113:2 

spoke 16:16 69:13,19 

105:12,14,21 106:6 

106:19 107:3,7,15 

spoken 17:12 

spot 62:17 

sprayed 89:21 

spread 38:5 81:12 

85:19 

spring 56:1 

St 5:22 6:6 66:17 

stabilization 46:5 

stabilize 41:20 

staff 2:9 7:1 11:4 117:7 

117:11 

stakeholders 20:18 

25:12 26:2 27:11 74:4 

standard 26:8,11 50:3 

75:12,16 

standards 1:3 2:11,15 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
140 

5:11,14 6:13,16 87:14 

87:19 102:14,22 

110:5 111:8,10,15,18 

112:2 

standing 111:5 

standpoint 116:4 

stands 122:4 

star-6 4:5 10:13 

star-7 4:6 10:13 

starch 31:17 

start 10:14 13:13 17:19 

20:9 30:19 36:10 40:8 

45:3 48:22 53:19 

63:17 73:22 81:1 

83:20 94:19 99:11 

104:4 109:21 113:22 

115:18 123:8 

started 3:5 13:6 58:10 

81:11 105:16 121:15 

starting 14:22 49:14 

114:11 

state 21:8 114:12 

115:12 120:6 

states 1:1 37:20 38:6 

39:5,9 45:8,14 84:16 

117:1 

Statistic 57:21 

statisticians 56:6 

Statistics 55:3 

status 45:20 

statutory 54:14 

stay 88:4 119:1 

stayed 123:4 

step 27:3 

stepping 25:15 

sterilizing 28:15 

Steve 1:16 8:13 27:18 

27:20 28:11 30:11 

48:17 52:19 53:11,11 

53:14,15,19,21 57:3,3 

57:14 59:8,10,11 

62:14,14,16 63:4 66:7 

66:14 69:1,19 70:4 

71:18 72:17 

stock 21:9 29:1,2,18,18 

30:7 96:12 

stocks 28:16,20 30:2 

stop 69:1 116:21 

120:18 

story 14:15 

straight 3:5 

strategies 74:19 76:20 

97:11 

streams 46:10 

strengthened 55:16 

stress 37:15 106:2 

stressors 100:15 

101:20 102:5,15 

stretching 55:13 

strictly 107:1 

striking 112:18 

strip 43:7,9 47:10 

strong 111:8 121:19 

stronger 103:1 

strongly 16:13 54:16 

95:20 

structure 51:2 

struggle 102:3 113:9 

studied 114:11 

studies 105:20 115:12 

study 14:16 

stuff 38:20 39:16 

subcommittee 20:14 

21:1,4,18,21 22:8,9 

22:13 23:11 69:14 

74:10,13 124:10 

Subcommittees 23:13 

23:20 

subject 14:8 22:12 

subjecting 106:2 

submitted 21:15 40:21 

52:11 95:14 99:20 

subsequent 21:20 

substance 42:1 47:2 

72:11 88:20 90:12 

substances 14:2,5 

21:11 31:5 41:17 

95:12 

substantial 84:9 

subsurface 38:8 

successfully 18:5 

succinctly 124:9 

Sue 1:13 8:2,2 

sued 90:18 

suffer 101:19 

suffices 46:20 

sufficient 60:1 74:21 

87:22 88:3 

suggest 59:14 89:10 

suggested 37:9 

suggestions 24:16 

summer 111:22 

sunlight 102:20 

sunset 20:21 21:18 

22:1 

supplement 96:2 

supplemented 96:9 

supplied 29:1 

suppliers 56:14 61:20 

supply 15:6 

support 20:21 21:3,14 

21:18 23:3 51:8 52:13 

76:2 95:20 96:14,21 

97:20 103:1 104:20 

117:3 

supported 49:8 81:14 

supporters 99:19 

supportive 120:13 

supports 95:7 

supposed 58:8,11 

surface 38:8 75:14 

surprising 101:1 

survey 50:8 51:6 55:5 

57:19 58:1 

suspension 119:1 

sustainability 24:13 

25:3 112:14 

sustainable 22:17 27:5 

84:14 115:5 

Suzanne 83:17 92:12 

92:14 93:6,9,10,13,16 

93:19,22 94:1 98:8,12 

98:22 99:10,14 103:6 

Suzanne's 94:1 

Swaffar 1:21 9:10,11 

62:15 

sway 120:5 

synthetic 31:5 67:12 

68:14 70:13 71:1 

72:19 115:14 122:15 

synthetics 71:20 

system 14:16 43:15 

49:22 82:17 115:10 

116:3 120:20 124:22 

systems 49:19 112:14 

112:19 117:8 121:6 

T

Taiwan 105:17 

taken 58:8 

talk 44:17 66:17 86:18 

103:10 108:13 

talked 37:11 86:16 

talking 8:2 14:1 37:7 

69:17 70:2 77:2 79:17 

79:21 126:17 

talks 3:10 

tampering 86:14 

tap 116:12 

tape 121:6 

tapped 48:4 

tasks 116:8 

teach 36:15 

technical 4:22 80:6 

104:7 

technique 29:8 

technologically 3:17 

Ted 20:5,5 30:16,16,18 

36:4,6,9,12 39:19,22 

40:1,20 

teleconference 6:18 

telephone 1:8 68:17,19 

68:21 

tell 3:17 33:20 34:10 

77:21 112:9 124:7 

telling 95:15 

Temple 101:3 

term 54:10 120:7 

terms 24:14 66:9 69:20 

70:1 82:8 

testimony 48:15 57:1 

79:11 103:7 

testing 15:8,9,13 16:17 

17:10,17 

tests 15:11 16:19 

thankful 76:6 

thanks 7:1,13 8:1,5,9 

9:22 13:1 17:15 18:19 

24:20 26:13 30:11 

49:1 53:7 56:22 63:2 

79:22 98:13 102:1 

108:12 114:19,20 

126:11 

thereof 43:21 

things 19:13 22:10 

23:17 56:21 60:8 65:5 

66:21 78:4 86:19 

110:6 115:1 116:5 

119:21 

third 32:1 110:14 

Thorn 99:2 104:3 109:9 

126:1 

thoughtful 126:15 

thoughts 7:9 28:10 

51:17 

thousand 117:7 

thousands 85:22 

threatening 76:10 

three 4:18 11:14,15 

12:3 32:2 45:22 47:4 

51:2 64:17 78:4 

107:19 

three-years 47:11 

Thursday 6:10 126:7,8 

126:18 

till 75:6,11 

tillage 75:12,16,16,19 

76:1,3,10 

timely 62:7 

timer 4:17,18 117:17 

times 56:16 62:22 

Timothy 80:17 83:14 

85:3 91:4 92:20,21 

98:18 125:17 

tiny 60:4 113:9 

to-face 6:2 

today 6:3,10,21 9:16,17 

40:3 48:15 51:17 64:2 

98:1 100:3 101:1 

103:7 106:8 114:6 

125:6 

today's 5:14 6:17 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
141 

told 35:18 70:17 98:14 

117:10 

Tom 1:9,11 4:16 6:20 

6:20 7:13,14 9:22 

13:1 17:4 20:11 24:6 

26:5 27:18 33:11 

44:17 53:5 57:11 68:9 

79:18 94:15 119:10 

124:5 

Tonda 80:17 83:14 

92:22,22 98:18 

125:18 

tone 71:3 

Tony 37:12 

tool 18:9 29:22 96:1 

117:9,11 118:10,18 

119:1 121:2,12 

122:20 123:20 124:22 

tools 58:20 76:8 106:21 

118:20 

top 46:15 116:16 

125:14 

topic 25:9 39:11 41:1 

97:17,18 

topics 75:2 98:2 

topsoil 46:17 

total 101:9 

totally 64:9 118:11 

123:6,11 

touch 77:4 

toxic 47:14 88:20,21 

toxicity 88:17 89:5 

track 58:18 59:6 

trackhoe 46:8 

tracks 46:8 

Trade 64:1 

tradeoffs 100:19 

training 16:18 

traits 101:15,17 

Trans-Atlantic 87:10 

transcript 12:18 

transcripts 12:20 

transferred 55:8 57:20 

transition 43:8 

transparency 14:20 

41:12 

transparent 113:1 

transplant 64:17 

transplanted 64:11 

transplanter 64:3,7 

65:13 114:8 116:18 

transplanting 64:14 

65:10 

transport 37:1 38:19 

102:6 

Traore 80:18 83:15 93:3 

125:19 

trays 65:2 

treating 106:11 

tree 29:3 

tremendous 27:14 

38:18,19 

trench 41:19,20 

trends 58:18 

trickle 38:22 

tripolyphosphate 32:4 

true 22:17 97:2 115:7,9 

truly 20:19 23:21 

104:13 115:5 

try 10:22 12:2 23:1 

24:17 69:11 103:9 

115:20 

trying 24:21 29:20 

62:10 68:12 103:15 

104:7 115:2,3 118:9 

Tucker 69:16 73:10 

Tuesday 1:7 126:5 

Tully 75:7 

turn 4:13 5:6 83:10 

102:2 106:15 

turning 6:19 

twice 63:9 92:18,20,21 

125:9 

two 8:8 10:21 32:3 

39:11 46:21 65:15 

72:2 78:14 82:12 84:3 

86:4,22 87:3 105:11 

107:22 123:5 126:7 

two-pronged 17:13 

twofold 89:18 

type 89:14 

typical 64:15 

typically 84:19 

typing 103:14,14 

U

U.S 50:9 87:9,18 100:17 

101:15 102:8 104:17 

unable 56:11 

unanimous 123:9 

unattainable 116:14 

unbalanced 102:7 

uncertainty 67:7 

unclear 46:14 

unconventional 36:22 

37:4,19 

understand 39:14 

41:13 72:4 73:3 87:21 

122:5 123:11,13 

understanding 17:21 

106:12 

understands 38:17 

unfair 110:15 

unfortunately 121:20 

uniform 32:14 51:16 

64:21 

unique 120:20 121:3 

United 1:1 37:20 38:6 

39:5,9 117:1 

University 75:7 76:18 

85:22 105:13,14 

unmute 4:1,6 10:13 

unmuted 44:16,18 

103:10 

unnoticed 124:2 

unsustainably 112:17 

untenable 43:22 

up-front 57:8 

upcoming 5:20 

upgrade 82:12 

uptake 90:3 

urge 23:1 27:14 96:10 

111:2,7 

urged 100:6 

urges 84:5 

urging 56:5 86:5 

usage 106:20 

USDA 6:12 23:7 54:22 

57:21 58:2 62:6 81:22 

82:3,8,13 114:9 117:3 

USDA's 55:2 57:18 

USDA-approved 32:2 

use 14:5 15:12 21:11,11 

23:13,14 27:12 29:6 

29:22 30:7 31:5 32:18 

33:4,18 34:17 35:2 

37:6 46:3,19 51:13 

55:18 61:12 64:5 65:3 

67:7 68:13 70:1,13,19 

71:7 76:2 77:2 82:4 

82:13 84:11 89:3 

96:10 104:20 105:2 

105:10,18 106:16,22 

107:5,11 115:10,14 

115:19 118:13 119:17 

119:19 122:15 123:18 

uses 31:21 50:21 78:3 

89:21,22 90:6 95:21 

usually 5:4 10:8 

utilize 29:13 

utilizing 29:4 

V

valid 23:10 

valuable 67:10 126:14 

variables 23:21 

varied 96:8 

varieties 106:16 

variety 76:4 106:21 

various 20:18 27:9 

43:22 101:4 

vary 23:15 

vast 33:14 100:17 

vegetable 59:19 63:1 

vegetables 60:2,4 

vegetation 50:19 51:15 

100:1 

ventilation 102:19 

verbally 87:4 

verify 50:14 

versions 54:11,19 

versus 3:11 28:6 30:7 

75:12 115:5 123:17 

viable 49:3 76:3 97:1 

105:4 

Vice 1:11 

view 56:10 

virgin 67:1,3,3 70:12 

72:1 123:16,20 

visited 111:21 

visual 50:10,17 

vital 7:7 

vocal 120:9 

voice 121:19 

voices 112:18 

voids 46:17 

volume 101:17 

volumes 102:2 

voluntarily 47:10 

volunteered 113:12 

vote 20:22 21:20 64:6 

vulnerable 102:11 

W

walk 102:4 

wanted 24:10 27:21 

39:10 61:8 62:3 66:5 

70:5 77:4 81:20 

107:22 111:22 116:1 

124:7 

wanting 67:20 

Washington 76:18 

wasn't 71:11 123:6 

waste 37:5 90:8 

watch 113:7 

water 17:10,17 37:5 

38:8 43:13 46:5 65:12 

90:8 106:10 

waters 38:8 

watershed 38:7 

waterways 85:21 

way 22:14,17 41:13 

50:14 56:5 58:1 59:13 

60:10 61:19 85:11 

106:18 115:17 122:4 

ways 62:8 89:11 

wealth 97:20 

weather 79:6 102:5 

web 80:3 93:14 

webinar 1:5,8 5:8,15,18 

6:5,21 7:3,5 81:8 

109:20 125:13 126:5 

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webinars 12:17 126:8 

website 6:1 39:6 111:19 

weeds 27:1 

week 6:5,6,11 69:18 

85:2 106:13 

week's 70:3 

weigh 23:7 

welcome 3:3,10 5:13 

7:5 111:20 

weld 42:12 

welding 42:15 46:6 

welfare 96:2 99:15 

100:10,13,19 102:13 

111:8 

went 126:20 

Western 45:11 

whatsoever 115:17 

wheel 65:12 

wholesale 112:6 

Wholesalers 21:15 

wholly 117:1 

wide 43:8 100:15 

widely 31:20 118:21 

120:12 121:4 

wider 76:4 

widespread 30:7 

wiggle 118:9 

wild 49:2,4 50:3 51:14 

wildcraft 26:8 

wildlife 50:21 51:5 

willingness 112:22 

winter 64:9 

Wisconsin 37:13 38:11 

won 90:18 

wonder 18:22 

wondered 66:7 

wondering 16:11 17:7 

24:15 34:10 51:22 

wood 29:18 

word 110:22 

words 79:3 

work 5:17 14:17 17:8,9 

18:6 19:1,5 22:8,12 

23:9,11 36:13,14,20 

36:21 40:16 41:3,11 

54:1 56:13 58:3 61:1 

61:19 62:11 75:4 81:4 

81:17 85:15 91:3 

97:16 105:16 111:4 

117:12 118:5 

worked 39:7 60:20 

76:19 115:11 

working 19:14 23:3 

25:16 26:16 27:1,8 

29:10 51:9 52:9 56:3 

59:17 60:22 72:7 

76:11,20,21 81:19 

93:17 102:21 

world 81:18 

worries 117:19 

worth 18:9 

wouldn't 30:8 35:5 

wrap 107:19 

wrapping 109:20 

wrestling 28:3 

write 47:14 

written 13:20 16:12 

21:2 50:12 59:16 

86:17,19 87:5 91:10 

91:21 95:14 98:1 

99:20 100:20 101:3 

113:5 

www.fracktracker.org

39:6 

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Y

yard 42:10 

year 50:8 64:8,8,12 

65:14 116:17 117:6 

years 13:22 19:14 38:1 

45:8 57:22 61:4 65:13 

76:17 81:11,20 100:7 

105:3 114:10 117:1 

118:8 120:15 123:5 

yield 64:22 74:20 75:20 

76:10 

yields 100:18 

Z

0

1

1,200 49:8 

1:00 1:9 3:2,4 126:9 

100 43:7 114:9 115:13 

11:50 93:6 

12 46:1 81:20 93:7 

13 9:18 10:1 45:7 65:14 

15 9:18 10:2 65:15 

15-foot 47:7 

16 1:7 

2

2.5 60:2 

20 48:3 

2014 54:6 

2015 55:14 57:16 58:16 

2017 55:6 

2018 1:5,7 5:8 64:4 

66:10 74:14 76:13 

85:13 124:12 

2019 56:1 117:6,7 

205 82:2 

205.311 82:15 

24 45:8 111:5 

24th 5:21 

250-sub-bed 64:15 

26th 5:21 

3

3:15 126:20 

30th 54:8 

311 82:2 

32 40:20 

36 47:16 

40 81:11 

42 50:8 

48 50:9 

4

50 111:21 

5A 82:4 

5

6

6,000 124:21 

606 56:8,16,19 57:5 

60:13,15 61:6,21,22 

62:3 

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C E R T I F I C A T E 

This is to certify that the foregoing transcript 

In the matter of: National Organic Standards Board

Fall 2018 Public Comment Webinar

Before: USDA

Date: 10-16-18

Place: webinar

was duly recorded and accurately transcribed under 

my direction; further, that said transcript is a 

true and accurate record of the proceedings. 

-----------------------

Court Reporter 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 
1

 UNITED STATES DEPARTMENT OF AGRICULTURE

 + + + + +

 NATIONAL ORGANIC STANDARDS BOARD

 + + + + +

 FALL 2018 PUBLIC COMMENT WEBINAR

 + + + + +

 THURSDAY,

OCTOBER 18, 2018

 The webinar was held via telephone at

1:00 p.m., Tom Chapman, NOSB Chair, presiding. 

BOARD MEMBERS PRESENT 

TOM CHAPMAN, Chair

HARRIET BEHAR, Vice Chair

SCOTT RICE, Secretary

ASA BRADMAN 

JESSE BUIE 

LISA DE LIMA 

STEVE ELA 

DAVE MORTENSEN 

EMILY OAKLEY 

A-DAE ROMERO-BRIONES 

ERIC SCHWARTZ 

ASHLEY SWAFFAR 

STAFF PRESENT 

DR. PAUL LEWIS, Ph.D., Director, Standards

Division, National Organic Program

MICHELLE ARSENAULT, Advisory Board Specialist, 

National Organic Program 

DEVON PATTILLO, Materials Specialist, Standards

 Division, National Organic Program 

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P-R-O-C-E-E-D-I-N-G-S 

(1:07 p.m.) 

 MS. ARSENAULT: So, welcome. This is 

Michelle from NOP again. We're going to do a 

little bit of housekeeping before we get started. 

So if you're online, and you're trying to look in 

through your computer and you can't, there is a 

dial in number you can dial in on the phone. 

We tend to get less feedback if you're 

dialed in on the phone, and if you're using a 

headset, but some folks have no problem. So it's 

up to you. 

We ask that you please stay on mute 

throughout the call. Background noises are our 

biggest challenge. We can mute you from our end, 

but if you're going to be speaking later, then we 

have to find you in the list and unmute you. And 

it just takes a little extra time. So we hope 

that everyone will self-mute themselves. 

I think we have a pretty good crew. 

They're pretty well versed in webinars, and we 

usually don't have any issues. So thank you for 

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that. If you are on a phone that does not have a 

mute button, you can use star-6 to mute yourself 

and star-7 to unmute yourself. 

Let's see. So as a participant, you 

should see somewhere on the left-hand side of 

your screen a chat function and a raise your 

hand. We're asking people not to raise their 

hands. You have to sign up ahead of time to 

speak on the webinar. And Tom Chapman, the Board 

Chair, will call on you when it's your turn, so 

no need to raise your hands and let us know that 

you have a question. 

We're going to be using a timer, and 

Tom's going to go over this in a bit. People 

have a three-minute comment time. So we'll start 

the timer a few seconds after you start talking. 

And you'll hear a beeping noise at the end of 

your three minutes. And we ask that you finish 

your sentence or stop talking at that point. 

And if you're having any technical 

issues, the ReadyTalk.com website is to stay on 

the screen. They have a really good customer 

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service line. There's a phone number you can 

call. If you want to get immediate assistance, 

you can chat with them, or you can email them. 

And they should help you overcome any technical 

issues that you're having. 

And finally, we're having a 

transcript, so there's a transcriptionist on the 

call with us. So we'll have transcripts of the 

webinar which occurred on Tuesday, this webinar 

today, as well as the in-person comments that 

will happen at the meeting next week in St. Paul. 

Those will be available a couple of weeks after 

the meeting concludes. 

All right. And I'm going to turn it 

over now to Paul Lewis, the Standards director, 

who will officially open the meeting. 

DR. LEWIS: Great, thank you, 

Michelle. Good afternoon, everyone. I'd like to 

welcome NOSB members of the public today to the 

National Organic Standards Board Public Comment 

webinar. And I appreciate NOSB members 

participating in this call and for all your work 

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serving on the Board. 

This webinar provides the opportunity 

for the public to provide comments to the NOSB as 

part of the Board's upcoming public, face-to-face 

meeting scheduled for October 24th/26th, next 

week in St. Paul, Minnesota. Please consult the 

NOSB website for further information about the 

face-to-face meeting. 

This meeting, like other meetings of 

the NOP, operates under provisions of the Federal 

Advisory Committee Act. And I am looking forward 

to hearing comments from the public to assist the 

NOSB in preparing their recommendations to the 

USDA in response to NOSB work agenda items. 

I want to also thank my NOP Standards 

Division colleagues for their help behind the 

scenes to bring it to today's teleconference. 

Before I turn the meeting over to Mr. 

Tom Chapman, Chair of the Board, I want to add a 

personal note. This will be the last public 

comment webinar for Tom chairing for this NOSB 

meeting. I want to thank Tom for his outstanding 

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service chairing the NOSB Public Comment Webinar 

series over the past two years. 

Tom, your leadership has resulted in 

the public comment webinar being a seamless 

process, offering increased access for the public 

to provide information to the NOSB to assist the 

Board in the development of recommendations for 

the Department. Tom, thank you again for your 

service. 

Tom, the meeting is yours. 

MR. CHAPMAN: Thank you, Paul. And 

thank for those kind words. I value these 

webinars quite a bit. And I imagine future 

chairs will also value them just as much and 

facilitate, I hope, hopefully, as seamless of a 

meeting as possible, given how much technology 

and everything else is involved in these. 

That being said, I'll just say thanks 

for all the support of the NOSB staff, 

particularly Michelle, and Devon, to help us 

identify, hunt down, and figure out whose phone 

numbers or which individuals are about to speak. 

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So thanks to everyone for making this a success, 

and we'll get started with my general comments. 

So again, I'd like to welcome everyone 

to the second public comment webinar prior to our 

Fall meeting and appreciate --- just extend a 

thanks and appreciation for everyone's time, 

including Board members, and the members of the 

public who are here to provide their feedback. 

Michelle, if you could be so kind as 

to take the roll? 

(No audible response.) 

MR. CHAPMAN: Michelle, if you're 

speaking, you're on mute. 

MS. ARSENAULT: Sorry, Tom. I was on 

mute, getting the timer ready. All right. So we 

have Tom Chapman. 

MR. CHAPMAN: Present. 

MS. ARSENAULT: Harriet Behar? 

MS. BEHAR: Present. 

MS. ARSENAULT: Scott Rice? 

MR. RICE: Present. 

MS. ARSENAULT: Jesse Buie? 

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MS. ARSENAULT: Asa Bradman? 

MR. BRADMAN: Present. 

MS. ARSENAULT: Hi, Asa. Lisa de 

Lima? 

MS. DE LIMA: Present. 

MS. ARSENAULT: All right. Steve Ela? 

MR. ELA: Present. 

MS. ARSENAULT: Thanks, Steve. 

Dave Mortensen? 

(No audible response.) 

MS. ARSENAULT: I'm not seeing Dave 

at the moment. I will come back to him. Emily 

Oakley, are you on the line? 

MS. OAKLEY: Present. 

MS. ARSENAULT: Okay, Emily. A-dae 

Briones? 

(No audible response.) 

MS. ARSENAULT: I did not find A-dae's 

number, so let me get back to her. Eric 

Schwartz? 

MR. SCHWARTZ: Present. 

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 MS. ARSENAULT: Hello, Eric. Ashley 

Swaffar? 

MS. SWAFFAR: I'm here. 

MS. ARSENAULT: All right. I'm going 

to run back through. So Rick Greenwood is not 

going to be with us today. He was unable to make 

it. Dan Seitz was not able to make it. He had 

some family issues to deal with. And Sue Baird 

is not going to be with us either. 

So let me go back here. Dave 

Mortensen, have you joined? 

(No audible response.) 

MS. ARSENAULT: If you're talking, 

you're on mute. 

(No audible response.) 

MS. ARSENAULT: All right. And A-dae 

Briones? 

(No audible response.) 

MS. ARSENAULT: All right. So, Tom, 

I count ten present. 

MR. CHAPMAN: Ten present. 

MS. ARSENAULT: Go ahead. 

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MR. CHAPMAN: Okay. Ten present, so 

we do have a quorum. And we are expecting Dave 

and A-dae to dial-in. When they do, we will note 

it if we noticed it on the call log. 

So some logistical steps, as Michelle 

already stated. Please, members of the public 

and Board members, keep yourself on mute unless 

it's your turn to talk. It's always easier for 

individuals to mute themselves. And always be 

careful, if you have a computer and a phone 

going, or a speaker phone, because the speaker 

itself might pick up feedback. Star-6 to mute, 

star-7 to unmute if you do it on your phone. 

So we'll start public comments in the 

order of the list that has been provided. If the 

commenter isn't present at the time that we call 

upon them, we'll skip them, but we'll come back 

at the end as time permits. 

At the time, going down the list, I'll 

call the speaker who is up next as well as 

several speakers after it who are on deck. The 

program and I try to ID some members ahead of 

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time to make sure the speakers are here. So if 

we can't ID a phone number, we may ask that you 

comment into the staff to ID yourself. 

Also, just be aware that we've had 

several no-shows on these, and so we may skip 

several names at a time. So just, if you're on 

the list, be prepared to speak, I guess, on very 

little notice. 

Just so we're prepared, up first is 

Johnathan Simpson. And we have not identified 

Johnathan. So if you're on the line, Johnathan, 

please do comment in to the program so we can 

identify your phone number. After Johnathan will 

be Geo Honigford, and then Justin Ellis. 

When called upon to speak, we ask that 

speakers give their full name and relevant 

affiliations for the record. We ask that you 

disclose all relevant affiliations pertaining to 

matters of business before the Board. And if 

members of the NOSB want further clarification, I 

encourage you to ask questions after the public 

commenter has finished their comments. 

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Comment times will be three minutes 

per commenter. Out of respect for the Board and 

other commenters, I ask that you finish as close 

to that three minute mark as possible. And, 

Michelle -- you'll hear a buzzer at that threeminute mark --- and, Michelle, are you ready to 

play that? 

MS. ARSENAULT: I am. Here it is, 

two, one ---

MR. CHAPMAN: There you go. 

MS. ARSENAULT: Does everyone hear 

that all right? 

MR. CHAPMAN: Begin with the 

commenter, and then I'll probably interrupt you. 

So we just ask that you finish up as close to 

that as possible. And at that point, I'll 

facilitate any questions from the Board at both 

numbers. Just speak up like we did at the last 

one, and I'll call upon you. 

We don't take any questions from the 

public for public commenters, only questions from 

the Board members. All public commenters are 

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allotted only one time slot, either in person or 

at one of the webinars, in totality. And then, 

like Michelle said, there will be transcripts of 

these calls. 

Anything else, Michelle? 

MS. ARSENAULT: No, I think we covered 

everything. 

MR. CHAPMAN: All right. Then with 

that, we'll get this started. And again, first 

up, Johnathan Simpson, are you here? 

(No audible response.) 

MR. CHAPMAN: Johnathan going once, 

going twice, all right. That was the first one. 

The next up is Geo Honigford. Geo, are you here? 

MS. ARSENAULT: Geo is on the line. 

He is muted. Let me unmute him. 

MR. HONIGFORD: Hello, can you hear 

me? 

MS. ARSENAULT: Geo, you are unmuted 

now. Go ahead. 

MR. HONIGFORD: Okay. 

MR. CHAPMAN: We can hear you now. 

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MR. HONIGFORD: Okay, great. My name 

is Geo --- Good morning, Geo --

MR. CHAPMAN: Geo? 

MR. HONIGFORD: Hello? 

MR. CHAPMAN: So after Geo will be 

Justin Ellis and then Mary Cox. Geo, you can 

start with your name and affiliation for the 

record and then go on with your comments. 

MR. HONIGFORD: Great. My name's Geo 

Honigford. I run Hurricane Flats Farm. I'm a 

certified organic farmer in Vermont, certified by 

Vermont Organic Farmers. 

So I want to talk about the paper pot 

transplanter. I've been using this since it 

first --- since I first found out about it and 

was the first farmer in Vermont to use it. So 

it's been eight or ten years I've been using it. 

It's a crazy appropriate technology for a farm my 

size. 

Basically, I'm sort of in the $150,000 

a year category for a small vegetable farm and 

often don't even have enough employees on my farm 

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to run any kind of --- other kind of transplanter 

which would take three people, one on a tractor 

and two on the back. This is something that 

plants just as fast, and it just takes one 

person. 

And so I think -- I know that they're 

working on redeveloping a formula for the paper. 

And I think they should be given time at minimum 

to allow this to happen. 

When I look at other things that are 

happening in the world of organic farming, I look 

at some of my neighbors who use reams of plastic. 

I mean, we talk about sustainability and what 

sustainable practices are. I mean, here in 

Vermont this time of year there's dumpsters full 

at the vegetable farms, organic certified 

vegetable farms, filling up with plastic that 

they use just for weed control. I mean, we're 

not looking at those issues. 

I also make a lot of hay. And the 

twine I use on my baler has been treated, and 

that's allowable, because there are no other 

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sources. If you use non-treated twine, it just 

rots and the bales will fall apart. So we've 

allowed some usage of different things when it 

becomes appropriate. And I think this is an 

appropriate one. 

So that sort of concludes my comments. 

MR. CHAPMAN: Thank you, Geo. Any 

questions from anyone on the Board? Any 

questions from the Board members? 

MS. OAKLEY: Tom, this is Emily. 

MR. CHAPMAN: Emily, go ahead. 

MS. OAKLEY: Thank you. Thank you for 

your comments. I wanted to ask you, when you 

found out that this particular pot transplanter 

is going to be discontinued for use at the end of 

this year, December 2018, do you ---

(Telephonic interference.) 

MR. HONIGFORD: So I didn't catch the 

question. It was kind of garbled. So if someone 

could repeat that on a clearer line? 

MR. CHAPMAN: Yes. Emily, you're a 

little quiet, but Emily asked just when you found 

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out that paper pots would not be allowed for the 

next ---

MR. HONIGFORD: When did I find out? 

MR. CHAPMAN: Yes. When were you 

informed? 

MR. HONIGFORD: I think it started 

this past growing season. I can't exactly pick a 

date. But I think it was just before we started 

in March or April. But I don't know exactly when 

it was. 

MR. CHAPMAN: Emily was that ---

MR. HONIGFORD: What was that? 

MS. OAKLEY: Yes. 

MR. CHAPMAN: I'm asking Emily was 

that not ---

MS. OAKLEY: Yes. 

MR. MORTENSEN: I had a quick 

question. 

MR. CHAPMAN: Dave is here. Dave, go 

ahead. 

MR. MORTENSEN: Yes, this is Dave 

Mortensen. And thank you for the call. Could 

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you explain for us how it is that the paper pots 

are helping you with your weed management? 

MR. HONIGFORD: Well, they don't help 

with the weed management. But it helps with my 

planting. I can plant -- basically, on a tray of 

onions I can plant 500 plants in about two 

minutes which would have been pretty laborious 

doing it by hand. And I could do that as one 

individual. 

I can plant faster with the paper pot 

transplanter than you do with a mechanical 

transplanter. So it has enabled me to increase 

my production without increasing my labor costs. 

Because I can plant so much quicker cheaper. 

MR. MORTENSEN: Right. And could you 

just then explain how it is that it helps you to 

not rely so heavily on plastic? 

MR. HONIGFORD: You can't use plastic 

with the system. Because you can't -- there's 

no way of poking holes through the plastic to get 

the chain to work. The chain needs to --- you 

need to pull it along the ground. You need a 

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continuous strip to operate it. So there's no 

way you could use plastic with this system unless 

you put the plastic on later and cut around it, 

which would be laborious. 

MR. MORTENSEN: Yeah, thanks. 

MR. CHAPMAN: But, yeah, just to 

clarify that point, the plastic -- and your point 

of reference is a black plastic. It's not an 

alternative to this. Black plastic won't mulch--

MR. HONIGFORD: No. 

MR. CHAPMAN: -- for a different 

purpose. You're just ---

MR. HONIGFORD: Correct. 

MR. CHAPMAN: -- saying that you see 

a lot of waste in the black plastic, and you see 

value in this --

(Simultaneous speaking.) 

MR. HONIGFORD: I'm sorry if people 

think I'm conflating the two, I'm not. They're 

two different things. But I'm simply trying to 

point out that we allow unsustainable practices 

to go on in the organic world. And since so many 

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people use black plastic, we kind of turn a blind 

eye to it even though, I think, in my opinion, 

that's a much more unsustainable practice than 

the use of a paper pot transplanter. 

MR. CHAPMAN: All right. Did you have 

a question for Geo? 

(Simultaneous speaking.) 

MS. BEHAR: That's a really a good 

question. You talked about using your baling 

twine. How do you use your hay? Do you mulch 

with that, or do you remove the twine prior to 

using the hay? 

MR. HONIGFORD: Yeah, yeah. If we use 

it for mulch, we remove the twine, because that's 

not organically approved to put into the ground. 

But most of the hay we produce, we sell to the 

horse people for feed. 

MS. BEHAR: Thanks. That was just a 

side tangent. 

MR. CHAPMAN: All right. Not hearing 

other commenters, Geo, since you mentioned it, 

I'm just going to ask real briefly, what are your 

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thoughts on biodegradable plastic mulches --

MR. HONIGFORD: I have never --- I 

obviously have never used one, given that I'm 

certified. I would love to be able to try to use 

it. I've heard they don't break down very well 

and you end up with a lot of trash in the field 

until they break down. So I think I'd give it a 

shot. So I guess I'm okay with doing it. But 

I'd rather use that than black plastic, 

obviously. 

MR. CHAPMAN: All right. Thank you --

MS. BEHAR: I have one more question. 

MR. CHAPMAN: Oh, Emily -- or, I'm 

sorry, Harriet. Go ahead. 

MS. BEHAR: Hi. So if you have to 

give up your organic certification in order to 

keep using the paper pots, do you anticipate 

that, if and when they are allowed, you would 

come back to organic certification? 

MR. HONIGFORD: Yeah. I'm not saying 

I would give up my organic certification. I'd 

probably look to switch to another type of 

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transplanter that would increase my cost, 

increase my labor force. But it could be a route 

that I go, to just dropping my certification. I 

don't know. I'd have to give it long and deep 

thought. I don't have an answer to that 

question. 

MS. BEHAR: Okay, thank you. 

MR. CHAPMAN: Okay. 

MR. HONIGFORD: But I appreciate 

everybody's time. Thank you very much. 

MR. CHAPMAN: Yeah, appreciate your 

time too. And thank you for your comments. 

MR. HONIGFORD: All right. You're 

welcome. Bye-bye. 

MR. CHAPMAN: Yes. Before we move on 

to more commenters, just for the record, Dave is 

now present, as you could tell from his question. 

And then A-dae, I believe, is also on the line 

with us. A-dae, can you say present if you're 

here? 

(No audible response.) 

MR. CHAPMAN: A-dae might be on mute. 

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A-dae, are you here? I got a text from you 

saying you joined. 

(No audible response.) 

MR. CHAPMAN: All right. Still not 

hearing from A-dae. We'll check in a moment 

again. 

So next up on the commenter list is 

Justin Ellis. After Justin is Mary Cox. Mary 

Cox, we haven't identified you yet on the list. 

After Mary is Michael Moss. Have we identified -

- yeah, Michael is here. 

 So, Justin, can you hear us? 

MR. ELLIS: Yes, I can. 

MR. CHAPMAN: And we can hear you. 

You can start with your name and affiliation. 

MR. ELLIS: Sure, yeah. Justin Ellis. 

I work for the Dramm Corporation, Manitowoc, 

Wisconsin. We produce a liquid fish hydrolysate 

fertilizer for use in organic growing. 

MR. CHAPMAN: Great, and just proceed 

with your comments. 

MR. ELLIS: Okay. Thank you all for 

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the opportunity, for allowing me to address you 

today. Specifically, I'm addressing the 

questions regarding testing the proper amount of 

acid used by liquid fish fertilizers. 

So hydrolysate liquid fish fertilizers 

typically remove no components from the fish 

scraps used in the production process, that is no 

compound proteins, microbiology, et cetera, is 

removed for other food or industrial processes. 

This creates more acid living solution 

that requires the addition of allowed acids plus 

stabilities. Without acid, the product is 

strictly rendered unusable and no longer an 

efficacious fertilizer. 

An upward drift in the pH level occurs 

as part of the normal production process in which 

hydrolysates which do not strip out physical 

ingredients such as bone oils. For example, it 

is well understood that adding calcium to various 

compounds or solutions will increase their pH. 

The fish bones, which remain and continue to 

break down in fish hydrolysate solutions as they 

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age, are one of the many factors affecting the 

upward drift. 

The Dramm Corporation has conducted 

trials which indicate that the amount of total 

acid required to maintain a pH level equal to or 

greater than 3.5 throughout the production 

process is 90 percent greater than what would be 

needed to maintain stability and yield a product 

with pH as equal to or greater than 3.5 if the pH 

level was allowed to drop below that threshold as 

has been stated in the process. 

Specifically, a greater dose of acid 

is added to fish off of slurry at the initial 

stage of production, such that its pH level drops 

below 3.05, it will eventually rise to a level 

greater than 3.5 as the solution ages in the 

vault throughout the production process. It 

ultimately gains a more stable character and 

consistency throughout the process. 

Additionally, Dramm has engaged a 

third party laboratory to conduct inoculation 

analysis to test the viability of harmful 

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bacteria surviving the introduction from outside 

sources during and after the production process 

at different pH levels. 

These tests have concluded that, at a 

pH level of 3.5, the fertilizer blend was 

effective in achieving the greater than 5-log 

reduction against E-coli and Salmonella after 24 

hours and greater than 6-log after 48 hours. 

It concluded that a minimum of 72 

hours whole time was required to eliminate the 

survival of these harmful bacteria. At a much 

higher pH level of 4.9, it took much longer for 

the bacteria kill stage to be affected, including 

that and eight-day whole time was required to 

eliminate the survival of these bacteria. 

While no specific quantitative scale 

was identified, the results strongly suggested, 

as pH rises, the risk of the presence of harmful 

bacteria increases exponentially. In short, 

lower pH levels are necessary to ensure that 

contamination of harmful bacteria cannot occur. 

So in conclusion, as we have 

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consistently practiced to date, Dramm Corporation 

is committed to maintaining a pH level of 3.5 or 

higher in its products' final form prior to their 

sale and shipment from our facilities. 

I would respectfully ask the Board to 

consider lowering the pH level guidance to a 

value closer to 3.0 in order to allow for the 

highly variable nature of the premature fish 

hydrolysate solutions. Thank you. 

MR. CHAPMAN: Thank you, Justin. 

Comments from the Board, or any questions from 

the Board? 

MR. BRADMAN: I have a question. 

MR. CHAPMAN: Asa? 

MR. BRADMAN: Two questions, one, what 

acids do you use to bring it down to screen? And 

then also, you mentioned you used fish scraps. I 

just wanted to confirm whether you also use any 

other sources of fish, such as wild fish stocks, 

for your production? 

MR. ELLIS: Sure. So the majority of 

the acid that we use is food grade phosphoric 

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acid. We also use, for one of our blends, 

sulfuric acid, which are the two that are 

approved for use in our production. 

And the second part of your question, 

we are using scrap fish from the Great Lakes 

commercial fishing fleet. So we get the scrap 

after the filets and other parts for human 

consumption have been removed. So we use no wild 

caught targeted fish species. For our industry, 

we use by-products of the commercial fishing 

fleets here in the mid-west. 

MR. BRADMAN: In the final product, is 

the phosphoric acid a significant source of 

phosphorus from the final product? 

MR. ELLIS: We get a good portion of 

our phosphorus from the bone that we let digest 

in the fish, hydrolysate fertilizers. It's not a 

significant part of, I wouldn't say. It's 

certainly a part. But as much or more so comes 

from the fish carcasses themselves. 

MR. BRADMAN: Thank you. 

MR. CHAPMAN: Other questions? 

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MR. ELA: Tom, I have a question. 

This is Steve. I just want to be clear. From my 

understanding of your comment, you would love to 

see the pH recommendation drop to 3.0 from 3.5. 

But if we leave it at 3.5, are you in favor or 

against having just the 3.5 at the end of the 

process versus trying to maintain it at 3.5 

during the process? 

MR. ELLIS: Yeah, I believe we'd 

rather have it at 3.5 at the end. Our studies 

have shown that it requires a lot more of the 

phosphoric acid to maintain that 3.5. As the 

solution ages, it would have to be a further 

addition to keep it down at that 3.5. 

Where, as I said, if we're able to 

dose it with a little higher at the beginning of 

the process, bring the pH down closer to three, 

it requires much less acid overall added to the 

product. Because it doesn't tend to rise, the pH 

doesn't tend to rise as it ages. 

MR. ELA: Great. I just wanted to 

make sure I understood that correctly. So thank 

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you. 

MR. ELLIS: Yes. 

MS. BEHAR: This is Harriet. So I'm 

just kind of wondering, I think your process is 

somewhat unique in how this might affect other 

people who make fish emulsion if it was lowered 

to 3.0. 

MR. ELLIS: Well, we're making a fish 

hydrolysate which is quite a bit different than 

fish emulsion. There's a number of other 

companies primarily based out on the East Coast 

that also make fish hydrolysate. 

Fish emulsions tend to be a heated 

product where oils, and potentially bone meals, 

and other collagens, and other products are 

removed from the product as it's being processed. 

So I'm guessing that other hydrolysate 

manufacturers would run into the same issues that 

we have in that the addition of acid at the 

beginning will slow the evolution and the upward 

rise in pH. 

And, you know, we've found that this 

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bony fish that we use here in the Midwest, that 

that happens fairly quickly. And potentially the 

guys on the East Coast, if they're dealing with 

more cartilage at the base, they might not have 

the same issues that we do. 

MS. BEHAR: Thank you. 

MR. CHAPMAN: Any other questions for 

Justin? 

Justin, I just want to follow-up on 

your written comments on what answered to AFIS. 

So you don't use -- you don't use whole fish 

unless it comes to you via an agency or something 

for invasive control. What's the reasoning for 

not using the whole fish? Is it an economic --

MR. ELLIS: No. I think it's more of 

just the ethics of how we're trying to -- we're 

trying to divert a potential waste stream. And 

the company started by scraping alewives, which 

were a herring-type fish, off the shores in 

northeastern Wisconsin. 

And it's primarily a waste stream 

diversion that's really grown. We do get some 

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invasive Asian carp occasionally, but it is not 

something that we've ever spent time researching 

or been interested in. I just want to be 

procuring whole fish. You know, we're not 

interested in catching wild fish just to grind 

them up and turn them into a fertilizer. 

MR. CHAPMAN: Are you aware of 

competitors that have that as part of their 

supply chain, or is that common in this 

marketplace, the whole fish -- whole fish? 

MR. ELLIS: As far as I know, there 

are some emulsion companies that do target whole 

fish with the idea that they will be caught --

(Telephonic interference.) 

MR. ELLIS: -- for fertilizer. But 

I'm not sure as far as the hydrolysate companies 

how they're sourcing whole fish. 

MR. CHAPMAN: Okay. Thank you very 

much. 

MR. ELLIS: Thank you. 

MR. ELA: Tom, I have a ---

MR. CHAPMAN: Oh, go ahead. 

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MR. ELA: Tom, I have a follow-up 

question. 

MR. CHAPMAN: Go ahead, Steve. 

MR. ELA: Yeah, this is Steve. Could 

you just -- you talked about hydrolysate and 

emulsion products. Could you clarify the 

difference between the two for me? 

MR. ELLIS: Sure. So what we make is 

a -- it's a hydrolysate product. So we're 

getting the fish scraps in. It's not any real 

big secret to it. We grind them up, and then we 

do a secondary grind. We add it to a tank. 

And what's happening is the enzymes 

that are naturally present in the fish themselves 

are what's actually breaking the fish down, 

breaking the product down into a liquid once it's 

in our storage tanks. It's done at very low 

temperatures. And the hydrolysates generally 

aren't removing any products or anything else. 

Where emulsions, they start with 

mainly fish scrap or a whole fish that are being 

ground up. And then it's usually heated up, 

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because they're looking to extract oils. Those 

oils can go into the cosmetic industry, they can 

go into the, like, fish oil for human consumption 

industry. 

Sometimes they'll also remove the bone 

then at that point. And that could be sold as 

bone meal. And what you're left then is sort of 

a concentrated, usually a higher nitrogen, lower 

phosphorus, lower potassium product that is quite 

a bit different than the hydrolysates that we 

make. 

MR. ELA: Thank you. 

MR. ELLIS: You're welcome. 

MR. CHAPMAN: Okay. Justin, thank you 

again for your time --

MR. ELLIS: Thank you guys. 

MR. CHAPMAN: -- and your comments 

here. So up next we have Mary Cox, and then on 

deck is Michael Moss, and then Jay Kurtz. Mary, 

are you here? 

MS. COX: Yeah, we're here. 

MR. CHAPMAN: Excellent. We can hear 

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you. Mary, you can start with your name and 

affiliation and then proceed into your comments. 

MS. COX: Okay. 

MS. ARSENAULT: Tom, I'm sorry. If I 

could interrupt just for one second to remind 

Mary. I have your PowerPoint slides loaded, and 

you'll have to cue me to advance to the next 

slide. 

MS. COX: Okay. So it's my cousin, 

Conor Buckley, and we both work with Socius 

Ingredients. And we're both going to speak. So 

Conor is going to start, Conor Buckley, on Page 

1. 

MR. CHAPMAN: So just --- Mary, sorry, 

it's a formality of our process that we only 

allow one speaker at a time for a slot. So we're 

going to need ---

MS. COX: Oh. 

MR. CHAPMAN: -- either you or Conor 

to speak but not both. I apologize. 

MS. COX: Okay, okay. 

(Off-record comments.) 

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talk about the challenges in securing organic 

tamarind seeds. Because I think that was one of 

-- some comments that were online, if that's 

okay. 

MR. CHAPMAN: Yes, go for it. 

MS. COX: Okay. 

MR. CHAPMAN: And I will start your 

time now. But if you could start with your name 

and affiliation for the record. 

MS. COX: Okay. So I'm Mary Cox, and 

I work with Socius Ingredients. And on Page 2 of 

the PowerPoint, the company was formed in 2000 

for a food ingredient company. And we're focused 

on proteins, natural colors and hydrocolor 

corollaries. 

So tamarind seed gum is Glyloid brand, 

and it was manufactured --- oh, do you mind going 

onto Page 3 --- manufactured by DSPG in Goyko in 

Japan. In 2004, it got FDA generally recognized 

as safe accreditation. And in 2018 --

(Telephonic interference.) 

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MS. COX: -- Canada accreditation. 

So I'm going to talk about the 

challenges in securing organic tamarind seed. 

Just as a reminder, the tamarind tree produces a 

pod-like fruit. When someone thinks of tamarind, 

they are referring to the pod, but 34 percent of 

the pod is actually seeds. 

Tamarind seed gum is made from the 

seeds. And while they're part of the commercial 

part of the pod, the seeds are underutilized 

byproducts. There are many applications possible 

with the seeds, but at the moment their 

commercial use is limited to the textile, paper 

binding, and food additive industries. 

Would you mind going onto Slide Number 

5, please? 

So the epoxy and other applications of 

the gum are directly linked to the procurement of 

the best quality seeds. DSPG sources the 

tamarind kernel and powder from India and 

Thailand. Seventy-eight percent of the seed is 

kernel. The seed must be wilted to remove the 

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kernels from the shell, and afterwards then the 

kernel can be transported to another factory for 

grinding and grating into powder. 

In India, the seeds there are procured 

from wide and vast geographical areas and are 

sold in open markets. The textile industry is 

very large in India and seeds are mostly used as 

sizing agents to help strengthen yarn. 

Only a select amount of white seeds 

are used for gum manufacture. However, seeds for 

both industries are roasted and grinded in the 

same plants. The food additive industry is too 

small to have separate roasting and grinding 

plants. 

In Thailand, Tamarind trees grow 

naturally wild across the country. Seeds are 

generally discarded as waste, but some farmers 

manually removed the seeds from the pod as a side 

job. DSPG is the only company purchasing 

tamarind kernel powder from Thailand. 

We contacted the Organic Certification 

Board in Thailand, ACT, but we weren't able to 

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procure organic certified seeds. In our 

research, we contacted organic tamarind suppliers 

in Thailand and India. But each time they can 

only provide us with organic tamarind pulp 

powder. 

Organic pulp can't make tamarind seed 

gum. If they are organic certified fruit, we 

can't guarantee these seeds will be the highest 

quality for tamarind seed gum. To add to the 

complexity, roasters and grinders would also need 

to become organic certified. In India, the 

amount of seed for their food industry is so 

small compared to the textile industry that 

there's really no incentive for these plants to 

become organic certified. 

And finally, where we've used tamarind 

seed gum, it can -- it can be substituted for 

PGA, and polysorbates, and other ingredients. 

MR. CHAPMAN: Thank you, ma'am. And 

then I have to stop you ---

MS. COX: Okay. 

MR. CHAPMAN: -- I'm going to have to 

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stop you there since you've reached your time. 

But are there any questions from the Board? 

MS. BEHAR: Yes. This is Harriet. 

Have you tried to work with growers that 

currently provide the tamarind seeds that you're 

using for making into gums and see if they will 

get certified? 

MS. COX: So we have contacted, 

through DSPG in Japan, the tamarind kernel powder 

suppliers. Because DSPG gets the powder from 

India and Thailand. And we have contacted them. 

And they -- right now, at the moment, they say 

that it's unavailable. 

The growers are, like, in Thailand, 

the trees are just -- they're naturally growing 

around the country. And small farmers are 

picking it up as a side job. And then in India, 

the main reason that seeds are collected is for 

the textile industry. But we've done, like, the 

research with contacting organic certifiers, et 

cetera. 

MS. BEHAR: So from what I can see on 

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the National Organic Programs' Organic Integrity 

Database, it seems that there is some organic 

tamarind seed available. So I'm just kind of 

wondering about have you tried to facilitate the 

production of the tamarind seed gum by working 

with organic tamarind seeds or with the ---

(Simultaneous speaking.) 

MS. BEHAR: Go ahead. 

MS. COX: Yes. On the National 

Organic Database, there is organic tamarind 

powder and pulp. But there isn't organic seeds, 

from my search. But if there was seeds, then we 

would definitely be open to use organic seeds if 

they were the right quality for the gum. 

MS. BEHAR: All right, thank you. 

MR. CHAPMAN: Any other questions for 

Mary? 

(No audible response.) 

MR. CHAPMAN: Mary, I have a question. 

You talked about the sourcing in India through 

open air markets. I'm not sure everyone on the 

Board may be familiar with that. Are you able to 

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describe that in any more detail of, like, what 

that is, how that functions, the number of 

operators that may be involved? 

MS. COX: As much as I know about 

this, the seeds are mainly used in the textile 

industry there. And they're collected from, like, 

all around India and sold. And that's all I know 

so far on that. They do go to roasters, and they 

can be different plants, manufacturing plants 

that roast them. And then they're transferred to 

be ground in other manufacturing plants. 

MR. CHAPMAN: Okay. 

MS. COX: Yes. 

MR. CHAPMAN: Can you ---

MS. COX: I feel like --- it seems 

like it's very disorganized there and that the 

seeds, you know, are the by-product of the 

tamarind industry with the cause. 

MR. CHAPMAN: Okay. Thank you. I 

believe we don't have any other comments or 

questions for you, Mary. 

MS. COX: Okay. 

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MR. CHAPMAN: So thank you for your 

time. 

MS. COX: Thank you for your time. 

MR. CHAPMAN: Okay. Up next we have 

Michael Moss, followed by Jay Kurtz, and then 

Michael Luna on deck after that. Michael Moss, 

are you here with us? 

MR. MOSS: I am. 

MR. CHAPMAN: All right, we can hear 

you. You can start with your name and 

affiliation for the record. 

MR. MOSS: Thank you. My name is 

Michael Moss. And I'm an organic farmer in 

Boulder County, Colorado, certified by OPIA and 

speaking on my own behalf. 

Thank you for the opportunity to 

comment on the use of paper pots in my OSP. In 

the past, I have used cardboard and newspaper as 

mulches to help combat weed pressure and also 

help build compost. 

All of these materials were of varying 

qualities, with various inks, protective gloss 

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layers, and materials that I've started to feel 

uncomfortable with in the organic system. My 

focus as a farmer is to grow the highest 

nutritional quality produce possible, and it 

starts with my soil. In light of this inner 

conflict, I stopped --

(Telephonic interference.) 

-- I stopped using waste stream 

cardboard and paper in my operation. Four years 

ago, I started using the paper pot system, as I 

felt comfortable with the material. And --

(Telephonic interference.) 

MR. MOSS: -- accounts for 

approximately 20 percent of my yearly --

(Telephonic interference.) 

MR. MOSS: This allows me to have a 

higher germination rate and a reduced weed 

pressure. I also find that the use of this 

system is a huge labor savings for my farm, 

helping us achieve higher levels of 

sustainability. 

I have seen that, even in the dry 

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front range of Colorado, that the paper pots 

breakdown in the soil without any noticeable 

detrimental effects. When I decided to become 

certified two years ago, OTIA was very diligent 

in their process of certifying my farm. This 

included approval to use the paper pots as part 

of my LST. 

This process took months and much 

research on their part. One of my largest items 

by revenue is a salad mix. This mix is made up 

of fully matured lettuce heads that are harvested 

and then mixed to create a nutrient dense weed 

free salad mix. 

We use the paper pots to plant over 

4,000 heads of lettuce each week in our growing 

season. Without the paper pot system, we'll be 

forced to move to hand planting starts or a 

direct seated salad mix. 

Both of these current options will be 

highly detrimental to the value and success of 

these products. It's my request that the NOSB 

complete a full technical review of the paper 

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pots in organic systems. 

Organic farmers like myself who 

utilize the paper pots still have on hand 

supplies that we are not able to use during most 

recent growing season. I request that organic 

farmers that have been approved by the certifiers 

use this material to continue to use the paper 

pots during this review period so as not to waste 

money and materials. 

As an organic farmer, I'm committed to 

soil health and organic standards, but I also 

must balance the viability and longevity of my 

operation and its impact on my community, family 

and staff. 

I have been in discussions with OCIA, 

but I may need to no longer certify as organic 

all the parts of my farm if I cannot use the 

system. This decision process pains me deeply as 

I am fully committed to the principle of organic 

and regenerative farming. 

But thank you for your time. I hope 

that you can support the petition to allow the 

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use of paper pots on certified organic farms and 

uphold technical review of the materials. 

MR. CHAPMAN: Thank you, Michael. Any 

comments for Michael or any questions for 

Michael? 

MS. BEHAR: I have a question. 

MR. MORTENSEN: And I have one as 

well. 

MR. CHAPMAN: So we'll go with Harriet 

and then Dave. Harriet, go ahead. 

MS. BEHAR: Do you use paper in any 

other way on your farm, as a compost feed stock, 

or as a mulch? 

MR. MOSS: I do not. I've moved to 

growing my own mulches through cover cropping, 

and either mulching that in place on the fields, 

or harvesting that sort of used as compost. 

MR. MORTENSEN: So to the decision to, 

you know, sacrifice your certification is a 

pretty extreme one. Could you, you know, 

identify, like, the one or two constraints that 

make this particular loss of this tool so 

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important to your operation? 

MR. MOSS: Well, in Boulder County, we 

are a rapidly gentrifying population, and labor 

constraints are the number one greatest challenge 

to myself and other farmers in the county. As 

Colorado raises the minimum wage, it's really 

hard for us to find people who can support the 

work of the farm. 

So by having to move to hand planting 

each succession of lettuce, we're just not going 

to have the bodies to grow this product. And 

this is a product that I actually put out in a 

labeled, branded clam shell to compete against 

imported lettuce products from other parts of the 

country. And it's really taking off and has been 

a great exposure for our farm. 

MR. MORTENSEN: Thank you. 

MR. CHAPMAN: So, Michael, definitely 

this is -- economics is the reason for it. 

Otherwise, you'd have trouble making a 

profitable, competitive product. 

MR. MOSS: I would say economics is a 

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large component of it. Also for us, these soils 

that I'm on, publicly owned land, Boulder County 

open space, the weed pressure and the soil 

conditions are very challenging. So with the 

paper pot system, I can transplant a start very 

rapidly into a freshly cut bed. 

So I'm getting a head start on my weed 

management. And then I can come in with basket 

weeders or tools to be able to manage the weeds. 

As our properties improve, hopefully this is will 

go down, but right now, labor and weed pressure 

are some of my biggest concerns on the farm. 

MR. MORTENSEN: Could I just ask one 

more question? 

MR. CHAPMAN: Yes. 

MR. MORTENSEN: Could you explain for 

the Board how it is that the transplanting helps 

your weed management? 

MR. MOSS: Of course. So on the paper 

pot system, we start this --- we'll start a tray 

of lettuce in our greenhouse. And we would 

direct feed it. It would germinate, and we'd get 

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to the point where it's about the third set of 

true leaves, maybe the second set of true leaves. 

That's when we'd transplant them in the field. 

So before we transplant, we will go 

through and do a final prep stage which may be 

tilling or flame weeding the beds. And then we 

will plant the paper pots. 

So at that point, the head start is 

weeks over the weeds. So now we can come in with 

hand tools or our mechanized tools when the weeds 

are at thread stage and the lettuces are fully 

growing. 

MR. MORTENSEN: Thanks. So there're 

some clear agronomic as well as economic reasons, 

and labor, to have access to the tool. Thank 

you. 

MR. MOSS: Correct, thank you. 

MR. CHAPMAN: Any other questions? 

MS. OAKLEY: Tom, can you hear me, 

this is Emily. 

MR. CHAPMAN: You're a little quiet, 

Emily, but go ahead. If Michael can't hear it, 

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I'll try to repeat the question. Emily, go. 

MR. MOSS: I can hear. 

MS. OAKLEY: I'm talking a little 

louder. I just wanted to let you know that the 

Board has discussed this at length on the Crop 

Subcommittee. And we'll be discussing it at the 

meeting. 

Our current limitation right now is 

that we received the petition for the material 

too late in the process to have it on this 

meeting's voting docket. 

Because we really just had a couple of 

weeks turnarounds between each meeting, and 

really we would have to have a proposal ready for 

this meeting. And that didn't give us sufficient 

time to discuss whether or not we needed a 

technical review, et cetera. 

So right now, hopefully, we'll be able 

to have some dialogue with the National Organic 

Program to see if there might be the possibility 

of an extension of that 2018 deadline. They have 

some concerns about precedent setting, but we're 

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hoping that we might be able to continue that 

dialogue at this meeting and -- further back 

won't even be the product. 

So I just wanted to give you a little 

bit of the background of how that process works. 

And thank you so much for your comments. 

MR. MOSS: Great. Thank you for the 

explanation. 

MR. CHAPMAN: Any other questions 

from Board members? 

(No audible response.) 

MR. CHAPMAN: Hearing none, Michael, 

again thank you very much for your time and your 

detailed testimony here. 

MR. MOSS: Thank you. 

MR. CHAPMAN: So up next we have Jay 

Kurtz, followed by Matthew Luna. Matthew Luna, 

we haven't been able to identify you on the list. 

So if you're there, please text us in, and then 

after Matthew is Patty Lavera. Jay, are you on 

the line with us? 

MR. KURTZ: I am. 

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MR. CHAPMAN: All right, Jay. You can 

start with your name and affiliation for the 

record. 

MR. KURTZ: Thank you, Tom. My name 

is Jay Kurtz, and I am speaking today on behalf 

of Devrow. Devrow is a maker of collagen gel for 

the food industry, solely used in the skin, 

excuse me, as the skin in the making of sausages. 

For background, over about the past 15 

years approximately 50 percent of the fully 

cooked sausage category in the United States 

transitioned from using traditional intestine and 

cellulose casing in favor of collagen gels that 

are run through a full extruding sausage system. 

The food safety of these sausages, 

excuse me, of the sausages that are made using 

collagen gel as the casing, or as the skin, is 

frankly unparalleled. And the quality of the 

product is of the highest standard. 

As the market has and continues to 

evolve, the ability to meet consumer demands for 

skin-on organic sausages is certainly limited to 

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intestine casings which is becoming a significant 

barrier. 

Taking into consideration the 

precedent set of including process intestines on 

the National List 606, one of the key basis 

points was that there was an inability to amass 

enough organic runners or an identity preserved 

run. 

The same holds true in that regard for 

collagen gel in that there's a lack of specific 

type and cuts of animal skins that are necessary 

to make these collagen gels. 

Also, recognizing that gelatin is 

included on National List 606, and understanding 

that gelatin is derived from numerous collagen 

sources of an animal, as an example skin, bones, 

tendons, et cetera, gelatin is a further 

processed and de-natured, compared to collagen 

and compared to the animal skins used in collagen 

gel production. 

Based upon highlighting these two 

preceding examples, which are also detailed in 

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the submitted petition, Devrow does believe that 

strong consideration should be given to collagen 

gel during the 2019 spring meeting to be included 

on National List 606. 

That concludes my commentary today. 

I thank you for the time and consideration and 

look forward to any questions. 

MR. CHAPMAN: Thank you, Jay. Any 

questions for Jay? 

(No audible response.) 

MR. CHAPMAN: Jay, I am not hearing 

any questions. 

MS. DE LIMA: This is Lisa. I have a 

question. 

MR. CHAPMAN: Oh, Lisa, go ahead. 

MS. DE LIMA: Hi. So when you were 

talking about there being significant barriers, 

is that specifically you're talking about having 

single animal casings? There's not --- or is 

there actually a ---

MR. KURTZ: Well, it's twofold. 

MS. DE LIMA: -- an issue? 

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MR. KURTZ: Yes. It's twofold. It 

could be specific to single species sausage and 

single species casings or, more so, based upon 

traditional or different types of equipment used 

to make the sausage. 

So a collagen gel is different than a 

typical casing that would be stuffed with 

whatever type of meat is better to make the 

sausage. A collagen gel requires a specific type 

of equipment in order to make a co-extruded 

sausage, meaning the meat and the collagen gel 

are extruded or plugged at the same time, never 

requiring any hands to be touching that product. 

So it is twofold. It doesn't relate back to --

but it also relates back to the equipment used to 

make a sausage. 

MS. DE LIMA: As a follow-up to that, 

so it doesn't relate back to -- you're not saying 

that there's an issue of quantity to use the 

casings that are currently on the National List? 

It's a preference for equipment and for the 

single species. 

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MR. KURTZ: I would say that is a fair 

answer, yes, indeed. 

MS. DE LIMA: Okay, thank you. 

MR. KURTZ: You're welcome. 

MR. CHAPMAN: Okay, any other 

questions for Jay? 

(No audible response.) 

MR. CHAPMAN: Hearing none, Jay, thank 

you for your comments here today. 

Up next, well, do we have Matthew on 

now? Matthew, we haven't been able to identify 

your phone number. Are you on the line with us? 

(No audible response.) 

MR. CHAPMAN: Matthew, going once, 

going twice, all right. Next on my list was 

Patty. Patty, you're here, is that correct? 

MS. LUMA: Yes. 

MR. CHAPMAN: All right, we can hear 

you. Patty, hold on one second though. So James 

Paskind is up after that. James, we see you on 

the web portion, we don't have your phone number 

identified. So if you know your phone number, if 

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you could message that in to us, you could be 

ready to go next. 

And then Evan Perkins is after James. 

Evan, we haven't identified you. If you're on 

the line, please message in. And then after 

Evan, just so people are aware, is Deborah 

Attwood. So Deborah, you might be coming up 

quickly. 

Patty, if you could start with your 

name and affiliation for the record. 

MS. LOVERA: Sure. Hi, my name is 

Patty Lovera. I'm with Food and Water Watch, and 

we appreciate the opportunity to comment. We're 

also a member of the National Organic Coalition. 

So I just wanted to talk quickly about 

a couple of things. I know you heard we've 

received a bunch of things, a big group letter 

which we have signed onto. We submitted a 

petition from our membership, as well talking 

about the need to add energy infrastructure and 

impacts on organic to your agenda. 

And I think you heard quite a bit 

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about this on Tuesday which, you know, we're 

working in support of developments that you heard 

on Tuesday. We think this is an important issue 

that really needs some discussion with the lens 

of organic for a couple of reasons. 

One is just to really show the extent 

of the impact. It's obviously growing sites and 

what happens if agricultural land and organic 

agricultural land is the site of some kind of 

natural gas or oil drilling. 

But there's also other pieces of this 

industry that ends up impacting food producing 

land as well from the wastewater disposal, their 

fracking and mining in certain parts of the 

country to the source of water they needed for 

fracking and then the pipelines to get that gas 

to some kind of market. So there's a lot of 

areas with -- conflict with the places that we 

produce our food. 

I put a lead in our written comments 

that are submitted just of one news story that 

came out very recently in West Virginia. There 

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was an organic grower in the news that a 

helicopter came over his land. 

They were supposed to be dropping, you 

know, soil stabilization materials on a pipeline 

site not too far away. They hit his farm 

instead, and there was a lot of confusion about 

what that meant for his certification because all 

of this unapproved material was suddenly all over 

his farm. 

And I'm sure we're going to be hearing 

more and more of that. But the idea of putting 

it on the work plan for NOSB is to raise the 

awareness of this in the organic community, that 

people need to be proactive and have some 

guidance, including these impact mitigation plans 

that OFA and others are putting out there to get 

certifiers aware of that and spreading the word 

so that folks can protect themselves the best 

they can with this process, and also to raise the 

awareness of this process impact, the places 

where we raise our food, including organic food. 

So that's probably enough on that. I 

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think you've heard quite a bit about it and 

we're, you know, fully in support of having that 

conversation start. 

And then quickly, there have been a 

couple of other issues of enforcement, and 

oversight, and accreditation. I think you also 

heard about this from NOP. We support, you know, 

really focusing on improving the acreage data 

collection. We think this is an important part 

of how we understand the organic industry. 

But we think it's also an important 

part of kind of kind of verifying surges or 

changes we might see that are an important part 

of making sure NOP --- you don't have the 

opportunity for fraud. 

And then in the document that you all 

have about the accreditation oversight, we have 

some other things we put in our written comment 

in addition to what you all have in your 

discussion paper, including having NOP be able to 

investigate surges and enforce and, when 

equivalent, country partners take some action, 

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that we look at taking the same action. 

And the last piece I'll say is that we 

think the standards themselves are an important 

part of having --- I don't know if you'd be able 

to have that oversight, so things like the 

livestock practices and things we would really 

urge, you know, people take another look at. So 

thank you. 

MR. CHAPMAN: Thank you, Patty. Any 

questions for Patty? 

(No audible response.) 

MR. CHAPMAN: All right, Patty, not 

hearing any questions. Thank you for your 

comments here today. 

MS. LOVERA: Thanks. 

MR. CHAPMAN: Up next we have James. 

James, are you with us? 

MR. PASKIND: I am. 

MR. CHAPMAN: All right, James. So 

after James is Evan Perkins. Evan, we still 

haven't identified you so please, again, message 

us in if you're on the line. After James is 

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Deborah Attwood, and then David Ehreth. I've 

just butchered that. 

James, if you'd start with your name 

and affiliation for the record. 

MR. PASKIND: Certainly. My name is 

James Paskind. I'm a senior manager of Salm 

Partners, LLC. First of all, I appreciate the 

opportunity to provide input on the Devrow 

petition to include collagen gel in 7 CFR 

205.606. 

Salm Partners is a contract 

manufacturer. We make high quality, food safe, 

sausage products. Our product portfolio includes 

many "better for you" products including many all 

natural sausages. All of our sausage products 

are made with collagen gel as the product casing. 

We are here speaking today in support 

of the Devrow petition to add collagen gel to the 

National List, and we believe their proposal to 

be fact-based and rational. We're also hopeful 

that the technical review, as we understand, is 

underway and will support the petition details. 

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 But my primary purpose today is to 

describe the marketplace demand for organic 

sausages in a collagen casing. So first I'll 

address the growing preference for collagen 

casing sausages overall, and second, specifically 

address the unmet demand for organic sausages. 

The fully cooked sausage category has 

transitioned from sausage stuffed in processed 

pig intestine as the casing to collagen casing 

sausages made from collagen gel. Collagen 

casings now represent nearly half of the fully 

cooked sausage category, and there's consumer 

research that indicates an overall preference for 

collagen casing sausage products. 

Regarding organic sausages 

specifically, all the recipe ingredients, the 

meats, the seasonings, the condiments, are 

available as organic ingredients. The options 

for the sausage casing, which is less than one 

quarter of one percent of the formula, however, 

are much more limited in fully cooked sausages. 

Currently, the only casing option for 

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inorganic sausage is processed intestines which 

is included on the National List. So a lot of 

the sausage category, as driven by consumer 

preference, has evolved for collagen casings made 

from collagen gel. There's no opportunity for an 

organic sausage made with collagen gel. 

A specific example worth discussing 

briefly, of this unmet need, is chicken sausage. 

Chicken sausage is a high-growth segment of the 

fully cooked sausage category. Many of these 

products are blends of low-fat chicken and 

various vegetables and condiments. Many are also 

all natural products, and all of them can be 

considered "better for you" products. 

The only opportunity for organic 

offerings in this segment requires processed pig 

intestine casings. So this is an obvious show 

stopper for consumers that desire a high quality 

chicken sausage but will never purchase a product 

that includes a pork component. So a product 

named chicken sausage made with pork casings 

obviously is a significant limit in terms of 

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options for these consumers. 

Collagen gel solves the issue. It 

provides consumers interested in an organic 

chicken sausage a fully acceptable offering 

satisfying an unmet demand. This same rationale 

would, of course, apply to sausages made with 

other non-pork species such as an all-beef 

sausage. 

That concludes my comments, and I 

appreciate the opportunity to address the Board 

on this petition. Thanks very much. 

MR. CHAPMAN: Thanks, James. Any 

questions for James? 

MR. BRADMAN: I just have some 

questions. When you say, excuse me, there's more 

opportunity for single species products with 

collagen gel, so perhaps also what you're getting 

it is that there's more opportunity for Kosher 

products, say with the chicken sausage. Could 

you comment on that? 

MR. PASKIND: I believe there is. And 

right now Kosher products, for the most part, in 

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this category are cellulose casing. So the 

casing is stripped, and there is no casing 

involved. 

But certainly if there's the 

opportunity to procure -- and we understand there 

is -- Kosher collagen from Kosher livestock, then 

yes, the opportunity for Kosher would be expanded 

beyond the current. 

Because the same barrier exists with 

a processed pig intestine, as we've talked about. 

Obviously, for more than one reason, that's not 

the only proposal. But yes, that would be an 

additional aspect of the market that would be 

made available. 

MR. BRADMAN: Thank you. 

MR. PASKIND: Certainly. 

MR. CHAPMAN: Any other questions? 

(No audible response.) 

MR. CHAPMAN: Hearing none, James, 

thank you for your comments here today. 

MR. PASKIND: Thank you. 

MR. CHAPMAN: All right, up next we 

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have Evan Perkins. Evan, we haven't been able to 

identify you. Are you on the line with us, Evan? 

(No audible response.) 

MR. CHAPMAN: Evan going once, going 

twice, all right, Evan. We will pass. Up next 

we have Deborah Attwood. Deborah, are you here 

with us? 

(No audible response.) 

MR. CHAPMAN: Deborah, you might be 

mute on your side. I see you online, but I don't 

hear you. 

MS. ARSENAULT: I don't show her line 

as muted. So, I'll try to ---

MS. ATTWOOD: Can you hear me now? 

MR. CHAPMAN: Yes. Yes, we can, 

Deborah. 

MS. ATTWOOD: Okay, sorry about that. 

MR. CHAPMAN: Yeah, no problem. Hold 

on one second. So after Deborah, on deck is 

David Ehreth, and then Jim Adaskaveg. I'm sorry, 

Jim, I just butchered that. 

But, Deborah, if you start with your 

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name and affiliation. 

MS. ATTWOOD: Sure, thanks. Good 

afternoon, my name is Deborah Attwood. I'm an 

attorney with Steptoe and Johnson here in 

Washington, D.C. And I'm commenting on behalf of 

PURE Bioscience who is a petitioner seeking the 

addition of silver that hydrogens situate to the 

National list. 

Thank you for the opportunity to 

provide additional support for why the use of 

sulfur dihydrogen citrate, or SDC, in organic 

food processing and handling presents a 

reasonable certainty of no harm to the safety of 

human health or the environment. 

SDC has been the subject of robust 

reviews by two federal agencies, the Food and 

Drug Administration, and the Environmental 

Protection Agency. FDA reviewed the safety of 

SDC through its Food Contact Notification Program 

which is an internationally renowned program that 

establishes the safety of substances for contact 

with food. 

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EPA has reviewed the safety of SDC as 

part of the pesticide registration process under 

FIFRA, the Federal Insecticide, Fungicide and 

Rodenticide Act. Both agencies evaluated the 

impact of SDC on human health and on the 

environment. And both agencies concluded that 

SDC is safe for its intended use. 

As part of this review process, the 

information that PURE Bioscience provided to FDA 

and EPA was comprehensive. It included detailed 

descriptions of the chemical identity of SDC and 

its composition, including any potential 

impurities or by products that could result from 

its use. 

PURE Bioscience described how SDC is 

manufactured, and how it's intended to be used, 

and provided data to show that SDC killed food 

borne pathogenic organisms. 

Based on all of this information, both 

agencies evaluated how much SDC humans could 

potentially be exposed to under a worst case 

scenario and how much SDC could potentially get 

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into the environment, again using worse case 

assumptions. 

Both agencies would have considered 

the potential impact that a nanoscale substance 

could have on safety, but this was unnecessary, 

typically because SDC is not nanotechnology. 

To support the safety of these 

reviews, PURE Bioscience provided specific 

toxicological studies that demonstrated a wide 

safety margin between the worst case exposures as 

compared to potential levels of concern. 

Neither agency would have permitted 

SDC to be placed on the market unless they were 

convinced of the safety of the product for its 

intended use. 

In addition to these federal reviews, 

FDC is also a registered pesticide in California, 

a state that's recognized for its own stringent 

safety review for antimicrobials. 

Based on these existing comprehensive 

and conservative reviews by these agencies that 

have the relevant expertise to evaluate the human 

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and environmental safety of SDC, we respectfully 

submit that SDC would be a beneficial addition to 

the National List for use in organic food 

processing and handling. Thank you. 

MR. CHAPMAN: Thank you. I will start 

with some questions, and then open it up to the 

floor for some questions. 

So we've heard some public comment or 

received some public comment stating that SDC 

will break down into nano particles when in use. 

Do you have any further information to provide 

about comments received related to SDC and 

nanotechnology? 

MS. ATTWOOD: Sure. So PURE 

Bioscience, we did submit some additional --- we 

recognized the comments that were submitted to 

the docket on nanotechnology and did also provide 

our own additional comments responding to those. 

From a technical aspect, the 

representative from PURE Bioscience who will be 

attending the meeting will be better positioned 

to explain this for you. But the short answer is 

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no. 

SDC, in and of itself, it's not 

nanotechnology when it's made. It's an ionic 

substance. And then when it's used, it's not 

going to break down into anything further that 

what it already is. So while we understand the 

thought process that might lead to those 

concerns, from a scientific perspective they are 

just misplaced. 

MR. CHAPMAN: We received other 

comments about growing bacterial resistance to 

silver compounds and, you know, some scientific 

research that spoke to you, the need to 

essentially limit the use of silver in medical 

situations. Do you have any comments related to 

that? 

MS. ATTWOOD: So again, the product as 

it's used uses an incredibly low level of silver. 

And that's one of the benefits of SDC, is that 

it's a very narrowly tailored and an extremely 

low level of silver that's used in order to 

achieve the antimicrobial effect. 

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 Because overall, we consider that the 

benefits from using SDC and the potential for 

reduction in food borne illness would instead 

reduce the potential for antimicrobial resistance 

and have less food borne illness potential and, 

you know, most people come to doctors and get 

antibiotics and that type of medication. 

MS. OAKLEY: I also understand that 

another caller today will be commenting on that 

particular question as well. 

MR. CHAPMAN: Okay, thank you. Any 

other questions from Board members? 

(No audible response.) 

MR. CHAPMAN: I am not hearing any. 

So thank you for your comments here today --

MS. ATTWOOD: Thank you. 

MR. CHAPMAN: -- Deborah, and we'll be 

moving down the list. So next up is David 

Ehreth, and then following that will be Jim 

Adaskaveg. And after Jim will be Katherine 

DiMatteo. David, are you here online with us? 

(No audible response.) 

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MR. CHAPMAN: No, you're muted, David, 

on our end. Hold on. All right, you're unmuted. 

David, are you --- well, we've tried to unmute 

you at the same time. David, are you there? 

(No audible response.) 

MR. CHAPMAN: David? Are you getting 

it on your end? We're not hearing you. 

(No audible response.) 

MR. CHAPMAN: David? I'm not hearing 

you. So, Jim, are you on the line with us? 

MR. ADASKAVEG: Jim Adaskaveg here. 

MR. CHAPMAN: Yeah. All right, Jim, 

we got you. So David, if you can message in, for 

some reason we're not getting any audio from you. 

So we'll come back if we can figure it out. 

Jim, if you can start with your name 

and affiliation and proceed with your comments. 

MR. ADASKAVEG: Yes, I can. I'm Jim 

Adaskaveg. I'm a professor in the Department of 

Plant Pathology and Microbiology at the 

University of California, Riverside. I 

specialize in mycology, bacteriology, and 

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epidemiology of plant diseases. I'm an 

independent, although it's listed differently, 

I'm an independent advocate for the fungicide 

natamycin. 

Although the fungicide has been ---

this fungicide natamycin has been used in the 

food industry ---

MR. EHRETH: Oh, crap. 

MR. ADASKAVEG: Hello? 

MR. CHAPMAN: Okay --

(Simultaneous speaking.) 

MR. CHAPMAN: -- but you're not the 

speaker. 

MR. EHRETH: David Ehreth. 

MR. CHAPMAN: Okay, David. We'll come 

back to you. We hear you now. But ---

MR. EHRETH: Okay, thank you. 

MR. CHAPMAN: So, Jim, sorry about 

that, we'll give you some time back. 

MR. ADASKAVEG: All right. So I'm an 

independent advocate of the fungicide natamycin. 

And I'm not affiliated with --- it's kind of 

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listed here that I'm affiliated with DSM or PACE. 

But I'm actually a professor at the University of 

California. 

I've been working with this fungicide, 

and I'm pretty excited about it. Although it's 

been around in the food industry for 

approximately 50 years as a preservative of meats 

and dairy, with generally regarded as safe, GRAS, 

standing with the FDA, natamycin's actually a 

brand new fungicide for agricultural use with 

this registration in the last two years with the 

EPA. 

So EPA registered this fungicide as a 

biopesticide with exempt status of residue on 

agricultural commodities. The fungicide's a 

natural biofermentation product of Streptomyces 

nanolenses and other Streptomyces species. And 

this is the critical part. It has no 

bactericidal activity. It's not killing 

bacteria. It's only killing certain fungi that 

we've evaluated in. 

So for agricultural use, my interest 

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is in the development of new post-harvest 

fungicides. And I've evaluated hundreds of 

products from synthetic to biological controls 

over my career. 

I've worked with natamycin since 2012, 

evaluating its efficacy against plant pathogens 

of food commodities including citrus, stone 

fruit, tofu. And I found it to be a very 

effective fungicide. 

I propose it as a new FRAC group, and 

I'm a FRAC member. And FRAC now lists it as a 

fungicide. We just went to the Action Committee 

where they list all the different fungicides used 

in agriculture. And this natamycin chemical 

obtained FRAC Group 48 with a unique mode of 

action. 

It's a broad spectrum fungicide, and 

we have shown that it works on many plant 

pathogens. But it's still not effective against 

all plant pathogens, and it's certainly not 

effective on all fungi. So it has a niche for 

some of these plant pathogenic or in food 

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contaminating fungi. 

So natamycin, to me, is a very 

exciting chemistry. There has not been any 

reported resistance in filamentous fungi despite 

its widespread use in the food industry. 

In my research, I've shown that 

resistance to natamycin could not be detected in 

several penicillin species which are notorious 

post-harvest pathogens. And we were not able to 

find any such level of resistance. 

And so this is a remarkable, major 

advancement that we can use this thing. Because 

it's registered now as a conventional fungicide, 

as a post-harvest treatment. And we could use it 

alone or in mixtures to help prevent other 

fungicides for developing resistance. So it has 

multi potential uses. 

Natamycin can, if it's registered as 

an organic fungicide, since it is a natural 

product, this would be an extraordinary 

advancement for organic farming. Having an 

effective organic post-harvest fungicide would 

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help in protecting crops during shipment, in 

marketing, during that transportation period, and 

could help expand the organic industry 

tremendously in providing food. 

MR. CHAPMAN: All right, Jim. We'll 

have to wrap up your comments --

MR. ADASKAVEG: Okay. So my last 

statement is that I propose that natamycin will 

be great for organic farming. It follows a 

similar trend as polyoxin D that was recently 

considered by your group as a natural 

fermentation product. And therefore, I am 

supporting natamycin with a similar strategy as a 

pesticide, or potentially organic, for the 

industries of the United States. 

MR. CHAPMAN: Thank you. Thank you, 

Jim. Any questions for Jim? 

MS. BEHAR: Yeah, this is Harriet. 

MR. CHAPMAN: Go ahead, Harriet. 

MS. BEHAR: Would natamycin be placed 

in any way for consumers to know that it had been 

used upon the fruit that they would be eating? 

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MR. ADASKAVEG: Most packers label 

their boxes of what treatments are being used on 

that food. And that's, I think, required. So, 

like, on the fruit boxes, currently they say 

treated with, and they'll list the fungicides 

that they treat the commodity with. 

So that, I imagine, could be on that 

label as it is used. And it could be also 

indicating that it's organic pool, that it's an 

organic material on the box that way. 

MS. BEHAR: Yeah, I wasn't sure that 

there was a requirement that it --- but if it's 

on the box, it would not be out on the retail 

floor, for instance, the plums, or peaches, or 

whatever where people are preferring one at a 

time. There wouldn't be a sign or anything. 

So it's somewhat different with being 

used in bread products or cheese products where 

the consumer would actually see it on a retail --

-

MR. ADASKAVEG: Well, in some markets 

around the world, there are signs put out, like, 

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in Japan. They do put signs out, even at the 

marketing location. But that's not the case for 

other pesticides that are organically used, like 

copper or sulfur. I mean, there's no signs being 

posted for those types of materials either. In 

the US, there's no requirement for that, for 

example. But there are places around the world 

that they do to that. Yes, they do put those 

signs up. 

MS. BEHAR: That was our exact use in 

post-harvest handling. 

MR. ADASKAVEG: Right. That's exactly 

right. They did a required --- what they call a 

food additive college in Japan with what we have 

here. 

MS. BEHAR: And then, so one of our 

concerns was that it is used for human health. 

It's a health product. And it's also used 

actually on livestock as well. 

And there has been some resistance, I 

believe, by candida, you know, developed to the 

natamycin over time. So there is some concern 

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about using a health product that is very useful 

for maintaining human health and concern that 

resistance will get built over time if it was 

used, you know, regularly on fruit. 

MR. ADASKAVEG: Well, I work ---

obviously we're trying to develop safer products 

for post-harvest use. And from what I understand 

talking to the registrar, and talking to people 

who know about these things, the livestock usage 

in the United States is basically none. And the 

company that registered it originally is no 

longer in existence. So the amount of sales is 

actually not justifying what you're saying there 

with its losing livestock. 

And as far as medical use, you know, 

this is mainly for eye infections. And most of 

these things are happening in more or less third 

world countries. And, you know, I don't think 

there's any extensive use of this material, or 

hardly any at all in, you know, first world 

countries like the EU, or the United States, or 

Japan, and these types of places. 

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But obviously there are some 

additional uses on the books in case that some 

issues ever develop. But again, the amount of 

usage of this in that capacity is near zero, from 

what I understand. 

MS. BEHAR: Thank you. 

MR. ADASKAVEG: And as far as the 

resistance goes, there's no resistance to 

filamentous fungi. And candida's a yeast which 

is a unicellular fungus. And, you know, most of 

those reports are coming out of laboratories 

where they do mutagenesis and generate resistance 

for studying these types of things. 

So I haven't, you know, I've been very 

much involved with this, and I haven't really 

documented any filamentous fungus which is where 

all or most of the post-harvest pathogens of food 

crops, which is my specialty, are found. So I 

hope that answers your question. 

MS. BEHAR: Yes, thank you. 

MR. CHAPMAN: Any other questions, 

Jim? Okay. Hearing none, Jim, thank you for 

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your testimony here today. 

MR. ADASKAVEG: Okay. Thank you very 

much for having me. I appreciate it. 

MR. CHAPMAN: Yes. Yes. So, we'll 

head back to David. David, are you online with 

us? David? David, are you there? David, again, 

I don't know if you could hear me before. But we 

are not hearing you now. I'll give you another 

moment to try to unmute. 

All right, David, still not hearing 

you. So, we'll proceed on. And if we can figure 

out technical difficulties we'll come back to 

you. It might be best, if you're able to, to try 

to dial in the line, and then message us the 

number you're dialing in from. 

Well, up next then will be Katherine 

DiMatteo. Actually, I think we have you on mute. 

Yes, hold on. Katherine, are you there with us? 

MS. DIMATTEO: I am. Can you hear me? 

MR. CHAPMAN: Yes, we can. So, hold 

on, Katherine. After Katherine will be Mark 

Farinha, and then Sanford Bigelow. Of course, 

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we'll go back to David if and when we can figure 

out the technological fix. Katherine, if you 

could start with your name and affiliation for 

the record? 

MS. DIMATTEO: All right. Thank you. 

My name is Katherine DiMatteo. I'm a senior 

partner and associate at Wolf DiMatteo and 

Associates. And we are here today to support the 

re-listing of sodium carbonate peroxyhydrate, or 

SCP, which is a safe, environmentally friendly 

material, and is an alternative to copper 

sulphate. 

While SCP is often used as a 

disinfectant and sanitizer for water systems, 

there seems to be quite a lot of debate 

surrounding its use as an algicide in rice 

production, which is what I would like to address 

today. 

During the last Sunset Review copper 

sulphate, on copper sulphate, one report from 

2007, which was released before SCP was even 

allowed for use in rice, has been referenced by 

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the Crops Subcommittee, and is still being 

referenced today. 

The new report by the California Rice 

Research Board summarized that "To date we have 

not found an algicide that gives results like 

growers would anticipate." 

This is just one data point by one 

organization. There are many more current 

references that show SCP is an effective 

algicide. Some of those specifically have been 

done for rice. And many on algicides in general. 

However, change in these other 

references and reports have not been read by the 

Subcommittee or the NOSB. 

Also, in the discussion document for 

this meeting it assumes that SCP is not widely 

used, and cite 2010 data on California acreage in 

which copper sulphate was used, versus SCP. 

At the time copper sulphate was used 

97,757 times, versus SCP use of 1,277 times. I'd 

like to note again that this is when SCP first 

became available to California rice growers. 

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Remember, 2010. So, of course the uses rate 

would be very low. 

Subsequently, SCP has been gaining 

traction. Its peak usage thus far in 2014 of 

16,091 acres for California rice -- reported a 

low vetted national list. But not decisions made 

that take away materials that can provide a 

needed tool for organic farmers. 

Removing a material from the list 

based on the number of farmers who currently are 

using the tool is not a fair and equitable way to 

decide about who may need an alternative to what 

is on the list, or who may use it in the future. 

One material cannot be appropriate for 

all situations. Farmers need to be able to use a 

material that fits their needs when they need it. 

Thank you very much for the opportunity to 

comment. 

MR. CHAPMAN: Thank you. Any 

questions for Katherine? 

MS. OAKLEY: This is Emily. Can you 

hear me okay? 

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MR. CHAPMAN: Go ahead. I'll --

MS. OAKLEY: All right. I'll try to 

talk louder again. Sorry. Thank you, Kathy, for 

your comments. I was wondering if this recording 

that you just provided is for all rice in 

California? And if you are able to break that 

down by organic usage? 

MS. DIMATTEO: Unfortunately we can't 

break it down by organic usage yet. That's not 

the way the information is collected. 

MR. CHAPMAN: All right. 

MS. OAKLEY: I just want to say, I 

guess maybe put it out as part of the reason that 

we noted that it wasn't highly used is we didn't 

see a tremendous number of public comments that 

it was used very widely. And it wasn't 

originally included as an algicide. 

I did do a little bit of searching on 

the pesticide use reports database to try to 

determine usage among organic growers. And it 

was a little difficult to break that down by 

organic. But it seemed that there were some 

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uses, but very limited. 

And there's one -- if in fact that is 

in irrigation hoses. Like it's, you know, 

understandable it's under that listing. But part 

of our concern was that it was originally 

intended for use as a -- as you noted, for copper 

in rice. 

So, that can be part of that basic 

discussion that we're trying to elucidate through 

the public comments, and get more feedback on who 

is using it and how. So, thank you for your 

feedback. 

MS. DIMATTEO: Right. And I'd just 

like to send out a couple of things. And, yes, 

according to select data, most data collected 

isn't broken out unless it's specific, say the 

research of the report is done that way. 

Secondly, I would imagine that it's 

very difficult. Most farmer probably who may use 

SCP may not even know they're using SCP, because 

they recognize by brand name, a brand name 

product that they're using in which it is 

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contained. 

So, you know, if you want to collect 

data from farmers you may have to do it in a 

different way. Or discover the brand names that 

use SCP, or have a SCP formulation, and ask the 

question that way. 

We've found in listening to and 

reading many comments over time that especially 

on materials the farm community hasn't commented 

as much as those of us who have either the time, 

or have been paid, or are an NGO, to be able to, 

you know, gather the data, or to make a point. 

So I, we've always found it very 

troubling that a decision about the use of a 

material that may very much be a better 

alternative than, in this case copper sulphate, 

is judged on the number of comments that one 

receives about the product. That seems to not be 

a very reasonable way to make those kinds of 

judgments. 

And we, again, our company has always 

pointed out that this is a toolbox of tools. 

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Nobody's required to use them either all the 

time, or even some of the time. 

They're, the tools are there for 

farmers to choose to use when they really need 

them. And they need a set of alternatives. 

Because one size doesn't fit all. Each farming 

situation is different. 

So, just a caution from us that we 

have repeated many times. And I'm sure people on 

the NOSB who are listening in have heard us say 

this. But be careful about removing safe, 

environmentally friendly products that may be the 

best alternative for some farmers in their 

production systems. 

MR. CHAPMAN: Any other questions for 

Katherine? Hearing none, thank you, Katherine 

for your comments. I believe that --

MS. DIMATTEO: You're very welcome. 

MR. CHAPMAN: Thank you. I believe we 

have David on the line now. David, are you here 

with us? 

MR. EHRETH: Yes. Can you hear me? 

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MR. CHAPMAN: Yes, we can. 

MR. EHRETH: Okay. Good. 

MR. CHAPMAN: Hold on one second, 

David. So, after David it will be Mark Farinha, 

and then Sanford Bigelow. David, if you could 

start with your name and affiliation? 

MR. EHRETH: Okay. My name is David 

Ehreth. And I am with Alexander Valley Gourmet. 

And I would like to speak in support of using 

natamycin as a post-harvest rinse for organic 

products. 

I'm a partner in a small company that 

has produced natural live culture fermented 

pickles and sauerkraut for 14 years. And we 

depend on naturally occurring lactic acid 

bacteria for vegetable fermentation. 

Unfortunately, that same environment 

encourages bacterial, that encourages bacterial 

fermentation provides an ideal environment for 

spoilages. Because of this our products are very 

vulnerable to considerable losses cause by 

spoilages. 

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In our efforts to protect our food 

supply from synthetic chemical intrusion, 

producers of products like ours have long sought 

some completely natural, non-synthetic 

antimicrobial that while effective on fungi such 

as yeast, will have no impact on bacteria. 

Natamycin appears to be such an 

antimicrobial. And further, natamycin can be 

produced with non GMO organic ingredient inputs. 

The primary source of yeast in our 

process is the naturally occurring yeast on 

vegetables. Our fermentation depends on lactic 

acid bacteria also present on these vegetables. 

And therefore, we can't use broad spectrum 

antimicrobial washes like chlorine. 

Our experiments using natamycin as a 

post-harvest wash have resulted in as much as a 

30 percent yield improvement. The water 

solubility of native natamycin is very low. 

Vegetables washed with natamycin rinse 

have very small uptake. With a secondary water 

rinse, quantities of natamycin in the finished 

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products fall below detectable thresholds. 

Repeated studies have found that 

natamycin is safe to use as both a surface 

treatment, and as an ingredient. 

The World Health Organization, and 

many others, have studied the food safety aspects 

in natamycin, and concluded that it's safe for 

human consumption within defined limits. 

Studies by DeVore, et al, have shown 

that there is no observable increase in 

generational resistance to natamycin used in 

factories. 

In a paper by Dalhoff and Levy, 

concern has been expressed about the possibility 

of increased microbial resistance as a result of 

certain natamycin formulation with other 

chemicals. 

However, their expressed concern 

relates to the formulations of natamycin that 

increase acid resistance and solubility. Our 

discussion here, or at least my discussion is 

focused on natamycin, not on compounds of 

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natamycin combined with other chemicals. 

Because natamycin is completely 

natural and can be produced with organic 

ingredients it has been shown to be safe for 

human consumption, and has not negative 

demonstrated environmental effects, we recommend 

granting organic certification to properly 

produced natamycin. 

And just to put a footnote on this. 

We believe that natamycin is one of the most 

remarkable tools that can help promote organic 

and natural foods that contain live cultures, and 

have that lead to a very positive health outcome. 

So, we very strongly support 

natamycin. And I'll take any questions. Thank 

you for your time. 

MR. CHAPMAN: Thank you. Any 

questions for David? 

MS. BEHAR: Yes. This is Harriet. 

Are there other materials that can be used 

instead of natamycin that are already on the 

National list, or are natural, and don't need to 

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be on the National List? 

MR. EHRETH: There are other products 

that have been put forth. And we have 

experimented with them. None of them has shown 

the efficacy that natamycin has. 

And these other products are not, 

things like mustard oil, or products that contain 

mustard oil, or other things, they have an 

unfortunate organoleptic component that adds, you 

know, sometimes undesirable flavors, or other 

things to products that natamycin does not have. 

So, I would say that natamycin, to the 

best of my knowledge, is in a class of its own 

here. 

MS. BEHAR: I just have a follow-up. 

How much loss do you think we are having now in 

fruit due to the lack of the use of natamycin, in 

post-harvest handling? 

MR. EHRETH: Well, I can't speak, if 

you mean, when you say fruit, I can respond to 

the vegetable. And really, I have to narrow my 

observations to the fermented, inputs to the 

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fermented food business. Because that's the 

business I'm in, and very familiar with. 

I have at times lost an entire batch. 

And for us an entire batch would be about 12 

tons, and to spoilages. And I know that there 

are others, some of my other colleagues in the 

industry have had to reverse their effort to 

offer live culture foods, and reverted back to 

pasteurization, because they were simply unable 

to bear the losses. 

And these losses are periodic. They 

come, they go. They're, it's a sort of a ghost 

that haunts our industry, and drives up the 

price, the consumer price of our products. 

And so, we, I personally believe after 

studying this problem for years that natamycin is 

the single most effective tool against this. And 

because of its completely natural, the creation 

is non synthetic, and that it can be created with 

natural input, organic inputs, that this is a 

powerful tool for the fermented foods industry. 

MR. CHAPMAN: Other questions for 

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David? 

MS. OAKLEY: I have a question. This 

is Emily. 

MR. CHAPMAN: Hey, Emily. And we can 

hear you clearly. 

MS. OAKLEY: Yay. How many certified 

organic products comprise your overall line? 

MR. EHRETH: At present we have one 

product line that is certified organic. 

MS. OAKLEY: And how many, would that 

be in total? 

MR. EHRETH: No, no. 

MS. OAKLEY: Organic products you have 

in total? 

MR. EHRETH: We have ten products. 

MS. OAKLEY: Okay. So, ten. And one 

is organic? Thank you. 

MR. EHRETH: Yes. And if I could just 

explain very quickly, that these issues dovetail, 

in that our reluctance to offer a broader line of 

organics have to do with the economics here, that 

organics to begin with is more expensive from a 

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material basis. 

Combined then with spoilages, losses 

drives the price out of the reach of the average 

consumer. And we are very focused as a company 

on being able to offer products that the average 

consumer can afford. 

MR. CHAPMAN: Any other questions for 

David? 

MR. ELA: This is Steve. I have a 

question. 

MR. CHAPMAN: Go ahead. 

MR. ELA: Just, one of our concerns, 

and obviously the previous caller we talked a 

little bit about this, is the potential use of 

natamycin for human health, and the concerns over 

antibiotics used in agriculture, and crossing 

over to potential resistance in human health. Do 

you have any comments on that? 

MR. EHRETH: Yes, I do. First of all, 

my proposal here is, as I mentioned, one of the 

real miraculous characteristics of natamycin. Is 

that it can be used as a post-harvest rinse. And 

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then washed from the products to the point where 

it is non-detectable in a finished product. 

So, used as a post-harvest rinse I 

would point to its lack of solubility. And I 

know there are products on the market that have 

increased the solubility. 

And I can't speak to those, because I 

am not scientifically skilled to address that. I 

would leave that to others. But I do know that 

used as a post-harvest rinse it can be extremely 

effective, and virtually non-present in the 

finished product. 

As an ingredient we have also run 

experiments to see what would happen if we 

introduced natamycin into ferments that had a 

major yeast outbreak, and found that it was, I 

don't know another word to use, it was 

devastatingly effective. 

And then, that goes over to the 

question of safety, you know, human safety. And 

I know in the paper by Dalhoff and Levy there was 

concern expressed about two things. 

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One, the increased microbial 

resistance, just due to the resistance of certain 

formulations of natamycin in the human gut. And 

the second was the possibility of horizontal gene 

transfer. 

Those two subjects are way beyond my 

pay grade. And I would hearken back to both the 

FDA and the World Health Organization, European 

Food Safety Organization, and others who have 

studied this, and have generally concluded that 

natamycin used within defined limits is safe. 

So, the Dalhoff/Levy paper is an 

interesting one to read, but does not draw, it's 

not a scientific study. It is titled a letter, 

or a word of caution, is just how they phrased 

it. So, that's kind of where I'm at on that. 

MR. CHAPMAN: Any other questions? 

All right. 

MR. EHRETH: And by the way, the 

Dalhoff/Levy study, just quickly, the 

Dalhoff/Levy study doesn't speak to natamycin, 

per se. It speaks to natamycin combined with 

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other ingredients that cause it to be more water 

soluble, and more resistant to acid. 

MR. CHAPMAN: All right. Thank you, 

David. 

MR. EHRETH: Okay. All right. 

MR. CHAPMAN: And hearing no more 

questions. Sorry for the technological issues in 

there. 

MR. EHRETH: No. That was, the 

problem was on my end I'm sure. Thank you. 

MR. CHAPMAN: Okay. Yes. 

MR. EHRETH: Bye, bye. 

MR. CHAPMAN: Okay. Up next we have 

Mark Farinha. Mark, are you on the line with us? 

We might have you --

MR. FARINHA: I am here. 

MR. CHAPMAN: Okay, Mark, we can hear 

you. Hold on one second. After Mark we have 

Sanford Bigelow. After Sanford Bigelow we have 

Dallas McCann. 

Dallas, we haven't identified your 

phone number. So, if you're with us, please 

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message in. After Dallas will be Jane DeMarchie. 

Mark, if you can start with your name and 

affiliation? 

MR. FARINHA: Yes. My name is Mark 

Farinha. I'm a professor of microbiology. I am 

a food consultant and pharmaceutical consultant. 

I've been in the business for over 25 years. 

Today I want to address the NOSB on 

PURE bioscience, on their behalf for their silver 

dihydrogen citrate product. 

Today what I'd like to do is to focus 

on the matter of silver, and resistance to silver 

by microorganisms. Research on silver resistance 

spans about 70 years of formal research. 

But recently, in the last 20 years or 

so this has accelerated. And there's quite a lot 

more research in the last 20 years or so. This 

coincides with an expansion of the use of silver 

in wearables, in medical devices, in food 

packaging, and in food processing. 

Ionic silver has been attractive as a 

antimicrobial, because it is very broad in 

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spectrum, affecting not only just bacteria, but 

also fungi, and a number of viruses. 

This ability of silver to be effective 

is really centered on the broad action attacking 

and compromising many products of the cell, 

including the cell membrane, critical protein 

inside the cell, and even on the expression of 

DNA in microorganisms. 

Because of its broad spectrum of 

action resistance to silver appears to be surely 

difficult for organisms to achieve. The majority 

of reports on resistance, and I've done some of 

this work, deals with the expulsion of silver 

from the cell. 

And this is done by efflux pumping. 

Silver ions are pumped out of the cell at the end 

itself. This mechanism really just limits the 

amount of silver in the cell. And therefore, 

minimize the damage from the silver. 

This is typical for the cell. It 

crosses the cell, and reduces the fitness of 

cells. And it makes this sort of resistance 

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fairly transient, according to all observations 

that have been noted to date. 

When they're talking about PURE 

bioscience, and their product, this is of ionic 

silver that's combined with citrate, and is a 

fairly stable product. The citrate really makes 

the product enter the cell better, because it 

appears strew from microorganisms carrying the 

silver with it. 

It drains down to the silver until 

it's delivered to the target. And what this does 

is minimize the silver ions available for efflux 

pumping. 

And so, I think this particular 

application allows you to have something 

squarely, safely delivered, something that's 

fairly effective, and something you can deliver 

at a fairly low level. 

This means that the actual amount of 

silver used in the process is fairly small. And 

this correlates with induction of efflux pumping 

systems in bacteria. 

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So, I think when you look at the 

overall number of organisms affected by silver, 

you can see many of the common foodborne 

pathogens, this seems like a reasonable approach 

to treatment, especially food treatment, 

equipment treatment, and pre-treatment of food 

products. 

So, what I'm saying is, this broad 

antimicrobial activity of silver was a unique 

formulation of silver dihydrogen citrate should 

provide us with fairly safe food preparation and 

processing, even in organic facilities, with 

really an absence of development of resistant 

microorganisms. And that's my comment. Thank 

you. 

MR. CHAPMAN: Thank you, Mark. I'll 

start with some questions, and then I'll open it 

up to the Board. Are, if I understood your 

comment correctly, correct me if I'm wrong, 

you're saying that the silver with the citrate is 

the more effective sanitizer than perhaps what 

we've seen in studies submitted to us about just 

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silver alone. 

And that the resistance that's in 

those studies about silver is not applicable to 

the silver citrate product that we're discussing 

here. 

MR. FARINHA: When people talk about 

silver products they're really talking about two 

things now, nano particle silver and ionic 

silver. 

Nano particle silver causes resistance 

by excluding, and not taking out the particles 

themselves. For ionic silver, silver comes into 

the cell, and that free ionic silver is pumped 

back out of the cell. 

What you have with SDC, the silver 

dihydrogen citrate, is the citrate binds the 

silver, in turn the cells takes this up because 

it thinks it's normal food. And the silver being 

bound to the citrate is able to affect the 

targets in the cells, and not be easily available 

for pumping. 

This means you can use less silver in 

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the treatment. And it's more likely than not to 

show resistance. Not because the cells aren't 

capable of turning on efflux pumping. But it 

doesn't help them very much to do so. 

MR. CHAPMAN: Okay. Are you also 

qualified to speak to the some of the nano silver 

comments that we've received? And I can --

MR. FARINHA: Perhaps. Within the 

knowledge of what I've done with nano silver. 

MR. CHAPMAN: Okay. So, we received 

comments from folks that said that the sodium 

dehydrates, the FDC will, even if it's not a nano 

silver in its form, it will break down because of 

the citrate into a nano silver. Is that 

accurate? Is that accurate as? 

MR. FARINHA: I don't believe so. And 

I'll tell you my reasoning why. Nano particle 

silver is aggregate silver. And this is a 

problem with unbound ionic silver. 

Unbound ionic silver is perfectly 

capable of coalescing, and forming small 

particles. The citrate action prevents this from 

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happening, and stabilizes the ionic silver. 

This is a problem I've seen with other 

ionic silver products, is they will actually 

particalize and play out in the product, like on 

surfaces. And that is a problem. But I have not 

seen this to date with the SCD product. And so, 

I think it's unlikely to happen. 

MR. CHAPMAN: Okay. Do we have 

questions from other Board members? 

MR. MORTENSEN: I do. This is Dave 

Mortensen. Yes. So, thank you for the 

explanation. I am just wondering, if the 

organisms are, if their defense mechanism is to 

pump out the silver, what is the fate? 

Like when we think about pesticide 

fate in a plant or a microbial organism, we think 

about the fate in transport. What is the fate of 

the silver that's excreted? 

MR. FARINHA: Well, it remains 

outside, or it can be re-entered into the cell. 

It's like any other sort of pumping system. The 

cells pump it out, and then it's back outside. 

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MR. MORTENSEN: So, in this --

(Simultaneous speaking.) 

MR. FARINHA: I'm sorry. 

MR. MORTENSEN: If you could just walk 

us through? So, in this case where we're washing 

something we would, you know, it would have a 

antimicrobial effect. And then there would be 

silver ions that are released in the process back 

into the water? Is that how it would work? 

MR. FARINHA: Not from this particular 

product. This product enters the cell where it 

delivers the silver to bind to internal material 

inside the cell. And therefore, it cannot be 

pumped out. So, it would just be a contaminant 

that is killing the microorganism at that point. 

MR. MORTENSEN: And it would, that 

dead microorganism would be washed off the 

produce? 

MR. FARINHA: That is correct. 

MR. MORTENSEN: Yes. 

MR. FARINHA: But because of the 

stabilized product you're using so little of it 

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this falls very far below the level that you 

would normally find in effluent or water. And 

not to be this guy, it's such a low level of 

silver. 

MR. MORTENSEN: Thank you. 

MR. BRADMAN: I just have a quick 

follow-up question. 

MR. CHAPMAN: So, this is Asa. Asa 

you need to identify yourself to the court 

reporter, Asa the instructions. 

MR. BRADMAN: Yes. How are you 

defining what is a low level? 

MR. FARINHA: Lower level in terms of 

EPA levels. 

MR. BRADMAN: So, for water, for soil, 

for heating exposure? 

MR. FARINHA: Naturally occurring 

levels of silver, according to the EPA. And 

these are far below those levels. So, you're not 

adding to the silver burden already present in 

the natural environment. 

MR. BRADMAN: Okay. 

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MR. CHAPMAN: Other questions? Not 

hearing any, Mark, thank you for your testimony 

here. 

MR. FARINHA: Thank you very much. 

Thank you to the Board. Thank you for listening. 

MR. CHAPMAN: Up next we have Sanford 

Bigelow. Sanford, are you on the line with us? 

MR. BIGELOW: Yes, I am. Can you hear 

me? 

MR. CHAPMAN: All right. Yes, we can. 

And hold on one second. 

MR. BIGELOW: Great. 

MR. CHAPMAN: After Sanford is Dallas 

McCann. Dallas, we have not confirmed your phone 

number. So again, please message in. After 

Dallas is Jane DeMarchie, and then Jean-Marie 

Ngore Traore. Sanford, if you can start with 

your name and affiliation for the record? 

MR. BIGELOW: Great. I'm Sanford 

Bigelow. And Vanguard Global Associates, a 

consulting firm. I have a PhD in Chemistry from 

the American University in Washington, DC. And 

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I'm a Board Certified toxicologist. 

I provided written comments to the 

NOSB, for the NOSB Board. I'm presenting today 

on behalf of PURE Biosciences, and the use of 

their SDC product, as referred to by the previous 

speaker and Deborah Atwood. 

And I will call this product silver 

citrate in my presentation. I encourage the 

Board to approve the use of silver citrate as a 

synthetic substance in the National List 

The Board reviewed the peer petition, 

prepared the technical report. And the Board 

recommended to limit silver citrate use with 

particle sizes greater than 300 nanometers, based 

on their nano technology policy. 

VGA intends to make five major points 

regarding the Board recommendation, safe use of 

silver citrate in fruit. 

One, the Board recommendation on 

particle size will not work. Two, silver citrate 

contains silver ions which are not chemically 

defined as nano particles. 

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Three, the EPA and FDA have approved 

food uses for silver citrate. And both agencies 

recognize that silver citrate is composed of 

silver ions. The EPA and FDA have both 

determined that silver citrate is safe for food. 

This is point number four. 

Furthermore, no scientific articles 

had been published in "PubMed" from 1968 to 2018. 

And no articles reported that silver exposure 

promoted antibiotic resistance in microbes. 

Accordingly, if there was any evidence 

the EPA and FDA would have considered antibiotic 

resistance in their safety evaluations when they 

approved the use of silver citrate. 

The Board should not adopt the 

particle size recommendation for silver citrate 

use. Both the Board technical report, and their 

--- Board's review recognized that silver citrate 

contains silver ions. 

We strongly advocate that the Board 

does not adopt particle size recommendation 

because, one, it does not accurately describe 

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silver citrate composition in the PURE 

Bioscience's product. 

Two, the recommendation will 

unintentionally result in approving a different 

silver based disinfectant, for which a Board 

petition has not been filed. 

And three, the recommendation will 

result in disinfectant uses that are outside the 

compliance with existing EPA, FSIS, and FDA 

regulations for silver citrate uses in food. 

Thank you for your time and efforts. 

Are there any questions? 

MR. CHAPMAN: So yes. This is Tom. 

I have some follow-up questions. And then I'll 

open it up to the Board. 

So, we used the criteria laid out in 

the organic food production data in order to 

evaluate substances for inclusion on the National 

List. There is human health environmental risk, 

as well as compatibility with the system of 

organic production. 

And previous National Organic 

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Standards Boards have passed guidance stating 

that nano, from the Board level, not adopted by 

the National Organic program. But nano 

technology, and particularly the finding of 300 

nano particle size is incompatible with organic 

production systems. 

So, that annotation was placed on it 

to make it consistent with previous NOSB policy, 

as well as potentially compatible within organic 

production systems. 

So, you're saying that adding that 

annotation in there would not, would make this 

product not, would not be -- I guess I'm 

confused. Because the petitioner stated that 

this is not a nano product. And this inclusion 

of the nano product spectrum you're saying would 

disallow, would invalidate the use of this 

product. I guess I have not been reviewing this 

product then. So, help me --

MR. BIGELOW: You know -- Go ahead. 

MR. CHAPMAN: Can you help clarify 

this for me? 

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MR. BIGELOW: You're adding a 

criterion that no longer describes the petition 

use, or the petition product. The petition 

product contains silver ions. Silver ions are 

smaller than nano particles, according to FDA 

nano technology policy. 

Nano particles fall within the range 

of 1/100 nanometers, according to FDA's policy. 

A silver ion has a ionic radius of .29 

nanometers, or, you know, a circumference, ionic 

circumference of less than .6 nanometers, which 

is less than the range of nano particles 

recognized by FDA. 

Because silver is a, just like a 

calcium ion, a free calcium ion, or a free copper 

ion, which are already approved on the National 

List of Disinfectants, they would, it really 

solubilizes with citrates, as available for 

disinfectant use, disinfectant action. 

MR. CHAPMAN: Okay. 

MR. BIGELOW: Yes. So you're, by 

placing this criterion you're no longer 

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describing the petitioned product. It's a freely 

soluble ionic material. And it's smaller than, 

you know, nano particles. 

And just like other minerals that are 

used as disinfectants, they also will form, you 

know, ions. They may agglutinate as ions into 

nano particles. Who knows? And then they, you 

know. 

But if you want to place this 

criterion onto SDC, silver citrate, you may want 

to look at those other salts that are already on 

the National List. 

MR. CHAPMAN: Okay. 

MR. BIGELOW: And the EPA --

MR. CHAPMAN: Any questions? 

MR. BIGELOW: The EPA, when they 

exempted silver from a pesticide tolerance, they 

characterized the composition of silver citrate 

as not metallic silver. It was only silver ions 

that were generated from electrolytic generation. 

And those would be ions, not any metallic silver, 

or nano particles. So, they wanted to exempt the 

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silver, just the silver ion for this particular 

product. 

MR. CHAPMAN: Any additional questions 

from the Board? 

MR. ELA: This is Steve. 

MR. CHAPMAN: Go ahead, Steve. 

MR. ELA: And pardon my ignorance a 

little bit here. But when the previous speaker 

was talking about, while, you know, why the 

citrate was so critical for the action of the 

silver, so the cells couldn't, in essence pump it 

back out. 

But if you're saying the silver is 

actually as an ion in the cell, I'm a little 

confused as to why, if it's separate from the 

citrate at that point as a silver ion, why the 

cells can't go ahead and pump it out as a silver 

ion. 

MR. BIGELOW: Well, as all ions, all 

salts, there's dissociation between the anion and 

the cation. So, citrate is a tricarboxylic acid. 

And it will bind three atoms of silver. 

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The silver citrate is absorbed into 

the cell. And there's always association and reassociation of anions to cations in cellular 

milieu. 

The situation becomes is when the 

silver ion is associated it can, it's available 

to exert its disinfectant action by binding 

cellular molecules, and stopping cellular 

metabolism. And that's essentially what EPA and 

FDA recognize, the action of silver citrate. 

MR. ELA: So, once that silver is 

disassociated in the cell, what prevents it from, 

in that disassociated state, from recombining? 

And my chemistry is rusty here, to say the least. 

But combining back into, like one of our public 

commenters, written comments said, back into 

what, into something like a nano particle? 

MR. BIGELOW: I don't, I think that 

the level of silver citrate used, and the sheer 

massive quantity of cellular material in the 

microbe, just by mass action alone you're not 

going to have a lot of silver citrates, silver, 

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excuse me, silver ions re-associating with other 

silver ions. 

Plus, when one silver ion 

disassociates from citrate it, there may be a 

situation where the other silver ions will remain 

associated with the citrate. 

But the, clearly, based on 

antimicrobial testing, the silver ion is active 

in stopping or reducing the viability of these 

microbial organisms. 

MR. ELA: Thank you. 

MR. MORTENSEN: I have a question. I 

asked this question --

MR. CHAPMAN: Hold on. Hold on. Say, 

just for the court reporter --

MR. MORTENSEN: Yes. 

MR. CHAPMAN: Dave Mortensen, you have 

a question? 

MR. MORTENSEN: Thank you, Tom. 

Sorry. I'm just concerned about the fate. And 

the last speaker said that the concentration was 

so low that it was lower than the background 

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concentration in water, which I actually can't 

believe. 

But what is the, what concern do you 

have about the fate of the silver in the run 

state that comes off of these cleaning tables in 

processing facilities? 

MR. BIGELOW: If you look at the EPA 

standards for ambient water standards for silver, 

and I can't remember the PPM in the ambient water 

standard. 

But the idea that silver, when it 

dissociates from the citrate ion, it's going to 

become bound to cellular macro molecules. It's 

highly unlikely that once bound it will be 

effluxed from the cell. 

Nevertheless, there is some cellular 

influx. But one can easily suggest that silver 

will become bound to cellular macro molecules in 

neighboring cells, or in neighboring plant 

tissue, to the levels that are insignificant, 

according to the EPA and FDA safety evaluations, 

based on their approved uses in food. 

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MR. MORTENSEN: So, you have these 

dissolved and degrading microbial communities 

that are in the water, streaming, coming out of a 

facility. And probably the fate of the silver 

that is contingent on the decomposition rate of 

the single cell organisms, I would guess. Is 

that right? 

MR. BIGELOW: Yes. Yes. And the FDA 

approval has an environmental impact assessment 

associated with food contact use approvals. And 

so, I had mentioned that in my written 

statements. And so, your concern about silver 

burden in the environment from SDC use, FDA in 

approving the use in food had addressed that in 

their environmental impact statement assessment. 

MR. MORTENSEN: Okay. Thanks. I'll 

go back and look at that. Thank you. 

MR. MORTENSEN: Yes. 

MR. BRADMAN: Tom, I had a question. 

MR. CHAPMAN: Okay. Asa. 

MR. BRADMAN: You made two comments at 

the end of your initial comment period about, you 

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stated that, lack of approval will result in 

approval of other, in other's silver material. 

And you also I think said something about the 

result in use outside compliance. Can you be 

more specific about those statements? 

MR. BIGELOW: Sure. There are 

numerous silver based disinfectants approved by 

the EPA. The one that's been petitioned to the 

Board here is silver dihydrogen citrate, which is 

ionic silver. 

There are other silver disinfectants 

that are approved by the EPA. The Board may 

inadvertently approve the use of other silver 

disinfectants that do comply with this 

annotation. 

The second thing is when you do put in 

place adoptive annotation the, if, for one to use 

an SDC they would still be outside the approval, 

because it does not reflect the composition if 

these other silver disinfectants were to be used. 

The may fall outside the already regulated uses 

of the silver. 

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MR. BRADMAN: So, this is specifically 

about your concern about the particle size 

annotation? 

MR. BIGELOW: That's correct. 

MR. BRADMAN: All right. Thank you. 

I just wanted that clarification. 

MR. BIGELOW: Yes. Yes, sir. 

MR. CHAPMAN: Other questions? Okay. 

Thank you for your comments here today. Up next 

we have Dallas McCann. Dallas, are you on the 

line with us? Going once, going twice, and I'll 

skip over you. After Dallas we have Jane. Jane, 

are you on the line with us? 

MS. DEMARCHIE: Yes, I'm here. 

MR. CHAPMAN: All right then, I can 

hear you. And then after Jane we have JeanMarie. Jane, if you'd start with your name and 

affiliation? 

MS. DEMARCHIE: Sure. My name is Jane 

DeMarchie. And I represent the American Food 

Trade Association. AFTA represents over 700 

member companies that produce food, the row 

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crops, vegetables, grasses, and cover crops. 

We encourage the National Organics 

Standards Board and the National Organics Program 

to use AFTA as a resource for issues related to 

food breeding and food working. These, oral 

comments are exerted from our written comments, 

that were also this submission. 

AFTA supports the proposed regulatory 

language changes of the Organic Food Regulations. 

We understand that since the inception of the NOP 

access to a broader, higher quality organic food 

supply has evolved. 

Concerning the organic seed guidance 

AFTA would like to see the methods proposed to 

verify organic seed usage, to be reflective of 

how different types of organic growers supply 

organic seeds. 

Specifically, the value of using 

variety trialing to judge rival performance is 

accepted, and by all types of growers, even on 

your farm, or through an internal trial location. 

Comparatively, catalogues of 

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predominantly proprietal selection by small scale 

growers only, they're not necessarily factual 

records of proprietal performance in all 

production locations and conditions. 

AFTA strongly supports the change 

specifying a minimum of five sources. We support 

a refinement in the guidance that the sources be 

companies that can actually offer organic seed 

and planting stock of the equivalent variety. As 

a result, in some cases fewer than five sources 

will be able to be identified. 

On the excluded methods many of us 

that commute have made listed in the proposed 

methods table of vital components of current 

plant breeding, the fundamental concerns 

regarding regimented criteria for disputed 

methods. 

AFTA opposes the proposed excluded 

method of termination for transposons due to the 

lack of surety around the definition, and the 

prevalence of transposons in plants. As an 

example, the lettuce genome is 75 percent 

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transposable elements, peppers 76 percent, maize 

85 percent. 

AFTA supports the determination that 

embryo rescue should not be considered an 

excluded method by an LSC. We also urge the 

Materials Subcommittee not to include double 

haploid technology in the list of excluded 

methods. 

AFTA does not support the testing 

program proposed in the Materials Subcommittee 

proposal on genetic integrity transparency in 

seed grown on organic farms. 

As the proposal stands it may have the 

unintended consequences, depressing the growth of 

the developing organic seed industry, and 

reducing the depth and breadth of seed choices to 

organic farmers. 

The National Organic Program is a 

process based standard, and AFTA continues to 

believe that the contractual relationship between 

the seed sellers, seed buyer, and existing seed 

laws are already appropriate mechanisms to 

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provide assurances of seed quality. Thank you 

for your time. 

MR. CHAPMAN: Thank you. Any 

questions from the Board? Harriet? Sorry. 

Harriet, we had you muted. I didn't know if you 

had a question or not. 

MS. BEHAR: Yes. I have a question. 

MR. CHAPMAN: Okay. 

MS. BEHAR: So, I was wondering about 

the transparency for the growers when the seed 

company does not provide them with information on 

the presence of genetic engineering in the seed 

that may have, you know, probably was, you know, 

happened there through no fault, you know, or 

just, you know, out in the field. 

It wasn't that it was actually 

genetically engineered feed. But there can be a 

detected contamination in that feed. And then 

the producer doesn't know that it's present. And 

yet they are hoping to meet a certain market that 

will be testing. 

How do you propose we deal with that 

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issue if we don't require some testing and 

transparency? So, before the farmer buys the 

seed they know what they're getting. 

MS. DEMARCHIE: Sure. I think there 

are different answers to that. One of the things 

that we will recommend that growers are able to 

look at the seed, the purity on the existing seed 

tags, which in, you know, in many cases, you 

know, require high, over, you know, over 95 

percent. So, that is definitely a method for 

indication. So, that's the purity of, the 

genetic purity of that variety, you know. 

And I think we're also, what our 

members find is that in many cases growers are 

asking for tests. And they are receiving that 

data. 

Our concern is with the structure of 

the program, as it is written in the proposal. I 

think we're definitely open to further 

conversation about this topic. 

And perhaps, you know, additional data 

is needed before you go through the process of 

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establishing such an onerous testing requirement. 

MS. BEHAR: Okay. No further 

questions. 

MS. ARSENAULT: Tom, are you there? 

Tom, if you're talking you may be on mute. 

MR. CHAPMAN: I'm on mute. I'm on 

mute. Sorry. Looks like we figured out there's 

no further questions, Jane. Thank you for your 

testimony. 

MS. DEMARCHIE: Thank you. 

MR. CHAPMAN: And we'll move on to our 

last public commenter, who is Jean-Marie. And I 

think we had you muted. Jean-Marie, can you hear 

us? 

MR. NGORE TRAORE: I'm here. 

MR. CHAPMAN: Yes, we can hear you. 

If you could start with you name and affiliation 

for the record? 

MR. NGORE TRAORE: Yes. My name is 

Jean-Marie Ngore Traore. I'm owner of a small 

company, startup company, Wari Di Company. And 

we are dealing with import and export organic 

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fruit. 

We are concerned because we are going 

to export to U.S. companies from France and 

French Polynesia, and also from French Caribbean, 

on the organic fruits. 

Because we are familiar we are getting 

also the exports to the U.S. that are already 

grown. But our concern right now is to find from 

American goods organics. Because our concern is 

to import U.S. products to France. 

The reason why, and the main concern 

with dealing with the market, organic market. 

They don't have mass production. We don't 

produce enough. So, we need some organic foods. 

And they don't believe that we have products are 

organic. 

So, we have a predilection for us, 

particularly those products that are produced in 

U.S. And also organic products. It is basically 

our jobs to introduce some organic products in 

France from U.S. That's it. 

MR. CHAPMAN: Okay. Thank you for 

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your comments. I do know that the U.S. and 

European Union have an equivalency related to our 

organic standards, that do allow recognition of 

one standard in the other jurisdiction, and vice 

versa. I don't know if anyone from the program 

wants to speak further to that. 

MR. NGORE TRAORE: I know that the 

standards with Ecocert. So, we cannot use the 

U.S. But, what do you mean? 

MR. CHAPMAN: So Ecocert is a certifier 

who certifies to a specific standard. And the 

European regulations, which I don't know the most 

recent numbers, as well as the National Organic 

Program, under the Organic Foods Production Act 

in the U.S. 

The Government, the European Union, 

and the United States have determined each 

standard's equivalent. And so, you can sell 

products produced in the U.S. under the 

equivalency arrangement into the European Union 

without further certification, and vice versa. 

(Off-microphone comment.) 

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MR. CHAPMAN: Any other questions for 

Jean-Marie? 

MS. OAKLEY: Yes. This is Emily. Can 

you hear me again? 

MR. CHAPMAN: Yes. We can hear you 

loud and clear. 

MS. OAKLEY: Thanks. So, Jean-Marie, 

are you saying that French consumers don't 

believe that USDA certified organic products are 

organic? Is that what I heard you say? 

MR. NGORE TRAORE: Yes. We are from 

French products. They are organic certified. 

And ready to go to U.S. But we are looking for 

U.S. products to export which we import them, 

ship them to France, to the markets, to the 

European markets, yes. 

So, other people produce standard 

products, orange juice, apple juice, and all kind 

of U.S. products, organic food, and so on, from 

U.S. to export into the French market. 

 MR. CHAPMAN: So, this is the, 

National Organic stands for, works the standards 

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related to organic production, particularly under 

the U.S. standards. We're not a promotion board 

for products produced in the U.S., per se. 

But what you can look at is, there is, 

on the National Organic web page, under the USDA 

there's the Organic Integrity Database, OID. And 

on there you can find a list of everyone who is 

certified to the U.S. Organic Standards who is 

based in the U.S. or in a non-equivalent country. 

MR. NGORE TRAORE: Okay. Thank you. 

MR. CHAPMAN: Any other questions? 

All right. Jean Marie, thank you for your 

comments. 

MR. NGORE TRAORE: Thank you. 

MR. CHAPMAN: And at this time we will 

run through the public commenters that we skipped 

over to see if they've been able to join the call 

since then. 

So, starting at the top of the list. 

Jonathan Simpson? Is Jonathan Simpson here? 

Matthew Luna? Is Matthew Luna here? Evan 

Perkins? Is Evan Perkins here? And Dallas 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
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McCann? Is Dallas McCann here? 

All right. None of those folks are 

here. Then it looks like we've reached the end 

of our public comment webinar session. And we 

will go into recess, and then reconvene in St. 

Paul on Wednesday of next week. 

I appreciate all the Board members and 

the NOP staff time, as well as all the time from 

the public commenters who provided comment here, 

and waited on the line, or listened to other 

comments given. 

Again, this is highly valuable, as you 

can tell from the questions that you get from the 

Board members. This is probably one of the most 

valuable pieces of back and forth feedback that 

we can get. 

So, I appreciate everyone's 

participation. And I look forward to seeing 

folks in St. Paul. Take care, and have a good 

weekend, everybody. Thank you. 

(Whereupon, the above-entitled matter 

went off the record at 3:32 p.m.) 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
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A

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10:3 22:18,19,22 23:1 

23:5 

A-dae's 8:19 

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Alexander 93:8 

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89:17 

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35:16 46:22 134:3 

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American 113:22 

126:20 133:9 

amount 24:3 25:4 38:9 

39:12 83:12 84:3 

105:18 106:19 

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animal 54:11,16,19 

55:19 

anion 120:20 

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125:15,17 126:3 

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107:9 111:7 122:8 

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106:8 

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22:9,11 58:13 63:7 

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125:1,2,18 

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46:6 115:1,14 118:16 

123:22 125:7,12 

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124:14 

approximately 44:14 

53:10 77:7 

April 17:9 

areas 38:5 59:18 

arrangement 134:20 

ARSENAULT 1:19 2:3 

7:14,18,20,22 8:2,4,7 

8:9,12,16,19 9:1,4,13 

9:16,19,22 12:8,11 

13:6,15,19 35:4 68:12 

132:4 

articles 115:7,9 

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112:8,8,10 124:20 

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131:15 

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124:10 

Associates 86:8 113:20 

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126:21 

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Attwood 58:7 63:1 68:6 

68:14,17 69:2,3 72:14 

73:17 74:16 

Atwood 114:6 

audible 7:11 8:11,18 

9:12,15,18 13:11 

22:21 23:3 41:18 

52:11 55:10 57:7,13 

62:11 67:18 68:3,8 

74:13,22 75:5,8 

audio 75:14 

Neal R. Gross and Co., Inc. Neal R. Gross and Co., Inc. 

(202) 234-4433 (202) 234-4433 Washington DC Washington DC www.nealrgross.com www.nealrgross.com 
139 

available 4:12 41:3 

64:18 67:14 87:22 

106:12 108:20 118:18 

121:6 

average 100:3,5 

aware 11:4 32:7 58:6 

60:17 

awareness 60:13,20 

B

back 8:13,20 9:5,10 

10:17 15:3 21:19 52:2 

56:14,15,18 75:15 

76:16,19 85:5,12 86:1 

98:8 102:7 108:14 

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121:15,16 124:17 

137:15 

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53:9 122:22 

bacteria 26:1,11,13,15 

26:19,21 77:20 93:16 

94:6,13 105:1 106:22 

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93:18 

bactericidal 77:19 

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Baird 9:8 

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baler 15:21 

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114:14 116:5 122:7 

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beginning 29:16 30:20 

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Behar 1:11 7:18,19 20:8 

20:18 21:12,15 22:7 

30:3 31:6 40:3,22 

41:8,15 47:6,11 80:18 

80:20 81:11 82:10,16 

84:6,20 96:19 97:15 

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42:20 55:1 63:19 

66:21 82:21 92:17,19 

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135:9 

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92:13 97:13 

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Bigelow 85:22 93:5 

103:19,19 113:7,8,12 

113:19,20 117:20 

118:1,21 119:14,16 

120:19 121:18 123:7 

124:8 125:6 126:4,7 

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binding 37:14 121:7 

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biodegradable 21:1 

biofermentation 77:16 

biological 78:3 

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70:15 71:8 72:15,20 

104:9 106:4 

Bioscience's 116:2 

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bit 2:5 3:14 6:13 30:9 

34:10 52:5 58:22 61:1 

89:18 100:14 120:8 

black 19:8,9,15 20:1 

21:9 

blend 26:5 

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board 1:3,10,19 3:9 

4:20 5:1,19 6:7 7:7 

10:7 11:19 12:2,17,22 

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38:22 40:2 41:22 

49:17 51:5 52:10 

66:10 74:12 87:4 

107:18 110:9 113:5 

114:1,3,9,11,12,17,19 

115:15,17,20 116:5 

116:15 117:2 120:4 

125:9,12 127:3 130:4 

136:2 137:7,14 

Board's 5:4 115:18 

Boards 117:1 

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bone 24:18 28:16 30:14 

34:5,7 

bones 24:21 54:16 

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books 84:2 

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Boulder 43:14 48:2 

49:2 

bound 108:19 123:13 

123:14,18 

box 81:10,13 

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Bradman 1:12 8:2,3 

27:13,15 28:12,21 

66:14 67:15 112:6,11 

112:15,22 124:19,21 

126:1,5 

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90:21,21 91:4 

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109:13 

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Briones 8:17 9:17 

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104:22 105:4,9 107:8 

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broken 90:16 

Buckley 35:10,12 

Buie 1:12 7:22 8:1 

build 43:20 

built 83:3 

bunch 58:17 

burden 112:20 124:13 

business 11:19 98:1,2 

104:7 

butchered 63:2 68:21 

button 3:2 

buyer 129:21 

buys 131:2 

buzzer 12:5 

by-product 42:17 

by-products 28:10 

bye 103:12,12 

Bye-bye 22:14 

byproducts 37:11 

C

calcium 24:19 118:15 

118:15 

California 71:17 75:21 

77:3 87:3,17,22 88:5 

89:6 

call 2:14 3:10 4:2,8,22 

10:4,16,20 12:19 

17:22 82:13 114:7 

136:17 

called 11:15 

caller 74:9 100:13 

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Canada 37:1 

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capable 109:3,21 

capacity 84:4 

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carcasses 28:20 

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care 137:19 

career 78:4 

careful 10:10 92:11 

Caribbean 133:4 

carp 32:1 

carrying 106:8 

cartilage 31:4 

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casing 53:13,17 56:7 

63:16 64:3,5,9,9,14 

64:19,22 67:1,2,2 

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catalogues 127:22 

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catching 32:5 

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64:7,12 65:3,10 67:1 

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103:1 

causes 108:10 

caution 92:8 102:15 

cell 105:5,6,7,14,16,18 

105:20,21 106:7 

108:13,14 110:20 

111:11,13 120:14 

121:2,12 123:15 

124:6 

cells 105:22 108:17,20 

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cellular 121:3,8,8,20 

123:13,16,18 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
140 

cellulose 53:13 67:1 

centered 105:4 

certain 59:14 77:20 

95:16 102:2 130:20 

certainly 28:19 53:22 

63:5 67:4,16 78:20 

certainty 69:13 

certification 21:16,19 

21:21 22:3 38:21 

47:19 60:7 96:7 

134:21 

certified 14:11,11 15:16 

21:4 39:1,7,11,15 

40:7 43:14 45:4 47:1 

99:6,9 114:1 135:9,12 

136:8 

certifier 134:10 

certifiers 40:20 46:6 

60:17 

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certify 46:16 

certifying 45:5 

cetera 24:8 40:21 51:17 

54:17 

CFR 63:9 

chain 18:21,21 32:9 

Chair 1:9,10,11 3:10 

5:19 

chairing 5:21 6:1 

chairs 6:14 

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change 87:12 128:5 

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chat 3:6 4:3 

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cheese 81:18 

chemical 70:11 78:14 

94:2 

chemically 114:21 

chemicals 95:17 96:1 

chemistry 79:3 113:21 

121:14 

chicken 65:8,9,11,19 

65:21 66:4,19 

chlorine 94:15 

choices 129:16 

choose 92:4 

circumference 118:10 

118:11 

cite 87:17 

citrate 69:11 104:10 

106:5,6 107:10,20 

108:4,16,16,19 

109:14,22 114:8,9,13 

114:18,20 115:2,3,5 

115:14,16,18 116:1 

116:10 119:10,18 

120:10,16,21 121:1 

121:10,19 122:4,6 

123:12 125:9 

citrates 118:18 121:22 

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clam 48:13 

clarification 11:20 

126:6 

clarify 19:7 33:6 117:21 

class 97:13 

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clear 29:2 50:14 135:6 

clearer 16:20 

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Coalition 58:14 

Coast 30:11 31:3 

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collagen 53:6,13,17 

54:10,12,15,18,19 

55:2 56:6,9,11 63:9 

63:16,18 64:3,4,9,10 

64:10,14 65:4,5,6 

66:2,17 67:6 

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collected 40:18 42:6 

89:10 90:15 

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Colorado 43:14 45:1 

48:6 

colors 36:15 

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combined 96:1 100:2 

102:22 106:5 

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124:3 

comment 1:5 3:15 4:20 

5:21 6:1,4 7:4 11:3,12 

12:1 29:3 43:17 58:13 

61:18 66:20 72:8,9 

88:18 107:14,19 

124:22 134:22 137:4 

137:9 

commentary 55:5 

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commenter 10:16 

11:22 12:2,14 23:7 

132:12 

commenters 12:3,21 

12:22 20:21 22:16 

121:16 136:16 137:9 

commenting 69:5 74:9 

comments 4:10 5:3,12 

7:2 10:14 11:22 14:8 

16:6,13 22:12 23:21 

27:11 31:10 34:17 

35:2,22 36:4 42:20 

47:4 52:6 57:9 59:20 

62:14 66:9 67:20 

72:12,16,18 73:11,15 

74:15 75:17 80:6 89:4 

89:15 90:10 91:8,17 

92:17 100:18 109:7 

109:11 114:2 121:16 

124:21 126:9 127:6,6 

134:1 136:13 137:11 

commercial 28:6,10 

37:9,13 

committed 27:2 46:10 

46:19 

Committee 5:11 78:12 

commodities 77:15 

78:7 

commodity 81:6 

common 32:9 107:3 

communities 124:2 

community 46:13 60:13 

91:9 

commute 128:13 

companies 30:11 32:12 

32:16 126:22 128:8 

133:3 

company 31:18 36:13 

36:14 38:19 83:11 

91:21 93:12 100:4 

130:11 132:21,21,21 

Comparatively 127:22 

compared 39:13 54:18 

54:19 71:11 

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completely 94:4 96:2 

98:18 

complexity 39:10 

compliance 116:9 

125:4 

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component 49:1 65:20 

97:9 

components 24:6 

128:14 

composed 115:3 

composition 70:12 

116:1 119:18 125:19 

compost 43:20 47:12 

47:17 

compound 24:8 

compounds 24:20 

73:12 95:22 

comprehensive 70:10 

71:20 

comprise 99:7 

compromising 105:5 

computer 2:7 10:10 

concentrated 34:8 

concentration 122:21 

123:1 

concern 71:11 82:22 

83:2 90:5 95:14,18 

101:22 123:3 124:12 

126:2 131:17 133:8,9 

133:11 

concerned 122:20 

133:2 

Concerning 127:13 

concerns 49:12 51:22 

73:8 82:17 100:12,15 

128:15 

concluded 26:4,9 70:6 

95:7 102:10 

concludes 4:13 16:6 

55:5 66:9 

conclusion 26:22 

condiments 64:17 

65:12 

conditions 49:4 128:4 

conduct 25:21 

conducted 25:3 

confirm 27:18 

confirmed 113:14 

conflating 19:19 

conflict 44:6 59:18 

confused 117:14 

120:15 

confusion 60:6 

Conor 35:10,12,12,19 

consequences 129:14 

conservative 71:21 

consider 27:6 74:1 

considerable 93:21 

consideration 54:3 

55:2,6 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
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considered 65:14 71:3 

80:11 115:12 129:4 

consistency 25:19 

consistent 117:8 

consistently 27:1 

constraints 47:21 48:4 

consult 5:6 

consultant 104:6,6 

consulting 113:21 

consumer 53:21 64:12 

65:3 81:19 98:14 

100:4,6 

consumers 65:18 66:1 

66:3 80:21 135:8 

consumption 28:8 34:3 

95:8 96:5 

contact 69:19,21 

124:10 

contacted 38:21 39:2 

40:8,11 

contacting 40:20 

contain 96:12 97:7 

contained 91:1 

contains 114:21 115:19 

118:4 

contaminant 111:14 

contaminating 79:1 

contamination 26:21 

130:18 

contingent 124:5 

continue 24:21 46:7 

52:1 

continues 53:20 129:19 

continuous 19:1 

contract 63:11 

contractual 129:20 

control 15:18 31:13 

controls 78:3 

conventional 79:13 

conversation 61:3 

131:20 

convinced 71:14 

cooked 53:11 64:7,12 

64:21 65:10 

copper 82:4 86:11,19 

86:20 87:18,19 90:6 

91:16 118:15 

corollaries 36:16 

Corporation 23:17 25:3 

27:1 

correct 19:13 50:17 

57:16 107:19 111:19 

126:4 

correctly 29:22 107:19 

correlates 106:21 

cosmetic 34:2 

cost 22:1 

costs 18:13 

count 9:20 

countries 83:18,21 

country 38:16 40:16 

48:15 59:15 61:22 

136:9 

county 43:14 48:2,5 

49:2 

couple 4:12 51:12 

58:16 59:5 61:5 90:14 

course 49:19 66:6 

85:22 88:1 

court 112:9 122:15 

cousin 35:9 

cover 47:15 127:1 

covered 13:6 

Cox 14:6 23:8,9 34:18 

34:21 35:3,9,18,21 

36:1,7,11,11 37:1 

39:21 40:8 41:9 42:4 

42:13,15,22 43:3 

crap 76:8 

crazy 14:18 

create 45:12 

created 98:19 

creates 24:10 

creation 98:18 

crew 2:20 

criteria 116:16 128:16 

criterion 118:2,22 

119:10 

critical 77:18 105:6 

120:10 

Crop 51:5 

cropping 47:15 

crops 80:1 84:18 87:1 

127:1,1 

crosses 105:21 

crossing 100:16 

cue 35:7 

culture 93:13 98:8 

cultures 96:12 

current 45:19 51:8 67:8 

87:8 128:14 

currently 40:5 56:20 

64:22 81:4 88:10 

customer 3:22 

cut 19:3 49:6 

cuts 54:11 

D

D 80:10 

D.C 69:5 

dairy 77:8 

Dalhoff 95:13 101:21 

Dalhoff/Levy 102:12,20 

102:21 

Dallas 103:20,21 104:1 

113:13,14,16 126:10 

126:10,12 136:22 

137:1 

damage 105:19 

Dan 9:7 

data 61:8 70:17 87:7,17 

90:15,15 91:3,12 

116:17 131:16,21 

database 41:2,10 89:19 

136:6 

date 17:8 27:1 87:4 

106:2 110:6 

Dave 1:14 8:10,12 9:10 

10:2 17:19,19,21 

22:16 47:10 110:10 

122:17 

David 63:1 68:20 74:18 

74:21 75:1,3,4,6,9,13 

76:14,15 85:5,5,6,6,6 

85:10 86:1 92:20,20 

93:4,4,5,7 96:18 99:1 

100:8 103:4 

DC 113:22 

de 1:13 8:4,6 55:13,16 

55:22 56:17 57:3 

de-natured 54:18 

dead 111:17 

deadline 51:21 

deal 9:8 130:22 

dealing 31:3 132:22 

133:12 

deals 105:13 

debate 86:15 

Deborah 58:6,7 63:1 

68:6,6,9,16,19,22 

69:3 74:17 114:6 

December 16:16 

decide 88:12 

decided 45:3 

decision 46:18 47:18 

91:14 

decisions 88:6 

deck 10:21 34:19 43:6 

68:19 

decomposition 124:5 

deep 22:4 

deeply 46:18 

defense 110:13 

defined 95:8 102:11 

114:22 

defining 112:12 

definitely 41:13 48:18 

131:10,19 

definition 128:20 

degrading 124:2 

dehydrates 109:12 

deliver 106:17 

delivered 106:11,16 

delivers 111:12 

demand 64:2,6 66:5 

demands 53:21 

DeMarchie 104:1 

113:16 126:14,19,20 

131:4 132:10 

demonstrated 71:9 

96:6 

dense 45:12 

Department 1:1 6:8 

75:19 

depend 93:15 

depends 94:12 

depressing 129:14 

depth 129:16 

derived 54:15 

describe 42:1 64:2 

115:22 

described 70:15 

describes 118:2 

describing 119:1 

descriptions 70:11 

desire 65:18 

despite 79:4 

detail 42:1 

detailed 52:14 54:22 

70:10 

details 63:22 

detectable 95:1 

detected 79:7 130:18 

determination 129:3 

determine 89:20 

determined 115:5 

134:17 

detrimental 45:3,20 

devastatingly 101:18 

develop 83:6 84:3 

developed 82:21 

developing 79:16 

129:15 

development 6:7 78:1 

107:13 

developments 59:2 

devices 104:19 

Devon 1:21 6:20 

DeVore 95:9 

Devrow 53:6,6 55:1 

63:8,18 

Di 132:21 

dial 2:8,8 85:14 

dial-in 10:3 

dialed 2:10 

dialing 85:15 

dialogue 51:19 52:2 

difference 33:7 

different 16:3 19:11,20 

26:3 30:9 34:10 42:9 

56:4,6 78:13 81:17 

91:4 92:7 116:4 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
142 

127:16 131:5 

differently 76:2 

difficult 89:21 90:19 

105:11 

difficulties 85:12 

digest 28:16 

dihydrogen 69:11 

104:10 107:10 108:16 

125:9 

diligent 45:4 

DiMatteo 74:21 85:17 

85:19 86:5,6,7 89:8 

90:13 92:18 

direct 45:18 49:22 

directly 37:18 

director 1:18 4:15 

disallow 117:17 

disassociated 121:12 

121:13 

disassociates 122:4 

discarded 38:17 

disclose 11:18 

discontinued 16:15 

discover 91:4 

discuss 51:16 

discussed 51:5 

discussing 51:6 65:7 

108:4 

discussion 59:4 61:20 

87:15 90:9 95:21,21 

discussions 46:15 

diseases 76:1 

disinfectant 86:14 

116:5,8 118:19,19 

121:7 

disinfectants 118:17 

119:5 125:7,11,14,20 

disorganized 42:16 

disposal 59:13 

disputed 128:16 

dissociates 123:12 

dissociation 120:20 

dissolved 124:2 

diversion 31:22 

divert 31:17 

Division 1:18,22 5:16 

DNA 105:8 

docket 51:11 72:17 

doctors 74:6 

document 61:16 87:15 

documented 84:16 

doing 18:8 21:8 

dose 25:12 29:16 

double 129:6 

dovetail 99:19 

DR 1:18 4:17 

drains 106:10 

Dramm 23:17 25:3,20 

27:1 

draw 102:13 

drift 24:15 25:2 

drilling 59:10 

driven 65:3 

drives 98:13 100:3 

drop 25:10 29:4 

dropping 22:3 60:3 

drops 25:14 

Drug 69:17 

dry 44:22 

DSM 77:1 

DSPG 36:19 37:19 

38:19 40:9,10 

due 97:17 102:2 128:19 

dumpsters 15:15 

E

E-coli 26:7 

easier 10:8 

easily 108:20 123:17 

East 30:11 31:3 

eating 80:22 

Ecocert 134:8,10 

economic 31:14 50:14 

economics 48:19,22 

99:21 

effect 73:22 111:7 

effective 26:6 78:9,19 

78:21 79:22 87:9 94:5 

98:17 101:11,18 

105:3 106:17 107:21 

effects 45:3 96:6 

efficacious 24:14 

efficacy 78:6 97:5 

effluent 112:2 

efflux 105:15 106:12,21 

109:3 

effluxed 123:15 

effort 98:7 

efforts 94:1 116:11 

Ehreth 63:1 68:20 

74:19 76:8,14,14,17 

92:22 93:2,7,8 97:2 

97:19 99:8,12,15,18 

100:19 102:19 103:5 

103:9,12 

eight 14:17 

eight-day 26:14 

either 9:9 13:1 35:19 

47:16 82:5 91:10 92:1 

Ela 1:13 8:7,8 29:1,21 

32:21 33:1,4 34:12 

100:9,12 120:5,7 

121:11 122:11 

electrolytic 119:20 

elements 129:1 

eliminate 26:10,15 

Ellis 11:14 14:6 23:8,13 

23:16,16,22 27:21 

28:15 29:9 30:2,8 

31:15 32:11,15,20 

33:8 34:13,16 

elucidate 90:9 

email 4:3 

embryo 129:4 

Emily 1:14 8:13,16 

16:10,11,21,22 17:11 

17:14 21:13 50:20,22 

51:1 88:21 99:3,4 

135:3 

employees 14:22 

emulsion 30:6,10 32:12 

33:6 

emulsions 30:13 33:20 

enabled 18:12 

encourage 11:21 114:8 

127:2 

encourages 93:18,18 

ends 59:12 

energy 58:20 

enforce 61:21 

enforcement 61:5 

engaged 25:20 

engineered 130:17 

engineering 130:12 

ensure 26:20 

enter 106:7 

enters 111:11 

entire 98:3,4 

environment 69:14 

70:6 71:1 93:17,19 

112:21 124:13 

environmental 69:17 

72:1 96:6 116:19 

124:9,15 

environmentally 86:10 

92:12 

enzymes 33:13 

EPA 70:1,10 77:12,13 

112:14,18 115:1,4,12 

116:9 119:14,16 

121:9 123:7,21 125:8 

125:12 

epidemiology 76:1 

epoxy 37:17 

equal 25:5,9 

equipment 56:4,10,15 

56:21 107:6 

equitable 88:11 

equivalency 134:2,20 

equivalent 61:22 128:9 

134:18 

Eric 1:15 8:20 9:1 

especially 91:8 107:5 

essence 120:11 

essentially 73:14 121:9 

establishes 69:21 

establishing 132:1 

et 24:8 40:20 51:17 

54:17 95:9 

ethics 31:16 

EU 83:21 

European 102:8 134:2 

134:12,16,20 135:16 

evaluate 71:22 116:18 

evaluated 70:4,20 

77:21 78:2 

evaluating 78:6 

evaluations 115:13 

123:21 

Evan 58:3,4,6 62:20,20 

68:1,1,2,4,5 136:21 

136:22 

eventually 25:15 

everybody 137:20 

everybody's 22:10 

everyone's 7:6 137:17 

evidence 115:11 

evolution 30:20 

evolve 53:21 

evolved 65:4 127:12 

exact 82:10 

exactly 17:7,9 82:12 

example 24:18 54:16 

65:7 82:7 128:22 

examples 54:22 

Excellent 34:22 

excited 77:5 

exciting 79:3 

excluded 128:12,18 

129:5,7 

excluding 108:11 

excreted 110:18 

excuse 53:8,16 66:15 

122:1 

exempt 77:14 119:22 

exempted 119:17 

exert 121:7 

exerted 127:6 

existence 83:12 

existing 71:20 116:9 

129:21 131:7 

exists 67:9 

expand 80:3 

expanded 67:7 

expansion 104:18 

expecting 10:2 

expensive 99:22 

experimented 97:4 

experiments 94:16 

101:14 

expertise 71:22 

explain 18:1,16 49:16 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
143 

72:22 99:19 

explanation 52:8 

110:12 

exponentially 26:19 

export 132:22 133:3 

135:14,20 

exports 133:7 

exposed 70:21 

exposure 48:16 112:16 

115:9 

exposures 71:10 

expressed 95:14,18 

101:22 

expression 105:7 

expulsion 105:13 

extend 7:5 

extension 51:21 

extensive 83:19 

extent 59:6 

extra 2:18 

extract 34:1 

extraordinary 79:20 

extreme 47:20 

extremely 73:20 101:10 

extruded 56:12 

extruding 53:14 

eye 20:2 83:16 

F

face-to-face 5:4,8 

facilitate 6:15 12:17 

41:4 

facilities 27:4 107:12 

123:6 

facility 124:4 

fact 90:2 

fact-based 63:20 

factories 95:12 

factors 25:1 

factory 38:2 

factual 128:2 

fair 57:1 88:11 

fairly 31:2 106:1,6,17 

106:18,20 107:11 

fall 1:5 7:5 16:2 95:1 

118:7 125:21 

falls 112:1 

familiar 41:22 98:2 

133:6 

family 9:8 46:13 

far 32:11,16 42:8 60:5 

83:15 84:7 88:4 112:1 

112:19 

Farinha 85:22 93:4 

103:14,16 104:4,5 

108:6 109:8,16 

110:19 111:3,10,19 

111:21 112:13,17 

113:4 

farm 14:10,18,21,22 

44:19 45:5 46:17 

47:12 48:8,16 49:12 

60:5,9 91:9 127:21 

farmer 14:11,16 43:13 

44:3 46:10 90:19 

131:2 

farmers 14:12 38:17 

40:16 46:2,6 48:5 

88:8,10,15 91:3 92:4 

92:13 129:17 

farming 15:11 46:20 

79:21 80:9 92:6 

farms 15:16,17 47:1 

129:12 

fast 15:4 

faster 18:10 

fate 110:14,16,17,17 

122:20 123:4 124:4 

fault 130:14 

favor 29:5 53:13 

FDA 36:20 69:18 70:9 

77:9 102:8 115:1,4,12 

116:9 118:5,13 

121:10 123:21 124:8 

124:13 

FDA's 118:8 

FDC 71:17 109:12 

federal 5:10 69:16 70:3 

71:16 

feed 20:17 47:12 49:22 

130:17,18 

feedback 2:9 7:8 10:12 

90:10,12 137:15 

feel 42:15 44:1 

felt 44:11 

fermentation 80:12 

93:16,19 94:12 

fermented 93:13 97:22 

98:1,21 

ferments 101:15 

fertilizer 23:19 24:14 

26:5 32:6,15 

fertilizers 24:4,5 28:17 

fewer 128:10 

field 21:6 50:3 130:15 

fields 47:16 

FIFRA 70:3 

figure 6:21 75:15 85:11 

86:1 

figured 132:7 

filamentous 79:4 84:9 

84:16 

filed 116:6 

filets 28:7 

filling 15:17 

final 27:3 28:12,14 50:5 

finally 4:6 39:16 

find 2:17 8:19 17:3 

44:18 48:7 79:10 

112:2 131:14 133:8 

136:7 

finding 117:4 

finish 3:18 12:3,15 

finished 11:22 94:22 

101:2,12 

firm 113:21 

first 11:9 13:9,13 14:15 

14:15,16 63:7 64:3 

83:20 87:21 100:19 

fish 23:18 24:4,5,6,21 

24:22 25:13 27:8,17 

27:19,19 28:5,9,17,20 

30:6,8,10,12,13 31:1 

31:11,14,19 32:4,5,10 

32:10,13,17 33:10,14 

33:15,21,21 34:3 

fishing 28:6,10 

fit 92:6 

fitness 105:21 

fits 88:16 

five 114:16 128:6,10 

fix 86:2 

flame 50:6 

Flats 14:10 

flavors 97:10 

fleet 28:6 

fleets 28:11 

floor 72:7 81:14 

focus 44:3 104:11 

focused 36:14 95:22 

100:4 

focusing 61:8 

folks 2:11 60:18 109:11 

137:2,19 

follow-up 31:9 33:1 

56:17 97:15 112:7 

116:14 

followed 43:5 52:17 

following 74:19 

follows 80:9 

food 24:9 27:22 36:14 

37:14 38:12 39:12 

53:7,15 58:12 59:12 

59:19 60:21,21 63:12 

69:12,16,19,22 70:17 

72:3 74:3,5 76:7 77:6 

78:7,22 79:5 80:4 

81:3 82:14 84:17 94:1 

95:6 98:1 102:9 104:6 

104:19,20 107:5,6,11 

108:18 115:2,5 

116:10,17 123:22 

124:10,14 126:20,22 

127:5,5,9,11 135:19 

foodborne 107:3 

foods 96:12 98:8,21 

133:14 134:14 

footnote 96:9 

force 22:2 

forced 45:17 

form 27:3 109:13 119:5 

formal 104:14 

formality 35:15 

formed 36:13 

forming 109:21 

formula 15:7 64:20 

formulation 91:5 95:16 

107:10 

formulations 95:19 

102:3 

forth 97:3 137:15 

forward 5:11 55:7 

137:18 

found 14:15 16:14,22 

30:22 78:8 84:18 87:5 

91:7,13 95:2 101:16 

four 44:9 115:6 

FRAC 78:10,11,11,15 

fracking 59:14,16 

France 133:3,10,21 

135:15 

frankly 53:18 

fraud 61:15 

free 45:13 108:13 

118:15,15 

freely 119:1 

French 133:4,4 135:8 

135:12,20 

freshly 49:6 

friendly 86:10 92:12 

front 45:1 

fruit 37:5 39:7 78:8 

80:22 81:4 83:4 97:17 

97:20 114:18 133:1 

fruits 133:5 

FSIS 116:9 

full 11:16 15:15 45:22 

53:14 

fully 45:11 46:19 50:11 

53:10 61:2 64:7,11,21 

65:10 66:4 

function 3:6 

functions 42:2 

fundamental 128:15 

fungi 77:20 78:21 79:1 

79:4 84:9 94:5 105:2 

fungicide 70:3 76:3,5,6 

76:21 77:4,10,13 78:9 

78:12,17 79:13,19,22 

fungicide's 77:15 

fungicides 78:2,13 

79:16 81:5 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
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fungus 84:10,16 

further 5:7 11:20 29:13 

52:2 54:17 72:11 73:5 

94:8 131:19 132:2,8 

134:6,21 

Furthermore 115:7 

future 6:13 88:13 

G

gaining 88:3 

gains 25:18 

garbled 16:19 

gas 59:10,16 

gather 91:12 

gel 53:6,17 54:10,20 

55:3 56:6,9,11 63:9 

63:16,18 64:10 65:5,6 

66:2,17 

gelatin 54:13,15,17 

gels 53:13 54:12 

gene 102:4 

general 7:2 87:11 

generally 33:18 36:20 

38:17 77:8 102:10 

generate 84:12 

generated 119:20 

generation 119:20 

generational 95:11 

genetic 129:11 130:12 

131:12 

genetically 130:17 

genome 128:22 

gentrifying 48:3 

Geo 11:14 13:14,14,15 

13:19 14:2,2,3,5,6,9 

16:7 20:6,21 

geographical 38:5 

germinate 49:22 

germination 44:17 

getting 7:15 33:10 49:7 

66:17 75:6,14 131:3 

133:6 

ghost 98:12 

give 11:16 21:7,16,21 

22:4 51:15 52:4 76:19 

85:8 

given 6:16 15:8 21:3 

55:2 137:11 

gives 87:5 

Global 113:20 

gloss 43:22 

Glyloid 36:17 

GMO 94:9 

goods 133:9 

Gourmet 93:8 

Government 134:16 

Goyko 36:19 

grade 27:22 102:7 

granting 96:7 

GRAS 77:8 

grasses 127:1 

grating 38:3 

greater 25:6,7,9,12,16 

26:6,8 114:14 

greatest 48:4 

greenhouse 49:21 

Greenwood 9:5 

grind 32:5 33:11,12 

grinded 38:11 

grinders 39:10 

grinding 38:3,13 

ground 18:22 20:15 

33:22 42:11 

group 58:17 78:10,15 

80:11 

grow 38:15 44:3 48:11 

grower 60:1 

growers 40:4,14 87:6 

87:22 89:20 127:16 

127:20 128:2 130:10 

131:6,14 

growing 17:7 23:19 

40:15 45:15 46:5 

47:15 50:12 59:7 64:4 

73:11 

grown 31:22 129:12 

133:8 

growth 129:14 

guarantee 39:8 

guess 11:7 21:8 89:13 

117:13,18 124:6 

guessing 30:17 

guidance 27:6 60:15 

117:1 127:13 128:7 

gum 36:17 37:8,18 

38:10 39:7,9,17 41:5 

41:14 

gums 40:6 

gut 102:3 

H

half 64:11 

hand 3:7 18:8 45:17 

46:3 48:9 50:10 

handling 69:12 72:4 

82:11 97:18 

hands 3:8,11 56:13 

haploid 129:7 

happen 4:11 15:9 

101:14 110:7 

happened 130:14 

happening 15:11 33:13 

83:17 110:1 

happens 31:2 59:8 

hard 48:7 

harm 69:13 

harmful 25:22 26:11,18 

26:21 

Harriet 1:11 7:18 21:14 

30:3 40:3 47:9,10 

80:18,19 96:19 130:4 

130:5 

harvested 45:11 

harvesting 47:17 

haunts 98:13 

hay 15:20 20:10,12,16 

head 49:7 50:8 85:5 

heads 45:11,15 

headset 2:11 

health 46:11 69:14 70:5 

82:17,18 83:1,2 95:5 

96:13 100:15,17 

102:8 116:19 

hear 3:17 12:5,11 13:17 

13:22 23:12,14 34:22 

43:9 50:19,22 51:2 

57:18 68:11,14 76:16 

85:7,19 88:22 92:22 

99:5 103:17 113:8 

126:16 132:13,16 

135:4,5 

heard 21:5 58:16,22 

59:2 61:1,7 72:8 

92:10 135:10 

hearing 5:12 20:20 23:5 

52:12 55:11 57:8 

60:10 62:13 67:19 

74:14 75:7,9 84:22 

85:8,10 92:16 103:6 

113:2 

hearken 102:7 

heated 30:13 33:22 

heating 112:16 

heavily 18:17 

held 1:8 

helicopter 60:2 

Hello 9:1 13:17 14:4 

76:9 

help 4:4 5:16 6:20 18:3 

38:8 43:19,20 79:15 

80:1,3 96:11 109:4 

117:19,21 

helping 18:2 44:20 

helps 18:4,16 49:17 

herring-type 31:19 

Hey 99:4 

Hi 8:4 21:15 55:16 

58:11 

high 63:12 65:18 131:9 

high-growth 65:9 

higher 26:12 27:3 29:16 

34:8 44:17,20 127:11 

highest 39:8 44:3 53:19 

highlighting 54:21 

highly 27:8 45:20 89:14 

123:14 137:12 

hit 60:5 

hold 57:19 68:18 75:2 

85:18,20 93:3 103:18 

113:11 122:14,14 

holds 54:9 

holes 18:20 

Honigford 11:14 13:14 

13:17,21 14:1,4,9,10 

16:18 17:3,6,12 18:3 

18:18 19:10,13,18 

20:13 21:2,20 22:9,13 

hope 2:18 6:15 46:21 

84:19 

hopeful 63:20 

hopefully 6:15 49:10 

51:18 

hoping 52:1 130:20 

horizontal 102:4 

horse 20:17 

hoses 90:3 

hours 26:8,8,10 

housekeeping 2:5 

huge 44:19 

human 28:7 34:3 69:14 

70:5 71:22 82:17 83:2 

95:8 96:5 100:15,17 

101:20 102:3 116:19 

humans 70:20 

hundreds 78:2 

hunt 6:21 

Hurricane 14:10 

hydrocolor 36:15 

hydrogens 69:7 

hydrolysate 23:18 24:5 

24:22 27:9 28:17 30:9 

30:12,17 32:16 33:5,9 

hydrolysates 24:17 

33:18 34:10 

I

ID 10:22 11:2,3 

idea 32:13 60:11 123:11 

ideal 93:19 

identified 11:10 23:9,10 

26:17 57:22 58:4 

62:21 103:21 128:11 

identify 6:21 11:13 

47:21 52:18 57:11 

68:2 112:9 

identity 54:7 70:11 

ignorance 120:7 

illness 74:3,5 

imagine 6:13 81:7 

90:18 

immediate 4:2 

impact 46:13 59:7 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
145 

60:15,20 70:5 71:4 

94:6 124:9,15 

impacting 59:12 

impacts 58:21 

import 132:22 133:10 

135:14 

important 48:1 59:3 

61:9,11,13 62:3 

imported 48:14 

improve 49:10 

improvement 94:18 

improving 61:8 

impurities 70:13 

in-person 4:10 

inability 54:6 

inadvertently 125:13 

incentive 39:14 

inception 127:10 

include 63:9 129:6 

included 45:6 54:14 

55:3 65:2 70:10 89:17 

includes 63:13 65:20 

including 7:7 26:13 

54:4 60:15,21 61:20 

63:14 70:12 78:7 

105:6 

inclusion 116:18 

117:15 

incompatible 117:5 

increase 18:12 22:1,2 

24:20 95:10,20 

increased 6:5 95:15 

101:6 102:1 

increases 26:19 

increasing 18:13 

incredibly 73:18 

independent 76:2,3,21 

India 37:20 38:4,7 39:3 

39:11 40:11,17 41:20 

42:7 

indicate 25:4 

indicates 64:13 

indicating 81:9 

indication 131:11 

individual 18:9 

individuals 6:22 10:9 

induction 106:21 

industrial 24:9 

industries 37:14 38:11 

80:15 

industry 28:9 34:2,4 

38:6,12 39:12,13 

40:19 42:6,18 53:7 

59:12 61:10 76:7 77:6 

79:5 80:3 98:7,13,21 

129:15 

infections 83:16 

influx 123:17 

information 5:7 6:6 

70:9,19 72:11 89:10 

130:11 

informed 17:5 

infrastructure 58:20 

ingredient 36:14 94:9 

95:4 101:13 

ingredients 24:18 

35:11 36:12 39:18 

64:16,18 96:4 103:1 

initial 25:13 124:22 

inks 43:22 

inner 44:5 

inoculation 25:21 

inorganic 65:1 

input 63:8 98:20 

inputs 94:9 97:22 98:20 

Insecticide 70:3 

inside 105:7 111:13 

insignificant 123:20 

instance 81:14 

instructions 112:10 

integrity 41:1 129:11 

136:6 

intended 70:7,16 71:15 

90:6 

intends 114:16 

interest 77:22 

interested 32:3,5 66:3 

interesting 102:13 

interference 16:17 

32:14 36:22 44:7,12 

44:15 

internal 111:12 127:21 

internationally 69:20 

interrupt 12:14 35:5 

intestine 53:12 54:1 

64:9 65:17 67:10 

intestines 54:4 65:1 

introduce 133:20 

introduced 101:15 

introduction 26:1 

intrusion 94:2 

invalidate 117:17 

invasive 31:13 32:1 

investigate 61:21 

involved 6:17 42:3 67:3 

84:15 

ion 118:9,15,15,16 

120:1,14,16,18 121:6 

122:3,8 123:12 

ionic 73:3 104:21 106:4 

108:8,12,13 109:19 

109:20 110:1,3 118:9 

118:10 119:2 125:10 

ions 105:16 106:12 

111:8 114:21 115:4 

115:19 118:4,4 119:6 

119:6,19,21 120:19 

122:1,2,5 

irrigation 90:3 

issue 55:22 56:19 59:3 

66:2 131:1 

issues 2:22 3:21 4:5 9:8 

15:19 30:18 31:5 61:5 

84:3 99:19 103:7 

127:4 

items 5:14 45:9 

J

James 57:19,20 58:3 

62:16,17,19,20,22 

63:3,6 66:12,13 67:19 

Jane 104:1 113:16 

126:12,12,16,17,19 

132:8 

Japan 36:20 40:9 82:1 

82:14 83:22 

Jay 34:19 43:5 52:16,20 

53:1,5 55:8,9,11 57:6 

57:8 

Jean 136:12 

Jean- 126:16 

Jean-Marie 113:16 

132:12,13,20 135:2,7 

Jesse 1:12 7:22 

Jim 68:20,21 74:19,20 

75:10,11,12,16,18 

76:18 80:5,17,17 

84:22,22 

job 38:19 40:17 

jobs 133:20 

Johnathan 11:10,11,11 

11:13 13:10,12 

Johnson 69:4 

join 136:17 

joined 9:11 23:2 

Jonathan 136:20,20 

judge 127:19 

judged 91:17 

judgments 91:20 

juice 135:18,18 

jurisdiction 134:4 

justifying 83:13 

Justin 11:14 14:6 23:8 

23:8,12,16 27:10 31:8 

31:9 34:14 

K

Katherine 74:20 85:16 

85:18,21,21 86:2,6 

88:20 92:16,16 

Kathy 89:3 

keep 10:7 21:17 29:14 

kernel 37:20,22 38:2,20 

40:9 

kernels 38:1 

key 54:5 

kill 26:13 

killed 70:17 

killing 77:19,20 111:15 

kinds 91:19 

knowledge 97:13 109:9 

knows 119:7 

Kosher 66:18,22 67:6,6 

67:7 

Kurtz 34:19 43:5 52:17 

52:22 53:4,5 55:21 

56:1 57:1,4 

L

label 81:1,8 

labeled 48:13 

labor 18:13 22:2 44:19 

48:3 49:11 50:15 

laboratories 84:11 

laboratory 25:21 

laborious 18:7 19:4 

lack 54:10 97:17 101:4 

125:1 128:20 

lactic 93:15 94:12 

laid 116:16 

Lakes 28:5 

land 49:2 59:8,9,13 

60:2 

language 127:9 

large 38:7 49:1 

largest 45:9 

late 51:10 

Lavera 52:20 

laws 129:22 

layers 44:1 

lead 59:20 73:7 96:13 

leadership 6:3 

leave 29:5 101:9 

leaves 50:2,2 

left 34:7 

left-hand 3:5 

length 51:5 

lens 59:4 

Let's 3:4 

letter 58:17 102:14 

lettuce 45:11,15 48:10 

48:14 49:21 128:22 

lettuces 50:11 

level 24:15 25:5,10,14 

25:15 26:5,12 27:2,6 

73:18,21 79:10 

106:18 112:1,3,12,13 

117:2 121:19 

levels 26:3,20 44:20 

71:11 112:14,18,19 

123:20 

Levy 95:13 101:21 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
146 

Lewis 1:18 4:15,17 

light 44:5 

Lima 1:13 8:5,6 55:13 

55:16,22 56:17 57:3 

limit 65:22 73:14 

114:13 

limitation 51:8 

limited 37:13 53:22 

64:21 90:1 

limits 95:8 102:11 

105:17 

line 4:1 8:14 11:11 

13:15 16:20 22:18 

52:21 57:12 58:5 

62:22 68:2,12 75:10 

85:14 92:20 99:7,9,20 

103:14 113:7 126:11 

126:13 137:10 

linked 37:18 

liquid 23:18 24:4,5 

33:16 

Lisa 1:13 8:4 55:13,15 

list 2:17 10:15,19 11:7 

23:7,9 52:18 54:5,14 

55:4 56:20 57:15 

63:19 65:2 69:8 72:3 

74:18 78:13 81:5 88:6 

88:9,13 96:22 97:1 

114:10 116:19 118:17 

119:12 129:7 136:7 

136:19 

listed 76:2 77:1 128:13 

listened 137:10 

listening 91:7 92:10 

113:5 

listing 90:4 

lists 78:11 

little 2:5,18 11:8 16:22 

29:16 50:21 51:3 52:4 

89:18,21 100:14 

111:22 120:8,14 

live 93:13 96:12 98:8 

livestock 62:6 67:6 

82:19 83:9,14 

living 24:10 

LLC 63:7 

loaded 35:6 

location 82:2 127:21 

locations 128:4 

log 10:4 

logistical 10:5 

long 22:4 94:3 

longer 24:13 26:12 

46:16 83:12 118:2,22 

longevity 46:12 

look 2:6 15:10,11 21:22 

55:7 62:1,7 107:1 

119:11 123:7 124:17 

131:7 136:4 137:18 

looking 5:11 15:19 34:1 

135:13 

looks 132:7 137:3 

losing 83:14 

loss 47:22 97:16 

losses 93:21 98:10,11 

100:2 

lost 98:3 

lot 15:20 19:15 21:6 

29:11 59:17 60:6 65:2 

86:15 104:16 121:22 

loud 135:6 

louder 51:4 89:3 

love 21:4 29:3 

Lovera 58:11,12 62:15 

low 33:17 73:18,21 88:2 

88:6 94:19 106:18 

112:3,12 122:22 

low-fat 65:11 

lower 26:20 34:8,9 

112:13 122:22 

lowered 30:6 

lowering 27:6 

LSC 129:5 

LST 45:7 

LUMA 57:17 

Luna 43:6 52:17,17 

136:21,21 

M

ma'am 39:19 

macro 123:13,18 

main 40:18 133:11 

maintain 25:5,8 29:7,12 

maintaining 27:2 83:2 

maize 129:1 

major 79:11 101:16 

114:16 

majority 27:21 105:11 

maker 53:6 

making 7:1 30:8 40:6 

48:20 53:8 61:14 

manage 49:9 

management 18:2,4 

49:8,18 

manager 63:6 

Manitowoc 23:17 

manually 38:18 

manufacture 38:10 

manufactured 36:18,19 

70:16 

manufacturer 63:12 

manufacturers 30:18 

manufacturing 42:9,11 

March 17:9 

margin 71:10 

Marie 126:17 136:12 

mark 12:4,6 85:21 93:4 

103:14,14,17,18 

104:2,4 107:16 113:2 

market 53:20 59:17 

67:13 71:13 101:5 

130:20 133:12,12 

135:20 

marketing 80:2 82:2 

marketplace 32:10 64:2 

markets 38:6 41:21 

81:21 135:15,16 

Mary 14:6 23:8,8,10 

34:18,19 35:1,6,14 

36:11 41:17,19 42:21 

mass 121:21 133:13 

massive 121:20 

material 44:11 46:7 

51:9 60:8 81:10 83:19 

86:11 88:9,14,16 

91:15 100:1 111:12 

119:2 121:20 125:2 

materials 1:21 43:21 

44:1 46:9 47:2 60:4 

82:5 88:7 91:9 96:20 

129:6,10 

matter 104:12 137:21 

matters 11:19 

Matthew 52:17,17,20 

57:10,11,14 136:21 

136:21 

matured 45:11 

McCann 103:20 113:14 

126:10 137:1,1 

meal 34:7 

meals 30:14 

mean 15:13,14,18 82:4 

97:20 134:9 

meaning 56:11 

means 106:19 108:22 

meant 60:7 

meat 56:8,11 

meats 64:17 77:7 

mechanical 18:11 

mechanism 105:17 

110:13 

mechanisms 129:22 

mechanized 50:10 

medical 73:14 83:15 

104:19 

medication 74:7 

meet 53:21 130:20 

meeting 4:11,13,16 5:5 

5:8,9,18,22 6:10,16 

7:5 51:7,13,15 52:2 

55:3 72:21 87:16 

meeting's 51:11 

meetings 5:9 

member 58:14 78:11 

126:22 

members 1:10 4:19,21 

7:7,7 10:6,7,22 11:20 

12:22 16:9 52:10 

74:12 110:9 131:14 

137:7,14 

membership 58:19 

membrane 105:6 

mentioned 20:21 27:17 

100:20 124:11 

message 58:1,5 62:21 

75:13 85:14 104:1 

113:15 

metabolism 121:9 

metallic 119:19,21 

method 128:19 129:5 

131:10 

methods 127:14 128:12 

128:14,17 129:8 

Michael 23:10,11 34:19 

43:5,6,6,13 47:3,4,5 

48:18 50:22 52:12 

Michelle 1:19 2:4 4:18 

6:20 7:9,12 10:5 12:5 

12:6 13:3,5 

microbe 121:21 

microbes 115:10 

microbial 95:15 102:1 

110:16 122:10 124:2 

microbiology 24:8 

75:20 104:5 

microorganism 111:15 

111:17 

microorganisms

104:13 105:8 106:8 

107:14 

mid-west 28:11 

Midwest 31:1 

milieu 121:4 

mind 36:18 37:15 

minerals 119:4 

minimize 105:19 

106:12 

minimum 15:8 26:9 

48:6 128:6 

mining 59:14 

Minnesota 5:6 

minute 12:4,6 

minutes 3:18 12:1 18:7 

miraculous 100:21 

misplaced 73:9 

mitigation 60:15 

mix 45:10,10,13,18 

mixed 45:12 

mixtures 79:15 

mode 78:15 

molecules 121:8 

123:13,18 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
147 

moment 8:13 23:5 

37:12 40:12 85:9 

money 46:9 

months 45:8 

morning 14:2 

Mortensen 1:14 8:10 

9:11 17:17,21,22 

18:15 19:5 47:7,18 

48:17 49:13,16 50:13 

110:10,11 111:1,4,16 

111:20 112:5 122:12 

122:16,17,19 124:1 

124:16,18 

Moss 23:10 34:19 43:5 

43:6,8,12,13 44:13,16 

47:14 48:2,22 49:19 

50:17 51:2 52:7,15 

move 22:15 45:17 48:9 

132:11 

moved 47:14 

moving 74:18 

mulch 20:10,14 47:13 

mulch-- 19:9 

mulches 21:1 43:19 

47:15 

mulching 47:16 

multi 79:17 

mustard 97:7,8 

mutagenesis 84:12 

mute 2:13,15 3:2,2 7:13 

7:15 9:14 10:7,9,12 

22:22 68:10 85:17 

132:5,6,7 

muted 13:16 68:13 75:1 

130:5 132:13 

mycology 75:22 

N

name 11:16 14:1,7 

23:15 35:1 36:9 43:10 

43:12 53:2,4 58:10,11 

63:3,5 69:1,3 75:16 

86:3,6 90:21,21 93:6 

93:7 104:2,4 113:18 

126:17,19 132:17,19 

name's 14:9 

named 65:21 

names 11:6 91:4 

nano 72:10 108:8,10 

109:6,9,12,14,17 

114:15,22 117:2,3,5 

117:15,16 118:5,6,7 

118:12 119:3,7,22 

121:17 

nanolenses 77:17 

nanometers 114:14 

118:8,10,11 

nanoscale 71:4 

nanotechnology 71:6 

72:13,17 73:3 

narrow 97:21 

narrowly 73:20 

natamycin 76:4,6,21 

78:5,14 79:2,7,18 

80:8,13,20 82:22 

93:10 94:7,8,16,19,20 

94:22 95:3,7,11,16,19 

95:22 96:1,2,8,10,15 

96:21 97:5,11,12,17 

98:16 100:15,21 

101:15 102:3,11,21 

102:22 

natamycin's 77:9 

national 1:3,18,20,22 

4:20 41:1,9 51:19 

54:5,14 55:4 56:20 

58:14 63:19 65:2 69:8 

72:3 88:6 96:22 97:1 

114:10 116:18,22 

117:3 118:16 119:12 

127:2,3 129:18 

134:13 135:22 136:5 

native 94:19 

natural 36:15 59:10 

63:15 65:13 77:16 

79:19 80:11 93:13 

94:4 96:3,12,22 98:18 

98:20 112:21 

naturally 33:14 38:16 

40:15 93:15 94:11 

112:17 

nature 27:8 

near 84:4 

nearly 64:11 

necessarily 128:2 

necessary 26:20 54:11 

need 3:11 18:22,22 

35:17 39:10 46:16 

58:20 60:14 65:8 

73:13 88:12,15,16 

92:4,5 96:22 112:9 

133:14 

needed 25:8 51:16 

59:15 88:8 131:22 

needs 18:21 59:4 88:16 

negative 96:5 

neighboring 123:19,19 

neighbors 15:12 

Neither 71:12 

never 21:2,3 56:12 

65:19 

Nevertheless 123:16 

new 77:10 78:1,10 87:3 

news 59:21 60:1 

newspaper 43:18 

NGO 91:11 

Ngore 113:17 132:15 

132:19,20 134:7 

135:11 136:10,14 

niche 78:21 

nitrogen 34:8 

no-shows 11:5 

Nobody's 92:1 

noise 3:17 

noises 2:14 

non 94:9 98:19 

non-detectable 101:2 

non-equivalent 136:9 

non-pork 66:7 

non-present 101:11 

non-synthetic 94:4 

non-treated 16:1 

NOP 2:4 5:10,15 61:7 

61:14,20 127:10 

137:8 

normal 24:16 108:18 

normally 112:2 

northeastern 31:20 

NOSB 1:9 4:19,21 5:3,7 

5:13,14,21 6:1,6,19 

11:20 45:21 60:12 

87:14 92:10 104:8 

114:3,3 117:8 

note 5:20 10:3 87:21 

noted 89:14 90:6 106:2 

notice 11:8 

noticeable 45:2 

noticed 10:4 

Notification 69:19 

notorious 79:8 

number 2:8 4:1 8:20 

11:2,13 30:10 37:15 

42:2 48:4 57:12,21,22 

85:15 88:10 89:15 

91:17 103:22 105:2 

107:2 113:15 115:6 

numbers 6:22 12:18 

134:13 

numerous 54:15 125:7 

nutrient 45:12 

nutritional 44:4 

O

Oakley 1:14 8:14,15 

16:10,12 17:13,16 

50:19 51:3 74:8 88:21 

89:2,12 99:2,6,10,13 

99:16 135:3,7 

observable 95:10 

observations 97:22 

106:1 

obtained 78:15 

obvious 65:17 

obviously 21:3,10 59:7 

65:22 67:11 83:6 84:1 

100:13 

occasionally 32:1 

occur 26:21 

occurred 4:9 

occurring 93:15 94:11 

112:17 

occurs 24:15 

OCIA 46:15 

October 1:7 5:5 

OFA 60:16 

Off-microphone 134:22 

Off-record 35:22 

offer 98:8 99:20 100:5 

128:8 

offering 6:5 66:4 

offerings 65:16 

officially 4:16 

OID 136:6 

oil 34:3 59:10 97:7,8 

oils 24:18 30:14 34:1,2 

once 13:12 33:16 57:14 

68:4 121:11 123:14 

126:11 

onerous 132:1 

onions 18:6 

online 2:6 36:4 68:10 

74:21 85:5 

open 4:16 38:6 41:13 

41:21 49:3 72:6 

107:17 116:15 131:19 

operate 19:1 

operates 5:10 

operation 44:9 46:13 

48:1 

operators 42:3 

OPIA 43:14 

opinion 20:2 

opportunity 5:2 24:1 

43:16 58:13 61:15 

63:8 65:5,15 66:10,16 

66:18 67:5,7 69:9 

88:17 

opposes 128:18 

option 64:22 

options 45:19 64:18 

66:1 

oral 127:5 

orange 135:18 

order 10:15 21:16 27:7 

56:10 73:21 116:17 

organically 20:15 82:3 

organics 99:21,22 

127:2,3 133:9 

organism 110:16 

organisms 70:18 

105:11 107:2 110:13 

122:10 124:6 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
148 

organization 87:8 95:5 

102:8,9 

organoleptic 97:9 

originally 83:11 89:17 

90:5 

OSP 43:17 

other's 125:2 

OTIA 45:4 

outbreak 101:16 

outcome 96:13 

outside 26:1 110:20,22 

116:8 125:4,18,21 

outstanding 5:22 

overall 29:18 64:5,13 

74:1 99:7 107:2 

overcome 4:4 

oversight 61:6,17 62:5 

owned 49:2 

owner 132:20 

P

P-R-O-C-E-E-D-I-N-G-S

2:1 

p.m 1:9 2:2 137:22 

PACE 77:1 

packaging 104:20 

packers 81:1 

page 35:12 36:12,19 

136:5 

paid 91:11 

pains 46:18 

paper 14:13 15:7 17:1 

18:1,10 20:4 21:17 

37:13 43:17 44:9,10 

45:1,6,14,16,22 46:3 

46:7 47:1,11 49:5,19 

50:7 61:20 95:13 

101:21 102:12 

pardon 120:7 

part 5:4 24:16 28:4,18 

28:19 32:8 37:9,10 

45:6,9 61:9,12,13 

62:4 66:22 70:2,8 

77:18 89:13 90:4,8 

particalize 110:4 

participant 3:4 

participating 4:22 

participation 137:18 

particle 108:8,10 

109:17 114:14,20 

115:16,21 117:5 

121:17 126:2 

particles 72:10 108:11 

109:22 114:22 118:5 

118:7,12 119:3,7,22 

particular 16:14 47:22 

74:10 106:14 111:10 

120:1 

particularly 6:20 117:4 

133:18 136:1 

partner 86:7 93:12 

partners 61:22 63:7,11 

parts 28:7 46:17 48:14 

59:14 

party 25:21 

Paskind 57:20 62:18 

63:5,6 66:21 67:16,21 

pass 68:5 

passed 117:1 

pasteurization 98:9 

pathogenic 70:18 78:22 

pathogens 78:6,19,20 

79:9 84:17 107:4 

Pathology 75:20 

PATTILLO 1:21 

Patty 52:20 57:16,16,19 

58:9,12 62:9,10,12 

Paul 1:18 4:11,15 5:6 

6:11 137:6,19 

pay 102:7 

peaches 81:14 

peak 88:4 

peer 114:11 

penicillin 79:8 

people 3:7,14 15:2 

19:18 20:1,17 30:6 

48:7 58:6 60:14 62:7 

74:6 81:15 83:8 92:9 

108:6 135:17 

peppers 129:1 

percent 25:7 37:6,21 

44:14 53:10 64:20 

94:18 128:22 129:1,2 

131:10 

perfectly 109:20 

performance 127:19 

128:3 

period 46:8 80:2 124:22 

periodic 98:11 

Perkins 58:3 62:20 68:1 

136:22,22 

permits 10:18 

permitted 71:12 

peroxyhydrate 86:9 

person 13:1 15:5 

personal 5:20 

personally 98:15 

perspective 73:8 

pertaining 11:18 

pesticide 70:2 71:17 

80:14 89:19 110:15 

119:17 

pesticides 82:3 

petition 46:22 51:9 55:1 

58:19 63:9,18,22 

66:11 114:11 116:6 

118:2,3,3 

petitioned 119:1 125:8 

petitioner 69:6 117:14 

PGA 39:18 

pH 24:15,20 25:5,9,9,14 

26:3,5,12,18,20 27:2 

27:6 29:4,17,19 30:21 

Ph.D 1:18 

pharmaceutical 104:6 

PhD 113:21 

phone 2:8,10 3:1 4:1 

6:21 10:10,11,13 11:2 

11:13 57:12,21,22 

103:22 113:14 

phosphoric 27:22 

28:13 29:12 

phosphorus 28:14,16 

34:9 

phrased 102:15 

physical 24:17 

pick 10:12 17:7 

picking 40:17 

pickles 93:14 

piece 62:2 

pieces 59:11 137:15 

pig 64:9 65:16 67:10 

pipeline 60:4 

pipelines 59:16 

place 47:16 119:9 

125:17 

placed 71:13 80:20 

117:7 

places 59:18 60:20 82:7 

83:22 

placing 118:22 

plan 60:12 

plans 60:15 

plant 18:5,6,10,14 

45:14 50:7 75:20 76:1 

78:6,18,20,22 110:16 

123:19 128:15 

planting 18:5 45:17 

48:9 128:9 

plants 15:4 18:6 38:12 

38:14 39:14 42:9,9,11 

128:21 

plastic 15:12,17 18:17 

18:18,20 19:2,3,7,8,9 

19:15 20:1 21:1,9 

play 12:7 110:4 

please 2:13 5:6 10:6 

11:12 37:16 52:19 

58:5 62:21 103:22 

113:15 

plugged 56:12 

plums 81:14 

plus 24:11 122:3 

pod 37:6,7,10 38:18 

pod-like 37:5 

point 3:19 12:16 19:7,7 

19:21 34:6 50:1,8 

87:7 91:12 101:1,4 

111:15 115:6 120:16 

pointed 91:22 

points 54:6 114:16 

poking 18:20 

policy 114:15 117:8 

118:6,8 

Polynesia 133:4 

polyoxin 80:10 

polysorbates 39:18 

pool 81:9 

population 48:3 

pork 65:20,21 

portfolio 63:13 

portion 28:15 57:21 

positioned 72:21 

positive 96:13 

possibility 51:20 95:14 

102:4 

possible 6:16 12:4,16 

37:11 44:4 

post-harvest 78:1 79:9 

79:14,22 82:11 83:7 

84:17 93:10 94:17 

97:18 100:22 101:3 

101:10 

posted 82:5 

pot 14:13 16:14 18:10 

20:4 44:10 45:16 49:5 

49:20 

potassium 34:9 

potential 31:17 70:12 

71:4,11 74:2,4,5 

79:17 100:14,17 

potentially 30:14 31:2 

70:21,22 80:14 117:9 

pots 17:1 18:1 21:17 

43:17 45:1,6,14 46:1 

46:3,8 47:1 50:7 

powder 37:20 38:3,20 

39:5 40:9,10 41:11 

powerful 98:21 

PowerPoint 35:6 36:13 

PPM 123:9 

practice 20:3 

practiced 27:1 

practices 15:14 19:21 

62:6 

pre-treatment 107:6 

precedent 51:22 54:4 

preceding 54:22 

predilection 133:17 

predominantly 128:1 

preference 56:21 64:4 

64:13 65:4 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
149 

preferring 81:15 

premature 27:8 

prep 50:5 

preparation 107:11 

prepared 11:7,9 114:12 

preparing 5:13 

presence 26:18 130:12 

present 1:10,17 7:17,19 

7:21 8:1,3,6,8,15,22 

9:20,21 10:1,16 22:17 

22:19 33:14 94:13 

99:8 112:20 130:19 

presentation 114:8 

presenting 114:3 

presents 69:12 

preservative 77:7 

preserved 54:7 

presiding 1:9 

pressure 43:19 44:18 

49:3,11 

pretty 2:20,21 18:7 

47:20 77:5 

prevalence 128:21 

prevent 79:15 

prevents 109:22 121:12 

previous 100:13 114:5 

116:22 117:8 120:8 

price 98:14,14 100:3 

primarily 30:11 31:21 

primary 64:1 94:10 

principle 46:19 

prior 7:4 20:11 27:3 

proactive 60:14 

probably 12:14 21:22 

60:22 90:19 124:4 

130:13 137:14 

problem 2:11 68:18 

98:16 103:10 109:19 

110:2,5 

proceed 23:20 35:2 

75:17 85:11 

process 6:5 24:7,16 

25:7,11,17,19 26:2 

29:7,8,17 30:4 35:15 

45:5,8 46:18 51:10 

52:5 54:4 60:19,20 

70:2,8 73:7 94:11 

106:20 111:8 129:19 

131:22 

processed 30:16 54:18 

64:8 65:1,16 67:10 

processes 24:9 

processing 69:12 72:4 

104:20 107:12 123:6 

procure 39:1 67:5 

procured 38:4 

procurement 37:18 

procuring 32:4 

produce 20:16 23:18 

44:4 59:19 111:18 

126:22 133:14 135:17 

produced 93:13 94:9 

96:3,8 133:18 134:19 

136:3 

producer 130:19 

producers 94:3 

produces 37:4 

producing 59:12 

product 24:12 25:8 

28:12,14 29:19 30:14 

30:16 33:9,16 34:9 

48:11,12,21 52:3 

53:19 56:13 63:13,16 

65:19,20 71:14 73:17 

77:16 79:20 80:12 

82:18 83:1 90:22 

91:18 99:9 101:2,12 

104:10 106:4,6,7 

108:4 110:4,6 111:11 

111:11,22 114:5,7 

116:2 117:13,15,16 

117:18,19 118:3,4 

119:1 120:2 

production 18:13 24:7 

24:16 25:6,14,17 26:2 

27:20 28:3 41:5 54:20 

86:17 92:14 116:17 

116:21 117:6,10 

128:4 133:13 134:14 

136:1 

products 30:15 33:6,19 

45:21 48:14 63:13,14 

63:15 64:14 65:11,13 

65:14 66:16,19,22 

70:13 78:3 81:18,18 

83:6 92:12 93:11,20 

94:3 95:1 97:2,6,7,11 

98:14 99:7,13,15 

100:5 101:1,5 105:5 

107:7 108:7 110:3 

133:10,15,18,19,20 

134:19 135:9,12,14 

135:18,19 136:3 

products' 27:3 

professor 75:19 77:2 

104:5 

profitable 48:21 

program 1:18,20,22 

10:22 11:12 51:20 

69:19,20 117:3 127:3 

129:10,18 131:18 

134:5,14 

Programs' 41:1 

promote 96:11 

promoted 115:10 

promotion 136:2 

proper 24:3 

properly 96:7 

properties 49:10 

proposal 51:14 63:19 

67:12 100:20 129:11 

129:13 131:18 

propose 78:10 80:8 

130:22 

proposed 127:8,14 

128:13,18 129:10 

proprietal 128:1,3 

protect 60:18 94:1 

protecting 80:1 

Protection 69:18 

protective 43:22 

protein 105:6 

proteins 24:8 36:15 

provide 5:3 6:6 7:8 39:4 

40:5 63:8 69:10 72:11 

72:17 88:7 107:11 

130:1,11 

provided 10:15 70:9,17 

71:8 89:5 114:2 137:9 

provides 5:2 66:3 93:19 

providing 80:4 

provisions 5:10 

public 1:5 4:19,20 5:3,4 

5:12,20 6:1,4,5 7:4,8 

10:6,14 11:21 12:21 

12:21,22 72:8,9 89:15 

90:10 121:15 132:12 

136:16 137:4,9 

publicly 49:2 

published 115:8 

PubMed 115:8 

pull 18:22 

pulp 39:4,6 41:11 

pump 110:14,22 120:11 

120:17 

pumped 105:16 108:13 

111:14 

pumping 105:15 106:13 

106:21 108:21 109:3 

110:21 

purchase 65:19 

purchasing 38:19 

PURE 69:6 70:9,15 71:8 

72:14,20 104:9 106:3 

114:4 116:1 

purity 131:7,11,12 

purpose 19:12 64:1 

put 19:3 20:15 48:12 

59:20 61:18 81:22 

82:1,8 89:13 96:9 

97:3 125:16 

putting 60:11,16 

Q

qualified 109:6 

qualities 43:22 

quality 37:19 39:9 

41:14 44:4 53:18 

63:12 65:18 127:11 

130:1 

quantitative 26:16 

quantities 94:22 

quantity 56:19 121:20 

quarter 64:20 

question 3:12 16:19 

17:18 20:6,9 21:12 

22:6,17 27:13 28:4 

29:1 33:2 41:19 47:6 

49:14 51:1 55:14 

74:10 84:19 91:6 99:2 

100:10 101:20 112:7 

122:12,13,18 124:19 

130:6,7 

questions 11:21 12:17 

12:20,21 16:8,9 24:3 

27:11,15 28:22 31:7 

40:2 41:16 42:21 47:4 

50:18 52:9 55:7,9,12 

57:6 62:10,13 66:13 

66:15 67:17 72:6,7 

74:12 80:17 84:21 

88:20 92:15 96:15,18 

98:22 100:7 102:17 

103:7 107:17 110:9 

113:1 116:12,14 

119:15 120:3 126:8 

130:4 132:3,8 135:1 

136:11 137:13 

quick 17:17 112:6 

quicker 18:14 

quickly 31:2 58:8,15 

61:4 99:19 102:20 

quiet 16:22 50:21 

quite 6:13 30:9 34:9 

58:22 61:1 86:15 

104:16 

quorum 10:2 

R

radius 118:9 

raise 3:6,7,11 60:12,19 

60:21 

raises 48:6 

range 45:1 118:7,12 

rapidly 48:3 49:6 

rate 44:17 88:1 124:5 

rational 63:20 

rationale 66:5 

re- 121:2 

re-associating 122:1 

re-entered 110:20 

re-listing 86:9 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
150 

reach 100:3 

reached 40:1 137:3 

read 87:13 102:13 

reading 91:8 

ready 7:15 12:6 51:14 

58:2 135:13 

ReadyTalk.com 3:21 

real 20:22 33:10 100:21 

reams 15:12 

reason 40:18 48:19 

67:11 75:14 89:13 

133:11 

reasonable 69:13 91:19 

107:4 

reasoning 31:13 109:17 

reasons 50:14 59:5 

received 51:9 58:17 

72:9,12 73:10 109:7 

109:10 

receives 91:18 

receiving 131:15 

recess 137:5 

recipe 64:16 

recognition 134:3 

recognize 90:21 115:3 

121:10 

recognized 36:20 71:18 

72:16 115:18 118:13 

recognizing 54:13 

recombining 121:13 

recommend 96:6 131:6 

recommendation 29:4 

114:17,19 115:16,21 

116:3,7 

recommendations 5:13 

6:7 

recommended 114:13 

reconvene 137:5 

record 11:17 14:8 22:16 

36:10 43:11 53:3 

58:10 63:4 86:4 

113:18 132:18 137:22 

recording 89:4 

records 128:3 

redeveloping 15:7 

reduce 74:4 

reduced 44:17 

reduces 105:21 

reducing 122:9 129:16 

reduction 26:7 74:3 

reference 19:8 

referenced 86:22 87:2 

references 87:9,13 

referred 114:5 

referring 37:6 

refinement 128:7 

reflect 125:19 

reflective 127:15 

regard 54:9 

regarded 77:8 

regarding 24:3 64:15 

114:17 128:16 

regenerative 46:20 

regimented 128:16 

registered 71:17 77:13 

79:13,18 83:11 

registrar 83:8 

registration 70:2 77:11 

regularly 83:4 

regulated 125:21 

regulations 116:10 

127:9 134:12 

regulatory 127:8 

relate 56:14,18 

related 72:12 73:15 

127:4 134:2 136:1 

relates 56:15 95:19 

relationship 129:20 

released 86:21 111:8 

relevant 11:16,18 71:22 

reluctance 99:20 

rely 18:17 

remain 24:21 122:5 

remains 110:19 

remarkable 79:11 96:11 

remember 88:1 123:9 

remind 35:5 

reminder 37:4 

remove 20:11,14 24:6 

34:5 37:22 

removed 24:9 28:8 

30:16 38:18 

removing 33:19 88:9 

92:11 

rendered 24:13 

renowned 69:20 

repeat 16:20 51:1 

repeated 92:9 95:2 

report 86:20 87:3 90:17 

114:12 115:17 

reported 79:4 88:5 

115:9 

reporter 112:10 122:15 

reports 84:11 87:13 

89:19 105:12 

represent 64:11 126:20 

representative 72:20 

represents 126:21 

request 45:21 46:5 

require 131:1,9 

required 25:5 26:10,14 

81:3 82:13 92:1 

requirement 81:12 82:6 

132:1 

requires 24:11 29:11,18 

56:9 65:16 

requiring 56:13 

rescue 129:4 

research 39:2 40:20 

45:9 64:13 73:13 79:6 

87:4 90:17 104:13,14 

104:17 

researching 32:2 

residue 77:14 

resistance 73:11 74:4 

79:4,7,10,16 82:20 

83:3 84:8,8,12 95:11 

95:15,20 100:17 

102:2,2 104:12,13 

105:10,12,22 108:2 

108:10 109:2 115:10 

115:13 

resistant 103:2 107:13 

resource 127:4 

respect 12:2 

respectfully 27:5 72:1 

respond 97:20 

responding 72:18 

response 5:14 7:11 

8:11,18 9:12,15,18 

13:11 22:21 23:3 

41:18 52:11 55:10 

57:7,13 62:11 67:18 

68:3,8 74:13,22 75:5 

75:8 

result 70:13 95:15 

116:4,8 125:1,4 

128:10 

resulted 6:3 94:17 

results 26:17 87:5 

retail 81:13,19 

revenue 45:10 

reverse 98:7 

reverted 98:8 

review 45:22 46:8 47:2 

51:17 63:21 70:8 

71:19 86:19 115:18 

reviewed 69:18 70:1 

114:11 

reviewing 117:18 

reviews 69:16 71:8,16 

71:21 

rice 1:11 7:20,21 86:16 

86:22 87:3,11,22 88:5 

89:5 90:7 

Rick 9:5 

rinse 93:10 94:20,22 

100:22 101:3,10 

rise 25:15 29:19,20 

30:21 

rises 26:18 

risk 26:18 116:19 

rival 127:19 

Riverside 75:21 

roast 42:10 

roasted 38:11 

roasters 39:10 42:8 

roasting 38:13 

robust 69:15 

Rodenticide 70:4 

roll 7:10 

ROMERO-BRIONES

1:15 

rots 16:2 

route 22:2 

row 126:22 

run 9:5 14:10 15:1 

30:18 53:14 54:8 

101:13 123:4 136:16 

runners 54:7 

rusty 121:14 

S

sacrifice 47:19 

safe 36:21 63:12 70:7 

77:8 86:10 92:11 95:3 

95:7 96:4 102:11 

107:11 114:17 115:5 

safely 106:16 

safer 83:6 

safety 53:15 69:13,18 

69:21 70:1 71:5,7,10 

71:14,19 72:1 95:6 

101:20,20 102:9 

115:13 123:21 

salad 45:10,13,18 

sale 27:4 

sales 83:12 

Salm 63:6,11 

Salmonella 26:7 

salts 119:11 120:20 

Sanford 85:22 93:5 

103:19,19 113:6,7,13 

113:17,19 

sanitizer 86:14 107:21 

satisfying 66:5 

sauerkraut 93:14 

sausage 53:11,14 56:2 

56:5,9,11,16 63:13,15 

64:7,8,12,14,19 65:1 

65:3,6,8,9,10,19,21 

66:4,8,19 

sausages 53:8,15,16 

53:22 63:15 64:3,5,6 

64:10,15,21 66:6 

savings 44:19 

saying 19:14 21:20 

23:2 56:18 83:13 

107:8,20 117:11,16 

120:13 135:8 

scale 26:16 128:1 

SCD 110:6 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
151 

scenario 70:22 

scenes 5:17 

scheduled 5:5 

Schwartz 1:15 8:21,22 

scientific 73:8,12 

102:14 115:7 

scientifically 101:8 

Scott 1:11 7:20 

SCP 86:10,13,21 87:9 

87:16,18,20,21 88:3 

90:20,20 91:5,5 

scrap 28:5,6 33:21 

scraping 31:18 

scraps 24:7 27:17 

33:10 

screen 3:6,22 27:16 

SDC 69:11,15,19 70:1,5 

70:7,11,15,17,20,22 

71:6,13 72:1,2,9,12 

73:2,19 74:2 108:15 

114:5 119:10 124:13 

125:18 

se 102:22 136:3 

seamless 6:4,15 

search 41:12 

searching 89:18 

season 17:7 45:16 46:5 

seasonings 64:17 

seated 45:18 

second 7:4 28:4 35:5 

50:2 57:19 64:5 68:19 

93:3 102:4 103:18 

113:11 125:16 

secondary 33:12 94:21 

Secondly 90:18 

seconds 3:16 

secret 33:11 

Secretary 1:11 

securing 36:2 37:3 

seed 36:17 37:3,8,21,22 

39:6,9,12,17 41:3,5 

127:13,15 128:8 

129:12,15,16,21,21 

129:21 130:1,10,12 

131:3,7,7 

seeds 36:3 37:7,9,10,12 

37:19 38:4,7,9,10,16 

38:18 39:1,8 40:5,18 

41:6,11,12,13 42:5,17 

127:17 

seeing 8:12 137:18 

seeking 69:6 

seen 44:22 107:22 

110:2,6 

segment 65:9,16 

Seitz 9:7 

select 38:9 90:15 

selection 128:1 

self-mute 2:19 

sell 20:16 134:18 

sellers 129:21 

send 90:14 

senior 63:6 86:6 

sentence 3:19 

separate 38:13 120:15 

series 6:2 

service 4:1 6:1,9 

serving 5:1 

session 137:4 

set 50:1,2 54:4 92:5 

setting 51:22 

Seventy-eight 37:21 

sheer 121:19 

shell 38:1 48:13 

ship 135:15 

shipment 27:4 80:1 

shores 31:19 

short 26:19 72:22 

shot 21:8 

show 59:6 65:17 68:12 

70:17 87:9 109:2 

shown 29:11 78:18 

79:6 95:9 96:4 97:4 

side 3:5 20:19 38:18 

40:17 68:10 

sign 3:8 81:16 

signed 58:18 

significant 28:13,18 

54:1 55:17 65:22 

signs 81:22 82:1,4,9 

similar 80:10,13 

simply 19:20 98:9 

Simpson 11:10 13:10 

136:20,20 

Simultaneous 19:17 

20:7 41:7 76:11 111:2 

single 55:19 56:2,3,22 

66:16 98:17 124:6 

sir 126:7 

site 59:9 60:5 

sites 59:7 

situate 69:7 

situation 92:7 121:5 

122:5 

situations 73:15 88:15 

size 14:19 92:6 114:20 

115:16,21 117:5 

126:2 

sizes 114:14 

sizing 38:8 

skilled 101:8 

skin 53:7,8,17 54:16 

skin-on 53:22 

skins 54:11,19 

skip 10:17 11:5 126:12 

skipped 136:16 

slide 35:8 37:15 

slides 35:6 

slot 13:1 35:16 

slow 30:20 

slurry 25:13 

small 14:21 38:13 39:13 

40:16 93:12 94:21 

106:20 109:21 128:1 

132:20 

smaller 118:5 119:2 

Socius 35:10 36:12 

sodium 86:9 109:11 

soil 44:5 45:2 46:11 

49:3 60:4 112:15 

soils 49:1 

sold 34:6 38:6 42:7 

solely 53:7 

solubility 94:19 95:20 

101:4,6 

solubilizes 118:18 

soluble 103:2 119:2 

solution 24:10 25:16 

29:13 

solutions 24:20,22 27:9 

solves 66:2 

somewhat 30:5 81:17 

sorry 7:14 19:18 21:14 

35:4,14 68:17,20 

76:18 89:3 103:7 

111:3 122:20 130:4 

132:7 

sort 14:20 16:6 34:7 

47:17 98:12 105:22 

110:21 

sought 94:3 

source 28:13 59:15 

94:10 

sources 16:1 26:2 

27:19 37:19 54:16 

128:6,7,10 

sourcing 32:17 41:20 

space 49:3 

spans 104:14 

speak 3:9 6:22 11:7,15 

12:18 35:11,20 93:9 

97:19 101:7 102:21 

109:6 134:6 

speaker 10:11,11,20 

35:16 76:13 114:6 

120:8 122:21 

speakers 10:21 11:1,16 

speaking 2:16 7:13 

19:17 20:7 41:7 43:15 

53:5 63:17 76:11 

111:2 

speaks 102:22 

Specialist 1:19,21 

specialize 75:22 

specialty 84:18 

species 28:9 56:2,3,22 

66:7,16 77:17 79:8 

specific 26:16 54:10 

56:2,9 65:7 71:8 

90:16 125:5 134:11 

specifically 24:2 25:12 

55:18 64:5,16 87:10 

126:1 127:18 

specifying 128:6 

spectrum 78:17 94:14 

105:1,9 117:16 

spent 32:2 

spoilages 93:20,22 

98:5 100:2 

spoke 73:13 

spreading 60:17 

spring 55:3 

squarely 106:16 

St 4:11 5:6 137:5,19 

stabilities 24:12 

stability 25:8 

stabilization 60:4 

stabilized 111:22 

stabilizes 110:1 

stable 25:18 106:6 

staff 1:17 6:19 11:3 

46:14 137:8 

stage 25:14 26:13 50:5 

50:11 

standard 53:19 123:10 

129:19 134:4,11 

135:17 

standard's 134:18 

standards 1:3,18,21 

4:15,20 5:15 46:11 

62:3 117:1 123:8,8 

127:3 134:3,8 135:22 

136:2,8 

standing 77:9 

stands 129:13 135:22 

star-6 3:2 10:12 

star-7 3:3 10:13 

start 3:15,16 10:14 14:7 

23:15 33:20 35:1,12 

36:8,9 43:10 49:5,7 

49:20,20 50:8 53:2 

58:9 61:3 63:3 68:22 

72:5 75:16 86:3 93:6 

104:2 107:17 113:17 

126:17 132:17 

started 2:5 7:2 13:9 

17:6,8 31:18 44:1,10 

starting 136:19 

starts 44:5 45:17 

startup 132:21 

state 71:18 121:13 

123:5 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
152 

stated 10:6 25:11 

117:14 125:1 

statement 80:8 124:15 

statements 124:12 

125:5 

States 1:1 53:11 80:15 

83:10,21 134:17 

stating 72:9 117:1 

status 77:14 

stay 2:13 3:21 

steps 10:5 

Steptoe 69:4 

Steve 1:13 8:7,9 29:2 

33:3,4 100:9 120:5,6 

stock 47:12 128:9 

stocks 27:19 

stone 78:7 

stop 3:19 39:20 40:1 

stopped 44:6,8 

stopper 65:18 

stopping 121:8 122:9 

storage 33:17 

story 59:21 

strategy 80:13 

stream 31:17,21 44:8 

streaming 124:3 

strengthen 38:8 

Streptomyces 77:16,17 

strew 106:8 

strictly 24:13 

stringent 71:18 

strip 19:1 24:17 

stripped 67:2 

strong 55:2 

strongly 26:17 96:14 

115:20 128:5 

structure 131:17 

studied 95:6 102:10 

studies 29:10 71:9 95:2 

95:9 107:22 108:3 

study 102:14,20,21 

studying 84:13 98:16 

stuffed 56:7 64:8 

Subcommittee 51:6 

87:1,14 129:6,10 

subject 69:15 

subjects 102:6 

submission 127:7 

submit 72:2,15 

submitted 55:1 58:18 

59:21 72:16 107:22 

Subsequently 88:3 

substance 71:4 73:4 

114:10 

substances 69:21 

116:18 

substituted 39:17 

success 7:1 45:20 

succession 48:10 

suddenly 60:8 

Sue 9:8 

sufficient 51:15 

suggest 123:17 

suggested 26:17 

sulfur 69:11 82:4 

sulfuric 28:2 

sulphate 86:12,20,20 

87:18,19 91:16 

summarized 87:4 

Sunset 86:19 

suppliers 39:2 40:10 

supplies 46:4 

supply 32:9 94:2 

127:12,16 

support 6:19 46:22 

48:7 59:2 61:2,7 

63:17,22 69:10 71:7 

86:8 93:9 96:14 128:6 

129:9 

supporting 80:13 

supports 127:8 128:5 

129:3 

supposed 60:3 

surely 105:10 

surety 128:20 

surface 95:3 

surfaces 110:5 

surges 61:12,21 

surrounding 86:16 

survival 26:11,15 

surviving 26:1 

sustainability 15:13 

44:21 

sustainable 15:14 

Swaffar 1:16 9:2,3 

switch 21:22 

synthetic 78:3 94:2 

98:19 114:10 

system 18:19 19:2 44:2 

44:10,19 45:16 46:18 

49:5,20 53:14 110:21 

116:20 

systems 46:1 86:14 

92:14 106:22 117:6 

117:10 

T

table 128:14 

tables 123:5 

tags 131:8 

tailored 73:20 

takes 2:18 15:4 108:17 

talk 10:8 14:13 15:13 

36:2 37:2 58:15 89:3 

108:6 

talked 20:9 33:5 41:20 

67:10 100:13 

talking 3:16,19 9:13 

51:3 55:17,18 58:19 

83:8,8 106:3 108:7 

120:9 132:5 

tamarind 36:3,17 37:3,4 

37:5,8,20 38:15,20 

39:2,4,6,9,16 40:5,9 

41:3,5,6,10 42:18 

tangent 20:19 

tank 33:12 

tanks 33:17 

target 32:12 106:11 

targeted 28:9 

targets 108:20 

technical 3:20 4:4 

45:22 47:2 51:17 

63:21 72:19 85:12 

114:12 115:17 

technological 86:2 

103:7 

technology 6:16 14:18 

114:15 117:4 118:6 

129:7 

teleconference 5:17 

telephone 1:8 

Telephonic 16:17 32:14 

36:22 44:7,12,15 

tell 22:17 109:17 137:13 

temperatures 33:18 

ten 9:20,21 10:1 14:17 

99:15,16 

tend 2:9 29:19,20 30:13 

tendons 54:17 

termination 128:19 

terms 65:22 112:13 

test 25:22 

testimony 52:14 85:1 

113:2 132:9 

testing 24:3 122:8 

129:9 130:21 131:1 

132:1 

tests 26:4 131:15 

text 23:1 52:19 

textile 37:13 38:6 39:13 

40:19 42:5 

Thailand 37:21 38:15 

38:20,22 39:3 40:11 

40:14 

thanks 6:18 7:1,6 8:9 

19:5 20:18 50:13 

62:15 66:11,12 69:2 

124:16 135:7 

things 15:10 16:3 19:20 

58:16,17 61:18 62:5,6 

83:9,17 84:13 90:14 

97:7,8,11 101:22 

108:8 131:5 

thinks 37:5 108:18 

third 25:21 50:1 83:17 

thought 22:5 73:7 

thoughts 21:1 

thread 50:11 

three 3:18 12:1,4 15:2 

29:17 115:1 116:7 

120:22 

three- 12:5 

three-minute 3:15 

threshold 25:10 

thresholds 95:1 

THURSDAY 1:7 

tilling 50:6 

timer 3:13,16 7:15 

times 12:1 87:20,20 

92:9 98:3 

tissue 123:20 

titled 102:14 

today 4:10,19 9:6 24:2 

53:5 55:5 57:9 62:14 

63:17 64:1 67:20 74:9 

74:15 85:1 86:8,18 

87:2 104:8,11 114:3 

126:9 

today's 5:17 

tofu 78:8 

tolerance 119:17 

Tom 1:9,10 3:9 5:19,21 

5:22 6:3,8,10 7:14,16 

9:19 16:10 29:1 32:21 

33:1 35:4 50:19 53:4 

116:13 122:19 124:19 

132:4,5 

Tom's 3:14 

tons 98:5 

tool 47:22 50:15 88:8 

88:11 98:17,21 

toolbox 91:22 

tools 49:9 50:10,10 

91:22 92:3 96:11 

top 136:19 

topic 131:20 

total 25:4 99:11,14 

totality 13:2 

touching 56:13 

toxicological 71:9 

toxicologist 114:1 

traction 88:4 

tractor 15:2 

Trade 126:21 

traditional 53:12 56:4 

transcript 4:7 

transcriptionist 4:7 

transcripts 4:8 13:3 

transfer 102:5 

transferred 42:10 

transient 106:1 

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transitioned 53:12 64:8 

transparency 129:11 

130:10 131:2 

transplant 49:5 50:3,4 

transplanter 14:14 15:1 

16:14 18:11,12 20:4 

22:1 

transplanting 49:17 

transport 110:17 

transportation 80:2 

transported 38:2 

transposable 129:1 

transposons 128:19,21 

Traore 113:17 132:15 

132:19,20 134:7 

135:11 136:10,14 

trash 21:6 

tray 18:5 49:20 

treat 81:6 

treated 15:21 81:5 

treatment 79:14 95:4 

107:5,5,6 109:1 

treatments 81:2 

tree 37:4 

trees 38:15 40:15 

tremendous 89:15 

tremendously 80:4 

trend 80:10 

trial 127:21 

trialing 127:19 

trials 25:4 

tricarboxylic 120:21 

tried 40:4 41:4 75:3 

trouble 48:20 

troubling 91:14 

true 50:2,2 54:9 

try 10:22 21:4 51:1 

68:13 85:9,13 89:2,19 

trying 2:6 19:20 29:7 

31:16,17 83:6 90:9 

Tuesday 4:9 59:1,3 

turn 3:10 4:14 5:18 10:8 

20:1 32:6 108:17 

turnarounds 51:13 

turning 109:3 

twice 13:13 57:15 68:5 

126:11 

twine 15:21 16:1 20:10 

20:11,14 

two 6:2 12:9 15:3 18:6 

19:19,20 27:15 28:2 

33:7 45:4 47:21 54:21 

69:16 77:11 101:22 

102:6 108:7 114:20 

116:3 124:21 

twofold 55:21 56:1,14 

type 21:22 54:11 56:8,9 

74:7 

types 56:4 82:5 83:22 

84:13 127:16,20 

typical 56:7 105:20 

typically 24:6 71:6 

U

U.S 133:3,7,10,19,21 

134:1,9,15,19 135:13 

135:14,19,20 136:2,3 

136:8,9 

ultimately 25:18 

unable 9:6 98:9 

unapproved 60:8 

unavailable 40:13 

unbound 109:19,20 

uncomfortable 44:2 

understand 61:10 

63:21 67:5 73:6 74:8 

83:7 84:5 127:10 

understandable 90:4 

understanding 29:3 

54:14 

understood 24:19 

29:22 107:18 

underutilized 37:10 

underway 63:22 

undesirable 97:10 

unfortunate 97:9 

Unfortunately 89:8 

93:17 

unicellular 84:10 

unintended 129:14 

unintentionally 116:4 

Union 134:2,16,20 

unique 30:5 78:15 

107:9 

United 1:1 53:11 80:15 

83:10,21 134:17 

University 75:21 77:2 

113:22 

unmet 64:6 65:8 66:5 

unmute 2:17 3:3 10:13 

13:16 75:3 85:9 

unmuted 13:19 75:2 

unnecessary 71:5 

unparalleled 53:18 

unsustainable 19:21 

20:3 

unusable 24:13 

upcoming 5:4 

uphold 47:2 

uptake 94:21 

upward 24:15 25:2 

30:20 

urge 62:7 129:5 

usage 16:3 83:9 84:4 

88:4 89:7,9,20 127:15 

USDA 5:14 135:9 136:5 

use 3:2 14:16 15:12,18 

15:21 16:1,15 18:18 

19:2 20:1,4,10,13 

21:4,9 23:19 27:16,18 

27:22 28:1,3,8,10 

31:1,11,11 37:13 

41:13 43:17 44:18 

45:6,14 46:4,7,7,17 

47:1,11 56:19 69:10 

70:7,14 71:15 72:3,10 

73:14 77:10,22 79:5 

79:12,14 82:10 83:7 

83:15,19 86:16,22 

87:20 88:13,15 89:19 

90:6,19 91:5,14 92:1 

92:4 94:14 95:3 97:17 

100:14 101:17 104:18 

108:22 114:4,9,13,17 

115:14,17 117:17 

118:3,19 124:10,13 

124:14 125:4,13,17 

127:4 134:8 

useful 83:1 

uses 73:18 79:17 84:2 

88:1 90:1 115:2 116:8 

116:10 123:22 125:21 

usually 2:22 33:22 34:8 

utilize 46:3 

V

Valley 93:8 

valuable 137:12,15 

value 6:12,14 19:16 

27:7 45:20 127:18 

Vanguard 113:20 

variable 27:8 

variety 127:19 128:9 

131:12 

various 24:19 43:22 

65:12 

varying 43:21 

vast 38:5 

vault 25:17 

vegetable 14:21 15:16 

15:17 93:16 97:21 

vegetables 65:12 94:12 

94:13,20 127:1 

verify 127:15 

verifying 61:12 

Vermont 14:11,12,16 

15:15 

versa 134:5,21 

versed 2:21 

versus 29:7 87:18,20 

vetted 88:6 

VGA 114:16 

viability 25:22 46:12 

122:9 

vice 1:11 134:4,21 

Virginia 59:22 

virtually 101:11 

viruses 105:2 

vital 128:14 

voting 51:11 

vulnerable 93:21 

W

wage 48:6 

waited 137:10 

walk 111:4 

wanted 16:13 27:18 

29:21 51:4 52:4 58:15 

119:22 126:6 

wants 134:6 

Wari 132:21 

wash 94:17 

washed 94:20 101:1 

111:17 

washes 94:15 

washing 111:5 

Washington 69:5 

113:22 

wasn't 81:11 89:14,16 

130:16 

waste 19:15 31:17,21 

38:17 44:8 46:8 

wastewater 59:13 

Watch 58:12 

water 58:12 59:15 

86:14 94:18,21 103:1 

111:9 112:2,15 123:1 

123:8,9 124:3 

way 18:20 19:2 47:12 

80:21 81:10 88:11 

89:10 90:17 91:4,6,19 

102:6,19 

wearables 104:19 

web 57:21 136:5 

webinar 1:5,8 3:9 4:9,9 

4:21 5:2,21 6:1,4 7:4 

137:4 

webinars 2:21 6:13 

13:2 

website 3:21 5:7 

Wednesday 137:6 

weed 15:18 18:2,4 

43:19 44:17 45:12 

49:3,7,11,18 

weeders 49:9 

weeding 50:6 

weeds 49:9 50:9,10 

week 4:11 5:6 45:15 

137:6 

weekend 137:20 

weeks 4:12 50:9 51:13 

welcome 2:3 4:19 7:3 

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22:14 34:13 57:4 

92:18 

went 78:12 137:22 

weren't 38:22 

West 59:22 

white 38:9 

wide 38:5 71:9 

widely 87:16 89:16 

widespread 79:5 

wild 27:19 28:8 32:5 

38:16 

wilted 37:22 

Wisconsin 23:18 31:20 

Wolf 86:7 

wondering 30:4 41:4 

89:4 110:12 130:9 

word 60:17 101:17 

102:15 

words 6:12 

work 4:22 5:14 18:21 

23:17 35:10 36:12 

40:4 48:8 60:12 83:5 

105:13 111:9 114:20 

worked 78:5 

working 15:7 41:5 59:2 

77:4 127:5 

works 52:5 78:18 

135:22 

world 15:11 19:22 

81:22 82:7 83:18,20 

95:5 102:8 

worse 71:1 

worst 70:21 71:10 

worth 65:7 

wouldn't 28:18 81:16 

wrap 80:6 

written 31:10 59:20 

61:18 114:2 121:16 

124:11 127:6 131:18 

wrong 107:19 

X

Y

yarn 38:8 

Yay 99:6 

year 14:21 15:15 16:16 

yearly 44:14 

years 6:2 14:17 44:9 

45:4 53:10 77:7,11 

93:14 98:16 104:7,14 

104:15,17 

yeast 84:9 94:6,10,11 

101:16 

yield 25:8 94:18 

Z

zero 84:4 

0

1

1,277 87:20 

1/100 118:8 

1:00 1:9 

1:07 2:2 

12 98:4 

14 93:14 

15 53:9 

150,000 14:20 

16,091 88:5 

18 1:7 

1968 115:8 

2

2 36:12 

20 44:14 104:15,17 

2000 36:13 

2004 36:20 

2007 86:21 

2010 87:17 88:1 

2012 78:5 

2014 88:4 

2018 1:5,7 16:16 36:21 

51:21 115:8 

2019 55:3 

205.606 63:10 

24 26:7 

24th/26th 5:5 

25 104:7 

29 118:9 

3

3 36:19 

3.0 27:7 29:4 30:7 

3.05 25:15 

3.5 25:6,9,16 26:5 27:2 

29:4,5,6,7,10,12,14 

3:32 137:22 

30 94:18 

300 114:14 117:4 

34 37:6 

4

4,000 45:15 

4.9 26:12 

48 26:8 78:15 

5

5 37:16 

5-log 26:6 

50 53:10 77:7 

500 18:6 

6

6 118:11 

6-log 26:8 

606 54:5,14 55:4 

7

7 63:9 

70 104:14 

700 126:21 

72 26:9 

75 128:22 

76 129:1 

8

85 129:2 

9

90 25:7 

95 131:9 

97,757 87:20 

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C E R T I F I C A T E 

This is to certify that the foregoing transcript 

In the matter of: National Organic Standards Board

Fall 2018 Public Comment Webinar

Before: USDA

Date: 10-18-18

Place: webinar

was duly recorded and accurately transcribed under 

my direction; further, that said transcript is a 

true and accurate record of the proceedings. 

-----------------------

Court Reporter 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 
1

 UNITED STATES DEPARTMENT OF AGRICULTURE

 + + + + +

 NATIONAL ORGANIC STANDARDS BOARD

 + + + + +

 FALL 2018 MEETING

 + + + + +

 WEDNESDAY,

OCTOBER 24, 2018

 The Board met in Great River Ballrooms 

1&4 of the Intercontinental Saint Paul Riverfront 

Hotel, 11 Kellogg Boulevard East, St. Paul,

Minnesota at 8:30 a.m., Tom Chapman, Chairman,

presiding. 

PRESENT: 

TOM CHAPMAN, Chair

HARRIET BEHAR, Vice Chair

SCOTT RICE, Secretary

SUE BAIRD 

ASA BRADMAN 

JESSE BUIE 

LISA DE LIMA 

STEVE ELA 

RICK GREENWOOD 

DAVE MORTENSEN 

EMILY OAKLEY 

A-DAE ROMERO-BRIONES 

ERIC SCHWARTZ 

DAN SEITZ 

ASHLEY SWAFFAR 

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STAFF PRESENT: 

MICHELLE ARSENAULT, NOSB Advisory Board

Specialist, National Organic Program

SONIA JIMENEZ, Deputy Administrator, Specialty

Crops Program, Agricultural Marketing

Service 

DR. PAUL LEWIS, Ph.D., Director, Standards

Division, National Organic Program

CLARISSA MATHEWS, Ph.D., National List Manager

DEVON PATTILLO, Materials Specialist, National

Organic Program

DR. JENNIFER TUCKER, Ph.D., Deputy

Administrator, National Organic Program;

Designated Federal Official 

ALSO PRESENT: 

DAVE FREDERICKSON, Commissioner, Minnesota 

Department of Agriculture 

JULIE GROSSMAN, Ph.D., Professor and Organic 

Program Coordinator, University of 

Minnesota 

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 CONTENTS 

Call to Order. . . . . . . . . . . . . . . . . . . 4 

Introductions. . . . . . . . . . . . . . . . . . . 4 

Chairman's Report. . . . . . . . . . . . . . . . .55 

Secretary's Report . . . . . . . . . . . . . . . .57 

NOSB Report. . . . . . . . . . . . . . . . . . . .58 

Employee of the Quarter. . . . . . . . . . . . . 139 

Public Comments. . . . . . . . . . . . . . . . . 142 

Adjourn. . . . . . . . . . . . . . . . . . . . . 460 

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P-R-O-C-E-E-D-I-N-G-S 

8:35 a.m. 

 DR. TUCKER: Okay, everybody good 

morning. We're going to get started here. 

Welcome. We are officially opening the Fall 2018 

National Organic Standards Board meeting. 

My name is Jennifer Tucker. I'm the 

Deputy Administrator of the National Organic 

Program, which is part of the USDA's Agricultural 

Marketing Service. I'll serve as USDA's 

Designated Federal Officer for the meeting. 

First, I want to thank everyone for 

being here, making the trip to St. Paul, 

Minnesota. I'm going to start by introducing the 

AMS and NOP team. First next to me here is Dr. 

Paul Lewis, our Standards Division Director. 

Also supporting the meeting is our new National 

List manager, Dr. Clarissa Mathews. Stand up 

Clarissa. 

(Applause.) 

DR. TUCKER: I'd like to share a 

little bit about Clarissa, who started in the 

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role in June. Most recently, she served as an 

accreditation manager in our Accreditation and 

International Activities Division in NOP. 

Previously, Clarissa served as chair of the 

Institute of Environmental and Physical Sciences 

at Shepherd University, where she taught 

Environmental Science, developed curricula in 

sustainable food production and directed a 

veterans to Agriculture training program. 

Earlier in her career, Clarissa worked 

at the USDA ARS Appalachian Fruit Research 

Station in West Virginia. There, she 

investigated ecological methods of managing 

insect pests in orchards. Dr. Mathews earned a 

Bachelor's of Science from the University of 

Rochester and a Master's degree and Ph.D. in 

Entomology from the University of Maryland. 

So many of you have already interacted 

with Clarissa since she became National List 

manager, but let's give her another welcome. 

(Applause.) 

DR. TUCKER: We also have Devon 

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Pattillo who folks know well, and who is an 

amazing member of our Standards team. I'm going 

to tell you more about Devon later, and then also 

in the room we have Betsy Rakola, NOP's 

Compliance and Enforcement Division Director. 

Betsy's done terrific work. 

(Applause.) 

DR. TUCKER: Betsy's done terrific 

work on the Enforcement side over the past year 

and a half, and I'm really glad she's with us 

here this morning. Betsy also has a birthday on 

Friday, so wish her a happy birthday at the 

break. Yea, happy birthday. 

We also have a guest from another part 

of AMS, Sonia Jimenez, who is the Deputy 

Administrator for the AMS Specialty Crops 

Program. Sonia, we're very happy to have you 

here. 

(Applause.) 

DR. TUCKER: Later this morning, I'll 

be talking about a new learning management system 

for organic inspectors and certifiers, and we 

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would not be able to be where we are with the 

project without Sonia's team. They already have 

an infrastructure that we've plugged right into. 

She's been enormously helpful. So Sonia, thank 

you so much. 

Next, I want to introduce and thank 

Michelle Arsenault, our advisory board 

specialist. 

(Applause.) 

DR. TUCKER: These meetings would not 

be possible without Michelle. She does amazing 

work to bring us together each and every time. 

So again Michelle, thank you so much. I now want 

to welcome our two new members to the National 

Organic Standards Board, four of whom were 

appointed earlier this year. 

So Dr. James Greenwood from California 

is an environmental protection and resource 

conservation -- sits in the Environmental 

Protection and Resource Protection seat. Jim, go 

ahead and tell the audience about yourself. 

DR. GREENWOOD: First of all it's a 

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real pleasure to be here. I'm a faculty member 

at UCLA in the Department of Epidemiology, and 

also a professor within the Institute of 

Environmental Sustainability. One, partly for 

this group, I've been an organic avocado grower 

in southern California for probably the last 15 

years, and if any of you have any influence, we 

need rain, okay. So that's the issue. 

This year we got three inches of rain, 

and I know my colleagues on the Board, some of 

them had three inches of rain in an hour. So 

it's a big issue in southern California. But 

again, it's a pleasure to be here and I look 

forward to working with all of you. 

DR. TUCKER: Thank you very much, 

welcome. And we also have Mr. Eric Schwartz, 

also from California, and he is on one or our 

Organic Handling seats. So Eric, your turn to 

introduce yourself to the group. 

MR. SCHWARTZ: Well good morning. 

Like Rick, it's a pleasure to be here. I 

currently work for a vegetable cooperative, 

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represent 50 growers. It's about 160,000 crop 

acres in California for leafy greens. Our 

cooperative has about 70 percent of the organic 

leafy greens that are grown in the west coast. 

Prior to that, I worked for Dole for 

a number of years in both their conventional and 

their organic program. I was there from the 

beginning when they started their organic salad 

line. Prior to that, spent a lot of years in 

processing at Kraft for Birds Eye. 

In fact, I remember many times going 

down to Waseca and I learned how to do that in 

the winter time. But it's a pleasure to be here, 

and I'm looking forward to it. Thank you. 

DR. TUCKER: So welcome to both of 

you. To mark the occasion, I have letters here 

signed by Secretary Perdue, welcoming you to the 

Board. 

(Off microphone comments.) 

DR. TUCKER: Okay, I'm back. Okay. 

So here is a quick overview of our three-day 

agenda. This morning, we will hear from two 

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very, very special guests. We're really honored 

to have them here. 

Mr. Dave Frederickson, a past 

Commissioner of the Minnesota Department of 

Agriculture, and Dr. Julie Grossman, professor 

and organic program coordinator from the 

University of Minnesota. 

Then we'll hear an NOSB update and 

I'll provide an NOP update. The rest of the day 

will be dedicated to public comments. Tomorrow, 

we'll continue public comments and then turn to 

the subcommittees. This will continue into 

Friday, and then we'll close Friday with 

administrative activities, officer elections and 

a look ahead. 

To close, I'd like to give a special 

thank you to Tom Chapman, chair of the Board and 

chair of this meeting. This is Tom's fourth 

meeting chairing the Board. Let's give him a 

round of applause in advance for braving it. 

(Applause.) 

DR. TUCKER: Tom, I am handing it over 

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to you. 

MR. CHAPMAN: Thank you, Jennie. 

Thank you for right nice introduction. Hello and 

welcome everybody. Thank you for traveling here 

today to participate and observe the fall 

National Organic Standards Board meeting. I hope 

everyone traveled safely and is enjoying 

Minnesota's warm hospitality and chilly weather. 

This is a bit of a contrast from our last 

location in Tucson. 

Still, Minneapolis and St. Paul are a 

fitting location for our NOSB meeting, wellsteeped in food production amongst other 

industries. The Twin Cities came to prominence 

by harnessing hydropower to melt grain into 

flower. Given that history, I think it's a 

fitting place for us to have our NOSB meeting. 

With that, I'd like to take a moment 

to introduce or have the members introduce 

themselves, the other 13 members, and we'll start 

down here with A-Dae. 

MS. ROMERO-BRIONES: Good morning. My 

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name is A-Dae Romero-Briones, and I am Cacatua 

and Kiowa. I currently serve as the Director of 

Programs for Fresh Nations Development Institute, 

and my home base is in Lodi, California. 

MS. DE LIMA: Hi. I'm Lisa de Lima. 

I'm in the retailer's seat. I work at Mom's 

Organic Market as the Vice President of Grocery. 

It is my fourth year on the Board. 

MR. BRADMAN: Asa Bradman from UCBerkeley, School of Public Health, Center for 

Environmental Research in Children's Health. 

I've worked for many years at environmental 

exposures and agricultural issues in California. 

MR. ELA: Steve Ela, Ela Family Farms, 

organic fruit grower in western Colorado. 

MR. MORTENSEN: Dave Mortensen from 

the University of New Hampshire. My background 

is in food systems and agro-ecology. 

DR. SEITZ: Good morning. My name is 

Dan Seitz. I serve in a consumer seat, consumer 

member seat. I'm the Executive Director of the 

Council on Naturopathic Medical Education, and 

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also a board member on a food co-op, and I live 

in Great Barrington, Massachusetts in the 

Berkshires of western Massachusetts. 

MS. BEHAR: Hello. I'm Harriet Behar. 

I work with the University of Wisconsin Organic 

Laboratory, and I live on a farm. I've been a 

certified organic farmer for almost 20 years. I 

live in Gays Mills, Wisconsin, and believe me Tom 

it gets a little colder than this. 

MR. RICE: Good morning. My name is 

Scott Rice. I am in the certifier seat, and I am 

the External Affairs Coordinator with the 

Washington State Department of Agriculture 

Organic Program. This is my third year on the 

Board. 

MS. SWAFFAR: Hi, I'm Ashley Swaffar. 

I'm in the producer's seat. I'm from 

Fayetteville, Arkansas. I have a small organic 

mixed vegetable farm and I'm also the Director of 

Animal Welfare and Food Safety for Handsome Brook 

Farm. 

MR. BUIE: Good morning. I'm Jesse 

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Buie, president of Ole Brook Organics. I sit in 

a farmer's seat and I think this is my second 

year. 

(Off microphone comments.) 

MR. BUIE: Third? Goodness, okay. 

MS. BAIRD: Hi. I'm Sue Baird. I'm 

from Missouri. I'm the Executive Director of 

Mid-America Food, Mid-America Organic Association 

and Mid-America Food Hub. I serve as special 

interest group and so thank you for having me. 

MS. OAKLEY: Emily Oakley, Three 

Springs Farm, Oklahoma, and I'm in a farmer's 

seat. This is also my third year. 

MR. CHAPMAN: And I am Tom Chapman 

from Clif Bar and Company, where I work as the 

Director of Ingredients Sourcing, and I sit in 

the handler's seat. This is my fourth year on 

the Board. Thank you everyone for the 

introductions. As Dr. Tucker mentioned, we have 

two special guests here this morning, and I 

would like to introduce our first guest. 

Our first honored guest is Dave 

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Frederickson, who served as -- who serves as 

Commissioner of Minnesota Department of 

Agriculture since being appointed by Governor 

Mark Dayton in 2011. Frederickson was elected to 

the Minnesota Senate in 1986, where he served two 

terms. He was president of the Minnesota Farmers 

Union from 1991 to 2002, and president of the 

National Farmers Union from 2002 to 2006. 

At both organizations, he worked on 

federal farm policy and other issues important to 

farmers and ranchers. Frederickson continued his 

work on federal policy at Agricultural Outreach 

Director for U.S. Senator Amy Klobuchar from 2007 

to 2010, and the Frederickson family, family 

roots in farming go back to 1873. So he can 

maybe teach us a little bit about that grain 

mill. 

He and his wife Kay have operated a 

farm in Murdoch, Minnesota for more than 20 

years. Commissioner Frederickson's farming 

background and his wide range of experience in 

public service have given him the unique insights 

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to challenges facing Minnesota's agricultural 

industry. 

Today, he is focusing on ensuring 

Minnesota's Department of Ag fulfills its mission 

to protect the integrity of our food supply, the 

health of our environment and strength of our 

organic agricultural economy. These missions are 

close to the organic community both in the U.S. 

and in Minnesota, and I welcome Commissioner 

Frederickson and ask him to share to some remarks 

with us. 

(Applause.) 

MR. FREDERICKSON: Thank you very 

much, Mr. Chairman. Excuse me. Where did you 

get that lengthy bio? I'll tell you, that needs 

to be cut down. I'm a Norwegian Luther, and I 

was born guilty and so I just can't deal with 

that at 8:30 in the morning. 

(Laughter.) 

MR. FREDERICKSON: It's too much. 

Nonetheless, what you probably took away was I 

can't hold a job. 

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(Laughter.) 

MR. FREDERICKSON: Again, Dr. Tucker 

and Mr. Chairman and members of the Board, what a 

great pleasure it is for me to be here with you 

today to welcome you to the great city of St. 

Paul. Most people say well, you're from 

Minneapolis, and I say hell no, I'm from St. 

Paul. I live in St. Paul, one of the twin 

cities. 

So it's great to have the 

acknowledgment that St. Paul actually exists. 

Good to be here and thank you for choosing St. 

Paul. A wonderful venue here close to the river, 

so it's exciting hopefully for you to be here and 

certainly exciting for me to be here to welcome 

you. 

And again, I have to mention my 

colleague, Harriet. We've had a little fun back 

and forth about who's the coldest state, and so 

if that's all the far we get with the rivalry, 

I'm okay with that. Oh, I forgot to mention the 

Packers and the Vikings. Yeah, that's part of 

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our history also. 

Again, let me give you a little bit of 

history myself, rather than I'll give you the 

short -- why don't I do it this way? I'll give 

you the short life story in about two minutes. I 

was born the middle child of three kids. I was 

born in 1944. Yes, that makes me an old man 

today. I'm 74 and knocking the door on '75. I 

flunked retirement once, I don't plan to flunk 

again. 

I thought it would be a good idea to 

farm, and my dad said good gosh no, go get an 

education. You can always farm, which I thought 

was -- it was appropriate in 1962. You could. 

Today it's a whole different story for people in 

terms of you could always farm. It's sort of 

farm now, he should have said, because you could 

always go to school. 

So I went to school and my sister 

graduated from the University of Minnesota at a 

little campus in Morris, Minnesota. My brother 

graduated from the University of Minnesota. I 

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went off to a state university and I taught 

school for eight years before Kay and I, my 

spouse of 53 years, we were married in 1965. She 

was an Irish Catholic Katherine Ann Kennedy, and 

I was a Norwegian Lutheran. 

Lived seven miles apart. We were 

ecumenical before the word was popular and we 

married in '65. They called it a "mixed 

marriage" at the time, and he actually hate 

another one now, but by God we're going to show 

that we can make. 

No, we thank you. I taught for eight 

years. I taught behavior problem kids. Many of 

them are members of the Board now, and when my 

father's health failed, I chose to -- my wife and 

I chose to go back to the farm. 

And so we did. We went back in 1974, 

and farmed there until 1999. And then eventually 

leased the farm and eventually sold it to a 

cousin. So we no longer farm. We had two 

daughters, neither of them interested in farming 

and just made the decision one day to sell it to 

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a cousin. He said he was helping me, and he said 

you're never here anyway so why I don't you sell 

it to me, and I said sure, why not? 

So I did. One major mistake, I should 

have kept it for a few more years, and I would 

have had a shot at being a millionaire, but I 

didn't quite make it. So always a matter of 

farmer mentality I guess it is. You know, sell 

low right, make it in volume or something along 

those lines. 

We spent 25 years there. I in the 

meantime got angry at a state senate, my state 

senator and foolishly decided to run against him 

no expecting to win. Just thought somebody's got 

to this, and did and accidently won the election 

by 32 votes. We had two small kids at the time 

farming about 1,200 acres of corn and soybeans. 

My salary at the legislature was 

$22,900 and I hired a hired man for 25,000. 

Brilliant move. But I spent two terms in the 

Senate, and some people don't recognize this but 

early on I recognized that in my second term that 

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every now and then an innocent person is sent to 

serve in the legislature, and so I thought this 

was a good time to exit. 

And so I did, and was headed back to 

the farm to see if we couldn't, you know, 

actually turn a profit. I was sidetracked to the 

Minnesota Farmers Union and I spent what I 

thought would be just about six months filling an 

unexpired term of the president. That turned 

into nearly 11 years. 

At the end of those 11 years, I ran 

for and was selected to serve as president of the 

National Farmers Union. I traveled to our office 

at the time was Denver, Colorado, and so I 

maintained an apartment in Denver, a home in 

Minnesota and a hotel room in Washington, D.C. 

I was back here traveling out to a 

little meeting in Woodstock, Minnesota. Not the 

one that you people with beards remember, but the 

one out by Pipestone. Actually, they say if you 

remember Woodstock you weren't there. Yeah. 

(Laughter.) 

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MR. FREDERICKSON: Anyway, on the any 

I fell asleep at the wheel and I drove up the 

back end of a grain truck. I was doing about 60 

miles an hour and she was doing about 30, and I 

totaled a pickup, ended up in the hospital. My 

wife had to come out and pick me up and said 

that's kind of scary. I'd been on the road a 

significant amount. 

A couple of months later -- I survived 

it, got a new pickup out of the deal, I was 

flying back to Mexico City through Houston on up 

to the Twin Cities and the plane was struck by 

lightning, and this huge ball of fire went out 

from under the plane and I thought -- and the 

lights flashed and the wings rocked and people 

were screaming. 

I thought to myself I think I'm ready 

to retire. I think I've just received a sign 

from someone, and I was able to retire at that 

point. I sat around and stared out of the window 

after leaving, at the end of my term. One day my 

wife said you remember the vows we took in '65? 

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I said of course. 

Well, I'm okay with in sickness and in 

health. That's great, I'm happy about that. 

I'm actually okay with "until death do us part." 

Good. Where is this going? She said I am 

certainly not okay with you being home for lunch, 

so go find something to do. 

So I did. Our U.S. Senator, our 

senior Senator was elected to serve in the United 

States Senate. Amy is a long-time friend, and 

asked if I would come and work with her on her ag 

policy and ag outreach issues. So I was right 

here in the Twin Cities for the first four years 

of her term. 

Our governor was elected, Mark Dayton, 

and asked if I'd come over to the Department, and 

I've been there for two terms. He survived the 

first term. My role is basically to keep his 

name out of the paper for bad things and ensure 

that it gets in there for good things. I've got 

two and a half months so far left. So far, so 

good. But that makes me a really dangerous lame 

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duck, I suppose, at the end of the day. 

So that brings us here. You know a 

little bit about me at this point. My plan for 

retirement is to -- I've been working on an old 

boat for the past 20 years. I've finally got it 

done and I plan to drop it in the Mississippi 

here and take it to New Orleans in June or July 

of next year, Mississippi Solo. 

It should be great fun. I'm excited 

about it. It's about 1,850 miles. The boat is 

18 -- you know, my boat is so small and the 

river's so large. So it's a little scary, but 

you know, I've had a good life, right? So I'm 

looking forward to it. It should be great. I 

have a lot of friends up and down the river. I 

met one right now, Adam Wartheson, who says call 

me when you get to Winona, so what are friends 

for if you can't call them and use them once in a 

while. 

I have an outboard, so I'll be needing 

gas, Adam, at some point. I had a chance to 

again read your incredible bios. Last night, I 

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entertained myself by reading all about you. You 

know a little about me and I know a lot about 

you, except for Rick. Your bio was not present 

on the website quite yet. But that -- yeah, 

yeah, yours. 

But everyone else around here, hello, 

I know you. Great to see you again. What an 

incredible group of people. I'm just so excited 

to get a chance to read about you, read about 

your history. Jesse, I read all about you in 

your bio. What an incredible experience, and I 

don't like you remember whether it's two or three 

years either, so don't feel bad, you know. 

Just I'm just so impressed. Scott 

Rice, I know your director very well, Director 

Sadison (phonetic). I spent last week with him 

in Monterey in Mexico. We had a great 

opportunity to work with the Tri-National Accord, 

and thank you to USDA for pulling together the 

now new NAFTA agreement. 

I can't remember the initials. I 

guess it's USA, something to do with -- help me. 

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Yeah, sort of like that, you know, the Village 

People, right. 

(Off microphone comments.) 

MR. FREDERICKSON: Got it. Some of 

you got it, right? But thank you. Thank you 

because otherwise that meeting, that Tri-National 

Accord would have been difficult, and it is the 

Ministers of Agriculture from Mexico, the 

Ministers of Agriculture from the provinces in 

Canada, and the directors, secretaries or 

commissioners that serve in the states in the 

United States. 

We have met over the course of 27 

years, and generally it is pretty friendly. I 

was worried this year to go in and talk about the 

negotiations, but the good news is it's done. 

And so my hat's off to the administration for 

working through this process and making things 

better. 

I'm still concerned about the 232 

tariffs that are still in place. Right now, 

agriculture is held hostage and we are collateral 

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damage across the state and across the country. 

We're not price-setters. Farmers are price 

takers, and consequently we need that to get 

behind us as fast as we can. 

I believe that there's a significant 

amount of new interest in organic agriculture, 

and there's a new generation coming on board that 

are extremely interested in my earlier comments 

about the difficulty of getting into agriculture 

I think lend itself today to this new generation 

that are stepping up, saying I want to be 

involved in agriculture, but I view it 

differently. 

I view it from an urban warehouse, 

where I can grow things in the city and I can do 

it in a climate such as Wisconsin and Minnesota, 

where we can maximize our opportunity to grow 

food. We have that happening time and time and 

time again here in the Twin Cities. I'm really 

proud of that. I'm proud of the work that the 

Minnesota department is doing. 

Our efforts to promote organic 

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agriculture range from grants, loans. Our 

organic certification cost share, we've certainly 

helped with that process. One of our jewels in 

the crown, if you will, is our organic 

conference, which we've held for the past 15 

years. 

We have somewhere in the area of six 

to seven hundred people up at that area. You 

were there, I believe, last year and spoke. It's 

a conference that's sponsored by the Minnesota 

Department of Agriculture. Thank you for being 

there and sharing your 30 plus years of wisdom in 

organic agriculture. Learned that from your 

resume and today. 

A couple of years ago, I had an 

opportunity to travel to Cuba, to spend some time 

understanding their organic structure of 

agriculture. It all happened because of what 

they refer to as their special period. That's 

when the Soviet Union crumbled, and all of the 

resources that were flowing to Cuba dried up. 

Literally per capita, they lost 

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weight. They didn't have the food, and so at 

that time they determined that they had to be 

more self-sufficient. So they entered a period 

of rapid expansion of organic agriculture. I had 

the opportunity to spend time with Fernando 

Funes. The farm is called Finca Marta, named 

after his mother. 

He is Ph.D. There is an abundance of 

Ph.D.'s in Havana and certainly Cuba because they 

can go to college for free. He is an excellent 

spokesperson for organic agriculture, and we were 

fortunate to invite me to come to Minnesota and 

speak to our organic agriculture conference in 

St. Cloud a couple of years back. We've had 

breakout sessions at those workshops. 

Fernando took part fully during the 

time that he was here, and I will be going back 

to Havana on the 6th of November this year, and 

we'll be able to have a chance to be out at his 

farm and his spouse, and see some of the growth 

that's taken place on the farm over the past few 

years. I'm excited about that. 

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Let me just say that from a Department 

perspective in the work that we do, Minnesota has 

added more than 15,000 certified organic acres to 

its landscape, actually bringing the total number 

of certified acres to more than 130,000 in the 

state. We rank first nationally in the value of 

organic cow milk sales. We rank second in 

organic corn, soybean production and turkey 

sales. 

We produce about 15 percent of the 

nation's organic oats, with exactly 714 certified 

organic farms, we rank 7th in the United States 

and account for roughly four percent of the 

nation's certified organic farms. Again, keep in 

mind 714. 

We have in Minnesota 73,000 farms. In 

1945, we had 180,000 farms. And so you can see 

what's happened. We didn't create less land or 

more land. We just lost people on the land, and 

you can drive across the state of Minnesota, the 

state of any state and you will see the impact in 

small communities that has occurred in those 

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regions of the state and it's disappointing. 

So our one hope, of course, is to see 

organic agriculture grow, because we will see 

those numbers of farms move up instead of down. 

Organic sales are also strong in Minnesota, as 

consumers continue to value foods grown and 

raised using minimal off-farm inputs in ways that 

restore, maintain and enhance ecological harmony. 

The latest USDA certified organic 

survey published in September puts the value of 

organic sales in Minnesota at more than $106 

million, a 16 percent jump by the way since 2016. 

The work we do would certainly not be successful 

without a tremendously strong partnership that we 

have fostered with Minnesota's organic industry, 

and you're going to hear in just a few seconds 

from my colleague at the University of Minnesota. 

They are such an incredibly strong 

partner as we move forward hand in hand to strive 

to be supportive of the organic sector. We do 

this also through regular meetings with our 

Organic Advisory Task Force, many of whom are 

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here today. I see Jim Riddle in the back, former 

member of the Board. 

This team that guides our work to best 

utilize available resources for outreach and 

technical assistance for Minnesota's organic 

producers is incredibly helpful to us at the 

Department of Agriculture. We continue to use 

them to spread the word and spread the message 

across the state, but more particularly through 

the Minnesota legislature in efforts to move our 

program along. 

With that, your agenda is heavy and 

I'm looking forward to hearing from my partner 

from the University of Minnesota. Thank you very 

much. Again, welcome to Minnesota, where there's 

snow on the roof and water in the basement all on 

the same day. 

(Applause.) 

MR. CHAPMAN: So we also have DR. 

Julie Grossman from the faculty of the Department 

of Horticultural Science at the University of 

Minnesota here today. She is also the organic 

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program coordinator of the College of Food, 

Agriculture and Natural Resource Sciences. Julie 

received her Ph.D. from the University of 

Minnesota in Agronomy and Soil Science, and then 

was an NSF post-doctoral fellow at Cornell 

University. 

She was faculty at North Carolina 

State University in the Department of Soil 

Science prior to arriving at UMN in 2014. 

Julie's research explores management of plant, 

soil and microbe relationships to enhance soil 

fertility and organic systems, especially the 

process of biological nitrogen fixation and 

legume cover crops. 

Julie has a strong interest in 

sustainable agricultural education, is the former 

chair of the Sustainable Agricultural Education 

Association. She has authored over 45 peerreviewed articles, with the majority emphasizing 

soil fertility, management and organic systems. 

Dr. Grossman, I welcome you to share some 

comments here today. 

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(Applause.) 

DR. GROSSMAN: Thanks Tom for that 

nice introduction. How does this sound? Good, 

okay. I want to also thank the USDA, AMS and the 

NOP for inviting me to be here today. This is 

real pleasure. This is my first meeting. I was 

excited to hear that I had 20 minutes. I kind of 

couldn't believe it, and Michelle said oh yeah, 

we want you to give some opening remarks. 

I said oh great, how long? Five 

minutes, six minutes? No, we have 20. So I'm 

going to take full advantage of those 20 minutes. 

For those of you who are coming here from out of 

state, the University of Minnesota you might know 

is one of the few comprehensive land grant 

institutions. So we have all disciplines 

represented at the university. We have about 

50,000 students across the state. So we're a 

very, very big university. 

Within the cities, we have two 

campuses. So we have the St. Paul campus and the 

Minneapolis campus. St. Paul campus houses some 

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of the natural resource departments, some biology 

and all the agriculture. Also you'll hear me 

talk a little bit later about how lucky we are, 

because we're right here in the middle of the 

city. 

We actually have research and 

educational land, certified organic land, about 

six acres, that we can use to teach students. I 

was really excited to hear the Commissioner talk 

about the new generation. That's what I'd like 

to talk about today. If you guys want to talk to 

me about my research, we can do that later. I'm 

not going to touch, talk about that very much. 

But what I really want to do is share 

some personal reflections on how organic 

agriculture and especially academic agriculture 

education has changed in the last 30 years. It's 

really taken some huge strides, and what I want 

to argue is that by the way we're training those 

students, that's going to -- they're going to be 

the ones sitting in this room in 20 years. 

So we need to think beyond just how 

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we're training them to carry out production, 

thinking about all aspects of organic 

agriculture, from policy and decision-making 

skills to critical thinking skills to the 

economics of organics. Somebody, those students 

need to understand everything. So that's really 

what we're trying to do at the University of 

Minnesota, but also at many other land grant 

institutions around the country. 

About 20 to 30 years ago, as many of 

you know, if you have a student that wanted to do 

organic agriculture or sustainable agriculture, 

there were really only a few fringe institutions, 

you might say, that they could go to. I'm sure 

many of you know what those are. Many of them 

were found at small liberal arts colleges. 

I was at a small liberal arts college, 

not one that focused as agriculture. I was at a 

small college called Simmons College in Boston. 

I was a top biology student without about 15 

other biology majors, most of whom wanted to 

become doctors. That was, I wanted to make some 

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change in the world, but that really wasn't on my 

radar screen. I didn't want to be a doctor. 

So at some point in college I made 

this link between social justice, environmental 

science, biology, food access and all of the 

sudden I found myself in agriculture, in the 

middle of Boston, which was a tricky place to be 

when you wanted to study agriculture. 

I remember the day going in and 

talking to my advisor, and saying you know I 

think I figured it out. I think I know what I 

want to do. I want to, I want to study farming. 

My zoologist advisor was like well, there is an 

ag school somewhere in the middle of the state 

maybe you can go, and you can study there. You 

can go to their library, so I --. 

So long story short, I ended up doing 

a senior research project, which interestingly 

was on hairy vetch. Anybody know Drumlin Farm in 

Boston, outside of Boston? So I worked on 

Drumlin Farm, and at the time the manager of the 

farm, whose name I can't remember, says oh we're 

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trying this new crop. It's called a cover crop, 

and we're going to be looking at -- it's hairy 

vetch and it survives the winter. 

I was like ooh, that's great. So we 

went, it was the worse research project ever. He 

said we want you to go and see how well it 

survives. So diligently every month went out to 

this farm and I laid down this quadrant, a square 

and I would count the number of plants that 

existed in January, February, March, and it 

didn't really change, because they were sitting 

there frozen. 

So it was just a total bomb, but the 

nice side of it was that I am still working with 

hairy vetch in my research. So those, even 

though I'd say I probably didn't learn all that 

much about hairy vetch and nitrogen fixation, 

that experience of being on a farm and working 

with a manager had a profound impact on me and 

really got me to where I am today and what I'm 

working on. So those experiences are really, 

really important for students. 

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So around that time, this was about 

the late 90's, sustainable agriculture programs 

were really starting to boom in higher education. 

So youth were getting excited about organic 

agriculture. They were looking for, they were 

seeking programs that focus on that. But then 

when you found a program, they primarily taught 

you how to grow the food, you know. 

You could grow the food, you could 

produce the food, you could have an abundance of 

produce or whatever it was you were choosing to 

grow. But there were a lot of really critical 

skills that were left out of that that, that 

education. So things like marketing, economics, 

policy, those elements I mentioned earlier. 

This meant that future farmers or 

those working with farmers had to learn these 

skills on the job, and they often had somewhat 

dire consequences as you know, because they had 

to decide at some point where they were going to 

have their operation be viable or produce a high 

quality of life for themselves, and how to 

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balance those was really, really tough. 

So we really, we needed to make a 

shift in how we were thinking about that 

interdisciplinary aspect of education. So a lot 

has happened in the last 30 years, especially at 

the land grants. But many of these programs 

started out as very small fringe, or at least 

many started out as fringe universities. 

Now I would say at many land grant 

institutions if not most, it is integrated 

organics and sustainable ag education has been 

integrated throughout the curriculum, with many 

programs focusing exclusively or allowing a 

student to focus exclusively on organics, which 

is really, really exciting. 

Here at the University of Minnesota, 

we are privileged to have the Minnesota Institute 

for Sustainable Agriculture. Lisa, how many know 

MISA? Okay. They've been around for a very, 

very long time and they just actually celebrated 

their 25th anniversary last year. Their goal is 

to bring together the students and faculty and 

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staff at the University of Minnesota with 

producers and community working within 

sustainable agriculture. 

So I wanted to give a shout out to 

them, because they've really been instrumental in 

making Minnesota a hotbed for sustainable 

agriculture. So I, in my -- here in the bio, I 

went to graduate school here and then I went 

away. I was gone about 11 years in North 

Carolina. I taught at -- I was at Cornell and 

then at North NC State, where I was in the Soil 

Science Department, but I always sort of watching 

Minnesota and thinking I'd love to come back at 

some point and be based here. 

Sure enough, about four years ago, 

they created a new major, this was before I 

arrived. It was called a Food Systems major. 

It's interdisciplinary, undergraduate educational 

major that focuses on all those aspects of the 

way I think our students should be trained. So 

the food production, but also the other elements 

as well. 

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So I applied and came back very 

excited to be working with this program. We now 

have about 60 students in the major, so it's 

growing every year. Many of them are in a track 

that's designated exclusively for organic and 

local production. 

So students that are primarily focused 

on production, interested in production but the 

major also asks them to take classes that gets 

them to learn critical thinking skills, systems 

thinking skills, things that traditionally were 

not rooted in such majors. 

I mentioned we also have six acres of 

certified organic land. That's right out the 

back door in St. Paul. How many of you know the 

St. Paul campus? Okay, so you know it. So it's, 

you know, it's not -- it's in the city. It's on 

the edge of St. Paul, but it's -- you can get on 

a bus and in ten minutes you're in downtown 

Minneapolis. 

So it's a really nice opportunity for 

student learning, for students coming from an 

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urban background. Having those six acres outside 

of our classrooms provides an incredible 

opportunity for students to learn about organic 

production. 

So I teach a class that's called 

organic farming, farming and management. It's a 

lot of biology, but we also integrate other 

aspects as I think are important into this --

into the concepts we teach. 

But we use that land to teach students 

about practical skills as well, and in fact we're 

one of the few universities that have that. 

We're very, very lucky, because we can teach in 

the morning and then go in the classroom and then 

go out in the afternoon to the land and use that 

for our lab. It really is our lab. We spend 

time outside on that land. 

The six acres of land, even though it 

may sound small, also provides a lot of 

opportunities to research to take place. So I'd 

like to spend some time today highlighting some 

the diverse research projects that are taking 

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place at the University of Minnesota. As a land 

grant institution, we are obligated to conduct 

research with results that are keenly relevant to 

the stakeholders in the state. 

And so one of the things I've noticed 

and now comparing to other universities is the 

University of Minnesota really does a nice job of 

intentionally bringing together faculty across 

disciplines to carry out some of these projects. 

So for example as a soil scientist, I work very 

closely with economists, to make sure that things 

that we develop in our research or relevant 

economically to growers. So that's a nice 

network that we have at the university. 

The first project I want to highlight 

is one being directed by Dr. Mary Rogers. So 

she's an assistant professor on the Department of 

Horticulture Science at the U. One problem that 

faces organic farmers in our region is the 

appearance of the invasive spotted wing 

drosophila. 

It's an invasive pest to soft skin 

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fruit and berries, and has been responsible for 

significant economic damage around our state. So 

host plants for the spotted wing drosophila 

include strawberries, blueberries, raspberries 

and cherries. And, you know, many of you I'm 

sure think about fruit flies and you think about 

the flies land on rotting fruit. 

The problem of course with spotted 

wing drosophila is that it doesn't lay its eggs 

on rotting fruit. It lays its eggs on fresh 

fruit. So what happens? You end up harvesting 

your fresh fruit, you take a bite of your fresh 

fruit and you get a nice big worm and you're 

frustrated. Anybody, how many of you have heard 

of spotted wing drosophila? So many. So it's 

becoming a big problem in our area. 

Minnesota growers were losing 

approximately $2.2 million due to spotted wing 

drosophila-related damage. So this really made 

this problem one of thoughtful solutions. So 

Mary has been working on this for about four 

years, and their work is showing that the best 

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management practices to control spotted wing 

drosophila in organic systems are things like 

exclusion using tunnels. So plastic tunnels are 

a season extension. 

In-season sanitation, frequent 

harvesting of the berries and cultivar selection 

to avoid those peak spotted wing drosophila 

population times. The results or recommendations 

are being made widely available around the state. 

We have seminars. I think she said -- and 

workshops and webinars. I think she said she 

gave approximately 20 talks just last year alone 

to stakeholders who were interested in this 

issue. So we're doing some really great work. 

The second example is actually in our 

group, taking place on the down low in the soils. 

So we're a bunch of soil biology geeks and our 

lab is really excited about trying to come up 

with ways, management approaches that farmers can 

use that improve soil fertility, primarily 

through cover crops, so specifically legume cover 

crops. 

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So we worked and looked at biological 

nitrogen fixation and rhizobia interactions with 

those crops. Here in Minnesota we have a ton of 

high tunnels. As you might imagine we're cold, 

and high tunnels have allowed us to extend our 

season in a pretty big way. So a lot of farmers 

are putting them up and elsewhere in the country 

we're finding that farmers who have high tunnels 

in warmer --

We can't grow things in our high 

tunnels in the winter by and large. But 

elsewhere in the country, farmers are really 

pushing those tunnels to the max. So they are 

growing crop after crop after crop and after 

about 15 years of having cost share dollars 

building high tunnels, we've seen that the soils 

are struggling. They're being impacted by 

salinity, compaction. There are nutrient issues. 

So we for the last four years have 

been thinking about ways to sneak cover crops 

into these high tunnels. In Minnesota, it was 

pretty easy, because we found that they were 

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empty in the winter. They weren't in use for 

crops. 

So when I got here four years ago, I 

said well, let's put cover crops in. I want to 

put cover crops everywhere. That's kind of my 

goal. So let's get legumes into these tunnels, 

and we've been able to do that pretty 

successfully, and the really nice thing about it 

is that we've been able to do it using crops that 

typically don't survive outside the tunnel in the 

winter. 

So it's too cold to get some species 

to survive outside the tunnel, but the tunnel's 

just a little bit warmer. So we can use that 

time in the winter to really improve soils. So 

we've found that by growing legumes over the 

winter, we've been able to increase the amount of 

nitrogen that farmers can basically produce on 

their farm through nitrogen fixation. 

So that improves the farmer's bottom 

line by reducing off-farm fertilizer inputs, and 

of course increases soil health through organic 

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matters. So we're still working on that. We 

actually have multi-state OREI grant right now. 

We're working on a north to south gradient, 

looking at high tunnels from here down to 

Kentucky, where we have collaborators along the 

way, and we have replicated identical experiments 

in all states to try to understand how these 

different cover cropping systems might differ 

based on where you are on that north-south 

gradient. So it's been a really, really fun and 

exciting project. 

I also want to highlight a Minnesota 

research example from economics. This is a 

project that is helping farmers to better 

understand price premiums of their organic farm, 

organic crops and what they can bring in the 

marketplace. So this is being conducted by a 

faculty member who's in Applied Economics, and 

that's Metin Cakir. He's in the Department of 

Applied Economics at the U. 

You know, the people who are at the 

University of Minnesota, we call it the U. So 

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like that's our U. I know there are other U's, 

but sometimes I forget that. I say "the U." 

They said what's she, you know. So despite the 

large and growing importance of organic fruits, 

there's surprisingly little consensus on the 

retail premiums that they can bring in the 

marketplace. 

So in particular, the state of 

academic research on organic foods is hindered by 

this lack of comprehensive micro level data on 

organic marketing. So he's tackling that headon, and what he's doing is using a point of sale 

scanner around the state to compare organically 

and conventionally grown fresh fruits and 

vegetables, to determine how changes in organic 

price premiums might vary by over time, and how 

they vary across locations as well. 

So this project. It's -- we're just 

in the middle of it right now. But the project 

he's hoping will help farmers that are 

transitioning to organic production, as well as 

researchers who are working with organic food and 

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agriculture markets. It will help him by helping 

them better understand how price premiums are 

determined across the organic marketplace. 

Finally, although many people when 

they think about the University of Minnesota, 

they think about the campus we have here in the 

Twin Cities, and we do have many other campuses 

that are around the state. One of them in 

particular, many of them work in organics, but 

one of them in particular is a real hotbed of 

organic dairy research. 

Again, the University of Minnesota is 

well known for our 150 head of certified organic 

dairy, and 650 acres of certified organic land 

that is located in Morris, Minnesota. So that's 

about three hours away from here, and it's been 

around since about 2010. So it's been quite a 

while now. 

This program is known nationally as 

the University of Minnesota Organic Dairy 

Program, and it's directed by associate professor 

of Animal Science Brad Heins. Brad is great. He 

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also sites on the task force, the organic task 

force that brings together FDA with the 

University of Minnesota and stakeholders around 

Minnesota. 

Brad is trying to solve the most 

challenging aspects of organic dairy production, 

to help farmers weather the storm, the economic 

storm that they've face in recent years. In 

particular, although Dr. Heins' program is really 

widespread in its focus, he's very interested in 

grazing research, building a more robust cow, and 

his group also focuses on improving the 

nutritional quality of milk and meat across his 

many, many funded projects. 

Harriet might know Brad's name, 

because I think his students have now the MOSES 

poster competition award, you know first or 

second place for the last like five years. I 

mean he's just a -- he's a real excellent mentor 

for these students that are interested in organic 

dairy. 

So in closing, I wanted to highlight 

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Minnesota as an example of a university that is 

trying to prepare both graduate and undergraduate 

students with these skills that I feel are 

really, really important to bring about positive 

change in the world in coming years in organic 

and sustainable agriculture. 

There again, they're the ones that are 

going to be making these changes. They're going 

to be teaching our future students, they're going 

to be farming. But many of them are not going to 

be -- not all of them are going to be farmers. 

So some will, but most of them will be working 

with farmers. So it is really, really critical 

that the people that are making the decisions are 

knowledgeable. 

So I want to encourage us to continue 

to support programs that are trying to move 

beyond organic production, and get these students 

to think about their decision-making skills, hone 

their critical thinking skills. We need leaders 

who understand connections between food access 

and food skills, between social science and soil 

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science. 

Sometimes you might say I talk fast, 

you know, I introduce myself. And I say oh, I'm 

a soil scientist. You're a social scientist? 

No, soil scientist. So sometimes those 

differences get mired in the details, but they're 

really important to connect. And there are many 

multiple other disciplines that are really going 

to make our organic systems strong and healthy 

for tomorrow. 

So I really would like to help us 

think about that today while we're sitting here 

about how you go here. How did you all end up 

sitting at this table today? Where did your 

background come from, and what was your 

background that brought you here, and how can you 

share that with students? 

I'm really excited to be here. This 

is my first meeting, so I'm really excited to see 

how this works, and I look forward to meeting 

many of you. Thank you very much. 

(Applause.) 

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MR. CHAPMAN: Thank you. Thank you so 

much, both to Commissioner Frederickson and Dr. 

Grossman for your comments here today. I really 

appreciate it. A really great way to start off 

this meeting here in St. Paul, so thank you 

again. Right now we'll move on to my report as 

chair, and then proceed to the NOP's report as 

well. 

MR. CHAPMAN: This is my fourth report 

as chair, so I will keep it brief, as I'm sure 

you're all tired of hearing me mumble through 

this by now. My last few meetings, I've asked 

for patience as we've waited for the 

administration's leadership to be seated, and I'm 

happy to say that now we have a full USDA 

leadership team in place. 

At the last meeting, we heard from 

Undersecretary Ibach, and since then we have had 

both an AMS administrator and an NOP deputy 

administrator appointed. While no surprise to 

most people in this audience, I'd like to 

recognize Dr. Jenny Tucker, who was recently 

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selected as the deputy administrator of the NOP. 

I could spend probably too much time 

right now praising the selection of Dr. Tucker to 

head up the NOP. But I'd be remiss if I didn't 

sing just a few of her laurels. Hired under 

Miles-McEvoy in 2011 as associate deputy 

administrator, you'd probably be surprised that 

most of Miles' successes were probably done by 

Dr. Tucker's work behind the scenes. 

Dr. Tucker has a B.A. in Environmental 

Science from Wesleyan University, an M.S. in 

Management from Purdue University, and a Ph.D. in 

Science and Technology Studies from Virginia 

Tech. Over-achiever. 

(Laughter.) 

MR. CHAPMAN: So she knows -- so she's 

an environmentalist, knows people in management 

and technology as well to boot. I couldn't 

really think of anyone more prepared to lead the 

NOP during this current time. 

I know from talking with NOP staff, as 

well as members of the organic community that Dr. 

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Tucker commands a tremendous respect and trust, 

and I personally look forward to her honest, 

humble, straightforward leadership. Can I get a 

round of applause for Jenny? 

(Applause.) 

MR. CHAPMAN: Lastly, as we get 

started here today, I'd like to thank the Board, 

who has again volunteered and spent numerous 

hours discussing, reading, debating, and 

listening to comment in preparation for this 

meeting. That time is extremely valuable, and I 

appreciate everyone's dedication. 

With that, we will move on to the 

Secretary's report. Scott. 

MR. RICE: Thanks Tom. 

(Off microphone comments.) 

MR. RICE: Okay, I'll try this. 

MR. CHAPMAN: I think it's feedback 

from the beard. 

(Laughter.) 

MR. RICE: I'm a beard man. Mr. 

Chairman, the summary notes of the April 2018 bio 

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and meeting in Tucson have been distributed to 

Board members. Are there any corrections or 

comments? 

(No response.) 

MR. CHAPMAN: Seeing none -- seeing 

none, thank you Scott. We will accept the 

Secretary's report without objection by 

consensus, and seeing no objections, the report 

is accepted. Up next, I will hand the meeting 

over to Dr. Tucker for the NOP report. 

DR. TUCKER: Okay, good morning 

everybody. 

VOICES: Good morning. 

DR. TUCKER: Okay. I'm going to do a 

quick test here. Ooh, it works. Yes, okay. 

Okay. Welcome to St. Paul, Minnesota. It is so 

great to be here and to see all of you out here. 

I always start presentations by celebrating our 

certified organic farms and businesses in 

whatever city or state we are in. 

So there are 966 certified operations 

in Minnesota. Raise your hand if you are one of 

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them. 

(Show of hands.) 

DR. TUCKER: All right. We've got a 

number of folks out there. So thank you so much 

for being here. 

(Applause.) 

DR. TUCKER: And you can of course 

learn more about all of these operations in the 

Organic Integrity Database. So I'd like to 

actually show you a different view of the 

certified operations here in Minnesota by 

specifically focusing on a particular county that 

we're in right now, which is Ramsey County. 

So this is a different view of data 

from the Organic Integrity Database. It is an 

internal mapping system that allows us to see 

operations at the county level. So we can hone 

in on specific cities and on specific counties. 

We've invested in these data visualization tools 

for a lot of reasons. 

First, it helps us with audit 

planning. So when we do witness audits or review 

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audits, it's good to know where different 

operations are so we can plan audits efficiently 

and effectively. It also helps us with countylevel and state-level reporting of acreage. 

There's a lot of conversations about 

data, data quality and acreage reporting, and so 

having county level views and the ability to list 

data within county is going to be very helpful as 

we continue to make our reporting more robust. 

It's also helpful to view operations at a county 

level when we are approached by state officials 

who have questions related to emergency pest 

management programs. 

So being able to see if there are 

actually any operations in a county that might be 

impacted by a state program just gives us a lot 

more data to be able to make decisions with. So 

the map helps us assess possible impacts of state 

treatment programs. 

As certifiers report more acreage 

data, and we strongly encourage them to do so, 

and as they adopt our product taxonomy and the 

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Organic Integrity Database with more accurate 

reporting against product categories and item 

lists, we will be able to provide more data 

output, tables and graphics to provide the 

community with the data that you need for good 

research and decision-making. 

So data quality continues to be a 

need. When we launched the mapping of function, 

we learned that there was about a 75 percent 

match with census and postal service data. 

So there's still a lot of work to do 

on data quality, and so we're going to continue 

to reach out to our certifiers to up the data 

game. So if your information about your 

operation is not correct in the Organic Integrity 

Database, we strongly encourage you to contact 

your certifier, let your certifier know that 

that's important to you and why. 

So I like to also start presentations 

with reviewing USDA's principles for organic. So 

these were published in the 2018 Farm Bill, a 

legislative principles document. The goals are 

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protect the integrity of the USDA organic 

certified seal, and to deliver efficient and 

effective oversight of organic production 

practices to ensure organic products meet 

consistent standards. 

Let's take a look at our four key 

priorities for fiscal year 2019. So the 

government fiscal year starts at the beginning of 

October. So we are near the very beginning of 

our fiscal year, and so I'd like to walk through 

the four priorities, and then I'm going to show 

you what we've done in these different areas over 

the course of the last few months. 

The first three areas here are strong 

organic control systems, farm to market 

traceability, and robust enforcement were all 

part of the enforcement action plan that we 

published in May. So we're continuing these 

priorities into 2019. The outcomes of those will 

be trusted people, process, and rules, worldwide 

supply chain integrity and a level playing field 

for all. 

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Our fourth goal for FY '19 is to 

continue to support the standards and collaborate 

with the community, and the outcome of that will 

be ongoing engagement and transparency. So I'm 

going to walk through each of these four areas, 

highlighting some of the work that we've done 

over the past several months. 

So in the area of strong organic 

control systems, which lead to trusted people, 

processes, and rules, we have released new policy 

memos and letters related to fumigation and 

prohibited commodities. We've really upped our 

outreach on fumigation, so that the trade has a 

better sense of how to consider products crossing 

the border, and doing research to make sure that 

products that have been fumigated are not 

represented as organic. 

As part of this, we're collaborating 

with APHIS, a partner agency, for better data. 

Now last time I presented to the Board, I 

presented that there was a very, very high number 

of fumigation incidences. In the meantime, we've 

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worked very closely with APHIS to better 

understand the data, and that's led to much 

better data quality related to fumigation. 

So it actually turns out that the hits 

are actually much, much lower than we had 

thought, which is very, very positive and very 

good. It also allows us to do much more specific 

follow-up and investigations on any particular 

hits that we get. So that's been a piece of 

positive news of the last several months. 

We have been developing new models for 

risk-based oversight using diverse data sources. 

There are a lot of international agencies that do 

very good work on the risk of fraud. We're also 

using data from the Organic Integrity Database to 

help us identify points of risk in different 

parts of the world. We are continuing to conduct 

auditor -- audits of certifiers, both satellite 

offices and headquarters worldwide. 

Those audits have resulted in some 

enforcement action. We recently negotiated a 

consent order that led to the suspension of one 

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of our international certifiers. So those audits 

are a very important part of our enforcement 

mission. And we are advancing the enforcement 

role and learning management systems. I'm going 

to talk a little bit about those in particular. 

So here is the list of items that are 

being considered for the strengthening of organic 

enforcement rule-making, and I have been 

encouraged not to read the list to you. 

(Laughter.) 

DR. TUCKER: So I'm not reading the 

list. But it's there for you to read. So here's 

-- it's a snapshot of a number of different areas 

being considered. Many of these were covered in 

a webinar we did in July, and many of these come 

from NOSB recommendations. 

So sometimes it can take time to 

respond to recommendations, but we believe that 

this rule will cover a lot of areas that the 

Board has worked on, and has provided us feedback 

about. If you have feedback in these areas, we 

are accepting a communication at our guidance 

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box. 

That's nop.guidance@ams.usda.gov. We 

have received some best practice documents from 

different organizations --- a lot of folks who 

spend a lot of time thinking about these topics. 

So that input is very helpful. 

Let me talk a little bit about the 

virtual town hall that we had in July. This is 

just a snapshot of the different topic areas in 

order of the number of chats. And so not 

validated research by any stretch, but it does 

give a sense of how many -- how much energy there 

was around different topics. 

So there were about 400 folks who 

attended the webinar, and somebody did the math, 

I love this. There were approximately 14 chats 

were minute, and the top three topics were 

excluded operations, import certificate 

traceability, and standardization of inspector 

qualifications. The Board's being doing a lot of 

work on inspector qualifications recently, and 

has also advanced recommendations on exclusions. 

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So very helpful work. We are 

anticipating a proposed rule in the spring of 

2019 that will be announced in the Organic 

Insider. The process from there will be there 

will be there will be a formal public comment 

period like there are with all rules, and then 

the comments from the proposed rule will be 

considered in a final rule. 

So next, I'd like to show you sort of 

an initial front page of the Organic Integrity 

Learning Center. So this is -- I've been calling 

it the Learning Management System, LMS for short. 

We've officially named it the Organic Integrity 

Learning Center. 

So this center is going to be designed 

for certifiers and for inspectors, to really up 

the game on continuing education and training, to 

make sure that inspectors and certifiers have the 

right skill at the right time for the right 

operation. 

And so the center will provide online 

training to support professional development and 

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continuing education. We're really focusing on 

certifiers, inspectors, and reviewers to start, 

as well as professionals that are serving in 

compliance and enforcement roles. So there are 

times where certifiers need to conduct 

investigations, and so we're going to include 

training to improve their ability to do that, and 

to really help the folks who are really boots on 

the ground every single day out there on organic 

farms. 

This project directly supports our 

goals of fair and consistent certification and 

effective, fair enforcement. So if you would 

like to learn more about this other program and 

provide your feedback, we are going to have a 

virtual town hall on November 15th, where we're 

going to give sort of a test drive through the 

Learning Management System. 

You'll be able to ask questions and 

provide your feedback about course topics. So 

again, that will be November 15th from 1:00 to 

2:00 Eastern. We're going to post more details 

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later today in the Organic Insider. So I hope 

you'll be able to join us. 

Let's move on to the second area, farm 

to market traceability. So our first big success 

in this area is that we published a report, it's 

on the website on collaboration opportunities and 

technology needs related to supply chain 

integrity and import integrity. 

This was our formal response to the 

2017 OIG report. I committed at the last NOSB 

meeting that we would complete all of our AMS 

response items to the Office of Inspector 

General, and we did so, and this report was a big 

part of that. 

That has led to lot of follow-up 

conversations with the OIG, with CBP, Customs and 

Border Protection, and APHIS as we advance those 

specific projects. We have worked closely with 

Customs and Border Protection to scope our 

organic message set projects. 

If you remember from our last meeting, 

the organic message set is what makes the organic 

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import certificate an electronic part of CBP's 

import system. We've also initiated visioning 

for a global organic oversight and traceability 

system. So I'm going to talk a little bit about 

that. 

So part of our report this summer 

included a technology needs assessment. And so 

here's a look at our technology goals for the 

months ahead. We are interested in facilitating 

full supply chain traceability, allowing 

government entities to access, approve, and 

verify the validity of certificates and 

transactions. 

Implementing electronically based and 

secure oversight control systems. We need to 

have trusted users and secure data exchange. So 

that's an overview of our leading goals related 

to technology. And so technology is an area that 

I tend to think about and focus a lot on, and so 

I want to show you a couple of pictures that 

simply have started a conversation on what an 

international potential system could look like. 

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So block chain is a technology that's 

come up in the last couple of NOSB meetings. May 

or may not be a final technology for where we're 

headed here, but it is a framework for 

consideration. And so here's just one vision of 

how a technology solution could play out. You 

can have farms or initial consolidation points 

provide both data and product into the organic 

system. 

The data and products would then be 

exchanged and traced across handlers and brokers. 

Organic certifiers would be able to confirm 

transaction authenticity with oversight from the 

National Organic Program, and then an import 

certificate would transmit the data into CBP's 

system and then into the United States. 

So this is one vision. This was a 

vision that we first drafted out on a chart paper 

in spring 2018. So sort of our fix -- a first 

picture of folks who worked with me on the 

Organic Integrity Database know that that system 

was basically built out of a flip chart in my 

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office. So that one piece of paper visioning, I 

tend to enjoy doing that work. 

So as we continue to extend our 

thinking on this, we have another picture. And 

so this may in fact be a more accurate picture of 

what this ultimately could look like. So a 

second version of the vision would be really more 

about connected data strings, where a lot of 

different people or a lot of organizations have 

their own systems, and those systems are able to 

exchange data in a unified way. 

And so in this model, we might have 

organic oversight block chain or other system 

that would be fed by and would feed other chains 

and other systems. So here you could have a 

supply chain block chain. We have some supply 

chain leaders out there who are considering 

building their own block chains. You might have 

a government that builds a system. 

So for example Italy has invested in 

a country-wide system, and so data could be 

exported from these different systems onto a 

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stream of data that is then transmitted across 

the oversight system. Again, one of those nodes 

may be Customs and Border Protection as that data 

becomes import ready for our import systems with 

CBP. 

So lots of different ways of looking 

at this problem. We are just starting this 

conversation, and so I am now approached 

periodically by folks who are considering 

building block chains or exploring that idea for 

their own supply chain or their own sort of part 

of the organic universe. So I welcome those 

conversations so we really have a sense of all 

the diversity that's going on out there. 

Third area, robust enforcement, which 

will create a level playing field for all. So 

first, I want to highlight our Dairy Compliance 

Project. Now last time we were with you, we 

started talking about this project. We had 

called it a pasture surveillance project. Based 

on everything we've learned to date, we have 

reoriented. It is now a Dairy Compliance 

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Project. 

There are problems out there, and we 

are investigating and we are enforcing. We are 

doing unannounced inspections as part of 

investigations. We are also doing unannounced 

inspections as part of surveillance activities. 

This is one of our top priorities in the program, 

and so based on everything we've learned to date, 

we are going to continue that project also into 

2019. 

So this is going to be an ongoing 

series of investigations and compliance oversight 

effort. We have also overhauled our complaint 

intake process. We had started this process at 

the last NOSB meeting. We have continued it, so 

that we are able to classify complaints coming in 

more rapidly, and to respond to questions that 

really aren't complaints but are really 

questions. 

Where we get a complaint in that 

doesn't really have the evidence that would be 

needed to support an investigation, we provide 

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immediate feedback, so folks have a better sense 

of what is needed. I'm going to talk more about 

complaints in a bit here. 

We've also awarded a contract to 

expand our investigative capacity by 

approximately five people. It is still the case 

that more than half of the complaints that we get 

in are actually uncertified operations. So 

having some supplemental capacity to investigate 

complaints against uncertified operations will 

allow us to take action faster in those 

particular scenarios. 

We continue to work with APHIS and CBP 

to block non-compliant imports. We are building 

a new complaint management system which is more 

consistent with what other federal agencies have 

with an enforcement mission, and we are 

supporting investigations by our federal 

partners. 

So examples of federal partners are 

Office of Inspector General and Department of 

Justice. So that takes me to some comments. 

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We've gotten some questions about recent news 

reports related to domestic organic fraud. And 

so we can't comment on the details of open 

investigations or pending litigation. 

What we can say is that over the past 

year, we have done a comprehensive review of our 

pending case load, and we are confident that any 

open case with verified violations is actively 

being worked on by an NOP specialist, or has been 

referred to another partner such as other federal 

agencies or other governments for investigation. 

Some of these cases involve complex 

supply chains and players, and many players may 

become involved, both in the problem itself but 

also in the investigation. So building strong 

cases with deep evidence and providing due 

process to all the parties is a vital part of any 

investigative process. This takes time. 

I am fully confident in our compliance 

and enforcement team. We've added staff 

resources, improved intake, added new technology 

tools to assist investigations, and have built 

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strong bridges with other members of the federal 

enforcement family. 

We all know that a few bad actors can 

undermine the work and livelihood of thousands of 

good organic farmers who rely on consumer 

confidence in the organic seal. 

We are advancing strong cases quickly, 

and referring cases to other investigative teams 

where appropriate. It is important to remember 

that fraudulent organic food sales are the 

exception, not the rule. Working together with 

farmers, ranchers, certifiers, and other 

stakeholders like all of you here, we will all 

together ensure the organic seal remains the gold 

standard. 

Now I would like to turn to imports, 

and so I think one of the good ways of showing 

what we've done in this area is to review a case 

study. So we're going to review a case study of 

corn imported from Serbia. So in August, there 

was a blog post that highlighted some trade data 

that showed organic corn was being imported from 

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Serbia. 

This was the first time that a blogger 

had seen Serbia as a producer of organic corn, 

and there was no Organic Integrity Database 

listing for a Serbian corn producer. So as a 

result, many people started speculating that the 

imports might be fraudulent, and we heard from 

several stakeholders about this. 

Within two weeks, the NOP took quick 

action to obtain and analyze data, and we 

confirmed organic integrity. Here's how we did 

it. First, we used the ACE database, that CBP 

sourced for all trade and import data, to get 

information on the supply chain. Then we 

contacted the North American importer for further 

information. The importer immediately provided 

an organic certificate for the Serbian source. 

Second, we contacted the certifier who 

is listed on the certificate. This allowed us to 

verify the certificate and get more information 

about the operation's acreage and production 

capacity. The certifier quickly cooperated and 

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confirmed that the Serbian producer had enough 

land to produce the amount of corn that they 

exported. 

Finally, we examined available market 

analyses from the USDA's Foreign Agriculture 

Service. We found that the Serbian government 

has been investing in organic transition, 

providing a fast-growing supply of organic 

products. We also learned that they had a bumper 

corn crop in 2017 thanks to good weather 

conditions. 

We are keeping in touch with our local 

FAS contacts to monitor the situation moving 

forward. The NOP has developed this sort of 

rapid response model when we receive questions 

about imports. 

When we have access to data, we're 

able to act quickly to resolve doubts or to 

identify new areas for surveillance. The trade 

data showed that Serbian organic imports before 

there was a listing in Integrity for a Serbian 

corn grower. This understandably raised 

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concerns. 

Our priority is ensuring organic 

integrity worldwide. There are both good and bad 

actors around the world. So we're developing the 

risk-based systems that will detect the 

differences. Two key take-homers here. First, 

another example of why accurate and timely data 

in the Organic Integrity Database is so critical. 

A lot of certifiers are reporting data 

more frequently and we really need the trade's 

help to emphasize the importance of up-to-date 

data across your supply chain with your 

certifiers. We need better data to ensure a 

level playing field to protect our borders and 

facilitate fair trade. 

Second, in this case the certifier was 

able to substantiate that the farm could produce 

the yield seen in the export. Not all certifiers 

are generating verifiable yield data. We did a 

recent webinar with certifiers to review ways to 

do this. This is part of our ongoing work, to 

ensure fair and consistent certification around 

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the world. 

So let's take a look at our import 

investigation strategy from here. We are 

pursuing cases with sufficient evidence, 

continuing to work specific cases with CBP and 

APHIS. We're focusing on oversight in the Black 

Sea region on certifiers, and then also on 

surrendered operations who are now seeking recertification. 

So we're really keeping an eye on 

those cases, and particularly in reconfirming 

that yields reported are possible. We are 

increasing our emphasis in other geographic areas 

based on complaints and our risk-based model, and 

we're going to continue to increase certifier 

training on how to calculate yield estimates and 

on the non-compliance process evidence and 

appeals. 

I've showed this slide in the past few 

meetings, and I'm going to continue to show it, 

because it is core to all enforcement. The 

Organic Foods Production Act, regulations and 

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legally defensible evidence. Enforcement depends 

on all three. So I get asked a fair amount well, 

what does legally defensible evidence look like? 

So let's take a look at that. 

So here are examples of evidence that 

are often gathered by NOP and by certifiers. So 

we're not expecting complainants to have all of 

this information when you submit a complaint. 

I'm going to get to those elements in just a 

second. But here are some of the types of 

evidence that we look for when we're conducting 

investigations, and that certifiers need to be 

looking for when they conduct theirs. 

This is not an exhaustive list, nor is 

it in any kind of specific order. But it does 

give a sense of the kind of documentation and 

evidence that best supports the investigations as 

they unfold. Now I'm going to turn to how you 

can help and talk more about complaint submittals 

and what can constitute an effective complaint. 

So we're going to focus on who, what, 

when and where. So who, we need brand name, 

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operation name, manufacturer, U.S. importer, and 

certifier. Any combination of those that you 

have, as well as any information you have about 

the supply chain. 

The what includes product packaging 

and the label, product lot numbers, photographs, 

invoices, bills of lading, certificates. You 

need to check the scope for alignment with the 

complaint. So for example, we had an email, it's 

a great sort of case study, an email that 

included a handling certificate and the email 

said well, I'm not sure that the crop was 

actually grown on certified land. 

So there was concern about the 

validity of the crop, that the crop was certified 

as organic. Well, it was a handling certificate, 

and so to really verify the crop, we need a crop 

certificate. So take a look at your certificates 

when you're looking at a complaint, to make sure 

the certificate actually aligns with the scope 

that you are looking at and concerned about. 

It also is very helpful to have a 

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specific regulatory violation. What part of the 

rule do you believe is being violated, and how 

does your evidence show that it is being 

violated? Finally, when and where. So provide 

the details of when you observe the alleged 

violation, date and times, the location it 

occurred. 

So for example websites or specific 

store, and if it is in the case of an import a 

specific ship or port if known. That's how we 

were able to work with the Serbian bit. We had 

country information about a specific time and 

place. 

So complaints are an important tool 

for maintaining organic integrity, and the U.S. 

government has a unique ability to enforce. 

Buyers, in turn, have a unique ability to see 

what's happening on the ground. We encourage all 

organic buyers to do research on their supply 

chains. If you're concerned about the integrity 

of the product you're getting from a handler or 

broker, ask for the certificate for the original 

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product. 

If they're unwilling to provide supply 

chain information, that's important data for you 

to consider. Traceability is core to organic 

integrity. Be sure before you buy. Preventing 

fraud takes all of us. 

Moving to the fourth area, supporting 

the standards, collaborating with the community. 

This will lead to transparency and engagement. 

I'm going to touch on some very special topics 

here, first starting with National List rulemaking. 

We have new National List rules. They 

are in clearance. Our goal is to move ahead 

quickly with rule-making once we have NOSB 

recommendations. We expect a final rule 

addressing multiple substances shortly, and other 

rules should quickly follow. We'll also continue 

to support technical reports for the National 

Organic Standards Board. 

In FY 2018, we invested $250,000 on 

technical reports. These investments are not 

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impacted by the expiration of the Farm Bill. 

I've been asked that question, so I wanted to 

share that. We also invest a lot of time on 

material inquiries and conflicts. 

There are times when certifiers make 

decisions on materials, and those decisions 

conflict. In those cases, we analyze the 

disagreement and determine next steps. So 

consistency and material determinations is a 

critical element of fair and consistent 

certification, and it supports organic farmer 

needs. 

So I'd like to cover a very specific 

topic that's generated a lot of interest for this 

particular meeting, and that is paper pots. So 

paper pots is an example where there was a 

material conflict. Some certifiers approved it, 

and others did not. Those that approved the 

paper pots likened them to regular pots used in 

production, or saw the paper pots as similar to 

the current listing for newspaper and recycled 

paper. They saw it as being agroenvironmentally 

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sound, and approved them. 

Other certifiers did not allow them. 

They are an input into the soil, they are not 

made of newspaper or recycled paper, and they 

have an adhesive that is believed to be 

synthetic. The product, and as far as we know 

the adhesive, is not on the National List. 

This conflict was raised to the NOP, 

and we agreed with the certifiers that did not 

allow the paper pots. Paper pots are 

fundamentally different from any paper allowances 

on the National List. They are not made of 

recycled -- not made of newspaper or recycled 

paper. 

They're not used as mulches or compost 

feed stocks, which are the only allowances of 

paper in crop production. Because this came out 

of a certifier conflict, in February 2018 NOP 

notified certifiers that producers using them 

could continue to do so for the remainder of the 

2018 growing season. Then, that use needed to 

stop. 

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We provided this grace period because 

of the certifier conflict. Paper pots have since 

been petitioned to be listed on the National List 

as an allowed synthetic production aid for crops. 

The Board's considering that listing now, with a 

discussion document at this meeting. 

If the Board recommends paper pots, 

the USDA will consider that recommendation. If 

USDA agrees with the Board's recommendation that 

will involve rule-making, including providing the 

public with an opportunity to comment. We have 

been asked to extend the allowance of paper pots 

while the Board does its work. 

We've put a lot of thought into this, 

and we've decided not to allow that. First, we 

must be fair to the many farmers who have been 

told that paper pots cannot be used. Second, 

allowing continued use of a material because 

certifiers were wrong in allowing its use in the 

first place sets a bad precedent. 

Synthetic materials are not allowed in 

crop production unless they're on the National 

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List. Paper pots are currently not on the list. 

We look forward to hearing the Board's 

deliberation on this topic. 

Finally, at the last NOSB meeting 

there was interest in increasing our outreach to 

the American Indian tribal community. Last 

month, the Organic Program participated in an AMS 

consultation with a group of tribe 

representatives. During the session, we shared 

our strategy to strengthen organic integrity. 

We provided background on the National 

Organic Standards Board and opportunities for the 

Native American and Alaska Native community to 

engage with the NOSB and NOP. So many thanks to 

Paul Lewis for advancing that consultation. 

Thank you. 

Okay. I am going to switch gears now 

into our peer review, which we have been 

reporting on annually at the NOSB meeting. 

Quality management is an important part of what 

we do to ensure the integrity of our 

accreditation system. So last fall I reported on 

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our 2017 peer review, and I am now ready to 

report on our 2018 peer review. 

We worked with ANSI again this year. 

We changed our approach. So we took a bit of a 

different tack this year. The reviews have over 

time gotten very, very detailed, with a lot of 

focus on records and very specific aspects of 

checklists. This round, we asked ANSI to take a 

more systems-level view of our program, and to 

focus on the areas where the challenges are most 

clear, such as imports and dairy oversight. 

We also asked them to view our system 

through a risk-based lens, which is also a key 

emphasis of the newest version of 17011 -- that's 

the ISO standard. And so there are two slides 

here that have opportunities for improvement and 

recommendations. 

Again, it's a very different list than 

what we had last year. A lot of the observations 

last year again were focused very specifically on 

documents and checklists, where this time again 

we asked for a very systemic view, which is 

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really helpful in charting and has really 

informed our goals for FY '19. 

So one of our big problems right now 

is we don't actually have a dedicated quality 

manager. That position has been vacant for a 

bit. We have gotten permission to hire one. So 

I have approval authority to hire a quality 

manager, and we really need that to maintain our 

systems effectively. We will be developing a 

document that summarizes our relationships with 

other organizations. 

While there are many mechanisms that 

we have to avoid conflicts of interest, they're 

not all written down in one place, which is 

something that the ISO standard recommends. So 

that was -- is an opportunity for improvement. 

We do not have sufficient auditors and we don't 

have sufficient personnel to handle complaints 

and enforcement actions. 

Now we did receive new funding in the 

middle of the fiscal year, when Congress passed 

their '18 budget. Many thanks to all of those 

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who helped advocate for that increased funding. 

That is helping with our ability to hire and do 

staff augmentation to meet our mission. 

Internationally, we've learned that 

the procedures for residue testing aren't real 

well clearly understood by international 

certifiers and satellite offices, and we aren't 

auditing satellite offices as much as we would 

like to. So these are observations confirmed by 

ANSI. So having external organizations help you 

see these things that, you know, having them on 

paper is very helpful in planning. 

ANSI also recommended that we 

establish stronger quantitative objectives and 

performance indicators to effectively monitor our 

goals. We do, this is repeated from last year, 

we do have challenges with our own internal 

document controls. This is a side effect of not 

having a quality manager in place, so I think 

that will be a situation that's remedied by that 

hire. 

Some comments on our certificate and 

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our terms of accreditation. The need for 

additional training was emphasized. We've been 

emphasizing certifier and inspector training, but 

we also need to continue to train our own staff 

in the area of risk assessment and investigative 

methods. 

And so finally ANSI confirmed what I 

think we know, that certifier audit trail 

exercises are not always providing adequate 

detail to verify and fully document full supply 

chains. 

So here are the initial actions that 

we're taking. A lot of our '19 goals were 

designed to address these concerns. We have been 

approved to hire a quality manager. We've been 

approved to hire additional auditors. We are 

launching the Learning Management System. It 

will include import oversight topics as well as 

residue sampling testing, analysis topics, and 

other issues. 

We are developing risk-based oversight 

models and continuing to refine audit planning 

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based on the available resources that we have. 

I am going to close by summarizing our 

FY '19 goals across all four of these areas. So 

FY '19 goals related to strong organic control 

systems. We're going to publish the proposed 

rule that we discussed. We have already launched 

a pilot version of our Learning Management 

System. We now need to get training into it for 

organic certifiers and inspectors. 

We are expecting that to be fielded by 

January 2018 (sic) in advanced of our certifier 

training in February. We're going to continue to 

conduct face-to-face training sessions with 

certifiers. We're developing a risk-based 

certifier oversight model, and we're maintaining 

and negotiating organic equivalency emphasizing 

oversight and enforcement. 

For FY '19 goals related to farm to 

market traceability, we'll be contracting with 

Customs and Border Protection to program the 

organic import certificate into the automated 

commercial environment. We'll be 

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institutionalizing business processes related to 

fumigation, data analysis, investigations and 

notifications. 

Developing a concept of operations and 

architecture for the traceability system that I 

showed you a couple of pictures of, and we're 

going to be completing a memorandum of agreement 

to access CBP and ACE data across all harmonized 

trade codes. So those are our activities related 

to farm to market traceability. 

Our goals related to robust 

enforcement, we will be launching our new 

compliance and enforcement database system to get 

us in line with other enforcement agencies. It 

has been our consistent goal to resolve 90 

percent of appeals within 180 days, and for the 

past couple of years, we've really hit that mark. 

In FY '19, we hope to resolve 80 percent of the 

complaint cases opened in FY 2017 and earlier, 

and by the end of FY '19 we want to be trending 

towards resolving 75 percent of new complaints 

within 180 days. 

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Again, investigations can take time, 

particularly when they involve other federal 

partners. And so we plan to resolve most 

complaints much faster. There are complaints 

that will remain open for longer periods of time, 

where a more in-depth investigation is justified 

and warranted. 

And then finally we'll complete the 

2018 Dairy Compliance Project with associated 

adverse actions and increased training with 

certifiers, and we'll initiate our 2019 Dairy 

Compliance Project. For FY '19 goals and 

standards and collaboration, we're 

institutionalizing our streamlining actions to 

reduce National List rule-making time frames. 

Again, the Standards Division has done 

a really nice job of re-envisioning how National 

List rules can be published faster, getting new 

tools to farmers and to processors as needed. We 

will be posting a call for nominations in 2019 

for Board seats that will be opening in 2020. 

From an NOP staffing perspective, we have a 

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number of vacancies we've been approved to fill. 

I am recruiting to replace the 

associate deputy administrator position that was 

vacated when I took on this new role. We are 

currently interviewing for additional 

accreditation managers. We have approval to hire 

a quality manager, a new trade systems lead, 

auditors, and an additional compliance and 

enforcement specialist. 

We will also be hosting two NOSB 

meetings in FY '19, and in addition to those 

face-to-face meetings and our certifier training, 

we are also dedicated to continuing our online 

public engagement or virtual town halls. In the 

past few months, we've conducted two webinar 

training events for certifiers. 

In May, we posted a public webinar on 

technology initiatives. In July, we hosted the 

Strengthening Organic Rule-making webinar and in 

November, again we're going to host the webinar 

on the Learning Management System. So these are 

important ways for us to share our work with you 

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and to get your feedback and input. 

And so that is our look ahead at FY 

'19. I want to thank you all for being here 

today and for listening to this presentation. 

I'm going to now turn it back to Tom to 

facilitate questions from the Board. 

MR. CHAPMAN: Thank you very much 

Jenny for that detailed and thorough public 

update. I'm going to open up to questions from 

the Board. Emily. 

MS. OAKLEY: Thank you, Jenny. I 

wanted to talk to you not surprisingly about 

paper pots. So one of my big objectives, small 

scale farmers and especially direct to consumer 

growers getting and staying certified organic. 

I'm concerned that this decision might lead to 

loss of smaller scale growers and their dropping 

of certification. 

So I wanted to ask you one, about your 

concerns about that, and then two, I'm also 

equally interested in seeing growers engage in 

the NOSB process, and I was really heartened to 

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see that we had approximately 80 comments from 

growers specifically about paper pots, which in 

93 years is a really large number of growers 

engaging on a topic. 

Since you stated that we probably 

won't be able to get an extension of the 2018 

deadline that we're going to keep working on 

trying to change your mind if possible, what can 

those stakeholders do to try to request an 

extension that might lead to that result? Thank 

you. 

DR. TUCKER: Thank you. I appreciate 

the question and again, this is not a decision 

that is made lightly. Our first fidelity must be 

to the USDA organic regulations and to the 

National List, and that protecting the integrity 

of the organic seal goes back to the Organic Food 

Production Act and the regulations as published. 

And so those decisions are never easy, 

but we have to have fidelity to the regulations. 

I only wish that the product had been petitioned 

earlier, so the Board could have considered and 

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had this conversation much earlier and used. We 

believe the certifiers that decided not to allow 

this were correct, and so we have to uphold the 

decision-making of certifiers that weighed this 

against the list correctly. 

So I think certainly hearing from 

stakeholders both through this meeting and 

through any follow-up communication such as 

letters sort of formalizing that. I think we 

haven't gotten a lot of formal letters at USDA 

about this. So I have been asking sort of weekly 

who is writing about this, and we haven't gotten 

a lot of communication on this until this 

meeting. 

And so I think many out in the 

audience have heard my little talk about the 

importance of letter writing and that letters 

matter. So I would give that advice. 

MS. OAKLEY: Could I follow up with 

that? So when if people were to write to the 

USDA, should they be writing to NOP, should they 

be writing to the Secretary of Agriculture? Do 

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you have some suggestions for where they could 

direct that communication most effectively? 

DR. TUCKER: So letters that are sent, 

and so this is just a little bit of sort of 

education on how the USDA correspondence system 

works. There are entire manuals on 

correspondence. So in the USDA it's called 

controlled correspondence. Anything that is sent 

to the Secretary or the Undersecretary gets 

entered into a magic system and assigned a 

number, and so -- and responses are tracked. 

And in fact my performance is assessed 

based on my ability to get responses done and in 

the system. So I think writing to the 

Undersecretary and the Secretary level helps 

express your priorities and why they're important 

to you, and what potential economic impacts might 

be experienced in specific cases. 

So you can always write to me and in 

fact if you write the to the Secretary and 

Undersecretary, we'd always appreciate your 

cc'ing me so I know it's coming. It's just 

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helpful to have a copy of that, of that 

correspondence. 

MS. OAKLEY: Thank you for letting me 

ask one more. I just want to make a comment that 

I think it is a big ask to get growers involved 

in the process. So I don't want them to feel 

disillusioned that they made comments to the 

NOSB, and now they're being asked to make 

comments to another level. 

But I think if stakeholders in the 

room can hear this dialogue and communicate that 

and try to encourage participation among farmers, 

and not have them feel disheartened, I think that 

would be a really effective tool for this 

dialogue. So thanks. 

DR. TUCKER: Yeah. I do think that 

part of ongoing engagement with the government is 

remembering that you can't just do it once, 

right. So public comments are important, letters 

are important, phone calls are important, visits 

are important. So there are stakeholders who 

communicate in a lot of different ways. There 

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are other stakeholders who, you know, make one 

comment or send a letter and that's it. 

I know folks are doing their normal 

day jobs, and that is their number one mission, 

and hearing from multiple folks in different 

ways. This is where I think if you're a member 

of some kind of coalition or group that can 

represent the perspectives of multiple farmers, 

one of the letter -- the letter that we've gotten 

on paper pots so far has been from a certifier 

advocating for its operations. So that's another 

important vehicle. 

MR. CHAPMAN: Ashley. 

MS. SWAFFAR: Thanks. Jenny, I have 

three questions. I'll ask them one at a time. 

So this summer the NOSB Executive Committee asked 

for a work agenda request to address antibiotics 

in pre-second day of life day-old chicks. Can 

you please explain further the rationale used for 

the program's denial of our work agenda request? 

DR. TUCKER: Okay. So first, I want 

to thank you for the work agenda request. A lot 

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of thought goes into those work agenda items. I 

think they are a very, very important tool for 

defining the scoping the work of the Board. So I 

think the formality of the work agenda process is 

a useful construct for both a sort of project 

management and also for communications. 

One of the first, when we look at 

petitions, we look at them against a number of 

criteria, and the first criteria is is the work 

agenda something that can be implemented because 

it's within the scope of the Act and the 

regulations? So just a very quick review that 

Organic Food Production Act is owned by Congress. 

The Act is owned by Congress, and then 

the agency owns the regs that implement that Act. 

And the Act on this is pretty clear on we call it 

sort of the day-old chicks part of the Act. The 

work agenda would have directly conflicted with 

something that the Act is fairly clear upon. So 

it was determined by USDA that if the Board 

worked on it, it would not be within our 

statutory authority to carry forward, and so 

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therefore we can't really approve that work 

agenda item. We'd be working on something that 

we don't have the authority to implement, and 

that's not a good use of your time and resources. 

MS. SWAFFAR: Okay. My second 

question is that we've had several commenters 

write in for several meetings on how they feel 

that we can work on that, and that's adding to 

205.238(c)(1), stating that the prohibition on 

antibiotic treatment applies to poultry not under 

organic management prior to day two of life. 

Consumer Union did a -- has wrote that 

in for varying, I guess four meetings now or 

more. Do you think that OFPA would still have 

the conflict, even if we wrote that in? 

DR. TUCKER: If we believe that the 

work agenda was -- is not included under the 

provisions of OFPA. On this one we did. We did 

get feedback from our general counsel on it and 

they're very familiar with our regulations. And 

so some work agenda items we are able to approve 

right at the program. Other agenda items when 

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they relate to statutory authority, we do pull in 

other folks from across USDA. This was one of 

those cases. 

MS. SWAFFAR: Okay. Third question 

not related to day-old chicks. 

(Laughter.) 

MS. SWAFFAR: So just to general 

review, from the time you receive a complaint 

until the time that complaint is finished, what 

is your typical time line there? Because I know 

you talked about one was two weeks, but I think 

that's pretty unusual. 

DR. TUCKER: So what is -- it depends 

-- it depends a little bit on the nature of it. 

So let me give sort of a couple of business rules 

on how that works. So when a complaint comes in, 

the first thing we look at, and we -- so we have 

a complaint intake specialist, and so -- and 

Betsy works very closely with that intake 

specialist to look at every single complaint that 

comes in. 

So one of the first things we look at 

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is is this actually a complaint, or is it really 

a question and not a complaint. And so if it's a 

question, then we answer the question and then if 

it really isn't a complaint, it's simply handled 

as a question. So those are handled within --

within a few days to a week. 

Second, we look at the complaint for 

whether there is evidence, and what the nature of 

that evidence is, and we look at whether the 

operation is certified or not. So if it is a 

certified operation, then often but not always we 

will refer it to the certifier, because the 

certifier has the best on the ground knowledge 

about what's happening with that particular 

operation. 

Now if there is reason to believe that 

the certifier is somehow either involved or had a 

problem, then we might keep it ourselves. But if 

we don't see a potential issue with a certifier, 

we'll refer it. And we give the certifiers a 

deadline for getting back to us with their 

investigative results. 

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That's an area we're working on in 

terms of getting more timely responses from 

certifiers on complaint investigations. Part of 

our training needs to be training more on how to 

conduct these complaints. There have been times 

where we've gotten complaints in where on at 

first look, it feels like a complaint but it 

actually isn't, that it's a complaint about the 

policy not the operation. 

And so it will be a complaint that 

says this operation is doing these awful things, 

but it turns out that actually the complainant 

doesn't like the policy, or doesn't like the 

regulation as written but the operation, based on 

all available evidence, is compliant. And so 

those take sometimes a little bit of time to 

identify as I call them policy complaints. 

But often, we are able to and want to 

close those on the faster side, because there 

isn't evidence that the operation is actually 

violating the regulations as written. There's 

evidence that somebody doesn't like the 

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regulations. 

So for the investigations where there 

is a -- there is good evidence or there's 

signaling of the potential to get good evidence, 

those take longer. And so if it is significant 

violations that might also involve other types of 

violations beyond organic, so for example 

identity theft or other types of violations, 

those are where we will consider referrals to 

other federal agencies. 

Once a case has been referred to 

another federal agency, it becomes their case 

often, which means that we then don't have 

control over the time line. So again, the nature 

of the case, the evidence that comes with it, 

whether the operation is certified or not, those 

are all the variables that will dictate how long 

those kinds of things take. Does that answer the 

question sort of? 

MR. CHAPMAN: Harriet. 

MS. BEHAR: Good things come in 

threes. I also have threes. I also have three 

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questions. So the first point is about the 

Organic Integrity Database. I was thrilled to 

see that you're looking at the county level, 

because that has always been a frustration for me 

and I think I've given comment to that program. 

But I was wondering too if you were 

going to be asking the certifier for information 

on fields that they are managing organically, 

that may not be directly adjoining their home 

farm, which would then, you know, follow the 

residential address. There's a lot of leased 

land and whatever, you know, land that is not 

directly adjoining. 

I think that that would be useful both 

for like drift watch and that sort of thing for 

people to then be aware that this is organic 

land, and as well to for crop insurance windows. 

Farmers are applying for crop insurance. Then 

it's already categorized as organic land in the 

database. 

DR. TUCKER: That's a great question, 

and so the first question I would ask back is 

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well, how not adjoining exactly is this land, 

because are still seeing some violations on 4009, 

who needs to be certified. We are seeing some 

incidences where we have operations that have 

fields that aren't really anywhere close to each 

other that are still under the same 

certification, that really in all rights should 

be separately certified. 

So that is always the first question. 

The database can accommodate reporting of acreage 

at an awful lot of different levels, and so for 

at least one large certifier that has electronic 

systems that are managing this, they report 

there's an operation level reporting tab in the 

Excel template, and then there's a product level 

tab. 

So some certifiers are, if they're 

multiple fields, here's the field, here's the 

acreage, here's the crop. Here's the field, 

here's the acreage, here's the crop. Now those 

are not affiliated specifically with addresses at 

the acreage, at the item level or the product 

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level. I would say to get more granularity on 

the address itself, I'd go back to the original 

question of should they just be separately 

certified. 

Right now, the database is oriented 

around the entity that is certified. So one 

certification, one listing, unless you're dual 

certified and then you're listed twice. So we do 

have some challenges with addresses, that not all 

certifiers provide both addresses. The regs are 

pretty open on this in terms of the type of 

address. So we do get both addresses, but not 

all certifiers report both and not all are doing 

address checking. 

MS. BEHAR: Just to respond to this, 

to respond to that, there's a lot of rented land 

that may even have been rented for generations 

from a relative or whatever that is not 

contiguous, and I know especially in California 

much of the land is leased. It could be again 

leased for 10 years, 20 years, and it may not be 

contiguous. But it's been with that operator. I 

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think typically certification has gone with the 

operator and not necessarily by parcel. 

I think that asking each parcel if 

they have a separate certification and pay a full 

certification fee might be a little bit. But 

that's not really what I'm asking for. I'm just 

asking for the certifiers to maintain a location 

for all those various fields, because again, that 

could be useful to the producer as well as to 

people who are just trying to find, you know, 

which -- is this the organic field or not as far 

as for drift issues or whatever. 

DR. TUCKER: Yeah, some certifiers do 

provide separate certificates, and then list 

those certificates separately in the database. 

So those would be considered separate 

certifications for the purpose of the database. 

So they have a unique NOP code. It may end up 

being six fields with separate certificates and 

therefore separate listings in the database. 

So a lot of challenges I think of the 

public-private partnership when it comes to data 

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is while there's a lot of concern about fair and 

consistent certification practices, the same kind 

of challenges and fair consistent certification 

also lead to data is consistent and standardized, 

it's the same sort of package of challenges. 

MS. BEHAR: Okay. So the second one, 

totally different. On the import fraud, I think 

there's no -- I think there is a coincidence, not 

a coincidence that the largest fraud that we've 

had on the imports is in an area where we have 

very low domestic production in corn and 

soybeans. 

So I'm just wondering, has there been 

any thought within the NOP, we've had public 

comment about this, that another way to prevent 

that fraud is to bring up the domestic 

production, to really get -- it's maybe above you 

Jenny, but to have the USDA make a concerted 

effort to see organic as a priority, and to try 

to improve and increase the knowledge and 

accessibility of organic production and then 

certification. 

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So that I think that that would even 

help with domestic problems if people felt more 

accessible to an understanding of what the 

regulations actually say. 

DR. TUCKER: Yeah, I appreciate that 

comment and those -- our conversations that we 

certainly have had is how can we support domestic 

production. There are a lot of private sector 

initiatives that are rolling out in that. I 

think are sound and sensible certification 

materials from a few years ago are still accessed 

quite often to help with the transition. 

There will be a part of the Learning 

Management System for organic producers who might 

be interested in seeking certification. A lot of 

that is -- it really does take local work, and it 

really is a cultural element, as well as for the 

government, providing sort of education and costshare assistance. It's also very much sort of 

local communication and facilitation. 

MS. SWAFFAR: Okay. My last point is 

as member of the Livestock Subcommittee, I would 

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be remiss if I wasn't talking about the 

antibiotic use in day-old chicks. So I'm 

wondering about a kind of perhaps a guidance 

document that could encourage producers to at 

least seek out the information if those chicks 

had been given antibiotics, either in vivo or at 

day-old, because I know in the marketplace on the 

conventional side, that it is being somewhat 

phased out. 

So I think some transparency on this 

issue might cause it to not -- to operators to 

choose hatcheries that are not doing that, as 

long as there's some transparency. But right now 

since they don't look at those day-old chicks or 

the eggs that they've treated, that there's no 

knowledge. 

So I'm just wondering if we could do 

a guidance document instead to encourage movement 

away from that. 

DR. TUCKER: So guidance documents are 

going to require kind of the same scrutiny 

honestly as regulations. So the first question 

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when we talk about wanting to do a guidance 

document was well, show us how it is authorized 

by the Act and the regs. So it's sort of a com 

-- we can't do guidance on things that are 

outside the authorities of either. 

I would say that this is where I think 

private sector labeling in terms of if this is a 

claim that is important, there are USDA processverified programs that can verify that that has 

been confirmed, certain production practices that 

are outside sort of statutory authority, but are 

perhaps a differentiator in the market. 

I think those process-verified 

programs may be a useful option to consider that 

kind of differentiated marketing. 

MR. CHAPMAN: Lisa. 

MS. DE LIMA: Jenny, can you talk a 

little bit about the BPA that was on the Handling 

Subcommittee's work plan, that's been moved from 

the active work agenda to the, I guess, not 

active, how we did have handful of public 

comments come through asking for an update and 

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why they weren't seeing that come forward? 

DR. TUCKER: Sure. So the BPA was a 

work agenda item that was actually initiated by 

the National Organic Program several years ago. 

So I think four years or so, where we sent a memo 

to the Board asking them to -- asking the Board 

to work on this topic or consider this topic. 

I would say honestly a lot's happened 

since then, and I think that right now, as a 

program, we've determined that it's -- we 

initiated the work agenda and now we're saying 

yeah, actually that's not as important a priority 

as some of the other topics such as imports. And 

so sometimes we have to make tradeoffs on where 

we want to spend energy and time, and so I think 

you have more recently received a work agenda 

item on imports, which the group has been 

pursuing very diligently and I appreciate that 

work. 

That means that some other items will 

need to be deprioritized, and for the moment, BPA 

is one of them. So I think in terms of community 

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planning, being open about what we're actively 

working on and what for right now is sort of 

tabled, I think helps people plan in terms of 

monitoring what's happening with the Board. So 

we want to be honest and open about the fact that 

right now we're deprioritizing this NOP-initiated 

item. 

MR. CHAPMAN: Dave. 

MR. MORTENSEN: Jenny and NOP 

colleagues, I want to echo what Emily had to say 

about paper pots, and then I also wanted to make 

a couple of assertions. You could choose to 

respond to the assertions. They're not really 

questions. 

DR. TUCKER: Okay. 

MR. MORTENSEN: It's my view that the 

not allowing paper pot use in field season 2019 

is disproportionately severe, and the impacts 

will be very large. Other than the soil 

hydroponic issues since I've been on the Board 

and I'm in my second year, I have heard more 

comments about this than any other issue. 

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It's my view that this is an issue 

that we have to be very careful that we're not 

regionally biased in our decision-making. This 

is small and intermediate-sized growers that are 

poorly represented at a meeting like this, and 

that frankly are much less likely to have 

organized voices in contrast to large growers who 

often have had speakers coming to us who are paid 

representatives or expert agronomists or whatever 

that can commit three days to come to this 

meeting and make such presentations. 

Finally, during one of our 

subcommittee calls about three or five months 

ago, it was indicated that you were hearing 

little in Washington, D.C. about the paper pot 

issue. We can see from the public comments and 

the written comments and the discussion that 

we've had that we've been hearing a lot from 

small growers, that to me this is an indication 

of our problem with our information feed into 

this system as Emily alluded to at the end of her 

comments. 

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 Small farmers are dispersed, they're 

small. Their profit margins usually are very 

thin, and time and to take out, to be keeping up 

with all the sorts of rulemaking and writing is 

extremely constrained. I can't imagine, I don't 

know of a single farmer that would know that they 

should be writing to you or to the Secretary of 

Agriculture of the United States about an issue 

like paper pots. 

That simply wouldn't even be in the 

minds of anyone that I know, and I probably know 

about 50 pretty well, of having been on their 

farms. So I just feel like this kind of an issue 

doesn't get a fair shake, because the system in 

my view is somewhat broken with regard to the 

voice, or the lack thereof, in Washington, D.C. 

on such an issue. Thank you. 

DR. TUCKER: I appreciate that. I 

think all the comments on paper pots have been 

both eloquent and helpful, and so I genuinely 

appreciate this feedback. 

MR. CHAPMAN: Scott. 

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 MR. RICE: Thanks. Jenny, we've 

talked a lot about exclusions in the upcoming 

rulemaking, and the one question that I've 

received is about the $5,000 exemption. I know 

that's written into OFPA for small producers, but 

it's become comically small. I know that that 

was there. That maybe let people, kind of let 

small producers test the waters of whether they 

wanted to become certified after that. 

It's also again just so small that it 

doesn't really provide any sort of sensible kind 

of level, and we're more looking at it either way 

or a disincentive or incentive. 

DR. TUCKER: You know, that's an 

interesting question. Right now, we have not 

been looking at that as part of the rulemaking. 

Exemptions are fundamentally different from 

exclusions. You know it's interesting. Joan, 

our secretary in our front office, gets a lot of 

calls from newly beginning farmers who are 

working under the exemption. 

We sort of had that conversation about 

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should that limit be raised. I'm not sure what 

it would need to be raised to make a substantive 

difference. So I think it's an interesting thing 

to sort of keep an eye on. If you folks are 

interested in sort of providing feedback on that, 

right now it's not part of the regs. But I do 

think just as civil penalties go up with 

inflation, should the exemption also go up with 

inflation? It's sort of an interesting question 

that I don't have an answer to. But it's a good 

question. 

MR. CHAPMAN: Asa. 

MR. BRADMAN: I'm not getting a light 

here, but I think this is working. I wanted to 

follow up on Lisa's comments and questions about 

BPA. It sounded like from your response that it 

was an issue of priorities for the decision to 

temporarily put the BPA question on hold. 

That it's not necessarily a question 

of jurisdiction or authority. So I just wanted 

to clarify that, and that maybe we can look 

forward to working on the BPA issue. 

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DR. TUCKER: Yeah, I think it's a good 

question. I think when you read the memo to the 

Board that went in 2014, I'm not entirely sure 

that that memo really stated yes, this is 

absolutely in the statutory authority or no, it 

isn't. So I think that if we decided to 

reactivate that, I think that would be sort of 

part of the question in terms of where are the 

limits of the statutory authority with respect to 

packaging. 

And so I do think it is a larger 

question that would need to asked if that item 

were reactivated. I think for right now, it's 

not in the priority set given the other 

challenges that we are jointly facing as a 

community. 

MR. CHAPMAN: Rick. 

DR. GREENWOOD: Jenny, a quick 

question on residue testing. As I mentioned, I'm 

an organic avocado farmer. I've had my avocados 

tested once in 17 years for residue, and that 

came through a county inspector. Is there or are 

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there guidelines for residue testing that go to 

the certifiers, or is there a plan to have 

something standardized, because I think that's an 

important component of the enforcement 

activities? 

DR. TUCKER: Yeah, I agree with the 

importance of residue testing, so a few comments 

on that. There was a residue testing rule in 

2000, was it '13, '14, that requires residue 

testing five percent is the level. We've also 

required residue testing with respect to some of 

the import investigation going on, that specific 

imports from specific regions and commodities 

were required, heightened testing there. 

I think testing is a great tool, both 

for monitoring surveillance and for enforcement. 

So the residue testing pool formalized the five 

percent. When we talked to certifiers about it, 

we talked about the importance of testing in 

collecting evidence but also risk-based oversight 

in enforcement. 

We need to and are in the process of 

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updating our residue testing guidance for 

certifiers. The guidance is pretty out of date 

in terms of the types of substances that should 

be and can be tested. Also certainly detection 

limits are dropping over time as technology 

evolves. 

So that, those documents need a bit of 

an overhaul now, so need to be overhauled in the 

context of enforcement and where the greatest 

risks are in the market, because of a number of 

commodities on a market or a geographic area, or 

for example fumigants. So I think there's 

certainly work to be done there. 

We will be doing more training on 

sampling and testing through the Learning 

Management Center, for certifiers to make sure 

they're sending their folks out with better 

instructions on how to sample, where to sample, 

when to sample. 

DR. GREENWOOD: Okay. A follow-up 

question since everyone else asked three. But 

this is still on residues. Do you share data 

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with FDA, because they do a tremendous amount of 

residue testing on import foods. So do you get 

any residue data back from them, because it could 

be a good source? 

DR. TUCKER: We do get residue data 

from FDA, and so that's -- and we use those to 

inform investigations. We also closely 

collaborate with our science and technology 

program within our agency, Agricultural Marketing 

Service, and so they also have a residue testing 

program. So yes, we do get notifications from 

FDA. They're a good partner on that one. 

MR. CHAPMAN: Steve, then Emily. 

MR. ELA: Jenny, you've been great 

about as you've come on board with us about 

transparency, and I really appreciate your candid 

comments about what your decision-making 

processes are. For this meeting, we've received 

a number of comments from our stakeholders about 

a couple of things within NOP, and one is first 

of all the shortened time to -- for not having 

the full 30 days for people to comment, 

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especially when we have a complex agenda. 

And then the other is coming back to 

the subcommittee notes that people, that are no 

longer being published. I understand the cost 

and time issues, and why those decisions were 

made. But what ways can we get more timely and 

better information out to our stakeholders, so 

they have time to fully vet some of our decisions 

and follow our process? It seems like we're not 

quite where we need to be on that. 

DR. TUCKER: Okay, thanks for the 

comment. This just came up yesterday as well at 

the National Organic Coalition meeting, so I'm 

going to repeat some stuff that some folks may 

have heard yesterday, but hopefully you won't 

mind hearing it twice. 

So first, the subcommittee notes, we 

will be reinitiating that posting process, and so 

we heard that feedback. Thank you so much. All 

right. We heard that feedback loudly and 

clearly. From an agency perspective, remember we 

are -- NOP is one program of many within our 

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agency, and we post by far the most on the 

website. 

So the Public Affairs team, every 

single time a document has to get posted, they 

have to review it, because nothing goes up on the 

website without them having a sense of what's 

going to happen, and it has to also be reviewed 

for what's called Section 508 compliance, which 

means making sure it's accessible for people with 

disabilities, which takes time. So all of that 

takes time. 

And so understandably, Public Affairs 

has said to all programs hey, you know, take a 

look at what you're posting. You're really --

what does your community actually need? So it 

also relates to just we also get complaints about 

how there's so much on our website that it's hard 

to find things. 

So where we can find documents that 

perhaps if people aren't using as much, that 

they're going to be times where we'll make 

decisions about looking across the labor that 

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goes into that. It was taking about 20 hours a 

month to post those minutes. That's a lot of 

time, and it's time that we are not spending 

doing something else. 

I think the other thing is sometimes 

folks appreciate having things but never say it. 

So we don't know if people are using it or not, 

right? So once we stopped posting subcommittee, 

we got, heard a lot oh, you're not posting 

subcommittee. No one had ever said before that 

wow, thanks for posting those subcommittee notes, 

we really use them and this is why. 

And so I think if there's stuff on the 

website that you really appreciate and want to 

continue letting us know that, I got some really 

direct and helpful feedback from the community 

about the importance of posting enforcement 

actions. So yeah, that's an area where we really 

are advancing in what we're posting and really 

advocating for that. 

So we'll continue to post technical 

reports on the NOSB meeting, materials. 

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Recognize it's an awful lot of documents. So we 

are reposting the subcommittee notes. But I 

wanted to give some sort of context on why that 

kind of happened, and that we did hear you and we 

are returning to those postings. 

Now in terms of the comment period, 

I'm going to try and briefly walk through the 

process. So once a meeting ends, the clearance 

for the Federal Register announcement for the 

next meeting immediately goes into clearance. So 

in fact Michelle has already written the meeting 

announcement for the next meeting, the Spring 

2019 meeting. I've already cleared it and it's 

ready to go into USDA. 

That takes a little bit of time, 

because it goes in the Federal Register. So a 

lot of people need to look at that before it's 

actually published. But I wouldn't -- usually 

now we're getting to the point where we can 

announce the next meeting fairly soon after the 

previous meeting. 

When that happens, it opens what we 

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call the public docket, the open docket. So then 

that docket is literally opened for anyone to do 

public comments on all the way up to when the 

public comment period closes. So if folks want 

to post materials in that open docket, they 

can't. So for example, the last meeting the 

Board said hey, if you have information on this 

please post it in the open docket once it's 

launched, and indeed people did, and that was 

helpful. 

Where we I think want to look at the 

business process further has to do with sort of 

the late end of that process, where the 

subcommittee's done its work and its package of 

discussion documents and proposals that's ready 

to go online and the public comment period. 

Well, it has been opened all along. It really 

starts in earnest because now there's something 

to really read and comment on. 

Now this is always going to be a 

balance between the amount of time the Board gets 

to work on stuff and the amount of time the 

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public gets to comment on stuff. 

So we have really compressed the 

period that breaches those two as fast as we can. 

So once we get in the proposals and documents, 

Michelle has to bundle all of those into a master 

document, and it really does need to go through 

some level of USDA clearance. 

We have managed to get that clearance 

down to about a week and a half. We're not going 

to get it any faster than that. There are a lot 

of people who need to look at 100 and whatever 

pages before it goes up on a government website. 

I think that's normal. And so we have briefings 

internally about what these documents are, where 

the controversies might lie, remind everybody of 

the process that unfolds. A week and a half in a 

big federal system is actually fairly rapid to 

get all that done. 

So that leaves us with either you guys 

get less time to work on proposals, there's 

shortened public comment, or we find a way to 

post interim drafts in the open docket as you go 

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along. So let's say you finish a proposal or you 

finish a discussion document early. You have an 

early interim draft. 

Where I think we might have some room 

to move would be how could we introduce a 

governance process where that material could get 

reviewed, but it could be posted in the open 

docket for people to read? So I think there 

might be some room there. At the same time, you 

guys know sometimes you're working on these 

documents until the very last minute, and those 

aren't going to be available as an interim basis. 

So I think it's important for 

everybody to understand the full time line, 

because it also explains how we've implemented 

the open docket recommendation from the Board. I 

think that process can work well. I'm not sure 

we're maximizing those tools quite yet. Did that 

answer the question? 

MR. ELA: Yeah, I think that's great, 

and again I appreciate your being flexible on 

learning what works and what doesn't work, and I 

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know as a committee chair, I mean just knowing 

that when we finish documents in committee that 

we can go ahead and send them to Michelle, 

instead waiting until that last week and a half, 

you know. That's something we need to be aware 

of. 

So I think it's a learning curve for 

all of us. But thank you for that. Thank you 

for your attempts to be transparent. Really, I 

appreciate that. 

MR. CHAPMAN: Briefly Emily. 

MS. OAKLEY: Very briefly. Some 

stakeholders have expressed concern that given 

short comment periods or concerns over the work 

agenda, that if they would like to suggest that 

the Board send a document back to subcommittee 

for further work, they have fear that it might be 

removed from the work agenda because of staying 

on the work agenda for too long. 

So we talked about that already 

yesterday, and I was just wanting to have you 

clarify that for stakeholders, and give us 

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guidance on that. 

DR. TUCKER: Thank you for that. It's 

a great question. We have really formalized the 

front end of the work agenda process in I think a 

very smart and healthy way that really encourages 

collaboration and honesty about what's possible 

and what's not, and what the priorities are and 

what the priorities aren't. 

I think that in general when something 

is approved and is on the work agenda, if it's 

actively being worked on it needs to go back to 

the subcommittee for more work. I don't see that 

as increasing the risk of it, of it being taken 

off. So I think part of the goal and the purpose 

of the Board is to bring up those controversies 

and to make sure that we get it right, and to 

make sure that we get it with the best and most 

public comment to inform any government action 

that happens from there. 

So if that takes going back to the 

subcommittee for another round and more 

discussion, then I don't see that as creating 

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risk for that item per se. 

MR. CHAPMAN: Okay. I'm going to wrap 

up with one question from myself, and then we'll 

take a break, and Jenny I think it's a brief one. 

But in your presentation, so going back to your 

presentation, you were talking about equivalency 

agreements, trade agreements and a focus on 

compliance and enforcement. As you look into 

those, what -- do you have some details on that 

you can share? What does that mean? 

DR. TUCKER: Sure, what does that 

mean? So for example I think as equivalency has 

evolved over time, everybody sort of learned 

along the way of, you know, what equivalency is 

and isn't and what it entails and what it 

doesn't. 

I think in the early time of 

equivalency arrangements, and before some of the 

I think the import fraud became front and center, 

there was a strong emphasis when negotiating 

equivalency on the standards. 

So the practice standards and the 

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National List. So let's compare those, let's 

compare standards, and I think over time there's 

been a real expansion in attention to -- it's not 

just about the standards. It's also about your 

system overall, your ability to investigate 

complaints effectively, your ability to accredit 

effectively, oversee all the entities 

effectively. 

I think as we've seen with data, the 

importance of having transparency in operations. 

So for example, the Organic Integrity Database is 

actually fairly unique as a public registry of 

certified operations. Other governments don't 

have that, and so that makes it harder to verify 

organic certification of operations in 

equivalency arrangements. 

So I think taking closer look at data 

on systems, on enforcement systems and making 

sure all of those systems are sound including --

in addition to looking at the standards 

themselves. It really does need to be about the 

entire control. So that's the eye to which I'm 

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thinking when we're talking about a future and 

maintaining equivalency arrangements. Does that 

MR. CHAPMAN: Yes, thank you, and 

thank you to the Board for your questions, and 

thank you Jenny for your transparent answers. 

It's been a very valuable discussion. Before we 

move to break, I think we have one last item to 

cover, and I will pass it back to Jenny to do 

that. 

DR. TUCKER: So we do, and this is a 

fun one. So a while ago, I think like three 

meetings ago, I got to announce that we had an 

employee of the quarter for Lisa Brines. And so 

we gave that award to Lisa and now I have another 

one to give for one of the NOP staff members 

who's present, and that is Devon Pattillo. So 

Devon was our employee of the quarter this 

period. Come on down, Devon. 

(Applause.) 

DR. TUCKER: So Devon gets a few 

things for being employee of the quarter. He 

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gets -- first of all he gets a plaque, a 

certificate of achievement that proudly 

recognizes Devon Pattillo as employee of the 

quarter for July, August and September 2018. Put 

this up on your wall, and he also gets the Roving 

Statue. So the statue says "National Organic 

Program Employee of the Quarter in honor your 

outstanding service." So he gets to keep this 

for the quarter, and the he needs to mail it 

back. Joe will give you the code, so they'll 

mail that back to us. But this rotates and the 

employee of the quarter gets to keep it on their 

desk for that period. So that ought to increase 

your luggage fee significantly. 

And then to keep, Devon had the choice 

of a clock or a suitcase, and he chose the 

suitcase. So most people choose suitcase. It's 

a roll bag for his various travels, to ensure 

organic integrity. 

(Applause.) 

DR. TUCKER: So Devon, congratulations 

and I'm going to give you a hug, and we'll do 

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pictures later. Okay. I think that takes us to 

the break. 

MR. CHAPMAN: Yeah. I had a question. 

Is that luggage certified organic? 

DR. TUCKER: You know, I get that 

question a lot, and you know, most items we have 

that have the seal is actually certified -- is 

actually organic cotton. But with a suitcase, 

you know, we've got to take a little bit of 

license here. Okay, thank you. 

MR. CHAPMAN: That's good, and I think 

the Board also extends its congratulations to 

Devon. You're an amazing resource for us, and I 

don't think we could do our work without you. So 

thank you so much. 

(Applause.) 

MR. CHAPMAN: Okay. So with that, we 

will move to break. We're about 45 minutes 

behind schedule, but we'll make it up somehow. 

We will start back up -- sorry, my watch is on 

Pacific time. We'll start back up at 11:15 with 

public comments. Just so folks know, the first 

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public commenter up is Lynn Coody. So at 11:15. 

We're in recess. 

(Whereupon, the above-entitled matter 

went off the record at 11:01 a.m. and resumed at 

11:17 a.m.) 

MR. CHAPMAN: Okay. We're going to 

get started. Lynn, give me one moment. I've got 

to run through some formalities. 

DR. TUCKER: Okay. I'm just waiting. 

MR. CHAPMAN: We're ready. Okay. 

We're going to come back to order. We have eight 

members present, which is a quorum. I ask 

members of the public to either sit down at this 

time or take their conversations outside. So 

we're going to start the public comment. Before 

we get to that, we're going to go over a quick 

couple of formalities on process. 

I normally go through a lengthy review 

of our conflict of interest policy. In the 

interest of time, I'm going to keep it quite 

brief. But basically the NOSB's operations are 

governed by our conflict of interest policy. Our 

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conflict of interest policy can be found in our 

policies and procedures manual. 

Prior to every meeting, a matrix of 

the proposals and discussion documents before the 

Board is distributed to the members. The members 

are asked to present any conflicts of interest. 

At this time, no conflicts of interest were 

disclosed, but for just flexibility I'm also 

going to allow members to express any conflicts 

they may have here at this meeting. 

Seeing none, we don't have any 

conflicts of interest. So we normally go through 

that at the beginning of every subcommittee, but 

given that we have no conflict of interest 

disclosed here, we will not be doing that for the 

sake of time. Moving on, I'm going to really 

briefly review our public comment policy. So all 

persons wishing to comment to the NOSB need to 

sign up first prior, and it's a first-come, kind 

of first-serve format. 

Comments are limited to one comment 

per person. No proxies allowed, and that's one 

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comment either at the in-person meeting or at the 

webinars. Persons are going to be called to 

speak roughly in order of what's on the speaker's 

list here. Clearly, we're running behind 

schedule so we may call folks late or call folks 

early, depending on how we run against that 

schedule. 

If we skip over someone, we'll try to 

come back to you if time allows. We're going to 

try to keep everyone who's on our schedule for 

today in today. So that means we may cut some 

breaks short or run a little bit late if 

necessary. 

I ask that members of the public 

please try to take conversations outside. I also 

ask everyone, members of the public as well as 

members of the Board to silence your cellphones 

or computers, so that we can clearly hear the 

speakers commenting to us. Use of media to 

document these meetings is allowed. I ask that 

members of the public who are using media to 

respect both of the stanchions, as well as the 

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speakers going up and try and limit their use of 

this so as not distracting to either the speaker 

or the Board. 

Lastly, the commenters should refrain 

from making personal -- you can go to the second 

page Michelle -- I'll go through this. This is 

actually quick. So time robin is three minutes 

per speaker. We have -- do we have the color 

thing up there? I can't see it, but it's 

probably lower. 

So it goes green when you start 

speaking. At one minute it will go yellow, and 

then when the time is expired it will go red and 

buzz? At that red buzzer, I do ask that 

commenters try to wrap up their comments on that 

last, their last sentence there. 

We ask that commenters start with 

their name and relevant affiliates at the 

beginning of public comment. If any member of 

the Board has a question about the relevant 

affiliations of a speaker, I ask that you hold 

until the end of their comment and then ask any 

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additional questions at that time. 

Again, commenters have three minutes, 

but once that three minutes is completed, then I 

will look for questions from the Board that they 

may have for that individual speaker. 

Individuals providing public comment to the Board 

are asked to refrain from personal attacks that 

might impugn the character of any individual. If 

we hear any of that coming, I will interrupt the 

speaker and ask them to refrain from that 

activity. 

Then members of the public, I ask to 

clearly and succinctly convey their issues before 

the Board. With that, I think that's the 

formalities, and so we will start with the first 

commenter up. I will call Lynn Coody and on deck 

is Christine Badger. Lynn, if you could start 

with your name and relevant affiliations. 

MS. COODY: Hi. My name is Lynn Coody 

and I'm presenting comments for the Organic 

Produce Wholesalers Coalition, seven businesses 

that distribute fresh organic produce across the 

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U.S. and internationally. In our comments to the 

NOSB, we express our own ideas and also provide a 

conduit for the voices of many certified growers 

who supply our businesses. 

Ethylene for pineapples. OPWC has 

provided detailed written comments on 15 of the 

2020 sunset materials specifically focused on how 

these materials are currently used and needed by 

produce growers and handlers. One of these 

comments is on ethylene for pineapple production. 

At the last Board meeting, Emily asked me for 

information about the horticultural need for 

ethylene. 

In response, OPWC created a survey 

which we sent to all pineapple producers listed 

in the Organic Integrity Database, as well as 

agronomist researchers and handlers who work with 

pineapple. 

We summarized the information they 

provided in our written comments, and concluded 

that induction of flowering is a critically 

important element of an integrated system of 

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horticultural practices used to produce organic 

pineapple, and at this time ethylene is the only 

commercially available option for floral 

induction. 

Therefore, ethylene satisfies the 

evaluation criterion of necessity for this use, 

and OPWC strongly supports the recommendation for 

continued list of ethylene gas for pineapple. 

Genetic integrity of seed. OPWC 

believes that finding ways to keep seed and 

planting stock free from contamination by genetic 

engineering is critically important. We support 

the proposal for a pilot program focused on seed 

corn. Our comments detail eight reasons why we 

think the proposal provides a reasonable way to 

transition from discussion of this critical issue 

into taking action to address it. 

Sodium citrate. OPWC respectfully 

disagrees with the committee's recommendation to 

approve the petition. We agree that evaluation 

of sodium citrate presents broader issues. We 

concluded that NOSB review of inputs to inputs is 

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outside the scope of OFPA, and we think that 

taking action on this outlier material could have 

unintended consequences on the use of other 

natural materials that are long-standing organic 

inputs. 

Paper planting pots. OPWC supports 

the request for technical review of this 

product's manufacturing process as a step towards 

further review as a production aid. We urge the 

Board to prioritize action as we know that many 

produce growers who are managing operations on 

different scales have been using this material in 

good faith with approval of their certifiers. 

To avoid disruption of these certified 

operations, we urge withdrawal of the NOP's 2018 

phase out requirement to allow time for NOSB to 

review paper pots. Thank you for the chance to 

comment. 

MR. CHAPMAN: Thank you. Questions 

for Lynn? Harriet. 

MS. BEHAR: I wasn't sure if it was 

working. Hello Lynn. Thank you very much for 

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your very detailed comments. I think anyone who 

does public comments could look at your comments 

and learn how to do a comment that makes it 

really easy for the National Organic Standards 

Board to review. 

I want to especially thank you for 

pointing out not only what you dislike about a 

proposal, but also pulling out the items that you 

specifically like and specifically on the genetic 

integrity transparency so at least we learn if 

we're headed in the right direction. 

I have a question about the sucrose 

octanoate esters. You I believe were the only 

public commenter both before and now to 

specifically state that you wanted to keep it. 

Many had no comment. So I'm just wondering, do 

any of your producers use it? Have they used it 

in the past and found it to be effective on their 

farms, in the crops section? 

MS. COODY: Well, I have stated OPWC 

often doers these surveys of growers, and we did 

at the prior sunset period for this we did a 

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large survey about the good old 2017 materials, 

when there was a whole big batch of them, and 

that material was included on that one. 

At that time, we got two growers who 

reported they were using it. So that's been a 

few, a couple of years ago now. But we suggested 

that the listing not be removed because we felt 

that it had met all of the criteria, except for 

possible, possibly people weighing in on it. And 

as has been noted here earlier, it's really 

difficult to get farmers to write in. 

We have the advantage of having 

basically produce buyers connecting with these 

growers. So they have a reason to open emails 

from us. Even with that, we get -- it's 

difficult to get comments on these types of 

materials. So we are suggesting that when NOSB 

is taking a material off the list, that there be 

more due diligence to try to get information from 

farmers. 

We suggested two methods to do that. 

One is to work with the Organic Integrity 

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Database to try to identify which type of growers 

who are likely to be using this and contact them 

directly, which is what we do when we have, we 

need information about that. So you can look at 

our comments for more information about that. 

That's the type of thinking we have. 

It's hard to know who needs these 

materials with the system that we're using right 

now, in my opinion. 

MR. CHAPMAN: Emily. 

MS. OAKLEY: Thank you so much for 

your detailed comments on ethylene. I really 

appreciate that, and I also want to express 

appreciation for your very thorough reading of 

the marine materials discussion document. I 

wanted to ask you a specific question. 

You expressed some concern, as a few 

other commenters have as well, that certifiers 

may not have the skills necessary to accurately 

or adequately certify seaweed or marine 

macroalgae to the wild crop standard. 

MS. COODY: Yeah. 

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MS. OAKLEY: And I think that is a 

legitimate concern. But I wanted to ask you how 

do we address that in the face of the fact that 

we know those same products are being currently 

certified to the wild crop standard for stock 

feed and then also some cases human consumption? 

MS. COODY: Yeah. I think that it 

definitely would take a specialty inspector to 

have that kind of information. I read a couple 

of different reviews about how one might go about 

assessing these seaweed areas, and it required a 

knowledge of the food chain, the substrate, the 

tidal, the tidal patterns, etcetera. 

And so there could either -- there's 

kind of two ways to go about it. You can train 

certifiers to be, to have littoral ecologists on 

your staff, or you can have a dumbed down 

standard that is easy, that has really distinct, 

clear criteria for being able to evaluate it. So 

either way, I'm not sure that is -- that second 

one, I'm not sure it's really addressing the 

concerns about seaweed. 

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So I'm not sure exactly how to make it 

happen, and I'm not clear exactly how it is being 

certified right now, whether those certifications 

are meeting the true standards of expectation as 

expressed by the subcommittee in its document. 

So I don't know about that, yeah. Thank you, and 

thanks for reading all those comments. 

MR. CHAPMAN: Okay. I've got Asa, 

Dave and myself, then I've got to cut it off 

there. Asa. 

MR. BRADMAN: I just wanted to ask if 

you can elaborate a bit more on the comments on 

the AITC, and if any of your producers, have they 

specifically expressed interest in this, or is 

this something that you feel like, based on your 

experience, would be helpful? There's clearly 

disagreement there between your review of our 

proposal. 

MS. COODY: Yeah, yeah. Thanks for 

that question. Luckily we can call it AITC 

because it's so darn hard to pronounce. It's a 

tongue-twister. So basically this is a product 

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that's derived from -- it's from mustard plants, 

and we suggested that one possible use for it 

would be to replace the materials that are 

currently used for nursery stock certification. 

So as you know, right now we allow some use of 

non-organic nursery stock, which can be fumigated 

with just about everything. 

So I come from Oregon where there's 

lots of nurseries and lots of fruit stock being 

sent around the state. We were thinking it would 

be a great idea if we could find a way to use 

this particular material through a very discrete 

annotation just for that use, to foster the use 

of organic nursery stock. 

It's really difficult to produce 

organic nursery stock because it's -- I mean like 

say for apple trees. It sits there for years 

before it's coming out of the nursery, and then 

it has to be a protected to a very, very high 

degree to pass these phytosanitary 

certifications. 

So yeah, we do certify. I mean we do 

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have a lot of growers who are certified for fruit 

production and nursery production who would be 

happy to be able to access more organic nursery 

stock, especially nursery stock that, for 

example, is specifically designed to deal with 

fire blight and other really difficult issues 

that face organic growers more so than -- you 

know, they're challenged by this more so than 

conventional growers. 

MR. BRADMAN: Would this material be 

accepted by APHIS or USDA to meet those 

phytosanitary standards? 

MS. COODY: Well, that's a darn good 

question Asa, and if I had more time in this 

comment period I could have looked that up a 

little bit better. 

But that's why we suggested that it 

come back again, and that there be a chance to 

assess that. We have -- there was some 

information in the TR stating that phytosanitary 

requirements are state by state, sometimes even 

region by region depending on which diseases and 

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insects are endemic. 

So that's a good question, and I think 

probably we'd have to be talking to state 

departments of ag about that. 

MR. CHAPMAN: Dave. 

MR. MORTENSEN: Yeah, I mean I also 

just wanted to echo that I really like the idea 

of using the Organic Integrity Database in a more 

active effort on the part of NOP and OSB to get 

information from the growers who are impacted by 

some of these changes. I thought that was 

really, really wise. Thank you. 

MS. COODY: Thanks, Dave. 

MR. CHAPMAN: Okay, and I have one 

last question. You commented on silver 

dihydrogen citrate, stating I believe something 

along the lines of it not being necessary for 

production. We heard some different comments 

from other produce handlers. Is this something 

you could go into a little bit? 

MS. COODY: Right. So we were not 

necessarily sure whether that one was necessary 

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for produce. We were actually favorably disposed 

toward that one when we first read it because it 

does have a different mode of action than most of 

the other things that we have on the list, and 

that's something that OPWC does support. 

Our concern came up when we read the 

EPA's information that was in the TR, that stated 

something like, you'll have to look at my 

comments to get the quote. But it's something 

like when you use this, you must be able to 

notify the municipal water disposal system, 

because it has an impact on that. 

So we were concerned about impacts on 

water, because we know that when in many cases 

when it's used for produce, it's not going -- the 

wastewater's not going into even a municipal 

system. 

It's a rural system. It's sometimes, 

you know, ponds and different underground systems 

right on the site. So we felt like again, we 

needed more time to take a look at that issue, 

because we felt like it did have some legs. 

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So it wasn't a matter of not reading 

it or not feeling like it was necessary for 

produce. We just had a lot more questions about 

that material. So that's, that was our comment 

on that one. 

MR. CHAPMAN: Thank you. Is it really 

brief? Jesse. 

MR. BUIE: Yes, just really. 

MR. CHAPMAN: Really brief. 

MR. BUIE: Yeah. Was there any 

concern for beneficial, the effects on beneficial 

bacteria in the soil? 

MS. COODY: We had general concerns 

for the use of that material in any capacity 

because of the warnings about wastewater. So 

since wastewater, in some cases in produce 

operations it is going onto soil or into, like I 

said, waste treatment systems that are other than 

municipal systems, yeah we had some additional 

questions on that based on the EPA's own words. 

I know on the webinar, there were 

someone who directed Dave to go look at those, 

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that EPA document. So that's an important one, 

and I think it needs to have some more scrutiny. 

MR. CHAPMAN: Thank you. 

MS. COODY: Okay, thanks. 

MR. CHAPMAN: Thank you, Lynn. Up 

next is Christie Badger, followed by Jaydee 

Hanson. 

MS. BADGER: Good morning. My name is 

Christie Badger, and I'm speaking on behalf of 

the National Organic Coalition. Thank you for 

your service on the Board and for your commitment 

to organic integrity. 

I have a comment regarding the limited 

comment period, but I think we've heard a bit 

about that. So I'd just like to say yesterday in 

the NOC pre-NOSB meeting we heard Deputy 

Administrator Jenny Tucker say that the open 

document is an under-utilized resource, and that 

she thinks we could come up with a process to use 

the open docket as a two-way communication tool 

between stakeholders and the NOSB. 

We would encourage the use of this --

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of the open document for questions from the 

subcommittee, and not just draft materials, and 

request this be taken into consideration. In 

addition, she shared plans to restart posting of 

subcommittee notes. Thank you Dr. Tucker. Your 

spirit of collaboration is greatly appreciated. 

Paper pots. With much information and 

many comments shared regarding this ingenious low 

tech system, NOC would like to add our voice to 

those requesting the prohibition be extended on 

paper pots. NOC asks the NOSB to add your voice 

by putting forth a resolution to recommend the 

prohibition be postponed. 

Natamycin. NOC supports the Crop 

Subcommittee's voice to add natamycin to 205.602, 

non-synthetic substances prohibited for use in 

organic crop production. As an antimicrobial 

substance that has medical application, and is 

known to result in anti-microbial resistance, 

nanomycin should not be allowed in organic crop 

production. 

As demonstrated in research included 

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in the petition and reviewed in the TR, nanomycin 

has resulted in resistance in candida albicans. 

Anti-microbials with medical uses should not be 

used in agriculture, and particularly not organic 

agriculture. Further, NOC would ask the NOSB to 

put nanomycin on the livestock work agenda, to be 

listed at 205.604 as a prohibited non-synthetic. 

Energy infrastructure impacts. Please 

add the study of energy infrastructure impacts to 

the work agenda, with an end goal of guidance for 

instruction developed by the NOP that would 

provide resources that could be shared with 

certifiers and producers, to aid in maintaining 

certification and improve consistent application 

of the standards. 

One such resource that has been proven 

effective by the Ohio Ecological Food and Farm 

Association and has prevented decertification on 

more than one occasion is the Organic Agriculture 

Impact Mitigation Plan. We are not asking the 

NOP or the NOSB to take controversial action 

against any industry or practice. Thank you. 

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MR. CHAPMAN: Thank you. Emily. 

MS. OAKLEY: Thank you for your 

comments on paper pots. I know that we discussed 

within our subcommittee the issue of precedent 

that the program is concerned about, and I just 

wanted to know if you saw any similarities 

between paper pots and some other issues. 

MS. BADGER: Thanks, Emily. We 

definitely do. There are so many issues right 

now that -- I mean if we're being frank, 

sometimes come under the don't ask, don't tell, 

let's not talk about it. GMO vaccines. We need 

to petition them to be on the National List. 

Treated twine being used all over farms, sodium 

nitrate, inerts, naled and after the last TR 

perhaps paper itself. 

MR. CHAPMAN: Steve. 

MR. ELA: Natamycin. I appreciate 

your comments. It's one I go, I mean I tend to 

agree but I struggle with a little bit because it 

obviously could have use for anti-rot and 

preservation of fruit, and certainly with patulin 

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and some of those other things which are human 

health concerns as well. 

It could help prevent some of those. 

I mean is your thought on banning it just it has 

that crossover on human health for treatment of 

human health, and you think that's significant 

enough to actually put that, to protect that use 

only for human health? 

MS. BADGER: Steve, I am really glad 

you did ask that question actually. I do feel 

strongly enough. Do you know, one of the 

webinars which you know I take very close notes 

on, one of the speakers suggested that oh, in the 

U.S. it's not really used for human health. 

That's only in Third World countries. 

It is amazing we had -- there were 

probably a dozen people on a NOC call when we 

were discussing this, and one of them who is new 

to our group, working with I'm sorry, I can't 

even tell, Maine Organic --

PARTICIPANT: MOFPA. 

MS. BADGER: Thank you, MOFPA, 

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actually said -- he goes you know, I actually 

have personal experience with this. I had 

something wrong with my eye, and my eye doctor 

was like it really hard to find any medication 

that actually works for eyes anymore, and he said 

I had to use nanomycin, and it was the only thing 

that cured this. 

Then the other thing that I just have 

to say, and so many people know I'm very kind of 

blunt. But I'm just going to say this, Steve. 

You know, the candida albicans yeast infection, 

the gentleman that never, that said that it's not 

used just must have never had one, but frankly, 

you know. 

(Laughter.) 

MR. CHAPMAN: I think we'll stop that 

comment there. Ashley, you ready to follow up 

that? 

MS. SWAFFAR: Are you the one to ask 

about gums, or should I direct that comment, 

question to someone else? 

MS. BADGER: It should be directed to 

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someone else. I'd be happy to try to answer it, 

but I'm not certainly -- that's not one of my 

strongest points. 

MS. SWAFFAR: Okay. Would Abby be the 

better person to direct my question about --

MS. BADGER: Can you tell me what the 

question is, and then maybe I could --

MS. SWAFFAR: Well, you guys suggested 

that the gellan gum should expire, but you guys 

also suggested that we delist carrageenan and 

gellan gum. Is there a replacement for that? So 

I just -- and I said that when I voted for carra 

-- to remove carrageenan. 

I was very concerned that the next 

time that gums came around, that everybody should 

see we shouldn't remove them from the National 

List. So I want to know some more detail on why 

you say that. 

MS. BADGER: I am going to actually, 

if I could, refer that to our member 

organization, Beyond Pesticides, and again 

because it's just not my strongest area. 

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MR. CHAPMAN: Harriet. 

MS. BEHAR: So I have a question about 

the energy infrastructure. So we have been 

struggling with this, of how it fits in. So your 

point of providing information to aid producers 

and certifiers in maintaining their organic 

certification during the activities of energy 

infrastructure moving through organic land. 

This is -- so this is what -- this is 

the direction that you're looking, that you would 

like to take. Because so it's not a banning of 

it; it's just a matter of how to best, a best 

practice in a way or guidance for certifiers, so 

that across the country and across the world when 

this occurring, those operators and certifiers 

can deal with this, so it allows that land to 

retain organic production. 

Is that the way you're looking, that 

our work agenda item maybe would look? 

MS. BADGER: Right. So my next 

sentence I didn't get to, but I'll just say 

prohibited substances can be identified when 

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energy infrastructure occurs on organic farms, 

and alternative materials and practices that do 

not jeopardize the viability of certified 

operations are available and have been used. 

We heard on one of the webinars from 

Doug Raubenolt, who is an organic inspector. He 

has been hired through these impact mitigation 

plans to oversee farms, organic farms where this 

work is taking place. He presented on the 

webinar four distinct questions that he had, and 

that was just one person. 

So we've talked about putting together 

an expert panel that could come up with and 

inform this discussion with some very distinct 

points for clarification, that the Board could 

then discuss and some perhaps guidance for 

certifiers could be provided. Right now, there 

is nothing so everybody's winging it. 

MR. CHAPMAN: Thank you. Thank you 

for your comments. We'll move along. Thank you 

for your comments. 

MS. BADGER: Thank you. 

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MR. CHAPMAN: So up next, I had called 

Jaydee Hanson. Jaydee Hanson had provided 

comments previously on the webinar, and we only 

allow one comment in the webinar or in person. 

So I'll be moving to the next commenter, which is 

Gwendolyn Wyard, and Gwendolyn is Johanna 

Mirenda. Sorry for putting you on the spot there 

Gwen. Gwen, if you can start with your name and 

affiliation for the record. 

MS. WYARD: All right. Good morning 

NOSB, NOP staff and ladies and gentleman of the 

gallery. My name is Gwendolyn Wyard. I serve as 

Vice President for Regulatory and Technical 

Affairs for the Organic Trade Association. First 

I'd like to welcome Dr. Greenwood and Mr. 

Schwartz, and I should also welcome Scott Rice's 

beard to this meeting. 

(Laughter.) 

MS. WYARD: All right. So I'm going 

to focus on two topics this morning, with one 

take-home message for each topic. The first is 

pull-u-lan, pullulan. The Organic Trade 

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Association is the petitioner of this material. 

In short, pullulan is produced via fermentation 

and this is used to make vegetarian capsules that 

are then used for encapsulated dietary 

supplements that are certified to the "made with" 

category. 

Organic capsules are not commercially 

available, and the only alternative at this time 

is an animal-based gelatin capsule, which is not 

appropriate for vegetarian products. So why the 

petition? Since at least 2003, as far as I am 

aware of, certifiers have been classifying 

pullulan as agricultural and allowing it in the 

30 percent non-organic portion of a made with 

product. 

In response to NOP guidance that came 

out in 2014, certifiers are now classifying as 

non-agricultural, which means it must appear on 

the National List to be allowed in NOP certified 

products. Without its continued allowance, we 

estimate that the economic impact to the organic 

dietary supplement sector would be over $825 

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million. 

Our take-home message on this topic is 

that we recognize that there is some debate about 

the classification status, and we agree that 

there's some ambiguity to it. For all the 

reasons that are documented in the technical 

report, which is well done and in our comments, 

we believe that it should be classified as nonagricultural, and more importantly, we want it to 

go through the full NOSB National Review process, 

appear on the National List and be under 

continuous NOSB review. 

Organic seed usage. The Organic Trade 

Association emphasizes that organic seed is the 

foundation to a thriving farming, organic farming 

system, and in order to require operators to 

demonstrate continuous improvement of organic 

seed usage, over time a regulatory change is 

needed. 

Take-home message on this topic is 

that this has been on NOSB's work plan for a very 

long time. There's been great work that's gone 

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into it, and while the proposal to update 

existing guidance continues to surface a swarm of 

discontent if you will, we believe that there's 

very strong support to revise the regulation to 

require continuous improvement. 

We find the intent of your proposal to 

be clear on the regulatory change. We believe 

that wordsmithing, the ands, ors, commas at this 

point is counterproductive to progress, and we 

ask you to please pass this portion, make a 

single motion to pass the regulatory change 

that's in that proposal, and bring the guidance 

back to subcommittee for more work. 

In closing, the Organic Trade 

Association represents 9,500 members across the 

U.S. and across the supply chain. We're here 

because we're committed to both promoting and 

protecting organic agriculture and making organic 

a part of everyone's everyday lives. The NOSB 

process is very important to our organization and 

to our members, so we thank you all for your time 

and dedication that you put into your work. 

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Thank you. 

MR. CHAPMAN: Thank you. Questions 

from the Board? Lisa? 

MS. DE LIMA: Do you have any insight 

on the time line on the availability of organic 

pullulan? 

MS. WYARD: Availability of organic 

pullulan. So the company Capsugel has been 

working on organic pullulan for some time. 

Actually, the parent company is Lonza. They are 

European. They are committed to not only making 

the perfect product with the quality that meets 

everyone's specifications, but they're also 

committed to being able to meet the demand which 

is continuously growing. 

I believe that they will be here today 

if you can direct that comment to them, but I 

think you probably will get the same answer, that 

they are working as quickly as possible. People 

are lining up out the door to use organic 

pullulan, because the only way that you can use 

-- put the USDA organic seal on a dietary 

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supplement is to use an organic capsule. 

The weight of that capsule, if you're 

using non-organic pullulan-based capsules, only 

will allow it into the made with category. So 

there's a huge incentive to use organic. This 

petition is to keep the continued use in the made 

with category only. That petition's very 

specific to supplements in the made with category 

only. 

When organic becomes available, we're 

absolutely confident that that's where companies 

will go, so that they can use that USDA organic 

seal. 

MR. CHAPMAN: I had a question and 

then we'll go to Harriet. So did you indicate 

that pullulan's not allowed or not mentioned in 

international standards? What's going on in 

those markets? What are companies using as an 

alternative? 

MS. WYARD: Yeah. So that's an 

interesting situation. We are unique in the 

United States in that we're the only country, 

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we're the only regulation that is actually 

looking at the capsules. So in Europe, they're 

not considered. They don't calculate them when 

they do the organic percentage, and they don't 

look at the composition. 

So they're really, they're basically 

viewed as packaging. So that's why you're seeing 

it. I noticed in the TR-2 it goes through all 

the different international standards. It's 

either they're not on the list or it's not 

allowed. 

But that's because they're not 

considering the capsule the way that we do, where 

not only do we look at the composition of the 

capsule that's used for a dietary supplement, but 

we also calculate it into the percentage of 

organic. 

MR. CHAPMAN: Harriet. 

MS. BEHAR: So thank you for your very 

detailed comments on the genetic integrity 

transparency document, and I had a couple of 

responses. As far as the level of purity, it 

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would be up to the producer of the seed to go 

within those specific level of purity just to 

make the database collection of information 

clear. 

But if they wanted to have the 

specific level of purity, they could do that as 

well. It's not meant to constrict what 

information is being transferred. We're just 

looking for transparency, so that the producers 

who are growing out that seed know at least what 

they're starting out with. 

And then there's some other aspects 

that we will be dealing with. I also wanted to 

ask you about your response to the paper pots and 

expanding it to other uses of paper beyond just 

pots, like seed tape and things like that. We 

really haven't had a chance to talk about it 

within the Crop Subcommittee, but we also have 

not clarified what our technical review will be 

covering, so we will discuss if want to be adding 

that. 

I know that whatever happens, we don't 

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want to slow down our work on paper pots, but I 

don't know if adding those things would or would 

not. So would you encourage us to make sure if 

we took longer, that we should try to look at 

every use of paper that we could think of and try 

to get that covered in the TR, or would you be 

okay if we only did a TR just on the pots? 

MS. WYARD: I'm going to stay in my 

lane on that question, and I'm going to defer to 

our Farm Policy Director, Jo Mirenda, who's up I 

think in a couple of commenters, if that's okay. 

All right, great. Thank you for the 

clarification. 

MR. CHAPMAN: Thank you, Gwen. All 

right. Up next is Jo Mirenda, followed by Beth 

Unger on deck. Jo, if you could start with your 

name and affiliation for the record. 

MS. MIRENDA: Okay, I have new 

affiliation. Good morning. My name is Johanna 

Mirenda and I'm the Farm Policy Director for the 

Organic Trade Association. I'll be commenting 

today on paper pots and marine materials. 

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The Organic Trade Association supports 

the allowance of paper to be planted in the soil 

when used as a planting aid, because paper is 

already allowed for equivalent uses such a mulch. 

In terms of the impact on human health or the 

environment, there is no meaningful difference 

between the allowance of paper as mulch and the 

petition use of paper. Both have direct contact 

with the soil; both uses allow paper to 

biodegrade. 

In our written comments, we further 

address the issue of adhesives. In short, we 

support a technical review of those adhesives 

that are intentionally added after the paper is 

manufactured, to further formulate the paper into 

final products. 

As the NOSB proceeds with its review, 

we strongly encourage the Board to take a broad 

approach for reviewing paper-based planting aids 

to be inclusive of generic products that are 

paper-based and used as planting or seeding aids. 

There's a broad spectrum of paper-based products 

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that are made from the same types of materials, 

paper, and used in the same manner, planted in 

the ground, but are designed in slightly 

different ways. 

If the listing is limited only to pots 

and containers, you might find yourselves in this 

position reviewing new petitions for nearly 

identical materials that are designed in slightly 

different ways, such as the tapes that Harriet 

mentioned. 

A broadened approach will make 

efficient use of your time to review this variety 

of materials, and will also allow for a scaleneutral review of paper-based planting aids, 

which could be designed by a variety of 

manufacturers for various scales of production. 

On to marine plants. The intended 

goal of the Materials Subcommittee is to protect 

marine environments from potential contamination 

and destruction caused by marine plant 

harvesting, and we fully support this effort. 

But we do have questions about the 

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feasibility of implementing a requirement that 

marine plants be certified organic as a means for 

achieving these specific sustainability goals. 

In our written comments, we identify several 

areas of study such as assessing the 

sustainability outcomes of the each, the crop's 

certification scope versus the wild crop's 

certification scope, and also assessing existing 

efforts of NGOs and other relevant organizations 

that are active in marine ecosystem 

sustainability. 

We look forward to further discussion 

on this topic with OTA's members and with the 

NOSB. Thank you. 

MR. CHAPMAN: I will start with 

Harriet and Sue and Emily. 

MS. BEHAR: In your former life as 

working with OMRI, there is an OMRI mulch that's 

approved, that's listed. Weed Barrier I think 

it's called. I see it advertised and I see the 

OMRI listing. I'm just wondering, was that 

virgin paper, was that recycled paper? Did it 

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have adhesives, because you know, there's already 

a mulch that's a paper mulch, and I'm wondering 

how deeply OMRI reviewed that and if there's some 

synergy here with the discussion on paper pots. 

MS. MIRENDA: The composition of that 

specific product I can't recall on the spot. But 

in general, when paper is being reviewed under 

its current listings on the National List, there 

is a mulch or a feedstock, it's a deceivingly 

complex listing, and I can guarantee that OMRI 

and many other certifiers have had in-depth 

conversations about what is paper, what are the 

different sources, what are the different 

composition fibers, what are the additives, when 

are they added? 

If you add the adhesives and the inks 

before it's paper, those are okay. But if the 

paper is finished and then it's being further 

processed into a pot, how do we deal with those? 

In fact, this was a topic of training at the 

Accredited Certifiers Association training back 

in 2018, and the ACA is looking to build best 

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practices around this, because there's a lot that 

goes into this listing, there's a lot of 

different types. 

In terms of virgin paper specifically, 

so we're looking at that term in contrast to 

recycled paper, because recycled is what's in the 

listing. There's no definition for recycled. So 

it's unclear whether that's limited just to paper 

that's 100 percent recycled content coming out of 

a commercial paper recycling facility, or is it 

you have some cardboard boxes ready to go to the 

dump, but instead you're using them on your -- as 

mulch or something. 

So recycled, repurposed, reused, 

diverted from the waste stream, all of these 

interpretations are currently being used in the 

absence of a definition. And that -- I'll leave 

it with that. 

MR. CHAPMAN: Sue. 

MS. BAIRD: Yes. I'm sorry. We've 

heard overwhelmingly from stakeholders asking if 

we could intercede for a grace period for 

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implementation for prohibiting paper pots, and I 

know in your work you've reviewed a lot of this 

stuff. 

Do you have any specific instances 

where there could be a prohibition by NOP, but 

they've said oh yeah, but we're going to give you 

a grace period to implement that? 

MS. MIRENDA: Sure. On the first 

point, I'll just confirm that the Organic Trade 

Association in our written comments did support 

an extension of this 2018 phase out period. So 

that position is based on acknowledgment that we 

feel there's a negligible impact on organic 

integrity because synthetic paper with synthetic 

processing aids and additives is already being 

used in the organic system. 

So this is really a question of 

implementation of this deceivingly complex of 

listing of paper and the annotations that 

surround it. And in terms of similar examples, 

the one that first came to mind for me is -- this 

is the handling example, but sodium and potassium 

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lactate. 

So these are two individual 

substances. The NOPs, they're not currently on 

the National List, but they had been allowed 

under an old interpretation that if you combine 

two materials on the National List and you get a 

third new one, sure use it. 

Obviously, that is not an 

interpretation is not is or should be used today. 

So the NOP issued a memo saying these materials 

need to be petitioned, they need to go on the 

National List. This Board did review those 

petitions, issued a recommendation to approve. 

Rulemaking is still in progress, and throughout 

this whole period certifiers are allowing these 

materials. 

So to me that's a good example because 

there's differing interpretations. There's good 

faith effort on behalf of the certifiers who do 

their due diligence of reviewing these materials, 

and instead of disrupting the marketplace for 

certified operators that have been using these 

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approved materials by their certifiers, just sort 

of let the process play out. 

MR. CHAPMAN: Thank you. Emily. 

MS. OAKLEY: After that comment, can 

I have two, because now I wanted to ask Jenny 

what her response to that might be, and if that 

might provide a window for extending the grace 

period. 

DR. TUCKER: I am sensing a theme. 

You know what I'll say is that we're going to 

take the all the comments from this meeting back, 

and I'll be providing an update to our senior 

leadership on the key topics that came up in this 

meeting. So I appreciate the comments. 

MR. MORTENSEN: Just for the record, 

could Jo restate those substances? I couldn't 

make out what you said. 

MS. MIRENDA: Sodium lactate and 

potassium lactate. 

MR. MORTENSEN: Thank you 

MS. MIRENDA: And I believe they were 

petitioned together, so there's one petition, one 

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recommendation. 

MS. OAKLEY: So my actual question was 

about reading materials. Thank you very much for 

your detailed comments, and you expressed support 

for the concept of using the wild crop standard 

as a tool for trying to address the environmental 

impact. I was wondering if you could elaborate 

on that a bit. 

MS. MIRENDA: Sure. So in our written 

comments, we did support the logic of using our 

existing organic certification system, very 

strong, gold standard, to evaluate the 

sustainable production of materials, including 

that may end up being used in crop inputs, 

because they align with the Organic Foods 

Production Act criteria for the National List. 

That being said, we still had 

questions about what really is the problem we're 

trying to solve in terms of potential 

contamination and over-harvesting of marine 

plants. We really wanted to have this Board and 

the community have a better understanding of the 

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real problem, so that we're sure that whatever 

solution is proposed will address that problem. 

So with the difference, different 

requirements for crops versus wild crops 

standards, and given the lack of specificity in 

the standards for marine agriculture 

specifically, at this point we're not fully 

convinced that this is the right solution. 

We just have questions about it and 

support continued work either through a working 

group or an expert panel, bringing together other 

stakeholders so we can really get an 

understanding of this issue that we feel is 

important. 

MR. CHAPMAN: Steve. 

MR. ELA: Coming back to paper pots, 

we're wrestling in the Crop Subcommittee of how 

to ask like for a technical report, so we're not 

asking for approval of a product, but an ordinary 

thing. So taking paper as a planting aid is a 

great idea. How would you -- you know, does this 

say we're going to allow any adhesive obviously 

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is not, I don't think, a door we want to open 

because that's just ad hoc. 

Do you have any suggestions of how we 

should approach the whole adhesive issue, so that 

it becomes something we can get a TR on, 

something we can annotate? You know, I guess I'd 

just appreciate your feedback on how we should 

proceed, in your opinion. 

MS. MIRENDA: Sure. So there has been 

a lot of work done on newspaper and recycled 

paper. There was just a full technical report 

done last year, and goes into a lot of 

information about the adhesives, the glues, the 

inks, the dyes, the toners, the laundry list of 

things that are used in paper manufacturing. 

So consider that as a starting point 

just to assess what's already been reviewed and 

approved, and then finding your sliver scope of 

something that could be used in a limited scope 

technical report. That could be a way to balance 

conducting a thorough technical review on the 

unique aspects of these paper-based planting 

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aids, without slowing down the process to do 

another full TR. 

MR. ELA: I guess one of the issues 

though like the TR on paper or on newspaper, you 

know, it listed a few adhesives and then it kind 

of goes "and many others." That's where, you 

know, it's -- I mean we recognize there are many 

others and some are proprietary, etcetera, 

etcetera. 

But in terms of allowing a use beyond 

recycled paper given the issues there, I guess 

we're still wrestling with if you try and approve 

just a few adhesives, how do you -- how do you 

know that? Kind of this could be a percentage, 

or how do we wrap our hands around that whole 

issue and contain it so it doesn't approve 

something that just becomes, excuse, becomes 

anything goes? 

MS. MIRENDA: Well, the fact that the 

technical reports lists a ton of materials, then 

kind of goes on to say, you know, etcetera, 

there's just a lot, gives you a sense that 

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there's already lots of synthetics being used in 

paper that can be used as mulch directly on the 

soil left to biodegrade. 

So consider looking at what additional 

risks might be involved with a paper pot. That 

might have some adhesives which may or may not be 

exactly what's already being used in paper, 

regardless of whether you may be able to identify 

those or not. But I'll stop there. 

MR. CHAPMAN: Okay. Thank you for 

your comments. We're going to have to stop 

there. 

MS. MIRENDA: Okay. 

MR. CHAPMAN: Thank you. Up next is 

Beth, followed by Sam Welsch. Beth, if you can 

start with your name and affiliation. 

MS. UNGER: Good morning. I'm Beth 

Unger, Regulatory Engagement Manager at CROPP 

Cooperative, and I want to thank you for the 

opportunity to provide comment. I apologize that 

I'm going to go over the same old ground you've 

been hearing for the last two days, but you know, 

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there's a few things that I wanted to bring to 

your attention. 

So I'm focused on the Materials 

Subcommittee genetic integrity transparency of 

seed, the Crop Subcommittee's strengthening the 

organic seed guidance, and the NOP process for 

publishing information for the National Organic 

Standards Board meeting. 

First, the genetic transparency of 

seed. A lot of thought and work went into the 

proposal. There's a lot of things that we really 

liked about it. Corn was the very right choice 

to start off with as being the highest risk. The 

GMO crops out there. Putting the burden on 

producers using conventional seed to obtain test 

results is a disincentive to use conventional 

seed. So it's really accomplishing two things at 

the same time. 

Reporting results provides visibility 

on contamination levels. It's something that 

this committee has dealt with over the years, and 

it's information that isn't widely available. So 

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we think that that's a great idea. We also like 

the fact that the subcommittee included sampling 

protocol, which is really a key element for 

obtaining good data in the first place. The 

proposal would have had added clarity of 

organized in a manner to highlight the 

responsibility by stakeholder. 

It was a little bit confusing that 

way, a little disconnect going on there. But and 

we did have information on that in our written 

comments that you could refer to. But overall, 

we think that that was a very well thought-out 

proposal. 

Strengthening the organic seed 

guidance. As stated in previous comments over 

many years on this topic. CROPP supports the use 

of organic seed through our own internal policy. 

Although one can always improve on written 

proposals, there were key elements in the 

proposal the NOP can use to strengthen the 

guidance document, and also regulatory. We 

especially appreciate the recommendation to add 

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to the regulations at 205.204(a)(1)(i), requiring 

improvement in the search, sourcing and use of 

organic seed. We urge you to pass a proposal at 

this meeting. 

On the process, I'm going to be really 

brief. We thought it would be a good idea. I 

know that these proposals don't all come at one 

time. If you would just get them through 

clearance and posted as they become available, to 

give us time to reach out to stakeholders to give 

better and more thorough public comment. Thank 

you. 

MR. CHAPMAN: Thank you, Beth. 

Harriet. 

MS. BEHAR: So I'm going to ask on a 

totally different. I hope you can answer. How 

do you feel about putting on the work agenda 

review of GMO vaccines and modifying the current 

listing in the regulation about allowing excluded 

vaccines, but only if they're listed? Or should 

that be removed completely and just allow, or I 

mean we probably should put it on the work 

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agenda. So that's my opinion. 

I'm wondering if you think it should 

stay as is, or should we work on this to clarify 

that? 

MS. UNGER: I believe that if you 

worked on that, that would be consistent with 

205.600. 

MR. CHAPMAN: Ashley. 

MS. SWAFFAR: I just want to clarify. 

We did submit that as a work agenda request item. 

MR. CHAPMAN: Thank you, Beth. 

MS. UNGER: Thanks. 

MR. CHAPMAN: Up next is Sam, followed 

by Zea Sonnebend. Sam, give us your name and 

affiliation. 

MR. WELSCH: Yes. My name is Sam 

Welsch. I'm with OneCert. First, I want to 

discuss a couple of items on the National List. 

I support removal of the microcrystalline cheese 

wax, because it's not essential for mushroom 

production, and it can often contain antibiotics. 

I support the removal of sucrose octanoate esters 

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which are not being used, at least in the 

beekeeping area, and because they're probably not 

an effective treatment anyway. 

Regarding the petition for pullulan, 

I want to advise you to be careful of claims that 

it can be certified organic. I've looked into 

that for years in trying to track down those who 

claim to have a certified organic pullulan, only 

to find out when we ask questions that the 

certifications are being surrendered or 

suspended. There are currently no certified 

organic pullulan on the Organic Integrity 

Database. 

I know there's aspects that prevent 

compliance in manufacturing process, so be 

careful about accepting claims without evidence. 

Regarding inspector qualifications, 

obviously I support high quality inspector 

qualifications, but I do oppose the licensing of 

inspectors, adding additional burdens there. We 

already have an accreditation that requires 

certifiers to have qualified staff, and it's not 

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limited to inspectors. 

It includes our reviewers and others 

making decisions about certification. I also 

includes the NOP. So we need to look at all 

levels to have consistency in quality, training, 

education and I'm very pleased that NOP is 

working on that to ask that in conjunction with 

ACA, the Accredited Certifiers Association, which 

is also working very actively in developing best 

practices guidance for our members and others in 

the industry. 

I think adoption of those is key. One 

example of an issue where we don't have 

consistency and we need some guidance from the 

NOP is recently we had found that somebody was 

selling product that was not on the National 

List, or they had -- or they had surrendered. 

The previous certifier was telling our client who 

was buying product from them that because they 

had a contract that was issued before they 

surrendered, they could still accept shipment of 

product as organic from that now uncertified 

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operation. 

That's contrary to what I think is the 

general practice among certifiers. It turns out 

upon further investigation that that previous 

certifier had only initially inspected them one 

time. They had never been audited, and it was 

one of the operators who was, pled guilty to 

fraud. 

So they were getting permission from 

a certifier to continue to ship organic product, 

even after they had surrendered their 

certification. We need guidance, instructions 

from the NOP to make sure no certifier is telling 

somebody when you're no longer certified you can 

still ship organic product. 

MR. CHAPMAN: Thank you. Questions 

for Sam? Harriet. 

MS. BEHAR: I'm unaware that the 

microcrystalline cheese wax could contain 

antibiotics. I'm not sure who's the lead on 

that. Where did you -- since you mentioned that 

we should always look for evidence if a claim is 

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being made, I'm just joking. But where did you 

get that information, because that's very 

interesting to me? 

MR. WELSCH: That was on SDS sheets on 

products that we were requested to approve for 

use. 

MS. BEHAR: So you actually saw an 

MSDS? 

MR. WELSCH: Yeah. That's a bit 

dated. That was -- that was information we had 

at the time it was initially listed so we knew it 

was being done at that time. 

MS. BEHAR: So we're talking probably 

12 years ago or something like that? 

MR. WELSCH: Yeah. So I'm not sure if 

that still is current. We've never approved the 

use of it. The people that wanted to went to 

other certifiers. 

MS. BEHAR: Well, I wonder if any 

certifiers out there who are going to come up and 

give public comment could help clarify if they're 

still seeing that out there. 

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MR. CHAPMAN: All right. I've got 

Steve and then Ashley. 

MR. ELA: Sam, when you say you would 

support delisting microcrystalline cheese wax, it 

seemed like in the public comments there was some 

-- it was unclear to me whether there were or 

were not suitable alternatives. Some people said 

there were, some people said there weren't. In 

your experience are there alternatives for those 

producers that do want to grow on logs? 

MR. WELSCH: There seemed to be at the 

time when we were initially looking at it. 

MR. ELA: Would those be --

(Simultaneous speaking.) 

MR. WELSCH: Yeah. I think there's 

the ones that were listed, the soy waxes and 

things. 

MR. CHAPMAN: Ashley. 

MS. SWAFFAR: Okay, a couple of very 

different questions for you. The first one is 

SOEs. As an international certifier, I'd kind of 

like to get your scope on that. EPA doesn't have 

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a listing here in the U.S. for SOEs. Do you see 

SOEs being used anywhere else around the world? 

Do you certify bees at all? 

MR. WELSCH: We do certify some 

beekeeping, but mostly wild harvested areas. 

We're not aware of anybody who's using it. 

MS. SWAFFAR: Okay, and a follow-up 

question. Since you didn't submit written 

comments, my question is paper pots. What's your 

stance on paper pots? 

MR. WELSCH: Well, I don't want to be 

too unpopular here, but we're one of the 

certifiers who never approved them, and we're in 

fact surprised that other certifiers had. We 

looked at it because of when we asked for 

information about what's in them, it was obvious 

that they included synthetic adhesives and other 

components that were not on the National List. 

So you know, for consistency we've 

also supported the extended period for pullulan 

to continue to be allowed, even while it's being 

petitioned. So I'm not going to speak in favor 

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or against the extension, but I do understand. 

It's important to be consistent, and it's hard to 

be consistent when you make different rules on 

how popular the option is, rather than go back to 

the rule. 

I tend to look at what's in the rule, 

what's in the law, what's in the regulations, and 

say that's what we should be doing. It should be 

extraordinary circumstances where we don't follow 

that. 

MR. CHAPMAN: Thank you, Sam. I think 

that's it. Thank you. Up next is Zea, followed 

by Phil LaRocca. If you could start with your 

name and affiliation. 

MS. SONNABEND: Greetings. I'm Zea 

Sonnebend from CCOF and Fruitilicious Farm in 

Watsonville, California. I'm a former member of 

the NOSB in the scientist seat from 2012 to 2016. 

I'm also one of the historical voices of NOSB, 

having been to one of the very early NOSB 

meetings here in Minneapolis in 1993 I believe, 

so I know a lot about the past. 

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Anyway, we would like to comment about 

strengthening the organic seed and the genetic 

integrity of seed. CCOF supports the rule change 

to 205.204. Certifiers really need something 

that they can use to justify that growers are 

continuing to improve in their organic seed 

requirement. 

So we fully support Gwendolyn's 

position of at least pass that part of it, and 

maybe take back the guidance portion for further 

work. 

On the genetic integrity of seed, we 

support the proposal strongly, that there be seed 

tags that have purity indications. We also very 

strongly support the retaining of a sample of 

seed, but we'd like it to be for 18 months 

instead of 12 months because you don't usually 

see a problem in the seed until you harvest the 

crop that resulted from that seed several months 

later. 

And then at harvest if you find a 

problem, it takes some time to do an 

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investigation and trace it back, and that might 

take you through the next planting season. So 18 

months would be better, and so that's our 

position on that. 

We strongly support the excluded 

methods terminology which as you know we did a 

lot of the work spearheading that effort, and 

hope that work continues on that. I also just 

want to say a few things about the change to the 

inerts annotation, which I understand has fallen 

off the table and is not being worked on, even 

though the NOSB passed a recommendation. 

There are two significant problems 

that still remain. One is that this effort 

started because the EPA came here and said they 

did not want their old List 4 still mentioned in 

the federal regulations. So they would really 

like that to change. Just because they haven't 

been back doesn't mean they don't still want it. 

We worked with them for many years on 

the Inerts Working Group trying to get that 

changed, and we have a change they could agree 

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with and we could agree with so we want you to do 

it. And second of all, because it's in limbo, 

it's really inhibited new product development. 

So all these potential tools that 

organic farmers could be using aren't being 

developed because don't know what to put in for 

inerts, because they don't know what the 

regulatory scheme is going to be. 

So since the buzzer hasn't run, I will 

also say that historically there is quite a bit 

of precedent for grace periods and different 

practices that come into effect. CCOF does not 

have a position on paper pots. We also have 

never allowed them. 

But personally, I would just like to 

point to the biggest grace period that happened 

in the past was when the inerts policy first came 

into effect it was quite a radical change from 

what was being done, and an 18 month period was 

given for inerts to come into compliance with the 

federal rule. 

Eighteen months so that the EPA could 

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take another -- reclassify some manufacturers to 

reformulate, et cetera. Thank you. 

MR. CHAPMAN: Thank you, Zea. 

Questions for Zea? Harriet. 

MS. BEHAR: For the farmers retaining 

samples under the genetic integrity, do you feel 

we need to give a little bit more direction 

besides the 18 months on how to keep samples? 

MR. SONNABEND: I think that easily 

could be done, and certifier training would be a 

good place to do it, and then certifiers can tell 

people. It's as simple as putting some seed in a 

mason jar, putting a label on it saying the 

variety and the date you put it aside. And you 

know, really very simple. It doesn't have to be 

an involved thing. 

MR. CHAPMAN: Thank you, Zea. Thank 

you. Up next is Phil, followed by David 

Wallinga. 

MR. LaROCCA: Good morning. My name 

is Phil LaRocca. I am the owner and winemaker of 

LaRocca Vineyards. I also sit as the Chairman of 

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the Board of Directors for CCOF and I am here to 

actually speak for some of our certified organic 

dairy producers in California. Jenny, thank you 

because you covered some of the issues that I'm 

going to deal with here. 

First of all, I will say we are one of 

the rare bodies that actually asked for 

regulations, and there's a reason for that. It's 

these strict regulations that make us who we are. 

It also gives us a place, standing in the 

marketplace. Organic stands out. It is felt by 

some of our dairy producers that they are 

following the rule to where it should be, and 

this is what we are asking you, to make sure that 

the organic livestock and dairy standards are 

followed through the fullest, highest degree of 

precision. 

It is felt that some of our producers 

are doing this, and by so doing are being 

discriminated a little bit in the marketplace by 

other growers that may not be following the 

practices. I'm not a dairy producer. I make 

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wines, so I'm doing my best to help some of our 

growers out. 

But I'd also like to carry these 

statements and make them ditto onto egg and 

poultry production as well. Now this is my area 

here that's concerning me always, and that's 

drift. Drift is a problem that the organic 

community has faced on and on. We just recently 

had an issue where an organic peach grower was 

drifted upon. 

Fortunately, his neighbor was a 

friend, a conventional grower who had insurance 

and was able to cover his crop because his crop 

was fully lost, and now he's going through the 

period of trying to regain his organic 

certification again. 

What I would like to see happen is 

some form of government crop insurance, whether 

it be through the NAP program, where certified 

organic growers are protected from drift, whether 

it be pesticide, herbicide, fungicide or genetic 

drift. 

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On that same topic, it was brought up 

to me yesterday that we're going to have areas 

that have been affected by the flood and the 

hurricanes, and they are probably going to be 

dusted with some heavy chemicals for mosquitos. 

So this Board should be aware that 

something's going to take place there, and that 

there may be some organic farms involved, so what 

are we going to do about it. On the last note, I 

want to say that I'm very grateful to be in this 

room, because I consider some extremely brilliant 

minds to be here. 

We're all here for a great purpose and 

that is to grow healthy food and make this world 

a better place. I realize that if we all thought 

the same it would probably be pretty boring. But 

at the same time, we have to remember let's have 

our differences but also what we are trying to 

accomplish we'd like to see at CCOF. 

Let's make organic the norm, that we 

all need to work together. We are only one 

percent of agriculture, and to gain into that 

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percentile we need to work together and respect 

each other. So thank you. 

MR. CHAPMAN: Thank you, Phil. 

Harriet. 

MS. BEHAR: This actually is more of 

a question for Jenny and Paul. I know when Miles 

was the deputy administrator, we were -- there 

was guidance on drift actually listed as an item 

that the National Organic Program was working on. 

I live in the Upper Midwest and drift is a very 

large issue for us. 

And I don't know at one point at just 

stopped appearing on the list, with no 

explanation. So I'm wondering if there is 

anything happening within -- the NOSB never saw 

what Miles was working on, neither did the 

public, and I think that's an issue. I'm just 

curious what's going on with that. 

DR. TUCKER: Yeah. That's a good, a 

good question. Can you hear me, yeah? A good 

question and I appreciate your asking about the 

status of that. There was, and it was talked 

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about I think during a couple of meetings a while 

ago, the possibility of looking at drift. I 

think it was in the form of guidance at the time. 

And that, that document was 

distributed within, within USDA, and there were a 

lot of very, very good questions about it that 

sort of sent us back to really being, consider 

all the different variables that were associated 

with it. So the document has not moved forward 

since then because the complexity of this is 

really enormous. 

So that continues to be addressed on 

an operation-specific basis with certifiers. But 

at this time, that guidance is not active on our 

work agenda. 

MR. LaROCCA: Our comment. In 

California, we're trying to work on that. But it 

always seems that the fellow or person who has 

drifted was the guilty party. We need to reverse 

that. It's kind of like we're guilty until we 

prove ourselves innocent, and it shouldn't be 

like that. If you're drifted and your whole 

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livelihood is at stake, we should have some 

backing by either state or federal government to 

come in and say we're the innocent party here and 

we need to be covered, and we're not really 

seeing that. 

MR. CHAPMAN: Thank you, thank you. 

MR. LaROCCA: Yeah, thank you. 

MR. CHAPMAN: Asa? Phil, sorry. We 

still have a question for you. 

MR. BRADMAN: So just one follow-up 

question. Do you have a database or is there any 

central repository of information on the number 

of drift incidents and who is affected and what 

crops and the monetary loss? 

MR. LaROCCA: I don't have that with 

me now, but I bet we have some of that at CCOF. 

MR. BRADMAN: If you could submit 

something like that, that would be great. 

MR. LaROCCA: Okay, thank you. That 

was the national database on that Asa that Purdue 

University keeps, that have 4.5 million acres of 

arable crop land was drifted on last summer, for 

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example, by specific compounds. 

MR. BRADMAN: But that's not 

necessarily just organic though. 

MR. LaROCCA: You can break it down to 

organic and conventional. 

MR. BRADMAN: Okay great, thanks. 

MR. CHAPMAN: Okay. Next up is David, 

followed by Glenn Kern. David, if you could 

start with your name and affiliation. 

MR. WALLINGA: Good afternoon. My 

name's David Wallinga. I'm a physician and 

Senior Health Officer at the Natural Resources 

Defense Council, which uses science and public 

health and advocacy to protect public health and 

the environment. 

So I am here to talk about the use of 

human antibiotics in organic poultry production, 

and how it bears on public health as well as 

consumer understanding of the organic label. 

Consistently, polling shows that U.S. consumers 

want meat and poultry products raised with fewer 

or no antibiotics, and most consumers do so under 

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the impression that buying those products is 

important for their own health and the health of 

their families and it is. 

The CDC and the World Health 

Organization, for example, among other leading 

health authorities, agree that using antibiotics 

in food animal production ultimately increases 

the spread of antibiotic resistance that's now 

epidemic, and that poses a rising threat to all 

of us here. 

So many consumers therefore seek out 

approved labels such as organic or raised without 

antibiotics because they think it means zero 

antibiotics used, and in a case of raised without 

antibiotics they would be right. But 

unfortunately that's not true of the USDA 

approved organic label. 

When its own label fails to meet 

consumer concerns or understanding, that's a 

problem that the USDA should and needs to 

address. So specifically NRDC urges the USDA to 

support this Board's request for its work plan to 

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include a prohibition on use of antibiotics in 

organic agriculture without exception. This 

would include, for example, the current practice 

of routinely injecting gentamicin and 

aminoglycoside antibiotic by hatcheries into 

their eggs just before the chicks hatch. 

Gentamicin is an important human drug 

that's injected into very sick patients when 

other drugs don't work. Among other things, for 

example, it's used in newborns who have lifethreatening meningitis, sepsis or other systemic 

infections. It's also used in adults. 

I suspect most consumers would be 

surprised to learn to gentamicin is routinely 

used in organic chicken production. When they do 

learn it, I think it would conflict with their 

common understanding of what a USDA organic label 

represents. The current exemption allows for 

antibiotic use in production before chicks turn 

two days old, and that exemption dates back to 

1990 when the OFPA was passed. 

At that point, day-old chicks never 

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having been given antibiotics were unavailable. 

But that was a generation ago, almost 30 years, 

and we're in a different era now. Now they are 

freely available. I would point to written 

comments from both the National Organic Coalition 

as well as Consumer Reports that make clear that 

this exemption is no longer necessary and in fact 

would be easy to fix. 

So in summation, I urge the USDA to 

reconsider its denial of the Livestock 

Subcommittee's request to add this issue to its 

work plan. Thank you. 

MR. CHAPMAN: Thank you. Ashley. 

MS. SWAFFAR: Yeah. What data do you 

have that suggests that antibiotics are routinely 

used in organic poultry? 

MR. WALLINGA: Well in the U.S., we 

don't actually collect data on usage by species 

or on the farm. So USDA has been consistently 

been asked to do so by advocates like myself. 

The General Accounting Office has consistently 

recommended it as well, but we still do not 

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collect on farm use data. 

So we can't answer that question. 

However, when extension agencies, for example, or 

other publications talk about the use in poultry 

production, that's listed as a common use. In 

addition, we know from Public Health Canada 

having done a study several years ago, looking at 

hatchery production in Quebec, that it was almost 

uniformly used at that point. 

MS. SWAFFAR: In a different country. 

MR. WALLINGA: In a different country, 

right. 

MS. SWAFFAR: Not in the U.S., in the 

U.S. 

MR. WALLINGA: Not in the U.S., 

because again in the U.S. we don't actually track 

antibiotic use at the farm. So we're a little 

bit in the dark. 

MS. SWAFFAR: Yeah, so I'm sorry. 

This is as a member of the poultry industry for a 

lot of years, I know that it's not a routinely 

used thing in especially the egg industry. So 

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that's --

MR. WALLINGA: I hope that's the case 

and with -- if the NOSB were able to put that in 

their work plan, maybe that's a fact that they 

could establish. 

MS. SWAFFAR: Yeah, and my other 

follow-up to your suggestion on asking the NOP to 

let us work on that. I think that it needs to be 

elevated probably to the Secretary's level. So 

those comments need to be directly written in and 

lobbied to the Secretary level. 

MR. WALLINGA: Okay, thank you. 

MR. CHAPMAN: Rick. 

DR. GREENWOOD: Yeah. I have a 

question. Do you have any data about the 

survival of for instance gentamicin, which is a 

protein after cooking? My thought is that if you 

cook an egg or you cook meat that has antibiotic, 

does it survive? So is it at that level not a 

risk anymore for resistance? 

MR. WALLINGA: Right. I mean it's a 

common misconception that what we're talking 

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about is residues of antibiotics in the meat or 

in the food product. That's not the issue. The 

issue is that when you expose the bacteria in the 

egg or in the animal to an antibiotic, that it in 

fact spurs resistant bacteria to form and then 

spread. 

So we do know that from the NARMS 

program that there are routinely antibioticresistant bacteria on food products where 

antibiotics are routinely used. So that's true 

for chicken as well as other species. 

DR. GREENWOOD: I get that part of it. 

I'm thinking of a human gut changing to flora and 

developing resistance in an individual. 

MR. WALLINGA: Well, you can get human 

gut flora changing by being exposed to antibiotic 

resistance bacteria on the meat or other food 

products that they eat, because those bacteria 

can transfer their resistance genes onto other 

bacteria in the human gut. 

DR. GREENWOOD: No, I know that. 

MR. WALLINGA: Yeah. 

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DR. GREENWOOD: I'm just thinking 

about a source, and I think there's too much 

antibiotics. I mean don't get me wrong, but I'm 

just thinking how much of that survives cooking 

for exposure to individuals. I've never seen any 

data for it, but it seems they won't survive 

cooking. 

MR. WALLINGA: I don't know of that 

data. But again in my own personal opinion, 

that's a little bit of a distraction from the 

other issue that I'm talking about, which is the 

resistance among the bacteria that we know are on 

food. 

DR. GREENWOOD: Thank you. 

MR. CHAPMAN: Thank you. Asa, do you 

have something briefly? 

MR. BRADMAN: Just very briefly. I 

just want to thank you for your comments. I'm a 

public health person. It's an issue that's 

worldwide and of concern to a lot of people 

concerned about health. So I think it's 

important that you raised this. Thank you. 

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MR. WALLINGA: Thanks. 

MR. CHAPMAN: Thank you. Up next is 

Glenn Kern, followed by Peter Nell. Glenn, if 

you can start with your name and affiliation. 

MR. KERN: My name --

MR. CHAPMAN: Thank you for your 

comments here today. 

(Laughter.) 

MR. KERN: That's it. My name is 

Glenn Kern, and I'm offering these comments on 

behalf of the Carolina Farm Stewardship 

Association or CFSA for short. CFSA works in a 

variety of ways to expand the footprint of 

organic farming in the Carolinas. A crucial 

component of this work is supporting conventional 

farmers who transition to organic production of 

our region's most reliable crops. 

Many of these farmers have become 

important voices in support of transforming 

agriculture in the Carolinas to a more 

sustainable model. This is a transformation that 

is urgently needed. The CAFOs and chemicalNeal R. Gross and Co., Inc. 

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dependent crop farms that dominate the coastal 

regions of the Carolinas present unacceptable 

risks to human health and the environment, in the 

context of a changing climate. 

Severe flooding like that caused by 

Hurricane Florence last month is predicted to 

become more common and with it, the risk of 

contamination for nearby communities and 

ecosystems. Organic management is a way for 

conventional farms in the coastal regions of the 

Carolinas to adapt to the risks of climate 

change. 

CFSA is in favor of farmers growing 

organic sweet potatoes, soybeans, corn, wheat, 

vegetable and yes, organic tobacco, if this 

valuable crop is what they choose to grow in 

order to stay afloat. Indeed, more than half of 

all certified organic crop farms in North 

Carolina have made the choice to grow organic 

tobacco as part of their rotations. 

Yet organic tobacco may soon be lost 

to farmers in the Carolinas. At the NOSB meeting 

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in Jacksonville, this Board considered a petition 

to add fatty alcohols to the National List for 

use as a sucker control agent in tobacco. This 

substance had been allowed by some certifiers for 

years based on the determination that it was a 

non-synthetic. 

However, the Board classified fatty 

alcohols as a synthetic and then did not 

recommend it for addition to the National List. 

Regrettably, not a single grower of organic 

tobacco was heard from at that meeting. Without 

the use of fatty alcohols, many farmers who grow 

organic tobacco will have to abandon this crop 

and perhaps organic certification altogether. 

Organic tobacco accounts for nearly 50 

percent of all organic crop sales in the 

Carolinas, and there is every reason to think 

that the loss of this lucrative market will be 

more devastating to our organic farmers than the 

thousand year flood they experienced last month. 

It's our understanding that a revised 

petition for fatty alcohols has been filed. If 

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and when the NOSB reviews this revised petition, 

you will hear from organic farmers in the 

Carolinas who grow tobacco. CFSA will make sure 

of that. I thank you for all the work you do on 

behalf of organic agriculture and for your 

consideration of these comments. I'm happy to 

try to answer any questions you may have. 

MR. CHAPMAN: Emily. 

MS. OAKLEY: Thank you for your 

comments. In the absence of fatty alcohols, what 

are organic producers using right now? 

MR. KERN: That's a good question. I 

am -- I have spoken to some farmers and they have 

said that they are -- that mineral oil and 

soybean oil do not work. I have also heard third 

hand that some certifiers are continuing to allow 

the use of fatty alcohols, but that -- that's not 

something I can speak to directly. 

MR. CHAPMAN: Thank you. Up next is 

Peter, followed by Kate Mendenhall. Peter, if 

you can start with your name and affiliation. 

MR. NELL: Hello. My name is Peter 

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Nell, and I'm a policy specialist with CCOF. 

Today, I'll be commenting on the Materials 

Subcommittee's discussion document on marine 

materials and the 2020 sunset review of elemental 

sulfur. 

CCOF, as you might know, is a nonprofit organization governed by the people who 

grow and make our food. We certify over 3,000 

operations in 44 states and three countries. 

CCOF shares the concern that marine materials are 

under threat of over-harvesting habitat 

degradation and destruction. 

However, CCOF does not support 

requiring organic certification of marine 

materials to the wild crop standards. CCOF does 

not certify marine materials, and the discussion 

document notes that certifiers that do have 

difficulty adapting the National Organic 

Standards to aquatic systems. 

The Board should establish a working 

group to determine the feasibility of integrating 

-- of integrating fishery certification, 

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sustainability verifications or attestations for 

all ocean source inputs, seaweeds, fish products, 

et cetera into the National Organic Standards. 

We recommend that the Board determine 

a phase-in goal that all marine materials be 

sourced from third party verified and/or 

certified sustainable fisheries within ten years. 

Obviously we understand the complexity of this 

issue. 

Additionally, organic claims on input 

products are currently outside the scope of NOP 

enforcement. Therefore, it would be difficult 

for certifiers to verify input compliance to the 

wild crop standards. 

Regarding elemental sulfur, over 1,000 

CCOF members list the substance on their OSP. 

Some list both dusting and wettable sulfur 

products, and use them in a wide variety of crops 

for pest and disease control, and also for soil 

fertility. CCOF encourages our members to 

comment, but they don't always have the capacity 

to directly submit their own comments. 

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In this case, we direct -- we 

conducted direct outreach to our members that 

list elemental sulfur on their OSPs. Some of 

them did submit written comments, and in many 

cases they responded to us and I included that 

comment, their comments in our written comments. 

Given the importance of elemental 

sulfur to many organic producers, NOSB should 

carefully consider whether additional safety 

precautions or limitations should be required for 

its use. Thanks for your time. 

MR. CHAPMAN: Thank you. Emily. 

MS. OAKLEY: Thank you for your 

comments on marine materials. I know that you've 

stated also in your written comments that you're 

concerned that this would be difficult for 

certifiers to verify. If we were requiring that 

the ingredients, the marine macroalgae itself 

were to be certified to the wild crop standard, 

what's your concern there if they were to have a 

certificate and then would also be on the Organic 

Integrity Database for that product? 

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 I'm not totally sure how that's 

different from verification of other materials, 

other naturals that we have right now. 

MR. NELL: Sure. I think our 

assumption was that the entire product was to be 

certified. However, yesterday at the NOC meeting 

you did mention that it was going to be a single 

ingredient. I'm happy to talk with our team and 

discuss that further. But at this time, I'm not 

sure. 

MS. OAKLEY: If you do discuss that 

with your team and you have further thoughts, if 

you'd post those to the open docket that would be 

really helpful. 

MR. NELL: Absolutely. Thanks Emily. 

MR. CHAPMAN: Thank you Peter. 

MR. NELL: Thanks. 

MR. CHAPMAN: Up next is Kate, 

followed by Michelle Smolarski. Sorry if I 

butchered that Michelle. Kate, if you could 

start with your name and affiliation. 

MS. MENDENHALL: Thank you. Thank you 

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members of the National Organic Standards Board 

for the opportunity to speak before you today. 

My name is Kate Mendenhall. I'm the Director of 

the Organic Farmers Association, and I'm also an 

organic farmer in Iowa. 

The Organic Farmers Association was 

founded in 2016 as a national grassroots 

membership organization that provides a strong 

and unified national voice for domestic certified 

organic producers. 

Organic Farmers Association works to 

build and support a farmer-led national organic 

farmer movement, and national policy platform by 

developing and advocating policies that benefit 

organic farmers, strengthening and supporting the 

capacity of organic farmers and farm 

organizations, and supporting collaboration and 

leadership among organic farmer organizations. 

What sets us apart is that we are 

farmer-led and farmer-controlled. Only certified 

organic farmers drive our policy positions. All 

domestic certified organic farmers are invited 

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annually to submit policy priorities, which are 

then vetted by an elected policy committee of 

certified organic farmers. 

OFA organic farm members vet these 

policies and then vote on them, following our 

restrict one farm-one vote policy, where all 

farmers have an equal seat at the table. Our 

membership and network of certified organic 

farmers is diverse and spans across all 50 states 

and U.S. territories. 

Organic Farmers Association greatly 

supports the work and role of the NOSB in 

maintaining the integrity of the USDA organic 

label. We urge the NOP to complete its work on 

the NOSB recommendations that remain in the 

status of outstanding and in process. Farmers 

and consumers trust and rely on the NOP enacting 

the NOSB recommendations in a timely and 

transparent manner, and we ask that you make this 

a priority for 2019. 

We urge the NOP to issue guidance 

based on the 2015 proposed origin of livestock 

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rule and publish a final rule in 2019; to put 

more resources and attention into pasture rule 

compliance; to implement the organic livestock 

and poultry practices rule; to stand by the 2010 

NOSB vote and recommendation to not allow 

certified organic hydroponics; and to immediately 

stop labeling and material listing as invalid 

listing, as no definition nor explanation of 

procedures for determination and management for 

the term exists. 

We submitted a number of specific 

recommendations in our written comments. Most 

notably, our national farm membership has 

prioritized organic integrity as their number one 

concern. This is directed at both domestic 

integrity, with consistent enforcement of the 

pasture rule specifically, but all organic 

standards nationally across region, farm size and 

certifier. 

Also import integrity is essential. 

We must act more swiftly and effectively to 

protect American organic farmers against import 

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fraud. Thank you for the opportunity to address 

you today. 

MR. CHAPMAN: Thank you. Questions, 

Emily? 

MS. OAKLEY: I just wanted to say 

thank you for being here. It's really nice to 

have a farmer organization at the table 

representing farmers. 

MS. MENDENHALL: Thank you. 

MR. CHAPMAN: Harriet. 

MS. BEHAR: In the positions that 

you've put in your written comments, were they 

split positions or was it a pretty universal 

agreement on those items? 

MS. MENDENHALL: We have a pretty 

strict policy for how our policy positions come 

forward. We are split up into six regions 

nationally, and so for any policy position to be 

accepted, it has to go -- it has to receive 

national support of 60 percent, and then it also 

has to receive two-thirds of the regions also 

showing 60 percent. 

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 In our last year, we just started in 

2016, so we've only been through one round of 

annual policy resolutions. But all of our 

policies pass, I believe, are over 80 percent 

nationally and in each region. So we're quite 

united as a national farmer voice, and that was 

really I think comforting and exciting to see in 

this first year. 

MR. CHAPMAN: Thank you. Thank you 

for your comments. 

MS. MENDENHALL: Thank you. 

MR. CHAPMAN: Up next is Michelle, 

followed by Tom Harding. 

MS. SMOLARSKI: Good afternoon. My 

name is Michelle Smolarski, and I work with the 

International Food Additives Council, an 

association representing manufacturers of food 

ingredients. IFAC supports the Handling 

Subcommittee's recommendations to relist several 

sunset review substances, and we thank the Board 

for the opportunity to provide comments today. 

IFAC strongly supports the 

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subcommittee's recommendation to retain xanthan 

gum on the National List. Xanthan gum 

contributes unique thickening, stabilizing, 

emulsifying and texturizing attributes to foods 

and beverages, and is widely used in foods for 

populations with allergies and celiac disease, 

including gluten-free products. 

Production of xanthan gum does not 

harm the environment, and aligns with organic 

principles, as it relies on a natural process 

with no harmful metabolites or byproducts. In 

addition, since xanthan gum is produced through 

the natural process of bacterial growth, IFAC 

believes it more appropriately fits the 

description of a non-synthetic, and suggests the 

NOSB consider moving xanthan gum to 205.605(a). 

IFAC also supports the subcommittee's 

recommendation to relist gellan gum. Gellan gum 

is also produced for bacterial fermentation and 

provides the organic industry with unique 

stabilizing and thickening properties needed for 

a variety of applications, including suspending 

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important nutrients in foods and beverages, in 

fortified beverages. 

Furthermore, gellan gum provides the 

organic community with a gel source suitable for 

vegetarians and those with cultural or religious 

dietary restrictions. In addition, IFAC strongly 

supports the relisting of lecithin de-oiled at 

205.606. De-oiled lecithin has a unique 

functionality higher than that of powdered 

lecithin, and is commonly used in oil and water 

emulsions. 

De-oiled lecithin provided to the 

organic industry by IFAC members does not contain 

modified proteins and is fully compliant with the 

prohibited use of any ingredients derived from 

genetic engineering in organic foods. 

Finally, IFAC would like to express 

our support for these subcommittee's 

recommendation to retain gum arabic, locust bean 

gum, carob bean gum and guar gum on the National 

List. Gum arabic is used worldwide as an 

emulsifier in common foods like granola bars and 

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salad dressings, allowing these products to be 

shelf stable and therefore more accessible. It's 

also used to impart texture and thicken foods. 

Carob bean gum, also known as locust 

bean gum, delays ice crystal formation and is 

used as a stabilizer, thickener and fat replacer, 

as well as an adjunct gelling agent and 

texturizer to other hydrocolloids in dairy 

deserts, baked goods and dressings and sauces. 

Guar gum is preferred due to its 

superior water binding and viscosity abilities 

that are not replicated by organic alternatives. 

Because of guar gum's unique technical 

attributes, it keeps frozen dairy products 

consistent through freeze-thaw cycles from 

manufacturer to consumption. 

In closing, we would also like to 

express our strong support for relisting 

alginate, mono and diglycerides, magnesium 

stearate, phosphoric acid and tragacanth gum. 

Thank you for the opportunity to comment. 

MR. CHAPMAN: Thank you. Questions, 

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Harriet. 

MS. BEHAR: Has anyone looked into 

possibly producing in the like the locust bean 

gum or the carob bean gum as an organic product? 

MS. SMOLARSKI: Unfortunately I am 

not a technical expert. I know that there has 

been -- at this point, I don't -- I'm not able to 

phone a friend. I cannot call on our technical 

experts in our membership. But I'm happy to 

follow up to provide some more historic 

information. 

MS. BEHAR: And submit something to 

the docket. We would like to see that. 

MS. SMOLARSKI: Yeah. 

MR. CHAPMAN: Thank you. Up next we 

have Tom Harding and I think we will break there 

then for lunch. So Tom, you could start with the 

name and affiliation. 

MR. HARDING: Thank you. Tom Harding. 

I'm here representing Green Ag Supply as a 

consultant. First of all, I want to thank you 

all for the good work that you continue to do, 

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not that it's easy. I'm here representing Green 

Ag Supply, who petitioned fatty alcohols for the 

use on organic corps, specifically organic 

tobacco crops. 

We have taken the recommendations of 

the NOP, the NOSB and the Subcommittee and others 

who have been very involved, and we have 

submitted a new and revised petition to the NOP 

for the use of fatty alcohols on organic tobacco 

crops. It contains much new and additional 

technical information, field trials, et cetera, 

material trials. Hopefully it will be 

considered, reviewed, received and final approval 

for the National List. 

If we can be of assistance in any way, 

our scientists, our farmers will be ready to 

answer of the additional questions you may have, 

and we hope that they will be all be here when 

this final review. Once again, we want to 

encourage the Board to put on its work list the 

materials appeals process. 

I know that you have a lot on your 

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work agenda already, but I think it would save a 

lot of time and money if we had an appeals 

process, versus having to go back through the 

whole resubmission. Separately from Green Ag 

Supply, I want to speak on behalf of the term the 

gold standard, which is the National Organic 

Standards Program, the NOP, the OFPA were as 

organic as it is regulated within 205, that it is 

the gold standard. 

We have to be very careful. I've 

participated in a number of panels in the last 

few months, and I see all kinds of programs 

coming out even using the term organic within the 

framework of their name, or in some parts of 

their work. 

I'm not against any of those things. 

I think we must do everything possible to make 

and keep the NOP legal standards the gold 

standards, which can include incrementally 

improving these standards through the process 

established within OFPA. 

It does us no good to argue about 

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these points, but it's most important that we 

protect the term "organic." I think we have to 

be very careful. When over 75 percent of the 

current marketplace recognizes the USDA organic 

seal, it's really important that we must legally 

protect and value the word "organic." 

I can tell you that without this 

protection, we will have a confused marketplace 

which continues to have to some degree a lot of 

confusion right now. I want to thank you all 

very much. 

I want us to work together on behalf 

of the term "organic," and I want to remember one 

thing. NOP organic standards are the gold 

standards. I thank you very much. 

MR. CHAPMAN: Thank you. Questions 

for Tom. Emily. 

MS. OAKLEY: Thank you for your 

comments. I wanted to ask you the same question 

that I asked Mr. Kern. In the absence of fatty 

alcohols, what are organic producers using right 

now for sucker control? 

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MR. HARDING: Well, we just came 

through a whole series of field trials this 

season, and they have tried mineral oils. They 

were doing soybean oils. They were doing peanut 

oils, a number of things, all of them trying 

them. The problem with that is they don't work. 

It's a significant amount of additional labor. 

Almost all of it has to be done, to 

some extent I should say, by hand. It exposes 

them to green tobacco disease, the workers. It's 

a health and wellness issue as well. So frankly 

we're not using anything that really does a good 

job. There are a number of competitive products 

on the market that use similar processes. 

But we know that fatty alcohols work. 

We've had a debate about that. For years, it was 

recognized as a natural product by the detergents 

industry and also the cosmetics industry. It's 

derived from palm kernel. It's a natural oil. 

Where we lose the whole issue and drift over into 

the synthetic side is in the fractionation, the 

esterification process. So we haven't found 

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anything that works like it. 

MR. CHAPMAN: Dave. 

MR. MORTENSEN: Yeah Tom, just so that 

we're clear, because we spent a lot of time 

discussing this and working through this, the 

fatty alcohols are used effectively as a growth 

regulator clipping chemical. 

MR. HARDING: Specifically sucker 

control. 

MR. MORTENSEN: Right, right, and so 

in the absence of the chemical and it sounds like 

these other compounds are not working in field 

trials, it would be done by hand as it used to be 

done before the growth regulators were used, is 

that right? 

MR. HARDING: Yes, and at that time we 

were a little less than 25 percent of the 

marketplace. We're now substantially grown since 

then. We'll probably lose 50 to 60 percent of 

our organic growers. The trouble with that is we 

also lose the sweet potatoes. We also lose many 

other crops that are grown organically. 

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 So we would have a reduction for sure 

in growers, because most of them are pretty 

sophisticated today, small, medium and large. 

They use machines wherever they can. 

MR. CHAPMAN: Emily. 

MR. MORTENSEN: Thanks. 

MS. OAKLEY: So I'm just unclear. I 

don't want to belabor this, but are people still 

using fatty alcohols right now? 

MR. HARDING: Well of course right now 

we don't need them anymore. But at the point, 

yes. We have certifiers arguing about that 

point. One of them approved them on the basis of 

natural. 

We go through the whole petition 

process with him, and there's a debate going on. 

Of course, that's why we came to petition the 

Board, so we could get all of that behind us, and 

really make sure our growers are within the 

system and the framework it is. 

MR. CHAPMAN: Thank you, Tom. 

MR. HARDING: Thank you. 

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MR. CHAPMAN: Okay. It is 1:02 right 

now. We are going to take just an hour break for 

lunch. So we'll be reconvening at two o'clock 

sharp. So folks know, the first two people up 

after break are Peggy Miars and then Mark Kastel. 

We are in recess. 

(Whereupon, the above-entitled matter 

went off the record at 1:02 p.m. until 2:05 p.m.) 

MR. CHAPMAN: All right. If Board 

members can take their seat. Members of the 

public could take their seat, we're about to get 

started. Okay. The majority of the Board is 

present, as well as the DFO, and so we will come 

back into order and proceed with public comment. 

Up first is Peggy Miars, followed by 

Mark Kastel. Peggy, if you can start with your 

name and affiliation for the record. 

MS. MIARS: Good afternoon. I'm Peggy 

Miars, Executive Director of OMRI, the Organic 

Materials Review Institute. I missed the last 

two NOSB meetings due to travel commitments, but 

I understand at the spring meeting this year that 

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some disparaging remarks were made about OMRI 

during public comments. 

So I'm going to start by repeating 

some of the comments I made at the April 2016 

meeting, where I explained OMRI's role in the 

organic community. At that time, an NOSB 

training presentation was posted on the website, 

and on the screen I have a slide from that 

presentation. 

But there is a piece missing, and 

there still is. Okay. OMRI is an important 

stakeholder in the organic community. The NOP, 

in its interim instruction for material review, 

allows certifiers to consult with OMRI, and we 

have worked on technical reports. OMRI has 

provided information and assistance to NOSB 

members whenever requested, and we provide 

comments during meetings to assist the organic 

community. 

Certifiers subscribe to OMRI to 

receive technical assistance, and they rely on 

OMRI product decisions. Certified operations 

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also rely on the OMRI products list when sourcing 

inputs for which the certifier has final 

approval. Consumers rely on the OMRI listed seal 

when they choose products at their home and 

garden retailers. 

So you'll see OMRI commenting at every 

meeting, and we're a resource for material review 

information and technical assistance. So while 

OMRI is not called a certifier in the U.S. 

organic sector, we are accredited by the USDA to 

ISO 17065 to certify input products. 

Since 2011, when the NOSB unanimously 

recommended that the NOP establish accreditation 

for material review organizations or MROs, OMRI 

has advocated for such accreditation. The NOP 

did not implement that recommendation. However, 

in the interim instruction for material review, 

OMRI was named, along with the California 

Department of Food and Agriculture Organic's 

Input Material Program, as MROs that certifiers 

may consult with. 

Being ISO 17065 accredited, OMRI is 

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obligated to accept applications from any company 

that applies. OMRI is also obligated to review 

any input products that submit the required 

information and that meets the scope of our 

review program. Finally, OMRI is obligated to 

list any products that are compliant with the 

organic standards. 

We do not make decisions based on 

personal opinions or a company's reputation. 

Decisions are objective and based on fact. OMRI 

does not take positions for or against materials. 

Our job is to review input product compliance to 

organic standards. 

We are a neutral MRO that was created 

in 1997 as a non-profit organization by and for 

the organic community, and we continue to provide 

a valuable service through our rigorous review 

program. Thank you for allowing me to clarify 

OMRI's role once again. 

MR. CHAPMAN: Thank you, Peggy. Any 

questions for Peggy? Steve. 

MR. ELA: Could you provide your 

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thoughts, and I'm coming back to, like, paper and 

paper pots, and how we as a board should address. 

I mean obviously it's a petition for a product, 

which we don't deal with, but how we can address 

it as a generic issue and deal with the issue of 

adhesives that perhaps are added after the paper 

is made. 

We know there's many adhesives in the 

paper, but do you have any thoughts of how, what 

would be a good way to proceed? 

MS. MIARS: Thank you for that 

question, and I am going to defer that to our 

technical director, who's on the list coming up 

later today. 

MR. CHAPMAN: Any other questions for 

Peggy? Harriet. 

MS. BEHAR: So do -- how do you 

consult with the certifiers then? Do they pay a 

fee to you or can anyone call you? How does that 

work? 

MS. MIARS: We have a subscription 

program. We have a certifier subscription 

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program where they sign a contract with us. We 

are basically a contractor for them doing work 

just like a lab or an inspector or that sort of 

thing. There is an annual subscription fee. We 

also offer subscriptions to the general public. 

Anyone who wants to pay an annual fee can then 

contact us for any kind of technical assistance. 

For example, we have subscribers that 

are libraries, colleges, universities, that sort 

of thing, so that they get our newsletter, they 

get our list and information so that their 

clientele can refer to it. So in other words to 

answer your question, anyone from the public can 

be a subscriber and get assistance from us. 

MR. CHAPMAN: Thank you, Peggy. I'm 

sorry, Dan. 

DR. SEITZ: How do you select people 

to do the technical reviews? In other words, I'm 

very glad to hear that you approach your work 

very objectively and so forth. But someone's 

background, whether that they've been in industry 

or academia, can color sort of the approach that 

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they take to reviewing a material. 

So what are the checks and balances 

that you have to make sure that the technical 

reviews we get are as objective as possible? 

MS. MIARS: So I just want to clarify. 

Are you talking about the product reviews that we 

do or are you talking about technical reports? 

DR. SEITZ: Well, the technical 

reports for the NOSB, if I understood you 

correctly, yeah. 

MS. MIARS: Yes. Well, what we have 

done is we typically rely on our advisory council 

members. These are people with decades of 

experience in the organic community. Many of --

or I won't say many, but some of them have 

Ph.D.s, and so they understand chemistry and 

science. 

So the review is first -- I'll tell 

you about our review process. First we do an 

administrative review, make sure we have all the 

documentation and paper work and so forth. Then 

it moves on to a technical review, where we have 

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a technical reviewer who then looks at the 

ingredients, the manufacturing process and so 

forth, all that kind of detail. 

Once we have all the information and 

all the answers that we need, then the staff puts 

together something called a findings of fact, and 

that spells out all the information and a 

recommendation. For most products, the decision 

then goes to an external review panel, who are 

again made up of people with experience in the 

organic community. We have certifiers and so 

forth that sit on those review panels. 

Some products, if it's really simple 

and we've seen that kind before and it's pretty 

easy, those will be determined by an internal 

review panel of qualified and trained staff. 

MR. CHAPMAN: Emily. 

MS. OAKLEY: Just a clarification. 

That was for your internal product review, right? 

MS. MIARS: Oh. I'm sorry, yes. 

MS. OAKLEY: That's okay. That's 

okay. I just want to be sure that Dan --

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MS. MIARS: I got confused. I asked 

the question, and then I got confused, yes. 

MS. OAKLEY: No, it's okay. I just 

want to make sure Dan understood. 

MS. MIARS: But thank you for 

clarifying that. So anyway, yes. For the 

technical reports, we typically rely on our 

advisory council members as I said, to either 

author or to have a technical review. It depends 

on the substance, it depends on the time line, it 

depends on the availability of people. So 

sometimes the staff will be the author. 

Sometimes our advisory council members will be 

the author. 

MR. CHAPMAN: Thank you, Peggy. 

MS. MIARS: Thank you. 

MR. CHAPMAN: Up next is Mark Kastel. 

On deck is Shannon Helms. Mark, if you could 

start with your name and affiliation. 

MR. KASTEL: Thank you, Mr. Chair. My 

name is Mark Kastel. I am with the Cornucopia 

Institute. We are a farm policy research group. 

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Who owns the organic label? We all do. First of 

all, we wish Dr. Tucker well. She's inheriting a 

troubled program. 

When we founded the commercial organic 

movement in the 1980s and asked Congress to pass 

OFPA, this was viewed as a social and economic 

justice vehicle for family farmers. $50 billion 

a year later, how's it working? Farm gate prices 

for milk are down 25 to 50 percent, 50 percent. 

Farmers are selling out. 

Some organic fresh market vegetable 

producers are telling us that CSA and market 

sales are down as much as 30 percent. They can't 

compete with pseudo-industrial organics or 

hydroponics. Organic world crop producers can't 

compete with phony imports from China or former 

Soviet bloc countries, untrustworthy countries in 

any kind of commerce. 

While the NOP and this Board focuses 

on important microissues, organic farmers are 

losing their livelihoods. Conflicts of interest, 

closing the revolving door. What if we had a 

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former certifier head the NOP? Congress charged 

the USDA with oversight of certifiers 

specifically, and past OIG audits were damning in 

their criticism of the accreditation program. 

What if that farmer, what if that 

former certifier becomes a cheerleader, the 

cheerleader-in-chief at the ACA meetings on 

behalf of the certifiers he's supposed to be 

overseeing? What if he makes secret, behind the 

scenes deals with those certifiers which are 

worth millions to them? 

What if based on FOIA documents, the 

largest certifiers that are found guilty of major 

improprieties are let off the hook? Then what if 

he leaves the USDA and goes to work gaining some 

lucrative consulting contracts with the same 

certifiers that he favored in the decisions while 

he was running the program? How would that look 

to the public? 

What if a former NOP leader overrules 

a certifier and allows an operator to substitute 

a small porch holding maybe three to five percent 

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of the birds in a hen house, when the law clearly 

states that all organic livestock, all must have 

access to the outdoors? 

And then what if that same former NOP 

official waltzes through that proverbial 

revolving door and becomes a lobbyist for the 

same ag producer that that favorable ruling 

benefitted? What if now you can close that 

loophole and close that revolving door? Thank 

you. 

MR. CHAPMAN: Thank you, Mark. 

Questions for Mark? Dan. 

DR. SEITZ: First, I want to say 

Jenny, I really appreciate the NOP's focus on 

enforcement, and I think it's so key, and Mark, 

your organization has for a number of years 

highlighted what you consider to be non-adherence 

to various pasture rules and other aspects of the 

dairy industry. 

So just in a couple of sentences, what 

do you see are the main areas where certain dairy 

farms are not in compliance with the rule, the 

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rules of the NOSB? 

MR. KASTEL: Well first of all, this 

criticism isn't directed at Dr. Tucker, and I'm 

from Missouri, so I'm waiting for them to show 

tangible results from this new program you're 

instituting. So farmers right now can't sell --

farmers can't even go out of business, I'm not 

exaggerating. 

So farmers are on suicide watch, and 

I'm not exaggerating. Their co-ops are getting 

them psychological help. They can't sell their 

cows. They can't -- they have loans on their 

cows. They can't quit milking unless they sell 

their assets. There's no market for organic 

cows. They can't sell their farms. 

So the NOP accreditation program has 

allowed some of these dairies -- I don't have to 

visit them, although if you look at our website 

I've visited them. There's photographs. We 

don't have to hire airplanes to fly over. We've 

spent thousands. 

If you look at the manure management 

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plans, the nutrient management plans that the 

state regulators have publicly available for 

these CAFOs, the average organic farm in this 

country has about one cow per acre. Some of 

these have ten cows per acre, and if you don't 

think that's a funny enough joke, some of those 

CAFOs in their organic systems plan have them 

cutting hay off the same pasture. 

So we don't know how much annual 

growth they cut, but if it was 50 percent, that 

would be an effective stocking rate of 20 cows 

per acre. That ain't funny to me. And then so 

what's the tie-in here with the revolving door, 

conflict of interest, certifiers not doing their 

job, QAI? 

It's a matter of public record. If 

you go to the Cornucopia Institute website, we 

have a tab which is called under Programs, 

Projects called the FOIA reading room, and you 

can see the basis for some of these statement. 

So Shamrock, with thousands of cows in the desert 

outside of Phoenix, was criticized by the USDA, 

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found guilty of breaking the law. 

QAI was criticized. What happened to 

them? Nothing. CCOF, certifier -- I'm almost 

done here, Mr. Chair, thank you. CCOF certified 

Rockview in Amargosa Valley, Nevada. They had 

5,000 cows, 2500 organic. They were forced to 

reduce that to 300 after our complaint. They 

never should have been certified in the first 

place by CCOF. 

Finally Aurora, after the Washington 

Post story gave us all a black eye in this 

community, was found by the NOP to have been 

inspected by their certifier, the Colorado 

Department of Agriculture in November of the 

previous year, after pasture took place. All 

that, Doctor, happened during the last 

administration at the NOP, and the result is that 

farmers are losing their livelihood now. 

So we really applaud the initiative 

that's going on now, cautiously optimistic and 

we'll be hoping to positively critique it when 

it's done. If not, we'll resume our criticism. 

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But thank you for the initiative. 

MR. CHAPMAN: Thank you, Mark. Any 

other questions? Thank you Mark. 

MR. KASTEL: Thank you for the 

opportunity. 

MR. CHAPMAN: Up next is Shannon 

Helms, followed by David Meyer. Shannon, you can 

start with your name and affiliation. 

MS. HELMS: Yes. Hi, my name is 

Shannon Helms. I'm Regulatory Manager for CP 

Kelco. CP Kelco has provided comments in support 

of the relisting of gellan gum and xanthan gum. 

CP Kelco's customers and organic community 

benefit from the use of gums because while they 

are used in very small amounts as ingredients in 

foods and beverages, gums provide options for 

healthier choices in dietary considerations such 

as fat replacers, replacements for gluten or 

replacement for traditional thickeners. 

CP Kelco supports the continued 

listing of gellan gum. Gellan gum is an approved 

additive under the FDA, and gellan meets the FDA 

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definition of a stabilizer and thickener, and as 

such gellan gum may be used to achieve the 

technical and functional effects as listed in the 

standards of identity. 

Gellan gum provides the Organic 

industry with unique properties to formulate 

products for consumers across various application 

segments. Gellan gum can be used in fortified 

beverages to suspend proteins, minerals, 

vitamins, fiber and pulp. Calcium fortified 

beverages such as rice, soy and almond are of 

great interest to the organic community. 

Gellan gum also provides the organic 

community with a non-animal gel source suitable 

for vegetarians, vegans and those with religious 

or dietary restrictions. Based on the unique 

functionality of gellan gum and the numerous 

organic applications, this substance is essential 

to organic food production and should be retained 

on the list. 

Xanthan gum. We would like to 

reiterate our previous request that the NOSB 

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consider listing the substance as a non-synthetic 

under 205.605(a). Xanthan is a natural extracellular polysaccharide, and is produced through 

the natural process of bacterial growth, so it 

may be best placed at 205.605(b). 

Xanthan gum is produced from natural 

sources. Fermentation is a natural process used 

in food production for centuries. Xanthan gum 

contributes unique attributes to food and 

beverages, thus allowing many more organic 

products to be formulated and marketed to the 

consumer. 

Xanthan gum functions as an effective 

thickener, stabilizer and emulsifier, with 

texturizing attributes that are attractive to 

many applications. The typical amounts of 

xanthan gum used are small, less than one percent 

of the process food, and usually less than .25 

percent due to its effectiveness. 

This also makes xanthan gum preferable 

to other gums, which may require much more of the 

addictive to be used to accomplish the same 

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effect. Xanthan gum is used in various food and 

beverage formulations. Xanthan gum is also an 

important ingredient widely used in foods for 

populations with allergens and celiac disease. 

Production of xanthan gum does not 

harm the environment, and aligns with the organic 

principles as it relies on natural processes with 

no harmful metabolites or byproducts. As xanthan 

gum is safe, aligns with organic principles and 

lacks organic alternatives, CP Kelco urges that 

the substance be relisted. 

MR. CHAPMAN: Thank you. Harriet. 

MS. BEHAR: There was a public comment 

that there was a possibility that genetically 

modified organisms are used in the production or 

could be or may be used in the production of 

gellan gum, and I'm wondering if you can speak to 

whether that is a possibility, and if that's 

something that certifiers and material review 

organizations should be looking at when they are 

allowing this substance? 

MS. HELMS: There are possibly 

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products used in the formulation of some gellan 

gums, not our gellan gums, that could be 

considered GM. Many of our gellan gums go 

through a third-party certification for non-GMO, 

and it really is manufacturer to manufacturer. 

MR. CHAPMAN: To clarify that, gellan 

gum can be made non-genetically modified? 

MS. HELMS: Yes, it can. 

MR. CHAPMAN: Thank you. Any other 

questions? 

MS. BEHAR: Have you noticed any 

increase in purchases of gellan gum, especially 

since it seems the natural foods industry is 

moving away from carrageenan? 

MS. HELMS: I'm going to let either 

David or Wanda actually address that. They're 

closer to the sales and the technical, but yes. 

MR. CHAPMAN: Thank you. Up next is 

David Meyer, and then Wanda Jurlina. Dave, you 

can start with your name and affiliation. 

MR. MEYER: Good afternoon. I'm David 

Meyer. I'm the Midwest Technical Service Manager 

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for CP Kelco, and I'll be talking about xanthan 

gum today. So we just heard a little bit about 

it, and I'm going to go through some reasons that 

it's very unique and very important in food 

science, and in making different food products. 

So xanthan gum provides thickening. 

It can provide suspension, it provides cling, and 

one very unique property is that it's coldsoluble, and this is very important in the 

production of a lot of foods. It also has 

excellent syneresis control, which is unique and 

a very important attribute as well. 

It stabilizes emulsions and it 

stabilizes foams. It's used in a very wide range 

of pH, temperature and it is enzyme-stable to 

most enzymes. It provides high viscosity at very 

low concentrations as you just heard, and it's 

not chemically modified. 

So what food applications is xanthan 

gum used in? It's used in dressings and sauces 

and syrups, toppings, baked goods, especially 

gluten-free baked goods, bakery fillings, 

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beverages, dairy and non-dairy, confectionary, 

batters and breadings, low-fat spreads. This is 

a small list of the thousands of different 

products that xanthan gum can be used in. 

One very unique attribute that xanthan 

gum has, it's a very long molecule, and when you 

add shear and you add heat, it actually unwinds 

and unfolds, and then it snaps back into place 

when the heat, when it's cooled down or the shear 

is no longer there. That's very important for 

suspension. So that's why it can be used in 

salad dressings and hold particulates up. 

This slide is really hard to see, I 

understand. But I just want to point out a few. 

This compares xanthan gum to carrageenan to 

gellan to pectin to guar and to locust bean gum 

across many different food products. Some things 

to understand, baked goods in especially glutenfree baked goods, xanthan gum is very unique. 

It's cold-soluble, which is quite 

unique there. So it's very good in dry-mix 

beverages. It's used in dressing and sandwich 

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spreads, as I said. So there's a lot of 

important attributes that it has that makes it 

unique and very important in the food industry. 

Xanthan gum has a high elastic 

modulus, meaning it's very good at suspension, 

and it has very high pseudoplasticity, meaning at 

rest it suspends everything, and then when you 

pump it or you mix it or when you're swallowing 

it, it gets really thin. It thins out almost 

like water under heat or under stress. But when 

you stop, it snaps back into position. 

As I mentioned before, it's coldsoluble and it's salt-stable after hydration, 

which is also very important for many different 

applications. Thank you for your time. 

MR. CHAPMAN: Thank you. Any 

questions for David? Thank you. Up next is 

Wanda Jurlina, and on deck is Robin Hadlock 

Seeley. Wanda, if you'd start with name and 

affiliation. 

MS. JURLINA: Okay, and it's that 

button? Okay. All right. Wanda Jurlina. I am 

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Technical Service Manager for the Americas for CP 

Kelco. I've spent my entire career working with 

hydrocolloids, and I'm going to be talking to you 

today about gellan gum. 

So as I've talked to you before in the 

past, when we talk about these hydrocolloids and 

gums, people kind of lump them all together. But 

each one of them has a very unique set of 

properties. Up here, I've put up a slide that's 

talking specifically about those that can create 

a gel. David's just told you about gellan gum, 

which is a thickening ingredient and very unique 

in its properties. 

I'm going to be talking about both 

high and low acyl gellan gum. High acyl is the 

one that is up for relisting at this time. Low 

acyl we've submitted a petition, and would like 

to see it added to the list. 

If you look at these properties like 

solubility, whether they can be used in 

applications like capsules, how heat-stable the 

gels are, the functionality of these ingredients, 

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you'll see that there's a range of Xs across the 

chart, designating different places where each 

one of these gelling agents can perform. 

The thing to see with these really is 

that not all of them can be used for everything. 

So when talking a little bit more about the two 

different types of gellan gums, high acyl is the 

one that is on the right-hand side. So these 

ingredients that we're talking about are all 

polysaccharides. 

So long chains of sugar molecules 

linked together. In nature, the bacteria 

sphingomonas elodea that makes gellan gum puts 

some side chains on that molecule. That's the 

high acyl. You've got two side chains, one on 

the top and one on the bottom, an acetate and a 

glycerate group. 

If we leave those molecules on, we get 

the high acyl with its unique properties. We 

remove those side chains and we have low acyl, 

which has very unique properties as well. If we 

look at those properties and we start with high 

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acyl, because that's the one that's already 

approved as a non-synthetic, it's really pretty 

easy to use in the world of gellan gum. 

It gives us opaque gels and 

suspensions. We use it extensively in non-dairy 

milks and in organic dairy milks for suspension 

of nutrients, flavoring components. The low acyl 

gellan gum, one of the areas where it has some 

unique properties really comes down to that 

capsule application, where it has some stability 

benefits over other ingredients. 

I've listed here a few of the 

applications just to familiarize you with the 

types of products that they go in, give you a 

feel for where they have overlap, but where 

they're each unique. They offer the organic 

producers alternatives to other ingredients that 

are on the list at this time. 

MR. CHAPMAN: Questions for Wanda? 

Harriet. 

MS. BEHAR: When gellan gum was first 

put on the National List, how come it was only 

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high acyl? Was the petition for --

MS. JURLINA: I would say that's an 

excellent question, and I don't know if you can 

find good results or good information within the 

program's records. We originally submitted the 

petition for both of them to be added, and were 

told that only high acyl would be added. 

MR. CHAPMAN: Steve. 

MR. ELA: So we also have a petition 

before us now on tamarind seed gum. I know each 

of these gums have different properties, I fully 

understand that. At some point, I mean even 

though they have different properties, is there a 

maximum number of gums that we need to pretty 

well cover the spectrum? 

MS. JURLINA: It depends on how 

efficient a manufacturer wants to be in solving a 

specific problem. So tamarind seed gum has been 

promoted to the dressings and sauces industry as 

a clean label thickening ingredient for those 

types of applications. It has a pretty unique 

texture and consistency, can be along the lines 

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of very gloppy and very structured. 

So a lot of it comes down to what a 

particular manufacturer is hoping to do with 

their products. They're trying to produce an 

organic product that looks like a commercial nonorganic product at this time. It will be 

challenging to do that with something like 

tamarind seed gum. 

MR. CHAPMAN: Thank you. 

MS. JURLINA: All right, thank you. 

MR. CHAPMAN: Up next is Robin, 

followed by Jessica Walden on deck. Robin, if 

you can start with your name and affiliation. 

MS. HADLOCK SEELEY: Yes. Hello from 

Down East Maine. I am Robin Hadlock Seeley, 

recently retired from Cornell University, where I 

served as a senior research associate in the 

Department of Ecology and Evolutionary Biology 

and a faculty fellow at the Atkinson Center for a 

Sustainable Future. 

I'm now a faculty affiliate at the 

School of Marine Science and Ocean Engineering at 

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the University of New Hampshire. One of my 

research foci is state and federal policy on 

seaweed harvesting around the North Atlantic 

Ocean, particularly the U.S. and New England, and 

the environmental impacts of seaweed harvesting. 

The best way to gain an understanding 

of the importance of preserving old growth 

seaweed forests is to dive underwater or to spend 

hours watching shore birds foraging in the 

seaweed. But since we can't do that today, let's 

just spend a few moments looking at some 

underwater video, looking at how vulnerable fish 

populations use these forests. 

(Video plays.) 

MS. HADLOCK SEELEY: And I will 

mention that the National Maine Fisheries Service 

has recently designated these rockweed beds as 

essential fish habitat for juvenile cod, which 

are in deep, deep trouble in the New England 

area. 

These rockweed forests, also known as 

kelp in the organic market, are suffering under 

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the heavy demands for organic agricultural 

products that contain this seaweed. How much are 

they suffering? Dr. Heike Lotze of Dalhousie 

University in Nova Scotia recently observes that 

we don't have any old growth rockweed forests 

left in Nova Scotia, because everything has been 

harvested. 

The seaweed industry in Maine has 

admitted that the demand for organic ascophyllum 

or rockweed or kelp drives them to take seaweed 

from conservation areas in Maine, wild islands 

under protection from the U.S. Fish and Wildlife 

Service, Maine Coast Heritage Trust, the Nature 

Conservancy, National Audubon and others. 

One pressing question for the NOSB and 

the organic community is whether seaweed harvests 

should be and can be held to the wild crop 

harvest standard in 205.207. There's a lot of 

debate about this, but I want to close by 

pointing out that in the comments submitted to 

you, there have been a lot of good ideas and a 

lot of cautionary notes. 

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A working group is essential, I think, 

to hash out the details of how this could work, 

and find common ground, examining impacts on the 

organic sector and to wild native marine 

ecosystems. 

So please support the notion of 

creating a working group, so the good ideas that 

have already been proposed can be further 

explored and teased apart for organic integrity, 

but also to keep the organic label from degrading 

the integrity of this wild native marine 

ecosystem. 

MR. CHAPMAN: Emily. 

MS. OAKLEY: Thank you, Robin, for 

your comments. Could you elaborate a little bit, 

based on the written comments that you've 

provided on some thoughts for the working group 

and ways that you would see it being led and 

being most effective. 

MS. HADLOCK SEELEY: Yes. In my 

written comments, I suggested that it could be 

co-led by a marine conservation biologist and an 

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industry member, so that those two sides could 

lead and there wouldn't be dominance by one side 

or the other. I've been in groups where a 

professional facilitator is involved, and that 

was extremely helpful when the sides are quite 

far apart. 

Another thing I wanted to mention is 

that this working group could go through the 

sustainability certification from the marine -- I 

forgot what the initials are, MSC, from MSC. Not 

that you would adopt the MSC standards wholesale, 

but there's certainly elements of the MSC 

certification that they spent a long time working 

through that would be helpful to NOP, I think. 

MR. CHAPMAN: Rick. 

DR. GREENWOOD: A quick question in 

terms of percentage of harvest. I assume all of 

the kelp is not harvested by organic individuals. 

So do you have an idea if it's 50-50 or 80-30, 

and where I'm going with this is maybe it's a 

broader issue than just for the organic community 

to look at. 

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MS. HADLOCK SEELEY: Oh, it certainly 

is a broader issue, but you guys are organic, so 

I'm coming to talk about the organic. I have no 

access to data that would tell me how much of the 

market is organic or not. Emily visited Maine, 

and she might know better, but I certainly don't 

know. 

MR. CHAPMAN: Thank you. Dan. 

DR. SEITZ: Well, Rick just asked one 

of my questions, but my other question is are 

these kelp beds being harvested illegally? You 

mentioned that there's harvesting going on in 

protected areas, places where fishermen have 

certain rights over protecting the beds for the 

sake of the fishing industry. So are there still 

just open season on these kelp beds, or are 

things happening illegally? 

MS. HADLOCK SEELEY: So for 90 percent 

of the coast, there's virtually no regulations on 

seaweed harvest. There's no limit to what you 

can take, the amount you can take. There's no 

limit on where you can take it all -- except for 

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the federal lands. The federal lands are off 

limits, but everything else is open. 

And right now, there's a lawsuit at 

the level of the Maine Supreme Court, because 

land owners, including conservation land owners, 

are making the case that they have ability to 

turn seaweed harvesters away because of their 

ownership of the seaweed. But that's still in 

the courts and quite complicated. So we're just 

waiting for a decision on that. 

MR. CHAPMAN: Asa. 

MR. BRADMAN: You just hinted at the 

question I was going to ask, but who -- when you 

say land ownership, you know, and we're talking 

about a marine environment where you know in many 

places once you're out past the mean high tide 

mark, it's not -- land owners don't control that 

environment. So I'm curious about tensions 

between both federal, state and then individual 

jurisdiction, and how to approach that. 

Because I know for me it's distressing 

to hear about, you know, possibly damaging a wild 

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resource for organic agriculture. 

MS. HADLOCK SEELEY: Well, this could 

be a 30-minute law lecture, but in Maine and 

Massachusetts, Maine and Massachusetts are 

subject to the colonial ordinance, which means 

that the upland land owner owns down to mean low 

water, not high water the way it is in other 

states in New England, but low water. 

So the upland land owner actually owns 

everything in the inner tidal zone. But subject 

to fishing, fowling and navigational rights that 

were in that 1620 ordinance. The question is, is 

seaweed part of the public trust right to fish or 

not. Now the seaweed companies are saying that 

seaweed is a fish, and so by rights because they 

come in a boat and take it in a boat, it's 

therefore a fish. 

So by the colonial ordinance, they are 

within their rights to come in and fish for a 

plant, and the land owners are saying no, it's 

really a plant. So since it's a plant, you don't 

have a public trust right and come and take it, 

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and that's what the lawsuit is about. 

So any minute now we expect the high 

court of Maine to come and tell us whether 

seaweed is really a fish or not a fish. 

MR. CHAPMAN: Briefly. 

MS. OAKLEY: Even within this 

discussion, you know, we're conflating 

ascophyllum nodosum with kelp, which you and 

others have helped us realize over time it's 

actually not kelp. And so one of the questions 

that we had in the discussion document was the 

feasibility of listing the species on the 

ingredients list, to help understand what it is 

that a producer is using. 

I know some of the public comments 

actually referred to a desire not to associate 

rockweed with kelp, so that consumers aren't 

confused by the potential changes in benefits. 

What are your thoughts on listing species? 

MS. HADLOCK SEELEY: Oh I think they 

absolutely have to be listed, and there's 

elements of the seaweed industry that request 

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that it be separated out too, because sometimes a 

consumer will want to buy rockweed for one 

purpose and go to a bag and see that it's listed 

as kelp when it really is rockweed. Yeah, I 

think that's essential, because otherwise it 

misleads the consumer. 

And part of that is a biological 

reason, because consumers are getting more and 

more educated about these seaweeds. They know 

that kelp grows really quickly. It regrows a 

centimeter a day, whereas rockweed will grow four 

centimeters in a growing season. So educated 

consumers are now wanting to turn away from 

rockweed and use the rapidly growing kelp, not 

only because it grows rapidly but because it can 

also be farmed. 

Rockweed can't be farmed. So if you 

buy kelp, you'll often be buying something that 

was farmed. But you'll never be buying farmed 

rockweed, because it doesn't exist. 

MR. CHAPMAN: Thank you. 

MS. HADLOCK SEELEY: Thank you. 

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MR. CHAPMAN: Up next is Jessica 

Walden, followed by Alexis Randolph. Jessica, if 

you can start with your name and affiliation. 

MS. WALDEN: Okay. Hello, I'm Jessica 

Walden with QAI. Today I'll be commenting on the 

sunset material calcium carbonate. The Handling 

Subcommittee proposal doesn't describe whether 

certain forms of calcium carbonate, namely 

precipitated calcium carbonate, are covered under 

the subcommittee's recommendation to approve its 

continued listing. 

Certifiers often refer to the 

technical report when determining whether a 

particular form of a material is covered under 

that national listing of the material. So if you 

look at the most recent TR posted in 2018, the TR 

refers to precipitated calcium carbonate as 

synthetic, which is confusing. 

It's unclear whether or not the 

authors of the TR are aware of the NOP's 

classification of materials document and criteria 

for determining synthetic versus non-synthetic. 

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The TAP review carried out in 1995 did include 

precipitated calcium carbonate as one of the 

other names for calcium carbonate that was 

approved for listing way back in the day. 

This contributed to the allowance of 

precipitated calcium carbonate, I'll call it PCC 

from this point onward, in processed organic 

products by organic certifiers. So we suggest 

that the NOSB clarify that the TRs are not 

necessarily the place to inform certifiers and 

the industry of the formal material 

classification status, and that it is the NOSB's 

responsibility during their review of the 

materials to make that determination. 

QAI's written comments pointed out 

that the starting substance is mined calcium 

carbonate, which does undergo a chemical change 

during the purification process, and then is 

reformed into calcium carbonate. So this is the 

PCC processing steps. In other words, the 

starting material is chemically the same as the 

final material, which according to the NOP 

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decision tree would result in a non-synthetic 

material. 

The situation is similar to 

purification steps for other non-synthetic 

materials on the National List like lactic acid 

and citric acid, which QAI discusses in greater 

detail in our written comments. So we hope that 

the final recommendation for calcium carbonate 

will address the following: 

Clarification that the TR should not 

be the place to advise the industry on the final 

material classification; clarifying that where a 

non-synthetic material may have gone through a 

chemical change during purification steps, if it 

is reformed into a pure grade of the starting 

non-synthetic material, the classification status 

of the purified product does not change, since 

the final product is a purified version of the 

starting material and not a new material that has 

been created through a chemical reaction. 

Or, that you clarify that this 

particular issue will be addressed in the future 

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by the NOSB, but for now the status of PCC is not 

affected while further research is carried out. 

Thank you. 

MR. CHAPMAN: Scott. 

MR. RICE: Thanks for your comments, 

Jessica, and I know Oregon Tilth also expressed 

similar observations. One question for you. 

Would you say there's any other info in the most 

recent TR that would suggest a synthetic 

classification, or is it just perhaps a different 

read or not recognizing the decision tree? 

MS. WALDEN: The TR is a little bit 

confusing. I have read it a couple of times and 

in one place it talks about the main 

manufacturing process as being this particular 

process, where a chemical change does exist, and 

then later it calls it out as a synthetic form of 

calcium carbonate. 

So I think it really just -- it was 

hard for me to follow, but because we rely on, 

you know, as we're a certifier for reviewing the 

calcium carbonate, if we're looking at a PCC spec 

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sheet, and under the TR that's classified as or 

called out as synthetic, then we would think that 

that material's not allowed under the National 

List, under NOP. 

So I think the TR informs how calcium 

carbonate can be manufactured, but it's just 

unclear which would be allowed under the National 

List listing and which wouldn't. 

MR. RICE: So I guess a follow-up for 

the program in terms of a process to address 

this, would that be, in terms of respecting how 

that decision tree is used by a certifier or by 

the TR, I'm not recalling an instance where we've 

run into that, and would the process be to 

address something like that? 

DR. PAUL LEWIS: Thanks, Scott. So I 

think the best way to look at this is relying on 

a decision tree that is shared in terms of the 

TR. Again, it's just a document that the Board 

uses to help in terms of developing 

recommendations, and the Board can look at the TR 

as a guide. But it's not the sole document in 

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terms of providing direction, providing decision 

tree. 

Obviously for the public to look at 

the recommendations that the Board provides, 

taking into account the TR and public comments 

that are brought up at a meeting like this. 

MR. RICE: Thank you. 

MR. CHAPMAN: Other questions? 

Harriet. 

MS. BEHAR: Would this bring up an 

issue that perhaps the PCC should be petitioned 

for 605(b)? 

MS. WALDEN: Well, I guess it depends 

on how it's assessed. I don't think there was an 

opportunity for the Handling Subcommittee to 

actually make determination on this particular 

form of calcium carbonate because it wasn't 

included in the proposal. 

You know, QAI would look at it as it 

would be a non-synthetic material based on 

precedent with other non-synthetic materials on 

the National List because it is a purification 

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step. It's not forming a new material. But it 

would be up to the subcommittee to look at it and 

make the determination based on the decision 

tree. But I don't know, think it needs to be 

petitioned. It's just rather including that in a 

review. 

MR. CHAPMAN: So in looking at the 

PPM, the Policies and Procedures Manual, a 

technical review is defined as a report prepared 

by a third-party expert under contract addressing 

the environment, human and industrial impact of a 

petitioned material per OFPA and regulatory 

evaluation criteria, to aid in the thorough 

evaluation of that material by the NOSB. 

So in our own definition, it does not 

refer to it as a tool to be used by certifiers to 

make determinations, or that it being a 

determining document, rather an aid to the NOSB 

itself. But you don't think that is sufficient? 

MS. WALDEN: No. I think that that is 

completely fine, so long as the -- I guess then 

the proposals or the final recommendations needs 

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to encompass the forms that are being used, 

perhaps in a more thorough fashion, at least for 

this material. 

Maybe it wasn't necessarily known of 

the forms that are used in handling, but yeah. 

So there needs to be -- something needs --

certifiers need to be able to look somewhere, to 

try to determine whether a material would be 

included. 

Or maybe not. Maybe we just assess 

it. But it causes confusion amongst certifiers 

about the status. So it's just letting you know. 

MR. CHAPMAN: Thank you. Any other 

questions? Seeing none, thank you, Jessica. 

MS. WALDEN: Thank you. 

MR. CHAPMAN: Up next is Alexis, 

followed by Charlotte Vallaeys. 

MS. RANDOLPH: Okay, this one? 

MR. CHAPMAN: If you could start with 

your name and affiliation. 

MS. RANDOLPH: Okay, thanks. Hi, 

everybody. My name is Alexis Randolph. I am 

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with QAI, an organic certification agency from 

San Diego, California. I'm here today supporting 

the proposal for a risk assessment approach for 

accreditation. 

QAI has a very robust risk assessment 

program for our own operators, and I'd like to 

share some concepts with the Board and NOP. In 

our industry, risk is a loss of organic 

integrity. Determined by the likelihood it will 

happen, given the facts available, risk factors 

can be a combination of elements applicable to 

all operations and specific to certain operation 

types. 

Potential for loss of organic 

integrity increases when an operation has 

multiple risk elements at play. Additionally, 

some risk factors can be significant as they 

indicate an already compromised system. QAI 

applies a risk assessment three times in the 

annual certification process for each operator: 

at application review, post-inspection and after 

the operator mitigates any corrective actions. 

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We utilize a scoring system that 

results in a high, medium or low risk, and each 

risk factor has a weighted value. Here's an 

example of some questions and our method used 

when applied to all operators. A number one is 

added to the pink column by the reviewer for each 

item applicable to that operator. 

You can see questions have been given 

a weight value of five to twenty points, and an 

item such as prior suspension indicates a 

previously compromised system. Therefore, it has 

more weight in the risk calculation. Whereas an 

operator using a lot of inputs is something to 

look closely at, but isn't in itself a 

significant risk. 

The form calculates a risk score in 

the right-hand column and the higher the total 

score, the higher the risk. We have 32 total 

risk factors for operators. This is just a few, 

but you can see that they fall into three basic 

categories: operator history, commitment to 

organic and site-specific conditions. 

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The NOSB recommendation has done a 

nice job identifying risks across all these areas 

for evaluation of certifiers. Commitment is 

important and sometimes overlooked. I think a 

few more items in this category could be added 

once the NOP takes up the proposal, such as 

attending NOP trainings, this NOSB meeting, 

online webinars and other activities that 

indicate the certification agency is engaged and 

staying current on the issues. 

It's important to have an outcomebased action from any assessment. QAI's outcomes 

include inspection frequency, additional 

sampling, unannounced visits, inspector selection 

and specific instructions that focus on specific 

areas in the next audit. High risk operators 

will always have additional actions taken. 

For medium risk operators, our file 

reviewers have latitude to decide if additional 

inspections or sampling is mandatory prior to 

certification, even though the operator did not 

score as a high risk. 

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Low risk operators may also randomly 

be selected for five percent unannounced or 

sampling, or they're otherwise not on our radar. 

The NOSB recommendation is an excellent start for 

risk assessment programs are never static. 

It's important to analyze the 

effectiveness. How many high risk scores are 

there, did the result match your experience with 

the company and if not what needs to be adjusted. 

Lastly, risk assessments are just one 

tool. We always need to focus on the big 

picture. Thank you. 

MR. CHAPMAN: Questions. Scott. 

MR. RICE: Thanks, Alexis. I 

appreciate all your comments here and written. I 

think you echoed some other comments from the 

public on this being not an exhaustive list, and 

we tried to communicate as well of just a 

starting point. So I think having the metric of 

risk assessment is a really great tool as well, 

and I think the intent of the proposal is to give 

the program something to jump off from and 

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continue to evolve and work on and keep 

improving. 

I think similar to the inspector 

qualifications discussions that we've had, I 

think it's the interest of the Board and the 

community to continue that dialogue with the 

program, and not just have this be something that 

is delivered and never seen again. So I think 

your comments are a good stepping off point for 

that. 

MS. RANDOLPH: Thank you. As far as 

continuous improvement process, we have the 

starter risk assessment program based on the EU 

standards requiring it for operators in order to 

determine how many annual inspections to have. 

Once we started that, we realized the value in it 

and we continue to refine our program year after 

year. 

So I look forward to the NOP 

implementing such a program for their 

accreditation process, and I think it will be 

beneficial for everyone and be refined over the 

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years to come. So thank you very much. 

MR. CHAPMAN: I have a question for 

you too. 

MS. RANDOLPH: Sorry. 

MR. CHAPMAN: Hold on. Are you able 

to share your 16 risk assessments? Yours is for 

the certifier not --

MS. RANDOLPH: Correct. 

MR. CHAPMAN: Yeah, yeah. 

MS. RANDOLPH: Yeah. 

MR. CHAPMAN: So are you able to share 

that to the open docket? 

MS. RANDOLPH: I am able to share it. 

This was very high level. Three minutes is hard. 

It's super-complex. So it's much more complex 

than what I just presented, because we go into a 

lot of the detail about how did we decide what 

the risk factors are, and then how do we verify 

those with operators, sort of along the lines of 

what the NOSB proposal looked like in terms of 

what steps to take. 

So I can share that, but you'll 

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probably have questions. So I'm happy to do that 

and happy to answer any questions by the Board or 

the program afterwards. 

MR. CHAPMAN: Yes, that would be 

great. How common of a practice is this amongst 

certifiers, the risk assessment, to the best of 

your knowledge? 

MS. RANDOLPH: Well, I mean to my 

knowledge, I know it's very common with 

certifiers that certify internationally. Like I 

said, it's a requirement for the EU, and 

certifiers are also always sharing information 

and our best practices with each other. So I 

think more certifiers have been taking this on as 

one tool. 

MR. CHAPMAN: All right. But each 

certifier kind of sets their own criteria and 

weightings? 

MS. RANDOLPH: Yes, yes. Each 

certifier sets up their own system, and then 

actually our -- our assessment system is looked 

at when we have our EU accreditation visits. 

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MR. CHAPMAN: Okay, thank you. 

MS. RANDOLPH: Yes. 

MR. CHAPMAN: Thank you. I keep 

seeing movement from Dan. I assume he's raising 

his hand, but I think he's just typing. Sorry. 

(Laughter.) 

MR. CHAPMAN: Up next is Charlotte, 

and on deck is Jackie DeMinter. Charlotte, if 

you could start with your name and affiliation. 

MS. VALLAEYS: Good afternoon. My 

name is Charlotte Vallaeys. I'm a senior policy 

analyst with Consumer Reports, an independent 

non-profit organization that works side by side 

with consumers to create a fair, safer and 

healthier world. One of our areas of focus is 

food labels, which we rate to empower consumers 

with knowledge to make better and more informed 

decisions when shopping for food. 

We also do nutrition and sensory 

ratings of packaged foods, and we recently 

incorporated whether a food is certified organic 

into our nutrition rating system. 

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Copies of the October Consumer Reports 

magazine are available to you and for you on the 

table back there. So please check out our 

nutrition bar ratings and our note about why we 

give more points to products that are USDA 

organic. 

On the magazine's cover, it tells the 

story of banned drugs found in meat. Our food 

system is broken in many ways. We think it's 

critical therefore for consumers to have access 

to foods from a system that is backed by strong 

and meaningful standards, with additional 

oversight and enforcement, and that is easily 

identified on the foods label. 

We end our cover story by telling 

consumers that one thing they can do is choose 

organic. But when the Organic label falls short, 

we ask you to strengthen the standards. Thank 

you to the NOSB's Livestock Subcommittee for 

putting in the work plan request, and we urge the 

USDA to support it, prohibiting the use of 

antibiotics in organic agriculture without 

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exceptions. 

Eliminating the routine use of 

antibiotics in animals that aren't sick is a top 

priority for Consumer Reports, given the 

connection between the overuse of antibiotics and 

the development of antibiotic resistance, 

especially in pathogens. 

While the organic standards prohibit 

the use of antibiotics, there is an exception. 

OFPA exempts day-old chicks from organic 

management. That means that all organic chickens 

and turkeys could be treated with antibiotics 

while they're still in the egg and on the first 

day of life, and sold as organic. 

We often write about what organic 

means. Again, in this magazine you'll see it in 

the nutrition bar story. When we're talking 

about livestock and meat and poultry, can we 

write organic means no antibiotics were used? 

No, we can't. We have to put in a disclaimer, 

except for day-old poultry. Can you please just 

fix this? 

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We asked the USDA to take action on 

this for the first time in 2015. The Secretary 

of Agriculture at the time responded, quote, the 

NOP will be requesting that the NOSB provide a 

recommendation on management practices for dayold chicks, end quote. This is not a 

controversial issue. 

Even Tyson and Purdue have entirely 

stopped using antibiotics in hatcheries and dayold chicks. At Consumer Reports, we're not 

beholden to any interests other than telling 

consumers the truth, and we'd like the truth to 

be that organic means no antibiotics, period. 

Thank you. 

MR. CHAPMAN: Ashley. 

MS. SWAFFAR: Charlotte, I just want 

to say thank you for all of your diligence in 

bringing this up for many, many years. Obviously 

you've heard what the program said this morning, 

that it would require a change in OFPA. I know 

you've done some legal analysis on that. Could 

you kind of go into what, how you see we actually 

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could work on this? 

MS. VALLAEYS: Sure, yes. The fact 

that the exemption is in OFPA is obviously an 

issue. So before we brought this to the 

Secretary of Agriculture in 2015, we had a full 

legal analysis done. Essentially what it boils 

down to, well first of all I encourage everybody 

to read it. The summary of it is in the comments 

that we submitted. 

But what it boils down to is that OFPA 

exempts the day-old poultry from organic 

management in general. It does not prohibit that 

a singular component of the organic standards, in 

this case prohibiting antibiotics, be applied to 

day-old poultry. 

So we're not asking change OFPA, 

require organic management as a whole for day-old 

poultry. We're just asking in the regulations to 

put in a singular prohibition on antibiotics, 

that's it. So according to our legal analysis, 

that requires NOSB action. In 2015 the Secretary 

of Agriculture said that that would be requested. 

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So we think it shouldn't be that difficult to do. 

MS. SWAFFAR: And Charlotte, just like 

told the commenter earlier this morning, I think 

we need to elevate this to the Secretary level 

again. 

MS. VALLAEYS: I agree, and we will. 

MS. SWAFFAR: Yeah, thank you. 

MS. SWAFFAR: Charlotte, I really 

appreciate that Consumer Reports is focusing on 

the health benefits of eating organics. 

Occasionally, there are backlashes against 

organic food, and there was a study that came out 

of Stanford that claimed that there's no 

difference between organic food and 

conventionally grown food, and was picked up I 

saw by a magazine like the Harvard Health 

Magazine picked that up and some others. 

Have you looked at those studies, and 

what do you think is happening in those types of 

studies that get pretty wide circulation, because 

they're somewhat sensational in terms of their 

findings? 

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 MS. VALLAEYS: So we actually wrote a 

story on Monday. It's on CR.org under News, and 

it's reporting on the new study published in 

JAMA, and it's prospective cohort study out of 

France that found a 25 percent risk reduction for 

breast cancer and lymphoma when people eat 

organic food. So again, after we posted that 

story there was backlash to us picking it up and 

telling consumers about the benefits. 

What we see consistently is that they 

tend to criticize that it wasn't a well-run 

study. It absolutely was, or that you can't draw 

a conclusion based on one study, which we agree 

with. So you know, we do what we can to tell 

consumers when studies like this come out and 

they support eating organic, that it doesn't 

prove anything, but it's another piece of 

evidence to support this kind of bigger picture 

that organic does have health benefits. 

MR. CHAPMAN: Thank you. 

MS. VALLAEYS: Thank you. 

MR. CHAPMAN: Up next is Jackie, and 

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on deck is Rudy Amador. Jackie, if you can 

start with your name and affiliation. 

MS. DeMINTER: Good afternoon. My 

name is Jackie DeMinter. I am the Certification 

Policy Manager at MOSA. We certify about 2,125 

operations throughout the United States. I will 

be commenting today on paper pots. 

At the spring meeting, I commented on 

this topic to bring your awareness to the issue, 

and since then I've taken part in submitting a 

petition for your consideration. While the 

petitions were for a specific paper chain pot, 

MOSA recognizes that all paper pots are being 

impacted by this conversation. 

In 2019, we will have to prohibit all 

paper pots including newspaper pots, recycled 

cardboard boxes and the paper chain pots. While 

we weren't the first certifier to allow paper to 

be used as a pot, we were probably the first to 

allow the paper chain pots. The rationale then 

is the same as it now. 

Paper is on the National List as a 

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compost feedstock in mulch. The additives used 

in the paper pots are included in other paper we 

would allow. In fact, we would allow these exact 

pots to be removed and composted. Secondarily, 

but worthy of mention, the additives are also 

allowed as inert substances in pesticides. 

Originally, we didn't consider the 

recycled nature of the paper. However, with the 

publication of 50.34-1, we now align with the 

best practices recently presented to certifiers 

for the review of paper, which supported a 

liberal interpretation of what it means to be 

recycled, and did not feel that an analysis of 

the full manufacturing process of the paper is 

necessary. 

Allowable sources of recycled paper 

include any paper that has been diverted from a 

waste stream, has been previously used in any 

manner, or includes any amount of recycled 

content, and of course newspaper including virgin 

newsprint. Recognizing this new focus on the 

recycled nature of paper, the petition broadly 

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lists other paper and includes hemp paper. 

It would seem contrary to practical 

judgment to say that paper or fibers from organic 

hemp could not be used to make a paper pot. 

Farmer comments have spoken to the efficacy of 

the paper pot system, specifically the reduction 

of fossil fuel use, plastic, mulch, money, labor, 

time, etcetera. There has to be value on 

sustainability in organics. 

Rather than a specific focus on this 

one paper chain pot, we ask that you consider the 

generic category of paper as a crop production 

aid in your discussions, and we also again ask 

the NOP to extend the phase out requirement. We 

approve paper pots in good faith in what we 

thought was solid rationale and practical 

application of the standards, and so did many 

other certifiers. 

We recognize that the standards do not 

spell out everything for us, and we don't expect 

them to. There is room for interpretation, and 

try as we might, certifiers do not always agree. 

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We'd argue that far more farmers have been 

allowed to use the paper pot system than have not 

been, and we also certify a number of farmers 

that use other paper pots too. Seeing negative 

impacts to farms using any paper pots is 

disheartening. 

MR. CHAPMAN: Emily. 

MS. DeMINTER: I had one more 

sentence, to thank the NOSB for their work. 

(Laughter.) 

MR. CHAPMAN: You can always add that 

in. 

MS. OAKLEY: This is a question for 

the program. Could we consider this paper 

recycled by the time it's applied to the soil as 

a mulch for the transplant itself, because it was 

originally used in the greenhouse as a first-time 

use for growing the seedling? 

DR. TUCKER: So I think we're hearing 

a lot of great information on paper pots at this 

meeting. I look forward to taking this feedback 

back. So seriously, keep the comments coming. 

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This is very, very helpful. I think this is why 

we have public meetings, is to have this kind of 

diversity of opinion. So it's all useful. 

MR. CHAPMAN: Harriet. 

MS. BEHAR: So again, also for Jenny, 

I mean if someone rolled up newspaper into a pot, 

I mean are we -- so I think the reason for MOSA 

and the other certifiers was they were looking at 

the generic material, and not its necessarily its 

use. So we see now that we need it listed and 

annotated by a production aid. 

But we also feel that the -- at least 

I do, that the original rationale for allowing it 

was not highly flawed in putting something that 

wasn't already allowed on the land. 

So again, and I think there were quite 

a few certifiers in the public comment who said 

they did not allow it, but they did agree to an 

extended phase out period, to give the NOSB their 

time to put it on the National List in the 

correct place with the right annotation. 

MR. CHAPMAN: Do we have a question 

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coming? 

MS. BEHAR: So the question is what do 

you think the economic impact will be on your 

producers, and would there be any economic impact 

to MOSA if the paper pots do go away at the end 

of this year? 

MS. DeMINTER: I certainly think that 

there will be economic impact to MOSA, because we 

have had clients tell us that they will have to 

choose between their certification and the pots, 

and the pots are going to win, because the pots 

are what makes their farm sustainable. 

Certification is secondary to that farming. 

Their clients know they grow their 

products organically, so that doesn't sound like 

as big of a factor in their business 

considerations. But I certainly don't want to 

speak to the farmers, and there's a number of 

them out here that I know are going to be 

speaking. 

In fact, the petitioner John 

Hendrickson is here, and he'll be speaking in 

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just a bit, and can speak far more about the 

farmers that he works with on the ground and that 

use this system. As far as we are concerned, you 

know, there will be clients that aren't able to 

or will need to choose to certify, excuse me, 

drop certification for either a portion of their 

operation or their entire operation. It might 

just not become feasible for them anymore. 

MR. CHAPMAN: Thank you. Jenny, and 

then Steve. 

DR. TUCKER: I just wanted to make a 

brief comment on material reviews, and this is 

sort of a general comment for folks. When we do 

get a material conflict at the NOP level, we do 

take into consideration good faith reviews. No 

certifier received a notice of non-compliance for 

having approved paper pots. 

MS. DeMINTER: Thank you for that. 

DR. TUCKER: So I think that as I 

shared this morning, there were good reasons why 

certifiers said they were allowed. There were 

good reasons why they said they weren't, and we 

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agreed with that group. So but that doesn't mean 

that we -- material reviews are really important, 

and are really, really important for certifiers 

to do well, and occasionally certifiers are going 

to come to different answers. 

If we find that a certifier really did 

a frankly crappy job at reviewing a material, 

then that can lead to a notice of non-compliance, 

because they really need to raise their game on 

material reviews. But I did want to emphasize 

that certifiers who did approve paper pots did 

not receive any kind of non-compliance on this 

issue. 

MS. DeMINTER: If you didn't hear me, 

I said thank you for that. 

DR. TUCKER: Okay, thank you. 

MR. CHAPMAN: And we do have the 

administrator saying "crappy" in the record now, 

so that's also pretty sweet. Steve. 

MR. ELA: Same question I've been 

asking others, paper pots. As we look in Crop 

Subcommittee on that petition, and we've heard 

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that probably --

I mean we can't do it as a product, so 

we have to make the generic, which I mean I think 

we're kind of coming around from hearing comments 

here to paper as a planting aid, how would you --

how would you approach this, because it's not a 

material. It's a whole, it's hemp, it's paper, 

it's adhesives. 

How would you suggest we approach that 

to list it without opening up the whole world to 

any adhesive out here, or limiting the amount of 

adhesive or trying to make it as concise and 

focused as we can while not running into this 

problem in the future? 

MS. DeMINTER: I think that we would 

encourage you to follow the same process you 

followed with compost, feedstock and mulch. The 

technical reviews there, as Jo Mirenda pointed 

out I think, that there are a number, I mean a 

wide array of synthetics included in just generic 

paper. 

So if we want to hone in on specific 

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categories of those in your technical review, I 

don't think that, you know, as a certifier we're 

not going to be opposed to that necessarily, but 

I think we would recognize the discrepancy on 

allowing all of those additives to be used as 

mulch between the rows and then the pots in the 

rows can only have a certain amount of additives. 

So it's this consistency. Part of my 

job is to try to explain to farmers why we do the 

things we do, and I need to be able to explain 

that reasoning. Right now, we allow the paper 

pots because it makes sense to allow the paper 

pots. Mulch and compost feedstocks are allowed, 

and to try to explain to a farmer than you can do 

those things and you can put the compost right 

around the plant in the hole, but you've got to 

take that pot off, it just -- the logic doesn't 

work for the farmers. 

So that's what I -- your goal is to 

give us something that we can work with, that 

makes sense and is reasonable and is practical. 

MR. CHAPMAN: So do you have any -- I 

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mean in a case like the paper pots, where we're 

adding adhesives after the paper, I mean recycled 

mulch we're just taking the product. We're 

putting it out there. I can see in the future we 

can oh sure, we're taking this paper pot, but 

we're having to use it after the fact. 

That kind of opens up the door for if 

we just say paper is an aid or something. It 

would open, potentially open the door to 

materials we really don't want in paper pots 

added after the fact. So I'm trying to figure 

out how do we limit just, you know, I mean we 

were talking about antibiotics and 

microcrystalline cheese wax earlier. 

Or, you know, how do you limit in an 

annotation or some kind of wording, so that it's 

kind of, the same adhesives used as in paper or 

MS. DeMINTER: If you -- well, you 

guys probably didn't see the original petition 

that I had submitted on behalf of MOSA that was 

geared toward a very generic categorical listing, 

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because we're not supposed to petition branding 

products. So it was a very generic categorical 

listing for paper, and it did just that, 

including additives typically added to paper. 

It was trying to broadly allow all of 

-- well, maybe not all of, but the common 

ingredients you would see in paper that's used as 

a mulcher or compost feed stock, because if it's 

allowed in those uses, those same ingredients are 

allowed in those uses, why does it not logically 

make sense to allow them to be used in the 

manufacture of the pot. 

It's used in the manufacture of an 

envelope or a cardboard, you know, piece that I 

can use on my farm as recycled paper. So that's 

the challenge I think you're up against to some 

degree. But if you -- if I were in your shoes 

and really wanted to hone in on these, the 

additives, I'd probably get with some of the 

manufacturers out here that make these products, 

and see what additive categories or types are 

really necessary in the manufacture of these 

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types of products. 

To not use additives, breaks down the 

product maybe and there's input that they could 

give you that would be helpful in determining 

which additives you want to consider. 

MR. CHAPMAN: Thank you, Jackie. 

Thank you. We're going to have to move on now, 

but thank you for your comments. 

MS. DeMINTER: All right, thank you. 

MR. CHAPMAN: Up next is Rudy Amador, 

followed by Richard Mathews. Rudy, if you can 

start with your name and affiliation for the 

record. 

MR. AMADOR: Yes good afternoon. My 

name is Rudy Amador, I work with Dole Tropical 

Products, and I'm Director of Sustainable 

Agriculture there. 

I want to start off by thanking the 

Board, because I'm a bit cut off there at the 

end. So thank the Board first for your service, 

NOP for hosting, and Michelle, I wish I had five 

percent of your organizational skills, and I'd be 

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a much better employee. 

I'm basically here today to talk about 

the importance of ethylene for the tropical fruit 

products that we produce and export to the United 

States. We basically have been working with 

organic bananas for about 25 years, organic 

pineapples for about 15. We work basically in 

those five countries that are on my slide there. 

I wanted to point out that I'm 

slightly biased because I'm from Costa Rica, and 

may mention them more than the other countries 

during this talk. But I would want to point out 

that we also work with organic fair trade bananas 

and Organic fair trade pineapples, and that is 

relevant to my exposition here and we'll explain 

at the very end. 

You'll be hearing probably tomorrow 

from some growers that came from Costa Rica to 

explain how they use ethylene in pineapples. I 

just want to say that it's basically the most 

important agricultural practice in pineapple 

production. Ethylene is used to trigger 

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flowering and that has impact on determining the 

ability to produce weekly values, also the 

ability of controlling pests effectively. 

So without ethylene in pineapples, 

there wouldn't be pineapples basically. And also 

we work with ethylene in bananas. I don't know 

if most people know this, but bananas are 

harvested green and shipped green. They need to 

be shipped green in order to survive the 

transport period through the markets. 

And when the bananas are out in the 

markets there are facilities, ripening facilities 

sometimes owned by retailers or other groups, 

that will use ethylene to ripen the fruit and get 

it to the supermarket with a uniform. Without 

ethylene again in bananas, there wouldn't be a 

banana product for the consumers. 

Alternatives. There was a webinar 

last week and there was someone from Dole, our 

research director of Pineapples, that explained 

the issue of alternatives. So you go back to the 

information he provided last week. But I do want 

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to say that the ethylene's purpose was determined 

by nature, so you really cannot replace ethylene. 

What you can maybe try to do is try to 

force the plants to produce more of their own 

ethylene and get that same effect. But that will 

be discussed also tomorrow by one of the growers 

who's bringing some research that was done in 

Costa Rica earlier in the year. 

Regarding the international regulatory 

situation, while ethylene is approved in organics 

in the United States, by the European Union, by 

Canada, in Costa Rica also, there's going to be 

someone from the Ministry of Agriculture from 

Costa Rica referencing that tomorrow. 

Here I just wanted to point out that 

within the codex system, it has also been 

reviewed and the U.S. delegation has voted for 

that. This is my last light. Basically the 

impact of ethylene removal in the growing area, 

the growers would be converting back into 

conventional, which we don't want. 

There would be a loss of thousands of 

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jobs in the source countries. There'd be no 

organic pineapples or bananas for the U.S. 

consumer in this case. Also, a loss of growing 

market for retailers processors. 

MR. CHAPMAN: Thank you for your 

comments. I have to stop you there. 

MR. AMADOR: Okay, yes. 

MR. CHAPMAN: Harriet. 

MS. BEHAR: What is the rotation crop 

with pineapples? 

MR. AMADOR: There is no rotation 

crop. There's a fallow period that goes between 

one crop and the next. Normally we use macuna 

bean as a green manure between the crops. 

MS. BEHAR: And how long is that 

fallow period between growing? So a field could 

be growing pineapple for ten years, maybe get 

eight crops or something from it? It's not a 

full year is it? 

MR. AMADOR: It's a perennial. 

Normally you can do two crops. So you will -- in 

a farm, you basically have it separated in 

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sections. You'll be rotating around the 

sections, so that that farm is going to be 

producing product on a weekly basis to be able to 

supply what the market needs. 

MS. BEHAR: So what's the fallow time 

between? 

MR. AMADOR: It's going to depend --

in our country, it rains quite a bit. It's going 

to depend a lot on weather. So if it's raining a 

lot, the fallow period is going to be longer, 

because you're not able to get in to prepare. 

But it could be anywhere from six weeks to ten, 

twelve, uh-huh. 

MR. CHAPMAN: Dave. 

MR. MORTENSEN: In reading through the 

materials, it raised a question in my mind. When 

you go into the marketplace in the Northeast, at 

least the stores that my wife and I shop in, 

organic bananas are always more green than the 

conventional labeled bananas are by a good bit. 

I've wondered, does that have anything to do or 

the way or the amount of ethylene that's used in 

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the ripening process? 

MR. AMADOR: Not in the case of 

organic bananas. That's more an issue of how the 

ripener wants to, or the supermarket that's 

ordering the color that they want. So in that 

particular market, they may want the bananas to 

be greener. That's a decision that can be made. 

In the case of pineapples, however, it 

is true. When you see organic pineapples, the 

shell color is essentially going to be green, 

because in organics we cannot use a synthetic 

that allows the degreening of the pineapples. 

However, I would like to point out that the 

inside of the organic pineapple is actually much 

better than conventional, because the product's 

going to be out there one or two weeks more. 

You're going to have a sweeter pineapples, so 

definitely go for organic pineapples when you see 

them, even though they're green. 

MR. CHAPMAN: Okay, thank you very 

much. Next up is Richard Mathews, followed by 

Jennifer Berkebile. Richard, if you'd start with 

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your name and affiliation. 

MR. MATTHEWS: Richard Mathews, 

Executive Director of the Western Organic Dairy 

Producers Alliance. First of all, I want to 

thank you for considering our comments, 

encouraging you to relist the livestock 

materials. 

Now shifting gears, in 2000, we were 

asked to include split operations in the final 

rule. We also included a provision that once 

something left organic for conventional 

management, that it could not come back. Why am 

I telling you this? 

Because we have a certifier who was 

allowing organic farmers to convert organic 

calves born of organic mothers on an organic 

operation to conventional, for raising as 

conventional for nine to twelve months, and then 

conversion back to organic. 

We filed a complaint on August 16th. 

On October 1st, we were told that the case was 

closed with no action. This is not a policy 

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issue. This is about violations of Section 

201(a)(5) and Section 236(b)(1). These are 

willful violations. Now historically the 

National Organic Standards Board has been more 

than willing. They haven't been shy about 

telling the USDA when they are wrong. 

It is now your time to tell the USDA 

that they are wrong, the decision is 

unacceptable, and the decision needs to be 

reversed immediately. 

(Applause.) 

MR. MATHEWS: Any questions? 

MR. CHAPMAN: Ashley. 

MS. SWAFFAR: I have a sunset question 

for you. On hydrated lime, you were like the 

only person that realized we asked anything about 

maybe changing the annotation in the future. Do 

you think any of your producers, if they could 

use hydrated lime for deodorizing animal waste, 

would that be a beneficial tool for them or not? 

MR. MATHEWS: I'm not in it -- well, 

I can't really say that it would be a beneficial 

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tool. 

MS. SWAFFAR: Thanks. 

MR. CHAPMAN: Harriet. 

MS. BEHAR: Can you speak to the 

economic impact on that decision that that's had 

on the members of WODPA, which you are the 

executive director of? 

MR. MATHEWS: There's only one reason 

-- well, there's two reasons for any farmer to do 

this. First of all, it's cheaper to raise calves 

conventionally than it is organically. They save 

about a $1,000 per animal. 

So it's an economic incentive tool. 

It also allows them to disregard the feed 

provisions, the livestock healthcare provisions, 

the livestock living conditions provisions, the 

pasture provisions. 

So while these certifiers are allowing 

these two violations, there are multiple 

additional violations. It all gets back to 

economics. Who wants to do it? The very large 

farmers want to do it, those who have trouble 

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raising animals. The good farmers don't need 

that. 

And so every farmer who is following 

the rules is placed at an economic disadvantage. 

You multiply that thousands of dollars a head by 

tens of thousands of animals, you are creating 

severe economic disadvantage to all the farmers 

who comply with the rules. 

MR. CHAPMAN: Thank you. Thank you, 

Richard. Briefly Dan. 

DR. SEITZ: You know, would you just 

please close the lop on what you've just 

described? So the herd is transitioned back to 

conventional, and then is the whole herd sold to 

some farming operation to then be -- as a onetime sale to be used as -- for organic milking 

operation? What happens to that herd once it's 

converted back to conventional? 

MR. MATHEWS: Well, it's not a 

conversion of a whole herd. It's an organic 

operation that is already required to follow the 

regulations. 

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Now they might fall in the two track origin 

of livestock issue, where those who had taken 

advantage of the feed exemption are now required 

to only source organic animals as replacements or 

additions to their herd, versus the one that's at 

100 percent organic feed, who because of a glitch 

in the regulations has been allowed to 

continuously transition animals that were 

conventional to organic, to either build the herd 

or provide replacement animals. 

This isn't that at all. This is an 

organic operation seeking economic advantage, and 

wanting to skirt the rules because it's easier 

than it is to raise an organic calf. It's that 

simple. Does that answer your question? 

DR. SEITZ: Not quite, because what 

happens at the end of that year with those 

animals that were transitioned back to organic? 

I don't understand --

MR. MATHEWS: They go right into the 

milking herd. Yeah, they go into organic 

livestock management. 

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DR. SEITZ: Oh I see, okay. So meat 

sales, milking sales, whatever that may be. 

Okay, great. Thanks. 

MR. CHAPMAN: Yeah, Richard thank you. 

Thank you for your comments. I have a question 

for Jenny, which might be the same question for 

you, which is Jenny, can you provide any more 

context to what we just heard? 

DR. TUCKER: Sure, and you know, I 

think I'm going to spend a little bit of time on 

this, because I've been getting a lot of 

questions on this one. So I think I'm going to 

share sort of broadly how we think -- how when we 

get a complaint like this, what do we do? What 

are we thinking about? 

Because I think having the community 

understand the thought process and the kinds of 

questions that I and our team ask might help in 

this dialogue. 

So when we get a complaint, I 

mentioned this morning one of the things that we 

look at is it is -- is it a policy complaint or 

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is it -- so that involves looking at sort of the 

regs, looking at the evidence, looking at what we 

have. 

When it is a complaint that comes in, 

we think often okay, what would happen, just 

hypothetically, what would happen if we did an 

adverse action here? So what is that? That's 

like a proposed suspension or a proposed 

revocation. So let's -- let's just follow that 

thread on hypothetically what would happen. 

And then the next important question 

would be and what if that was appealed? So 

proposed adverse actions are appealed, often 

appealed. So then what would happen on appeal? 

What would the lawyers on the opposite side 

argue? So how would they read the regulations in 

a different way than we read the regulations, and 

is that argument -- is that argument actually 

believable? 

I have to look at that question from 

the viewpoint of an administrative law judge, who 

is not in the organic community, doesn't 

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necessarily know about organic production, is a 

lawyer, is an administrative law judge who is 

going to take all the evidence. 

So first, I've been doing appeals now. 

I've reviewed appeals for the program with 

certifiers actions against operations that are 

appealed to the program level. 

I've been looking at those for about 

five years now. So we're getting actually pretty 

good at anticipating what the arguments might be 

on the other side. We have to be very cognizant 

of what would happen on an appeal should we lose, 

because we have been down that road before. So 

setting policy through complaints and the appeals 

process, we've really tried very hard to avoid 

doing that, okay. 

Now that's sort of the general comment 

on complaints. Now I'm going to turn in terms of 

origin of livestock, and again am putting myself 

in the viewpoint of a lawyer for another, for an 

opposite, an administrative law judge. What 

would likely get pointed to in an origin of 

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livestock case is the documented known regulatory 

uncertainty in this part of the regulations. 

So this is an area where NOSB has made 

recommendations. This is an area where the OIG 

has had findings in two organic milk audits 

related to origin of livestock, and he has 

written that there is differences in 

interpretation between certifiers. We have a 

proposed rule that was published in 2015. That 

rule has not been finalized. 

So there's a whole trail of documented 

regulatory questions on origin of livestock, 

where it's sort of acknowledged in a lot of 

places, including proposed rule, that there's 

regulatory uncertainty in this particular area. 

Now there are lots of different areas where one 

could be uncertain in this area, and people can 

reference very specific parts of that section of 

the rule and say this is why we are right. 

Then other people are going to point 

at other parts of that section and say this is 

why we are right. We have to have full 

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confidence that we would win -- and an 

administrative law judge to feel comfortable 

taking that kind of action, given the uncertainty 

with origin of livestock. We did not feel 

comfortable and we can't take an adverse action 

in this particular case. 

Now there are many parts of the 

livestock regulations, such as the pasture 

standard, which are much more regulatorily clear. 

We have a final pasture rule, it's been passed. 

We've done a whole bunch of training on it. That 

right now, when we're looking at the Pasture 

Compliance Project, the Dairy Compliance Project, 

that's where our focus is, is in the parts of the 

regulation that are very clear on grazing season, 

on all the different aspects of pasture. 

That's -- and antibiotic use and all 

sorts of other parts of the organic regulations 

related to livestock that are very, very clear. 

That is where we are focusing. Origin of 

livestock is regulatorily uncertain ground. A 

good lawyer is also going to look back at OFPA 

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and see what OFPA has to say about origin of 

livestock. 

So those are all of the kinds of 

variables that we have to take into account when 

we look at specific complaint. So I just want to 

share. I know a lot of you will disagree, and 

you'll tell me where in the regulations you're 

looking. 

The lawyer has a whole other different 

perspective on that. We have to be pragmatic in 

how we view these complaints, and setting policy 

through complaints and appeals processes is very 

dangerous territory indeed. Thank you. 

MS. BEHAR: So Jenny, would there be 

-- what is the thought within the program for 

dealing with this regulatory uncertainty? 

DR. TUCKER: Origin of livestock, I 

tell everyone this too, so thank you for allowing 

me to sing this song again. So I appreciate the 

challenges, particularly for small producers in 

writing letters to the Secretary. It doesn't 

mean it doesn't work. So there are lots of 

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avenues for communicating. 

This is not an area -- honestly, I 

hear a lot about origin of livestock, not an area 

that has been heard as a distinct and incredibly 

high priority issue back at USDA. So generally 

when an origin of livestock gets brought up to 

us, it is one of a list of many things. 

We want you to do this, this, this, 

this and this and origin of livestock is 

somewhere in that last. Sometimes it's even 

number one, but it's one of, you know, five or 

ten things. And so there has not yet been a --

when you think about all the different things 

that people are interested in, origin of 

livestock has not been the clear melody in the 

song. 

And so I would as an industry, as a 

community, this is an area you want to get behind 

and say here are the economic arguments for 

finalizing a livestock, origin of livestock rule. 

Here are the benefits, here are costs, here's 

what we thought of the proposed rule in 2015. 

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That communication is helpful. 

Then the administration can make a 

decision on what it wants to do moving forward. 

But until we hear, the administration hears a 

unified voice on this topic, it is hard to --

it's not on the regulatory agenda right now. 

MR. CHAPMAN: Thank you, and I think 

we need to move on with public comment at this 

time. Just so folks know we were planning to 

take a break at 3:45, but given how far we are 

behind on the schedule, we will be working 

through that break. So if any Board members do 

need to take a break, please feel free to stand 

up and quietly walk out of the room and do what 

you need to do. 

Right now, we're tracking to wrap up 

around six o'clock. There is another event in 

this hotel that is using the public space around 

six o'clock, so I would really like to wrap up at 

that time, because it's going to become loud and 

distracting. 

So I guess I am looking at the Board 

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members and saying choose your questions wisely, 

because I will probably start curtailing the 

questions asked to keep us moving along, and to 

give every commenter a chance to speak. With 

that, Jennifer is up and then Jenny Cruse is on 

deck. Jennifer, if you can start with your name 

and affiliation. 

MS. BERKEBILE: Sure. Good afternoon. 

My name is Jen Berkebile. I'm the Materials 

Program Manager at Pennsylvania Certified 

Organic. We certify over 1,500 organic crop, 

livestock and handling operations in the U.S. 

Today, I'll be reiterating my written comments on 

marine materials, paper pots, sodium citrate and 

sodium chloride for the generation of chlorine 

dioxide gas. 

First regarding marine materials. I 

really appreciated Emily's comments at the NOC 

meeting on this topic, especially addressing the 

slippery slope fear, because that is also my 

fear. 

I want to express my support for a 

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working group on this topic. I would like to see 

it not just address the wild crop standard, but 

also the availability of organic marine 

vegetation. 

Some aquatic plants are listed at 

205.606. But if they are possibly not 

commercially available for use in processed 

products, are they commercially available for use 

in crop inputs? I would also like to see the 

working group recommend an adequate time period 

for manufacturers and producers to come into 

compliance with these annotations should they be 

adopted. 

Next, I want to add my voice in with 

those who are requesting that the NOP reconsider, 

and that the NOSB support a reconsideration of 

the use up period for paper pots. In allowing 

paper as we control and as a compost additive, 

you as a Board have already said that paper used 

as a crop input is compatible with organic 

farming, and safe for human health and the 

environment. 

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Therefore, there is little to no risk 

to organic integrity to extend the used up 

deadline. Next, I want to express my concern 

with a listing for sodium citrate for use in 

blood meal. PCO has traditionally considered 

anti-coagulants and other processing aids to be a 

part of the standard of identity of blood meal, 

and therefore outside of the scope of review. 

This can be thought of similarly to 

paper, which is allowed without additional review 

of the processing aids used during the 

manufacturing process. I'm very concerned that a 

specific listing for sodium citrate will 

unintentionally lead to the prohibition of blood 

meal, due to the presence of other non-approved 

processing aids. 

I recommend that the NOSB either 

consider processing aids in blood meal as a part 

of the standard of identity, therefore allowing 

them without review, or take a look at all 

additives in blood meal and address them 

together. 

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Finally, I want to comment on sodium 

chloride for the generation of chlorine dioxide 

gas. As written, this annotation is a little 

confusing, and it is unclear whether or not we 

need to review other ingredients used during the 

generation process. I want to reiterate that the 

listing for chlorine dioxide at 205.605(b) should 

be updated to read "Chlorine dioxide gas 

generated from sodium chloride." Thank you all 

for your time and dedication on the Board, and 

for the opportunity to comment here today. 

MR. CHAPMAN: Emily. 

MS. OAKLEY: Thank you for your 

written comments on -- why does it seem like --

here we go. Is that better, okay. Thank you for 

your comments on marine materials, and you said 

of the 19 crop inputs in aquatic plant extracts 

that PCO approves, seven already contained 

certified organic marine macroalgae. 

MS. BERKEBILE: Uh-huh. 

MS. OAKLEY: Could you tell me a 

little bit about that? 

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MS. BERKEBILE: I believe the -- from 

my memory, I believe they contained thoravin 

kelp, which is a certified organic and I think 

unrealistic as well. And then some of the other 

ones that I mentioned, we don't know whether 

they're certified organic, whether they're 

marine, so any other questions? 

MR. CHAPMAN: Thank you. 

MS. BERKEBILE: Thank you. 

MR. CHAPMAN: Up next is Jenny Cruse, 

followed by John Hendrickson on deck. Jenny, if 

you can start with your name and affiliation. 

MS. CRUSE: I'm Jenny Cruse with the 

Accredited Certifiers Association. Our primary 

mission is to ensure consistent implementation of 

USDA organic regulations through collaboration, 

education of accredited certification agencies. 

We have 53 certifier member organizations. 

Today I'd like to highlight a few key 

points from the ACA's written comments that were 

submitted to the docket. Our comments are 

generated through working group participation, 

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survey feedback and Listserv discussion. On the 

subject of paper pots, we support an amendment to 

the National List that would enable the use of 

paper as a mechanism for planting and 

transplanting. 

Using paper in this way could reduce 

reliance on plastics, and it seems that the 

environmental effects would be comparable to use 

of paper for mulch or compost feedstock, both of 

which are currently allowed. We also support an 

extended deadline for discontinuing the allowance 

of paper pots as this petition process plays out. 

Please note that these comments relate 

to paper only. We're not advocating for the use 

of any commercial paper padding systems or for 

the allowance of any additional materials used in 

the manufacturing of those systems. 

On the subject of organic seed search 

requirements, we applaud the Crop Subcommittee's 

stated intention to develop language that allows 

farmers to use non-organic seeds, as long as they 

demonstrate their organic seed search is valid 

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and improving. However, the proposed language 

doesn't seem to yield that level of flexibility. 

Any final language should discuss 

improvements in terms of long-term patterns as 

opposed to year over year comparisons, and should 

be careful about the "and" language. Requiring 

improvements searching sourcing and use of 

organic seed every year is actually a fairly 

inflexible requirement if read literally. 

Sometimes use cannot be improved in a 

given year, even if searching and sourcing 

improvements are grateful of this. We'd also 

like to repeat that seed search quality would be 

greatly enhanced through use of a comprehensive 

organic seed database funded or established by 

the NOP. 

On the CACS Subcommittee proposal on 

training and oversight of inspector and 

certification review personnel, what I'd like to 

highlight is that the ACA has done extensive work 

on this question, on the question of inspector 

training and qualifications over the last couple 

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of years. 

We attached the ACA guidance on 

inspector qualifications to our written comments. 

This was developed by a working group on the 

topic in 2017 and early 2018, with participation 

from Margaret Scoles of IOIA. IOIA also worked 

with the ACA to develop a survey of accredited 

certifiers on the subject of inspector training, 

and the survey had a response rate of over 50 

percent. 

One interesting observation is that 

around a quarter of responding organizations 

reported that they did not have a mechanism in 

place to ensure timely feedback on the inspection 

reports of new inspectors, once they had 

completed basic training and field training. 

The ACA board agreed it would be 

useful for all certifiers to put such mechanisms 

into place. A redacted version of those survey 

results was attached to our written comments, and 

we believe the information can be useful to 

consider as the conversation moves forward. Than 

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you all for your hard work and for the 

opportunity to comment. 

MR. CHAPMAN: Harriet. 

MS. BEHAR: Thank you for sharing that 

survey. That's going to help us with setting our 

priorities, I think, on what should be done in 

the inspector training. 

I had a specific question. You had an 

evaluation form in there for evaluating 

inspectors specifically, and I was wondering how 

these certifiers felt if there was a consensus to 

all share the same evaluation form, so they could 

then be used universally between agencies or not? 

MS. CRUSE: We included that as an 

attachment to the instruction document that was 

published early in 2018, as a tool for optional 

use. I know that there are some certifiers who 

would be in favor of using it and others who have 

forms that they've developed that they prefer to 

use too. So I don't feel I could get a unified 

response to that. 

MR. CHAPMAN: Thank you. Up next is 

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John Hendrickson with Stephanie Rose on deck. 

John, if you can start with your name and 

affiliation. 

MR. HENDRICKSON: John Hendrickson, 

organic farmer, Stone Circle Farm and owner of 

small farm works, a business dedicated to 

providing innovative tools to small farms, 

including paper pots. I want to begin by 

bringing up a procedural issue regarding the 

petition I submitted to get paper pots allowed on 

organic farms. 

I was told I could not submit a 

petition for a specific commercial product. 

Rather, the petition had to be for a generic 

material. With Jackie DeMinter, a petition on 

the generic use of paper as a paper pot was 

submitted in advance of the deadline to get on 

the agenda for this meeting. 

This petition was returned with a 

request for detailed information about the 

particular paper pot product that I use and sell. 

This seemed to go directly against petition 

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guidelines. The strategy I was trying to follow 

was first to get the use of paper as a paper pot 

added to the organic rule, and then the company 

that makes the paper chain pots would submit 

their specific product to OMRI for review. 

This seemed a logical and procedurally 

correct path to follow. This strategy was based 

on my reading and understanding of the technical 

reviews that have been conducted on paper, which 

acknowledge that a great many synthetic materials 

are known to be components of recycled paper, 

given that recycled paper is a waste stream 

product. 

As you know, paper has commanded the 

attention of the NOSB in the past. Several 

technical reviews have been conducted. The 

technical reviews are quite clear that paper and 

paper products, including recycled paper, contain 

a great deal of additional ingredients. The 

decision to allow recycled paper has been made 

knowing that the exact materials contained in 

recycled paper are largely unknown, as well as 

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about any clear definition of recycled. 

As the rule reads now, the paper pots 

that I sell could be shredded and applied to the 

ground as mulch or added to the compost pile, but 

not used as a paper pot. I would like to 

contrast the use of these thin strips of paper 

pots with the use of plastic mulch. Does anyone 

know how many miles of plastic mulch are used on 

certified organic farms? 

I don't either. But the use of small 

amounts of paper certainly pales in comparison to 

the environmental impact of manufacturing, 

applying, removing and disposal of plastic mulch, 

which I have chosen not to use on my farm. Not 

allowing paper chain pots will have severe 

economic impacts, including but not limited to 

farmers facing a very difficult decision between 

using paper pots or continuing to be certified, 

certifiers losing clients, farmers having 

unusable equipment and unused inventory of paper 

pots, farmers dropping crops from their rotation, 

farmers having to hire more labor in a tight 

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labor market, or buy new and different equipment 

for transplanting, and reverting to less 

efficient and less productive planting systems. 

The company that makes the paper chain 

pots is committed to compliance with organic 

standards. They are willing and eager to submit 

their product for OMRI review. I urge the NOP to 

allow the use of paper chain pots on organic 

farms while the NOSB considers the petition, 

conducts any reviews deemed appropriate, and 

votes at a future meeting. Thank you. 

MR. CHAPMAN: Thank you. I'm going to 

actually put someone from the program on the 

spot, but probably Devon to speak to the first 

petition. Devon's not here. Maybe Clarissa. 

And I was somewhat involved and I think Steve was 

somewhat involved, so maybe he'd be able to speak 

to it as well. 

I do not believe it was rejected 

because it was a generic. It was rejected 

because it wasn't deemed sufficient at the time 

of submittal, which is a common occurrence in a 

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first-time petition. Is that --

MR. HENDRICKSON: Yeah, I acknowledge 

that, and believe that to be correct. However, 

asking for the very specific ingredients and 

amounts of those ingredients in the particular 

product that I sell seemed to go above and 

beyond. The purpose of that petition was just to 

get the use of paper as a paper pot added to the 

organic rule. 

MR. CHAPMAN: Yeah, Steve do you want 

to --

MR. ELA: Yeah. I mean I agree with 

what you're saying, although it comes back to 

kind of the adhesive issue too, of adding 

adhesives after the paper is made was I think 

where we got hung up a little bit. 

MR. CHAPMAN: Yeah. 

MR. ELA: It's a tough one, and I 

agree with Tom. I think I did see that original 

submission. It just wasn't complete enough for 

us to act on it. 

MR. CHAPMAN: Yeah, and then once we 

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get the information, there was a need to seek 

information to determine how similar or different 

this was from paper, and without knowing that, 

it's hard to come to that conclusion. It would, 

you know, there is a strong likelihood that you 

would have gotten questions from the program or 

from the subcommittee asking for that 

clarification later. That would have also 

delayed the petition. 

And then just so you're aware, even an 

earlier submission may not have been sufficient 

time to make this meeting as well. The general 

time line on, I would say on average a petition 

at a minimum is generally about 18 months. 

MR. HENDRICKSON: Which is again why, 

why I would really urge the extension of the 

deadline on use of the paper pots, to allow the 

petition process to unfold. 

MR. CHAPMAN: Fair point. Questions 

from the Board? I see Dave. 

MR. MORTENSEN: Yeah, thank you John. 

We heard from two callers last week in the public 

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comment about the displacement of the need for 

and reliance upon the plastic phase, because and 

I for me personally, that clinches it, because I 

have seen many farms with just piles of plastic 

in one of the fields, because they simply don't 

know what to do with the plastic that they've 

generated. 

So to me this is a very clear need 

that we -- with both environmental and economic 

impacts. Thank you for outlining that. 

MR. HENDRICKSON: Thank you. 

MS. BEHAR: Do you know if anyone in 

the United States is looking to produce these 

pots? There were some public comments about 

looking at domestic production. 

MR. HENDRICKSON: I can tell you that 

a company in Japan is very interested in opening 

up a factory here in the United States. 

MR. CHAPMAN: All right. 

MR. HENDRICKSON: I would note that in 

addition to the paper part of the system, there 

are a bunch of other components which you know we 

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are manufacturing all of those things 

domestically now, creating jobs in our local 

community. 

MR. CHAPMAN: Thank you. Okay. Next 

up is Stephanie Rose, followed by Nate Lewis. 

MS. ROSE: I'm Stephanie Rose. I'm 

representing PQ Corporation, a manufacturer of 

aqueous potassium silicate. I would like to 

address some of the concerns raised by the Crop 

Subcommittee during the sunset review of 

potassium silicate. 

I appreciate the huge task that is set 

before the NOSB and overall, and I agree that 

materials on the approved list should have clear 

benefits to the organic grower. Those are where 

I supply the NOSB with five independent studies, 

four journal articles and 13 additional extension 

publications covering a variety of crops, 

including blueberries, basil, oranges, grapes, 

haps and pumpkins, for efficacy as a fungicide 

and an insecticide. 

Another benefit to the organic farmer 

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is minimizing resistance through rotational use 

with other fungicides and insecticides of 

different mechanisms. Regarding systematic 

mechanisms concerns. It is important to keep the 

application method in mind when discussing this 

critical issue. Potassium silicate for disease 

and insect control is applied via foliar 

application. 

As noted in several Michigan State 

Agricultural Extension publications, potassium 

silicate is a contact protected-type fungicide 

applied to the foliage. A reference utilized in 

Technical Report 2014 on aqueous potassium 

silicate is a study on the horticultural effects 

of silicon on sunflowers. 

The article states that the effects on 

sunflower traits depend upon source and 

concentration of silicon. Silica when applied to 

the soil is taken up by the roots and deposited 

in cells. The efficacy data submitted to you 

that I mentioned earlier utilized foliar 

application, not root application. 

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The applications are not the same, the 

mechanisms are not the same, and this should be 

kept in mind when reviewing information on the 

effects of silicon on plants. 

Two additional studies referenced in 

the 2014 Technical Report on aqueous potassium 

silicate. One, a study conducted by Mattson on 

morphological traits of several flowering plants 

utilized a substrate drench. The second, an 

article by Mayland and Shewmaker discussing the 

changes in forage. Again, the silica is taken up 

by roots. Foliar application is a different 

application and different mechanism. It works as 

a surface protectant. 

Regarding the concerns over digesting 

silica to containing plants, unfortunately the 

information is limited and conflicting, even 

within the article by Mayland and Shewmaker. 

Therefore, I was not able to find a clear answer 

for you. In this case, it feels best to revert 

back to the basics of silicon accumulation in 

plants. 

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It is well-documented that the persona 

of silica that a plant will accumulate varies 

from plant to plant, from .1 percent to 10 

percent. Grasses and rices are very high 

accumulators, while plants like tomatoes 

accumulate so little they're considered nonaccumulators. 

MR. CHAPMAN: Questions? Asa. 

MR. BRADMAN: I just want to clarify. 

So you're saying that when you're applying it as 

a foliar application it's not necessarily being 

incorporated into the structure of the plant, 

that it's acting as a contact pesticide against 

fungi or perhaps other pathogens? And can you 

tell us what the mechanism is against those 

pathogens, and is there any structural change to 

the plant? 

MS. ROSE: No. It is my understanding 

that when it's taken up into the plant, deposited 

in the cells, it's taken up through the root 

system, okay. The MSU Extension was clear to 

state in most of their publications that this 

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should be applied, that it's a surface 

protectant, but it's not a systematic. 

There were several comments about 

these are systematic mechanisms, silica matrix is 

not. So we guessed through their efficacy trials 

that they have determined that it is definitely 

not, doesn't act as a systematic. 

MR. BRADMAN: Okay. By systematic, 

you mean systemic? 

MS. ROSE: Sorry, sorry. Systemic. 

It isn't real clear what the mechanism is. 

There's some theories over providing a surface, 

you know, a coating on the surface of the plant, 

and I guess I can't answer all of your questions. 

MR. BRADMAN: Okay. 

MS. ROSE: That is what I found in 

doing research. I'm looking on what 

recommendations are and what studies have said. 

MR. BRADMAN: Okay, thank you. 

MR. CHAPMAN: Dave. 

MR. MORTENSEN: Yeah. In the 

technical literature that we were looking at, and 

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I was the lead on this particular one, there was 

-- it was strongly implied that the compound was 

systemic, whether it was applied to the soil or 

applied to the leaves. 

And the implications in what we were 

reviewing and what we had in front of us were 

that uptake in the leaves was occurring across 

the cuticle and across and through the stomata, 

so that the compound actually enters the inside 

of the plant. 

That was what gave rise to our concern 

about human exposure to vegetable, green leafs, 

and such grown and harvested after being sprayed. 

I also would like to thank you for the 

additional efficacy data that you provided, 

because we did not have very much to look at when 

we were going through this process, and it's 

helpful to see that now. We did not have very 

much of that before. Thanks. 

MR. CHAPMAN: Thank you. Up next is 

Nate Lewis, followed by Taylor Ivy. Nate, if you 

can start with your name and affiliation. 

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 MR. N. LEWIS: Sure. Thanks for 

taking all these public comments. My name's Nate 

Lewis. I'm an associate consultant with Wolf 

DiMatteo and Associates, and an organic farmer in 

Olympia, Washington, where we hold all four 

scopes of certification, a thing I like to tell 

everybody. 

But the comments I'm going to present 

are on behalf of Wolf DiMatteo and Associates. 

So, I'm here instead of Bill Wolf, but I wanted 

to bring forward one of his themes, which is to 

always think like an earthworm, and bring it 

through a couple of items. 

So, when evaluating films and fibers 

like paper pots or compost feedstocks or 

biodegradable mulch film, think like an 

earthworm. Use those ASTM standards that are 

incorporated by reference for biodegradability 

and compostability. They're good, objective 

tools for at least looking at that aspect of 

those particular materials. 

Earthworms don't care about whether or 

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not the product's bio-based. They care about 

whether it is biodegradable. And so we encourage 

you as a Board to take another look at that mulch 

film recommendation and listing around the biobased content, because right now there are no 

products available on the market to replace 

polyethylene film. 

Liquid fish products. They're good 

for the soil. Organic farmers use them and need 

them. We support its continued renewal. We also 

agree with the Crop Subcommittee that taking a 

look at sustainability of our planet's fisheries 

is absolutely a critical element in these 

reviews. It's a bigger issue than what can be 

covered in the sunset. So, come back to that, 

but let's complete the sunset process for liquid 

fish. 

Sodium nitrate, not so good for 

earthworms. The time has come, I think, for the 

USDA to move forward on rulemaking to completely 

prohibit sodium nitrate. There's consensus in 

the organic community that it should be 

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prohibited. It's bad for the soil. There's 

growing concerns about perchlorate contamination, 

which poses a health risk, and there's really no 

reason for continued delays in the process. 

And, with that, maybe we can regain a 

little bit of time for future commenters, unless 

there's questions. 

MR. CHAPMAN: Questions for Nate? 

MS. SWAFFAR: So, what do you think we 

should do about paper pots moving forward? 

MR. N. LEWIS: Paper pots. Well, I 

guess there's -- the way I look at it, there's 

two competing tracks of issues here. One is an 

enforcement issue, which has to do with the 

deadline for stopping its use; and there's 

another issue, which is the petition process and 

the adding it to the National List process. 

So the first one, the enforcement, 

that's really USDA's job. I see the program as 

the one who runs enforcement, and I actually 

agree with personally -- and I should say I'm 

going to take off my Wolf DiMatteo hat and put on 

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my small farmer hat, because we haven't really 

come to a position on these specific issues at 

Wolf DiMatteo and Associates. 

But as a small farmer and a 

stakeholder, I actually agree with USDA's 

interpretations of the regulations. I think 

being strict about how we look at those 

annotations is critical. I don't like to see 

people massaging annotations to allow for 

materials. 

So I agree with their approach, but I 

also see -- I see it as a correctable violation 

if someone would use a paper pot in the future. 

Paper is on the National List. It's just 

restricted for use. So it's not a prohibited 

substance application, in my view, and if someone 

used paper pots past the deadline, they would 

certainly deserve to receive a notice of noncompliance. But I don't believe that their land 

would should be out of certification for three 

years, requiring that transition. 

So I don't use paper pots on my farm, 

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but if I did and it was as important to me as I'm 

hearing it is to a lot of other farmers, I would 

just keep using it and I would get that noncompliance and I would appeal that non-compliance 

-- or I'd wait 'til it was a proposed suspension, 

and I would appeal that proposed suspension and I 

would just drag it out until you all got it on 

the National List. 

(Laughter.) 

MR. N. LEWIS: But that's what I would 

do. If someone chooses to withdraw 

certification, if you all could also agree that 

it was not a prohibited substance application, 

then they could come back into certification when 

it was on without that three year wait period. 

I think the National List process is 

cumbersome, and Steve you brought up a lot of 

those issues, but I don't think you should 

request a TR. You have all the information you 

need to make that determination with the current 

TR. 

MR. CHAPMAN: Steve, briefly. 

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MR. ELA: Actually, it's a quick 

question for Paul, I guess, that Nate brought up. 

I mean, in terms of the sodium nitrate issue, 

where it's sitting on your desk, and I think a 

public commenter brought up the issue, that it's 

not in our sunset reviews now because we pulled 

it. I mean, the Board voted to pull it out. So 

actually it's kind of this weird thing where we 

have this product still being used, but we're not 

reviewing it because it's on your desk. But if 

we're going to keep using it, we should review 

it. 

DR. P. LEWIS: The sodium nitrate 

issue is a complicated issue. We've had 

conversation internally in the department about 

the issue overall, but there's really no movement 

on the issue at this time. That's really where 

we are on this issue. 

MR. CHAPMAN: I have a question for 

Nate about sodium nitrate. Has Wolf DiMatteo and 

Associates considered petitioning to have it 

listed on 205.602? 

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MR. N. LEWIS: Well, it sort of seems 

like it would be redundant to -- there is already 

an outstanding recommendation to have it 

prohibited. So I don't quite understand what 

would be accomplished by an additional 

recommendation to have it prohibited. I think at 

this point it's --

MR. ELA: It would potentially get it 

back on the work agenda. 

MR. N. LEWIS: Oh, I see. So then the 

NOSB could continue to agree that it should be 

prohibited. 

MR. ELA: And then put it back out 

there under a new --

MR. N. LEWIS: It's certainly 

something worth considering. 

MR. CHAPMAN: Anything else for Nate? 

Nate, thank you. 

MR. N. LEWIS: Thank you. 

MR. CHAPMAN: Up next is Taylor Ivy, 

followed by Kelly Abbott. Taylor, if you could 

start with your name and affiliation. 

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MR. IVY: Okay. My name is Taylor 

Ivy. I work for Isagro USA. We are the 

manufacturer of AITC. AITC is not new to this 

Board. I've seen the petition submitted to you, 

and it's both thorough and detailed in terms of 

technical details supporting its approval. 

Instead of rehashing those details, 

I'd like to briefly highlight where we see the 

greatest needs at the grower level. One, for 

remediation of soil that has become infested by 

newly emerging or exotic plant pathogen or 

nematode. A good example of this would be the 

increased prevalence of macrophomina in 

strawberries in Florida five to ten years ago. 

It was relatively unheard of, not 

talked about very much. Last year, I 

unfortunately found myself standing in a fiveacre field of strawberries that had over 20 

percent plant mortality due to macrophomina, and 

there are plenty more examples close to that one. 

Two, over time, even with proper 

growing practices, certain diseases in nematode 

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populations can grow to levels well beyond 

control of current organic treatments. In 

instances like these, the farmer is forced to 

either stop farming or to become a conventional 

farmer. 

An example is verticillium wilt. This 

is a very big problem in California. 

Microsclerotia, which is the resting structure 

for verticillium, can remain viable for 14 years 

in the soil. So rotation is clearly not an 

option. 

And, three, as stated by our first 

public commenter, plant nurseries who wish to 

sell to organic growers in some situations have 

no way, other than conventional fumigants, to 

reduce disease and nematode populations to a 

point where the plants can not only survive until 

they're sold but also pass soil tests to attain 

nursery stock certifications. 

We believe that AITC, given its 

natural origin in the plant family Brassicaceae 

and biopesticide status is clearly the best 

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solution for organic growers who are in desperate 

need of significant disease and nematode 

reduction. Thank you, and I have no comments on 

paper pots. 

(Laughter.) 

MS. BEHAR: Steve. 

MR. ELA: So, as a Board, I mean, and 

as an organic industry, there are certain organic 

natural products that we don't allow because 

they're so broad spectrum, and those we put on 

the prohibited list. This is a very broad 

spectrum material. It does come from a natural 

source, I agree, and so it's very tempting in 

that sense. 

But it's non-selective. It's broad 

spectrum. I mean, those big red flags for me. 

And so can you address how you would respond? I 

mean how is it really different than metam sodium 

or some of these others? It's still killing most 

things in the soil. 

MR. IVY: Understood. When you -- we 

have a growing body of evidence, and we would I'm 

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sure be willing to share that data with you in 

the not-so-distant future, that after treatment 

with AITC, the microbial diversity is much 

greater than after a treatment with something 

like, as you said, MITC or methyl bromide or Pic 

60. You know the list. 

So we have growing evidence showing 

that, although it is considered broad spectrum 

against many disease pathogens and nematodes, it 

is leaving more of the non-pathogen communities 

intact. And there is certainly research that 

shows that the primary way that this product is 

broken down in the soil is as a food source to 

certain microbes. I hope that helps. 

MS. BEHAR: Any other questions? 

Dave? 

MR. MORTENSEN: I was curious. So, a 

number of mustard cover crop species produce high 

concentrations of various forms of 

isothiocynates. And I was curious, do you have a 

sense for the concentration relative to a cover 

crop concentration of isothiocynates in the soil? 

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MR. IVY: Cover crops achieve much 

lower concentrations than one can achieve with 

AITC in its purest form. With AITC, you can 

adjust your concentration to whatever is 

necessary for the targeted pathogen or nematode 

species. It can be as low as you'd like it to be 

or as high as you choose for it to be. 

With a cover crop, it can only achieve 

a low concentration of AITC and your results will 

be limited, based on research and what we've 

seen. 

MS. BEHAR: Emily. 

MS. OAKLEY: I'm a huge cover crop 

fan, so I appreciate your comment, but you can 

also grow cover crops over successive years to 

achieve results over the long term. 

MR. IVY: Understood, thank you. 

MS. BEHAR: Thank you. Abby 

Youngblood's on next with Kyla Smith on deck. 

Please state your name and affiliation. 

MS. YOUNGBLOOD: Hi. This is Abby 

Youngblood, Executive Director at the National 

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Organic Coalition. And I'm extremely grateful 

for the work that you do as members of the NOSB. 

On marine materials, NOC agrees with 

many other commenters that the NOSB and National 

Organic Program should establish a working group 

to develop standards for seaweed harvesting as a 

crop input and to provide more clarity for algae 

that is certified as organic under the wild crop 

harvesting practice standard. 

NOC strongly opposes the petition for 

silver dihydrogen citrate, and we urge you to 

reject it. SDC poses health and environmental 

risks, particularly the risk of increasing 

resistance to antibiotics in silver-based 

medications. 

Although the petition does not mention 

nanotechnology, nanosilver would be allowed if 

the petition is approved without an annotation to 

exclude it, and we're dismayed that, despite the 

NOSB's recommendation in 2010 to prohibit 

nanotechnology in organic production, there's 

still no clear prohibition. 

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In the absence of a clear prohibition, 

persistent oversight from public interest groups 

is required to ensure that the NOSB does not 

approve a petition for an engineered 

nanomaterial. It also results in extra work for 

the Board in reviewing petitions that include 

nanomaterials. 

On excluded methods, thank you to the 

Board for keeping this issue front and center, 

and for continuing to review additional next 

generation GE techniques. We support the 

proposal to list embryo rescue in plants as not 

an excluded method. 

Regarding transposons, at this time 

NOC is arguing that only transposons developed 

via use of in vitro nucleic acid techniques 

should be determined to be excluded. Transposons 

that induce via chemicals or irradiation should 

be considered under the method of induced 

mutagenesis. 

NOC recognizes that seed used in 

organic production is at risk for genetic 

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contamination, and we want to make progress in 

our efforts to protect the genetic integrity of 

crops. Much of the proposal on genetic integrity 

transparency makes sense to us, but our members 

do have some specific concerns with this 

proposal, and we urge the NOSB to work to address 

those concerns as you look at moving this effort 

forward. 

The need to collect more data has been 

an overarching theme in the efforts to develop a 

seed purity standard, and one way to begin data 

collection would be to start a pilot project with 

organic seed suppliers for a set timeframe, as we 

describe in more detail in our written comments. 

This would provide anonymous 

information on the range and concentration of 

contamination levels, and would inform 

conversations about a reasonable threshold level. 

Regarding GMO vaccines, we need to 

ensure that organic livestock producers continue 

to have access to essential vaccines, while at 

the same time bringing consistency and 

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eliminating GMO vaccines in organic that are 

unnecessary. GMO vaccines are being used in 

organic production, but they should first be 

reviewed and then placed on the National List. 

For a variety of reasons, that's not happening. 

Thank you. 

MR. CHAPMAN: Thank you. Questions 

for Abby? Asa. 

MR. BRADMAN: If I remember correctly, 

your comments also opposed the delisting AITC? 

MS. YOUNGBLOOD: Yes. 

MR. BRADMAN: And I'm curious if you 

have any thoughts about a proposal earlier today, 

or suggestion, that it should be considered for 

nursery as perhaps a way to avoid the use of more 

harsh, prohibited materials. Is there a possible 

window there that you might support or agree with 

or understand? I'm curious about that. 

MS. YOUNGBLOOD: I would need to bring 

that back to our membership before I could answer 

that, but I can discuss that further with some of 

our members and see if that came up in our 

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conversations. 

MR. CHAPMAN: Any other questions? 

Thank you, Abby. I believe we skipped 

over Kelly Abbott. Kelly Abbott's next, and on 

deck is Kyla Smith. Kelly, if you can start with 

your name and affiliation. 

MS. ABBOTT: Thank you and good 

afternoon, or good evening I guess at this point. 

My name is Kelly Abbott, and I am the technical 

supervisor for farm and livestock at Oregon 

Tilth. I've been in the organic certification 

industry for nearly 20 years, but I am going to 

admit this is my first NOSB meeting. 

I appreciate this opportunity and 

would like to focus my brief comment period on 

genetic integrity transparency of seed. Oregon 

Tilth fully recognizes that GM contamination is a 

top concern and that there are increasing 

challenges of preserving genetic integrity in 

organic seed, especially in corn seed. 

Oregon Tilth supports the principle of 

collecting data to establish a baseline of GM 

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contamination in organic crops, and Tilth would 

also support such a baseline as an essential 

measure to establishing GM thresholds under the 

NOP. 

Oregon Tilth cannot, however, support 

a mandate of purity disclosures for corn seed. 

Such a mandate would create an increased 

liability for labeling patented GM content, 

increase financial burdens on the farmers, and 

ultimately could lead to a reduction in organic 

seed diversity and availability. We would like 

to recommend that the data being continuously 

collected by private verification companies be 

utilized on a confidential level, as has been 

offered at previous NOSB meetings. 

We encourage the Board to continue the 

conversation to increase transparency with 

regards to GM contamination in organic corn seed 

production, but feel this mandate is premature 

and will cause not only financial burdens but 

affect the availability of organic corn seed 

diversity. Thank you for your consideration. 

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MR. CHAPMAN: Questions? Harriet. 

MS. BEHAR: Are you aware of -- do you 

certify any corn seed dealers or growers? 

MS. ABBOTT: I don't have the facts on 

how many we have, but --

MS. BEHAR: Are you aware,0 are any of 

them doing any genetic testing and sharing that 

information with their growers or buyers of the 

seed? 

MS. ABBOTT: I'd be happy to put you 

in contact with our program manager, who drafted 

this guidance. I think we're more looking at a 

broad base of how this would affect corn 

production and farmers in general. 

MR. CHAPMAN: Thank you. Up next is 

Kyla Smith, with Molly Schaus on deck. Kyla, if 

you can start with your name and affiliation. 

MS. SMITH: Good afternoon. My name 

is Kyla Smith. I am the interim co-executive 

director at Pennsylvania Certified Organic. PCO 

certifies over 1,500 operations throughout the 

U.S. I'll be commenting on the Crop 

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Subcommittee's proposal on strengthening the 

organic seed guidance, as well as the Materials 

Subcommittee's proposal on genetic integrity of 

seed. 

Regarding the seed guidance proposal, 

I'll focus my comments specifically on the 

proposed regulatory language change. We did 

provide written comments that cover the entire 

proposal. We support the concept of continuous 

improvement in the use of organic seed, and the 

proposed language definitely conveys that 

sentiment. 

That said, as certifiers we hang our 

hat on the specific language in the regulations. 

Placements of commas and ands versus ors do 

matter. When the language is unclear, certifiers 

interpret and enforce inconsistently. This leads 

to these items needing to be further clarified 

through best practice documents, program handbook 

documents, or may even find their way back onto 

your work plan, all of which take additional time 

and resources. 

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The proposed language does not give 

certifiers enough flexibility to both enforce 

continuous improvement and evaluate the 

operator's entire system. The proposed language 

will lead certifiers to issue non-compliances 

when an operation, one, does not improve in the 

areas of searching, sourcing, and use due to the 

use of the word "and" versus "or," and does not 

improve the -- or does not -- and/or, it's 

important -- or does not improve their seed usage 

every year for circumstances outside of their 

control, such as seed being unavailable due to 

crop failure. 

PCO supports the recommended language 

submitted by the Accredited Certifiers 

Association. The ACA's proposed language would 

allow farmers some flexibility while still 

improving in the areas of searching, sourcing, or 

use, which seems to meet the intent of the 

subcommittee. 

We don't have a preference on when in 

the process this wordsmithing takes place, but 

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encourage that it does take place prior to being 

published in the Federal Register in the final 

form so we don't come up against the barriers of 

implementation and enforcement that I've 

described. 

Regarding the genetic integrity of 

seed proposal, PCO respectfully asks for the 

proposal to go back to subcommittee for 

additional work. The document references 

sampling and/or testing, obtaining purity levels, 

et cetera, but lacks clarity on who will hold 

these roles and responsibilities, which is 

critical to give clear intention and direction to 

the NOP. Thank you all for your service and for 

the opportunity to comment. 

MR. CHAPMAN: Questions? Dave. 

MR. MORTENSEN: I just wanted to say 

thank you for pointing out the need to be precise 

with language, and also for the constructive 

input. We're trying to get this moving, and the 

feedback was very helpful and constructive. 

Thank you. 

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 MS. SMITH: Thanks. 

MR. CHAPMAN: Emily. 

MS. OAKLEY: I'm curious, as a grower, 

if I use organic seed and couldn't obtain it the 

next year due to a crop failure, would you truly 

interpret this language to mean that I wasn't 

compliant? Because when I read comments like 

that, I'm a little surprised, just because it 

seems like an overly strict interpretation of 

that language and a punishment of the farmers. 

So just more of a curious question. 

MS. SMITH: I think that that's part 

of the problem, that some certifiers could take a 

very strict interpretation and some would not. I 

mean, we've heard about issues in vagueity of 

language in regards to origin of livestock and 

pointing at different parts of the regulation, 

and being very confident in one's interpretation. 

And so unless it is uber-clear, we'll run into 

that issue. 

MS. OAKLEY: Thanks. 

MR. CHAPMAN: Thank you. 

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MS. SMITH: Thank you. 

MR. CHAPMAN: Up next is Molly, 

followed by Michael Crotser. Molly, if you could 

start with your name and affiliation. 

MS. SCHAUS: Yeah. Molly Schaus, 

Minnesota Food Association. My name is Molly 

Schaus, and I work as the farm director for 

Minnesota Food Association, which is a program of 

the Food Group here in Minnesota. Thank you for 

hearing this statement. 

Minnesota Food Association operates a 

100-acre certified organic farm in the St. Croix 

Valley that serves as a land-based education 

program and business incubator for beginning 

farmers who want to start their own independent 

vegetable farms. We seek to address the specific 

barriers that beginning farmers of color and 

immigrant farmers face, barriers that are 

amplified over the ones faced by their white 

counterparts. 

Currently, there 11 farm teams at 

Minnesota Food Association, all of them certified 

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organic. There are farmers from seven different 

cultures. We offer land access, weekly classes, 

in-field technical assistance, and access to 

shared equipment and infrastructure. We seek to 

offer training that is tailored to farmers' 

individual goals. We also provide education and 

market access by aggregating a CSA from all 

growers in the program, operating two weekly 

farmer's markets, and fulfilling wholesale 

contracts. The farm is a diverse and supportive 

community. 

I tell you all this because Minnesota 

Food Association and the farmers in the education 

program believe deeply in the value of organic 

certification. It is a tool that allows them to 

access markets with higher price points, and it 

is a tool that allows farmers to build health 

within their own communities. 

I am asking you to consider how the 

decisions you make impact beginning farmers of 

color and immigrant farmers. 

How can you work to build increased 

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access to organic certification? For example, 

long-term land access is a major challenge that 

beginning farmers of color and immigrant farmers 

face as they seek to become certified organic 

since there are systemic barriers to access of 

land and credit. With less capital and credit, 

it is much more difficult to purchase land. 

For the last three years, we have 

offered technical assistance to a farmer who 

wanted to transition his farm and his parents' 

farm to organic. He was participating in our 

classes, implementing organic growing practices, 

filling out a Practice Organic packet, learning 

how to keep the records needed for certification, 

and where to find organic inputs. 

However, he was unable to begin the 

three-year transition to organic because he and 

his family were never able to get a land lease 

that lasted longer than the one season. This 

past season, he was finally able to become 

certified organic when a small portion of 

certified land became available for rent, but he 

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still does not have long-term land access. 

How can organic standards and 

regulations address the needs of farmers who want 

to transition to organic, but cannot because they 

do not have stable land access? I want to farm 

in a community where all farmers have equitable 

access to organic certification and the tools 

required to achieve it. 

I believe that as you, the members of 

the National Organic Standards Board, consider, 

revise, and write regulations, you have a 

responsibility to consider how what you do will 

impact all members and potential members of the 

organic growing community and to address the 

specific needs of beginning farmers of color and 

immigrant growers. Thank you. 

(Applause.) 

MR. CHAPMAN: Thank you. Any 

questions for Molly? Asa. 

MR. BRADMAN: I've worked with groups 

in California that have programs that sound 

similar to yours and also raised similar issues. 

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I've been on the Board now for two years. I'm 

curious if you have any concrete suggestions on 

how we could further some of the issues that 

you've raised, and maybe, if not, that's 

something that we could get input on from the 

organic community. 

MS. SCHAUS: I have a couple of ideas. 

I figured someone was going to ask this. So, 

barriers that come up often are the cost of 

certification, and while there are cost-share 

programs in many states, and we're fortunate to 

have one in Minnesota, it's a reimbursement 

rather than a lowering of the upfront cost. So 

the farmer still have to front at least $700, 

even if they're going to get 550 of that back. 

I personally think there's some worth 

in considering transition time when there are 

institutional barriers that prevent people from 

having land access, that it's unreasonable to 

expect that people can farm like -- to require 

that someone farms for three years on the same 

piece of land if they want -- like if it's 

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because they cannot access land for longer than 

that. 

I think that there are also -- some of 

the regulations involving saved seeds and saved 

seeds that are culturally important to someone or 

to their family, when certifiers might not see 

the cultural importance of like that specific 

plant versus like -- so like what's the 

importance of this mustard that you're growing 

versus like one that seems identical that you can 

buy in the seed catalogue, but actually it's like 

the seeds that you brought over from your country 

of origin? Those are a couple of ideas that I 

have. 

I also just think that it's important 

when you write rules and change rules that you 

consider impacts that spread throughout the 

system. 

MR. CHAPMAN: Dave, is it a question 

or a statement? 

MR. MORTENSEN: Yeah. I guess just 

add on, that in Lincoln, Nebraska where I work 

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and in Pennsylvania, one other thing that's 

working and I don't know that we've ever thought 

about how all this interfaces with the 

regulations, I know I haven't, is the use of 

public land and all sorts of interesting and 

creative leases on public land. 

So if we were able to think more 

actively about local and regional use of public 

lands, that it enables a lot of cool things to 

happen in a longer term. 

MS. SCHAUS: Yes. Yeah. I mean we, 

for the most part, all of us farm on land that 

was taken, and so how can you restore common 

spaces? 

MR. MORTENSEN: Thank you for raising 

this important issue. 

MS. SCHAUS: Thank you. 

MR. CHAPMAN: Thank you. Up next is 

Michael, followed by Anne Ross. Michael, if you 

could start with your name and affiliation. 

MR. CROTSER: I'm Michael Crotser, the 

certification manager at CROPP Cooperative. I 

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want to thank the NOSB and the National Organic 

Program for the opportunity to speak. My first 

comment will be to discuss the feasibility of 

requiring organic seaweed in organic crop 

production. 

Certification of seaweed as a 

fertilizer would provide a level of verification 

that does not currently exist. Mandating organic 

seaweed use would assure that the harvest 

maintains or improves the natural resources of 

aquatic ecosystems. However, this would set up a 

precedent that other natural materials may need 

to be certified as a crop input. 

Sourcing seaweed as a fertilizer is a 

way to circumvent natural nutrient cycling that 

organic farmers are expected to follow, and 

encourages nutrient sourcing under an input-based 

model. Classifying seaweed as an organic input 

does not address this concern. Using fresh water 

materials is a commendable suggestion and should 

be explored. Eurasian milfoil is infestive weed 

infesting fresh waters and should be considered. 

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A working group would benefit 

measuring the environmental impact of harvesting 

marine algae. Experts could provide harvest 

strategy guidelines to mitigate environmental 

risk. The working group may conclude that marine 

algae should not be used in organic production. 

My second comment will focus on 

strengthening and unifying enforcement. Working 

with roughly 2,000 farmer members and numerous 

organic certifiers, we have a unique window to 

see varying policy and practices of standard 

enforcement. 

It is critical that we maintain our 

market and our commitment to consumers. We 

encourage the May 2018 Organic and Enforcement 

Action Plan for pasture surveillance program and 

the interim instruction document on organic 

inputs. We also support the collaborative work 

on the proposed rule for strengthening organic 

enforcement. 

We welcome rulemaking transparency and 

the opportunity to provide input. As a member of 

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the Accredited Certifiers Association, we support 

the working group in developing a best practices 

guide. We must maintain a strong USDA Organic 

seal. We are seeking solutions for uniform 

standard enforcement. 

We recognize three paths forward 

listed in the order of logical preference. One, 

encourage the NOP to publish clear and consistent 

expectations. This will direct a level playing 

field among certifiers. 

Two, ask accredited certifiers to 

comply with ACA best practices to create 

certifier consistency. 

And, three, anticipate additional 

third party certification to meet consumer and 

business needs. 

We appreciate the work accredited 

certifiers do. As a former certification 

specialist, I know what hard work it is, and 

their work is critical. I want to thank the 

National Organic Program and the National Organic 

Standards Board for their time today. 

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MR. CHAPMAN: Thank you. Questions? 

Emily. 

MS. OAKLEY: Just a comment. I just 

want to say that I appreciated your comments on 

marine materials. So, thank you. 

MR. CHAPMAN: Thank you. 

MR. CROTSER: Thank you. 

MR. CHAPMAN: Up next, we have Anne 

Ross, followed by Nicole Dehne. Anne, if you 

could start with your name and affiliation. 

MS. ROSS: Good afternoon. My name is 

Anne Ross, and I'm an attorney working as a farm 

policy analyst and researcher for the Cornucopia 

Institute. One of my primary job duties has been 

to investigate import fraud. 

Not long ago, I received an anonymous 

tip that a certified organic grain operation 

located in Eastern Europe hired an individual 

away from their certifier to manage the certified 

operation's organic division. 

According to the tipster, this 

individual was scheming with his former 

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colleagues who were still employed by the 

certifier to fraudulently label conventional 

grain as organic. Anonymous tips providing such 

limited information can be dead end or can take 

time to sort out, but I think there's a lesson 

here. 

When a certifier's employees, 

consultants, or board members are subsequently 

hired or retained by an operation that the 

certifier certifies, there's a potential conflict 

of interest. This is also true when employees or 

consultants change employment in the opposite 

direction, from certified operation to certifier, 

or even between the NOP and these entities. 

To be fair, the revolving door can 

function in a good way, in that it allows 

different sectors of the organic community to 

make good use of the knowledge and expertise of 

individuals who have dedicated their work in this 

area, but only if we make rules and policies 

around a conflict that could arise. Why? 

Because potential conflicts of interest are in 

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fact conflicts of interest only if they're 

effectively managed. So let's manage these 

conflicts of interest by formally recognizing 

they exist, and are a risk factor for certifier 

fraud, and let's manage them through disclosure 

requirements. 

The NOP should recognize if a 

certified operation hires an individual 

previously employed by a certifier, there's a 

potential conflict we need to manage. If a 

certifier hires a former NOP employee as an 

employer-consultant, there's a potential conflict 

we need to manage. The NOP should require that 

the nature of these relationship be made publicly 

available. 

Requiring public disclosure would be 

consistent with other industries, professions, 

and governing bodies that require disclosure in 

potential conflict situations. These industries 

recognize that this is not a hypothetical 

problem, but circumstances faced by good people 

by virtue of their positions and capitalized upon 

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by a few unethical opportunists. 

Adding this risk factor and disclosure 

requirement helps in fraud detection. It 

protects all of the ethical certifiers and their 

employees from the appearance of bias, and it 

increases public confidence in the organic label. 

Addressing the revolving door scenario allows us 

to focus on productive conflicts, conflicts of 

ideas, and not on breaches of trust that all too 

often accompany unmanaged conflicts of interest. 

I've also submitted written comments 

on this topic which includes more detailed 

recommendations. Thank you very much for your 

time and service to this Board, and I'm happy to 

take any questions. 

MR. CHAPMAN: Good timing. Emily. 

MS. OAKLEY: Thank you. I read your 

comments that were detailed. How would you 

suggest that the NOSB approach this issue? Or do 

you consider this a NOP level concern? 

MS. ROSS: I think the NOSB can 

address it and that there's a very easy way to 

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address it now, and that's to simply add former 

employees as a risk factor. Employees are 

already in there as a risk factor in the 

documents. I think it's page 39 or 40. So 

simply add former employees there. That's the 

first step. 

And I think eventually we need to move 

to disclosure. It helps public trust, and rarely 

do I think transparency is a bad thing. So I 

think the very first step is just simply add 

former employees in what the committee has 

already put forth. 

MR. CHAPMAN: Thank you. 

MS. ROSS: Thank you. 

MR. CHAPMAN: Up next is Nicole, 

followed by Phoebe Judge. Nicole, if you could 

start with your name and affiliation. 

MS. DEHNE: Hi. My name is Nicole 

Dehne. I'm the certification director for 

Vermont Organic Farmers, LLC. We're the 

certification program of NOFA Vermont. We 

certify over 700 organic producers in Vermont. 

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I'd like to thank the NOSB for all of your hard 

work, and the opportunity to give comment today 

on a number of agenda items. 

We strongly support the CS's work on 

the proposal to strengthen the NOP's organic seed 

guidance. We agree that progress towards full 

adoption of organic seed and planting stock is 

far from being achieved, but we commend the 

NOSB's work to clarify the goal of continuous 

improvement and to work with certifiers and 

growers to implement reasonable measures towards 

this goal. 

It was clear that the CS adopted 

public comments on this revised proposal, and we 

agree with the changes made and feel the result 

is a much stronger proposal. One area that 

remains problematic is the section that states 

that non-organic seed can be used if there's no 

organic seed available of equivalent variety with 

the desired level of purity from GMO 

contamination. 

It seems unlikely that organic seed 

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will have more GMO contamination than 

conventional seed. It also seems unrealistic to 

expect non-organic seed companies to tag their 

seed with information about GMO purity. If only 

organic seed companies comply with this new 

requirement, then producers will be choosing 

between a known contamination and an unknown 

contamination, and this may encourage the use of 

non-organic seed. 

Paper pots. I am going to comment. 

The paper pot transplanting system has been a 

game-changer for our producers, our veggie 

producers in Vermont. The 2017 TR on newspaper 

and other recycled paper contains descriptions of 

inks and adhesives used in these products. This 

means that these items were considered when this 

material was reviewed and approved for addition 

to the National List. We strongly feel that if 

newspaper and other recycled paper is allowed for 

organic crop production, that paper used for 

paper pots should be allowed for organic crop 

production as well. 

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We strongly recommend that the NOSB 

ask the NOP to extend the current allowance of 

the material through the 2019 growing season to 

allow the NOSB to review the petition and to 

officially approve the material for use on 

organic farms and for the NOP to engage in 

rulemaking. 

Also, in general, we support the 

efforts of the CACS to outline areas of 

improvement for the training and oversight of 

inspector and certification review personnel. We 

support the document and its goals, but would 

like to ensure that the NOSB recommends to the 

NOP that the program develop and articulate 

skills and knowledge that inspectors and 

certification staff need, but allow for 

flexibility for how those skills and knowledge 

are taught. Thank you. 

MR. CHAPMAN: Harriet. 

MS. BEHAR: On the transparency of the 

genetic contamination, do you feel it's more 

beneficial for farmers to know what the amount of 

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genetic contamination might be, or would it be 

better just as it is now and they just don't 

know? But then, of course, neither way would 

they lose their certification on the final crop. 

But, I mean, would it cause stress by knowing or 

something? I don't know. 

MS. DEHNE: I think it's the 

usefulness of the knowledge. So, if we're using 

it but we're using it to make a choice, then if 

we don't have the other information then the 

choice -- then the knowledge isn't very useful. 

So, in this particular case, when 

we're saying, you know, that if you can choose 

non-organic seed if the organic seed has some GMO 

contamination, it's only valuable if we can 

compare apples to apples. 

MS. BEHAR: The proposal requires all 

seed planted on organic land to have that level 

of purity testing. So either the organic seed 

supplier, the non-organic seed supplier, or the 

farmer would have to produce that. So there 

would be knowledge at some point in the system. 

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MS. BEHAR: You know, I guess it 

wouldn't have to happen before purchase, if they 

chose. I mean, it would be nice to know, but 

they would know at some point and it would be 

part of the organic system plan, so we would have 

that database to track. 

MS. DEHNE: Harriet, if that were the 

case, that would make sense. I'm just concerned 

about how we regulate the non-organic seed 

producers, even if it's on the organic farm. 

That seems tough to me. 

MR. CHAPMAN: Thank you. Up next is 

Phoebe Judge, followed by Kiki Hubbard. Phoebe, 

if you could start with your name and 

affiliation. 

MS. JUDGE: My name is Phoebe Judge 

and I work at Vermont Organic Farmers as a 

materials review specialist. I appreciate all 

the thoughtful work from the members of the NOSB 

and for giving me the comment period. 

Firstly, I would like to stress how 

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vitally important it is for organic producers to 

be able to utilize technologies that help them 

improve efficiency and reduce labor. The paper 

pot transplanting system is one of these 

technologies. Expanding the use of paper, 

including paper from hemp, to be used as a tool 

applied to the soil as a planting aid, including 

as pots and seed tapes, is a low-risk expansion 

from allowing newsprint and recycled to be a 

compost, feedstock, or a mulch. 

We strongly encourage the NOSB to ask 

the NOP to extend the use-up period for these 

paper pots to the end of 2019 growing season 

while the Crops Subcommittee reviews the petition 

to add paper as a planting aid. 

Secondly, as the NOSB considers the 

use of vaccines as a tool for organic livestock 

production, it is important to ensure the use of 

non-organic -- non-GMO vaccines are used when 

possible. VOF currently allows only the use of 

non-GMO vaccines on our certified farms. We 

require vaccine manufacturers to sign an 

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affidavit stating which of their vaccines comply 

with the NOP's and the NOSB's working definition 

of non-GMO production methods. 

We would, however, support the use of 

GMO vaccines in the case when no non-GMO vaccine 

is available for the treatment of a disease. If 

GMO vaccines are to be used in organic livestock 

production, however, we ask that the vaccines be 

added to the National List according to 

205.600(a). 

Lastly, we appreciate the NOSB's 

attention to the issue of Bisphenol A, or BPA, in 

food packaging, and support continued research 

into alternatives to BPA. 

More broadly, we urge the NOSB to add 

the issues of phthalates in organic milk and 

dairy to its work agenda. Phthalates are a group 

of chemicals that have been linked to a wide 

range of reproductive and neurodevelopmental 

problems, and they have no place in the 

consumer's idea of what organic means. 

We share the concerns of our 

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colleagues at the Center for Food Safety and 

elsewhere that phthalates in organic milk and 

dairy products must be reduced. We would also 

ask that the NOSB request input from organic 

dairy producers and processors on which products 

and suppliers they use for equipment containing 

phthalates, and to generate ideas for reducing 

these contaminants. Thank you again for your 

work. 

MR. CHAPMAN: Questions? Ashley. 

MS. SWAFFAR: So, when you ask those 

vaccine manufacturers, what are the excluded 

methods that you list? 

MS. JUDGE: We supply the affidavit 

that includes both the NOP's definition of a nonGMO production method and the NOSB's working 

definition. 

MS. SWAFFAR: So transposons aren't 

included in that at this time? 

MS. JUDGE: No. 

MR. CHAPMAN: Thank you. 

MS. JUDGE: Thanks. 

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MR. CHAPMAN: Up next we have Kiki 

Hubbard, followed by Pat Kerrigan. Kiki, if you 

could start with your name and affiliation. 

MS. HUBBARD: Good afternoon. My name 

is Kiki Hubbard. I'm the director of advocacy 

and communications for Organic Seed Alliance. We 

are a mission-driven organization that works 

nationally to ensure that organic farmers have 

the seed they need through research, education, 

and advocacy. 

My comments today will touch on three 

topics. First, OSA is very supportive of the 

work of the Materials Subcommittee to provide 

further clarity on excluded methods. We support 

passing this proposal and encourage ongoing 

clarification of definitions per our written 

comments. 

Secondly, OSA appreciates the hard 

work of the Materials Subcommittee on the 

incredibly complicated issue of genetic integrity 

and transparency. We're pleased to see ideas 

fleshed out to move the conversation forward, and 

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we're especially happy to see a proposal that 

underscores the importance of sourcing organic 

seed when it's available to incentive broader 

adaption of this critical organic input, when 

appropriate. 

However, we do believe the proposal 

could use more work, and we don't support it at 

this time, at least as written. 

OSA agrees that testing for and 

monitoring unwanted trace developed through 

excluded methods is a very good idea, and we hope 

to gain more clarity about the purpose and goal 

of this proposal and how the findings of any type 

of pilot project would be used at this meeting. 

Lastly, we're very happy to see the 

organic seed proposal back on the agenda this 

week. It's important that these changes to the 

seed regulation and guidance for certifiers move 

forward for a number of reasons, not the least of 

which is to spur the development of more organic 

varieties that help organic farmers stay 

competitive and adapt to changing climates and 

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markets. 

As the availability and diversity of 

organic seed increases, policy must follow suit 

to ensure increased adoption in a measurable and 

reasonable way. OSA supports amending the 

organic regulations at Section 205.204 as written 

in the proposal. 

We support most of the proposed 

changes in NOP's organic seed guidance document. 

In particular, we're pleased to see stronger 

language that emphasizes the role of on-farm 

trials and aspects of non-compliance. We do 

offer additional changes to the guidance to 

consider in our written comments. 

OSA's research team has seen firsthand that many organic farmers are increasingly 

conducting organic variety trials, and so this is 

why we're again very pleased to see trials 

highlighted in the proposal. 

Seed represents profound potential for 

transforming how we farm and what we eat, and it 

helps the success of farmers who grow 

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organically. So we're very grateful that the 

Board continues to make organic seed policy a 

priority, and we're very grateful for your time 

and your service. Thank you. 

MR. CHAPMAN: Harriet. 

MS. BEHAR: I want to thank you, Kiki, 

for helping me get in touch with seed suppliers 

and flesh out some of those issues on both of 

those proposals, organic seed and genetic 

integrity. That was very useful to talk with 

them, and I think some of them will be giving 

public comment as well. 

MS. HUBBARD: You're welcome. 

MR. CHAPMAN: Emily. 

MS. OAKLEY: Thanks, Kiki. I have a 

question on the Crop Subcommittee's proposal to 

amend NOP Guidance 5029 and the section for 

4.1.3(d), contamination from GMO consideration: 

non-organic seed can be used if there is no 

organic seed equivalent available, or available 

of equivalent variety with the desired level of 

purity from GMO contamination. 

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Because, as an organic farmer, we've 

discussed this in the Crop Subcommittee, you 

know, organic seed is about more than just nonGMO contamination. So I'm curious. As was 

mentioned in the previous comment, how extensive 

do you think this would be applied? Do you think 

this is a very small percentage of seed that 

would be opted out for in this level of the 

document? 

MS. HUBBARD: Well, it of course 

depends by crop type. We are concerned -- first 

of all, I think already that can be used as a 

reason to not source seed that has levels of 

contamination that might exceed a desired level 

of purity, especially per a contract agreement or 

something like that. 

We are concerned with that existing 

language right now, with references to seed 

purity, because there currently is not an 

industry standard. And so it is potentially 

confusing and potentially difficult to enforce. 

So as this time, we recommend leaving out 

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references to seed purity until the Material 

Subcommittee provides more direction through 

their work on genetic integrity and transparency. 

MR. CHAPMAN: Thank you, Kiki. Up 

next is Pat, followed by Alan Lewis. 

MR. KERRIGAN: Hello everyone. I'm 

Pat Kerrigan with the Organic Consumers 

Association and Regeneration Midwest. To NOSB 

members, NOP staff and organic stakeholders, 

Southwestern Minnesota organic vegetable farmer 

Jack Hedin recently quoted in The Star Tribune as 

saying "In an era of more frequent and more 

intense rainfall during the growing season, the 

Upper Midwest may simply be becoming too wet, too 

often to grow fresh market vegetables 

profitably." 

It's hard to imagine that many of us 

will be left in 20 or 30 years, much less how he 

industry can grow in response to consumer demand. 

One of the most sobering editorials of the many 

sobering editorials I've read this year. 

His farm, Featherstone Farms, has been 

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instrumental in helping to build a thriving Twin 

Cities organic food scene, which features dozens 

of restaurants selling locally and organically 

produced foods, and the largest food co-op 

network in the country. 

But as Jack Hedin points out, our 

producers are facing a grave and growing climate 

change threat. Climate change is the elephant in 

the organic room, and we simply can no longer 

ignore because it is not part of the NOSB work 

agenda. We cannot continue to ignore what's 

happening in the world around us and across the 

Midwest. 

Our climate change crisis and how the 

organic community can respond needs to be a 

perennial part of the NOSB's work plan. 

Improving soil health and soil resilience is not 

only good land stewardship, but it's becoming 

more and more critical for keeping both the soil 

and those who farm it on the land. 

We are well underway, but have so very 

little time and we have so much to accomplish. 

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We simply must accelerate our efforts. The good 

news is that the soil solution is indeed under 

our feet, and that the regenerative agriculture 

movement is becoming all the rage all across the 

country. 

In my work with Organic Consumers 

Association and Regeneration Midwest, I am so 

fortunate to be able to spend my work days 

learning about and speaking with regional 

regenerators, along with their governmental, nonprofit, academic and business allies. 

Through the 13 state Regenerative 

Midwest Network, we are building consumer 

awareness and market demand, as well as market 

infrastructure for regenerative organic products 

in the Midwest and beyond. 

I'm encouraged and inspired by Midwest 

regenerative leaders such as Gabe Brown and his 

cover crop cocktails, David Brandt and Regi 

Haslett-Marroquin, who are doing a fantastic job 

in educating farmers and ranchers about the many 

benefits of incorporating regenerative practices 

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into their operations. 

And I'm very grateful for the work 

that Minnesota Sustainable Farm Association, the 

Minnesota Institute for Sustainable Agriculture 

-- oh man, it goes so short. We can regenerate 

soil health. We can do it. We have to do it and 

we need to take a stand for soil. Thank you. 

MR. CHAPMAN: Thank you, Pat. Any 

questions for Pat? I'm not seeing any. Thank 

you, Pat. Up next is Alan Lewis, and on deck is 

Jay Feldman. Alan, if you can start with your 

name and affiliation. 

MR. ALAN LEWIS: Alan Lewis. I work 

for Natural Grocers. It's a family-run health 

food chain, 150 stores, all certified organic in 

19 states west of the Mississippi. Organic is 

meaningless. I've been on the road almost every 

day in October and every day I hear somebody tell 

me that organic is meaningless and it's 

infuriating, and I know it's infuriating to all 

of you as well. 

Typically, this is someone in 

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agriculture in their 20's, and I take a breath 

and I take them aside and I remind them that the 

traditional knowledge of health and ecology are 

what organic is all about, and the new science of 

the soil biome and the human biome have finally 

caught up to our traditional understanding, and 

that human health and global health and climate 

change, nutrient density and all of these are 

tied up in the ethic of organic, and it's 

anything but meaningless. 

So here's the problem. If we're 

facing all of these complex chronic diseases 

especially in that generation, and we know now 

that all of our organic practices are the cure 

for complex chronic disease, we have a whole, 

people from all walks of life, all over the world 

coming back to ecologically responsible 

practices. 

There are two million food retailers 

in the U.S. Fewer than a thousand are certified 

organic processors, handlers one-tenth of one 

percent. The 99.9 percent are taking beautiful 

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organic produce and products, transporting them 

in contaminated trucks, putting them in 

contaminated totes, storing them in contaminated 

coolers, washing them in contaminated water and 

exposing them in particular to egregious toxic 

chemicals under conventional pest control 

regimens. 

So we're not really delivering on the 

organic promise. So maybe those 20-somethings 

are right. We have one tool in the tool box that 

is in OFPA Jenny, and it could really help the 

situation, and that's the logo on the screen. It 

is illegal for exempt or excluded operations to 

use the USDA organic seal, and yet 99.9 percent 

of retailers in the United States are able to and 

often use that seal and represent themselves as 

certified organic operation. 

We need to use that tool so that 

consumers who are looking for certified organic, 

clean, helpful, healthy organic products know 

where they can find it. 

There's many retailers in the room 

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this time around, including the co-op grocers, 

all of them spent hundreds of thousands of 

dollars getting certified, having an organic 

system plan, getting audited, correcting noncompliances and working with organic pest 

control. It's incredibly important to consumers, 

and that's ultimately what's going to make 

organic meaningful again and forever. Thank you. 

MR. CHAPMAN: Thank you. Thank you 

Alan, timing was great. Questions for Alan. 

Emily? 

MS. OAKLEY: Is it appropriate to ask 

you for a specific example of an inappropriate 

use of the USDA seal in a retailer situation? 

MR. ALAN LEWIS: So I've sent a number 

of examples to NOP enforcement. One is Aldi in 

Kansas City, in fact all of their remodeled 

stores. It's public knowledge. They're using a 

teal and mauve stylized version of the seal, 

which is against the law as a motif in their 

produce department. 

They have no organic system plan, no 

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organic controls, and yet that logo is everywhere 

for consumers to see. Related to that is bulk 

products at almost every non-certified retail. 

Those are transported without a system plan. 

They're all unaudited. They're opened and 

relabeled by a non-certified operation, and the 

green, white and brown logo is on the bulk bin. 

Now I like promoting organic and I 

like to see the seal, but we have a disconnect 

and there's a tool to connect this. Make the 

retailers and the distributors in the supply 

chain comply with a verified organic system plan, 

because the health effects of organic I don't 

think are coming through, particularly because of 

the pest control materials that are being put 

outside the store, in the store and throughout 

the supply chain. 

MR. CHAPMAN: Thank you, and Alan has 

submitted written comments with photos of those 

examples, so you can go find that one. I had Dan 

and Steve. Dan, then Steve. 

DR. SEITZ: So Alan, just to 

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understand, so you're -- if I understand you 

correctly, you're saying that food may be kept in 

an organic state all the way until it gets to a 

retailer, and when it reaches the retailer, if 

they're not certified, apart from the advertising 

abuses that you've observed, that just the normal 

store practices may compromise the organic 

quality. Is that sort of the core of what you're 

saying? 

MR. ALAN LEWIS: That's correct, Dan. 

There's only one, for instance, national pest 

control company that can do a proper organic pest 

control program. The other two or three big ones 

that are left are consolidation have no 

capability to do this, and they're the ones 

deployed throughout the food system and 

particularly in retail. 

MR. CHAPMAN: Steve. 

MR. ELA: So you touched on bulk 

displays, repackaging and such. I mean certainly 

we know there's a lot of stores that have both 

conventional and organic produce displayed, 

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commingled. Can you go a little further on that? 

MR. ALAN LEWIS: Well it was another 

-- that is correct. You've seen pictures, 

locations. You cite song and verse of the OFPA 

so that the enforcement folks don't have any 

extra leg work to do. They can answer the 

questions. I sent pictures of a Whole Foods in 

Boulder displaying unstickered bell peppers 

conventional on one shelf, unstickered organic 

bell peppers right underneath it, and I raised 

the question whether this was a compliant organic 

system plan to prevent commingling. 

Both the certifier and the NOP pretty 

much said don't worry your pretty little head, 

that's fine. Gravity and customers and moving 

stuff around doesn't make sense. I think there 

should be an organic section and conventional 

section, and certainly not conventional over 

organic. 

So it's an example of something where 

the certifier is defending a practice that would 

be one phone call to say tell your guy not to do 

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it that way. 

MR. CHAPMAN: Harriet, briefly. 

MS. BEHAR: Are you aware that the 

Organic Trade Association, oh geez it's been at 

least 15 years ago, put out a book called "Good 

Organic Retailing Practices" to try to help 

retailers do a better job, especially those that 

are not certified, to understand the practices 

they need, like don't put the organic underneath 

dripping non-organic produce from above. Have 

you seen that or heard about that? 

MR. ALAN LEWIS: I haven't seen that 

particular document. NOP has one for retailer 

compliance, general retail compliance. If you 

drop an apple on the floor, don't call the 

police. Wash it off, put it back on the display, 

things like that. 

Some retailers are better, not all are 

bad. I think my example at Aldi's kind of an 

egregious use of the seal, because I once 

submitted a seal with the wrong color brown on 

it, and Sam Welsch kicked that out, nonNeal R. Gross and Co., Inc. 

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compliance, right? So mauve and pink I think 

would have thrown him into conniption. 

Kroger's, pretty good, and you know 

I'm the organic police. That's what I do on 

vacations, go into grocery stores. So I think 

some are more committed than others. But still 

you see this logo, and what I want the singular 

message here is consumers need to see the logo 

and think certified supply chain. 

Right now they're seeing the logo and 

assuming that all that bulk, and all the apples 

and oranges and everything are properly accounted 

for and protected, and it would be a really 

important tool for the federal government to 

start using to enforce. 

MR. CHAPMAN: Thank you, Alan. 

MR. ALAN LEWIS: Thank you. 

MR. CHAPMAN: And retailer beware if 

Alan's coming to vacation in your town. Up next 

is Jay, followed by Albert Straus. Jay, give us 

your name --

MR. FELDMAN: Good afternoon. My 

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name's Jay Feldman. I'm Executive Director of 

Beyond Pesticides and a former NOSB member from 

2010 to 2015. Thank you all for your service. 

Thank you NOSB members and NOP staff. So 

continuing in Alan's, in the spirit of Alan Lewis 

and continuous improvement, we'd like to raise 

some serious process issues with you all today. 

We may not always agree on decisions 

that are made by the Board, but we must and 

should agree on the process, the decision-making 

process. We need a rigorous transparent process 

of review of national materials, on National List 

materials, that builds and protects the organic 

brand. 

That process must do two things. It 

must show the public that critical scientific and 

essentiality issues are considered, and it must 

incentivize the market to make available nontoxic products compatible with protection of 

public health and the environment. 

So we need to create a record, and the 

important elements of that record are rigorous, 

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robust and reported review, documentation of all 

positions of all stakeholders, transparency 

through the release of detailed notes. 

The public needs to see that the Board 

considered all issues related to cradle to grave 

adverse effects, compatibility with organic 

practices, including biodiversity, ecosystem, 

protection of the ecosystem including soil 

management and essentiality. 

The Board should reinstitute the 

practice of documenting minority positions. One 

of the many examples on the agenda of this 

meeting is sodium carbonate peroxyhydrate, which 

is noted to be highly toxic to bees. The CS 

voted two to delist five to relist without any 

explanation of the discussion and consideration 

of the criteria for listing. 

Work plan. The public discussion of 

the work plan that we heard earlier today is a 

positive sign. Until we fix the work plan 

setting process, we suggest that the Board 

announce at every board meeting work plan 

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requests that have been rejected by NOP, and NOP 

has the opportunity to provide its reasoning. 

In addition, when a proposed work plan 

item is rejected or removed, put the issue into 

the Subcommittee notes. Then the public could 

weigh in when the notes are docketed and 

according to Board policy by the way, passed by 

this Board. 

Inerts. At this point, we are out of 

compliance with the law, and put listed materials 

in legal jeopardy. Then there are thematic 

concerns. We need a fermentation policy. The 

issue of gellan gum came up. A true example of 

the breakdown in the process. CBI is not 

disclosed as a part of the original petition or 

in the sunset process, and as a result the nondisclosure of sources and detailed description of 

manufacturing procedures cannot be evaluated. 

Unless a manufacturer has sourced 

organic or non-GE corn for its glucose syrup used 

in the fermentation process, it should be 

considered made with excluded methods. Now this 

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is true for other fermentation mediums, xanthan 

gum, et cetera. We need a sanitation policy. 

The Board should not be approving chlorine 

materials at this meeting until such a policy is 

in place. Thank you. 

MR. CHAPMAN: Thank you, Jay. Emily. 

MS. OAKLEY: Yeah. I appreciate your 

comments about listing the minority view, because 

it is definitely something that I thought of as 

we made those deliberations, and then realized 

that that's not tracked through the documents. 

So then stakeholders don't necessarily understand 

how it is that some people came to the decision 

to vote the way that they did, when it isn't a 

unanimous vote. 

So you've suggested that we put the 

minority view back in as I understand it, when 

the PPM is slightly different than what you're 

suggesting. So how is it that you would suggest 

a road map for discussing or addressing after the 

fact votes, representing divergent views or 

voting positions? 

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MR. FELDMAN: Well, we have to 

remember that this Board has the statutory 

responsibility to advise the Secretary. So we 

need a little more pushback, folks, in terms of 

the policy and procedures. 

One critical element in representing 

the stakeholders, and I don't -- it doesn't 

matter which side you're on on a particular 

issue, is that that voice is heard through these 

documents. 

And that process is -- can only be 

expressed through the minority view, or at least 

-- I mean I would consider that the views of the 

Subcommittee, because they're being expressed and 

discussed. So yeah, I mean what -- you hit the 

nail on the head in pointing to the PPM, because 

that obviously establishes the process of review 

in the outline. 

The thing that's important to remember 

here is that the process that we use for 

approving a petition is the same process we 

should be using in the sunset process. If you 

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look at this meeting at the documents for 

petition review, they're much more thorough. 

There's much -- they're much more robust. 

We need that same documentation, that 

same attention to new science, new information on 

essentiality, and I would argue, as was the case 

when I served on the Board, checklists for the 

sunset process so that the public can look at 

this. 

Even if they don't agree with the 

solution, well they can say well that was wellreasoned. There's science here. I trust the 

Board is doing its due diligence. So it does go 

back to the PPM. 

MR. CHAPMAN: I mean I'm looking at 

the PPM. We have a section for a minority view. 

There's also no section I'm aware of that 

prohibits the accurate summation of the 

discussions of the Subcommittee. If anything, if 

it's missing from individual proposals that was 

missed by those individual members of those 

subcommittees. But is there some prohibition 

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that I am missing that you're referring to? 

MR. FELDMAN: Well, it's not a 

question of a prohibition. It's a question of an 

affirmative policy requiring that the stakeholder 

voices are heard through those documents, and I 

didn't see -- I could be wrong. I didn't see any 

attention to minority views throughout the 

proposals or documents that was provided to the 

public. 

I'm not just saying that, you know, 

two people disagreed with the majority. I mean 

I'm talking about a documented, cited 

justification for positions that are voiced by 

both sides, including the minority side. 

So the answer to your question I think 

Tom is that yes, we'd like to see an affirmative 

requirement that the documents that are presented 

to the public cover the waterfront, as it were, 

of those issues and positions. 

MR. CHAPMAN: Emily. 

MS. OAKLEY: I completely agree with 

you in theory, and I'm sitting here trying to 

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think about how practicality would be applied in 

this, because you know many times some of those 

decisions aren't made until the vote is made, and 

that discussion takes place during the course of 

the meeting. 

But we're voting on a document as it's 

written. So that would lengthen the process, 

because we would have to then take that document 

back, craft a minority description for why people 

abstained or voted no, then bring it back again 

potentially to vote on that finalized version of 

the proposal or whatever it may be, sunset 

review, that we're then sending back for a final 

approval by the NOP. 

But it is -- I just want to say it's 

something I will give a lot more thought to. I 

think we can discuss it as a group. I think 

practically it might be a little challenging, but 

we should try to explore it. 

MR. FELDMAN: Thank you. 

MR. CHAPMAN: Thank you. 

MR. FELDMAN: Thanks. 

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MR. CHAPMAN: Up next, we have Albert 

followed by Dale Woods. Albert, can you start 

with your name and affiliation? 

MR. STRAUS: Affiliation, okay. My 

name's Albert Straus. I'm founder and CEO of 

Straus Family Creamery and have an organic dairy 

farm. We were the first certified organic dairy 

and creamery west of the Mississippi River, and 

my company's built on relationships with our 

farmers, with our customers. 

Organic integrity and creating a model 

that's actually showing the world that farms, 

livestock farms, dairy farms are a primary 

solution to climate change. So but what we need, 

and I appreciate you guys, your work, your 

efforts and Scott's beard. 

But the tools that I'm trying to --

certifiers, when they're looking at dairies, need 

tools to be able to benchmark or to really come 

up with a baseline for farms. I presented a tool 

before. It was a pasture stocking rate tool. 

I've now found a -- it's actually an app for a 

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hunting app, which actually gives you parcels, 

the name of the parcel, the acreage of the 

parcel. 

And then in collaboration with this 

pasture stocking rate, we can see that -- there's 

one instance I have is a 1,200 cow dairy that's 

on 312 acres, that my calculation says that they 

should only be able to milk 624 cows. So it's a 

baseline to have certifiers and inspectors look 

at, and then to kind of say if there's some 

difference, show us where the proof is. 

The second part of what I wanted to 

talk to you guys about is we've been -- we were 

the first dairy to have a carbon farm plan to 

sequester 2,000 metric tons per year. Twenty 

percent of that is from adding compost and using 

animals to graze and planting hedge rows and wind 

breaks. 

We've been working with a NASA 

scientist to quantify the amount of growth of 

biomass or pastures and crops using satellite 

imagery, and to -- it's to really build the case 

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for -- the economic case for farmers to do these 

practices. So this is a graph of the nine 

dairies that supply our creamery, and when they 

went organic and then proved over the last 18 

years, the improvement of biomass production. 

And then what we also are showing is 

that there's probably about 100 acres, excuse me, 

$100 per acre per year savings by growing more to 

feed on farm versus having to buy off-farm feed. 

So we're really trying to make something that can 

be expandable, really make a difference, and show 

that farms are really a viable entity. Thank 

you. 

MR. CHAPMAN: Any questions for 

Albert? Harriet. 

MS. BEHAR: Did you bring any ice 

cream? 

MR. STRAUS: We're in the wrong part 

of the country. 

(Laughter.) 

MR. CHAPMAN: So maybe -- maybe the 

Seattle meeting then? 

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the economic, the economic impact of having 

dairies convert or do continuous conversion. If 

there's a ten percent surplus of organic milk and 

these farms are producing more and more milk, 

you're depressing the price for everybody in the 

industry. 

So the dairy farmers are suffering all 

over the country. The excess production is the 

driving force behind it. So I want to add that 

to kind of just the logic behind it, okay? Thank 

you. 

MR. CHAPMAN: Lisa. 

MS. DE LIMA: Hi, I have a question 

about something you put in your written comment 

about the gums on 606. You had mentioned that 

you were in support of delisting the gums, 

because there were organic versions available, 

and I was wondering if you use any of those gums 

and are able to source organic? So these are --

would be gum arabic, carob and guar? 

MR. CHAPMAN: Can I add to that? If 

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you could also talk about the quantity that you 

source, and whether or not you've had any issues 

in the past? 

MR. STRAUS: The only thing we have to 

use gums are for -- are soft serve, because we 

don't add gums to any of our products unless we 

absolutely have to. The only one we have to use 

some gums are for -- it's a very small amount, I 

think less -- like .2 percent of the mix, in our 

soft serve mix, and it's -- I'm pretty sure we 

have an organic source. 

We don't use these other carrageenan 

with the concern about carcinogens. We don't use 

a lot of these different ones. There is a little 

bit of -- now that I'm thinking about it, there 

is a little bit of gum in I think the chocolate 

chips that we buy. But other than that, I still 

think that using organic sources is -- they're 

available. 

We just need to kind of stop allowing 

the excuses of innovation is driven by necessity. 

You have to have organic sources. I'm sure they 

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can find a way to do it. 

MR. CHAPMAN: Do you know how long 

you've been using organic sources of gums? 

MR. STRAUS: It's been a few years. 

MR. CHAPMAN: More than five? 

MR. STRAUS: They haven't had soft 

serve out that long so somewhere in the three to 

five year. 

MR. CHAPMAN: Okay. Thank you for 

providing that detail. It's appreciated. Thank 

you. 

MR. STRAUS: Thank you. 

MR. CHAPMAN: Up next is Dale, 

followed by Dave Colson. 

MR. WOODS: I appreciate the post five 

o'clock crowd still here. It's really nice. I'm 

Dale Woods. I'm with the California Department 

of Food and Agriculture. I'm the program manager 

for the fertilizer program, which has both the 

conventional and an organic input portion to the 

program. 

We are both -- as the organic portion 

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of the program, we operate both as an MRO, a 

material review organization, but we also have a 

regulatory function for both organics and all 

other fertilizer issues. I want to talk about a 

couple of things this time. 

At the last meeting, I talked about --

I brought up the issue of the liquid fish and how 

to consider the pH 3.5 limitation, and the 

comparison of either using a drift method or an 

absolutely low floor for it, and I'm still kind 

of waiting for a response from NOP for how --

some suggestions about how the CDFA and OMRI can 

kind of come to an agreement about that. 

Also on the liquid fish, for some time 

the NOSB has been asking a lot, the fertilizer 

producers who came questions about their 

environmental concerns about the fish they were 

sourcing. 

I'm actually very glad that this is 

now being moved to more of a work agenda thing, 

because it was kind of clear to me that the 

number of people you had coming here and 

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providing information was an extremely limited 

type group of people, and I don't think you were 

getting a clear picture of what is actually being 

sourced in the world of fish. 

It's a real mess between animal feeds 

and fertilizers. They're deeply intertwined, and 

it would not have been served well to have dealt 

with it with just some comment during this time 

frame. 

Quick question, quick comment on kelp. 

There was a question about how much kelp is being 

used in conventional and organic. We register 

about 10,000 fertilizing labels, and I would tell 

you right now that the vast majority of the 

labels that have kelp in them are in the organic, 

in the organic system. 

That does not mean that the vast 

majority of kelp is being used in the organic 

system. The conventional people who do use it 

use it in a much larger acreage, you know, 

because we're talking about big conventional 

grape growers or something like that. 

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So there's a significant amount of 

kelp that is used in those products, and I could 

not in any way give you any figures about what 

that is because they're not necessarily required 

to give us specific use numbers. Within the 

organic portion, those labels that we do 

register, there's big commercial ag people. 

There's home and garden, tons of home and garden 

people. 

There's a lot of specialty products, 

which is where the largest number of labels that 

we have, they have kelp in them, are those 

specialty products which are used for the 

specialty cannabis market. So that is -- that's 

one of the largest number of labels we have. I 

have no idea about anything else, okay. 

I will mention real quickly paper 

pots. CDFA has not dealt with paper pots because 

no one has asked us. But if it is continued to 

be talked about as a real fertilizing material, 

anyone in California who wants to use it will 

have to register those paper pots with us. 

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 Any time it's mentioned as a benefit 

to soils, it becomes then under our purview and 

they're going to have to register that product. 

MR. CHAPMAN: Thank you, Dave. I've 

got a question, then we'll do Steve and I think 

Emily's got a question. Related to the 

questions, the liquid fish questions that we had 

been asking, and the sustainability of fish, 

there's been questions around, and I don't know 

to what extent you can disclose an aggregate data 

or not. Do you have a sense of the market origin 

of the fish? Is it a byproduct? Is it a product 

that's wild caught specifically for the 

fertilizer products? Is there other origins? 

MR. WOODS: U.S. and Mexican producers 

are basically doing stuff that's split between --

I mean their primary market is the pet food 

market, I mean and then human fish oil stuff. So 

the fertilizer is purely an afterthought. But if 

the fertilizer people aren't going to take it, it 

gets tossed. It's purely a waste product. 

That is maybe a little bit less true 

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internationally, but it is still a part of the 

issue. All these guys are sourcing stuff. Most 

of it is as an afterthought for the other 

markets. But some of it is truly wild caught, 

and some of it is -- some of the stuff is 

actually cultivated. 

MR. CHAPMAN: Okay. Steve, then 

Emily. 

MR. ELA: So two questions on the 

fish. How would -- I mean it's now on our work 

agenda. How would you suggest we craft a TR 

request or word to get a better answer on this, 

exactly what you were just saying? Do you have 

any thoughts? 

MR. WOODS: Yeah, I don't know. 

That's my concern, is it's a -- they're not 

necessarily interested in getting a lot of 

information to the fertilizer world because it's 

a blip on their economic thing. I mean sure, 

they'll sell it to the fertilizer people, but if 

the fertilizer people --

If a registrant asks them too many 

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questions, they say go away, we're not going to 

sell it to you. You're not worth my time. So 

it's going to be hard. It's going to be really 

hard. 

MR. ELA: And then your last comment. 

So on the paper pots, if it's used as a mulch, is 

that -- do you call that a fertilizer? 

MR. WOODS: You see the reason -- the 

reason we did not have to deal with it is that we 

viewed this as a certifier question, because as 

long as it's a pot, it's basically a planting 

issue. They're using a pot, they're planting it. 

That's in the certifier realm. That's not in an 

MRO. That's not in our MRO stuff. 

However, because it's not really a 

fertilizing input as long as there's no claims 

made for it. But as soon as claims are made that 

this is a benefit to the soil, that is that it 

provides soil-amending qualities, now you're by 

state law drawn into our fertilizer realm, and 

then those products must be registered with the 

Department in order to be sold in California. 

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MR. ELA: So if they just don't say 

anything, they just apply a mulch. 

MR. WOODS: Well here's -- here's the 

problem, is that this meeting has done that. You 

know, the manufacturer could sit there and just 

say hey, here's a pot, you know, and we'd never 

pay any attention to it at all. But now in the 

world of organics, everyone is saying okay, 

here's these paper pots. 

They've been used for this purpose, 

and by the way they have soil-amending 

functionality. So now it's been drawn into our 

world, whether we wanted it or not. 

MR. CHAPMAN: Dale, can you briefly 

describe the scope of authority of the CDFA 

material review, since it's different than OMRI 

or other material review organizations? 

MR. WOODS: The original, the origin 

of our stuff is basically to deal with review for 

fertilizing products to be used in California. 

That is our original mandate. However, our list 

is available to anyone. Certain certifiers 

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throughout the U.S. and wherever use our, use our 

list. 

We have suppliers, we have people 

coming from all over the world that are 

registering products with us. We have a little 

over 2,000 organic OEM products that we have 

listed. If you wish to distribute a product as 

an organic input material for growing in 

California, it must by law be registered in 

California. If it's not, it's subject to 

quarantine and/or civil penalties. 

MR. CHAPMAN: But your program doesn't 

go to the extent to review pesticides per se --

MR. WOODS: We do not. There's a 

large number of things we don't deal with. We 

don't deal with anything associated with animal, 

livestock issue, nothing with processing and 

handling, nothing with pesticide. It's purely 

this one little piece. 

MR. CHAPMAN: Yeah, thank you. Emily? 

MS. OAKLEY: Thanks for your comments 

on liquid fish. When we requested that for the 

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work agenda, we actually focused on wild caught 

fish harvested whole exclusively for the use as 

fertilizer. But I'm hearing in your comments 

concern about byproduct fertilizers, that might 

be the byproduct of the pet food industry or 

human oil consumption; is that correct? 

MR. WOODS: Sure. Almost, I'd say the 

larger fish people are out there -- out 

collecting fish knowing, you know, probably the 

larger ones are out there collecting fish, 

knowing they're bringing it in for the pet food 

market and the leftovers go to the fertilizer 

world. 

So that is wild caught fish focused 

directly on fertilizer. Not their primary goal, 

but that is a piece of what they're out there 

for. 

MS. OAKLEY: You're saying it provides 

part of the economic benefit of that product? 

MR. WOODS: Yes, yes. 

MS. OAKLEY: So we should potentially 

expand the scope of the review? 

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MR. WOODS: Well, I just think it 

complicates it. I don't really know where you're 

going to go with it. 

MS. OAKLEY: Okay, thank you. 

MR. WOODS: Thank you. 

MR. CHAPMAN: Thank you, Dan. Up 

next is Dave Colson, followed by, I apologize if 

I butcher this name, but I think Bjarne Pedersen. 

Dave, if you start with your name and 

affiliation. 

MR. COLSON: Good afternoon. My name 

is Dave Colson. I'm a proud certified organic 

farmer from Durham, Maine, and I'm also the 

Organic Agricultural Services Director for the 

Maine Organic Farmers and Gardeners Association. 

I'd like to focus my comments on the marine 

materials discussion. 

My comments are in addition to those 

submitted by MOFGA Certification Services. 

Regarding the feasibility of requiring all 

seaweed harvested for use in organic crop 

production to be certified to the wild crop 

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standards, MOFGA believes this would be difficult 

to accomplish in practice. 

MOFGA Certification Services currently 

certifies sea vegetables for human and animal 

food using different aspects of the national 

rule. The impetus for developing the standards 

was due to the change in the particular seaweed 

product kelp from the classification of a feed 

supplement to a feed additive. 

Many farmers around Maine and around 

the country told us of the need for this product 

in the feed rations and their wanting to continue 

to allow the use of kelp. A certified process 

needed to be developed. 

The sea vegetable standard was put 

together not with a comprehensive look at the 

ocean ecosystem, the intrinsic value of seaweed 

contributions of the marine environment, or how 

harvest of these crops might affect the 

environment, but in a somewhat convoluted process 

of utilizing the existing land-based standard and 

applying it to a seed-based crop. 

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While not perfect, this standard did 

allow for the continued use of kelp in livestock 

feed and for the certification of kelp for the 

human consumer market. Now we are facing 

questions of sustainability and the value of a 

number of seaweeds in the marine ecosystem, and 

not just as a product for human and animal 

consumption. 

History has shown us they were not 

always good stewards of the ocean, its flora and 

fauna. Settlers came to Maine and the maritime 

provinces for the abundant resources of seafood, 

sturgeon, cod, haddock, herring and more. One by 

one we've seen these resources depleted. Shrimp 

has not been harvested from the Gulf of Maine for 

three years now. 

A new market for sea urchins booming 

just a few years ago has dried up. Lobsters, one 

of the bright spots in Maine fisheries, but their 

abundance can be traced in part to the decline of 

their predators. Now we are in the process of 

taking the very foundation of the marine 

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ecosystem, seaweed, and exploiting for commercial 

use. 

I realize that the portion of seaweed 

harvested and used by the organic community is 

small in comparison to the amount of total kelp 

or ascophyllum harvested in Atlantic waters. But 

we as an organic community have an opportunity to 

step back, look at the larger context of the 

oceans and their resources, and make a choice 

that can send a message to the wider community 

about safeguarding our natural resources. Isn't 

this what organic farming was all about in the 

beginning? That was fast. 

I appreciate the chance to make 

comments, and thank you for your work. 

MR. CHAPMAN: Thank you, Dave. Any 

questions for Dave? Emily. 

MS. OAKLEY: Thank you for your 

comments. I know both in MOFGA's comments and in 

the comments of one of the producers that MOFGA 

certifies, there is concern that if this 

requirement for wild caught standard 

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certification for the ingredient, in this case 

rockweed for a crop input were mandated, that it 

would push producers into pristine areas. 

But when I read that I was thinking 

well, wouldn't that then be excluded because it 

would be not adhering to the environmental impact 

portion, not destructive to the environment in 

the wild crop standard? I was wondering if you 

had any thoughts on that. 

I would also just want to note that 

some of this rockweed in Maine is harvested for 

livestock feed, and the exact same operators and 

the same boats and the same materials then go out 

and harvest rockweed in a different area for crop 

input. So I think that's where that concern was 

coming from, that they would be moving into more 

pristine areas for the crop input. Thoughts on 

that? 

MR. COLSON: Yes. So one of the 

interesting things about thinking about pristine 

areas, and in some ways these are conserved areas 

but Robin Hadlock Seeley talked a little bit 

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about this earlier, in the establishment of the 

sea vegetable harvesting guidelines, we had to 

apply a number of buffers, and this was included, 

I believe in the certification, MOFGA 

certification services comments. 

So things like 20 miles from a nuclear 

facility, three miles from a commercial boatbuilding facility, three miles from an industrial 

waste discharge area, three miles from any city 

or town sewage discharge, three miles from a 

harbor or thoroughfare and there's, you know, 

more in addition to that. 

So a pristine area would be one that 

would be considered to be not near any of those 

things. So harvesting from that area in a sense 

would be the default place for harvesters to go, 

since it would be easy for them to pinpoint where 

that area was and that they were harvesting those 

certified organic seaweeds from those areas. 

MR. CHAPMAN: Any other questions? 

Thank you. 

MR. COLSON: Thank you. 

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MR. CHAPMAN: Up next is Bjarne, 

followed by Doug Currier. If you could start 

with your name correct if I messed up and 

affiliation. 

MR. PEDERSEN: Thank you, I think 

you're doing fine. My name is Bjarne Pedersen, 

and I'm from Denmark. I'm affiliated with and 

represent a Danish company, Ellepot. Ellepot 

manufactures a paper pot system. I'm very 

thankful for the opportunity to be here to 

present this comment on paper pots. 

We support the petition for paper pots 

and we commend it to be part of a more general 

use of paper as a generic material for a crop 

production aid. I believe we may have a solution 

here. I have assisted Ellepot in developing 

papers for seven years now, including material 

for input to organics. 

Today, we have a virgin paper approved 

by Soil Association in the United Kingdom. 

Without the use of these petroleum-based 

additives mentioned in the petition. We have 

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applied for the same at WSDA but were rejected, 

as we cannot use newspaper or recycled for 

Ellepot. 

We spent two to three years working 

with the UK certifier to identify the materials 

that they will allow us to use, and after their 

approval we now have annual audits with 

inspection of our production. 

The UK certification is under the EU 

and as I understand, due to the trade agreements 

with the U.S., a grower over here could now 

actually import young plants for organic crops 

with this paper. 

I think it would be better to have the 

paper certified over here, to allow the grower to 

produce the Ellepot at his own facility. Making 

an Ellepot, we use a special additive. It's from 

a material that was actually suggested to us by 

the Soil Association. It was already approved as 

an input material as a soil conditioner. 

The important feature of this material 

is the home composting certification by TUV 

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Austria, formerly Von Schott (phonetic). It is 

my understanding that the material for this 

should be either home compostable or 

biodegradable in soil to be accepted. This is 

something that I would recommend for the Board to 

look into as a claim for the adhesives. 

Ellepot has a range of other papers 

using the same petroleum-based additives as 

mentioned in the petition, and again I would like 

to say that the Ellepot have these two new 

products now approved in the UK. One is for 

paper pots; the other is a weed barrier. Both 

are developed directly for the organic crops, and 

they were fully plant-based papers. They don't 

contain any petroleum-based components at all. 

I wish to leave you with this comment, 

to let you know that we do, we can do these 

papers without the binders that are mentioned in 

the petition. Thank you. 

MR. CHAPMAN: Harriet, and then Steve. 

MS. BEHAR: So I'm looking at your 

website. Hello. Do you do any of your pots in a 

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chain type system, or are they all individual? 

MR. PEDERSEN: They are all individual 

pots. We manufacture the machinery and sell or 

lease the machinery to the grower, and then 

afterwards we sell the paper to the grower and 

they can produce any number of paper pots that 

they wish to use. They're not in a chain. 

They're individual pots. 

MS. BEHAR: And are they available 

here in the United States? Do you have 

distributors here? 

MR. PEDERSEN: We have distributors 

here, yes. We have many customers in the U.S. 

today as it is, conventional growers. We've had 

questions from organic certified growers for I 

think six or seven years now for papers to be 

used, and well we've been working on developing a 

special paper for that segment, because we're 

very careful on what we have them leave in the 

soil afterwards, as the paper is intended to stay 

in the soil. 

MR. CHAPMAN: Steve. 

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adhesives. You said there's the one material 

that I assume you can't say what it is exactly, 

but it's approved by the Soil Association. You 

think you could -- I mean obviously one of the 

benefits of like the paper pots that we've been 

talking about is the chain, so they can quickly 

transplant. 

Could you develop a product like that, 

or is that without the adhesives? Is that 

difficult? 

MR. PEDERSEN: I don't -- I think we 

might be able to develop it, but for the Ellepot 

system, we're looking in a different direction, 

as the transplanting machines for the Ellepot are 

taking them from trays and putting them into the 

soil, which our machines work quite well today. 

The chain is based on materials that 

I think is probably the main challenge, because 

it's been very difficult for us also to make the 

paper that we have today. 

But what we've been looking into is 

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generally bio-based materials that are home 

compostable, because you can get bio-based 

materials that are very, very long lifetime in 

soil, and we don't want to use that at all. So 

the strength of material is very difficult to 

obtain. 

MR. CHAPMAN: Dave. 

MR. MORTENSEN: I was just curious. 

Is your company primarily an implement 

manufacturer or a paper product manufacturer or 

both? 

MR. PEDERSEN: It's a full system, 

because we don't sell the paper without putting 

the machine there first actually. So it's a full 

system of the machine, the paper, the tray and 

sometimes also the substrate. Usually the grower 

have their own substrate mixes and then we build 

this system around what the substrate they want 

to use, so that it's kind of a flexible system 

around that. 

MR. MORTENSEN: Yeah. The farmers 

here that we've heard from have been buying. I 

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don't know the planter, but it's a planter that's 

adapted for the kind of paper product that 

they're using now. That's my impression anyway, 

but thank you. 

MR. CHAPMAN: Thank you. Up last we 

have Doug Currier. Doug, if you could start with 

your name and affiliation. 

MR. CURRIER: Thanks. My name is Doug 

Currier. Hello to the Board members. I am the 

Technical Director of the Organic Materials 

Review Institute. I'm going to comment on the 

marine materials discussion document and the 

sodium citrate proposal. 

So first OMRI supports the creation of 

a working group which aims to address consistent 

review standards for products certified using the 

wild crop harvesting practice standard, NOP 

guidances and NOP Policy 12-1. While OMRI does 

not certify products, we recognize the need for 

consistency in wild crop certification, not just 

for marine materials but for crop, wild crop 

products as well. OMRI is open to providing 

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assistance to that working group. 

Currently, OMRI lists 94 products as 

allowed in the category of aquatic plant products 

synthetically extracted in the crop fertilizer 

and soil amendments class. OMRI also currently 

lists 28 products allowed in the category of 

aquatic plant products not synthetic. 

There are hundreds of products listed 

in our generic fertilizers blended category, some 

of which do formulate with aquatic plants. So 

it's unclear whether a global supply chain of 

certified organic aquatic plants would meet the 

current demands of input manufacturers, in 

addition to the current demand for a certified 

organic marine materials used in livestock feed 

rations, as well as materials listed at 205.606. 

While the present discussion document 

identifies the 2015 sunset review as the genesis 

of concerns regarding the ecological harvesting 

marine materials, I'm sure the Board is aware 

that there are other non-waste stream materials 

that are not associated with the National List 

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materials. 

Therefore, another route is likely 

required for those materials if the ecological 

impacts of their use is considered in the future. 

Sodium citrate. While OMRI does 

delist blood meal products manufactured from 

blood treated with sodium citrate, there are 

blood meal products manufactured from blood 

treated with other anti-coagulants, as well as 

blood meal manufactured using untreated blood, 

which are also listed. 

OMRI's view is that incidental amounts 

of residual anti-coagulant is allowed in blood 

meal, given that mechanical processing steps 

typical of blood meal manufacturing such as 

centrifugation and heating will generally result 

in their sufficient removal. Anti-foam is used 

when handling but is viewed in the same way. 

The issue of ancillary substances in 

animal byproducts certainly does not stop with 

blood meal. Meat and bone meal products are also 

at risk of containing some amount of residual 

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processing aids, which are used in handling a 

volume of byproduct materials. 

In an effort to avoid the piecemeal 

approval of synthetic processing aids, the NOSB 

could respond to individual petitions with a 

consistent message that NOP Guidance 5033 and 

5033-1 are sufficient to assess input compliance, 

and in these documents there is plain language 

guidance on the review of materials extracted 

from non-organic sources. Thank you. 

MR. CHAPMAN: Emily? 

MS. OAKLEY: Thank you for your 

comments on marine materials. Some of the 

concern that was expressed by stakeholders was 

the difficulty for certifiers to verify the 

organic status of that particular ingredient. So 

I wanted to ask if you're aware at this point of 

materials that OMRI does list that do contain 

certified organic marine macroalgae? 

Obviously that claim can't be stated 

as a USDA organic seal product. But could you 

discuss or address the feasibility for certifiers 

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to go back to a product and then verify if it 

were required to be certified to the wild crop 

standard, its certification for that ingredient? 

MR. CURRIER: So we're talking about 

crop products here, and so OMRI looks at crop 

products differently than products considered for 

livestock consumption and human consumption. So 

we ask the question based on the definitions at 

205-2 and 205.300, whether or not the product is 

intended for livestock or human consumption. If 

it is ingredients, agricultural ingredients 

listed on the label would come under the use of 

the term "organic." 

And so crop products, specifically 

crop fertilizers, you know, could include 

certified organic on the label, and we would --

we would need to look and ensure that that's 

true. But other types of uses of the term 

"organic" are outside of our -- the scope of the 

use of the term "organic." Hopefully that 

answers that question. 

MR. CHAPMAN: All right. I think 

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that's it. Thank you very much. 

MR. CURRIER: Yeah. 

MR. CHAPMAN: That concludes public 

comment for today. It's what, 5:52, so just 

before six o'clock. We start up tomorrow at 8:30 

in the same location. Also starting with public 

comment. 

If the people are here, the first 

public commenter tomorrow is Cori Skolaski, 

followed by Marisol Oviedo. And just so folks 

know to put it on their schedules, it looks like 

Organic Valley is hosting a networking reception 

featuring delicious organic cocktails, and that's 

good, because the only food I eat is delicious, 

and it's here in Ballrooms 2 and 3. So that's 

Thursday from 6:30 to 9:00. 

Right now we'll go into recess and 

reconvene tomorrow at 8:30. 

(Pause.) 

MR. CHAPMAN: Just a note for folks 

still in the room before you rush out, if we find 

ourselves ahead of schedule tomorrow, we may move 

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into the Livestock section, which is right now on 

the agenda on Friday. So just to repeat, if we 

find ourselves ahead of the schedule tomorrow, we 

might move into the Livestock section on Thursday 

afternoon/evening. 

(Whereupon, the above-entitled matter 

went off the record at 5:54 p.m.) 

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a.m 1:10 4:2 142:4,5 

abandon 222:13 

Abbott 362:21 372:4,7 

372:9 374:4,10 

Abbott's 372:4 

Abby 166:4 367:18,21 

371:8 372:3 

abilities 235:11 

ability 60:7 68:7 84:16 

84:17 92:2 101:13 

138:5,6 276:6 316:2,3 

able 7:1 22:19 29:19 

48:7,9,17 60:14,17 

61:3 68:19 69:2 71:12 

72:10 74:16 79:18 

80:17 84:11 99:6 

105:21 108:18 153:19 

156:3 158:10 173:14 

190:8 207:13 217:3 

236:7 287:7 293:5,11 

293:13 308:4 311:10 

319:3,11 346:17 

352:19 381:18,20 

385:7 399:2 409:8 

412:15 427:19 428:8 

430:20 452:13 

above-entitled 142:3 

243:7 460:6 

absence 182:17 223:10 

239:20 241:11 369:1 

absolutely 124:5 

174:11 227:15 278:21 

301:12 357:13 431:7 

433:10 

abstained 426:10 

abundance 29:8 39:10 

444:20 

abundant 444:12 

abuses 415:6 

ACA 181:22 196:8 

253:7 340:20 341:2,7 

341:17 388:12 

ACA's 338:20 376:16 

academia 248:22 

academic 35:16 50:9 

409:11 

accelerate 409:1 

accept 58:6 196:21 

246:1 

accepted 58:9 156:11 

231:19 450:4 

accepting 65:22 195:16 

access 37:5 53:21 

70:11 79:17 95:8 

156:3 254:3 275:4 

296:10 370:21 380:2 

380:3,7,16 381:1,2,5 

382:1,5,7 383:19 

384:1 

accessed 115:11 

accessibility 114:21 

accessible 115:3 129:9 

235:2 

accidently 20:15 

accommodate 111:10 

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accomplish 208:19 

260:22 408:22 443:2 

accomplished 362:5 

accomplishing 191:17 

Accord 25:18 26:7 

account 30:13 285:5 

331:4 

accounted 418:12 

Accounting 215:21 

accounts 222:15 

accredit 138:6 

accreditation 5:2,2 

89:22 93:1 97:6 

195:21 245:13,15 

253:4 255:16 288:4 

292:21 294:22 

accredited 181:21 

196:8 245:10,22 

338:14,17 341:7 

376:15 388:1,11,17 

accumulate 353:2,6 

accumulation 352:21 

accumulators 353:5,7 

accurate 61:1 72:5 80:7 

424:18 

accurately 152:19 

ACE 78:12 95:8 

acetate 267:16 

achieve 259:2 367:1,2,8 

367:16 382:8 

achieved 394:8 

achievement 140:2 

achieving 180:3 

acid 235:20 282:5,6 

369:16 

acknowledge 344:10 

347:2 

acknowledged 329:13 

acknowledgment 17:11 

183:12 

acre 256:4,5,12 363:18 

429:8 

acreage 60:4,6,20 

78:21 111:10,19,20 

111:22 428:2 434:20 

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35:8 42:13 43:1,18 

51:14 211:21 428:7 

429:7 

act 79:18 81:22 99:18 

104:11,13,14,15,16 

104:17,19 117:3 

186:16 230:21 347:21 

354:7 

acting 353:13 

action 62:17 64:21 

75:11 78:10 136:18 

148:17 149:2,10 

158:3 162:21 290:12 

298:1 299:21 321:22 

327:7 330:3,5 387:16 

actions 91:19 93:12 

96:10,14 130:18 

288:22 290:17 327:13 

328:6 

active 117:20,21 157:9 

180:10 210:14 

actively 76:8 119:1 

136:11 196:9 385:8 

activities 5:3 10:14 

74:6 95:9 125:5 167:7 

290:8 

activity 146:11 

actors 77:3 80:4 

actual 186:2 

acyl 266:15,15,17 267:7 

267:15,19,20 268:1,7 

269:1,7 

ad 188:2 

Adam 24:16,21 

adapt 221:11 403:22 

adapted 454:2 

adapting 224:18 

adaption 403:4 

add 161:9,11,15 162:9 

181:16 192:22 215:11 

222:2 264:7,7 305:11 

335:14 384:22 393:1 

393:5,10 399:15 

400:15 430:10,22 

431:6 

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178:14 181:15 192:5 

247:6 266:18 269:6,7 

289:6 290:5 312:11 

313:4 344:3 345:4 

347:8 400:9 

addictive 260:22 

adding 105:8 176:20 

177:2 195:20 312:2 

347:14 358:17 392:2 

428:16 

addition 97:11 138:20 

161:4 216:6 222:9 

233:12 234:6 349:21 

395:17 421:3 442:18 

447:12 455:14 

additional 93:2,16 97:5 

97:8 146:1 159:19 

190:4 195:20 226:9 

237:10,17 240:7 

290:13,17,19 296:12 

323:20 336:10 339:16 

344:19 350:17 352:5 

355:15 362:5 369:10 

375:21 377:9 388:14 

404:13 

Additionally 225:10 

288:16 

additions 325:5 

additive 258:22 313:21 

335:18 443:9 449:17 

additives 181:14 

183:15 232:16 303:1 

303:5 311:5,7 313:4 

313:19 314:2,5 

336:21 448:22 450:8 

address 93:14 103:17 

110:11 112:2,12,14 

148:17 153:3 178:12 

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282:9 284:10,15 

335:2 336:21 350:9 

365:17 370:6 379:16 

382:3,14 386:19 

392:22 393:1 454:15 

457:22 

addressed 210:12 

282:22 

addresses 111:21 

112:9,10,12 

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153:21 286:10 334:19 

392:7 422:20 

adequate 93:9 335:10 

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adhesive 87:5,7 187:22 

188:4 310:11,12 

347:14 

adhesives 178:12,13 

181:1,16 188:13 

189:5,13 190:6 

200:17 247:6,8 310:8 

312:2,17 347:15 

395:15 450:6 452:2 

452:10 

adjoining 110:9,13 

111:1 

Adjourn 3:18 

adjunct 235:7 

adjust 367:4 

adjusted 291:9 

Neal R. Gross and Co., Inc. Neal R. Gross and Co., Inc. 

(202) 234-4433 (202) 234-4433 Washington DC Washington DC www.nealrgross.com www.nealrgross.com 
462 

administration 26:17 

257:17 333:2,4 

administration's 55:14 

administrative 10:14 

249:20 327:21 328:2 

328:21 330:2 

administrator 2:3,7 4:8 

6:16 55:19,20 56:1,7 

97:3 160:17 209:7 

309:18 

admit 372:13 

admitted 272:9 

adopt 60:22 274:11 

adopted 335:13 394:13 

adoption 196:12 394:7 

404:4 

adults 214:12 

advance 10:20 69:17 

343:17 

advanced 66:22 94:11 

advancing 65:3 77:7 

89:15 130:19 

advantage 34:12 

151:12 325:3,12 

adverse 96:10 327:7,13 

330:5 420:6 

advertised 180:20 

advertising 415:5 

advice 100:18 

advise 195:5 282:11 

423:3 

advisor 37:10,13 

advisory 2:2 7:7 31:22 

249:12 251:8,13 

advocacy 212:14 402:5 

402:10 

advocate 92:1 

advocated 245:15 

advocates 215:20 

advocating 103:11 

130:20 228:14 339:14 

Affairs 13:12 129:3,12 

169:14 

affect 373:21 374:13 

443:19 

affidavit 400:1 401:14 

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affiliated 111:21 448:7 

affiliates 145:18 

affiliation 169:9 177:17 

177:19 190:16 194:15 

201:14 212:9 220:4 

223:21 227:21 236:18 

243:17 251:19 258:8 

262:20 265:20 270:13 

280:3 287:20 295:9 

302:2 314:12 321:1 

334:7 338:12 343:3 

355:22 362:22 367:20 

372:6 374:17 379:4 

385:20 389:10 393:17 

398:16 402:3 410:12 

427:3,4 442:10 448:4 

454:7 

affiliations 145:21 

146:18 

affirmative 425:4,16 

afloat 221:17 

afternoon 43:15 212:10 

232:14 243:18 262:21 

295:10 302:3 314:14 

334:8 372:8 374:18 

389:11 402:4 418:22 

442:11 

afternoon/evening

460:5 

afterthought 436:19 

437:3 

ag 16:4 23:11,12 37:14 

40:11 157:4 236:20 

237:2 238:4 254:7 

435:7 

agencies 64:13 75:16 

76:11 95:14 109:10 

216:3 338:17 342:13 

agency 63:19 104:15 

109:12 127:9 128:21 

129:1 288:1 290:9 

agenda 9:22 32:12 

103:17,20,22 104:1,4 

104:10,18 105:2,17 

105:21,22 117:20 

118:3,11,16 128:1 

135:15,18,19 136:4 

136:10 162:6,10 

167:19 193:17 194:1 

194:10 210:15 238:1 

333:6 343:18 362:9 

394:3 400:17 403:16 

408:11 420:12 433:20 

437:11 441:1 460:2 

agent 222:3 235:7 

agents 267:3 

aggregate 436:10 

aggregating 380:7 

ago 28:15 36:10 41:15 

48:3 115:11 118:4 

120:14 139:12,13 

151:6 198:14 210:2 

215:2 216:7 363:14 

389:16 417:5 444:18 

agree 125:6 148:20 

163:20 171:4 203:22 

204:1 213:6 300:6 

301:13 304:22 306:18 

347:12,19 350:13 

357:11 358:21 359:5 

359:11 360:12 362:11 

365:13 371:17 394:6 

394:15 419:8,10 

424:10 425:21 

agreed 87:9 309:1 

341:17 

agreement 25:20 95:7 

231:14 406:15 433:13 

agreements 137:7,7 

449:10 

agrees 88:9 368:3 

403:9 

agricultural 2:3 4:9 

12:13 15:12 16:1,7 

33:16,17 127:9 

170:13 171:9 272:1 

315:21 351:10 442:14 

458:11 

agriculture 1:1 2:13 5:9 

10:5 13:13 15:3 26:8 

26:9,22 27:6,9,12 

28:1,11,13,18 29:4,11 

29:13 31:3 32:7 33:2 

35:2,16,16 36:3,12,12 

36:18 37:6,8 39:2,5 

40:18 41:3,7 51:1 

53:6 79:5 100:22 

121:8 162:4,5,19 

172:18 187:6 208:22 

214:2 220:20 223:5 

245:19 257:14 277:1 

296:22 298:3 299:5 

299:22 314:17 317:13 

409:3 410:4 411:1 

432:18 

agro-ecology 12:18 

agroenvironmentally

86:22 

agronomist 147:17 

agronomists 120:9 

Agronomy 33:4 

ahead 7:21 10:15 70:9 

85:14 98:2 135:3 

459:22 460:3 

aid 88:4 149:9 162:13 

167:5 178:3 187:20 

286:13,18 304:13 

306:11 310:5 312:8 

399:7,15 448:15 

aids 178:19,21 179:14 

183:15 189:1 336:6 

336:11,16,18 457:1,4 

aims 454:15 

ain't 256:12 

airplanes 255:20 

AITC 154:13,20 363:3,3 

364:20 366:3 367:3,3 

367:9 371:10 

Alan 407:5 410:10,11 

410:13,13 413:10,10 

413:15 414:18,22 

415:10 416:2 417:12 

418:16,17 419:5 

Alan's 418:19 419:5 

Alaska 89:13 

Albert 418:20 427:1,2,5 

429:15 

albicans 162:2 165:11 

alcohols 222:2,8,12,22 

223:10,17 237:2,9 

239:21 240:15 241:6 

242:9 

Aldi 413:16 

Aldi's 417:19 

Alexis 280:2 287:16,22 

291:14 

algae 368:7 387:3,6 

alginate 235:19 

align 186:15 303:9 

alignment 83:8 

aligns 83:20 233:9 

261:6,9 

alleged 84:5 

allergens 261:4 

allergies 233:6 

Alliance 321:4 402:6 

allies 409:11 

allow 75:11 87:2,10 

88:15 100:2 143:9 

149:16 155:5 169:4 

174:4 178:9 179:13 

187:22 193:21 223:16 

230:5 302:18,20 

303:3,3 306:18 

311:11,12 313:5,11 

344:20 346:8 348:17 

359:9 365:9 376:17 

396:4,16 443:13 

444:2 449:6,15 

Allowable 303:16 

allowance 88:12 170:20 

178:2,7 281:5 339:11 

339:16 396:2 

allowances 87:11,16 

allowed 47:5 78:19 88:4 

88:21 143:22 144:20 

161:20 170:19 174:16 

175:11 178:4 184:4 

200:21 204:14 222:4 

255:17 284:3,7 303:6 

305:2 306:15 308:21 

311:13 313:9,10 

325:7 336:10 339:10 

343:10 368:17 395:19 

395:21 455:3,6 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
463 

456:13 

allowing 40:13 70:10 

88:18,19 119:17 

170:13 184:15 189:10 

193:19 235:1 246:18 

260:10 261:21 306:13 

311:5 321:15 323:18 

331:18 335:17 336:19 

345:15 399:9 431:20 

allows 59:16 64:7 144:9 

167:16 214:18 244:14 

253:21 320:12 323:14 

339:20 380:15,17 

390:16 392:7 399:20 

alluded 120:21 

almond 259:11 

alternative 168:2 170:8 

174:19 

alternatives 199:7,9 

235:12 261:10 268:17 

316:18,21 400:14 

altogether 222:14 

Amador 302:1 314:10 

314:14,15 318:7,11 

318:20 319:7 320:2 

Amargosa 257:5 

amazing 6:2 7:11 

141:13 164:16 

ambiguity 171:5 

amend 405:17 

amending 404:5 

amendment 339:2 

amendments 455:5 

American 78:15 89:6 

89:13 230:22 

Americas 266:1 

aminoglycoside 214:5 

amount 22:8 27:6 48:17 

79:2 82:2 127:1 

132:21,22 240:7 

275:21 303:19 310:11 

311:7 319:22 396:22 

428:20 431:8 435:1 

445:5 456:22 

amounts 258:15 260:16 

345:11 347:5 456:12 

amplified 379:19 

AMS 4:15 6:15,16 34:4 

55:19 69:11 89:7 

Amy 15:13 23:10 

analyses 79:5 

analysis 93:19 95:2 

298:21 299:6,20 

303:13 

analyst 295:12 389:13 

analyze 78:10 86:7 

291:6 

ancillary 456:19 

and/or 225:6 376:9 

377:10 440:11 

ands 172:8 375:15 

angry 20:12 

animal 13:20 51:22 

213:7 218:4 322:19 

323:12 434:5 440:16 

443:4 444:7 456:20 

animal-based 170:9 

animals 297:3 324:1,6 

325:4,8,10,18 428:17 

Ann 19:4 

Anne 385:19 389:8,9,12 

anniversary 40:21 

annotate 188:6 

annotated 306:11 

annotation 155:13 

203:10 306:21 312:16 

322:17 337:3 368:18 

annotations 183:19 

335:12 359:8,9 

announce 131:20 

139:13 420:22 

announced 67:3 

announcement 131:9 

131:12 

annual 232:3 248:4,6 

256:9 288:20 292:15 

449:7 

annually 89:19 229:1 

anonymous 370:15 

389:16 390:3 

ANSI 90:3,8 92:10,13 

93:7 

answer 107:3 109:18 

123:10 134:19 166:1 

173:18 193:16 216:2 

223:7 237:17 248:13 

294:2 325:15 352:19 

354:14 371:20 416:6 

425:15 437:12 

answers 139:6 250:5 

309:5 458:21 

anti-coagulant 456:13 

anti-coagulants 336:6 

456:9 

Anti-foam 456:17 

anti-microbial 161:19 

Anti-microbials 162:3 

anti-rot 163:21 

antibiotic 105:10 116:2 

213:8 214:5,19 

216:17 217:18 218:4 

218:16 297:6 330:17 

antibiotic- 218:8 

antibiotics 103:17 

116:6 194:21 197:20 

212:17,22 213:6,13 

213:14,15 214:1 

215:1,15 218:1,10 

219:3 296:22 297:3,5 

297:9,12,19 298:9,13 

299:14,19 312:13 

368:14 

anticipate 388:14 

anticipating 67:2 

328:10 

antimicrobial 161:17 

anybody 37:19 45:14 

200:6 

anymore 165:5 217:20 

242:11 308:8 

anyway 20:2 22:1 195:3 

202:1 251:6 454:3 

apart 19:6 228:19 273:9 

274:6 415:5 

apartment 21:15 

APHIS 63:19 64:1 69:17 

75:13 81:6 156:11 

apologize 190:20 442:7 

app 427:22 428:1 

Appalachian 5:11 

appeal 327:14 328:12 

360:4,6 

appealed 327:12,13,14 

328:7 

appeals 81:18 95:16 

237:21 238:2 328:4,5 

328:14 331:12 

appear 170:18 171:11 

appearance 44:20 

392:5 

appearing 209:13 

applaud 257:19 339:19 

applause 4:20 5:21 6:7 

6:19 7:9 10:20,21 

16:12 32:18 34:1 

54:22 57:4,5 59:6 

139:20 140:20 141:16 

322:11 382:17 

apple 155:17 417:15 

apples 397:16,16 

418:11 

applicable 288:11 

289:7 

application 161:18 

162:14 259:7 268:10 

288:21 304:17 351:5 

351:8,22,22 352:12 

352:13 353:11 359:16 

360:13 

applications 233:22 

246:1 259:18 260:16 

263:19 265:15 266:21 

268:13 269:21 352:1 

applied 42:1 49:18,20 

289:5 299:14 305:15 

345:3 351:7,12,18 

354:1 355:3,4 399:7 

406:6 426:1 449:1 

applies 105:10 246:2 

288:19 

apply 439:2 447:3 

applying 110:18 345:13 

353:10 443:22 

appointed 7:16 15:3 

55:20 

appreciate 55:4 57:12 

99:12 101:21 115:5 

118:18 121:18,21 

127:16 130:6,14 

134:21 135:10 152:13 

163:18 185:14 188:7 

192:22 209:21 254:14 

291:15 300:9 331:19 

350:12 367:14 372:14 

388:17 398:19 400:11 

422:7 427:15 432:15 

445:14 

appreciated 161:6 

334:18 389:4 432:10 

appreciates 402:18 

appreciation 152:14 

approach 90:4 178:19 

179:11 188:4 248:19 

248:22 276:20 288:3 

310:6,9 359:11 

392:19 

approached 60:11 73:8 

approaches 46:19 

appropriate 18:14 77:9 

170:10 346:10 403:5 

413:12 

appropriately 233:14 

approval 91:7 97:6 

149:13 187:19 237:13 

245:3 363:6 426:14 

449:7 457:4 

approve 70:11 105:1,21 

148:20 184:13 189:12 

189:16 198:5 280:10 

304:15 309:11 369:4 

396:5 

approved 86:17,18 87:1 

93:15,16 97:1 136:10 

180:19 185:1 188:18 

198:16 200:13 213:12 

213:17 242:13 258:21 

268:2 281:4 308:17 

317:10 350:14 368:18 

395:17 448:19 449:19 

450:11 452:4 

approves 337:18 

approving 422:3 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
464 

423:21 

approximately 45:18 

46:12 66:16 75:6 99:1 

April 57:22 244:4 

aquatic 224:19 335:5 

337:17 386:11 455:3 

455:7,10,12 

aqueous 350:8 351:13 

352:6 

arabic 234:19,21 

430:21 

arable 211:22 

architecture 95:5 

area 28:7,8 45:16 63:8 

69:3,5 70:18 73:15 

77:18 85:7 93:5 108:1 

114:10 126:11 130:18 

166:22 195:2 207:5 

271:20 317:19 329:3 

329:4,15,17 332:2,3 

332:18 390:20 394:16 

446:14 447:9,13,15 

447:18 

areas 62:12,14 63:5 

65:13,19,21 66:9 

79:19 81:13 90:10 

94:3 153:11 180:5 

200:5 208:2 254:21 

268:8 272:11 275:13 

290:2,16 295:15 

329:16 376:7,18 

396:9 446:3,17,21,21 

447:19 

argue 35:19 238:22 

305:1 327:16 424:6 

arguing 242:12 369:15 

argument 327:18,18 

arguments 328:10 

332:19 

Arkansas 13:18 

arrangements 137:18 

138:16 139:2 

array 310:20 

arrived 41:17 

arriving 33:9 

ARS 5:11 

Arsenault 2:2 7:7 

article 351:16 352:10 

352:18 

articles 33:19 350:17 

articulate 396:14 

arts 36:16,17 

Asa 1:14 12:9 123:12 

154:8,10 156:14 

211:8,20 219:15 

276:11 353:8 371:8 

382:19 

ascophyllum 272:9 

278:8 445:6 

Ashley 1:22 13:16 

103:13 165:17 194:8 

199:2,18 215:13 

298:15 322:13 401:10 

aside 205:14 411:2 

asked 23:11,16 55:12 

82:2 86:2 88:12 90:8 

90:12,22 102:8 

103:16 124:12 126:21 

143:6 146:7 147:11 

200:15 206:7 215:20 

239:20 251:1 252:5 

275:9 298:1 321:9 

322:16 334:3 435:19 

asking 100:11 110:7 

113:3,6,7 117:22 

118:6,6 162:20 

182:21 187:19 206:14 

209:21 217:7 299:16 

299:18 309:21 347:4 

348:7 380:19 433:15 

436:8 

asks 42:9 161:11 377:7 

437:22 

asleep 22:2 

aspect 40:4 356:20 

aspects 36:2 41:19 

43:8 52:6 90:7 176:12 

188:22 195:14 254:18 

330:16 404:12 443:5 

assertions 119:12,13 

assess 60:18 156:19 

188:17 287:10 457:7 

assessed 101:12 

285:14 

assessing 153:11 

180:5,8 

assessment 70:7 93:5 

288:3,5,19 290:12 

291:5,20 292:13 

294:6,21 

assessments 291:10 

293:6 

assets 255:14 

assigned 101:10 

assist 76:22 244:18 

assistance 32:5 115:19 

237:15 244:16,21 

245:8 248:7,14 380:3 

381:9 455:1 

assistant 44:17 

assisted 448:16 

associate 51:21 56:6 

97:3 270:17 278:16 

356:3 

associated 96:9 210:8 

440:16 455:22 

Associates 356:4,9 

359:3 361:21 

association 14:8 33:18 

162:18 169:14 170:1 

171:14 172:15 177:21 

178:1 181:21 183:10 

196:8 220:12 228:4,6 

228:11 229:11 232:17 

338:14 376:16 379:6 

379:8,11,22 380:13 

388:1 407:8 409:7 

410:3 417:4 442:15 

448:20 449:19 452:4 

assume 274:17 295:4 

452:3 

assuming 418:11 

assumption 227:5 

assure 386:9 

ASTM 356:17 

Atkinson 270:19 

Atlantic 271:3 445:6 

attached 341:2,20 

attachment 342:15 

attacks 146:7 

attain 364:18 

attempts 135:9 

attended 66:15 

attending 290:7 

attention 138:3 191:2 

230:2 344:15 400:12 

424:5 425:7 439:7 

attestations 225:1 

attorney 389:12 

attractive 260:15 

attribute 263:12 264:5 

attributes 233:4 235:14 

260:9,15 265:2 

audience 7:21 55:21 

100:16 

audit 59:21 93:8,22 

290:16 

audited 197:6 413:4 

auditing 92:8 

auditor 64:18 

auditors 91:17 93:16 

97:8 

audits 59:22 60:1,2 

64:18,20 65:1 253:3 

329:5 449:7 

Audubon 272:14 

augmentation 92:3 

August 77:20 140:4 

321:20 

Aurora 257:10 

Austria 450:1 

authenticity 71:13 

author 251:9,12,14 

authored 33:18 

authorities 117:5 213:6 

authority 91:7 104:22 

105:3 106:1 117:11 

123:20 124:5,9 

439:15 

authorized 117:2 

authors 280:20 

automated 94:21 

availability 173:5,7 

251:11 335:3 373:11 

373:21 404:2 

available 32:4 46:9 79:4 

94:1 108:15 134:12 

148:3 168:4 170:8 

174:10 191:22 193:9 

215:4 256:2 288:10 

296:2 335:7,8 357:6 

381:22 391:15 394:19 

400:6 403:3 405:20 

405:20 419:18 430:18 

431:19 439:22 451:9 

avenues 332:1 

average 256:3 348:13 

avocado 8:5 124:20 

avocados 124:20 

avoid 46:7 91:13 

149:14 328:15 371:15 

457:3 

award 52:17 139:15 

awarded 75:4 

aware 110:16 135:5 

170:12 200:6 208:6 

280:20 348:10 374:2 

417:3 424:17 455:20 

457:17 

aware,0 374:6 

awareness 302:9 

409:14 

awful 108:11 111:11 

131:1 

B

B.A 56:10 

Bachelor's 5:15 

back 9:20 15:15 17:18 

19:16,17 21:4,17 22:3 

22:11 29:14,17 32:1 

41:13 42:1,15 98:5 

99:17 107:21 110:22 

112:2 127:3 128:2 

135:16 136:11,20 

137:5 139:9 140:10 

140:11 141:20,21 

142:11 144:9 156:18 

172:13 181:21 185:11 

187:16 201:4 202:10 

203:1,19 210:7 

214:20 238:3 243:14 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
465 

247:1 264:8 265:11 

281:4 296:3 305:22 

316:21 317:20 321:12 

321:19 323:20 324:13 

324:18 325:18 330:22 

332:5 347:13 352:21 

357:15 360:14 362:9 

362:13 371:20 375:20 

377:8 383:15 403:16 

411:17 417:16 422:17 

424:14 426:9,10,13 

445:8 458:1 

backed 296:11 

background 12:17 

15:21 43:1 54:15,16 

89:11 248:21 

backing 211:2 

backlash 301:8 

backlashes 300:11 

bacteria 159:12 218:3,5 

218:9,17,18,20 

219:12 267:12 

bacterial 233:13,19 

260:4 

bad 23:19 25:13 77:3 

80:3 88:20 358:1 

393:9 417:19 

Badger 146:17 160:6,8 

160:9 163:8 164:9,22 

165:22 166:6,19 

167:20 168:22 

bag 140:18 279:3 

Baird 1:14 14:6,6 

182:20 

baked 235:9 263:21,22 

264:18,19 

bakery 263:22 

balance 40:1 132:21 

188:20 

balances 249:2 

ball 22:13 

Ballrooms 1:8 459:15 

banana 316:17 

bananas 315:6,13 

316:6,7,11,16 318:2 

319:19,20 320:3,6 

banned 296:8 

banning 164:4 167:11 

bar 14:15 296:4 297:17 

barrier 180:19 450:12 

barriers 377:3 379:17 

379:18 381:5 383:9 

383:18 

Barrington 13:2 

bars 234:22 

base 12:4 374:13 

based 41:14 49:9 70:14 

73:20 74:8 81:14 94:1 

101:13 108:14 154:15 

159:20 183:12 222:5 

229:22 246:8,10 

253:12 259:16 273:16 

285:20 286:3 290:12 

292:13 301:13 344:7 

357:5 367:10 452:18 

458:8 

baseline 372:22 373:2 

427:20 428:9 

basement 32:16 

basic 289:20 341:16 

basically 23:18 48:18 

71:22 142:21 151:13 

154:22 175:6 248:2 

315:2,5,7,20 316:5 

317:18 318:22 436:16 

438:11 439:19 

basics 352:21 

basil 350:19 

basis 134:12 210:13 

242:13 256:20 319:3 

batch 151:2 

batters 264:2 

bean 234:19,20 235:4,5 

236:3,4 264:16 

318:14 

beard 57:19,21 169:17 

427:16 

beards 21:19 

bears 212:18 

beautiful 411:22 

becoming 45:16 407:14 

408:18 409:4 

beds 271:17 275:11,14 

275:16 

beekeeping 195:2 

200:5 

bees 200:3 420:14 

beginning 9:8 62:8,9 

122:20 143:13 145:19 

379:14,17 380:20 

381:3 382:15 445:13 

behalf 160:9 184:19 

220:11 223:5 238:5 

239:12 253:8 312:21 

356:9 

Behar 1:13 13:4,4 

109:21 112:15 114:6 

149:21 167:2 175:19 

180:17 193:15 197:18 

198:7,13,19 205:5 

209:5 231:11 236:2 

236:12 247:17 261:13 

262:11 268:21 285:10 

306:5 307:2 318:9,15 

319:5 323:4 331:14 

342:4 349:12 365:6 

366:15 367:12,18 

374:2,6 396:20 

397:17 398:2 405:6 

417:3 429:16 450:21 

451:9 

behavior 19:13 

beholden 298:11 

belabor 242:8 

believable 327:19 

believe 13:8 27:5 28:9 

34:8 65:18 84:2 100:2 

105:16 107:16 150:13 

157:16 171:8 172:3,7 

173:16 185:21 194:5 

201:21 232:4 338:1,2 

341:21 346:19 347:3 

359:19 364:20 372:3 

380:14 382:9 403:6 

447:4 448:15 

believed 87:5 

believes 148:10 233:14 

443:1 

bell 416:8,10 

benchmark 427:19 

beneficial 159:11,11 

292:22 322:20,22 

396:22 

benefit 228:14 258:14 

350:22 387:1 436:1 

438:18 441:19 

benefits 268:11 278:18 

300:10 301:9,19 

332:21 350:15 409:22 

452:6 

benefitted 254:8 

Berkebile 320:22 334:8 

334:9 337:20 338:1,9 

Berkeley 12:10 

Berkshires 13:3 

berries 45:1 46:6 

best 32:3 45:22 66:3 

82:17 107:13 136:17 

167:12,12 181:22 

196:9 207:1 260:5 

271:6 284:17 294:6 

294:13 303:10 352:20 

364:22 375:19 388:2 

388:12 

bet 211:16 

Beth 177:15 190:15,15 

190:17 193:13 194:11 

Betsy 6:4,11 106:19 

Betsy's 6:6,8 

better 26:19 49:14 51:2 

63:14,19 64:1,3 75:1 

80:13 126:17 128:7 

156:16 166:5 186:22 

193:11 203:3 208:15 

275:6 295:17 315:1 

320:15 337:15 397:2 

417:7,18 437:12 

449:14 

beverage 261:2 

beverages 233:5 234:1 

234:2 258:16 259:9 

259:11 260:10 264:1 

264:22 

beware 418:18 

beyond 35:22 53:18 

109:7 166:21 176:15 

189:10 347:7 364:1 

409:16 419:2 

bias 392:5 

biased 120:3 315:10 

big 8:12 34:19 45:13,16 

47:6 69:4,13 91:3 

98:13 102:5 133:17 

151:2 291:11 307:16 

364:7 365:16 415:13 

434:21 435:7 

bigger 301:18 357:14 

biggest 204:16 

Bill 61:21 86:1 356:10 

billion 252:7 

bills 83:7 

bin 414:7 

binders 450:18 

binding 235:11 

bio 16:15 25:3,11 41:7 

57:22 

bio- 357:4 

bio-based 357:1 453:1 

453:2 

biodegradability

356:18 

biodegradable 356:16 

357:2 450:4 

biodegrade 178:10 

190:3 

biodiversity 420:7 

biological 33:13 47:1 

279:7 

biologist 273:22 

biology 35:1 36:20,21 

37:5 43:7 46:17 

270:18 

biomass 428:21 429:5 

biome 411:5,5 

biopesticide 364:22 

bios 24:22 

birds 9:10 254:1 271:9 

birthday 6:11,12,13 

Bisphenol 400:12 

bit 4:22 11:9 15:16 18:2 

24:3 35:3 48:14 65:5 

66:7 70:4 75:3 84:11 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
466 

90:4 91:6 101:4 

106:14 108:16 113:5 

117:18 126:7 131:15 

141:9 144:12 154:12 

156:16 157:20 160:14 

163:20 186:8 192:8 

198:9 204:10 205:7 

206:20 216:18 219:10 

263:2 267:6 273:15 

283:12 308:1 314:19 

319:8,20 326:10 

337:22 347:16 358:6 

431:15,16 436:22 

446:22 

bite 45:12 

Bjarne 442:8 448:1,6 

black 81:6 257:11 

blended 455:9 

blight 156:6 

blip 437:19 

bloc 252:17 

block 71:1 72:13,16,18 

73:10 75:14 

blog 77:21 

blogger 78:2 

blood 336:5,7,14,18,21 

456:6,7,8,8,10,10,13 

456:15,21 

blueberries 45:4 

350:19 

blunt 165:10 

Board's 66:20 88:5,9 

89:2 213:22 

boat 24:5,10,11 277:16 

277:16 

boat- 447:7 

boats 446:13 

bodies 206:7 391:18 

body 365:22 

boils 299:6,10 

bomb 38:13 

bone 456:21 

book 417:5 

boom 39:3 

booming 444:17 

boot 56:18 

boots 68:8 

border 63:15 69:17,19 

73:3 94:20 

borders 80:14 

boring 208:16 

born 16:17 18:6,7 

321:16 

Boston 36:19 37:7,20 

37:20 

bottom 48:20 267:16 

Boulder 416:8 

Boulevard 1:9 

box 66:1 412:10 

boxes 182:11 302:17 

BPA 117:18 118:2,21 

123:16,18,22 400:12 

400:14 

Brad 51:22,22 52:5 

Brad's 52:15 

Bradman 1:14 12:9,9 

123:13 154:11 156:10 

211:10,17 212:2,6 

219:17 276:12 353:9 

354:8,15,19 371:9,12 

382:20 

brand 82:22 419:14 

branding 313:1 

Brandt 409:19 

Brassicaceae 364:21 

braving 10:20 

breaches 133:3 392:9 

breadings 264:2 

break 6:13 137:4 139:8 

141:2,18 212:4 

236:16 243:2,5 

333:10,12,13 

breakdown 421:14 

breaking 257:1 

breakout 29:15 

breaks 144:12 314:2 

428:18 

breast 301:6 

breath 411:1 

bridges 77:1 

brief 55:10 137:4 

142:21 159:7,9 193:6 

308:12 372:15 

briefings 133:13 

briefly 131:7 135:11,12 

143:17 219:16,17 

278:5 324:10 360:22 

363:8 417:2 439:14 

bright 444:19 

brilliant 20:20 208:11 

Brines 139:14 

bring 7:12 40:22 49:16 

50:6 53:4 114:16 

136:15 172:12 191:1 

285:10 302:9 356:11 

356:12 371:19 426:10 

429:16 

bringing 30:4 44:8 

187:11 298:18 317:7 

343:9 370:22 441:11 

brings 24:2 52:2 

broad 178:18,22 365:10 

365:11,15 366:8 

374:13 

broadened 179:11 

broader 148:21 274:21 

275:2 403:3 

broadly 303:22 313:5 

326:13 400:15 

broken 121:15 296:9 

366:13 

broker 84:22 

brokers 71:11 

bromide 366:5 

Brook 13:20 14:1 

brother 18:21 

brought 54:16 208:1 

285:6 299:4 332:6 

360:17 361:2,5 

384:12 433:7 

brown 409:18 414:7 

417:21 

budget 91:22 

buffers 447:3 

Buie 1:15 13:22 14:1,5 

159:8,10 

build 181:22 228:12 

325:9 380:17,22 

408:1 428:22 453:17 

building 47:16 52:11 

72:18 73:10 75:14 

76:15 409:13 447:8 

builds 72:19 419:13 

built 71:22 76:22 427:9 

bulk 414:2,7 415:19 

418:11 

bumper 79:9 

bunch 46:17 330:11 

349:22 

bundle 133:5 

burden 191:14 

burdens 195:20 373:9 

373:20 

bus 42:19 

business 95:1 106:15 

132:12 255:7 307:16 

343:6 379:14 388:16 

409:11 

businesses 58:19 

146:21 147:4 

butcher 442:8 

butchered 227:20 

button 265:22 

buy 85:5 279:2,18 

346:1 384:11 429:9 

431:17 

buyers 84:17,19 151:13 

374:8 

buying 196:19 213:1 

279:18,19 453:22 

buzz 145:14 

buzzer 145:14 204:9 

byproduct 436:12 

441:4,5 457:2 

byproducts 233:11 

261:8 456:20 

C

Cacatua 12:1 

CACS 340:17 396:9 

CAFOs 220:22 256:3,7 

Cakir 49:19 

calcium 259:10 280:6,8 

280:9,17 281:2,3,6,16 

281:19 282:8 283:18 

283:22 284:5 285:17 

calculate 81:16 175:3 

175:16 

calculates 289:16 

calculation 289:12 

428:7 

calf 325:14 

California 7:17 8:6,12 

8:17 9:2 12:4,13 

112:19 201:17 206:3 

210:17 245:18 288:2 

364:7 382:21 432:17 

435:21 438:22 439:20 

440:9,10 

call 3:4 24:16,18 49:22 

96:20 104:16 108:17 

132:1 144:5,5 146:16 

154:20 164:17 236:8 

247:19 281:6 416:22 

417:15 438:7 

called 19:8 29:6 36:19 

38:1 41:17 43:5 73:20 

101:7 129:8 144:2 

169:1 180:20 245:9 

250:6 256:18,19 

284:2 417:5 

callers 348:22 

calling 67:11 

calls 102:20 120:13 

122:20 283:17 

calves 321:16 323:10 

campus 18:21 34:21,22 

34:22 42:16 51:6 

campuses 34:21 51:7 

Canada 26:10 216:6 

317:12 

cancer 301:6 

candid 127:16 

candida 162:2 165:11 

cannabis 435:14 

capability 415:15 

capacity 75:5,9 78:22 

159:14 225:21 228:16 

capita 28:22 

capital 381:6 

capitalized 391:22 

Capsugel 173:8 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
467 

capsule 170:9 174:1,2 

175:13,15 268:10 

capsules 170:3,7 174:3 

175:2 266:21 

carbon 428:14 

carbonate 280:6,8,9,17 

281:2,3,6,17,19 282:8 

283:18,22 284:6 

285:17 420:13 

carcinogens 431:13 

cardboard 182:11 

302:17 313:14 

care 356:22 357:1 

career 5:10 266:2 

careful 120:2 195:5,16 

238:10 239:3 340:6 

451:19 

carefully 226:9 

carob 234:20 235:4 

236:4 430:21 

Carolina 33:7 41:10 

220:11 221:19 

Carolinas 220:14,20 

221:2,11,22 222:17 

223:3 

carra 166:12 

carrageenan 166:10,13 

262:14 264:15 431:12 

carried 281:1 283:2 

carry 36:1 44:9 104:22 

207:3 

case 75:6 76:7,8 77:18 

77:19 80:16 83:10 

84:9 109:11,12,15 

213:14 217:2 226:1 

276:6 299:14 312:1 

318:3 320:2,8 321:21 

329:1 330:6 352:20 

397:12 398:9 400:5 

424:6 428:22 429:1 

446:1 

cases 76:12,16 77:7,8 

81:4,5,11 86:7 95:19 

101:18 106:3 153:6 

158:14 159:16 226:5 

catalogue 384:11 

categorical 312:22 

313:2 

categories 61:2 289:21 

311:1 313:21 

categorized 110:19 

category 170:6 174:4,7 

174:8 290:5 304:12 

455:3,6,9 

Catholic 19:4 

caught 411:6 436:13 

437:4 441:1,14 

445:22 

cause 116:11 373:20 

397:5 

caused 179:20 221:5 

causes 287:11 

cautionary 272:22 

cautiously 257:20 

CBI 421:14 

CBP 69:16 73:5 75:13 

78:12 81:5 95:8 

CBP's 70:1 71:15 

cc'ing 101:22 

CCOF 201:16 202:3 

204:12 206:1 208:19 

211:16 224:1,6,10,13 

224:15 225:16,20 

257:3,4,9 

CDC 213:4 

CDFA 433:12 435:18 

439:15 

celebrated 40:20 

celebrating 58:18 

celiac 233:6 261:4 

cellphones 144:17 

cells 351:20 353:20 

cellular 260:3 

census 61:10 

center 12:10 67:11,14 

67:15,21 126:16 

137:19 270:19 369:9 

401:1 

centimeter 279:11 

centimeters 279:12 

central 211:12 

centrifugation 456:16 

centuries 260:8 

CEO 427:5 

certain 117:10 254:21 

275:14 280:8 288:12 

311:7 363:22 365:8 

366:14 439:22 

certainly 17:15 23:6 

28:2 29:9 31:13 100:6 

115:7 126:4,13 

163:22 166:2 274:12 

275:1,6 307:7,17 

345:11 359:18 362:15 

366:11 415:20 416:18 

456:20 

certificate 66:18 70:1 

71:15 78:17,19,20 

83:11,16,18,20 84:22 

92:22 94:21 140:2 

226:21 

certificates 70:12 83:7 

83:18 113:14,15,19 

certification 28:2 68:12 

80:22 81:9 86:11 

98:18 111:7 112:7 

113:1,4,5 114:2,3,22 

115:10,15 138:15 

155:4 162:14 167:7 

180:7,8 186:11 196:3 

197:12 207:16 222:14 

224:14,22 262:4 

274:9,13 288:1,20 

290:9,21 302:4 

307:10,13 308:6 

338:17 340:19 356:6 

359:20 360:12,14 

372:11 380:15 381:1 

381:14 382:7 383:10 

385:22 386:6 388:15 

388:18 393:19,21 

396:11,16 397:4 

442:19 443:3 444:3 

446:1 447:4,5 449:9 

449:22 454:20 458:3 

certifications 113:17 

154:3 155:21 195:10 

364:19 

certified 13:7 30:3,5,11 

30:14 31:9 35:7 42:14 

51:13,14 58:19,21 

59:11 62:2 83:13,15 

98:15 107:10,11 

109:16 111:3,8 112:4 

112:6,8 122:9 138:13 

141:4,7 147:3 149:14 

153:5 154:3 156:1 

168:3 170:5,19 180:2 

184:22 195:6,8,11 

197:14 206:2 207:19 

221:18 225:7 226:19 

227:6 228:9,20,22 

229:3,8 230:6 244:22 

257:4,8 295:21 

334:10 337:19 338:3 

338:6 345:9,18 368:8 

374:20 379:12,22 

381:4,21,22 386:13 

389:17,19 390:13 

391:8 399:21 410:15 

411:20 412:17,19 

413:3 415:5 417:8 

418:9 427:7 442:12 

442:22 443:13 447:19 

449:15 451:15 454:16 

455:12,14 457:19 

458:2,16 

certifier 13:11 61:17,17 

78:18,22 80:16 81:15 

83:2 87:18 88:2 93:3 

93:8 94:11,15 97:12 

103:10 107:12,13,17 

107:19 110:7 111:12 

196:18 197:5,10,13 

199:21 205:10 230:19 

245:2,9 247:22 253:1 

253:6,21 257:3,13 

283:21 284:12 293:7 

294:17,20 302:18 

308:16 309:6 311:2 

321:14 338:18 388:13 

389:19 390:2,10,13 

391:4,9,11 416:13,21 

438:10,13 449:5 

certifier's 390:7 

certifies 374:21 390:10 

443:4 445:21 

certify 152:20 155:22 

200:3,4 224:8,16 

245:11 294:10 302:5 

305:3 308:5 334:11 

374:3 393:22 454:19 

cetera 205:2 225:3 

237:11 377:11 422:2 

CFSA 220:12,12 221:13 

223:3 

chain 62:21 69:7 70:10 

71:1 72:13,16,16,17 

73:11 78:14 80:12 

83:4 85:3 153:12 

172:16 302:12,17,20 

304:11 344:4 345:15 

346:4,8 410:15 

414:12,17 418:9 

451:1,7 452:7,18 

455:11 

chains 72:14,18 73:10 

76:13 84:20 93:11 

267:11,14,15,20 

chair 1:12,13 5:4 10:17 

10:18 33:17 55:7,10 

135:1 251:20 257:4 

chairing 10:19 

Chairman 1:10 16:14 

17:3 57:22 205:22 

Chairman's 3:8 

challenge 313:16 381:2 

452:19 

challenged 156:8 

challenges 16:1 90:10 

92:17 112:9 113:21 

114:3,5 124:15 

331:20 372:19 

challenging 52:6 270:7 

426:18 

chance 24:21 25:9 

29:19 149:17 156:18 

176:17 334:4 445:14 

change 37:1 38:11 53:5 

99:8 171:18 172:7,11 

202:3 203:9,18,22 

204:18 221:12 281:17 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
468 

282:14,17 283:16 

298:20 299:16 353:16 

375:7 384:16 390:12 

408:8,8,14 411:8 

427:14 443:7 

changed 35:17 90:4 

203:22 

changes 50:15 53:8 

157:11 278:18 352:11 

394:15 403:17 404:9 

404:13 

changing 218:13,16 

221:4 322:17 403:22 

character 146:8 

charged 253:1 

Charlotte 287:17 295:7 

295:8,11 298:16 

300:2,8 

chart 71:18,22 267:2 

charting 91:1 

chats 66:10,16 

cheaper 323:10 

check 83:8 296:3 

checking 112:14 

checklists 90:8,21 

424:7 

checks 249:2 

cheerleader 253:6 

cheerleader-in-chief

253:7 

cheese 194:19 197:19 

199:4 312:14 

chemical 241:7,11 

281:17 282:14,20 

283:16 

chemical- 220:22 

chemically 263:18 

281:21 

chemicals 208:5 

369:18 400:18 412:6 

chemistry 249:16 

cherries 45:5 

chicken 214:15 218:11 

chickens 297:11 

chicks 103:18 104:17 

106:5 116:2,5,14 

214:6,19,22 297:10 

298:6,10 

child 18:6 

Children's 12:11 

chilly 11:8 

China 252:16 

chips 431:17 

chloride 334:15 337:2,9 

chlorine 334:15 337:2,7 

337:8 422:3 

chocolate 431:16 

choice 140:15 191:12 

221:19 397:9,11 

445:9 

choices 258:17 

choose 116:12 119:12 

140:17 221:16 245:4 

296:16 307:10 308:5 

334:1 367:7 397:13 

chooses 360:11 

choosing 17:12 39:11 

395:6 

chose 19:15,16 140:16 

398:4 

chosen 345:14 

Christie 160:6,9 

Christine 146:17 

chronic 411:12,15 

Circle 343:5 

circulation 300:20 

circumstances 201:9 

376:11 391:21 

circumvent 386:15 

cite 416:4 

cited 425:12 

cities 11:14 17:9 22:12 

23:13 27:19 34:20 

51:7 59:18 408:2 

citrate 148:18,21 

157:16 334:14 336:4 

336:13 368:11 454:13 

456:5,7 

citric 282:6 

city 17:5 22:11 27:15 

35:5 42:17 58:20 

413:17 447:9 

civil 123:7 440:11 

claim 117:8 195:8 

197:22 450:6 457:20 

claimed 300:13 

claims 195:5,16 225:10 

438:16,17 

clarification 168:15 

177:13 250:18 282:10 

348:8 402:16 

clarified 176:19 375:18 

clarify 123:21 135:22 

194:3,9 198:21 

246:18 249:5 262:6 

281:9 282:21 353:9 

394:9 

clarifying 251:6 282:12 

Clarissa 2:5 4:18,19,22 

5:4,10,19 346:15 

clarity 192:5 368:7 

377:11 402:14 403:12 

class 43:5 455:5 

classes 42:9 380:2 

381:12 

classification 171:4 

280:21 281:12 282:12 

282:16 283:10 443:8 

classified 171:8 222:7 

284:1 

classify 74:16 

classifying 170:12,17 

386:18 

classroom 43:14 

classrooms 43:2 

clean 269:20 412:20 

clear 90:11 104:16,19 

153:19 154:2 172:7 

176:4 215:6 241:4 

330:9,15,19 332:15 

344:17 345:1 349:8 

350:14 352:19 353:21 

354:11 368:22 369:1 

377:13 388:8 394:13 

433:21 434:3 452:1 

clearance 85:14 131:8 

131:10 133:7,8 193:9 

cleared 131:13 

clearly 92:6 128:21 

144:4,18 146:13 

154:16 254:1 364:10 

364:22 

client 196:18 

clientele 248:12 

clients 307:9,14 308:4 

345:19 

Clif 14:15 

climate 27:16 221:4,11 

408:7,8,14 411:7 

427:14 

climates 403:22 

clinches 349:3 

cling 263:7 

clipping 241:7 

clock 140:16 

close 10:13,16 16:8 

17:13 94:2 108:19 

111:5 164:12 254:8,9 

272:19 324:12 363:20 

closed 321:22 

closely 44:11 64:1 

69:18 106:19 127:7 

289:14 

closer 138:17 262:17 

closes 132:4 

closing 52:22 172:14 

235:17 252:22 

Cloud 29:14 

co-executive 374:19 

co-led 273:22 

co-op 13:1 408:4 413:1 

co-ops 255:10 

coalition 103:7 128:13 

146:21 160:10 215:5 

368:1 

coast 9:4 272:13 

275:19 

coastal 221:1,10 

coating 354:13 

cocktails 409:19 

459:13 

cod 271:18 444:13 

code 113:18 140:10 

codes 95:9 

codex 317:16 

cognizant 328:11 

cohort 301:4 

coincidence 114:8,9 

cold 47:4 48:12 

cold- 263:8 265:12 

cold-soluble 264:20 

colder 13:9 

coldest 17:19 

collaborate 63:2 127:8 

collaborating 63:18 

85:8 

collaboration 69:6 

96:13 136:6 161:6 

228:17 338:16 428:4 

collaborative 387:18 

collaborators 49:5 

collateral 26:22 

colleague 17:18 31:17 

colleagues 8:10 119:10 

390:1 401:1 

collect 215:18 216:1 

370:9 

collected 373:13 

collecting 125:20 

372:22 441:9,10 

collection 176:3 370:12 

college 29:10 33:1 

36:17,19,19 37:3 

colleges 36:16 248:9 

colonial 277:5,18 

color 145:8 248:22 

320:5,10 379:17 

380:21 381:3 382:15 

417:21 

Colorado 12:15 21:14 

257:13 

Colson 432:14 442:7,11 

442:12 446:19 447:22 

column 289:6,17 

com 117:3 

combination 83:2 

288:11 

combine 184:5 

come 22:6 23:11,16 

29:12 41:13 46:18 

54:15 65:15 71:2 

109:21 117:22 118:1 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
469 

120:10 127:15 139:19 

142:11 144:9 155:8 

156:18 160:19 163:11 

168:13 193:7 198:20 

204:12,20 211:3 

231:16 243:13 268:22 

277:16,19,22 278:3 

293:1 301:15 309:5 

321:12 335:11 348:4 

357:15,19 359:2 

360:14 365:12 377:3 

383:9 427:19 433:13 

458:12 

comes 106:16,21 

109:15 113:22 268:9 

270:2 327:4 347:13 

comfortable 330:2,5 

comforting 232:7 

comically 122:6 

coming 27:7 34:13 

42:22 53:5 74:16 

101:22 120:8 128:2 

146:9 155:18 182:9 

187:16 238:13 247:1 

247:13 275:3 305:22 

307:1 310:4 411:17 

414:14 418:19 433:22 

440:4 446:16 

commanded 344:14 

commands 57:1 

commas 172:8 375:15 

commend 394:8 448:13 

commendable 386:20 

comment 57:10 67:5 

76:3 88:11 102:4 

103:2 110:5 114:15 

115:6 127:22 128:12 

131:6 132:4,16,19 

133:1,21 135:14 

136:18 142:15 143:17 

143:18,21 144:1 

145:19,22 146:6 

149:18 150:3,16 

156:15 159:4 160:13 

160:14 165:17,20 

169:4 173:17 185:4 

190:20 193:11 198:21 

202:1 210:16 225:21 

226:6 235:21 243:14 

261:13 306:17 308:12 

308:13 328:17 333:8 

337:1,11 342:2 349:1 

367:14 372:15 377:15 

386:3 387:7 389:3 

394:2 395:10 398:21 

405:12 406:5 430:15 

434:8,10 438:5 

448:11 450:16 454:11 

459:4,7 

commented 157:15 

302:8 

commenter 142:1 

146:16 150:14 169:5 

300:3 334:4 361:5 

364:13 459:9 

commenters 105:6 

145:4,15,17 146:2 

152:18 177:11 358:6 

368:4 

commenting 144:19 

177:21 224:2 245:6 

280:5 302:7 374:22 

commerce 252:18 

commercial 94:22 

182:10 252:4 270:5 

339:15 343:13 435:7 

445:1 447:7 

commercially 148:3 

170:7 335:7,8 

commingled 416:1 

commingling 416:12 

Commissioner 2:12 

10:4 15:2,20 16:9 

35:9 55:2 

commissioners 26:11 

commit 120:10 

commitment 160:11 

289:21 290:3 387:14 

commitments 243:21 

committed 69:10 

172:17 173:11,14 

346:5 418:6 

committee 103:16 

135:1,2 191:21 229:2 

393:11 

committee's 148:19 

commodities 63:12 

125:13 126:11 

common 214:17 216:5 

217:22 221:7 234:22 

273:3 294:5,9 313:6 

346:22 385:13 

commonly 234:10 

communicate 102:11 

102:22 291:18 

communicating 332:1 

communication 65:22 

100:8,13 101:2 

115:20 160:20 333:1 

communications 104:6 

402:6 

communities 30:22 

221:8 366:10 380:18 

community 16:8 41:2 

56:22 61:5 63:3 85:8 

89:6,13 118:22 

124:16 129:15 130:16 

186:22 207:8 234:4 

244:6,12,19 246:16 

249:14 250:11 257:12 

258:13 259:12,14 

272:16 274:21 292:6 

326:16 327:22 332:18 

350:3 357:22 380:11 

382:6,14 383:6 

390:17 408:15 445:4 

445:7,10 

compaction 47:18 

companies 174:11,18 

277:14 373:13 395:3 

395:5 

company 14:15 173:8 

173:10 246:1 291:9 

344:3 346:4 349:17 

415:12 448:8 453:9 

company's 246:9 427:9 

comparable 339:8 

compare 50:13 138:1,2 

397:16 

compares 264:15 

comparing 44:6 

comparison 345:11 

433:9 445:5 

comparisons 340:5 

compatibility 420:6 

compatible 335:20 

419:19 

compete 252:14,16 

competing 358:13 

competition 52:17 

competitive 240:13 

403:22 

complainant 108:12 

complainants 82:7 

complaint 74:13,20 

75:15 82:8,19,20 83:9 

83:19 95:19 106:8,9 

106:16,18,20 107:1,2 

107:4,7 108:3,7,8,10 

257:7 321:20 326:14 

326:20,22 327:4 

331:5 

complaints 74:16,18 

75:3,7,10 81:14 84:14 

91:18 95:21 96:4,4 

108:5,6,17 129:16 

138:6 328:14,18 

331:11,12 

complete 69:11 96:8 

229:14 347:20 357:16 

completed 146:3 

341:16 

completely 193:21 

286:21 357:20 425:21 

completing 95:7 

complex 76:12 128:1 

181:10 183:18 293:15 

411:12,15 

complexity 210:10 

225:8 

compliance 6:5 68:4 

73:17,22 74:12 76:19 

95:13 96:9,12 97:8 

129:8 137:8 195:15 

204:20 225:13 230:3 

246:12 254:22 330:13 

330:13 335:12 346:5 

359:19 360:4 417:14 

417:14 418:1 421:10 

457:7 

compliances 413:5 

compliant 108:15 

234:14 246:6 378:7 

416:11 

complicated 276:9 

361:14 402:20 

complicates 442:2 

comply 324:8 388:12 

395:5 400:1 414:12 

component 125:4 

220:15 299:13 

components 200:18 

268:7 344:11 349:22 

450:15 

composition 175:5,14 

181:5,14 

compost 87:15 303:1 

310:17 311:13,15 

313:8 335:18 339:9 

345:4 356:15 399:10 

428:16 

compostability 356:19 

compostable 450:3 

453:2 

composted 303:4 

composting 449:22 

compound 355:2,9 

compounds 212:1 

241:12 

comprehensive 34:15 

50:10 76:6 340:14 

443:16 

compressed 133:2 

compromise 415:7 

compromised 288:18 

289:11 

computers 144:18 

concentration 351:18 

366:21,22 367:4,9 

370:16 

concentrations 263:17 

366:19 367:2 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
470 

concept 95:4 186:5 

375:9 

concepts 43:9 288:7 

concern 83:14 114:1 

135:13 152:17 153:2 

158:6 159:11 219:20 

224:10 226:20 230:15 

336:3 355:11 372:18 

386:19 392:20 431:13 

437:16 441:4 445:21 

446:15 457:14 

concerned 26:20 83:21 

84:20 98:16 158:13 

163:5 166:14 219:21 

226:16 308:3 336:12 

398:9 406:11,17 

concerning 207:6 

concerns 80:1 93:14 

98:20 135:14 153:22 

159:13 164:2 213:19 

350:9 351:4 352:15 

358:2 370:5,7 400:22 

421:12 433:17 455:19 

concerted 114:18 

concise 310:12 

conclude 387:5 

concluded 147:20 

148:22 

concludes 459:3 

conclusion 301:13 

348:4 

concrete 383:2 

conditioner 449:20 

conditions 79:11 

289:22 323:16 

conduct 44:2 64:17 

68:5 82:13 94:13 

108:5 

conducted 49:17 97:15 

226:2 344:9,16 352:7 

conducting 82:11 

188:21 404:17 

conducts 346:10 

conduit 147:3 

confectionary 264:1 

conference 28:5,10 

29:13 

confidence 77:6 330:1 

392:6 

confident 76:7,19 

174:11 378:18 

confidential 373:14 

confirm 71:12 183:9 

confirmed 78:11 79:1 

92:9 93:7 117:10 

conflating 278:7 

conflict 86:7,17 87:8,18 

88:2 105:15 142:19 

142:22 143:1,14 

214:16 256:14 308:14 

390:10,21 391:10,12 

391:19 

conflicted 104:18 

conflicting 352:17 

conflicts 86:4 91:13 

143:6,7,9,12 252:21 

390:22 391:1,3 392:8 

392:8,10 

confused 239:8 251:1,2 

278:18 

confusing 192:8 280:18 

283:13 337:4 406:21 

confusion 239:10 

287:11 

congratulations 140:21 

141:12 

Congress 91:21 104:13 

104:14 252:5 253:1 

conjunction 196:7 

connect 54:7 414:10 

connected 72:8 

connecting 151:13 

connection 297:5 

connections 53:21 

conniption 418:2 

consensus 50:5 58:8 

342:11 357:21 

consent 64:22 

consequences 39:19 

149:3 

consequently 27:3 

Conservancy 272:14 

conservation 7:19 

272:11 273:22 276:5 

conserved 446:21 

consider 63:14 85:4 

88:8 109:9 117:14 

118:7 188:16 190:4 

208:11 210:7 226:9 

233:16 254:17 260:1 

303:7 304:11 305:14 

314:5 336:18 341:22 

380:19 382:10,12 

384:17 392:20 404:14 

423:13 433:8 

consideration 71:5 

161:3 223:6 302:11 

308:15 373:22 405:18 

420:16 

considerations 258:17 

307:17 

considered 65:7,14 

67:8 99:22 113:16 

175:3 222:1 237:13 

262:3 336:5 353:6 

361:21 366:8 369:19 

371:14 386:22 395:16 

419:17 420:5 421:22 

447:14 456:4 458:6 

considering 72:17 73:9 

88:5 175:13 321:5 

362:16 383:17 

considers 346:9 399:16 

consistency 86:9 196:5 

196:14 200:19 269:22 

311:8 370:22 388:13 

454:20 

consistent 62:5 68:12 

75:16 80:22 86:10 

95:15 114:2,3,4 

162:14 194:6 201:2,3 

230:16 235:15 338:15 

388:8 391:17 454:15 

457:6 

consistently 212:20 

215:19,21 301:10 

consolidation 71:7 

415:14 

constitute 82:20 

constrained 121:5 

constrict 176:7 

construct 104:5 

constructive 377:19,21 

consult 244:14 245:21 

247:18 

consultant 236:21 

356:3 

consultants 390:8,12 

consultation 89:8,15 

consulting 253:16 

consumer 12:20,20 

77:5 98:14 105:12 

212:19 213:19 215:6 

260:12 279:2,6 

295:12 296:1 297:4 

298:10 300:9 318:3 

388:15 407:19 409:13 

444:4 

consumer's 400:21 

consumers 31:6 212:20 

212:22 213:11 214:13 

229:17 245:3 259:7 

278:17 279:8,13 

295:14,16 296:10,16 

298:12 301:9,15 

316:17 387:14 407:7 

409:6 412:19 413:6 

414:2 418:8 

consumption 153:6 

235:16 441:6 444:8 

458:7,7,10 

contact 61:16 152:2 

178:8 248:7 351:11 

353:13 374:11 

contacted 78:15,18 

contacts 79:13 

contain 189:16 194:21 

197:19 234:13 272:2 

344:18 450:15 457:18 

contained 337:18 338:2 

344:21 

containers 179:6 

containing 352:16 

401:6 456:22 

contains 237:10 395:14 

contaminants 401:8 

contaminated 412:2,3 

412:3,4 

contamination 148:11 

179:19 186:20 191:20 

221:8 358:2 370:1,17 

372:17 373:1,18 

394:21 395:1,7,8 

396:21 397:1,15 

405:18,22 406:4,14 

content 182:9 303:20 

357:5 373:8 

CONTENTS 3:2 

context 126:9 131:3 

221:4 326:8 445:8 

contiguous 112:19,22 

continue 10:11,12 31:6 

32:7 53:16 60:9 61:12 

63:2 72:3 74:9 75:13 

81:15,20 85:18 87:20 

93:4 94:12 130:15,21 

197:10 200:21 236:22 

246:16 292:1,6,17 

362:11 370:20 373:16 

408:11 443:12 

continued 15:11 74:15 

88:18 148:8 170:20 

174:6 187:10 258:20 

280:11 357:10 358:4 

400:13 435:19 444:2 

continues 61:7 172:2 

203:8 210:12 239:9 

405:2 

continuing 62:18 64:17 

67:17 68:1 81:5 93:22 

97:13 202:6 223:16 

345:18 369:10 419:5 

continuous 171:12,17 

172:5 292:12 375:9 

376:3 394:9 419:6 

430:3 

continuously 173:15 

325:8 373:12 

contract 75:4 196:20 

248:1 286:10 406:15 

contracting 94:19 

contractor 248:2 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
471 

contracts 253:16 

380:10 

contrary 197:2 304:2 

contrast 11:9 120:7 

182:5 345:6 

contributed 281:5 

contributes 233:3 

260:9 

contributions 443:18 

control 46:1 62:15 63:9 

70:15 94:4 109:14 

138:22 222:3 225:19 

239:22 241:9 263:11 

276:17 335:18 351:7 

364:2 376:12 412:6 

413:6 414:15 415:12 

415:13 

controlled 101:8 

controlling 316:3 

controls 92:18 414:1 

controversial 162:21 

298:7 

controversies 133:15 

136:15 

conventional 9:6 116:8 

156:9 191:15,16 

207:12 212:5 220:15 

221:10 317:21 319:20 

320:15 321:11,17,18 

324:14,18 325:9 

364:4,15 390:2 395:2 

412:6 415:22 416:9 

416:17,18 432:20 

434:12,19,21 451:14 

conventionally 50:14 

300:15 323:11 

conversation 70:21 

73:8 100:1 122:22 

302:14 341:22 361:15 

373:17 402:22 

conversations 60:5 

69:16 73:13 115:6 

142:14 144:15 181:12 

370:18 372:1 

conversion 321:19 

324:20 430:3 

convert 321:15 430:3 

converted 324:18 

converting 317:20 

convey 146:13 

conveys 375:11 

convinced 187:8 

convoluted 443:20 

Coody 142:1 146:16,19 

146:19 150:20 152:22 

153:7 154:19 156:13 

157:13,21 159:13 

160:4 

cook 217:18,18 

cooking 217:17 219:4,7 

cool 385:9 

cooled 264:9 

coolers 412:4 

cooperated 78:22 

cooperative 8:22 9:3 

190:19 385:22 

coordinator 2:15 10:6 

13:12 33:1 

Copies 296:1 

copy 102:1 

core 81:21 85:4 415:8 

Cori 459:9 

corn 20:17 30:8 77:20 

77:22 78:3,5 79:2,10 

79:22 114:11 148:14 

191:12 221:14 372:20 

373:6,18,21 374:3,13 

421:20 

Cornell 33:5 41:10 

270:16 

Cornucopia 251:21 

256:17 389:13 

Corporation 350:7 

corps 237:3 

correct 61:15 100:3 

293:8 306:21 344:7 

347:3 415:10 416:3 

441:6 448:3 

correctable 359:12 

correcting 413:4 

corrections 58:2 

corrective 288:22 

correctly 100:5 249:10 

371:9 415:2 

correspondence 101:5 

101:7,8 102:2 

cosmetics 240:18 

cost 28:2 47:15 128:4 

383:9,13 

cost- 115:18 

cost-share 383:10 

Costa 315:10,18 317:8 

317:12,14 

costs 332:21 

cotton 141:8 

council 12:22 212:13 

232:16 249:12 251:8 

251:13 

counsel 105:19 

count 38:9 

counterparts 379:20 

counterproductive

172:9 

counties 59:18 

countries 164:15 224:9 

252:17,17 315:8,11 

318:1 

country 27:1 36:9 47:7 

47:12 84:12 167:14 

174:22 216:10,11 

256:4 319:8 384:12 

408:5 409:5 429:19 

430:9 443:11 

country-wide 72:21 

county 59:12,13,17 

60:7,8,10,15 110:3 

124:22 

county- 60:3 

couple 22:9 28:15 

29:14 70:20 71:2 95:6 

95:17 106:15 119:12 

127:20 142:17 151:6 

153:9 175:21 177:11 

194:18 199:19 210:1 

254:20 283:13 340:22 

356:13 383:7 384:13 

433:5 

course 23:1 26:13 31:2 

45:8 48:22 59:7 62:13 

68:20 242:10,17 

303:20 397:3 406:10 

426:4 

court 276:4 278:3 

courts 276:9 

cousin 19:20 20:1 

cover 33:14 38:1 46:21 

46:21 47:20 48:4,5 

49:8 65:19 86:13 

139:9 207:13 269:15 

296:7,15 366:18,21 

367:1,8,13,15 375:8 

409:19 425:18 

covered 65:14 177:6 

206:4 211:4 280:9,14 

357:15 

covering 176:20 350:18 

cow 30:7 52:11 256:4 

428:6 

cows 255:12,13,15 

256:5,11,21 257:6 

428:8 

CP 258:10,11,13,20 

261:10 263:1 266:1 

CR.org 301:2 

cradle 420:5 

craft 426:9 437:11 

crappy 309:7,18 

cream 429:17 

creamery 427:6,8 429:3 

create 30:18 73:16 

266:10 295:14 373:7 

388:12 419:21 

created 41:16 147:14 

246:14 282:20 

creating 136:22 273:7 

324:6 350:2 427:11 

creation 454:14 

creative 385:6 

credit 381:6,6 

crisis 408:14 

criteria 104:9,9 151:8 

153:19 186:16 280:21 

286:13 294:17 420:17 

criterion 148:6 

critical 36:4 39:12 

42:10 53:13,20 80:8 

86:10 148:16 296:10 

351:6 357:13 359:8 

377:13 387:13 388:20 

403:4 408:19 419:16 

423:6 

critically 147:21 148:12 

criticism 253:4 255:3 

257:22 

criticize 301:11 

criticized 256:22 257:2 

critique 257:21 

Croix 379:12 

crop 9:1 38:1,1 47:14 

47:14,14 79:10 83:12 

83:15,15,17,17 87:17 

88:22 110:17,18 

111:19,20 152:21 

153:5 161:14,17,20 

176:18 186:5,14 

187:17 191:5 202:19 

207:13,13,18 211:22 

221:1,16,18 222:13 

222:16 224:15 225:14 

226:19 252:15 272:17 

304:12 309:21 318:9 

318:12,13 334:11 

335:2,9,20 337:17 

339:19 350:9 357:11 

366:18,22 367:8,13 

368:7,8 374:22 

376:13 378:5 386:4 

386:13 395:20,21 

397:4 405:16 406:2 

406:11 409:19 442:21 

442:22 443:22 446:2 

446:8,14,17 448:14 

454:17,20,21,21 

455:4 458:2,5,5,14,15 

crop's 180:6,7 

CROPP 190:18 192:16 

385:22 

cropping 49:8 

crops 2:3 6:16 33:14 

46:21,22 47:3,20 48:2 

48:4,5,9 49:16 88:4 

150:19 187:4,4 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
472 

191:14 211:14 220:17 

225:18 237:4,10 

241:22 318:14,18,21 

345:21 350:18 367:1 

367:15 370:3 373:1 

399:14 428:21 443:19 

449:12 450:13 

crossing 63:14 

crossover 164:5 

Crotser 379:3 385:21 

385:21 389:7 

crowd 432:16 

crown 28:4 

crucial 220:14 

crumbled 28:20 

Cruse 334:5 338:10,13 

338:13 342:14 

crystal 235:5 

CS 394:13 420:14 

CS's 394:4 

CSA 252:12 380:7 

Cuba 28:16,21 29:9 

cultivar 46:6 

cultivated 437:6 

cultural 115:17 234:5 

384:7 

culturally 384:5 

cultures 380:2 

cumbersome 360:17 

cure 411:14 

cured 165:7 

curious 209:18 276:18 

366:17,20 371:12,18 

378:3,11 383:2 406:4 

453:8 

current 56:20 86:21 

181:8 193:18 198:16 

214:3,18 239:4 

290:10 360:20 364:2 

396:2 455:13,14 

currently 8:22 12:2 

89:1 97:5 147:8 153:4 

155:4 182:16 184:3 

195:11 225:11 339:10 

379:21 386:8 399:20 

406:19 443:3 455:2,5 

curricula 5:7 

curriculum 40:12 

Currier 448:2 454:6,8,9 

458:4 459:2 

curtailing 334:2 

curve 135:7 

customers 258:13 

416:15 427:10 451:13 

Customs 69:16,19 73:3 

94:20 

cut 16:16 144:11 154:9 

256:10 314:19 

cuticle 355:8 

cutting 256:8 

cycles 235:15 

cycling 386:15 

D

D.C 21:16 120:15 

121:16 

dad 18:12 

dairies 255:17 427:18 

429:3 430:3 

dairy 51:11,14,20 52:6 

52:21 73:17,22 90:11 

96:9,11 206:3,12,15 

206:22 235:8,14 

254:19,21 264:1 

268:6 321:3 330:13 

400:17 401:3,5 427:6 

427:7,13 428:6,14 

430:8 

Dale 427:2 432:13,17 

439:14 

Dalhousie 272:3 

damage 27:1 45:2,19 

damaging 276:22 

damning 253:3 

Dan 1:21 12:20 248:16 

250:22 251:4 254:12 

275:8 295:4 324:10 

414:20,21 415:10 

442:6 

dangerous 23:22 

331:13 

Danish 448:8 

dark 216:18 

darn 154:21 156:13 

data 50:10 59:14,19 

60:6,6,8,17,21 61:3,5 

61:7,10,12,13 63:19 

64:2,3,12,15 70:16 

71:8,10,15 72:8,11,21 

73:1,3 77:21 78:10,13 

79:17,20 80:7,9,12,13 

80:19 85:3 95:2,8 

113:22 114:4 126:22 

127:3,5 138:9,17 

192:4 215:14,18 

216:1 217:15 219:6,9 

275:4 351:20 355:15 

366:1 370:9,11 

372:22 373:12 436:10 

database 59:9,15 61:1 

61:16 64:15 71:21 

78:4,12 80:8 95:13 

110:2,20 111:10 

112:5 113:15,17,20 

138:11 147:16 152:1 

157:8 176:3 195:13 

211:11,20 226:22 

340:15 398:7 

date 73:21 74:8 84:6 

126:2 205:14 

dated 198:10 

dates 214:20 

daughters 19:21 

Dave 1:17 2:12 10:3 

12:16 14:22 119:8 

154:9 157:5,13 

159:22 241:2 262:19 

319:14 348:20 354:20 

366:16 377:16 384:19 

432:14 436:4 442:7,9 

442:12 445:16,17 

453:7 

David 205:18 212:7,8 

212:11 258:7 262:16 

262:19,21 265:17 

409:19 

David's 266:11 

day 10:9 19:22 22:21 

24:1 32:17 37:9 68:9 

103:4,18 105:11 

279:11 281:4 297:14 

410:18,18 

day- 298:5,9 

day-old 103:18 104:17 

106:5 116:2,7,14 

214:22 297:10,21 

299:11,15,17 

days 95:16,22 107:6 

120:10 127:22 190:22 

214:20 409:8 

Dayton 15:4 23:15 

de 1:15 12:5,5 117:17 

173:4 430:14 

de-oiled 234:7,8,12 

dead 390:4 

deadline 99:7 107:21 

336:3 339:11 343:17 

348:17 358:15 359:17 

deal 16:17 22:10 156:5 

167:16 181:19 206:5 

247:4,5 344:19 438:9 

439:19 440:15,16 

dealers 374:3 

dealing 176:13 331:16 

deals 253:10 

dealt 191:21 434:7 

435:18 

death 23:4 

debate 171:3 240:16 

242:16 272:19 

debating 57:9 

decades 249:13 

deceivingly 181:9 

183:18 

decertification 162:18 

decide 39:20 290:19 

293:17 

decided 20:13 88:15 

100:2 124:6 

decision 19:22 98:16 

99:13 123:17 250:8 

276:10 282:1 283:11 

284:12,18 285:1 

286:3 320:7 322:8,9 

323:5 333:3 344:20 

345:17 422:13 

decision-making 36:3 

53:19 61:6 100:4 

120:3 127:17 419:10 

decisions 53:14 60:17 

86:6,6 99:19 128:5,8 

129:22 196:3 244:22 

246:8,10 253:17 

295:18 380:20 419:8 

426:3 

deck 146:16 177:16 

251:18 265:18 270:12 

295:8 302:1 334:6 

338:11 343:1 367:19 

372:5 374:16 410:10 

decline 444:20 

dedicated 10:10 91:4 

97:13 343:6 390:19 

dedication 57:12 

172:22 337:10 

deemed 346:10,21 

deep 76:16 271:19,19 

deeply 181:3 380:14 

434:6 

default 447:16 

defending 416:21 

Defense 212:13 

defensible 82:1,3 

defer 177:9 247:12 

defined 286:9 

defining 104:3 

definitely 153:8 163:9 

320:18 354:6 375:11 

422:9 

definition 182:7,17 

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345:1 400:2 401:15 

401:17 

definitions 402:16 

458:8 

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Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
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delisting 199:4 371:10 

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407:19 409:14 455:14 

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339:22 

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Denver 21:14,15 

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156:22 

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353:19 

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369:17 

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403:20 

Devon 2:6 5:22 6:3 

139:17,18,19,21 

140:3,15,21 141:13 

346:14 

Devon's 346:15 

DFO 243:13 

dialogue 102:11,15 

292:6 326:19 

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Diego 288:2 

dietary 170:4,22 173:22 

175:15 234:6 258:17 

259:16 

differ 49:8 

difference 123:3 178:6 

187:3 300:14 428:11 

429:11 

differences 54:6 80:6 

208:18 329:7 

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64:16 65:13 66:4,9,13 

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149:12 153:10 157:18 

158:3,19 175:9 179:4 

179:9 181:13,13 

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264:3,17 265:14 

267:2,7 269:11,13 

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329:16 330:16 331:9 

332:13 346:1 348:2 

351:3 352:12,13 

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452:14 

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226:16 300:1 345:17 

381:7 406:21 443:1 

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difficulty 27:9 224:18 

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diglycerides 235:19 

dihydrogen 157:16 

368:11 

diligence 151:19 

184:20 298:17 424:13 

diligently 38:7 118:18 

DiMatteo 356:4,9 

358:22 359:3 361:20 

dioxide 334:16 337:2,7 

337:8 

dire 39:19 

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173:17 178:8 226:1,2 

388:9 

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154:17 

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54:8 

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421:15 

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Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
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422:20 

discussion 88:6 120:17 

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411:12 

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191:16 

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168:14 332:4 

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333:21 

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210:5 

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diverse 43:22 64:12 

229:9 380:10 

diversity 73:14 306:3 

366:3 373:11,22 

404:2 

diverted 182:15 303:17 

division 2:5 4:16 5:3 

6:5 96:16 389:20 

docket 132:1,1,2,5,8 

133:22 134:8,16 

160:20 227:13 236:13 

293:12 338:21 

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doctor 37:2 165:3 

257:16 

doctors 36:22 

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116:4,18 117:2 129:4 

133:6 134:2 135:16 

144:20 152:15 154:5 

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329:1,11 425:12 

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131:1 132:15 133:4 

133:14 134:11 135:2 

143:4 253:12 375:19 

375:20 393:4 422:11 

423:10 424:1 425:5,8 

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63:15 66:20 72:2 74:4 

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130:4 143:15 201:8 

206:19,19 207:1 

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328:4,16 354:17 

374:7 409:20 424:13 

436:16 448:6 

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dollars 47:15 324:5 

413:3 

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228:22 230:15 349:15 

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390:15 392:7 

doubts 79:18 

Doug 168:6 448:2 454:6 

454:6,8 

downtown 42:19 

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Dr 2:4,7 4:3,15,18,21 

5:14,22 6:8,20 7:10 

7:17,22 8:15 9:15,20 

10:5,22 12:19 14:19 

17:2 32:19 33:21 34:2 

44:16 52:9 55:2,22 

56:3,9,10,22 58:10,11 

58:14 59:3,7 65:11 

99:12 101:3 102:16 

103:21 105:16 106:13 

110:21 113:13 115:5 

116:20 118:2 119:15 

121:18 122:14 124:1 

124:18 125:6 126:20 

127:5 128:11 136:2 

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140:21 141:5 142:9 

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209:19 217:14 218:12 

218:21 219:1,14 

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305:19 308:11,19 

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209:10 210:2 211:13 

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376:7,12 378:5 

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Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
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291:7 

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251:8 262:15 308:6 

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278:22 288:11,16 

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309:10 

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138:18 225:12 230:16 

254:15 296:13 358:14 

358:18,20 377:4 

387:8,12,15,20 388:5 

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396:6 

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Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
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373:2 

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224:20 245:13 368:5 

372:22 

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316:14,16 317:2,5,10 

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356:14 

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108:15,20,22 109:3,4 

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446:12 

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154:1,2 190:7 437:13 

452:3 

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49:13 53:1 72:20 80:7 

83:9 84:8 86:16 109:7 

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248:8 289:4 363:12 

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183:20 363:20 413:16 

414:20 420:12 

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263:11 269:3 291:4 

exception 77:11 214:2 

297:9 

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34:7 35:9 39:4 42:2 

46:18 54:18,19 

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203:5 369:8,13,17 

401:12 402:14 403:11 

412:13 421:22 446:5 

exclusion 46:3 

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122:18 

exclusively 40:13,14 

42:5 441:2 

excuse 16:14 189:17 

308:5 429:7 

excuses 431:21 

executive 12:21 14:7 

103:16 243:19 321:3 

323:7 367:22 419:1 

exempt 412:13 

exemption 122:4,21 

123:8 214:18,20 

215:7 299:3 325:3 

Exemptions 122:17 

exempts 297:10 299:11 

exercises 93:9 

exhaustive 82:14 

291:17 

exist 279:20 283:16 

386:8 391:4 

existed 38:10 

existing 172:2 180:8 

186:11 406:17 443:21 

exists 17:11 230:10 

exit 21:3 

exotic 363:11 

expand 75:5 220:13 

441:22 

expandable 429:11 

expanding 176:15 

399:5 

expansion 29:4 138:3 

399:8 

expect 85:16 278:2 

304:20 383:20 395:3 

expectation 154:4 

expectations 388:9 

expected 386:16 

expecting 20:14 82:7 

94:10 

experience 15:21 25:11 

38:18 154:16 165:2 

199:9 249:14 250:10 

291:8 

experienced 101:18 

222:20 

experiences 38:21 

experiments 49:6 

expert 120:9 168:13 

187:11 236:6 286:10 

expertise 390:18 

experts 236:9 387:3 

expiration 86:1 

expire 166:9 

expired 145:13 

explain 103:19 311:9 

311:10,14 315:15,19 

explained 244:5 316:20 

explains 134:15 

explanation 209:14 

230:8 420:16 

exploiting 445:1 

explore 426:19 

explored 273:9 386:21 

explores 33:10 

exploring 73:10 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
477 

export 80:18 315:4 

exported 72:22 79:3 

expose 218:3 

exposed 218:16 

exposes 240:9 

exposing 412:5 

exposition 315:15 

exposure 219:5 355:12 

exposures 12:13 

express 101:16 143:9 

147:2 152:13 234:17 

235:18 334:22 336:3 

expressed 135:13 

152:17 154:5,14 

186:4 283:6 423:12 

423:14 457:14 

extend 47:5 72:3 88:12 

304:14 336:2 396:2 

399:12 

extended 161:10 

200:20 306:19 339:11 

extending 185:7 

extends 141:12 

extension 46:4 99:6,10 

183:11 201:1 216:3 

348:16 350:17 351:10 

353:21 

extensive 340:20 406:5 

extensively 268:5 

extent 240:9 436:10 

440:13 

external 13:12 92:10 

250:9 

extra 369:5 416:6 

extra- 260:2 

extracted 455:4 457:9 

extracts 337:17 

extraordinary 201:9 

extremely 27:8 57:11 

121:5 208:11 274:5 

368:1 434:1 

eye 9:10 81:10 123:4 

138:22 165:3,3 

257:11 

eyes 165:5 

F

face 52:8 153:3 156:7 

379:18 381:4 

face-to-face 94:13 

97:12 

faced 207:8 379:19 

391:21 

faces 44:19 

facilitate 80:15 98:6 

facilitating 70:9 

facilitation 115:20 

facilitator 274:4 

facilities 316:12,12 

facility 182:10 447:7,8 

449:16 

facing 16:1 124:15 

345:17 408:7 411:12 

444:4 

fact 9:11 43:11 72:5 

101:12,20 119:5 

131:11 153:3 181:20 

189:19 192:2 200:14 

215:7 217:4 218:5 

246:10 250:6 299:2 

303:3 307:21 312:6 

312:11 391:1 413:17 

422:21 

factor 289:3 307:16 

391:4 392:2 393:2,3 

factors 288:10,17 

289:19 293:18 

factory 349:18 

facts 288:10 374:4 

faculty 8:1 32:20 33:7 

40:22 44:8 49:18 

270:19,21 

failed 19:15 

fails 213:18 

failure 376:13 378:5 

fair 68:12,13 80:15,22 

82:2 86:10 88:16 

114:1,3 121:14 

295:14 315:13,14 

348:19 390:15 

fairly 104:19 131:20 

133:17 138:12 340:8 

faith 149:13 184:19 

304:15 308:15 

fall 1:5 4:5 11:5 89:22 

289:20 325:1 

fallen 203:10 

fallow 318:12,16 319:5 

319:10 

falls 296:17 

familiar 105:20 

familiarize 268:13 

families 213:3 

family 12:14 15:14,14 

77:2 252:7 364:21 

381:18 384:6 427:6 

family-run 410:14 

fan 367:14 

fantastic 409:20 

far 17:20 23:21,21 87:6 

103:10 113:11 129:1 

170:11 175:22 274:6 

292:11 305:1 308:1,3 

333:10 394:8 

farm 13:6,19,21 14:12 

15:10,19 18:12,13,16 

18:17 19:16,19,20 

21:5 29:6,20,21 37:19 

37:21,22 38:8,18 

48:19 49:15 61:21 

62:15 69:3 80:17 86:1 

94:18 95:10 110:10 

162:17 177:10,20 

201:16 215:19 216:1 

216:17 220:11 228:16 

229:4 230:13,18 

251:22 252:8 256:3 

307:12 313:15 318:22 

319:2 343:5,6 345:14 

359:22 372:10 379:7 

379:12,21 380:10 

381:10,11 382:5 

383:20 385:12 389:12 

398:11 404:21 407:22 

408:20 410:3 427:7 

428:14 429:9 

farm-one 229:6 

farmed 19:18 279:16,17 

279:19,19 

farmer 13:7 20:8 86:11 

121:6 124:20 228:5 

228:13,18 231:7 

232:6 253:5 304:5 

311:14 323:9 324:3 

343:5 350:22 356:4 

359:1,4 364:3,5 381:9 

383:14 387:9 397:21 

406:1 407:10 442:13 

farmer's 14:2,12 48:20 

380:9 

farmer-controlled

228:20 

farmer-led 228:12,20 

farmers' 380:5 

farming 15:15,20 19:21 

20:17 37:12 43:6,6 

53:10 171:15,15 

220:14 307:13 324:15 

335:21 364:4 445:12 

farms 12:14 30:12,14 

30:16,17 31:4 58:19 

68:10 71:7 121:13 

150:19 163:14 168:1 

168:8,8 208:8 221:1 

221:10,18 254:22 

255:15 305:5 343:7 

343:11 345:9 346:9 

349:4 379:16 383:21 

396:6 399:21 407:22 

427:12,13,13,20 

429:12 430:5 

FAS 79:13 

fashion 287:2 

fast 27:4 54:2 133:3 

445:13 

fast-growing 79:8 

faster 75:11 96:4,18 

108:19 133:10 

fat 235:6 258:18 

father's 19:15 

fatty 222:2,7,12,22 

223:10,17 237:2,9 

239:20 240:15 241:6 

242:9 

fauna 444:11 

favor 200:22 221:13 

342:18 

favorable 254:7 

favorably 158:1 

favored 253:17 

Fayetteville 13:18 

FDA 52:2 127:1,6,12 

258:22,22 

fear 135:17 334:20,21 

feasibility 180:1 224:21 

278:12 386:3 442:20 

457:22 

feasible 308:8 

Featherstone 407:22 

feature 449:21 

features 408:2 

featuring 459:13 

February 38:10 87:18 

94:12 

fed 72:14 

federal 2:8 4:11 15:10 

15:12 75:16,18,20 

76:10 77:1 96:2 

109:10,12 131:9,16 

133:17 203:17 204:21 

211:2 271:2 276:1,1 

276:19 377:2 418:14 

fee 113:5 140:14 247:19 

248:4,6 

feed 72:14 87:16 

120:20 153:6 313:8 

323:14 325:3,6 429:9 

429:9 443:8,9,12 

444:3 446:12 455:15 

feedback 57:18 65:20 

65:21 68:15,20 75:1 

98:1 105:19 121:21 

123:5 128:19,20 

130:16 188:7 305:21 

339:1 341:14 377:21 

feeds 434:5 

feedstock 181:9 303:1 

310:17 339:9 399:10 

feedstocks 311:13 

356:15 

feel 25:13 53:3 102:6,13 

105:7 121:13 154:15 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
478 

164:10 183:13 187:13 

193:17 205:6 268:15 

303:13 306:12 330:2 

330:4 333:13 342:20 

373:19 394:15 395:18 

396:21 

feeling 159:2 

feels 108:7 352:20 

feet 409:3 

Feldman 410:11 418:22 

419:1 423:1 425:2 

426:20,22 

fell 22:2 

fellow 33:5 210:18 

270:19 

felt 115:2 151:7 158:20 

158:22 206:11,18 

342:11 

fermentation 170:2 

233:19 260:7 421:12 

421:21 422:1 

Fernando 29:5,16 

fertility 33:12,20 46:20 

225:20 

fertilizer 48:21 386:7,14 

432:19 433:4,15 

436:14,19,20 437:18 

437:20,21 438:7,20 

441:3,12,15 455:4 

fertilizers 434:6 441:4 

455:9 458:15 

fertilizing 434:13 

435:20 438:16 439:20 

fewer 212:21 411:20 

fiber 259:10 

fibers 181:14 304:3 

356:14 

fidelity 99:14,20 

field 62:21 73:16 80:14 

111:18,19 113:11 

119:17 237:11 240:2 

241:12 318:16 341:16 

363:18 388:10 

fielded 94:10 

fields 110:8 111:5,18 

113:8,19 349:5 

figure 312:11 

figured 37:11 383:8 

figures 435:3 

file 290:18 

filed 222:22 321:20 

fill 97:1 

filling 21:8 381:13 

fillings 263:22 

film 356:16 357:4,7 

films 356:14 

final 67:8 71:3 85:16 

178:16 230:1 237:13 

237:19 245:2 281:22 

282:8,11,18 286:22 

321:9 330:10 340:3 

377:2 397:4 426:13 

finalized 329:10 426:11 

finalizing 332:20 

finally 24:5 51:4 79:4 

84:4 89:4 93:7 96:8 

120:12 234:17 246:5 

257:10 337:1 381:20 

411:5 

financial 373:9,20 

Finca 29:6 

find 23:7 113:10 129:18 

129:19 133:21 155:11 

165:4 172:6 179:6 

195:9 202:21 269:4 

273:3 309:6 352:19 

375:20 381:15 412:21 

414:20 432:1 459:21 

460:3 

finding 47:8 148:10 

188:18 

findings 250:6 300:22 

329:5 403:13 

fine 286:21 416:15 

448:6 

finish 134:1,2 135:2 

finished 106:9 181:18 

fire 22:13 156:6 

first 4:12,15 7:22 14:21 

14:22 23:13,18 30:6 

34:6 44:15 52:17 

54:19 59:21 62:14 

69:4 71:18,19 73:17 

78:2,12 80:6 85:11 

88:15,20 99:14 

103:21 104:7,9 

106:17,22 108:7 

110:1,22 111:9 

116:22 127:20 128:17 

140:1 141:22 143:19 

146:15 158:2 169:14 

169:21 183:8,21 

191:9 192:4 194:17 

199:20 204:17 206:6 

232:8 236:21 243:4 

243:15 249:18,19 

252:1 254:13 255:2 

257:8 268:21 297:13 

298:2 299:7 302:18 

302:19 314:20 321:4 

323:10 328:4 334:17 

344:2 346:14 358:18 

364:12 371:3 372:13 

386:2 393:6,10 

402:12 406:11 427:7 

428:14 453:14 454:14 

459:8 

first- 404:15 

first-come 143:19 

first-serve 143:20 

first-time 305:17 347:1 

Firstly 398:22 

fiscal 62:7,8,10 91:21 

fish 225:2 271:12,18 

272:12 277:13,15,17 

277:19 278:4,4 357:8 

357:17 433:7,14,17 

434:4 436:7,8,12,18 

437:10 440:22 441:2 

441:8,9,10,14 

fisheries 225:7 271:16 

357:12 444:19 

fishermen 275:13 

fishery 224:22 

fishing 275:15 277:11 

fits 167:4 233:14 

fitting 11:12,17 

five 34:10 52:18 75:6 

120:13 125:10,17 

253:22 289:9 291:2 

314:21 315:8 328:9 

332:11 350:16 363:14 

420:15 432:5,8,15 

five- 363:17 

fix 71:19 215:8 297:22 

420:20 

fixation 33:13 38:17 

47:2 48:19 

flags 365:16 

flashed 22:15 

flavoring 268:7 

flawed 306:14 

flesh 405:8 

fleshed 402:22 

flexibility 143:8 340:2 

376:2,17 396:17 

flexible 134:21 453:19 

flies 45:6,7 

flip 71:22 

flood 208:3 222:20 

flooding 221:5 

floor 417:15 433:10 

flora 218:13,16 444:10 

floral 148:3 

Florence 221:6 

Florida 363:14 

flower 11:16 

flowering 147:21 316:1 

352:8 

flowing 28:21 

flunk 18:9 

flunked 18:9 

fly 255:20 

flying 22:11 

foams 263:14 

foci 271:2 

focus 39:6 40:14 52:10 

70:19 82:21 90:7,10 

137:7 169:20 254:14 

290:15 291:11 295:15 

303:21 304:10 330:14 

372:15 375:6 387:7 

392:8 442:16 

focused 36:18 42:7 

90:20 147:7 148:13 

191:3 310:13 441:1 

441:14 

focuses 41:19 52:12 

252:19 

focusing 16:3 40:13 

59:12 68:1 81:6 300:9 

330:20 

FOIA 253:12 256:19 

foliage 351:12 

foliar 351:7,21 352:12 

353:11 

folks 6:1 59:4 66:4,14 

68:8 71:20 73:9 75:1 

103:3,5 106:2 123:4 

126:17 128:14 130:6 

132:4 141:22 144:5,5 

243:4 308:13 333:9 

416:5 423:4 459:10 

459:20 

follow 85:18 100:19 

110:10 123:15 128:9 

165:17 201:9 236:10 

283:20 310:16 324:21 

327:9 344:1,7 386:16 

404:3 

follow-up 64:8 69:15 

100:8 126:20 200:7 

211:10 217:7 284:9 

followed 160:6 177:15 

190:15 194:13 201:12 

205:18 206:16 212:8 

220:3 223:20 227:19 

232:13 243:15 258:7 

270:12 280:2 287:17 

310:17 314:11 320:21 

338:11 350:5 355:21 

362:21 379:3 385:19 

389:9 393:16 398:14 

402:2 407:5 418:20 

427:2 432:14 442:7 

448:2 459:10 

following 206:13,21 

229:5 282:9 324:3 

food 5:8 11:13 12:18 

13:1,20 14:8,9 16:5 

27:18 29:1 33:1 37:5 

39:8,9,10 41:17,21 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
479 

50:22 53:21,22 77:10 

99:17 104:13 153:12 

162:17 208:14 213:7 

218:2,9,17 219:13 

224:8 232:16,17 

245:19 259:19 260:8 

260:9,18 261:1 263:4 

263:5,19 264:17 

265:3 295:16,18,21 

296:8 300:12,14,15 

301:7 366:13 379:6,8 

379:9,11,22 380:13 

400:13 401:1 408:2,4 

410:15 411:19 415:2 

415:16 432:18 436:17 

441:5,11 443:5 

459:14 

foods 31:6 50:9 81:22 

127:2 186:15 233:4,5 

234:1,16,22 235:3 

258:16 261:3 262:13 

263:10 295:20 296:11 

296:14 408:4 416:7 

foolishly 20:13 

footprint 220:13 

forage 352:11 

foraging 271:9 

force 31:22 52:1,2 

317:4 430:10 

forced 257:6 364:3 

Foreign 79:5 

forests 271:8,13,21 

272:5 

forever 413:8 

forget 50:2 

forgot 17:21 274:10 

form 207:18 210:3 

218:5 280:14 283:17 

285:17 289:16 342:9 

342:12 367:3 377:3 

formal 67:5 69:9 100:10 

281:11 

formalities 142:8,17 

146:15 

formality 104:4 

formalized 125:17 

136:3 

formalizing 100:9 

formally 391:3 

format 143:20 

formation 235:5 

former 32:1 33:16 

180:17 201:17 252:16 

253:1,6,20 254:4 

388:18 389:22 391:11 

393:1,5,11 419:2 

formerly 450:1 

forming 286:1 

forms 280:8 287:1,5 

342:19 366:19 

formulate 178:15 259:6 

455:10 

formulated 260:11 

formulation 262:1 

formulations 261:2 

forth 17:19 161:12 

248:20 249:21 250:3 

250:12 393:12 

fortified 234:2 259:8,10 

fortunate 29:12 383:11 

409:8 

Fortunately 207:11 

forward 8:14 9:14 24:14 

31:19 32:13 54:20 

57:2 79:14 89:2 

104:22 118:1 123:22 

180:12 210:9 231:17 

292:19 305:21 333:3 

341:22 356:11 357:20 

358:10 370:8 388:6 

402:22 403:19 

fossil 304:7 

foster 155:13 

fostered 31:15 

found 36:16 37:6 39:7 

47:22 48:16 79:6 

143:1 150:18 196:15 

240:22 253:13 257:1 

257:12 296:8 301:5 

354:16 363:17 427:22 

foundation 171:15 

444:22 

founded 228:7 252:4 

founder 427:5 

four 7:15 23:13 30:13 

41:15 45:21 47:19 

48:3 62:6,11 63:5 

94:3 105:13 118:5 

168:10 279:11 350:17 

356:5 

fourth 10:18 12:8 14:17 

55:9 63:1 85:7 

fowling 277:11 

fractionation 240:21 

frame 434:9 

frames 96:15 

framework 71:4 238:14 

242:20 

France 301:5 

frank 163:10 

frankly 120:6 165:13 

240:11 309:7 

fraud 64:14 76:2 85:6 

114:7,9,16 137:19 

197:8 231:1 389:15 

391:5 392:3 

fraudulent 77:10 78:7 

fraudulently 390:2 

Frederickson 2:12 10:3 

15:1,4,11,14 16:10,13 

16:20 17:2 22:1 26:4 

55:2 

Frederickson's 15:20 

free 29:10 148:11 

264:19 333:13 

freely 215:4 

freeze-thaw 235:15 

frequency 290:13 

frequent 46:5 407:12 

frequently 80:10 

fresh 12:3 45:10,12,12 

50:14 146:22 252:11 

386:19,22 407:15 

Friday 6:12 10:13,13 

460:2 

friend 23:10 207:12 

236:8 

friendly 26:14 

friends 24:15,17 

fringe 36:13 40:7,8 

front 67:10 122:19 

136:4 137:19 355:6 

369:9 383:14 

frozen 38:12 235:14 

fruit 5:11 12:15 45:1,6,7 

45:10,11,12,13 155:9 

156:1 163:22 315:3 

316:14 

Fruitilicious 201:16 

fruits 50:4,14 

frustrated 45:14 

frustration 110:4 

fuel 304:7 

fulfilling 380:9 

fulfills 16:4 

full 34:12 55:15 70:10 

93:10 113:4 127:22 

134:14 171:10 188:11 

189:2 299:5 303:14 

318:19 329:22 394:6 

453:12,14 

fullest 206:16 

fully 29:16 76:19 93:10 

128:8 179:21 187:7 

202:8 207:14 234:14 

269:11 372:17 450:14 

fumigants 126:12 

364:15 

fumigated 63:16 155:6 

fumigation 63:11,13,22 

64:3 95:2 

fun 17:18 24:9 49:10 

139:12 

function 61:8 390:16 

433:3 

functional 259:3 

functionality 234:9 

259:17 266:22 439:12 

functions 260:13 

fundamentally 87:11 

122:17 

funded 52:14 340:15 

funding 91:20 92:1 

Funes 29:6 

fungi 353:14 

fungicide 207:21 

350:20 351:11 

fungicides 351:2 

funny 256:6,12 

further 78:15 103:19 

132:12 135:17 149:9 

162:5 178:11,15 

180:12 181:18 197:4 

202:10 227:9,12 

273:8 283:2 371:21 

375:18 383:3 402:14 

416:1 

Furthermore 234:3 

future 39:16 53:9 139:1 

270:20 282:22 310:14 

312:4 322:17 346:11 

358:6 359:13 366:2 

456:4 

FY 63:1 85:21 91:2 94:3 

94:4,18 95:18,19,20 

96:12 97:11 98:2 

G

Gabe 409:18 

gain 208:22 271:6 

403:12 

gaining 253:15 

gallery 169:12 

game 61:14 67:17 

309:9 

game-changer 395:12 

garden 245:5 435:8,8 

Gardeners 442:15 

gas 24:21 148:8 334:16 

337:3,8 

gate 252:8 

gathered 82:6 

Gays 13:8 

GE 369:11 

geared 312:22 

gears 89:17 321:8 

geeks 46:17 

geez 417:4 

gel 234:4 259:14 266:11 

gelatin 170:9 

gellan 166:9,11 233:18 

233:18 234:3 258:12 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
480 

258:21,21,22 259:2,5 

259:8,13,17 261:17 

262:1,2,3,6,12 264:16 

266:4,11,15 267:7,13 

268:3,8,21 421:13 

gelling 235:7 267:3 

gels 266:22 268:4 

general 69:13 75:21 

105:19 106:7 136:9 

159:13 181:7 197:3 

215:21 248:5 299:12 

308:13 328:17 348:12 

374:14 396:8 417:14 

448:13 

generally 26:14 332:5 

348:14 453:1 456:16 

generate 401:7 

generated 86:14 337:9 

338:22 349:7 

generating 80:19 

generation 27:7,10 

35:10 215:2 334:15 

337:2,6 369:11 

411:13 

generations 112:17 

generic 178:20 247:5 

304:12 306:9 310:3 

310:20 312:22 313:2 

343:14,16 346:20 

448:14 455:9 

genes 218:19 

genesis 455:18 

genetic 148:9,11 150:9 

175:20 191:4,9 202:2 

202:12 205:6 207:21 

234:16 369:22 370:2 

370:3 372:16,19 

374:7 375:3 377:6 

396:21 397:1 402:20 

405:9 407:3 

genetically 261:14 

gentamicin 214:4,7,14 

217:16 

gentleman 165:12 

169:11 

genuinely 121:20 

geographic 81:13 

126:11 

getting 27:9 39:4 84:21 

96:18 98:15 107:21 

108:2 123:13 131:19 

197:9 255:10 279:8 

326:11 328:9 413:3,4 

434:3 437:17 

give 5:20 10:16,19 18:2 

18:3,4 34:9 41:4 

66:12 68:17 82:16 

100:18 106:15 107:20 

131:3 135:22 139:16 

140:10,22 142:7 

183:6 193:10,10 

194:14 198:21 205:7 

268:14 291:21 296:5 

306:19 311:20 314:4 

334:4 376:1 377:13 

394:2 418:20 426:16 

435:3,5 

given 11:16 15:22 

110:5 116:6 124:14 

135:13 143:14 187:5 

189:11 204:20 215:1 

226:7 288:10 289:8 

297:4 330:3 333:10 

340:11 344:12 364:20 

456:14 

gives 60:16 189:22 

206:10 268:4 428:1 

giving 398:21 405:11 

glad 6:10 164:9 248:19 

433:19 

Glenn 212:8 220:3,3,10 

glitch 325:6 

global 70:3 411:7 

455:11 

gloppy 270:1 

glucose 421:20 

glues 188:13 

gluten 258:18 

gluten- 264:18 

gluten-free 233:7 

263:22 

glycerate 267:17 

GM 262:3 372:17,22 

373:3,8,18 

GMO 163:12 191:14 

193:18 370:19 371:1 

371:2 394:20 395:1,4 

397:14 400:5,7 

401:16 405:18,22 

406:4 

goal 40:21 48:6 63:1 

85:14 95:15 136:14 

162:10 179:18 225:5 

311:19 394:9,12 

403:12 441:15 

goals 61:22 68:12 70:8 

70:17 91:2 92:16 

93:13 94:3,4,18 95:11 

96:12 180:3 380:6 

396:12 

God 19:10 

gold 77:14 186:12 

238:6,9,18 239:14 

Goodness 14:5 

goods 235:9 263:21,22 

264:18,19 

gosh 18:12 

gotten 76:1 90:6 91:6 

100:10,12 103:9 

108:6 348:6 

governance 134:6 

governed 142:22 224:7 

governing 391:18 

government 62:8 70:11 

72:19 79:6 84:16 

102:17 115:18 133:12 

136:18 207:18 211:2 

418:14 

governmental 409:10 

governments 76:11 

138:13 

governor 15:3 23:15 

grace 88:1 182:22 

183:7 185:7 204:11 

204:16 

grade 282:15 

gradient 49:3,10 

graduate 41:8 53:2 

graduated 18:20,22 

grain 11:15 15:16 22:3 

389:17 390:3 

granola 234:22 

grant 34:15 36:8 40:9 

44:2 49:2 

grants 28:1 40:6 

granularity 112:1 

grape 434:22 

grapes 350:19 

graph 429:2 

graphics 61:4 

Grasses 353:4 

grassroots 228:7 

grateful 208:10 340:12 

368:1 405:1,3 410:2 

grave 408:7 420:5 

Gravity 416:15 

graze 428:17 

grazing 52:11 330:15 

greater 282:6 366:4 

greatest 126:9 363:9 

greatly 161:6 229:11 

340:14 

green 145:11 236:20 

237:1 238:4 240:10 

316:8,8,9 318:14 

319:19 320:10,19 

355:12 414:7 

greener 320:7 

greenhouse 305:17 

greens 9:2,4 

Greenwood 1:16 7:17 

7:22 124:18 126:20 

169:15 217:14 218:12 

218:21 219:1,14 

274:16 

Greetings 201:15 

grocers 410:14 413:1 

grocery 12:7 418:5 

Grossman 2:14 10:5 

32:20 33:21 34:2 55:3 

ground 68:9 84:18 

107:13 179:3 190:21 

273:3 308:2 330:21 

345:4 

group 8:5,19 14:10 25:8 

46:16 52:12 89:8 

103:7 118:17 164:19 

187:11 203:21 224:21 

251:22 267:17 273:1 

273:7,17 274:8 309:1 

335:1,10 338:22 

341:4 368:5 379:9 

387:1,5 388:2 400:17 

426:17 434:2 454:15 

455:1 

groups 274:3 316:13 

369:2 382:20 

grow 27:15,17 31:3 

39:8,9,12 47:10 

199:10 208:14 221:16 

221:19 222:12 223:3 

224:8 279:11 307:14 

364:1 367:15 404:22 

407:15,19 

grower 8:5 12:15 79:22 

207:9,12 222:10 

350:15 363:9 378:3 

449:11,15 451:4,5 

453:16 

growers 9:1 44:13 

45:17 98:15,17,21 

99:2,3 102:5 120:4,7 

120:19 147:3,9 

149:11 150:21 151:4 

151:14 152:1 156:1,7 

156:9 157:10 202:5 

206:21 207:2,20 

241:20 242:2,19 

315:18 317:6,20 

364:14 365:1 374:3,8 

380:8 382:16 394:11 

434:22 451:14,15 

growing 42:4 47:14 

48:16 50:4 87:21 

173:15 176:10 221:13 

279:12,14 305:18 

317:19 318:3,16,17 

358:2 363:22 365:22 

366:7 381:12 382:14 

384:9 396:3 399:13 

407:13 408:7 429:8 

440:8 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
481 

grown 9:4 31:6 50:14 

83:13 241:18,22 

300:15 355:13 

grows 279:10,15 

growth 29:20 233:13 

241:6,14 256:10 

260:4 271:7 272:5 

428:20 

guar 234:20 235:10,13 

264:16 430:21 

guarantee 181:10 

guess 20:8 25:22 

105:13 117:20 188:6 

189:3,11 284:9 

285:13 286:21 333:22 

354:14 358:12 361:2 

372:8 384:21 398:2 

guessed 354:5 

guest 6:14 14:21,22 

guests 10:1 14:20 

guidance 65:22 116:3 

116:18,20 117:1,4 

126:1,2 136:1 162:10 

167:13 168:16 170:16 

172:2,12 191:6 

192:15,21 196:10,14 

197:12 202:10 209:8 

210:3,14 229:21 

341:2 374:12 375:2,5 

394:6 403:18 404:9 

404:13 405:17 457:6 

457:9 

guidances 454:18 

guide 284:22 388:3 

guidelines 125:1 344:1 

387:4 447:2 

guides 32:3 

guilty 16:17 197:7 

210:19,20 253:13 

257:1 

Gulf 444:15 

gum 166:9,11 233:2,2,8 

233:12,16,18,18 

234:3,19,20,20,20,21 

235:4,5,10,20 236:4,4 

258:12,12,21,21 

259:2,5,8,13,17,21 

260:6,8,13,17,20 

261:1,2,5,9,17 262:7 

262:12 263:2,6,20 

264:4,6,15,16,19 

265:4 266:4,11,15 

267:13 268:3,8,21 

269:10,18 270:8 

421:13 422:2 430:21 

431:16 

gum's 235:13 

gums 165:20 166:15 

258:14,16 260:21 

262:2,2,3 266:7 267:7 

269:11,14 430:16,17 

430:19 431:5,6,8 

432:3 

gut 218:13,16,20 

Gwen 169:8,8 177:14 

Gwendolyn 169:6,6,12 

Gwendolyn's 202:8 

H

habitat 224:11 271:18 

haddock 444:13 

Hadlock 265:18 270:14 

270:15 271:15 273:20 

275:1,18 277:2 

278:20 279:22 446:22 

hairy 37:19 38:2,15,17 

half 6:10 23:21 75:7 

133:9,16 135:4 

221:17 

hall 66:8 68:16 

halls 97:14 

Hampshire 12:17 271:1 

hand 31:19,19 58:9,22 

223:16 240:9 241:13 

295:5 404:16 

handbook 375:19 

handful 117:21 

handing 10:22 

handle 91:18 

handled 107:4,5 

handler 84:21 

handler's 14:17 

handlers 71:11 147:9 

147:17 157:19 411:21 

handling 8:18 83:11,16 

117:18 183:22 232:18 

280:6 285:15 287:5 

334:12 440:18 456:18 

457:1 

hands 59:2 189:15 

Handsome 13:20 

hang 375:13 

Hanson 160:7 169:2,2 

happen 129:7 154:2 

207:17 288:10 327:5 

327:6,10,14 328:12 

385:10 398:3 

happened 28:18 30:18 

40:5 118:8 131:4 

204:16 257:2,16 

happening 27:18 84:18 

107:14 119:4 209:15 

275:17 300:19 371:5 

408:12 

happens 45:11 131:22 

136:19 176:22 324:17 

325:17 

happy 6:12,13,17 23:3 

55:15 156:3 166:1 

223:6 227:8 236:9 

294:1,2 374:10 

392:14 403:1,15 

haps 350:20 

harbor 447:11 

hard 129:17 152:7 

154:21 165:4 201:2 

264:13 283:20 293:14 

328:15 333:5 342:1 

348:4 388:19 394:1 

402:18 407:17 438:3 

438:4 

harder 138:14 

Harding 232:13 236:16 

236:19,19 240:1 

241:8,16 242:10,22 

harm 233:9 261:6 

harmful 233:11 261:8 

harmonized 95:8 

harmony 31:8 

harnessing 11:15 

Harriet 1:13 13:4 17:18 

52:15 109:20 149:20 

167:1 174:15 175:18 

179:9 180:16 193:14 

197:17 205:4 209:4 

231:10 236:1 247:16 

261:12 268:20 285:9 

306:4 318:8 323:3 

342:3 374:1 396:19 

398:8 405:5 417:2 

429:15 450:20 

harsh 371:16 

Harvard 300:16 

harvest 202:18,21 

272:18 274:17 275:20 

386:9 387:3 443:19 

446:14 

harvested 200:5 272:7 

274:18 275:11 316:8 

355:13 441:2 442:21 

444:15 445:4,6 

446:11 

harvesters 276:7 

447:16 

harvesting 45:11 46:6 

179:21 271:3,5 

275:12 368:6,9 387:2 

447:2,15,18 454:17 

455:19 

harvests 272:16 

hash 273:2 

Haslett-Marroquin

409:20 

hat 358:22 359:1 

375:14 

hat's 26:17 

hatch 214:6 

hatcheries 116:12 

214:5 298:9 

hatchery 216:8 

hate 19:9 

Havana 29:9,18 

hay 256:8 

he'll 307:22 

head 51:13 56:4 253:1 

324:5 416:14 423:16 

head- 50:11 

headed 21:4 71:4 

150:11 

headquarters 64:19 

health 12:10,11 16:6 

19:15 23:3 48:22 

164:2,5,6,8,14 178:5 

212:12,14,14,18 

213:2,2,4,6 216:6 

219:19,21 221:3 

240:11 300:10,16 

301:19 335:21 358:3 

368:12 380:17 408:17 

410:6,14 411:3,7,7 

414:13 419:20 

healthcare 323:15 

healthier 258:17 295:15 

healthy 54:9 136:5 

208:14 412:20 

hear 9:22 10:8 31:16 

34:7 35:2,9 102:11 

131:4 144:18 146:9 

209:20 223:2 248:19 

276:22 309:14 332:3 

333:4 410:18 

heard 45:14 55:17 78:7 

100:16 119:21 128:15 

128:19,20 130:9 

157:18 160:14,16 

168:5 182:21 222:11 

223:15 263:2,17 

298:19 309:22 326:8 

332:4 348:22 378:15 

417:11 420:19 423:9 

425:5 453:22 

hearing 32:13 55:11 

89:2 100:6 103:5 

120:14,18 128:16 

190:22 305:19 310:4 

315:17 360:2 379:10 

441:3 

hears 333:4 

heartened 98:22 

heat 264:7,9 265:10 

heat-stable 266:21 

heating 456:16 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
482 

heavy 32:12 208:5 

272:1 

hedge 428:17 

Hedin 407:11 408:6 

heightened 125:14 

Heike 272:3 

Heins 51:22 

Heins' 52:9 

held 26:22 28:5 272:17 

hell 17:7 

hello 11:3 13:4 25:6 

149:22 223:22 270:14 

280:4 407:6 450:22 

454:9 

Helms 251:18 258:7,9 

258:10 261:22 262:8 

262:15 

help 25:22 50:20 51:1 

52:7 54:11 64:16 68:8 

80:11 82:19 92:10 

115:2,12 164:3 

198:21 207:1 255:11 

278:13 284:20 326:18 

342:5 399:2 403:21 

412:11 417:6 

helped 28:3 92:1 278:9 

helpful 7:4 32:6 60:8,10 

66:6 67:1 83:22 91:1 

92:12 102:1 121:20 

130:16 132:10 154:16 

227:14 274:5,14 

306:1 314:4 333:1 

355:18 377:21 412:20 

helping 20:1 49:14 51:1 

92:2 405:7 408:1 

helps 59:21 60:3,18 

101:15 119:3 366:14 

392:3 393:8 404:22 

hemp 304:1,4 310:7 

399:6 

hen 254:1 

Hendrickson 307:22 

338:11 343:1,4,4 

347:2 348:15 349:11 

349:16,20 

herbicide 207:21 

herd 324:13,14,17,20 

325:5,9,21 

Heritage 272:13 

herring 444:13 

hey 129:13 132:7 439:6 

Hi 12:5 13:16 14:6 

146:19 258:9 287:21 

367:21 393:18 430:14 

high 39:21 47:4,5,8,10 

47:16,21 49:4 63:21 

155:19 195:18 263:16 

265:4,6 266:15,15 

267:7,15,19,22 269:1 

269:7 276:16 277:7 

278:2 289:2 290:16 

290:22 291:7 293:14 

332:5 353:4 366:18 

367:7 

higher 39:3 234:9 

289:17,18 380:16 

highest 191:13 206:16 

highlight 44:15 49:12 

52:22 73:17 192:6 

338:19 340:20 363:8 

highlighted 77:21 

254:17 404:19 

highlighting 43:21 63:6 

highly 306:14 420:14 

hindered 50:9 

hinted 276:12 

hire 91:6,7 92:2,21 

93:15,16 97:6 255:20 

345:22 

hired 20:19,19 56:5 

168:7 389:18 390:9 

hires 391:8,11 

historic 236:10 

historical 201:19 

historically 204:10 

322:3 

history 11:16 18:1,3 

25:10 289:21 444:9 

hit 95:17 423:15 

hits 64:4,9 

hoc 188:2 

hold 16:22 123:18 

145:21 264:12 293:5 

356:5 377:11 

holding 253:22 

hole 311:16 

home 12:4 21:15 23:6 

110:9 245:4 435:8,8 

449:22 450:3 453:1 

hone 53:19 59:17 

310:22 313:18 

honest 57:2 119:5 

honestly 116:22 118:8 

332:2 

honesty 136:6 

honor 140:7 

honored 10:1 14:22 

hook 253:14 

hope 11:6 31:2 69:1 

95:18 193:16 203:8 

217:2 237:18 282:7 

366:14 403:11 

hopefully 17:14 128:15 

237:12 458:20 

hoping 50:20 257:21 

270:3 

horticultural 32:21 

147:12 148:1 351:14 

Horticulture 44:18 

hospital 22:5 

hospitality 11:8 

host 45:3 97:20 

hostage 26:22 

hosted 97:18 

hosting 97:10 314:21 

459:12 

hotbed 41:6 51:10 

hotel 1:9 21:16 333:18 

hour 8:11 22:4 243:2 

hours 51:16 57:9 130:1 

271:9 

house 254:1 

houses 34:22 

Houston 22:11 

how's 252:8 

Hub 14:9 

Hubbard 398:14 402:2 

402:4,5 405:13 

406:10 

hug 140:22 

huge 22:13 35:18 174:5 

350:12 367:13 

human 153:6 164:1,5,6 

164:8,14 178:5 

212:17 214:7 218:13 

218:15,20 221:3 

286:11 335:21 355:12 

411:5,7 436:18 441:6 

443:4 444:4,7 458:7 

458:10 

humble 57:3 

hundred 28:8 

hundreds 413:2 455:8 

hung 347:16 

hunting 428:1 

Hurricane 221:6 

hurricanes 208:4 

hydrated 322:15,19 

hydration 265:13 

hydrocolloids 235:8 

266:3,6 

hydroponic 119:20 

hydroponics 230:6 

252:15 

hydropower 11:15 

hypothetical 391:20 

hypothetically 327:6,10 

I

Ibach 55:18 

ice 235:5 429:16 

idea 18:11 73:10 155:11 

157:7 187:21 192:1 

193:6 274:19 400:21 

403:11 435:16 

ideas 147:2 272:21 

273:7 383:7 384:13 

392:9 401:7 402:21 

identical 49:6 179:8 

384:10 

identified 167:22 

296:14 

identifies 455:18 

identify 64:16 79:19 

108:17 152:1 180:4 

190:8 449:5 

identifying 290:2 

identity 109:8 259:4 

336:7,19 

IFAC 232:18,22 233:13 

233:17 234:6,13,17 

ignore 408:10,11 

illegal 412:13 

illegally 275:11,17 

imagery 428:22 

imagine 47:4 121:5 

407:17 

immediate 75:1 

immediately 78:16 

131:10 230:6 322:10 

immigrant 379:18 

380:21 381:3 382:16 

impact 30:21 38:19 

158:12 162:20 168:7 

170:21 178:5 183:13 

186:7 286:11 307:3,4 

307:8 316:1 317:19 

323:5 345:12 380:20 

382:13 387:2 430:2 

446:6 

impacted 47:17 60:16 

86:1 157:10 302:14 

impacts 60:18 101:17 

119:18 158:13 162:8 

162:9 271:5 273:3 

305:5 345:16 349:10 

384:17 456:4 

impart 235:3 

impetus 443:6 

implement 104:15 

105:3 183:7 230:3 

245:16 394:11 453:9 

implementation 183:1 

183:18 338:15 377:4 

implemented 104:10 

134:15 

implementing 70:14 

180:1 292:20 381:12 

implications 355:5 

implied 355:2 

import 66:18 69:8 70:1 

70:2 71:14 73:4,4 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
483 

78:13 81:2 84:9 93:18 

94:21 114:7 125:12 

127:2 137:19 230:20 

230:22 389:15 449:12 

importance 50:4 80:11 

100:17 125:7,19 

130:17 138:10 226:7 

271:7 315:3 384:7,9 

403:2 

important 15:10 38:22 

43:8 53:4 54:7 61:18 

65:2 77:9 84:14 85:3 

89:20 97:22 101:16 

102:19,20,20,21 

103:12 104:2 117:8 

118:12 125:4 134:13 

147:22 148:12 160:1 

172:20 187:14 201:2 

213:2 214:7 219:22 

220:19 234:1 239:1,5 

244:11 252:20 261:3 

263:4,9,12 264:10 

265:2,3,14 290:4,11 

291:6 309:2,3 315:21 

327:11 351:4 360:1 

376:10 384:5,15 

385:16 399:1,18 

403:17 413:6 418:14 

419:22 423:19 449:21 

importantly 171:9 

imported 77:20,22 

importer 78:15,16 83:1 

imports 75:14 77:16 

78:7 79:16,20 90:11 

114:10 118:13,17 

125:13 252:16 

impressed 25:14 

impression 213:1 454:3 

improprieties 253:14 

improve 46:20 48:15 

68:7 114:20 162:14 

192:18 202:6 376:6,9 

376:10 399:3 

improved 76:21 340:10 

improvement 90:16 

91:16 171:17 172:5 

193:2 292:12 375:10 

376:3 394:10 396:10 

419:6 429:5 

improvements 340:4,7 

340:12 

improves 48:20 386:10 

improving 52:12 

238:20 292:2 340:1 

376:18 408:17 

impugn 146:8 

in-depth 96:6 181:11 

in-field 380:3 

in-person 144:1 

In-season 46:5 

inappropriate 413:13 

incentive 122:13 174:5 

323:13 403:3 

incentivize 419:18 

inches 8:9,11 

incidences 63:22 111:4 

incidental 456:12 

incidents 211:13 

include 45:4 68:6 93:18 

214:1,3 238:19 281:1 

290:13 303:17 321:9 

369:6 458:15 

included 70:7 83:11 

105:17 151:3 161:22 

192:2 200:17 226:5 

285:18 287:9 303:2 

310:20 321:10 342:14 

401:19 447:3 

includes 83:5 196:2,4 

303:19 304:1 392:12 

401:15 

including 88:10 138:19 

186:13 233:7,22 

276:5 286:5 302:16 

303:20 313:4 329:14 

343:8 344:18 345:16 

350:19 399:6,7 413:1 

420:7,8 425:14 

448:17 

inclusive 178:20 

inconsistently 375:17 

incorporated 295:21 

353:12 356:18 

incorporating 409:22 

increase 48:17 81:15 

114:20 140:13 262:12 

373:9,17 

increased 92:1 96:10 

363:13 373:7 380:22 

404:4 

increases 48:22 213:7 

288:15 392:6 404:3 

increasing 81:13 89:5 

136:13 368:13 372:18 

increasingly 404:16 

incredible 24:22 25:8 

25:11 43:2 

incredibly 31:18 32:6 

332:4 402:20 413:6 

incrementally 238:19 

incubator 379:14 

independent 295:12 

350:16 379:15 

Indian 89:6 

indicate 174:15 288:18 

290:9 

indicated 120:14 

indicates 289:10 

indication 120:19 

indications 202:14 

indicators 92:15 

individual 146:5,8 

184:2 218:14 276:19 

380:6 389:18,22 

391:8 424:20,21 

451:1,2,8 457:5 

individuals 146:6 219:5 

274:18 390:19 

induce 369:18 

induced 369:19 

induction 147:21 148:4 

industrial 286:11 447:8 

industries 11:14 391:17 

391:19 

industry 16:2 31:15 

162:22 196:11 216:20 

216:22 233:20 234:13 

240:18,18 248:21 

254:19 259:6 262:13 

265:3 269:19 272:8 

274:1 275:15 278:22 

281:11 282:11 288:8 

332:17 365:8 372:12 

406:20 407:19 430:7 

441:5 

inert 303:6 

inerts 163:15 203:10,21 

204:7,17,20 421:9 

infection 165:11 

infections 214:12 

infested 363:10 

infesting 386:22 

infestive 386:21 

inflation 123:8,9 

inflexible 340:9 

influence 8:7 

info 283:8 

inform 127:7 136:18 

168:14 281:10 370:17 

information 61:14 

78:14,16,20 82:8 83:3 

84:12 85:3 110:7 

116:5 120:20 128:7 

132:7 147:12,19 

151:19 152:4,5 153:9 

156:20 157:10 158:7 

161:7 167:5 176:3,8 

188:13 191:7,22 

192:10 198:2,10 

200:16 211:12 236:11 

237:11 244:16 245:8 

246:4 248:11 250:4,7 

269:4 294:12 305:20 

316:22 341:21 343:20 

348:1,2 352:3,17 

360:19 370:16 374:8 

390:4 395:4 397:10 

424:5 434:1 437:18 

informed 91:2 295:17 

informs 284:5 

infrastructure 7:3 

162:8,9 167:3,8 168:1 

380:4 409:15 

infuriating 410:20,20 

ingenious 161:8 

ingredient 227:8 261:3 

266:12 269:20 446:1 

457:16 458:3 

ingredients 14:16 

226:18 232:18 234:15 

250:2 258:15 266:22 

267:9 268:11,17 

278:13 313:7,9 337:5 

344:19 347:4,5 

458:11,11 

inheriting 252:2 

inhibited 204:3 

initial 67:10 71:7 93:12 

initially 197:5 198:11 

199:12 

initials 25:21 274:10 

initiate 96:11 

initiated 70:2 118:3,11 

initiative 257:19 258:1 

initiatives 97:18 115:9 

injected 214:8 

injecting 214:4 

inks 181:16 188:14 

395:15 

inner 277:10 

innocent 21:1 210:21 

211:3 

innovation 431:21 

innovative 343:7 

input 66:6 87:3 98:1 

225:10,13 245:11,20 

246:3,12 314:3 

335:20 368:7 377:20 

383:5 386:13,18 

387:22 401:4 403:4 

432:20 438:16 440:8 

446:2,15,17 448:18 

449:20 455:13 457:7 

input-based 386:17 

inputs 31:7 48:21 

148:22,22 149:5 

186:14 225:2 245:2 

289:13 335:9 337:17 

381:15 387:18 

inquiries 86:4 

insect 5:14 351:7 

insecticide 350:21 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
484 

insecticides 351:2 

insects 157:1 

inside 320:14 355:9 

Insider 67:4 69:1 

insight 173:4 

insights 15:22 

inspected 197:5 257:13 

inspection 290:13 

341:14 449:8 

inspections 74:4,6 

290:20 292:15 

inspector 66:19,21 

69:12 75:21 93:3 

124:22 153:8 168:6 

195:17,18 248:3 

290:14 292:3 340:18 

340:21 341:3,8 342:7 

396:11 

inspectors 6:22 67:16 

67:18 68:2 94:9 

195:20 196:1 341:15 

342:10 396:15 428:9 

inspired 409:17 

instance 217:16 284:13 

415:11 428:6 

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Institute 5:5 8:3 12:3 

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256:17 389:14 410:4 

454:11 

instituting 255:6 

institution 44:2 

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institutionalizing 95:1 

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387:17 

instructions 126:18 

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147:22 

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376:19 

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41:18 

interest 14:10 27:6 

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91:13 142:19,20,22 

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390:11,22 391:1,3 

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437:17 

interesting 122:15,18 

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interestingly 37:18 

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interim 133:22 134:3,12 

244:13 245:17 374:19 

387:17 

intermediate-sized

120:4 

internal 59:16 92:17 

192:17 250:15,19 

internally 133:14 

361:15 

international 5:3 64:13 

65:1 70:22 92:6 

174:17 175:9 199:21 

232:16 317:9 

internationally 92:4 

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interpret 375:17 378:6 

interpretation 184:5,9 

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378:9,14,18 

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184:18 359:6 

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intertwined 434:6 

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introduce 7:6 8:19 

11:19,19 14:21 54:3 

134:5 

introducing 4:14 

introduction 11:3 34:3 

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invalid 230:7 

invasive 44:20,22 

inventory 345:20 

invest 86:3 

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85:21 

investigate 75:9 138:5 

389:15 

investigated 5:13 

investigating 74:3 

investigation 74:22 

76:11,15 81:3 96:6 

125:12 197:4 203:1 

investigations 64:8 

68:6 74:5,12 75:18 

76:4,22 82:12,17 95:2 

96:1 108:3 109:2 

127:7 

investigative 75:5 

76:18 77:8 93:5 

107:22 

investing 79:7 

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invite 29:12 

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invoices 83:7 

involve 76:12 88:10 

96:2 109:6 

involved 27:12 76:14 

102:5 107:17 190:5 

205:16 208:8 237:7 

274:4 346:16,17 

involves 327:1 

involving 384:4 

IOIA 341:6,6 

Iowa 228:5 

Irish 19:4 

irradiation 369:18 

Isagro 363:2 

islands 272:11 

ISO 90:15 91:15 245:11 

245:22 

isothiocynates 366:20 

366:22 

issue 8:8,12 46:14 

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120:1,16 121:8,13,17 

123:17,22 148:16 

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187:13 188:4 189:16 

196:13 207:9 209:11 

209:17 215:11 218:2 

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225:9 229:21 240:11 

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274:21 275:2 282:22 

285:11 298:7 299:4 

302:9 309:13 316:21 

320:3 322:1 325:2 

332:5 343:9 347:14 

351:6 357:14 358:14 

358:16 361:3,5,14,14 

361:16,17,18 369:9 

376:5 378:20 385:16 

392:19 400:12 402:20 

421:4,13 423:9 433:7 

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456:19 

issued 184:10,13 

196:20 

issues 12:13 15:10 

23:12 47:18 93:20 

113:12 119:20 128:5 

146:13 148:21 156:6 

163:7,9 189:3,11 

206:4 290:10 358:13 

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382:22 383:3 400:16 

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Italy 72:20 

item 61:2 105:2 111:22 

118:3,17 119:7 

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167:19 194:10 209:8 

289:7,10 421:4 

items 65:6 69:12 104:1 

105:21,22 118:20 

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375:18 394:3 395:16 

Ivy 355:21 362:20 363:1 

363:2 365:21 367:1 

367:17 

J

Jack 407:11 408:6 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
485 

Jackie 295:8 301:22 

302:1,4 314:6 343:15 

Jacksonville 222:1 

JAMA 301:4 

James 7:17 

January 38:10 94:11 

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jar 205:13 

Jay 410:11 418:20,20 

419:1 422:6 

Jaydee 160:6 169:2,2 

Jen 334:9 

Jennie 11:2 

Jennifer 2:7 4:7 320:22 

334:5,6 

Jenny 55:22 57:4 98:8 

98:11 103:14 114:18 

117:17 119:9 122:1 

124:18 127:14 137:4 

139:6,9 160:17 185:5 

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306:5 308:9 326:6,7 

331:14 334:5 338:10 

338:11,13 412:11 

jeopardize 168:3 

jeopardy 421:11 

Jesse 1:15 13:22 25:10 

159:7 

Jessica 270:12 280:1,2 

280:4 283:6 287:14 

jewels 28:3 

Jim 7:20 32:1 

Jimenez 2:3 6:15 

Jo 177:10,15,16 185:16 

310:18 

Joan 122:18 

job 16:22 39:18 44:7 

96:17 240:13 246:12 

256:15 290:2 309:7 

311:9 358:19 389:14 

409:20 417:7 

jobs 103:4 318:1 350:2 

Joe 140:10 

Johanna 169:6 177:19 

John 307:21 338:11 

343:1,2,4 348:21 

join 69:2 

jointly 124:15 

joke 256:6 

joking 198:1 

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judge 327:21 328:2,21 

330:2 393:16 398:14 

398:17,17 401:14,20 

401:22 

judgment 304:3 

Julie 2:14 10:5 32:20 

33:2,15 

Julie's 33:10 

July 24:7 65:15 66:8 

97:18 140:4 

jump 31:12 291:22 

June 5:1 24:7 

jurisdiction 123:20 

276:20 

Jurlina 262:19 265:18 

265:21,22 269:2,16 

270:10 

justice 37:4 75:22 

252:7 

justification 425:13 

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justify 202:5 

juvenile 271:18 

K

Kansas 413:17 

Kastel 243:5,16 251:17 

251:20,21 255:2 

258:4 

Kate 223:20 227:18,20 

228:3 

Katherine 19:4 

Kay 15:18 19:2 

keenly 44:3 

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keeping 79:12 81:10 

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keeps 211:21 235:14 

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Kelco's 258:13 

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Kelly 362:21 372:4,4,5 

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434:10,11,15,18 

435:2,12 443:8,13 

444:2,3 445:5 

Kennedy 19:4 

Kentucky 49:5 

kept 20:5 352:3 415:2 

Kern 212:8 220:3,5,9,10 

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kernel 240:19 

Kerrigan 402:2 407:6,7 

key 62:6 80:6 90:13 

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kids 18:6 19:13 20:16 

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405:6,15 407:4 

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kinds 109:18 238:12 

326:17 331:3 

Kingdom 448:20 

Kiowa 12:2 

Klobuchar 15:13 

knew 198:11 

knocking 18:8 

knowing 135:1 344:21 

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knowledge 107:13 

114:20 116:16 153:12 

294:7,9 295:17 

390:18 396:15,17 

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413:18 

knowledgeable 53:15 

known 51:13,19 84:10 

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287:4 329:1 344:11 

395:7 

knows 56:16,17 

Kraft 9:10 

Kroger's 418:3 

Kyla 367:19 372:5 

374:16,16,19 

L

lab 43:16,16 46:18 

248:3 

label 83:6 205:13 

212:19 213:17,18 

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296:17 390:2 392:6 

458:12,16 

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labels 213:12 295:16 

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435:15 

labor 129:22 240:7 

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399:3 

Laboratory 13:6 

lack 50:10 121:16 187:5 

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lactate 184:1 185:18,19 

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lading 83:7 

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lame 23:22 

land 30:18,19,19 34:15 

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144:12 

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Laughter 16:19 17:1 

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169:18 220:8 295:6 

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429:20 

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132:9 

launching 93:17 95:12 

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laurels 56:5 

law 201:7 254:1 257:1 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
486 

277:3 327:21 328:2 

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373:10 376:5 

leader 253:20 

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leadership 55:14,16 

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leading 70:17 213:5 

leads 375:17 

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leafy 9:2,4 

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150:10 214:14,16 

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137:13 

learning 6:21 42:22 

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68:18 93:17 94:7 

97:21 115:13 126:15 

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409:9 

lease 381:18 451:4 

leased 19:19 110:11 

112:20,21 

leases 385:6 

leave 182:17 267:18 

450:16 451:19 

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355:4,7 

leaving 22:21 366:10 

406:22 

lecithin 234:7,8,10,12 

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273:18 

left 23:21 39:13 190:3 

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415:14 

leftovers 441:12 

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legal 238:18 298:21 

299:6,20 421:11 

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legislative 61:22 

legislature 20:18 21:2 

32:10 

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lengthy 16:15 142:18 

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lesson 390:5 

let's 5:20 10:19 48:4,6 

62:6 69:3 81:2 82:4 

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208:17,20 271:10 

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391:5 

letter 100:17 103:2,9,9 

letters 9:16 63:11 100:9 

100:10,17 101:3 

102:19 331:21 

letting 102:3 130:15 

287:12 

level 50:10 59:17 60:4,7 

60:11 62:21 73:16 

80:14 101:15 102:9 

110:3 111:14,15,22 

112:1 122:12 125:10 

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293:14 300:4 308:14 

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397:18 405:21 406:8 

406:14 

levels 111:11 191:20 

196:5 364:1 370:17 

377:10 406:13 

Lewis 2:4 4:16 89:15 

284:16 350:5 355:21 

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297:14 411:16 

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lights 22:15 

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Lima 1:15 12:5,5 

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limbo 204:2 

lime 322:15,19 

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275:20,22 312:12,15 

limitation 433:8 

limitations 226:10 

limited 143:21 160:13 

179:5 182:8 188:19 

196:1 345:16 352:17 

367:10 390:4 434:1 

limiting 310:11 

limits 124:9 126:5 

276:2 

Lincoln 384:22 

line 9:9 48:21 95:14 

106:10 109:14 134:14 

173:5 251:10 348:13 

lines 20:10 157:17 

269:22 293:19 

lining 173:20 

link 37:4 

linked 267:12 400:18 

liquid 357:8,16 433:7 

433:14 436:7 440:22 

Lisa 1:15 12:5 40:18 

117:16 139:14,15 

173:3 430:13 

Lisa's 123:15 

list 2:5 4:18 5:19 60:7 

65:6,9,12 82:14 85:11 

85:13 87:7,12 88:3 

89:1,1 90:18 96:15,18 

99:16 100:5 113:14 

138:1 144:4 148:8 

151:18 158:4 163:13 

166:17 170:19 171:11 

175:10 181:8 184:4,6 

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194:18 196:17 200:18 

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246:6 247:13 248:11 

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268:18,22 278:13 

282:5 284:4,8 285:22 

291:17 302:22 306:20 

310:10 332:7 339:3 

350:14 358:17 359:14 

360:8,16 365:11 

366:6 369:12 371:4 

395:18 400:9 401:13 

419:12 439:21 440:2 

455:22 457:18 

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147:15 162:7 180:19 

189:5 193:20 198:11 

199:16 209:8 216:5 

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278:21 279:3 306:10 

335:5 361:22 388:7 

421:10 440:7 455:8 

455:16 456:11 458:12 

listening 57:10 98:4 

listing 78:5 79:21 86:21 

88:5 112:7 151:7 

179:5 180:21 181:10 

182:2,7 183:19 

193:19 200:1 230:7,8 

258:21 260:1 278:12 

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313:3 336:4,13 337:7 

357:4 420:17 422:8 

listings 113:20 181:8 

lists 61:3 189:20 304:1 

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Listserv 339:1 

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340:9 

literature 354:22 

litigation 76:4 

little 4:22 13:9 15:16 

17:18 18:2,21 21:18 

24:3,12 25:2 35:3 

48:14 50:5 65:5 66:7 

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106:14 108:16 113:5 

117:18 120:15 131:15 

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216:17 219:10 241:17 

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337:3,22 347:16 

353:6 358:6 378:8 

408:22 416:1,14 

423:4 426:18 431:14 

431:16 436:22 440:5 

440:19 446:22 

littoral 153:16 

live 13:1,6,8 17:8 

209:10 

Lived 19:6 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
487 

livelihood 77:4 211:1 

257:18 

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332:20,20 334:12 

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399:17 400:7 427:13 

440:17 444:2 446:12 

455:15 458:7,10 

460:1,4 

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LLC 393:20 

LMS 67:12 

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locally 408:3 

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location 11:10,12 84:6 

113:7 459:6 

locations 50:17 416:4 

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236:3 264:16 

Lodi 12:4 

logic 186:10 311:17 

430:11 

logical 344:6 388:7 

logically 313:10 

logo 412:12 414:1,7 

418:7,8,10 

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long 34:10 37:17 40:20 

109:17 116:13 135:19 

171:22 264:6 267:11 

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432:2,7 438:11,16 

453:3 

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382:1 

long-time 23:10 

longer 19:20 96:5 109:5 

128:4 177:4 197:14 

215:7 264:10 319:10 

381:19 384:1 385:10 

408:9 

Lonza 173:10 

look 8:13 10:15 54:20 

57:2 62:6 70:8,22 

72:6 81:2 82:3,4,11 

83:18 89:2 98:2 104:7 

104:8 106:17,20,22 

107:7,9 108:7 116:14 

123:21 129:14 131:17 

132:11 133:11 137:8 

138:17 146:4 150:2 

152:4 158:8,21 

159:22 167:19 175:5 

175:14 177:4 180:12 

196:4 197:22 201:6 

253:18 255:18,22 

266:19 267:22 274:22 

280:16 284:17,21 

285:3,19 286:2 287:7 

289:14 292:19 305:21 

309:21 326:22 327:20 

330:22 331:5 336:20 

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195:6 200:15 236:2 

293:20 294:21 300:18 

looking 9:14 24:14 

32:13 38:2 39:5 49:4 

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110:3 122:12,16 

129:22 138:20 167:10 

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181:22 182:5 190:4 

199:12 210:2 216:7 

261:20 271:11,12 

283:22 286:7 306:8 

327:1,2,2 328:8 

330:12 331:8 333:22 

349:13,15 354:17,22 

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424:15 427:18 450:21 

452:14,22 

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458:5 459:11 

loophole 254:9 

lop 324:12 

lose 240:20 241:19,21 

241:21 328:12 397:4 

losing 45:17 252:21 

257:18 345:19 

loss 98:17 211:14 

222:18 288:8,14 

317:22 318:3 

lost 28:22 30:19 207:14 

221:21 

lot 9:9 24:15 25:2 39:12 

40:4 43:7,19 47:6 

59:20 60:5,16 61:11 

64:13 65:19 66:4,5,20 

69:15 70:19 72:8,9 

80:9 83:6 86:3,14 

88:14 90:6,19 93:13 

100:10,13 102:22 

103:22 110:11 111:11 

112:16 113:21 114:1 

115:8,15 120:18 

122:2,19 130:2,9 

131:1,17 133:10 

141:6 156:1 159:3 

182:1,2 183:2 188:10 

188:12 189:22 191:10 

191:11 201:22 203:7 

210:6 216:21 219:20 

237:22 238:2 239:9 

241:4 263:10 265:1 

270:2 272:18,21,22 

289:13 293:17 305:20 

319:9,10 326:11 

329:13 331:6 332:3 

360:2,17 385:9 

415:21 426:16 431:14 

433:15 435:10 437:17 

lot's 118:8 

lots 73:6 155:9,9 190:1 

329:16 331:22 

Lotze 272:3 

loud 333:20 

loudly 128:20 

love 41:13 66:16 

low 20:9 46:16 114:11 

161:8 263:17 266:15 

266:16 267:20 268:7 

277:6,8 289:2 291:1 

367:6,9 433:10 

low-fat 264:2 

low-risk 399:8 

lower 64:5 145:10 

367:2 

lowering 383:13 

Luckily 154:20 

lucky 35:3 43:13 

lucrative 222:18 253:16 

luggage 140:14 141:4 

lump 266:7 

lunch 23:6 236:17 

243:3 

Luther 16:16 

Lutheran 19:5 

lymphoma 301:6 

Lynn 142:1,7 146:16,17 

146:19 149:20,22 

160:5 

M

M.S 56:11 

machine 453:14,15 

machinery 451:3,4 

machines 242:4 452:15 

452:17 

macroalgae 152:21 

226:18 337:19 457:19 

macrophomina 363:13 

363:19 

macuna 318:13 

magazine 296:2 297:16 

300:16,17 

magazine's 296:7 

magic 101:10 

magnesium 235:19 

mail 140:9,11 

main 254:21 283:14 

452:19 

Maine 164:20 270:15 

271:16 272:8,11,13 

275:5 276:4 277:3,4 

278:3 442:13,15 

443:10 444:11,15,19 

446:11 

maintain 31:8 91:8 

113:7 387:13 388:3 

maintained 21:15 

maintaining 84:15 

94:15 139:2 162:13 

167:6 229:13 

maintains 386:10 

major 20:4 41:16,17,19 

42:3,9 253:13 381:2 

majority 33:19 243:12 

425:11 434:14,18 

majors 36:21 42:12 

making 4:13 26:18 41:6 

53:8,14 85:12 129:9 

138:18 145:5 172:18 

173:11 196:3 263:5 

276:6 449:16 

man 18:7 20:19 57:21 

410:5 

manage 389:19 391:2,5 

391:10,13 

managed 133:8 391:2 

management 6:21 

33:10,20 43:6 46:1,19 

56:12,17 60:13 65:4 

67:12 68:18 75:15 

89:20 93:17 94:7 

97:21 104:6 105:11 

115:14 126:16 221:9 

230:9 255:22 256:1 

297:11 298:5 299:12 

299:17 321:12 325:22 

420:9 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
488 

manager 2:5 4:18 5:2 

5:20 37:21 38:19 91:5 

91:8 92:19 93:15 97:7 

190:18 258:10 262:22 

266:1 302:5 334:10 

374:11 385:22 432:18 

managers 97:6 

managing 5:13 110:8 

111:13 149:11 

mandate 373:6,7,19 

439:21 

mandated 446:2 

Mandating 386:8 

mandatory 290:20 

manner 179:2 192:6 

229:19 303:19 

manual 143:2 286:8 

manuals 101:6 

manufacture 313:12,13 

313:22 451:3 

manufactured 178:15 

284:6 456:6,8,10 

manufacturer 83:1 

235:16 262:5,5 

269:17 270:3 350:7 

363:3 421:19 439:5 

453:10,10 

manufacturers 179:16 

205:1 232:17 313:20 

335:11 399:22 401:12 

455:13 

manufactures 448:9 

manufacturing 149:8 

188:15 195:15 250:2 

283:15 303:14 336:12 

339:17 345:12 350:1 

421:18 456:15 

manure 255:22 318:14 

map 60:18 422:20 

mapping 59:16 61:8 

March 38:10 

Margaret 341:6 

margins 121:2 

marine 152:15,20 

177:22 179:17,19,20 

180:2,10 186:20 

187:6 224:3,10,14,16 

225:5 226:14,18 

270:22 273:4,11,22 

274:9 276:15 334:14 

334:17 335:3 337:16 

337:19 338:7 368:3 

387:3,5 389:5 442:16 

443:18 444:6,22 

454:12,21 455:15,20 

457:13,19 

Marisol 459:10 

maritime 444:11 

mark 9:16 15:4 23:15 

95:17 243:5,16 

251:17,18,21 254:11 

254:12,15 258:2,3 

276:17 

market 12:7 62:15 69:4 

79:4 94:19 95:10 

117:12 126:10,11 

222:18 240:14 252:11 

252:12 255:14 271:22 

275:5 318:4 319:4 

320:6 346:1 357:6 

380:7 387:14 407:15 

409:14,14 419:18 

435:14 436:11,17,18 

441:12 444:4,17 

marketed 260:11 

marketing 2:3 4:10 

39:14 50:11 117:15 

127:9 

marketplace 49:17 50:7 

51:3 116:7 184:21 

206:11,20 239:4,8 

241:18 319:17 

markets 51:1 174:18 

316:10,12 380:9,16 

404:1 437:4 

marriage 19:9 

married 19:3,8 

Marta 29:6 

Mary 44:16 45:21 

Maryland 5:17 

mason 205:13 

Massachusetts 13:2,3 

277:4,4 

massaging 359:9 

master 133:5 

Master's 5:16 

match 61:10 291:8 

material 86:4,9,17 

88:18 134:6 149:2,12 

151:3,18 155:12 

156:10 159:4,14 

170:1 230:7 237:12 

244:13 245:7,14,17 

245:20 249:1 261:19 

280:6,14,15 281:11 

281:21,22 282:2,12 

282:13,16,19,19 

285:20 286:1,12,14 

287:3,8 306:9 308:12 

308:14 309:2,7,10 

310:7 343:15 365:12 

395:17 396:3,5 407:1 

433:2 435:20 439:16 

439:17 440:8 448:14 

448:17 449:18,20,21 

450:2 452:2 453:5 

material's 284:3 

materials 2:6 86:6 

88:21 115:11 130:22 

132:5 147:7,8 149:4 

151:1,17 152:8,15 

155:3 161:2 168:2 

177:22 179:1,8,13,18 

184:6,10,16,20 185:1 

186:3,13 189:20 

191:3 224:2,4,10,15 

224:16 225:5 226:14 

227:2 237:21 243:20 

246:11 280:21 281:14 

282:5 285:21 312:10 

319:16 321:7 334:9 

334:14,17 337:16 

339:16 344:10,21 

350:14 356:21 359:10 

368:3 371:16 375:2 

386:12,20 389:5 

398:19 402:13,19 

414:15 419:12,13 

421:10 422:4 442:17 

446:13 449:5 452:18 

453:1,3 454:10,12,21 

455:15,16,20,21 

456:1,3 457:2,9,13,18 

math 66:15 

Mathews 2:5 4:18 5:14 

314:11 320:21 321:2 

322:12,21 323:8 

324:19 325:20 

matrix 143:3 354:4 

matter 20:7 100:18 

142:3 159:1 167:12 

243:7 256:16 375:16 

423:8 460:6 

matters 49:1 

MATTHEWS 321:2 

Mattson 352:7 

mauve 413:19 418:1 

max 47:13 

maximize 27:17 

maximizing 134:18 

maximum 269:14 

Mayland 352:10,18 

meal 336:5,7,15,18,21 

456:6,8,10,14,15,21 

456:21 

mean 52:19 135:1 

137:10,12 155:16,22 

157:6 163:10,19 

164:4 189:7 193:22 

203:19 217:21 219:3 

247:3 269:12 276:16 

277:6 294:8 306:6,7 

309:1 310:2,3,19 

312:1,2,12 331:22 

347:12 354:9 361:3,7 

365:7,16,18 378:6,15 

385:11 397:5 398:4 

415:20 423:13,15 

424:15 425:11 434:17 

436:17,18 437:10,19 

452:5 

meaning 265:5,6 

meaningful 178:6 

296:12 413:8 

meaningless 410:17,19 

411:10 

means 109:13 118:20 

129:9 144:11 170:18 

180:2 213:13 277:5 

297:11,16,19 298:13 

303:12 395:16 400:21 

meant 39:16 176:7 

measurable 404:4 

measure 373:3 

measures 394:11 

measuring 387:2 

meat 52:13 212:21 

217:18 218:1,17 

296:8 297:18 326:1 

456:21 

mechanical 456:14 

mechanism 339:4 

341:13 352:13 353:15 

354:11 

mechanisms 91:12 

341:18 351:3,4 352:2 

354:4 

media 144:19,21 

medical 12:22 161:18 

162:3 

medication 165:4 

medications 368:15 

medium 242:3 289:2 

290:18 

mediums 422:1 

meet 62:4 92:3 156:11 

173:14 213:18 376:19 

388:15 455:12 

meeting 1:5 4:6,11,17 

10:18,19 11:6,12,17 

21:18 26:6 34:6 54:19 

54:20 55:5,17 57:11 

58:1,9 69:11,21 74:15 

86:15 88:6 89:4,19 

100:7,14 120:5,11 

127:18 128:13 130:22 

131:8,10,11,12,13,20 

131:21 132:6 143:3 

143:10 144:1 147:11 

154:4 160:16 169:17 

185:11,14 191:8 

193:4 221:22 222:11 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
489 

227:6 243:22 244:5 

245:7 285:6 290:7 

302:8 305:21 334:19 

343:18 346:11 348:12 

372:13 403:14 420:13 

420:22 422:4 424:1 

426:5 429:22 433:6 

439:4 

meetings 7:10 31:21 

55:12 71:2 81:20 

97:11,12 105:7,13 

139:13 144:20 201:21 

210:1 243:21 244:18 

253:7 306:2 373:15 

meets 173:12 246:4 

258:22 

melody 332:15 

melt 11:15 

member 6:2 8:1 12:21 

13:1 32:2 49:18 103:6 

115:22 145:19 166:20 

201:17 216:20 274:1 

338:18 387:22 419:2 

members 7:14 11:19,20 

17:3 19:14 56:22 58:2 

77:1 139:16 142:12 

142:13 143:5,5,9 

144:14,16,17,21 

146:12 172:15,21 

180:13 196:10 225:16 

225:20 226:2 228:1 

229:4 234:13 243:10 

243:10 244:17 249:13 

251:8,13 323:6 

333:12 334:1 368:2 

370:4 371:22 382:9 

382:13,13 387:9 

390:8 398:20 407:9 

419:4 424:21 454:9 

membership 228:8 

229:8 230:13 236:9 

371:20 

memo 118:5 124:2,4 

184:10 

memorandum 95:7 

memory 338:2 

memos 63:11 

Mendenhall 223:20 

227:22 228:3 231:9 

231:15 232:11 

meningitis 214:11 

mentality 20:8 

mention 17:17,21 227:7 

271:16 274:7 303:5 

315:11 368:16 435:17 

mentioned 14:19 39:15 

42:13 124:19 174:16 

179:10 197:21 203:16 

265:12 275:12 326:21 

338:5 351:21 406:5 

430:16 436:1 448:22 

450:9,18 

mentor 52:19 

mess 434:5 

message 32:8 69:20,22 

169:21 171:2,20 

418:8 445:10 457:6 

messed 448:3 

met 1:8 24:16 26:13 

151:8 

metabolites 233:11 

261:8 

metam 365:18 

method 289:4 351:5 

369:13,19 401:16 

433:9 

methods 5:13 93:6 

151:21 203:6 369:8 

400:3 401:13 402:14 

403:11 421:22 

methyl 366:5 

Metin 49:19 

metric 291:19 428:15 

Mexican 436:15 

Mexico 22:11 25:17 

26:8 

Meyer 258:7 262:19,21 

262:22 

Miars 243:5,15,18,19 

247:11,21 249:5,11 

250:20 251:1,5,16 

Michael 379:3 385:19 

385:19,21 

Michelle 2:2 7:7,11,13 

34:8 131:11 133:5 

135:3 145:6 227:19 

227:20 232:12,15 

314:21 

Michigan 351:9 

micro 50:10 

microbe 33:11 

microbes 366:14 

microbial 366:3 

microcrystalline

194:19 197:19 199:4 

312:14 

microissues 252:20 

microphone 9:19 14:4 

26:3 57:16 

Microsclerotia 364:8 

Mid-America 14:8,8,9 

middle 18:6 35:4 37:7 

37:14 50:19 91:21 

Midwest 209:10 262:22 

407:8,14 408:13 

409:7,13,16,17 

miles 19:6 22:4 24:10 

209:6,16 345:8 447:6 

447:7,8,9,10 

Miles' 56:8 

Miles-McEvoy 56:6 

milfoil 386:21 

milk 30:7 52:13 252:9 

329:5 400:16 401:2 

428:8 430:4,5 

milking 255:13 324:16 

325:21 326:2 

milks 268:6,6 

mill 15:17 

million 31:12 45:18 

171:1 211:21 411:19 

millionaire 20:6 

millions 253:11 

Mills 13:8 

mind 30:15 99:8 128:16 

183:21 319:16 351:5 

352:3 

minds 121:11 208:12 

mined 281:16 

mineral 223:14 240:3 

minerals 259:9 

minimal 31:7 

minimizing 351:1 

minimum 348:14 

Ministers 26:8,9 

Ministry 317:13 

Minneapolis 11:11 17:7 

34:22 42:20 201:21 

Minnesota 1:10 2:12,16 

4:14 10:4,7 15:2,5,6 

15:19 16:9 18:20,21 

18:22 21:7,16,18 

27:16,21 28:10 29:12 

30:2,16,20 31:5,11,17 

32:10,14,15,22 33:4 

34:14 36:8 40:16,17 

41:1,6,13 44:1,7 

45:17 47:3,21 49:12 

49:22 51:5,12,15,20 

52:3,4 53:1 58:16,22 

59:11 379:6,8,9,11,22 

380:12 383:12 407:10 

410:3,4 

Minnesota's 11:8 16:1 

16:4 31:15 32:5 

minority 420:11 422:8 

422:17 423:12 424:16 

425:7,14 426:9 

minute 66:17 134:11 

145:12 278:2 

minutes 18:5 34:7,11 

34:11,12 42:19 130:2 

141:18 145:7 146:2,3 

293:14 

mired 54:6 

Mirenda 169:7 177:10 

177:15,18,20 181:5 

183:8 185:18,21 

186:9 188:9 189:19 

190:13 310:18 

MISA 40:19 

misconception 217:22 

misleads 279:6 

missed 243:20 424:21 

missing 244:10 424:20 

425:1 

mission 16:4 65:3 

75:17 92:3 103:4 

338:15 

mission-driven 402:7 

missions 16:7 

Mississippi 24:6,8 

410:16 427:8 

Missouri 14:7 255:4 

mistake 20:4 

MITC 366:5 

mitigate 387:4 

mitigates 288:22 

mitigation 162:20 168:7 

mix 265:8 431:9,10 

mixed 13:19 19:8 

mixes 453:17 

mode 158:3 

model 72:12 79:15 

81:14 94:15 220:21 

386:18 427:11 

models 64:11 93:22 

modified 234:14 261:15 

262:7 263:18 

modifying 193:18 

modulus 265:5 

MOFGA 442:19 443:1,3 

445:20 447:4 

MOFGA's 445:19 

MOFPA 164:21,22 

molecule 264:6 267:14 

molecules 267:11,18 

Molly 374:16 379:2,3,5 

379:6 382:19 

Mom's 12:6 

moment 11:18 118:21 

142:7 

moments 271:11 

Monday 301:2 

monetary 211:14 

money 238:2 304:7 

monitor 79:13 92:15 

monitoring 119:4 

125:16 403:10 

mono 235:19 

Monterey 25:17 

month 38:7 89:7 130:2 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
490 

204:19 221:6 222:20 

months 21:8 22:9 23:21 

62:13 63:7 64:10 70:9 

97:15 120:13 202:16 

202:17,19 203:3 

204:22 205:8 238:12 

321:18 348:14 

morning 4:4 6:11,20 

8:20 9:22 11:22 12:19 

13:10,22 14:20 16:18 

43:14 58:11,13 160:8 

169:10,20 177:19 

190:17 205:20 298:19 

300:3 308:20 326:21 

morphological 352:8 

Morris 18:21 51:15 

mortality 363:19 

Mortensen 1:17 12:16 

12:16 119:9,16 157:6 

185:15,20 241:3,10 

242:6 319:15 348:21 

354:21 366:17 377:17 

384:21 385:15 453:8 

453:21 

MOSA 302:5,13 306:7 

307:5,8 312:21 

MOSES 52:16 

mosquitos 208:5 

mother 29:7 

mothers 321:16 

motif 413:20 

motion 172:11 

move 20:20 31:4,19 

32:10 53:17 55:6 

57:13 69:3 85:14 

134:5 139:8 141:18 

168:20 314:7 333:8 

357:20 393:7 402:22 

403:18 459:22 460:4 

moved 117:19 210:9 

433:20 

movement 116:18 

228:13 252:5 295:4 

361:16 409:4 

moves 249:22 341:22 

moving 79:13 85:7 

143:16 167:8 169:5 

233:16 262:14 333:3 

334:3 358:10 370:7 

377:20 416:15 446:16 

MRO 246:14 433:1 

438:14,14 

MROs 245:14,20 

MSC 274:10,10,11,12 

MSDS 198:8 

MSU 353:21 

mulch 178:4,7 180:18 

181:2,2,9 182:13 

190:2 303:1 304:7 

305:16 310:17 311:6 

311:13 312:3 339:9 

345:4,7,8,13 356:16 

357:3 399:10 438:6 

439:2 

mulcher 313:8 

mulches 87:15 

multi-state 49:2 

multiple 54:8 85:17 

103:5,8 111:18 

288:16 323:19 

multiply 324:5 

mumble 55:11 

municipal 158:11,16 

159:19 

Murdoch 15:19 

mushroom 194:20 

mustard 155:1 366:18 

384:9 

mutagenesis 369:20 

N

N 356:1 358:11 360:10 

362:1,10,15,19 

NAFTA 25:20 

nail 423:16 

naled 163:15 

name 4:7 12:1,19 13:10 

23:19 37:22 52:15 

82:22 83:1 145:18 

146:18,19 160:8 

169:8,12 177:17,19 

190:16 194:14,16 

201:14 205:20 212:9 

220:4,5,9 223:21,22 

227:21 228:3 232:15 

236:18 238:14 243:17 

251:19,21 258:8,9 

262:20 265:19 270:13 

280:3 287:20,22 

295:9,11 302:2,4 

314:12,15 321:1 

334:6,9 338:12 343:2 

355:22 362:22 363:1 

367:20 372:6,9 

374:17,18 379:4,6 

385:20 389:10,11 

393:17,18 398:15,17 

402:3,4 410:12 

418:21 427:3 428:2 

442:8,9,11 448:3,6 

454:7,8 

name's 212:11 356:2 

419:1 427:5 

named 29:6 67:13 

245:18 

names 281:3 

nanomaterial 369:5 

nanomaterials 369:7 

nanomycin 161:20 

162:1,6 165:6 

nanosilver 368:17 

nanotechnology

368:17,21 

NAP 207:19 

NARMS 218:7 

NASA 428:19 

natamycin 161:14,15 

163:18 

Nate 350:5 355:21,21 

356:2 358:8 361:2,20 

362:17,18 

nation's 30:11,14 

national 1:3 2:2,5,5,6,7 

4:6,8,17 5:19 7:14 

11:6 15:8 21:13 71:14 

85:11,13,19 87:7,12 

88:3,22 89:11 96:15 

96:17 99:16 118:4 

128:13 138:1 140:6 

150:4 160:10 163:13 

166:16 170:19 171:10 

171:11 181:8 184:4,6 

184:12 186:16 191:7 

194:18 196:16 200:18 

209:9 211:20 215:5 

222:2,9 224:18 225:3 

228:1,7,9,12,13 

230:13 231:20 232:6 

233:2 234:20 237:14 

238:6 268:22 271:16 

272:14 280:15 282:5 

284:3,7 285:22 

302:22 306:20 322:4 

339:3 358:17 359:14 

360:8,16 367:22 

368:4 371:4 382:10 

386:1 388:21,21 

395:18 400:9 415:11 

419:12,12 443:5 

455:22 

nationally 30:6 51:19 

230:18 231:18 232:5 

402:8 

Nations 12:3 

native 89:13,13 273:4 

273:11 

natural 33:2 35:1 149:4 

212:12 233:10,13 

240:17,19 242:14 

260:2,4,6,7 261:7 

262:13 364:21 365:9 

365:12 386:10,12,15 

410:14 445:11 

naturals 227:3 

nature 106:14 107:8 

109:14 267:12 272:13 

303:8,22 317:2 

391:14 

Naturopathic 12:22 

navigational 277:11 

NC 41:11 

near 62:9 447:14 

nearby 221:8 

nearly 21:10 179:7 

222:15 372:12 

Nebraska 384:22 

necessarily 113:2 

123:19 157:22 212:3 

281:10 287:4 306:9 

311:3 328:1 353:11 

422:12 435:4 437:17 

necessary 144:13 

152:19 157:17,22 

159:2 215:7 303:15 

313:22 367:5 

necessity 148:6 431:21 

need 8:8 27:3 35:22 

36:6 53:20 61:5,8 

68:5 70:15 80:10,13 

82:12,22 83:8,17 91:8 

93:1,4 94:8 118:21 

123:2 124:12 125:22 

126:7,8 128:10 

129:15 131:17 133:6 

133:11 135:5 138:21 

143:18 147:12 152:4 

163:12 184:11,11 

196:4,14 197:12 

202:4 205:7 208:21 

209:1 210:19 211:4 

217:10 242:11 250:5 

269:14 287:7 291:11 

300:4 306:10 308:5 

309:9 311:10 316:8 

324:1 333:8,13,15 

337:5 348:1 349:1,8 

357:9 360:20 365:2 

370:9,19 371:19 

377:18 386:12 391:10 

391:13 393:7 396:16 

402:9 410:7 412:18 

417:9 418:8 419:11 

419:21 421:12 422:2 

423:4 424:4 427:14 

427:18 431:20 443:11 

454:19 458:17 

needed 40:2 74:22 75:2 

87:21 96:19 147:8 

158:21 171:19 220:22 

233:21 381:14 443:14 

needing 24:20 375:18 

needs 16:15 69:7 70:7 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
491 

86:12 108:4 111:3 

136:11 140:9 152:7 

160:2 213:20 217:8 

286:4,22 287:6,6 

291:9 319:4 322:9 

363:9 382:3,15 

388:16 408:15 420:4 

negative 305:4 

negligible 183:13 

negotiated 64:21 

negotiating 94:16 

137:20 

negotiations 26:16 

neighbor 207:11 

neither 19:21 209:16 

397:3 

Nell 220:3 223:22 224:1 

227:4,15,17 

nematode 363:12,22 

364:16 365:2 367:5 

nematodes 366:9 

network 44:14 229:8 

408:5 409:13 

networking 459:12 

neurodevelopmental

400:19 

neutral 179:14 246:14 

Nevada 257:5 

never 20:2 99:19 130:6 

165:12,13 197:6 

198:16 200:13 204:14 

209:15 214:22 219:5 

257:8 279:19 291:5 

292:8 381:18 439:6 

new 4:17 6:21 7:14 

12:17 22:10 24:7 

25:20 27:6,7,10 35:10 

38:1 41:16 63:10 

64:11 75:15 76:21 

79:19 85:13 91:20 

95:12,21 96:18 97:4,7 

164:18 177:18 179:7 

184:7 204:3 237:8,10 

255:5 271:1,4,19 

277:8 282:19 286:1 

301:3 303:21 341:15 

346:1 362:14 363:3 

395:5 411:4 424:5,5 

444:17 450:10 

newborns 214:10 

newest 90:14 

newly 122:20 363:11 

news 26:16 64:10 76:1 

301:2 409:2 

newsletter 248:10 

newspaper 86:21 87:4 

87:13 188:10 189:4 

302:16 303:20 306:6 

395:13,19 449:2 

newsprint 303:21 399:9 

NGOs 180:9 

nice 11:3 34:3 38:14 

42:21 44:7,13 45:13 

48:8 96:17 231:6 

290:2 398:4 432:16 

Nicole 389:9 393:15,16 

393:18 

night 24:22 

nine 321:18 429:2 

nitrate 163:15 357:18 

357:21 361:3,13,20 

nitrogen 33:13 38:17 

47:2 48:18,19 

NOC 160:16 161:9,11 

161:14 162:5 164:17 

227:6 334:18 368:3 

368:10 369:15,21 

nodes 73:2 

nodosum 278:8 

NOFA 393:21 

nominations 96:20 

non- 171:8 224:6 270:5 

353:6 359:18 360:3 

401:15 406:3 409:10 

413:4 417:22 419:18 

421:16 

non-adherence 254:17 

non-agricultural

170:18 

non-animal 259:14 

non-approved 336:15 

non-certified 414:3,6 

non-compliance 81:17 

308:16 309:8,12 

360:4 404:12 

non-compliances

376:5 

non-compliant 75:14 

non-dairy 264:1 268:5 

non-GE 421:20 

non-genetically 262:7 

non-GMO 262:4 399:19 

399:21 400:3,5 

non-organic 155:6 

170:14 174:3 339:21 

394:18 395:3,9 

397:14,20 398:10 

399:19 405:19 417:10 

457:10 

non-pathogen 366:10 

non-profit 246:15 

295:13 

non-selective 365:15 

non-synthetic 161:16 

162:7 222:6 233:15 

260:1 268:2 280:22 

282:1,4,13,16 285:20 

285:21 

non-waste 455:21 

NOP 4:15 5:3 10:9 34:5 

55:19 56:1,4,20,21 

58:10 76:9 78:9 79:14 

82:6 87:8,18 89:14 

96:22 100:21 113:18 

114:14 119:9 127:20 

128:22 139:16 157:9 

162:11,21 169:11 

170:16,19 183:5 

184:10 191:6 192:20 

196:4,6,15 197:13 

217:7 225:11 229:14 

229:17,21 237:6,8 

238:7,18 239:14 

244:12 245:13,15 

252:19 253:1,20 

254:4 255:16 257:12 

257:17 274:14 281:22 

284:4 288:7 290:6,7 

292:19 298:4 304:14 

308:14 314:21 335:15 

340:16 346:7 373:4 

377:14 388:8 390:14 

391:7,11,13 392:20 

396:2,6,14 399:12 

405:17 407:9 413:16 

416:13 417:13 419:4 

421:1,1 426:14 

433:11 454:17,18 

457:6 

NOP's 6:4 55:7 149:15 

254:14 280:20 394:5 

400:2 401:15 404:9 

NOP-initiated 119:6 

nop.guidance@ams....

66:2 

NOPs 184:3 

norm 208:20 

normal 103:3 133:13 

415:6 

normally 142:18 143:12 

318:13,21 

north 33:7 41:9,11 49:3 

78:15 221:18 271:3 

north-south 49:9 

Northeast 319:17 

Norwegian 16:16 19:5 

NOSB 2:2 3:12 10:8 

11:12,17 65:16 69:10 

71:2 74:15 85:15 89:4 

89:14,19 97:10 98:22 

102:8 103:16 130:22 

143:18 147:2 148:22 

149:16 151:17 160:21 

161:11 162:5,21 

169:11 171:10,12 

172:19 178:17 180:14 

201:18,19,20 203:12 

209:15 217:3 221:22 

223:1 226:8 229:12 

229:15,18 230:5 

233:16 237:6 243:21 

244:6,16 245:12 

249:9 255:1 259:22 

272:15 281:9 283:1 

286:14,18 290:1,7 

291:4 293:20 298:4 

299:21 305:9 306:19 

329:3 335:16 336:17 

344:15 346:9 350:13 

350:16 362:11 368:2 

368:4 369:3 370:6 

372:13 373:15 386:1 

392:19,21 394:1 

396:1,4,13 398:20 

399:11,16 400:15 

401:4 407:8 408:10 

419:2,4 433:15 457:4 

NOSB's 142:21 171:21 

281:12 296:19 368:20 

394:9 400:2,11 

401:16 408:16 

not-so-distant 366:2 

notably 230:13 

note 208:9 296:4 

339:13 349:20 446:10 

459:20 

noted 151:10 351:9 

420:14 

notes 57:22 128:3,17 

130:11 131:2 161:5 

164:12 224:17 272:22 

420:3 421:5,6 

notice 308:16 309:8 

359:18 

noticed 44:5 175:8 

262:11 

notifications 95:3 

127:11 

notified 87:19 

notify 158:11 

notion 273:6 

Nova 272:4,6 

November 29:18 68:16 

68:21 97:20 257:14 

NRDC 213:21 

NSF 33:5 

nuclear 447:6 

nucleic 369:16 

number 9:6 30:4 38:9 

59:4 63:21 65:13 

66:10 97:1 99:3 

101:11 103:4 104:8 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
492 

126:10 127:19 211:12 

230:11,14 238:11 

240:5,13 254:16 

269:14 289:5 305:3 

307:18 310:19 332:11 

366:18 394:3 403:19 

413:15 433:22 435:11 

435:15 440:15 444:6 

447:3 451:6 

numbers 31:4 83:6 

435:5 

numerous 57:8 259:17 

387:9 

nurseries 155:9 364:13 

nursery 155:4,6,14,16 

155:18 156:2,3,4 

364:19 371:15 

nutrient 47:18 256:1 

386:15,17 411:8 

nutrients 234:1 268:7 

nutrition 295:19,22 

296:4 297:17 

nutritional 52:13 

O

o'clock 243:3 333:17,19 

432:16 459:5 

Oakley 1:18 14:11,11 

98:11 100:19 102:3 

135:12 152:11 153:1 

163:2 185:4 186:2 

223:9 226:13 227:11 

231:5 239:18 242:7 

250:18,21 251:3 

273:14 278:6 305:13 

337:13,21 367:13 

378:3,21 389:3 

392:17 405:15 413:12 

422:7 425:21 440:21 

441:18,21 442:4 

445:18 457:12 

oats 30:11 

objection 58:7 

objections 58:8 

objective 246:10 249:4 

356:19 

objectively 248:20 

objectives 92:14 98:13 

obligated 44:2 246:1,2 

246:5 

observation 341:11 

observations 90:19 

92:9 283:7 

observe 11:5 84:5 

observed 415:6 

observes 272:4 

obtain 78:10 191:15 

378:4 453:6 

obtaining 192:4 377:10 

obvious 200:16 

obviously 163:21 184:8 

187:22 195:18 225:8 

247:3 285:3 298:18 

299:3 423:17 452:5 

457:20 

occasion 9:16 162:19 

occasionally 300:11 

309:4 

occurred 30:22 84:7 

occurrence 346:22 

occurring 167:15 355:7 

occurs 168:1 

ocean 225:2 270:22 

271:4 443:17 444:10 

oceans 445:9 

octanoate 150:13 

194:22 

October 1:7 62:9 296:1 

321:21 410:18 

OEM 440:6 

OFA 229:4 

off-farm 31:7 48:21 

429:9 

offer 248:5 268:16 

380:2,5 404:13 

offered 373:15 381:9 

offering 220:10 

office 21:13 69:12 72:1 

75:21 122:19 215:21 

officer 4:11 10:14 

212:12 

offices 64:19 92:7,8 

official 2:8 254:5 

officially 4:5 67:13 

396:5 

officials 60:11 

OFPA 105:14,18 122:5 

149:1 214:21 238:7 

238:21 252:6 286:12 

297:10 298:20 299:3 

299:10,16 330:22 

331:1 412:11 416:4 

Ohio 162:17 

OIG 69:10,16 253:3 

329:4 

oil 223:14,15 234:10 

240:19 436:18 441:6 

oils 240:3,4,5 

Oklahoma 14:12 

old 18:7 24:4 151:1 

184:5 190:21 203:16 

214:20 271:7 272:5 

298:6,10 

Ole 14:1 

Olympia 356:5 

OMRI 180:18,18,21 

181:3,10 243:19 

244:1,11,14,15,20,22 

245:1,3,6,9,14,18,22 

246:2,5,10 344:5 

346:7 433:12 439:16 

454:14,18,22 455:2,5 

456:5 457:18 458:5 

OMRI's 244:5 246:19 

456:12 

on-farm 404:11 

once 18:9 24:18 85:15 

102:18 109:11 124:21 

130:8 131:8 132:8 

133:4 146:3 237:19 

246:19 250:4 276:16 

290:6 292:16 321:10 

324:17 341:15 347:22 

417:20 

one's 378:18 

one- 324:15 

one-tenth 411:21 

OneCert 194:17 

ones 35:21 53:7 199:16 

338:5 379:19 415:13 

415:15 431:14 441:10 

ongoing 63:4 74:11 

80:21 102:17 402:15 

online 67:21 97:13 

132:16 290:8 

onward 281:7 

ooh 38:4 58:15 

opaque 268:4 

open 76:3,8 96:5 98:9 

112:11 119:1,5 132:1 

132:5,8 133:22 134:7 

134:16 151:14 160:17 

160:20 161:1 188:1 

227:13 275:16 276:2 

293:12 312:9,9 

454:22 

opened 95:19 132:2,17 

414:5 

opening 4:5 34:9 96:21 

310:10 349:17 

opens 131:22 312:7 

operate 433:1 

operated 15:18 

operates 379:11 

operating 380:8 

operation 39:21 61:15 

67:20 83:1 107:10,11 

107:15 108:9,11,14 

108:20 109:16 111:14 

197:1 288:12,15 

308:7,7 321:17 

324:15,17,21 325:12 

376:6 389:17 390:9 

390:13 391:8 412:17 

414:6 

operation's 78:21 

389:20 

operation-specific

210:13 

operations 58:21 59:8 

59:11,17 60:2,10,15 

66:18 75:8,10 81:8 

95:4 103:11 111:4 

138:10,13,15 142:21 

149:11,15 159:17 

168:4 224:9 244:22 

288:12 302:6 321:9 

328:6 334:12 374:21 

410:1 412:13 

operator 112:22 113:2 

253:21 288:20,22 

289:7,13,21 290:21 

operator's 376:4 

operators 116:11 

167:15 171:16 184:22 

197:7 288:6 289:5,19 

290:16,18 291:1 

292:14 293:19 446:12 

opinion 152:9 188:8 

194:1 219:9 306:3 

opinions 246:9 

opportunists 392:1 

opportunities 43:20 

69:6 89:12 90:16 

opportunity 25:18 

27:17 28:16 29:5 

42:21 43:3 88:11 

91:16 190:20 228:2 

231:1 232:21 235:21 

258:5 285:15 337:11 

342:2 372:14 377:15 

386:2 387:22 394:2 

421:2 445:7 448:10 

oppose 195:19 

opposed 311:3 340:5 

371:10 

opposes 368:10 

opposite 327:15 328:21 

390:12 

opted 406:8 

optimistic 257:20 

option 117:14 148:3 

201:4 364:11 

optional 342:16 

options 258:16 

OPWC 147:5,14 148:7,9 

148:18 149:6 150:20 

158:5 

oranges 350:19 418:12 

orchards 5:14 

order 3:4 64:22 66:10 

82:15 142:11 144:3 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
493 

171:16 221:17 243:14 

292:14 316:9 388:7 

438:22 

ordering 320:5 

ordinance 277:5,12,18 

ordinary 187:19 

Oregon 155:8 283:6 

372:10,16,21 373:5 

OREI 49:2 

Organic's 245:19 

organically 50:13 110:8 

241:22 307:15 323:11 

405:1 408:3 

organics 14:1 36:5 

40:11,14 51:9 252:14 

300:10 304:9 317:10 

320:11 433:3 439:8 

448:18 

organisms 261:15 

organization 166:21 

172:20 213:5 224:7 

228:8 231:7 246:15 

254:16 295:13 402:7 

433:2 

organizational 314:22 

organizations 15:9 

66:4 72:9 91:11 92:10 

180:9 228:17,18 

245:14 261:20 338:18 

341:12 439:17 

organized 120:7 192:6 

oriented 112:5 

origin 229:22 325:1 

328:19,22 329:6,12 

330:4,20 331:1,17 

332:3,6,9,14,20 

364:21 378:16 384:13 

436:11 439:18 

original 84:22 112:2 

306:13 312:20 347:19 

421:15 439:18,21 

originally 269:5 303:7 

305:17 

origins 436:14 

Orleans 24:7 

ors 172:8 375:15 

OSA 402:12,18 403:9 

404:5 

OSA's 404:15 

OSB 157:9 

OSP 225:16 

OSPs 226:3 

OTA's 180:13 

ought 140:13 

outboard 24:20 

outcome 63:3 

outcome- 290:11 

outcomes 62:19 180:6 

290:12 

outdoors 254:3 

outlier 149:2 

outline 396:9 423:18 

outlining 349:10 

output 61:4 

outreach 15:12 23:12 

32:4 63:13 89:5 226:2 

outside 37:20 43:1,17 

48:10,13 117:5,11 

142:14 144:15 149:1 

225:11 256:22 336:8 

376:11 414:16 458:19 

outstanding 140:8 

229:16 362:3 

Over-achiever 56:14 

over-harvesting 186:20 

224:11 

overall 138:5 192:11 

350:13 361:16 

overarching 370:10 

overhaul 126:8 

overhauled 74:13 126:8 

overlap 268:15 

overlooked 290:4 

overly 378:9 

overrules 253:20 

oversee 138:7 168:8 

overseeing 253:9 

oversight 62:3 64:12 

70:3,15 71:13 72:13 

73:2 74:12 81:6 90:11 

93:18,21 94:15,17 

125:20 253:2 296:13 

340:18 369:2 396:10 

overuse 297:5 

overview 9:21 70:17 

overwhelmingly 182:21 

Oviedo 459:10 

owned 104:13,14 

316:13 

owner 205:21 277:6,9 

343:5 

owners 276:5,5,17 

277:20 

ownership 276:8,14 

owns 104:15 252:1 

277:6,9 

P

P 361:13 

P-R-O-C-E-E-D-I-N-G-S

4:1 

p.m 243:8,8 460:7 

Pacific 141:21 

package 114:5 132:14 

packaged 295:20 

packaging 83:5 124:10 

175:7 400:13 

Packers 17:22 

packet 381:13 

padding 339:15 

page 67:10 145:6 393:4 

pages 133:12 

paid 120:8 

pales 345:11 

palm 240:19 

panel 168:13 187:11 

250:9,16 

panels 238:11 250:12 

paper-based 178:19,21 

178:22 179:14 188:22 

papers 448:17 450:7,14 

450:18 451:16 

parcel 113:2,3 428:2,3 

parcels 428:1 

parent 173:10 

parents' 381:10 

part 4:9 6:14 17:22 23:4 

29:16 62:17 63:18 

65:2 69:14 70:1,6 

73:11 74:4,6 76:17 

80:21 84:1 89:20 

102:17 104:17 108:3 

115:13 122:16 123:6 

124:8 136:14 157:9 

172:19 202:9 218:12 

221:20 277:13 279:7 

302:10 311:8 329:2 

336:7,18 349:21 

378:12 385:12 398:6 

408:10,16 421:15 

428:12 429:18 437:1 

441:19 444:20 448:13 

PARTICIPANT 164:21 

participate 11:5 

participated 89:7 

238:11 

participating 381:11 

participation 102:12 

338:22 341:5 

particular 50:8 51:9,10 

52:9 59:12 64:8 65:5 

75:12 86:15 107:14 

155:12 270:3 280:14 

282:22 283:15 285:16 

320:6 329:15 330:6 

343:21 347:5 355:1 

356:21 397:12 404:10 

412:5 417:13 423:8 

443:7 457:16 

particularly 32:9 81:11 

96:2 162:4 271:4 

331:20 368:13 414:14 

415:17 

particulates 264:12 

parties 76:17 

partly 8:4 

partner 31:19 32:13 

63:19 76:10 127:12 

partners 75:19,20 96:3 

partnership 31:14 

113:22 

parts 64:17 238:14 

329:18,21 330:7,14 

330:18 378:17 

party 210:19 211:3 

225:6 388:15 

pass 139:9 155:20 

172:10,11 193:3 

202:9 232:4 252:5 

364:18 

passed 91:21 203:12 

214:21 330:10 421:7 

passing 402:15 

pasture 73:20 230:2,17 

254:18 256:8 257:15 

323:17 330:8,10,12 

330:16 387:16 427:21 

428:5 

pastures 428:21 

Pat 402:2 407:5,7 410:8 

410:9,10 

patented 373:8 

path 344:7 

pathogen 363:11 367:5 

pathogens 297:7 

353:14,16 366:9 

paths 388:6 

patience 55:13 

patients 214:8 

patterns 153:13 340:4 

Pattillo 2:6 6:1 139:17 

140:3 

patulin 163:22 

Paul 1:9,9 2:4 4:13,16 

11:11 17:6,8,8,11,13 

34:21,22 42:15,16,18 

55:5 58:16 89:15 

209:6 284:16 361:2 

Pause 459:19 

pay 113:4 247:18 248:6 

439:7 

PCC 281:6,20 283:1,22 

285:11 

PCO 336:5 337:18 

374:20 376:14 377:7 

peach 207:9 

peak 46:7 

peanut 240:4 

pectin 264:16 

Pedersen 442:8 448:5,6 

451:2,12 452:12 

453:12 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
494 

peer 89:18 90:1,2 

peer- 33:18 

Peggy 243:5,15,16,18 

246:20,21 247:16 

248:15 251:15 

penalties 123:7 440:11 

pending 76:4,7 

Pennsylvania 334:10 

374:20 385:1 

people 17:6 18:15 

20:21 21:19 22:15 

25:8 26:2 28:8 30:19 

49:21 51:4 53:14 

55:21 56:17 62:20 

63:9 72:9 75:6 78:6 

100:20 110:16 113:10 

115:2 119:3 122:7 

127:22 128:3 129:9 

129:20 130:7 131:17 

132:9 133:11 134:8 

140:17 151:9 164:17 

165:9 173:19 198:17 

199:7,8 205:12 

219:20 224:7 242:8 

243:4 248:17 249:13 

250:10 251:11 266:7 

301:6 316:7 329:17 

329:20 332:14 359:9 

383:18,20 391:21 

411:16 422:13 425:11 

426:9 433:22 434:2 

434:19 435:7,9 

436:20 437:20,21 

440:3 441:8 459:8 

peppers 416:8,10 

percent 9:3 30:10,13 

31:12 61:9 95:16,18 

95:21 125:10,18 

170:14 182:9 208:22 

222:16 231:20,22 

232:4 239:3 241:17 

241:19 252:9,9,13 

253:22 256:10 260:17 

260:19 275:18 291:2 

301:5 314:22 325:6 

341:10 353:3,4 

363:19 411:22,22 

412:14 428:16 430:4 

431:9 

percentage 175:4,16 

189:14 274:17 406:7 

percentile 209:1 

perchlorate 358:2 

Perdue 9:17 

perennial 318:20 

408:16 

perfect 173:12 444:1 

perform 267:3 

performance 92:15 

101:12 

period 28:19 29:3 67:6 

88:1 131:6 132:4,16 

133:3 139:19 140:13 

150:22 156:15 160:14 

182:22 183:7,11 

184:15 185:8 200:20 

204:16,19 207:15 

298:13 306:19 316:10 

318:12,16 319:10 

335:10,17 360:15 

372:15 398:21 399:12 

periodically 73:9 

periods 96:5 135:14 

204:11 

permission 91:6 197:9 

peroxyhydrate 420:13 

persistent 369:2 

person 21:1 143:22 

166:5 168:11 169:4 

210:18 219:19 322:16 

persona 353:1 

personal 35:15 145:5 

146:7 165:2 219:9 

246:9 

personally 57:2 204:15 

349:3 358:21 383:16 

personnel 91:18 340:19 

396:11 

persons 143:18 144:2 

perspective 30:2 96:22 

128:21 331:10 

perspectives 103:8 

pest 44:22 60:12 

225:19 412:6 413:5 

414:15 415:11,12 

pesticide 207:21 

353:13 440:18 

pesticides 166:21 

303:6 419:2 440:13 

pests 5:14 316:3 

pet 436:17 441:5,11 

Peter 220:3 223:20,20 

223:22 227:16 

petition 148:20 162:1 

163:13 170:11 174:6 

178:8 185:22 195:4 

222:1,22 223:1 237:8 

242:15,17 247:3 

266:17 269:1,6,9 

302:11 303:22 309:22 

312:20 313:1 339:12 

343:10,13,14,15,19 

343:22 346:9,15 

347:1,7 348:9,13,18 

358:16 363:4 368:10 

368:16,18 369:4 

396:4 399:14 421:15 

423:21 424:2 448:12 

448:22 450:9,19 

petition's 174:7 

petitioned 88:3 99:21 

184:11 185:22 200:22 

237:2 285:11 286:5 

286:12 

petitioner 170:1 307:21 

petitioning 361:21 

petitions 104:8 179:7 

184:13 302:12 369:6 

457:5 

petroleum-based

448:21 450:8,15 

pH 263:15 433:8 

Ph.D 2:4,5,7,14 5:16 

29:8 33:3 56:12 

Ph.D.'s 29:9 

Ph.D.s 249:16 

phase 149:16 183:11 

304:14 306:19 349:2 

phase-in 225:5 

phased 116:9 

Phil 201:13 205:18,21 

209:3 211:8 

Phoebe 393:16 398:14 

398:14,17 

Phoenix 256:22 

phone 102:20 236:8 

416:22 

phonetic 25:16 450:1 

phony 252:16 

phosphoric 235:20 

photographs 83:6 

255:19 

photos 414:19 

phthalates 400:16,17 

401:2,7 

Physical 5:5 

physician 212:11 

phytosanitary 155:20 

156:12,20 

Pic 366:5 

pick 22:6 

picked 300:15,17 

picking 301:8 

pickup 22:5,10 

picture 71:20 72:4,5 

291:12 301:18 434:3 

pictures 70:20 95:6 

141:1 416:3,7 

piece 64:9 72:1 244:10 

301:17 313:14 383:22 

440:19 441:16 

piecemeal 457:3 

pile 345:4 

piles 349:4 

pilot 94:7 148:13 

370:12 403:14 

pineapple 147:10,15,18 

148:2,8 315:21 

318:17 320:14 

pineapples 147:5 315:7 

315:14,19 316:4,5,20 

318:2,10 320:8,9,12 

320:17,18 

pink 289:6 418:1 

pinpoint 447:17 

Pipestone 21:20 

place 11:17 26:21 29:21 

37:7 43:20 44:1 46:16 

52:18 55:16 84:13 

88:20 91:14 92:19 

168:9 192:4 205:11 

206:10 208:7,15 

257:9,15 264:8 

281:10 282:11 283:14 

306:21 341:14,19 

376:22 377:1 400:20 

422:5 426:4 447:16 

placed 260:5 324:4 

371:4 

Placements 375:15 

places 267:2 275:13 

276:16 329:14 

plain 457:8 

plan 18:9 24:3,6 60:2 

62:17 96:3 117:19 

119:3 125:2 162:20 

171:21 213:22 215:12 

217:4 256:7 296:20 

375:21 387:16 398:6 

408:16 413:4,22 

414:4,12 416:12 

420:18,19,20,22 

421:3 428:14 

plane 22:12,14 

planet's 357:12 

planning 59:22 92:12 

93:22 119:1 333:9 

plans 161:4 168:8 

256:1,1 

plant 33:10 179:20 

277:20,21,21 311:16 

337:17 353:2,3,3,12 

353:17,19 354:13 

355:10 363:11,19 

364:13,21 384:8 

455:3,7 

plant-based 450:14 

planted 178:2 179:2 

397:18 

planter 454:1,1 

planting 148:11 149:6 

178:3,19,21 179:14 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
495 

187:20 188:22 203:2 

310:5 339:4 346:3 

394:7 399:7,15 

428:17 438:11,12 

plants 38:9 45:3 155:1 

179:17 180:2 186:21 

317:4 335:5 352:4,8 

352:16,22 353:5 

364:17 369:12 449:12 

455:10,12 

plaque 140:1 

plastic 46:3 304:7 

345:7,8,13 349:2,4,6 

plastics 339:7 

platform 228:13 

play 71:6 185:2 288:16 

players 76:13,13 

playing 62:21 73:16 

80:14 388:9 

plays 271:14 339:12 

please 103:19 132:8 

144:15 162:8 172:10 

273:6 296:3 297:21 

324:12 333:13 339:13 

367:20 

pleased 196:6 402:21 

404:10,18 

pleasure 8:1,13,21 9:13 

17:4 34:6 

pled 197:7 

plenty 363:20 

plugged 7:3 

plus 28:12 

point 22:20 24:3,21 

37:3 39:20 41:14 

50:12 110:1 115:21 

131:19 167:5 172:9 

183:9 187:7 188:16 

204:16 209:12 214:22 

215:4 216:9 236:7 

242:11,13 264:14 

269:12 281:7 291:19 

292:9 315:9,12 

317:15 320:13 329:20 

348:19 362:7 364:17 

372:8 397:22 398:5 

421:9 457:17 

pointed 281:15 310:18 

328:22 

pointing 150:7 272:20 

377:18 378:17 423:16 

points 64:16 71:7 166:3 

168:15 239:1 289:9 

296:5 338:20 380:16 

408:6 

police 417:16 418:4 

policies 143:2 228:14 

229:5 232:4 286:8 

390:20 

policy 15:10,12 23:12 

36:3 39:15 63:10 

108:9,13,17 142:19 

142:22 143:1,17 

177:10,20 192:17 

204:17 224:1 228:13 

228:21 229:1,2,6 

231:16,16,18 232:3 

251:22 271:2 295:11 

302:5 321:22 326:22 

328:14 331:11 387:11 

389:13 404:3 405:2 

421:7,12 422:2,4 

423:5 425:4 454:18 

polling 212:20 

polyethylene 357:7 

polysaccharide 260:3 

polysaccharides

267:10 

ponds 158:19 

pool 125:17 

poorly 120:5 

popular 19:7 201:4 

population 46:8 

populations 233:6 

261:4 271:13 364:1 

364:16 

porch 253:22 

port 84:10 

portion 170:14 172:10 

202:10 308:6 381:21 

432:20,22 435:6 

445:3 446:7 

poses 213:9 358:3 

368:12 

position 91:5 97:3 

179:7 183:12 202:9 

203:4 204:13 231:18 

265:11 359:2 

positions 228:21 

231:11,13,16 246:11 

391:22 420:2,11 

422:22 425:13,19 

positive 53:4 64:6,10 

420:20 

positively 257:21 

possibility 210:2 

261:14,18 

possible 7:11 60:18 

81:12 99:8 136:6 

151:9 155:2 173:19 

238:17 249:4 371:16 

399:20 

possibly 151:9 236:3 

261:22 276:22 335:6 

post 68:22 77:21 129:1 

130:2,21 132:5,8 

133:22 227:13 257:11 

432:15 

post-doctoral 33:5 

post-inspection 288:21 

postal 61:10 

posted 97:17 129:4 

134:7 193:9 244:7 

280:16 301:7 

poster 52:17 

posting 96:20 128:18 

129:14 130:8,9,11,17 

130:19 161:4 

postings 131:5 

postponed 161:13 

pot 119:17 120:15 

181:19 190:5 302:12 

302:19 304:4,6,11 

305:2 306:6 311:17 

312:5 313:12 343:16 

343:21 344:2 345:5 

347:8 359:13 395:11 

399:4 438:11,12 

439:6 448:9 

potassium 183:22 

185:19 350:8,11 

351:6,10,13 352:6 

potatoes 221:14 241:21 

potential 70:22 101:17 

107:19 109:4 179:19 

186:19 204:4 278:18 

288:14 382:13 390:10 

390:22 391:10,12,19 

404:20 

potentially 312:9 362:8 

406:20,21 426:11 

441:21 

pots 86:15,16,19,19,20 

87:10,10 88:2,7,12,17 

89:1 98:13 99:2 

103:10 119:11 121:9 

121:19 149:6,17 

161:7,11 163:3,7 

176:14,16 177:1,7,22 

179:5 181:4 183:1 

187:16 200:9,10 

204:13 247:2 302:7 

302:13,16,16,17,20 

303:2,4 304:15 305:4 

305:5,20 307:5,10,11 

307:11 308:17 309:11 

309:21 311:6,12,13 

312:1,10 334:14 

335:17 339:2,12 

343:8,10 344:4 345:2 

345:7,15,18,21 346:5 

346:8 348:17 349:14 

356:15 358:10,11 

359:17,22 365:4 

395:10,21 399:8,13 

435:18,18,22 438:6 

439:9 448:11,12 

450:12,22 451:3,6,8 

452:6 

poultry 105:10 207:5 

212:17,21 215:16 

216:4,20 230:4 

297:18,21 299:11,15 

299:18 

powdered 234:9 

PPM 286:8 422:18 

423:16 424:14,16 

PQ 350:7 

practical 43:11 304:2 

304:16 311:21 

practicality 426:1 

practically 426:18 

practice 66:3 137:22 

162:22 167:13 197:3 

214:3 294:5 315:21 

368:9 375:19 381:13 

416:21 420:11 443:2 

454:17 

practices 46:1 62:4 

114:2 117:10 148:1 

168:2 182:1 196:10 

204:12 206:22 230:4 

294:13 298:5 303:10 

363:22 381:12 387:11 

388:2,12 409:22 

411:14,18 415:7 

417:6,8 420:7 429:2 

pragmatic 331:10 

praising 56:3 

pre-NOSB 160:16 

pre-second 103:18 

precautions 226:10 

precedent 88:20 163:4 

204:11 285:21 386:12 

precipitated 280:9,17 

281:2,6 

precise 377:18 

precision 206:17 

predators 444:21 

predicted 221:6 

prefer 342:19 

preferable 260:20 

preference 376:21 

388:7 

preferred 235:10 

premature 373:19 

premiums 49:15 50:6 

50:16 51:2 

preparation 57:10 

prepare 53:2 319:11 

prepared 56:19 286:9 

presence 336:15 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
496 

present 1:11 2:1,10 

25:3 139:17 142:12 

143:6 221:2 243:13 

356:8 448:11 455:17 

presentation 98:4 

137:5,6 244:7,9 

presentations 58:18 

61:19 120:11 

presented 63:20,21 

168:9 293:16 303:10 

425:17 427:20 

presenting 146:20 

presents 148:21 

preservation 163:22 

preserving 271:7 

372:19 

president 12:7 14:1 

15:6,7 21:9,12 169:13 

presiding 1:10 

pressing 272:15 

pretty 26:14 47:6,22 

48:7 104:16 106:12 

112:11 121:12 126:2 

208:16 231:13,15 

242:2 250:14 268:2 

269:14,21 300:20 

309:19 328:9 416:13 

416:14 418:3 431:10 

prevalence 363:13 

prevent 114:15 164:3 

195:14 383:18 416:12 

prevented 162:18 

Preventing 85:5 

previous 131:21 192:15 

196:18 197:4 257:15 

259:22 373:15 406:5 

previously 5:4 169:3 

289:11 303:18 391:9 

price 27:2 49:15 50:16 

51:2 380:16 430:6 

price-setters 27:2 

prices 252:8 

primarily 39:7 42:7 

46:20 453:9 

primary 338:14 366:12 

389:14 427:13 436:17 

441:15 

principle 372:21 

principles 61:20,22 

233:10 261:7,9 

prior 9:5,9 33:9 105:11 

143:3,19 150:22 

289:10 290:20 377:1 

priorities 62:7,11,19 

74:7 101:16 123:17 

136:7,8 229:1 342:6 

prioritize 149:10 

prioritized 230:14 

priority 80:2 114:19 

118:12 124:14 229:20 

297:4 332:5 405:3 

pristine 446:3,17,20 

447:13 

private 115:8 117:7 

373:13 

privileged 40:17 

probably 8:6 16:21 

38:16 56:2,7,8 99:5 

121:11 145:10 157:3 

164:17 173:18 193:22 

195:2 198:13 208:4 

208:16 217:9 241:19 

294:1 302:19 310:1 

312:20 313:19 315:17 

334:2 346:14 429:7 

441:9 452:19 

problem 19:13 44:18 

45:8,16,20 73:7 76:14 

107:18 120:20 186:18 

187:1,2 202:18,22 

207:7 213:20 240:6 

269:18 310:14 364:7 

378:13 391:21 411:11 

439:4 

problematic 394:17 

problems 74:2 91:3 

115:2 203:13 400:20 

procedural 343:9 

procedurally 344:6 

procedures 92:5 143:2 

230:9 286:8 421:18 

423:5 

proceed 55:7 188:8 

243:14 247:10 

proceeds 178:17 

process 26:18 28:3 

33:13 62:20 67:4 

74:14,14 76:17,18 

81:17 98:22 102:6 

104:4 125:22 128:9 

128:18 131:8 132:12 

132:13 133:16 134:6 

134:17 136:4 142:17 

149:8 160:19 171:10 

172:20 185:2 189:1 

191:6 193:5 195:15 

229:16 233:10,13 

237:21 238:3,20 

240:22 242:16 249:19 

250:2 260:4,7,18 

281:18 283:15,16 

284:10,14 288:20 

292:12,21 303:14 

310:16 320:1 326:17 

328:15 336:12 337:6 

339:12 348:18 355:17 

357:16 358:4,16,17 

360:16 376:22 419:7 

419:10,11,11,15 

420:21 421:14,16,21 

423:11,17,20,21,22 

424:8 426:7 443:13 

443:20 444:21 

process- 117:8 

process-verified

117:13 

processed 181:19 

281:7 335:7 

processes 63:10 95:1 

127:18 240:14 261:7 

331:12 

processing 9:10 183:15 

281:20 336:6,11,16 

336:18 440:17 456:14 

457:1,4 

processors 96:19 

318:4 401:5 411:21 

produce 30:10 39:10,11 

39:21 48:18 79:2 

80:17 146:21,22 

147:9 148:1 149:11 

151:13 155:15 157:19 

158:1,15 159:3,16 

270:4 315:4 316:2 

317:4 349:13 366:18 

397:21 412:1 413:21 

415:22 417:10 449:16 

451:6 

produced 170:2 233:12 

233:19 260:3,6 408:4 

producer 78:3,5 79:1 

113:9 176:1 206:22 

254:7 278:14 

producer's 13:17 

producers 32:6 41:2 

87:19 115:14 116:4 

122:5,8 147:15 

150:17 154:13 162:13 

167:5 176:9 191:15 

199:10 206:3,12,18 

223:11 226:8 228:10 

239:21 252:12,15 

268:17 307:4 321:4 

322:18 331:20 335:11 

370:20 393:22 395:6 

395:12,13 398:11 

399:1 401:5 408:7 

433:16 436:15 445:20 

446:3 

producing 236:3 319:3 

430:5 

product 60:22 61:2 

71:8 83:5,6 84:21 

85:1 87:6 99:21 

111:15,22 154:22 

170:15 173:12 181:6 

187:19 196:16,19,22 

197:10,15 204:3 

218:2 226:22 227:5 

236:4 240:17 244:22 

246:12 247:3 249:6 

250:19 270:5,6 

282:17,18 310:2 

312:3 314:3 316:17 

319:3 343:13,21 

344:5,13 346:7 347:6 

361:9 366:12 436:3 

436:12,21 440:7 

441:19 443:8,11 

444:7 452:9 453:10 

454:2 457:21 458:1,9 

product's 149:8 320:15 

357:1 

production 5:8 11:13 

30:8 36:1 41:21 42:6 

42:8,8 43:4 50:21 

52:6 53:18 62:3 78:21 

81:22 86:20 87:17 

88:4,22 99:18 104:13 

114:11,17,21 115:8 

117:10 147:10 149:9 

156:2,2 157:18 

161:17,21 167:17 

179:16 186:13,16 

194:21 207:5 212:17 

213:7 214:15,19 

216:5,8 220:16 233:8 

259:19 260:8 261:5 

261:15,16 263:10 

304:12 306:11 315:22 

328:1 349:15 368:21 

369:22 371:3 373:19 

374:14 386:5 387:6 

395:20,22 399:18 

400:3,8 401:16 429:5 

430:9 442:22 448:15 

449:8 

productive 346:3 392:8 

products 62:4 63:14,16 

71:10 79:9 153:4 

170:10,20 178:16,20 

178:22 198:5 212:21 

213:1 218:9,18 225:2 

225:11,18 233:7 

235:1,14 240:13 

245:1,4,11 246:3,6 

250:8,13 259:7 

260:11 262:1 263:5 

264:4,17 268:14 

270:4 272:2 281:8 

296:5 307:15 313:2 

313:20 314:1,16 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
497 

315:4 335:8 344:18 

357:6,8 365:9 395:15 

401:3,5 409:15 412:1 

412:20 414:3 419:19 

431:6 435:2,10,13 

436:14 438:21 439:20 

440:5,6 450:11 

454:16,19,22 455:2,3 

455:6,7,8 456:6,8,21 

458:5,6,6,14 

professional 67:22 

274:4 

professionals 68:3 

professions 391:17 

professor 2:14 8:3 10:5 

44:17 51:21 

profit 21:6 121:2 224:7 

409:11 

profitably 407:16 

profound 38:19 404:20 

program 2:2,3,5,6,7,15 

4:9 5:9 6:17 9:7 10:6 

13:14 32:11 33:1 39:7 

42:2 51:19,21 52:9 

60:16 68:14 71:14 

74:7 89:7 90:9 94:20 

105:22 110:5 118:4 

118:10 127:9,11 

128:22 140:7 148:13 

163:5 207:19 209:9 

218:8 238:7 245:20 

246:5,18 247:22 

248:1 252:3 253:4,18 

255:5,16 284:10 

288:6 291:22 292:7 

292:13,17,20 294:3 

298:19 305:14 328:5 

328:7 331:15 334:10 

346:13 348:6 358:19 

368:5 374:11 375:19 

379:8,14 380:8,14 

386:2 387:16 388:21 

393:21 396:14 415:13 

432:18,19,21 433:1 

440:12 

program's 103:20 

269:5 

programs 12:3 39:2,6 

40:6,13 53:17 60:13 

60:19 117:9,14 

129:13 238:12 256:18 

291:5 382:21 383:11 

progress 172:9 184:14 

370:1 394:6 

prohibit 297:8 299:12 

302:15 357:21 368:20 

prohibited 63:12 

161:16 162:7 167:22 

234:15 358:1 359:15 

360:13 362:4,6,12 

365:11 371:16 

prohibiting 183:1 

296:21 299:14 

prohibition 105:9 

161:10,13 183:5 

214:1 299:19 336:14 

368:22 369:1 424:22 

425:3 

prohibits 424:18 

project 7:2 37:18 38:5 

44:15 49:11,14 50:18 

50:19 68:11 73:18,19 

73:20 74:1,9 96:9,12 

104:5 330:13,13 

370:12 403:14 

projects 43:22 44:9 

52:14 69:18,20 

256:19 

prominence 11:14 

promise 412:9 

promote 27:22 

promoted 269:19 

promoting 172:17 

414:8 

pronounce 154:21 

proof 428:11 

proper 363:21 415:12 

properly 418:12 

properties 233:21 

259:6 266:9,13,19 

267:19,21,22 268:9 

269:11,13 

property 263:8 

proposal 134:1 148:13 

148:15 150:8 154:18 

172:1,6,12 191:11 

192:5,13,20 193:3 

202:13 280:7 285:18 

288:3 290:6 291:21 

293:20 340:17 369:12 

370:3,6 371:13 375:1 

375:3,5,9 377:7,8 

394:5,14,16 397:17 

402:15 403:1,6,13,16 

404:7,19 405:16 

426:12 454:13 

proposals 132:15 133:4 

133:20 143:4 192:19 

193:7 286:22 405:9 

424:20 425:8 

proposed 67:2,7 94:5 

187:2 229:22 273:8 

327:8,8,13 329:9,14 

332:22 340:1 360:5,6 

375:7,11 376:1,4,16 

387:19 404:8 421:3 

proprietary 189:8 

prospective 301:4 

protect 16:5 62:1 80:14 

164:7 179:18 212:14 

230:22 239:2,6 370:2 

protectant 352:14 

354:2 

protected 155:19 

207:20 275:13 418:13 

protected-type 351:11 

protecting 99:16 

172:18 275:14 

protection 7:18,20,20 

69:17,19 73:3 94:20 

239:8 272:12 419:19 

420:8 

protects 392:4 419:13 

protein 217:17 

proteins 234:14 259:9 

protocol 192:3 

proud 27:20,20 442:12 

proudly 140:2 

prove 210:21 301:17 

proved 429:4 

proven 162:16 

proverbial 254:5 

provide 10:9 61:3,4 

67:21 68:15,20 71:8 

74:22 84:4 85:2 

112:10 113:14 122:11 

147:2 162:12 185:7 

190:20 232:21 236:10 

244:17 246:16,22 

258:16 263:7 298:4 

325:10 326:7 368:7 

370:15 375:8 380:6 

386:7 387:3,22 

402:13 421:2 

provided 65:20 78:16 

88:1 89:11 147:6,20 

168:17 169:2 234:12 

244:16 258:11 273:17 

316:22 355:15 425:8 

provides 43:2,19 

148:15 191:19 228:8 

233:20 234:3 259:5 

259:13 263:6,7,16 

285:4 407:2 438:19 

441:18 

providing 76:16 79:8 

88:10 93:9 115:18 

123:5 146:6 167:5 

185:12 285:1,1 343:7 

354:12 390:3 432:10 

434:1 454:22 

provinces 26:9 444:12 

provision 321:10 

provisions 105:18 

323:15,15,16,17 

proxies 143:22 

pseudo-industrial

252:14 

pseudoplasticity 265:6 

psychological 255:11 

public 3:16 10:10,11 

12:10 15:22 67:5 

88:11 97:14,17 98:8 

102:19 114:14 117:21 

120:16 129:3,12 

132:1,3,4,16 133:1,21 

136:18 138:12 141:22 

142:1,13,15 143:17 

144:14,16,21 145:19 

146:6,12 150:2,14 

193:11 198:21 199:5 

209:17 212:13,14,18 

216:6 219:19 243:11 

243:14 244:2 248:5 

248:13 253:19 256:16 

261:13 277:13,22 

278:15 285:3,5 

291:17 306:2,17 

333:8,18 348:22 

349:14 356:2 361:5 

364:13 369:2 385:5,6 

385:8 391:16 392:6 

393:8 394:14 405:12 

413:18 419:16,20 

420:4,18 421:5 424:8 

425:9,18 459:3,6,9 

public-private 113:22 

publication 303:9 

publications 216:4 

350:18 351:10 353:22 

publicly 256:2 391:14 

publish 94:5 230:1 

388:8 

published 31:10 61:21 

62:18 69:5 96:18 

99:18 128:4 131:18 

301:3 329:9 342:16 

377:2 

publishing 191:7 

pull 106:1 361:7 

pull-u-lan 169:22 

pulled 361:6 

pulling 25:19 150:8 

pullulan 169:22 170:2 

170:13 173:6,8,9,21 

195:4,8,12 200:20 

pullulan's 174:16 

pullulan-based 174:3 

pulp 259:10 

pump 265:8 

pumpkins 350:20 

punishment 378:10 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
498 

purchase 381:7 398:3 

purchases 262:12 

Purdue 56:12 211:20 

298:8 

pure 282:15 

purely 436:19,21 

440:18 

purest 367:3 

purification 281:18 

282:4,14 285:22 

purified 282:17,18 

purity 175:22 176:2,6 

202:14 370:11 373:6 

377:10 394:20 395:4 

397:19 405:22 406:15 

406:19 407:1 

purpose 113:17 136:14 

208:13 279:3 317:1 

347:7 403:12 439:10 

pursuing 81:4 118:18 

purview 436:2 

push 446:3 

pushback 423:4 

pushing 47:13 

put 48:4,5 88:14 123:18 

140:4 162:6 164:7 

172:22 173:22 193:22 

204:6 205:14 217:3 

230:1 231:12 237:20 

266:9 268:22 297:20 

299:19 306:20 311:15 

341:18 346:13 358:22 

362:13 365:10 374:10 

393:12 414:15 417:5 

417:9,16 421:4,10 

422:16 430:15 443:15 

459:11 

puts 31:10 250:5 

267:13 

putting 47:7 161:12 

168:12 169:7 191:14 

193:17 205:12,13 

296:20 306:14 312:4 

328:19 412:2 452:16 

453:13 

Q

QAI 256:15 257:2 280:5 

282:6 285:19 288:1,5 

288:18 

QAI's 281:15 290:12 

quadrant 38:8 

qualifications 66:20,21 

195:17,19 292:4 

340:22 341:3 

qualified 195:22 250:16 

qualities 438:19 

quality 39:22 52:13 

60:6 61:7,12 64:3 

89:20 91:4,7 92:19 

93:15 97:7 173:12 

195:18 196:5 340:13 

415:8 

quantify 428:20 

quantitative 92:14 

quantity 431:1 

quarantine 440:11 

quarter 3:14 139:14,18 

139:22 140:4,7,9,12 

341:12 

Quebec 216:8 

question 86:2 99:13 

105:6 106:4 107:2,3,3 

107:5 109:19 110:21 

110:22 111:9 112:3 

116:22 122:3,15 

123:9,11,18,19 124:2 

124:8,12,19 126:21 

134:19 136:3 137:3 

141:3,6 145:20 

150:12 152:16 154:20 

156:14 157:2,15 

164:10 165:21 166:5 

166:7 167:2 174:14 

177:9 183:17 186:2 

200:8,9 209:6,20,21 

211:9,11 216:2 

217:15 223:12 239:19 

247:12 248:13 251:2 

269:3 272:15 274:16 

275:10 276:13 277:12 

283:7 293:2 305:13 

306:22 307:2 309:20 

319:16 322:14 325:15 

326:5,6 327:11,20 

340:21,21 342:8 

361:2,19 378:11 

384:19 405:16 416:11 

425:3,3,15 430:14 

434:10,11 436:5,6 

438:10 458:8,21 

questions 60:12 68:19 

74:17,19 76:1 79:15 

98:6,9 103:15 110:1 

119:14 123:15 139:5 

146:1,4 149:19 159:3 

159:20 161:1 168:10 

173:2 179:22 186:18 

187:9 195:9 197:16 

199:20 205:4 210:6 

223:7 231:3 235:22 

237:17 239:16 246:21 

247:15 254:12 258:3 

262:10 265:17 268:19 

275:10 278:10 285:8 

287:14 289:4,8 

291:13 294:1,2 

322:12 326:12,18 

329:12 334:1,3 338:7 

348:6,19 353:8 

354:14 358:7,8 

366:15 371:7 372:2 

374:1 377:16 382:19 

389:1 392:15 401:10 

410:9 413:10 416:7 

429:14 433:16 436:7 

436:7,9 437:9 438:1 

444:5 445:17 447:20 

451:15 

quick 9:21 58:15 78:9 

104:12 124:18 142:16 

145:7 274:16 361:1 

434:10,10 

quickly 77:7 78:22 

79:18 85:15,18 

173:19 279:10 435:17 

452:7 

quietly 333:14 

quit 255:13 

quite 20:7 25:4 51:17 

115:12 128:10 134:18 

142:20 204:10,18 

232:5 264:20 274:5 

276:9 306:16 319:8 

325:16 344:17 362:4 

452:17 

quorum 142:12 

quote 158:9 298:3,6 

quoted 407:11 

R

radar 37:2 291:3 

radical 204:18 

rage 409:4 

rain 8:8,9,11 

rainfall 407:13 

raining 319:9 

rains 319:8 

raise 58:22 309:9 

323:10 325:14 419:6 

raised 31:7 79:22 87:8 

123:1,2 212:21 

213:12,14 219:22 

319:16 350:9 382:22 

383:4 416:10 

raising 295:4 321:17 

324:1 385:15 

Rakola 6:4 

Ramsey 59:13 

ran 21:11 

ranchers 15:11 77:12 

409:21 

Randolph 280:2 287:18 

287:21,22 292:11 

293:4,8,10,13 294:8 

294:19 295:2 

randomly 291:1 

range 15:21 28:1 

263:14 267:1 370:16 

400:19 450:7 

rank 30:6,7,12 

rapid 29:4 79:15 133:17 

rapidly 74:17 279:14,15 

rare 206:7 

rarely 393:8 

raspberries 45:4 

rate 256:11 295:16 

341:9 427:21 428:5 

rating 295:22 

ratings 295:20 296:4 

rationale 103:19 302:20 

304:16 306:13 

rations 443:12 455:16 

Raubenolt 168:6 

re- 81:8 

re-envisioning 96:17 

reach 61:13 193:10 

reaches 415:4 

reaction 282:20 

reactivate 124:7 

reactivated 124:13 

read 24:22 25:9,9,10 

65:9,12 124:2 132:19 

134:8 153:9 158:2,6 

283:11,13 299:8 

327:16,17 337:8 

340:9 378:7 392:17 

407:21 446:4 

reading 25:1 57:9 65:11 

152:14 154:7 159:1 

186:3 256:19 319:15 

344:8 

reads 345:2 

ready 22:17 73:4 90:1 

131:14 132:15 142:10 

165:17 182:11 237:16 

real 8:1 34:6 51:10 

52:19 92:5 138:3 

187:1 354:11 434:5 

435:17,20 

realize 208:15 278:9 

445:3 

realized 292:16 322:16 

422:10 

realm 438:13,20 

reason 107:16 151:14 

206:8 222:17 279:8 

306:7 323:8 358:4 

406:13 438:8,9 

reasonable 148:15 

311:21 370:18 394:11 

404:5 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
499 

reasoned 424:12 

reasoning 311:11 421:2 

reasons 59:20 148:14 

171:6 263:3 308:20 

308:22 323:9 371:5 

403:19 

recall 181:6 

recalling 284:13 

receive 79:15 91:20 

106:8 231:19,21 

244:21 309:12 359:18 

received 22:18 33:3 

66:3 118:16 122:4 

127:18 237:13 308:16 

389:16 

reception 459:12 

recess 142:2 243:6 

459:17 

reclassify 205:1 

recognize 20:21 55:22 

131:1 171:3 189:7 

304:19 311:4 388:6 

391:7,20 454:19 

recognized 20:22 

240:17 

recognizes 140:3 239:4 

302:13 369:21 372:17 

recognizing 283:11 

303:21 391:3 

recommend 161:12 

222:9 225:4 335:10 

336:17 373:12 396:1 

406:22 450:5 

recommendation 88:8 

88:9 134:16 148:7,19 

184:13 186:1 192:22 

203:12 230:5 233:1 

233:18 234:19 245:16 

250:8 280:10 282:8 

290:1 291:4 298:5 

357:4 362:3,6 368:20 

recommendations 46:8 

65:16,18 66:22 85:16 

90:17 229:15,18 

230:12 232:19 237:5 

284:21 285:4 286:22 

329:4 354:18 392:13 

recommended 92:13 

215:22 245:13 376:14 

recommends 88:7 

91:15 396:13 

reconfirming 81:11 

reconsider 215:10 

335:15 

reconsideration 335:16 

reconvene 459:18 

reconvening 243:3 

record 142:4 169:9 

177:17 185:15 243:8 

243:17 256:16 309:18 

314:13 419:21,22 

460:7 

records 90:7 269:5 

381:14 

recruiting 97:2 

recycled 86:21 87:4,13 

87:13 180:22 182:6,6 

182:7,9,14 188:10 

189:11 302:16 303:8 

303:13,16,19,22 

305:15 312:2 313:15 

344:11,12,18,20,22 

345:1 395:14,19 

399:9 449:2 

recycling 182:10 

red 145:13,14 365:16 

redacted 341:19 

reduce 96:15 257:7 

339:6 364:16 399:3 

reduced 401:3 

reducing 48:21 401:7 

reduction 242:1 301:5 

304:6 365:3 373:10 

redundant 362:2 

refer 28:19 107:12,20 

166:20 192:11 248:12 

280:12 286:16 

reference 329:18 

351:12 356:18 

referenced 352:5 

references 377:9 

406:18 407:1 

referencing 317:14 

referrals 109:9 

referred 76:10 109:11 

278:16 

referring 77:8 425:1 

refers 280:17 

refine 93:22 292:17 

refined 292:22 

reflections 35:15 

reformed 281:19 

282:15 

reformulate 205:2 

refrain 145:4 146:7,10 

regain 207:15 358:5 

regard 121:15 

regarding 160:13 161:8 

195:4,17 225:15 

317:9 334:17 343:9 

351:3 352:15 369:14 

370:19 375:5 377:6 

442:20 455:19 

regardless 190:8 

regards 373:18 378:16 

regenerate 410:5 

Regeneration 407:8 

409:7 

regenerative 409:3,12 

409:15,18,22 

regenerators 409:10 

Regi 409:19 

regimens 412:7 

region 44:19 81:7 

156:22,22 230:18 

232:5 

region's 220:17 

regional 385:8 409:9 

regionally 120:3 

regions 31:1 125:13 

221:2,10 231:17,21 

register 131:9,16 377:2 

434:12 435:7,22 

436:3 

registered 438:21 

440:9 

registering 440:5 

registrant 437:22 

registry 138:12 

Regrettably 222:10 

regrows 279:10 

regs 104:15 112:10 

117:3 123:6 327:2 

regular 31:21 86:19 

regulate 398:10 

regulated 238:8 

regulation 108:14 

172:4 175:1 193:19 

330:15 378:17 403:18 

regulations 81:22 

99:15,18,20 104:12 

105:20 108:21 109:1 

115:4 116:22 193:1 

201:7 203:17 206:8,9 

275:19 299:18 324:22 

325:7 327:16,17 

329:2 330:8,18 331:7 

338:16 359:6 375:14 

382:3,11 384:4 385:4 

404:6 

regulator 241:7 

regulatorily 330:9,21 

regulators 241:14 

256:2 

regulatory 84:1 169:13 

171:18 172:7,11 

190:18 192:21 204:8 

258:10 286:12 317:9 

329:1,12,15 331:16 

333:6 375:7 433:3 

rehashing 363:7 

reimbursement 383:12 

reinitiating 128:18 

reinstitute 420:10 

reiterate 259:22 337:6 

reiterating 334:13 

reject 368:12 

rejected 346:19,20 

421:1,4 449:1 

relabeled 414:6 

relate 106:1 339:13 

related 60:12 63:11 

64:3 69:7 70:17 76:2 

94:4,18 95:1,9,11 

106:5 329:6 330:19 

414:2 420:5 436:6 

relates 129:16 

relationship 391:14 

relationships 33:11 

91:10 427:9 

relative 112:18 366:21 

relatively 363:15 

release 420:3 

released 63:10 

relevant 44:3,12 145:18 

145:20 146:18 180:9 

315:15 

reliable 220:17 

reliance 339:7 349:2 

relies 233:10 261:7 

religious 234:5 259:15 

relist 232:19 233:18 

321:6 420:15 

relisted 261:11 

relisting 234:7 235:18 

258:12 266:16 

rely 77:5 229:17 244:21 

245:1,3 249:12 251:7 

283:20 

relying 284:17 

remain 96:5 203:14 

229:15 364:9 

remainder 87:20 

remains 77:14 394:17 

remarks 16:10 34:9 

244:1 

remediation 363:10 

remedied 92:20 

remember 9:11 21:19 

21:21 22:22 25:12,21 

37:9,22 69:21 77:9 

128:21 208:17 239:13 

371:9 423:2,19 

remembering 102:18 

remind 133:15 411:2 

remiss 56:4 116:1 

remodeled 413:17 

removal 194:19,22 

317:19 456:17 

remove 166:13,16 

267:20 

removed 135:18 151:7 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
500 

193:21 303:4 421:4 

removing 345:13 

renewal 357:10 

rent 381:22 

rented 112:16,17 

reoriented 73:22 

repackaging 415:20 

repeat 128:14 340:13 

460:2 

repeated 92:16 

repeating 244:3 

replace 97:2 155:3 

317:2 357:6 

replacement 166:11 

258:19 325:10 

replacements 258:18 

325:4 

replacer 235:6 

replacers 258:18 

replicated 49:6 235:12 

report 3:8,10,12 55:6,7 

55:9 57:14 58:7,8,10 

60:20 69:5,10,13 70:6 

90:2 111:13 112:13 

171:7 187:18 188:11 

188:20 280:13 286:9 

351:13 352:6 

reported 81:12 89:22 

151:5 341:13 420:1 

reporting 60:4,6,9 61:2 

80:9 89:19 111:10,14 

191:19 301:3 

reports 76:2 85:19,22 

130:22 189:20 215:6 

244:15 249:7,9 251:7 

295:12 296:1 297:4 

298:10 300:9 341:15 

repository 211:12 

reposting 131:2 

represent 9:1 103:8 

412:16 448:8 

representatives 89:9 

120:9 

represented 34:17 

63:17 120:5 

representing 231:8 

232:17 236:20 237:1 

350:7 422:21 423:6 

represents 172:15 

214:18 404:20 

reproductive 400:19 

repurposed 182:14 

reputation 246:9 

request 99:9 103:17,20 

103:22 149:7 161:3 

194:10 213:22 215:11 

259:22 278:22 296:20 

343:20 360:19 401:4 

437:12 

requested 198:5 244:17 

299:22 440:22 

requesting 161:10 

298:4 335:15 

requests 421:1 

require 116:21 171:16 

172:5 260:21 298:20 

299:17 383:20 391:13 

391:18 399:22 

required 125:11,14 

153:11 226:10 246:3 

324:21 325:3 369:3 

382:8 435:4 456:3 

458:2 

requirement 149:16 

180:1 202:7 294:11 

304:14 340:9 392:3 

395:6 425:17 445:22 

requirements 156:21 

187:4 339:19 391:6 

requires 125:9 195:21 

299:21 397:17 

requiring 193:1 224:14 

226:17 292:14 340:6 

359:21 386:4 391:16 

425:4 442:20 

rescue 369:12 

research 5:11 12:11 

33:10 35:6,12 37:18 

38:5,15 43:20,22 44:3 

44:12 49:13 50:9 

51:11 52:11 61:6 

63:15 66:11 84:19 

161:22 251:22 270:17 

271:2 283:2 316:20 

317:7 354:17 366:11 

367:10 400:13 402:9 

404:15 

researcher 389:13 

researchers 50:22 

147:17 

residential 110:11 

residual 456:13,22 

residue 92:5 93:19 

124:19,21 125:1,7,8,9 

125:11,17 126:1 

127:2,3,5,10 

residues 126:22 218:1 

resilience 408:17 

resistance 161:19 

162:2 213:8 217:20 

218:14,17,19 219:12 

297:6 351:1 368:14 

resistant 218:5,9 

resolution 161:12 

resolutions 232:3 

resolve 79:18 95:15,18 

96:3 

resolving 95:21 

resource 7:18,20 33:2 

35:1 141:13 160:18 

162:16 245:7 277:1 

resources 28:21 32:4 

76:21 94:1 105:4 

162:12 212:12 230:2 

375:22 386:10 444:12 

444:14 445:9,11 

respect 57:1 124:9 

125:11 144:22 209:1 

respectfully 148:18 

377:7 

respecting 284:11 

respond 65:18 74:17 

112:15,16 119:13 

365:17 408:15 457:5 

responded 226:5 298:3 

responding 341:12 

response 58:4 69:9,12 

79:15 123:16 147:14 

170:16 176:14 185:6 

341:9 342:21 407:19 

433:11 

responses 101:11,13 

108:2 175:22 

responsibilities 377:12 

responsibility 192:7 

281:13 382:12 423:3 

responsible 45:1 

411:17 

rest 10:9 265:7 

restart 161:4 

restate 185:16 

restaurants 408:3 

resting 364:8 

restore 31:8 385:13 

restrict 229:6 

restricted 359:15 

restrictions 234:6 

259:16 

resubmission 238:4 

result 78:6 99:10 

161:19 257:17 282:1 

291:8 394:15 421:16 

456:16 

resulted 64:20 162:2 

202:19 

results 44:3 46:8 

107:22 191:16,19 

255:5 269:4 289:2 

341:20 367:9,16 

369:5 

resume 28:14 257:22 

resumed 142:4 

retail 50:6 414:3 415:17 

417:14 

retailer 413:14 415:4,4 

417:13 418:18 

retailer's 12:6 

retailers 245:5 316:13 

318:4 411:19 412:15 

412:22 414:11 417:7 

417:18 

Retailing 417:6 

retain 167:17 233:1 

234:19 

retained 259:19 390:9 

retaining 202:15 205:5 

retire 22:18,19 

retired 270:16 

retirement 18:9 24:4 

returned 343:19 

returning 131:5 

reused 182:14 

reverse 210:19 

reversed 322:10 

revert 352:20 

reverting 346:2 

review 59:22 76:6 77:18 

77:19 80:20 89:18 

90:1,2 104:12 106:8 

129:5 142:18 143:17 

148:22 149:7,9,17 

150:5 154:17 171:10 

171:12 176:19 178:13 

178:17 179:12,14 

184:12 188:21 193:18 

224:4 232:20 237:19 

243:20 244:13 245:7 

245:14,17 246:2,5,12 

246:17 249:18,19,20 

249:22 250:9,12,16 

250:19 251:9 261:19 

281:1,13 286:6,9 

288:21 303:11 311:1 

336:8,10,20 337:5 

340:19 344:5 346:7 

350:10 361:11 369:10 

396:4,11 398:19 

419:12 420:1 423:17 

424:2 426:13 433:2 

439:16,17,19 440:13 

441:22 454:11,16 

455:18 457:9 

reviewed 33:19 129:7 

134:7 162:1 181:3,7 

183:2 188:17 237:13 

317:17 328:5 371:4 

395:17 

reviewer 250:1 289:6 

reviewers 68:2 196:2 

290:19 

reviewing 61:20 178:19 

179:7 184:20 249:1 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
501 

283:21 309:7 352:3 

355:6 361:10 369:6 

reviews 90:5 153:10 

223:1 248:18 249:4,6 

308:12,15 309:2,10 

310:18 344:9,16,17 

346:10 357:14 361:6 

399:14 

revise 172:4 382:11 

revised 222:21 223:1 

237:8 394:14 

revocation 327:9 

revolving 252:22 254:6 

254:9 256:13 390:15 

392:7 

rhizobia 47:2 

Rica 315:10,18 317:8 

317:12,14 

rice 1:13 13:10,11 

25:15 57:15,17,21 

122:1 259:11 283:5 

284:9 285:7 291:14 

Rice's 169:16 

rices 353:4 

Richard 314:11 320:21 

320:22 321:2 324:10 

326:4 

Rick 1:16 8:21 25:3 

124:17 217:13 274:15 

275:9 

Riddle 32:1 

right-hand 267:8 

289:17 

rights 111:7 275:14 

277:11,15,19 

rigorous 246:17 419:11 

419:22 

ripen 316:14 

ripener 320:4 

ripening 316:12 320:1 

rise 355:11 

rising 213:9 

risk 64:14,16 93:5 

136:13 137:1 191:13 

217:20 221:7 288:3,5 

288:8,10,16,17,19 

289:2,3,12,15,16,18 

289:19 290:16,18,22 

291:1,5,7,10,20 

292:13 293:6,18 

294:6 301:5 336:1 

358:3 368:13 369:22 

387:5 391:4 392:2 

393:2,3 456:22 

risk-based 64:12 80:5 

81:14 90:13 93:21 

94:14 125:20 

risks 126:10 190:5 

221:3,11 290:2 

368:13 

rivalry 17:20 

river 1:8 17:13 24:15 

427:8 

river's 24:12 

Riverfront 1:9 

road 22:7 328:13 

410:17 422:20 

robin 145:7 265:18 

270:11,12,15 273:14 

446:22 

robust 52:11 60:9 62:16 

73:15 95:11 288:5 

420:1 424:3 

Rochester 5:16 

rocked 22:15 

Rockview 257:5 

rockweed 271:17,21 

272:5,10 278:17 

279:2,4,11,14,17,20 

446:2,11,14 

Rogers 44:16 

role 5:1 23:18 65:4 97:4 

229:12 244:5 246:19 

404:11 

roles 68:4 377:12 

roll 140:18 

rolled 306:6 

rolling 115:9 

Romero-Briones 1:19 

11:22 12:1 

roof 32:16 

room 6:4 21:16 35:21 

102:11 134:4,9 

208:11 256:19 304:21 

333:14 408:9 412:22 

459:21 

root 351:22 353:20 

rooted 42:12 

roots 15:15 351:19 

352:12 

Rose 343:1 350:5,6,6 

353:18 354:10,16 

Ross 385:19 389:9,11 

389:12 392:21 393:14 

rotates 140:11 

rotating 319:1 

rotation 318:9,11 

345:21 364:10 

rotational 351:1 

rotations 221:20 

rotting 45:7,10 

roughly 30:13 144:3 

387:9 

round 10:20 57:4 90:8 

136:21 232:2 

route 456:2 

routine 297:2 

routinely 214:4,14 

215:15 216:21 218:8 

218:10 

Roving 140:5 

rows 311:6,7 428:17 

Rudy 302:1 314:10,11 

314:15 

rule 65:19 67:2,7,8 

77:11 84:2 85:16 94:6 

125:8 201:5,6 202:3 

204:21 206:13 230:1 

230:1,2,4,17 254:22 

321:10 329:9,10,14 

329:19 330:10 332:20 

332:22 344:3 345:2 

347:9 387:19 443:6 

rule- 85:11 

rule-making 65:8 85:15 

88:10 96:15 97:19 

rulemaking 121:4 122:3 

122:16 184:14 357:20 

387:21 396:7 

rules 62:20 63:10 67:6 

85:13,18 96:18 

106:15 201:3 254:18 

255:1 324:4,8 325:13 

384:16,16 390:20 

ruling 254:7 

run 20:13 142:8 144:6 

144:12 204:9 284:14 

378:19 

running 144:4 253:18 

310:13 

runs 358:20 

rural 158:18 

rush 459:21 

S

Sadison 25:16 

safe 261:9 335:21 

safeguarding 445:11 

safely 11:7 

safer 295:14 

safety 13:20 226:9 

401:1 

Saint 1:9 

sake 143:16 275:15 

salad 9:8 235:1 264:12 

salary 20:18 

sale 50:12 324:16 

sales 30:7,9 31:5,11 

77:10 222:16 252:13 

262:17 326:2,2 

salinity 47:18 

salt-stable 265:13 

Sam 190:15 194:13,14 

194:16 197:17 199:3 

201:11 417:22 

sample 126:18,18,19 

202:15 

samples 205:6,8 

sampling 93:19 126:15 

192:2 290:14,20 

291:3 377:10 

San 288:2 

sandwich 264:22 

sanitation 46:5 422:2 

sat 22:20 

satellite 64:18 92:7,8 

428:21 

satisfies 148:5 

sauces 235:9 263:20 

269:19 

save 238:1 323:11 

saved 384:4,4 

savings 429:8 

saw 86:20,22 163:6 

198:7 209:15 300:16 

saying 27:11 37:10 

118:11 184:10 205:13 

277:14,20 309:18 

334:1 347:13 353:10 

397:13 407:12 415:2 

415:9 425:10 437:13 

439:8 441:18 

says 24:16 37:22 

108:11 140:6 428:7 

scale 98:14,17 

scale- 179:13 

scales 149:12 179:16 

scanner 50:13 

scary 22:7 24:12 

scenario 392:7 

scenarios 75:12 

scene 408:2 

scenes 56:9 253:10 

Schaus 374:16 379:5,5 

379:7 383:7 385:11 

385:17 

schedule 141:19 144:5 

144:7,10 333:11 

459:22 460:3 

schedules 459:11 

scheme 204:8 

scheming 389:22 

school 12:10 18:18,19 

19:2 37:14 41:8 

270:22 

Schott 450:1 

Schwartz 1:20 8:16,20 

169:16 

science 5:7,15 32:21 

33:4,9 37:5 41:12 

44:18 51:22 53:22 

54:1 56:11,13 127:8 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
502 

212:13 249:17 263:5 

270:22 411:4 424:5 

424:12 

Sciences 5:5 33:2 

scientific 419:16 

scientist 44:10 54:4,4,5 

201:18 428:20 

scientists 237:16 

Scoles 341:6 

scope 69:19 83:8,20 

104:11 149:1 180:7,8 

188:18,19 199:22 

225:11 246:4 336:8 

439:15 441:22 458:19 

scopes 356:6 

scoping 104:3 

score 289:16,18 290:22 

scores 291:7 

scoring 289:1 

Scotia 272:4,6 

Scott 1:13 13:11 25:14 

57:14 58:6 121:22 

169:16 283:4 284:16 

291:13 

Scott's 427:16 

screaming 22:16 

screen 37:2 244:8 

412:12 

scrutiny 116:21 160:2 

SDC 368:12 

SDS 198:4 

se 137:1 440:13 

sea 81:7 443:4,15 

444:17 447:2 

seafood 444:12 

seal 62:2 77:6,14 99:17 

141:7 173:22 174:13 

239:5 245:3 388:4 

412:14,16 413:14,19 

414:9 417:20,21 

457:21 

search 193:2 339:18,22 

340:13 

searching 340:7,11 

376:7,18 

season 46:4 47:6 87:21 

119:17 203:2 240:3 

275:16 279:12 330:15 

381:19,20 396:3 

399:13 407:13 

seat 7:20 12:6,20,21 

13:11,17 14:2,13,17 

201:18 229:7 243:10 

243:11 

seated 55:14 

seats 8:18 96:21 

Seattle 429:22 

seaweed 152:20 153:11 

153:22 271:3,5,8,10 

272:2,8,10,16 275:20 

276:7,8 277:13,14,15 

278:4,22 368:6 386:4 

386:6,9,14,18 442:21 

443:7,17 445:1,3 

seaweeds 225:2 279:9 

444:6 447:19 

second 14:2 20:22 30:7 

46:15 52:18 69:3 72:7 

78:18 80:16 82:10 

88:17 105:5 107:7 

114:6 119:21 145:5 

153:20 204:2 352:9 

387:7 428:12 

Secondarily 303:4 

secondary 307:13 

Secondly 399:16 

402:18 

seconds 31:16 

secret 253:9 

secretaries 26:10 

secretary 1:13 9:17 

100:22 101:9,15,20 

121:7 122:19 217:11 

298:2 299:5,21 300:4 

331:21 423:3 

Secretary's 3:10 57:14 

58:7 217:9 

section 129:8 150:19 

322:1,2 329:18,21 

394:17 404:6 405:17 

416:17,18 424:16,17 

460:1,4 

sections 319:1,2 

sector 31:20 115:8 

117:7 170:22 245:10 

273:4 

sectors 390:17 

secure 70:15,16 

seed 148:9,10,13 

171:13,14,18 176:1 

176:10,16 191:5,6,10 

191:15,17 192:14,17 

193:3 202:2,3,6,12,13 

202:16,18,19 205:12 

269:10,18 270:8 

339:18,22 340:8,13 

340:15 369:21 370:11 

370:13 372:16,20,20 

373:6,11,18,21 374:3 

374:9 375:2,4,5,10 

376:10,12 377:7 

378:4 384:11 394:5,7 

394:18,19,22 395:2,3 

395:4,5,9 397:14,14 

397:18,19,20 398:10 

399:8 402:6,9 403:3 

403:16,18 404:3,9,20 

405:2,7,9,19,20 406:3 

406:7,13,18 407:1 

seed-based 443:22 

seeding 178:21 

seedling 305:18 

seeds 339:21 384:4,5 

384:12 

seeing 58:5,5,8 98:21 

111:2,3 118:1 143:11 

175:7 198:22 211:5 

287:14 295:4 305:4 

410:9 418:10 

seek 116:5 213:11 

348:1 379:16 380:4 

381:4 

seeking 39:6 81:8 

115:15 325:12 388:4 

Seeley 265:19 270:14 

270:15 271:15 273:20 

275:1,18 277:2 

278:20 279:22 446:22 

seen 47:16 78:3 80:18 

138:9 219:5 250:14 

292:8 349:4 363:4 

367:11 404:15 416:3 

417:11,12 444:14 

segment 451:18 

segments 259:8 

Seitz 1:21 12:19,20 

248:17 249:8 254:13 

275:9 324:11 325:16 

326:1 414:22 

select 248:17 

selected 21:12 56:1 

291:2 

selection 46:6 56:3 

290:14 

self-sufficient 29:3 

sell 19:22 20:2,8 255:6 

255:11,13,15 343:21 

345:3 347:6 364:14 

437:20 438:2 451:3,5 

453:13 

selling 196:16 252:10 

408:3 

seminars 46:10 

senate 15:5 20:12,21 

23:10 

senator 15:13 20:13 

23:8,9 

send 103:2 135:3,16 

445:10 

sending 126:17 426:13 

senior 23:9 37:18 

185:12 212:12 270:17 

295:11 

sensational 300:21 

sense 63:14 66:12 

73:13 75:1 82:16 

129:6 189:22 311:12 

311:21 313:11 365:14 

366:21 370:4 398:9 

416:16 436:11 447:15 

sensible 115:10 122:11 

sensing 185:9 

sensory 295:19 

sent 21:1 101:3,8 118:5 

147:15 155:10 210:7 

413:15 416:7 

sentence 145:16 

167:21 305:9 

sentences 254:20 

sentiment 375:12 

separate 113:4,14,16 

113:19,20 

separated 279:1 318:22 

separately 111:8 112:3 

113:15 238:4 

sepsis 214:11 

September 31:10 140:4 

sequester 428:15 

Serbia 77:20 78:1,3 

Serbian 78:5,17 79:1,6 

79:20,21 84:11 

series 74:12 240:2 

serious 419:7 

seriously 305:22 

serve 4:10 12:2,20 14:9 

21:2,12 23:9 26:11 

169:12 431:5,10 

432:7 

served 5:1,4 15:1,5 

270:17 424:7 434:7 

serves 15:1 379:13 

service 2:4 4:10 15:22 

61:10 79:6 127:10 

140:8 160:11 246:17 

262:22 266:1 271:16 

272:13 314:20 377:14 

392:14 405:4 419:3 

services 442:14,19 

443:3 447:5 

serving 68:3 

session 89:9 

sessions 29:15 94:13 

set 69:20,22 124:14 

266:8 350:12 370:13 

386:11 

sets 88:20 228:19 

294:17,20 

setting 328:14 331:11 

342:5 420:21 

Settlers 444:11 

seven 19:6 28:8 146:21 

337:18 380:1 448:17 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
503 

451:16 

severe 119:18 221:5 

324:7 345:15 

sewage 447:10 

shake 121:14 

Shamrock 256:21 

Shannon 251:18 258:6 

258:7,10 

share 4:21 16:10 28:2 

33:21 35:14 47:15 

54:17 86:3 97:22 

115:19 126:22 137:10 

288:7 293:6,11,13,22 

326:13 331:6 342:12 

366:1 400:22 

shared 89:9 161:4,8 

162:12 284:18 308:20 

380:4 

shares 224:10 

sharing 28:12 294:12 

342:4 374:7 

sharp 243:4 

shear 264:7,9 

sheet 284:1 

sheets 198:4 

shelf 235:2 416:9 

shell 320:10 

Shepherd 5:6 

Shewmaker 352:10,18 

shift 40:3 

shifting 321:8 

ship 84:10 197:10,15 

shipment 196:21 

shipped 316:8,9 

shoes 313:17 

shop 319:18 

shopping 295:18 

shore 271:9 

short 18:4,5 37:17 

67:12 135:14 144:12 

170:2 178:12 220:12 

296:17 410:5 

shortened 127:21 

133:21 

shortly 85:17 

shot 20:6 

shout 41:4 

show 19:10 59:2,10 

62:11 67:9 70:20 

81:20 84:3 117:2 

255:4 419:16 428:11 

429:11 

showed 77:22 79:20 

81:19 95:6 

showing 45:22 77:17 

231:22 366:7 427:12 

429:6 

shown 444:9 

shows 212:20 366:12 

shredded 345:3 

Shrimp 444:14 

shy 322:5 

sic 94:11 

sick 214:8 297:3 

sickness 23:2 

side 6:9 38:14 92:18 

108:19 116:8 240:21 

267:8,14,15,20 274:2 

295:13,13 327:15 

328:11 423:8 425:14 

sides 274:1,5 425:14 

sidetracked 21:6 

sign 22:18 143:19 

248:1 399:22 420:20 

signaling 109:4 

signed 9:17 

significant 22:8 27:5 

45:2 109:5 164:6 

203:13 240:7 288:17 

289:15 365:2 435:1 

significantly 140:14 

silence 144:17 

silica 351:18 352:11,16 

353:2 354:4 

silicate 350:8,11 351:6 

351:11,14 352:7 

silicon 351:15,18 352:4 

352:21 

silver 157:15 368:11 

silver-based 368:14 

similar 86:20 183:20 

240:14 282:3 283:7 

292:3 348:2 382:22 

382:22 

similarities 163:6 

similarly 336:9 

Simmons 36:19 

simple 205:12,15 

250:13 325:15 

simply 70:21 107:4 

121:10 349:5 393:1,5 

393:10 407:14 408:9 

409:1 

Simultaneous 199:14 

sing 56:5 331:19 

single 68:9 106:20 

121:6 129:4 172:11 

222:10 227:7 

singular 299:13,19 

418:7 

sister 18:19 

sit 14:1,16 142:13 

205:22 250:12 439:5 

site 158:20 

site-specific 289:22 

sites 52:1 

sits 7:19 155:17 

sitting 35:21 38:11 

54:12,14 361:4 

425:22 

situation 79:13 92:20 

174:21 282:3 317:10 

412:12 413:14 

situations 364:14 

391:19 

six 21:8 28:7 34:11 35:8 

42:13 43:1,18 113:19 

231:17 319:12 333:17 

333:19 451:16 459:5 

size 230:18 

skill 67:19 

skills 36:4,4 39:13,18 

42:10,11 43:11 53:3 

53:19,20,22 152:19 

314:22 396:15,17 

skin 44:22 

skip 144:8 

skipped 372:3 

skirt 325:13 

Skolaski 459:9 

slide 81:19 244:8 

264:13 266:9 315:8 

slides 90:15 

slightly 179:3,8 315:10 

422:18 

slippery 334:20 

sliver 188:18 

slope 334:20 

slow 177:1 

slowing 189:1 

small 13:18 20:16 24:11 

30:22 36:16,17,19 

40:7 43:19 98:13 

120:4,19 121:1,2 

122:5,6,8,10 242:3 

253:22 258:15 260:17 

264:3 331:20 343:6,7 

345:10 359:1,4 

381:21 406:7 431:8 

445:5 

smaller 98:17 

smart 136:5 

Smith 367:19 372:5 

374:16,18,19 378:1 

378:12 379:1 

Smolarski 227:19 

232:14,15 236:5,14 

snaps 264:8 265:11 

snapshot 65:13 66:9 

sneak 47:20 

snow 32:16 

sobering 407:20,21 

social 37:4 53:22 54:4 

252:6 

sodium 148:18,21 

163:14 183:22 185:18 

334:14,15 336:4,13 

337:1,9 357:18,21 

361:3,13,20 365:18 

420:13 454:13 456:5 

456:7 

SOEs 199:21 200:1,2 

soft 44:22 431:5,10 

432:6 

soil 33:4,8,11,11,20 

41:11 44:10 46:17,20 

48:22 53:22 54:4,5 

87:3 119:19 159:12 

159:17 178:2,9 190:3 

225:19 305:15 351:19 

355:3 357:9 358:1 

363:10 364:10,18 

365:20 366:13,22 

399:7 408:17,17,19 

409:2 410:6,7 411:5 

420:8 438:18 448:20 

449:19,20 450:4 

451:20,21 452:4,17 

453:4 455:5 

soil-amending 438:19 

439:11 

soils 46:16 47:16 48:15 

436:2 

sold 19:19 297:14 

324:14 364:18 438:22 

sole 284:22 

solid 304:16 

Solo 24:8 

solubility 266:20 

soluble 263:9 265:13 

solution 71:6 187:2,8 

365:1 409:2 424:11 

427:14 448:15 

solutions 45:20 388:4 

solve 52:5 186:19 

solving 269:17 

somebody 36:5 66:15 

108:22 196:15 197:14 

410:18 

somebody's 20:14 

someone's 248:20 

something's 208:7 

somewhat 39:18 116:8 

121:15 300:21 346:16 

346:17 443:20 

song 331:19 332:16 

416:4 

Sonia 2:3 6:15,17 7:4 

Sonia's 7:2 

SONNABEND 201:15 

205:9 

Sonnebend 194:14 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
504 

201:16 

soon 131:20 221:21 

438:17 

sophisticated 242:3 

sorry 141:20 164:19 

169:7 182:20 211:8 

216:19 227:19 248:16 

250:20 293:4 295:5 

354:10,10 

sort 18:16 26:1 41:12 

67:9 68:17 71:19 

73:11 79:14 83:10 

100:9,11 101:4 104:5 

104:17 106:15 109:19 

110:15 114:5 115:18 

115:19 117:3,11 

119:2 122:11,22 

123:4,5,9 124:7 131:3 

132:12 137:13 185:1 

210:7 248:3,9,22 

293:19 308:13 326:13 

327:1 328:17 329:13 

362:1 390:5 415:8 

sorts 121:4 330:18 

385:5 

sound 34:3 43:19 87:1 

115:10 138:19 307:15 

382:21 

sounded 123:16 

sounds 241:11 

source 78:17 127:4 

219:2 225:2 234:4 

259:14 318:1 325:4 

351:17 365:13 366:13 

406:13 430:20 431:2 

431:11 

sourced 78:13 225:6 

421:19 434:4 

sources 64:12 181:13 

260:7 303:16 421:17 

431:18,22 432:3 

457:10 

sourcing 14:16 193:2 

245:1 340:7,11 376:7 

376:18 386:14,17 

403:2 433:18 437:2 

south 49:3 

southern 8:6,12 

Southwestern 407:10 

Soviet 28:20 252:17 

soy 199:16 259:11 

soybean 30:8 223:15 

240:4 

soybeans 20:17 114:12 

221:14 

space 333:18 

spaces 385:14 

spans 229:9 

speak 29:13 144:3 

200:22 206:2 223:18 

228:2 238:5 261:17 

307:18 308:1 323:4 

334:4 346:14,17 

386:2 

speaker 145:2,8,21 

146:5,10 

speaker's 144:3 

speakers 120:8 144:19 

145:1 164:13 

speaking 145:12 160:9 

199:14 307:20,22 

409:9 

spearheading 203:7 

spec 283:22 

special 10:1,16 14:9,20 

28:19 85:10 449:17 

451:18 

specialist 2:2,6 7:8 

76:9 97:9 106:18,20 

224:1 388:19 398:19 

specialty 2:3 6:16 

153:8 435:10,13,14 

species 48:12 215:18 

218:11 278:12,19 

366:18 367:6 

specific 59:18,18 64:7 

69:18 81:5 82:15 84:1 

84:8,10,12 86:13 90:7 

101:18 125:12,13 

152:16 174:8 176:2,6 

180:3 181:6 183:4 

212:1 230:11 269:18 

288:12 290:15,15 

302:12 304:10 310:22 

329:18 331:5 336:13 

342:8 343:13 344:5 

347:4 359:2 370:5 

375:14 379:16 382:15 

384:7 413:13 435:5 

specifically 46:21 

59:12 90:20 99:2 

111:21 147:7 150:9,9 

150:15 154:14 156:5 

182:4 187:7 213:21 

230:17 237:3 241:8 

253:3 266:10 304:6 

342:10 375:6 436:13 

458:14 

specifications 173:13 

specificity 187:5 

spectrum 178:22 

269:15 365:10,12,16 

366:8 

speculating 78:6 

spell 304:20 

spells 250:7 

spend 28:16 29:5 43:16 

43:21 56:2 66:5 

118:15 271:8,11 

326:10 409:8 

spending 130:3 

spent 9:9 20:11,20 21:7 

25:16 57:8 241:4 

255:21 266:2 274:13 

413:2 449:4 

sphingomonas 267:13 

spirit 161:6 419:5 

split 231:13,17 321:9 

436:16 

spoke 28:9 

spoken 223:13 304:5 

spokesperson 29:11 

sponsored 28:10 

spot 169:7 181:6 

346:14 

spots 444:19 

spotted 44:20 45:3,8,15 

45:18 46:1,7 

spouse 19:3 29:20 

sprayed 355:13 

spread 32:8,8 213:8 

218:6 384:17 

spreads 264:2 265:1 

spring 67:2 71:19 

131:12 243:22 302:8 

Springs 14:12 

spur 403:20 

spurs 218:5 

square 38:8 

St 1:9 4:13 11:11 17:5,7 

17:8,11,12 29:14 

34:21,22 42:15,16,18 

55:5 58:16 379:12 

stability 268:10 

stabilizer 235:6 259:1 

260:14 

stabilizes 263:13,14 

stabilizing 233:3,21 

stable 235:2 382:5 

staff 2:1 41:1 56:21 

76:20 92:3 93:4 

139:16 153:17 169:11 

195:22 250:5,16 

251:12 396:16 407:9 

419:4 

staffing 96:22 

stake 211:1 

stakeholder 192:7 

244:12 359:5 425:4 

stakeholders 44:4 

46:13 52:3 77:13 78:8 

99:9 100:7 102:10,21 

103:1 127:19 128:7 

135:13,22 160:21 

182:21 187:12 193:10 

407:9 420:2 422:12 

423:7 457:14 

stance 200:10 

stanchions 144:22 

stand 4:18 230:4 

333:13 410:7 

standard 77:15 90:15 

91:15 152:21 153:5 

153:18 186:5,12 

226:19 238:6,9 

272:18 330:9 335:2 

336:7,19 368:9 

370:11 387:11 388:5 

406:20 443:15,21 

444:1 445:22 446:8 

454:17 458:3 

standardization 66:19 

standardized 114:4 

125:3 

standards 1:3 2:4 4:6 

4:16 6:2 7:15 11:6 

62:5 63:2 85:8,20 

89:12 96:13,16 

137:21,22 138:2,4,20 

150:4 154:4 156:12 

162:15 174:17 175:9 

187:5,6 191:8 206:15 

224:15,19 225:3,14 

228:1 230:18 238:7 

238:18,19,20 239:14 

239:15 246:7,13 

259:4 274:11 292:14 

296:12,18 297:8 

299:13 304:17,19 

322:4 346:6 356:17 

368:6 382:2,10 

388:22 443:1,6 

454:16 

standing 206:10 363:17 

stands 206:11 

Stanford 300:13 

Star 407:11 

stared 22:20 

start 4:14 11:20 55:4 

58:18 61:19 68:2 

141:20,21 142:15 

145:11,17 146:15,17 

169:8 177:16 180:15 

190:16 191:13 201:13 

212:9 220:4 223:21 

227:21 236:17 243:16 

244:3 251:19 258:8 

262:20 265:19 267:22 

270:13 280:3 287:19 

291:4 295:9 302:2 

314:12,18 320:22 

334:2,6 338:12 343:2 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
505 

355:22 362:22 370:12 

372:5 374:17 379:4 

379:15 385:20 389:10 

393:17 398:15 402:3 

410:11 418:15 427:2 

442:9 448:2 454:6 

459:5 

started 4:4,22 9:8 40:7 

40:8 57:7 70:21 73:19 

74:14 78:6 142:7 

203:15 232:1 243:12 

292:16 

starter 292:13 

starting 39:3 73:7 85:11 

176:11 188:16 281:16 

281:21 282:15,19 

291:19 459:6 

starts 62:8 132:18 

state 13:13 17:19 19:1 

20:12,12 27:1 30:6,20 

30:21,21 31:1 32:9 

33:8 34:14,18 37:14 

41:11 44:4 45:2 46:9 

50:8,13 51:8 58:20 

60:11,16,18 150:15 

155:10 156:21,21 

157:3 211:2 256:2 

271:2 276:19 351:9 

353:22 367:20 409:12 

415:3 438:20 

state-level 60:4 

stated 99:5 124:4 

150:20 158:7 192:15 

226:15 339:20 364:12 

457:20 

statement 256:20 

379:10 384:20 

statements 207:4 

states 1:1 23:10 26:11 

26:12 30:12 49:7 

71:16 121:8 174:22 

224:9 229:9 254:2 

277:8 302:6 315:5 

317:11 349:13,18 

351:16 383:11 394:17 

410:16 412:15 451:10 

static 291:5 

stating 105:9 156:20 

157:16 400:1 

Station 5:12 

statue 140:6,6 

status 171:4 209:22 

229:16 281:12 282:16 

283:1 287:12 364:22 

457:16 

statutory 104:22 106:1 

117:11 124:5,9 423:2 

stay 177:8 194:3 221:17 

403:21 451:20 

staying 98:15 135:18 

290:10 

stearate 235:20 

steeped 11:13 

step 149:8 286:1 393:6 

393:10 445:8 

Stephanie 343:1 350:5 

350:6 

stepping 27:11 292:9 

steps 86:8 281:20 

282:4,14 293:21 

456:14 

Steve 1:16 12:14 

127:13 163:17 164:9 

165:10 187:15 199:2 

246:21 269:8 308:10 

309:19 346:16 347:10 

360:17,22 365:6 

414:21,21 415:18 

436:5 437:7 450:20 

451:22 

stewards 444:10 

stewardship 220:11 

408:18 

stock 148:11 153:5 

155:4,6,9,14,16 156:4 

156:4 313:8 364:19 

394:7 

stocking 256:11 427:21 

428:5 

stocks 87:16 

stomata 355:8 

Stone 343:5 

stop 87:22 165:16 

190:9,11 230:7 

265:11 318:6 364:4 

431:20 456:20 

stopped 130:8 209:13 

298:9 

stopping 358:15 

store 84:9 414:16,16 

415:7 

stores 319:18 410:15 

413:18 415:21 418:5 

storing 412:3 

storm 52:7,8 

story 18:5,15 37:17 

257:11 296:8,15 

297:17 301:2,8 

straightforward 57:3 

strategy 81:3 89:10 

344:1,7 387:4 

Straus 418:20 427:4,5,6 

429:18 430:1 431:4 

432:4,6,12 

strawberries 45:4 

363:14,18 

stream 73:1 182:15 

303:18 344:12 455:21 

streamlining 96:14 

strength 16:6 453:5 

strengthen 89:10 

192:20 296:18 394:5 

strengthening 65:7 

97:19 191:5 192:14 

202:2 228:15 375:1 

387:8,19 

stress 265:10 397:5 

398:22 

stretch 66:11 

strict 206:9 231:16 

359:7 378:9,14 

strides 35:18 

strings 72:8 

strips 345:6 

strive 31:19 

strong 31:5,14,18 33:15 

54:9 62:14 63:8 76:15 

77:1,7 94:4 137:20 

172:4 186:12 228:8 

235:18 296:11 348:5 

388:3 

stronger 92:14 394:16 

404:10 

strongest 166:3,22 

strongly 60:21 61:16 

148:7 164:11 178:18 

202:13,15 203:5 

232:22 234:6 355:2 

368:10 394:4 395:18 

396:1 399:11 

struck 22:12 

structural 353:16 

structure 28:17 353:12 

364:8 

structured 270:1 

struggle 163:20 

struggling 47:17 167:4 

student 36:11,20 40:14 

42:22 

students 34:18 35:8,20 

36:5 38:22 40:22 

41:20 42:3,7,22 43:3 

43:10 52:16,20 53:3,9 

53:18 54:17 

studies 56:13 300:18 

300:20 301:15 350:16 

352:5 354:18 

study 37:8,12,15 77:19 

77:19 83:10 162:9 

180:5 216:7 300:12 

301:3,4,12,13 351:14 

352:7 

stuff 128:14 130:13 

132:22 133:1 183:3 

416:16 436:16,18 

437:2,5 438:14 

439:19 

sturgeon 444:13 

stylized 413:19 

subcommittee 115:22 

120:13 128:3,17 

130:8,10,11 131:2 

135:16 136:12,21 

143:13 154:5 161:2,5 

163:4 172:13 176:18 

179:18 187:17 191:4 

192:2 237:6 280:7 

285:15 286:2 296:19 

309:22 340:17 348:7 

350:10 357:11 376:20 

377:8 399:14 402:13 

402:19 406:2 407:2 

421:5 423:14 424:19 

subcommittee's 117:19 

132:14 161:15 191:5 

215:11 224:3 232:19 

233:1,17 234:18 

280:10 339:19 375:1 

375:3 405:16 

subcommittees 10:12 

424:22 

subject 277:5,10 339:2 

339:18 341:8 440:10 

submission 347:20 

348:11 

submit 82:8 194:10 

200:8 211:17 225:22 

226:4 229:1 236:12 

246:3 343:12 344:4 

346:6 

submittal 346:22 

submittals 82:19 

submitted 230:11 237:8 

266:17 269:5 272:20 

299:9 312:21 338:21 

343:10,17 351:20 

363:4 376:15 392:11 

414:19 417:21 442:19 

submitting 302:10 

subscribe 244:20 

subscriber 248:14 

subscribers 248:8 

subscription 247:21,22 

248:4 

subscriptions 248:5 

subsequently 390:8 

substance 161:18 

222:4 225:16 251:10 

259:18 260:1 261:11 

261:21 281:16 359:16 

360:13 

substances 85:17 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
506 

126:3 161:16 167:22 

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substantially 241:18 

substantiate 80:17 

substantive 123:2 

substitute 253:21 

substrate 153:12 352:9 

453:16,17,18 

success 69:4 404:22 

successes 56:8 

successful 31:13 

successfully 48:8 

successive 367:15 

succinctly 146:13 

sucker 222:3 239:22 

241:8 

sucrose 150:12 194:22 

sudden 37:6 

Sue 1:14 14:6 180:16 

182:19 

suffering 271:22 272:3 

430:8 

sufficient 81:4 91:17,18 

286:19 346:21 348:11 

456:17 457:7 

sugar 267:11 

suggest 135:15 281:8 

283:9 310:9 392:19 

420:21 422:19 437:11 

suggested 151:6,21 

155:2 156:17 164:13 

166:8,10 273:21 

422:16 449:18 

suggesting 151:17 

422:19 

suggestion 217:7 

371:14 386:20 

suggestions 101:1 

188:3 383:2 433:12 

suggests 215:15 

233:15 

suicide 255:9 

suit 404:3 

suitable 199:7 234:4 

259:14 

suitcase 140:16,17,17 

141:8 

sulfur 224:5 225:15,17 

226:3,8 

summarized 147:19 

summarizes 91:10 

summarizing 94:2 

summary 57:22 299:8 

summation 215:9 

424:18 

summer 70:6 103:16 

211:22 

sunflower 351:17 

sunflowers 351:15 

sunset 147:7 150:22 

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423:22 424:8 426:12 

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super-complex 293:15 

superior 235:11 

supermarket 316:15 

320:4 

supervisor 372:10 

supplement 170:22 

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supplemental 75:9 

supplements 170:5 

174:8 

supplier 397:20,20 

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supply 16:5 62:21 69:7 

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93:10 147:4 172:16 

236:20 237:2 238:5 

319:4 350:16 401:14 

414:11,17 418:9 

429:3 455:11 

support 53:17 63:2 

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115:7 148:12 158:5 

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202:13,15 203:5 

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387:18 388:1 394:4 

396:8,12 400:4,13 

402:14 403:7 404:8 

430:17 448:12 

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303:11 

supporting 4:17 75:18 

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228:17 288:2 363:6 

supportive 31:20 

380:10 402:12 

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86:11 148:7 149:6 

161:14 178:1 192:16 

202:3 229:12 232:18 

232:22 233:17 234:7 

258:20 372:21 376:14 

404:5 454:14 

suppose 24:1 

supposed 253:8 313:1 

Supreme 276:4 

surface 172:2 352:14 

354:1,12,13 

surplus 430:4 

surprise 55:20 

surprised 56:7 200:14 

214:14 378:8 

surprisingly 50:5 98:12 

surrendered 81:8 

195:10 196:17,21 

197:11 

surround 183:20 

surveillance 73:20 74:6 

79:19 125:16 387:16 

survey 31:10 147:14 

151:1 339:1 341:7,9 

341:19 342:5 

surveys 150:21 

survival 217:16 

survive 48:10,13 

217:19 219:6 316:9 

364:17 

survived 22:9 23:17 

survives 38:3,7 219:4 

suspect 214:13 

suspend 259:9 

suspended 195:11 

suspending 233:22 

suspends 265:7 

suspension 64:22 

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268:6 289:10 327:8 

360:5,6 

suspensions 268:5 

sustainability 8:4 180:3 

180:6,11 225:1 274:9 

304:9 357:12 436:8 

444:5 

sustainable 5:8 33:16 

33:17 36:12 39:2 

40:11,18 41:3,6 53:6 

186:13 220:21 225:7 

270:20 307:12 314:16 

410:3,4 

Swaffar 1:22 13:16,16 

103:14 105:5 106:4,7 

115:21 165:19 166:4 

166:8 194:9 199:19 

200:7 215:14 216:10 

216:13,19 217:6 

298:16 300:2,7,8 

322:14 323:2 358:9 

401:11,18 

swallowing 265:8 

swarm 172:2 

sweet 221:14 241:21 

309:19 

sweeter 320:17 

swiftly 230:21 

switch 89:17 

syneresis 263:11 

synergy 181:4 

synthetic 87:6 88:4,21 

183:14,14 200:17 

222:8 240:21 280:18 

280:22 283:9,17 

284:2 320:11 344:10 

455:7 457:4 

synthetically 455:4 

synthetics 190:1 

310:20 

syrup 421:20 

syrups 263:21 

system 6:21 59:16 

67:12 68:18 70:2,4,22 

71:9,16,21 72:13,19 

72:21 73:2 75:15 

89:22 90:12 93:17 

94:8 95:5,13 97:21 

101:5,10,14 115:14 

120:21 121:14 133:17 

138:5 147:22 152:8 

158:11,17,18 161:9 

171:16 183:16 186:11 

242:20 288:18 289:1 

289:11 294:20,21 

295:22 296:9,11 

304:6 305:2 308:3 

317:16 349:21 353:21 

376:4 384:18 395:11 

397:22 398:6 399:4 

413:4,22 414:4,12 

415:16 416:12 434:16 

434:19 448:9 451:1 

452:14 453:12,15,18 

453:19 

systematic 351:3 354:2 

354:4,7,8 

systemic 90:22 214:11 

354:9,10 355:3 381:5 

systems 12:18 33:12 

33:20 41:17 42:10 

46:2 49:8 54:9 62:15 

63:9 65:4 70:15 72:10 

72:10,15,22 73:4 80:5 

91:9 94:5 97:7 111:13 

138:18,18,19 158:19 

159:18,19 224:19 

256:7 339:15,17 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
507 

346:3 

systems-level 90:9 

T

tab 111:14,16 256:18 

table 54:14 203:11 

229:7 231:7 296:3 

tabled 119:3 

tables 61:4 

tack 90:5 

tackling 50:11 

tag 395:3 

tags 202:14 

tailored 380:5 

take-home 169:21 

171:2,20 

take-homers 80:6 

taken 29:21 35:18 

136:13 161:3 237:5 

290:17 302:10 325:2 

351:19 352:11 353:19 

353:20 385:13 

takers 27:3 

takes 75:22 76:18 85:6 

129:10,11 131:15 

136:20 141:1 202:22 

290:6 376:22 426:4 

talk 26:15 35:3,9,11,11 

35:13 54:2 65:5 66:7 

70:4 75:2 82:19 98:12 

100:16 117:1,17 

163:12 176:17 212:16 

216:4 227:8 266:6 

275:3 315:2,12 

405:10 428:13 431:1 

433:4 

talked 106:11 122:2 

125:18,19 135:20 

168:12 209:22 266:5 

363:16 433:6 435:20 

446:22 

talking 6:21 37:10 

56:21 73:19 116:1 

137:6 139:1 157:3 

198:13 217:22 219:11 

249:6,7 263:1 266:3 

266:10,14 267:6,9 

276:14 297:17 312:13 

425:12 434:21 452:7 

458:4 

talks 46:12 283:14 

tamarind 269:10,18 

270:8 

tangible 255:5 

TAP 281:1 

tape 176:16 

tapes 179:9 399:8 

targeted 367:5 

tariffs 26:21 

task 31:22 52:1,1 

350:12 

taught 5:6 19:1,12,13 

39:7 41:10 396:18 

taxonomy 60:22 

Taylor 355:21 362:20 

362:21 363:1 

teach 15:16 35:8 43:5,9 

43:10,13 

teaching 53:9 

teal 413:19 

team 4:15 6:2 7:2 32:3 

55:16 76:20 129:3 

227:8,12 326:18 

404:15 

teams 77:8 379:21 

teased 273:9 

tech 56:14 161:9 

technical 32:5 85:19,22 

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171:6 176:19 178:13 

187:18 188:11,20,21 

189:20 235:13 236:6 

236:8 237:11 244:15 

244:21 245:8 247:13 

248:7,18 249:3,7,8,22 

250:1 251:7,9 259:3 

262:17,22 266:1 

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363:6 372:9 380:3 

381:9 454:10 

techniques 369:11,16 

technologies 399:2,5 

technology 56:13,18 

69:7 70:7,8,18,18 

71:1,3,6 76:21 97:18 

126:5 127:8 

tell 6:3 7:21 16:15 

163:11 164:20 166:6 

205:11 239:7 249:18 

275:4 278:3 301:14 

307:9 322:7 331:7,18 

337:21 349:16 353:15 

356:6 380:12 410:18 

416:22 434:13 

telling 196:18 197:13 

252:12 296:15 298:11 

301:9 321:13 322:6 

tells 296:7 

temperature 263:15 

template 111:15 

temporarily 123:18 

tempting 365:13 

ten 42:19 225:7 256:5 

318:17 319:12 332:12 

363:14 430:4 

tend 70:19 72:2 163:19 

201:6 301:11 

tens 324:6 

tensions 276:18 

term 20:22 21:9 22:21 

23:14,18 182:5 

230:10 238:5,13 

239:2,13 367:16 

385:10 458:13,18,20 

terminology 203:6 

terms 15:6 18:16 20:20 

23:17 93:1 108:2 

112:11 117:7 118:22 

119:3 124:8 126:3 

131:6 178:5 182:4 

183:20 186:19 189:10 

274:17 284:10,11,18 

284:20 285:1 293:20 

300:21 328:18 340:4 

361:3 363:5 423:4 

terrific 6:6,8 

territories 229:10 

territory 331:13 

test 58:15 68:17 122:8 

191:15 

tested 124:21 126:4 

testing 92:5 93:19 

124:19 125:1,7,8,10 

125:11,14,15,17,19 

126:1,15 127:2,10 

374:7 377:10 397:19 

403:9 

tests 364:18 

texture 235:3 269:22 

texturizer 235:8 

texturizing 233:4 

260:15 

thankful 448:10 

thanking 314:18 

thanks 34:2 57:15 

79:10 89:14 91:22 

102:15 103:14 122:1 

128:11 130:11 154:7 

154:19 157:13 160:4 

163:8 194:12 212:6 

220:1 226:11 227:15 

227:17 242:6 283:5 

284:16 287:21 291:14 

323:2 326:3 355:19 

356:1 378:1,21 

401:22 405:15 426:22 

440:21 454:8 

theft 109:8 

theirs 82:13 

thematic 421:11 

theme 185:9 370:10 

themes 356:11 

theories 354:12 

theory 425:22 

thereof 121:16 

thicken 235:3 

thickener 235:6 259:1 

260:14 

thickeners 258:19 

thickening 233:3,21 

263:6 266:12 269:20 

thin 121:3 265:9 345:6 

things 23:19,20 26:18 

27:15 39:14 42:11 

44:5,11 46:2 47:10 

92:11 106:22 108:11 

109:18,21 117:4 

127:20 129:18 130:6 

139:22 158:4 164:1 

176:16 177:2 188:15 

191:1,11,17 199:17 

203:9 214:9 238:16 

240:5 264:17 275:17 

311:10,15 326:21 

332:7,12,13 350:1 

365:20 385:9 417:17 

419:15 433:5 440:15 

446:20 447:6,15 

thinks 160:19 

thins 265:9 

third 13:14 14:5,13 

73:15 106:4 164:15 

184:7 223:15 225:6 

388:15 

third-party 262:4 

286:10 

thoravin 338:2 

thorough 98:8 152:14 

188:21 193:11 286:13 

287:2 363:5 424:2 

thoroughfare 447:11 

thought 18:11,13 20:14 

21:2,8 22:14,17 64:6 

88:14 104:1 114:14 

157:11 164:4 191:10 

193:6 208:15 217:17 

304:16 326:17 331:15 

332:22 336:9 385:2 

422:9 426:16 

thought-out 192:12 

thoughtful 45:20 

398:20 

thoughts 227:12 247:1 

247:9 273:17 278:19 

371:13 437:14 446:9 

446:17 

thousand 222:20 

411:20 

thousands 77:4 255:21 

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Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
508 

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thread 327:10 

threat 213:9 224:11 

408:8 

threatening 214:11 

three 8:9,11 14:11 18:6 

25:12 51:16 62:14 

66:17 82:2 103:15 

109:22 120:10,13 

126:21 139:12 145:7 

146:2,3 224:9 253:22 

288:19 289:20 293:14 

359:20 360:15 364:12 

381:8 383:21 388:6 

388:14 402:11 415:13 

432:7 444:16 447:7,8 

447:9,10 449:4 

three-day 9:21 

three-year 381:17 

threes 109:22,22 

threshold 370:18 

thresholds 373:3 

thrilled 110:2 

thriving 171:15 408:1 

thrown 418:2 

Thursday 459:16 460:4 

tidal 153:13,13 277:10 

tide 276:16 

tie-in 256:13 

tied 411:9 

tight 345:22 

Tilth 283:6 372:11,17 

372:21 373:1,5 

timeframe 370:13 

timely 80:7 108:2 128:6 

229:18 341:14 

times 9:11 46:8 68:5 

84:6 86:5 108:5 

129:21 283:13 288:19 

426:2 

timing 392:16 413:10 

tip 389:17 

tips 390:3 

tipster 389:21 

tired 55:11 

tobacco 221:15,20,21 

222:3,11,13,15 223:3 

237:4,9 240:10 

today 11:5 16:3 17:5 

18:8,15 27:10 28:14 

32:1,22 33:22 34:5 

35:11 38:20 43:21 

54:12,14 55:3 57:7 

69:1 98:4 144:11,11 

173:16 177:22 184:9 

220:7 224:2 228:2 

231:2 232:21 242:3 

247:14 263:2 266:4 

271:10 280:5 288:2 

302:7 315:2 334:13 

337:11 338:19 371:13 

388:22 394:2 402:11 

419:7 420:19 448:19 

451:14 452:17,21 

459:4 

told 88:17 266:11 269:7 

300:3 321:21 343:12 

443:11 

Tom 1:10,12 10:17,22 

13:8 14:14 34:2 57:15 

98:5 232:13 236:16 

236:17,19 239:17 

241:3 242:21 347:19 

425:16 

Tom's 10:18 

tomatoes 353:5 

tomorrow 10:10 54:10 

315:17 317:6,14 

459:5,9,18,22 460:3 

ton 47:3 189:20 

toners 188:14 

tongue-twister 154:22 

tons 428:15 435:8 

tool 84:14 102:14 104:2 

125:15 160:20 186:6 

286:16 291:11,20 

294:15 322:20 323:1 

323:13 342:16 380:15 

380:17 399:6,17 

412:10,10,18 414:10 

418:14 427:20,21 

tools 59:19 76:22 96:19 

134:18 204:4 343:7 

356:20 382:7 427:17 

427:19 

top 36:20 66:17 74:7 

267:16 297:3 372:18 

topic 66:9 86:14 89:3 

99:4 118:7,7 169:21 

171:2,20 180:13 

181:20 192:16 208:1 

302:9 333:5 334:19 

335:1 341:5 392:12 

topics 66:5,13,17 68:20 

85:10 93:18,19 

118:13 169:20 185:13 

402:12 

toppings 263:21 

tossed 436:21 

total 30:4 38:13 289:17 

289:18 445:5 

totaled 22:5 

totally 114:7 193:16 

227:1 

totes 412:3 

touch 35:13 79:12 

85:10 402:11 405:7 

touched 415:19 

tough 40:1 347:18 

398:12 

town 66:8 68:16 97:14 

418:19 447:10 

toxic 412:5 419:19 

420:14 

TR 156:20 158:7 162:1 

163:15 177:6,7 188:5 

189:2,4 280:16,16,20 

282:10 283:9,12 

284:1,5,13,19,21 

285:5 360:19,21 

395:13 437:11 

TR-2 175:8 

trace 203:1 403:10 

traceability 62:16 66:19 

69:4 70:3,10 85:4 

94:19 95:5,10 

traced 71:11 444:20 

track 42:4 195:7 216:16 

325:1 398:7 

tracked 101:11 422:11 

tracking 333:16 

tracks 358:13 

trade 63:13 77:21 78:13 

79:19 80:15 95:9 97:7 

137:7 169:14,22 

171:13 172:14 177:21 

178:1 183:9 315:13 

315:14 417:4 449:10 

trade's 80:10 

tradeoffs 118:14 

traditional 258:19 

411:3,6 

traditionally 42:11 

336:5 

tragacanth 235:20 

trail 93:8 329:11 

train 93:4 153:15 

trained 41:20 250:16 

training 5:9 35:19 36:1 

67:17,22 68:7 81:16 

93:2,3 94:8,12,13 

96:10 97:12,16 108:4 

108:4 126:14 181:20 

181:21 196:5 205:10 

244:7 330:11 340:18 

340:22 341:8,16,16 

342:7 380:5 396:10 

trainings 290:7 

traits 351:17 352:8 

transaction 71:13 

transactions 70:13 

transfer 218:19 

transferred 176:8 

transformation 220:21 

transforming 220:19 

404:21 

transition 79:7 115:12 

148:16 220:16 325:8 

359:21 381:10,17 

382:4 383:17 

transitioned 324:13 

325:18 

transitioning 50:21 

transmit 71:15 

transmitted 73:1 

transparency 63:4 85:9 

116:10,13 127:16 

138:10 150:10 175:21 

176:9 191:4,9 370:4 

372:16 373:17 387:21 

393:9 396:20 402:21 

407:3 420:2 

transparent 135:9 

139:6 229:19 419:11 

transplant 305:16 

452:8 

transplanting 339:5 

346:2 395:11 399:4 

452:15 

transport 316:10 

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transporting 412:1 

transposons 369:14,15 

369:17 401:18 

travel 28:16 243:21 

traveled 11:7 21:13 

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tray 453:15 

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treated 116:15 163:14 

297:12 456:7,9 

treatment 60:19 105:10 

159:18 164:5 195:3 

366:2,4 400:6 

treatments 364:2 

tree 282:1 283:11 

284:12,18 285:2 

286:4 

trees 155:17 

tremendous 57:1 127:1 

tremendously 31:14 

trending 95:20 

Tri-National 25:18 26:6 

trials 237:11,12 240:2 

241:13 354:5 404:12 

404:17,18 

tribal 89:6 

tribe 89:8 

Tribune 407:11 

tricky 37:7 

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Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
509 

328:15 

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323:22 

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truck 22:3 

trucks 412:2 

true 154:4 213:16 

218:10 320:9 390:11 

421:13 422:1 436:22 

458:18 

truly 378:5 437:4 

trust 57:1 229:17 

272:13 277:13,22 

392:9 393:8 424:12 

trusted 62:20 63:9 

70:16 

truth 298:12,12 

try 49:7 57:17 99:9 

102:12 114:19 131:7 

144:8,10,15 145:1,15 

151:19 152:1 166:1 

177:4,5 189:12 223:7 

287:8 304:22 311:9 

311:14 317:3,3 417:6 

426:19 

trying 36:7 38:1 46:18 

52:5 53:2,17 99:8 

113:10 186:6,19 

195:7 203:21 207:15 

208:18 210:17 240:5 

270:4 310:12 312:11 

313:5 344:1 377:20 

425:22 427:17 429:10 

Tucker 2:7 4:3,7,21 

5:22 6:8,20 7:10 8:15 

9:15,20 10:22 14:19 

17:2 55:22 56:3,10 

57:1 58:10,11,14 59:3 

59:7 65:11 99:12 

101:3 102:16 103:21 

105:16 106:13 110:21 

113:13 115:5 116:20 

118:2 119:15 121:18 

122:14 124:1 125:6 

127:5 128:11 136:2 

137:11 139:11,21 

140:21 141:5 142:9 

160:17 161:5 185:9 

209:19 252:2 255:3 

305:19 308:11,19 

309:16 326:9 331:17 

Tucker's 56:9 

Tucson 11:10 58:1 

tunnel 48:10,13 

tunnel's 48:13 

tunnels 46:3,3 47:4,5,8 

47:11,13,16,21 48:6 

49:4 

turkey 30:8 

turkeys 297:12 

turn 8:18 10:11 21:6 

77:16 82:18 84:17 

98:5 214:19 276:7 

279:13 328:18 

turned 21:9 

turns 64:4 108:12 197:3 

TUV 449:22 

twelve 319:13 321:18 

twenty 289:9 428:15 

twice 112:8 128:16 

twin 11:14 17:8 22:12 

23:13 27:19 51:7 

408:1 

twine 163:14 

two 7:14 9:22 14:20 

15:5 18:5 19:20 20:16 

20:20 23:17,21 25:12 

34:20 78:9 80:6 90:15 

97:10,15 98:20 

105:11 106:11 133:3 

151:4,21 153:15 

169:20 184:2,6 185:5 

190:22 191:17 203:13 

214:20 243:3,4,21 

267:6,15 274:1 

318:21 320:16 323:9 

323:19 325:1 329:5 

348:22 352:5 358:13 

363:21 380:8 383:1 

388:11 411:19 415:13 

419:15 420:15 425:11 

437:9 449:4 450:10 

two-thirds 231:21 

two-way 160:20 

type 112:11 152:1,6 

403:13 406:11 434:2 

451:1 

types 82:10 109:6,8 

126:3 151:16 179:1 

182:3 267:7 268:14 

269:21 288:13 300:19 

313:21 314:1 458:18 

typical 106:10 260:16 

456:15 

typically 48:10 113:1 

249:12 251:7 313:4 

410:22 

typing 295:5 

Tyson 298:8 

U

U 44:18 49:20,22 50:1,2 

U's 50:1 

U.S 15:13 16:8 23:8 

83:1 84:15 147:1 

164:14 172:16 200:1 

212:20 215:17 216:13 

216:14,15,16 229:10 

245:9 271:4 272:12 

317:17 318:2 334:12 

374:22 411:20 436:15 

440:1 449:11 451:13 

uber-clear 378:19 

UC- 12:9 

UCLA 8:2 

ultimately 72:6 213:7 

373:10 413:7 

UMN 33:9 

unable 381:16 

unacceptable 221:2 

322:9 

unanimous 422:15 

unanimously 245:12 

unannounced 74:4,5 

290:14 291:2 

unaudited 414:5 

unavailable 215:1 

376:12 

unaware 197:18 

uncertain 329:17 

330:21 

uncertainty 329:2,15 

330:3 331:16 

uncertified 75:8,10 

196:22 

unclear 182:8 199:6 

242:7 280:19 284:7 

337:4 375:16 455:11 

under-utilized 160:18 

undergo 281:17 

undergraduate 41:18 

53:2 

underground 158:19 

undermine 77:4 

underneath 416:10 

417:9 

underscores 403:2 

Undersecretary 55:18 

101:9,15,21 

understand 36:6 49:7 

49:15 51:2 53:21 64:2 

128:4 134:14 201:1 

203:10 225:8 243:22 

249:16 264:14,18 

269:12 278:13 325:19 

326:17 362:4 371:18 

415:1,1 417:8 422:12 

422:17 449:10 

understandably 79:22 

129:12 

understanding 28:17 

115:3 186:22 187:13 

212:19 213:19 214:17 

222:21 271:6 344:8 

353:18 411:6 450:2 

understood 92:6 249:9 

251:4 365:21 367:17 

underwater 271:8,12 

underway 408:21 

unethical 392:1 

unexpired 21:9 

unfold 82:18 348:18 

unfolds 133:16 264:8 

unfortunately 213:16 

236:5 352:16 363:17 

Unger 177:16 190:17 

190:18 194:5,12 

unheard 363:15 

unified 72:11 228:9 

333:5 342:20 

uniform 316:15 388:4 

uniformly 216:9 

unifying 387:8 

unintended 149:3 

unintentionally 336:14 

Union 15:7,8 21:7,13 

28:20 105:12 317:11 

unique 15:22 84:16,17 

113:18 138:12 174:21 

188:22 233:3,20 

234:8 235:13 259:6 

259:16 260:9 263:4,8 

263:11 264:5,19,21 

265:3 266:8,12 

267:19,21 268:9,16 

269:21 387:10 

united 1:1 23:9 26:12 

30:12 71:16 121:8 

174:22 232:6 302:6 

315:4 317:11 349:13 

349:18 412:15 448:20 

451:10 

universal 231:13 

universally 342:13 

universe 73:12 

universities 40:8 43:12 

44:6 248:9 

university 2:15 5:6,15 

5:17 10:7 12:17 13:5 

18:20,22 19:1 31:17 

32:14,21 33:3,6,8 

34:14,17,19 36:7 

40:16 41:1 44:1,7,14 

49:22 51:5,12,20 52:3 

53:1 56:11,12 211:21 

270:16 271:1 272:4 

unknown 344:22 395:7 

unmanaged 392:10 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
510 

unnecessary 371:2 

unpopular 200:12 

unrealistic 338:4 395:2 

unreasonable 383:19 

unstickered 416:8,9 

untreated 456:10 

untrustworthy 252:17 

unusable 345:20 

unused 345:20 

unusual 106:12 

unwanted 403:10 

unwilling 85:2 

unwinds 264:7 

up-to-date 80:11 

upcoming 122:2 

update 10:8,9 98:9 

117:22 172:1 185:12 

updated 337:8 

updating 126:1 

upfront 383:13 

uphold 100:3 

upland 277:6,9 

upped 63:12 

Upper 209:10 407:14 

uptake 355:7 

urban 27:14 43:1 

urchins 444:17 

urge 149:9,15 193:3 

215:9 229:14,21 

296:20 346:7 348:16 

368:11 370:6 400:15 

urgently 220:22 

urges 213:21 261:10 

USA 25:22 363:2 

usage 171:13,18 

215:18 376:10 

USDA 5:11 25:19 31:9 

34:4 55:15 62:1 88:8 

88:9 99:15 100:10,21 

101:5,7 104:20 106:2 

114:18 117:8 131:14 

133:7 156:11 173:22 

174:12 210:5 213:16 

213:20,21 214:17 

215:9,19 229:13 

239:4 245:10 253:2 

253:15 256:22 296:5 

296:21 298:1 322:6,7 

332:5 338:16 357:20 

388:3 412:14 413:14 

457:21 

USDA's 4:9,10 61:20 

79:5 358:19 359:5 

use-up 399:12 

useful 104:5 110:14 

113:9 117:14 306:3 

341:18,21 397:11 

405:10 

usefulness 397:8 

users 70:16 

uses 162:3 176:15 

178:4,9 212:13 

284:20 313:9,10 

458:18 

usually 121:2 131:18 

202:17 260:18 453:16 

utilize 32:4 289:1 399:2 

utilized 351:12,21 

352:9 373:14 

utilizing 443:21 

V

vacancies 97:1 

vacant 91:5 

vacated 97:4 

vacation 418:19 

vacations 418:5 

vaccine 399:22 400:5 

401:12 

vaccines 163:12 193:18 

193:20 370:19,21 

371:1,2 399:17,19,21 

400:1,5,7,8 

vagueity 378:15 

valid 339:22 

validated 66:11 

validity 70:12 83:15 

Vallaeys 287:17 295:10 

295:11 299:2 300:6 

301:1,21 

Valley 257:5 379:13 

459:12 

valuable 57:11 139:7 

221:16 246:17 397:15 

value 30:6 31:6,10 

239:6 289:3,9 292:16 

304:8 380:14 443:17 

444:5 

values 316:2 

variables 109:17 210:8 

331:4 

varies 353:2 

varieties 403:21 

variety 179:12,15 

205:14 220:13 225:18 

233:22 350:18 371:5 

394:19 404:17 405:21 

various 113:8 140:18 

179:16 254:18 259:7 

261:1 366:19 

vary 50:16,17 

varying 105:13 387:11 

vast 434:14,17 

vegans 259:15 

vegetable 8:22 13:19 

221:15 252:11 355:12 

379:16 407:10 443:15 

447:2 

vegetables 50:15 

407:15 443:4 

vegetarian 170:3,10 

vegetarians 234:5 

259:15 

vegetation 335:4 

veggie 395:12 

vehicle 103:12 252:7 

venue 17:13 

verifiable 80:19 

verification 227:2 

373:13 386:7 

verifications 225:1 

verified 76:8 117:9 

225:6 414:12 

verify 70:12 78:20 

83:17 93:10 117:9 

138:14 225:13 226:17 

293:18 457:15 458:1 

Vermont 393:20,21,22 

395:13 398:18 

verse 416:4 

version 72:7 90:14 94:7 

282:18 341:19 413:19 

426:11 

versions 430:18 

versus 180:7 187:4 

238:3 280:22 325:5 

375:15 376:8 384:8 

384:10 429:9 

verticillium 364:6,9 

vet 128:8 229:4 

vetch 37:19 38:3,15,17 

veterans 5:9 

vetted 229:2 

viability 168:3 

viable 39:21 364:9 

429:12 

Vice 1:13 12:7 169:13 

video 271:12,14 

view 27:12,14 59:10,14 

60:10 90:9,12,22 

119:16 120:1 121:15 

331:11 359:16 422:8 

422:17 423:12 424:16 

456:12 

viewed 175:7 252:6 

438:10 456:18 

viewpoint 327:21 

328:20 

views 60:7 422:21 

423:13 425:7 

Vikings 17:22 

Village 26:1 

Vineyards 205:22 

violated 84:2,4 

violating 108:21 

violation 84:1,6 359:12 

violations 76:8 109:6,7 

109:8 111:2 322:1,3 

323:19,20 

virgin 180:22 182:4 

303:20 448:19 

Virginia 5:12 56:13 

virtual 66:8 68:16 97:14 

virtually 275:19 

virtue 391:22 

viscosity 235:11 263:16 

visibility 191:19 

vision 71:5,17,18 72:7 

visioning 70:2 72:1 

visit 255:18 

visited 255:19 275:5 

visits 102:20 290:14 

294:22 

visualization 59:19 

vital 76:17 

vitally 399:1 

vitamins 259:10 

vitro 369:16 

vivo 116:6 

VOF 399:20 

voice 121:16 161:9,11 

161:15 228:9 232:6 

333:5 335:14 423:9 

voiced 425:13 

voices 58:13 120:7 

147:3 201:19 220:19 

425:5 

volume 20:9 457:2 

volunteered 57:8 

Von 450:1 

vote 229:5,6 230:5 

422:14,15 426:3,11 

voted 166:12 317:17 

361:7 420:15 426:10 

votes 20:16 346:11 

422:21 

voting 422:22 426:6 

vows 22:22 

vulnerable 271:12 

W

wait 360:5,15 

waited 55:13 

waiting 135:4 142:9 

255:4 276:10 433:11 

Walden 270:12 280:2,4 

280:5 283:12 285:13 

286:20 287:15 

walk 62:10 63:5 131:7 

333:14 

walks 411:16 

wall 140:5 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
511 

Wallinga 205:19 212:10 

212:11 215:17 216:11 

216:15 217:2,12,21 

218:15,22 219:8 

220:1 

waltzes 254:5 

Wanda 262:16,19 

265:18,19,22 268:19 

wanted 36:11,21,22 

37:8 41:4 52:22 86:2 

98:12,19 119:11 

122:9 123:14,20 

131:3 150:15 152:16 

153:2 154:11 157:7 

163:6 176:5,13 185:5 

186:21 191:1 198:17 

231:5 239:19 274:7 

308:11 313:18 315:9 

317:15 356:10 377:17 

381:10 428:12 439:13 

457:17 

wanting 117:1 135:21 

279:13 325:13 443:12 

wants 248:6 269:17 

320:4 323:21 333:3 

435:21 

warehouse 27:14 

warm 11:8 

warmer 47:9 48:14 

warnings 159:15 

warranted 96:7 

Wartheson 24:16 

Waseca 9:12 

Wash 417:16 

washing 412:4 

Washington 13:13 

21:16 120:15 121:16 

257:10 356:5 

wasn't 37:1 116:1 

149:21 159:1 285:17 

287:4 301:11 306:15 

346:21 347:20 378:6 

waste 159:18 182:15 

303:18 322:19 344:12 

436:21 447:9 

wastewater 159:15,16 

wastewater's 158:16 

watch 110:15 141:20 

255:9 

watching 41:12 271:9 

water 32:16 158:11,14 

234:10 235:11 265:10 

277:7,7,8 386:19 

412:4 

waterfront 425:18 

waters 122:8 386:22 

445:6 

Watsonville 201:17 

wax 194:20 197:19 

199:4 312:14 

waxes 199:16 

way 18:4 31:12 35:19 

41:20 47:6 49:6 55:4 

72:11 114:15 122:12 

132:3 133:21 136:5 

137:14 148:15 153:20 

155:11 167:13,18 

173:21 175:13 188:20 

192:9 221:9 237:15 

247:10 271:6 277:7 

281:4 284:17 319:22 

327:17 339:6 358:12 

364:15 366:12 370:11 

371:15 375:20 386:15 

390:16 392:22 397:3 

404:5 415:3 417:1 

421:7 422:14 432:1 

435:3 439:11 456:18 

ways 31:7 46:19 47:20 

73:6 77:17 80:20 

97:22 102:22 103:6 

128:6 148:10 153:15 

179:4,9 220:13 

273:18 296:9 446:21 

weather 11:8 52:7 

79:10 319:9 

webinar 65:15 66:15 

80:20 97:15,17,19,20 

159:21 168:10 169:3 

169:4 316:18 

webinars 46:11 144:2 

164:12 168:5 290:8 

website 25:4 69:6 129:2 

129:6,17 130:14 

133:12 244:7 255:18 

256:17 450:22 

websites 84:8 

WEDNESDAY 1:7 

weed 180:19 386:21 

450:12 

week 25:16 107:6 133:9 

133:16 135:4 316:19 

316:22 348:22 403:17 

weekly 100:11 316:2 

319:3 380:2,8 

weeks 78:9 106:11 

319:12 320:16 

weigh 421:6 

weighed 100:4 

weighing 151:9 

weight 29:1 174:2 

289:9,12 

weighted 289:3 

weightings 294:18 

weird 361:8 

welcome 4:5 5:20 7:14 

8:16 9:15 11:4 16:9 

17:5,15 32:15 33:21 

58:16 73:12 169:15 

169:16 387:21 405:13 

welcoming 9:17 

Welfare 13:20 

well- 11:12 424:11 

well-documented

353:1 

well-run 301:11 

wellness 240:11 

Welsch 190:15 194:16 

194:17 198:4,9,15 

199:11,15 200:4,11 

417:22 

went 18:19 19:1,17 

22:13 38:5,7 41:8,8 

124:3 142:4 191:10 

198:17 243:8 429:4 

460:7 

weren't 21:21 48:1 

118:1 199:8 302:18 

308:22 

Wesleyan 56:11 

west 5:12 9:4 410:16 

427:8 

western 12:15 13:3 

321:3 

wet 407:14 

wettable 225:17 

wheat 221:14 

wheel 22:2 

white 379:19 414:7 

wholesale 274:11 380:9 

Wholesalers 146:21 

wide 15:21 225:18 

263:14 300:20 310:20 

400:18 

widely 46:9 191:22 

233:5 261:3 

wider 445:10 

widespread 52:10 

wife 15:18 19:15 22:6 

22:22 319:18 

wild 152:21 153:5 180:7 

186:5 187:4 200:5 

224:15 225:14 226:19 

272:11,17 273:4,11 

276:22 335:2 368:8 

436:13 437:4 441:1 

441:14 442:22 445:22 

446:8 454:17,20,21 

458:2 

Wildlife 272:12 

willful 322:3 

willing 322:5 346:6 

366:1 

wilt 364:6 

win 20:14 307:11 330:1 

wind 428:17 

window 22:20 185:7 

371:17 387:10 

windows 110:17 

winemaker 205:21 

wines 207:1 

wing 44:20 45:3,9,15,18 

46:1,7 

winging 168:18 

wings 22:15 

Winona 24:17 

winter 9:13 38:3 47:11 

48:1,11,15,17 

Wisconsin 13:5,8 27:16 

wisdom 28:12 

wise 157:12 

wisely 334:1 

wish 6:12 99:21 252:2 

314:21 364:13 440:7 

450:16 451:7 

wishing 143:18 

withdraw 360:11 

withdrawal 149:15 

witness 59:22 

WODPA 323:6 

Wolf 356:3,9,10 358:22 

359:3 361:20 

won 20:15 

wonder 198:19 

wondered 319:21 

wonderful 17:13 

wondering 110:6 

114:13 116:3,17 

150:16 180:21 181:2 

186:7 194:2 209:14 

261:17 342:10 430:19 

446:8 

Woods 427:2 432:15,17 

436:15 437:15 438:8 

439:3,18 440:14 

441:7,20 442:1,5 

Woodstock 21:18,21 

word 19:7 32:8 239:6 

376:8 437:12 

wording 312:16 

words 159:20 248:12 

248:18 281:20 

wordsmithing 172:8 

376:22 

worked 5:10 9:5 12:12 

15:9 37:20 47:1 64:1 

65:20 69:18 71:20 

76:9 90:3 104:21 

136:11 194:6 203:11 

203:20 244:15 341:6 

382:20 

workers 240:10 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
512 

working 8:14 24:4 

26:18 38:14,18,21 

39:17 41:2 42:2 45:21 

49:1,3 50:22 53:12 

77:11 99:7 105:2 

108:1 119:2 122:21 

123:14,22 134:10 

149:22 164:19 173:9 

173:19 180:18 187:10 

196:7,9 203:21 209:9 

209:16 224:20 241:5 

241:12 252:8 266:2 

273:1,7,17 274:8,13 

315:5 333:11 335:1 

335:10 338:22 341:4 

368:5 385:2 387:1,5,8 

388:2 389:12 400:2 

401:16 413:5 428:19 

449:4 451:17 454:15 

455:1 

works 54:20 58:15 

101:6 106:16,19 

134:22 165:5 220:12 

228:11 241:1 295:13 

308:2 343:6 352:13 

402:7 

workshops 29:15 46:11 

world 37:1 53:5 64:17 

80:4 81:1 164:15 

167:14 200:2 208:14 

213:4 252:15 268:3 

295:15 310:10 408:12 

411:16 427:12 434:4 

437:18 439:8,13 

440:4 441:13 

worldwide 62:20 64:19 

80:3 219:20 234:21 

worm 45:13 

worried 26:15 

worry 416:14 

worse 38:5 

worth 253:11 362:16 

383:16 438:2 

worthy 303:5 

wouldn't 121:10 131:18 

274:2 284:8 316:5,16 

398:3 446:5 

wow 130:11 

wrap 137:2 145:15 

189:15 333:16,19 

wrestling 187:17 

189:12 

write 100:20 101:19,20 

105:7 151:11 297:15 

297:19 382:11 384:16 

writing 100:12,17,21,22 

101:14 121:4,7 

331:21 

written 91:14 108:14,21 

120:17 122:5 131:11 

147:6,20 178:11 

180:4 183:10 186:9 

192:10,18 200:8 

215:4 217:10 226:4,6 

226:15 230:12 231:12 

273:16,21 281:15 

282:7 291:15 329:7 

334:13 337:3,14 

338:20 341:3,20 

370:14 375:8 392:11 

402:16 403:8 404:6 

404:14 414:19 426:7 

430:15 

wrong 88:19 165:3 

219:3 322:6,8 417:21 

425:6 429:18 

wrote 105:12,15 301:1 

WSDA 449:1 

Wyard 169:6,10,12,19 

173:7 174:20 177:8 

X

xanthan 233:1,2,8,12 

233:16 258:12 259:21 

260:2,6,8,13,17,20 

261:1,2,5,8 263:1,6 

263:19 264:4,5,15,19 

265:4 422:1 

Xs 267:1 

Y

Yea 6:13 

year 6:9 7:16 8:9 12:8 

13:14 14:3,13,17 24:8 

26:15 28:9 29:18 

40:21 42:4 46:12 62:7 

62:8,10 76:6 90:3,5 

90:19,20 91:21 92:16 

119:21 188:12 222:20 

232:1,8 243:22 252:8 

257:15 292:17,18 

307:6 317:8 318:19 

325:17 340:5,5,8,11 

360:15 363:16 376:11 

378:5 407:21 428:15 

429:8 432:8 

years 8:7 9:6,9 12:12 

13:7 15:20 19:2,3,13 

20:5,11 21:10,11 

23:13 24:5 25:13 

26:14 28:6,12,15 

29:14,22 35:17,21 

36:10 40:5 41:9,15 

45:22 47:15,19 48:3 

52:8,18 53:5 95:17 

99:3 112:21,21 

115:11 118:4,5 

124:21 151:6 155:17 

191:21 192:16 195:7 

198:14 203:20 215:2 

216:7,21 222:5 225:7 

240:16 254:16 293:1 

298:18 315:6 318:17 

328:9 341:1 359:21 

363:14 364:9 367:15 

372:12 381:8 383:1 

383:21 407:18 417:5 

429:5 432:4 444:16 

444:18 448:17 449:4 

451:16 

yeast 165:11 

yellow 145:12 

yesterday 128:12,15 

135:21 160:15 208:2 

227:6 

yield 80:18,19 81:16 

340:2 

yields 81:12 

young 449:12 

Youngblood 367:21,22 

371:11,19 

Youngblood's 367:19 

youth 39:4 

Z

Zea 194:14 201:12,15 

205:3,4,17 

zero 213:13 

zone 277:10 

zoologist 37:13 

0

1

1&4 1:9 

1,000 225:15 323:12 

1,200 20:17 428:6 

1,500 334:11 374:21 

1,850 24:10 

1:00 68:21 

1:02 243:1,8 

10 112:21 353:3 

10,000 434:13 

100 133:11 182:9 325:6 

429:7,8 

100-acre 379:12 

106 31:11 

11 1:9 21:10,11 41:9 

379:21 

11:01 142:4 

11:15 141:21 142:1 

11:17 142:5 

12 198:14 202:17 

12-1 454:18 

13 11:20 125:9 350:17 

409:12 

130,000 30:5 

139 3:14 

14 66:16 125:9 364:9 

142 3:16 

15 8:6 28:5 30:10 36:20 

47:15 147:6 315:7 

417:5 

15,000 30:3 

150 51:13 410:15 

15th 68:16,21 

16 31:12 293:6 

160,000 9:1 

1620 277:12 

16th 321:20 

17 124:21 

17011 90:14 

17065 245:11,22 

18 24:11 91:22 202:16 

203:2 204:19 205:8 

348:14 429:4 

180 95:16,22 

180,000 30:17 

1873 15:15 

19 63:1 91:2 93:13 94:3 

94:4,18 95:18,20 

96:12 97:11 98:3 

337:17 410:16 

1944 18:7 

1945 30:17 

1962 18:14 

1965 19:3 

1974 19:17 

1980s 252:5 

1986 15:5 

1990 214:21 

1991 15:7 

1993 201:21 

1995 281:1 

1997 246:15 

1999 19:18 

1st 321:21 

2

2 431:9 459:15 

2,000 387:9 428:15 

440:6 

2,125 302:5 

2.2 45:18 

2:00 68:22 

2:05 243:8 

20 13:7 15:19 24:5 34:7 

34:11,12 35:21 36:10 

46:12 112:21 130:1 

256:11 363:18 372:12 

407:18 447:6 

20's 411:1 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
513 

20-somethings 412:9 

2000 125:9 321:8 

25th 40:21 

27 26:13 

650 51:14 

6th 29:18 

2002 15:7,8 28 455:6 

2003 170:11 

2006 15:8 3 70 9:3 

2007 15:13 3 459:15 

201(a)(5) 322:2 

2010 15:14 51:17 230:4 

3,000 224:8 

3.5 433:8 

714 30:11

73,000 30:16 

,15 

368:20 419:3 3:45 333:10 74 18:8 

2011 15:4 56:6 245:12 30 22:4 28:12 35:17 

2012 201:18 36:10 40:5 127:22 239:3 

2014 33:9 124:3 170:17 170:14 215:2 252:13 7th 30:12 

351:13 352:6 407:18 

2015 229:22 298:2 30-minute 277:3 

299:5,21 329:9 300 257:7 

332:22 419:3 455:18 312 428:7 459:18 

2016 31:12 201:18 32 20:16 289:18 8:35 4:2 

228:7 232:2 244:4 39 393:4 

2017 69:10 79:10 90:1 80-30 274:19 

95:19 151:1 341:5 4 825 170:22 

395:13 4 3:4,6 203:16 

2018 1:5,7 4:5 57:22 4.1.3(d) 405:18 

61:21 71:19 85:21 4.5 211:21 9,500 172:15 

87:18,21 90:2 94:11 40 393:4 9:00 459:16 

96:9 99:6 140:4 400 66:14 

149:15 181:22 183:11 4009 111:2 90's 39:2 

280:16 341:5 342:16 44 224:9 93 99:3 

387:15 45 33:18 141:18 94 455:2 

2019 62:7,19 67:3 74:10 460 3:18 966 58:21 

96:11,20 119:17 

131:13 229:20 230:1 5

302:15 396:3 399:13 5,000 122:4 257:6 

2020 96:21 147:7 224:4 5:52 459:4 

205 238:8 5:54 460:7 

205-2 458:9 50 9:1 121:12 222:15 

205.204 202:4 404:6 229:9 241:19 252:7,9 

205.204(a)(1)(i) 193:1 

205.207 272:18 

252:9 256:10 341

50-50 274:19 

:9 

205.238(c)(1) 105:9 

205.300 458:9 

50,000 34:18 

50.34-1 303:9 

205.600 194:7 5029 405:17 

205.600(a) 400:10 

205.602 161:15 361:22 

5033 457:6 

5033-1 457:7 

205.604 162:7 508 129:8 

205.605(a) 233:16 

260:2 

53 19:3 338:18 

55 3:8 

205.605(b) 260:5 337:7 

205.606 234:8 335:6 

550 383:15 

57 3:10 

455:16 58 3:12 

22,900 20:19 

232 26:20 6

236(b)(1) 322:2 

24 1:7 

6:30 459:16 

60 22:3 42:3 231:20,22 

25 20:11 241:17 252:9 241:19 366:6 

260:18 301:5 315:6 605(b) 285:12 

25,000 20:19 606 430:16 

250,000 85:21 624 428:8 

2500 257:6 65 19:8 22:22 

7

700 383:14 393:22 

75 18:8 61:9 95:21 

8

8:30 1:10 16:18 459:5 

80 95:18 99:1 232:4 

9

90 95:15 275:18 

99.9 411:22 412:14 

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514

C E R T I F I C A T E 

This is to certify that the foregoing transcript 

In the matter of: National Organic Standards Board

Fall 2018 Meeting

Before: USDA

Date: 10-24-18

Place: St. Paul, MN

was duly recorded and accurately transcribed under 

my direction; further, that said transcript is a 

true and accurate record of the proceedings. 

-----------------------

Court Reporter 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 
1

 UNITED STATES DEPARTMENT OF AGRICULTURE

 + + + + +

 NATIONAL ORGANIC STANDARDS BOARD

 + + + + +

 FALL 2018 MEETING

 + + + + +

 THURSDAY,

OCTOBER 25, 2018

 The Board met in Great River Ballrooms 

1&4 of the Intercontinental Saint Paul Riverfront 

Hotel, 11 Kellogg Boulevard East, St. Paul,

Minnesota at 8:30 a.m., Tom Chapman, Chairman,

presiding. 

PRESENT 

TOM CHAPMAN, Chair

HARRIET BEHAR, Vice Chair

SCOTT RICE, Secretary

SUE BAIRD 

ASA BRADMAN 

JESSE BUIE 

LISA DE LIMA 

STEVE ELA 

RICK GREENWOOD 

DAVE MORTENSEN 

EMILY OAKLEY 

A-DAE ROMERO-BRIONES 

ERIC SCHWARTZ 

DAN SEITZ 

ASHLEY SWAFFAR 

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STAFF PRESENT: 

MICHELLE ARSENAULT, NOSB Advisory Board 

Specialist, National Organic Program 

SONIA JIMENEZ, Deputy Administrator, Specialty 

Crops Program, Agricultural Marketing 

Service 

DR. PAUL LEWIS, Ph.D., Director, Standards 

Division, National Organic Program 

CLARISSA MATHEWS, Ph.D., National List Manager 

DEVON PATTILLO, Materials Specialist, National 

Organic Program 

DR. JENNIFER TUCKER, Ph.D., Deputy 

Administrator, National Organic Program; 

Designated Federal Official 

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 CONTENTS 

Public Comments. . . . . . . . . . . . . . . . . . 4 

Materials Subcommittee 

Topics

2018 Research Priorities 

Genetic integrity transparency of seed grown

on organic land. . . . . . . . . . . . . . 233

Excluded methods determinations

 October 2018 . . . . . . . . . . . . . . . 274 

Marine materials in organic crop

production . . . . . . . . . . . . . . . . 285 

Compliance, Accreditation and Certification

Subcommittee 

Topics

Developing criteria for risk-based accreditation

oversight. . . . . . . . . . . . . . . . . 311

Training and oversight of inspector and

certification reviewer personnel . . . . . 312

Analysis of feedback from the Spring 2018

import panel . . . . . . . . . . . . . . . 312 

Adjourn. . . . . . . . . . . . . . . . . . . . . 379 

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 P-R-O-C-E-E-D-I-N-G-S 

8:30 a.m. 

 CHAIRMAN CHAPMAN: Welcome back 

everybody. We'll get started now. Looking 

around the room it looks like all the Board 

members are present so we'll come back into 

order. 

First up today will be public comment. 

Public comment will run through lunch. We'll 

break for lunch sometime in the noontime hour and 

then come back with the Materials Subcommittee; 

the Compliance, Accreditation, & Certification 

Subcommittee. If time allows, potentially the 

Livestock Subcommittee. 

Up first on public comment is Marisol 

Ovieda followed by Michael Sligh. 

Just as a quick reminder, it's three 

minutes for public comment. Only one speaking 

opportunity. The light will be green for the 

first two minutes, yellow for the last minute, 

and then turn red when the buzzer goes. 

At that point we ask that the speakers 

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wrap up what they have to say. We'll open it up 

at that point to the Board to ask questions of 

the speaker. Then I will always call the speaker 

and the one on deck. 

With that, Marisol, start with your 

name and affiliation for the record. 

MS. OVIEDA: My name is Marisol Ovieda 

and I'm with the Northwest Horticultural Council 

out of Yakima, Washington. The Northwest 

Horticultural Council represents growers, 

packers, and shippers of apples, pears, and 

cherries in Idaho, Oregon, and Washington on 

federal and international policy and regulatory 

issues. 

While the NHC submitted written 

comments on a number of materials for organic 

tree fruit growers and handlers, I will focusing 

my oral comments on the continued use of 

elemental sulfur and sulfurous acid in the 

National Organic Program. 

In many ways the Pacific Northwest is 

the epicenter of organic palm fruit and cherry 

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production in the United States. Washington 

State is the national leader in the production of 

organic apples, pears, and cherries. Over seven 

million boxes of organic apples are now harvested 

from over 14,000 acres. 

This amounts to over 90 percent of the 

entire organic apple crop in the United States. 

There is also a significant amount of organic 

pears and cherries with more than 4,000 acres 

planted across the Pacific Northwest. 

As recognized by the Crop Subcommittee 

elemental sulfur is a critical tool for the tree 

fruit industry and the orchard setting. It is a 

vital insecticide used to control russet mites in 

organic apples and pears and has been used by our 

growers for over 100 years. 

This product is also used to control 

scab and brown rot in organic apples, pears, and 

cherries. In particular, elemental sulfur is one 

of the few options available to treat powdery 

mildew. 

It is an essential material that our 

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organic growers depend on. There are no 

alternatives to the elemental sulfur that 

provides the same level of control and are as 

compatible with the materials used during the 

growing season. 

Elemental sulfur is also used to 

adjust soil pH which ensures better nutrient 

uptake, improve water penetration, and enhances 

overall plant health. This, in turn, provides a 

healthy soil environment for the beneficial 

insects and microbial activity. It is a 

necessary tool for organic production. It is 

worth noting Pacific Northwest growers use the 

wettable application of elemental sulfur. 

Sulfur's acid is used as a plant and 

soil amendment. It is generated on site by 

burning 99 percent elemental sulfur in sulfur 

burners which irrigation water then passes 

through. This allows organic growers to take 

water with a high pH of 8.3 or higher and reduce 

it to a level of 6.5 pH. 

This makes the water more conducive to 

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plant and soil health and improves water 

absorption. Irrigation water with a high pH if 

left untreated causing calcium carbonate on the 

leaf and fruit surface. By lowering it, it 

results in better nutrient uptake. 

On behalf of the growers and packers 

that we represent, the Northwest Horticulture 

Council strongly supports the continued use of 

these vital tools for insect control and plant 

and soil health. We ask the members of the Board 

to support the continued listing of these 

products as they are critical to maintain the 

production of organic tree fruit. Thank you. 

CHAIRMAN CHAPMAN: Thank you. 

Any questions? Steve. 

MR. ELA: I've got a question on 

natamycin for you guys. Do you see any need for 

that in the Northwest tree fruits? 

MS. OVIEDA: It's something that's 

being vetted through our growers at the moment. 

We didn't put in support for it at the moment. 

We're trying to get more feedback on it but it's 

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something that is on the table for our growers. 

CHAIRMAN CHAPMAN: Thank you. 

Up next is Michael Sligh followed by 

Tom Warmuth. 

Michael, if you would start with your 

name and affiliation. 

MR. SLIGH: Good morning. I'm Michael 

Sligh, senior adviser to RAFI and founding member 

of this Board. I also rise in support today for 

North Carolina organic tobacco farmers for the 

repetitioning of fatty alcohol for tobacco 

suckering. 

Organic fraud. We strongly support 

and applaud all actions now to close supply chain 

loopholes, strengthen oversight, increase realtime data access, and achieve consistent 

interpretations of standards across all size 

operations both domestically and internationally. 

Legitimate organic operations and our 

overall organic integrity is at stake. Focusing 

more on high-risk locations and operations, 

ports, satellite offices while developing greater 

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rewards for those who remain in compliance is 

key. As well as greater coordination of such 

initiatives that are emerging in the interim. 

New genetics techniques as part of the 

NOSB task force strongly urge not only adoption 

of these new additional recommendations but that 

this full work agenda be completed in time for a 

final vote of approval by your next spring 

meeting. 

It is critical that this also be 

accompanied by guidance and instruction out to 

certifiers as soon as possible. This is a 

critical issue that we must become more proactive 

on to avoid harm to our supply chains. 

OFPA. We urge all present to strong 

oppose any attempts during this extended farm 

bill cycle to weaken the OFPA and its delegate 

balance of responsibilities and authorities that 

have served our community so well for so long. 

It is vital that we remain united and strong 

against such attacks. Nothing less than the 

heart of the law is at stake. 

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A call for fairness. As the original 

Board we made strong recommendations to the USDA 

to create a nationwide system for farmers, 

certifiers, and county emergency management to 

try to avoid toxic sprays on organic farms during 

emergency crises and for USDA to develop a system 

of compensation for such farms that lose their 

crops through no fault of their own. 

I think now is the time to look at 

such a universal compensation plan that would 

also address a growing number of additional such 

harms as fracking, testing and GMO contamination, 

and pesticide drift. 

This is a fundamental issue of 

fairness, one that we must stand firm on as a 

principle. We have an obligation to protect 

organic farmers. We urge you to put this topic 

back on your work agenda. 

Finally, North Carolina is home to 

over half of the 300 plus organic tobacco farmers 

and they are very concerned about the loss of 

this essential material to remove suckers from 

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their tobacco plants. We urge NOSB to strongly 

reconsider the allowance of this use while 

prioritizing organic research, define long-term 

organic solutions. 

I know your sacrifice and I thank you 

for all your good work. 

CHAIRMAN CHAPMAN: Thank you, Michael. 

Questions? Emily. 

MS. OAKLEY: Thank you for your 

comments on emergency management and 

compensation. You said that was at one point on 

the original Board's work agenda? 

MR. SLIGH: Well, it was our 

recommendations as well. We made recommendations 

to the agency very concerned that there are many 

crises that happened. In North Carolina we've 

already had two such events this year, South 

Carolina, Texas. 

This is now, unfortunately, a very 

common occurrence. Once the disaster happened, 

it's too late because people don't have 

electricity. They can't contact emergency 

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management. They're in a crisis so we have to 

have this. 

I was really excited to see your slide 

yesterday about being able to map on a county 

level. That's the kind of data that emergency 

management needs to have ahead of time and the 

farmers need to have that relationship and the 

certifiers need to work with them so they 

understand that. 

We also are very aware that in a 

crisis like that, their ability to be able to 

avoid spraying organic farms is a very difficult 

task, especially if it's an aerial application. 

That's why we think this compensation 

fund is an issue of fairness. I mean, if you 

lose your crop by no fault of your own, you know, 

we have to have a way to deal with that. 

Unfortunately, this is part of our world now. 

CHAIRMAN CHAPMAN: Harriet. 

MS. BEHAR: Hi Michael. Do you feel 

this compensation fund could be managed through 

the National Organic Program, or do you see it 

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perhaps a partnership with maybe Farm Service 

Agency or Risk Management? Do you have any idea 

just to kind of help us with a start on this 

because it is a big concept. 

MR. SLIGH: Well, yes. I think all of 

those options should be explored and we should 

find the one that has the current already 

capacity to do that. There are such compensation 

funds in conventional agriculture around grain 

bins, around all kinds of systems. This is not a 

new concept. 

I think it is something that could be 

managed by numerous departments. I don't want 

today to decide that it should be one or the 

other but I think that's the conversation we need 

to have. 

We did explore this in some depth with 

the last administration and had lengthy 

conversations and even proposed a very finished 

kind of compensation fund idea. That is 

something that we could also resurface if that 

was interesting. 

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CHAIRMAN CHAPMAN: Dan. 

DR. SEITZ: Michael, as someone who 

has a long history with the NOSB and OP, I was 

wondering what your thoughts are on substances 

that are being petitioned under Section 205.606? 

My impression is that at the start there were a 

number of substances that were useful, and then 

there was the thought that we should not exclude 

them but we want the organic supply to develop. 

Our concern now, or at least the 

concern of some of us, is that as substances are 

added to that, it may actually retard the 

development of an organic supply because it's 

already on so there may be less of an incentive. 

From your historical perspective, how do you look 

at petitions under that section of the 

regulations? 

MR. SLIGH: Well, I mean, I think our 

original thought and understanding was that we 

would be in this continuous improvement phase and 

that we wanted to do everything we could to 

stimulate the organic alternative to all inputs 

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over time. 

I would say that were we have been 

handicapped is in the lack of sufficient organic 

research in a timely proactive manner so that we 

end up with all these bottlenecks. Once we 

establish a substitute, it is, indeed, difficult 

then to make that transition without having that 

forward looking in that preparation. 

I think it is a question of us being 

more proactive and building that runway because 

we can continue to grow the organic input market 

and expand our capacity if we can kind of get 

that train running in the proper order. 

MR. CHAPMAN: I have a question for 

you, Michael. So you mentioned the need for 

fatty alcohols for sucker control. We reviewed 

this a year ago and there was a lot of concern 

around using a synthetic growth regulator for 

primarily economic reasons. How do you --

MR. SLIGH: It turned out that the one 

NOSB meeting I missed was Jacksonville. I was in 

India and I was unaware of this whole question. 

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I've had tobacco farmers call me since then. 

I've gone out and met with them, 

looked at their alternatives, and realized that 

we were very involved in the tobacco buy-out 

debate in North Carolina and that these 300 farms 

represent many conventional farmers who converted 

to organic because they saw this as a better 

market for them and they have a long rotation of 

crops. 

I would not have been in favor of a 

petition that would have encouraged this product 

for wide use beyond tobacco. I also would not be 

supportive of this product as a long-term 

solution. I would only be supportive of this if 

we coupled it with a research priority on your 

behalf, as well as going to OREI and making this 

case. I think they have tried to find 

alternatives. 

I went and saw some of the effects of 

the alternatives they tried. You may or may not 

know in tobacco you need fewer bigger leaves with 

really high quality to get a market premium. If 

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you don't sucker you get a lot of small leaves 

and you lose your premium. 

You try some of these other sprays 

that burns the leaves or it doesn't work. 

Unfortunately with the loss of the tobacco quota 

program the size of acreage in organic has now 

had to expand, a crop that used to be very much a 

hand-held crop, if you will. 

If you're talking 20, 40 acres and you 

have to go out and hand sucker it every week for 

10 weeks, that's totally unrealistic and they 

would drop out if that's the only alternative 

they have. They cannot afford that. It's kind 

of a rock and a hard place in the short term. 

CHAIRMAN CHAPMAN: Jesse and then 

Emily. 

MR. BUIE: So you are wanting this to 

be restricted to tobacco only? 

MR. SLIGH: It's my understanding that 

the new petition that has been -- I'm sorry. 

MR. BUIE: My question was -- the 

question is that your petition is restricting 

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fatty alcohols to tobacco? 

MR. SLIGH: It's not my petition but 

it's my understanding that the tobacco farmers 

are wanting it only for tobacco and that maybe 

part of the error in the earlier petition was a 

broader implication. 

CHAIRMAN CHAPMAN: Emily. 

MS. OAKLEY: So you said that you 

would be interested in seeing this material 

allowed exclusively for tobacco and for a short 

time, until alternatives can be developed. I 

just want to say I understand that thinking, but 

my concern is that when a material is added to 

the National List, at this point it's really 

difficult to get it off, so I'm not sure that 

alternatives would be developed. 

MR. SLIGH: The original Board 

recommended Chilean nitrate would go off in five 

years. I do understand what you're talking 

about. I think getting at your issue of how do 

we couple the alternative research agenda linked 

to the allowance of something that is not where 

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we want to be long term. 

Those two have to be hand in glove. 

I think there is still not. I think that is why 

in my comments I'm trying to say those two things 

must be linked together. The whole idea of 

sunset was to be that you continuously look for 

that improvement. I think we have to do a more 

consistent job with it. 

CHAIRMAN CHAPMAN: Harriet. 

MS. BEHAR: We perhaps might look at 

having a hard expiration date. We might do a 

hard expiration date so then it would actually 

sunset. That might be a way for some of the 

members to get over there, but on this only give 

it five years. 

CHAIRMAN CHAPMAN: Paul, can you speak 

to the hard expiration date? 

DR. LEWIS: Yes. Harriet, I 

appreciate what you're adding here but once the 

material is added to the list, it goes through a 

sunset process so it's going to be really 

difficult to start addressing issues of having 

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expiration dates. 

What you can do is you can look at it 

in terms of the sunset process and look at that 

as a renewal issue. In terms of saying over a 

period of time once it's on the list, it's up for 

renewal, not for an expiration as you're 

characterizing it. 

MR. CHAPMAN: All right. I've got one 

last question and then we're going to let you go, 

Michael. You commented here and in your written 

comments you talked about making it -- rewarding 

operations that continually have no 

noncompliances. What would that mean in 

operationally or tactically? 

MR. SLIGH: I'm very honored and lucky 

to get to work with organic farmers around the 

world. The most consistent thing I heard from 

farmers who have been involved in certification 

for a very long time, and they don't have 

noncompliance, and they pretty much get the same 

kind of inspection every year and nothing really 

changes and it's not that exciting, or even that 

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innovative for them. 

I think as we think about a shift 

toward a more risk-based model, we would put more 

emphasis on where the problems are and we would 

look at way to reward those farmers who have 

noncompliance over a long period of time with 

either a shorter, you know, easy form of your tax 

form or a shorter inspection or something that 

would reward them. 

I mean, we're even talking, you know, 

a little bit could you even have a bi-year. I 

mean, these are the kinds of things I know have 

problems with them and it's just at the debate 

level. Strongly I believe that we are not 

rewarding those farms that remain in compliance 

long term sufficiently. 

MR. CHAPMAN: Thank you, Michael. 

MR. SLIGH: Yes. Thank you. 

MR. CHAPMAN: Up next is Tom, followed 

by Jamie Welch. 

Tom, if you can start with your name 

and affiliation. 

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MR. WARMUTH: Good morning. My name 

is Tom Warmuth. I reside in Kure Beach, North 

Carolina. I'm a biologist. I'm the lake and 

pond municipal representative for BioSafe Systems 

and pretty much work in water treatment and 

surface water management. 

BioSafe Systems is a privately owned 

American company that manufactures 

environmentally responsible disease and pathogen 

control products. I would like to thank the NOSB 

for the opportunity to speak in additional to our 

written comments and supporting material. 

I would also like to thank the other 

written comment submitters for their support for 

sodium carbonate peroxyhydrate, which I will 

refer to as SCP to try to save time. And to 

retain its listing of synthetic substances 

allowed for use in organic crop production. 

SCP is currently listed as an 

alternative to copper sulfate. I would like to 

give some supporting notations, aspects, and uses 

of SCP in support of it. 

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Effective and sustainable chemistry 

that associates in the water producing hydrogen 

peroxide which is the real active which then 

breaks down further into oxygen and water. As a 

side note, SCP is widely used in safety. 

It's also NSF and ANSI Standard 60 

certified in potable water sources, drinking 

water system, as well as waste water affluent 

disinfection. It's used in drinking water as 

well as waste water. It's used in whitening 

toothpaste, dishwashing detergent, and laundry 

determine as well. 

There's a bit of focus on rice in some 

comments, but SCP is clearly not just used in 

rice waters, although I can see why there's a 

focus there because you've got a lot of acreage, 

a lot of water plants grown in water. But there 

is a much larger use pattern in organic 

irrigation ponds, irrigation canals that feed 

organic waters, and it goes on and on from there. 

In the organic markets we have two SCP 

labels for use in water on many listed surfaces; 

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ground cover, mats, greenhouse floors, on crops, 

animal bedding, and animal watering, and further 

from there. The use of SCP is increasing over 

time as more individuals learn of its potential 

uses. 

There is also a positive what I call 

an organic influence with the continued listing 

of SCP. It's not only organic farmers who 

benefit from this chemistry, it's influential to 

other non-organic farmers, lake managers, public 

and private water body managers, potable waste 

water entities, government agencies and other 

current potential users are drawn to SCP as an 

option and assured of the safety and benefits 

because of that organic listing. A farmer may 

not be certified organic but may want to do what 

they can to be more organic or sustainable. 

The benefits compared to copper 

sulfate is really a matter of utilizing best 

management practices or best product for a given 

application. Copper sulfate may not be a 

responsible option due to many factors. 

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Copper sulfate is one of the oldest 

chemistries and it's use but it's limited in 

water quality, poor water quality, increased 

hardness, alkalinity, causes and teleconference 

precipitate out of the water and into the soil 

which then has problems with metallic copper in 

your soil. 

It doesn't have the poor efficacy 

issues. It does not have any discharge or runoff 

restrictions. It does not cause phytotoxicity or 

plant growth or accumulate in the plant like 

copper can. Using rice as an example, there are 

studies showing soil copper toxicity in rice, 

measurable copper in the chaff, and polished 

grain has been also observed. 

It goes on from there. Anyhow, it's 

the position of the BioSafe Systems and so many 

others that users of sodium carbonate 

peroxyhydrate across the markets for use in 

agricultural, horticulture, greenhouse growers, 

cannabis, animal health, meat and poultry 

processing, drinking, and waste water treatment. 

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Thank you. 

MR. CHAPMAN: Questions from the 

Board? 

Emily. 

MS. OAKLEY: I might as well since 

this is my material. I just wanted to explain 

that some of the references to rice was 

originally allowed on the national list with the 

hope that it would replace, or at least 

substitute some use for copper sulfate. We 

haven't seen that as a wide-spread use but that 

was its original intention. 

MR. WARMUTH: Right. 

MR. CHAPMAN: Steve. 

MR. ELA: I just want to follow up on 

what Emily said. We did have questions 

originally as we were looking at this whether it 

was actually being used and whether it was 

effective. From what I've heard, I think we've 

had some public comments that it is being used. 

Could you reiterate for sure that 

there is actually use of it, for example, on 

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rice? I mean, I think really we're saying is 

this an essential material and is it being used. 

Is that correct that --

MR. SLIGH: That is correct, yes. 

MR. ELA: Do you see that use 

increasing? 

MR. SLIGH: Yes, we do. 

MR. CHAPMAN: Thank you. 

MR. SLIGH: Thank you. 

MR. CHAPMAN: Up next is Jamie Welch 

followed by Shelly Connor. 

MR. WELCH: My name is Jamie Welch. 

I'm a scientist and also the product manager of 

technology at EnviroLogix, which is a global 

leader in GMO diagnostics, so feel free to use 

this as a technical resource anytime you need us. 

EnviroLogix advises customers 

throughout the food supply chain on GMO sampling 

and testing. The comments I have today pertain 

to the proposed genetic integrity testing of corn 

seed. 

The absence of required GMO testing in 

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the USDA National Organic Program relations 

provides the opportunity for unintended and 

unrealized GMO contamination and certified 

organic products. 

The public disclosure is such elevated 

GMO content in organic products could undermine 

the consumer trust in the organic program and 

damage brands. I think we can all agree that the 

NOP does not need another damaging investigative 

report. 

GMO contamination of organic products 

can occur at a number of points in the food 

supply chain from cultivation to processing and 

that would include seed contamination, GMO crosspollution, harvesting, transportation, storage, 

and processing. A foundational requirement for 

GMO-free seed or GMO-free organic products is 

GMO-free seed. 

The GMO concentration will only 

increase from this baseline value. Organic 

farmers deserve GMO data to make informed seed 

purchasing decisions that align without endNeal R. Gross and Co., Inc. 

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market needs. 

Transparent GMO data requires the 

communication of the GMO content level in each 

seed lot. The traditional method for measuring 

GMO contamination and seed is by PCR in a 

reference laboratory where they are looking for 

the GMO DNA sequences. 

DCR analysis requires a highly skilled 

scientific staff, requires dedicate lab space, 

and also expensive instrumentation. The standard 

cost for GMO testing of corn is about $450 and 

takes about five days to get test results back. 

Some organic seed companies have 

acquired in-house GMO testing capabilities to 

reduce analysis cost and time to result. This 

can be accomplished by employing immunoassay 

strips to detect and quantify the concentration 

of GMO proteins in raw grain and seed. 

The EnviroLogix QuickScan system is 

the global industry standard for non-GMO identity 

preservation programs that need accurate decision 

point testing. The total analysis time including 

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sampling, grinding, extraction, and running the 

assay is about 10 minutes and the cost is $35 

which is about 1/13th the price of sending it out 

for like a PCR result. 

Anytime the standard can reduce the 

cost and complexity of compliance without 

sacrificing testing integrity should be 

considered a positive development. It is 

recognized that PCR analysis performed at an ISO 

17025 accredited laboratory is being performed by 

a trained scientific staff. 

Therefore, the recommendation that 

seed companies or farmers that perform 

immunoassay testing in-house be required to have 

annual training and successful general 

proficiency samples is appropriate and warranted. 

The introduction of this proposed rule 

change is a positive development for the NOP and 

the organic brand. It helps ensure farmers have 

the information and tools they need to deliver 

the quality organic product they seek to supply. 

Thank you for your service and the opportunity to 

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provide some comment. I am open for questions. 

MR. CHAPMAN: Harriet. 

MS. BEHAR: Hi Jamie. 

MR. WELCH: Hi Harriet. 

MS. BEHAR: Just to be open, I did 

talk to Jamie extensively. 

Two questions. One is the proposal as 

written. Do your tests meet the statistical 

accuracy that we are requiring in the proposal? 

The second is would you tell us what 

percentage of your customers are organic seed 

producers and how many are not organic seed 

producers? Is it widely used in both areas? 

MR. WELCH: Good questions. Yes, it 

does meet the statistical accuracy that you're 

talking about, the 20 percent relative standard 

deviation around those different kind of levels 

of GMO contamination. 

Right now there are some organic seed 

companies that are using this. An example would 

be blue river hybrids which I think is one of the 

largest, if not the largest, organic seed, corn 

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seed producer in the U.S. There are other seed 

companies that are using it as well. 

Our big markets are the non-GMO 

identity preservation programs in the U.S., the 

Cargill, ADM, Bunge run where they are testing 

every truck that is coming through a facility to 

verify what the GMO content is to know whether 

they accept that or not. 

MR. CHAPMAN: Dave. 

MR. MORTENSEN: Thanks for the 

presentation. 

MR. WELCH: Sure. 

MR. MORTENSEN: I was reading up on 

your testing procedures and realized that it's 

trait based so it could be a herbicide resident 

trait, a BT trait, etc., etc. Could you give us 

a sense for the range in cost if you did the full 

sweep of typical traits in, for example, maze 

where it's maybe seven traits. 

MR. WELCH: So the price that I gave 

you, the $35, is actually a comb that has 10 

different strips on it. Each strip detects a 

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different trait so that is actually looking for 

the complete -- the traits that have been 

released to the marketplace. 

Something for soy where there is 

really only three or four traits that have been 

released to the marketplace is a much cheaper 

product which is only $12 or something like that. 

The price is reflective of how many 

traits are out there. When new traits are added 

to the marketplace, then we add new strips to the 

comb to make sure there is complete coverage. 

MR. CHAPMAN: Harriet. Harriet first 

and then I'll get to you. 

MS. BEHAR: Is there anyone who has 

your system that will do the testing on a custom 

basis for others? You know, people send them 

samples and then --

MR. WELCH: Yeah. Illinois Crop 

Improvement has our system. I'm trying to think 

it there are some other state labs that might 

have it. Maybe Iowa State has our system. There 

are some options out there where if you didn't 

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want to invest in buying the system, or even have 

the volumes that would justify buying. 

Typically the smallest kit that we 

have includes 40 tests so maybe you're not 

processing 40 lots in a year so you could send 

them off for analysis. That would probably still 

be a cheaper price point as opposed to sending it 

out for PCR analysis. The value is having it on 

site and getting that real-time result if that's 

needed. In certain markets it's incredibly 

valuable. 

MR. CHAPMAN: Asa. 

MR. BRADMAN: I just want to 

understand about your testing a little bit and 

whether you're able to evaluate DNA methylation 

changes, gene expression and not just alterations 

in the code. 

MR. WELCH: That's a good question. 

Our test is actually testing the genetically 

modified proteins that are being expressed. If 

you're looking for some of the new gene editing 

traits that will eventually be making it to the 

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marketplace, then this is not a product that 

would actually satisfy that need. 

I think the thought is that initially 

if some of those new gene-edited traits make it 

to the marketplace, it will probably be stacked 

in some of these traditional transgenic traits, 

the herbicide tolerances or the insecticidal 

traits that are on the market. In that event, 

this technology will be effective. 

Once you start moving to new gene 

edited traits that can only be detected through 

molecular sequence identification, then you're 

going to have to have some sort of onsite 

molecular detection methodology. 

CHAIRMAN CHAPMAN: Thank you. 

MR. WELCH: Thanks. 

CHAIRMAN CHAPMAN: Up next is Jamie 

Welch followed by -- sorry. Up next is Shelly 

Connor followed by Casey Hughes. 

MS. CONNOR: Hello. My name is Shelly 

Connor and I'm with Wild Farm Alliance. We are a 

small non-profit led by a national group of 

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ecological farming advocates and wildlands 

proponents who support farming practices that 

promote sustainable food production and 

biodiversity. 

First, I want to thank you for passing 

the recommendation to eliminate the incentive to 

convert native ecosystems overnight to organic 

crop land at your spring meeting. 

We have begun work on a draft native 

ecosystem guidance document and we are confident 

in our ability to bring together a broad set of 

stakeholders and to create a draft that will help 

farmers, certifiers, and inspectors to determine 

if the land contains a native ecosystem. 

Once we by buy-in from the 

stakeholders, we will hand our draft off either 

to the NOP or NOSB depending on your capacity and 

interest to move it forward. Second, we urge the 

NOSB to create a working group to address marine 

materials. 

There is broad agreement that this 

issue is important and that potential solutions 

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need to be explored. The working group members 

should include marine biologists, 

conservationist, farmers, companies that harvest, 

and certifiers. This diverse set of voices will 

bring important viewpoints to the table and work 

together to find middle ground and a path 

forward. 

The kelp, seaweed, and algae species 

being harvested are key parts of Marine 

ecosystems and essential for providing habitat 

for aquatic species and maintaining biodiversity. 

Unsustainable harvesting coupled with the effects 

of climate change will devastate these fragile 

ecosystems and the wildlife they support. 

This issue and how it is resolved 

reflects the integrity of the organic label. The 

label cannot be complicit in destroying our 

ocean's health in order to grow food. We address 

this issue in more detail in our written comments 

submitted by my colleague Jo Ann Baumgartner. 

Finally, the NOSB decision-making 

process needs to remain transparent. We are 

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happy to hear that the notes from the 

subcommittee meetings will be made public again. 

This transparency will ensure sound decision 

making. 

Thank you for your service on the NOSB 

and your work to maintain the integrity of the 

label. 

CHAIRMAN CHAPMAN: Questions? 

Emily. Asa. 

MR. BRADMAN: I just want to make a 

comment about you mentioned a middle ground with 

marine materials. Just from my perspective, 

there shouldn't be a middle ground when we think 

about the language for this. We want to come up 

with a system that protects newer environments 

and then we'll adapt any use for organic 

agriculture to that. 

But I wouldn't think of it as a 

compromise. Rather, what is the best approach to 

protect the wild environment. Just a semantic 

issue but I want to make at least my point on 

that. Thanks. 

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MR. CHAPMAN: Emily. 

MS. OAKLEY: So I wanted to ask the 

Program about the draft guidance that the Wild 

Farm Alliance is working on. I know this is a 

different regulatory situation that we're working 

in but as they continue to work on this draft 

guidance, what would be the best approach to 

engage with them on that effort? 

DR. LEWIS: Let me try to address 

that, Emily. I think in this case to engage with 

the program is to have conversations with us. We 

are happy to explore what they're thinking about 

and to just engage with us is really the best way 

to handle it. 

MS. OAKLEY: So does that mean they 

should just contact you directly with some of the 

work that they are thinking of doing and create a 

dialogue with you? 

DR. LEWIS: Sure. 

CHAIRMAN CHAPMAN: Thank you. 

Up next we have Casey Hughes followed 

by Orlando Rojas Esquivel. Sorry if I said that 

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wrong. 

Start with your name and affiliation. 

MS. HUGHES: Good morning. My name is 

Casey Hughes and I'm speaking to you on behalf of 

the National Organic Coalition. Thank you for 

the opportunity to address the Board. I thank 

each of you for the important work that you do as 

volunteers on the NOSB. 

This morning I'll be discussing three 

topics; use of antibiotics in day-old chicks, the 

need for comprehensive review of sanitizers, 

cleansers, and disinfectants, and the use of BPA 

and organic food packaging. 

Antibiotics. NOC supports the need to 

eliminate the use of antibiotics in poultry in 

all stages of life. As our colleague Charlotte 

Vallaeys outlined in her comments, even though 

antibiotics are prohibited in organic production, 

there is an exception for the use in day-old 

chicks. We appreciate the Board's work on this 

issue and we are prepared to support the Board 

for their advocating to the USDA. 

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Sanitizers, cleansers, and 

disinfectants. The NOSB would benefit from a 

comprehensive review of these substances to 

inform decision making when a new material is 

petitioned or a material is reviewed at sunset. 

The NOSB could refer to this review to 

judge whether materials currently on the national 

list meet the same need or if there's a special 

characteristic to the material under review that 

justifies its placement or renewal on the 

national list. 

This review may help the Board 

identify areas where there are gaps in necessary 

materials to aid in the promotion of organic food 

safety. A reference document of this kind would 

create efficiencies, saving time and energy for 

the Board during a material review process. As 

we have heard from Dr. Tucker, this is a priority 

when approving agenda items for the Board to work 

on in the future. 

Lastly, BPA. The NOSB must have the 

ability to advance issues of importance to 

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organic stakeholders such as packaging substances 

like BPA that are used in organic food handling. 

BPA opposes serious hazards and not support this 

elimination from organic food packaging. 

At the same time, known alternatives 

might also present some problems and NOSB should 

approach the issue of good packaging in a 

comprehensive way. We strongly suggest that the 

NOSB inform its deliberations with a technical 

review on BPA and BPA alternatives. 

While the NOP no longer finds this a 

priority, we urge the NOSB to request this be 

added to the work agenda as a priority for 

organic stakeholders. Thank you for considering 

my comments. 

CHAIRMAN CHAPMAN: Thank you. 

Questions? Harriet. 

MS. BEHAR: How does BPA and your 

concern about it affect your food purchases? Do 

you try to somehow seek out food that is packaged 

with a label that says no BPA? I'm not sure why 

you care. Tell me why. 

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MS. HUGHES: Sure. In my person view, 

I feel it is a very consumer-facing issue 

obviously and something that has side-spread 

attention in the marketplace. I do avoid it and 

I would say my peers also have this awareness and 

avoid products with BPA on the packaging. 

CHAIRMAN CHAPMAN: Thank you. 

Up next is Orlando followed by Laura 

Gomez. I understand we may need a translation on 

this speaker. 

MS. OAKLEY: Point of order. 

CHAIRMAN CHAPMAN: Yes. 

MS. OAKLEY: If someone needs a 

translation, can we give them double time? 

CHAIRMAN CHAPMAN: Nope. 

MS. OAKLEY: Really? 

CHAIRMAN CHAPMAN: No. 

MS. OAKLEY: Why not? 

CHAIRMAN CHAPMAN: It's three minutes 

per speaker for the speaking amount. 

MS. OAKLEY: I would move that we give 

them double time. 

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CHAIRMAN CHAPMAN: We have 

approximately, I think, five or six speakers. 

MS. OAKLEY: Thank you. 

(Responses for Mr. Rojas are given by 

a translator.) 

MR. ROJAS: Good morning. My name is 

Orlando Rojas from Costa Rica. I used to be a 

dairy farmer since my childhood and for the last 

10 years I've been an organic farmer that we 

established with my family in order to protect 

the health of my family. 

I'm also the president of the Organic 

Pineapple Cooperative Coopeproagro that carries 

26 families that are searching for environmental 

care and financial support for their families. 

I'm also the president of the Organic 

Agricultural Board of Costa Rica. 

The project is run by myself, my wife, 

and my son and daughter, plus eight employees. 

We are working up to 30 -- I'm going to translate 

hectares to acres for the audience and you guys 

to understand more the area. Fourteen hectares 

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means 30 acres. 

As you can see in the picture, I am 

also -- well, my project supplies the drone 

imagery and services for the co-op. All the 

inventory would be drone imagery for technical 

reference. 

We have our own spraying system to 

apply all the fertilizers and make the flower 

induction. It's called a spray room. We use 

four pounds of ethylene per application which you 

can see in the picture. We also are a flower 

induction service for the co-op. With the 

penalty, I hope to continue our business for our 

family and the employees. Thank you. 

CHAIRMAN CHAPMAN: Thank you. 

Any questions? Harriet. 

MS. BEHAR: How many years in 

succession will the field stay in pineapple? 

MR. ROJAS: How many years in a row? 

MS. BEHAR: My understanding is that 

there is really not a crop rotation other than 

fallow time where there might be a cover crop and 

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that pineapple is grown year and year in the same 

field. I'm just wondering how many years can 

that be sustained without possibly disease or 

insect problems. 

MR. ROJAS: The pineapple cycle takes 

30 months from planting to planting. In that 

division we use legumes as a rotation crop and 

the crop takes three months. With organic matter 

input we can go up to four cycles. That means 12 

years. 

CHAIRMAN CHAPMAN: Thank you very 

much. 

Up next is Laura Gomez followed by 

Nestor Ramirez. 

MS. GOMEZ: Good morning. My name is 

Laura Gomez and I come here to speak on behalf of 

a lot of families including mine that are small 

organic pineapple farmers from different parts of 

Costa Rica. 

I thank you so much for giving me an 

opportunity to express our great concern that the 

NOSB might decide to ban the ethylene use in the 

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organic pineapple flower induction. 

My husband, my two daughters, and 

myself run a little organic pineapple farm in La 

Virgen de Sarapiqui since 10 years ago. Our 

whole production is exported by Coopeproagro, a 

farmer co-op that we founded with 26 other 

families three years ago. 

Our whole production is actually being 

sold to the American west coast under the co-op's 

brand name Eco Sweet Organic Pineapple. To 

fulfill our fruit needs all year around we need 

to program volumes every week of the year in a 

constant manner. 

That is why letting the crop to flower 

naturally will never let us accomplish the agreed 

volume since this would leave us with no control 

of the quality and timing of the fruit making it 

impossible for us to grow this way. 

The use of ethylene allows us to have 

security and efficiency in the fruit production 

and a rotation of the plantation since all the 

fruit will flower at the same time allowing us a 

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controlled fruit volume to deliver. 

We have implemented the technology of 

ethylene flower induction in our farm with a very 

accessible investment in our spray room that 

won't reach the $700. The ethylene gas is very 

cheap and we use very few to make our crop 

flower. 

All our farmers have this spray room 

regardless of how small they are. We all have 

been trained in good agricultural practices and 

labor safety for the proper use of the ethylene 

cylinder. 

The PVC pipes we use in our spray room 

were installed since nine years ago and they are 

fully compliant with the global gap protocols and 

labor safety. It is not true that we as small 

farmers can't have access to this technology. It 

is accessible to all growers. 

Please keep the ethylene in the list 

for use in organic pineapple. We are working 

hard to supply the American market with our super 

sweet healthy fruit and we need certainty on the 

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regulations to keep making our wonderful product 

accessible to the most population all year 

around. Thank you very much, and pura vida. 

CHAIRMAN CHAPMAN: Sue and then 

Harriet. 

MS. BAIRD: How often do you have to 

spray ethylene gas? 

MS. GOMEZ: Once a year. 

MS. BAIRD: Once a year application? 

MS. GOMEZ: Yes. 

MS. BAIRD: Do you feel -- I'm sorry. 

Do you feel as if applying or spraying with 

ethylene gas improves the quality of your fruit 

and, therefore, would enhance pest management? 

MS. GOMEZ: It helps us regulate the 

flowering so we can spray for the pesticides. We 

have a perfect fruit. Well, the best fruit we 

can. 

MS. BAIRD: So it's serving two 

purposes then? 

MS. GOMEZ: Yes. 

CHAIRMAN CHAPMAN: Harriet. 

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research on other methods or natural materials 

that could replace ethylene going on in Costa 

Rica? 

MS. GOMEZ: They have like other 

things but none has really -- I'm really not into 

very much technical but for us we don't have 

anything better than that. The research has been 

bad I guess. This is our only option. 

CHAIRMAN CHAPMAN: Dave. 

MR. MORTENSEN: Thank you for the 

presentation. I was curious do you share the 

spray equipment across the cooperative members? 

MS. GOMEZ: No. We are kind of far 

away from the others. We have our own equipment. 

CHAIRMAN CHAPMAN: Thank you. 

MS. GOMEZ: Thank you. 

CHAIRMAN CHAPMAN: Up next is Nestor 

Ramirez followed by Rolando Soto. 

(Responses by Mr. Ramirez are given by 

a translator.) 

MR. RAMIREZ: Hello. My name is 

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Nestor Ramirez. This morning I will share some 

pictures of my operation, my farm, with my 

family. The farm is located in the northern 

plains of Costa Rica very close to the Nicaraguan 

border. 

We are very proud to be in the organic 

business. Getting to know the other person is 

very well kept in labor safety and environment is 

very encouraging for us. This story can't 

continue if the ethylene is going to be banned 

from our operations. 

I attend the Stow meeting in 2015. 

One of the tasks that the NOSB at that time 

ordered was to look out for some research about 

options of ethylene. After doing a lot of 

consultation with some colleagues and some 

universities in Costa Rica, he is bringing four 

research projects about use of ethylene options. 

The first one was in 2003, 2006 the 

second one, and we just finished in 2018 two 

research projects because we were to have the 

discussion in 2020 so we needed to rush. We have 

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the results here for you to have a copy. In none 

of them we have had a positive or good result to 

finding some other options. 

The use of smoke was checked, cold 

water with ice, and ice. None of them are a 

feasible option. I have copies of the research. 

2003 and 2006 investigations are going to be 

given complete to you. The final investigation 

results this year we just finished so it will be 

handed to you according to the opportunity. 

Thank you. 

CHAIRMAN CHAPMAN: Questions from the 

Board? Sue. 

MS. BAIRD: Yes. Thank you very much. 

I really appreciate that. I'm going to ask you 

another question. What pollinators do you use to 

pollinate your flowers? 

MR. RAMIREZ: The bees are natural 

pollinators in the crops of Costa Rica. 

MS. BAIRD: So you don't have to 

import honey bees or anything like that? You're 

just using natural --

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MS. BAIRD: Okay. Thank you very 

much. 

CHAIRMAN CHAPMAN: Dave. 

MR. MORTENSEN: This is a crop that I 

don't know very much about and I've learned a lot 

from the presentations. Could you explain to us 

what happens with the fruit maturation process if 

you don't spray ethylene? 

MR. RAMIREZ: If we don't use 

ethylene, we can't program the harvest. 

MR. MORTENSEN: You can't properly 

harvest? 

MR. RAMIREZ: No, we can't program the 

harvest. 

MR. MORTENSEN: Oh, you can't program 

the harvest. You can't schedule when the fruit 

will be ready to harvest. Is that correct? 

MR. RAMIREZ: It's impossible to 

operate a farm when you don't know when the fruit 

is coming. 

MR. MORTENSEN: Okay. Thank you. 

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CHAIRMAN CHAPMAN: Steve. 

MR. ELA: Do you use the same rotation 

cover cropping that the previous speakers 

mentioned? 

INTERPRETER: Pardon me? 

MR. ELA: The rotation or the cover 

cropping, the fallow time, is that similar on 

your farm as the others? 

MR. RAMIREZ: You can see in the image 

in the presentation -- as you can see in the 

picture, all the borders of the farms are covered 

with green covers. 

In this case, he uses corn and some 

plantains to separate the neighbor farms and keep 

the integrity of the crop, and the production of 

these parts are distributed among the employees. 

Also, when he plant after one cycle, after the 

plastic mulch removal, it leaves the soil to rest 

for 30 days. In the tropics the natural 

vegetation will grow again and break the cycle. 

MR. ELA: Are all of your crops grown 

organically and is there any issue with GMO 

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contamination of your corn? 

INTERPRETER: Pardon me? 

MR. ELA: Are all of the crops used in 

rotation grown organically and is there any 

problem with GMO contamination of the corn crop? 

MR. RAMIREZ: All the inputs that we 

use on the farm are authorized by the 

certification agency. Specifically to that 

question, the corn is a local variety that we use 

so there is not any imported seed. 

MR. SOTO: Good morning, I'm Rolando 

Soto from Costa Rica, and I have been a producer 

of organic pineapple for ten years. And I'm part 

of the Association of Bioecological Producers of 

the North of Costa Rica, Probio. 

Organic station is formed by 36 more 

producers with no more than five hectares each 

and it is the support of 450 families which is 

the equivalent of ten percent of organic 

production in Costa Rica. 

We have been working on this project 

for ten years located in one of the poorest areas 

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in the country, such as the county of Upala and 

Guatuso, both in the north part of the country. 

We have worked the land for many years. We are 

farmers who love organic agriculture, and we're 

looking for continuous improvement. 

2.6 percent of the exports in Costa 

Rica is organic pineapple. And there is a 

tendency to increase that volume which causes 

environmental improvements and healthier 

products. 

However, this does not motivate 

scientists and big suppliers to come up with more 

efficient alternatives for flower induction for 

organic pineapples. There isn't a great variety 

of supplies for organic production. 

The absence of ethylene for flowering 

will cause a disappearance of organic production 

affecting the environment and American customers 

who want organic pineapple and families who live 

out of this organic production. 

(Off the record comments.) 

MS. BEHAR: You can give the 

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translation for that. 

INTERPRETER: Okay. 

MR. SOTO: In conclusion, we want 

ethylene to remain an approved product for 

organic production as the only supply for 

flowering at this moment. Thank you. 

MS. BEHAR: Questions? Emily. 

MS. OAKLEY: Where is the increase in 

organic production coming from? Are conventional 

fields being transitioned to organic? Or are 

other organic crops being transitioned to 

pineapple? Are needed ecosystems being converted 

to pineapple? 

MR. SOTO: More people are consuming 

organic products, including pineapple, so they 

believe that conventional will convert to 

organic. 

MS. BEHAR: I have a quick question 

myself. I don't see anyone else. Are all of the 

pineapples being shipped into the US market, are 

they going domestically and perhaps overseas, 

maybe European Union or other countries? 

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but mostly American. 

MS. BEHAR: Gracias. 

MR. SOTO: Thank you. 

MS. BEHAR: Next up is Luis Carlos 

Gonzalez Miranda and on deck is Christian Herrera 

Leon. 

MR. GONZALEZ: Hello, my name is Luis 

Carlos Gonzalez. I'm an organic pineapple 

farmer. 

I want to speak about the importance 

of the use of ethylene in the uniformity of the 

production of the pineapple crops, either in 

conventional as in organics. 

All the agricultural practices done in 

the pineapple crop is to achieve a uniformity of 

the plantation within the same lot. This is the 

very beginning of the land preparation which is 

very important. We try to achieve the best 

conditions to have the uniformity in the 

planting. 

Then we do the plastic mulch coverage. 

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We have three kinds of planting materials as you 

can see in the picture. Those three types can be 

mixed in the same lot. We need uniformity. 

Those then must be selected by weight 

to have the same size. As you can see in the 

picture, you can mix in the plantation different 

size of plantlets. Then that will give different 

types of pineapple. In this chart, you can see 

the uniformity of the planting material within 

the lot, all over the place. 

At nine months, you achieve enough 

weight to make the flower induction at the 

plantation. We need to achieve six pounds for a 

plant to have a good size of the fruit. 

Next please, next. We do the 

applications of ethylene at low temperatures to 

reduce the volatilization of the ethylene. We 

mix it with -- charcoal to capture the gas and 

release it in the water and release it in the 

plantation. 

I'm just going to finish relating the 

chart. It's not dangerous, like 30 years of 

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northern 

experience using, very low cost per acre, 

efficiency of more than 95 percent in the 

applications, and a plantation where the ethylene 

is not violent. Muchas gracias. 

MS. BEHAR: Gracias, Maestro. 

(Laughter.) 

MS. BEHAR: Next up is Christian 

Herrera Leon, and on deck is Oscar Salas Porras. 

MR. HERRERA: Hello, good morning. 

It's an honor to be here addressing to this new 

Board. We were in Vermont three years ago on the 

same issue. My name is Christian Herrera. I'm 

the general manager of Cooperagro, this organic 

club that you have been hearing of. 

So far, we're located in the 

place of Costa Rica in the humid, tropical region 

with a precipitation of 4,000 millimeters of rain 

through the year with a variation of temperatures 

of 100 degrees Fahrenheit and the lowest, that we 

call it cold for us, is reaching the 65s. 

So here you must understand that 

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 Michelle always chooses the coldest weather like 

Vermont in here to make us freeze, okay. 

(Laughter.) 

MR. HERRERA: Our operation is 100 

percent full organic area. It's 26 families 

associated that work in the field in the 

projects, 350 acres so far with an expansion of 

maybe 100 percent of the area for the next couple 

of years with a huge investment. 

And we are direct exporters to Europe. 

We are accredited, and we have in Costa Rica our 

own law, our own decree that rules all the 

organic farming in Costa Rica. And we have the 

equivalency recognized by the European community. 

So the government checks and fiscalizes in the 

farms, has the approval to get to the European 

markets. 

So we have to achieve three different 

certifications. We have to run the USDA organic, 

we have to run separately the European 

certificate plus our national decree. And 

stapled to that, we need to include the Good 

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 Agricultural Practices and Operations. 

Our technology package, as you have 

seen, we love technology, so we have a multidisciplinary team in there as associates of the 

co-op. It's a technical -- unified technical 

practice, so we are a multi-site farming and NOAA 

GPO, because we use the same technical package. 

It's so fascinating, myself being four 

years in the organic business, coming from 

conventional to organic, all the passion invested 

in the growers, checking all this new world of 

biological controls, which is completely, I 

think, newly born. 

And we have to do a lot more research. 

In the picture, you can see trichoderma affecting 

our fusarium, which is the biggest plant --

disease in the crop. So we need to keep on doing 

more research. 

That's a picture of the rotation of 

the crops. Normally in Costa Rica, our legumes 

can take up to three months to grow. And we 

shred everything to reincorporate the vegetation 

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 back to the fields before fructification so we 

won't increment the weed growth within the crop. 

But the normal resting time that we 

leave is no less than six months, because after 

that we just leave the natural vegetation to 

break up, and it's covered by weeds. And then 

everything is shredded. 

By the way, pineapple crop is one of 

the most -- the plantation that most puts biomass 

back into the soil with 350 tons of fresh biomass 

each cycle of three years, okay. All that 

plantation in case of organics is shredded back 

to the soil, okay. 

MR. CHAPMAN: Thank you, thank you. 

Any questions? Emily? 

MS. OAKLEY: Thank you. You talked 

about the expansion of the organic pineapple 

industry in Costa Rica. Is that conversion from 

conventional to organic? And does any of it 

include conversion of native forests into organic 

production? 

MR. HERRERA: Well, Costa Rica, we can 

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 brag about worldwide that we have 25 percent of 

our area protected by law in national parks. So 

25 percent of the Costa Rican area is already 

protected. We are a country that is smaller than 

the Minnesota state. So we're pretty small. We 

don't have more land to grow. 

In transition, specifically in 

pineapple transition, when you don't have any in 

between seal, or you're organic or you're not, so 

you're going to -- you have to grow for three 

years. And the cycle takes, in three years, two 

crops. So you have to harvest twice in the same 

area being sold as conventional to achieve that 

transition. 

And you're going to lose no less than 

$40,000 per hectare which could be, like, around 

$20,000 per acre planted in a transition time of 

three years. So for us, it's much cheaper just 

to leave the area resting for those three years, 

with the timeframe that the certification allows 

us, to achieve the transition. 

So yes, there are areas now, very few, 

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 being transitioned from conventional to organic 

that way, leave resting for two years. But for 

the grower, it's a huge investment because we 

have to leave our land, which is very limited in 

Costa Rica, resting with no more income then. So 

we have to make good that numbers in the 

financial structure to convert that. 

And the last question from the other 

exposer, many of the cattle areas that are going 

into crisis because of productivity yields 

whatsoever, that is expensive cattle farming. 

There are some of the farms that might be 

choosing to convert into pineapple crops after 

logically the authorization of first the 

government, and then the certification agency. 

MR. CHAPMAN: Dave? 

MR. MORTENSEN: Yes. Your photographs 

were showing us the cover crop, the legume cover 

crop. With the cooperative, is the cover crop's 

something that is part of a best management 

practices followed by all? 

MR. HERRERA: Well, we have to renew 

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 the certification every year. And now, because 

of some bad histories about fraud happening, 

Costa Rica with organic pineapples, okay, we have 

pushed the certification to go with the net area. 

It's not the same thing of certifying 

100 hectares of apples, which is for perennials, 

instead of a crop that cycles very fast. You 

need to keep on planting pineapple every week to 

achieve the weekly program every week next year. 

So we have all the activities being done the same 

week all through the farm. 

So that means that there is a big 

difference between the gross area of the farm 

which in the past the certification agency used 

to put only the total acreage of the farm and not 

the net area being planted for pineapples. 

In the last three years, the Organic 

Chamber, with the community grower, has pushed 

the certifications in case of pineapples to make 

the mass balances more detailed to when the fruit 

is coming. So the mass balances now, now we see 

a certifications saying they would train in the 

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 crop, okay, and we design how to keep the record 

of the mass balances strict to the area to be 

planted. 

Now in pineapple, in organic 

pineapple, it takes four months than 

conventional, because our growth is much slower 

because of nutrition. So that means that we can 

be -- from planting to harvest we can go from 14 

to 15 months, okay. 

So depending on the timing, the 

certification shows up making the audit. Then we 

can tell these crops will be harvested within the 

next year, and that will give us in specific 

tons, and this is the mass balances. 

The next year, they're going to match 

what we program, but we can't grow more than what 

we stated last year before. Because then we 

reduce the open space where you can put some 

other goal is, right? 

MR. MORTENSEN: So I'm not sure my 

question was so clear. I just wanted to know --

that was very helpful -- but are cover crops 

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 being used routinely, regularly, by you and your 

farmer colleagues? 

MR. HERRERA: Yes. Well, in the 

experience of Costa Rica, being the worldwide 

leader in pineapple export, is that we have 

already crops that have 35 years constantly, 

conventional. 

So we have been working very hard the 

last three years, because the European community 

is starting to check the nutrient -- the 

nutrition contents of the soil and what you get 

out of the harvests. And then in pineapple crop 

you get up to 100 tons out every harvest. 

So it's really intense. And for us 

it's very challenging. But we have been working 

that organical package, and the nutrition program 

will input the exact amount of nutrients that we 

take out. So that will guarantee the 

sustainability. 

And now, using legumes that are with 

a fixation of 50 to 90 kilos of nitrogen per 

hectare, remember we're in the tropics, we have 

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 growth all year round. So it's been fascinating, 

personally in my case, to keep on just getting to 

learn all this technology that all the growers 

have been really pushing to learn about. 

I don't know if that -- okay, we're 

here 35 years dealing already with the same 

yields. And we don't use no herbicides to 

destroy the plantation, to plant again as fast as 

we can, so we have to shred everything in green. 

And that means a lot of machinery and 

a lot of biomass going into the last -- by the 

way, last week we were checking the biomass 

nitrogen input of the crop. And we were getting 

up to 500 kilos of nitrogen every three-year 

cycle. Because all the biomass goes into the 

shredder with decomposers, and yams, and all 

this. 

MR. CHAPMAN: Thank you. Dan? 

DR. SEITZ: Can you use the plastic 

mulch more than once? And how -- it appears that 

you're using a lot of that. How are you then 

disposing of the plastic mulch? And is that a 

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 problem for you? 

MR. HERRERA: Well, in the matter of 

fact, there is a lot of -- a big movement of the 

conventional farmers to go in using plastic mulch 

because they can avoid the use of herbicides. 

In our case, in organic, we need the 

use of plastic mulch. And what we have done for 

the last three years is to use a slightly thicker 

plastic, because the cycle takes 32 months. So 

plastic, being exposed to this humidity, to the 

heat, during 30-something months, there's going 

to be -- if it's too thin, it's going to destroy. 

And then we're going to have a headache picking 

it up, you know, manually. 

So we're going to a thicker plastic, 

so it's much easier to remove all the carpet. 

And then we send it to the recycling agencies. 

And thankfully, in Costa Rica, we have the banana 

business giving a lot of plastic material, so we 

have a big industry of recycling all these 

agricultural plastic products. 

MR. CHAPMAN: Sue? 

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 MS. BAIRD: Did I understand that 

you're certifying under an internal control 

system group certification? 

MR. HERRERA: Pardon me? 

MS. BAIRD: Your certification 

program, are you certifying under a group 

certification process? 

MR. HERRERA: In GLOBALG.A.P. 

certification we are multi-sites. Since we are -

- the farm grows itself within the growers. And 

in the USDA organic specific, yes, with a group 

of growers. 

MS. BAIRD: Okay. I just wondered 

that. Personal, do you know Luis Brenes? 

MR. HERRERA: Luis Brenes, yes. We 

have had some arguments in the past. Yeah, he's 

very knowledgeable. But, well, he's one of the 

leaders in organic technology in Costa Rica. But 

--

MR. CHAPMAN: That's enough. 

MR. HERRERA: We have had some 

argument with him. He's very clever and very 

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 knowledgeable about everything. 

MR. CHAPMAN: I don't think Luis is on 

our agenda today so --

MR. HERRERA: And I would love to 

understand why those laughs are? 

MR. CHAPMAN: Thank you. 

MR. HERRERA: Because I don't know if 

--

MR. CHAPMAN: Thank you for that --

MR. HERRERA: -- he's a character up 

here. 

MR. CHAPMAN: I do have a question for 

you as well. I'm curious to know, because we've 

gotten some questions about rotational practices 

in pineapple. Would a change in your rotational 

practice have an impact on your need to use 

ethylene? 

MR. HERRERA: Well, I think in the 

rest of the presentation you might see that if we 

leave a pineapple crop naturally to flower by 

themselves, there's been a slight tendency it'll 

be seasonal because of all period temperatures 

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 are cold weather, like go down to 65. 

Below 68, the plantation will go into 

stress because of the cold weather. And then it 

will start releasing the endogenous ethylene. 

And then it will start popping like popcorn all 

over the plantation. 

So then, you -- in the pineapple crop 

and even more in organic, you just can't go with 

the personal every time just to pick what is 

ripened. And it's something that we really 

argued with Mr. Bondarela (phonetic) three years 

ago. 

It is not a matter of just going into 

your orchard, just picking up what you find ripe. 

You need to program containers. Each container -

- with an organic we're making 3.5 containers per 

 hectare of harvest. And we need to fill a 20-ton 

container. So it's not a matter of just going 

randomly picking up what is ripened all around. 

Then we're going to have a big gap in 

August with no fruit, and the market will suffer 

that. And the shelves in the supermarket will be 

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 empty, replaced by any other conventional 

product. And then we'll have a peak of 

production that will come from May to July. 

And then the market will crash, 

because we know that organic market is really 

sensitive and sensible to over-production. So 

the way of -- and just for example, one of the 

reasons we spray everything -- and thankfully 

pineapple crop absorbs everything fully through 

the axiles -- is that we don't put personnel in 

there. 

And we have a density of 60,000 plants 

per acre, 25,000 square acre. So it's really 

tight to put person in there making a mechanical 

damage to let disease getting in. 

(Foreign language spoken.) 

No mechanical damage. So as soon as 

it is planted, just maybe the blood meal that we 

go and put with a little spoon, ten grams per 

plant, and then no more personnel until harvest. 

We have to keep that plantation 

steady, not being mixed. So it's impossible to 

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 think of going every time just picking pineapple. 

Then sizing is a thing. We have a three-kilo 

fruit, which is a jumbo four, size four, and then 

for Northern Europe we're sending 12 which is 

like a pound and a half fruit. 

MR. CHAPMAN: Chris, I'm going to wrap 

it up here. Because we do need to move on. I'm 

understanding, correct me if I'm wrong, that 

regardless of the rotational crop, you would 

still need ethylene. 

MR. HERRERA: Definitely. 

MR. CHAPMAN: Thank you. 

MR. HERRERA: Definitely. There is no 

option, and there's the research. Now we comply 

with you guys that there's the research done by 

universities. There's still warm, you know, the 

old one just closed last week. 

MR. CHAPMAN: Thank you. 

MR. HERRERA: So thank you very much 

for your comments. 

MR. CHAPMAN: Thank you very much. Up 

next we have Oscar Salas Porras and then on deck 

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 is Olman Briceno Fallas. Sorry, I am butchering 

names. I should give this back to Harriet. 

Oscar, if you could start with your 

name and affiliation. 

MR. PORRAS: Good morning to all, 

thank you for your attention. I am the Executive 

Director of the Organic Agricultural Chamber in 

Costa Rica. 

Don't worry, I am not in technology, 

so I'm going to be brief. In Costa Rica, the 

engineers are the ones that speaks and takes the 

show. 

After the Board meeting in 2015, all 

the organic production growers understood that 

they needed to gather efforts. And they 

established the Organic Agriculture Chamber in 

early 2016 to help the government implement all 

the legislation and the rules to guarantee the 

integrity of our industry. 

The Chamber wasn't born to make 

locally in the government of Costa Rica, or with 

our commercial partners outside of Costa Rica, to 

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 release or ease the rules to make it easier. The 

reason the Chamber was born was to implement the 

strictest and latest legislation rules for the 

industry. 

Now the Chamber represents 95 percent 

of all the area of organic pineapple in Costa 

Rica. One of the most important achievements the 

Chamber has done is for us to put up to the Costa 

Rican Congress an investigation about the organic 

fraud that happened in the latest years with a 

conclusion from the Congress of Costa Rica about 

that. 

Our Chamber is here to support all the 

ruling that the NOSB and the NOP in general will 

issue about our industry and puts into your 

access all the technology and information that we 

have gathered among our associates. 

In this case specifically, we wanted 

to ask to keep the ethylene in their list, 

because otherwise we cannot grow. Thank you. 

MR. CHAPMAN: Questions? 

(No audible response.) 

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 MR. PORRAS: Thank you. 

MR. CHAPMAN: Thank you very much. I 

think we used a lot of questions on the last 

speaker. 

(Laughter.) 

MR. CHAPMAN: Olman is up next 

followed by Wendy Jimenez. You can start with 

your name and affiliation. 

MR. FALLAS: Hello, good morning. 

Well, I remember a boss of mine used to ask me a 

question quite often. He said, what keeps you up 

at night every day? And when looking at the 

organic production in Costa Rica, and basically 

with all these questions that you have had, the 

big issues for me are ethylene and the fraud. 

But I'm going to concentrate on the 

ethylene issue. If this multi-sectoral 

consultation team decides to get ethylene out of 

the official products that can be used in 

organics, there are four things that are going to 

happen. 

The first is that the sustainable 

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 livelihoods of many people that I know are going 

to be over. They cannot reinvent themselves. 

The second is that there's no 

possibility of them substituting their work in 

their farms for other products that are going to 

provide them with enough money to buy their food 

and to sustain their families. 

The third is that there are going to 

be many workers that are going to be laid off. 

And the fourth is that the consumer in 

the United States, without the use of ethylene, 

is not going to be only affected with pineapple 

but eventually it will be affecting also bananas, 

avocados, and other products and vegetables. 

Well, when assessing the proposal, you 

know, we have looked at the very fine details and 

the concepts, and every word that has been put 

forward. And I have not seen any proposal yet 

that takes in consideration the people, you know. 

And from a modern, deliberate, 

republic policy making, one of the things that we 

have to begin is to think about the people. And 

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 I have not seen that yet. So I think that that 

is missing for me. 

I represent right now CANAPEP, that is 

the most important chamber of exporters of 

products of Costa Rica. And we are very 

concerned to see this. In this chart you will 

see how many growers do we have, but only three 

percent of all the area is organic. And that 

will be gone without ethylene. 

From our perspective, what we need to 

do is work together as a team and try to 

collaborate and look for -- to address both of 

the issues, the ethylene in this particular case, 

but also work together to avoid the fraud so we 

don't see any in Costa Rica. 

As my friend Oscar said, there's a 

Congressional report from an investigative report 

that took many months of work to address this 

issue of the fraud. And we have names and people 

involved in this issue. And we want consequences 

with this. Thank you very much. Any questions? 

MR. CHAPMAN: Dave? 

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 MR. MORTENSEN: Olman, I can assure 

you we are thinking of the people also. But 

thank you --

MR. FALLAS: Thank you. 

MR. MORTENSEN: -- for highlighting 

that. 

MR. FALLAS: Thank you, Mr. Mortensen. 

That gives it a lot of focus. 

MR. MORTENSEN: I'm curious that you 

prefaced your statement by saying there are 

things that keep you up awake at night about 

organic production of pineapple, and it's not 

ethylene. Could you tell us what those things 

are? 

MR. FALLAS: The two things that I 

mentioned, probably I didn't express myself as 

clear as I wanted, but the two things that keep 

me up at night is the elimination of ethylene, 

because of the impact it has, you know, and the 

other is the fraud. 

MR. MORTENSEN: Okay, thank you. 

MR. FALLAS: All right, sir. 

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 MR. MORTENSEN: Thank you for that 

clarification. 

MR. CHAPMAN: Dan? 

DR. SEITZ: Can you give us a little 

information on the ways in which fraud is carried 

out in the pineapple industry? 

MR. FALLAS: Well, fraud -- there's 

always -- when you have the stimulus of earning 

good money without working, there's always going 

to be people that are going to try to play -- to 

outsmart and outfox the system. 

And the system cannot work without 

three things, basically. We have analyzed this 

very, very thoroughly. And the Congress of Costa 

Rica has identified how it works. You have 

corrupt public servants, you have corrupt 

certifiers, and you have corrupt growers. You 

cannot do a fraud without these three components 

getting aligned together and working under the 

same, you know, type of tune, basically to 

simplify it. 

MR. CHAPMAN: Emily? 

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 MS. OAKLEY: I wanted to address your 

concern that people are not a part of the 

decision making, because I think they absolutely 

are. 

When we discussed this in the spring, 

a lot of public comments came in about this 

material saying that, you know, if it were 

applied for now there really isn't a criteria 

under OFFA that allows for just commercial 

viability of a crop, for fruiting so that it's 

easy to harvest. 

I think it's the people that have 

spoken widely to the members on the Board and 

that give us consideration in our deliberations. 

So definitely we are thinking of the farmers. 

MR. FALLAS: Thank you, Emily. I 

appreciate your comment. 

MR. CHAPMAN: Asa? 

MR. BRADMAN: I just have a comment 

here. I work with a group looking at pesticide 

exposures to agricultural workers in Costa Rica. 

And we have seen higher exposures compared to US 

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 populations for many conventional pesticides. So 

I also see a benefit to people in Costa Rica with 

expansion of organic production of any number of 

crops. 

MR. FALLAS: Yeah. I think that there 

is a trend. I mean, I believe that when you look 

at what's going on in the world with a more 

informed consumer, we will continue to see people 

more -- looking at the labels and looking at what 

we are doing about it. So we really need to get 

our act together. 

Here the regulator is always in the 

markets. Because look, Costa Rica is a small 

country. We know each other very well, you know. 

So we know who is who. So when somebody pops up 

like a miracle pineapple grower, that Ms. Emily 

Oakley already mentioned, where does it come 

from? We know where it comes from. And the 

Congress knows, and the police as well. So we 

need to really address these issues thoroughly 

and decisively, you know. 

But again, for example, my friend 

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 Christian Herrera worked for many years in the 

conventional. So we have to take all the 

agrochemicals and everything out of his truck. 

And now he's an organic guy, you know. 

So he can answer to you, Mr. Bradman, 

exactly what it meant for him to come from a 

conventional grower for many years -- that was 

the one who started pineapple in Costa Rica -- to 

becoming an organic advocate right now, okay. So 

the tide is turning, I think, in one way or 

another. 

MR. CHAPMAN: Thank you. 

MR. FALLAS: All right. 

MR. CHAPMAN: Thank you for your 

comments. 

MR. FALLAS: Thank you very much, Mr. 

Chapman. Enjoy having you. 

MR. CHAPMAN: Up next is Wendy Jimenez 

followed by Emily Musgrave. Wendy, you can start 

with your name and affiliation. 

MS. JIMENEZ: Thank you, good morning. 

My name is Wendy Jimenez, and I work for CAPA 

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 Costa Rica which is a branch of Central American 

Produce Association here in Portland, Oregon. 

And yes, it is very cold. 

CAPA Costa Rica has been exporting 

organic pineapples for 12 years. Since 2006, we 

started our organic pineapple exports for the 

American market by organizing a group of small 

farmers who make a tremendous effort to grow 

organic pineapples compliant with costly organic 

certifications, including the USDA NOP, a 

tremendous effort considering the drastic 

climatic conditions in the humid tropics of Costa 

Rica. 

Currently, this organic program 

represents 20 percent of our sales to the United 

States. Costa Rica exports approximately $900 

million per year. Of this amount, $21 million 

responds to sales of organic pineapple. This can 

only mean that these sales respond to smaller 

producers. 

The demand for organic pineapple 

requires programming throughout the whole year. 

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 Every client must request the fruit that they are 

interested in buying at least five months before 

the harvest period. 

An organic pineapple farmer does not 

plant and grow just to look for markets later on. 

They grow organic fruit with a previously 

established commitment to provide that pineapple 

to a customer or a processor within a defined 

period and with a settled volume. 

Farmers must use ethylene. It is 

naturally generated and used in a process that is 

only to activate a floral induction. And that 

same product will never be used recurrently in 

the development or commercialization of this 

fruit. Without the use of ethylene, organic 

pineapple cannot be produced, considering there 

will be no controlled method of production. 

Eventually, without organic pineapple 

exports, a global supply chain could end. This 

would obviously affect the United States, which 

is the main consumer of organic pineapple in the 

world. The use of ethylene is imperative for 

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 organic products. Thank you very much. 

MR. CHAPMAN: Thank you. Any 

questions? Steve? 

MR. ELA: I'm curious. We've heard 

about the rotations with organic production. 

What would a conventional grower do? Would they 

come out of -- and pineapples -- would they come 

out of pineapples? And then what would be their 

practices before they replant? 

MS. JIMENEZ: Before they go out 

conventional? 

MR. ELA: So in the conventional 

pineapple system, is there that cover crop 

rotation as well? Or do they finish one crop, go 

immediately back into another crop? And I guess, 

what are the differences between the organic 

rotation and the conventional rotation? 

MS. JIMENEZ: Well, that is actually a 

very technical question. And that should be 

addressed to my teammates over there. But 

obviously, I think we should explain very well 

that, if you go from conventional to organic, you 

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 have to wait a lot of time. But like I said, 

this is a very technical issue, and I'm not 

really the person to discuss it. 

MR. CHAPMAN: Thank you. 

MS. JIMENEZ: Thank you. 

MR. CHAPMAN: Up next is Emily 

Musgrave, followed by Arturo Solorzano Arroyo. 

Emily, you can start with your name and 

affiliation. 

MS. MUSGRAVE: Good morning. My name 

is Emily Musgrave. I'm the organic program 

manager at Driscoll's. I'd like to thank the 

NOSB for their commitment to protect the 

integrity the organic program and uphold the 

vital regulatory processes of the NOP. Your work 

is tremendous, and it does not go unnoticed. 

Today, my comments focus on the 

continued allowance of elemental sulfur, 

sulfurous acid, and liquid fish products on the 

national list. 

Driscoll's supports the continued 

listing of elemental sulfur for use in organic 

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 production on the national list. Dusting sulfur 

is a critical tool for organic strawberry growers 

as a fungicide and miticide specifically used to 

target powdery mildew, a fungal disease that 

plagues organic strawberry growers. 

Organic strawberry growers commonly 

use both dusting sulfur and wettable sulfur in 

rotation with each other. Growers have found the 

two formulations show different efficacies, and 

rotating the products limits plant stress and 

reduces the risk of phytotoxicity. 

Our growers do not believe the sole 

use of wettable sulfur is a viable alternative to 

dusting sulfur. Dusting sulfur gets more 

thorough coverage than wettable sulfur and 

penetrates deeper into the strawberry crown. 

We would like to reiterate that 

removing elemental sulfur from the national list 

would cause significant challenges to organic 

growers and damages to crops from powdery mildew. 

That being said, Driscoll's is 

continuously researching other viable methods 

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 other than dusting sulfur for the control of 

powdery mildew, including efficacy tests of 

specific strains and application methods of bio 

control agents. 

Driscoll's supports the continued 

listing of sulfurous acid on the national list. 

It is an important practice for controlling and 

adjusting the pH in irrigation water across all 

berry types. Sulfurous acid has proved to be the 

most effective method of soil acidification after 

soil preparation is completed. Balanced soil pH 

is essential for ensuring proper nutrient uptake, 

microbe activity, and plant health. 

Driscoll's supports the continued use 

of liquid fish products for use in organic 

production, as it is a critical source of 

fertility across all berry types. The vast 

majority of our growers use liquid fish products 

as it is a key nitrogen supplement for long-term 

perennial crops. We do encourage the Board's 

continued research regarding the sustainable 

sourcing of fish for these fertilizers. 

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 I thank the National Organic Standards 

Board for you service and for consideration of my 

comments. 

MR. CHAPMAN: Thank you. Emily? 

MS. OAKLEY: This is a little offtopic, but do you guys use aquatic plant extracts 

or seaweed, kelp products? And do you support or 

have an opinion on addressing the environmental 

impact of those harvests as well? 

MS. MUSGRAVE: Yeah, that's a great 

question. A lot of our growers do use quite a 

few different algae and those types of marine 

products. And I think I agree with some of the 

other certifiers that have commented that it 

would just be getting the regulation right, 

there. So I think if certifiers came out and 

found a way to do it, I think our growers would 

support it, and Driscoll's would support it. 

Thank you. 

MR. CHAPMAN: Asa? 

MR. BRADMAN: Hello. Would you 

explain the dust, sulfur dust application 

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 methods, and the kind of equipment that's used? 

MS. MUSGRAVE: Yeah. That's a good 

question. So it's really specialized equipment 

for dusting sulfur, rather than wettable sulfur, 

which is actually one of the reasons why we're 

doing research on other, you know, biopesticides, 

because it's very expensive. 

The machines range, I think, from 

anywhere to, like, $12,000 to $15,000. And 

they're specifically only used for dusting 

sulfur. So that could be prohibitive to some 

growers if they're not able to get that cost. So 

it's a very specific machinery used. 

And that's why we're looking at things 

such as BT and other biopesticides. But we're 

still in the very early stages. It's not ready 

for commercial development yet. But yes, the --

what's used for dusting sulfur is really specific 

for that crop for strawberry growers. 

MR. BRADMAN: Could you explain the 

equipment a little bit? Like, how is the 

material applied, and is there any attempt to 

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 direct the application, what level, that kind of 

thing? 

MS. MUSGRAVE: Yeah. That's a little 

bit beyond, kind of beyond my scope. I do know a 

little bit about it. I mean, right, there's a 

few different -- so you've got your dusting 

sulfur which, you know, is used as a powder and 

gets better coverage. And then you've got your 

wettable sulfur, and then the micronized sulfur 

that goes into the sulfur burner. 

I don't know the specifics exactly 

regarding how, you know, growers are using it in 

the machines. But I do know that they follow 

lots of, you know, they're looking at wind 

patterns, and weather, and there's protective 

gear. So they do follow that. 

I do know that dusting sulfur can be a 

little bit hard on the plants also, you know. 

It's a little bit harsh on the plant which is 

another reason, you know, why it's an important 

tool. And without it, powdery mildew would be a 

big issue. But that's another reason why we're 

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 looking into alternatives. 

But that's a good question, Asa. I 

could get back to you on the specifics with my 

colleagues. Thank you. 

MR. CHAPMAN: Dave? 

MR. MORTENSEN: Yeah. And I think 

that the subcommittee was focusing more on it, or 

at least there was a lot of discussion about 

human exposure by former field workers. So maybe 

less on the plant reaction and more on human 

exposure. 

MS. MUSGRAVE: Human exposure, 

exactly. Thank you. 

MR. CHAPMAN: I have a question about 

-- we have a petition before us on silver 

dihydrogen citrate that could be used as an antimicrobial wash on fruits and vegetables. Does 

Driscoll's have a thought or a position on this 

material? 

MS. MUSGRAVE: That's a good question. 

I don't think we have currently looked into it. 

But if that could be something that we could look 

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 into on the open docket, we'd be happy to comment 

on that. 

MR. CHAPMAN: Yeah. I mean, we 

received maybe three comments from the organic 

industry or so. And so I was just looking to see 

if there was further feedback from other handlers 

that would potentially be using this product if 

it was a need or a necessity for them. 

MS. MUSGRAVE: Yeah. I can definitely 

look into that and get back to you. Thank you. 

MR. CHAPMAN: Thank you. 

Up next is Arturo, and then we'll 

break after that. After break will be Melody 

Morrell. 

MR. SOLORZANO: Good morning. My name 

is Arturo Solorzano. My thanks to the Board for 

giving us this opportunity to interact with the 

US and NOSB. I'm the national director of the 

Agricultural National Research Institute. I'm 

also a representative of the Ministry of 

Agriculture of Costa Rica. 

On behalf of the government of Costa 

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 Rica, we ask for the NOP to authorize the use of 

ethylene as an input for organic production of 

pineapple for over five years due to the lack of 

other inputs, commercial available for the 

organic production. 

Change or modifications in inputs will 

impact directly on farmers due to the more than 

90 percent of commercial organic pineapple is 

exported to the US directly from Costa Rica. 

Ethylene is a viable gas -- is a 

viable material that can meet the needs of all 

sizes of organic farms, not only in Costa Rica 

but also in a lot of Central American countries. 

So without ethylene, it would be 

impossible to achieve the uniform ripening 

necessary for timely harvest of the fruit 

treatment. 

Also, I want to mention that climate 

change in the last year has increased a lot with 

the effect to development of natural flowering 

that happens a lot. This way, development of 

climate change is making a lot of -- a huge 

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 amount of undesirable fruits with not uniformity 

at all. 

Because we have fruits from ripened 

fruits and ripening fruit at the same time. Then 

these temperatures, cold temperatures will allow 

the production of natural flowering and natural 

fruits. With these natural fruits, then we will 

have pests all over at different times. 

And as you can see, we can have, in 

the picture over there, the small fruits, green 

fruit, unripened then, and then we will have 

pests all over them. And because of the 

management from all these kind of pests will be 

for different strategical management for the 

farmers. 

Because the small fruits will bring 

another pest. So the farmers cannot really match 

the technical process that they use to control 

one mold or one larvae at the different size of 

fruits. It's not only a matter of making easy to 

crop the final process but also to manage the 

pest development in the production. So with 

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 ethylene really, the farmers will not really have 

a method of developing of the pests. 

There's a different pest now can also 

be evolving there. Also thank you. We are 

really in the tropical part of the country. So 

we are really in process of how to manage with 

the environmental condition. We will really put 

all our efforts and means in agriculture to help 

the farmers to develop. 

MR. CHAPMAN: Thank you, thank you. 

Questions, Harriet? 

MS. BEHAR: So just to summarize what 

you -- just to summarize what you've said, that 

when a field has different flowering times within 

a pineapple field, so if ethylene is not being 

used, that you'll have higher pest pressure 

because the moths are attracted to the flowers. 

And then the larvae from those moths will then 

attack the less mature pineapple. And you'll 

have significant losses. Is that what I'm 

understanding? 

MR. SOLORZANO: You just summarized it 

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 just perfectly, certainly. We would have fruits 

of different sizes, of different amounts. Then 

it keeps attracting a different pest. So you can 

imagine the different strategical management. So 

it's a food safety issue as well, because the 

farmer has to get into the fields many times, as 

other speakers already mentioned. 

MS. BEHAR: So then the reason for the 

use of ethylene is not just for getting the 

pineapple to market but also as an important pest 

control material by having uniform flowering. 

MR. SOLORZANO: Uniform fruit 

development. Yes. 

MR. CHAPMAN: Emily then Ashley. 

MS. OAKLEY: I just wanted to let 

people know that there are more comments to that 

effect for the pest and disease control and the 

Organic Produce Wholesaler Coalition's comments. 

So if people want to see more about that, it's 

there. 

MR. CHAPMAN: Ashley? 

MS. SWAFFAR: I just want to say thank 

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 you to all the growers from Costa Rica that came. 

Because that's a huge effort that you guys made 

to come here and give us your comments. And we 

really appreciate that you guys came. Thank you. 

(Applause.) 

MR. SOLORZANO: Thanks to all of you. 

I appreciate all your help on this issue. 

MR. CHAPMAN: Thank you very much. 

Okay, by my clock, which is on Pacific time, so 

by my other clock, it's 10:23. Let's take a 22 

minute break and come back promptly at 10:45. 

We're in recess. 

First up when we come back is Melody 

Morrell and on deck is Stephen Walker. 

(Whereupon, the above-entitled matter 

went off the record at 10:23 a.m. and resumed at 

10:50 a.m.) 

 MR. CHAPMAN: Okay. So I see all 

Board members present, so we'll get started. And 

I just need to find my spot. Melody, so we'll 

start with Melody Morrell followed by Stephen 

Walker. Melody, if you can start with your name 

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 and affiliation for the record. 

MS. MORRELL: Sure. My name is Melody 

Morrell. I work at the Cornucopia Institute. 

have studied shipping logs as I followed the 

importation of organic corn and soy from suspect 

countries. I've seen who's consignee, shipper, 

and notified party are all listed as FedEx. No 

transparency. 

Cheap, often fake organic feed is 

propping up organic factory farm operations and 

is spread over the marketplace. Cheap feed means 

cheaper meat, milk, and eggs. These are now 

conventional products sold at depressed organic 

prices. 

Your continued attention to tracking 

organic products through the entire supply chain 

is critical to the integrity of the program and 

consumer trust. I'm so glad to hear about your 

current efforts and hope the NOP can move very 

quickly. 

The natural evolution of organic 

farming is subverted when regulations are bent to 

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 fit the conventional model. Rather than leaving 

room for the improvement of organic practices, we 

are ushering in a kinder, gentler, conventional 

agriculture. 

Real organic farmers are being forced 

out of business. Organic farmers who grow 

produce in soil now compete with hydroponic 

factories using organic inputs. Even during 

tomato season, organic hydroponic tomatoes 

dominate my rural Minnesota grocery store and our 

local organic buying club. They are cheap, 

sometimes even matching conventional prices. 

Hydroponic operations require an 

enormous amount of energy-expensive 

infrastructure and do nothing to improve or 

maintain the soil as OFFA directs. 

In 2010, the Board determined that 

they cannot be certified organic, but here we 

are. This spring, the European Union revised its 

organic standards to prohibit hydroponic 

production under their organic label. The EU 

will no longer import produce labeled organic if 

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 it was grown hydroponically beginning in 2021. 

I emailed the pertinent parts of that 

new regulation, if you haven't seen it yet. It 

includes a clear definition of organic soil-bound 

production. It is unclear what it will mean for 

the US/EU organic equivalency arrangement when 

our labels do not mean the same thing. Factory 

farm and hydroponic products dominate the market 

in part because they have been allowed to bear a 

seal that they have not earned. 

Thank you for you continuing and very 

complicated efforts to protect a true marketplace 

alternative. And thanks especially to Jennifer 

Tucker for her efforts on improved transparency 

at the NOP. It's much appreciated. 

MR. CHAPMAN: Questions? 

(No audible response.) 

MR. CHAPMAN: Thank you very much. Up 

next is Stephen Walker followed by Michael Menes. 

And if you could start with your name and 

affiliation. 

MR. WALKER: Good morning, I'm Steve 

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 Walker, Operations Manager at MOSA. We certify 

2,100 organic operations, and most of those are 

here in the upper Midwest, a veritable GMO hot 

zone. 

Most of the certified operations 

include 1,400 corn growers plus lots of beans, 

alfalfa, and other at risk crops. We review many 

GMO contamination prevention plans, and we 

investigate GMO contamination cases. 

At previous meetings, we expressed our 

frustration when reasonable prevention plans 

proved ineffective, and I said something about 

probably having GMO dust on my eyelashes. And we 

talked about some math, including the ridiculous 

amounts of buffer required to truly protect 

genetic integrity on an average seed corn field. 

And yet we still strive to promote that organic 

means non-GMO. So we're thankful to see further 

progress toward a fair regulatory approach. 

We support the general direction and 

the sound concepts in the proposal, but even with 

the urgency of this growing issue, we think the 

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 proposal still needs some refinement and clarity. 

We have some concerns around sensibly sharing 

burdens within the organic community, 

practicality of enforcement, and unfair impacts 

on geographic regions with more GMO production. 

We also think the proposal should 

emphatically call for USDA support in order for 

coexistence to be successful. We organic folks 

are doing our fair share. Maybe there's a bit 

more we can do, and that's why the concepts in 

this proposal are important. 

But there's only so much each of us 

can do in the face of increasing contamination 

threats. And yet, the public expects our organic 

economic engine to be GMO-free. 

There are remaining moral questions of 

fairness and responsibility. We won't meet 

consumers' organic purity expectations unless we 

have more support and leadership from the USDA 

and not just the National Organic Program. Lack 

thereof makes for failed coexistence, and that 

harms our organic label. 

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 The proposal does a good job of 

explaining the necessity for genetic integrity 

transparency and sets a reasonable forward 

course. But this path also continues our 

defensive position with disappointing 

acquiescence towards contamination. We'd like to 

see a little more call to arms. 

We appreciate the proposal's 

perspective on financial losses from genetic 

contamination, a problem that conventional US 

agriculture created for itself. 

We find the 17 points to be thorough, 

but hard to follow. We'd like more clarity on 

responsibilities, perhaps organized by 

stakeholder, including certifiers, labs, 

inspectors, NOP, organic and conventional seed 

suppliers and growers. 

And looking down the path a bit, we 

wonder if transparency of test results will 

create a geographic disadvantage for growers and 

seed suppliers in places that have more 

contamination from GMO production like here in 

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 Minnesota. And then our written comments get 

into a lot more details about various points in 

the proposal. 

MR. CHAPMAN: Thank you. 

MR. WALKER: Okay. 

MR. CHAPMAN: Harriet? 

MS. BEHAR: Can you speak a little bit 

more about the practicality issue, which specific 

parts of the proposal you felt were impractical 

for implementation? 

MR. WALKER: I guess for that I'd 

refer to our written comments. It's fairly well 

outlined in here, and I didn't memorize point by 

point of the 17, but we did comment on, you know, 

not every single point, but some are little 

practicality things, who's responsible. There's 

a couple language things in there that maybe 

needed more clarification. 

MR. CHAPMAN: Dan, then Harriet. 

DR. SEITZ: If this were posted on the 

open docket, would your organization be willing 

to actually put in suggested wordings, and 

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 changes, and so forth? From our standpoint, if 

people actually give us wording that they think 

works better, it makes our task easier. 

MR. WALKER: Yeah, I think we could 

take a stab at that. We didn't do that for this 

written comment, but on the other 5029 seed one, 

we did quite a bit of that sort of suggested 

wordsmithing. 

MR. CHAPMAN: Harriet? 

MS. BEHAR: Would you rather that it 

had been a tolerance level rather than the 

transparency allowance? You kind of alluded to 

that we needed a stronger stance on this. 

MR. WALKER: No. I think transparency 

is a good way to go. And if you get into set 

levels, then you're -- that's contrary to, I 

think, what NOSB said your intentions were. And 

that comes across more in our comments on the 

other seed issue at hand. 

MR. CHAPMAN: Thank you. 

MR. WALKER: Okay, yeah. Thanks for 

all your work very much. 

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 MR. CHAPMAN: Up next is Michael 

followed by Sandra Mays. Michael, start with 

your name and affiliation. 

MR. MENES: Good morning, Mike Menes, 

True Organic Products. Thank you for the 

opportunity to comment. Thank you to the NOSB 

and the NOP for all the stuff that you do for the 

organic industry. We appreciate your attention 

to detail as we wade through the many -- as you 

wade through the many comments on the issues. 

I can tell you a little bit about our 

company. True Organic Products is the nation's 

largest organic fertilizer manufacturer. We're 

family-owned, and we've been doing this since 

2005. We manufacture our liquid and pelleted 

fertilizer in two locations, in Helm, California, 

and out in Boardman, Oregon, on the eastern side 

of the state. And this slide will show a few of 

our growers that use our products. 

I'm here again today to comment on the 

tools for organic fertility. Accepted practices 

of crop rotation, composting by diversity, are 

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 well proven and have been successful. Organic 

fertilizer manufacturers like ourselves fill the 

need for situations where additional soil 

fertility is needed to keep up with the growing 

demand of organic produce. 

It is important for international and 

domestic growers to understand that these inputs 

used in their farming practices contribute to the 

overall organic integrity. 

Today, I'll be updating you on 

positions that I commented on at the spring NOSB 

meeting earlier this year. Specifically this is 

in regards to the support of liquid fish. Thank 

you again for putting it on the work program. 

True Organic Products is in support of 

the work that's done for this and continues to 

have interest in having that remain on the NOP's 

approved materials list for use in organic 

production. 

There are a limited number of liquid 

fertilizers that are available in organic 

production. Sunsetting liquid fish would limit 

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 the tools available for growing crop organically 

and thus limiting the availability of things like 

what you've heard today, organic berries, 

certainly salads, almonds, apples, celery, and so 

much more. 

We support the work and the agenda to 

answer the questions about the environmental 

impact of fishing solely for fertilizer versus 

byproducts of fishing for oil and fish meal. 

Previously, we commented on the status 

of sodium nitrate and its availability. 

Anecdotally, we had understood widespread use, 

particularly in crops in regions that require 

nitrogen to be delivered to the plant very 

quickly in a wide range of growing conditions. 

Another time we shared results of 

detectable levels of sodium perchlorate that was 

limited to the retail market. Recently, we 

obtained a sample that is available to farmers. 

It was a 2,000-pound bulk bag. And we detected 

33 parts per million of perchlorate in that which 

is higher than the limit stated which is, I 

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 think, six parts per billion or micrograms per 

liter. 

In closing, True Organics, again, is 

in support of maintaining the NOP approved list 

and re-listing of liquid fish. Please continue 

to make progress on the prohibition of sodium 

nitrate. 

Additionally, we're in support of 

systematically vetting the inputs for the -- make 

sure that the intents and purposes of the OFPA 

are met. Thank you. 

MR. CHAPMAN: Thank you. Harriet? 

MS. BEHAR: Would you be willing to 

put in a petition for the prohibition of sodium 

nitrate, placing it on 602? 

MR. MENES: I had considered that as a 

suggestion yesterday. I thought it was a good 

suggestion and certainly will look into that. 

And, yeah, I think that's certainly a possibility 

for us to do. 

MR. CHAPMAN: Rick? 

DR. GREENWOOD: Question. So you had 

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 one sample that had perchlorate. Have you tested 

more than one sample? I mean, how pervasive is 

it? 

MR. MENES: Well, turns out that a 

2,000-bulk bag is pretty expensive. And we can't 

go around the nation to be able to find that. So 

we looked for one locally and were able to 

purchase one and then test that. 

We have that in a chain of custody. 

So it's certainly an issue on sampling. But 

we're interested in finding out. Most of the 

samples really were from retail, or online 

retailer. But the one we wanted to make sure and 

follow up at this meeting to find out if there is 

something in there. 

The retail ones where it's Chilean 

nitrate at 1600, and it was part of my written 

comment, we've got results there as high as 2,500 

parts per million. And this one as low as 33 for 

that big bulk sample but still very much higher 

than the drinking water standard. 

DR. GREENWOOD: All right, thank you. 

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 MR. MENES: Thank you. 

MR. CHAPMAN: Eric? 

MR. SCHWARTZ: Did that sample trigger 

any regulatory action? 

MR. MENES: No. No, we took it for 

ourselves to be able to present here. And we 

didn't do anything with it. I'm sure there's 

some mechanism in order to be able to do that, 

but we haven't explored that. 

MR. CHAPMAN: Thank you. 

MR. MENES: Okay, thank you. 

MR. CHAPMAN: Up next is Sandra Mays 

followed by Kelly Monaghan. 

MS. MAYS: Good morning. I'm Sandy 

Mays. I represent Wolf, DiMatteo & Associates. 

I'm a senior associate. And in this comment, 

I'll cover the pullulan petition, seaweeds, and 

inspector requirements, as well as unfinished 

business that is holding organic back. 

Wolf, DiMatteo & Associates has 

clients in the dietary supplements sector that we 

have assisted with organic compliance. Adding 

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 pullulan to the national list as a nonagricultural substance allowed for use in 

products labeled made with organic, allows the 

existing market established before the 

reclassification of pullulan to continue, and 

brings the substance under the review by the NOSB 

and the national list sunset process. 

We are aware that there is research 

and development underway to produce certified 

organic pullulan, but there is not a commercially 

available supply at this time. We anticipate 

that when an organic pullulan capsule is 

available that supplement companies will eagerly 

respond. 

We have international clients that 

harvest certified organic seaweeds and kelps. 

I've observed their work many times and found 

that extreme care is taken in order to ensure a 

sustainable harvest. 

If or when a working group does come 

into play, we strongly encourage that it include 

international operators so that the NOSB can 

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 obtain a more worldly look at the differing rates 

of seaweed growth, harvesting styles, and 

sustainability measures put into place to protect 

their natural resources. 

As for inspector requirements, IOIA 

and ACA organizations are the experts regarding 

what is happening on the ground with inspectors 

as well as what is needed to strengthen their 

performance and ensure that the NOP standards are 

being upheld. We ask that you give priority 

consideration to the comments of the IOIA and the 

ACA. 

We've submitted comments on some of 

these topics for years, all unfinished important 

business, a few listed here on this slide, inert 

sodium nitrate, mulch film, and requiring organic 

when available. Our comments are rooted in a 

philosophy of continuous improvement that organic 

is seeking the gentlest ways to produce better 

food and fiber. 

So we ask, don't shrink the national 

list tool box as a goal in and of itself. We 

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 need choices, not just one solution for every 

problem. Be open to innovation and creativity 

that fits the organic philosophy. The 

precautionary principle cuts both ways. Thank 

you so much. 

MR. CHAPMAN: Thank you. Emily? 

MS. OAKLEY: I'm not asking any 

questions, just a comment that I want to echo 

that I couldn't agree more with you that a 

working group should include international 

operators as well. Because that's a missing link 

right now in the comments. So thank you. 

MS. MAYS: Absolutely. 

MR. CHAPMAN: Thank you. 

MS. MAYS: Thank you. 

MR. CHAPMAN: Up next is Kelly 

followed by Rebekah Ritson. 

MS. MONAGHAN: My name is Kelly 

Monaghan. I'm an IOIA accredited organic process 

inspector, trainer, and consultant. I'm 

commenting on behalf of IOIA, the International 

Organic Inspectors Association. 

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 IOIA is a non-profit educational 

organization with a global membership of organic 

inspectors and certifiers. IOIA provides quality 

inspector and reviewer training and promotes 

consistency and integrity in the organic 

certification process. 

Thank you for the opportunity to 

provide comments today and for incorporating 

comments received at the last NOSB meeting on 

this topic. 

Inspectors play a critical role in 

ensuring organic integrity. IOIA is especially 

pleased to see that your proposal focuses equally 

on inspectors and on reviewers who handle organic 

files. 

The global organic movement recently 

created Organic 3.0 to guide the industry into 

the future. IFOAM's description of one key 

element of this strategy focuses on progressive 

improvement toward best practice. This captures 

well IOIA's opinion on this topic. 

What is needed is not a one-time 

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 improvement but a structure that allows and 

supports all players to continually improve their 

skills and abilities. 

IOIA applauds the list of topics for 

skill development outlined in your proposal, 

particularly the requirement for operators to 

provide a sample audit in their organic system 

plan, continuing education, especially if it were 

level appropriate education, categorization of 

inspection by scope and skills -- the NOP could 

incentivize certifiers to this end -- team 

inspections, an underutilized tool, and import 

protocols, a great topic for the USDA's learning 

management system. 

IOIA recommends adding fraud 

detection, forensic investigation, and risk-based 

criteria for audit selection. 

IOIA supports all forms of mentoring. 

However, facilitation of an 

apprenticeship/mentor, peer mentor program is not 

an appropriate role for the USDA. The third 

party system of training already in place, using 

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 IOIA certifiers and the ACA, can serve as the 

foundation for such a program. 

IOIA is an expert voice in the 

development of curriculum and testing protocols 

and looks forward to working collaboratively with 

certifiers, the ACA, and the NOP to design and 

continue to improve an effective standardized 

system. 

In closing, IOIA knows that 

qualifications, training, and continuing 

education are all important for inspectors and 

reviewers. But those factors alone do not 

guarantee a good inspection. Well trained and 

qualified inspectors can do a poor job without 

good forms, adequate time, or appropriate 

compensation. 

Competence should be outcome-based and 

not simply measured by having the appropriate 

qualifications and training. Any proposal should 

incorporate these elements so that a professional 

inspector is well-prepared and supported to 

conduct efficient, rigorous inspections and find 

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 fraud if it exists. 

IOIA remains ready, willing and able 

to assist in continuing to build on the strengths 

of the existing organic inspection system. 

Thank you again for the opportunity to 

comment and for your hard work on behalf of the 

sector. 

MR. CHAPMAN: Thank you. Questions? 

Harriet? 

MS. BEHAR: Hi, Kelly. I'm just kind 

of wondering, part of this document was to 

encourage more consistency. I know there's many 

trainings of various certifiers in-house, and 

IOIA does trainings. 

But not everyone is trained to the 

same level, to the same quality, and we all know 

one inspector, it's a very unique position, has 

different -- So I'm just wondering, when you were 

saying it doesn't belong with the NOP, can the 

NOSB and the NOP play a role in encouraging 

consistency? 

MS. MONAGHAN: Thank you, Harriet. I 

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 absolutely think that they can. I think what 

IOIA wanted to say there is just the way that the 

USDA in 2002 didn't sort of reinvent the wheel by 

taking over the existing third party system. 

We just want to re-emphasize, I think, 

that there are structures in place within the 

ACA, within certain certifiers, and certainly the 

IOIA, that can provide a good foundational 

building block for a type of standardized system. 

I think Jenny's comments yesterday 

regarding the ACA survey that happened this week 

or this summer, and I believe you have the 

summaries, will provide all of you with a really 

good indication of some of the disparity and the 

importance for standardization. And IOIA 

absolutely supports that. 

MR. CHAPMAN: Scott? 

MR. RICE: Just a quick comment 

reiterating that I think the goal is to reduce 

that or not have that redundancy of reinventing 

the wheel. And I understand that the NOP and 

IOIA have had some good discussions to see where 

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 the program can fill in those gaps, and have a 

role, and not supplant the good work that you 

guys have already done. 

MS. MONAGHAN: Thank you. 

MR. CHAPMAN: Dave? 

MR. MORTENSEN: This is an area that 

I'm less familiar with, how this works on the 

ground. But I was interested, from the farmers 

from Costa Rica that we're discussing, how in a 

bad case, music is made when you have a farmer, 

an inspector, and an exporter that are working 

together to work around organic regulations. 

I don't know if you were hearing that 

earlier. But his point was, which I thought was 

very interesting, that having a community of 

farmers police the farmer to inspector 

interaction in a local region was a very 

effective way of keeping things on the up and up 

with regard to fraud in a local area. 

Do you know, is that a common 

occurrence, that farmers in a community, whether 

it be in Croatia or in Costa Rica, are working 

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 together to ensure that the local process on the 

ground in the country is actually working 

effectively? 

MS. MONAGHAN: I'm afraid I don't 

personally know that, Dave. But notwithstanding 

the fact that I'm standing here, I will ensure 

that IOIA can provide a written response to that 

question. 

I know that IOIA absolutely supports 

peer mentoring, field inspections, group 

inspections, and increasingly does that in order 

to, you know, raise the bar for the 

qualifications of the inspectors and help each 

other grow in groups and region. 

MR. CHAPMAN: Thank you. 

MS. MONAGHAN: Thank you again. 

MR. CHAPMAN: Up next is Rebekah 

Ritson followed by David Hiltz. Rebekah, if you 

can start with your name and affiliation. 

MS. RITSON: Good morning. I'm 

Rebekah Ritson, Organic Regulatory specialist for 

Grain Millers. Thank you for the opportunity to 

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 provide oral comment today. 

Grain Millers is a whole food 

ingredient manufacturer and merchandiser 

headquartered in Eden Prairie, Minnesota. We 

have been involved in organic food production for 

more than 30 years. 

We appreciate the hard work and 

dedication of the NOSB and would like to offer 

comment on two of the proposals from the 

Compliance Accreditation and Certification 

Subcommittee that we feel will lead to positive 

change and improved organic integrity industry 

wide. 

Regarding the proposal for developing 

criteria for risk-based accreditation oversight, 

we are eager to see this proposal move forward. 

Ensuring all certifiers are held to a high 

standard and provide consistent oversight of 

their certified operations is critical to the 

organic industry's reputation and personally to 

our business. 

Right now, the proposal is somewhat 

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 unclear on how the identification of inspectors 

would impact the frequency and/or length of 

accreditation audits for certifiers. 

We do want to voice our support of 

more frequent audits for certifiers identified as 

high risk and echo the Organic Trade 

Association's call for additional development of 

the identified risk factors via matrix or other 

risk assessment tool. 

In addition to the excellent list of 

risk factors that you've already identified in 

the proposal, we would suggest that significant 

changes in the number of certified operations 

overseen should be included as an indicator of 

risk. 

And what I mean by that is substantial 

increases in a certified operation just in a 

given year or a couple of years without 

appropriate staffing adjustments, restructuring, 

or other changes to operational management, can 

result in overextended staff with detrimental 

impacts on quality inspection reviews and, just 

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 frankly, possible noncompliances being missed. 

Substantial decreases in certified 

operations is also an indicator, because it could 

be due to service, timeliness, or other issues 

that are pervasive throughout the certification 

agency. 

We also strongly support the inclusion 

of Factor Number 8 on incomplete or minimum data 

reporting as a risk factor. We would ask that 

you expand upon that factor to encompass other 

data quality measures such as frequency of 

updates, duplicative entries, and other data 

quality measures that I'm sure are available when 

determining risk associated with Organic 

Integrity Database reporting. 

Regarding the training and oversight 

of inspector and certification review personnel, 

we wholeheartedly support the standardized 

curriculum for all organic inspectors, including 

scored online trainings to establish a minimum 

baseline of inspector knowledge and skills. 

In particular, we would ask that this 

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 training include more comprehensive audit trail 

exercise training. Mass balance audits, and 

really all audits, are an area where great 

improvements need to be made. 

We would also encourage advanced 

trainings in forensic accounting, evidence 

development, sample collection, and traceback 

investigations as a requirement for all 

inspectors that conduct unannounced inspections, 

as these are often a major component of 

investigation into fraud or persistent regulatory 

compliance problems. 

Finally, we recognize the value of 

inspector pairs or teams for highly complex or 

very large operations and would like to voice our 

support for the implementation of this practice 

as soon as possible, as it would likely increase 

the efficacy and quality of inspections for these 

types of operations. Thank you. 

MR. CHAPMAN: Thank you. Harriet? 

MS. BEHAR: As a buyer of grain, do 

you ever require a certain type of seed of your 

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 growers? And is that seed always organic? 

MS. RITSON: I think that may tie back 

to the written comments that we submitted. I am 

not the best person to answer that question, but 

I will do my best. 

Particularly for our organic soybeans, 

we do have buyers in Japan that are looking for 

really specific characteristics and traits. And 

so we do contract with our growers to produce the 

seed that has those traits. We do our best to 

source organically, but some years that's well 

below 50 percent. And in talking it over with 

our crop specialists, the best they've ever been 

able to do is about 60 percent. 

MR. CHAPMAN: Thank you very much. Up 

next is David Hiltz followed by Trudy Bialic. 

MR. HILTZ: Good morning, and thank 

you very much. I'm David Hiltz. I'm a 

regulatory scientist with Acadian Seaplants. 

We're a marine plant company from Nova Scotia, 

Canada. 

I want to offer thanks to the NOP and 

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 the NOSB staff for all of their past and ongoing 

work. We appreciate the opportunity to provide 

input on marine materials which is a subject that 

we have commented on many times, beginning at the 

2003 meeting in Austin. 

Acadian appreciates the ongoing 

efforts of the Board to ensure sustainable 

harvest of marine plants. However, we continue 

to be concerned about the language and various 

discussion documents that present the overharvesting of ascophyllum nodosum as an accepted 

fact. 

For example, in the most recent 

discussion document, it would suggest that 

scientific community has concluded that 

widespread over-harvesting is occurring, in 

contrast to the industry position that current 

activities are sustainable. 

This conclusion is not consistent with 

many of the comments on record from renowned 

phycologists and marine scientists such as 

Doctors Brawley, Beal, Fegley, and Ugarte whose 

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 research has led to the conclusion that 

ascophyllum is currently being sustainably 

harvested. 

For those who are unfamiliar with the 

harvest of ascophyllum, manual or mechanical 

cutters move across the inner tidal zone and 

remove the top portion of the algae while leaving 

the holdfast and the thallus of the plant intact. 

This allows for a rapid regrowth in 

subsequent years with average growth rates being 

15 to 20, or sorry, 12 centimeters which is 

approximately five inches in our areas. 

Harvesting is mostly regulated by 

local governments and laws that limit the amount 

of ascophyllum that can be removed in a given 

year. Current allowed exploitation rates range 

from 17 to 23 percent of the amount of 

ascophyllum in a given shore sector. 

And it should be noted that this 

allowed harvest rate removes less material than 

estimates of biomass that is naturally shed from 

the beds annually due to storm and wave action. 

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 The suggestion that there are no old 

growth areas of ascophyllum in Nova Scotia or 

Maine is not consistent with facts. In Nova 

Scotia, for example, the total annual harvest is 

less than ten percent of the estimated standing 

stock. In Maine, it is less than two percent of 

the estimated standing stock. 

There are many beds of ascophyllum in 

both areas that have never been harvested due to 

their geographical locations or their 

conservation efforts in the areas. 

It is not in the interest of Acadian 

or any other marine plant company to harvest 

ascophyllum in an unsustainable manner. The end 

result of that would be the creation of a market 

that we could not then fulfill. 

It is for this reason that our company 

has employed a team of marine scientists and has 

used their findings to create a science-based 

regulated seaweed harvest that has been 

recognized as a model of integrated ecosystembased managements that is being adopted in other 

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 jurisdictions around the world. 

Thank you for your time. 

MR. CHAPMAN: Thank you. Emily? 

MS. OAKLEY: I'm so glad that you're 

here, because you didn't provide written 

comments. So I'm glad to be able to ask you 

questions. 

You made two points, one that it's not 

in your interest to over-harvest, and that you 

have a team of scientists on your staff which 

seems like it would lend itself ideally to being 

able to support certification to the wild-crop 

standard. 

What are your thoughts on that, 

firstly? And then I have a follow-up after that. 

MR. HILTZ: Thanks, Emily. So 

certification of the wild-crop standard, the 

material that Acadian Seaplants currently 

harvests for our crop inputs is not currently 

certified for wild harvest. 

But we do have a division of our 

company that manufactures the dried seaweed meal 

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 for use in animal feeds and human supplements. 

That material is currently certified. We have a 

certifier in Canada that does certify that 

material to their interpretation of the NOP wild 

harvest rule. 

Yes, I mean, certainly we could 

probably expand all of our harvest to cover that. 

We feel that the rules, as they're currently 

written, are open to that. But they are 

ambiguous in the fact that it is up to the 

interpretation of the certifier as to how they 

would do that. 

So if that is going to be -- moving 

forward with the Board we hope there would be 

more concrete rules put in place for that. 

MS. OAKLEY: Thank you. And then you 

said that government regulations already limit 

harvest rates. And so I was wondering if there's 

a percentage of your boats or operations that are 

annually reviewed by those government entities. 

MR. HILTZ: So in Canada, for example, 

there's an annual report made to the Department 

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 of Fisheries there that details all of the 

sectors that we have been licensed to harvest. 

It looks at the assessments that our scientists 

have done in cooperation with scientists from the 

government to agree on an amount of biomass in 

that sector. 

It then reviews the landings that we 

bring in from that harvested sector in that year 

and matches the two up to make sure that we're 

not in any way over-harvesting. We have a 

resource team in place as the harvest is going on 

to make sure that we're not doing that. Because 

again, we don't want to damage that resource. 

We're depending on it for the subsequent years. 

MS. OAKLEY: So just to follow-up, no 

one actually, from the government, does onsite 

inspections right now that's, like, on the boats 

themselves? It's more of a dialogue with the 

scientists in an office, just to clarify? 

MR. HILTZ: That absolutely is true. 

I can check with my resource team, but I do not 

believe the government places inspectors in the 

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 field to look at that. 

MR. CHAPMAN: Asa? 

MR. BRADMAN: Yeah, I just have a 

question about impacts on fauna or other aspects 

of the ecosystem. I can imagine a situation 

where, you know, your nutrient extraction is 

replicable and sustainable over time. It's 

sustainable and it says that it's replicable over 

time. 

But are there other impacts on fish, 

or shellfish, or other marine life that are 

considered in -- you mentioned licensing or other 

evaluations of impacts on the environment. If 

you could comment on that, I'd appreciate it. 

MR. HILTZ: Yes. Thanks for the 

question. And in more recent years, we are 

seeing inquiries from the public and other 

agencies who are looking for information on that. 

A lot of the early research that 

Acadian had done was focused more on the 

sustainability of the ascophyllum itself. But as 

those questions have come up, we've started to 

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 interface with more groups, especially in Maine, 

working with the Maine Seaweed Council and other 

scientists there to try to understand what 

impacts that our harvesting could be having. 

We've been harvesting for 30 years in 

Nova Scotia. And we've seen no negative impacts 

of the harvest there on any local fish, fauna, or 

anything else. 

MR. BRADMAN: When you say you've seen 

no impacts, how do you come to that conclusion? 

What information are you using? 

MR. HILTZ: Just the conclusion that, 

you know, that has been observed in the 

environment. You would think that if years and 

years of this harvest, which has been going on by 

us and even before us, was having some negative 

impact, it would have been observed by the 

Department of Fisheries and Oceans there who are 

studying the rockweed harvest that they regulate 

up there. 

MR. CHAPMAN: Dan? 

DR. SEITZ: So we heard diametrically 

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 opposite testimony about Nova Scotia. Why would 

you think there would be such a difference in 

terms of your perception versus other testimony 

we've heard? 

MR. HILTZ: Sorry, you heard testimony 

--

DR. SEITZ: We've had diametrically 

opposite testimony about the adverse 

environmental impact in Nova Scotia from the 

harvesting of rockweed. So why do you think your 

perception and that perception are so far apart? 

MR. HILTZ: I'm not sure what that 

researcher who provided the information in Nova 

Scotia is drawing their conclusion on. 

Our head resource scientist has worked 

with Acadian for 25 years to study the 

ascophyllum resource. We've worked extensively 

with the Department of Fisheries and Oceans up 

there who regulates this resource to do studies 

that show that what we're doing is sustainable 

and any effects that we're seeing on the 

ecosystem are short-term. 

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 I don't know what else to say. To 

suggest in Nova Scotia that there are no areas of 

ascophyllum that have never been cut is just not 

consistent with the facts. We've mapped the 

entire coastline up there. There are areas that 

we don't harvest from, there are areas that other 

companies don't harvest from just because of 

their location. 

MR. CHAPMAN: Thank you very much. 

MR. HILTZ: Thanks for your time. 

MR. CHAPMAN: Up next is Trudy 

followed by Nathan Hecht. Trudy, you can start 

with your name and affiliation. 

MS. BIALIC: My name is Trudy Bialic. 

I represent PCC Community Markets. We are a 

community-owned and operated grocery retailer in 

the Seattle metropolitan area. We have nearly 

60,000 members. So I'm speaking as both a 

retailer and a consumer -- as a consumer voice as 

well. 

First, I want to thank Michelle 

Arsenault for her support over the many years and 

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 Dr. Tucker for her service in stepping up for the 

program as well. Thank you. 

In many cases, the consumers 

connection and relationship with organics is on 

the ingredient panel. That's what they see. So 

we want to comment on flavors and gums, if I can 

get the time to get to gums. 

On flavors, we oppose relisting 

flavors as a category. We are asking that NOSB 

can push the industry to show progress in 

developing and adopting organic flavors according 

to the original 1995 plan set by NOSB and also to 

set a deadline to sunset non-organic flavors. 

FDA we know allows manufacturers to 

conceal production of flavors as confidential 

business information. FDA does not require 

flavor companies to disclose ingredients of all 

the chemicals or grass. And companies can 

maintain secrecy of their formulas and hide that 

flavors are produced in ways or with substances 

that they may not wish to disclose. 

In fact, under US law, biotech 

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 generated compounds are legally classified as 

natural flavors. Natural cheese flavor, for 

example, can be a production, a product of 

biotechnology as well as a biotech substitute for 

MSG called S336 which is called natural flavor on 

the label. 

Organic consumers do not want 

mysterious flavors in their food. And with the 

lack of transparency between CBI and also this 

loophole under the US law, it makes it really 

difficult to know the origins or the process that 

these flavors are developed. 

We believe, actually, that consumers 

want organically produced flavors in organic 

foods. So it would be very important for the NOP 

and certifiers to explain to consumers how they 

can determine that flavors in organic products 

actually meet the requirements of the annotation. 

When flavors were approved for 

addition to the national list, NOSB laid out a 

plan that included a provision that manufacturers 

should document in their handling plans progress 

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 towards wholly organic natural flavors. So given 

the concerns voiced, actually, also by the 

Handling Committee, we feel that the proposal 

doesn't go quite far enough. 

And to make sure that we progress 

towards the original 1995 plan, it's been almost 

20 years after all, we would ask that the NOSB 

propose setting a deadline for realizing the 1995 

plan by adding an expiration date to the proposed 

listing. 

On xanthan gum, we urge NOSB to sunset 

xanthan gum. Any plain reading of 205.600 would 

show that it prohibits synthetic additives used 

primarily to recreate or improve texture such as 

xanthan gum. We believe it's illegally and 

improperly listed on the list, since its primary 

purpose and use is to create or improve texture. 

Thank you. 

MR. CHAPMAN: Thank you. And, Judy, I 

have a question and then, Emily, did you --

Emily, Dan and then Steve. Hold on, and then 

Harriet. 

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 So, on that last point you raised 

about plain reading 205.600(b), I have it here in 

front of me and it reads, in addition to the 

criteria as set forth in the Act, any synthetic 

substance used as a processing aid or adjuvant 

will be evaluated against the following criteria. 

And then, the criteria you cited is 

then listed. 

So, I guess, can you explain to me how 

xanthan gum is used as a processing aid or 

adjuvant? 

MS. BIALIC: It's usually as a 

stabilizer or texturizer, but it's used to 

improve texture primarily. 

MR. CHAPMAN: As an ingredient? 

MS. BIALIC: As an ingredient. 

MR. CHAPMAN: But not as a processing 

aid or adjuvant? 

MS. BIALIC: No, not --

MR. CHAPMAN: So then --

MS. BIALIC: -- to my understanding 

because it's listed on the ingredient panel. If 

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 it was a processing aid, it would not be on the 

ingredient panel. 

MR. CHAPMAN: So, given that that 

further requirement is restricted to only 

processing aids and adjuvants, how is that 

applicable to xanthan gum? 

MS. BIALIC: Because it's a synthetic 

and it's on -- it's a synthetic and a synthetic 

should not be used primary -- it's primary use 

should not be used to create -- recreate flavor 

or texture. 

MR. CHAPMAN: So, we should require 

that, even though it's not a requirement in OFPA 

or in the standards? Is that what you're saying? 

MS. BIALIC: I'm not -- maybe I'm not 

clear on the question. 

MR. CHAPMAN: 205.600(b) limits the 

further requirement about texture to processing 

aids and adjuvants. 

MS. BIALIC: My question would have to 

do with what -- how adjuvants, it's not defined 

under OFPA. And so, I believe that the adjuvants 

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 are then -- it would be kicked over to a preexisting USDA definition of adjuvants and it 

would be used as an adjuvant in that -- under 

that definition. 

MR. CHAPMAN: And --

MS. BIALIC: And I believe it would 

fit under the adjuvant definition of USDA, 

although it's not an OFPA proper. It's not 

defined under OFPA. 

MR. CHAPMAN: Can you share that 

adjuvant definition? 

MS. BIALIC: I don't have that on me, 

no. 

MR. CHAPMAN: Okay. 

Next up is Emily. 

MS. OAKLEY: You can skip me. 

MR. CHAPMAN: Dan? 

DR. SEITZ: You ran out of time. I 

was wondering if there were any other substances 

that you wanted to mention? 

MS. BIALIC: I would like to mention 

that gellan gum is also a product of bacterial 

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 fermentation and we have had anecdotal reports 

from consumers over the years that they've had 

reactions to products of bacterial fermentation 

causing digestive upset. 

Gellan gum is not listed as grass, so 

that's another concern. It's not listed as grass 

and it also, let's see, there is one study only, 

there's really insufficient evidence overall on 

fermented gums to refute or confirm that there 

are reactions to fermented gums. 

So, one of the asks that we have on 

the fermented gums is that NOSB could add to its 

work agenda consideration of a policy to address 

concerns about these gums produced through 

bacterial fermentation. 

MR. CHAPMAN: Steve? 

DR. SEITZ: We have a petition for 

tamarind seed gum on the docket. Given your 

comments, I could kind of guess what your answer 

might be of whether we should add that or not, 

but could you chime in on that? 

MS. BIALIC: I haven't -- to be 

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 honest, I haven't studied tamarind gum. Is it --

if it's a product of bacterial fermentation, it 

would fall under that request to add to the work 

agenda. 

DR. SEITZ: It's not --

MS. BIALIC: Okay. The other gums --

DR. SEITZ: It's a fermented agent. 

MS. BIALIC: -- the locust bean gum, 

the carob bean gum, the tamarind gums, those gums 

we have no objection to. 

MR. CHAPMAN: Harriet? 

MS. BEHAR: This is more a question 

for Lisa, our Handling Committee Chair. 

Are you -- just, there were some 

questions about adding things to the work agenda, 

especially the flavors, perhaps. 

So, I'm just wondering if your 

Committee will take that under advisement? 

MS. DE LIMA: Sure, I mean, I keep a 

list of everything that comes up in public 

comment and we'll discuss it when we get back to 

Subcommittee. 

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 MR. CHAPMAN: Ashley? 

MS. SWAFFAR: So, where were you last 

year on carrageenan? I believe you said that you 

wanted it de-listed also. 

MS. BIALIC: Correct. 

MS. SWAFFAR: And now, you're saying 

gellan gum should be de-listed which many, many 

manufacturers used as an alternative to 

carrageenan. 

They listened to consumers and 

retailers and replaced it with gellan gum. And, 

we've heard from them that gellan gum is the only 

alternative. 

So, are you suggesting we should just 

eliminate an entire class of products? 

MS. BIALIC: There are -- I don't know 

about all the gums, but the locust bean gum, the 

guar gum, the carob bean gum, we don't have 

objections to. 

We are concerned about the fermented 

bacterial gums because of the anecdotal reports 

that we've heard. 

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 And, there was something else I wanted 

to say about that and I can't remember what it 

is. 

MS. OAKLEY: I mean you quoted a --

MS. BIALIC: Oh, yes, it actually 

narrows the market choices because a lot of 

times, they're in inorganic foods, they're 

commonly derived from wheat, corn, soy. 

So, if you're gluten free or if you're 

allergenic, it's really narrowing the choices 

that you can purchase as an organic consumer. 

They have to avoid those because there's no 

transparency on how these gums -- what these gums 

are derived from. 

Xanthan gum or gellan gum, they can be 

corn, soy or wheat. 

So, if they don't know how they're 

derived, it means that all those consumers who 

may be sensitive to corn, wheat or soy don't buy 

those products. 

So, while they may be functional, 

there's no transparency in those particular two 

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 gums. And, it can be a detriment to enlarging 

the market. It's narrowing the market, in our 

view. 

We're seeing customers not buy these 

products because they can't tell what they're 

made from and they're having -- some of them are 

having reactions. 

MS. OAKLEY: So, carrageenan would be 

the alternative for them? 

MS. BIALIC: Carrageenan, they had --

they were avoiding as well. They were avoiding 

as well. 

MS. OAKLEY: Right, and I understand 

they avoid that. But, for those people who have 

sensitivities and allergies for the gellan gum, 

carrageenan is an alternative. 

MS. BIALIC: I would --

MS. OAKLEY: Or a product that has to 

have some type of something to suspend it or 

something like that. 

MS. BIALIC: Well, you know, I think 

it gets down to the question of essentiality. Do 

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 you really need gums for these products to exist? 

Why not shake them up? 

And, that's what we hear from 

consumers. They say, we don't want these gums in 

there. So, they don't buy them. 

And we saw the market react to 

carrageenan and we're seeing the market react to 

some of these other gums, too. 

MR. CHAPMAN: Emily? 

MS. OAKLEY: You had -- sorry -- I'm 

over here. 

You touched on what I was going to ask 

originally which was consumer confidence or 

concern about these products. 

So, you're saying like how many 

consumers are you hearing from or how widespread 

of an issue do you feel this is in terms of the 

ingredient lists of these products and consumer 

concern over their inclusion? 

MS. BIALIC: It's a really good 

question. I can't quantify it and that's why I 

bring it up. And, I acknowledge openly, its 

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 anecdotal and there just simply isn't enough 

research on gellan gum, for example, to refute or 

confirm the reports that we've heard. 

I've looked and I've only found one --

and one study I included in my comments and it 

referred to they fed rats for four weeks on 

gellan gum and they found that the intestinal 

microvilli adhered to one another and decreased 

digestion of nutrients in the gut. 

We cannot confirm or deny that because 

there's no other evidence to concur it to. But, 

it does seem like a bad idea to us to eat 

something that's sticky, that can't be digested, 

has no nutritional value, may impair the ability 

of the microvilli and may decrease digestion of 

nutrients. 

That just doesn't seem like a good 

idea. And, on top of hearing from consumers that 

they are having reactions or it's restricting 

their purchases because they're allergic to corn, 

soy or wheat, combined, there is some reaction. 

I can't quantify it and we aren't 

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 surveying our members, but we are hearing from 

them and we do a customer service database with 

comments from customers. I included a couple of 

comments in my written remarks. 

MR. CHAPMAN: A follow up to the 

allergen questions. Can you help me understand 

why the Food Allergen Labeling Consumer 

Protection Act is insufficient to protect organic 

consumers from corn, soy and wheat allergens? 

MS. BIALIC: I'm not -- I certainly 

don't mean to suggest that it's inadequate, but 

without really knowing, they can't determine. It 

may contain corn, soy or wheat would be a label. 

It wouldn't necessary say it does. 

So, they can't tell whether it's 

something that they're allergic to or not. 

MR. CHAPMAN: Okay. 

And, then, following up in the series 

of questions that I started with, I spent the 

five-ish minutes that you were getting peppered 

with other questions to try and search the interwebs for a USDA definition of adjuvant. I was 

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 unable to find one that was relevant to food. 

And, frankly, I'd be surprised if 

there is one from the USDA related to food since 

most of the food regulation for the USDA, at 

least for a consumer packed product, would be 

limited to, like meat products through FSIS. 

So, and then I tried the FDA and I 

couldn't find anything briefly. 

So, if you have additional information 

in that regard, it would be much appreciated. 

MS. BIALIC: You know, I tried to 

scout that down myself. I found one with EPA 

which wasn't very gratifying, to tell you the 

truth. 

But, I don't -- it's being used as a 

term referring to adjuvants in OFPA, so it's a 

little bit of a concern that I don't really know 

what that -- how that's being referred to. 

But, in general, an adjuvant would be 

defined as something to help facilitate an action 

or a result or it's a facilitator. So --

MR. CHAPMAN: Yeah. 

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 MS. BIALIC: -- in that respect, a gum 

is a facilitator of texture, in the general 

sense. 

But, yes, there is no firm definition. 

I can't pin it to. 

MR. CHAPMAN: Thank you. 

A-dae? Sorry. 

MS. ROMERO-BRIONES: Hi, so my 

comments are related to your comments on 

lecithin. Would you be the person that I would 

ask about these comments that you submitted? The 

written comments about lecithin? 

MS. BIALIC: Oh, on de-oiled lecithin? 

I don't even remember what I said, to tell you 

the truth. 

MS. ROMERO-BRIONES: So, basically, 

you said that there is organic de-oiled lecithin 

available. And by de-listing it, it would 

increase the organic supply. 

And, you went into great detail about 

the market around soy lecithin. But, there, and 

again, going back to the conversation about 

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 allergens, so there's a lot of people who are 

allergic to soy, so I was wondering if you had 

any information about de-oiled lecithin other 

than soy? 

MS. BIALIC: I don't. I know there's 

safflower lecithin, but I don't know about the 

availability. 

My reference to the soy lecithin came 

out of an OTA report comment from a supplier. 

MR. CHAPMAN: That safflower lecithin, 

is it organic? 

MS. BIALIC: Pardon? 

MR. CHAPMAN:Is that safflower lecithin 

organic? 

MS. BIALIC: I am not hearing you, I'm 

so sorry. 

MR. CHAPMAN: Is the safflower 

lecithin you referenced organic? 

MS. BIALIC: I can't recall, to tell 

you the truth. I believe it is. I believe there 

is organic safflower lecithin on the market, yes. 

MR. CHAPMAN: Thank you. 

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 Dan? 

DR. SEITZ: Having been involved with 

a food co-op for many years, the one ingredient 

that I get the most comments on are flavors 

because that seems like such a strange category, 

natural flavors and people say, gee, what could 

that mean? 

And, I was surprised to hear that that 

could even encompass GMO flavors that are 

developed with GMO technology. 

Can you just elaborate a little bit 

more on just what is the nature of these flavors 

and are there organic flavors across a wide 

spectrum of different needs? 

And, what would happen if tomorrow 

these so-called natural flavors were not allowed 

in organic products? 

MS. BIALIC: I think consumers by and 

large would hope that the flavors in a food come 

primarily from the major ingredients themselves 

and not from a minute compound, that they expect 

that foods are inherently flavorful or should be 

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 inherently flavorful in and of themselves and not 

needing flavors, not needing an additive to give 

-- to make it palatable or appealing. 

DR. SEITZ: Thank you. And, just can 

you elaborate a little bit more on the range of 

actual substances or technologies used to make 

the so-called natural flavors? 

Because you intimated that you can 

have GE manufacturer and some would actually be 

probably more, quote, natural in some sense. 

So, if you could just give us a little 

sense of sort of this spectrum of that term 

encompasses, if you have that knowledge. 

MS. BIALIC: The definition of natural 

flavors, I don't have it before me, but the 

definition, as I recall, refers to -- it includes 

-- or products of fermentation. 

And so, it's the clause, products of 

fermentation that allow genetically engineered 

products to be included. 

It's actually a definition. And, I've 

talked to Consumers Union, example, for about 

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 this definition and they felt that it was --

Michael Hansen felt that it was a good 

definition, if I may quote him, I hope I'm not 

out of line on that. 

He felt it was a good definition and -

- but it does -- it was created before genetic 

 engineering, so the loophole comes because of 

that emerging technology in the '90s. 

That's the reason that genetically 

engineered flavors may be included. 

The definition, though, essentially is 

sound. 

As far as availability of organic 

flavors, I don't believe that we have done a good 

enough job in pushing the industry to comply with 

that 20-year proposal from 1995. It's been 20 

years, that's a long time. 

I think our ask is that it be added to 

work plan to make the manufacturers show 

progress. 

But, we are concerned about how --

what kind of transparency there can be or how can 

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 a certifier verify that a flavor is not produced 

in prohibited -- with prohibited methods? 

It's not a transparent process and 

without having transparency, and coupled with the 

loophole, it makes it very difficult. 

MR. CHAPMAN: Thank you. 

MS. BIALIC: Thank you. 

MR. CHAPMAN: Thank you for 

withstanding our several questions. 

Up next is Nathan followed by Jose 

Hernandez. 

If you could start with your name and 

affiliation? 

MR. HECHT: Yes, good morning, NOSB 

members. 

My name is Nathan Hecht. I am a 

graduate student of research here at the 

University of Minnesota in the Organic and 

Sustainable Food Systems Research Program. 

We would like to comment on the 2018 

research priorities for organic crops. 

By way of introduction, I'd like to 

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 just briefly highlight our recent research 

efforts in organic food systems which has 

included, among other projects, nitrogen 

contributions from legume cover crops, nutrient 

cycling and soil health in organic cash crops, 

inter-cropped or in rotation with cover crops, 

season extension options for northern climates, 

organic management on spotted wing drosophila, 

organic production of day-neutral strawberries 

and yield benefits of pollinator farmscaping 

flower strips. 

As research scientists at Minnesota's 

Land Grant Institution, we are passionate about 

helping to guide the regional organic sector with 

research-based solutions to complex agri-food 

challenges. 

We, as a research community, are 

uniquely aware of both grower priorities and 

interests as well as the current gaps in academic 

knowledge where more research funding and support 

is critical. 

After review of the 2018 research 

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 priorities, we would like to highlight and 

comment on the following areas of organic crop 

research that we believe are important for --

specifically for the future of Minnesota organic 

agriculture and are worthy for consideration by 

the NOSB. 

So, to begin, we request the Board for 

research on what I'm calling agroecological 

farmscaping practices. These are landscape 

design and planting strategies organic growers 

can use to integrate a diversity of plant forms 

into their farms and better manage biodiversity 

based ecosystem services. 

One example of this is managing for 

natural enemies and wild pollinators by 

establishing or conserving natural habitat areas. 

So, in this slide, this is a figure 

from the Xerces Society that sort of highlights 

some examples of farming for pollinators and this 

next one highlights some examples of farming for 

natural enemies. 

And the point is sort of the holistic 

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 and diverse -- biodiverse landscape that you can 

see there. 

So, we need more research on, (a) crop 

yield cost benefits -- costs and benefits of 

establishing beneficial insect habitat for pest 

natural enemies and pollinators and, (b) the 

influence of landscape context on farmscaping 

practices. 

We also request support for further 

research on covered agriculture including high 

and low tunnels, greenhouses and gold frames. 

You can see on the left some examples 

of low tunnels for strawberries and, there on the 

right, a prototype of a deep winger greenhouse. 

Given the unique climatic challenges 

of growing at more northern latitudes in 

Minnesota, research is crucial in helping farmers 

figure out how to extend the growing season, 

increase profits and mitigate risks. 

More research is needed on all aspects 

of growing in these systems including quality of 

plastic used for tunnels, sustainable soil as 

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 potting mixes, appropriate cultivar development, 

disease and pest management and a nutrient water 

and waste cycling. 

Finally, in all areas of organic 

research, we request support for research that is 

both interdisciplinary, that is that it aims to 

collaborate between traditional and academic 

departments and participatory involving 

stakeholders, especially farmers in all steps of 

the research progress. 

Thank you for attention and 

consideration. We are grateful for this 

opportunity to share our perspective with the 

hope that it may help to guide USDA's efforts and 

we honor your service and your dedication to the 

improvement of the U.S. organic agriculture. 

Thank you. 

MR. CHAPMAN: Emily? 

MS. OAKLEY: I just wanted to thank 

you for commenting on research topics, because 

I've been doing this lead for three years now and 

it's nice to have someone come up and speak 

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 exclusively to that. So, thank you. 

MR. HECHT: Thank you. 

MR. CHAPMAN: Harriet? 

MS. BEHAR: I second that and I 

encourage you to continually send us ideas. 

MR. CHAPMAN: Thank you very much. 

Up next is Jose Hernandez, followed by 

Terry Shistar. 

MR. HERNANDEZ: Yes, good morning. My 

name is Jose Hernandez, I'm from St. Paul, 

Minnesota. I am an agronomist. I was trained in 

agronomy in Costa Rica at the Earth University 

and now I hold a PhD in soil science from the 

University of Minnesota. 

I worked for about eight years in 

research and outreach in the areas of nutrient 

management and soil quality at the University of 

Minnesota. 

And now, I work as an R&D manager for 

a Canadian company, Precision Farming. 

I come here today to represent organic 

consumers. My family and I are of the organic 

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 consumers and we are members of an organic 

community support to agriculture farm and we also 

buy organic at our co-op in the Mississippi 

Market every week for about 18 years now since we 

live here. 

We value the organic certification and 

the standards. I understand the Board today is 

reviewing their position on the use of ethylene 

as an allowed synthetic for organic pineapple. 

As a consumer, I am here to ask the 

Board to support the use of ethylene in organic 

pineapple for flower induction. 

As a consumer, I am primarily 

concerned about pesticide usage and abuse, 

effects in the environment and residues of these 

chemicals in the food we ingest as well as best 

economic practices. 

I think the ethylene use for flower 

induction is safe and, moreover, there is not a 

viable alternative for organic producers. 

Prohibiting the use of ethylene will 

be devastating for small pineapple producers as 

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 some of these growers -- some of these many cause 

undesirable consequences like some of these guys 

may go back to conventional pineapple, for 

example, and maybe force or maybe causing --

maybe exposing people to pesticides, you know, 

workers, families, towns, water waste soils. 

And other consequences may be they're 

lowering their supply of these pineapples and, 

therefore, increasing prices and making the 

availability of these products for, you know, 

medium and low income families. 

I urge the Board to support the use of 

ethylene for flower induction in organic 

pineapple. Organic farm is critical in our food 

systems and we are facing the same challenges to 

feed a growing population in this world. 

So, we should be using science-based, 

common sense standards and regulation to allow 

our organic producers be competitive in a 

thriving organic farming business. 

Thank you very much for the 

opportunity to comment. 

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 MR. CHAPMAN: Thank you. 

Questions? Thank you very much. 

MR. HERNANDEZ: Thank you. 

MR. CHAPMAN: Up next is Terry Shistar 

followed by Jose Quirce. 

Terry, you can start with your name 

and affiliation. 

MS. SHISTAR: Okay, my name is Terry 

Shistar and I'm on the Board of Directors of 

Beyond Pesticides. 

Board members, with your expertise in 

many areas guide us in our efforts to promote 

organic practices. Looks like I have to advance. 

We've submitted comments on all of the 

issues before the Board at this meeting but I'll 

just address a few. 

First, it's time to stop adding 

listings to 606. It once made sense to allow a 

small proportion of non-organic ingredients and 

processed organic foods if they were not 

available in organic form. 

However, now that the -- any 

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 agricultural commodity can be produced 

organically, listing on 606 only stifles organic 

production of new organic crops and promotes 

chemical intensive production. 

Finally, in the time that it takes to 

add new regulations, petitioners could overcome 

obstacles to supplying the organic products. Do 

not approve the petitions for tamarind seed gum, 

Ethiopian peppers, Japones peppers or collagen 

gel casing. 

Antimicrobials used in medicine should 

not be used in agriculture. The spread of 

antimicrobial resistance is a healthcare crisis 

of major proportions. Many infectious diseases 

are resistant to the most commonly prescribed 

antimicrobials, resulting in longer lasting 

infections, higher medical expenses, and the need 

for more expensive or hazardous medications. 

Microbes of all sorts, fungi and well 

as bacteria, evolve quickly and antimicrobials 

provide strong selection pressure for those 

strains with genes for resistance. 

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 Do not allow the use silver dihydrogen 

citrate of natamycin, which are antimicrobials 

used in human medicine. Natamycin treats 

infections of candida and other pathogens and 

resistance to natamycin is found in candida 

albicans. Ionic silver is used in surgical 

dressings and is associated with bacterial 

resistance to silver and antibiotics. 

Fumigants are not compatible with 

organic production. Organic production uses 

practices that feed soil organisms who feed crop 

plants. It creates healthy soil food webs. 

Using a toxic chemical to wipe our soil biology 

is the antithesis of organic practices. 

Do not approve the petition of ally 

isothiocyanate. It would be difficult to find a 

practice less compatible with organic production 

than soil fumigation with what the technical 

review calls a broad spectrum antimicrobial 

compound that effectively kills both plant 

pathogens and beneficial soil microorganisms. 

Finally, organic production must 

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 protect marine ecosystems. Promotion and 

protection of biodiversity and ecosystem health 

is central to organic production. Marine 

ecosystems are at risk and the organic community 

should protect them from further damage. 

Thank you. 

MR. CHAPMAN: Ashley? 

MS. SWAFFAR: I have multiple 

questions, but I'll just ask the one first about 

SOEs and oxalic acid. 

So, oxalic acid, I share your same 

viewpoint on we don't have apiary standards, so 

why are we reviewing those materials? 

So, I thank you for putting that 

comment in there. 

And then, on SOEs --

MS. SHISTAR: I'm sorry, I didn't hear 

you. 

MS. SWAFFAR: On SOEs --

MS. SHISTAR: Oh, SOEs. 

MS. SWAFFAR: -- you mentioned that, 

you know, we haven't heard from beekeepers and we 

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 maybe shouldn't relist it because we don't have 

standards here in the U.S. 

Are you aware of anything 

internationally since the U.S. doesn't produce 

much honey at all, it's all coming out of Brazil, 

any -- do you know anything about any of that 

production in Brazil? 

MS. SHISTAR: No. 

MS. SWAFFAR: Okay. I might have 

questions later. 

Is that all? Can I go --

MR. CHAPMAN: Sorry, I had Steve, Asa 

and A-dae. 

Steve: 

MR. ELA: I support your comments 

about antibiotic use in agriculture and human 

use. Is there -- would you just draw the line if 

there is any human use for an antibiotic that 

should not be used in agriculture or is there 

some threshold, I mean, if it's extremely minor 

use, I guess, yes, we kind of wrestle with these 

questions that, you know, black and white 

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 sometimes becomes very rigid. 

MS. SHISTAR: Well, it's hard to draw 

a line in a hypothetical situation, right? But, 

the problem is that any time you use antibiotics, 

antimicrobials, you're increasing the chance of 

resistance. 

And, we just don't have that many 

antimicrobials left that can treat human disease. 

So, you know, it would take a lot to convince me 

that something needed to be used in agriculture 

if it was used to treat human disease. 

MR. ELA: And, I guess as a follow up, 

if a, I mean, let's take natamycin which is an 

antifungal, which could reduce rots and things in 

fruits which also have human health consequences, 

for example, patulin and some of those. 

Where -- is there any tradeoff there? 

MS. SHISTAR: Well, I think you have 

other options with the fruit. And, as I said, 

any use of these antimicrobials increases the 

chance of resistance. 

So, even the use in medicine increases 

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 the chance of resistance. So, it's really that's 

where I think the risk benefit needs to be, you 

know, needs to take place. 

My view is that it doesn't belong in 

agriculture because the risks are too high. 

MR. CHAPMAN: Asa? 

MR. BRADMAN: I have a question about 

AITC. Yesterday, there was a suggestion by a 

commenter that there may be a use for AITC with 

nursery stock and that use of it in that setting 

only might actually reduce the use of harsher 

conventional pesticides for nursery stock that's 

produced and then moved into the organic sector. 

And, I'm curious if you have any 

thoughts on that particular use of AITC? 

MS. SHISTAR: Well, first of all, I 

don't think we have any control over what happens 

in the non-organic sector which is where those 

things are being grown, where they're being 

fumigated with those highly toxic materials. 

And, adding, you know, adding 

something to the national list only increases the 

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 risk in organic. It's just not compatible with 

the way we do things in organic. 

MR. BRADMAN: Right, but these are --

sorry, my mic seems to be problematic. 

These are plants that are, you're 

right, they're produced in the non-organic sector 

and then they're moved into the organic sector. 

MS. SHISTAR: Right. 

MR. BRADMAN: So, I guess, again, is 

there a use there that it might actually reduce 

the use of some harsher conventional pesticides? 

MS. SHISTAR: I don't --

MR. BRADMAN: And is that --

MS. SHISTAR: -- see it. 

MR. BRADMAN: Okay. 

MR. CHAPMAN: Okay, I had A-dae, then 

we'll to Rick then Ashley and Emily. 

MS. ROMERO-BRIONES: So, my question 

is regards to your comment on Japones peppers 

under 606. 

So, one of the things I struggled with 

was figuring out how to get information about the 

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 availability of organic supply for some of the 

materials that are being proposed to be listed 

under 606. 

And, in your comments, you mentioned 

that we should take a lesson from the experience 

with hops. Can you just briefly summarize that 

for me? Because I'm not privy to that. 

MS. SHISTAR: Well, the main lesson is 

that, as long as you're allowing the non-organic 

product, there's no incentive to develop the 

market for the organic product. 

The hops was a very complicated thing 

because hops -- because the people who use the 

hops had to contract with the hop growers and 

they're contracting for a specific varieties. 

But, the -- they worked it out, you 

know? And, I think the same thing happens with 

peppers and with just about anything that I can 

imagine being petitioned for 606 is such a long 

period between the time that if you approve it, 

you know, if you were to approve the petition 

here and now, it's going to take at least a 

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 couple years before they can use them because of 

all the regulatory process it goes through. 

And, peppers are not that hard to 

grow. Right, Emily? So, it's something that 

could easily -- there could easily be organic 

producers that fill that market that fall into 

the market in that time. 

MR. CHAPMAN: Then I had Rick. 

DR. GREENWOOD: I had a question. You 

were very definitive about not using antibiotics 

in agriculture. But, I wanted to hope that you 

could clarify that doesn't mean not using them 

for infected animals? 

MS. SHISTAR: Well, what we're -- as I 

understand the regulations, the regulations 

require that organic producers treat infected 

animals --

DR. GREENWOOD: Okay, well I --

MS. SHISTAR: -- but they go out of 

the organic system. 

DR. GREENWOOD: Yes, but I just wanted 

to make sure that that was clear. 

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 MS. SHISTAR: Yes, yes, yes. 

MR. CHAPMAN: Ashley and then Emily? 

MS. SWAFFAR: So, everyone's favorite 

topic is paper pots so I had a question for you. 

So, I always look to you and Jay for 

the conservative voice in the room and --

` MS. SHISTAR: And here we are saying 

that you should have an extension. 

MS. SWAFFAR: Yes, I wanted -- because 

you raised concerns about the adhesives and you 

guys always raise a lot of concerns and I think 

they're always well thought out and I appreciated 

them. 

So, why should we have an extension on 

an item if you have a concern about the adhesive? 

MS. SHISTAR: Well, because I read the 

TR on newspaper and recycled paper and I was, you 

know, when I read it, I think I said this last 

time I was up here, we were lobbying for a TR on 

newspaper because we thought, oh, if all these 

new inks, it's probably, you know, there's 

probably new information that make it less, you 

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 know, maybe things are less toxic, maybe the 

colored inks annotation isn't necessary. 

But then, readying the TR, there are 

so many things that can be in paper. So, you 

know, and then looking at the petition on the 

paper pots, it seemed like this is peanuts 

compared to what is already allowed. 

And that -- and it also seemed like 

the particular -- the adhesives that they're 

talking about are already in the paper. 

So, I, you know, it just -- so, I'm 

looking at, okay, so what if you can't approve 

this petition this time. So, what if you approve 

it the next time, what happens -- well, if you --

if they stop allowing paper pots, then you'd 

have, you know, people going off and finding some 

new way of doing things or else threatening their 

certification and I really don't like that 

tactic. 

But, and then, they come back, you 

know, and say, okay, you've approved them and 

then it'll be a couple years before they actually 

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 use them because it won't go on the list. 

Okay, but what if you approve an 

extension here and then you approve -- and you 

approve something that's on there. If you don't 

approve it, then people have to go do something 

else. 

But, if you do approve it, after 

approving the extension then it causes much less 

disruption and, you know, those people won't have 

had to go. 

And, sure, you would have had, you 

know, it'll still be time for it to be on --

it'll still be a couple years before it's 

actually on the national list. But, you probably 

won't mind proposing another extension at that 

point since you've already approved the material. 

MR. CHAPMAN: Thank you, thank you. 

MS. SWAFFAR: Just one word answer 

follow up. If we were voting on paper pots 

today, would you say to list or not? 

MS. SHISTAR: I couldn't tell you. I 

think that it's important to look at the 

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 technical review and get all the information. 

I'm not going to say that they should be approved 

right now. 

I think it's an ingenious system, it's 

saved a lot of work for a lot of small growers. 

MR. CHAPMAN: Thank you. 

MS. SHISTAR: So, I hope that it turns 

out well. 

MR. CHAPMAN: Thank you, Terry. 

Emily? 

MS. OAKLEY: Two follow ups, one to 

Asa's question about AITC. I mean, I think the 

question the way you were proposing it was 

sounding as if we would approve that material in 

the hope that conventional growers would then use 

it for products or plants that organic farmers 

would then buy. Is that what I was hearing? 

MR. BRADMAN: No. Well, I mean I 

guess my hope would be is that there could be a 

certified organic --

Hello? Is this working now? 

MR. CHAPMAN: Yes, we can hear you. 

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 MR. BRADMAN: -- that there could 

ultimately be a certified organic phyto, you 

know, sanitation certified product that was 

produced entirely with less toxic organic methods 

that can then go into the organic system. It 

would create a market for that kind of nursery 

stock. 

Not that we would approve something 

with the idea that, you know, maybe conventional 

growers would somehow switch out, you know, this 

material. 

MS. OAKLEY: Thanks for that 

clarification. 

And, just to A-dae's point, and I hope 

my head shaking was clear. I was trying to say 

that, Japones peppers, capsicum frutescens and 

it's very easy to grow and I could grow that. 

MR. CHAPMAN: Can you also process it 

into a dried product in a --

MS. OAKLEY: I knew you were going to 

say that. 

MR. CHAPMAN: -- third-party additive 

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 FSMA approved facility? 

MS. OAKLEY: I knew you were going to 

say that, and so, let's carry that discussion 

over to the Handling Subcommittee section. 

MR. CHAPMAN: All right. 

I don't see any other questions for 

you, Terry. Again, thank you for answering our 

numerous questions. 

MS. SHISTAR: Okay. 

MR. CHAPMAN: Up next is Jose followed 

by Laura Batcha. 

MR. QUIRCE: Good afternoon, good 

morning. Good afternoon, my name is Jose Carlos 

Quirce. I'm here today on behalf of the Ministry 

of Foreign Trade of Costa Rica, its trade 

representative in the United States of America. 

I would like to thank the National 

Organic Standards Board for giving us the 

opportunity today to provide our comments and 

suggestions regarding the involvement of ethylene 

gas in the production of organic pineapple. 

In addition, I would like to underline 

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 our recommendation of the transparent way in 

which the United States is conducting this 

rulemaking process. 

I want to take this opportunity to 

respectfully urge the Board to vote against the 

exclusion of ethylene gas from the national list 

and, instead, extend a sunset period for the use 

of ethylene gas in organic pineapple for an 

additional five years in accordance with the 

Organic Foods Production Act. 

Costa Rica has been positioned as 

number one producer and exporter of pineapple in 

the world with more than 2.2 million tons in 

2017. 

Pineapples are Costa Rica's second 

most important products in terms of value and 

Costa Rica is the main supplier of pineapples in 

the U.S. market. 

Producers of the commodity include 141 

exporting companies of which 63 percent 

represents small and medium sized enterprises. 

And, they employ 32,000 workers 

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 according to statistics form 2017. 

Pineapple growers provided 85 percent 

of pineapple imported by U.S. which in 2017 

reached $633 million and 976 tons. 

In addition, in 2017, organic 

pineapple represented 21.5 percent of the total 

organic production in our country. That same 

year, it was the second most important product in 

Costa Rica organic production. 

Organic producers have 1,875 hectares 

of certified organic land growing on an average 

and a rate of 14 percent in yearly basis, taking 

into account the years 2012 to 2017. 

Due to this high productivity levels 

and efficiencies, Costa Rica has positioned 

itself in the right place to increase pineapple 

production from 29 tons to 49 tons per hectares, 

almost 66 percent increase in the last 25 years. 

Costa Rica has decades of genuine 

commitment to sustainable production from both 

pineapple growers and organic pineapple growers. 

The industry is an important 

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 contributor to the export diversification policy 

and the development of our country. 

A change in worldwide regulations like 

the use of ethylene in organic pineapple 

flowering might affect hundreds of people and a 

good amount of small and medium sized producers. 

These producers work hard to 

differentiate their products and to comply with 

market requirements while meeting the strictest, 

most secure safety and health center. 

In all this, ethylene gas is a key 

factor for the production. 

Thank you very much. 

MR. CHAPMAN: Thank you. 

Any questions for Jose? 

(No audible response.) 

MR. CHAPMAN: Thank you very much. 

MR. QUIRCE: Thank you. 

MR. CHAPMAN: Up next is Laura 

followed by Natalie Krout. 

MS. BATCHA: Hi, I'm Laura Batcha with 

the Organic Trade Association and I wanted to 

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 talk to you today about origin of livestock, 

clarify something around flavors, and if I have 

time, to talk about the impact to our membership 

of a shortened period for providing comments on 

the docket for this meeting. 

So, just on the flavors discussion 

that happened before, clarify that the Organic 

Trade Association a few years ago submitted a 

petition to require organic flavors when 

commercially available, passed by the Board, when 

to USDA, went through the proposed rule process. 

We're waiting on a final rule. That petition was 

in accordance with the 1995 recommendation passed 

by the Standards Board. 

So, I just wanted to make sure 

everyone and new Board members understood that. 

On origin of livestock, we've heard 

discussions about it here at the meeting in the 

session and in the hallway. There's really a 

couple of issues. 

One of them is new and one of them is 

old and I have a request for the Board in regards 

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 to this discussion. 

So, the new issue is the sort of what 

we would consider the revelation of the practice 

of moving an animal born to an organic mother out 

of organic production on a certified organic farm 

and then moving it back in later for a retransition one animal at a time. 

That practice is against our 

longstanding understanding of how the rule should 

operate as a trade association. 

The old issue was, of course, the two 

track system and continuous transition that the 

Board passed six recommendations on between '94 

and 2006 for which there was an OIG audit that 

referenced this issue. 

And there was a proposed rule that was 

released, comments were received and the proposed 

rule was closed at USDA. 

We heard from the program, there are 

real challenges around taking clarifying action 

with the underlying rule being the state that it 

is. 

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 Yet, we don't have the proposed rule 

moving to final on the unified agenda at USDA. 

So, this is a conundrum, you can't get 

there from here. So, my request to the Board is 

for you all to consider passing a resolution at 

this meeting urging the Secretary to move 

directly to final rule on origin of livestock. 

The information is all there, 1,500 

comments were received. Five opposed the proposed 

rule as written and those objections to the 

proposed rule were on the basis of there being an 

under supply of milk which we all know is not the 

situation now. 

So, I would respectfully request you 

consider that as you finish your week out. 

On the comment period, I will just 

say, 13 business days where a membership-based 

organization. As the leader of the organization, 

I don't like our positions to be driven by staff 

thinking in a vacuum. 

We reflect the will of our members and 

we have really good processes about how we review 

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 the comments, we form task forces, we go out we 

vet a draft comment, then the working group 

releases the draft comment to the entire 

membership so that thousands of members have an 

opportunity to see where we're going with 

something, provide comment, finalize them, submit 

them. 

That's a lot of process for the team 

to work through in 13 business days. It limits 

our ability to give you guys good input from the 

trade. 

Thank you. 

MR. CHAPMAN: Questions for Laura? 

Ashley? 

MS. SWAFFAR: So, Laura, we heard from 

the program and last year from the Secretary 

about some of the items that this Board has 

worked on and wants to work on that we should 

just have the industry do process verified 

labels. 

Does the trade association have any 

views on adding more labels to products? 

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 MS. BATCHA: So, I think the 

suggestion of PVP being an alternative route to 

advance issues is an interesting one and one that 

we have considered as a trade association and 

done some sort of strategic work amongst the 

memberships and sort of, in theory, it might make 

sense. 

What we've run into in engaging with 

staff at the process verified program through an 

attempt to do that for transitional certification 

program and some other ideas is, again, one of 

these what we're finding ourselves in which are 

Catch-22's. 

So, our thinking on how you might use 

PVP to advance some of this stuff would be that 

it would be entirely tethered to organic. And 

so, you would have to be certified organic first 

and we would want to utilize the existing ACAs as 

the verification arm for whatever this additional 

layer was. 

The feedback that we've gotten most 

recently from the process verified program is 

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 they don't think they can allow cabining and 

tethering to the organic standards and the 

exclusive use of the organic ACAs. 

So, we're getting two different 

conflicting suggestions about how that path 

forward might be an option for us just because, 

quite frankly, we're the Organic Trade 

Association, we're not interested in a process 

verified claim in a vacuum that isn't tied 

exclusively to organic as the base. 

MR. CHAPMAN: Dan? 

DR. SEITZ: I didn't quite understand 

the point you made about flavors. Are you saying 

that the Board has, and if you can refresh my 

memory, that the Board has already put out a 

recommendation that that language be adopted, 

that you must use organic flavors and may only 

use others if organic is not available and that 

hasn't yet been acted on? 

MS. BATCHA: Yes, so I'll do my best 

to clarify. I think most of you that know our 

team at OTA know that I am certainly not the 

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 flavor expert and Gwendolyn is. But, I know 

enough to I think answer your question. 

So, the Organic Trade Association 

petitioned for the change in the listing of 

natural flavors as a nonsynthetic, 

nonagricultural allowed ingredient. 

And, our petition called for there to 

be an annotation to that listing requiring that 

organic be used when available which was 

consistent with what NOSB did back in 1995. 

That petition went through the 

process, to the Board, approved the petition, 

back to USDA. USDA has released the proposed 

rule, received comments on proposed rules, 

closed. We're waiting on a final rule. 

We don't have any indication to think 

that the final rule is stalled in any way. But, 

I just wanted to make sure that the folks on the 

Board understood that the issue came through the 

process. You guys made a recommendation and 

action has happened. 

Does that help? 

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 DR. SEITZ: It helps a lot. Thanks. 

MR. CHAPMAN: Paul, can you at all 

speak to the status of that proposed rule? 

DR. LEWIS: Sure, thank you, Tom. 

So, I think Dr. Tucker mentioned this 

during her opening remarks because we have a 

number of National List rules that are going 

through the clearance process. It's really hard 

in terms to make an estimation for the Board and 

for the public as to when that will go through 

clearance. 

Clearance goes through a number of 

levels. So, we appreciate peoples patience as we 

go through reviewing the public comments and, 

more important in terms of just, importantly, 

going through the clearance process in the 

Department. 

MR. CHAPMAN: Would it be fair to say 

it's being actively worked on? 

DR. LEWIS: Yes, I would say it's 

actively worked on and obviously, briefing 

leadership in the Department in terms of how to 

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 move forward on this. 

Thank you. 

MR. CHAPMAN: Any other questions for 

Laura? 

Laura, in terms -- I have a quick one 

on the comment piece. If we were to piecemeal 

our proposals out, would that meet the needs of 

the Trade Association to get feedback from its 

membership? What other suggestions do you have? 

There's clearly -- there was some --

I'm not sure if you were here earlier, there was 

some explanation of the tradeoff between Board 

time to work on stuff, NOP clearance times and 

then the amount of time the public has. 

What's your suggestions that we --

MS. BATCHA: Yes, so I completely 

recognize that everybody needs more time in the 

system and certainly don't disagree with the 

outline of how long it takes to move something 

through USDA and the time it takes you guys to 

get to a recommendation. 

I think asynchronously posting them as 

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 final recommendations, from my perspective, would 

be a preferred route to posting drafts because I 

think it's just really hard to get to the heart 

of the matter in a membership organization when 

you're having a conversation about something that 

may change by the time it gets posted. 

So, I think I, from a workflow and 

getting really good feedback for the Board would 

prefer to see them posted one at a time as they 

get finalized. 

MR. CHAPMAN: Thank you. 

MS. BATCHA: Thank you. 

MR. CHAPMAN: Thank you, Laura. 

Up next is Natalie followed by Keith 

Lindsey. 

MS. KROUT-GREENBERG: Great. Good 

afternoon, my name is Natalie Krout-Greenberg. I 

am the Director of Inspection Services at the 

California Department of Food and Agriculture. 

I'd like to extend a welcome to the 

two new NOSB Board members, Dr. Greenwood and Mr. 

Schwartz from California. 

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 The Inspection Services Division 

provides inspection and enforcement oversight to 

agriculture commodities in California and 

specific to this audience, Inspection Services 

houses both the California organic input 

materials program and the California State 

Organic program. 

Since Dr. Dale Woods already covered 

specific areas to the OIM program yesterday, my 

comments will be focused on the SOP and reflect 

the work being done relative to the Pasture Rule 

as well as imported grain products. 

California Organic Foods Act of 1979 

established the state organic program. And, in 

2003, the Act was written to conform with the NOP 

standards. 

And then, 2016, it was recast as the 

California Organic Food and Farming Act. 

Some numbers for a perspective, 

California accounts for more that 40 percent of 

all organic products sold in the U.S. and the 

state has 1.7 million acres in organic 

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 production. 

This past fiscal year, the state 

organic program registered over 4,200 organic 

operations in California who process nearly 2,000 

cost share applications reimbursing just over 

$1.1 million, handled over a 100 complaints, 

conducted over 1,400 inspections. 

And, during the past three years, the 

SOP obtained 883 organic samples and analyzed 

them for pesticide residues of which 

approximately 4 percent of the surveillance 

samples were found positive. 

We have seven state staff dedicated to 

organic program, five of which do enforcement 

work solely. And, we hold contracts with 53 

counties who perform work on inspections on 

behalf of the state organic program for CDFA. 

The California Organic Product 

Advisory Committee, or COPAC, makes 

recommendations to the SOP and the California 

Secretary of Agriculture. 

Through public comment and at our 

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 COPAC meetings, the complaint process and 

meetings with organic dairy industry, we have 

heard concerns associated with enforcement of the 

pasture rule as well as imported grain products. 

First, regarding enforcement of the 

pasture rule, there are 85 registered dairy 

operations in California. Our team has been 

working closely with the industry to understand 

the issues and with our partners at the NOP and 

certifiers in the state to address the voiced 

concerns. 

This is an organic enforcement 

priority in our state. 

Second, regarding imported products, 

California is an 86 percent grain deficit state. 

We receive grain by ship, rail and truck in order 

to feed the state's livestock population. 

The SOP continues to work closely with 

our state mandated feed inspection program and 

federal partners to provide surveillance to the 

products coming through our California borders. 

We continue to collaborate with the 

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 NOP and I want to thank Dr. Tucker and her team 

for help addressing these concerns. 

And, finally, I appreciate your time 

as NOSB members and your dedication to that. 

I'd be happy to answer any questions. 

Thank you. 

MR. CHAPMAN: Thank you. 

Any questions? I know I have a 

question. 

Okay, I will go then. So, first of 

all, thank you for speaking. I want to recognize 

as one of the four Californians on this Board. 

And, as people know, any chance I have to brag 

about California. 

There's five? Did I miss someone? 

Who'd I miss? No, there's four of us. Yes, four 

Californians. 

I always take a chance to brag about 

California. I really want to recognize the State 

of California, particularly the CDFA program for 

its contribution to organic integrity and 

enforcement, with the programs you outlined and 

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 the stats you just outlined show the large share 

of the burden that the State of California takes 

up. 

And, it should be recognized that that 

then frees up federal resources for enforcement 

integrity activities elsewhere throughout the 

nation. 

And, that doesn't come free, that 

comes out of costs the California organic 

producers and handlers who then through fees 

assessed on them fund that state organic program. 

And I'm hoping California can, through 

a course of dialogue, share some of its best 

practices its learned in its enforcement program, 

particularly its surveillance program. 

As an organic consumer, I'm always 

heartened when I go to my farmers' market and see 

a CDFA inspector checking organic certificates at 

the market. And I think I spook them when I 

thank them for that activity. 

But, it's heartening to see it 

actually happening out there and seeing that 

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 enforcement at all levels of the supply chain 

beyond, you know, big operators as well as grain 

like you spoke about, also though down to that 

farmers' market level. 

And then, my question for you, if 

you're prepared to answer it was the share kind 

of where are your enforcement challenges and what 

role you would see the NOSB in playing in that 

arena. 

MS. KROUT-GREENBERG: Okay, so, to 

your first point, Tom, and thank you for those 

comments to the state organic program. 

So, for your first point as far as 

relative to our enforcement surveillance work, 

you did mention farmers' markets. 

So, one of the unique things about 

Inspection Services Division, we house three 

particular branches. 

One is our Center for Analytical 

Chemistry which does all of our enforcement work 

tied to analysis. 

The other is our Feed Fertilizer 

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 Livestock Drugs program which Dale is a part of. 

And then, we have our Inspection and 

Compliance Branch. So, that houses organic and 

houses direct marketing and houses our food 

safety program that's handling all things FSMA 

related. 

So, with that, you mentioned, we go to 

farmers' markets, but we have contracts with DPR, 

Department of Pesticide Regulations, tied to our 

chemistry lab. And, when they are out also 

exploring markets whether it's a farmers' market 

or whether in a retail operation, they share that 

organic data with us as well. 

And so, leveraging that, leveraging 

our feed partners, we're able to have 

surveillance arms in multiple facets throughout 

and across the division. 

Regarding challenges, I think we've 

seen probably some of the biggest challenges 

surface within the most recent 12 months to 18 

months. 

And, for us, it was visibility into 

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 our ports of entry. California has 11 ports of 

entry. And, just when you have borders and our 

that much of a grain deficit state, understanding 

and knowing what's coming into those ports was a 

challenge. 

We work closely in our relationship 

with the Food and Drug Administration as well as 

our partners at USDA. 

But, just having that visibility into 

those database systems and how it was working was 

probably the biggest challenge as of late and it 

continues to be. 

And so, that's, I guess, one thing 

that I have continually been working with our 

partners at the NOP to have that added visibility 

as well as our state partners in the feed 

inspection program because they do have a strong 

relationship with FDA in that sense as well, just 

from a food safety perspective. 

But, that, when you marry those pieces 

all together, it gives you added value in that 

surveillance program. 

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 MR. CHAPMAN: Thank you. Thank you 

very much for your comments. 

MS. KROUT-GREENBERG: Thank you. 

MR. CHAPMAN: Up next is Keith Lindsey 

followed by Dolana Blount. 

Keith? Keith, going once? Keith 

going twice? All right, no Keith. 

Dolana Blount, are you here? I think 

you are. 

If you could start with your name and 

affiliation? After Dolana is Alesia Bock. 

MS. BLOUNT: Thank you. 

My name is Dolana Blount, I with PURE 

Bioscience, the petitioner for silver dihydrogen 

citrate. 

I thank you for the opportunity to 

present you with additional comments in support 

of its listing on the national list. 

The need for SDC is especially 

important in organic and conventional processing 

and production. SDC based products like pure 

hard surface disinfectant sanitizer and pure 

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 control processing aid enhance food safety 

practices and support processors in meeting 

robust food safety programs. 

Produce processing which, to date, has 

not seen a processing kill stip available will 

especially benefit from SDC. 

Several food industry leaders 

consultants and our customers including the 

leading produce processor have already shared 

their support for SDC in the written comments. 

SDC is a molecular complex of ionic 

silver weakly bound to a citrate ion. Citric 

acid supports the ion in solution and assist 

entry into the bacterial cell. This is not 

nanotechnology and it does not meet the most 

standard recognized definitions of 

nanotechnology. 

When formulated for use, SDC solutions 

are 95 percent water with silver present only at 

.003 to .016 percent. 

Ionic silver is strongly attracted to 

sulfidal groups which are found in structural and 

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 functional components of an organism and will 

bind to those complexes while silver ions are 

taken into an organism by the citrate. 

This dual mode of action results in 

rapid efficacy while mitigating resistance. 

After use, any remaining silver and 

bacterial waste will be transported into the 

facility's waste water treatment system. 

SDC is used in facilities that have 

either onsite waste water treatment that 

discharge to publically owned treatment works or 

the discharge to surface waters under the 

appropriate EPA or state permit. 

Here, they will be met with 

concentrations of organic matter and other 

compounds, primarily sulfides and be rendered 

inert. 

Only insoluble silver salts and very 

minor amounts of silver ion, if any, are expected 

to survive the water treatment process in the 

facility. 

In the sludge, silver concentrations 

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 are estimated to be approximately 20 fold lower 

than the level required disposal as a toxic waste 

and any silver that can remain in the water has a 

final estimated environmental concentration which 

is below the EPA's national recommended water 

quality criteria for aquatic life. 

This is even under worst case 

assumptions of use. 

Through our registrations with USEPA 

and FDA, the human and environmental exposures 

have been already thoroughly evaluated and 

considered safe. 

And finally, while we recognize what 

you are trying to accomplish by adding the 

particle size restriction to the listing, we feel 

strongly that this misrepresents the petition 

substance. 

There are no particles in SDC so this 

disclaimer is confusing and will require users of 

SDC based products to continually prove that this 

irrelevant criterion is met. 

We feel confident that SDC will be a 

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 positive addition for organic processors and a 

good addition to the national list. 

Thank you for your time and for all of 

your efforts in the organic program. 

MR. CHAPMAN: Thank you. 

I think I'll start with one question 

and then we can have Steve and maybe we'll 

actually start with two. 

So, I want to talk about the nano or 

ask about the nano pieces that you talked on 

there. Because we received several public 

comments about saying that this is nanotechnology 

and I just kind of want to get to the root of 

that. 

Correct me if I'm right in the 

understanding of your logic. This is not a nano 

material because it's less than one nanometers 

and it's not specifically engineered for its 

size? 

MS. BLOUNT: Certainly, yes. It is 

simply ionic silver, so it's atomic in scale. 

There's silver atoms with citrate ions. 

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 Nanoparticles are clusters of silver 

that are then compounded and capped in order to 

prevent aggregation. They are maneuvered to not 

act the way or be the way that a silver ion is in 

nature. 

Ours is a silver salt really no 

different than a silver nitrate which is a 

balance of ionic silver in an organic solution. 

MR. CHAPMAN: Okay. 

We heard from a commenter yesterday 

about fear of using this and I guess there's EPA 

restriction about municipalities being notified 

about waste water containing silver. 

And the fear that this would be used 

in locations not on municipal water. 

Do you have any thoughts or comments 

on that? 

MS. BLOUNT: So, the people -- I don't 

have knowledge of facilities that aren't required 

to report. The facilities that would use our 

product either have, you know, waste water 

treatment facilities in house where what the 95 

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 percent, 94 percent of the silver that would be 

used in our worst case assumptions go to the 

sludge. Any remaining would be in the water, as 

I reported before. 

Those then send out to a publically 

owned water treatment and they would still have 

to notify to them if silver was at a level above 

the EPA concentrations. 

It's only facilities that then 

directly export to waters that would have to go 

under a state permit or an EPA permit. 

MR. CHAPMAN: I guess that's slightly 

different. Would a use of this material -- would 

it be a potential use of this material to wash 

produce in the field --

MS. BLOUNT: No, it is not. 

MR. CHAPMAN: -- directly after 

harvest? 

MS. BLOUNT: No, it is a post-harvest 

-- it's a processing aid when it's used directly 

on produce. It's used within processing 

facilities by definition. It is not a harvest 

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 use at all. 

MR. CHAPMAN: Thank you. 

Steve? 

MR. ELA: I guess following up on that 

a little bit, but I mean, you're talking about 

approved waste water facilities and 

municipalities. 

I mean, for example, our own 

processing plant, we're on septic system. We 

don't have a municipal sewer system. 

So, I'm, you know, I didn't see like 

as we were talking about this that we needed to 

annotate it for only for use in processing plants 

attached with municipal water systems. That 

really hadn't come up until this discussion. 

So, how do we -- I mean, is a septic 

system what you're calling an approved -- I mean, 

that's -- our county approves that, but it's not 

really fitting your definition of what you're 

defining. 

MS. BLOUNT: My comments were simply 

to help you understand that there's two levels of 

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 regulation for the silver's fate in the end and 

that primarily the plants that we deal with and 

the produce processors or the food processors, 

they don't have to just be produce processors, 

typically have onsite waste water treatment. 

In certain areas, we've dealt with 

poultry processors in investigative use where 

they may, instead of going to a publically owned 

work, they may discharge straight to water just 

because their volumes are so small. But that is 

under permit. 

So, I'm sorry if I'm not understanding 

your question. 

MS. ELA: Well, I mean so a septic 

system is somewhere in between the two. It's not 

straight discharge to water because it goes 

through a leech field and such. But, yet, it's 

sort of is. 

And, I think, I mean, in somebody 

hearing we've got a product that now you're 

saying you only sell to these big processors, but 

when we put it on the list, that doesn't limit it 

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 to the big processors. 

And, I mean, we have to think of the 

generic broad based, you know, what could happen. 

And so, how do -- I mean, I'm hearing we need to 

annotate it much more tightly for who can use it 

and who can't. 

MS. BLOUNT: And, I didn't mean to 

intimate that we only sell to large processors. 

The evaluations through the environmental impact 

statement that the FDA made for our -- for the 

use as a direct food application as a processing 

aid took into account what happens to that silver 

waste down the streamline. 

I highlighted for you the largest 

ways. I'm not a waste water expert so I don't 

want to make statements that I can't support 

other than the fact that the EPA has determined 

the use as a surface disinfectant and sanitizer 

and the silver that would end up into waterways 

through any disposal was not of concern based on 

their evaluation as well as the FDA's 

environmental impact statement which is part of 

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 the FCN also made that conclusion. 

MR. ELA: So, would a septic system be 

okay or not? 

MS. BLOUNT: Well, so what I know of 

our product is it is ionic silver which is highly 

reactive with organic matter. So, when you hit a 

septic system, it's going to make all of that 

silver inert. You essentially have an inert form 

of silver, but it's not going to disrupt that 

system. 

MR. ELA: And then, when that tank's 

pump, you can get notify -- I mean, if it's in 

the sludge, because you pump septic tanks you 

then need to notify the municipality that sludge 

goes to? 

MS. BLOUNT: I don't have an answer, 

I'm sorry. 

MR. CHAPMAN: I've got two follow ups, 

maybe easier, maybe not. 

I understand that it's use in relation 

to fruits and vegetables excludes citrus and 

grapes for wine making. Do you know why those 

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 two crops were excluded? 

MS. BLOUNT: Sure. When we were going 

forward, we were looking at the exposure 

allowance that the FDA had. We also didn't feel 

that grapes and citrus were a big market for us 

or a big need for an antimicrobial processing 

aid. It just wasn't something that we felt was 

necessary that we needed to fight for. 

MR. CHAPMAN: Would something with 

those crops lead to a greater exposure? 

MS. BLOUNT: No, the exposures were 

when you do an FCN you say, what are you 

treating? And, what is, you know, the human 

eating habits and exposures based on that? 

What we found in uses that relatively 

no silver is left on the food after it's treated. 

When it runs through the processing process, per 

se, but when you're using a modeled system in 

order to do this, they have weighted averages 

based on consumption practices of people. 

And, that was just some place where we 

felt that it might take us over a comfortable 

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 limit that the FDA might find concerning. So, we 

didn't include it. 

MR. CHAPMAN: Okay. And then, we've 

heard lots of comments about the use of silver in 

medical uses and concerns around, you know, 

microbial resistance. 

Have you heard concerns about this 

from medical associations, from CDC or other 

similar regulatory agencies about microbial 

resistance and the use of this material in 

agriculture or in food production? 

MS. BLOUNT: I have heard none. I 

have heard the comments, you know, that were 

presented here to this group, but I have not 

heard specifically, nor has our company heard 

those same comments. 

I think that Mark Farina shared 

comments in webinars with you about microbial 

resistance and why that's low. Silver has such a 

broad spectrum of action that it's different than 

an antibiotic which you take and you ingest and 

typically are made to have very specific targets 

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 in order to kill microbes that makes an easier 

way for them to grow resistance but with a broad 

spectrum, silver ions work on the outside of the 

cell, on the inside of the cell. 

With SDC, and let me back up, that 

resistance that they see against silver is simply 

in a transient mechanism where when silver is 

present, the cell is able to try to pump the 

silver out of the cell to mitigate the damage. 

That costs the cell a lot of energy. 

It's not sustainable. 

So, with SDC, the beauty is that the 

citrate hides the silver. It's able to get on 

the inside before it's really recognized, before 

that mechanism is established and it's already 

killed the microorganism before that pumping 

action really takes place. 

MR. CHAPMAN: Thank you. I think 

that's all the questions, thank you very much. 

Up next, Alesia Bock and then up last 

is Marty Mesh. 

MS. BOCK: Hi, I'm Alesia Bock. I'm 

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 with AgriSystems International Consulting Group 

for organic clients. 

However, today I'm commenting on my 

own behalf. After hearing some comments today, I 

felt the need to provide some information to the 

Board for your consideration. 

As a food professional, I've been in 

the food industry as a quality and R&D 

professional for almost 30 years and I've been in 

the organic industry for about 20 years. 

And, just some comments regarding what 

you might have heard today. First of all, I 

wanted to say xanthan gum, while you might have 

heard that it's not grass, there's some grass 

information you can self-grass. 

However, xanthan gum is listed in FDA 

Part 172 of 21 CFR Subpart G as a food additive 

directly approved for human consumptions. So, 

xanthan gum is already listed as approved for 

human consumption. 

And, xanthan gum is considered by 

processors to be an ingredient and as needing to 

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 be labeled as such. It's not considered a 

processing aid or adjuvant. If it's functioning 

in the finished product, it must be labeled as an 

ingredient not a processing aid. 

Number two, even if gums such as 

xanthan gum are from microbial fermentations from 

soy, corn or wheat, FDA labeling indicates 

whether the final ingredient is considered an 

allergen. 

Obviously, corn, soy and wheat are 

allergens. However, gums in this case are nonallergenic. 

In the case of natural flavors, while 

I appreciate the need to develop organic flavors 

and potentially take the category of natural 

flavors and make them more specific like we did 

with colors several years ago, I wanted to 

mention that handlers who use natural flavors, 

even if they're not organic, must fill out a 

supplier affidavit from their certifier. 

And I know because we've done it many 

times back before I was a consultant, I worked in 

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 the food industry. We had to show that those 

ingredients were not processed using GMO, 

irradiation or any other prohibited methods. 

And, some of these flavor affidavits 

are about three to four pages long. So, they're 

very in depth. 

So, to state that these flavors may be 

from genetic processing for use for organic is 

incorrect. 

Finally, and I think I need to channel 

John who used to always be last in the public 

comments to increase or maintain the toolbox for 

processors, I normally deal with handling 

comments, but for today, I would like to mention 

that ethylene for farmers, especially organic 

pineapple farmers, my personal opinion, based on 

what I heard today, ethylene's been on the list 

and it's been through Boards several times. 

It's been sunsetted many times and 

stays on the list for a reason. And, for those 

who are using it for organic pineapple farming, 

even though your marketing, NOSB doesn't take 

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 into account the market necessarily for 

commercial availability, they I think please 

consider keeping it in the toolbox because 

converting conventional land to organic, even in 

the case of pineapples in Costa Rica, I think 

would be a good thing for the organic industry 

and consumers. 

Thank you for your time. 

MR. CHAPMAN: Thank you. 

Questions? 

(No audible response.) 

MR. CHAPMAN: Thank you. 

(Off microphone comments.) 

MR. CHAPMAN: All right, up last is 

Marty Mesh. 

MR. MESH: Marty Mesh with Bellevue 

Gardens Organic Farm, that's the affiliation and 

that's how I'm here as well as personal comments. 

For the new Board members, welcome and 

I started my journey in 1972 as a farm worker in 

conventional agriculture, in '73 I started 

growing organic personally. 

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 In '76 I started Bellevue Gardens 

Organic Farm and we shipped a lot of semis of 

watermelons to California. 

In '87, I helped start Florida Organic 

Growers and our certification program now known 

as Quality Certification Services as well as the 

nonprofit doing education, advocacy, working on 

improving food systems, social justice and 

policy. 

I've worked on probably six farm bills 

and gotten some tucked in organic certification 

cost share in farm bills in the past and other 

things and we're working on getting, obviously, 

more money for organic research in it which the 

research will come in. 

I'm no longer employed by FOG and QCS 

but the passion is never going to go away. This 

is what I've been doing for decades and I'm not 

stopping now to try to leave the planet better 

than how I found it, and leave farm land, my 

soil, better than how I first got it when I 

inherited it. 

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 So, thanks to the National Organic 

Program and the NOSB for their good work. I 

served on the Board for two meetings in the 

rotating certifier regimen before accreditation 

of the first round. 

I echo the comments on the national 

list on the toolbox. You know, I was probably 

helped be responsible for ethylene in the 

beginning and I've helped keep it that way. 

And, I -- really, I mean, if you look 

at conventional pineapple production and what the 

small use of ethylene does, i.e., if you look at 

fatty alcohol, whatever it is, you know, and what 

that does for people that smoke cigarettes or, 

you know, being able to choose organic tobacco 

and the farm workers and farmers that are exposed 

to all the poisons and stuff, I mean, I've got to 

say, you know then go after petroleum distill --

the petroleum dormant oil. 

You know, if you're going to take 

everything out of the toolbox, then go after 

petroleum dormant oil and see how that works out 

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 for the fruit growers. 

So, you know, the cotton delinting 

issue that I begged the Board to continue with, 

that resulted in Farm Aid moving all their cotton 

to certified organic cotton. 

So, the difference in acreage on just 

a little material is really substantial. 

Michael's comments on tying it to 

research I thought was helpful and, in fact, you 

know folks, you know, that I was involved in 

trying to get an industry wide check off and now 

we're moving towards a voluntary check off 

because USDA didn't go to referendum with the 

check off vote. 

But, a voluntary check off we hope 

everybody will be involved in and we'll have 

public comment opportunity out the first week of 

November I believe. 

In 1996, I begged against the listing 

of sodium nitrate. And, I'm passionate -- ah, 

shit, man. You know, I do have got a couple -- I 

do have a couple other comments if there's a 

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 question on it, I could give it to you. 

MR. CHAPMAN: All right, we'll look 

around. I've got myself first and then --

MR. MESH: And then, I did have 

deferred time --

MR. CHAPMAN: Hold on, hold on, I've 

got a question for you, Marty, first and then 

we'll see if anyone else has a question for you. 

I was wondering if you could comment 

on whether or not you thought Scott's beard was 

compliant with the system of organic agriculture? 

(Laughter.) 

MR. MESH: Yes, I'm not going to --

I'm not going there. I had to trim up and shape 

up, but I think it's fine. 

MR. CHAPMAN: Do you want to wrap up 

real briefly? 

MR. MESH: The seaweed part, as 

somebody that took their daughter to watch whales 

when I was working on the Farm Bill in August in 

policy meetings, and had her and a three-year-old 

come back and say, dad, you know, the orcas 

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 aren't there because there's no salmon because of 

the habitat destruction. 

So, I really applaud the effort to 

look at the sustainability of wild crop 

harvesting of seaweed and applaud that process. 

And then, I also echo Laura made the 

point about a longer comment period. You know, I 

will try to provide comments and submit comments, 

but we need more time to do so. 

MR. CHAPMAN: Thank you, Marty. 

MR. MESH: And then, also then the 

last thing, I didn't say was that I support the 

continuing improvement of organic seed as a 

farmer that saves seeds for decades and still do, 

but you know, that continuing improvement process 

to try to help get more viable seed opportunities 

for organic farmers to utilize. 

MR. CHAPMAN: Thank you, thank you, 

Marty. 

Any other questions for Marty? 

Anything beard related? 

(Laughter.) 

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 MR. CHAPMAN: Okay, thank you very 

much, Marty. 

MR. MESH: Well, the last thing 

between me and lunch or you and lunch, so and 

then, I'm missing a hoodie and I'm from Florida 

so, it's really cold. If there's a hoodie that 

somebody finds it's somewhere in this building. 

(Laughter.) 

MR. CHAPMAN: All right. If you find 

a missing hoodie, you can bring it to us and 

we'll get it to Marty. 

Yes, Asa? 

MR. BRADMAN: (off microphone comments) 

I just wanted to thank you for your comments and 

the spirit that you bring to the Board and the 

conversation here. 

And, I just want to give you a shout 

out and some applause. 

(Applause.) 

MR. MESH: Now Emily's going to take 

it all back. 

MR. CHAPMAN: Emily? 

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 MS. OAKLEY: This is actually just a 

comment to all stakeholders that before I joined 

the NOSB I didn't follow this process very 

closely. And, everyone always comes up and 

thanks us for all the work that we do. But, I 

also thank you for all the time that you take to 

read all those materials and to provide us with 

important comments that help us in our work. So, 

thank you for what you do. 

(Applause.) 

MR. CHAPMAN: All right, it's 12:52 

and we have concluded public comment. I want to 

thank all the commenters, particularly as 

mentioned earlier, the delegation that came all 

the way from Costa Rica. 

Public comment is vital in this 

reaching all communities, be it handlers or small 

farmers and everyone in between. It is vitally 

important to this process and it's extremely 

difficult to do that and I really thank folks 

that go above and beyond to get the message out 

and get those comments back to us. 

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 So, thank you very much and we 

appreciate everything. And, I think Jenny wants 

to say something as well. 

DR. TUCKER: And, I want to thank you, 

you facilitated that beautifully. There's a lot 

going on with these public comments and to stay 

as focused and on point is hard. And so, thank 

you very, very much. 

MR. CHAPMAN: Thank you. 

(Applause.) 

MR. CHAPMAN: All right, it's still 

12:52, so we will break until let's call it 2:15. 

But we're starting right at 2:15 so no wandering 

in at like 2:20, 2:25, 2:15 we'll start back up 

with the Materials Subcommittee. 

(Whereupon, the above-entitled matter 

went off the record at 12:53 p.m. and resumed at 

2:21 p.m.) 

 MR. CHAPMAN: We've got all Board 

members present so we'll come back into order. 

And first up on our agenda today is 

Materials. Once concluded, we will either move 

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 on to CACS or take a break and then move on to 

CACS. And, if time allows, we will get started 

with the Livestock Subcommittee. 

So at this time, I'm going to hand the 

meeting over to the Materials Subcommittee Chair, 

Harriet. 

MS. BEHAR: Hope everyone had a good 

lunch and is fortified. 

Okay, so the first thing I wanted to 

do is just give you an update on the sanitizer 

work agenda item. And that is we are moving 

forward with that. 

I actually did visit the Ecolab 

research and development facility on my way up 

here and made some very good contacts and helping 

us kind of coalesce into exactly how we're going 

to do this comprehensive review, what our goals 

are. And we do have, of course, obviously, the 

Organic Food Production Act that we are based 

upon. 

But to just to let all of you who did 

mention in public comment about the sanitizer 

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 work agenda item that it is not languishing. I 

won't guarantee that anything will be coming 

forward at the next meeting, but we are 

definitely moving forward. 

So first on our agenda we do have four 

items in the -- in the Materials Subcommittee 

research priorities, genetic integrity of seed, 

excluded methods and -- what's our fourth item? 

The marine materials. 

So I will be basically the sandwich in 

between the two pieces of bread of Emily. And so 

we'll start out with research priorities and 

Emily. 

MS. OAKLEY: All right, this will be a 

shorter piece of bread. So this is a portion of 

the NOSB's tasks that have been going on since 

2012, and we thank the stakeholders for their 

comments on these priorities. 

For those who may not be familiar, the 

Livestock, Crops, Handling and Materials 

Subcommittees submit their priorities. Over the 

past couple of years, we've worked on 

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 prioritizing previous years' priorities, taking 

some items off that may not be as important or as 

significant at the current time and then 

addressing any new priorities that have come up. 

So as stakeholders present comments to 

us for new materials or new research topics, we 

do take those into consideration. We track them 

through both the spring and fall meetings, 

written comments and oral, take them back in each 

Subcommittee and discuss them. And then 

additional topics that come up to individual 

members are also discussed. 

So I won't review in too much detail 

those criteria, but they are listed in the 

proposal. So what I want to do is just discuss 

those areas that were most significantly 

addressed by public comment. 

So in the Livestock Subcommittee, the 

evaluation of methionine in the context of a 

system approach in organic poultry production 

received a significant amount of feedback. And 

one commenter also suggested that we address the 

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 issue that the FDA has now recommended black 

soldier fly larvae as a poultry feed input and 

that the Livestock Subcommittee consider 

requesting a TR on this material as a natural 

alternative to methionine. 

Another issue in livestock that also 

received more attention than others was the 

organic livestock breeding, especially for 

outdoor access. One commenter pointed to the 

University of Guelph's research in this subject. 

In Crops we did receive, as we have 

for the past several years, quite a bit of 

feedback on the biodegradable biobased mulch film 

topic. A number of stakeholders across the 

spectrum wrote in about that. 

The organic no-till also did receive 

quite a bit of comment, and we did receive a 

comment to include expanding the scope of this as 

to whether or not this topic might increase 

opportunities for carbon sequestration on organic 

farms. 

We heard a little bit less about some 

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 of the other subjects but did hear a little bit 

about the disease management, management and 

control of invasive insects, nutrition in organic 

crops. And then we did hear some comment on the 

side-by-side organic input trials that came 

actually directly from the Crops Subcommittee 

itself rather than through public comment. 

Just a caution that we not consider 

the results from side-by-side trials as 

sufficient on their own for making policy 

decisions on the national list. 

In Handling, celery got some 

attention, and alternatives to BPA got quite a 

bit of comment. And I know that that's not an 

active -- BPA is no longer an active item on the 

Handling Subcommittee, but it is important to 

note through public comment that there is quite a 

bit of interest still within the stakeholder 

community on this subject and adding -- how do 

you pronounce that word -- phthalates, thank you, 

to this work agenda item -- or this, sorry, this 

research priority as well, so asking for research 

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 on that subject as well. 

Materials, I think the greatest amount 

of comment came in the integrity of breeding 

lines and ways of mitigating small amounts of 

unwanted genetic material, prevention of GMO crop 

contamination, and the evaluation of 

effectiveness. 

In terms of new topics that have come 

up, we heard about increasing the focus or 

specificity on soil health, climate change, 

pathogen prevention, specifically in terms of raw 

manure intervals that are needed to prevent 

pathogens, alternatives to fatty alcohols, we've 

obviously heard that here in this meeting, and it 

was also in written comments. And then, of 

course, we heard today, covered agriculture and 

ecological farmscape practices. 

I think one thing that wasn't actually 

mentioned as a specific research priority but 

came out through some of the public comments from 

land owners in Maine might be alternatives to 

some of the seaweed materials. There were 

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 definitely comments that alluded to the fact that 

there are a lot of materials available for input 

fertilities for organic producers and evaluating 

maybe the effectiveness of some of the rock weed 

or kelp materials when other materials might be 

available. 

Are there any questions or comments or 

additions, things I might have missed? 

All right, I am done. 

DR. LEWIS: Harriet, can I make a few 

remarks? Thank you. So I want to, again, thank 

the Material Subcommittee for working on this 

issue. Let me just make a few remarks about the 

research priorities in terms of what we do next 

with this. 

So when we get the final document, 

we'll be sharing this with the National Institute 

of Food and Agriculture to help them in terms of 

strategizing, providing direction in terms of 

research funding, and one of the recommendations 

that you addressed was for control of fire 

blight. 

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 And recently -- the NIFA recently 

announced 25 grants that support farmers and 

ranchers grow and market high-quality organic 

food, fiber, and other products through the 

Organic Agriculture Research and Extension 

Initiative and their Organic Transitions Program. 

One of the grants that they are funding is 

optimization of a bacteriophage for managing a 

fire blight disease. So I just want to at least 

let you know that in terms of information that 

you provide for them helps them in terms of their 

funding, so you can see a direct relation with 

them. 

Also appreciate, in terms of one of 

the -- one of the research priorities dealing 

with biodegradable biobased mulch. So this is 

something that we're also going to be looking at 

as a program, so thank you for raising that and 

drawing attention also to the public comments 

that came in in that area. 

MS. OAKLEY: Harriet, if I may, one 

more comment. Within the last couple of years 

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 we've included the Executive Summary that is 

largely the document that many people read. They 

don't read this whole longer discussion of each 

research priority when the program is presenting 

this to NIFA and others. 

We've also discussed on the 

subcommittee ways of expanding access to these 

priorities within the academic research community 

and will be discussing that further in terms of 

steps that we might take to help increase that. 

VICE CHAIR BEHAR: And I want to thank 

the Program for doing the advocacy work and to 

the other -- to the research -- the place where 

the money resides for research --

DR. LEWIS: Thank you. 

VICE CHAIR BEHAR: -- and bringing 

that forward for us. We appreciate that. 

DR. LEWIS: You're welcome. Thank 

you. 

VICE CHAIR BEHAR: Tom? 

CHAIRMAN CHAPMAN: Yes, two things. 

One, really appreciate the Program sharing that 

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 and all the work on this item. Sometimes, 

sometimes I feel like we make recommendations and 

they just go into a black hole. But with these 

research priorities, like it's great to see that 

we're setting some priorities, the Program has 

taken it internally, and funding and other 

direction is being sent out from that point 

forward. It's really great to see the influence 

and the process working here, and this is just --

reiterates the strong public/private partnership 

that the NOSB is meant to facilitate. So I'm 

happy about that. 

My other just general comment to 

people in the audience that are still here is we 

got a lot of great comments for our research 

ideas at the fall meeting, which I think we're 

open to receive great comments on research ideas 

anywhere, anytime, anyplace. 

But the most effective location for 

that is the spring meeting, so if we receive it 

at the spring meeting, we can review it at the 

subcommittee level and then bring it forward in 

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 the fall. We always publish this in the fall, 

and so just the spring meeting is a bit more 

timely. 

We'll take all the comments, and we'll 

review it, but you won't see this document again 

until the 2019 Research Priorities, so getting 

that in the spring or in the open docket is 

really the best way to get it timely added to the 

research priorities. 

VICE CHAIR BEHAR: Are there any other 

comments? Well at this time I -- oh, Steve? 

MR. ELA: Well, I just wanted -- from 

what you just said, Tom, I think one of the 

problems we have in the spring is we don't 

actually put the research priorities out there, 

so there's not anything to respond to. 

So I wonder if it would be a good idea 

on the spring docket just to publish this list 

again as we put those things out in the packet so 

people can say oh, this was your list. They can 

respond and give us feedback of what we should 

add, and then we can do the updated list in the 

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 fall. 

CHAIRMAN CHAPMAN: That's a great 

idea. I hope the future Materials chair and lead 

on this item will take that forward. 

MS. OAKLEY: And that is a great idea. 

The only trouble with that idea is that it's 

sometimes like herding cats to get everybody to 

have the time to address research priorities 

within their subcommittees. So we could publish 

the previous year's, but we would need to make 

clear that they are not the current year's 

finalized version. 

MR. ELA: Yeah, I would just suggest 

we publish the one we have now and say this was 

last year's, what should we add or take away. So 

we get public comment ahead of when we're trying 

to finalize it. 

VICE CHAIR BEHAR: I think we want to 

facilitate as much public input as we can. 

Anyone else? Okay, at this time I will entertain 

a motion to -- well, Emily, would you like to --

CHAIRMAN CHAPMAN: There's already a 

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 motion. 

VICE CHAIR BEHAR: So we're ready to 

vote? 

CHAIRMAN CHAPMAN: Yes, if there's no 

more discussion. Seeing no more discussion, I 

think we can move to a vote. So this comes as a 

seconded motion from the subcommittee. The 

motion was made by Emily, and it was seconded by 

myself. And the motion was to adopt the 

document, which was the 2018 Research Priorities, 

which is in the agenda that has been previously 

distributed. 

Voting will start with Emily and will 

proceed around the room. This is our first vote, 

so I'm going to spend a little time explaining 

it. We've got some new members, and it's been a 

while. 

We're going to proceed around the room 

in order, so starting with Emily, Sue, and then 

so on. You'll say your vote. The options are 

yes, no, abstain. Recuse is also an option, but 

we would have expected recusals at this point. 

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 So yes, no, and abstain, and we'll go around the 

room. Just a note that it switches each time you 

vote, so the next item we vote on, Sue would 

start, and it loops around the room, and the 

Chair always votes last. 

So on this motion, a yes vote is to 

adopt the proposal, a no vote is to fail the 

proposal, and the voting starts with Emily. 

MS. OAKLEY: Yes. 

MS. BAIRD: Yes. 

MR. BUIE: Yes. 

MS. SWAFFAR: Yes. 

MR. RICE: Yes. 

VICE CHAIR BEHAR: Yes. 

DR. SEITZ: Yes. 

MR. MORTENSEN: Yes. 

MR. ELA: Yes. 

MR. BRADMAN: Yes. 

DR. GREENWOOD: Yes. 

MS. DE LIMA: Yes. 

MR. SCHWARTZ: Yes. 

MS. ROMERO-BRIONES: Yes. 

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 CHAIRMAN CHAPMAN: Chair votes yes. 

Fifteen yes, the motion passes. Harriet, back to 

you. 

VICE CHAIR BEHAR: Okay. The next 

item is the complicated title of Genetic 

Integrity Transparency of Seed Grown on Organic 

Land. This document grew out of what we've been 

calling Seed Purity for the previous about five 

documents, and Dan Seitz and Dave Mortensen were 

my partners on the development of this fairly 

complicated document. 

The fact that the docket was late in 

coming out -- many commenters who gave excellent 

comments also mentioned that they felt they could 

have been more thoughtful and probably give even 

further comments if it went back to subcommittee, 

and so we on the subcommittee have decided to do 

that. So we will be bringing it back to 

subcommittee. 

However, this is your chance. So we 

would like to give you until December 7th, that's 

a Friday, to give us comments on the document as 

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 it currently exists. So for those of you who 

felt that you did not get enough time to give us 

information, we're not going to give you 

something new to look at, but you can kind of 

take a second shot at what we gave you this time 

around, and then we will bring something forward 

at the spring meeting. 

With that said, I do want to kind of 

go over some of the points that were in the 

document to kind of let you know what we've heard 

and what we think we might head forward with and 

give you some idea of maybe what you want to 

comment in the future. 

I want to thank everyone for the 

almost universal support for the direction that 

this proposal has taken. It is somewhat 

different from what we have put forward in the 

past. It's a difficult issue, and the Materials 

Subcommittee appreciated all the suggestions, and 

especially the agreement that this was a good 

first step. 

This proposal is meant to aid organic 

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 farmers in their choices in seed. There's a 

growing number of non-GMO farmers who may also 

need this information. So there are farmers who 

are not organic who are growing into the non-GMO 

market who need to know, as well, what is the 

genetic contamination of the seed that they are 

using. 

As just a personal interest, this 

spring when I came to Washington, D.C. for the 

OTA fly-in, a group of us visited the new Risk 

Management Agency Administrator, and he shared 

with us that his son, who is now taking over the 

farm, has now started to enter the non-GMO 

market. So that made me think that this is a 

larger issue than just for the organic community. 

The administrator also noted that farmers need 

multiple market opportunities and help in 

accessing those markets. 

So there were quite a few comments 

about the burden that organic farmers would have 

under this proposal. I think some of it was 

maybe not clearly understood, which of course 

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 could be the fault of the writer, or just the 

fact, too, that it was fairly complicated. 

For farmers who use organic seed, all 

organic producers would be mandated, under this 

proposal, to test for presence of genetic 

contamination, and there were those levels of 

purity that they could fit into. 

For farmers who choose to use nonorganic seed on organic land, they could ask 

their seed supplier to provide that information. 

If that non-organic seed supplier chooses not to, 

then the farmer would be required to do the 

testing and provide that in their organic system 

plan to their certifier. 

As we heard from one speaker, Jamie 

Welch from EnviroLogix, this is available. It's 

publicly available. Farmers could mail samples 

to a laboratory, and I don't know what they're 

going to charge, but the baseline cost for them 

is $35. So we're not asking farmers to do $450 

PCR tests in order meet this proposal. We wanted 

this to be accessible. 

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 And of course, if and when this moves 

beyond corn -- this is kind of a pilot project 

just for field corn -- that may not always be the 

case for every type of commodity that might have 

a genetically-modified equivalent, but we felt 

that this -- that's kind of why corn, since it's 

pervasively tested in the marketplace. 

The other thing, too, is that if 

farmers are in a region where there may not be a 

lot of organic seed available to them, or a lot 

of other organic farmers, they all know each 

other. So if they work together buying nonorganic seed, they could buy the same lot and 

share the cost of the testing between them. So 

in some regions that would maybe help again with 

the cost. 

It's a little bit of -- nobody likes 

to add cost or have to spend more money, but part 

of it is also, this is a little bit of the 

medicine that they need to take because they need 

to know that information, because at the other 

end, when they grow their crop, there will be 

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 people testing. 

And so if they are trying to get into 

a market, they need to know what they are 

starting out with or else they'll go through a 

whole season of growing an organic crop, and it 

will be rejected. So that's kind of actually the 

main purpose of this is to really protect organic 

farmers so they know what they're getting up 

front before they even plant. 

The testing requirements, there were 

quite a few comments about patents and legal 

protection on proprietary traits that might be 

present, so I will do a little bit more, and I'll 

ask my co-writers to help me with this, on 

whether or not that testing is prohibited and how 

difficult this might be. 

That was a question I can ask Jamie as 

well, for what kind of traits they are looking 

for. But I don't think that there is that much 

in field corn that would be considered 

proprietary. Most of those proprietary traits 

are in genetically-modified seed, which would not 

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 be allowed to be planted on organic land anyway. 

As far as violating seed labeling laws 

by putting the level of purity on the seed tag, 

we can look at that as well. Perhaps there could 

be a second tag on the bag, or it's somehow 

provided up front to the farmer. I would prefer 

that the farmer would not have to make a phone 

call and catch somebody. We just want it to be 

as transparent as possible. 

As far as there were questions about 

what is a lot and what are the testing options, 

we can go into that a little bit more clearly in 

the proposal next time. 

The Organic Trade Association had a 

lot of support for their point that it should 

have been organized a little better, as far as 

the 17 items that were part of the proposal, by 

actually assigning which item needs to be done by 

which party. What does the organic seed supplier 

provide? What do they have to do? What does the 

farmer have to do? So we can do that fairly 

easily, and we intend to. 

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 As far as the level of purity, the 

seed tester would have the choice of either 

providing the exact level of purity, or they 

could be within those categories. It's really a 

transparency-based proposal. 

There were comments about whether the 

traits should be -- it says now all known traits 

versus commercially-available traits. I 

understand that the testing would be harder for 

everything that has ever been put out there, but 

that was put in there partially because of the 

experimental genetically-modified wheat that we 

had problems with in Washington State, and that 

was not a commercially-available trait, and yet 

it did cause quite a bit of consternation for 

farmers when that contamination appeared in their 

wheat. So I'm not sure how we'll deal with that, 

but we'll take a look and see if there's any way 

to capture that or not. 

Retaining seed samples, there was --

for farmers, that -- and I found this kind of 

interesting that a certifier recommended this, 

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 and it was many certifiers then -- other 

certifiers who didn't like it. But I agree that 

the farmers should save that sample. We could 

give some direction on how easy that would be and 

how much they would have to retain. 

Again, this is something for the 

farmers to protect them, so if they find genetic 

contamination in their final crop, they could go 

back and verify that level of purity by testing 

the sample, so they would have kind of a 

secondary check. Besides the tests that they 

receive from the supplier, they could then check 

their own sample. And this would provide 

information to the farmer whether or not their 

genetically-modified mitigation efforts are 

effective or not on their own farm so that they 

could modify what they are doing. 

The other thing is about the database. 

So the database, the purpose to that was to start 

gaining information about what is the pervasive 

nature of genetic contamination in the field corn 

seed supply. 

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 And it's not going to be, obviously, 

everything, but since organic farmers do use a 

fair amount of non-organic seed, and especially 

in areas where there are not organic seed 

suppliers and people especially in the Southeast 

and the South, we felt that it was important to 

see -- it would show both hot spots, but it would 

also show areas where there was a pretty good 

chance that people could grow seed corn and not 

have GM contamination. So it would offer seed 

growers some information about where they could 

go. 

I know one seed grower right now is 

growing out organic seed corn for sale in the 

United States, and he's doing it in France. So 

if we can identify some areas in the United 

States, within our borders, that there's less 

chance of contamination, that would be good 

information for them as well, and we could keep 

that -- yeah, Dave, just -- okay, go ahead. 

MR. MORTENSEN: Just on that point, 

which I think is a really important one, you're 

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 making the point that it helps us as a community 

to not only identify hot spots and cold spots --

so clean places and less clean places with regard 

to the germplasm, it also enables us to determine 

the characteristics of that place that tend to 

keep it a good place or a place that we need to 

take some action to see if we can get 

neighborhood behaviors to change in the farming 

community. 

And I think that's a really hopeful 

thing that could be an outgrowth of this 

proposal, you know, this way of thinking about 

the problem, because in my opinion, to date, the 

whole issue, which a number of our presenters and 

visitors have presented about co-existence, we 

really don't understand what co-existence looks 

like when it's working well, and then I guess 

we're not co-existing when it's not working well. 

So I think this helps us get there. 

VICE CHAIR BEHAR: Thank you, Dave. 

There were a few that wanted us to have a more 

clearly-stated purpose and goal. We will do 

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 that. Oh, I want to go back to the database. 

So the last thing with the database, 

which now we have a little bit more time to 

discuss with the Program would be who would 

manage it. And I do have in the proposal that it 

could possibly even be farmed out. I haven't 

asked any organization if they want to do it, but 

I've thought about OMRI, I've thought about a 

certifier, I've thought about -- I don't know. 

I don't know who would do it. It 

could be done internally by the NOP, or it could 

be farmed out, either one, as far as maintaining 

the information that all the certifiers are 

giving of the state or province and country of 

origin of the seed and what that level of purity 

was. 

And I think through that there would 

be -- it would be anonymous who grew the seed and 

who planted the seed because the documentation 

within the certifier can't be FOIAed. That's 

confidential information, and the only thing that 

the certifiers are passing on is where the seed 

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 was grown and what the level of purity was. And 

it's by state, so it's not by county. 

So if you -- you know, it would be 

Minnesota. I don't think that you could 

necessarily say that it was any specific farmer 

or any specific seed grower who grew that in 

Minnesota and be able to attribute a high level 

of GM contamination through that database 

because, again, we want people to feel 

comfortable in giving the information. 

Okay, open for discussion. Sue? 

MS. BAIRD: I really appreciate all 

the work that's gone into this document. I think 

that you guys have done a great job of looking at 

different issues. 

However, I am a little concerned about 

the direction. We have been told for 20-plus 

years that organic certification is a process 

certification and not a product certification or 

not based on testing. And if we implement this, 

we will be moving into a testing of product 

certification as opposed to process 

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 certification. 

The only place in the regulation that 

even mentions testing at all is 205.671, when it 

talks about pesticide residue testing being 5 

percent above EPA. I love the whole idea of what 

we're trying to do here. I'm concerned about 

requiring testing, which is not part of the 

regulation currently. 

VICE CHAIR BEHAR: Dave or Tom? 

MR. MORTENSEN: Yes, thank you, Sue. 

I think that the whole spirit of the draft is 

helping the farmer know where they're starting. 

Because if they don't know where they're 

starting, meaning seed out of the bag into the 

planter box, and there are problems on the back 

end, we have -- this whole idea that we have the 

capacity to identify patterns of behavior that 

result in good or bad outcomes is undone by not 

having that insight. 

And so this isn't intended to be 

something where we're coming down on the farmer; 

rather, enabling the farmer to do what it is 

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 they're trying to do, sometimes in places where 

it's difficult to do that, and then having the 

information they need to know how to take 

remedial steps. 

VICE CHAIR BEHAR: Tom? 

CHAIRMAN CHAPMAN: Similarly on the 

cost concern, I was -- I mean most of the 

comments I received that were somewhat critical 

of this was the cost burden of the testing, and I 

was curious to hear from the farmer members, as 

this would be borne by the farmers, what they 

thought of those comments. 

VICE CHAIR BEHAR: Steve? 

MR. ELA: Grow perennials. 

(Laughter.) 

CHAIRMAN CHAPMAN: In your 

representative role, I think is what I meant. 

MR. ELA: Like for the corn, I can't 

really speak to it because we really are so 

different. But in my head I go okay, this is the 

pilot case. If it were expanded to represent all 

organic seeds, I could see, for vegetable 

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 growers, where you're buying small lots for a 100 

row feet or less, that testing requirement could 

-- that's where it could really add up. 

Where you're planting 100 acres of 

something, it's one thing. Where you're planting 

20 square feet of something, it's a whole 

different story. So that scalability of the 

amount of seed you're buying and such, the cost 

burden could become important. 

VICE CHAIR BEHAR: Asa? 

MR. BRADMAN: I just want to follow up 

with Sue's comment. How would you see this 

proposal for testing different from requirements 

to test for pesticides periodically in organic 

products? 

Can you hear me now? Okay. How would 

you see this proposal as being different from 

testing that's done for pesticide residues in 

organic produce, and is that a case that also 

kind of went beyond the process-based versus 

testing? And I was just curious if you feel like 

this proposal contradicts those requirements. 

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 MS. BAIRD: There are no requirements 

for producers to test for pesticides. The only 

time the certifiers are required -- a percentage 

-- is it five percent of their crops. Is if 

five, Scott? I think so. Of their clients to 

test for pesticides, but producers are not 

required, nor -- I've lost my train of thought. 

But even so, they do five percent, or 

they do in case of a complaint. But producers do 

not required to be tested. And this says every 

lot has to be tested. 

MR. BRADMAN: Right, so the 

distinction here is the producer requirement --

MS. BAIRD: Right. 

MR. BRADMAN: -- versus the certifier. 

MS. BAIRD: Right. 

VICE CHAIR BEHAR: Jesse? 

MR. BUIE: As a small farmer, I'm 100 

percent organic, so it would not be a factor to 

me. But I think you said it would be about $35? 

VICE CHAIR BEHAR: That's what the 

cost is to the people who have that testing 

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 system in place. I don't know what Iowa State 

might charge someone. But I would think it would 

be less than $100, but probably -- maybe $50 or 

something. 

MR. BUIE: Okay. Is that per batch or 

--

VICE CHAIR BEHAR: Per lot. 

MR. BUIE: Well, yes. Okay. That's -

-

VICE CHAIR BEHAR: Okay. Emily? 

MS. OAKLEY: I mean, I think the 

question comes down to how many lots would an 

individual producer have in a given year. I 

can't imagine it being more than a couple hundred 

dollars in a season, which is not costprohibitive in my view. 

I have many expenses that are far 

beyond that. I obviously don't grow grain crops, 

and we did explicitly exclude vegetable corn, and 

there aren't very many vegetable crops that would 

be at risk ever in the future and require any 

additional testing, so I think it's kind of 

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 weighing apples to oranges. But I don't think a 

couple hundred dollars is of concern. 

VICE CHAIR BEHAR: Ashley? 

MS. SWAFFAR: I just want to make sure 

you guys spell that out really, really clear on 

those vegetable crops because I'm just thinking 

on my small, or anybody else's small market farm 

that -- Emily, you're kind of in my boat. You 

grow a jillion different things for a variety, 

and so just please make sure you specify that 

very, very clearly, because, boy, if we've got to 

test all the varieties of tomatoes that we grow, 

boy, that could add up real quick. 

VICE CHAIR BEHAR: Just to respond to 

that, it would be at-risk crops that would be 

under this proposal, so until there becomes --

and at-risk would be defined sometime in the 

future of what can be cross-pollinated easily --

I mean, tomatoes don't typically cross-pollinate 

with others, even right next to them. So that 

would not be a heavily at-risk crop. 

Okay. So next is Sue. 

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 MS. BAIRD: I'm involved with some 

non-GMO grain crop growers, specifically corn. 

They have to test to sell as non-GMO. By the 

time they do their whole package, it costs about 

$125, I think, for the package, and they lot per 

field and per times of harvest. So it could, 

depending on how many fields you've got, it could 

run into thousands of dollars. But non-GMO 

people do it anyway, so the precedent is there. 

MR. MORTENSEN: Maybe just -- and I 

don't know how much time you want to spend on 

this -- these are the kind of details, getting 

this feedback and getting it from the 

stakeholders. It will be extremely valuable. 

I think we do need to just remind 

ourselves that we're talking about seed into the 

planter box, so you could buy a lot in and plant 

that in five or 10 fields. That's a very typical 

thing to do in Nebraska, for example. 

So in that case we're talking about a 

small sampling on the front end where you may be 

-- I think -- it would be fairly typical of a 

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 grower to have two or three field corn cultivars 

that they might be buying in. In that case it 

would be three samples. 

VICE CHAIR BEHAR: Emily and then 

Ashley. 

MS. OAKLEY: I was just going to make 

that clarification that the proposal says each 

seed lot, not each field. So the lot is defined 

by the seed as Dave just explained. 

VICE CHAIR BEHAR: Ashley? 

MS. SWAFFAR: Harriet, I just wanted 

to follow up. When you were asking for the 

public to comment to the subcommittee by 

December, you're wanting them to do that through 

the open docket? Just so that I'm informed that 

I need to run that by the Program? 

VICE CHAIR BEHAR: Yes. There will be 

an open docket, but we don't know exactly when. 

So we'll be trying to communicate -- I was trying 

to give the subcommittee enough time and you guys 

enough time, but the docket may not be open for a 

few weeks yet, so Tom is going to speak to that. 

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 CHAIRMAN CHAPMAN: Yes. The 

regulatory process released in the docket; the 

Program does everything they can to get it out as 

quickly as possible, but there are items beyond 

their control from date of when it's going to be 

open is not possible, and so there is a chance, 

although probably unlikely, that the docket won't 

be open up until December 7th. 

I also believe the Government is on a 

continuing resolution until the 7th. So that's 

also not particularly good timing, budgetwise, if 

there's no budget approved for the Federal 

Government. So we might want to look at, instead 

of setting a firm date, perhaps a number of weeks 

after the docket opens to get those comments in. 

Since folks have the proposal in front 

of them, they can start working on those 

comments, and then they just need to submit it to 

that docket once it opens. So I think a short 

time after the docket is sufficient, in my 

opinion, so it's something like two weeks. But 

I'm looking for the Board to give feedback on 

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 that. I see some head-nodding, so --

VICE CHAIR BEHAR: Yes. I think --

CHAIRMAN CHAPMAN: -- we want to just 

revise that to say, two weeks. Please provide 

comments to the open docket within two weeks of 

its opening so we can have it timely and be able 

to have the subcommittee be able to make 

revisions to this as necessary. Does that 

satisfy -- yes. 

VICE CHAIR BEHAR: Yes. So everyone 

is given due notice out there in the audience to 

start. You have your homework. Tom? 

CHAIRMAN CHAPMAN: Do folks have a 

sense of how many public comments we heard from 

grain farmers who would be most impacted by this? 

VICE CHAIR BEHAR: Not that many. 

CHAIRMAN CHAPMAN: Not that --

VICE CHAIR BEHAR: Mostly through 

Organic Valley, and then it was mostly certifiers 

and grain Organic Seed Alliance, American Seed 

Trade Association, and some seed suppliers. 

CHAIRMAN CHAPMAN: Okay. It would be 

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 great if, in the interim time period, if members 

of the public who have contact with grain farmers 

could try to solicit their feedback on this exact 

proposal as well, since they would probably be 

disproportionately impacted by this. 

VICE CHAIR BEHAR: Personally -- well, 

this went out to the Organic Farmers Association 

to OFARM, and I asked them, but they didn't 

respond. But OFA did. 

I guess I could go a little bit into 

the background. In the development of this, 

Kiki, as I mentioned during the public comment, 

provided the names of a group of different seed 

suppliers, both organic and non-organic that 

service organic farmers. 

I called all of them and kind of ran 

the proposal by them and tweaked it according to 

what works for them, what doesn't work, and 

trying to be as practical as possible. So it was 

not really done in a vacuum; it was done mostly 

with seed growers and the testing community, 

rather than farmers. 

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 More comments? Any other discussion? 

I would encourage the NOSB as well, not just the 

Materials Subcommittee, to please read that again 

and for you all to get us comments on it as well, 

because it is quite detailed, and it's kind of a 

different approach. 

One last thing; there were a few 

comments about wanting zero tolerance, and that 

we should have gone towards tolerance, but our 

regulation does not have that. You could have 

presence of genetic modification, contamination, 

in your seed and yet still sell the crop as 

certified organic. 

You're not allowed to use genetic 

engineering intentionally in the production of an 

organic crop, but if it's there unintentionally 

you do not lose your certification. So we wanted 

to kind of stay within those bounds and not set a 

tolerance level. 

So with that, we're going back to 

subcommittee unless there are some more comments. 

CHAIRMAN CHAPMAN: Do you want me to 

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 make a motion? 

VICE CHAIR BEHAR: Okay. So I'm going 

to make the motion --

CHAIRMAN CHAPMAN: To refer back to 

subcommittee. 

MS. OAKLEY: I second. 

VICE CHAIR BEHAR: Okay, to go back to 

subcommittee with this. 

CHAIRMAN CHAPMAN: All right, unless 

there is further discussion, I'll take it to the 

voting. Okay. 

So we have a motion from Harriet and a 

second from Emily. The motion is to refer the 

Genetic Integrity Transparency of Seed Grown on 

Organic Land proposal back to subcommittee. 

This isn't a matter of business; is 

should have said this at the start of this item. 

The Board conducts matters of business by a twothirds majority vote. This is not a matter of 

business to refer back to subcommittee and 

therefore it follows Robert's Rules of Order, and 

Robert's Rules of Order dictates that an 

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 amendment, something to refer back to 

subcommittee would only require a simple 

majority. So this is only a simple majority 

vote; eight votes will send this back. 

A yes vote would refer this back to 

subcommittee; a no vote would keep it on our 

agenda here for further discussion and votes. So 

the voting starts with Sue. 

MS. BAIRD: Yes. 

MR. BUIE: Yes. 

MS. SWAFFAR: Yes. 

MR. RICE: Yes. 

VICE CHAIR BEHAR: Yes. 

DR. SEITZ: Yes. 

MR. MORTENSEN: Yes. 

MR. ELA: Yes. 

MR. BRADMAN: Yes. 

DR. GREENWOOD: Yes. 

MS. DE LIMA: Yes. 

MR. SCHWARTZ: Yes. 

MS. ROMERO-BRIONES: Yes. 

MS. OAKLEY: Yes. 

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 CHAIRMAN CHAPMAN: Chair votes yes. 

MR. RICE: That's 15 yes, zero no. 

CHAIRMAN CHAPMAN: Fifteen yes, zero 

no; the motion passes. This is referred back to 

subcommittee, and I hand the meeting back to 

Harriet. 

VICE CHAIR BEHAR: Okay. Michelle? 

Oh, I have it. Okay. So Excluded Methods 

Determination, and we put a date on it because 

this is kind of an ongoing item on our agenda, 

and we thought that over time, we're going to 

want to try to keep track of which determinations 

we had at which time. So going forward we're 

going to try to have a month and a year on each 

of these, and it will be called Excluded Method 

Determinations. 

So in this is a repeat of the 

terminology that we passed in the fall of 2016, 

and the various criteria by which we determine if 

a method of production would be considered an 

excluded method, meaning genetic engineering or 

genetic modification or -- there are many 

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 different ways of saying that. 

And so also included was a chart 

including everything up to this date that we have 

determined to be an excluded method. So we'll 

probably keep doing that just to kind of have a 

running total so that the most recent document 

would not just include only the item that we're 

discussing for this proposal, but would kind of 

keep all of them in one place to help everyone 

see where we're at so you wouldn't have to keep 

going back and looking at previous documents. 

So we did receive quite a few comments 

about the transposons with discussion that the 

naturally-occurring transposons occurred due to 

drought, heat, or other means of physical stress 

are not an excluded method. We did have 

universal agreement on that. 

For the method transposon produced 

through chemical, artificial, ultraviolet 

radiation, or other synthetic stress or 

interaction, we had quite a bit of non-agreement 

there, feeling that we needed to separate out the 

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 chemical, artificial, ultraviolet light, and put 

in in vitro transposons -- transposons produced 

through in vitro manipulation. 

So that would be into the nuclei; that 

would be the excluded method, and the chemical, 

artificial, ultraviolet light and radiation or 

other synthetics would be to be determined yet, 

because that is more of an induced mutagenesis 

system. 

Also, in further discussion with the 

Program, transposons are actually the result of a 

method; they are not actually the method. So we 

want to take back the transposon part entirely 

and bring that forward in another document in the 

spring and separate out those three methods that 

result in a transposon. For those of you who 

didn't read that, it's kind of a jumping gene 

type of change to the genetic makeup of an 

organism. 

However, we would like to bring 

forward for a vote the embryo rescue in plants as 

a non-excluded method and let that be allowed for 

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 use in organic seeds and crops and plants. 

So I believe Michelle has the change -

- thank you, and thank you to Tom for helping 

 with that. So I'd like to open it up for 

discussion from the --

CHAIRMAN CHAPMAN: Can you show the 

Word document? We just removed references to 

transposons from the document and added it back 

to the TBD list, so we'll show that really 

briefly so folks will understand the entirety of 

the amendment when it gets requested. 

It's the Word document. Sorry, 

Michelle, I can't hear you. 

VICE CHAIR BEHAR: It's in the table. 

It's in the Excluded Methods. 

CHAIRMAN CHAPMAN: If you could just 

project the Word document, and then we'll scroll 

through it. 

VICE CHAIR BEHAR: Okay, while they're 

looking for that, I hope I explained it. If you 

don't understand it, this your chance to ask me 

questions. Any questions on what we're about to 

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 do and why we are doing it? Well, if you want to 

talk about transposons, you can, but it is going 

back to subcommittee, and it is considered a To 

Be Determined Material right now. 

MS. SWAFFAR: I do want to talk about 

transposons because it relates to livestock. So 

I think that I learned a lot through this via 

Harriet on transposons and how vaccines are made. 

Those people who thought that vaccines 

were made from excluded methods technically were 

never made from excluded methods because 

transposons even though it's a process. It's 

something -- that's how they're made, and that's 

why I think it's very critical that our work 

agenda request for vaccines hopefully be accepted 

by the Program to put on our work agenda because 

technically there are no excluded methods for 

vaccines at this time because transposons are not 

an excluded method through us. 

So if we were to -- I was very 

hesitant to vote on this on transposons because I 

felt like that was the work-around that the 

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 industry had for vaccines at this moment. 

VICE CHAIR BEHAR: And so we now have 

some time too, to figure out how those 

transposons were -- which method was used. Are 

they in vitro? Are they through chemical or 

radiation, etc., or are they naturally-occurring 

transposons? So we'll try to dig a little deeper 

into how those vaccines are actually made. Good 

luck. I think, you know, through some of the 

universities, I think maybe I could get some 

help. 

DR. LEWIS: Just a point of 

clarification for Ashley; in terms of the work 

agenda request that you submitted to the Program 

and based on the conversation now, is there any 

modification that you'd like to make to the work 

agenda request to address your question? 

MS. SWAFFAR: No. I think our work 

agenda request still possibly stands as it is, 

just because there's a lot of people that have --

we're not sure how every vaccine is made, and so 

there's some made with transposons and possibly 

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 other methods. We would just like to address it 

once and for all for clarity across the industry 

and across certifiers. 

DR. LEWIS: Great, thanks for the 

clarification. 

VICE CHAIR BEHAR: Just for the 

public, to remind them that we have asked for a 

work agenda item to review some work on livestock 

vaccines that have been produced through excluded 

methods. Tom, you look like Michelle. 

CHAIRMAN CHAPMAN: All right, I do. 

So like we said, so people have some sense of the 

edits; it's just removing the references to 

transposons. You'll see when we get to the 

proposal section that it's limited to discussing 

embryo rescue of plants, and then you'll see in 

the TBD section we added the transposons back in 

there. Then at the end at the actual proposal, 

it only mentions embryo rescue, not transposons. 

VICE CHAIR BEHAR: One other item I 

wanted to bring to the attention of the Board is 

that we did kind of bring forward items that we 

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 would be looking at for the next reiteration of 

this excluded method determination document, 

April 2019, and that includes induced mutagenesis 

which will take into account the transposon 

method. 

So we were already planning on that, 

and I encourage the public too, that if they see 

items that we don't have on our To Be Determined 

list that you feel need to be reviewed as 

excluded or not, to bring them to our attention, 

because this is a fast-moving area of science, 

and it's really hard -- a lot of ways to keep 

track of what could be out there. 

More discussion? Okay, I will make 

the motion to remove the transposon information 

from the document and only include as the 

proposal part to add embryo rescue in plants 

should be listed, not an excluded method. Emily? 

MS. OAKLEY: I'll second. 

CHAIRMAN CHAPMAN: All right. So we 

have a motion to amend to remove the mention of 

transposons from the proposal in the document. 

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 So we'll vote first on the motion to amend. 

That's a simple majority. Then if there's no 

further discussion we can move to adopt the 

amended proposal, and that would be a two-thirds 

vote. 

So the first vote is to adopt the 

motion to amend, which is to delete the sections 

that you saw earlier, as well as delete the 

transposons section here from the proposal 

wording. A yes vote is to amend the document and 

delete the language; a no vote is to retain the 

original version. The voting will start with 

Jesse. 

MR. BUIE: Yes. 

MS. SWAFFAR: Yes. 

MR. RICE: Yes. 

VICE CHAIR BEHAR: Yes. 

DR. SEITZ: Yes. 

MR. MORTENSEN: Yes. 

MR. ELA: Yes. 

MR. BRADMAN: Yes. 

DR. GREENWOOD: Yes. 

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 MS. DE LIMA: Yes. 

MR. SCHWARTZ: Yes. 

MS. ROMERO-BRIONES: Yes. 

MS. OAKLEY: Yes. 

MS. BAIRD: Yes. 

CHAIRMAN CHAPMAN: Chair votes yes. 

MR. RICE: That's 15 yes, zero no, 

zero absent. 

CHAIRMAN CHAPMAN: Motion passes; 

further discussion? All right. Seeing no 

further discussion, we'll vote on the main 

motion. This is a seconded motion that came from 

the subcommittee. The motion was made by Harriet 

and seconded by Dan. 

I'll read the amended proposal, which 

they say must recommend the NOP add the following 

table to excluded or non-excluded methods to the 

NOP excluded methods guidance -- a lot of 

excluded there. Embryo rescue in plants should 

be listed not an excluded method. 

This is a two-thirds majority vote. A 

yes vote is to adopt this amended proposal, and 

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 the voting will start with Ashley. 

MS. SWAFFAR: Yes. 

MR. RICE: Yes. 

VICE CHAIR BEHAR: Yes. 

DR. SEITZ: Yes. 

MR. MORTENSEN: Yes. 

MR. ELA: Yes. 

MR. BRADMAN: Yes. 

DR. GREENWOOD: Yes. 

MS. DE LIMA: Yes. 

MR. SCHWARTZ: Yes. 

MS. ROMERO-BRIONES: Yes. 

MS. OAKLEY: Yes. 

MS. BAIRD: Yes. 

MR. BUIE: Yes. 

CHAIRMAN CHAPMAN: Chair votes yes. 

MR. RICE: That's 15 yes, zero no, 

zero absent. 

CHAIRMAN CHAPMAN: The motion passes. 

Harriet? 

VICE CHAIR BEHAR: Somebody's got work 

to do. So I'm going to pass this now to Emily, 

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 and she's going to discuss the public comment and 

the discussion document Marine Materials in 

Organic Crop Production. 

MS. OAKLEY: Thanks, Harriet. So I 

just first want to recognize that this is work 

that was started by the Board prior to my time 

and in particular by Dr. Jean Richardson, so 

thank you very much to her work. A lot of this 

discussion document took from her original work, 

so I just want to acknowledge that and thank her. 

I also just want to say that the 

reason that we're still working on this issue, 

even though it's kind of laid out pretty clearly 

in the discussion document is that this is a long 

trajectory and that the concern over 

environmental impact for the harvest of marine 

macroalgae hasn't gone away. Even though this is 

a difficult issue to address, the fact that it's 

hard doesn't mean that we shouldn't try to tackle 

it. 

So I will spare you the whole 

discussion of how we got to where we are, because 

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 that's in the discussion document pretty clearly. 

But what I want to say is that we got unanimous 

support throughout this process, from when it 

first came up in 2016 until now, to address the 

issue of sustainability. 

What we tackled and tried to address 

was, what are we talking about when we talk about 

sustainability in seaweed? And in this case, 

we're really addressing the environmental impact. 

So then we discussed, well, how can we 

address the environmental impact? What tools are 

available to us? And in the absence of thirdparty certification that our university agreed 

upon by both industry, conservationists, 

producers, consumers, we looked to the tool that 

we already have at our disposal, which is the 

wild crop standard. 

So that's what we did with the 

discussion document was to put out this really 

new idea or way of looking at a crop input to see 

what stakeholders would think, to get their 

feedback, and to try to be as transparent about 

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 our thinking process as possible. We don't 

assume that it's the only correct way to look at 

this, or even the correct way, but it's to try to 

continue this dialogue about how to address this 

issue. 

So we basically took the approach of 

addressing the crop section of this for the time 

being. I know that some you might remember, but 

new people might not know this; we did address 

this also from a handling perspective, and 

originally it was looking at nomenclature. We 

decided to try to sort of run a test run through 

addressing this issue on a more focused scale and 

crops. And so that's where we are now. 

I'll give you a little bit from the 

discussion document, and then I'll summarize some 

of the public comments, but what I'm really most 

interested in in this portion of the meeting is 

hearing from my fellow Board members. 

I've combed the public comments very 

carefully and clearly, but what I don't know 

necessarily is where everyone else stands on this 

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 issue, and that will be really important to know 

as we go forward and try to figure out what the 

right direction would be to take. 

So I think the most important thing to 

note is that what we are trying to do with this 

when we address the wild crop standard here is to 

address the environmental impact and not 

destructive to the environment. 

We're also looking at the 

contamination piece of the wild crop standard, 

but I think what's also critical to note is that 

marine macroalgaes are really different from a 

lot of other crop inputs, and that they're 

harvested directly from a wild, native, 

ecosystem. There really aren't that many other 

crop inputs that can meet that category. I can 

think of a few, and some commenters provided some 

as well, but this is a really unique situation, 

and I think we've heard from the stakeholders on 

that. 

I think the other issue that we 

realized for so many in this discussion was that 

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 the Wild Crop Standard is loose or vague in some 

of its terms, certainly compared to a crop 

production standard. And we know that, and we 

recognize that we would need additional guidance 

or additional information of help format how such 

a standard could be applied in a marine 

environment. 

There are certifiers who are doing it 

now, and they're trying to adapt terrestrial 

standards as best they can to a marine ecosystem, 

but if we were to move forward in any direction 

on this, we will definitely need more input on 

how to do that, and I think that can only be done 

with experts in the field, producers, and wide 

group of stakeholders. 

So just to summarize some of the 

public comments; there was really a spectrum. 

There were those who felt that we shouldn't be 

harvesting all or some types of seaweeds at all 

for use in crop inputs because those marine 

environments are so fragile and don't recover 

quickly. Then there were those who felt that 

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 current standards or current government 

regulations are already sufficient to regulate 

the industry and their activities. 

So that's a pretty broad spectrum, but 

none of those people said we shouldn't address 

the environmental impact. I think they all 

recognize the need for that. 

So I think that in terms of the 

greatest degree of concern that got brought 

forward through the public comment, there were 

two main areas. One was concern that by 

certifying a crop input ingredient there might be 

a domino effect of increased scrutiny on other 

natural crop inputs, where that might lead to the 

request for certification for many others. 

So what I'll say first is that we 

sometimes give a tremendous amount of scrutiny to 

synthetics that we use, and sometimes those 

synthetics are found in incredibly small 

quantities on farms and on fields, and we should 

give scrutiny. But at the same time, I don't 

think we want to stop looking at or stop 

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 investigating more deeply the natural materials 

that we apply, sometimes in very large 

quantities. 

That being said, the intent of this is 

not to create a domino effect, and I want to 

spell that out really clearly. I think the 

difference here is what I tried to illustrate 

earlier, that this is an ingredient from a wild, 

native, ecosystem and it is a very unique 

situation. It is not the same thing as compost. 

So I hope that can help assuage some 

concerns, but another, probably predominant 

concern was the difficulty of certifiers to 

verify organic claims since certifying 

fertilizers was out of NOP's purview. 

But I think what might have not been 

clear from the discussion document is that we're 

not looking to certify the fertilizer. We're 

looking to certify the ingredient, and in this 

case seaweed is treated as an agricultural crop, 

both in livestock and in human consumption. 

So we're still considering it an 

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 agricultural crop, but it's an ingredient that 

goes into an input. So the input, the product 

itself, would not be certified, but that 

ingredient, the agricultural crop of seaweed, 

we're suggesting would be. 

We did hear comments from some people 

thinking that that might not pass the legal 

muster, the NOP, so I'd really like to find out 

if that's true and discuss this further with the 

Program once we go further with this in the 

Materials Subcommittee. 

I think it's also important to realize 

that there are some boats that are currently 

harvesting, as we've heard from some testimony 

already, marine macroalgae for the use of 

livestock feed, and in that case it is already 

certified to the wild crop standard. 

In that same boat those same 

harvesters will then go and harvest the same 

exact same species for a crop input, and that's 

not getting certified. So in some cases we have 

this sort of double standard situation on the 

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 exact same species and marine environment, so I 

think that's part of what we're trying to address 

here. 

There are also some products already 

on the list that do contain certified seaweed 

ingredients. Now, whether or not -- as we heard 

from material review organizations, they're going 

to go then verify that -- we know that it's being 

done, and I think that if we treated this 

ingredient itself as the certified input, it 

would lessen the burden on certifiers and 

material reviewer organizations because the 

product would then come with that certification, 

and presumably would then be searchable on the 

Organic Integrity Database as well. So there 

would be multiple ways to check that. 

So there was some concern expressed 

that certifiers don't have the skills needed to 

certify, and unfortunately if that's the case, we 

already have them doing that work. So we 

probably need to address that regardless of 

whether or not we're going to include crop input 

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 ingredients in wild crop certification, and I 

think that some of the certifiers that do do this 

right now would greatly like to see increased 

standards or guidance for harvesting seaweed. 

think that's something that can be addressed and 

discussed later. 

There were suggestions also for thirdparty certification, and I think we could look to 

some of those standards like the Marine 

Stewardship Council, but they're not universally 

agreed upon. I also wonder if we really have the 

authority to require a third-party certification. 

There were suggestions for just 

annotations within the language in the national 

list, maybe using some of the wording or even 

additional wording in the wild crop standard, but 

not requiring a certification. I think the 

problem with that that I can see initially is 

that we don't have a verification process at that 

point. 

Then it just becomes an attestation 

that someone says they're doing what they say 

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 they're doing, which is why we ended up 

continuing to come back to this idea of wild crop 

certification, because that's why we created 

organic in the first place, so that we can verify 

that we are doing what we say we're doing. 

I think I would be remiss if I just 

didn't note that there were a number of residents 

in Maine who wrote in about the impact of 

harvesting on their lives and their communities 

and on their property. There were also producers 

that wrote in saying that they try to make the 

best case possible for those landowners. 

But we did have one specific landowner 

that said -- in the case of rockweed in Maine --

they had someone come in an intertidal zone, 

which we have already heard is up for the old 

contention -- that they asked the producer to 

stop harvesting. They did, and then not 18 

months later another producer came in and was 

harvesting the same species in the same area. So 

I think some of those issues could also be 

addressed potentially through this. 

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 People asked for a phase-in period if 

we were going to do something like this, and I 

think that's a definite given. They also asked 

for guidance and additional standards. Some 

pointed out that terms were used interchangeably 

in this document, and they were. Initially that 

was intentional, but I think it would be better 

if we just start using marine macroalgae and 

provide some definitions. 

So just in conclusion, even though 

this is a new way of looking at a crop input, I 

don't think that means it's outside of our 

purview or scope of investigation. I think that 

the farmers and consumers who rely on us to 

review materials are depending on us to examine 

and verify the environmental impact of these 

materials. 

I also just want to say that there was 

widespread support, regardless of anyone's 

comments, on the creation of a working group, so 

I will be discussing this with Jennie to see if 

that's possible. This would be an informal 

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 group; it wouldn't be a task force. Anyone would 

be invited, and I think we'd want a wide range of 

stakeholders' participation in this to help us 

scope this issue, decide if wild crop 

certification might actually be feasible, and if 

not, what other ways might be better to try to 

address this. 

This is a long-term process. This is 

obviously not something that we're going to 

figure out in the short term, and it will 

probably be beyond my term on this board. So 

some of you new people might want to take it on, 

just like it was handed to me. 

So I guess in conclusion, for real, I 

think that we can find a middle ground. I really 

don't think we're that far away. I think you can 

hear from the testimony that there's a lot of 

consensus on the desire to address this; it's 

just trying to figure out what is the best means 

to do that. 

As I said at the beginning -- I just 

want to end with that -- even though this is 

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 hard, I don't think that means that we can't 

figure it out. I do think we can. I'm really 

curious to hear what everybody thinks, and if you 

have reservations, please share them now, and any 

thoughts. Thanks. 

VICE CHAIR BEHAR: Any comments from 

the Board for Emily? Thank you for all of your -

- kind of above and beyond for a landlocked 

 Oklahoman to take the ocean to heart. Steve? 

MR. ELA: Thanks, Emily. This is one 

that makes my head swim, pun not intended. I'm 

trying to work through the wild harvesting in my 

head, and it comes back that some of these 

seaweed products are international. 

I understand we're only USDA, and 

we're certifying to USDA, but given where some of 

these products might come from international 

companies, do you have any thoughts on how we 

handle that? 

MS. OAKLEY: Yes, that's a really 

great question, because if we don't address that, 

this won't go anywhere. 

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 I think my first stop is to look at 

the OMRI list of products that are out there and 

maybe try to contact some individual producers of 

products and see if there are some people that 

may have contacts with international producers of 

these materials, and also to get a better sense 

of how many products are coming internationally 

versus maybe from the North Atlantic, which where 

it seems the majority of it might be 

concentrated; also kind of in the Mediterranean 

region. 

I don't know how you pronounce this 

one, but I'd call it maerl, which is one of the 

red algae and has probably one of the most clear 

environmental impacts, because it's achieved 

through dredging. But yes, I definitely think 

we've got to look at international users and 

producers before this would go anywhere. 

VICE CHAIR BEHAR: Asa? 

MR. BRADMAN: I actually haven't 

raised my hand, but I will say that I think this 

issue is really important. I think it's hard, 

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 but we have to deal with it. This can't be 

ignored. Any situation where we're basically 

extracting resources from wild environment to put 

them on a human-manipulated environment, organic 

or not, it needs to be considered. 

I'm a little concerned about the wild 

harvesting criteria. It looks like they're 

divided a little bit, and you have to either 

maintain or improve that. I don't get, actually, 

how the improve aspect of that could apply here. 

I think if you're taking something out of a wild 

environment, you're definitely not improving it. 

But we have to not damage it. 

I think this is a really hard nut to 

crack, but I just want to state again, middle 

ground here, I think what we really want to 

support is not a middle ground, but we don't want 

to compromise and sacrifice some zones. We want 

to come up with some standard that protects it. 

I actually like the idea of a 

certified wild-crafted product, and then we have 

some criteria defining what that is. If we can 

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 actually get that through rulemaking, then we 

have a common understanding of what makes this 

material legitimate in the organic sector. 

VICE CHAIR BEHAR: Okay, Steve, and 

then A-dae. Oh, you want to respond? Steve, Adae, and then Rick. 

MS. OAKLEY: Can I quickly respond to 

that? I think that's a really good point. I 

think that the reality, though, is that we 

already have a middle ground, because we have 

those who don't want to see it harvested at all, 

and those who think that we need any changes from 

the status quo. 

So just in my line of thinking, I 

don't think either one of those is probably going 

to be the correct path forward. So when I say a 

middle ground, I guess I'm trying to say, can we 

bring those two ends of the spectrum closer 

together? But I agree, we don't want to 

compromise marine environments. There will be 

those who will say that just by allowing it at 

all, we are. So I just want to put that out 

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 there. 

MR. BRADMAN: Right, and I guess I 

would be comfortable with not allowing it if we 

felt like it did compromise environments. 

VICE CHAIR BEHAR: Okay, back to Steve 

and then A-dae. 

MR. ELA: Yes, I'm just following up 

on my previous comment. This is probably one of 

those cases where my ignorance is going to show, 

but are the Europeans -- is there any place we 

can plagiarize? 

MS. OAKLEY: Yes, the EU came up and 

commented, and I'll be looking at that. 

MS. ROMERO-BRIONES: So can the 

Program answer the question that you posed them 

in your summary, which was, "Is this out of the 

purview of the Board when it comes to 

ingredients?" Was that your question? 

MS. OAKLEY: I don't want to make them 

answer that right now, because I don't know what 

their answer would be. I want to give them ample 

time to think about that, unless it's favorable, 

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 of course. 

MS. ROMERO-BRIONES: I asked that 

because if getting their perspective would help 

us understand how we need to frame this, and if 

we're spinning our wheels on something that 

they're going to immediately reject, that's a 

consideration. 

On a more personal note, this issue is 

very close and dear to my heart. I come from a 

community that has been harvesting and eating 

some of the seaweeds that we're talking about for 

thousands of years. My family just came from 

harvesting seaweed on the coast for out tribal 

community in the beginning of this year, and I 

think that perspective, for sure, has not been 

articulated at all in these conversations. 

It's to the point in California where 

you can actually have physical altercations when 

it comes to seaweed harvesting along the coast of 

California, particularly between tribal seaweed 

gatherers and the organic community where some of 

these organic products or supposed organic 

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 products are being sold in places like the Bay 

Area. 

So I think there's a lot of 

perspectives that need to be considered, and 

there are grey areas. It makes me really, really 

sad and emotional to think that some of the 

traditional foods that have sustained tribal 

communities for a thousand years are being used 

as fertilizer or cow feed, particularly because 

some of these tribal communities face some of the 

highest insecurity rates in this country, and 

when it comes to winter months, seaweed is a 

pretty important food staple for a lot of hungry 

families. 

I haven't quite gotten to the point 

where I'm comfortable with having wild food 

labeled organic under the Wild Food Provision, so 

at this point I'm really opposed to moving 

forward on anything until we get those 

perspectives on the table. 

VICE CHAIR BEHAR: Rick was next, then 

Sue, then Tom, and then Emily. 

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 DR. GREENWOOD: Remember yesterday I 

asked the question about quantity of kelp that 

was harvested versus organic versus conventional, 

and I think when we look at this whole area, we 

need to make sure that we have a wide range of 

harvesters that include the conventional people, 

because they probably have practices that are 

incompatible with what we're looking for. 

I know we don't have jurisdiction, but 

I think we need their input when we come up with 

something. I'd hate to have us come up with 

something that's very good, and then meanwhile 

you go down to the ocean and there's other people 

destroying the kelp beds. So if we can do it in 

a way that would cover that whole area of 

harvesting, I think it would be very beneficial. 

VICE CHAIR BEHAR: So it -- does the 

Program want to -- then Sue. 

DR. GREENWOOD: Can I just make one 

remark? Just in terms of the Program's 

perspective on this, one thing to take into 

account is -- and we've been talking about this 

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 in the executive committee and also here at the 

meeting in the beginning, was thinking about the 

Program's role and our engagement with the 

federal partners. 

And when I think about this activity 

obviously it means being engaged with NOAA in 

terms of what NOAA's responsibilities are in 

terms of their Fisheries management and other 

factors. So one thing to think as you work 

through this issue is the relationship with NOAA 

in terms of their regulatory authority in this 

matter. 

VICE CHAIR BEHAR: Sue? 

MS. BAIRD: I appreciate A-dae's 

perspective; I had not thought about that. I 

like the idea of moving into wild crops harvest 

as opposed to crops. There's a definite 

difference in wild crops, which means you don't 

add any inputs; you do no management of it. You 

just harvest it. Crops, you have that management 

practice. 

I've done inspections for wild crop 

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 harvesting for a few certifiers. There's not a 

whole lot of certifiers out there that do wild 

crop harvesting. Some do a much better job of 

defining criteria to preserve the natural culture 

of that crop than do others. 

I find it interesting -- and you were 

asking, could we plagiarize some -- FairWild is 

an organization that certifies wild crop 

harvesting, and in fact, NOP has recognized 

FairWild's standards as meeting our standards, 

the organic wild crop harvesting standards. It's 

based on risk assessment; what practices are you 

implementing that will preserve that colony of 

wild crops? 

So I agree we've got to do something. 

We've got to do something to address the 

sustainability of our natural habitats; food 

habitats, whether it's food or fertilizer, 

whatever we use it for; we have to preserve it, 

and the only way we can do that is some kind of 

regulatory action. 

Wild crops is where it fits; it 

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 doesn't fit in crop production, because we're not 

doing production practices. Just my take on it. 

VICE CHAIR BEHAR: Emily? 

MS. OAKLEY: I just wanted to respond 

to A-dae and say that we should discuss how best 

to incorporate and approach and include tribal 

communities. I completely agree with that 

perspective, and I think it's incredibly painful 

to see that collision of perspectives, and I hope 

we can try to address some of that, at least in 

this discussion document. Thank you. 

VICE CHAIR BEHAR: Any other comments? 

Dave? 

MR. MORTENSEN: I think this work that 

you're spearheading here, Emily, underscores that 

our foodshed is much larger than the fields and 

the farms that we farm. If we follow the logic, 

if we're internally consistent, at our very last 

meeting we voted to protect ecosystems of high 

integrity or not recently-disturbed, for the 

purposes of enhancing ecosystem services. 

It seems to me this is -- I mean, how 

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 can we not do this if we vote in favor of 

protecting the environment ecosystems and 

ecosystem integrity and services? I agree with 

you that A-dae's points were really moving and 

definitely need to be in this. 

I moved to New Hampshire two months 

ago. I would say every other morning on public 

radio there's at least a 10-minute piece on the 

declining fisheries in the North Atlantic; 

haddock, cod. The size distribution of lobsters 

has shifted to very small lobsters. It's 

affecting catch. Native American peoples, but 

mostly European peoples in the Northeast. 

So this whole thing is interconnected 

deeply. I think we all know that, and when we 

start taking things out of an already depleted 

ecosystem, we certainly have to be concerned 

about that. So I applaud you for pursuing this, 

and it seems to me to be entirely consistent with 

what we've been working on since I got on the 

board. 

VICE CHAIR BEHAR: Okay. I think 

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 we're going to wrap that up, and I want to just 

echo what Dave said. We're the terrestrial 

world, and the marine world, and we're very 

connected. The oceans are the vast majority of 

the coverage of our planet, so we need to be part 

of the stewardship of that as well. 

So with that, the Materials 

Subcommittee will come to a close, and we've 

eaten our sandwich. 

CHAIRMAN CHAPMAN: All right. So up 

next is CACS. What time is it? It is 3:52, so 

we will take a brief break and come back at 4:10 

and start up with the CACS. I want to thank 

Harriet for taking us through the Materials 

Subcommittee. We're in recess, and we'll be back 

at 4:10. 

(Whereupon, the above-entitled matter 

went off the record at 3:52 p.m. and resumed at 

4:11 p.m.) 

 MR. CHAPMAN: It looks like we have 12 

members present, so that's enough to call it a 

quorum. And we'll come back into session, so up 

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 next on the agenda is the Compliance, 

Accreditation, & Certification Subcommittee 

chaired by Scott Rice. 

I will hand the meeting over to Scott 

in a second. I just remind him it's, what time 

is it? 4:10. And if we do have time, we would 

like to get to the livestock sections. 

So just warning you to, you know, 

track yourself, check that beard to make sure 

that beard might not want to talk too much just 

so we can move along. 

MR. RICE: Okay, we did a lot of work 

on the CACS this year, it's been defined by the 

focus of the program and the community on 

integrity of the organic supply chain. 

There's been a lot of discussion on 

that both about domestic and international supply 

chains. Had a lot of comprehensive and detailed 

discussion in a number of areas that integrity 

touches on. 

And that's to say every corner of 

organic trade certification and accreditation. 

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 So you'll recall a lot of panel discussions and 

public comments, discussion amongst the Board, 

written comment. 

It's truly been great, and I thank 

everyone for their input. We've focused on about 

the last year on inspector and reviewer 

qualifications in training. And also assessing 

risk when addressing accreditation oversight. 

So the first, taking a look at what 

we're looking at today. We've got a proposal on 

risk criteria for accreditation oversight as well 

as training and oversight of inspector and 

certification reviewer personnel. 

And we're going to get a sneak peek of 

the LMS system or the Organic Integrity Learning 

System. Is that really it? The OLLS, the 

Organic Integrity Learning System now, is that 

what we're? All right. 

And a verbal update from Tom on the 

feedback that we saw from the spring 2018 work 

and panel. So as we dive in here. 

Looking at risk criteria for 

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 accreditation oversight in early this year the 

NOP requested that the NOSB provide input on the 

factors that contribute to an accredited 

certifier having a higher risk of fraud and that 

either within its organization or the operation 

that it certifies. 

We're looking to establish that 

criteria for assessing the factors when engaging 

in the oversight. And that oversight includes 

onsite visits as well as desk audit activities of 

the certifier in both their primary and satellite 

offices for those that have those offsite 

facilities or locations rather. 

And as I said we received a wealth of 

information that informed us and in the most 

recent public comment period solicited some ideas 

for additional criteria that were not considered 

in this. 

And again, received some really great 

feedback. And so I was going to summarize some 

of the comments that we heard as well as some of 

those additional criteria points. 

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 We did, excuse me, we presented this 

as an unranked list, but many commenters 

suggested that the list really should be ranked 

based on the level or degree of risk that is 

seen. 

Further commenters pointed to the 

importance of developing a scorecard or a risk 

matrix to group and rank risk behaviors. And/or 

consider a category of probability or likelihood 

against a category of consequence severity. 

Commenters also pointed to the 

importance of looking at these factors 

proactively and how certifiers implemented 

mitigations to address them before issues arise. 

So that we're not just reacting to the things 

that we find in an auditor. 

Commenters strongly advised 

prioritizing required data reporting, 

specifically aggregate acreage data. And as we 

heard in other discussions today, data is 

continually coming up as an important piece of 

integrity and ensuring that we have the most 

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 comprehensive data will help in all of our 

efforts. 

In relation to the data reporting, 

it's suggested that overseas certifiers be 

directed to work with domestic certifiers to send 

the information requested by certifiers here to 

confirm data that may not necessarily be 

available in the Organic Integrity Database. 

We've heard about some challenges in 

that communications were either long response 

times or no response. It's suggested that the 

certifiers be directed by NOP to respond to that 

information request. 

One comment noted that instead of 

focusing on the number or lack of positive 

residue sampling results to focus on the sampling 

system in place to ensure it's sufficient and 

meeting the requirements as set out by the NOP. 

Other commenters wished to see greater 

detail in the risk mitigation actions and when 

outcomes of those measures would warrant a noncompliance or prevent a certifier from gaining 

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 initial accreditation. 

Just to point out again the intent 

when drafting those various response steps was 

that any findings would be evaluated and 

responded to as other findings would in an audit. 

Which depending on what is found may 

include non-compliance action or adverse action 

when it's deemed necessary. 

And commenters suggested a greater 

detail of definitions, well, greater detail in 

definitions for some of the terms used so that 

the risk factors may be applied equally and 

objectively. 

And on a similar note, looking to have 

a better understanding of what say average means 

when it comes to risk factors such as residue 

samples or number of non-compliances issued. 

This relates again to the overall 

importance of accessibility to the data and that 

there's a common baseline of understanding and 

common access to the data. 

Regarding risk factors on reporting 

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 that data to the Organic Integrity Database there 

were some comments that did not feel reporting 

the minimum data required should be considered a 

risk factor for a couple of reasons. 

One being that the certifier would be 

meeting the requirements, if not the minimal, as 

well as the fact that the database is still 

relatively new. 

Certifiers are continuing to update 

their systems and are also cautious about not 

wishing to disclose confidential business 

information. 

Again, I think some of those 

challenges can be addressed through aggregate 

data, and I think we're seeing that already. 

Some commenters wanted clarification 

on what a breakdown in a control system is or 

looks like. There's general support for greater 

scrutiny during certification audits. 

Concern was expressed regarding the 

cost of those longer, more detailed, deep dive 

audits, more intense audits, and that that cost 

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 should be born at least, in part, by USDA. 

Right now we as certifiers receive a 

bill for those services and it's a hefty one no 

matter the size of the certifier. 

Something that I think we're happy to 

have happen and respect the work that NOP puts 

into that but the more that we start looking at 

other or additional factors and the longer those 

audits are there's definitely, I can see a 

tipping point, as some pointed out. 

Finally, there was some concern 

expressed about the identification of one risk 

factor as the sign of potential fraud. And just 

to reiterate this was a list intended as a guide 

to looking at areas that have been noted as risk. 

It's not the intention for the 

presence of one to automatically trigger greater 

scrutiny again pointing back to that initial idea 

of ranking this, of creating some sort of matrix. 

We heard some from some folks the last 

couple days of examples of how they've 

incorporated that into their systems. And invite 

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 those folks to share some of those models in the 

public docket. 

And a number of commenters noting a 

holistic systems-based approach is essential when 

evaluating risk. So lots of, again, really good, 

really good feedback and then diving into 

specifically some of those comments speaking to 

additional criteria that we may have overlooked 

in the first round. 

Some suggested adding that a certifier 

providing service to an operation that employs a 

former member of the certifier staff or a 

certifier hiring or seeking advice or in an 

advisory capacity or consultancy services from 

someone who's previously employed by an operation 

that certifies or alternatively a certifier 

engaging with a formal, former rather USDA 

employee. 

There might be something like a 

cooling off period or some expectation that there 

would be a separation of time to avoid any real 

or perceived conflicts. 

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 Another suggestion if a certifier 

misses one or more of the NOP annual trainings, 

NOSB meetings were also noted, that specific to 

the annual trainings that NOP include an 

evaluation of whether the appropriate staff were 

in attendance at the training. 

And an evaluation of whether the 

information received at the training is 

adequately disseminated to certifier and 

inspector personnel. 

We do see a really good turnout at 

those annual NOP trainings. And it's an 

excellent opportunity for that community to 

exchange ideas and strategies but it would be 

great to get to a 100 percent on that. 

Another idea of including a greater 

specificity in the criteria regarding 

requirements specific to dairy management. That 

would be training and creating dairy-specific 

risk factors. 

Another suggestion of program review 

or internal audit if USDA sees that those audit 

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 reports contain major non-compliances or a 

significant number of minor non-compliances. 

That might trigger a closer look at what's going 

on there. 

Another risk factor might be failure 

to implement and maintain internal procedures 

supporting the stability of the certification 

agency. 

This again speaks to that overall 

control or quality system that should be in place 

if something like that is seen perhaps more 

emphasis is needed on verifying the health of 

other parts of the certifier's quality system to 

ensure that the full range of the certifier's 

procedures are robust enough to handle the 

present capacity as well as future growth. 

That kind of ties into another 

suggested a surge in applications for 

certification could potentially be a risk if 

there's a lack of resources to keep up with that 

demand for services. 

And sort of be the flip side of that 

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 is a drop could suggest the presence of a system 

that is inadequate at providing the necessary 

services to maintain a healthy control system. 

Let's see here. There were other 

areas of feedback that didn't necessarily fall 

into the column of a risk factor per se and 

thought it worthwhile to mention here. 

One being a suggestion that NOP 

improve the process by which it engages in peer 

reviews. Heard some public comments on that 

pointing to several aspects of what those peer 

reviews look like in terms of qualifications of 

staff or if those involved what their respective 

expertise is. 

Looking at strength in oversight and 

response to the import of organic grain. That's, 

of course, something that we've heard about in 

general quite a bit. 

In frequent communication with the 

U.S. Customs and Border Patrol ACE System to 

 provide more standardized, detailed info on 

organic products. We heard from the program on 

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 efforts already underway to address that. 

And strengthening and making 

consistent the process by which certifiers engage 

in those internal reviews and following up on 

their findings. And more closer look at kind of 

getting those processes or expectations more even 

across the board. 

I know that we've seen a good 

flexibility, or enjoyed flexibility in how we 

approach those internal audits. Whether it's 

done by the program itself or an outside auditor, 

having that flexibility is still important. But 

having some common expectations of what that 

audit looks at would be a worthwhile focus. 

And finally, the NOP should 

incorporate risk-based accreditation into the 

equivalency agreements that they engage in so 

that foreign certifiers are held at the same 

scrutiny that our domestic certifiers here the 

U.S. are. 

 And moving on from that, you know, as 

we heard in a lot of comments. There's an 

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 interest in continuing to engage in this process 

and that this is not a finite list. 

This is not a finite process, so we 

don't hand it off, and it just disappears. So 

looking to continue to be engaged and have this 

be more of a living document or a living process 

and would invite the program just to comment on 

perhaps how they see that best operating. 

And the criteria, any thoughts on the 

criteria itself and just an opportunity for 

feedback there. Yes, sure. 

DR. TUCKER: So I would say generally 

I want to just overall thank and appreciate all 

the thought that has come into this. I think I 

shared yesterday when we were looking at 

priorities for moving forward. 

Inspector qualifications and training 

is incredibly key. Risk-based oversight is 

incredibly key, and technology is incredibly key. 

And all three of those variables have been sort 

of folded nicely into this set of work from both 

the Board and the public comments. 

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 I'm intrigued with that as I do 

additional research on how other industries are 

implementing risk-based oversight. So much of it 

comes back to personnel. The personnel is always 

at the core of any risk-based system. 

Which, you know, when you stop and 

think about actually really make sense. But to 

have it be that overt as your personnel is your 

risk is I think clarifying. 

And so I think the way that the 

proposal was crafted and thoughtfulness of the 

comments are very much appreciated. 

We are looking in terms of our 

accreditation and international activities group 

how do we think about certifier audits in a 

different way, in a risk-based approach that's 

still consistent under the regulations? 

So we need a system that is again hifidelity to the regs while also reflecting kind 

of the world and environment we're in. 

I think I mentioned that we have a new 

staff member with a lot of skill in risk-based 

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 thinking, economics, and a really good eye for 

all the different international resources that 

are available for assessing risk which has been 

very eye-opening and helpful. 

In terms of the equivalency 

arrangements, there is a group of countries that 

comes together on a regular basis as a working 

group. And so there's a meeting in December 

where we'll be talking about some of these issues 

and how all of us can work together. 

Those conversations on risk-based have 

already begun in terms of both where there are 

sort of high risks how we collaborate. I think 

the enforcement collaboration, in particular, is 

really improved over the past couple of years. 

Also, I think one of the risks in 

talking about risk-based oversight is that you 

have to remember that you can add all sorts of 

things at high risk but that means you also just 

from a resources perspective, you have to 

identify what the low risk is and what that 

means. 

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 And then how you would detect a red 

flag at low risk that would elevate it in high 

risk. So you end up having enough of a 

monitoring system. But we do need to work both 

sides of the spectrum here, and so that's sort of 

the holistic. 

You can't just concentrate on doing 

more, more, more at the top. You also have to 

think about, okay, well what does that mean we're 

not going to do as a result in order to 

reallocate resources responsibly while still 

having a red-flag system? 

So this is going to take a little bit 

of time and some experimentation, but we're 

already taking steps in terms of introducing, for 

example, unannounced inspections not only of 

operations but we've had a couple of unannounced 

visits with certifiers, and so I think continuing 

that element of it. 

So that's my overarching reaction to 

this work. Again, I'm very, very grateful for 

the comments and insight from the community as 

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 well as the Board, so thank you. 

MR. RICE: Thanks, Jenny. Appreciate 

the feedback and insight on how the program's 

tackling this. I wanted to open up to discussion 

and any questions or comments from board members 

on this. Emily. 

MS. OAKLEY: This is back to your 

question I guess to the program to how we can use 

this document as a living document? It kind of 

reminds me to some extent the excluded methods 

process that we're working through. 

So do you have thoughts or does the 

program have thoughts on how we can, you know, 

pass what we've got before but continue to work 

on it, especially on the couple of comments we 

got? 

MR. RICE: Yes, I'm not quite sure. 

think having that ability to have the open docket 

for the community to continue to weigh in but 

having a way to capture that similar to that 

excluded methods process would be helpful too so 

that we're all on the same page and can see in a 

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 centralized fashion where the thought process is 

and where the action is. 

I don't know if Jenny, you want to add 

anything to that or thoughts on how process-wise 

we can do that? 

DR. TUCKER: I would love to have this 

be sort of an ongoing conversation so whether 

that means there's sort of a living document and 

sort of an artifact that collects that ongoing 

conversation. I'm open to that. 

I think there does come a point at 

which there are going to be some things that we 

do from a risk-based oversight perspective that 

perhaps we don't publish because, you know, at 

some point you want to be able to do some of this 

and have it be at least a little bit of a 

surprise. 

So isn't, you know, by the way, we're 

going to come in look at drawer one, four, and 

five of your, you know. And so I think there is 

when we're looking at risk-based oversight a real 

balance between transparency, openness in the 

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 process. 

We always want the process to be fair, 

and so I think openness and transparency supports 

fairness. And also sometimes when you're, you 

know, playing poker there are times when you're 

not showing your hand. And so that is part of 

it. 

Sorry, somebody brought up a poker 

reference earlier in the meeting, so I'm feeling 

the need to extend that metaphor a little bit. 

MR. RICE: It's better than a beard. 

Tom. 

MR. CHAPMAN: Sometimes you hold them, 

and sometimes you share them, all right, my 

memory of the song "The Joker" is not that great. 

A couple of things on this that I've 

been thinking about. One, is we all have 

opinions on the risks that are out there in the 

accreditation field. 

And we got the public comments; the 

committee put them out in this document. But we 

also have to respect the fact that the people 

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 doing accreditation, running an accreditation 

program also have a perspective and an experience 

that also needs to be weighed in on this. 

And so our own opinions may not be the 

only opinions that matter on this. That being 

said, the other thing we need to keep in mind is 

the difference between all potential risks and 

the minimum amount to accurately segment the 

certifiers into high, medium, and low risk. 

And you may not need to identify all 

risks to be able to appropriately segment into 

high, medium, and low. We did get some comments 

from certifiers that I wasn't particularly a fan 

of. 

But everyone's entitled to their 

opinion around, you know, assigning high risk to 

minimum requirements as an example. And if you 

hit the minimum requirements that should subject 

you to a higher risk rating and I cannot disagree 

with that more. 

Risk doesn't mean that you're noncompliant. Risk just means that there's the 

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 potential for an issue there. There's risk, 

there's opportunity, and it needs to be evaluated 

further. 

So that's a couple things to keep in 

mind. How I would like to see us move forward on 

this in my own mind is I'd love the program to go 

and take back these factors knowing the resources 

that they have, the capabilities. 

The programs that are already in place 

and the processes, see how they interact with how 

they run their accreditation programs and then 

come back to us in a period of time to give us 

feedback on what of these 13 criteria were 

useful. 

Which ones they're looking to 

incorporate or have already incorporated and how 

they're going about managing that risk. Or 

whether they may have additional questions and 

then that's how we can continue this conversation 

forward. 

But to some degree, this document 

needs to be internalized by the National Organic 

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 Program and turned into a Risk Management Program 

for accreditation. And unfortunately, we're not 

the ones to be able to write that in its full 

detail. 

The other comment I just want to make 

from opinion and I don't know if others of that 

committee had a different opinion. We chose not 

to rank these items, that's not to say that they 

shouldn't be ranked. 

But again it was to kind of respect 

that we were trying to identify risk factors. 

But of course, some risk factors may weigh more 

than other risk factors than those. 

And I'd hope that the program would 

take that into account as they have, you know, 

this special insight of what they see when they 

go out and do these accreditation audits. 

And the impact of certain risk factors 

have on their assessment of certifiers. I think 

at that point a weighting of these would be quite 

appropriate for them to implement in their own 

program. 

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 As another avenue forward and as part 

of the public comment, we received information 

about risk assessments and certification of 

clients. And I also could see that as an area of 

us continuing and expanding those conversations. 

To take a further look into risk 

factors with clients and making a similar 

document that we would recommend into certifiers 

to be able to take a more holistic approach and 

identify general risk factors that should 

highlight and segment their clientele for greater 

or less scrutiny. 

MR. RICE: Thank, Tom. I've got Rick, 

Emily, Harriet, and Dave. 

DR. GREENWOOD: Question actually for 

Jenny and Paul. I assume you have historical 

data where you should be able to rank these, and 

I guess the question we need to think about too 

is, are we talking about financial risk or 

reputational risk? 

I mean there's all kinds of risk and 

so I'm just wondering taking these 13 items will 

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 you be able to sort of do that and give us 

feedback in terms of what's the riskiest and what 

you think the risk is? 

DR. TUCKER: I think, so over, I think 

we still have some learning to do. That's how I 

think I would respond to that. I think we have 

over the past three years had, maybe three or 

four years. 

We've had simply because of sort of 

transitions in career and other variable we've 

had almost 100 percent turnover in our 

accreditation and international activities 

division. 

We are at a point right now where we 

have the strongest accreditation team that we 

have ever had. I mean, that's natural in an 

organization to build over time. 

And it does mean that the quality of 

the detection they're able to do now at a 

system's level is much more robust. And so we 

need a bit of time to be able to get more audits 

done at that level of assessment before I'm going 

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 to feel comfortable that we're even able to rank 

these. 

Now some of these jump out as, yes, 

absolutely. And so, I mean honestly, number 11 

seems like a big one. Right? If you have an 

open, it takes a lot to get a proposed suspension 

or proposed revocation or to have another 

government kick you out of their system. Right? 

So that one, yes, right, that's a big 

one. Other ones are interesting in terms of how 

you would actually then translate it into some 

kind of quantitatively fair assessment. We need 

a little bit more time to think through that. 

That's it. 

DR. GREENWOOD: You think about risk, 

and there's, risk isn't one word, really. I mean 

it's the whole thing. You think about Chipotle 

and food poisoning, and it was reputational risk 

and financial risk. So you have to sort of parse 

it out to see what you're really looking for. 

DR. TUCKER: Yes, reputational harm is 

certainly part of it, and certainly I think the 

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 case studies for that are very clear in imports 

in dairy. Right? 

And so those highlight very specific 

parts or sectors of the market. They both have a 

high market impact in term of financial impact, 

but also just reputationally that's, you know, 

consumers get those things. 

And so, yes, reputational harm is part 

of that. How do you translate that into how 

you're looking at a particular certifier and then 

again to do like a proposed suspension or 

revocation you also have to have a lot of 

evidence against very specific citations. 

So the risk-based model might help you 

see where to look but it really also comes down 

to do you actually have violations that you have 

strong evidence for that are against certain 

clauses. 

I think one of the things we're doing 

based on all the audits we've had to help inform 

this is we are creating more of hierarchy in 

threes of the citations themselves. 

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 In terms of when you look across all 

the citations in the regs, which ones, and that's 

another element that hasn't really been captured. 

It's sort of captured in 12 a little 

bit. "Received a non-compliance that points to a 

breakdown in a control system." 

So that means actually really looking 

at the regs and saying, "Okay, what would in the 

regs there'd have to be a non-compliance against 

for me to consider that?" 

So at some point, all of this, then 

also has to feed back into, "How would I actually 

cite it?" So that again is a process that takes 

time and thought. 

So, for example, we've done citations 

of certifiers in the past where, well, they 

didn't have staff that knew the wild crops 

regulations very well. Or we had mistakes in 

certificates, or we had mistakes in a material 

review. 

So at one point are those three 

separate violations? And at what point is 

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 actually you don't have sufficient, capable staff 

to carry out your mission? 

And that's an entirely different part 

of the reg and so getting real thoughtful in 

terms of how we map all those pieces to each 

other. 

Is this a system capability issue? Is 

it a personnel issue? What is the actual issue 

and how does that pertain to risk? That's the 

work we're doing right now. 

MR. RICE: Thank you. Emily. 

MS. OAKLEY: This is a question for 

the program. We got really public comment on 

this document, so I was wondering the extent to 

which the program is engaged in that public 

comment and able to incorporate some of that in 

this current proposal? 

DR. TUCKER: I think the public 

comment that has been coming in, I certainly read 

the public comment and I agree with the short 

window. So I think we need to spend more time on 

those. But they're certainly a resource side by 

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 side with the work of the Board. 

MR. RICE: All right, Harriet. 

MS. BEHAR: So part of doing, you 

know, risk-based is I think also having a robust 

accreditation system for the certifiers, and I'm 

very happy to hear that you're feeling very 

confident about the current staff. 

Because that can be a very big 

deterrent to fraud if when they are being 

accredited it's very obvious that the people who 

are there know what to look for, know how to look 

for it. 

Understand the systems in great depth 

and can go through some of these risk factors 

without actually having them look like it's a 

risk-based assessment. It's just the robust 

system of review. 

So, no, I think this is a good, it's 

got its value and its approach, but I think 

moving too far to just risk-based, I think, I 

don't want us to forget that we need a robust 

baseline as well. 

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 Including enforcement because there's 

nothing that discourages something than hearing 

that somebody else got punished for doing 

something wrong. 

DR. TUCKER: Right, I think the riskbased is one approach within a broad portfolio 

which includes the basic regs and accreditation 

system. 

So for example, it's not that like 

mid-term accreditation audits are going away if 

you're a low risk or something. So there will 

always be sort of a baseline that's in the regs 

that we will always follow. 

So, yes, the other thing, not only do 

we have better staff. We also have a better 

system now. We have with the remaining Farm Bill 

funding we did buy an accreditation management 

system which is also very helpful in actually 

tracking and being able to really start looking 

at trends over time with non-compliances. 

MR. RICE: And Dave. 

MR. MORTENSEN: Yes, I had a question 

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 and a suggestion. I was, and I preface my 

comments about such certification work by, you 

know, this is not my field. 

But I was really struck by the comment 

this morning by the pineapple farmer that the 

farmers themselves can serve as eyes on the 

ground and collectively be sort of looking after 

things in their neighborhood. 

And so I just, this reading the 

document it's very much the certifier looking 

after, but I'm wondering if there are ways that 

we can be moving in a direction where we're 

encouraging farmers to work collaboratively to 

not rat on your neighbor but at least be, you 

know, eyes on the ground to keep things on the up 

and up. And calling things into question when 

they see it. 

I didn't see anything of that flavor 

in this, but that's a question then, is should it 

be? Or is this not appropriate for this kind of 

thinking the way we are looking at avoiding the 

problem of undesirable outcomes in integrity? 

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 MR. RICE: Ashley, I think you have a 

response. 

MS. SWAFFAR: Yes, so I don't think 

that this document is the right place for that, 

but I do think that is a critical piece that can 

help with fraud detection. 

You know, I fielded a formal complaint 

this year that came from another grower. So, you 

know, if they've contacted me because they didn't 

know how to do it. 

So, you know, that's a way for us to 

expand on complaints and educating producers how 

to file a complaint. You know, they don't know 

how to do that. 

So I think that's a good piece for 

certifiers to tell their clients how to file a 

complaint. 

MR. MORTENSEN: Thank you, Ashley, and 

then the suggestion is I think it's now about a 

year and a half ago, maybe two years ago, that my 

recollection, that some of the big fraud concerns 

began to be discussed actively on the phones with 

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 NOSB. 

And I would find it helpful, and we 

had a beautiful panel on this issue at the last 

meeting, I believe, where we talked a lot about 

this approach. 

I would find it very helpful if an 

NOSB member if we could have a, you know, fairly 

comprehensive and robust report back to keep the 

analysts and members up to date on how we're 

doing on this issue. 

Because, many of us I'm sure we're 

being asked, you know, what are you guys doing? 

You know, I was at the MOSES conference, there 

were 50 farmers that Harriet and I sat in on a 

session. 

And I'm not feeling all that wellinformed about that as a board member. 

MR. CHAPMAN: By us, do you mean the 

NOSB or do you mean the National Organic Program? 

MR. MORTENSEN: I mean us board 

members, we board members be kept up to date I 

guess by the NOP folks on how we're doing. You 

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 know, are things getting better, are they about 

the same? You know, are we backsliding? I don't 

have a good sense for that. 

MR. CHAPMAN: So Jenny had a large 

portion of her presentation on Wednesday about 

enforcement activities that the NOP is taking. I 

want to make sure that we provide --

MR. MORTENSEN: I hope I was paying 

attention to that. I didn't hear a lot about the 

international issue in the grain trade from the 

east, which I think is what got us going about 

this; I remember specific phone calls. 

John Bobbe, you know, I don't know. I 

don't feel well-informed after that session. 

It's no knock on Jenny's thing, I heard some 

very helpful things. I didn't hear things about 

that. 

MR. RICE: About like Serbia and the 

--

MR. CHAPMAN: Serbia and you know 

corn, are we feeling better about the corn 

market? Are we feeling better about soybeans? 

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 You know, yes, those sorts of things. 

Is it possible that you know, lower 

prices from eastern Europe continue to be nagging 

at the price of organic grains in the U.S.? I 

didn't get a flavor for that. Those kind of 

specifics. 

MR. RICE: Jenny. 

DR. TUCKER: You know, it may be, yes, 

I realize the presentation on Wednesday, it 

focused, you know, I had all these time 

constraints, right, and I wanted cover the full 

range of both what I felt we had done as a 

program and what we were going to be focused on 

in the next year. 

If we can, I'll ask permission, if we 

have, you know, five or ten minutes tomorrow 

morning. We do have kind of a one-page fact 

sheet that we use to illustrate where we believe 

we are. 

One of the challenges with fraud is 

we're never going to be done. Right? And so we 

do have that conversation internally as well. 

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 "How are we going to know when we're done?" And 

the answer is we're never going to be done. 

I am actually more concerned about the 

challenge shifting. Right? Everybody's really 

focused on the Black Sea; I'm actually right now 

more focused, I'm as focused on the Black Sea as 

I am in other emerging risk areas. 

So we're never done and it's never 

going to, this is just be an ongoing thing. I 

think I can provide more specifics that I believe 

illustrate the actions we have done in more 

specificity than perhaps I presented on Wednesday 

if we can build in a few minutes for that 

tomorrow morning, I'd be happy to bring it up on 

Michelle's computer and just scroll through that 

if that would be useful. Would that help? 

MR. MORTENSEN: It would be useful to 

me. 

DR. TUCKER: Okay. 

MR. MORTENSEN: And maybe other 

members, so I would find that kind of detail 

generally helpful. Jenny, I think that I totally 

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 get it that it's a moving target. 

I just would find it helpful to be 

better informed about where we are. And what the 

current and anticipated targets are that we're 

concerned about. Those sorts of things would be 

helpful for the Board to be appraised of. 

Thanks. 

MR. RICE: Great. Any, Steve. 

MR. ELA: I just have a question, and 

I'm not sure quite how to answer it because I 

don't, or how to pose it. I mean do we see any, 

I mean we have the state programs, and we have 

the private certification programs. 

And I know state programs are 

hamstrung by full-time equivalents and budgets, I 

mean, so are private ones but, you know, they 

have to work within a governmental mandate. 

Do we see any real differences between 

programs? I mean are there any red flags we need 

to be aware of between private certifiers and 

state programs or is it just some states do 

better than others? 

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 Some private certifiers do better than 

others, I mean are there any inherent problems or 

flags in the system? Like you say I'm not trying 

to point any fingers, I'm just curious if, you 

know, different modes of action have different 

results. 

MR. CHAPMAN: I just want to point out 

real quick there's actually three. There's 

private; there's non-profit, for-profit and 

state. 

MR. ELA: Good point, sure. 

MR. RICE: And state organic programs. 

DR. TUCKER: So I'm sorry, so you're 

looking for sort of a generalized sort of 

description of --

MR. ELA: I guess I'm just wondering 

if, I mean, in the time we've been accrediting 

certifiers and you've been issuing noncompliances or anything. 

Is there any, do you see any 

differences between the structure of the program 

and ability to follow through or risk factors or 

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 --

DR. TUCKER: So I think a couple of 

them have been raised through here like the 

presence of satellite offices is automatically a 

risk. 

And also from an audit perspective 

that is a bit of a challenge in that, you know, 

we publicize the fact we have about 80 

certifiers. 

When you start actually adding in the 

number of satellite offices, it actually jumps up 

to more like 120 offices. And so getting out to 

visit all of those satellite offices is a 

challenge. 

So automatically that is going to be a 

risk just in terms of any distributed 

organization. They're going to be challenges and 

how do you get word from the mother ship out to 

all the other ships? I mean, that's just going 

to be part of it. 

I don't think I could characterize, 

sort of further than that. I think it is 

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 interesting to look at sort of the size dynamics 

of different certifiers and how many operations 

they have in terms of what that looks like in 

terms of staffing profiles and risk management. 

You know, how large do you need to be 

in order to have like a real solid infrastructure 

or quality management or things like that? I 

think honestly we try and be really transparent 

about this. 

In that, if you go to our website, you 

go to the Organic Integrity Database. If you 

look up a certifier, you can access their most 

recent audit. 

So and we have a lot of folks in the 

stakeholder community who keep a very close eye 

on the most recent audit. So once audit reports 

are finalized, certifiers have a chance to give 

their corrective actions and we evaluate those 

corrective actions. 

Those audit reports do go online. So 

I think if there are questions about any 

particular certifier, reading those audit reports 

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 will give you a general sense of what's going on 

with any particular group. 

MR. RICE: Great, thank you. Any 

further discussion or questions on this area? 

Yes. 

DR. TUCKER: One very quick final 

action. We've been really, you know, talking 

about all the areas of improvement and risk with 

certifiers. 

I do want to say there are a lot of 

certifiers doing an amazing job out there. And 

so we tend to focus on well, where do we need to 

improve? Where do we need to get better? 

But there are some amazing people out 

there doing amazing work to protect this market 

and this industry. And I just want to make sure 

that we do a shout out to the work that they are 

doing. 

Because it is an incredible group of 

professionals working out there on the ground 

every single day. 

MR. RICE: Let's give a round of 

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 applause for our certifiers. All right. Thanks 

for that, really great discussion. And with 

that, I think we can move to, let me get my place 

here. 

MR. CHAPMAN: We'll move to a vote. 

MR. RICE: Move to a vote. 

MR. CHAPMAN: All right. So this is a 

motion that comes from the CACS subcommittee and 

motion was made by Scott Rice and seconded by 

Ashley Swaffar. And it's a motion to approve the 

proposal on developing criteria for risk-based 

accreditation oversight. 

A yes vote is to adopt this proposal, 

a no vote is to reject it, and the voting starts 

with Scott. 

MR. RICE: Yes. 

MS. BEHAR: Yes. 

DR. SEITZ: Yes. 

MR. MORTENSEN: Yes. 

MR. ELA: Yes. 

MR. BRADMAN: Yes. 

DR. GREENWOOD: Yes. 

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 MS. DE LIMA: Yes. 

MR. SCHWARTZ: Yes 

MS. ROMERO-BRIONES: Yes. 

MS. OAKLEY: Yes. 

MS. BAIRD: Yes. 

MR. BUIE: Yes. 

MS. SWAFFAR: Yes. 

MR. CHAPMAN: Chair votes yes. 

MR. RICE: That's 15 yes, zero no, 

zero absent. 

MR. CHAPMAN: The motion passes. 

MR. RICE: Thanks, Tom. Next up we 

have training and oversight of inspector and 

certification review personnel, and I turn it 

over to Harriet who was the lead on this one. 

Harriet. 

MS. BEHAR: Okay, so we did get some 

really great comments on this. And I say really 

great because most of them were positive, so I 

like that. 

There were some reminders that as we 

continue to develop inspector training modules 

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 and various methods and standardization that 

certifiers should always be kept in the loop. 

I think that's understood, but we will 

keep that in mind. The Organic Seed Association 

said always keep seed issues in mind. 

There was some really great 

information provided by both IOIA and ACA giving 

us some really good topics for trainings areas 

where inspectors could use baseline skill 

trainings and knowledge as well as more advanced. 

So it could be kind of a priority 

setting list from both of those organizations. I 

like too that IOIA also brought up that it's not 

only knowledge of the organic standards that's 

important for a good inspector. 

They have to be a good interviewer, an 

excellent observer, and then be able to 

communicate that information in a clear, concise 

way to the certifier in order to do a good job in 

passing on the information that the certifier 

needs to make their determinations. 

Most of the commenters agreed that it 

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 was a good idea to include certification review 

personnel in this area. Although some certifiers 

felt that they needed to be more directive to 

their own employees and that they feel that 

they're already doing a good job. 

However, they did agree that this was 

an area that should not be forgotten that 

reviewers also need to understand the regs and be 

able to read what's being communicated to them 

and picture what's being transmitted. 

Because they have a basic 

understanding of handling or livestock or crops 

or wild harvest when those items are being 

discussed so they can then make their final 

review. 

IOIA also recommended looking at other 

post-secondary educational institutions as places 

to provide knowledge and skills to organic 

inspectors. 

And they felt that a more in-depth 

survey could be done where current inspectors 

could express where they feel they might be 

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 lacking in skills and knowledge in order to do a 

good job. 

There was discussion that the 

National Organic Program should step up and help 

fund some of the more advanced trainings that 

right now it's kind of part of the, you know, the 

inspector's pay and the non-profit or these, you 

know, small staff organizations are putting on 

these trainings and they don't have the real 

funding behind them to do some of these more 

technical trainings. 

Especially to bring in outside 

personnel that might be fairly expensive. So 

that was an interesting. Others also talked too 

about when we discussed having a list of what 

skills inspectors had so all certifiers would 

then have access to that. 

Some were concerned about the privacy 

for the inspectors that there would have to be 

some kind of release or something. So that was 

something I had not considered, but that's an 

interesting thought. 

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 Again, ACA had some great survey 

questions. They had quite an extensive public 

comments on this and even examples of like an 

evaluation form of inspectors and that sort of 

thing so that we could really see that the 

certifiers, you know, have the starts of a really 

robust system. 

We know that there's some areas where 

there can be improvement, but it's definitely an 

area where they are not ignoring this. They are 

paying attention because when there's a poorly 

written report or they get a complaint from a 

client that the inspector didn't know what they 

were doing. 

Of course, both of those kind of make 

their job a lot harder and reflect poorly on the 

certifier. So the same thing with inspectors as 

far as doing some kind of survey to see where 

there's areas of lacking. 

There was discussion about doing the 

same with review staff. Where do they feel they 

need some more help? And that sort of thing to 

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 help make sure that we're not just filling in 

gaps that are not there and then ignoring areas 

that we never knew were a problem. 

So but mostly very much the public 

agreed with where we went and liked what we did. 

And the public comments mostly gave us a little 

bit more on the priority areas that we can set by 

using these tools that we have laid out here. 

And that's it. 

MR. RICE: Thanks, Harriet. 

Discussion from the Board and question? Ashley 

or someone else while Ashley prepares her 

thoughts? Tom. 

MR. CHAPMAN: I mean I don't have any 

deep thoughts on this other than I think it was 

an excellent proposal that we received a lot of 

support on. And I look forward to passing it. 

MR. RICE: Ashley. 

MS. SWAFFAR: Yes, so I've been 

fortunate to live on both sides of this issue as 

a client, as an inspector, and now back as a 

client. 

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 So I feel like I've seen a whole gamut 

of fun stuff between inspectors and reviewers. 

And, you know, I just want to say for inspectors 

I don't feel that IOA's the only way, you know, 

for training for inspectors. 

All right, mic difficulties here. But 

I do want to point out that I really think it's 

critical when we're looking at inspectors in 

scopes. 

You know, I was a livestock and crop 

inspector, but it was not all species of 

livestock. And I think that is what I heard from 

clients so much is you know, "Man, I have this 

inspector. They didn't know a thing about 

chickens." 

And that's so frustrating for a 

client. So I think that's a place that really 

needs to be looked at by certifiers when they're 

assigning inspectors to operations. It's really 

looking at what do they know anything on a 

commercial level on those operations? 

Not just like for poultry, you know 

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 backyard, but you don't know what you're looking 

at going into a larger farm. It can be very 

challenging because I see looking at an 

inspection, some of those inspectors, they don't 

do a great on mass balances. 

And those are the critical areas that 

we're looking at for fraud prevention and things 

like that. So you know, really specializing in 

what they're doing. 

And then the same thing with review 

staff because I see a lot of variation with 

review staff when they're reviewing files, and so 

I think, you know, specialized training for them 

is critical on this too. 

MR. RICE: Sue. 

MS. BAIRD: Yes, I echo what Ashley 

says, I think that I think the inspector needs to 

be upfront with what they can do scope-wise. 

Sometimes they say, "Well, I've got a lot of 

stock," and I think that's livestock. 

And livestock might be a dairy but 

certainly not a poultry or vice versa. And I 

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 think the certifier needs to be diligent to 

pursue what the scope of the inspector's 

knowledge base is. 

And I also heard and I applaud someone 

who said that sometimes it's beneficial that we 

have team inspectors. And I see that especially 

when you go into the really complex handling 

operations. 

To date, there are some, but a lot of 

certifiers still want to give you maybe four 

hours to do a complex operation. And it just 

don't work. 

Not if people do a real true mass 

balance. Not if you're going to be comprehensive 

enough to detect a fraud. 

Now you can go in and maybe do an 

overview. So I think it needs to be education of 

our industry as well. That they understand to 

protect their reputation and to protect the whole 

Organic Integrity's reputation. 

They must be prepared to pay for a 

more comprehensive and to be; just I'll put it 

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 there, be prepared to pay for a more 

comprehensive inspection. 

When I was a QA manager at Cargill, 

we had a HACCP audit, and we expected those 

auditors to be there for a week. I mean that's 

just the way it is. 

If you're going to do a comprehensive 

that's just what we allocated to do it on HACCP 

inspection you expect them to a good four hours. 

So I think it's not only, not only the 

inspectors but we need to educate our clients 

themselves on what to expect and the value for 

them. 

MR. RICE: Thanks. Ashley. 

MS. SWAFFAR: Yes, I will say I see 

that a lot because I honestly in new poultry get 

a whole lot of chicken inspections and they've 

got to, they got a taste of it for those first 

mass balances that I did. 

They were used to it by the end, but 

they just didn't understand why it was so 

thorough. And when you explain to them, you want 

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 me to do this to you, and then you want me to do 

it to your neighbor, they kind of got it. 

Like, oh, it makes sense now. You 

know, so I think there's some education there for 

sure. 

MR. RICE: All right. 

MS. BEHAR: So having been an organic 

inspector trainer for many years and having 

mentored many inspectors and having done team 

inspections and having done multiple-day 

inspections, I agree with you. 

So I think that one area of team 

inspections and peer mentoring is kind of an area 

that is very, very useful that has not really 

been instituted, and there's times as an 

inspector trainer that I would see someone in a 

class. 

And within 25 minutes of discussion on 

some subject, I could tell who got it and who 

didn't. And I really have been trying to figure 

out what is that magic? What is that? 

You know, and it was hard for me to 

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 say what does it mean that they got it? But they 

understood the traceability; they understood the 

holistic system, they understood how in an 

interview you might hear something off to the 

side. 

Like "Oh, I'm using my brother-inlaw's bin," or something like that. And it's in 

a discussion about a family wedding or something 

like that they're talking about and that you have 

to follow that thread, because, oh, that bin was 

not on your organic system plan and we have to go 

visit it. 

So and it's the same thing at a 

handler. There might be some discussion about oh 

I had to change a supplier when you're looking at 

the warehouse. But certain people will 

understand that that was an important kernel of 

information and others it will go right over 

their heads. 

And I don't know how you identify that 

and I don't exactly how you instill that in 

people. But I think mentoring is a very good way 

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 because most people learn by experiencing. 

And so if it's like on the job 

training with somebody there to kind of be the 

safety net to make sure that the job is being 

done correctly, I think that really works well. 

But there is really very little 

funding for this because that's a big burden on 

the mentored inspector if they're just going to 

go along on these inspections and not get paid. 

And it's extra work for the actual 

inspector who's probably the one who takes the 

responsibility for the inspection to then spend 

the time with a mentee and go over things and 

say, oh, this was missed or whatever. 

So I'm not really sure with the 

program or whatever but I would like to continue 

working, especially on the mentoring and the team 

inspections which I think can be very, very 

useful. 

MR. RICE: Sue. 

MS. BAIRD: I wanted to commend the 

subcommittee on identifying approving skills how 

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 to diffuse negative situations. I think that's 

pretty critical. 

Especially we seem to be becoming more 

of a society that perhaps would take offense at 

things. And my way of doing it is to become a 

little bit more Southern lady the further along 

we get. 

We get into a tense situation and I 

just kind of giggle, "I just don't understand how 

this is just not balancing." And just get a 

little bit more dumb the whole time as I go 

along. 

Now that's my method, and it works for 

a little old Southern lady, I'm not sure how 

other people do it. But I think that's critical 

as well. 

We don't want to portray to our 

clients that they're committing fraud. We just 

need to help them to understand that there's 

another piece of information we need here. 

And I think that's critical. We're 

seeing some strange climate out there. People 

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 really want to get angry; it appears to me. So I 

like that addition on that. 

MR. RICE: Okay, I wanted to respond 

real quick. In terms of, I agree there's that 

aptitude that some people just innately have, but 

then it's important to look at some of the 

resources that we have outside of our, kind of 

certification frame of mind. 

And one of the things that we take 

advantage of or have the ability to advantage of 

some courses and trainings through the state that 

maybe are more targeted to investigative 

situations that we've found are really helpful 

for our staff both review and inspection. 

And one of the things that's been 

really helpful if sending folks to training on 

investigations that includes the IRAC method 

where you identify the issue, the section of the 

rule that applies to that issue. 

The application of that and coming to 

a conclusion and keeping it very fact focused. 

And I think when you're able to kind of walk that 

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 line it also helps address some of those 

diffusing kind of situations where it's, you 

know, we're not attacking a person we're looking 

at an issue, and we can tie it directly to the 

rule. 

And if you find yourself out in left 

field and you can't tie it to the rule, then you 

need to walk back a little bit. But it's sort of 

touching on a few things in there. 

And also I wanted to highlight that 

there were a number of commenters that also from 

certifiers saying that they appreciated a 

baseline but still wanted to maintain some or 

hold on to some flexibility in how they get to 

that baseline. 

And I think that's really important 

when we don't want to necessarily take tools that 

are working away from anybody but still allow 

that innovation. 

Ashley and then I think we need to 

wind it up. 

MS. SWAFFAR: Great. So I just want 

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 to say I do think there's a lot of really great 

inspectors out there that do a really good job. 

But we're getting ready to lose a 

whole lot of inspectors. If you look at the age 

of inspectors out there, I mean, they're ready to 

hang it up and go home. 

So like they're tired of being on the 

road. I did it for three season, and I couldn't 

cut it. I want to be in Arkansas. So I think 

that this document is critical moving forward 

for, you know, for such a growing industry that 

we have. 

We need inspectors, and we need better 

guidelines on, you know, what we expect out of 

those inspectors. So hopefully this can get in 

place before a lot of those folks retire and the 

new that comes on. 

MR. CHAPMAN: Do we need a round of 

applause for the inspectors? 

MR. RICE: I think that would only be 

fair. All right, I think we are ready to move to 

a vote. 

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 MR. CHAPMAN: It's not projecting, but 

I can get it off my screen. All right, so the 

motion, we have a motion that comes from the 

subcommittee. The motion was made by Harriet and 

seconded by Rick. 

The motion is to adopt the proposal as 

guidance of the NOP inspector certification 

review personnel training and oversight. 

A yes vote to adopt this proposal and 

a no vote is to reject it, and the voting starts 

with Harriet. 

MS. BEHAR: Yes. 

DR. SEITZ: Yes. 

MR. MORTENSEN: Yes. 

MR. ELA: Yes. 

MR. BRADMAN: Yes. 

DR. GREENWOOD: Yes. 

MS. DE LIMA: Yes. 

MR. SCHWARTZ: Yes. 

MS. ROMERO-BRIONES: Yes. 

MS. OAKLEY: Yes. 

MS. BAIRD: Yes. 

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 MR. BUIE: Yes. 

MS. SWAFFAR: Yes. 

MR. RICE: Yes. 

MR. CHAPMAN: Chair votes yes. 

MR. RICE: That's 15 yes, zero no, 

zero absent. 

MR. CHAPMAN: The motion passes. 

MR. RICE: I'm going to turn it over 

to Jenny Tucker now for a look at the Integrity 

Learning Center. 

DR. TUCKER: Is this automatically on? 

It's off, okay. So my main goal here is to just 

show you this is real. 

And to give you a sneak people and to 

invite you to come to the November 15th the 

webinar to lead more. And so the goal of the 

Organic Integrity Learning Center is to provide 

online training. 

So that's the piece of the action that 

we're filling is the online training to support 

the professional development and continuing 

education of organic professionals working to 

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 protect organic integrity. 

Now, we are really focusing on 

inspector and reviewers and certifiers. We'll 

also have a section for organic farmers and 

handlers. 

That's where we will put all of our 

collection, for example of Sound and Sensible 

modules because they're a very good training in 

there for our farmers and handlers that came out 

of the Sound and Sensible Initiative. 

So we are still working on what all 

the different topics will be, this is where 

having feedback from you will be helpful during 

the webinar and where the NOSB worked so far. 

It will be very informative in 

building this out. So this is hosted on a 

platform called blackboard.com. Blackboard is 

used by colleges and universities across the 

country. 

And so this is the landing page on the 

Blackboard server so we already have the 

infrastructure stood up and so this is just a 

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 placeholder home page. 

Eventually, once this is launched 

which we're really targeting for January. Where 

people will be able to come and register for the 

system. 

They'll be able to go to a dashboard, 

and they'll literally be able to see the courses 

that they can register for. So the different 

topics that they can register for depending on 

who they are whether they're an inspector, 

reviewer, or certifier. 

They'll be able to see their completed 

courses, they'll be able to print a transcript 

that shows what they have successfully completed. 

So then an independent inspector, for 

example, couple print out their transcript and 

take it to a certifier and say, "Hey, here's the 

continuing ed that I have done in this system." 

Now we are developing material that we 

don't believe exists out there in the public 

domain that we think everyone needs. We are also 

interested in a crowdsourcing content that other 

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 folks have already developed and that are either 

willing to just give us to up and make available 

to others. 

Or we are willing to commission 

training development depending on the topic. And 

so we're looking for a content in a lot of 

different ways. And we do see this being an 

ongoing effort. 

Based on the competencies and skill 

that continue to emerge as the top priorities. 

So again just wanted to provide that this is 

actually a system that lives on a server that 

people will be able to log into and take training 

through, again, ideally starting sometime in 

January. 

MR. RICE: Excellent, that's for the 

sneak peek, Jenny. And I'll look forward to 

learning some more about that. 

DR. TUCKER: Yes, thanks for the work 

from the Board on this and all the stakeholders 

who have contributed to this effort so far. 

MR. RICE: Great, thank you. Now I'll 

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 turn it over to Tom for a synopsis for a synopsis 

of a lot of what we've been talking about. 

MR. CHAPMAN: All right, so this is 

the verbal update, analysis, and feedback from 

the spring 2018 import panel. 

And there's no document in here yet. 

The concept here was to provide a summary of 

comments and concepts received from both the 

publish and the panels. And both panels at the 

spring 2018 meeting bucketed into major themes or 

actions. 

This document is sufficient as kind of 

being a strategic roadmap for potential future 

action with possible next steps carry's the 

responsibility in potentially some ranking of 

importance or impact for prioritization work. 

Some of these items that were 

discussed in that meeting are already under 

action either by the NOP or by the NOSB by the 

fact of the two matters we just passed. 

So and then just by evidence of the 

NOP 2019 strategic plan that was shared 

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 yesterday. So we really just wanted to put this 

on the agenda so members of the public who have 

provided their comment knew that we were 

continuing to work on that, collate that 

information, and continue to work forward to 

present then something that was usable by future 

NOSBs and the program the program to find ways to 

increase organic integrity and supply chains. 

Just, if we were to try to get it out 

at this meeting given other priorities and other 

workload. It would have been a deterrent to the 

the robust comment and feedback we received. 

So more on that to come. And we hope 

to have something that will come forward in the 

spring 2019 meeting. 

MR. RICE: Great, thanks Tom. With 

that, we complete the work of the CACS, and I 

turn it back to you Tom. 

MR. CHAPMAN: Thank you, Scott. 

Actually, I think we can get through the 

livestock section in three minutes. 

MR. RICE: No, I think we will, I will 

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 give you three minutes of your life back today. 

Perhaps there was one too many beard jokes that 

took up too much time. 

So we will move into recess in a 

moment. We'll start back up tomorrow morning at 

8:30 with the Livestock Subcommittee. Following 

that will be the Handling Subcommittee. And then 

following that and if we're running behind we 

won't stop for lunch. 

Following that will then be the Crop 

Subcommittee, after that we would deal with any 

deferred proposals. Review the NOSB work agenda 

and then go forward with officer elections. 

Hopefully wrapping up by 5:30 or 5:00 

so folks can set their prices folks can go by 

4:30 or 5:00 so folks can get their flights. 

 One last thing is to yet again remind 

folks that there's a networking reception, I 

believe, next door feature delicious cocktails 

and hors-d'oeuvres. Hopefully, they have organic 

pineapple as well. 

And that starts at 6:30 and runs to 

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9:00. Thank you, everyone, for public comment. 

The Board for its attention, participation today, 

and the NOP as well. We'll stand in recess, 

until tomorrow at 8:30. 

(Whereupon, the above-entitled matter 

went off the record at 5:28 p.m.) 

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A- 301:5 

A-dae 1:18 157:7 

174:13 177:16 301:5 

302:6 308:5 

A-dae's 184:14 306:14 

309:4 

a.m 1:10 4:2 102:16,17 

abilities 121:3 

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42:22 154:14 192:10 

328:18 349:22 368:10 

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94:12 115:6,7 116:6,8 

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135:12 205:15 220:8 

220:13 226:15 259:7 

269:6,7 329:15 

331:11 333:3 334:9 

334:17 335:1,19,21 

336:1 339:16 341:19 

355:17 356:9 368:22 

374:4,6,7,12,13 

375:13 

above-entitled 102:15 

232:16 310:17 379:5 

absence 28:22 57:16 

286:12 

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354:10 372:6 

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124:1,16 126:9 

137:20 336:4 

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ACA 118:6,12 122:1,6 

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academic 163:19 166:7 

241:8 

Acadian 131:19 132:6 

134:12 135:18 138:20 

140:16 

ACAs 193:18 194:3 

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132:11 278:15 

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210:14 

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224:1 281:4 305:22 

333:15 

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333:17 335:12,15 

340:5 341:7,10,17 

353:12 

accredited 31:10 62:11 

119:19 313:3 340:10 

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ACE 322:20 

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60:11,13 62:18 65:13 

65:21 67:9 98:15 

achieved 299:15 

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acid 5:19 7:15 90:19 

92:6,9 173:10,11 

208:13 

acidification 92:10 

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285:10 

acquiescence 108:6 

acquired 30:14 

acre 61:1 65:17 75:13 

75:13 

acreage 18:6 24:16 

67:15 227:6 314:19 

acres 6:5,9 18:9 45:21 

46:1 62:7 199:22 

262:4 

act 85:11 145:4 155:8 

186:10 199:13,15,18 

212:4 233:19 

acted 194:19 

action 116:4 133:22 

156:20 190:20 195:21 

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257:7 307:21 316:7,7 

329:2 349:5 352:7 

372:19 376:14,19 

actions 9:14 315:20 

347:11 351:18,19 

376:11 

activate 88:12 

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343:22 

activities 67:10 132:18 

203:6 290:3 313:10 

325:14 335:12 345:6 

activity 7:11 92:13 

203:20 306:5 

actual 160:6 280:18 

339:8 366:10 

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add 34:10 148:12,20 

149:3 171:6 243:22 

244:15 251:18 262:3 

265:13 281:17 283:16 

306:19 326:18 329:3 

added 15:12 19:13 

20:20 34:9 43:13 

161:18 206:15,21 

243:8 277:8 280:17 

adding 20:19 116:22 

121:15 144:9 149:15 

170:17 176:21,21 

192:22 210:14 237:19 

319:10 350:10 

addition 128:10 143:20 

145:3 185:22 187:5 

211:1,2 368:2 

additional 10:6 11:11 

23:11 112:3 128:7 

156:9 186:9 193:19 

207:17 235:11 264:22 

289:4,5 294:16 296:4 

313:17,22 318:8 

319:8 325:2 332:18 

Additionally 114:8 

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221:17 

additives 144:13 

address 11:11 37:19 

38:18 40:9 41:6 81:12 

81:18 84:1 85:20 

148:13 170:16 201:10 

235:22 244:8 279:17 

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297:7,18 298:21 

307:16 308:10 314:14 

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addressed 89:20 

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93:8 202:2 235:4 

286:9 287:7,13 312:8 

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181:9 

Adjourn 3:14 

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147:3,7,11 155:22 

156:19 222:2 

adjuvants 146:5,19,21 

146:22 147:2 156:16 

ADM 33:5 

administration 14:18 

206:7 

administrator 2:6,15 

249:11,16 

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282:3,6 283:22 

353:13 371:6,9 

adopted 134:22 194:16 

adopting 142:11 

adoption 10:5 

advance 42:22 170:13 

193:3,15 

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357:5 

advantage 368:10,10 

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advice 319:13 

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319:14 

advocacy 225:7 241:12 

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aerial 13:13 

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188:5 

affidavit 222:20 

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affiliation 5:6 9:6 22:22 

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90:9 103:1 105:21 

111:3 126:19 141:13 

162:13 170:7 207:11 

224:17 

affluent 24:8 

afford 18:13 

afraid 126:4 

afternoon 185:12,13 

198:17 

age 370:4 

Neal R. Gross and Co., Inc. Neal R. Gross and Co., Inc. 

(202) 234-4433 (202) 234-4433 Washington DC Washington DC www.nealrgross.com www.nealrgross.com 
381 

agencies 25:12 71:17 

138:18 219:9 

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317:14 

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343:20 

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368:4 

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agri-food 163:15 

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45:17 49:10 59:15 

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39:17 57:4 77:16 

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256:20 

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146:1 208:1 213:20 

216:12 218:7 222:2,4 

227:4 248:22 

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aims 166:6 

AITC 176:8,9,15 183:12 

albicans 172:6 

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Alesia 207:11 220:20 

220:22 

alfalfa 106:7 

algae 38:8 93:12 133:7 

299:14 

align 29:22 

aligned 83:19 

alkalinity 26:4 

allergen 155:6,7 222:9 

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222:12 

allergens 155:9 158:1 

222:11 

allergic 154:20 155:16 

158:2 

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allowance 12:2 19:22 

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253:1 271:14 276:22 

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233:2 

alluded 110:12 239:1 

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almonds 113:4 

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105:13 150:8,13 

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43:10 57:13 96:1 

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282:10 

amended 282:4 283:15 

283:22 

amendment 7:16 273:1 

277:11 

America 185:16 

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Analytical 204:19 

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154:1 

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angry 368:1 

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136:1 190:4,7 

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Ann 38:20 

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181:2 195:8 

annotations 294:14 

announced 240:2 

annual 31:15 134:4 

136:22 320:2,4,12 

annually 133:22 136:20 

anonymous 258:18 

ANSI 24:6 

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anti- 96:16 

antibiotic 174:16,18 

219:21 

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179:10 

anticipate 117:11 

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antifungal 175:14 

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172:19 218:6 

antimicrobials 171:11 

171:16,20 172:2 

175:5,8,20 

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anybody 265:7 369:18 

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anyplace 242:18 

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242:18 

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apiary 173:12 

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309:18 362:4 

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93:22 95:1 216:11 

368:20 

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200:5 321:18 

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289:6 316:12 

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apply 46:8 291:2 

300:10 

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appreciate 20:19 41:20 

53:15 84:17 102:4,7 

108:8 111:8 127:7 

132:2 138:14 196:13 

202:3 222:14 232:2 

240:14 241:17,22 

259:12 306:14 324:13 

328:2 

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156:10 180:12 248:19 

325:12 369:12 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
382 

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apprenticeship/mentor

121:20 

approach 39:19 40:7 

43:7 106:19 235:20 

271:6 287:6 308:6 

319:4 323:10 325:16 

334:9 340:19 341:6 

344:5 

appropriate 31:16 

121:9,21 122:15,18 

128:19 166:1 209:13 

320:5 333:21 342:20 

appropriately 331:11 

approval 10:8 62:16 

approve 171:8 172:15 

178:20,21 181:12,13 

182:2,3,4,5,7 183:14 

184:8 353:10 

approved 58:4 112:18 

114:4 143:19 181:21 

182:16 183:2 185:1 

195:12 214:6,17 

221:18,19 268:12 

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approving 42:19 182:8 

366:22 

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87:16 133:12 200:11 

210:1 

April 281:3 

aptitude 368:5 

aquatic 38:11 93:6 

210:6 

area 45:22 62:5,8 65:2 

65:3,13,19 67:4,13,16 

68:2 78:6 81:8 125:6 

125:19 130:3 141:17 

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304:2 305:4,15 334:4 

352:4 356:2,7 358:10 

364:12,13 

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56:22 65:22 66:9 

133:12 134:2,9,11 

141:2,5,6 164:2,16 

166:4 167:16 170:12 

199:9 215:6 235:16 

256:4,8,16 290:11 

304:5 311:19 318:15 

322:5 347:7 352:8 

355:8 358:8,19 359:2 

359:7 361:6 

arena 204:9 

argued 74:11 

argument 72:22 

arguments 72:16 

Arkansas 370:9 

arm 193:19 

arms 108:7 205:16 

arrangement 105:6 

arrangements 326:6 

Arroyo 90:7 

Arsenault 2:4 141:22 

articulated 303:16 

artifact 329:9 

artificial 275:19 276:1,6 

Arturo 90:7 97:12,16 

Asa 1:14 35:12 39:9 

84:18 93:20 96:2 

138:2 174:12 176:6 

230:12 262:10 299:19 

Asa's 183:12 

ascophyllum 132:11 

133:2,5,15,18 134:2,8 

134:14 138:21 140:17 

141:3 

Ashley 1:21 101:14,21 

150:1 173:7 177:17 

180:2 192:14 265:3 

267:5,10 279:13 

284:1 343:1,18 

353:10 359:11,12,18 

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280:7 295:17 296:1,3 

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237:22 250:20 267:12 

307:7 

asks 148:11 

aspect 300:10 

aspects 23:21 138:4 

165:20 322:11 

assay 31:2 

assessed 203:11 

assessing 80:15 312:7 

313:8 326:3 

assessment 128:9 

307:12 333:19 335:22 

336:12 340:16 

assessments 137:3 

334:3 

assigning 253:18 

331:16 360:19 

assist 123:3 208:13 

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172:7 201:3 

associates 24:2 63:4 

78:17 116:15,20 

association 56:14 87:2 

119:22 188:22 189:8 

190:10 192:21 193:4 

194:8 195:3 197:8 

253:14 269:21 270:7 

355:4 

Association's 128:7 

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assuage 291:11 

assume 287:2 334:16 

assumptions 210:8 

213:2 

assure 82:1 

assured 25:14 

asynchronously

197:22 

at-risk 265:15,17,21 

Atlantic 299:8 309:9 

atomic 211:21 

atoms 211:22 

attached 214:14 

attack 100:19 

attacking 369:3 

attacks 10:21 

attempt 94:22 193:10 

attempts 10:16 

attend 52:12 

attendance 320:6 

attention 44:4 77:6 

103:15 111:8 166:11 

236:7 237:13 240:19 

280:21 281:10 345:9 

358:11 379:2 

attestation 294:21 

attracted 100:17 208:21 

attracting 101:3 

attribute 259:7 

audible 78:22 105:17 

188:16 224:11 

audience 45:21 199:4 

242:14 269:11 

audit 68:11 121:7,17 

130:1 190:14 313:10 

316:5 320:22,22 

323:14 350:6 351:13 

351:16,16,20,22 

363:4 

auditor 314:16 323:11 

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335:21 337:20 341:10 

August 74:21 228:20 

Austin 132:5 

authorities 10:18 

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306:11 

authorization 66:14 

authorize 98:1 

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automatically 318:17 

350:4,15 372:11 

availability 113:2,11 

158:7 161:13 169:10 

178:1 224:2 

available 6:20 98:4 

112:21 113:1,19 

117:11,13 118:17 

129:13 157:18 170:21 

189:10 194:18 195:9 

208:5 239:2,6 250:16 

250:17 251:10 286:12 

315:8 326:3 375:2 

avenue 334:1 

average 106:16 133:10 

187:11 316:15 

averages 218:19 

avocados 80:14 

avoid 10:14 11:5 13:12 

44:4,6 71:5 81:14 

151:12 152:14 319:21 

avoiding 152:11,11 

342:21 

awake 82:11 

aware 13:10 117:8 

163:18 174:3 348:20 

awareness 44:5 

axiles 75:10 

B

b 165:6 

back 4:3,6,11 11:18 

30:12 64:1,10,12 77:2 

89:15 96:3 97:10 

102:11,13 116:19 

131:2 149:21 157:22 

169:3 181:20 190:6 

195:10,13 220:5 

222:22 228:22 230:21 

231:22 232:14,20 

235:9 247:2,16,18 

255:9 258:1 260:15 

271:20 272:4,7,15,20 

273:1,4,5 274:4,5 

275:11 276:13 277:8 

278:3 280:17 295:2 

298:13 302:5 310:12 

310:15,22 318:18 

325:4 328:7 332:7,12 

338:12 344:8 359:21 

369:8 377:18 378:1,5 

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backsliding 345:2 

backyard 361:1 

bacteria 171:20 

bacterial 147:22 148:3 

148:15 149:2 150:21 

172:7 208:14 209:7 

bacteriophage 240:8 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
383 

bad 51:9 67:2 125:10 

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bag 113:20 115:5 253:5 

260:14 

BAIRD 1:14 50:6,9,11 

50:19 53:14,20 54:2 

72:1,5,13 246:10 

259:12 263:1,14,16 

266:1 273:9 283:5 

284:14 306:14 354:5 

361:16 366:21 371:22 

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212:8 329:22 362:14 

Balanced 92:11 

balances 67:20,21 68:2 

68:14 361:5 363:19 

balancing 367:10 

Ballrooms 1:8 

ban 47:22 

banana 71:18 

bananas 80:13 

banned 52:10 

bar 126:12 

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216:3,20 218:14,20 

223:16 233:19 259:20 

279:15 307:12 314:4 

337:20 341:6 375:9 

baseline 29:20 129:21 

250:19 316:20 340:22 

341:12 355:9 369:13 

369:15 

basic 341:7 356:11 

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83:20 157:16 234:10 

287:6 300:2 

basis 34:16 187:12 

191:11 326:7 

batch 264:5 

Batcha 185:11 188:21 

188:21 193:1 194:20 

197:16 198:12 

Baumgartner 38:20 

Bay 304:1 

Beach 23:2 

Beal 132:22 

bean 149:8,9 150:17,18 

beans 106:6 

bear 105:9 

beard 228:10 229:21 

311:9,10 330:11 

378:2 

beautiful 344:3 

beautifully 232:5 

beauty 220:12 

becoming 86:9 367:3 

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beds 133:22 134:8 

305:14 

beekeepers 173:22 

bees 53:18,21 

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beginning 59:18 105:1 

132:4 226:9 297:21 

303:14 306:2 

begun 37:9 326:12 

behalf 8:6 17:16 41:4 

47:16 97:22 119:21 

123:6 185:14 200:17 

221:4 

BEHAR 1:13 13:20 

20:10 32:3,5 34:14 

43:18 46:17,20 51:1 

57:22 58:7,18 59:3,5 

61:5,7 100:12 101:8 

109:7 110:10 114:13 

123:10 130:21 149:12 

167:4 233:7 241:11 

241:16,20 243:10 

244:18 245:2 246:14 

247:4 257:20 260:9 

261:5,13 262:10 

263:17,21 264:7,10 

265:3,14 267:4,10,17 

269:2,10,16,18 270:6 

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277:14,19 279:2 

280:6,20 282:17 

284:4,21 298:6 

299:19 301:4 302:5 

304:21 305:17 306:13 

308:3,12 309:22 

340:3 353:17 354:17 

364:7 371:12 

behavior 260:17 

behaviors 257:8 314:8 

believe 22:14 58:16 

85:6 91:12 124:12 

137:22 143:13 144:15 

146:22 147:6 150:3 

158:20,20 161:14 

164:3 227:18 268:9 

277:2 344:4 346:18 

347:10 374:20 378:19 

Bellevue 224:16 225:1 

belong 123:19 176:4 

beneficial 7:10 165:5 

172:21 305:16 362:5 

benefit 25:9 42:2 85:2 

176:2 208:6 

benefits 25:14,18 

163:10 165:4,4 

bent 103:22 

berries 113:3 

berry 92:9,17 

best 25:19,20 39:19 

40:7,13 50:17 59:19 

66:20 120:20 131:4,5 

131:10,13 168:16 

194:20 203:13 243:8 

289:10 295:12 297:19 

308:5 324:8 

better 7:7 8:5 17:7 51:8 

95:8 110:3 118:19 

164:12 225:19,21 

253:16 296:7 297:6 

299:6 307:3 316:15 

330:11 341:15,15 

345:1,21,22 348:3,22 

349:1 352:13 370:13 

beyond 17:12 95:4,4 

170:10 204:2 231:21 

251:2 262:20 264:18 

268:4 297:11 298:8 

bi-year 22:11 

Bialic 131:16 141:14,14 

145:12,16,19,21 

146:7,15,20 147:6,12 

147:21 148:22 149:6 

149:8 150:5,16 151:5 

152:10,17,21 153:20 

155:10 156:11 157:1 

157:13 158:5,12,15 

158:19 159:18 160:14 

162:7 

big 14:4 33:3 57:12 

67:12 71:3,20 74:20 

79:15 95:22 115:20 

204:2 215:21 216:1 

218:5,6 336:5,9 340:8 

343:21 366:7 

bigger 17:21 

biggest 63:16 205:19 

206:11 

bill 10:17 228:20 318:3 

341:16 

billion 114:1 

bills 225:10,12 

bin 365:7,10 

bind 209:2 

bins 14:10 

bio 92:3 

biobased 236:13 

240:16 

biodegradable 236:13 

240:16 

biodiverse 165:1 

biodiversity 37:4 38:11 

164:12 173:2 

Bioecological 56:14 

biological 63:12 

biologist 23:3 

biologists 38:2 

biology 172:13 

biomass 64:9,10 70:11 

70:12,15 133:21 

137:5 

biopesticides 94:6,15 

BioSafe 23:4,7 26:17 

Bioscience 207:14 

biotech 142:22 143:4 

biotechnology 143:4 

bit 22:11 24:13 35:14 

94:21 95:4,5,18,19 

107:9 108:18 109:7 

110:7 111:11 156:17 

159:11 160:5 214:5 

236:12,17,22 237:1 

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251:17,19 252:13 

253:12 254:15 258:3 

270:10 275:21 287:15 

300:8 322:18 327:13 

329:16 330:10 335:21 

336:13 338:5 350:7 

359:7 367:6,11 369:8 

black 174:22 236:1 

242:3 347:5,6 

Blackboard 373:17,21 

blackboard.com

373:17 

blight 239:22 240:9 

block 124:9 

blood 75:18 

Blount 207:5,8,12,13 

211:20 212:18 213:16 

213:19 214:21 216:7 

217:4,16 218:2,11 

219:12 

blue 32:21 

board 1:3,8 2:4 4:5 5:2 

8:10 9:9 11:2 19:17 

27:3 41:6,21 42:12,17 

42:19 45:17 53:13 

61:11 77:13 84:13 

93:2 97:16 102:19 

104:17 132:7 136:14 

164:7 168:7,11 

169:12 170:9,11,15 

185:18 186:5 189:10 

189:14,16,22 190:13 

191:4 192:17 194:14 

194:15 195:12,19 

196:9 197:12 198:8 

198:21 202:12 221:6 

224:19 226:3 227:3 

230:15 232:19 268:22 

272:18 280:21 285:6 

287:19 297:11 298:7 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
384 

302:17 309:21 312:2 

323:7 324:22 328:1,5 

340:1 344:17,20,21 

348:6 359:11 375:20 

379:2 

Board's 12:12 41:20 

92:20 

Boardman 111:17 

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boat 265:8 292:18 

boats 136:19 137:17 

292:13 

Bobbe 345:13 

Bock 207:11 220:20,22 

220:22 

body 25:11 

Bondarela 74:11 

border 52:5 322:20 

borders 55:11 201:21 

206:2 256:17 

born 63:13 77:20 78:2 

190:4 318:1 

borne 261:11 

boss 79:10 

bottlenecks 16:5 

Boulevard 1:9 

bound 208:12 

bounds 271:18 

box 118:22 260:15 

266:17 

boxes 6:4 

boy 265:11,13 

BPA 41:12 42:21 43:2,3 

43:10,10,18,21 44:6 

237:13,15 

Bradman 1:14 35:13 

39:10 84:19 86:5 

93:21 94:20 138:3 

139:9 176:7 177:3,9 

177:13,15 183:18 

184:1 230:13 246:18 

262:11 263:12,15 

273:17 282:21 284:8 

299:20 302:2 353:21 

371:16 

brag 65:1 202:13,18 

branch 87:1 205:3 

branches 204:18 

brand 31:19 48:10 

brands 29:8 

Brawley 132:22 

Brazil 174:5,7 

bread 234:11,15 

break 4:10 55:20 64:6 

97:13,13 102:11 

232:12 233:1 310:12 

breakdown 317:17 

338:6 

breaks 24:4 

breeding 236:8 238:3 

Brenes 72:14,15 

Briceno 77:1 

brief 77:10 310:12 

briefing 196:21 

briefly 156:8 163:1 

178:6 228:17 277:10 

bring 37:11 38:5 99:16 

137:8 153:22 230:10 

230:15 242:22 248:6 

276:14,20 280:21,22 

281:10 301:18 347:14 

357:12 

bringing 52:17 241:16 

247:18 

brings 117:6 

broad 37:11,21 172:19 

216:3 219:20 220:2 

290:4 341:6 

broader 19:6 

brother-in- 365:6 

brought 290:9 330:8 

355:13 

brown 6:18 

BT 33:16 94:15 

bucketed 376:10 

budget 268:12 

budgets 348:15 

budgetwise 268:11 

buffer 106:15 

BUIE 1:15 18:17,21 

246:11 263:18 264:5 

264:8 273:10 282:14 

284:15 354:6 372:1 

build 123:3 335:17 

347:13 

building 16:10 124:9 

230:7 373:16 

bulk 113:20 115:20 

Bunge 33:5 

burden 203:2 249:20 

261:9 262:9 293:11 

366:7 

burdens 107:3 

burner 95:10 

burners 7:18 

burning 7:17 

burns 18:4 

business 46:13 52:7 

63:9 71:19 104:6 

116:19 118:15 127:21 

142:16 169:20 191:17 

192:9 272:16,18,20 

317:11 

butchering 77:1 

buy 80:6 151:19 152:4 

153:5 168:3 183:17 

251:13 266:17 341:17 

buy-in 37:15 

buy-out 17:4 

buyer 130:21 

buyers 131:7 

buying 35:1,2 88:2 

104:11 251:12 262:1 

262:8 267:2 

buzzer 4:21 

byproducts 113:9 

C

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CACS 233:1,2 310:11 

310:13 311:13 353:8 

377:17 

calcium 8:3 

California 111:16 

198:19,22 199:3,5,6 

199:13,18,20 200:4 

200:18,20 201:7,15 

201:21 202:14,19,20 

203:2,9,12 206:1 

225:3 303:17,20 

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call 5:3 11:1 17:1 25:6 

61:21 107:7 108:7 

128:7 232:12 253:8 

299:13 310:21 

called 46:9 143:5,5 

195:7 270:16 274:15 

373:17 

calling 164:8 214:17 

247:8 342:16 

calls 172:19 345:12 

Canada 131:21 136:3 

136:21 

Canadian 167:20 

canals 24:19 

CANAPEP 81:3 

candida 172:4,5 

cannabis 26:21 

CAPA 86:22 87:4 

capabilities 30:14 

332:8 

capability 339:7 

capable 339:1 

capacity 14:8 16:12 

37:17 260:17 319:14 

321:16 

capped 212:2 

capsicum 184:16 

capsule 117:12 

capture 60:18 254:19 

328:20 

captured 338:3,4 

captures 120:20 

carbon 236:20 

carbonate 8:3 23:15 

26:18 

care 43:22 45:15 

117:18 

career 335:10 

carefully 287:21 

Cargill 33:5 363:3 

Carlos 59:5,9 185:13 

carob 149:9 150:18 

Carolina 9:10 11:19 

12:16,18 17:5 23:3 

carpet 71:16 

carrageenan 150:3,9 

152:8,10,16 153:7 

carried 83:5 

carries 45:13 

carry 185:3 339:2 

carry's 376:14 

case 17:17 40:10 55:13 

64:12 67:19 70:2 71:6 

78:18 81:13 125:10 

210:7 213:2 222:11 

222:13 224:5 251:4 

261:21 262:19 263:9 

266:20 267:2 286:8 

291:20 292:16 293:19 

295:12,14 337:1 

cases 106:9 142:3 

292:21 302:9 

Casey 36:19 40:21 41:4 

cash 163:5 

casing 171:10 

catch 253:8 309:12 

Catch-22's 193:13 

categories 254:4 

categorization 121:9 

category 142:9 159:5 

222:15 288:16 314:9 

314:10 

cats 244:7 

cattle 66:9,11 

cause 26:10 57:17 

91:19 169:1 254:15 

causes 26:4 57:8 182:8 

causing 8:3 148:4 

169:4 

caution 237:8 

cautious 317:10 

CBI 143:9 

CDC 219:8 

CDFA 200:17 202:20 

203:18 

celery 113:4 237:12 

cell 208:14 220:4,4,8,9 

220:10 

center 188:10 204:19 

372:10,17 

centimeters 133:11 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
385 

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173:3 

centralized 329:1 

certain 35:10 124:7 

130:22 215:6 333:18 

337:17 365:16 

certainly 101:1 113:4 

114:18,19 115:10 

124:7 136:6 155:10 

194:22 197:18 211:20 

289:2 309:17 336:22 

336:22 339:19,22 

361:22 

certainty 49:22 

certificate 62:21 

certificates 203:18 

338:19 

certification 3:8,12 

4:12 21:18 56:8 65:20 

66:15 67:1,4,14 68:11 

72:3,5,7,9 120:6 

127:10 129:5,17 

135:12,17 168:6 

181:18 193:10 225:5 

225:6,11 259:18,19 

259:19,22 260:1 

271:17 286:13 290:15 

293:13 294:1,8,12,17 

295:3 297:5 311:2,22 

312:13 317:19 321:7 

321:19 334:3 342:2 

348:13 354:14 356:1 

368:8 371:7 

certifications 62:19 

67:19,22 87:10 

certified 24:7 25:16 

29:3 104:18 106:5 

117:9,16 127:19 

128:13,17 129:2 

135:20 136:2 183:20 

184:2,3 187:11 190:5 

193:17 227:5 271:13 

292:3,17,21 293:5,10 

300:21 

certifier 136:3,11 162:1 

222:20 226:4 250:14 

254:22 258:9,20 

263:15 313:4,11 

315:22 317:5 318:4 

319:10,12,13,16 

320:1,9 325:15 

337:10 342:10 351:12 

351:22 355:19,20 

358:17 362:1 374:11 

374:17 

certifier's 321:13,14 

certifiers 10:12 11:4 

13:8 37:13 38:4 83:17 

93:14,16 108:15 

120:3 121:11 122:1,6 

123:13 124:7 127:17 

128:3,5 143:16 

201:10 255:1,2 

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269:19 280:3 289:8 

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349:1,18 350:9 351:2 

351:17 352:9,11 

353:1 355:2 356:2 

357:16 358:6 360:18 

362:10 369:12 373:3 

certifies 307:8 313:6 

319:16 

certify 106:1 136:3 

291:18,19 293:19 

certifying 67:5 72:2,6 

290:12 291:14 298:16 

CFR 221:17 

chaff 26:14 

chain 9:14 28:18 29:13 

88:19 103:16 115:9 

204:1 311:15 

chains 10:14 311:18 

377:8 

chair 1:12,13 149:13 

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279:2 280:6,20 

282:17 283:6 284:4 

284:16,21 298:6 

299:19 301:4 302:5 

304:21 305:17 306:13 

308:3,12 309:22 

354:8 372:4 

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Chairman 1:10 4:3 8:14 

9:2 12:7 13:19 15:1 

18:15 19:7 20:9,16 

36:15,17 39:8 40:20 

43:16 44:7,12,15,17 

44:19 45:1 46:15 

47:11 50:4,22 51:10 

51:16,18 53:12 54:4 

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245:4 247:1 261:6,16 

268:1 269:3,13,17,22 

271:22 272:4,9 274:1 

274:3 277:6,16 

280:11 281:20 283:6 

283:9 284:16,19 

310:10 

challenge 206:5,11 

347:4 350:7,14 

challenges 91:19 

163:16 165:15 169:15 

190:20 204:7 205:18 

205:19 315:9 317:14 

346:20 350:17 

challenging 69:15 

361:3 

chamber 67:18 77:7,16 

77:20 78:2,5,8,13 

81:4 

chance 175:5,21 176:1 

202:13,18 247:20 

256:9,18 268:6 

277:21 351:17 

change 31:18 38:13 

73:15 98:6,19,22 

127:12 188:3 195:4 

198:6 238:10 257:8 

276:18 277:2 365:15 

changes 21:22 35:16 

110:1 128:13,20 

301:12 

channel 223:10 

CHAPMAN:Is 158:13 

character 73:10 

characteristic 42:9 

characteristics 131:8 

257:5 

characterize 350:21 

characterizing 21:7 

charcoal 60:18 

charge 250:19 264:2 

Charlotte 41:16 

chart 60:8,22 81:6 

275:2 

cheap 49:6 103:9,11 

104:11 

cheaper 34:6 35:7 

65:18 103:12 

check 69:10 137:21 

227:11,12,14,15 

255:11,12 293:16 

311:9 

checked 53:4 

checking 63:11 70:12 

203:18 

checks 62:15 

cheese 143:2 

chemical 171:4 172:13 

275:19 276:1,5 279:5 

chemicals 142:18 

168:16 

chemistries 26:2 

chemistry 24:1 25:9 

204:20 205:10 

cherries 5:12 6:3,9,19 

cherry 5:22 

chicken 363:17 

chickens 360:15 

chicks 41:10,20 

childhood 45:8 

Chilean 19:18 115:16 

chime 148:21 

Chipotle 336:17 

choice 254:2 

choices 119:1 151:6,10 

249:1 

choose 226:15 250:8 

chooses 62:1 250:11 

choosing 66:13 

chose 333:7 

Chris 76:6 

Christian 59:6 61:7,12 

86:1 

cigarettes 226:14 

citations 337:13,22 

338:2,15 

cite 338:13 

cited 145:7 

citrate 96:16 172:2 

207:15 208:12 209:3 

211:22 220:13 

Citric 208:12 

citrus 217:21 218:5 

claim 194:9 

claims 291:14 

clarification 83:2 

109:18 184:13 267:7 

279:13 280:5 317:16 

clarify 137:19 179:12 

189:2,7 194:21 

clarifying 190:20 325:9 

CLARISSA 2:11 

clarity 107:1 108:13 

280:2 

class 150:15 364:17 

classified 143:1 

clause 160:18 

clauses 337:18 

clean 257:3,3 

cleansers 41:12 42:1 

clear 68:21 82:17 105:4 

146:16 179:22 184:15 

244:11 265:5 291:17 

299:14 337:1 355:18 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
386 

clearance 196:8,11,12 

196:16 197:13 

clearly 24:14 197:10 

249:22 253:12 265:11 

285:13 286:1 287:21 

291:6 

clearly-stated 257:22 

clever 72:22 

client 88:1 358:13 

359:21,22 360:17 

clientele 334:11 

clients 116:21 117:15 

221:2 263:5 334:4,7 

343:16 360:13 363:11 

367:18 

climate 38:13 98:18,22 

238:10 367:22 

climates 163:7 

climatic 87:12 165:15 

clock 102:9,10 

close 9:14 52:4 303:9 

310:8 351:15 

closed 76:17 190:18 

195:15 

closely 201:8,18 206:6 

231:4 

closer 301:18 321:3 

323:5 

closing 114:3 122:9 

club 61:14 104:11 

clusters 212:1 

co-existence 257:15,16 

co-existing 257:18 

co-op 46:4,12 48:6 63:5 

159:3 168:3 

co-op's 48:9 

co-writers 252:14 

coalesce 233:16 

Coalition 41:5 

Coalition's 101:18 

coast 48:9 303:13,19 

coastline 141:5 

cocktails 378:19 

cod 309:10 

code 35:17 

coexistence 107:8,21 

cold 53:4 61:21 74:1,3 

87:3 99:5 230:6 257:2 

coldest 62:1 

collaborate 81:12 166:7 

201:22 326:13 

collaboration 326:14 

collaboratively 122:5 

342:13 

collagen 171:9 

collate 377:4 

colleague 38:20 41:16 

colleagues 52:16 69:2 

96:4 

collection 130:7 373:7 

collectively 342:7 

collects 329:9 

colleges 373:18 

collision 308:9 

colony 307:13 

colored 181:2 

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comb 33:21 34:11 

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come 4:6,11 39:14 

47:16 57:12 75:3 

85:17 86:6 89:7,7 

102:3,11,13 117:20 

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166:22 167:21 181:20 

203:8 214:15 225:15 

228:22 232:20 235:4 

235:11 238:8 293:13 

295:2,15 298:17 

300:19 303:9 305:10 

305:11 310:8,12,22 

324:14 329:11,19 

332:12 372:15 374:4 

377:13,14 

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149:20 161:7 203:9 

231:4 245:6 264:12 

298:13 302:17 303:19 

304:12 316:16 325:4 

326:7 337:15 353:8 

370:17 371:3 

comfortable 218:22 

259:10 302:3 304:16 

336:1 

coming 33:6 54:21 58:9 

63:9 67:21 174:5 

201:21 206:4 234:2 

247:13 260:21 299:7 

314:21 339:19 368:20 

commend 366:21 

comment 4:8,9,15,18 

23:14 32:1 39:11 

84:17,19 97:1 109:14 

110:6 111:6,20 

115:18 116:16 119:8 

123:6 124:18 127:1,9 

138:14 142:6 149:21 

158:9 162:20 164:2 

169:22 173:15 177:19 

191:16 192:2,3,6 

197:6 200:22 227:17 

228:9 229:7 231:2,12 

231:16 233:22 235:17 

236:17,18 237:4,7,14 

237:17 238:3 240:22 

242:13 244:16 248:13 

262:12 267:13 270:12 

285:1 290:10 302:8 

312:3 313:16 315:14 

324:7 333:5 334:2 

339:13,16,19,20 

342:4 377:3,12 379:1 

commented 21:10 

93:14 112:11 113:10 

132:4 302:13 

commenter 176:9 

212:10 235:22 236:9 

commenters 231:13 

247:13 288:17 314:2 

314:6,11,17 315:19 

316:9 317:16 319:3 

355:22 369:11 

commenting 119:21 

166:20 221:3 

commercial 77:22 84:9 

94:17 98:4,8 224:2 

360:21 

commercialization

88:14 

commercially 117:10 

189:10 

commercially-availa...

254:8,14 

commission 375:4 

commitment 88:7 

90:13 187:20 

committee 144:3 

149:13,18 200:19 

306:1 330:21 333:7 

committing 367:18 

commodities 199:3 

commodity 171:1 

186:19 251:4 

common 12:20 125:20 

169:18 301:2 316:20 

316:21 323:13 

commonly 91:6 151:8 

171:15 

communicate 267:19 

355:18 

communicated 356:9 

communication 30:3 

322:19 

communications

315:10 

communities 231:17 

295:9 304:8,10 308:7 

community 10:19 62:14 

67:18 69:9 107:3 

125:15,21 132:15 

141:15 163:17 168:2 

173:4 237:19 241:8 

249:15 257:1,9 

270:21 303:10,14,21 

311:14 320:13 327:22 

328:19 351:15 

community-owned

141:16 

companies 30:13 31:13 

32:20 33:2 38:3 

117:13 141:7 142:17 

142:18 186:20 298:18 

company 23:8 111:12 

131:20 134:13,17 

135:22 167:20 219:15 

compared 25:18 84:22 

181:7 289:2 

compatible 7:4 172:9 

172:17 177:1 

compensation 11:7,10 

12:11 13:14,21 14:8 

14:20 122:16 

compete 104:7 

Competence 122:17 

competencies 375:9 

competitive 169:19 

complaint 201:1 263:9 

343:7,13,17 358:12 

complaints 200:6 

343:12 

complete 34:2,11 53:8 

377:17 

completed 10:7 92:11 

374:12,14 

completely 63:12 

197:16 308:7 

complex 130:14 163:15 

208:11 362:7,11 

complexes 209:2 

complexity 31:6 

compliance 3:8 4:12 

10:1 22:15 31:6 

116:22 127:10 130:12 

205:3 311:1 315:22 

compliances 349:19 

compliant 49:15 87:9 

228:11 331:22 

complicated 105:12 

178:12 247:5,11 

250:2 

complicit 38:17 

comply 76:14 161:15 

188:8 

component 130:10 

components 83:18 

209:1 

compost 291:10 

composting 111:22 

compound 159:21 

172:20 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
387 

compounded 212:2 

compounds 143:1 

209:16 

comprehensive 41:11 

42:3 43:8 130:1 

233:17 311:18 315:1 

344:8 362:14,22 

363:2,7 

compromise 39:19 

300:18 301:20 302:4 

computer 347:15 

conceal 142:15 

concentrate 79:16 

327:7 

concentrated 299:10 

concentration 29:19 

30:17 210:4 

concentrations 209:15 

209:22 213:8 

concept 14:4,11 376:7 

concepts 80:17 106:21 

107:10 376:8 

concern 15:10,11 16:17 

19:13 43:19 47:21 

84:2 148:6 153:14,19 

156:17 180:15 216:20 

261:7 265:2 285:15 

290:9,11 291:13 

293:17 317:20 318:11 

concerned 11:21 12:15 

81:6 132:9 150:20 

161:21 168:14 259:16 

260:6 300:6 309:17 

347:3 348:5 357:18 

concerning 219:1 

concerns 107:2 144:2 

148:14 180:10,11 

201:3,11 202:2 219:5 

219:7 291:12 343:21 

concise 355:18 

concluded 132:15 

231:12 232:22 

conclusion 58:3 78:11 

132:19 133:1 139:10 

139:12 140:14 217:1 

296:10 297:14 368:21 

concrete 136:15 

concur 154:11 

condition 100:7 

conditions 59:20 87:12 

113:15 

conducive 7:22 

conduct 122:22 130:9 

conducted 200:7 

conducting 186:2 

conducts 272:18 

conference 344:13 

confidence 153:13 

confident 37:10 210:22 

340:7 

confidential 142:15 

258:21 317:11 

confirm 148:9 154:3,10 

315:7 

conflicting 194:5 

conflicts 319:22 

conform 199:15 

confusing 210:19 

Congress 78:9,11 

83:14 85:19 

Congressional 81:17 

connected 310:4 

connection 142:4 

Connor 28:11 36:19,20 

36:21 

consensus 297:18 

consequence 314:10 

consequences 81:20 

169:2,7 175:15 

conservation 134:11 

conservationist 38:3 

conservationists

286:14 

conservative 180:6 

conserving 164:16 

consider 190:3 191:5 

191:15 224:3 236:3 

237:8 314:9 338:10 

consideration 80:19 

84:14 93:2 118:11 

148:13 164:5 166:12 

221:6 235:7 303:7 

considered 31:8 114:16 

138:12 193:4 210:12 

221:21 222:1,8 

252:20 274:20 278:3 

300:5 304:4 313:17 

317:3 357:21 

considering 43:14 

87:11 88:16 291:22 

consignee 103:6 

consistency 120:5 

123:12,21 

consistent 9:16 20:8 

21:17 127:18 132:19 

134:3 141:4 195:10 

308:18 309:19 323:3 

325:17 

constant 48:13 

constantly 69:6 

consternation 254:15 

constraints 346:11 

consultancy 319:14 

consultant 119:20 

222:22 

consultants 208:8 

consultation 52:16 

79:18 

Consulting 221:1 

consumer 29:7 80:10 

85:8 88:21 103:18 

141:19,19 151:11 

153:13,18 155:7 

156:5 168:10,13 

203:16 

consumer-facing 44:2 

consumers 142:3 143:7 

143:13,16 148:2 

150:10 151:18 153:4 

153:16 154:18 155:9 

159:18 160:22 167:22 

168:1 224:7 286:15 

296:14 337:7 

consumers' 107:18 

consuming 58:14 

consumption 218:20 

221:20 291:21 

consumptions 221:18 

contact 12:22 40:16 

270:2 299:3 

contacted 343:9 

contacts 233:15 299:5 

contain 155:13 293:5 

321:1 

container 74:15,18 

containers 74:15,16 

containing 212:13 

contains 37:14 

contamination 11:12 

29:3,11,14 30:5 32:18 

56:1,5 106:8,9 107:13 

108:6,10,22 238:6 

249:6 250:6 254:16 

255:8,21 256:10,18 

259:8 271:11 288:10 

content 29:6 30:3 33:7 

374:22 375:6 

contention 295:17 

contents 3:1 69:11 

context 165:7 235:19 

continually 21:12 121:2 

167:5 206:14 210:20 

314:21 

continue 16:11 40:6 

46:13 52:10 85:8 

114:5 117:5 122:7 

132:8 201:22 227:3 

287:4 324:5 328:14 

328:19 332:19 346:3 

354:22 366:16 375:10 

377:5 

continued 5:18 8:8,11 

25:7 90:18,21 92:5,14 

92:21 103:15 

continues 108:4 112:16 

201:18 206:12 

continuing 105:11 

121:8 122:10 123:3 

229:13,15 268:10 

295:2 317:9 324:1 

327:18 334:5 372:21 

374:18 377:4 

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118:18 190:12 

continuously 20:6 

91:22 

contract 131:9 178:14 

contracting 178:15 

contracts 200:15 205:8 

contradicts 262:22 

contrary 110:16 

contrast 132:17 

contribute 112:8 313:3 

contributed 375:21 

contribution 202:21 

contributions 163:4 

contributor 188:1 

control 6:14,17 7:3 8:9 

16:16 23:10 48:16 

72:2 92:1,4 99:18 

101:11,17 176:17 

208:1 237:3 239:21 

268:5 317:17 321:10 

322:3 338:6 

controlled 49:1 88:17 

controlling 92:7 

controls 63:12 

conundrum 191:3 

conventional 14:9 17:6 

58:9,16 59:14 63:10 

64:19 65:13 66:1 68:6 

69:7 71:4 75:1 85:1 

86:2,7 89:6,11,12,17 

89:22 103:13 104:1,3 

104:12 108:10,16 

169:3 176:12 177:11 

183:15 184:9 207:20 

224:4,21 226:11 

305:3,6 

conversation 14:15 

157:22 198:5 230:16 

279:15 329:7,10 

332:19 346:22 

conversations 14:19 

40:11 303:16 326:11 

334:5 

conversion 64:18,20 

convert 37:7 58:16 66:7 

66:13 

converted 17:6 58:12 

converting 224:4 

convince 175:9 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
388 

cooling 319:20 

Coopeproagro 45:13 

48:5 

Cooperagro 61:13 

cooperation 137:4 

cooperative 45:13 

51:13 66:19 

coordination 10:2 

COPAC 200:19 201:1 

copies 53:6 

copper 23:20 25:18,21 

26:1,6,12,13,14 27:10 

copy 53:1 

core 325:5 

corn 28:20 30:11 32:22 

55:13 56:1,5,9 103:5 

106:6,16 151:8,16,19 

154:20 155:9,13 

222:7,10 251:2,3,6 

252:20 255:21 256:9 

256:14 261:18 264:19 

266:2 267:1 345:21 

345:21 

corner 311:21 

Cornucopia 103:3 

correct 28:3,4 54:18 

76:8 150:5 211:15 

287:2,3 301:16 

corrective 351:18,19 

correctly 366:5 

corrupt 83:16,16,17 

cost 30:11,15 31:2,6 

33:17 61:1 94:12 

165:4 200:5 225:12 

250:19 251:14,16,18 

261:7,9 262:8 263:22 

317:21,22 

cost- 264:15 

Costa 45:7,17 47:19 

51:3 52:4,17 53:19 

56:12,15,20 57:6 

61:17 62:11,13 63:20 

64:18,22 65:3 66:5 

67:3 69:4 71:18 72:18 

77:8,10,21,22 78:6,8 

78:11 79:13 81:5,15 

83:14 84:21 85:2,13 

86:8 87:1,4,12,16 

97:21,22 98:9,12 

102:1 125:9,22 

167:12 185:15 186:11 

186:15,17 187:9,15 

187:19 224:5 231:15 

costly 87:9 

costs 165:4 203:9 

220:10 266:4 

cotton 227:2,4,5 

Council 5:8,10 8:8 

139:2 294:10 

counties 200:16 

countries 58:22 98:13 

103:6 326:6 

country 57:1,2 65:4 

85:14 100:5 126:2 

187:7 188:2 258:14 

304:11 373:19 

county 11:4 13:4 57:1 

214:18 259:2 

couple 19:21 62:8 

109:17 128:18 155:3 

179:1 181:22 182:13 

189:20 227:21,22 

234:22 240:22 264:14 

265:2 317:4 318:21 

326:15 327:17 328:15 

330:16 332:4 350:2 

374:16 

coupled 17:15 38:12 

162:4 

course 108:4 190:11 

203:13 233:18 238:16 

249:22 251:1 303:1 

322:17 333:12 358:15 

courses 368:11 374:7 

374:13 

cover 25:1 46:22 55:3,6 

66:18,18,19 68:22 

89:13 116:17 136:7 

163:4,6 305:15 

346:11 

coverage 34:11 59:22 

91:15 95:8 310:5 

covered 55:11 64:6 

165:10 199:8 238:16 

covers 55:12 

cow 304:9 

crack 300:15 

crafted 325:11 

crash 75:4 

create 11:3 37:12,19 

40:17 42:16 108:20 

134:19 144:17 146:10 

184:6 291:5 

created 108:11 120:17 

161:6 295:3 

creates 172:12 

creating 318:19 320:19 

337:21 

creation 134:15 296:20 

creativity 119:2 

crises 11:6 12:16 

crisis 13:1,11 66:10 

171:13 

criteria 3:10 84:8 

121:17 127:15 145:4 

145:6,7 210:6 235:14 

274:19 300:7,22 

307:4 312:11,22 

313:8,17,22 319:8 

320:17 324:9,10 

332:13 353:11 

criterion 210:21 

critical 6:12 8:12 10:10 

10:13 91:2 92:16 

103:17 120:11 127:19 

163:21 169:14 261:8 

278:14 288:11 343:5 

360:8 361:6,14 367:2 

367:15,21 370:10 

Croatia 125:22 

crop 3:7 6:7,11 13:16 

18:7,8 23:18 34:18 

37:8 46:21,22 47:7,8 

48:14 49:6 54:5 55:15 

56:5 59:16 63:17 64:2 

64:8 66:18,19 67:7 

68:1 69:12 70:13 

73:20 74:7 75:9 76:9 

84:10 89:13,14,15 

94:19 99:21 111:22 

113:1 131:13 135:19 

164:2 165:3 172:11 

229:4 238:5 251:22 

252:5 255:8 265:21 

266:2 271:12,16 

285:3 286:17,20 

287:7 288:6,10,13,16 

289:1,2,20 290:12,14 

291:20 292:1,4,17,20 

293:22 294:1,16 

295:2 296:11 297:4 

306:22 307:3,5,8,11 

308:1 360:10 378:10 

crop's 66:19 

cropping 55:3,7 

crops 2:7 11:8 17:9 

25:1 53:19 55:21 56:3 

58:11 59:13 63:20 

65:12 66:13 68:12,22 

69:6 85:4 91:20 92:20 

106:7 113:13 162:21 

163:4,5,6 171:3 218:1 

218:10 234:20 236:11 

237:4,6 263:4 264:18 

264:20 265:6,15 

277:1 287:14 306:16 

306:17,18,20 307:14 

307:22 338:17 356:12 

cross- 29:14 

cross-pollinate 265:19 

cross-pollinated

265:18 

crowdsourcing 374:22 

crown 91:16 

crucial 165:17 

cultivar 166:1 

cultivars 267:1 

cultivation 29:13 

culture 307:4 

curious 51:12 73:13 

82:9 89:4 176:14 

261:10 262:21 298:3 

349:4 

current 14:7 25:13 

103:19 132:17 133:16 

163:19 235:3 244:11 

290:1,1 339:17 340:7 

348:4 356:21 

currently 23:19 42:7 

87:14 96:21 133:2 

135:18,19 136:2,8 

248:1 260:8 292:13 

curriculum 122:4 

129:19 

custody 115:9 

custom 34:15 

customer 88:8 155:2 

customers 28:17 32:11 

57:18 152:4 155:3 

208:8 

Customs 322:20 

cut 141:3 370:9 

cuts 119:4 

cutters 133:6 

cycle 10:17 47:5 55:17 

55:20 64:11 65:11 

70:15 71:9 

cycles 47:9 67:7 

cycling 163:5 166:3 

cylinder 49:12 

D

D.C 249:9 

dad 228:22 

dae 301:6 

dairy 45:8 201:2,6 

320:18 337:2 361:21 

dairy-specific 320:19 

Dale 199:8 205:1 

damage 29:8 75:15,17 

137:13 173:5 220:9 

300:13 

damages 91:20 

damaging 29:9 

Dan 1:20 15:1 70:18 

83:3 109:19 139:21 

144:21 147:17 159:1 

194:11 247:9 283:14 

dangerous 60:22 

dashboard 374:6 

data 9:16 13:5 29:21 

30:2 129:8,11,12 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
389 

205:13 314:18,19,20 

315:1,3,7 316:19,21 

317:1,3,15 334:17 

database 129:15 155:2 

206:10 255:18,19 

258:1,2 259:8 293:15 

315:8 317:1,7 351:11 

date 20:11,12,17 144:9 

208:4 257:13 268:5 

268:14 274:9 275:3 

344:9,21 362:9 

dates 21:1 

daughter 45:19 228:19 

daughters 48:2 

Dave 1:17 33:9 51:10 

54:4 66:16 81:22 96:5 

125:5 126:5 247:9 

256:20 257:20 260:9 

267:9 308:13 310:2 

334:14 341:21 

David 126:18 131:16,18 

day 79:12 352:21 

day-neutral 163:9 

day-old 41:10,19 

days 30:12 55:19 

191:17 192:9 318:21 

DCR 30:8 

de 1:15 48:4 149:19 

246:20 273:19 283:1 

284:10 354:1 371:18 

de-listed 150:4,7 

de-listing 157:18 

de-oiled 157:13,17 

158:3 

deadline 142:13 144:8 

deal 13:17 215:2 223:13 

254:17 300:1 378:11 

dealing 70:6 240:15 

dealt 215:6 

dear 303:9 

debate 17:5 22:13 

decades 187:19 225:18 

229:14 

December 247:21 

267:14 268:8 326:8 

decide 14:14 47:22 

297:4 

decided 247:17 287:12 

decides 79:18 

decision 30:21 39:3 

42:4 84:3 

decision-making 38:21 

decisions 29:22 237:11 

decisively 85:21 

deck 5:4 59:6 61:8 

76:22 102:14 

declining 309:9 

decomposers 70:16 

decrease 154:15 

decreased 154:8 

decreases 129:2 

decree 62:12,21 

dedicate 30:9 

dedicated 200:13 

dedication 127:8 

166:15 202:4 

deemed 316:8 

deep 165:14 317:21 

359:15 

deeper 91:16 279:7 

deeply 291:1 309:15 

defensive 108:5 

deferred 228:5 378:12 

deficit 201:15 206:3 

define 12:3 

defined 88:8 146:21 

147:9 156:20 265:17 

267:8 311:13 

defining 214:20 300:22 

307:4 

definite 296:3 306:17 

definitely 76:11,13 

84:15 97:9 234:4 

239:1 289:12 299:16 

300:12 309:5 318:9 

358:9 

definition 105:4 147:2,4 

147:7,11 155:22 

157:4 160:14,16,21 

161:1,3,5,11 213:22 

214:19 

definitions 208:16 

296:9 316:10,11 

definitive 179:10 

degree 290:9 314:4 

332:21 

degrees 61:20 

delegate 10:17 

delegation 231:14 

delete 282:7,8,11 

deliberate 80:20 

deliberations 43:9 

84:14 

delicious 378:19 

delinting 227:2 

deliver 31:20 49:1 

delivered 113:14 

demand 87:21 112:5 

321:21 

density 75:12 

deny 154:10 

Department 1:1 136:22 

139:18 140:18 196:17 

196:22 198:19 205:9 

departments 14:13 

166:8 

depend 7:1 

depending 37:17 68:10 

137:14 266:7 296:15 

316:6 374:9 375:5 

depleted 309:16 

depressed 103:13 

depth 14:17 223:6 

340:13 

Deputy 2:6,14 

derived 151:8,14,18 

description 120:18 

349:15 

deserve 29:21 

design 68:1 122:6 

164:10 

Designated 2:16 

desire 297:18 

desk 313:10 

destroy 70:8 71:12 

destroying 38:17 

305:14 

destruction 229:2 

destructive 288:8 

detail 38:19 111:9 

157:20 235:13 315:20 

316:10,10 333:4 

347:21 

detailed 67:20 271:5 

311:18 317:21 322:21 

details 80:16 109:2 

137:1 266:12 

detect 30:17 327:1 

362:15 

detectable 113:17 

detected 36:11 113:20 

detection 36:14 121:16 

335:19 343:6 

detects 33:22 

detergent 24:11 

determination 274:9 

281:2 

determinations 3:6 

274:12,16 355:21 

determine 24:12 37:13 

143:17 155:12 257:4 

274:19 

determined 104:17 

216:17 275:4 276:7 

278:4 281:8 

determining 129:14 

deterrent 340:9 377:11 

detriment 152:1 

detrimental 128:21 

devastate 38:13 

devastating 168:22 

develop 11:6 15:9 

100:9 178:10 222:14 

354:22 

developed 19:11,16 

143:12 159:10 375:1 

developing 3:10 9:22 

100:2 127:14 142:11 

314:7 353:11 374:19 

development 15:13 

31:8,18 88:14 94:17 

98:20,21 99:22 

101:13 117:9 121:5 

122:4 128:7 130:7 

166:1 188:2 233:14 

247:10 270:11 372:21 

375:5 

deviation 32:17 

DEVON 2:12 

diagnostics 28:15 

dialogue 40:18 137:18 

203:13 287:4 

diametrically 139:22 

140:7 

dictates 272:22 

dietary 116:21 

difference 67:13 140:2 

227:6 291:7 306:18 

331:7 

differences 89:16 

348:18 349:21 

different 32:17 33:22 

34:1 40:5 47:18 60:6 

60:7 62:18 91:9 93:12 

95:6 99:8,14,19 100:3 

100:14 101:2,2,3,4 

123:18 159:14 194:4 

212:7 213:13 219:20 

248:17 259:15 261:20 

262:7,13,17 265:9 

270:13 271:6 275:1 

288:12 325:16 326:2 

333:7 339:3 349:5,5 

351:2 373:12 374:8 

375:7 

differentiate 188:8 

differing 118:1 

difficult 13:12 16:6 

19:15 20:22 143:11 

162:5 172:16 231:20 

248:18 252:16 261:2 

285:18 

difficulties 360:6 

difficulty 291:13 

diffuse 367:1 

diffusing 369:2 

dig 279:7 

digested 154:13 

digestion 154:9,15 

digestive 148:4 

dihydrogen 96:16 

172:1 207:14 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
390 

diligent 362:1 

DiMatteo 116:15,20 

direct 62:10 95:1 205:4 

216:11 240:12 

directed 315:5,12 

direction 106:20 239:19 

242:7 248:15 255:4 

259:17 288:3 289:11 

342:12 

directive 356:3 

directly 40:16 98:7,9 

191:7 213:10,17,20 

221:18 237:6 288:14 

369:4 

director 2:9 77:7 97:18 

198:18 

Directors 170:9 

directs 104:16 

disadvantage 108:20 

disagree 197:18 331:19 

disappearance 57:17 

disappears 324:4 

disappointing 108:5 

disaster 12:20 

discharge 26:9 209:11 

209:12 215:9,16 

disciplinary 63:4 

disclaimer 210:19 

disclose 142:17,21 

317:11 

disclosure 29:5 

discourages 341:2 

discuss 90:3 149:21 

235:10,15 258:4 

285:1 292:9 308:5 

discussed 84:5 235:12 

241:6 286:10 294:6 

343:22 356:14 357:15 

376:18 

discussing 41:9 125:9 

241:9 275:8 280:15 

296:21 

discussion 52:22 96:8 

132:10,14 185:3 

189:6 190:1 214:15 

241:3 245:5,5 259:11 

271:1 272:10 273:7 

275:13 276:10 277:5 

281:14 282:3 283:10 

283:11 285:2,9,14,22 

286:1,19 287:16 

288:22 291:17 308:11 

311:16,19 312:2 

328:4 352:4 353:2 

357:3 358:20 359:11 

364:18 365:8,14 

discussions 124:22 

189:18 312:1 314:20 

disease 23:9 47:3 63:17 

75:15 91:4 101:17 

166:2 175:8,11 237:2 

240:9 

diseases 171:14 

dishwashing 24:11 

disinfectant 207:22 

216:18 

disinfectants 41:12 

42:2 

disinfection 24:9 

disparity 124:14 

disposal 210:2 216:20 

286:16 

disposing 70:22 

disproportionately

270:5 

disrupt 217:9 

disruption 182:9 

disseminated 320:9 

distill 226:18 

distinction 263:13 

distributed 55:16 

245:12 350:16 

distribution 309:10 

dive 312:21 317:21 

diverse 38:4 165:1 

diversification 188:1 

diversity 111:22 164:11 

divided 300:8 

diving 319:6 

division 2:10 47:7 

135:21 199:1 204:17 

205:17 335:13 

DNA 30:7 35:15 

docket 97:1 109:21 

148:18 189:5 243:7 

243:18 247:12 267:15 

267:18,21 268:2,7,15 

268:19,20 269:5 

319:2 328:18 

Doctors 132:22 

document 37:10 42:15 

123:11 132:14 143:22 

239:16 241:2 243:5 

245:10 247:7,11,22 

248:10 259:13 275:6 

276:14 277:7,8,12,17 

281:2,16,22 282:10 

285:2,9,14 286:1,19 

287:16 291:17 296:6 

308:11 324:6 328:9,9 

329:8 330:21 332:21 

334:8 339:14 342:10 

343:4 370:10 376:6 

376:12 

documentation 258:19 

documents 132:10 

247:9 275:11 

doing 40:17 52:15 

63:17 85:10 94:6 

107:9 111:14 137:12 

140:20 166:21 181:17 

225:7,18 241:12 

255:17 256:15 275:5 

278:1 289:8 293:20 

294:22 295:1,5,5 

308:2 327:7 331:1 

337:19 339:10 340:3 

341:3 344:10,12,22 

352:11,15,18 356:5 

358:14,18,20 361:9 

367:5 

Dolana 207:5,8,11,13 

dollars 264:15 265:2 

266:8 

domain 374:21 

domestic 112:7 311:17 

315:5 323:19 

domestically 9:18 

58:21 

dominate 104:10 105:8 

domino 290:13 291:5 

door 378:19 

dormant 226:19,22 

double 44:14,22 292:22 

DPR 205:8 

Dr 2:9,14 15:2 20:18 

40:9,19 42:18 70:19 

83:4 109:20 114:22 

115:22 139:22 140:7 

142:1 147:18 148:17 

149:5,7 159:2 160:4 

179:9,18,21 194:12 

196:1,4,5,20 198:21 

199:8 202:1 232:4 

239:10 241:15,18 

246:15,19 273:14,18 

279:12 280:4 282:18 

282:22 284:5,9 285:7 

305:1,19 324:12 

329:6 334:15 335:4 

336:15,21 339:18 

341:5 346:8 347:19 

349:13 350:2 352:6 

353:18,22 371:13,17 

372:11 375:19 

draft 37:9,12,16 40:3,6 

192:2,3 260:11 

drafting 316:3 

drafts 198:2 

drastic 87:11 

draw 174:17 175:2 

drawer 329:19 

drawing 140:14 240:19 

drawn 25:13 

dredging 299:16 

dressings 172:7 

dried 135:22 184:19 

drift 11:13 

drinking 24:7,9 26:22 

115:21 

Driscoll's 90:12,21 

91:21 92:5,14 93:18 

96:18 

driven 191:19 

drone 46:3,5 

drop 18:12 322:1 

drosophila 163:8 

drought 275:15 

Drug 206:7 

Drugs 205:1 

dual 209:4 

due 25:22 98:3,7 129:4 

133:22 134:9 187:14 

269:11 275:14 

dumb 367:11 

duplicative 129:12 

dust 93:22,22 106:13 

dusting 91:1,7,14,14 

92:1 94:4,10,18 95:6 

95:17 

dynamics 351:1 

E

eager 127:16 

eagerly 117:13 

earlier 19:5 112:12 

125:14 197:11 231:14 

282:8 291:8 330:9 

early 77:17 94:16 

138:19 313:1 

earned 105:10 

earning 83:8 

Earth 167:12 

ease 78:1 

easier 71:16 78:1 110:3 

217:19 220:1 

easily 179:5,5 253:22 

265:18 

east 1:9 345:11 

eastern 111:17 346:3 

easy 22:7 84:11 99:20 

184:17 255:4 

eat 154:12 

eaten 310:9 

eating 218:14 303:10 

echo 119:8 128:6 226:6 

229:6 310:2 361:16 

Eco 48:10 

Ecolab 233:13 

ecological 37:1 238:17 

economic 16:19 107:15 

168:17 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
391 

economics 326:1 

ecosystem 37:10,14 

138:5 140:22 164:13 

173:2 288:15 289:10 

291:9 308:21 309:3 

309:17 

ecosystem- 134:21 

ecosystems 37:7 38:10 

38:14 58:12 173:1,4 

308:19 309:2 

ed 374:18 

Eden 127:4 

edited 36:11 

editing 35:21 

edits 280:13 

educate 363:11 

educating 343:12 

education 121:8,9 

122:11 225:7 362:17 

364:4 372:22 

educational 120:1 

356:17 

effect 98:20 101:17 

290:13 291:5 

effective 24:1 27:19 

36:9 92:10 122:7 

125:18 242:19 255:16 

effectively 126:3 

172:20 

effectiveness 238:7 

239:4 

effects 17:19 38:12 

140:21 168:15 

efficacies 91:9 

efficacy 26:8 92:2 

130:18 209:5 

efficiencies 42:16 

187:15 

efficiency 48:20 61:2 

efficient 57:13 122:22 

effort 40:8 87:8,11 

102:2 229:3 375:8,21 

efforts 77:15 100:8 

103:19 105:12,14 

132:7 134:11 163:2 

166:14 170:12 211:4 

255:15 315:2 323:1 

eggs 103:12 

eight 45:19 167:15 

273:4 

either 22:7 37:16 59:13 

209:10 212:21 232:22 

254:2 258:12 300:8 

301:15 313:5 315:10 

375:1 376:19 

ELA 1:16 8:16 27:15 

28:5 55:2,6,21 56:3 

89:4,12 174:15 

175:12 214:4 215:14 

217:2,11 243:12 

244:13 246:17 261:14 

261:18 273:16 282:20 

284:7 298:10 302:7 

348:9 349:11,16 

353:20 371:15 

elaborate 159:11 160:5 

elections 378:13 

electricity 12:22 

element 120:19 327:19 

338:3 

elemental 5:19 6:12,19 

7:2,6,14,17 90:18,22 

91:18 

elements 122:20 

elevate 327:2 

elevated 29:5 

eliminate 37:6 41:15 

150:15 

elimination 43:4 82:18 

else's 265:7 

emailed 105:2 

embryo 276:21 280:16 

280:19 281:17 283:19 

emerge 375:10 

emergency 11:4,6 

12:10,22 13:5 

emerging 10:3 161:8 

347:7 

Emily 1:17 12:8 18:16 

19:7 27:4,16 39:9 

40:1,10 58:7 64:15 

83:22 84:16 85:16 

86:19 90:6,8,11 93:4 

101:14 119:6 135:3 

135:16 144:20,21 

147:15 153:9 166:18 

177:17 179:4 180:2 

183:10 230:22 234:11 

234:13 244:21 245:8 

245:13,19 246:8 

264:10 265:8 267:4 

272:13 281:18 284:22 

298:7,10 304:22 

308:3,15 328:6 

334:14 339:11 

Emily's 230:20 

emotional 304:6 

emphasis 22:4 321:12 

emphatically 107:7 

employ 186:22 

employed 134:18 

225:16 319:15 

employee 319:18 

employees 45:19 46:14 

55:16 356:4 

employing 30:16 

employs 319:11 

empty 75:1 

enables 257:4 

enabling 260:22 

encompass 129:10 

159:9 

encompasses 160:13 

encourage 92:20 

117:21 123:12 130:5 

167:5 271:2 281:7 

encouraged 17:11 

encouraging 52:9 

123:20 342:13 

end- 29:22 

ended 295:1 

endogenous 74:4 

ends 301:18 

enemies 164:15,21 

165:6 

energy 42:16 220:10 

energy-expensive

104:14 

enforcement 107:4 

199:2 200:14 201:3,5 

201:12 202:22 203:5 

203:14 204:1,7,14,20 

326:14 341:1 345:6 

engage 40:8,10,13 

323:3,17 324:1 

engaged 306:6 324:5 

339:15 

engagement 306:3 

engages 322:9 

engaging 193:8 313:8 

319:17 

engine 107:15 

engineered 160:19 

161:10 211:18 

engineering 161:7 

271:15 274:21 

engineers 77:11 

enhance 50:14 208:1 

enhances 7:8 

enhancing 308:21 

Enjoy 86:17 

enjoyed 323:9 

enlarging 152:1 

enormous 104:14 

ensure 31:19 39:3 

117:18 118:9 126:1,6 

132:7 315:17 321:14 

ensures 7:7 

ensuring 92:12 120:12 

127:17 314:22 

enter 249:13 

enterprises 186:21 

entertain 244:20 

entire 6:7 103:16 141:5 

150:15 192:3 

entirely 184:4 193:16 

276:13 309:19 339:3 

entirety 277:10 

entities 25:12 136:20 

entitled 331:15 

entries 129:12 

entry 206:1,2 208:14 

EnviroLogix 28:14,17 

30:19 250:16 

environment 7:10 

39:20 52:8 57:18 

138:13 139:14 168:15 

288:8 289:7 293:1 

300:3,4,12 309:2 

325:20 

environmental 45:14 

57:9 93:8 100:7 113:7 

140:9 210:4,10 216:9 

216:22 285:16 286:9 

286:11 288:7 290:6 

296:16 299:15 

environmentally 23:9 

environments 39:15 

289:21 301:20 302:4 

EPA 156:12 209:13 

212:11 213:8,11 

216:17 260:5 

EPA's 210:5 

epicenter 5:22 

equally 120:13 316:12 

equipment 51:13,15 

94:1,3,21 

equivalency 62:14 

105:6 323:17 326:5 

equivalent 56:19 251:5 

equivalents 348:15 

Eric 1:19 116:2 

error 19:5 

especially 13:13 105:13 

120:12 121:8 139:1 

149:16 166:9 207:19 

208:6 223:15 236:8 

248:20 256:3,5 

328:15 357:12 362:6 

366:17 367:3 

Esquivel 40:22 

essential 6:22 11:22 

28:2 38:10 92:12 

319:4 

essentiality 152:22 

essentially 161:11 

217:8 

establish 16:6 129:20 

313:7 

established 45:10 

77:16 88:7 117:4 

199:14 220:15 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
392 

establishing 164:16 

165:5 

estimated 134:5,7 

210:1,4 

estimates 133:21 

estimation 196:9 

Ethiopian 171:9 

ethylene 46:10 47:22 

48:19 49:3,5,11,19 

50:7,13 51:3 52:10,15 

52:18 54:9,11 57:16 

58:4 59:12 60:16,17 

61:3 73:17 74:4 76:10 

78:19 79:15,17,18 

80:11 81:9,13 82:13 

82:18 88:10,15,22 

98:2,10,14 100:1,15 

101:9 168:8,11,18,21 

169:13 185:20 186:6 

186:8 188:4,11 

223:15 226:8,12 

ethylene's 223:17 

EU 104:21 302:12 

Europe 59:1 62:10 76:4 

346:3 

European 58:22 62:14 

62:16,20 69:9 104:19 

309:13 

Europeans 302:10 

evaluate 35:15 351:18 

evaluated 145:6 210:11 

316:4 332:2 

evaluating 239:3 319:5 

evaluation 216:21 

235:19 238:6 320:5,7 

358:4 

evaluations 138:13 

216:9 

event 36:8 

events 12:17 

eventually 35:22 80:13 

88:18 374:2 

everybody 4:4 197:17 

227:16 244:7 298:3 

Everybody's 347:4 

everyone's 180:3 

331:15 

evidence 130:6 148:8 

154:11 337:13,17 

376:21 

evolution 103:21 

evolve 171:20 

evolving 100:4 

exact 69:17 254:3 270:3 

292:20 293:1 

exactly 86:6 95:11 

96:13 233:16 267:18 

365:21 

examine 296:15 

example 26:12 27:22 

32:20 33:18 75:7 

85:22 132:13 134:4 

136:21 143:3 154:2 

160:22 164:14 169:4 

175:16 214:8 266:19 

327:16 331:17 338:15 

341:9 373:7 374:16 

examples 164:19,20 

165:12 318:21 358:3 

excellent 128:10 

247:13 320:13 355:17 

359:16 375:16 

exception 41:19 

exchange 320:14 

excited 13:3 

exciting 21:22 

exclude 15:8 264:19 

excluded 3:6 218:1 

234:8 274:8,15,21 

275:4,16 276:5 

277:15 278:10,11,17 

278:19 280:9 281:2 

281:10,18 283:17,18 

283:19,20 328:10,21 

excludes 217:21 

exclusion 186:6 

exclusive 194:3 

exclusively 19:10 167:1 

194:10 

excuse 314:1 

executive 77:6 241:1 

306:1 

exercise 130:2 

exist 153:1 

existing 117:4 123:4 

124:4 147:2 193:18 

exists 123:1 248:1 

374:20 

expand 16:12 18:7 

129:10 136:7 343:12 

expanded 261:21 

expanding 236:18 

241:7 334:5 

expansion 62:7 64:17 

85:3 

expect 159:21 363:9,12 

370:14 

expectation 319:20 

expectations 107:18 

323:6,13 

expected 209:19 

245:22 363:4 

expects 107:14 

expenses 171:17 

264:17 

expensive 30:10 66:11 

94:7 115:5 171:18 

357:13 

experience 61:1 69:4 

178:5 331:2 

experiencing 366:1 

experimental 254:12 

experimentation

327:14 

expert 122:3 195:1 

216:15 

expertise 170:11 

322:14 

experts 118:6 289:14 

expiration 20:11,12,17 

21:1,6 144:9 

explain 27:6 54:7 89:21 

93:22 94:20 143:16 

145:9 363:22 

explained 267:9 277:20 

explaining 108:2 

245:15 

explanation 197:12 

explicitly 264:19 

exploitation 133:16 

explore 14:17 40:12 

explored 14:6 38:1 

116:9 

exploring 205:11 

export 69:5 188:1 

213:10 

exported 48:5 98:9 

exporter 125:11 186:12 

exporters 62:10 81:4 

exporting 87:4 186:20 

exports 57:6 87:6,16 

88:19 

exposed 71:10 226:16 

exposer 66:9 

exposing 169:5 

exposure 96:9,11,12 

218:3,10 

exposures 84:21,22 

210:10 218:11,14 

express 47:21 82:16 

356:22 

expressed 35:20 

106:10 293:17 317:20 

318:12 

expression 35:16 

extend 165:18 186:7 

198:20 330:10 

extended 10:16 

extension 163:7 180:8 

180:14 182:3,8,15 

240:5 

extensive 358:2 

extensively 32:6 140:17 

extent 328:10 339:14 

extra 366:10 

extracting 300:3 

extraction 31:1 138:6 

extracts 93:6 

extreme 117:18 

extremely 174:20 

231:19 266:14 

eye 326:1 351:15 

eye-opening 326:4 

eyelashes 106:13 

eyes 342:6,15 

F

face 107:13 304:10 

facets 205:16 

facilitate 156:20 242:11 

244:19 

facilitated 232:5 

facilitation 121:19 

facilitator 156:21 157:2 

facilities 209:9 212:19 

212:20,22 213:9,22 

214:6 313:13 

facility 33:6 185:1 

209:21 233:14 

facility's 209:8 

facing 169:15 

fact 71:3 126:6 132:12 

136:10 142:22 216:17 

227:9 239:1 247:12 

250:2 285:18 307:9 

317:7 330:22 346:17 

350:8 368:21 376:20 

factor 129:8,9,10 

188:12 263:19 317:4 

318:13 321:5 322:6 

factories 104:8 

factors 25:22 122:12 

128:8,11 306:9 313:3 

313:8 314:12 316:12 

316:16,22 318:8 

320:20 332:7 333:11 

333:12,13,18 334:7 

334:10 340:14 349:22 

factory 103:10 105:7 

facts 134:3 141:4 

Fahrenheit 61:20 

fail 246:7 

failed 107:21 

failure 321:5 

fair 106:19 107:9 

196:18 256:3 330:2 

336:12 370:21 

fairly 109:12 247:10 

250:2 253:21 266:22 

344:7 357:13 

fairness 11:1,15 13:15 

107:17 330:4 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
393 

FairWild 307:7 

FairWild's 307:10 

fake 103:9 

fall 1:5 149:3 179:6 

235:8 242:16 243:1,1 

244:1 274:18 322:5 

Fallas 77:1 79:9 82:4,7 

82:15,22 83:7 84:16 

85:5 86:13,16 

fallow 46:22 55:7 

familiar 125:7 234:19 

families 45:14,15 47:17 

48:7 56:18 57:19 62:5 

80:7 169:6,11 304:14 

family 45:10,11 46:14 

52:3 167:22 303:12 

365:8 

family-owned 111:14 

fan 331:13 

far 51:14 61:15 62:7 

140:11 144:4 161:13 

204:13 253:2,10,16 

254:1 258:12 264:17 

297:16 340:20 358:18 

373:14 375:21 

Farina 219:17 

farm 10:16 14:1 36:21 

40:4 48:3 49:3 52:2,3 

54:20 55:8 56:7 67:11 

67:13,15 72:10 

103:10 105:8 168:2 

169:14 190:5 224:17 

224:20 225:2,10,12 

225:20 226:16 227:4 

228:20 249:13 255:16 

265:7 308:17 341:16 

361:2 

farmed 258:6,12 

farmer 25:15 45:8,9 

48:6 59:10 69:2 88:4 

101:6 125:10,16 

229:14 250:12 253:6 

253:7,21 255:14 

259:5 260:12,21,22 

261:10 263:18 342:5 

farmers 9:10 11:3,17,20 

13:7 17:1,6 19:3 

21:16,18 22:5 25:8,10 

29:21 31:13,19 37:13 

38:3 47:18 49:8,17 

57:4 71:4 84:15 87:8 

88:10 98:7 99:15,17 

100:1,9 104:5,6 

113:19 125:8,16,21 

165:17 166:9 183:16 

223:15,16 226:16 

229:17 231:18 240:2 

249:1,2,3,16,20 250:3 

250:8,17,20 251:9,11 

252:8 254:16,21 

255:3,7 256:2 261:11 

269:15 270:2,7,15,22 

296:14 342:6,13 

344:14 373:4,9 

farmers' 203:17 204:4 

204:15 205:8,11 

farming 37:1,2 62:13 

63:6 66:11 103:22 

112:8 164:19,20 

167:20 169:20 199:18 

223:21 257:8 

farms 11:5,7 13:12 17:5 

22:15 55:11,14 62:16 

66:12 80:5 98:12 

164:12 236:21 290:20 

308:17 

farmscape 238:17 

farmscaping 163:10 

164:9 165:7 

fascinating 63:8 70:1 

fashion 329:1 

fast 67:7 70:8 

fast-moving 281:11 

fate 215:1 

fatty 9:11 16:16 19:1 

226:13 238:13 

fault 11:8 13:16 250:1 

fauna 138:4 139:7 

favor 17:10 309:1 

favorable 302:22 

favorite 180:3 

FCN 217:1 218:12 

FDA 142:14,16 156:7 

206:18 210:10 216:10 

218:4 219:1 221:16 

222:7 236:1 

FDA's 216:21 

fear 212:11,14 

feasible 53:6 297:5 

feature 378:19 

fed 154:6 

federal 2:16 5:13 

201:20 203:5 268:12 

306:4 

FedEx 103:7 

feed 24:19 103:9,11 

169:16 172:11,11 

201:17,19 204:22 

205:15 206:16 236:2 

292:16 304:9 338:12 

feedback 3:12 8:22 

97:6 193:21 197:8 

198:8 235:21 236:13 

243:21 266:13 268:22 

270:3 286:22 312:20 

313:20 319:6 322:5 

324:11 328:3 332:13 

335:2 373:13 376:4 

377:12 

feeds 136:1 

feel 13:20 28:15 44:2 

50:11,12 127:11 

136:8 144:3 153:17 

210:15,22 218:4 

242:2 259:9 262:21 

281:9 317:2 336:1 

345:14 356:4,22 

358:21 360:1,4 

feeling 275:22 330:9 

340:6 344:16 345:21 

345:22 

fees 203:10 

feet 262:2,6 

Fegley 132:22 

fellow 287:19 

felt 109:9 161:1,2,5 

218:7,22 221:5 

247:14 248:2 251:5 

256:6 278:22 289:18 

289:22 302:4 346:12 

356:3,20 

fermentation 148:1,3 

148:15 149:2 160:17 

160:19 

fermentations 222:6 

fermented 148:9,10,12 

149:7 150:20 

fertilities 239:3 

fertility 92:17 111:21 

112:4 

fertilizer 111:13,16 

112:2 113:8 204:22 

291:18 304:9 307:18 

fertilizers 46:8 92:22 

112:21 291:15 

fewer 17:21 

fiber 118:20 240:4 

fidelity 325:19 

field 46:18 47:2 62:6 

96:9 100:14,15 

106:16 126:10 138:1 

213:15 215:17 251:3 

252:20 255:21 266:6 

267:1,8 289:14 

330:19 342:3 369:7 

fielded 343:7 

fields 58:10 64:1 101:6 

266:7,18 290:20 

308:16 

Fifteen 247:2 274:3 

fight 218:8 

figure 164:17 165:18 

279:3 288:2 297:10 

297:19 298:2 364:20 

figuring 177:22 

file 343:13,16 

files 120:15 361:12 

fill 74:17 112:2 125:1 

179:6 222:19 

filling 359:1 372:20 

film 118:16 236:13 

final 10:8 53:8 99:21 

189:12 191:2,7 

195:15,17 198:1 

210:4 222:8 239:16 

255:8 352:6 356:14 

finalize 192:6 244:17 

finalized 198:10 244:12 

351:17 

finally 11:19 38:21 

130:13 166:4 171:5 

172:22 202:3 210:13 

223:10 318:11 323:15 

financial 45:15 66:7 

108:9 334:19 336:19 

337:5 

find 14:7 17:17 38:6 

74:14 102:20 108:12 

115:6,14 122:22 

156:1,8 172:16 219:1 

230:9 255:7 292:8 

297:15 307:6 314:16 

344:2,6 347:21 348:2 

369:6 377:7 

finding 53:3 115:11 

181:16 193:12 

findings 134:19 316:4,5 

323:5 

finds 43:11 230:7 

fine 80:16 228:15 

fingers 349:4 

finish 60:21 89:14 

191:15 

finished 14:19 52:20 

53:9 222:3 

finite 324:2,3 

fire 239:21 240:9 

firm 11:15 157:4 268:14 

first 4:8,15,20 34:12 

37:5 52:19 66:14 

79:22 102:13 141:21 

170:17 173:9 176:16 

193:17 201:5 202:10 

204:11,13 221:12 

225:21 226:5 227:17 

228:3,7 232:21 233:9 

234:5 245:14 248:21 

282:1,6 285:5 286:4 

290:16 295:4 299:1 

312:9 319:9 363:18 

firstly 135:15 

fiscal 200:2 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
394 

fiscalizes 62:15 

fish 90:19 92:15,18,22 

112:13,22 113:9 

114:5 138:10 139:7 

fisheries 137:1 139:18 

140:18 306:8 309:9 

fishing 113:8,9 

fit 104:1 147:7 250:7 

308:1 

fits 119:3 307:22 

fitting 214:19 

five 19:18 20:15 30:12 

45:2 56:17 88:2 98:3 

133:12 186:9 191:9 

200:14 202:15 247:8 

263:4,5,8 266:18 

329:20 346:16 

five-ish 155:20 

fixation 69:21 

flag 327:2 

flags 348:19 349:3 

flavor 142:17 143:2,5 

146:10 162:1 195:1 

223:4 342:18 346:5 

flavorful 159:22 160:1 

flavors 142:6,8,9,11,13 

142:15,20 143:2,8,12 

143:14,17,19 144:1 

149:16 159:4,6,9,12 

159:13,16,19 160:2,7 

160:15 161:10,14 

189:2,6,9 194:13,17 

195:5 222:13,14,16 

222:18 223:7 

flexibility 323:9,9,12 

369:14 

flights 378:16 

flip 321:22 

floors 25:1 

floral 88:12 

Florida 225:4 230:5 

flower 46:8,11 48:1,14 

48:22 49:3,7 57:13 

60:12 73:20 163:11 

168:12,18 169:13 

flowering 50:16 57:16 

58:6 98:20 99:6 

100:14 101:11 188:5 

flowers 53:17 100:17 

fly 236:2 

fly-in 249:10 

focus 24:13,16 82:8 

90:17 238:9 311:14 

315:16 323:14 352:12 

focused 138:20 199:10 

232:7 287:13 312:5 

346:10,13 347:5,6,6 

368:21 

focuses 120:13,19 

focusing 5:17 9:20 96:7 

315:15 373:2 

FOG 225:16 

FOIAed 258:20 

fold 210:1 

folded 324:21 

folks 107:8 195:18 

227:10 231:20 268:16 

269:13 277:10 318:20 

319:1 344:22 351:14 

368:16 370:16 375:1 

378:15,15,16,18 

follow 27:15 95:13,16 

108:13 115:14 155:5 

175:12 182:19 183:11 

217:18 231:3 262:11 

267:12 308:17 341:13 

349:22 365:10 

follow-up 135:15 

137:15 

followed 4:16 9:3 22:19 

28:11 36:18,19 40:21 

44:8 47:13 51:19 

66:21 79:7 86:19 90:7 

102:21 103:4 105:19 

111:2 116:13 119:17 

126:18 131:16 141:12 

162:10 167:7 170:5 

185:10 188:20 198:14 

207:5 

following 145:6 155:18 

164:2 214:4 283:16 

302:7 323:4 378:6,8 

378:10 

follows 272:21 

food 28:18 29:12 37:3 

38:18 41:13 42:14 

43:2,4,19,20 80:6 

101:5 118:20 127:2,5 

143:8 155:7 156:1,3,4 

159:3,19 162:19 

163:2 168:16 169:14 

172:12 198:19 199:18 

205:4 206:7,19 208:1 

208:3,7 215:3 216:11 

218:16 219:11 221:7 

221:8,17 223:1 225:8 

233:19 239:18 240:4 

304:13,16,17 307:17 

307:18 336:18 

foods 143:15 151:7 

159:22 170:20 186:10 

199:13 304:7 

foodshed 308:16 

for-profit 349:9 

force 10:5 169:4 297:1 

forced 104:5 

forces 192:1 

foreign 75:16 185:15 

323:18 

forensic 121:16 130:6 

forests 64:20 

forget 340:21 

forgotten 356:7 

form 22:7,8 170:21 

187:1 192:1 217:8 

358:4 

formal 319:17 343:7 

format 289:5 

formed 56:16 

former 96:9 319:12,17 

forms 121:18 122:15 

164:11 

formulas 142:19 

formulated 208:18 

formulations 91:9 

forth 110:1 145:4 

fortified 233:8 

fortunate 359:20 

forward 16:8 37:18 38:7 

80:18 108:3 122:5 

127:16 136:14 194:6 

197:1 218:3 233:12 

234:3,4 241:17 242:8 

242:22 244:4 248:6 

248:11,17 274:13 

276:14,21 280:22 

288:2 289:11 290:10 

301:16 304:19 324:16 

332:5,20 334:1 

359:17 370:10 375:17 

377:5,14 378:13 

found 91:8 93:17 

117:17 154:4,7 

156:12 172:5 200:12 

208:22 218:15 225:20 

254:21 290:19 316:6 

368:13 

foundation 122:2 

foundational 29:16 

124:8 

founded 48:6 

founding 9:8 

four 34:5 46:10 47:9 

52:17 63:8 68:5 76:3 

76:3 79:20 154:6 

202:12,16,16 223:5 

234:5 329:19 335:8 

362:10 363:9 

Fourteen 45:22 

fourth 80:10 234:8 

fracking 11:12 

fragile 38:13 289:21 

frame 303:4 368:8 

frames 165:11 

France 256:15 

frankly 129:1 156:2 

194:7 

fraud 9:13 67:2 78:10 

79:15 81:14,19 82:20 

83:5,7,18 121:15 

123:1 125:19 130:11 

313:4 318:13 340:9 

343:6,21 346:20 

361:7 362:15 367:18 

free 28:15 151:9 203:8 

frees 203:5 

freeze 62:2 

frequency 128:2 129:11 

frequent 128:5 322:19 

fresh 64:10 

Friday 247:22 

friend 81:16 85:22 

front 145:3 252:9 253:6 

266:21 268:16 

fructification 64:1 

fruit 5:17,22 6:13 8:4,13 

48:11,17,20,22 49:1 

49:22 50:13,17,17 

54:8,17,20 60:14 

67:20 74:21 76:3,5 

88:1,6,15 98:16 99:4 

99:11 101:12 175:19 

227:1 

fruiting 84:10 

fruits 8:18 96:17 99:1,3 

99:4,7,7,10,16,20 

101:1 175:15 217:21 

frustrating 360:16 

frustration 106:11 

frutescens 184:16 

FSIS 156:6 

FSMA 185:1 205:5 

fulfill 48:11 134:16 

full 10:7 33:17 62:5 

321:14 333:3 346:11 

full-time 348:15 

fully 49:15 75:9 

Fumigants 172:9 

fumigated 176:20 

fumigation 172:18 

fun 360:2 

functional 151:21 209:1 

functioning 222:2 

fund 13:15,21 14:20 

203:11 357:5 

fundamental 11:14 

funding 163:20 239:20 

240:7,12 242:6 

341:17 357:10 366:7 

funds 14:9 

fungal 91:4 

fungi 171:19 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
395 

fungicide 91:3 

further 24:4 25:2 97:6 

106:18 146:4,18 

165:9 173:5 241:9 

247:16 272:10 273:7 

276:10 282:3 283:10 

283:11 292:9,10 

314:6 332:3 334:6 

350:22 352:4 367:6 

fusarium 63:16 

future 42:20 120:18 

164:4 244:3 248:13 

264:21 265:18 321:16 

376:13 377:6 

G

G 221:17 

gaining 255:20 315:22 

gamut 360:1 

gap 49:15 74:20 

gaps 42:13 125:1 

163:19 359:2 

Gardens 224:17 225:1 

gas 49:5 50:7,13 60:18 

98:10 185:21 186:6,8 

188:11 

gather 77:15 

gathered 78:17 

gatherers 303:21 

GE 160:9 

gear 95:16 

gee 159:6 

gel 171:10 

gellan 147:22 148:5 

150:7,11,12 151:15 

152:15 154:2,7 

gene 35:16,21 36:10 

276:17 

gene-edited 36:4 

general 31:15 61:13 

78:14 106:20 156:19 

157:2 242:13 317:18 

322:18 334:10 352:1 

generalized 349:14 

generally 324:12 

347:22 

generated 7:16 88:11 

143:1 

generic 216:3 

genes 171:22 

genetic 3:5 28:20 

106:16 108:2,9 161:6 

223:8 234:7 238:5 

247:5 249:6 250:5 

255:7,21 271:11,14 

272:14 274:21,22 

276:18 

genetically 35:19 

160:19 161:9 

genetically-modified

251:5 252:22 254:12 

255:15 

genetics 10:4 

gentler 104:3 

gentlest 118:19 

genuine 187:19 

geographic 107:5 

108:20 

geographical 134:10 

germplasm 257:4 

getting 19:20 35:9 52:7 

70:2,13 75:15 83:19 

93:15 101:9 155:20 

194:4 198:8 225:13 

243:6 252:8 266:12 

266:13 292:21 303:3 

323:6 339:4 345:1 

350:12 370:3 

giggle 367:9 

give 20:14 23:21 33:16 

44:14,21 57:22 60:7 

68:13 77:2 83:4 84:14 

102:3 110:2 118:10 

160:2,11 192:10 

228:1 230:17 233:10 

243:21 247:15,21,22 

248:2,3,12 255:4 

267:20 268:22 287:15 

290:17,21 302:21 

332:12 335:1 351:17 

352:1,22 362:10 

372:14 375:2 378:1 

given 25:20 45:4 51:20 

53:8 128:18 133:15 

133:18 144:1 146:3 

148:18 165:15 264:13 

269:11 296:3 298:16 

377:10 

gives 82:8 206:21 

giving 47:20 71:19 

97:17 185:18 258:14 

259:10 355:7 

glad 103:18 135:4,6 

global 28:14 30:20 

49:15 88:19 120:2,16 

GLOBALG.A.P 72:8 

glove 20:2 

gluten 151:9 

GM 256:10 259:8 

GMO 11:12 28:15,18,22 

29:3,6,11,14,19,21 

30:2,3,5,7,11,14,18 

32:18 33:7 55:22 56:5 

106:3,8,9,13 107:5 

108:22 159:9,10 

223:2 238:5 

GMO-free 29:17,17,18 

107:15 

goal 68:19 118:22 

124:19 257:22 372:12 

372:16 

goals 233:17 

gold 165:11 

Gomez 44:9 47:13,15 

47:16 50:8,10,15,21 

51:5,14,17 

Gonzalez 59:6,8,9 

gotten 73:14 193:21 

225:11 304:15 

government 25:12 

62:15 66:15 77:17,21 

97:22 136:17,20 

137:5,16,22 268:9,13 

290:1 336:8 

governmental 348:17 

governments 133:14 

GPO 63:7 

gracias 59:3 61:4,5 

graduate 162:17 

grain 14:9 26:15 30:18 

126:22 127:2 130:21 

199:12 201:4,15,16 

204:2 206:3 264:18 

266:2 269:15,20 

270:2 322:16 345:10 

grains 346:4 

grams 75:19 

Grant 163:13 

grants 240:2,7 

grapes 217:22 218:5 

grass 142:18 148:5,6 

221:14,14 

grateful 166:12 327:21 

gratifying 156:13 

greater 9:22 10:2 

218:10 315:19 316:9 

316:10 317:18 318:17 

320:16 334:11 

greatest 238:2 290:9 

greatly 294:3 

green 4:19 55:12 70:9 

99:10 

greenhouse 25:1 26:20 

165:14 

greenhouses 165:11 

Greenwood 1:16 

114:22 115:22 179:9 

179:18,21 198:21 

246:19 273:18 282:22 

284:9 305:1,19 

334:15 336:15 353:22 

371:17 

grew 247:7 258:18 

259:6 

grey 304:5 

grinding 31:1 

grocery 104:10 141:16 

gross 67:13 

ground 25:1 38:6 39:11 

39:13 118:7 125:8 

126:2 297:15 300:16 

300:17 301:10,17 

342:7,15 352:20 

group 36:22 37:19 38:1 

72:3,6,11 84:20 87:7 

117:20 119:10 126:10 

192:2 219:14 221:1 

249:10 270:13 289:15 

296:20 297:1 314:8 

325:14 326:6,8 352:2 

352:19 

groups 126:14 139:1 

208:22 

grow 16:11 38:18 48:18 

55:20 63:21 65:6,10 

68:16 78:20 87:8 88:5 

88:6 104:6 126:14 

179:4 184:17,17 

220:2 240:3 251:22 

256:9 261:14 264:18 

265:9,12 

grower 66:3 67:18 

85:16 86:7 89:6 

163:18 256:13 259:6 

267:1 343:8 

growers 5:10,17 6:16 

7:1,13,19 8:6,20 9:1 

26:20 49:18 63:11 

70:3 72:10,12 77:14 

81:7 83:17 91:2,5,6,8 

91:12,20 92:18 93:11 

93:17 94:12,19 95:12 

102:1 106:6 108:17 

108:20 111:19 112:7 

131:1,9 164:10 169:1 

178:14 183:5,15 

184:10 187:2,21,21 

225:5 227:1 256:11 

262:1 266:2 270:21 

growing 7:5 11:11 

106:22 112:4 113:1 

113:15 165:16,18,21 

169:16 187:11 224:22 

249:2,4 252:5 256:14 

370:11 

grown 3:5 24:17 47:1 

55:21 56:4 105:1 

176:19 247:6 259:1 

272:14 

grows 72:10 

growth 16:18 26:11 

64:2 68:6 70:1 118:2 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
396 

133:10 134:2 321:16 

guar 150:18 

guarantee 69:18 77:18 

122:13 234:2 

Guatuso 57:2 

Guelph's 236:10 

guess 51:9 89:15 

109:11 145:9 148:19 

174:21 175:12 177:9 

183:19 206:13 212:11 

213:12 214:4 257:17 

270:10 297:14 301:17 

302:2 328:8 334:18 

344:22 349:16 

guidance 10:11 37:10 

40:3,7 283:18 289:4 

294:4 296:4 371:7 

guide 120:17 163:14 

166:14 170:12 318:14 

guidelines 370:14 

gum 144:11,12,15 

145:10 146:6 147:22 

148:5,18 149:1,8,9 

150:7,11,12,17,18,18 

151:15,15 152:15 

154:2,7 157:1 171:8 

221:13,16,19,21 

222:6 

gums 142:6,7 148:9,10 

148:12,14 149:6,9,9 

150:17,21 151:13,13 

152:1 153:1,4,8 222:5 

222:11 

gut 154:9 

Gwendolyn 195:1 

H

habitat 38:10 164:16 

165:5 229:2 

habitats 307:17,18 

habits 218:14 

HACCP 363:4,8 

haddock 309:10 

half 11:20 76:5 343:20 

hallway 189:19 

Hampshire 309:6 

hamstrung 348:15 

hand 18:10 20:2 37:16 

110:19 233:4 274:5 

299:21 311:4 324:4 

330:6 

hand-held 18:8 

handed 53:10 297:13 

handicapped 16:3 

handle 40:14 120:14 

298:19 321:15 

handled 200:6 

handler 365:14 

handlers 5:17 97:6 

203:10 222:18 231:17 

373:5,9 

handling 43:2 143:22 

144:3 149:13 185:4 

205:5 223:13 234:20 

237:12,16 287:10 

356:12 362:7 378:7 

hang 370:6 

Hansen 161:2 

happen 79:21 159:15 

216:3 318:6 

happened 12:16,20 

78:10 124:11 189:7 

195:21 

happening 67:2 118:7 

203:22 

happens 54:8 98:21 

176:17 178:17 181:14 

216:12 

happy 39:1 40:12 97:1 

202:5 242:12 318:5 

340:6 347:14 

hard 18:14 20:11,12,17 

49:21 69:8 95:18 

108:13 123:6 127:7 

175:2 179:3 188:7 

196:8 198:3 207:22 

232:7 281:12 285:19 

298:1 299:22 300:14 

364:22 

harder 254:9 358:16 

hardness 26:4 

harm 10:14 336:21 

337:8 

harms 11:12 107:22 

Harriet 1:13 13:19 20:9 

20:18 32:2,4 34:12,12 

43:17 46:16 50:5,22 

77:2 100:11 109:6,19 

110:9 114:12 123:9 

123:22 130:20 144:22 

149:11 167:3 233:6 

239:10 240:21 247:2 

267:11 272:12 274:6 

278:8 283:13 284:20 

285:4 310:14 334:14 

340:2 344:14 354:15 

354:16 359:10 371:4 

371:11 

harsh 95:19 

harsher 176:11 177:11 

harvest 38:3 54:11,13 

54:15,17,18 65:12 

68:8 69:13 74:17 

75:20 84:11 88:3 

98:16 117:16,19 

132:8 133:5,20 134:4 

134:13,20 135:20 

136:5,7,18 137:2,11 

139:7,15,19 141:6,7 

213:18,22 266:6 

285:16 292:19 306:16 

306:20 356:13 

harvested 6:4 38:9 

68:12 133:3 134:9 

137:8 288:14 301:11 

305:3 

harvesters 292:19 

305:6 

harvesting 29:15 38:12 

118:2 132:11 133:13 

139:4,5 140:10 229:5 

289:19 292:14 294:4 

295:9,18,20 298:12 

300:7 303:10,13,19 

305:16 307:1,3,9,11 

harvests 69:12 93:9 

135:19 

hate 305:11 

hazardous 171:18 

hazards 43:3 

head 140:15 184:15 

248:11 261:20 298:11 

298:13 

head-nodding 269:1 

headache 71:13 

headquartered 127:4 

heads 365:19 

health 7:9 8:1,10 26:21 

38:18 45:11 92:13 

163:5 173:2 175:15 

188:10 238:10 321:12 

healthcare 171:13 

healthier 57:9 

healthy 7:10 49:22 

172:12 322:3 

hear 39:1 103:18 153:3 

159:8 173:17 183:22 

237:1,4 261:10 

262:16 277:13 292:6 

297:17 298:3 340:6 

345:9,16 365:4 

heard 21:17 27:19 

42:18 89:4 113:3 

139:22 140:4,5 

150:12,22 154:3 

173:22 189:17 190:19 

192:15 201:3 212:10 

219:4,7,12,13,15,15 

221:12,14 223:17 

236:22 238:9,14,16 

248:10 250:15 269:14 

288:19 292:14 293:6 

295:16 313:21 314:20 

315:9 318:20 322:10 

322:17,22 323:22 

345:15 360:12 362:4 

hearing 61:14 125:13 

153:16 154:18 155:1 

158:15 183:17 215:20 

216:4 221:4 287:19 

341:2 

heart 10:22 198:3 298:9 

303:9 

heartened 203:17 

heartening 203:21 

heat 71:11 275:15 

heavily 265:21 

Hecht 141:12 162:14,16 

167:2 

hectare 65:16 69:22 

74:17 

hectares 45:21,22 

56:17 67:6 187:10,17 

hefty 318:3 

held 127:17 323:18 

Hello 36:20 51:22 59:8 

61:9 79:9 93:21 

183:21 

Helm 111:16 

help 14:3 37:12 42:12 

77:17 100:8 102:7 

126:13 155:6 156:20 

166:14 195:22 202:2 

214:22 229:16 231:8 

239:18 241:10 249:17 

251:15 252:14 275:9 

279:11 289:5 291:11 

297:3 303:3 315:1 

337:14,20 343:6 

347:16 357:4 358:22 

359:1 367:19 

helped 225:4 226:8,9 

helpful 68:22 227:9 

326:4 328:21 341:18 

344:2,6 345:16 

347:22 348:2,6 

368:13,16 373:13 

helping 163:14 165:17 

233:15 260:12 277:3 

helps 31:19 50:15 

196:1 240:11 257:1 

257:19 369:1 

herbicide 33:15 36:7 

herbicides 70:7 71:5 

herding 244:7 

Hernandez 162:11 

167:7,9,10 170:3 

Herrera 59:6 61:8,9,12 

62:4 64:22 66:22 69:3 

71:2 72:4,8,15,21 

73:4,7,10,18 76:11,13 

76:19 86:1 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
397 

hesitant 278:21 

Hey 374:17 

Hi 13:20 32:3,4 123:10 

157:8 188:21 220:22 

hi- 325:18 

hide 142:19 

hides 220:13 

hierarchy 337:21 

high 7:20 8:2 17:22 

115:18 127:17 128:6 

165:10 176:5 187:14 

259:7 308:19 326:13 

326:19 327:2 331:9 

331:12,16 337:5 

high-quality 240:3 

high-risk 9:21 

higher 7:20 84:22 

100:16 113:22 115:20 

171:17 313:4 331:19 

highest 304:11 

highlight 163:1 164:1 

334:11 337:3 369:10 

highlighted 216:14 

highlighting 82:5 

highlights 164:18,20 

highly 30:8 130:14 

176:20 217:5 

Hiltz 126:18 131:16,17 

131:18 135:16 136:21 

137:20 138:15 139:12 

140:5,12 141:10 

hiring 319:13 

historical 15:15 334:16 

histories 67:2 

history 15:3 

hit 217:6 331:18 

hold 144:21 167:13 

200:15 228:6,6 

330:13 369:14 

holdfast 133:8 

holding 116:19 

hole 242:3 

holistic 164:22 319:4 

327:6 334:9 365:3 

home 11:19 370:6 

374:1 

homework 269:12 

honest 149:1 

honestly 336:4 351:8 

363:16 

honey 53:21 174:5 

honor 61:10 166:15 

honored 21:15 

hoodie 230:5,6,10 

hop 178:14 

hope 27:9 46:13 103:19 

136:14 159:19 161:3 

166:14 179:11 183:7 

183:15,19 184:14 

227:15 233:7 244:3 

277:20 291:11 308:9 

333:14 345:8 377:13 

hopeful 257:10 

hopefully 278:15 

370:15 378:14,20 

hoping 203:12 

hops 178:6,12,13,14 

hors-d'oeuvres 378:20 

Horticultural 5:8,10 

horticulture 8:7 26:20 

hosted 373:16 

hot 106:3 256:7 257:2 

Hotel 1:9 

hour 4:10 

hours 362:11 363:9 

house 204:17 212:22 

houses 199:5 205:3,4,4 

huge 62:9 66:3 98:22 

102:2 

Hughes 36:19 40:21 

41:3,4 44:1 

human 96:9,10,12 

136:1 172:3 174:16 

174:18 175:8,11,15 

210:10 218:13 221:18 

221:20 291:21 

human-manipulated

300:4 

humid 61:17 87:12 

humidity 71:10 

hundred 264:14 265:2 

hundreds 188:5 

hungry 304:13 

husband 48:2 

hybrids 32:21 

hydrogen 24:2 

hydroponic 104:7,9,13 

104:20 105:8 

hydroponically 105:1 

hypothetical 175:3 

I

i.e 226:12 

ice 53:5,5 

Idaho 5:12 

idea 14:2,20 20:5 

154:12,18 184:9 

243:17 244:3,5,6 

248:12 260:5,16 

286:20 295:2 300:20 

306:16 318:18 320:16 

356:1 

ideally 135:11 375:14 

ideas 167:5 193:11 

242:16,17 313:16 

320:14 

identification 36:12 

128:1 318:12 

identified 83:15 128:5,8 

128:11 

identify 42:13 256:16 

257:2 260:17 326:21 

331:10 333:11 334:10 

365:20 368:18 

identifying 366:22 

identity 30:20 33:4 

IFOAM's 120:18 

ignorance 302:9 

ignored 300:2 

ignoring 358:10 359:2 

illegally 144:15 

Illinois 34:18 

illustrate 291:7 346:18 

347:11 

image 55:9 

imagery 46:4,5 

imagine 101:4 138:5 

178:19 264:14 

immediately 89:15 

303:6 

immunoassay 30:16 

31:14 

impact 73:16 82:19 

93:9 98:7 113:8 128:2 

139:17 140:9 189:3 

216:9,22 285:16 

286:9,11 288:7 290:6 

295:8 296:16 333:18 

337:5,5 376:16 

impacted 269:15 270:5 

impacts 107:4 128:22 

138:4,10,13 139:4,6 

139:10 299:15 

impair 154:14 

imperative 88:22 

implement 77:17 78:2 

259:20 321:6 333:21 

implementation 109:10 

130:16 

implemented 49:2 

314:13 

implementing 307:13 

325:3 

implication 19:6 

import 3:13 53:21 54:1 

104:22 121:12 322:16 

376:5 

importance 42:22 

59:11 124:15 314:7 

314:12 316:19 376:16 

important 37:22 38:5 

41:7 59:19 78:7 81:4 

92:7 95:20 101:10 

107:11 112:6 118:14 

122:11 143:15 164:3 

182:22 186:16 187:8 

187:22 196:15 207:20 

231:8,19 235:2 

237:16 256:6,22 

262:9 288:1,4 292:12 

299:22 304:13 314:21 

323:12 355:15 365:17 

368:6 369:16 

importantly 196:15 

importation 103:5 

imported 56:10 187:3 

199:12 201:4,14 

imports 337:1 

impossible 48:18 54:19 

75:22 98:15 

impractical 109:9 

impression 15:6 

improperly 144:16 

improve 7:8 104:15 

121:2 122:7 144:14 

144:17 145:14 300:9 

300:10 322:9 352:13 

improved 105:14 

127:12 326:15 

improvement 15:20 

20:7 34:19 57:5 104:2 

118:18 120:20 121:1 

166:16 229:13,15 

352:8 358:9 

improvements 57:9 

130:4 

improves 8:1 50:13 

improving 225:8 

300:12 

in-depth 356:20 

in-house 30:14 31:14 

123:13 

inadequate 155:11 

322:2 

incentive 15:14 37:6 

178:10 

incentivize 121:11 

inches 133:12 

include 29:14 38:2 

62:22 64:20 106:6 

117:21 119:10 130:1 

186:19 219:2 236:18 

275:7 281:16 293:22 

305:6 308:6 316:7 

320:4 356:1 

included 128:14 143:21 

154:5 155:3 160:20 

161:10 163:3 241:1 

275:2 

includes 35:4 105:4 

160:16 281:3 313:9 

341:7 368:17 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
398 

including 30:22 47:17 

58:15 87:10 92:2 

106:14 108:15 129:19 

165:10,21 208:8 

275:3 320:16 341:1 

inclusion 129:7 153:19 

income 66:5 169:11 

incompatible 305:8 

incomplete 129:8 

incorporate 122:20 

308:6 323:16 332:16 

339:16 

incorporated 318:22 

332:16 

incorporating 120:8 

incorrect 223:9 

increase 9:15 29:20 

57:8 58:8 130:17 

157:19 165:19 187:16 

187:18 223:12 236:19 

241:10 377:8 

increased 26:3 98:19 

290:13 294:3 

increases 128:17 

175:20,22 176:22 

increasing 25:3 28:6 

107:13 169:9 175:5 

238:9 

increasingly 126:11 

incredible 352:19 

incredibly 35:10 290:19 

308:8 324:18,19,19 

increment 64:2 

independent 374:15 

India 16:22 

indicates 222:7 

indication 124:14 

195:16 

indicator 128:14 129:3 

individual 235:11 

264:13 299:3 

individuals 25:4 

induced 276:8 281:3 

induction 46:9,12 48:1 

49:3 57:13 60:12 

88:12 168:12,19 

169:13 

industries 325:2 

industry 6:13 30:20 

64:18 71:20 77:19 

78:4,15 83:6 97:5 

111:8 120:17 127:12 

132:17 142:10 161:15 

187:22 192:19 201:2 

201:8 208:7 221:8,10 

223:1 224:6 227:11 

279:1 280:2 286:14 

290:3 352:16 362:18 

370:11 

industry's 127:20 

ineffective 106:12 

inert 118:15 209:17 

217:8,8 

infected 179:13,16 

infections 171:17 172:4 

infectious 171:14 

influence 25:7 165:7 

242:8 

influential 25:9 

info 322:21 

inform 42:4 43:9 337:20 

informal 296:22 

information 31:20 

78:16 83:5 138:18 

139:11 140:13 142:16 

156:9 158:3 177:22 

180:22 183:1 191:8 

221:5,15 240:10 

248:3 249:3 250:10 

251:21 255:14,20 

256:11,19 258:13,21 

259:10 261:3 281:15 

289:5 313:15 315:6 

315:13 317:12 320:8 

334:2 355:7,18,20 

365:18 367:20 377:5 

informative 373:15 

informed 29:21 85:8 

267:15 313:15 344:17 

348:3 

infrastructure 104:15 

351:6 373:22 

ingenious 183:4 

ingest 168:16 219:21 

ingredient 127:3 142:5 

145:15,16,22 146:2 

153:18 159:3 195:6 

221:22 222:4,8 

290:12 291:8,19 

292:1,4 293:10 

ingredients 142:17 

159:20 170:19 223:2 

293:6 294:1 302:18 

inherent 349:2 

inherently 159:22 160:1 

inherited 225:22 

initial 316:1 318:18 

initially 36:3 294:18 

296:6 

Initiative 240:6 373:10 

initiatives 10:3 

inks 180:21 181:2 

innately 368:5 

inner 133:6 

innovation 119:2 

369:19 

innovative 22:1 

inorganic 151:7 

input 16:11 47:9 69:17 

70:13 98:2 132:3 

192:10 199:5 236:2 

237:5 239:2 244:19 

286:20 289:12 290:12 

292:2,2,20 293:10,22 

296:11 305:10 312:5 

313:2 

inputs 15:22 56:6 98:4 

98:6 104:8 112:7 

114:9 135:19 288:13 

288:16 289:20 290:14 

306:19 

inquiries 138:17 

insect 8:9 47:4 165:5 

insecticidal 36:7 

insecticide 6:14 

insects 7:11 237:3 

insecurity 304:11 

inside 220:4,14 

insight 260:19 327:22 

328:3 333:16 

insoluble 209:18 

inspection 21:21 22:8 

121:10 122:13 123:4 

128:22 198:18 199:1 

199:2,4 201:19 

204:17 205:2 206:17 

361:4 363:2,9 366:12 

368:14 

inspections 121:12 

122:22 126:10,11 

130:9,18 137:17 

200:7,16 306:22 

327:16 363:17 364:10 

364:11,13 366:9,18 

inspector 3:11 116:18 

118:5 119:20 120:4 

122:21 123:17 125:11 

125:16 129:17,21 

130:14 203:18 312:6 

312:12 320:10 324:17 

354:13,22 355:15 

358:13 359:21 360:11 

360:14 361:17 364:8 

364:16 366:8,11 

371:7 373:3 374:10 

374:15 

inspector's 357:7 362:2 

inspectors 37:13 

108:16 118:7 119:22 

120:3,11,14 122:11 

122:14 126:13 128:1 

129:19 130:9 137:22 

355:9 356:19,21 

357:16,19 358:4,17 

360:2,3,5,8,19 361:4 

362:6 363:11 364:9 

370:2,4,5,13,15,19 

installed 49:14 

instill 365:21 

Institute 97:19 103:3 

239:17 

instituted 364:15 

Institution 163:13 

institutions 356:17 

instruction 10:11 

instrumentation 30:10 

insufficient 148:8 155:8 

intact 133:8 

integrate 164:11 

integrated 134:21 

integrity 3:5 9:20 28:20 

31:7 38:16 39:6 55:15 

77:19 90:14 103:17 

106:16 108:2 112:9 

120:5,12 127:12 

129:15 202:21 203:6 

234:7 238:3 247:6 

272:14 293:15 308:20 

309:3 311:15,19 

312:15,17 314:22 

315:8 317:1 342:22 

351:11 372:9,17 

373:1 377:8 

Integrity's 362:20 

intend 253:22 

intended 260:20 298:11 

318:14 

intense 69:14 317:22 

intensive 171:4 

intent 291:4 316:2 

intention 27:12 318:16 

intentional 296:7 

intentionally 271:15 

intentions 110:17 

intents 114:10 

inter- 155:21 

inter-cropped 163:6 

interact 97:17 332:10 

interaction 125:17 

275:21 

interchangeably 296:5 

interconnected 309:14 

Intercontinental 1:9 

interdisciplinary 166:6 

interest 37:18 112:17 

134:12 135:9 237:18 

249:8 324:1 

interested 19:9 88:2 

115:11 125:8 194:8 

287:18 374:22 

interesting 14:22 

125:15 193:3 254:22 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
399 

307:6 336:10 351:1 

357:14,22 

interests 163:19 

interface 139:1 

interim 10:3 270:1 

internal 72:2 320:22 

321:6 323:4,10 

internalized 332:22 

internally 242:6 258:11 

308:18 346:22 

international 5:13 

112:6 117:15,22 

119:10,21 221:1 

298:14,17 299:5,17 

311:17 325:14 326:2 

335:12 345:10 

internationally 9:18 

174:4 299:7 

interpretation 136:4,11 

interpretations 9:17 

INTERPRETER 55:5 

56:2 58:2 

intertidal 295:15 

intervals 238:12 

interview 365:4 

interviewer 355:16 

intestinal 154:7 

intimate 216:8 

intimated 160:8 

intrigued 325:1 

introducing 327:15 

introduction 31:17 

162:22 

invasive 237:3 

inventory 46:5 

invest 35:1 

invested 63:10 

investigate 106:9 

investigating 291:1 

investigation 53:8 78:9 

121:16 130:11 296:13 

investigations 53:7 

130:8 368:17 

investigative 29:9 

81:17 215:7 368:12 

investment 49:4 62:9 

66:3 

invite 318:22 324:7 

372:15 

invited 297:2 

involved 17:4 21:18 

81:20 127:5 159:2 

227:10,16 266:1 

322:13 

involvement 185:20 

involving 166:8 

IOA's 360:4 

IOIA 118:5,11 119:19 

119:21 120:1,3,12 

121:4,15,18 122:1,3,9 

123:2,14 124:2,8,15 

124:22 126:7,9 355:7 

355:13 356:16 

IOIA's 120:21 

ion 208:12,13 209:19 

212:4 

ionic 172:6 208:11,21 

211:21 212:8 217:5 

ions 209:2 211:22 

220:3 

Iowa 34:21 264:1 

IRAC 368:17 

irradiation 223:3 

irrelevant 210:21 

irrigation 7:18 8:2 

24:19,19 92:8 

ISO 31:9 

isothiocyanate 172:16 

issue 10:13 11:14 13:15 

19:20 21:4 37:22 

38:15,19 39:21 41:21 

43:7 44:2 55:22 61:12 

78:15 79:17 81:19,20 

90:2 95:22 101:5 

102:7 106:22 109:8 

110:19 115:10 153:17 

190:2,11,15 195:19 

227:3 236:1,6 239:13 

248:18 249:15 257:14 

285:12,18 286:5 

287:5,13 288:1,21 

297:4 299:22 303:8 

306:10 332:1 339:7,8 

339:8 344:3,10 

345:10 359:20 368:18 

368:19 369:4 

issued 316:17 

issues 5:14 20:22 26:9 

42:22 79:15 81:13 

85:20 111:10 129:4 

170:15 189:20 193:3 

201:9 259:15 295:21 

314:14 326:9 355:5 

issuing 349:18 

it'll 73:21 181:22 182:12 

182:13 

item 180:15 233:11 

234:1,8 237:15,21 

242:1 244:4 246:3 

247:5 253:18 272:17 

274:10 275:7 280:8 

280:20 

items 42:19 192:17 

234:6 235:2 253:17 

268:4 280:22 281:8 

333:8 334:22 356:13 

376:17 

J

Jacksonville 16:21 

Jamie 22:20 28:10,12 

32:3,6 36:17 250:15 

252:17 

January 374:3 375:15 

Japan 131:7 

Japones 171:9 177:19 

184:16 

Jay 180:5 

Jean 285:7 

Jennie 296:21 

Jennifer 2:14 105:13 

Jenny 232:2 328:2 

329:3 334:16 345:4 

346:7 347:22 372:9 

375:17 

Jenny's 124:10 345:15 

Jesse 1:15 18:15 

263:17 282:13 

jillion 265:9 

Jimenez 2:6 79:7 86:18 

86:21,22 89:10,18 

90:5 

Jo 38:20 

job 20:8 108:1 122:14 

161:15 259:14 307:3 

352:11 355:19 356:5 

357:2 358:16 366:2,4 

370:2 

John 223:11 345:13 

joined 231:2 

Joker 330:15 

jokes 378:2 

Jose 162:10 167:7,10 

170:5 185:10,13 

188:15 

journey 224:20 

judge 42:7 

Judy 144:19 

July 75:3 

jumbo 76:3 

jump 336:3 

jumping 276:17 

jumps 350:11 

jurisdiction 305:9 

jurisdictions 135:1 

justice 225:8 

justifies 42:10 

justify 35:2 

K

keep 49:19 50:1 55:14 

63:17 67:8 68:1 70:2 

75:21 78:19 82:11,17 

112:4 149:19 226:9 

256:19 257:6 273:6 

274:12 275:5,9,10 

281:12 321:20 331:6 

332:4 342:15 344:8 

351:15 355:4,5 

keeping 125:18 224:3 

368:21 

keeps 79:11 101:3 

Keith 198:14 207:4,6,6 

207:6,7 

Kellogg 1:9 

Kelly 116:13 119:16,18 

123:10 

kelp 38:8 93:7 239:5 

305:2,14 

kelps 117:16 

kept 52:8 344:21 355:2 

kernel 365:17 

key 10:2 38:9 92:19 

120:18 188:11 324:18 

324:19,19 

kick 336:8 

kicked 147:1 

Kiki 270:12 

kill 208:5 220:1 

killed 220:16 

kills 172:20 

kilos 69:21 70:14 

kinder 104:3 

kinds 14:10 22:12 60:1 

334:21 

kit 35:3 

knew 184:20 185:2 

338:17 359:3 377:3 

knock 345:15 

knowing 155:12 206:4 

332:7 

knowledge 129:21 

160:13 163:20 212:19 

355:10,14 356:18 

357:1 362:3 

knowledgeable 72:17 

73:1 

known 43:5 225:5 

254:7 

knows 85:19 122:9 

Krout 188:20 

Krout-Greenberg

198:16,17 204:10 

207:3 

Kure 23:2 

L

La 48:3 

lab 30:9 205:10 

label 38:16,17 39:7 

43:21 104:21 107:22 

143:6 155:13 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
400 

labeled 104:22 117:3 

222:1,3 304:17 

labeling 155:7 222:7 

253:2 

labels 24:22 85:9 105:7 

192:20,22 

labor 49:11,16 52:8 

laboratory 30:6 31:10 

250:18 

labs 34:20 108:15 

lack 16:3 98:3 107:20 

143:9 315:15 321:20 

lacking 357:1 358:19 

lady 367:6,14 

laid 80:9 143:20 285:13 

359:8 

lake 23:3 25:10 

land 3:5 37:8,14 57:3 

59:18 65:6 66:4 

163:13 187:11 224:4 

225:20 238:21 247:7 

250:9 253:1 272:15 

landing 373:20 

landings 137:7 

landlocked 298:8 

landowner 295:13 

landowners 295:12 

landscape 164:9 165:1 

165:7 

language 39:14 75:16 

109:17 132:9 194:16 

282:11 294:14 

languishing 234:1 

large 130:15 159:19 

203:1 216:8 291:2 

345:4 351:5 

largely 241:2 

larger 24:18 249:15 

308:16 361:2 

largest 32:22,22 111:13 

216:14 

larvae 99:19 100:18 

236:2 

lasting 171:16 

Lastly 42:21 

late 12:21 206:11 

247:12 

latest 78:3,10 

latitudes 165:16 

laughs 73:5 

Laughter 61:6 62:3 

79:5 228:12 229:22 

230:8 261:15 

launched 374:2 

laundry 24:11 

Laura 44:8 47:13,16 

185:11 188:19,21 

192:13,15 197:4,5 

198:13 229:6 

law 10:22 62:12 65:2 

142:22 143:10 

law's 365:7 

laws 133:14 253:2 

layer 193:20 

lead 127:11 166:21 

218:10 244:3 290:14 

354:15 372:16 

leader 6:2 28:15 69:5 

191:18 

leaders 72:18 208:7 

leadership 107:19 

196:22 

leading 208:9 

leaf 8:4 

learn 25:4 70:3,4 366:1 

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278:7 

learning 121:13 312:15 

312:17 335:5 372:10 

372:17 375:18 

leave 48:16 64:4,5 

65:19 66:2,4 73:20 

225:19,20 

leaves 17:21 18:1,4 

55:18 

leaving 104:1 133:7 

lecithin 157:10,12,13 

157:17,21 158:3,6,8 

158:10,13,18,21 

led 36:22 133:1 

leech 215:17 

left 8:3 165:12 175:8 

218:16 369:6 

legal 252:11 292:7 

legally 143:1 

legislation 77:18 78:3 

legitimate 9:19 301:3 

legume 66:18 163:4 

legumes 47:7 63:20 

69:20 

lend 135:11 

length 128:2 

lengthy 14:18 

Leon 59:7 61:8 

lessen 293:11 

lesson 178:5,8 

let's 102:10 148:7 

175:13 185:3 232:12 

322:4 352:22 

letting 48:14 

level 7:3,21 13:5 22:14 

30:3 95:1 110:11 

121:9 123:16 204:4 

210:2 213:7 242:22 

253:3 254:1,3 255:9 

258:15 259:1,7 

271:19 314:4 335:20 

335:22 360:21 

levels 32:17 110:16 

113:17 187:14 196:13 

204:1 214:22 250:6 

leveraging 205:14,14 

LEWIS 2:9 20:18 40:9 

40:19 196:4,20 

239:10 241:15,18 

279:12 280:4 

licensed 137:2 

licensing 138:12 

life 41:16 138:11 210:6 

378:1 

light 4:19 276:1,6 

liked 359:5 

likelihood 314:9 

likes 251:17 

LIMA 1:15 149:19 

246:20 273:19 283:1 

284:10 354:1 371:18 

limit 112:22 113:22 

133:14 136:17 215:22 

219:1 

limited 26:2 66:4 

112:20 113:18 156:6 

280:15 

limiting 113:2 

limits 91:10 146:17 

192:9 

Lindsey 198:15 207:4 

line 161:4 174:17 175:3 

301:14 369:1 

lines 238:4 

link 119:11 

linked 19:21 20:5 

liquid 90:19 92:15,18 

111:15 112:13,20,22 

114:5 

Lisa 1:15 149:13 

list 2:11 19:14 20:20 

21:5 27:8 42:8,11 

49:19 78:19 90:20 

91:1,18 92:6 112:18 

114:4 117:1,7 118:22 

121:4 128:10 143:20 

144:16 149:20 176:22 

182:1,14,20 186:6 

196:7 207:18 211:2 

215:22 223:17,20 

226:7 237:11 243:18 

243:20,22 277:9 

281:9 293:5 294:15 

299:2 314:2,3 318:14 

324:2 355:12 357:15 

listed 23:19 24:22 

103:7 118:15 144:16 

145:8,22 148:5,6 

178:2 221:16,19 

235:14 281:18 283:20 

listened 150:10 

listing 8:11 23:17 25:7 

25:15 90:22 92:6 

144:10 171:2 195:4,8 

207:18 210:15 227:19 

listings 170:18 

lists 153:18 

liter 114:2 

literally 374:7 

little 22:11 35:14 48:3 

75:19 83:4 93:5 94:21 

95:3,5,18,19 108:7 

109:7,15 111:11 

156:17 159:11 160:5 

160:11 214:5 227:7 

236:22 237:1 245:15 

251:17,19 252:13 

253:12,16 258:3 

259:16 270:10 279:7 

287:15 300:6,8 

327:13 329:16 330:10 

336:13 338:4 359:6 

366:6 367:6,11,14 

369:8 

live 57:19 168:5 359:20 

livelihoods 80:1 

lives 295:9 375:12 

livestock 4:14 189:1,17 

191:7 201:17 205:1 

233:3 234:20 235:18 

236:3,6,8 278:6 280:8 

291:21 292:16 311:7 

356:12 360:10,12 

361:20,21 377:21 

378:6 

living 324:6,6 328:9 

329:8 

LMS 312:15 

lobbying 180:19 

lobsters 309:10,11 

local 56:9 104:11 

125:17,19 126:1 

133:14 139:7 

locally 77:21 115:7 

located 52:3 56:22 

61:15 

location 141:8 242:19 

locations 9:21 111:16 

134:10 212:15 313:13 

locust 149:8 150:17 

log 375:13 

logic 211:16 308:17 

logically 66:14 

logs 103:4 

long 10:19 15:3 17:8 

20:1 21:19 22:6,16 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
401 

161:17 178:9,19 

197:19 223:5 285:14 

315:10 

long-term 12:3 17:13 

92:19 297:8 

longer 43:11 104:22 

171:16 225:16 229:7 

237:15 241:3 317:21 

318:8 

longstanding 190:9 

look 11:9 15:15 20:6,10 

21:2,3 22:5 52:14 

81:12 85:6,13 88:5 

96:22 97:10 114:18 

118:1 138:1 180:5 

182:22 226:10,12 

228:2 229:4 248:4 

253:4 254:18 268:13 

280:10 287:2 294:8 

299:1,17 305:4 312:9 

321:3 322:12 323:5 

329:19 334:6 337:15 

338:1 340:11,11,15 

351:1,12 359:17 

368:6 370:4 372:9 

375:17 

looked 17:3 80:16 

96:21 115:7 154:4 

286:15 360:18 

looking 4:4 16:8 27:17 

30:6 34:1 35:21 57:5 

79:12 84:20 85:9,9 

94:14 95:14 96:1 97:5 

108:18 131:7 138:18 

181:5,12 218:3 

240:17 252:18 259:14 

268:22 275:11 277:20 

281:1 286:20 287:11 

288:9 290:22 291:18 

291:19 296:11 302:13 

305:8 312:10,22 

313:7 314:12 316:14 

318:7,15 322:15 

324:5,15 325:13 

329:21 332:15 336:20 

337:10 338:7 341:19 

342:7,10,21 349:14 

356:16 360:8,20 

361:1,3,7 365:15 

369:3 375:6 

looks 4:5 122:5 137:3 

170:13 257:16 300:7 

310:20 317:18 323:14 

351:3 

loop 355:2 

loophole 143:10 161:7 

162:5 

loopholes 9:15 

loops 246:4 

loose 289:1 

lose 11:7 13:16 18:2 

65:15 271:17 370:3 

loss 11:21 18:5 

losses 100:20 108:9 

lost 263:7 

lot 16:17 18:1 24:16,17 

30:4 47:17 52:15 54:6 

59:17 60:3,10 63:14 

70:10,11,21 71:3,19 

79:3 82:8 84:6 90:1 

93:11 96:8 98:13,19 

98:21,22 109:2 

138:19 151:6 158:1 

175:9 180:11 183:5,5 

192:8 196:1 220:10 

225:2 232:5 239:2 

242:15 251:10,10,13 

253:11,15 263:11 

264:7 266:5,17 267:8 

267:8 278:7 279:20 

281:12 283:18 285:8 

288:13 297:17 304:3 

304:13 307:2 311:12 

311:16,18 312:1 

323:22 325:22 336:6 

337:12 344:4 345:9 

351:14 352:10 358:16 

359:16 361:11,19 

362:9 363:16,17 

370:1,4,16 375:6 

376:2 

lots 35:5 95:14 106:6 

219:4 262:1 264:12 

319:5 

love 57:4 63:3 73:4 

260:5 329:6 332:6 

low 60:16 61:1 115:19 

165:11,13 169:11 

219:19 326:21 327:2 

331:9,12 341:11 

lower 210:1 346:2 

lowering 8:4 169:8 

lowest 61:20 

luck 279:9 

lucky 21:15 

Luis 59:5,8 72:14,15 

73:2 

lunch 4:9,10 230:4,4 

233:8 378:9 

M

machinery 70:10 94:13 

machines 94:8 95:13 

macroalgae 285:17 

292:15 296:8 

macroalgaes 288:12 

maerl 299:13 

Maestro 61:5 

magic 364:21 

mail 250:17 

main 88:21 178:8 

186:17 252:7 283:11 

290:11 372:12 

Maine 134:3,6 139:1,2 

238:21 295:8,14 

maintain 8:12 39:6 

104:16 142:19 223:12 

300:9 321:6 322:3 

369:13 

maintaining 38:11 

114:4 258:12 

major 130:10 159:20 

171:14 321:1 376:10 

majority 92:18 272:19 

273:3,3 282:2 283:21 

299:9 310:4 

makeup 276:18 

making 17:16 21:11 

35:22 39:4 42:4 48:17 

50:1 68:11 74:16 

75:14 80:21 84:3 

98:22 99:20 169:9 

217:22 237:10 257:1 

323:2 334:7 

man 227:21 360:13 

manage 99:21 100:6 

164:12 258:5 

managed 13:21 14:13 

management 11:4 

12:10 13:1,6 14:2 

23:6 25:20 50:14 

66:20 99:13,14 101:4 

121:14 128:20 163:8 

166:2 167:17 237:2,2 

249:11 306:8,19,20 

320:18 333:1 341:17 

351:4,7 

managements 134:22 

manager 2:11 28:13 

61:13 90:12 106:1 

167:19 363:3 

managers 25:10,11 

managing 164:14 240:8 

332:17 

mandate 348:17 

mandated 201:19 250:4 

maneuvered 212:3 

manipulation 276:3 

manner 16:4 48:13 

134:14 

manual 133:5 

manually 71:14 

manufacture 111:15 

manufacturer 111:13 

127:3 160:9 

manufacturers 112:2 

142:14 143:21 150:8 

161:19 

manufactures 23:8 

135:22 

manure 238:12 

map 13:4 339:5 

mapped 141:4 

marine 3:7 37:19 38:2,9 

39:12 93:12 131:20 

132:3,8,21 134:13,18 

138:11 173:1,3 234:9 

285:2,16 288:12 

289:6,10,20 292:15 

293:1 294:9 296:8 

301:20 310:3 

Marisol 4:15 5:5,7 

Mark 219:17 

market 16:11 17:8,22 

30:1 36:8 49:21 58:20 

74:21 75:4,5 87:7 

101:10 105:8 113:18 

117:4 134:15 151:6 

152:2,2 153:6,7 

157:21 158:21 168:4 

178:11 179:6,7 184:6 

186:18 188:9 203:17 

203:19 204:4 205:11 

218:5 224:1 240:3 

249:5,14,17 252:3 

265:7 337:4,5 345:22 

352:15 

marketing 2:7 205:4 

223:22 

marketplace 34:3,6,10 

36:1,5 44:4 103:11 

105:12 251:7 

markets 24:21 26:19 

33:3 35:10 62:17 

85:13 88:5 141:15 

204:15 205:8,11 

249:18 

marry 206:20 

Marty 220:21 224:15,16 

228:7 229:10,19,20 

230:2,11 

mass 67:20,21 68:2,14 

130:2 361:5 362:13 

363:19 

match 68:15 99:17 

matches 137:9 

matching 104:12 

material 6:22 11:22 

19:9,13 20:20 23:12 

27:6 28:2 42:4,5,9,17 

60:9 71:19 84:7 94:22 

96:19 98:11 101:11 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
402 

133:20 135:18 136:2 

136:4 182:16 183:14 

184:11 211:17 213:13 

213:14 219:10 227:7 

236:4 238:5 239:12 

278:4 293:7,12 301:3 

338:19 374:19 

materials 2:12 3:3,7 

4:11 5:16 7:4 37:20 

39:12 42:7,14 51:2 

60:1 112:18 132:3 

173:13 176:20 178:2 

199:6 231:7 232:15 

232:22 233:5 234:6,9 

234:20 235:6 238:2 

238:22 239:2,5,5 

244:3 248:18 271:3 

285:2 291:1 292:11 

296:15,17 299:6 

310:7,14 

math 106:14 

MATHEWS 2:11 

matrix 128:8 314:8 

318:19 

mats 25:1 

matter 25:19 47:8 71:2 

74:13,18 99:20 

102:15 198:4 209:15 

217:6 232:16 272:16 

272:19 306:12 310:17 

318:4 331:5 379:5 

matters 272:18 376:20 

maturation 54:8 

mature 100:19 

Mays 111:2 116:12,14 

116:15 119:13,15 

maze 33:18 

meal 75:18 113:9 

135:22 

mean 13:15 15:18 

21:13 22:10,12 28:1 

40:15 85:6 87:19 95:5 

97:3 105:5,7 115:2 

128:16 136:6 149:19 

151:4 155:11 159:7 

174:20 175:13 179:12 

183:12,18 214:5,8,16 

214:17 215:14,19 

216:2,4,7 217:12 

226:10,17 261:7 

264:11 265:19 285:19 

308:22 327:9 331:21 

334:21 335:16,18 

336:4,16 344:18,19 

344:20 348:11,12,16 

348:19 349:2,17 

350:19 359:14 363:5 

365:1 370:5 

meaning 260:14 274:21 

means 46:1 47:9 67:12 

68:7 70:10 100:8 

103:11 106:18 151:18 

275:15 296:12 297:19 

298:1 306:6,18 

316:15 326:19,22 

329:8 331:22 338:7 

meant 86:6 242:11 

248:22 261:17 

measurable 26:14 

measured 122:18 

measures 118:3 129:11 

129:13 315:21 

measuring 30:4 

meat 26:21 103:12 

156:6 

mechanical 75:14,17 

133:5 

mechanism 116:8 

220:7,15 

medical 171:17 219:5,8 

medications 171:18 

medicine 171:11 172:3 

175:22 251:20 

Mediterranean 299:10 

medium 169:11 186:21 

188:6 331:9,12 

meet 32:8,15 42:8 

98:11 107:17 143:18 

197:7 208:15 250:21 

288:16 

meeting 1:5 10:9 16:21 

37:8 52:12 77:13 

112:12 115:14 120:9 

132:5 170:15 188:9 

189:5,18 191:6 208:2 

233:5 234:3 238:14 

242:16,20,21 243:2 

248:7 274:5 287:18 

306:2 307:10 308:19 

311:4 315:18 317:6 

326:8 330:9 344:4 

376:10,18 377:10,15 

meetings 39:2 106:10 

201:1,2 226:3 228:21 

235:8 320:3 

Melody 97:13 102:13 

102:20,21,22 103:2 

member 9:8 319:12 

325:22 344:7,17 

members 4:6 8:10 

20:14 38:1 51:13 

84:13 102:19 141:18 

155:1 162:15 168:1 

170:11 189:16 191:21 

192:4 198:21 202:4 

224:19 232:20 235:12 

245:16 261:10 270:1 

287:19 310:21 328:5 

344:9,21,21 347:21 

377:2 

membership 120:2 

189:3 192:4 197:9 

198:4 

membership-based

191:17 

memberships 193:6 

memorize 109:13 

memory 194:15 330:15 

Menes 105:19 111:4,4 

114:16 115:4 116:1,5 

116:11 

mentee 366:13 

mention 98:18 147:20 

147:21 204:15 222:18 

223:14 233:22 281:21 

322:7 

mentioned 16:15 39:11 

55:4 82:16 85:17 

101:7 138:12 173:21 

178:4 196:5 205:7 

231:14 238:19 247:14 

270:12 325:21 

mentions 260:3 280:19 

mentor 121:20 

mentored 364:9 366:8 

mentoring 121:18 

126:10 364:13 365:22 

366:17 

merchandiser 127:3 

Mesh 220:21 224:15,16 

224:16 228:4,13,18 

229:11 230:3,20 

message 231:21 

met 1:8 17:2 114:11 

209:14 210:21 

metallic 26:6 

metaphor 330:10 

methionine 235:19 

236:5 

method 30:4 88:17 

92:10 100:2 274:15 

274:20,21 275:4,16 

275:18 276:5,12,12 

276:22 278:19 279:4 

281:2,5,18 283:20 

367:13 368:17 

methodology 36:14 

methods 3:6 51:2 91:22 

92:3 94:1 162:2 184:4 

223:3 234:8 274:8 

276:15 277:15 278:10 

278:11,17 280:1,10 

283:17,18 328:10,21 

355:1 

methylation 35:15 

metropolitan 141:17 

mic 177:4 360:6 

Michael 4:16 9:3,5,7 

12:7 13:20 15:2 16:15 

21:10 22:17 105:19 

111:1,2 161:2 

Michael's 227:8 

Michelle 2:4 62:1 

141:21 274:7 277:2 

277:13 280:10 

Michelle's 347:15 

microbe 92:13 

microbes 171:19 220:1 

microbial 7:11 96:17 

219:6,9,18 222:6 

micrograms 114:1 

micronized 95:9 

microorganism 220:16 

microorganisms

172:21 

microphone 224:13 

230:13 

microvilli 154:8,15 

mid-term 341:10 

middle 38:6 39:11,13 

297:15 300:15,17 

301:10,17 

Midwest 106:3 

Mike 111:4 

mildew 6:21 91:4,20 

92:2 95:21 

milk 103:12 191:12 

Millers 126:22 127:2 

millimeters 61:18 

million 6:4 87:17,17 

113:21 115:19 186:13 

187:4 199:22 200:6 

mind 182:15 331:6 

332:5,6 355:4,5 368:8 

mine 47:17 79:10 

minimal 317:6 

minimum 129:8,20 

317:3 331:8,17,18 

Ministry 97:20 185:14 

Minnesota 1:10 65:5 

104:10 109:1 127:4 

162:18 164:4 165:17 

167:11,14,18 259:4,7 

Minnesota's 163:12 

minor 174:20 209:19 

321:2 

minute 4:20 102:11 

159:21 

minutes 4:18,20 31:2 

44:19 155:20 346:16 

347:13 364:18 377:21 

378:1 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
403 

miracle 85:16 

Miranda 59:6 

misrepresents 210:16 

missed 16:21 129:1 

239:8 366:14 

misses 320:2 

missing 81:2 119:11 

230:5,10 

mission 339:2 

Mississippi 168:3 

mistakes 338:18,19 

mites 6:14 

miticide 91:3 

mitigate 165:19 220:9 

mitigating 209:5 238:4 

mitigation 255:15 

315:20 

mitigations 314:14 

mix 60:6,18 

mixed 60:3 75:22 

mixes 166:1 

mode 209:4 

model 22:3 104:1 

134:21 337:14 

modeled 218:18 

models 319:1 

modern 80:20 

modes 349:5 

modification 271:11 

274:22 279:16 

modifications 98:6 

modified 35:20 

modify 255:17 

modules 354:22 373:8 

mold 99:19 

molecular 36:12,14 

208:11 

moment 8:20,21 58:6 

279:1 378:5 

Monaghan 116:13 

119:18,19 123:22 

125:4 126:4,16 

money 80:6 83:9 

225:14 241:14 251:18 

monitoring 327:4 

month 274:14 

months 47:6,8 60:11 

63:21 64:4 68:5,9 

71:9,11 81:18 88:2 

205:20,21 295:19 

304:12 309:6 

moral 107:16 

morning 9:7 23:1 41:3 

41:9 45:6 47:15 52:1 

56:11 61:9 77:5 79:9 

86:21 90:10 97:15 

105:22 111:4 116:14 

126:20 131:17 162:14 

167:9 185:13 309:7 

342:5 346:17 347:14 

378:5 

Morrell 97:14 102:14,21 

103:2,3 

Mortensen 1:17 33:10 

33:13 51:11 54:5,12 

54:16,22 66:17 68:20 

82:1,5,7,9,21 83:1 

96:6 125:6 246:16 

247:9 256:21 260:10 

266:10 273:15 282:19 

284:6 308:14 341:22 

343:18 344:20 345:8 

347:17,20 353:19 

371:14 

MOSA 106:1 

MOSES 344:13 

mother 190:4 350:18 

moths 100:17,18 

motion 244:21 245:1,7 

245:8,9 246:6 247:2 

272:1,3,12,13 274:4 

281:15,21 282:1,7 

283:9,12,12,13 

284:19 353:8,9,10 

354:11 371:3,3,4,6 

372:7 

motivate 57:11 

move 37:18 44:21 76:7 

103:19 127:16 133:6 

191:6 197:1,19 

232:22 233:1 245:6 

282:3 289:11 311:11 

332:5 353:3,5,6 

370:21 378:4 

moved 176:13 177:7 

309:6 

movement 71:3 120:16 

moves 251:1 

moving 36:10 136:13 

190:4,6 191:2 227:4 

227:12 233:11 234:4 

259:21 304:18 306:16 

309:4 323:21 324:16 

340:20 342:12 348:1 

370:10 

MSG 143:5 

Muchas 61:4 

mulch 55:18 59:22 

70:20,22 71:4,7 

118:16 236:13 240:16 

multi- 63:3 

multi-sectoral 79:17 

multi-site 63:6 

multi-sites 72:9 

multiple 173:8 205:16 

249:17 293:16 

multiple-day 364:10 

municipal 23:4 212:15 

214:10,14 

municipalities 212:12 

214:7 

municipality 217:14 

Musgrave 86:19 90:7 

90:10,11 93:10 94:2 

95:3 96:12,20 97:9 

music 125:10 

muster 292:8 

mutagenesis 276:8 

281:3 

mysterious 143:8 

N

nagging 346:3 

name 5:6,7 9:6 22:21 

23:1 28:12 36:20 41:2 

41:3 45:6 47:15 48:10 

51:22 59:8 61:12 77:4 

79:8 86:20,22 90:8,10 

97:15 102:22 103:2 

105:20 111:3 119:18 

126:19 141:13,14 

162:12,16 167:10 

170:6,8 185:13 

198:17 207:10,13 

names 77:2 81:19 

270:13 

nano 211:9,10,16 

nanometers 211:17 

Nanoparticles 212:1 

nanotechnology

208:15,17 211:12 

narrowing 151:10 

152:2 

narrows 151:6 

Natalie 188:20 198:14 

198:17 

natamycin 8:17 172:2,3 

172:5 175:13 

Nathan 141:12 162:10 

162:16 

nation 115:6 203:7 

nation's 111:12 

national 1:3 2:5,10,11 

2:12,15 5:20 6:2 

13:22 19:14 27:8 29:1 

36:22 41:5 42:7,11 

62:21 65:2 90:20 91:1 

91:18 92:6 93:1 97:18 

97:19 107:20 117:1,7 

118:21 143:20 176:22 

182:14 185:17 186:6 

196:7 207:18 210:5 

211:2 226:1,6 237:11 

239:17 294:14 332:22 

344:19 357:4 

nationwide 11:3 

native 37:7,9,14 64:20 

288:14 291:9 309:12 

natural 51:2 53:18,22 

55:19 64:5 98:20 99:6 

99:6,7 103:21 118:4 

143:2,2,5 144:1 159:6 

159:16 160:7,10,14 

164:15,16,21 165:6 

195:5 222:13,15,18 

236:4 290:14 291:1 

307:4,17 335:16 

naturally 48:15 73:20 

88:11 133:21 

naturally-occurring

275:14 279:6 

nature 159:12 212:5 

255:21 

nearly 141:17 200:4 

Nebraska 266:19 

necessarily 224:1 

259:5 287:22 315:7 

322:5 369:17 

necessary 7:12 42:13 

98:16 155:14 181:2 

218:8 269:8 316:8 

322:2 

necessity 97:8 108:2 

need 8:17 13:7,8 14:15 

16:15 17:21 28:16 

29:9 30:21 31:20 36:2 

38:1 41:11,14 42:8 

44:9 48:11 49:22 60:3 

60:13 62:22 63:17 

67:8 71:6 73:16 74:15 

74:17 76:7,10 81:10 

85:10,20 97:8 102:20 

112:3 119:1 130:4 

153:1 165:3 171:17 

207:19 216:4 217:14 

218:6 221:5 222:14 

223:10 229:9 244:10 

249:3,5,16 251:20,20 

252:3 257:6 261:3 

266:15 267:16 268:18 

281:9 289:4,12 290:7 

293:21 301:12 303:4 

304:4 305:5,10 309:5 

310:5 325:18 327:4 

330:10 331:6,10 

334:18 335:21 336:12 

339:21 340:21 348:19 

351:5 352:12,13 

356:8 358:22 363:11 

367:19,20 369:8,20 

370:13,13,18 

needed 35:10 52:22 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
404 

58:12 77:15 109:18 

110:13 112:4 118:8 

120:22 165:20 175:10 

214:12 218:8 238:12 

275:22 293:18 321:12 

356:3 

needing 160:2,2 221:22 

needs 13:6 30:1 38:22 

44:13 48:11 98:11 

107:1 159:14 176:2,3 

197:7,17 253:18 

300:5 331:3 332:2,22 

355:21 360:18 361:17 

362:1,17 374:21 

negative 139:6,16 

367:1 

neighbor 55:14 342:14 

364:2 

neighborhood 257:8 

342:8 

Nestor 47:14 51:18 

52:1 

net 67:4,16 366:4 

networking 378:18 

never 48:15 88:13 

134:9 141:3 225:17 

278:11 346:21 347:2 

347:8,8 359:3 

new 10:4,6 14:11 18:20 

34:9,10 35:21 36:4,10 

42:4 61:10 63:11 

105:3 171:3,6 180:21 

180:22 181:17 189:16 

189:21 190:2 198:21 

224:19 235:4,6,6 

238:8 245:16 248:4 

249:10 286:20 287:9 

296:11 297:12 309:6 

317:8 325:21 363:16 

370:17 

newer 39:15 

newly 63:13 

newspaper 180:17,20 

NHC 5:15 

Nicaraguan 52:4 

nice 166:22 

nicely 324:21 

NIFA 240:1 241:5 

night 79:12 82:11,18 

nine 49:14 60:11 

nitrate 19:18 113:11 

114:7,15 115:17 

118:16 212:7 227:20 

nitrogen 69:21 70:13 

70:14 92:19 113:14 

163:3 

no-till 236:16 

NOAA 63:6 306:6,10 

NOAA's 306:7 

NOC 41:14 

nodosum 132:11 

nomenclature 287:11 

non- 117:1 222:11 

250:8 251:12 315:21 

331:21 349:18 

non-agreement 275:21 

non-compliance 316:7 

338:5,9 

non-compliances

316:17 321:1,2 

341:20 

non-excluded 276:22 

283:17 

non-GMO 30:20 33:3 

106:18 249:2,4,13 

266:2,3,8 

non-organic 25:10 

142:13 170:19 176:18 

177:6 178:9 250:11 

256:3 270:14 

non-profit 36:22 120:1 

349:9 357:7 

nonagricultural 195:6 

noncompliance 21:20 

22:6 

noncompliances 21:13 

129:1 

nonprofit 225:7 

nonsynthetic 195:5 

noontime 4:10 

NOP 29:9 31:18 37:17 

43:11 78:14 87:10 

90:15 98:1 103:19 

105:15 108:16 111:7 

114:4 118:9 121:10 

122:6 123:19,20 

124:21 131:22 136:4 

143:15 197:13 199:15 

201:9 202:1 206:15 

258:11 283:16,18 

292:8 307:9 313:2 

315:12,18 318:6 

320:2,4,12 322:8 

323:15 344:22 345:6 

371:7 376:19,22 

379:3 

NOP's 112:17 291:15 

Nope 44:15 

normal 64:3 

normally 63:20 223:13 

north 9:10 11:19 12:16 

17:5 23:2 56:15 57:2 

299:8 309:9 

Northeast 309:13 

northern 52:3 61:16 

76:4 163:7 165:16 

Northwest 5:8,9,21 

6:10 7:13 8:7,18 

NOSB 2:4 10:5 12:1 

15:3 16:21 23:10 

37:17,19 38:21 39:5 

41:8 42:2,6,21 43:6,9 

43:12 47:22 52:13 

78:14 90:13 97:18 

110:17 111:6 112:11 

117:6,22 120:9 

123:20 127:8 132:1 

142:9,12 143:20 

144:7,11 148:12 

162:14 164:6 195:10 

198:21 202:4 204:8 

223:22 226:2 231:3 

242:11 271:2 313:2 

320:3 344:1,7,19 

373:14 376:19 378:12 

NOSB's 234:16 

NOSBs 377:7 

notations 23:21 

note 24:5 237:17 246:2 

288:5,11 295:7 303:8 

316:14 

noted 133:19 249:16 

315:14 318:15 320:3 

notes 39:1 

notice 269:11 

notified 103:7 212:12 

notify 213:7 217:12,14 

noting 7:13 319:3 

notwithstanding 126:5 

Nova 131:20 134:2,3 

139:6 140:1,9,13 

141:2 

November 227:18 

372:15 

NSF 24:6 

nuclei 276:4 

number 5:16 11:11 15:7 

29:12 85:3 112:20 

128:13 129:8 186:12 

196:7,12 222:5 

236:14 249:2 257:14 

268:14 295:7 311:19 

315:15 316:17 319:3 

321:2 336:4 350:11 

369:11 

numbers 66:6 199:19 

numerous 14:13 185:8 

nursery 176:10,12 

184:6 

nut 300:14 

nutrient 7:7 8:5 69:10 

92:12 138:6 163:4 

166:2 167:16 

nutrients 69:17 154:9 

154:16 

nutrition 68:7 69:11,16 

237:3 

nutritional 154:14 

O

Oakley 1:17 12:9 19:8 

27:5 40:2,15 44:11,13 

44:16,18,21 45:3 58:8 

64:16 84:1 85:17 93:5 

101:15 119:7 135:4 

136:16 137:15 147:16 

151:4 152:8,13,18 

153:10 166:19 183:11 

184:12,20 185:2 

231:1 234:14 240:21 

244:5 246:9 264:11 

267:6 272:6 273:22 

281:19 283:4 284:13 

285:4 298:20 301:7 

302:12,19 308:4 

328:7 339:12 354:4 

371:21 

objection 149:10 

objections 150:19 

191:10 

objectively 316:13 

obligation 11:16 

observed 26:15 117:17 

139:13,17 

observer 355:17 

obstacles 171:7 

obtain 118:1 

obtained 113:19 200:9 

obvious 340:10 

obviously 44:3 88:20 

89:21 196:21 222:10 

225:13 233:18 238:14 

256:1 264:18 297:9 

306:6 

occur 29:12 

occurred 275:14 

occurrence 12:20 

125:21 

occurring 132:16 

ocean 298:9 305:13 

ocean's 38:18 

oceans 139:18 140:18 

310:4 

October 1:7 3:6 

OFA 270:9 

OFARM 270:8 

off- 93:5 

OFFA 84:9 104:16 

offense 367:4 

offer 127:8 131:22 

256:10 

office 137:19 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
405 

officer 378:13 

offices 9:22 313:12 

350:4,11,12,13 

official 2:16 79:19 

offsite 313:12 

OFPA 10:15,17 114:10 

146:13,22 147:8,9 

156:16 

OIG 190:14 

oil 113:9 226:19,22 

OIM 199:9 

Oklahoman 298:9 

old 76:17 134:1 189:22 

190:11 295:16 367:14 

oldest 26:1 

OLLS 312:16 

Olman 77:1 79:6 82:1 

OMRI 258:8 299:2 

once 12:20 16:5 20:19 

21:5 36:10 37:15 50:8 

50:9 70:20 170:18 

207:6 232:22 268:19 

280:2 292:10 351:16 

374:2 

one-page 346:17 

one-time 120:22 

ones 77:11 115:16 

332:15 333:3 336:10 

338:2 348:16 

ongoing 51:1 132:1,6 

274:10 329:7,9 347:9 

375:8 

online 115:12 129:20 

351:20 372:18,20 

onsite 36:13 137:16 

209:10 215:5 313:10 

OP 15:3 

open 5:1 32:1,5 68:18 

97:1 109:21 119:2 

136:9 242:17 243:7 

259:11 267:15,18,21 

268:6,8 269:5 277:4 

328:4,18 329:10 

336:6 

opening 196:6 269:6 

openly 153:22 

openness 329:22 330:3 

opens 268:15,19 

operate 54:20 190:10 

operated 141:16 

operating 324:8 

operation 52:2 62:4 

128:17 205:12 313:5 

319:11,15 362:11 

operational 128:20 

operationally 21:14 

operations 9:18,19,21 

21:12 52:11 63:1 

103:10 104:13 106:1 

106:2,5 127:19 

128:13 129:3 130:15 

130:19 136:19 200:4 

201:7 327:17 351:2 

360:19,21 362:8 

operators 117:22 

119:11 121:6 204:2 

opinion 93:8 120:21 

223:16 257:13 268:21 

331:16 333:6,7 

opinions 330:18 331:4 

331:5 

opportunities 229:16 

236:20 249:17 

opportunity 4:19 23:11 

29:2 31:22 41:6 47:21 

53:10 97:17 111:6 

120:7 123:5 126:22 

132:2 166:13 169:22 

185:19 186:4 192:5 

207:16 227:17 320:13 

324:10 332:2 

oppose 10:16 142:8 

opposed 35:7 191:9 

259:22 304:18 306:17 

opposes 43:3 

opposite 140:1,8 

optimization 240:8 

option 25:14,22 51:9 

53:6 76:14 194:6 

245:21 

options 6:20 14:6 34:22 

52:15,18 53:3 163:7 

175:19 245:20 253:11 

oral 5:18 127:1 235:9 

oranges 265:1 

orcas 228:22 

orchard 6:13 74:14 

order 4:7 16:13 38:18 

44:11 45:10 107:7 

116:8 117:18 126:11 

201:16 212:2 218:19 

220:1 232:20 245:19 

250:21 272:21,22 

327:10 351:6 355:19 

357:1 

ordered 52:14 

Oregon 5:12 87:2 

111:17 

OREI 17:16 

organical 69:16 

organically 55:22 56:4 

113:1 131:11 143:14 

171:2 

organics 59:14 64:12 

79:20 114:3 142:4 

organism 209:1,3 

276:19 

organisms 172:11 

organization 109:21 

120:2 191:18,18 

198:4 258:7 307:8 

313:5 335:17 350:17 

organizations 118:6 

293:7,12 355:12 

357:8 

organized 108:14 

253:16 

organizing 87:7 

origin 189:1,17 191:7 

258:15 

original 11:1 12:12 

15:19 19:17 27:12 

142:12 144:6 282:12 

285:9 

originally 27:8,17 

153:13 287:11 

origins 143:11 

Orlando 40:22 44:8 

45:7 

Oscar 61:8 76:22 77:3 

81:16 

OTA 158:9 194:22 

249:10 

outcome-based 122:17 

outcomes 260:18 

315:21 342:22 

outdoor 236:9 

outfox 83:11 

outgrowth 257:11 

outline 197:19 

outlined 41:17 109:13 

121:5 202:22 203:1 

outreach 167:16 

outside 77:22 220:3 

296:12 323:11 357:12 

368:7 

outsmart 83:11 

over- 132:10 

over-harvest 135:9 

over-harvesting 132:16 

137:10 

over-production 75:6 

overall 7:9 9:20 112:9 

148:8 316:18 321:9 

324:13 

overarching 327:20 

overcome 171:6 

overextended 128:21 

overlooked 319:8 

overnight 37:7 

overseas 58:21 315:4 

overseen 128:14 

oversight 3:11,11 9:15 

127:15,18 129:16 

199:2 312:8,11,12 

313:1,9,9 322:15 

324:18 325:3 326:17 

329:13,21 353:12 

354:13 371:8 

overt 325:8 

overview 362:17 

Ovieda 4:16 5:7,7 8:19 

owned 23:7 209:11 

213:6 215:8 

owners 238:21 

oxalic 173:10,11 

oxygen 24:4 

P

P-R-O-C-E-E-D-I-N-G-S

4:1 

p.m 232:17,18 310:18 

310:19 379:6 

Pacific 5:21 6:10 7:13 

102:9 

package 63:2,7 69:16 

266:4,5 

packaged 43:20 

packaging 41:13 43:1,4 

43:7 44:6 

packed 156:5 

packers 5:11 8:6 

packet 243:19 

page 328:22 373:20 

374:1 

pages 223:5 

paid 366:9 

painful 308:8 

pairs 130:14 

palatable 160:3 

palm 5:22 

panel 3:13 142:5 

145:22 146:2 312:1 

312:21 344:3 376:5 

panels 376:9,9 

paper 180:4,17 181:4,6 

181:10,15 182:19 

Pardon 55:5 56:2 72:4 

158:12 

parks 65:2 

parse 336:19 

part 10:4 13:18 19:5 

56:13 57:2 66:20 84:2 

100:5 105:9 115:17 

123:11 205:1 216:22 

221:17 228:18 251:18 

253:17 260:7 276:13 

281:17 293:2 310:5 

318:1 330:6 334:1 

336:22 337:8 339:3 

340:3 350:20 357:6 

partially 254:11 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
406 

participation 297:3 

379:2 

participatory 166:8 

particle 210:15 

particles 210:18 

particular 6:19 81:13 

129:22 151:22 176:15 

181:9 204:18 285:7 

326:14 337:10 351:22 

352:2 

particularly 113:13 

121:6 131:6 202:20 

203:15 231:13 268:11 

303:20 304:9 331:13 

partners 77:22 201:9 

201:20 205:15 206:8 

206:15,16 247:10 

306:4 

partnership 14:1 

242:10 

parts 38:9 47:18 55:16 

105:2 109:9 113:21 

114:1 115:19 321:13 

337:4 

party 103:7 121:22 

124:4 253:19 286:13 

294:8 

pass 284:22 292:7 

328:14 

passed 189:10,13 

190:13 274:18 376:20 

passes 7:18 247:2 

274:4 283:9 284:19 

354:11 372:7 

passing 37:5 191:5 

258:22 355:20 359:17 

passion 63:10 225:17 

passionate 163:13 

227:20 

pasture 199:11 201:4,6 

patents 252:11 

path 38:6 108:4,18 

194:5 301:16 

pathogen 23:9 238:11 

pathogens 172:4,21 

238:13 

patience 196:13 

Patrol 322:20 

pattern 24:18 

patterns 95:15 260:17 

PATTILLO 2:12 

patulin 175:16 

Paul 1:9,9 2:9 20:16 

167:10 196:2 334:16 

pay 357:7 362:21 363:1 

paying 345:8 358:11 

PCC 141:15 

PCR 30:5 31:4,9 35:8 

250:21 

peak 75:2 

peanuts 181:6 

pears 5:11 6:3,9,15,18 

peek 312:14 375:17 

peer 121:20 126:10 

322:9,11 364:13 

peers 44:5 

pelleted 111:15 

penalty 46:13 

penetrates 91:16 

penetration 7:8 

people 12:21 34:16 

58:14 80:1,19,22 

81:19 82:2 83:10 84:2 

84:12 85:2,8 101:16 

101:19 110:2 152:14 

158:1 159:6 169:5 

178:13 181:16 182:5 

182:9 188:5 202:13 

212:18 218:20 226:14 

241:2 242:14 243:20 

252:1 256:5,9 259:9 

263:22 266:9 278:9 

279:20 280:12 287:9 

290:5 292:6 296:1 

297:12 299:4 305:6 

305:13 330:22 340:10 

352:14 362:13 365:16 

365:22 366:1 367:15 

367:22 368:5 372:14 

374:4 375:13 

peoples 196:13 309:12 

309:13 

peppered 155:20 

peppers 171:9,9 177:19 

178:18 179:3 184:16 

perceived 319:22 

percent 6:6 7:17 32:16 

56:19 57:6 61:2 62:5 

62:8 65:1,3 78:5 81:8 

87:15 98:8 131:12,14 

133:17 134:5,6 

186:20 187:2,6,12,18 

199:20 200:11 201:15 

208:19,20 213:1,1 

260:5 263:4,8,19 

320:15 335:11 

percentage 32:11 

136:19 263:3 

perception 140:3,11,11 

perchlorate 113:17,21 

115:1 

perennial 92:20 

perennials 67:6 261:14 

perfect 50:17 

perfectly 101:1 

perform 31:13 200:16 

performance 118:9 

performed 31:9,10 

period 21:5 22:6 73:22 

88:3,9 178:20 186:7 

189:4 191:16 229:7 

270:1 296:1 313:16 

319:20 332:12 

periodically 262:14 

permission 346:15 

permit 209:13 213:11 

213:11 215:11 

peroxide 24:3 

peroxyhydrate 23:15 

26:19 

persistent 130:11 

person 44:1 52:7 75:14 

90:3 131:4 157:10 

369:3 

personal 72:14 74:9 

223:16 224:18 249:8 

303:8 

personally 70:2 126:5 

127:20 224:22 270:6 

personnel 3:12 75:10 

75:20 129:17 312:13 

320:10 325:4,4,8 

339:8 354:14 356:2 

357:13 371:8 

perspective 15:15 

39:12 81:10 108:9 

166:13 198:1 199:19 

206:19 287:10 303:3 

303:15 305:21 306:15 

308:8 326:20 329:13 

331:2 350:6 

perspectives 304:4,20 

308:9 

pertain 28:19 339:9 

pertinent 105:2 

pervasive 115:2 129:5 

255:20 

pervasively 251:7 

pest 50:14 99:17,22 

100:3,16 101:3,10,17 

165:5 166:2 

pesticide 11:13 84:20 

168:14 200:10 205:9 

260:4 262:18 

pesticides 50:16 85:1 

169:5 170:10 176:12 

177:11 262:14 263:2 

263:6 

pests 99:8,12,13 100:2 

petition 17:11 18:20,22 

19:2,5 96:15 114:14 

116:17 148:17 172:15 

178:21 181:5,13 

189:9,12 195:7,11,12 

210:16 

petitioned 15:5 42:5 

178:19 195:4 

petitioner 207:14 

petitioners 171:6 

petitions 15:16 171:8 

petroleum 226:18,19 

226:22 

pH 7:7,20,21 8:2 92:8 

92:11 

Ph.D 2:9,11,14 

phase 15:20 

phase-in 296:1 

PhD 167:13 

philosophy 118:18 

119:3 

phone 253:7 345:12 

phones 343:22 

phonetic 74:11 

photographs 66:17 

phthalates 237:20 

phycologists 132:21 

physical 275:15 303:18 

phyto 184:2 

phytotoxicity 26:10 

91:11 

pick 74:9 

picking 71:13 74:14,19 

76:1 

picture 46:2,11 55:11 

60:2,6 63:15,19 99:10 

356:10 

pictures 52:2 

piece 197:6 234:15 

288:10 309:8 314:21 

343:5,15 367:20 

372:19 

piecemeal 197:6 

pieces 206:20 211:10 

234:11 339:5 

pilot 251:2 261:21 

pin 157:5 

pineapple 45:13 46:18 

47:1,5,18 48:1,3,10 

49:20 56:13 57:7,19 

58:12,13,15 59:9,13 

59:16 60:8 64:8,17 

65:8 66:13 67:8 68:4 

68:5 69:5,12 73:15,20 

74:7 75:9 76:1 78:6 

80:12 82:12 83:6 

85:16 86:8 87:6,18,21 

88:4,7,16,18,21 89:13 

98:3,8 100:15,19 

101:10 168:9,12,22 

169:3,14 185:21 

186:8,12 187:2,3,6,16 

187:21,21 188:4 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
407 

223:16,21 226:11 

342:5 378:21 

pineapples 57:14 58:20 

67:3,16,19 87:5,9 

89:7,8 169:8 186:15 

186:17 224:5 

pipes 49:13 

place 18:14 60:10 61:17 

118:3 121:22 124:6 

136:15 137:11 176:3 

187:16 218:21 220:17 

241:13 257:5,6,6 

260:2 264:1 275:9 

295:4 302:10 315:17 

321:10 332:9 343:4 

353:3 360:17 370:16 

placeholder 374:1 

placement 42:10 

places 108:21 137:22 

257:3,3 261:1 304:1 

356:17 

placing 114:15 

plagiarize 302:11 307:7 

plagues 91:5 

plain 144:12 145:2 

plains 52:4 

plan 11:10 121:8 

142:12 143:21 144:6 

144:9 161:19 250:14 

365:11 376:22 

planet 225:19 310:5 

planning 281:6 

plans 106:8,11 143:22 

plant 7:9,15 8:1,9 26:11 

26:11 55:17 60:14 

63:16 70:8 75:20 88:5 

91:10 92:13 93:6 

95:19 96:10 113:14 

131:20 133:8 134:13 

164:11 172:20 214:9 

252:9 266:17 

plantains 55:14 

plantation 48:21 59:17 

60:6,13,20 61:3 64:9 

64:12 70:8 74:2,6 

75:21 

planted 6:10 65:17 

67:16 68:3 75:18 

253:1 258:19 

planter 260:15 266:17 

planting 47:6,6 59:21 

60:1,9 67:8 68:8 

164:10 262:4,5 

plantlets 60:7 

plants 12:1 24:17 75:12 

95:18 132:8 172:12 

177:5 183:16 214:13 

215:2 276:21 277:1 

280:16 281:17 283:19 

plastic 55:18 59:22 

70:19,22 71:4,7,9,10 

71:15,19,21 165:22 

platform 373:17 

play 83:10 117:21 

120:11 123:20 

players 121:2 

playing 204:8 330:5 

please 49:19 60:15 

114:5 224:2 265:10 

269:4 271:3 298:4 

pleased 120:13 

plus 11:20 45:19 62:21 

106:6 

point 4:22 5:2 12:11 

19:14 30:22 35:7 

39:21 44:11 109:13 

109:14,15 125:14 

145:1 164:22 182:16 

184:14 194:13 204:11 

204:13 229:7 232:7 

242:7 245:22 253:15 

256:21 257:1 279:12 

294:20 301:8 303:17 

304:15,18 316:2 

318:10 329:11,15 

333:20 335:14 338:11 

338:21,22 349:4,7,11 

360:7 

pointed 236:9 296:5 

314:6,11 318:10 

pointing 318:18 322:11 

points 29:12 108:12 

109:2 135:8 248:9 

309:4 313:22 338:5 

poisoning 336:18 

poisons 226:17 

poker 330:5,8 

police 85:19 125:16 

policy 5:13 80:21 

148:13 188:1 225:9 

228:21 237:10 

polished 26:14 

pollinate 53:17 

pollinator 163:10 

pollinators 53:16,19 

164:15,19 165:6 

pollution 29:15 

pond 23:4 

ponds 24:19 

poor 26:3,8 122:14 

poorest 56:22 

poorly 358:11,16 

popcorn 74:5 

popping 74:5 

pops 85:15 

population 50:2 169:16 

201:17 

populations 85:1 

Porras 61:8 76:22 77:5 

79:1 

portfolio 341:6 

portion 133:7 234:15 

287:18 345:5 

Portland 87:2 

portray 367:17 

ports 9:22 206:1,1,4 

pose 348:11 

posed 302:15 

position 26:17 96:18 

108:5 123:17 132:17 

168:8 

positioned 186:11 

187:15 

positions 112:11 

191:19 

positive 25:6 31:8,18 

53:2 127:11 200:12 

211:1 315:15 354:19 

possibility 80:4 114:19 

possible 10:12 129:1 

130:17 253:9 268:4,6 

270:19 287:1 295:12 

296:22 346:2 376:14 

possibly 47:3 258:6 

279:19,22 

post-harvest 213:19 

post-secondary 356:17 

posted 109:20 198:6,9 

posting 197:22 198:2 

potable 24:7 25:11 

potential 25:4,13 37:22 

213:14 318:13 331:7 

332:1 376:13 

potentially 4:13 97:7 

222:15 295:22 321:19 

376:15 

pots 180:4 181:6,15 

182:19 

potting 166:1 

poultry 26:21 41:15 

215:7 235:20 236:2 

360:22 361:22 363:16 

pound 76:5 

pounds 46:10 60:13 

powder 95:7 

powdery 6:20 91:4,20 

92:2 95:21 

practical 270:19 

practicality 107:4 109:8 

109:16 

practice 63:6 73:16 

92:7 120:20 130:16 

172:17 190:3,8 

306:21 

practices 25:20 37:2 

49:10 59:15 63:1 

66:21 73:14 89:9 

104:2 111:21 112:8 

164:9 165:8 168:17 

170:13 172:11,14 

203:14 208:2 218:20 

238:17 305:7 307:12 

308:2 

Prairie 127:4 

pre- 147:1 

precautionary 119:4 

precedent 266:9 

precipitate 26:5 

precipitation 61:18 

Precision 167:20 

predominant 291:12 

preface 342:1 

prefaced 82:10 

prefer 198:9 253:6 

preferred 198:2 

premium 17:22 18:2 

preparation 16:8 59:18 

92:11 

prepared 41:21 204:6 

362:21 363:1 

prepares 359:12 

prescribed 171:15 

presence 250:5 271:11 

318:17 322:1 350:4 

present 1:12 2:2 4:6 

10:15 43:6 102:19 

116:6 132:10 207:17 

208:19 220:8 232:20 

235:5 252:13 310:21 

321:16 377:6 

presentation 33:11 

51:12 55:10 73:19 

345:5 346:9 

presentations 54:7 

presented 219:14 

257:15 314:1 347:12 

presenters 257:14 

presenting 241:4 

preservation 30:21 

33:4 

preserve 307:4,13,19 

president 45:12,16 

presiding 1:10 

pressure 100:16 171:21 

presumably 293:14 

pretty 21:20 23:5 65:5 

115:5 256:8 285:13 

286:1 290:4 304:13 

367:2 

prevent 212:3 238:12 

315:22 

prevention 106:8,11 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
408 

238:5,11 361:7 

previous 55:3 106:10 

235:1 244:10 247:8 

275:11 302:8 

previously 88:6 113:10 

245:11 319:15 

price 31:3 33:20 34:8 

35:7 346:4 

prices 103:14 104:12 

169:9 346:3 378:15 

primarily 16:19 144:14 

145:14 159:20 168:13 

209:16 215:2 

primary 144:16 146:9,9 

313:11 

principle 11:16 119:4 

print 374:13,16 

prior 285:6 

priorities 3:4 162:21 

163:18 164:1 234:7 

234:12,18,21 235:1,4 

239:14 240:15 241:8 

242:4,5 243:6,9,15 

244:8 245:10 324:16 

375:10 377:10 

prioritization 376:16 

prioritizing 12:3 235:1 

314:18 

priority 17:15 42:18 

43:12,13 118:10 

201:13 237:22 238:19 

241:4 355:11 359:7 

privacy 357:18 

private 25:11 348:13,16 

348:20 349:1,9 

privately 23:7 

privy 178:7 

proactive 10:13 16:4,10 

proactively 314:13 

probability 314:9 

probably 35:6 36:5 

82:16 106:13 136:7 

160:10 180:21,22 

182:14 205:19 206:11 

225:10 226:7 247:15 

264:3 268:7 270:4 

275:5 291:12 293:21 

297:11 299:14 301:15 

302:8 305:7 366:11 

Probio 56:15 

problem 56:5 71:1 

108:10 119:2 175:4 

257:13 294:18 342:22 

359:3 

problematic 177:4 

problems 22:4,13 26:6 

43:6 47:4 130:12 

243:14 254:13 260:15 

349:2 

procedures 33:14 

321:6,15 

proceed 245:14,18 

process 20:21 21:3 

38:22 42:17 54:8 72:7 

88:11 99:18,21 100:6 

117:7 119:19 120:6 

126:1 143:11 162:3 

179:2 184:18 186:3 

189:11 192:8,19 

193:9,22 194:8 

195:12,20 196:8,16 

200:4 201:1 209:20 

218:17 229:5,15 

231:3,19 242:9 

259:18,22 268:2 

278:12 286:3 287:1 

294:19 297:8 322:9 

323:3 324:1,3,6 

328:11,21 329:1 

330:1,2 338:13 

process-based 262:20 

process-wise 329:4 

processed 170:20 

223:2 

processes 90:15 

191:22 323:6 332:10 

processing 26:22 29:13 

29:16 35:5 145:5,10 

145:17 146:1,5,18 

207:20 208:1,4,5 

213:20,21 214:9,13 

216:11 218:6,17 

222:2,4 223:8 

processor 88:8 208:9 

processors 208:2 

211:1 215:3,3,4,7,21 

216:1,8 221:22 

223:13 

produce 87:2 101:18 

104:7,22 112:5 117:9 

118:19 131:9 174:4 

208:4,9 213:15,21 

215:3,4 262:19 

produced 88:16 142:20 

143:14 148:14 162:1 

171:1 176:13 177:6 

184:4 275:18 276:2 

280:9 

producer 33:1 56:12 

186:12 263:13 264:13 

295:17,19 

producers 32:12,13 

56:14,17 87:20 

168:20,22 169:19 

179:6,16 186:19 

187:10 188:6,7 

203:10 239:3 250:4 

263:2,6,9 286:15 

289:14 295:10 299:3 

299:5,18 343:12 

producing 24:2 

product 6:17 17:11,13 

25:20 28:13 31:21 

34:7 36:1 50:1 58:4 

75:2 88:13 97:7 143:3 

147:22 149:2 152:18 

156:5 178:10,11 

184:3,19 187:8 

200:18 212:21 215:20 

217:5 222:3 259:19 

259:21 292:2 293:13 

300:21 

production 3:7 6:1,2 

7:12 8:13 23:18 37:3 

41:18 48:5,8,20 55:15 

56:20 57:15,17,20 

58:5,9 59:13 64:21 

75:3 77:14 79:13 

82:12 85:3 88:17 89:5 

91:1 92:16 98:2,5 

99:6,22 104:21 105:5 

107:5 108:22 112:19 

112:22 127:5 142:15 

143:3 163:9 171:3,4 

172:10,10,17,22 

173:3 174:7 185:21 

186:10 187:7,9,17,20 

188:12 190:5 200:1 

207:21 219:11 226:11 

233:19 235:20 271:15 

274:20 285:3 289:3 

308:1,2 

productivity 66:10 

187:14 

products 8:12 23:10 

29:4,6,11,17 44:6 

57:10 58:15 71:21 

79:19 80:5,14 81:5 

89:1 90:19 91:10 

92:15,18 93:7,13 

103:13,16 105:8 

111:5,12,19 112:15 

117:3 143:17 148:3 

150:15 151:20 152:5 

153:1,14,18 156:6 

159:17 160:17,18,20 

169:10 171:7 183:16 

186:16 188:8 192:22 

199:12,21 201:4,14 

201:21 207:21 210:20 

240:4 262:15 293:4 

298:14,17 299:2,4,7 

303:22 304:1 322:22 

professional 122:20 

221:7,9 372:21 

professionals 352:20 

372:22 

proficiency 31:16 

profiles 351:4 

profits 165:19 

program 2:5,7,10,13,15 

5:20 13:22 18:6 29:1 

29:7 40:3,11 48:12 

54:11,14,16 67:9 

68:16 69:16 72:6 

74:15 87:14 90:11,14 

103:17 107:20 112:14 

121:20 122:2 125:1 

142:2 162:19 190:19 

192:16 193:9,11,22 

199:6,7,9,14 200:3,14 

200:17 201:19 202:20 

203:11,14,15 204:12 

205:1,5 206:17,22 

211:4 225:5 226:2 

240:6,18 241:4,12,22 

242:5 258:4 267:16 

268:3 276:11 278:16 

279:14 292:10 302:15 

305:18 311:14 320:21 

322:22 323:11 324:7 

328:8,13 331:2 332:6 

333:1,1,14,22 339:13 

339:15 344:19 346:13 

349:21 357:4 366:16 

377:7,7 

program's 305:20 

306:3 328:3 

programming 87:22 

programs 30:21 33:4 

202:22 208:3 332:9 

332:11 348:12,13,14 

348:19,21 349:12 

progress 106:19 114:6 

142:10 143:22 144:5 

161:20 166:10 

progressive 120:19 

prohibit 104:20 

prohibited 41:18 162:2 

162:2 223:3 252:15 

Prohibiting 168:21 

prohibition 114:6,14 

prohibitive 94:11 

264:16 

prohibits 144:13 

project 45:18 46:3 

56:21 251:2 277:17 

projecting 371:1 

projects 52:18,21 62:7 

163:3 

promote 37:3 106:17 

170:12 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
409 

promotes 120:4 171:3 

promotion 42:14 173:1 

promptly 102:11 

pronounce 237:20 

299:12 

proper 16:13 49:11 

92:12 147:8 

properly 54:12 

property 295:10 

proponents 37:2 

proportion 170:19 

proportions 171:14 

proposal 32:7,9 80:15 

80:18 106:21 107:1,6 

107:11 108:1 109:3,9 

120:13 121:5 122:19 

127:14,16,22 128:12 

144:3 161:16 235:15 

246:7,8 248:16,22 

249:21 250:5,21 

253:13,17 254:5 

257:12 258:5 262:13 

262:17,22 265:16 

267:7 268:16 270:4 

270:17 272:15 275:8 

280:15,18 281:17,22 

282:4,9 283:15,22 

312:10 325:11 339:17 

353:11,13 359:16 

371:6,9 

proposal's 108:8 

proposals 127:9 197:7 

378:12 

propose 144:8 

proposed 14:19 28:20 

31:17 144:9 178:2 

189:11 190:16,17 

191:1,9,11 195:13,14 

196:3 336:6,7 337:11 

proposing 182:15 

183:13 

propping 103:10 

proprietary 252:12,21 

252:21 

protect 11:16 39:20 

45:10 90:13 105:12 

106:15 118:3 155:8 

173:1,5 252:7 255:7 

308:19 352:15 362:19 

362:19 373:1 

protected 65:2,4 

protecting 309:2 

protection 155:8 173:2 

252:12 

protective 95:15 

protects 39:15 300:19 

proteins 30:18 35:20 

protocols 49:15 121:13 

122:4 

prototype 165:14 

proud 52:6 

prove 210:20 

proved 92:9 106:12 

proven 112:1 

provide 32:1 80:6 88:7 

120:8 121:7 124:8,13 

126:7 127:1,18 132:2 

135:5 171:21 185:19 

192:6 201:20 221:5 

229:8 231:7 240:11 

250:10,13 253:20 

255:13 269:4 296:9 

313:2 322:21 345:7 

347:10 356:18 372:17 

375:11 376:7 

provided 140:13 187:2 

253:6 270:13 288:17 

355:7 377:3 

provides 7:3,9 29:2 

120:3 199:2 

providing 38:10 189:4 

239:19 254:3 319:11 

322:2 

province 258:14 

provision 143:21 

304:17 

public 3:2 4:8,9,15,18 

25:10 27:20 29:5 39:2 

83:16 84:6 107:14 

138:17 149:20 196:10 

196:14 197:14 200:22 

211:11 223:11 227:17 

231:12,16 232:6 

233:22 235:17 237:7 

237:17 238:20 240:19 

244:16,19 267:13 

269:14 270:2,12 

280:7 281:7 285:1 

287:17,20 289:17 

290:10 309:7 312:2 

313:16 319:2 322:10 

324:22 330:20 334:2 

339:13,15,18,20 

358:2 359:4,6 374:20 

377:2 379:1 

public/private 242:10 

publically 209:11 213:5 

215:8 

publicize 350:8 

publicly 250:17 

publish 243:1,18 244:9 

244:14 329:14 376:9 

pullulan 116:17 117:1,5 

117:10,12 

pump 217:12,13 220:8 

pumping 220:16 

pun 298:11 

punished 341:3 

pura 50:3 

purchase 115:8 151:11 

purchases 43:19 

154:20 

purchasing 29:22 

pure 207:13,21,22 

purity 107:18 247:8 

250:7 253:3 254:1,3 

255:9 258:15 259:1 

purpose 144:17 252:7 

255:19 257:22 

purposes 50:20 114:10 

308:21 

pursue 362:2 

pursuing 309:18 

purview 291:15 296:13 

302:17 

push 142:10 

pushed 67:4,18 

pushing 70:4 161:15 

put 8:21 11:17 22:3 

67:15 68:18 75:10,14 

75:19 78:8 80:17 

100:7 109:22 114:14 

118:3 136:15 194:15 

215:22 243:15,19 

248:17 254:10,11 

274:9 276:1 278:16 

286:19 300:3 301:22 

330:21 362:22 373:6 

377:1 

puts 64:9 78:15 318:6 

putting 112:14 173:14 

253:3 357:8 

PVC 49:13 

PVP 193:2,15 

Q

QA 363:3 

QCS 225:16 

qualifications 122:10 

122:19 126:13 312:7 

322:12 324:17 

qualified 122:14 

quality 17:22 26:3,3 

31:21 48:17 50:13 

120:3 123:16 128:22 

129:11,13 130:18 

165:21 167:17 210:6 

221:8 225:6 321:10 

321:13 335:18 351:7 

quantify 30:17 153:21 

154:22 

quantitatively 336:12 

quantities 290:20 291:3 

quantity 305:2 

question 8:16 16:9,14 

16:22 18:21,22 21:9 

35:18 53:16 56:9 

58:18 66:8 68:21 

73:12 79:11 89:19 

93:11 94:3 96:2,14,20 

114:22 126:8 131:4 

138:4,16 144:20 

146:16,20 149:12 

152:22 153:21 176:7 

177:18 179:9 180:4 

183:12,13 195:2 

202:9 204:5 211:6 

215:13 228:1,7,8 

252:17 264:12 279:17 

298:21 302:15,18 

305:2 328:8 334:15 

334:18 339:12 341:22 

342:16,19 348:9 

359:11 

questions 5:2 8:15 12:8 

27:2,16 32:1,7,14 

39:8 43:17 46:16 

53:12 58:7 64:15 

73:14 78:21 79:3,14 

81:21 89:3 100:11 

105:16 107:16 113:7 

119:8 123:8 135:7 

138:22 149:15 155:6 

155:19,21 162:9 

170:2 173:9 174:10 

174:22 185:6,8 

188:15 192:13 197:3 

202:5,8 220:19 

224:10 229:20 239:7 

253:10 277:22,22 

328:5 332:18 351:21 

352:4 358:2 

quick 4:17 58:18 

124:18 197:5 265:13 

349:8 352:6 368:4 

quickly 103:20 113:15 

171:20 268:4 289:22 

301:7 

QuickScan 30:19 

Quirce 170:5 185:12,14 

188:18 

quite 79:11 93:11 110:7 

144:4 194:7,12 

236:12,17 237:13,17 

249:19 252:11 254:15 

271:5 275:12,21 

304:15 322:18 328:17 

333:20 348:10 358:2 

quo 301:13 

quorum 310:22 

quota 18:5 

quote 160:10 161:3 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
410 

quoted 151:4 

R

R&D 167:19 221:8 

radiation 275:20 276:6 

279:6 

radio 309:8 

RAFI 9:8 

rail 201:16 

rain 61:18 

raise 126:12 180:11 

raised 145:1 180:10 

299:21 350:3 

raising 240:18 

Ramirez 47:14 51:19,20 

51:22 52:1 53:18 54:1 

54:10,14,19 55:9 56:6 

ran 147:18 270:16 

ranchers 240:3 

randomly 74:19 

range 33:17 94:8 

113:15 133:16 160:5 

297:2 305:5 321:14 

346:12 

rank 314:8 333:8 

334:17 336:1 

ranked 314:3 333:9 

ranking 318:19 376:15 

rapid 133:9 209:5 

rat 342:14 

rate 133:20 187:12 

rates 118:1 133:10,16 

136:18 304:11 

rating 331:19 

rats 154:6 

raw 30:18 238:11 

re- 190:6 

re-emphasize 124:5 

re-listing 114:5 

reach 49:5 

reached 187:4 

reaching 61:21 231:17 

react 153:6,7 

reacting 314:15 

reaction 96:10 154:21 

327:20 

reactions 148:3,10 

152:7 154:19 

reactive 217:6 

read 180:16,18 231:7 

241:2,3 271:3 276:17 

283:15 339:19 356:9 

reading 33:13 144:12 

145:2 342:9 351:22 

reads 145:3 

ready 54:18 94:16 

123:2 245:2 370:3,5 

370:21 

readying 181:3 

real 24:3 104:5 190:20 

228:17 265:13 297:14 

319:21 329:21 339:4 

348:18 349:8 351:6 

357:9 362:13 368:4 

372:13 

real- 9:15 

real-time 35:9 

reality 301:9 

realize 292:12 346:9 

realized 17:3 33:14 

288:22 

realizing 144:8 

reallocate 327:11 

reason 78:2 95:20,22 

101:8 134:17 161:9 

223:20 285:12 

reasonable 106:11 

108:3 

reasons 16:19 75:8 

94:5 317:4 

Rebekah 119:17 126:17 

126:18,21 

recall 158:19 160:16 

312:1 

recast 199:17 

receive 201:16 236:11 

236:16,17 242:17,20 

255:12 275:12 318:2 

received 97:4 120:9 

190:17 191:9 195:14 

211:11 235:21 236:7 

261:8 313:14,19 

320:8 334:2 338:5 

359:16 376:8 377:12 

recently-disturbed

308:20 

reception 378:18 

recess 102:12 310:15 

378:4 379:3 

reclassification 117:5 

recognize 130:13 

197:17 202:11,19 

210:13 285:5 289:4 

290:7 

recognized 6:11 31:9 

62:14 134:21 203:4 

208:16 220:14 307:9 

recollection 343:21 

recommend 283:16 

334:8 

recommendation 31:12 

37:6 186:1 189:13 

194:16 195:20 197:21 

recommendations 10:6 

11:2 12:14,14 190:13 

198:1 200:20 239:20 

242:2 

recommended 19:18 

210:5 236:1 254:22 

356:16 

recommends 121:15 

reconsider 12:2 

record 5:6 57:21 68:1 

102:16 103:1 132:20 

232:17 310:18 379:6 

recover 289:21 

recreate 144:14 146:10 

recurrently 88:13 

recusals 245:22 

Recuse 245:21 

recycled 180:17 

recycling 71:17,20 

red 4:21 299:14 327:1 

348:19 

red-flag 327:12 

reduce 7:20 30:15 31:5 

60:17 68:18 124:19 

175:14 176:11 177:10 

reduces 91:11 

redundancy 124:20 

refer 23:16 42:6 109:12 

272:4,13,20 273:1,5 

reference 30:6 42:15 

46:6 158:8 330:9 

referenced 158:18 

190:15 

references 27:7 277:7 

280:13 

referendum 227:13 

referred 154:6 156:18 

274:4 

referring 156:16 

refers 160:16 

refinement 107:1 

reflect 191:21 199:10 

358:16 

reflecting 325:19 

reflective 34:8 

reflects 38:16 

refresh 194:14 

refute 148:9 154:2 

reg 339:4 

regard 125:19 156:10 

257:3 

regarding 92:21 95:12 

118:6 124:11 127:14 

129:16 185:20 201:5 

201:14 205:18 221:11 

316:22 317:20 320:17 

regardless 49:9 76:9 

293:21 296:19 

regards 112:13 177:19 

189:22 

regimen 226:4 

region 61:17 125:17 

126:14 251:9 299:11 

regional 163:14 

regions 107:5 113:13 

251:15 

register 374:4,8,9 

registered 200:3 201:6 

registrations 210:9 

regrowth 133:9 

regs 325:19 338:2,8,9 

341:7,12 356:8 

regular 326:7 

regularly 69:1 

regulate 50:15 139:19 

290:2 

regulated 133:13 

134:20 

regulates 140:19 

regulation 93:15 105:3 

156:4 169:18 215:1 

260:2,8 271:10 

regulations 15:17 50:1 

103:22 125:12 136:17 

171:6 179:15,15 

188:3 205:9 290:2 

325:17 338:18 

regulator 16:18 85:12 

regulatory 5:13 40:5 

90:15 106:19 116:4 

126:21 130:11 131:19 

179:2 219:9 268:2 

306:11 307:21 

reimbursing 200:5 

reincorporate 63:22 

reinvent 80:2 124:3 

reinventing 124:20 

reiterate 27:21 91:17 

318:14 

reiterates 242:10 

reiterating 124:19 

reiteration 281:1 

reject 303:6 353:14 

371:10 

rejected 252:6 

related 156:3 157:9 

205:6 229:21 

relates 278:6 316:18 

relating 60:21 

relation 217:20 240:12 

315:3 

relations 29:1 

relationship 13:7 142:4 

206:6,18 306:10 

relative 32:16 199:11 

204:14 

relatively 218:15 317:8 

release 60:19,19 78:1 

357:20 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
411 

released 34:3,6 190:17 

195:13 268:2 

releases 192:3 

releasing 74:4 

relevant 156:1 

relist 174:1 

relisting 142:8 

rely 296:14 

remain 10:1,20 22:15 

38:22 58:4 112:17 

210:3 

remaining 107:16 209:6 

213:3 341:16 

remains 123:2 

remark 305:20 

remarks 155:4 196:6 

239:11,13 

remedial 261:4 

remember 69:22 79:10 

151:2 157:14 287:8 

305:1 326:18 345:12 

remind 266:15 280:7 

311:5 378:17 

reminder 4:17 

reminders 354:21 

reminds 328:10 

remiss 295:6 

removal 55:18 

remove 11:22 71:16 

133:7 281:15,21 

removed 133:15 277:7 

removes 133:20 

removing 91:18 280:13 

rendered 209:16 

renew 66:22 

renewal 21:4,6 42:10 

renowned 132:20 

repeat 274:17 

repetitioning 9:11 

replace 27:9 51:3 

replaced 75:1 150:11 

replant 89:9 

replicable 138:7,8 

report 29:10 81:17,17 

136:22 158:9 212:20 

344:8 358:12 

reported 213:4 

reporting 129:9,15 

314:18 315:3 316:22 

317:2 

reports 148:1 150:21 

154:3 321:1 351:16 

351:20,22 

represent 8:7 17:6 81:3 

116:15 141:15 167:21 

261:21 

representative 23:4 

97:20 185:16 261:17 

represented 187:6 

represents 5:10 78:5 

87:15 186:21 

republic 80:21 

reputation 127:20 

362:19,20 

reputational 334:20 

336:18,21 337:8 

reputationally 337:6 

request 43:12 88:1 

149:3 164:7 165:9 

166:5 189:22 191:4 

191:14 278:15 279:14 

279:17,19 290:15 

315:13 

requested 277:11 313:2 

315:6 

requesting 236:4 

require 104:13 113:13 

130:22 142:16 146:12 

179:16 189:9 210:19 

264:21 273:2 294:12 

required 28:22 31:14 

106:15 210:2 212:19 

250:12 263:3,7,10 

314:18 317:3 

requirement 29:16 

121:6 130:8 146:4,13 

146:18 262:2 263:13 

requirements 116:18 

118:5 143:18 188:9 

252:10 262:13,22 

263:1 315:18 317:6 

320:18 331:17,18 

requires 30:2,8,9 87:22 

requiring 32:9 118:16 

195:8 260:7 294:17 

rescue 276:21 280:16 

280:19 281:17 283:19 

research 3:4 12:3 16:4 

17:15 19:21 51:2,8 

52:14,18,21 53:6 

63:14,18 76:14,15 

92:21 94:6 97:19 

117:8 133:1 138:19 

154:2 162:17,19,21 

163:1,12,17,20,22 

164:3,8 165:3,10,17 

165:20 166:5,5,10,20 

167:16 225:14,15 

227:9 233:14 234:7 

234:12 235:6 236:10 

237:22,22 238:19 

239:14,20 240:5,15 

241:4,8,13,14 242:4 

242:15,17 243:6,9,15 

244:8 245:10 325:2 

research-based 163:15 

researcher 140:13 

researching 91:22 

reservations 298:4 

reside 23:2 

resident 33:15 

residents 295:7 

resides 241:14 

residue 260:4 315:16 

316:16 

residues 168:15 200:10 

262:18 

resistance 171:13,22 

172:5,8 175:6,21 

176:1 209:5 219:6,10 

219:19 220:2,6 

resistant 171:15 

resolution 191:5 

268:10 

resolved 38:15 

resource 28:16 137:11 

137:13,21 140:15,17 

140:19 339:22 

resources 118:4 203:5 

300:3 321:20 326:2 

326:20 327:11 332:7 

368:7 

respect 157:1 318:6 

330:22 333:10 

respectfully 186:5 

191:14 

respective 322:13 

respond 87:19 117:14 

243:16,21 265:14 

270:9 301:5,7 308:4 

315:12 335:6 368:3 

responded 316:5 

responds 87:18 

response 78:22 105:17 

126:7 188:16 224:11 

315:10,11 316:3 

322:16 343:2 

Responses 45:4 51:20 

responsibilities 10:18 

108:14 306:7 

responsibility 107:17 

366:12 376:15 

responsible 23:9 25:22 

109:16 226:8 

responsibly 327:11 

rest 55:18 73:19 

resting 64:3 65:19 66:2 

66:5 

restricted 18:18 146:4 

restricting 18:22 

154:19 

restriction 210:15 

212:12 

restrictions 26:10 

restructuring 128:19 

result 30:15 31:4 35:9 

53:2 128:21 134:15 

156:21 260:18 276:11 

276:16 327:10 

resulted 227:4 

resulting 171:16 

results 8:5 30:12 53:1,9 

108:19 113:16 115:18 

209:4 237:9 315:16 

349:6 

resumed 102:16 232:17 

310:18 

resurface 14:21 

retail 113:18 115:12,16 

205:12 

retailer 115:13 141:16 

141:19 

retailers 150:11 

retain 23:17 255:5 

282:11 

Retaining 254:20 

retard 15:12 

retire 370:16 

revelation 190:3 

review 41:11 42:3,6,9 

42:12,17 43:10 106:7 

117:6 129:17 163:22 

172:19 183:1 191:22 

233:17 235:13 242:21 

243:5 280:8 293:7 

296:15 320:21 338:20 

340:17 354:14 356:1 

356:15 358:21 361:10 

361:12 368:14 371:8 

378:12 

reviewed 16:16 42:5 

136:20 281:9 

reviewer 3:12 120:4 

293:12 312:6,13 

374:11 

reviewers 120:14 

122:12 356:8 360:2 

373:3 

reviewing 168:8 173:13 

196:14 361:12 

reviews 128:22 137:7 

322:10,12 323:4 

revise 269:4 

revised 104:19 

revisions 269:8 

revocation 336:7 

337:12 

reward 22:5,9 

rewarding 21:11 22:15 

rewards 10:1 

Rica 45:7,17 47:19 51:4 

52:4,17 53:19 56:12 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
412 

56:15,20 57:7 61:17 

62:11,13 63:20 64:18 

64:22 66:5 67:3 69:4 

71:18 72:18 77:8,10 

77:21,22 78:7,11 

79:13 81:5,15 83:15 

84:21 85:2,13 86:8 

87:1,4,13,16 97:21 

98:1,9,12 102:1 125:9 

125:22 167:12 185:15 

186:11,17 187:9,15 

187:19 224:5 231:15 

Rica's 186:15 

Rican 65:3 78:9 

rice 1:13 24:13,15 

26:12,13 27:7 28:1 

124:18 246:13 273:12 

274:2 282:16 283:7 

284:3,17 311:3,12 

328:2,17 330:11 

334:13 339:11 340:2 

341:21 343:1 345:18 

346:7 348:8 349:12 

352:3,22 353:6,9,16 

354:9,12 359:10,18 

361:15 363:14 364:6 

366:20 368:3 370:20 

372:3,5,8 375:16,22 

377:16,22 

Richardson 285:7 

Rick 1:16 114:21 

177:17 179:8 301:6 

304:21 334:13 371:5 

ridiculous 106:14 

rigid 175:1 

rigorous 122:22 

ripe 74:14 

ripened 74:10,19 99:3 

ripening 98:15 99:4 

rise 9:9 

risk 14:2 91:11 106:7 

128:6,8,9,11,15 129:9 

129:14 173:4 176:2 

177:1 249:10 264:21 

307:12 312:8,11,22 

313:4 314:4,7,8 

315:20 316:12,16,22 

317:4 318:12,15 

319:5 320:20 321:5 

321:19 322:6 325:9 

326:3,19,21 327:2,3 

331:9,16,19,21,22 

332:1,17 333:1,11,12 

333:13,18 334:3,6,10 

334:19,20,21 335:3 

336:15,16,18,19 

339:9 340:14 341:11 

347:7 349:22 350:5 

350:16 351:4 352:8 

risk- 341:5 

risk-based 3:10 22:3 

121:16 127:15 323:16 

324:18 325:3,5,16,22 

326:11,17 329:13,21 

337:14 340:4,16,20 

353:11 

riskiest 335:2 

risks 165:19 176:5 

326:13,16 330:18 

331:7,11 

Ritson 119:17 126:18 

126:20,21 131:2 

river 1:8 32:21 

Riverfront 1:9 

road 370:8 

roadmap 376:13 

Robert's 272:21,22 

robust 208:3 321:15 

335:20 340:4,16,21 

344:8 358:7 377:12 

rock 18:14 239:4 

rockweed 139:19 

140:10 295:14 

Rojas 40:22 45:4,6,7 

46:19 47:5 

Rolando 51:19 56:11 

role 120:11 121:21 

123:20 125:2 204:8 

261:17 306:3 

ROMERO-BRIONES

1:18 157:8,16 177:18 

246:22 273:21 283:3 

284:12 302:14 303:2 

354:3 371:20 

room 4:5 46:9 49:4,8,13 

104:2 180:6 245:14 

245:18 246:2,4 

root 211:13 

rooted 118:17 

rot 6:18 

rotating 91:10 226:4 

rotation 17:8 46:21 

47:7 48:21 55:2,6 

56:4 63:19 89:14,17 

89:17 91:8 111:22 

163:6 

rotational 73:14,15 

76:9 

rotations 89:5 

rots 175:14 

round 70:1 226:5 319:9 

352:22 370:18 

route 193:2 198:2 

routinely 69:1 

row 46:19 262:2 

rule 31:17 136:5 189:11 

189:12 190:9,16,18 

190:21 191:1,7,10,11 

195:14,15,17 196:3 

199:11 201:4,6 

368:19 369:5,7 

rulemaking 186:3 301:1 

rules 62:12 77:18 78:1 

78:3 136:8,15 195:14 

196:7 272:21,22 

ruling 78:14 

run 4:9 33:5 45:18 48:3 

62:19,20 193:8 266:8 

267:16 287:12,12 

332:11 

running 16:13 31:1 

275:6 331:1 378:8 

runoff 26:9 

runs 218:17 378:22 

runway 16:10 

rural 104:10 

rush 52:22 

russet 6:14 

S

S336 143:5 

sacrifice 12:5 300:18 

sacrificing 31:7 

sad 304:6 

safe 168:19 210:12 

safety 24:5 25:14 42:15 

49:11,16 52:8 101:5 

188:10 205:5 206:19 

208:1,3 366:4 

safflower 158:6,10,13 

158:17,21 

Saint 1:9 

salads 113:4 

Salas 61:8 76:22 

sale 256:14 

sales 87:15,18,19 

salmon 229:1 

salt 212:6 

salts 209:18 

sample 113:19 115:1,2 

115:20 116:3 121:7 

130:7 255:3,10,13 

samples 31:16 34:17 

115:12 200:9,12 

250:17 254:20 267:3 

316:17 

sampling 28:18 31:1 

115:10 266:21 315:16 

315:16 

Sandra 111:2 116:12 

sandwich 234:10 310:9 

Sandy 116:14 

sanitation 184:3 

sanitizer 207:22 216:18 

233:10,22 

sanitizers 41:11 42:1 

Sarapiqui 48:4 

sat 344:14 

satellite 9:22 313:11 

350:4,11,13 

satisfy 36:2 269:9 

save 23:16 255:3 

saved 183:5 

saves 229:14 

saving 42:16 

saw 17:7,19 153:6 

282:8 312:20 

saying 21:4 28:1 67:22 

82:10 84:7 123:19 

146:14 150:6 153:15 

180:7 194:13 211:12 

215:21 275:1 295:11 

338:8 369:12 

says 43:21 138:8 254:7 

263:10 267:7 294:22 

361:17 

scab 6:18 

scalability 262:7 

scale 211:21 287:13 

schedule 54:17 

Schwartz 1:19 116:3 

198:22 246:21 273:20 

283:2 284:11 354:2 

371:19 

science 167:13 281:11 

science-based 134:19 

169:17 

scientific 30:9 31:11 

132:15 

scientist 28:13 131:19 

140:15 

scientists 57:12 132:21 

134:18 135:10 137:3 

137:4,19 139:3 

163:12 

scope 95:4 121:10 

236:18 296:13 297:4 

362:2 

scope-wise 361:18 

scopes 360:9 

scorecard 314:7 

scored 129:20 

Scotia 131:20 134:2,4 

139:6 140:1,9,14 

141:2 

Scott 1:13 124:17 263:5 

311:3,4 353:9,15 

377:19 

Scott's 228:10 

scout 156:12 

SCP 23:16,19,22 24:5 

24:14,21 25:3,8,13 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
413 

screen 371:2 

scroll 277:17 347:15 

scrutiny 290:13,17,21 

317:19 318:18 323:19 

334:12 

SDC 207:19,21 208:6 

208:10,11,18 209:9 

210:18,20,22 220:5 

220:12 

se 218:18 322:6 

Sea 347:5,6 

seal 65:9 105:10 

Seaplants 131:19 

135:18 

search 155:21 

searchable 293:14 

searching 45:14 

season 7:5 104:9 163:7 

165:18 252:5 264:15 

370:8 

seasonal 73:22 

Seattle 141:17 

seaweed 38:8 93:7 

118:2 134:20 135:22 

139:2 228:18 229:5 

238:22 286:8 291:20 

292:4 293:5 294:4 

298:14 303:13,19,20 

304:12 

seaweeds 116:17 

117:16 289:19 303:11 

second 32:10 37:18 

52:20 80:3 167:4 

186:15 187:8 201:14 

248:5 253:5 272:6,13 

281:19 311:5 

secondary 255:11 

seconded 245:7,8 

283:12,14 353:9 

371:5 

secrecy 142:19 

Secretary 1:13 191:6 

192:16 200:21 

section 15:5,16 185:4 

280:15,17 282:9 

287:7 368:18 373:4 

377:21 

sections 282:7 311:7 

sector 116:21 123:7 

133:18 137:6,8 

163:14 176:13,18 

177:6,7 301:3 

sectors 137:2 337:4 

secure 188:10 

security 48:20 

seed 3:5 28:21 29:14,17 

29:18,21 30:4,5,13,18 

31:13 32:11,12,19,22 

33:1,1 56:10 106:16 

108:16,21 110:6,19 

130:22 131:1,10 

148:18 171:8 229:13 

229:16 234:7 247:6,8 

249:1,6 250:3,9,10,11 

251:10,13 252:22 

253:2,3,19 254:2,20 

255:22 256:3,4,9,10 

256:13,14 258:15,18 

258:19,22 259:6 

260:14 262:8 266:16 

267:8,9 269:20,20,21 

270:13,21 271:12 

272:14 355:4,5 

seeds 229:14 261:22 

277:1 

seeing 19:9 138:17 

140:21 152:4 153:7 

203:22 245:5 283:10 

317:15 367:22 

seek 31:21 43:20 

seeking 118:19 319:13 

seen 27:11 63:3 80:18 

81:1 84:22 103:6 

105:3 139:6,9 205:19 

208:5 314:5 321:11 

323:8 360:1 

sees 320:22 

segment 331:8,11 

334:11 

Seitz 1:20 15:2 70:19 

83:4 109:20 139:22 

140:7 147:18 148:17 

149:5,7 159:2 160:4 

194:12 196:1 246:15 

247:9 273:14 282:18 

284:5 353:18 371:13 

selected 60:4 

selection 121:17 

171:21 

self-grass 221:15 

sell 215:21 216:8 266:3 

271:12 

semantic 39:20 

semis 225:2 

send 34:16 35:5 71:17 

167:5 213:5 273:4 

315:5 

sending 31:3 35:7 76:4 

368:16 

senior 9:8 116:16 

sense 33:17 157:3 

160:10,12 169:18 

170:18 193:7 206:18 

269:14 280:12 299:6 

325:7 345:3 352:1 

364:3 

sensible 75:6 373:7,10 

sensibly 107:2 

sensitive 75:6 151:19 

sensitivities 152:15 

sent 242:7 

separate 55:14 275:22 

276:15 338:22 

separately 62:20 

separation 319:21 

septic 214:9,16 215:14 

217:2,7,13 

sequence 36:12 

sequences 30:7 

sequestration 236:20 

Serbia 345:18,20 

series 155:18 

serious 43:3 

servants 83:16 

serve 122:1 342:6 

served 10:19 226:3 

server 373:21 375:12 

service 2:8 14:1 31:22 

39:5 46:12 93:2 129:4 

142:1 155:2 166:15 

270:15 319:11 

services 46:4 164:13 

198:18 199:1,4 

204:17 225:6 308:21 

309:3 318:3 319:14 

321:21 322:3 

serving 50:19 

session 189:19 310:22 

344:15 345:14 

set 37:11 38:4 110:15 

142:12,13 145:4 

271:18 315:18 324:21 

359:7 378:15 

sets 108:3 

setting 6:13 144:8 

176:10 242:5 268:14 

355:12 

settled 88:9 

seven 6:3 33:19 200:13 

severity 314:10 

sewer 214:10 

shake 153:2 

shaking 184:15 

shape 228:14 

share 51:12 52:1 107:9 

147:10 166:13 173:11 

200:5 203:1,13 204:6 

205:12 225:12 251:14 

298:4 319:1 330:14 

shared 113:16 208:9 

219:17 249:11 324:15 

376:22 

sharing 107:2 239:17 

241:22 

shed 133:21 

sheet 346:18 

shellfish 138:11 

Shelly 28:11 36:18,20 

shelves 74:22 

shift 22:2 

shifted 309:11 

shifting 347:4 

ship 59:1 201:16 

350:18 

shipped 58:20 225:2 

shipper 103:6 

shippers 5:11 

shipping 103:4 

ships 350:19 

Shistar 167:8 170:4,8,9 

173:17,20 174:8 

175:2,18 176:16 

177:8,12,14 178:8 

179:14,19 180:1,7,16 

182:21 183:7 185:9 

shit 227:21 

shore 133:18 

short 18:14 19:10 

268:19 297:10 339:20 

short-term 140:22 

shortened 189:4 

shorter 22:7,8 234:15 

shot 248:5 

shout 230:17 352:17 

show 77:12 91:9 111:18 

140:20 142:10 144:13 

161:19 203:1 223:1 

256:7,8 277:6,9 302:9 

372:13 

showing 26:13 66:18 

330:6 

shows 68:11 374:14 

shred 63:22 70:9 

shredded 64:7,12 

shredder 70:16 

shrink 118:21 

side 24:5 111:17 321:22 

339:22 340:1 365:5 

side-by-side 237:5,9 

side-spread 44:3 

sides 327:5 359:20 

sign 318:13 

significant 6:8 91:19 

100:20 128:12 235:3 

235:21 321:2 

significantly 235:16 

silver 96:15 172:1,6,8 

207:14 208:12,19,21 

209:2,6,18,19,22 

210:3 211:21,22 

212:1,4,6,7,8,13 

213:1,7 216:12,19 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
414 

217:5,8,9 218:16 

219:4,19 220:3,6,7,9 

220:13 

silver's 215:1 

similar 55:7 219:9 

316:14 328:20 334:7 

Similarly 261:6 

simple 273:2,3 282:2 

simplify 83:21 

simply 122:18 154:1 

211:21 214:21 220:6 

335:9 

single 109:15 352:21 

sir 82:22 

site 7:16 35:9 

situation 40:5 138:5 

175:3 191:13 288:18 

291:10 292:22 300:2 

367:8 

situations 112:3 367:1 

368:13 369:2 

six 45:2 60:13 64:4 

114:1 190:13 225:10 

size 9:17 18:6 60:5,7,14 

76:3 99:19 210:15 

211:19 309:10 318:4 

351:1 

sized 186:21 188:6 

sizes 98:12 101:2 

sizing 76:2 

skill 121:5 325:22 355:9 

375:9 

skilled 30:8 

skills 121:3,10 129:21 

293:18 356:18 357:1 

357:16 366:22 

skip 147:16 

slide 13:3 111:18 

118:15 164:17 

Sligh 4:16 9:3,7,8 12:13 

14:5 15:18 16:20 

18:19 19:2,17 21:15 

22:18 28:4,7,9 

slight 73:21 

slightly 71:8 213:12 

slower 68:6 

sludge 209:22 213:3 

217:13,14 

small 18:1 36:22 47:17 

49:9,16 65:5 85:13 

87:7 99:10,16 168:22 

170:19 183:5 186:21 

188:6 215:10 226:12 

231:17 238:4 262:1 

263:18 265:7,7 

266:21 290:19 309:11 

357:8 

smaller 65:4 87:19 

smallest 35:3 

smoke 53:4 226:14 

sneak 312:14 372:14 

375:17 

so-called 159:16 160:7 

social 225:8 

society 164:18 367:4 

sodium 23:15 26:18 

113:11,17 114:6,14 

118:16 227:20 

SOEs 173:10,16,19,20 

soil 7:7,10,16 8:1,10 

26:5,7,13 55:18 64:10 

64:13 69:11 92:10,11 

92:11 104:7,16 112:3 

163:5 165:22 167:13 

167:17 172:11,12,13 

172:18,21 225:21 

238:10 

soil-bound 105:4 

soils 169:6 

sold 48:9 65:13 103:13 

199:21 304:1 

soldier 236:2 

sole 91:12 

solely 113:8 200:15 

solicit 270:3 

solicited 313:16 

solid 351:6 

Solorzano 90:7 97:15 

97:16 100:22 101:12 

102:6 

solution 17:14 119:1 

208:13 212:8 

solutions 12:4 37:22 

163:15 208:18 

somebody 85:15 

215:19 228:19 230:7 

253:8 330:8 341:3 

366:3 

Somebody's 284:21 

somewhat 127:22 

248:16 261:8 

son 45:19 249:12 

song 330:15 

SONIA 2:6 

soon 10:12 75:17 

130:17 

SOP 199:10 200:9,20 

201:18 

sorry 18:20 36:18 40:22 

50:11 77:1 133:11 

140:5 153:10 157:7 

158:16 173:17 174:12 

177:4 215:12 217:17 

237:21 277:12 330:8 

349:13 

sort 36:13 110:7 124:3 

160:12 164:18,22 

190:2 193:5,6 215:18 

287:12 292:22 318:19 

321:22 324:20 326:13 

327:5 329:7,8,9 335:1 

335:9 336:19 338:4 

341:12 342:7 349:14 

349:14 350:22 351:1 

358:4,22 369:8 

sorts 171:19 326:18 

346:1 348:5 

Soto 51:19 56:11,12 

58:3,14 59:1,4 

sound 39:3 106:21 

161:12 373:7,10 

sounding 183:14 

source 92:16 131:11 

sources 24:7 

sourcing 92:22 

South 12:17 256:6 

Southeast 256:5 

Southern 367:6,14 

soy 34:4 103:5 151:8,16 

151:19 154:21 155:9 

155:13 157:21 158:2 

158:4,8 222:7,10 

soybeans 131:6 345:22 

space 30:9 68:18 

spare 285:21 

speak 20:16 23:11 

47:16 59:11 109:7 

166:22 196:3 261:19 

267:22 

speaker 5:3,3 44:10,20 

79:4 250:15 

speakers 4:22 45:2 

55:3 101:7 

speaking 4:18 41:4 

44:20 141:18 202:11 

319:7 

speaks 77:11 321:9 

spearheading 308:15 

special 42:8 333:16 

specialist 2:5,12 

126:21 

specialists 131:13 

specialized 94:3 361:13 

specializing 361:8 

Specialty 2:6 

species 38:8,11 292:20 

293:1 295:20 360:11 

specific 68:13 72:11 

92:3 94:13,18 109:8 

131:8 178:15 199:4,9 

219:22 222:16 238:19 

259:5,6 295:13 320:3 

320:18 337:3,13 

345:12 

specifically 56:8 65:7 

78:18 91:3 94:10 

112:12 164:4 211:18 

219:15 238:11 266:2 

314:19 319:7 

specificity 238:10 

320:17 347:12 

specifics 95:11 96:3 

346:6 347:10 

specify 265:10 

spectrum 159:14 

160:12 172:19 219:20 

220:3 236:15 289:17 

290:4 301:18 327:5 

spell 265:5 291:6 

spend 245:15 251:18 

266:11 339:21 366:12 

spent 155:19 

spinning 303:5 

spirit 230:15 260:11 

spoke 204:3 

spoken 75:16 84:13 

spook 203:19 

spoon 75:19 

spot 102:20 

spots 256:7 257:2,2 

spotted 163:8 

spray 46:9 49:4,8,13 

50:7,16 51:13 54:9 

75:8 

spraying 13:12 46:7 

50:12 

sprays 11:5 18:3 

spread 103:11 171:12 

spring 3:12 10:8 37:8 

84:5 104:19 112:11 

235:8 242:20,21 

243:2,7,14,18 248:7 

249:9 276:15 312:20 

376:5,10 377:15 

square 75:13 262:6 

St 1:9 167:10 

stab 110:5 

stability 321:7 

stabilizer 145:13 

stacked 36:5 

staff 2:2 30:9 31:11 

128:21 132:1 135:10 

191:19 193:9 200:13 

319:12 320:5 322:13 

325:22 338:17 339:1 

340:7 341:15 357:8 

358:21 361:11,12 

368:14 

staffing 128:19 351:4 

stages 41:16 94:16 

stake 9:20 10:22 

stakeholder 108:15 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
415 

237:18 351:15 

stakeholders 37:12,16 

43:1,14 166:9 231:2 

234:17 235:5 236:14 

266:14 286:21 288:19 

289:15 375:20 

stakeholders' 297:3 

stalled 195:17 

stance 110:13 

stand 11:15 379:3 

standard 24:6 30:10,20 

31:5 32:16 115:21 

127:18 135:13,17 

208:16 286:17 288:6 

288:10 289:1,3,6 

292:17,22 294:16 

300:19 

standardization 124:15 

355:1 

standardized 122:7 

124:9 129:18 322:21 

standards 1:3 2:9 9:17 

93:1 104:20 118:9 

146:14 168:7 169:18 

173:12 174:2 185:18 

189:14 194:2 199:16 

289:10 290:1 294:4,9 

296:4 307:10,10,11 

355:14 

standing 126:6 134:5,7 

standpoint 110:1 

stands 279:19 287:22 

staple 304:13 

stapled 62:22 

start 5:5 9:5 14:3 15:6 

20:22 22:21 36:10 

41:2 74:4,5 77:3 79:7 

86:19 90:8 102:21,22 

105:20 111:2 126:19 

141:12 162:12 170:6 

207:10 211:6,8 225:4 

232:14 234:12 245:13 

246:4 255:19 268:17 

269:12 272:17 282:12 

284:1 296:8 309:16 

310:13 318:7 341:19 

350:10 378:5 

started 4:4 86:8 87:6 

102:19 138:22 155:19 

224:20,21 225:1 

233:2 249:13 285:6 

starting 69:10 232:13 

245:19 252:4 260:12 

260:14 375:14 

starts 246:8 273:8 

353:14 358:6 371:10 

378:22 

state 6:2 34:20,21 65:5 

111:18 190:21 199:6 

199:14,22 200:2,13 

200:17 201:10,13,15 

201:19 202:19 203:2 

203:11 204:12 206:3 

206:16 209:13 213:11 

223:7 254:13 258:14 

259:2 264:1 300:15 

348:12,14,21 349:10 

349:12 368:11 

state's 201:17 

stated 68:17 113:22 

statement 82:10 216:10 

216:22 

statements 216:16 

states 1:1 6:1,7 80:11 

87:16 88:20 185:16 

186:2 256:15,17 

348:21 

station 56:16 

statistical 32:8,15 

statistics 187:1 

stats 203:1 

status 113:10 196:3 

301:13 

stay 46:18 232:6 271:18 

stays 223:20 

steady 75:22 

step 248:21 357:4 

Stephen 102:14,21 

105:19 

stepping 142:1 

steps 166:9 241:10 

261:4 316:3 327:15 

376:14 

Steve 1:16 8:15 27:14 

55:1 89:3 105:22 

144:21 148:16 174:12 

174:14 211:7 214:3 

243:11 261:13 298:9 

301:4,5 302:5 348:8 

stewardship 294:10 

310:6 

sticky 154:13 

stifles 171:2 

stimulate 15:22 

stimulus 83:8 

stip 208:5 

stock 134:6,7 176:10 

176:12 184:7 361:20 

stood 373:22 

stop 170:17 181:15 

290:22,22 295:18 

299:1 325:6 378:9 

stopping 225:19 

storage 29:15 

store 104:10 

storm 133:22 

story 52:9 262:7 

Stow 52:12 

straight 215:9,16 

strains 92:3 171:22 

strange 159:5 367:22 

strategic 193:5 376:13 

376:22 

strategical 99:14 101:4 

strategies 164:10 

320:14 

strategizing 239:19 

strategy 120:19 

strawberries 163:9 

165:13 

strawberry 91:2,5,6,16 

94:19 

streamline 216:13 

strength 322:15 

strengthen 9:15 118:8 

strengthening 323:2 

strengths 123:3 

stress 74:3 91:10 

275:15,20 

strict 68:2 

strictest 78:3 188:9 

strip 33:22 

strips 30:17 33:22 

34:10 163:11 

strive 106:17 

strong 10:15,20 11:2 

171:21 206:17 242:10 

337:17 

stronger 110:13 

strongest 335:15 

strongly 8:8 9:13 10:5 

12:1 22:14 43:8 

117:21 129:7 208:21 

210:16 314:17 

struck 342:4 

structural 208:22 

structure 66:7 121:1 

349:21 

structures 124:6 

struggled 177:21 

student 162:17 

studied 103:4 149:1 

studies 26:13 140:19 

337:1 

study 140:16 148:7 

154:5 

studying 139:19 

stuff 111:7 193:15 

197:13 226:17 360:2 

styles 118:2 

subcommittee 3:3,9 

4:11,13,14 6:11 39:2 

96:7 127:11 149:22 

185:4 232:15 233:3,5 

234:6 235:10,18 

236:3 237:6,16 

239:12 241:7 242:22 

245:7 247:16,17,19 

248:19 267:13,20 

269:7 271:3,21 272:5 

272:8,15,20 273:2,6 

274:5 278:3 283:13 

292:11 310:8,15 

311:2 353:8 366:22 

371:4 378:6,7,11 

subcommittees 234:21 

244:9 

subject 132:3 236:10 

237:19 238:1 331:18 

364:19 

subjects 237:1 

submit 192:6 229:8 

234:21 268:18 

submitted 5:15 38:20 

118:13 131:3 157:11 

170:14 189:8 279:14 

submitters 23:14 

Subpart 221:17 

subsequent 133:10 

137:14 

substance 117:2,6 

145:5 210:17 

substances 15:4,7,11 

23:17 42:3 43:1 

142:20 147:19 160:6 

substantial 128:16 

129:2 227:7 

substitute 16:6 27:10 

143:4 

substituting 80:4 

subverted 103:22 

successful 31:15 107:8 

112:1 

successfully 374:14 

succession 46:18 

sucker 16:16 18:1,10 

suckering 9:12 

suckers 11:22 

Sue 1:14 50:4 53:13 

71:22 245:19 246:3 

259:11 260:10 265:22 

273:8 304:22 305:18 

306:13 361:15 366:20 

Sue's 262:12 

suffer 74:21 

sufficient 16:3 237:10 

268:20 290:2 315:17 

339:1 376:12 

sufficiently 22:16 

suggest 43:8 128:12 

132:14 141:2 155:11 

244:13 322:1 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
416 

suggested 109:22 

110:7 235:22 314:3 

315:4,11 316:9 

319:10 321:18 

suggesting 150:14 

292:5 

suggestion 114:17,18 

134:1 176:8 193:2 

320:1,21 322:8 342:1 

343:19 

suggestions 185:20 

194:5 197:9,15 

248:19 294:7,13 

sulfate 23:20 25:19,21 

26:1 27:10 

sulfidal 208:22 

sulfides 209:16 

sulfur 5:19 6:12,19 7:2 

7:6,14,17,17 90:18,22 

91:1,7,7,13,14,14,15 

91:18 92:1 93:22 94:4 

94:4,11,18 95:7,9,9 

95:10,17 

Sulfur's 7:15 

sulfurous 5:19 90:19 

92:6,9 

summaries 124:13 

summarize 100:12,13 

178:6 287:16 289:16 

313:20 

summarized 100:22 

summary 241:1 302:16 

376:7 

summer 124:12 

sunset 20:6,13,21 21:3 

42:5 117:7 142:13 

144:11 186:7 

sunsetted 223:19 

Sunsetting 112:22 

super 49:21 

supermarket 74:22 

supplant 125:2 

supplement 92:19 

117:13 

supplements 116:21 

136:1 

supplier 158:9 186:17 

222:20 250:10,11 

253:19 255:12 365:15 

suppliers 57:12 108:17 

108:21 256:5 269:21 

270:14 

supplies 46:3 57:15 

supply 9:14 10:14 15:9 

15:13 28:18 29:13 

31:21 49:21 58:5 

88:19 103:16 117:11 

157:19 169:8 178:1 

191:12 204:1 255:22 

311:15,17 377:8 

supplying 171:7 

support 8:11,21 9:9,13 

23:14,22 37:2 38:14 

41:21 43:3 45:15 

56:18 78:13 93:7,18 

93:18 106:20 107:7 

107:19 112:13,15 

113:6 114:4,8 128:4 

129:7,18 130:16 

135:12 141:22 163:20 

165:9 166:5 168:2,11 

169:12 174:15 207:17 

208:2,10 216:16 

229:12 240:2 248:15 

253:15 286:3 296:19 

300:17 317:18 359:17 

372:20 

supported 122:21 

supporting 23:12,21 

321:7 

supportive 17:13,14 

supports 8:8 41:14 

90:21 92:5,14 121:2 

121:18 124:16 126:9 

208:13 330:3 

supposed 303:22 

surface 8:4 23:6 205:20 

207:22 209:12 216:18 

surfaces 24:22 

surge 321:18 

surgical 172:6 

surprise 329:17 

surprised 156:2 159:8 

surveillance 200:11 

201:20 203:15 204:14 

205:16 206:22 

survey 124:11 356:21 

358:1,18 

surveying 155:1 

survive 209:20 

suspect 103:5 

suspend 152:19 

suspension 336:6 

337:11 

sustain 80:7 

sustainability 69:19 

118:3 138:21 229:4 

286:5,8 307:17 

sustainable 24:1 25:17 

37:3 79:22 92:21 

117:19 132:7,18 

138:7,8 140:20 

162:19 165:22 187:20 

220:11 

sustainably 133:2 

sustained 47:3 304:7 

Swaffar 1:21 101:22 

150:2,6 173:8,19,21 

174:9 180:3,9 182:18 

192:15 246:12 265:4 

267:11 273:11 278:5 

279:18 282:15 284:2 

343:3 353:10 354:7 

359:19 363:15 369:22 

372:2 

sweep 33:18 

sweet 48:10 49:22 

swim 298:11 

switch 184:10 

switches 246:2 

synopsis 376:1,1 

synthetic 16:18 23:17 

144:13 145:4 146:7,8 

146:8 168:9 275:20 

synthetics 276:7 

290:18,19 

system 11:3,6 24:8 

30:19 34:15,19,21 

35:1 39:15 46:7 72:3 

83:11,12 89:13 121:7 

121:14,22 122:8 

123:4 124:4,9 179:20 

183:4 184:5 190:12 

197:18 209:8 214:9 

214:10,17 215:15 

217:2,7,10 218:18 

228:11 235:20 250:13 

264:1 276:9 312:15 

312:16,17 315:17 

317:17 321:10,13 

322:1,3,20 325:5,18 

327:4,12 336:8 338:6 

339:7 340:5,17 341:8 

341:16,18 349:3 

358:7 365:3,11 374:5 

374:18 375:12 

system's 335:20 

systematically 114:9 

systems 14:10 23:4,7 

26:17 162:19 163:2 

165:21 169:15 206:10 

214:14 225:8 317:10 

318:22 340:13 

systems-based 319:4 

T

table 9:1 38:5 277:14 

283:17 304:20 

tackle 285:19 

tackled 286:6 

tackling 328:4 

tactic 181:19 

tactically 21:14 

tag 253:3,5 

taken 117:18 209:3 

242:6 248:16 

takes 30:12 47:5,8 

65:11 68:5 71:9 77:11 

80:19 171:5 197:19 

197:20 203:2 220:17 

336:6 338:13 366:11 

talk 32:6 189:1,3 211:9 

278:2,5 286:7 311:10 

talked 21:11 64:16 

106:14 160:22 211:10 

344:4 357:14 

talking 18:9 19:19 

22:10 32:16 131:12 

181:10 214:5,12 

266:16,20 286:7 

303:11 305:22 326:9 

326:17 334:19 352:7 

365:9 376:2 

talks 260:4 

tamarind 148:18 149:1 

149:9 171:8 

tank's 217:11 

tanks 217:13 

target 91:4 348:1 

targeted 368:12 

targeting 374:3 

targets 219:22 348:4 

task 10:5 13:13 110:3 

192:1 297:1 

tasks 52:13 234:16 

taste 363:18 

tax 22:7 

TBD 277:9 280:17 

team 63:4 79:18 81:11 

121:11 134:18 135:10 

137:11,21 192:8 

194:22 201:7 202:1 

335:15 362:6 364:9 

364:12 366:17 

teammates 89:20 

teams 130:14 

technical 28:16 43:9 

46:5 51:7 63:5,5,7 

89:19 90:2 99:18 

172:18 183:1 357:11 

technically 278:10,17 

techniques 10:4 

technologies 160:6 

technology 28:14 36:9 

49:2,17 63:2,3 70:3 

72:18 77:9 78:16 

159:10 161:8 324:19 

teleconference 26:4 

tell 32:10 43:22 68:12 

82:13 111:11 152:5 

155:15 156:13 157:14 

158:19 182:21 343:16 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
417 

364:19 

temperatures 60:16 

61:19 73:22 99:5,5 

ten 56:13,19,22 75:19 

134:5 346:16 

tend 257:5 352:12 

tendency 57:8 73:21 

tense 367:8 

term 18:14 20:1 22:16 

156:16 160:12 297:10 

297:11 337:5 

terminology 274:18 

terms 21:3,4 140:3 

153:17 186:16 196:9 

196:15,22 197:5 

238:8,11 239:14,18 

239:19 240:10,11,14 

241:9 279:13 289:2 

290:8 296:5 305:20 

306:7,8,11 316:11 

322:12 325:13 326:5 

326:12 327:15 335:2 

336:10 338:1 339:5 

350:16 351:3,4 368:4 

terrestrial 289:9 310:2 

Terry 167:8 170:4,6,8 

183:9 185:7 

test 30:12 35:19 108:19 

115:8 250:5 262:14 

263:2,6 265:12 266:3 

287:12 

tested 115:1 251:7 

263:10,11 

tester 254:2 

testimony 140:1,3,5,8 

292:14 297:17 

testing 11:12 28:19,20 

28:22 30:11,14,22 

31:7,14 33:5,14 34:15 

35:14,19 122:4 

250:13 251:14 252:1 

252:10,15 253:11 

254:9 255:9 259:20 

259:21 260:3,4,7 

261:9 262:2,13,18,21 

263:22 264:22 270:21 

tests 32:8 35:4 92:2 

250:21 255:11 

tethered 193:16 

tethering 194:2 

Texas 12:18 

texture 144:14,17 

145:14 146:11,18 

157:2 

texturizer 145:13 

thallus 133:8 

thankful 106:18 

thankfully 71:18 75:8 

thanks 33:10 36:16 

39:22 97:16 102:6 

105:13 110:21 131:22 

135:16 138:15 141:10 

184:12 196:1 226:1 

231:5 280:4 285:4 

298:5,10 328:2 348:7 

353:1 354:12 359:10 

363:14 375:19 377:16 

themes 376:10 

theory 193:6 

thereof 107:21 

thicker 71:8,15 

thin 71:12 

things 20:4 22:12 51:6 

79:20 80:21 82:11,13 

82:15,17 83:13 94:14 

109:16,17 113:2 

125:18 149:15 175:14 

176:19 177:2,21 

181:1,4,17 204:16 

205:5 225:13 239:8 

241:21 243:19 265:9 

309:16 314:15 326:19 

329:12 330:16 332:4 

337:7,19 342:8,15,16 

345:1,16,16 346:1 

348:5 351:7 361:7 

366:13 367:5 368:9 

368:15 369:9 

thinks 298:3 

third 80:8 121:21 124:4 

third- 286:12 294:7 

third-party 184:22 

294:12 

thirds 272:19 

thorough 91:15 108:12 

363:22 

thoroughly 83:14 85:20 

210:11 

thought 15:8,19 36:3 

96:18 114:17 125:14 

180:12,20 227:9 

228:10 258:8,8,9 

261:12 263:7 274:11 

278:9 306:15 322:7 

324:14 329:1 338:14 

357:22 

thoughtful 247:15 

339:4 

thoughtfulness 325:11 

thoughts 15:4 135:14 

176:15 212:16 298:5 

298:18 324:9 328:12 

328:13 329:4 359:13 

359:15 

thousand 304:8 

thousands 192:4 266:8 

303:12 

thread 365:10 

threatening 181:17 

threats 107:14 

three 4:17 34:5 41:9 

44:19 47:8 48:7 60:1 

60:2 61:11 62:18 

63:21 64:11 65:10,11 

65:18,19 67:17 69:9 

71:8 74:11 81:7 83:13 

83:18 97:4 166:21 

200:8 204:17 223:5 

267:1,3 276:15 

324:20 335:7,7 

338:21 349:8 370:8 

377:21 378:1 

three-kilo 76:2 

three-year 70:14 

three-year-old 228:21 

threes 337:22 

threshold 174:20 

thriving 169:20 

THURSDAY 1:7 

tidal 133:6 

tide 86:10 

tie 131:2 369:4,7 

tied 194:9 204:21 205:9 

ties 321:17 

tight 75:14 

tightly 216:5 

timeframe 65:20 

timeliness 129:4 

timely 16:4 98:16 243:3 

243:8 269:6 

times 99:8 100:14 

101:6 117:17 132:4 

151:7 197:13 222:22 

223:18,19 266:6 

315:11 330:5 364:15 

timing 48:17 68:10 

268:11 

tipping 318:10 

tired 370:7 

title 247:5 

tobacco 9:10,11 11:20 

12:1 17:1,4,12,21 

18:5,18 19:1,3,4,10 

226:15 

today 4:8 9:9 14:14 

28:19 73:3 90:17 

111:20 112:10 113:3 

120:8 127:1 167:21 

168:7 182:20 185:14 

185:19 189:1 221:3,4 

221:12 223:14,17 

232:21 238:16 312:10 

314:20 378:1 379:2 

told 259:17 

tolerance 110:11 271:8 

271:9,19 

tolerances 36:7 

Tom 1:10,12 9:4 22:19 

22:21 23:2 196:4 

204:11 241:20 243:13 

260:9 261:5 267:22 

269:12 277:3 280:10 

304:22 312:19 330:12 

334:13 354:12 359:13 

376:1 377:16,18 

tomato 104:9 

tomatoes 104:9 265:12 

265:19 

tomorrow 159:15 

346:16 347:14 378:5 

379:4 

tons 64:10 68:14 69:13 

186:13 187:4,17,17 

tool 6:12 7:12 91:2 

95:21 118:22 121:12 

128:9 286:15 

toolbox 223:12 224:3 

226:7,21 

tools 8:9 31:20 111:21 

113:1 286:11 359:8 

369:17 

toothpaste 24:11 

top 133:7 154:18 327:8 

375:10 

topic 11:17 93:6 120:10 

120:21 121:13 180:4 

236:14,19 375:5 

topics 3:4,10 41:10 

118:14 121:4 166:20 

235:6,11 238:8 355:8 

373:12 374:9 

total 30:22 67:15 134:4 

187:6 275:6 

totally 18:11 347:22 

touched 153:12 

touches 311:20 

touching 369:9 

towns 169:6 

toxic 11:5 172:13 

176:20 181:1 184:4 

210:2 

toxicity 26:13 

TR 180:17,19 181:3 

236:4 

traceability 365:2 

traceback 130:7 

track 190:12 235:7 

274:12 281:13 311:9 

tracking 103:15 341:19 

trade 128:6 185:15,15 

188:22 189:8 190:10 

192:11,21 193:4 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
418 

194:7 195:3 197:8 

253:14 269:21 311:22 

345:10 

tradeoff 175:17 197:12 

traditional 30:4 36:6 

166:7 304:7 

trail 130:1 

train 16:13 67:22 263:7 

trained 31:11 49:10 

122:13 123:15 167:11 

trainer 119:20 364:8,16 

training 3:11 31:15 

120:4 121:22 122:10 

122:19 129:16 130:1 

130:2 312:7,12 320:6 

320:8,19 324:17 

354:13,22 360:5 

361:13 366:3 368:16 

371:8 372:18,20 

373:8 375:5,13 

trainings 123:13,14 

129:20 130:6 320:2,4 

320:12 355:8,10 

357:5,9,11 368:11 

trait 33:15,16,16 34:1 

254:14 

traits 33:18,19 34:2,5,9 

34:9 35:22 36:4,6,8 

36:11 131:8,10 

252:12,18,21 254:7,7 

254:8 

trajectory 285:15 

transcript 374:13,16 

transgenic 36:6 

transient 220:7 

transition 16:7 65:7,8 

65:14,17,21 190:7,12 

transitional 193:10 

transitioned 58:10,11 

66:1 

transitions 240:6 

335:10 

translate 45:20 336:11 

337:9 

translation 44:9,14 

58:1 

translator 45:5 51:21 

transmitted 356:10 

transparency 3:5 39:3 

103:8 105:14 108:3 

108:19 110:12,14 

143:9 151:13,22 

161:22 162:4 247:6 

272:14 329:22 330:3 

transparency-based

254:5 

transparent 30:2 38:22 

162:3 186:1 253:9 

286:22 351:8 

transportation 29:15 

transported 209:7 

transposon 275:18 

276:13,16 281:4,15 

transposons 275:13,14 

276:2,2,11 277:8 

278:2,6,8,12,18,21 

279:4,7,22 280:14,17 

280:19 281:22 282:9 

treat 6:20 175:8,11 

179:16 

treated 218:16 291:20 

293:9 

treating 218:13 

treatment 23:5 26:22 

98:17 209:8,10,11,20 

212:22 213:6 215:5 

treats 172:3 

tree 5:17 6:12 8:13,18 

tremendous 87:8,11 

90:16 290:17 

trend 85:6 

trends 341:20 

trials 237:5,9 

tribal 303:13,20 304:7 

304:10 308:6 

trichoderma 63:15 

tried 17:17,20 156:7,11 

286:6 291:7 

trigger 116:3 318:17 

321:3 

trim 228:14 

tropical 61:17 100:5 

tropics 55:19 69:22 

87:12 

trouble 244:6 

truck 33:6 86:3 201:16 

Trudy 131:16 141:11,12 

141:14 

true 49:16 105:12 111:5 

111:12 112:15 114:3 

137:20 292:9 362:13 

truly 106:15 312:4 

trust 29:7 103:18 

truth 156:14 157:15 

158:20 

try 11:5 18:3 23:16 40:9 

43:20 59:19 81:11 

83:10 139:3 155:21 

220:8 225:19 229:8 

229:16 270:3 274:12 

274:14 279:7 285:19 

286:22 287:3,12 

288:2 295:11 297:6 

299:3 308:10 351:8 

377:9 

trying 8:22 20:4 34:19 

184:15 210:14 227:11 

244:16 252:2 260:6 

261:1 267:19,19 

270:19 288:5 289:9 

293:2 297:19 298:12 

301:17 333:11 349:3 

364:20 

tucked 225:11 

Tucker 2:14 42:18 

105:14 142:1 196:5 

202:1 232:4 324:12 

329:6 335:4 336:21 

339:18 341:5 346:8 

347:19 349:13 350:2 

352:6 372:9,11 

375:19 

tune 83:20 

tunnels 165:11,13,22 

turn 4:21 7:9 354:14 

372:8 376:1 377:18 

turned 16:20 333:1 

turning 86:10 

turnout 320:11 

turnover 335:11 

turns 115:4 183:7 

tweaked 270:17 

twice 65:12 207:7 

two 4:20 12:17 20:2,4 

24:21 32:7 48:2 50:19 

52:20 65:11 66:2 

82:15,17 91:9 111:16 

127:9 134:6 135:8 

137:9 151:22 183:11 

190:11 194:4 198:21 

211:8 214:22 215:15 

217:18 218:1 222:5 

226:3 234:11 241:21 

267:1 268:21 269:4,5 

290:11 301:18 309:6 

343:20 376:20 

two- 272:18 

two-thirds 282:4 

283:21 

tying 227:8 

type 83:20 124:9 

130:22 152:19 251:4 

276:18 

types 60:2,8 92:9,17 

93:12 130:19 289:19 

typical 33:18 266:18,22 

typically 35:3 215:5 

219:22 265:19 

U

U.S 33:1,4 166:16 174:2 

174:4 186:18 187:3 

199:21 322:20 323:20 

346:4 

Ugarte 132:22 

ultimately 184:2 

ultraviolet 275:19 276:1 

276:6 

unable 156:1 

unanimous 286:2 

unannounced 130:9 

327:16,17 

unaware 16:22 

unclear 105:5 128:1 

underline 185:22 

underlying 190:21 

undermine 29:6 

underscores 308:15 

understand 13:9 19:12 

19:19 35:14 44:9 

45:22 61:22 72:1 73:5 

112:7 124:21 139:3 

152:13 155:6 168:7 

179:15 194:12 201:8 

214:22 217:20 254:9 

257:16 277:10,21 

298:15 303:4 340:13 

356:8 362:18 363:21 

365:17 367:9,19 

understanding 15:19 

18:19 19:3 46:20 76:8 

100:21 145:21 190:9 

206:3 211:16 215:12 

301:2 316:15,20 

356:12 

understood 77:14 

113:12 189:16 195:19 

249:22 355:3 365:2,2 

365:3 

underutilized 121:12 

underway 117:9 323:1 

undesirable 99:1 169:2 

342:22 

undone 260:18 

unfair 107:4 

unfamiliar 133:4 

unfinished 116:18 

118:14 

unfortunately 12:19 

13:18 18:5 293:19 

333:2 

unified 63:5 191:2 

uniform 98:15 101:11 

101:12 

uniformity 59:12,16,20 

60:3,9 99:1 

unintended 29:2 

unintentionally 271:16 

Union 58:22 104:19 

160:22 

unique 123:17 165:15 

204:16 288:18 291:9 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
419 

uniquely 163:18 

united 1:1 6:1,7 10:20 

80:11 87:15 88:20 

185:16 186:2 256:15 

256:16 

universal 11:10 248:15 

275:17 

universally 294:10 

universities 52:17 

76:16 279:10 373:18 

university 162:18 

167:12,14,17 236:10 

286:13 

unnoticed 90:16 

unranked 314:2 

unrealistic 18:11 

unrealized 29:3 

unripened 99:11 

unsustainable 38:12 

134:14 

untreated 8:3 

unwanted 238:5 

Upala 57:1 

update 233:10 312:19 

317:9 376:4 

updated 243:22 

updates 129:12 

updating 112:10 

upfront 361:18 

upheld 118:10 

uphold 90:14 

upper 106:3 

ups 183:11 217:18 

upset 148:4 

uptake 7:8 8:5 92:12 

urge 10:5,15 11:17 12:1 

37:18 43:12 144:11 

169:12 186:5 

urgency 106:22 

urging 191:6 

US/EU 105:6 

usable 377:6 

usage 168:14 

USDA 11:2,6 29:1 41:22 

62:19 72:11 87:10 

107:7,19 121:21 

124:3 147:2,7 155:22 

156:3,4 189:11 

190:18 191:2 195:13 

195:13 197:20 206:8 

227:13 298:15,16 

318:1 319:17 320:22 

USDA's 121:13 166:14 

useful 15:7 332:14 

347:16,17 364:14 

366:19 

USEPA 210:9 

users 25:13 26:18 

210:19 299:17 

uses 23:21 25:5 55:13 

172:10 218:15 219:5 

ushering 104:3 

usually 145:12 

utilize 193:18 229:17 

utilizing 25:19 

V

vaccine 279:21 

vaccines 278:8,9,15,18 

279:1,8 280:9 

vacuum 191:20 194:9 

270:20 

vague 289:1 

Vallaeys 41:17 

Valley 269:19 

valuable 35:11 266:14 

value 29:20 35:8 130:13 

154:14 168:6 186:16 

206:21 340:19 363:12 

variable 335:10 

variables 324:20 

variation 61:19 361:11 

varieties 178:15 265:12 

variety 56:9 57:14 

265:9 

various 109:2 123:13 

132:9 274:19 316:3 

355:1 

vast 92:17 310:4 

vegetable 261:22 

264:19,20 265:6 

vegetables 80:14 96:17 

217:21 

vegetation 55:20 63:22 

64:5 

verbal 312:19 376:4 

verification 193:19 

294:19 

verified 192:19 193:9 

193:22 194:9 

verify 33:7 162:1 255:9 

291:14 293:8 295:4 

296:16 

verifying 321:12 

veritable 106:3 

Vermont 61:11 62:2 

versa 361:22 

version 244:12 282:12 

versus 113:8 140:3 

254:8 262:20 263:15 

299:8 305:3,3 

vet 192:2 

vetted 8:20 

vetting 114:9 

viability 84:10 

viable 91:13,22 98:10 

98:11 168:20 229:16 

vice 1:13 241:11,16,20 

243:10 244:18 245:2 

246:14 247:4 257:20 

260:9 261:5,13 

262:10 263:17,21 

264:7,10 265:3,14 

267:4,10,17 269:2,10 

269:16,18 270:6 

272:2,7 273:13 274:7 

277:14,19 279:2 

280:6,20 282:17 

284:4,21 298:6 

299:19 301:4 302:5 

304:21 305:17 306:13 

308:3,12 309:22 

361:22 

vida 50:3 

view 44:1 152:3 176:4 

264:16 

viewpoint 173:12 

viewpoints 38:5 

views 192:22 

violating 253:2 

violations 337:16 

338:22 

violent 61:4 

Virgen 48:4 

visibility 205:22 206:9 

206:15 

visit 233:13 350:13 

365:12 

visited 249:10 

visitors 257:15 

visits 313:10 327:18 

vital 6:14 8:9 10:20 

90:15 231:16 

vitally 231:18 

vitro 276:2,3 279:5 

voice 122:3 128:4 

130:15 141:19 180:6 

voiced 144:2 201:10 

voices 38:4 

volatilization 60:17 

volume 48:16 49:1 57:8 

88:9 

volumes 35:2 48:12 

215:10 

voluntary 227:12,15 

volunteers 41:8 

vote 10:8 186:5 227:14 

245:3,6,14,20 246:3,3 

246:6,7 272:19 273:4 

273:5,6 276:21 

278:21 282:1,5,6,10 

282:11 283:11,21,22 

309:1 353:5,6,13,14 

370:22 371:9,10 

voted 308:19 

votes 246:5 247:1 

273:4,7 274:1 283:6 

284:16 354:8 372:4 

voting 182:19 245:13 

246:8 272:11 273:8 

282:12 284:1 353:14 

371:10 

W

wade 111:9,10 

wait 90:1 

waiting 189:12 195:15 

walk 368:22 369:8 

Walker 102:14,22 

105:19,22 106:1 

109:5,11 110:4,14,21 

wandering 232:13 

wanted 15:21 27:6 40:2 

68:21 78:18 82:17 

84:1 101:15 115:13 

124:2 147:20 150:4 

151:1 166:19 179:11 

179:21 180:9 188:22 

189:15 195:18 221:13 

222:17 230:14 233:9 

243:12 250:21 257:21 

267:11 271:17 280:21 

308:4 317:16 328:4 

346:11 366:21 368:3 

369:10,13 375:11 

377:1 

wanting 18:17 19:4 

267:14 271:8 

wants 192:18 232:2 

warehouse 365:16 

warm 76:16 

Warmuth 9:4 23:1,2 

27:13 

warning 311:8 

warrant 315:21 

warranted 31:16 

wash 96:17 213:14 

Washington 5:9,12 6:1 

249:9 254:13 

wasn't 77:20 156:13 

218:7 238:18 331:13 

waste 24:8,10 25:11 

26:22 166:3 169:6 

209:7,8,10 210:2 

212:13,21 214:6 

215:5 216:13,15 

watch 228:19 

water 7:8,18,20,22 8:1 

8:2 23:5,6 24:2,4,7,8 

24:8,9,10,17,17,22 

25:11,12 26:3,3,5,22 

53:5 60:19 92:8 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
420 

115:21 166:2 169:6 

208:19 209:8,10,20 

210:3,5 212:13,15,21 

213:3,6 214:6,14 

215:5,9,16 216:15 

watering 25:2 

watermelons 225:3 

waters 24:15,20 209:12 

213:10 

waterways 216:19 

wave 133:22 

way 13:17 20:13 22:5 

40:13 43:8 48:18 64:8 

66:2 70:12 75:7 86:10 

93:17 98:21 110:15 

124:2 125:18 137:10 

162:22 177:2 181:17 

183:13 186:1 195:17 

212:4,4 220:2 226:9 

231:15 233:14 243:8 

254:18 257:12 286:20 

287:2,3 296:11 

305:15 307:20 325:10 

325:16 328:20 329:18 

342:21 343:11 355:19 

360:4 363:6 365:22 

367:5 

ways 5:21 83:5 118:19 

119:4 142:20 216:15 

238:4 241:7 275:1 

281:12 293:16 297:6 

342:11 375:7 377:7 

weaken 10:17 

weakly 208:12 

wealth 313:14 

weather 62:1 74:1,3 

95:15 

webinar 372:16 373:14 

webinars 219:18 

webs 155:22 172:12 

website 351:10 

wedding 365:8 

Wednesday 345:5 

346:9 347:12 

weed 64:2 239:4 

weeds 64:6 

week 18:10 48:12 67:8 

67:9,11 70:12 76:17 

124:11 168:4 191:15 

227:17 363:5 

weekly 67:9 

weeks 18:11 154:6 

267:22 268:14,21 

269:4,5 

weigh 328:19 333:12 

weighed 331:3 

weighing 265:1 

weight 60:4,12 

weighted 218:19 

weighting 333:20 

Welch 22:20 28:10,12 

28:12 32:4,14 33:12 

33:20 34:18 35:18 

36:16,18 250:16 

welcome 4:3 198:20 

224:19 241:18 

well- 344:16 

well-informed 345:14 

well-prepared 122:21 

Wendy 79:7 86:18,19 

86:22 

went 17:19 102:16 

157:20 189:11 195:11 

232:17 247:16 262:20 

270:7 310:18 359:5 

379:6 

west 48:9 

wettable 7:14 91:7,13 

91:15 94:4 95:9 

whales 228:19 

whatsoever 66:11 

wheat 151:8,16,19 

154:21 155:9,13 

222:7,10 254:12,17 

wheel 124:3,21 

wheels 303:5 

white 174:22 

whitening 24:10 

wholeheartedly 129:18 

Wholesaler 101:18 

wholly 144:1 

wide 17:12 113:15 

127:13 159:13 227:11 

289:14 297:2 305:5 

wide-spread 27:11 

widely 24:5 32:13 84:13 

widespread 113:12 

132:16 153:16 296:19 

wife 45:18 

wild 36:21 39:20 40:3 

135:20 136:4 164:15 

229:4 286:17 288:6 

288:10,14 289:1 

291:8 292:17 294:1 

294:16 295:2 297:4 

298:12 300:3,6,11 

304:16,17 306:16,18 

306:22 307:2,8,11,14 

307:22 338:17 356:13 

wild-crafted 300:21 

wild-crop 135:12,17 

wildlands 37:1 

wildlife 38:14 

willing 109:21 114:13 

123:2 375:2,4 

wind 95:14 369:21 

window 339:21 

wine 217:22 

wing 163:8 

winger 165:14 

winter 304:12 

wipe 172:13 

wish 142:21 

wished 315:19 

wishing 317:11 

withstanding 162:9 

Wolf 116:15,20 

wonder 108:19 243:17 

294:11 

wondered 72:13 

wonderful 50:1 

wondering 15:4 47:2 

123:11,18 136:18 

147:19 149:17 158:2 

228:9 334:22 339:14 

342:11 349:16 

Woods 199:8 

word 80:17 182:18 

237:20 277:7,12,17 

336:16 350:18 

wording 110:2 282:10 

294:15,16 

wordings 109:22 

wordsmithing 110:8 

work-around 278:22 

worked 57:3 86:1 

140:15,17 167:15 

178:16 192:18 196:19 

196:21 222:22 225:10 

234:22 373:14 

worker 224:20 

workers 80:9 84:21 

96:9 169:6 186:22 

226:16 

workflow 198:7 

working 37:19 38:1 

40:4,5 45:20 49:20 

56:21 69:8,15 83:9,19 

117:20 119:10 122:5 

125:11,22 126:2 

139:2 183:21 192:2 

201:8 206:10,14 

225:7,13 228:20 

239:12 242:9 257:17 

257:18 268:17 285:12 

296:20 309:20 326:7 

328:11 352:20 366:17 

369:18 372:22 373:11 

workload 377:11 

works 83:15 110:3 

125:7 209:11 226:22 

270:18 366:5 367:13 

world 13:18 21:17 

63:11 85:7 88:22 

135:1 169:16 186:13 

310:3,3 325:20 

worldly 118:1 

worldwide 65:1 69:4 

188:3 

worry 77:9 

worst 210:7 213:2 

worth 7:13 

worthwhile 322:7 

323:14 

worthy 164:5 

wouldn't 39:18 155:14 

275:10 297:1 

wrap 5:1 76:6 228:16 

310:1 

wrapping 378:14 

wrestle 174:21 

write 333:3 

writer 250:1 

written 5:15 21:10 

23:12,14 32:8 38:19 

109:1,12 110:6 

115:17 126:7 131:3 

135:5 136:9 155:4 

157:12 191:10 199:15 

208:10 235:9 238:15 

312:3 358:12 

wrong 41:1 76:8 341:4 

wrote 236:15 295:8,11 

X

xanthan 144:11,12,15 

145:10 146:6 151:15 

221:13,16,19,21 

222:6 

Xerces 164:18 

Y

Yakima 5:9 

yams 70:16 

year 12:17 16:17 21:21 

35:5 47:1,1 48:11,12 

50:2,8,9 53:9 61:19 

67:1,9 68:13,15,17 

70:1 87:17,22 98:19 

112:12 128:18 133:16 

137:8 150:3 187:8 

192:16 200:2 264:13 

274:14 303:14 311:13 

312:6 313:1 343:8,20 

346:14 

year's 244:10,11,15 

yearly 187:12 

years 6:16 19:19 20:15 

45:9 46:17,19 47:2,10 

48:4,7 49:14 56:13,22 

57:3 60:22 61:11 62:9 

63:9 64:11 65:11,11 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
421 

65:18,19 66:2 67:17 

69:6,9 70:6 71:8 

74:11 78:10 86:1,7 

87:5 98:3 118:14 

127:6 128:18 131:11 

133:10 137:14 138:16 

139:5,14,15 140:16 

141:22 144:7 148:2 

159:3 161:17 166:21 

167:15 168:4 179:1 

181:22 182:13 186:9 

187:13,18 189:8 

200:8 221:9,10 

222:17 234:22 236:12 

240:22 259:18 303:12 

304:8 326:15 335:7,8 

343:20 364:8 

years' 235:1 

yellow 4:20 

yesterday 13:4 114:17 

124:10 176:8 199:9 

212:10 305:1 324:15 

377:1 

yield 163:10 165:4 

yields 66:10 70:7 

Z

zero 271:8 274:2,3 

283:7,8 284:17,18 

354:9,10 372:5,6 

zone 106:4 133:6 

295:15 

zones 300:18 

0

003 208:20 

016 208:20 

1

1&4 1:9 

1,400 106:6 200:7 

1,500 191:8 

1,875 187:10 

1.1 200:6 

1.7 199:22 

1/13th 31:3 

10 18:11 31:2 33:21 

45:9 48:4 266:18 

10-minute 309:8 

10:23 102:10,16 

10:45 102:11 

10:50 102:17 

100 6:16 61:20 62:4,8 

67:6 69:13 200:6 

262:1,4 263:18 264:3 

320:15 335:11 

11 1:9 206:1 336:4 

12 34:7 47:9 76:4 87:5 

133:11 205:20 310:20 

338:4 

12,000 94:9 

12:52 231:11 232:12 

12:53 232:17 

120 350:12 

125 266:5 

13 191:17 192:9 332:13 

334:22 

14 68:8 187:12 

14,000 6:5 

141 186:19 

15 68:9 133:11 274:2 

283:7 284:17 354:9 

372:5 

15,000 94:9 

15th 372:15 

1600 115:17 

17 108:12 109:14 

133:17 253:17 

17025 31:10 

172 221:17 

18 168:4 205:20 295:18 

1972 224:20 

1979 199:13 

1995 142:12 144:6,8 

161:16 189:13 195:10 

1996 227:19 

2

2,000 200:4 

2,000-bulk 115:5 

2,000-pound 113:20 

2,100 106:2 

2,500 115:18 

2.2 186:13 

2.6 57:6 

2:15 232:12,13,14 

2:20 232:14 

2:21 232:18 

2:25 232:14 

20 18:9 32:16 87:15 

133:11 144:7 161:16 

210:1 221:10 262:6 

20-plus 259:17 

20-ton 74:17 

20-year 161:16 

20,000 65:17 

2002 124:3 

2003 52:19 53:7 132:5 

199:15 

2005 111:15 

2006 52:19 53:7 87:5 

190:14 

2010 104:17 

2012 187:13 234:17 

2015 52:12 77:13 

2016 77:17 199:17 

274:18 286:4 450 30:11 56:18 250:20 

2017 186:14 187:1,3,5 49 187:17 

187:13 

2018 1:5,7 3:4,6,12 5

52:20 162:20 163:22 5 260:4 

245:10 312:20 376:5 5:00 378:14,16 

376:10 5:28 379:6 

2019 243:6 281:3 5:30 378:14 

376:22 377:15 50 69:21 131:12 264:3 

2020 52:22 344:14 

2021 105:1 500 70:14 

205.600 144:12 5029 110:6 

205.600(b) 145:2 

146:17 

53 200:15 

205.606 15:5 6

205.671 260:3 6.5 7:21 

21 87:17 221:17 6:30 378:22 

21.5 187:6 60 24:6 131:14 

22 102:10 60,000 75:12 141:18 

23 133:17 602 114:15 

233 3:5 606 170:18 171:2 

25 1:7 65:1,3 140:16 177:20 178:3,19 

187:18 240:2 364:18 63 186:20 

25,000 75:13 633 187:4 

26 45:14 48:6 62:5 65 74:1 

274 3:6 65s 61:21 

285 3:7 66 187:18 

29 187:17 68 74:2 

3 7

3.0 120:17 700 49:5 

3.5 74:16 73 224:21 

3:52 310:11,18 76 225:1 

30 45:20 46:1 47:6 7th 247:21 268:8,10 

55:19 60:22 127:6 

139:5 221:9 8

30-something 71:11 

300 11:20 17:5 

8 129:8 

8.3 7:20 

311 3:11 8:30 1:10 4:2 378:6 

312 3:12,13 379:4 

32 71:9 80 350:8 

32,000 186:22 85 187:2 201:6 

33 113:21 115:19 86 201:15 

35 31:2 33:21 69:6 70:6 87 225:4 

250:20 263:20 883 200:9 

350 62:7 64:10 

36 56:16 9

379 3:14 9:00 379:1 

90 6:6 69:21 98:8 

4 900 87:16 

4 3:2 200:11 90s 161:8 

4,000 6:9 61:18 94 190:13 213:1 

4,200 200:3 95 61:2 78:5 208:19 

4:10 310:12,16 311:6 212:22 

4:11 310:19 976 187:4 

4:30 378:16 99 7:17 

40 18:9 35:4,5 199:20 

40,000 65:16 

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422

C E R T I F I C A T E 

This is to certify that the foregoing transcript 

In the matter of: National Organic Standards Board

Fall 2018 Meeting

Before: USDA

Date: 10-25-18

Place: St. Paul, MN

was duly recorded and accurately transcribed under 

my direction; further, that said transcript is a 

true and accurate record of the proceedings. 

-----------------------

Court Reporter 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 
1

 UNITED STATES DEPARTMENT OF AGRICULTURE

 + + + + +

 NATIONAL ORGANIC STANDARDS BOARD

 + + + + +

 FALL 2018 MEETING

 + + + + +

 FRIDAY,

OCTOBER 26, 2018

 The Board met in Great River Ballrooms 

1&4 of the Intercontinental Saint Paul Riverfront 

Hotel, 11 Kellogg Boulevard East, St. Paul,

Minnesota at 8:30 a.m., Tom Chapman, Chairman,

presiding. 

PRESENT 

TOM CHAPMAN, Chair

HARRIET BEHAR, Vice Chair

SCOTT RICE, Secretary

SUE BAIRD 

ASA BRADMAN 

JESSE BUIE 

LISA DE LIMA 

STEVE ELA 

RICK GREENWOOD 

DAVE MORTENSEN 

EMILY OAKLEY 

A-DAE ROMERO-BRIONES 

ERIC SCHWARTZ 

DAN SEITZ 

ASHLEY SWAFFAR 

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STAFF PRESENT: 

MICHELLE ARSENAULT, NOSB Advisory Board 

Specialist, National Organic Program 

SONIA JIMENEZ, Deputy Administrator, Specialty 

Crops Program, Agricultural Marketing 

Service 

CLARISSA MATHEWS, Ph.D., National List Manager 

DEVON PATTILLO, Materials Specialist, National 

Organic Program 

DR. JENNIFER TUCKER, Ph.D., Deputy 

Administrator, National Organic Program; 

Designated Federal Official 

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 CONTENTS 

Opening remarks. . . . . . . . . . . . . . . . . . 4 

Livestock Subcommittee 

Topics

2020 Sunset substance review 

Alcohols: ethanol, isopropanol . . . . . . . . . .22

Aspirin. . . . . . . . . . . . . . . . . . . . . .27

Biologics, vaccines. . . . . . . . . . . . . . . .29

Electrolytes . . . . . . . . . . . . . . . . . . .35

Glycerin . . . . . . . . . . . . . . . . . . . . .37

Phosphoric acid. . . . . . . . . . . . . . . . . .40

Lime, hydrated . . . . . . . . . . . . . . . . . .43

Mineral oil. . . . . . . . . . . . . . . . . . . .47 

Sucrose octanoate esters . . . . . . . . . . . . .51 

Discussion document: Oxalic acid . . . . . . . . .53 

Handling Subcommittee

Topics

2020 Sunset substances review 

Calcium carbonate. . . . . . . . . . . . . . . . .87 

Flavors. . . . . . . . . . . . . . . . . . . . . .90 

Gellan gum . . . . . . . . . . . . . . . . . . . .95

Oxygen . . . . . . . . . . . . . . . . . . . . . 104

Potassium chloride . . . . . . . . . . . . . . . 107 

Alginates. . . . . . . . . . . . . . . . . . . . 109

Calcium hydroxide. . . . . . . . . . . . . . . . 114

Ethylene . . . . . . . . . . . . . . . . . . . . 118

Glycerides (mono and di) . . . . . . . . . . . . 123

Magnesium stearate . . . . . . . . . . . . . . . 125

Phosphoric acid. . . . . . . . . . . . . . . . . 130

Potassium carbonate. . . . . . . . . . . . . . . 133 

Sulfur dioxide . . . . . . . . . . . . . . . . . 135 

Xanthan gum. . . . . . . . . . . . . . . . . . . 138

Fructooligosaccharides (FOS) . . . . . . . . . . 143

Gums: Arabic, Carob bean, Guar,

Locust bean. . . . . . . . . . . . . . . . 152 

Lecithin - de-oiled. . . . . . . . . . . . . . . 159 

Tragacanth gum . . . . . . . . . . . . . . . . . 173 

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 CONTENTS 

Handling Subcommittee

Topics

Proposal: Sodium chlorite for the generation of

chlorine dioxide gas . . . . . . . . . . . 178

Proposal: Silver dihydrogen citrate. . . . . . . 207

Proposal: Japones pepper . . . . . . . . . . . . 225

Proposal: Ethiopian pepper . . . . . . . . . . . 235

Proposal: Tamarind seed gum. . . . . . . . . . . 243

Discussion document: Pullulan. . . . . . . . . . 258 

Discussion document: Collagen gel (casing) . . . 262 

Crops Subcommittee

Topics

2020 Sunset substances review 

Alcohols: ethanol, isopropanol . . . . . . . . . 268

Sodium carbonate peroxyhydrate . . . . . . . . . 272

Newspaper or other recycled paper. . . . . . . . 278

Plastic mulch and covers . . . . . . . . . . . . 281 

Aqueous potassium silicate . . . . . . . . . . . 288 

Elemental sulfur . . . . . . . . . . . . . . . . 296 

Lime sulfur. . . . . . . . . . . . . . . . . . . 300 

Sucrose octanoate esters . . . . . . . . . . . . 316 

Hydrated lime. . . . . . . . . . . . . . . . . . 323 

Liquid fish products . . . . . . . . . . . . . . 326 

Sulfurous acid . . . . . . . . . . . . . . . . . 331 

Ethylene . . . . . . . . . . . . . . . . . . . . 335 

Microcrystalline cheesewax . . . . . . . . . . . 340 

Potassium chloride . . . . . . . . . . . . . . . 347 

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 CONTENTS 

Crops Subcommittee

Topics

Proposal: Allyl isothiocyanate (AITC). . . . . . 350 

Proposal: Sodium citrate . . . . . . . . . . . . 365 

Proposal: Natamycin. . . . . . . . . . . . . . . 374 

Proposal: Strengthening the organic seed guidance

 October 2018 . . . . . . . . . . . . . . . 387 

Discussion document: Ammonium citrate and

 Ammonium glycinate . . . . . . . . . . . . 399 

Discussion document: Calcium acetate . . . . . . 402 

Discussion document: Paper pots. . . . . . . . . 404 

Deferred Proposals/Final votes . . . . . . . . . 413 

NOSB work agendas/Materials update . . . . . . . 413 

Officer Elections. . . . . . . . . . . . . . . . 418 

Other business and closing remarks . . . . . . . 424 

Adjourn. . . . . . . . . . . . . . . . . . . . . 428 

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P-R-O-C-E-E-D-I-N-G-S 

8:35 a.m. 

 CHAIRMAN CHAPMAN: All right. It's 

8:35 and we'll come back into order for our last 

day of our NOSB meeting. Today we have the 

Livestock Subcommittee, the Handling 

Subcommittee, the Crops Subcommittee, a review of 

the work agenda and then officer elections. So 

quite a bit today. 

But before we get into any of that, 

we're going to follow up on the request from Dave 

for some more information about enforcement 

activities, and I'm going to hand it over briefly 

to Jenny to talk a bit more about that. 

DR. TUCKER: Okay. Well, we're 

starting by just reminding folks of the four NOP 

priorities, so that's the first slide. The goal 

here is to provide a bit more specificity around 

the actions that we've taken on imports and the 

successes that we have had in that area. So I 

think we sort of alluded to some of those 

yesterday, but we wanted to put them all in one 

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place. 

So why don't I just -- I can just get 

up and come over there. There's not that many 

slides. 

Okay. There we go. Thank you. 

So let's review specific actions on 

imports. And again, I think I alluded to a lot 

of these in Wednesday's presentation, but having 

them all in one place with a bit more specificity 

will help, I think. 

So USDA does continue to actively 

investigate foreign organic supply chains, and 

the Black Sea region certainly is an area of 

focus. So we have issued proposed and final 

revocations. We've successfully revoked three 

operations in Russia and Turkey and are pursuing 

a complaint for hearing against a fourth. 

Multiple other investigations are in 

progress with the cooperation of both private and 

federal partners using technology and risk 

assessment indices. And so OIG and APHIS are 

important partners with us. I've been talking 

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about the relationship building that's been 

happening there. 

We've been having close communication 

with U.S. importers. Increased information 

sharing there. We are investigating fumigation 

notices when products are destined for the 

organic market are treated at the border. 

So sort of outcomes of that. As we've 

been monitoring what's happening with 

certification in that region of the almost 1,200 

operations in that area that were formerly 

certified, only about 700 remain certified, so 

there's been a significant drop. 

Many have surrendered or have been 

suspended or revoked by their certifier, so the 

actions that I just spoke about in terms of 

revocations and hearings or actions and OP has 

taken. But certifiers are also taking action 

there. 

So the trade data. So the question is 

so what? What is the outcome? There has been a 

95 percent drop in the volume of organic corn 

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from Turkey, and so that is taking the difference 

between the highest imported volume that was 

recorded in January 2016 and the most recent data 

point which was August 2018. So 95 percent drop. 

So hopefully that communicates some progress. 

Next slide. Okay. Let's talk about 

specific action with certifiers. So face-to-face 

training in the U.S. and Europe. We have done 

webinars on adverse actions on verifying reported 

yields. This has been a challenge in terms of 

capability development. 

We have been doing unannounced 

inspections and testing. It's been required for 

all grain and oil seed suppliers in Turkey and 

the Black Sea and for all incoming vessels in 

that region. So testing has not only resulted in 

product being diverted from the organic supply 

chain, but it's also directly resulted in some of 

those surrenders that I mentioned. 

We have issued non-compliances to 

certifiers and we have proposed a suspension of a 

certifier's satellite office. That's on appeal 

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right now. 

We have also focused our oversight on 

all those surrendered operations just to make 

sure they don't just reapply through some other 

certifier. And so we have asked certifiers to be 

keeping us up to date. There has been some 

certifier shopping of surrendered operations in 

that area, but to date they have not been 

certified. 

Okay. Let's go ahead. So what we're 

doing, sort of government level. I talked about 

-- illustrated our rapid response approach for 

questionable imports. I walked through the 

Serbian case study on Wednesday. And so that 

rapid response approach allows us to pretty 

quickly figure out what's happening when we start 

seeing questionable imports. 

We have developed a standardized 

process for ship-specific checks and have been --

and investigated multiple shipments in that way. 

We've published two policy memos, I 

mentioned this on Wednesday, on the impacts of 

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APHIS requirements for organic imports. It's 

really raised awareness across the industry. 

And we're also partnering more with 

our perishable commodity licenses. That's run 

through a different program within AMS. And so 

we issued a joint letter and that's gotten a lot 

of coverage in the produce community. 

We are doing a much better job of 

sharing information on questionable imports. We 

have built relationships across APHIS. I did go 

to my Miami with APHIS in August. And we're 

communicating more with on-the-ground folks with 

the Foreign Ag Service. Those are bridges that 

are new for us in extending our capability 

overseas. 

We are ready, I mentioned on 

Wednesday, to contract with CBP to initiate 

organic message SAT programming. So now that 

we're in a new fiscal year, that will make that 

project able to move forward more quickly. 

Next slide. Okay. So what are some 

examples of blocked shipments? We had some corn 

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that were coming from -- corn was coming from 

Turkey. Crops were grown in Russia, Moldova and 

Kazakhstan. These were refused entry by APHIS. 

Corn and soybeans have been blocked coming from 

Turkey, with corn from Kazakhstan. 

APHIS has been a very valuable partner 

in this work. We have blocked shipments of 

chickpeas, and there was a blueberry shipment 

from Chile which was not only stopped, but 

recalled and destroyed. 

Let's keep going. All of this needs 

to be within a broader understanding of the risk. 

U.S. organic sector is now fully integrated with 

the global marketplace and imports have continued 

to increase in size and scope. So we are 

introducing new approaches to manage that, but 

when you look at the growth between 2011 and 

2017, we have gone from $667 million over 20 HS 

trade codes in 72 countries. It's increased to 

1.9 billion across 57 trade codes in 89 

countries. That's just in six years. So this is 

a tremendous growth out there in the market. 

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And then here are some of -- so 

pictures of the type of analysis we're now better 

able to do quickly. I've mentioned that we were 

able to recruit an economist with very tight ties 

in with the Foreign Ag Service, and he has done a 

really nice job of helping us access and analyze 

data sources that we haven't really looked --

been able to look at as thoroughly before. 

So here's a chart for example of 

import volume of organic corn where we're looking 

at Turkey, Argentina and Serbia. So Serbia again 

a case study I raised. Turkey we all know about. 

This is in metric tons, but it helps you see some 

of the trend lines over time. So you can see 

some growth in that Turkey market that has now 

dropped off. But this is also allowing us to see 

what is coming up and what has happened most 

recently so that we can adjust our risk-based 

oversight appropriately based on changes in these 

curves over time. 

So that's the end of that 

presentation. Again the goal was to give --

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respond to the Board's request for some 

additional context on both the actions we're 

taking and some of the successes over the last 

year. So thanks for listening. 

CHAIRMAN CHAPMAN: Any questions for 

Jenny? 

Dave? 

MEMBER MORTENSEN: Jenny, thank you. 

And that is the very kind of thing I was asking 

about, so thank you for going to the trouble of 

pulling that together. 

DR. TUCKER: Thank you for raising the 

question. 

MEMBER MORTENSEN: It's clarifying. 

Thank you. And it is encouraging to see the 

progress in outcomes by the steps that we're 

taking to make change. 

DR. TUCKER: It's a work in progress 

and will never be done, but we will keep on 

going. 

MEMBER MORTENSEN: So if I could, just 

a couple of questions. Of the approximately 500 

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operations, I think you used the word an 

operation would be a farm or would that be a 

certifying agency and a farm and a -- what would 

an operation be? 

DR. TUCKER: Yes, thanks for -- that's 

a good question. Operation includes farms and 

businesses, so we just call them certified 

operations. So listings in the Organic Integrity 

Database. 

MEMBER MORTENSEN: Okay. So could you 

give us some insight into what it was about those 

500 out of almost 1,200 that resulted in them 

having their organic certification revoked in a 

very short period of time? 

DR. TUCKER: So different suspensions 

and revocations would have happened for different 

reasons, and a lot of those were done at the 

certifier level. And so I don't -- we don't have 

case -- when a certifier suspends or somebody 

surrenders, it gets logged in the Organic 

Integrity Database. We don't have all the 

context for the investigation that occurred that 

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led to that outcome. 

MEMBER MORTENSEN: We wouldn't have 

access to that information? 

DR. TUCKER: So we -- I mean, honestly 

we could ask the certifiers for all of the 

investigative records that led to the suspension. 

I'm more interested in getting them out of the 

game and going to the -- making sure we're 

getting a broad coverage. 

Certifiers are our point of contact on 

the ground and that's what they're there for. 

And so we're doing capability development with 

them to make sure they're on the -- doing the 

right things on the ground and have issued 

notices of non-compliances. So I suspect that 

some of the non-compliances to certifiers caused 

them to change their actions which led to some of 

these adverse actions against operations. 

MEMBER MORTENSEN: Yes, because that 

-- to me this is an example of the discussion 

that we had on the risk-based modeling yesterday, 

hot spots of non-compliance, cool spots of good 

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behavior. It would be interesting if the data 

could be mined in a way that we had some sense 

for the collective qualities about an operation 

that leads it to be one of 500 and the collective 

qualities of an operation that leads it to be one 

of the other 700 so that it helps us target not 

only the operations in Turkey, but in Serbia or 

other places. Is that possible with the data 

that we have or not? 

DR. TUCKER: I'm not sure we 

immediately have that kind of data. This is a 

bit of a balance between -- there are a lot of 

hot spots out there. 

MEMBER MORTENSEN: Yes. 

DR. TUCKER: And so it's a bit of a 

balance between looking to what's next and 

analyzing where we actually think we've really 

had some impact. Yes, we can do more analysis on 

that to analyze it. I think honestly there are 

enough problems out there that I would rather 

take a more broad let's-go-to-the-next-hot-spot, 

and we know they're out there. 

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 MEMBER MORTENSEN: Okay. 

DR. TUCKER: Yes. 

MEMBER MORTENSEN: And just one last 

question: There is a spike for example in the 

Serbian grain trade in the graph. None or so low 

that it was -- you can't see it on the Y axis to 

2018 up to whatever 20,000 units. Does that set 

of a risk-based trigger? 

DR. TUCKER: Yes, and that's why we 

immediately when we saw the -- we heard about the 

crops coming in from -- so that was a -- it was a 

good flag. And we have immediately deployed 

Foreign Ag Services on the ground there. We also 

-- it is true that that government has been 

investing in organic production and I think -- so 

we have to remember that just because there's a 

spike doesn't mean they're all bad actors. That 

there are countries that are investing in organic 

MEMBER MORTENSEN: Yes. 

DR. TUCKER: -- as a growth area. 

MEMBER MORTENSEN: Yes. 

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DR. TUCKER: But I think we have a 

good indicator of what the government has been 

doing to foster that growth responsibly and we 

have our Foreign Ag Service on the ground. 

That's capabilities we didn't have a year-and-ahalf ago. 

MEMBER MORTENSEN: Yes. 

DR. TUCKER: And so I think that 

that's where we can -- again you see another sort 

of spike there that might tell me, well, gosh, 

maybe I need to go spend some time somewhere 

else, too. 

MEMBER MORTENSEN: Yes. 

DR. TUCKER: Yes, and that -- I think 

that's an early warning system that is new and 

that is useful. 

MEMBER MORTENSEN: Thank you, Jenny, 

for pulling this together. It's very helpful. 

Appreciate it. 

DR. TUCKER: Thank you. We are going 

to be; final comment, funding a project this 

year. I mentioned it at the spring; we weren't 

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able to get in place before the end of the fiscal 

year, but we are going to -- we are funding a 

project to do some pretty focal pilot commodity 

country studies. So how would you do a mass 

balance at a country level for a specific 

commodity? 

And so one of the case studies we'll 

do will be in the Black Sea region and then one 

of the case studies will be in South America. 

And I think that will also give us yet another 

repeatable process that we can quickly field when 

we see these risk areas. We can immediately 

deploy a team. Okay. Let's go to that country 

and do this kind of ground-level work. We don't 

have a specific repeatable process for doing that 

yet, but in six months we will. 

CHAIRMAN CHAPMAN: Since this isn't on 

the agenda, I'm going to ask folks to keep their 

questions brief so we can get back to agenda 

items. 

Emily? 

MEMBER OAKLEY: This is just a thank 

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you for that data. I think it was really helpful 

and I also think more of that at the beginning of 

each NOSB would be appreciated by the broader 

stakeholder community that might not be here 

today. But thank you so much. This was great. 

CHAIRMAN CHAPMAN: Harriet? 

VICE CHAIR BEHAR: Thank you. I 

reiterate thanking you, but our market -- and 

especially I think getting this out so this could 

deter bad actors because they know we're looking. 

But that being said, our market is still 

extremely attractive. And so I think we need to 

be continually improving. And I'm very happy 

about the block chain development because I think 

we need to stay ahead of them instead of them 

ahead of us. 

CHAIRMAN CHAPMAN: Okay. Thank you 

very much, Jenny, for that and pulling it 

together on such short notice. 

With that we will move back to our 

regular scheduled programming and I will hand it 

over to Ashley for the Livestock Subcommittee. 

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MEMBER SWAFFAR: So good morning, 

everyone. Welcome to the Livestock Committee. 

Many of you ended your evening with alcohol, so 

we're going to start our morning with alcohols. 

So we'll start this morning with the 

program reading the first item. 

DR. MATHEWS: Thank you. So we'll 

start the sunset reviews. We had Section 205. 

603 of the National List, Synthetic Substances 

Allowed for Use in Organic Livestock Production. 

Paragraph (a) is disinfectant sanitizer and 

medical treatment as applicable, alcohols. And 

the listing is ethanol disinfectant and sanitizer 

only prohibited as a feed additive. 

MEMBER SWAFFAR: Thank you. 

Jesse? 

MEMBER BUIE: The NOP has allowed 

ethanol use in organic livestock production for 

over 20 years. While there have been several --

while there are several alternatives to the 

material, ethanol is relatively harmless and 

provides an additional mean of disinfectant 

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thereby reducing the chances of developing 

bacterial resistance. 

Public comments were overwhelming in 

favor of relisting ethanol. It is unlikely that 

large-scale spills and associated environmental 

contaminations will occur under the allowed use 

of ethanol as a sanitizer and disinfectant in 

organized livestock production. 

Are there any questions? 

MEMBER SWAFFAR: Thanks, Jesse. 

Open it up. Anybody? 

(No audible response.) 

MEMBER SWAFFAR: I see no further 

debate. 

Tom? 

CHAIRMAN CHAPMAN: Okay. So this is 

a motion coming from the Crop Subcommittee. 

Motion is made by Jesse, seconded by Harriet. 

The motion is to remove ethanol-based products 

from the National List. 

To remind folks this is sunset voting 

and in sunset voting in order to ensure each make 

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material gets a vote we vote to remove. We make 

motions to remove. So if you do not want to 

remove the substance, if you do not want to 

sunset the substance, then you vote no. If you 

do want to sunset the substance, if you do want 

to remove it, then you vote yes. 

So this motion came from the 

subcommittee with six no votes. The voting will 

start with Dan. A no vote is to remove; a yes 

vote is to retain. 

Dan? 

MEMBER SEITZ: No. 

MEMBER MORTENSEN: No. 

MEMBER ELA: No. 

MEMBER BRADMAN: No. 

MEMBER GREENWOOD: No. 

MEMBER DE LIMA: No. 

MEMBER SCHWARTZ: No. 

MEMBER ROMERO-BRIONES: No. 

MEMBER OAKLEY: No. 

MEMBER BAIRD: No. 

MEMBER BUIE: No. 

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 MEMBER SWAFFAR: No. 

SECRETARY RICE: No. 

VICE CHAIR BEHAR: No. 

CHAIRMAN CHAPMAN: Chair votes no. 

SECRETARY RICE: It's 15 no; 0 yes; 0 

absent. 

CHAIRMAN CHAPMAN: Fifteen no. The 

motion fails. 

Ashley? 

MEMBER SWAFFAR: Great. Back to 

Jesse, isopropanol. 

Sorry, you want to read, Clarissa? 

DR. MATHEWS: Still in Section 205. 

603, paragraph (a), Alcohols. The listing is 

isopropanol disinfectant only. 

MEMBER BUIE: The NOP has allowed 

isopropanol alcohol use in livestock production 

for over 20 years. It is used as a disinfectant 

only. No specific or significant information was 

presented that warranted removal of the material 

during the 2017 sunset. 

Public comments were overwhelmingly in 

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favor of relisting isopropanol. 

Are there any questions? 

MEMBER SWAFFAR: Any discussion? 

(No audible response.) 

MEMBER SWAFFAR: Tom? 

CHAIRMAN CHAPMAN: Okay. We have a 

motion to remove isopropanol from the National 

List. The motion was made by Jesse and seconded 

by Harriet. A no vote is to retain; a yes vote 

is to remove. And the voting will start with 

Dave. 

MEMBER MORTENSEN: No. 

MEMBER ELA: No. 

MEMBER BRADMAN: No. 

MEMBER GREENWOOD: No. 

MEMBER DE LIMA: No. 

MEMBER SCHWARTZ: No. 

MEMBER ROMERO-BRIONES: No. 

MEMBER OAKLEY: No. 

MEMBER BAIRD: No. 

MEMBER BUIE: No. 

MEMBER SWAFFAR: No. 

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SECRETARY RICE: No. 

VICE CHAIR BEHAR: No. 

MEMBER SEITZ: No. 

CHAIRMAN CHAPMAN: Chair votes no. 

SECRETARY RICE: That's 0 yes; 15 no; 

0 absent. 

CHAIRMAN CHAPMAN: Fifteen no. The 

motion fails. 

Ashley? 

MEMBER SWAFFAR: Moving onto aspirin. 

DR. MATHEWS: The listing in 205.603(a) 

is aspirin, approved for health care use to 

reduce inflammation. 

MEMBER SWAFFAR: Okay. That's my 

material. So aspirin in an anti-inflammatory 

drug used for temporary relief of minor aches and 

pains. I think we all know what that substance 

does. 

Overwhelming support in the public 

comment to relist it, those saying it was 

critically important to the humane treatment of 

their animals and it's a widely-available 

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medication for use. So open it up for discussion. 

Yes, Harriet? 

VICE CHAIR BEHAR: Since I live and 

work in a livestock, organic livestock area, this 

is a very important tool. 

MEMBER SWAFFAR: Thanks. Anybody 

else? 

(No audible response.) 

MEMBER SWAFFAR: Tom? 

CHAIRMAN CHAPMAN: So this is a motion 

to remove aspirin from the National List. The 

motion is made by Ashley and seconded by Harriet. 

A no vote is to remove; a yes -- sorry. A no 

vote is to retain; a yes vote is to remove. And 

the voting will start with Steve. 

MEMBER ELA: No. 

MEMBER BRADMAN: No. 

MEMBER GREENWOOD: No. 

MEMBER DE LIMA: No. 

MEMBER SCHWARTZ: No. 

MEMBER ROMERO-BRIONES: No. 

MEMBER OAKLEY: No. 

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MEMBER BAIRD: No. 

MEMBER BUIE: No. 

MEMBER SWAFFAR: No. 

SECRETARY RICE: No. 

VICE CHAIR BEHAR: No. 

MEMBER SEITZ: No. 

MEMBER MORTENSEN: No. 

CHAIRMAN CHAPMAN: Chair votes no. 

SECRETARY RICE: That's 0 yes; 15 no; 

0 absent. 

CHAIRMAN CHAPMAN: The motion fails. 

Ashley? 

MEMBER SWAFFAR: Thanks. Next up is 

vaccines. 

Clarissa? 

DR. MATHEWS: in Section 205.603(a) the 

listing is biologics, vaccines. 

MEMBER SWAFFAR: Thank you. Harriet? 

VICE CHAIR BEHAR: Okay. So this is for 

relisting of this material that we will be voting 

on, but in addition we did ask for a work agenda 

item, which we have put forward to the National 

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Organic Program to deal with somewhat of the 

inconsistent implementation on whether or not 

genetically modified vaccines are allowed or not. 

Some certifiers allow, some do not. 

In public comment there was universal 

agreement that this material should remain on the 

National List. Some commented that it was the 

most commonly used preventative health care tool. 

People noted that it's not just for the 

improvement of the herd as far as not losing 

animals, but also for long-term genetic 

improvement, keeping as many of your animals 

healthy and alive. And as a preventative it's 

very useful in an organic system. 

Let's see. Numerous certifiers, 

advocacy groups and individual livestock 

operators all spoke to the need for this product 

and many spoke for the support for the work 

agenda item. There were not comments against 

adding this working -- adding to the work agenda, 

although some commenters were mute. 

MEMBER SWAFFAR: Thank you, Harriet. 

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We'll open for discussion. Anyone? 

CHAIRMAN CHAPMAN: There were no 

comments against adding to the work agenda? I 

thought I saw some in the written comment. 

VICE CHAIR BEHAR: I did not see any 

comments speaking against the work agenda. I did 

see some commenters who spoke for keeping 

vaccines on the list and then didn't say anything 

about the work agenda, and then others who spoke 

to both issues in support. 

MEMBER SWAFFAR: Tom, no discussion? 

Seriously? 

(No audible response.) 

MEMBER SWAFFAR: I just wanted to --

I'd call on myself then. I just say vaccines are 

critically important, and I think we heard that 

overwhelmingly from the public. And I do 

encourage the program to take a look at our work 

agenda request item because there is a very 

different take on this listing across certifiers 

with some asking if vaccines are -- asking their 

clients to double-check and see if their vaccines 

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are made from excluded methods whereas others 

don't address that at all. And so our work agenda 

request was to help with consistency for everyone 

throughout different certifiers. 

Steve? 

MEMBER ELA: For my own edification, 

Ashley, and not being a livestock person at all. 

So are there -- of the vaccines that maybe made 

using an excluded methods are there alternatives? 

MEMBER SWAFFAR: For many of those 

there are not. So what you have to deal with; 

obviously I understand the poultry vaccines, we 

are federally mandated by the FDA to give certain 

vaccines to birds to prevent Salmonella 

enteritidis, and those are the ones that could be 

made by excluded methods, and to my knowledge 

there are no alternatives for those. And there's 

a few others that are given to poultry also that 

don't have those. 

Emily? 

MEMBER OAKLEY: Do you have any concern 

that the program won't add this to your work 

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agenda? 

MEMBER SWAFFAR: Absolutely. 

MEMBER OAKLEY: Okay. I know that no 

one from the program who can directly answer that 

is here right now. I don't want to put Clarissa 

on the hot seat. 

Oh, you can answer it? 

DR. MATHEWS: I can say that the work 

agenda item request is currently under review and 

we do anticipate a response fairly soon. 

MEMBER SWAFFAR: A response that could 

say no. Yes. 

MEMBER MORTENSEN: I wonder as we talk 

about these things could we really speak into the 

mic? I can't hear most of this discussion. 

MEMBER OAKLEY: Can I just then 

clarify? I guess I'm saying that I would echo 

support for this work agenda item and I think 

probably many of us would. And if that would be 

helpful to the program and their deliberations, 

perhaps we could express that now. 

MEMBER SWAFFAR: Harriet? 

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 VICE CHAIR BEHAR: The work agenda item 

did specifically discuss the inconsistency 

between certifiers as well as that it's not our 

intention to take away either federally-mandated 

vaccines, nor to take away important tools for 

producers, but instead to just bring that 

consistency. Because right now there are some 

operations that cannot access GMO vaccines. 

MEMBER SWAFFAR: They're not GMO. 

They're made from excluded methods. Just want to 

say that. 

VICE CHAIR BEHAR: Okay. 

MEMBER SWAFFAR: Correct terminology. 

Any further discussion? 

(No audible response.) 

MEMBER SWAFFAR: Tom. 

CHAIRMAN CHAPMAN: So we have a motion 

to remove biologics, vaccines from the National 

List. The motion was made by Harriet, seconded 

by Jesse. A no vote is to retain; a yes vote is 

to remove. And the voting will start with Asa. 

MEMBER BRADMAN: No. 

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 MEMBER GREENWOOD: No. 

MEMBER DE LIMA: No. 

MEMBER SCHWARTZ: No. 

MEMBER ROMERO-BRIONES: No. 

MEMBER OAKLEY: No. 

MEMBER BAIRD: No. 

MEMBER BUIE: No. 

MEMBER SWAFFAR: No. 

SECRETARY RICE: No. 

VICE CHAIR BEHAR: No. 

MEMBER SEITZ: No. 

MEMBER MORTENSEN: No. 

MEMBER ELA: No. 

CHAIRMAN CHAPMAN: Chair votes no. 

SECRETARY RICE: That was 0 yes; 15 

no; 0 absent. 

CHAIRMAN CHAPMAN: The motion fails. 

Ashley? 

MEMBER SWAFFAR: Okay. Moving onto 

our next substance, electrolytes. 

Clarissa? 

DR. MATHEWS: At section 205.603(a) the 

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listing is electrolytes without antibiotics. 

MEMBER SWAFFAR: Thank you. Harriet? 

VICE CHAIR BEHAR: Electrolytes are 

used extensively for again promotion of health of 

replacement of vitamins and minerals. 

And there was universal support from 

certifiers, advocacy groups, farmer organizations 

and milk buyers and sellers all there. So 

basically every aspect of the organic community 

supported the relisting of electrolytes. 

MEMBER SWAFFAR: Thank you, Harriet. 

Open it up. Any discussion? 

(No audible response.) 

MEMBER SWAFFAR: Great. 

Tom? 

CHAIRMAN CHAPMAN: So we have a 

seconded motion from the Subcommittee. The motion 

is to remove electrolytes from the National List. 

The motion was made by Harriet and seconded by 

Dan. A yes vote is to remove; a no vote is to 

retain. And the voting will start with Rick. 

MEMBER GREENWOOD: No. 

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 MEMBER DE LIMA: No. 

MEMBER SCHWARTZ: No. 

MEMBER ROMERO-BRIONES: No. 

MEMBER OAKLEY: No. 

MEMBER BAIRD: No. 

MEMBER BUIE: No. 

MEMBER SWAFFAR: No. 

SECRETARY RICE: No. 

VICE CHAIR BEHAR: No. 

MEMBER SEITZ: No. 

MEMBER MORTENSEN: No. 

MEMBER ELA: No. 

MEMBER BRADMAN: No. 

CHAIRMAN CHAPMAN: Chair votes no. 

SECRETARY RICE: That was 0 yes; 15 no; 

and 0 absent. 

CHAIRMAN CHAPMAN: The motion fails. 

Ashley? 

MEMBER SWAFFAR: Thank you. Moving on 

next to glycerin. 

Clarissa? 

DR. MATHEWS: At Section 205.603(a) the 

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listing is glycerin allowed as a livestock teat 

dip. Must be produced through the hydrolysis of 

fats or oils. 

MEMBER SWAFFAR: Thanks. Moving on. 

Sue? 

MEMBER BAIRD: Glycerin is a byproduct 

of the soap manufacturing process. It can be 

either done synthetically or by natural 

hydrolysis, therefore the reason for the 

annotation. It is used extensively in teat dips 

either as the sole component or as an ingredient 

in others, including chlorhexidine. 

There was actually 18 comments and all 

of them were in support of using and relisting 

glycerin on the National List. Beyond Pesticides 

did want more clarification on the process of 

fermentation which is not addressed in this. 

MEMBER SWAFFAR: Thank you, Sue. 

Opening it up for discussion. Anyone? 

Tom? 

CHAIRMAN CHAPMAN: I mean, just as a 

procurer of glycerin in my day job there's -- the 

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fermentation segment of the glycerin supply chain 

is small to non-existent. It is almost all a 

product of the soap industry and other industries 

like that, but fermentation is a very, very small 

subsection. 

MEMBER SWAFFAR: Thank you. 

Any further discussion? 

(No audible response.) 

MEMBER SWAFFAR: Great. 

Tom? 

CHAIRMAN CHAPMAN: So this is a motion 

that comes from the -- a seconded motion that 

comes from the -- a seconded motion that comes 

from the Subcommittee. The motion is to remove 

glycerin. The motion was made by Sue and 

seconded by Harriet. The motion is to remove 

glycerin from the National List. A yes vote is 

to remove; a no vote is to retain. And the 

voting will start with Lisa. 

MEMBER DE LIMA: No. 

MEMBER SCHWARTZ: No. 

MEMBER ROMERO-BRIONES: No. 

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MEMBER OAKLEY: No. 

MEMBER BAIRD: No. 

MEMBER BUIE: No. 

MEMBER SWAFFAR: No. 

SECRETARY RICE: No. 

VICE CHAIR BEHAR: No. 

MEMBER SEITZ: No. 

MEMBER MORTENSEN: No. 

MEMBER ELA: No. 

MEMBER BRADMAN: NO. 

MEMBER GREENWOOD: No. 

SECRETARY RICE: That's 0 yes; 15 no; 

and 0 absent. 

CHAIRMAN CHAPMAN: The motion fails. 

Ashley? 

MEMBER SWAFFAR: Great. Moving on to 

phosphoric acid. 

Clarissa? 

DR. MATHEWS: At Section 205.603(a) the 

listing is phosphoric acid allowed as an 

equipment cleaning provided that no direct 

contact with organically-managed livestock or 

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land occurs. 

MEMBER SWAFFAR: Thank you. Moving on, 

Dan? Dan? 

MEMBER SEITZ: So phosphoric acid is 

allowed as an equipment cleaner provided that no 

direct contact with organically-managed livestock 

or land occurs 

There were 15 comments on this all in 

favor of continued listing. The substance is not 

without some problems. It can be harmful to 

health and the environment. Nonetheless it's 

considered by all commenters as being essential. 

A couple of commenters noted that there is some 

inconsistency among certifiers regarding whether 

there should be a rinse after use and this 

inconsistency comes from the fact that some of 

the phosphorous materials have inert ingredients 

included with them. So there were a couple of 

commenters who suggested that there be an 

annotation made for this substance in the future. 

MEMBER SWAFFAR: Okay. Opening it up to 

discussion. 

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VICE CHAIR BEHAR: Since I live in an 

organic dairy area this is an essential 

ingredient both on the farm and in processing, if 

it's a non-farm processing, for removal of milk 

stone in the pipelines. 

MEMBER SWAFFAR: Any further 

discussion? 

(No audible response.) 

MEMBER SWAFFAR: I would just like to 

say hopefully the Materials Committee can look at 

this also in their sanitizer review and we'll go 

from there. Great. 

Turning it back, Tom. 

CHAIRMAN CHAPMAN: So we have a 

seconded motion from the Subcommittee. The motion 

is to remove phosphoric acid from the National 

List. The motion was made by Dan and seconded by 

Harriet. A yes vote is to remove; a no vote is to 

retain, and the voting will start with Eric. 

MEMBER SCHWARTZ: No. 

MEMBER ROMERO-BRIONES: No. 

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MEMBER OAKLEY: No. 

MEMBER BAIRD: No. 

MEMBER BUIE: No. 

MEMBER SWAFFAR: No. 

SECRETARY RICE: No. 

VICE CHAIR BEHAR: No. 

MEMBER SEITZ: No. 

MEMBER MORTENSEN: No. 

MEMBER ELA: No. 

MEMBER BRADMAN: No. 

MEMBER GREENWOOD: No. 

MEMBER DE LIMA: No. 

CHAIRMAN CHAPMAN: Chair votes no. 

SECRETARY RICE: That's 0 yes; 15 no; 

0 absent. 

CHAIRMAN CHAPMAN: Motion fails. 

Ashley? 

MEMBER SWAFFAR: Thank you. Moving onto 

hydrated lime. 

Clarissa? 

DR. MATHEWS: At Section 205.603, 

paragraph (b) is Topical Treatment External 

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Parasiticide or Local Anesthetic as Applicable, 

the listing is lime, hydrated as an external pest 

control not permitted to cauterize physical 

alterations or deodorize animal wastes. 

MEMBER SWAFFAR: Thank you. A-dae? 

MEMBER ROMERO-BRIONES: Lime, hydrated 

is primarily used to control pests, and I 

emphasize that it is not permitted for use as --

to cauterize physical alterations or deodorize 

animal wastes. 

The majority of comment were in favor 

of relisting. The Subcommittee discussed a 

possible annotation. One commenter suggested that 

that is outside the purview of the Subcommittee, 

but the majority suggested relisting. 

MEMBER SWAFFAR: Great. Open it up for 

discussion. Anyone? 

(No audible response.) 

MEMBER SWAFFAR: I just want to say why 

we added that annotation part in there was 

because some certifiers have written in that 

hydrated lime -- many producers want to use it in 

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bedding for deodorizing animal waste, so we were 

looking to get comments there, and we did from 

one certifier that the operations that they work 

with do request hydrated lime to be used for 

bedding and for whitewash to help with 

deodorizing animal waste. So we will talk about 

that as a Subcommittee if we want to work on that 

annotation. 

Any other discussion? 

Harriet? 

VICE CHAIR BEHAR: Well, this is one of 

the strengths of our National List, that it -- if 

there was -- if it was going to be used in 

bedding, it would probably have to be -- have 

discussion with the Crops Subcommittee because of 

the effect that that bedding is not just going --

it's going to go out on the land. So that's one 

of the reasons I think it was not. So you can use 

hydrated lime on organic land -- I mean, on 

organic crops and livestock for those specific 

uses. So that is a strength in our National List 

that we can identify the specific areas and then 

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prohibit it in other areas. 

MEMBER SWAFFAR: Thank you. No further 

discussion. 

Tom? 

CHAIRMAN CHAPMAN: So it's a motion 

that comes from the Subcommittee. The motion is 

to remove hydrated lime. The motion was made by 

A-dae and seconded by Jesse. A yes vote is to 

remove; a no vote is retain, and the voting will 

start with A-dae. 

MEMBER ROMERO-BRIONES: No. 

MEMBER OAKLEY: No. 

MEMBER BAIRD: No. 

MEMBER BUIE: No. 

MEMBER SWAFFAR: No. 

SECRETARY RICE: No. 

VICE CHAIR BEHAR: No. 

MEMBER SEITZ: No. 

MEMBER MORTENSEN: No. 

MEMBER ELA: No. 

MEMBER BRADMAN: No. 

MEMBER GREENWOOD: No. 

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MEMBER DE LIMA: No. 

MEMBER SCHWARTZ: No. 

CHAIRMAN CHAPMAN: Chair votes no. 

SECRETARY RICE: That's 0 yes; 15 no; 

0 absent. 

CHAIRMAN CHAPMAN: The motion fails. 

Ashley? 

MEMBER SWAFFAR: Moving onto mineral 

oil. 

Clarissa? 

DR. MATHEWS: At Section 205.603(b) the 

listing is mineral oil for topical use and as a 

lubricant. 

MEMBER SWAFFAR: Thank you. A-dae? 

MEMBER ROMERO-BRIONES: So mineral oil 

acts as an external parasiticide when applied 

topically to animals infested with mites, lice 

and other parasites. 

The majority of commenters suggested 

relisting. One commenter wanted some 

clarification on the FDA listing because NOP was 

informed that mineral oil was not received -- has 

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not received approval through the FDA drug 

approval process for external label use by 

licensed veterinarians, but the majority 

suggested relisting. 

MEMBER SWAFFAR: Any discussion? 

Harriet? 

VICE CHAIR BEHAR: So this is an 

illustration that even if the NOSB requires 

something that the FDA and other areas within the 

USDA and the Federal Government have to also 

approve that use in order for it to be used in 

organic production. So even though the NOSB in 

response to producer requests voted to allow it 

for release of constipation, it was not approved 

by FDA. So it can't -- it's not allowed to be 

used. 

MEMBER SWAFFAR: Devon, you want to say 

anything about that? 

MR. PATTILLO: I think mineral oil is 

one of the substances that's in a proposed rule 

right now, and while it's -- I believe there are 

off-label uses allowed at veterinarian 

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discretion. 

PARTICIPANT: (Off microphone 

comments.) 

MR. PATTILLO: I believe under FDA 

regulations veterinarians are allowed to use 

substances for off-label uses in certain 

circumstances. I believe in the proposed rule we 

have some discussion about the FDA approval of --

and their -- I guess their perspective on these 

uses. 

MEMBER SWAFFAR: And for clarification 

one of those uses would be an oral use for 

impaction. 

So, Harriet? 

VICE CHAIR BEHAR: Just for 

clarification mineral oil is a petroleum product. 

MEMBER SWAFFAR: Steve? 

MEMBER ELA: So just so I'm clear, but 

the use externally as we read is approved by FDA? 

So it's just that for impaction or -- that is on 

the -- in the question mark? 

MEMBER SWAFFAR: Well, and like Devon 

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side, there is some approval for off-label use 

for veterinarians by the FDA. And that comes in 

the new set of rulemaking stuff, so they will 

have a discussion in there. But it's also used 

for lubrication and various other uses also. 

Harriet? 

VICE CHAIR BEHAR: So the lubrication 

is typically used by technicians who are doing 

artificial insemination, and so they're -- if 

you've never stuck your arm in a cow, it's quite 

an experience. 

MEMBER SWAFFAR: We'll leave it at that 

image. 

Back to you, Tom. 

CHAIRMAN CHAPMAN: We have a motion to 

remove mineral oil. It's a seconded motion that 

came from the Subcommittee. The motion was made 

by A-dae and seconded by Sue. A no vote is to 

retain; a yes vote is remove, and the voting will 

start with Emily. 

MEMBER OAKLEY: No. 

MEMBER BAIRD: No. 

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MEMBER BUIE: No. 

MEMBER SWAFFAR: No. 

SECRETARY RICE: No. 

VICE CHAIR BEHAR: No. 

MEMBER SEITZ: No. 

MEMBER MORTENSEN: No. 

MEMBER ELA: No. 

MEMBER BRADMAN: No. 

MEMBER GREENWOOD: No. 

MEMBER DE LIMA: No. 

MEMBER SCHWARTZ: No. 

MEMBER ROMERO-BRIONES: No. 

CHAIRMAN CHAPMAN: Chair votes no. 

SECRETARY RICE: That's 0 yes; 15 no; 

0 absent. 

CHAIRMAN CHAPMAN: Motion fails. 

Ashley? 

MEMBER SWAFFAR: Moving onto sucrose 

octanoate esters or from here on out SOEs. 

Clarissa? 

DR. MATHEWS: At Section 205.603(b) the 

listing is sucrose octanoate esters, CAS No's. 

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42922-74-7 and 58064-47-4, in accordance with 

approved labeling. 

MEMBER SWAFFAR: Thank you. 

Moving to Sue. 

MEMBER BAIRD: Yes, SOEs are -- belong 

to the organic chemical family bonding sucrose 

fatty acid esters and they're manufactured from 

sucrose, table sugar, and octanoic acid esters. 

They're registered as a biopesticide, but in this 

particular -- because we are addressing it as 

livestock, it's addressed for varroa mite control 

in honeybees. It has been listed -- and it is 

listed by EPA a such. 

There were seven public comments, but 

the two that were most pertinent, in my mind at 

least, was Beyond Pesticides said because they 

had supported continuing to keep it on the list 

and they said they're disappointed that they 

haven't seen any comments from beekeepers 

regarding the efficacy and hazard of SOEs in 

controlling varroa mites. And they made the 

comment they'd heard informally that beekeepers 

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don't use it because it's too hard to use. 

And then NOC, National Organic 

Consumers, made the point that the Environmental 

Protection Agency, even though it's approved for 

use, they don't have any currently listed or 

approved products that are to be used. So they 

thought that -- both of those thought that it 

should be removed. 

MEMBER SWAFFAR: Open it up for 

discussion. 

Harriet? 

VICE CHAIR BEHAR: So I was one of the 

people who voted yes to remove this product. I'm 

pretty sure I might be the only beekeeper on the 

Board. I have used this product myself. And when 

we were voting on it we did not have certain 

information. In the oxalic acid technical review 

there was a notation that the other product --

one of the other products on the National List 

for control of varroa mites, SOEs, was no longer 

registered by the EPA. There was no product 

registered by the EPA for use and that the 

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product itself was ineffective in controlling 

varroa mite. 

And so we could possibly deduce from 

that that the reason why there's no products 

registered is because nobody was buying it 

because it was ineffective. So there's a question 

of even if the product could be considered 

somewhat benign, if no one can actually use it in 

the United States, if there are no products --

because the EPA doesn't have anything registered, 

and if there are no products available and it's 

ineffective, why is it taking up space on the 

National List? 

Because during our deliberations for 

new products to put on the National List we 

always look to see if there are other products 

available. And so having a product that's 

actually not available and that nobody would 

actually want to use and having used it myself 

once, I would tell you I don't want to use it 

again. It is very hard on the bees. It's very, 

very difficult to use. It makes a total mess. 

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And it kills bees, so we don't want to be doing 

that. So I would -- I'm planning on voting yes 

for removal for this product for those reasons. 

In addition, we spoke during the 

Subcommittee calls about use in other countries. 

And so I'm not sure if Sue did any work, but I 

reached out to various certifiers, and I know 

Ashley also asked a certifier during the public 

-- you asked Sam Welsch of OneCert. He was one of 

the people I also reached out to. I spoke to 

organic inspectors, or emailed, and asked them if 

they had seen any use in other countries. And I 

also spoke with a seller of organic honey coming 

from Brazil and he said he didn't know of his 

suppliers using it. 

So by taking it off the National List 

I don't believe we're doing any harm or removing 

anything essential from the National List for 

either domestic or international honeybee 

production. 

MEMBER SWAFFAR: Tom? 

CHAIRMAN CHAPMAN: So look at ERS 

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import data, the vast majority of honey appears 

to come from Brazil. I don't see any comments 

from certifiers in Brazil about honey. Did you --

which -- I mean, are you able to share the 

specific certifiers that spoke to its non-usage? 

VICE CHAIR BEHAR: I talked with 

company called Suranda. 

CHAIRMAN CHAPMAN: Okay. 

VICE CHAIR BEHAR: And they -- he's 

actually a Brazilian and then he then asked 

around. 

CHAIRMAN CHAPMAN: Okay. 

VICE CHAIR BEHAR: They import organic 

honey from Brazil. 

CHAIRMAN CHAPMAN: Yes, Suranda is an 

American company, but in pulling data off of the 

OID, I mean 85 percent of the honey producers in 

Brazil are certified by IBD. I was unable to 

reach IBD, so I just haven't been able to verify 

that it's not used in Brazil. 

MEMBER SWAFFAR: Harriet? 

VICE CHAIR BEHAR: SOEs are not on the 

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European Union approved list of products. 

CHAIRMAN CHAPMAN: Is Brazil in the 

European Union? 

VICE CHAIR BEHAR: I don't know, but if 

anyone's selling into the EU, they would not be 

able to use it for organic production either. 

I think really more than whether or 

not it would be allowed there to me is if it's 

ineffective, I just think that eventually, even 

if some people are using it, they'll probably 

stop using it, which again was my experience. And 

there are much better products for the control of 

varroa mite that I'd rather see those be on the 

National List rather than saying, well, we 

already formic acid and sucrose octanoate esters, 

so why do we need oxalic, for instance? 

So, and I think too with consistency 

with the rest of the -- of the U.S. regulatory 

agencies if our EPA doesn't have anything 

registered, again why would we have something on 

our list, similar to what we just discussed with 

mineral oil. 

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MEMBER BAIRD: And I don't -- I'm 

sorry, did you say yes? Did you call me or not? 

MEMBER SWAFFAR: Dave was on the list, 

but I just want to remind board members to please 

talk into the mics. 

Dave was next. 

MEMBER MORTENSEN: Yes, I just was 

doing some Googling last night, nursing my cold 

and reading about these compounds. Marla Spivak 

at the University of Minnesota is like a 

nationally renowned beehive manager, bee 

community ecologist, and she pretty much echoes 

what Harriet just said about it being hard on 

bees and that there are other things that are 

more effective and less hard on bees. And so with 

that in mind I was left with the impression that 

this is not something that we keep on the list. 

MEMBER SWAFFAR: Thank you. 

Sue? 

MEMBER BAIRD: Well, perhaps I've just 

changed my mind. I was -- my point was that it 

did -- the review said that it was relatively 

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benign. In fact really benign on bees. You're 

saying that science says that's not true, so I'm 

not sure. 

I've thought about this a lot and the 

point is made that it's hard to use. I always 

hesitate -- and I also understand Harriet's 

argument that we could have other things on there 

if we take this off. I don't think that's ever 

been a criteria. We can put another thing on 

without taking something off. I'm always afraid 

to take something out of the toolbox. There are 

so few products out there. It is registered by 

EPA. There's no specific product that has been 

listed by EPA, but it is registered by EPA, and I 

think that's a point that might be taken. I just 

hate to take things off when someday -- maybe 

we're not using it now, but maybe someday we need 

it. I don't know. 

MEMBER SWAFFAR: Emily? 

MEMBER OAKLEY: I know that we can't 

necessarily quantify its use in Brazil, Tom, but 

I think in the absence of use here or in the 

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absence of comments from producers there I think 

this is actually great example of the sunset 

process and our ability to review materials for 

their effectiveness and their use. And I think 

should it become more widespread or used at all, 

to our knowledge in the future, it can always be 

re-petitioned for use. But I think this is an 

example of a compelling reason to remove 

something. 

MEMBER SWAFFAR: Thank you. 

Scott? 

SECRETARY RICE: I just was -- is there 

any reason to think efficacy would be different 

on -- in the environment in Brazil than here in 

the U.S.? I don't know if anybody has -- sounds 

like we just don't have that data. That was 

something that occurred to me. 

I just had a thought on any -- is 

there any reason to believe that efficacy would 

be different on bees in Brazil? If -- I know that 

we've heard efficacy is limited here, but that 

would just be a concern of mine in terms of 

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removing a tool if it's working elsewhere. 

MEMBER SWAFFAR: Tom? 

CHAIRMAN CHAPMAN: Yes, I mean, so from 

what I've read on this and what -- from the 

Subcommittee, I mean, it seems there's two 

arguments here: There's the efficacy argument, 

which seems to be a very valid argument for 

potentially delisting this material. And then 

there's the use argument. I guess I just want to 

point out that several members of this Board have 

pointed out the fact that it's difficult for us 

to get feedback from members of the community, 

small farmers here in the U.S., small farmers 

abroad. 

We saw the organization that went in 

to get the Costa Rican contingent here from Costa 

Rica. And this isn't -- the honey produced in 

Brazil is not being produced in Sao Paulo. It's 

not being produced in Rio de Janeiro. It's 

produced far out in the Amazon so it can comply 

with the large non-production areas, nonconventional production areas for the bees to 

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forage. And so you're talking about very rural, 

very small, very far out apiary production to get 

the majority of honey that comes here. 

So I wouldn't -- I just warn us 

against using -- weighing that reason too heavily 

given I don't know how effective our 16-day 

comment period was to get out to those folks in 

that rural area. 

MEMBER SWAFFAR: Harriet? 

VICE CHAIR BEHAR: To respond to Scott 

about the efficacy, would it be different in 

another region, having again used the product, I 

would say no. A big part of the reason it's so 

hard to use it's extremely sticky. I don't really 

believe it would be less sticky in a tropical 

climate. 

And in our deliberations we do look at 

items on the National List. Just in Livestock we 

have looked at a whole variety of various teat 

dips and the fact that there's four or five 

already on the list, and then we try to compare 

is this one needed? We do look at if something is 

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already on the list. So there could be two, three 

more materials that come forward for varroa mite 

control. And again, if it's not effective and 

there's nothing -- and I believe that there's 

nothing registered is because nobody was buying 

it, and so they didn't choose to relist or reregister with the EPA. I think just -- I don't 

think it necessarily belongs. 

And then lastly there are also 

systems-based approaches to control a varroa 

mite. My husband just walked in and he helps me. 

We work together on various types of varroa mite 

control which in conjunction with materials have 

kept our bees fairly healthy. So there isn't just 

only reliance on materials for control of this 

insect pest. 

MEMBER SWAFFAR: Dave? 

MEMBER MORTENSEN: Yes, I guess just to 

Tom's point and -- which I think is an excellent 

one, but -- and I realize ethylene is an 

extraordinary exception. I mean, we had 10 or so 

people coming from another country to speak to us 

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about it. It seems to be that we should have at 

least one comment from a beekeeper or someone, or 

a company that sells honey from the beekeepers 

that they've purchased from on behalf of those 

growers. Yes, because even in our debate about 

paper pots and all of that, we got lots and lots 

of comments on that, I think. Did it rise to the 

level of a letter to the Secretary of 

Agriculture? No, but the comment are there. 

So I think the absence of comments 

left me thinking this certainly can't be a very 

compelling product to have on the market for 

beekeepers. 

MEMBER SWAFFAR: I'm going to call on 

myself and then I'll call on Harriet. 

So I'm a little torn on this material. 

I was a vote on the Subcommittee to relist, but I 

think there are several things of why we're not 

getting comments that we're hearing from and that 

is because we don't produce that much honey in 

the U.S., organic, because we don't have 

apiculture standards. And that is my biggest pet 

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peeve about this material and the new petition 

material is we do not have standards, but people 

are petitioning us items to use for those 

standards. 

I fought on Livestock to even accept 

the petition for oxalic acid because we don't 

have bee standards. So a little pet peeve of 

mine. But so I think that's why we're not hearing 

any comments from producers is because we don't 

really have that much bee production in the U.S. 

Most of it comes from Brazil. And to Tom's point, 

those folks aren't involved in our process. 

But I am torn on this material because 

it's not registered with the EPA. It doesn't 

sound like it works for bee producers that do use 

it here in the U.S. And I think we have some 

other options that they could be using, so I feel 

like I'm going to -- I will be switching my vote. 

I voted to relist, but I will be voting to delist 

this material. 

Sorry. Harriet? 

VICE CHAIR BEHAR: Just to remind us 

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all that we did have a previous review comment 

period in the spring and we didn't hear anything. 

We do have a fairly active organic honey industry 

in Hawaii, which is part of the United States, 

and they have brought petitions forward and are 

paying attention, and yet we did not see any 

support for this product from the organic honey 

producers in Hawaii. 

MEMBER SWAFFAR: Steve? 

MEMBER ELA: A question maybe for Tom, 

I don't know. I mean, if -- those Brazilian 

growers, are they certifying to the U.S. 

standards? 

CHAIRMAN CHAPMAN: Yes. I mean, that 

data I cited with the certifiers was from the 

Organic Integrity Database. 

MEMBER ELA: Okay. 

MEMBER SWAFFAR: Great. Any further 

discussion? 

(No audible response.) 

MEMBER SWAFFAR: Tom? 

CHAIRMAN CHAPMAN: Okay. We have a 

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motion to remove sucrose octanoate esters from 

the National List. It's a seconded motion from 

the Subcommittee. The motion was made by Sue and 

seconded by Jesse. A yes vote is to remove; a no 

vote is to retain, and the voting will start with 

Sue. 

MEMBER BAIRD: This is a hard one, but 

I'll still going to say no. 

MEMBER BUIE: Also, but no 

MEMBER SWAFFAR: Yes. 

SECRETARY RICE: Yes. 

VICE CHAIR BEHAR: Yes. 

MEMBER SEITZ: Yes. 

MEMBER MORTENSEN: Yes. 

MEMBER ELA: Yes. 

MEMBER BRADMAN: Yes. 

MEMBER GREENWOOD: Yes. 

MEMBER DE LIMA: No. 

MEMBER SCHWARTZ: No. 

MEMBER ROMERO-BRIONES: Yes. 

MEMBER OAKLEY: Yes. 

CHAIRMAN CHAPMAN: Chair votes no. 

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SECRETARY RICE: That was 9 yes; 5 no 

-- no -- technical difficulties here. That was 10 

yes; 5 no; 0 absent. 

CHAIRMAN CHAPMAN: The motion passes. 

Ashley? 

MEMBER SWAFFAR: Moving onto our 

petitioned material. No introduction, so we'll 

just go right into Harriet. 

VICE CHAIR BEHAR: Okay. Oxalic acid. 

Let's stay in the beekeeping world. 

So this is actually the first time any 

subcommittee has done this, so just so the public 

knows that we decided that if we receive a 

petition but we cannot move through our entire 

process of a technical review and then a vote 

from Subcommittee to the full Board, we thought 

we would then just bring forward a discussion 

document so people could see the materials that 

are under review and get yet one more shot at 

giving us input. So there will be probably a 

petition proposal coming forward in the spring on 

this item. We actually did just receive the 

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technical review for this material. 

But we -- as far as -- the only 

comments that were received I saw were that we 

need apiculture standards, which I wholeheartedly 

agree. And I have tried to speak to the program 

about whether -- why this is not moving forward, 

but it really is not a priority I think partially 

because of what Ashley said, that there is not a 

clamoring for them within the borders of the 

United States. However, there are beekeepers who 

would like organic standards. There are 

certifiers who have standards. And so therefore 

having a material on the National List would be 

useful to beekeepers within our borders and of 

course those who sell into our market. 

Oxalic acid is an acid similar to 

formic acid which is on our National List. It can 

be applied to the hive in two ways: in a sugar 

syrup that then trickles down between the frames 

and as a vapor treatment. 

There are tools that beekeepers can 

either make or purchase that vaporize the oxalic 

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acid. And if you've ever seen a beehive, there's 

a small entrance in the bottom. You put the 

vaporizer in and then that vapor moves up and 

that causes the mites to fall off the bees. 

Typically the beekeeper has a screened bottom 

board where those mites fall through and 

underneath the hive. And they don't crawl back 

up, which is kind of a nice thing. We just don't 

want to have mites that can crawl around. 

The other use for it which I found to 

be quite interesting and that there is no other 

product available is that it could also be put in 

a sugar syrup and sprayed on packaged bees. So 

when beekeepers need to replace bees at times, 

they can purchase a queen and a package of bees 

usually in a screened box. And many times they 

will arrive from infested hives and be full of 

mites. And so the person buying those packages --

basically that package will die and they've spent 

$120 or whatever for that package. So this is a 

way for people who are selling packages to be 

able to then remove the mites and sell a cleaner 

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product to those buying those replacement bees. 

There is a concern that the material 

is categorized as very hazardous by the EPA 

because it is an acid. It also used for bleaching 

wood, although it's somewhat of a different 

formulation than what is being requested for use 

for control of varroa mites in organic honeybee 

hives. 

And we did ask a couple of questions 

for the public and we did not get any response to 

those questions, I think because there were no 

beekeepers. 

As the lead for this product I'm going 

to reach out, and once we get the TR and ask 

maybe some more specific questions, just on my 

own just to see what the demand is for it. And I 

will reach out to Brazil as well. 

You can even help me, Tom, with some 

contacts. I would appreciate that. 

However, I do know that in my little 

bee club in Southwest Wisconsin we have discussed 

this material extensively. We've seen vaporizing 

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equipment and we've talked to beekeepers that 

feel it's very effective and have used it 

continuously for a few years. So it is 

effective. It can be used. It's accessible. 

And I think that was a homemade vaporizer, so 

fairly inexpensive. 

MEMBER SWAFFAR: Thanks, Harriet. 

That was -- you told me it would be short and 

sweet. I'd hate to see long. 

So just to remind everyone, we are not 

voting on this. We're just discussing it and 

we'll come back after we receive a TR, maybe not 

spring, maybe fall. 

Dave? 

MEMBER MORTENSEN: Yes, in the reading 

that I've done on this; and I did talk to a 

beekeeper before I left the East, this compound 

is much more useful for varroa mite management in 

a hive. It's a little worrying to be thinking 

about the protective gear that you're wearing, 

and I was just imagining also you're working with 

bees. I guess this maybe happens when you're not 

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worried about also being protected from working 

with the bees themselves. It sounds clunky from 

a management point of view, but it's apparently 

much more effective in an integrated pest 

management program for hive management. 

MEMBER SWAFFAR: Anyone else? 

(No audible response.) 

MEMBER SWAFFAR: I just want to echo 

what I said earlier about SOEs. I'm very 

hesitant to be working on items for apicultures 

when we do not have standards from the program. 

So I'd like to ask the program to please move 

forward because there are people certifying and 

selling organic honey without standards. 

Okay. And that's it on that 

discussion. The Livestock Committee will now 

move onto other business that we have. 

If I could have the next slide? So 

we've talked to and we've heard lots of comments 

from the public at this meeting and prior 

meetings about origin of livestock and how it's a 

problem that the program is not moving forward to 

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that. 

So we've talked internally and we'd 

like to put forward a resolution, and that 

resolution states that it has come to the 

attention of the National Organic Standards Board 

that the continued state of varying interruptions 

-- interpretations of practices around the origin 

of livestock standards is creating market 

instability for organic producers. The 2015 USDA 

origin of livestock proposed rule was based on 

six recommendations from the NOSB between 1994 

and 2006. 

The proposed rule responds to findings 

from the July 2013 USDA Office of Inspector 

General audit report on organic milk operations 

stating that certifying agents were interpreting 

the origin of livestock requirements differently. 

Rulemaking is necessary to ensure 

consistent interpretation and enforcement of the 

standards for origin of livestock and provide 

industry with additional clarity of application 

of the organic dairy standards. 

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In early 2017 the origin of livestock 

proposed rule was removed from the Government's 

Unified Agenda Regulatory and Deregulatory 

actions. Support for this rule has been 

expressed through public comment by the majority 

of organic stakeholders. Strong federal 

oversight is essential for fair consistent 

certification and for creating a level playing 

field for all certified operations. 

So therefore be it resolved by 

unanimous vote the National Organic Standards 

Board as USDA's Federal Advisory Board on Organic 

Issues and representing organic farmers, 

ranchers, processors, retailers and consumers 

urges the Secretary to directly issue a final 

rule for origin of livestock that incorporates 

public comments submitted in response to the 

proposed rule. 

So that is other business. 

Harriet? 

VICE CHAIR BEHAR: I enthusiastically 

second this motion. 

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MEMBER SWAFFAR: Great. Open it up 

for discussion. 

Emily? 

MEMBER OAKLEY: I also 

enthusiastically support this resolution. And I 

have a question about the possibility of its 

delivery to the Secretary and how that takes 

place. 

MEMBER SWAFFAR: Jenny? 

DR. TUCKER: So after every NOSB 

meeting we go back and brief our leadership on 

what happened during the meeting, what they key 

issues were. Clearly two of those coming out of 

this meeting will be paper pots and origin of 

livestock. And so this will be communicated up 

the chain through our standard briefing process, 

so this will be shown to first the administrator. 

And then it will go up the ladder from there. 

MEMBER SWAFFAR: Emily? 

MEMBER OAKLEY: Just a follow-up. I 

don't know about precedents or effectiveness, but 

would it be effective for this to be delivered or 

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is it even appropriate for it to be delivered 

directly from the NOSB to the Secretary? 

DR. TUCKER: In the past it has been 

more effective to communicate through the program 

so that we can sort of present the work of the 

Board in context and so within the framework of 

the advisory board, the chain of command and 

operations. 

MEMBER SWAFFAR: Harriet? 

VICE CHAIR BEHAR: I would like also 

for the Secretary to know that the NOP's slogan 

is "Consumers Trust the Organic Label," and it's 

through consistency that that trust is imbedded. 

And so we're asking for consistency here, and the 

way it comes is through rulemaking and 

enforcement. And so we really would like to see 

this happen. 

Yes, it's true that there is great 

hardship out in the organic dairy farms, having 

-- I inspect them, I live with them, they're my 

neighbors. But also to me it's that protection 

of our label, that we have that integrity and 

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that consistency. So I encourage you to 

enthusiastically bring it forward. 

DR. TUCKER: And so let me also sort 

of continue with what the next step would be. So 

we'd brief it up the chain. It is -- we're --

it's the end of October here. The next window 

for the Unified Regulatory Agenda is the 

administration will start to consider items that 

are elevated from the programs or proposed from 

the programs sometime in January. And so that's 

when those conversations will begin to occur. 

Now the regulatory approach, there is 

-- remains the two for one regulations or set of 

principles related to regulation. So this rule 

would be evaluated against other rules being 

considered at -- across the agency and department 

in developing their regulatory agenda for the 

spring. 

MEMBER SWAFFAR: So I had Tom next. 

CHAIRMAN CHAPMAN: So it's a good 

thing we voted sucrose octanoate esters off the 

list. That's one. We just need to get to one 

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more. 

(Laughter.) 

CHAIRMAN CHAPMAN: Jenny is not 

laughing at that comment. 

I do want to echo my support for this 

as well as point that -- point out that OFPA does 

in its purpose lay out that one of the purposes 

of OFPA is to assure that the organic products 

are produced, meet a consistent standard. And 

from the feedback that we've heard from the 

public, that just does not seem to be the case 

when it comes to the origin of livestock. 

The NOSB has kind of done its work 

here in the past and I would hope that the USDA 

hears the community, the industry, the retailers, 

the processors, the ranchers about the need for 

this to go forward so that clarity can be brought 

to this section of the standard 

MEMBER SWAFFAR: Dan? 

MEMBER SEITZ: So this is a question 

for Jenny. First I want to say I also support 

this. 

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Jenny, I understand, though I don't 

agree with the philosophic idea of the removing 

two regulations for every new regulation that you 

might add, but this is -- the NOSB and NOP are in 

a unique situation in that these regulations 

don't apply to everyone. They just apply to the 

people who want to play this game, so to speak, 

the organic game. And the other thing is this is 

a regulations-based process. 

So what I wondering is whether the 

leadership within the USDA can -- sees this sort 

of structurally different, because it really does 

approach regulation from an entirely different 

standpoint from then regulations that apply to an 

entire industry say. 

DR. TUCKER: So a couple of comments 

on this. So there are -- especially within the 

agricultural marketing service there are actually 

a lot of different sectors that want to be 

regulated. So the organic folks aren't the only 

folks who want to be regulated. And so I think 

that -- it is -- while it is certainly special 

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about organic, there are a lot of special sectors 

that would actually really like regulation. And 

so I think that is a consistent tension. 

I think, yes, things to keep in mind 

that will come up with respect to origin of 

livestock, so putting it out on the table is that 

the regulations need to be linked directly with 

the act, the Organic Foods Production Act. And 

so the administration will take a careful look at 

what OFPA actually says about origin of livestock 

and that may also weigh into its willingness to 

pursue regulations around this that this 

administration is very focused on reading what 

thee act actually says, so what Congress has 

actually authorized. I think you've seen that in 

rulemaking that has occurred over the last period 

of time. And so that is something that needs to 

be taken into account is what OFPA actually says 

about origin of livestock. So that is a bit of a 

challenge here. 

So I think that the administration, 

third, has also made it clear; Mr. Ibach made 

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this sort of clear the last time he visited this 

group is that there -- the primary focus and 

prioritization is enforcing the standards we have 

and not moving the goal post. That's a metaphor 

that the Undersecretary used the last time he was 

here. So I think those are all variables that 

will play into the administration's consideration 

of this item. 

quality 

MEMBER SWAFFAR: Emily? 

MEMBER OAKLEY: I just want to ask a 

question and reiterate that stakeholders can 

definitely help us in this endeavor because the 

NOSB has essentially done what we can do. So as 

we discussed previously throughout this meeting, 

if people who care deeply about this issue can 

write about it and encourage farmers to write 

about it -- in other work that I do I know 

letters really do matter and a letter to the 

Secretary of the Agriculture is not 

insignificant. And five letters from producers 

is a lot of letters to the Secretary, but not 

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necessarily a hard ask for stakeholders to 

achieve. So just want to put that out there. 

And when you mentioned January as the 

time frame, I wondering would that be a strategic 

time to submit letters or is any time 

appropriate? 

DR. TUCKER: Any time is appropriate 

to submit letters. January will be the time 

where we will be actively briefing this issue. 

MEMBER SWAFFAR: I'm going to call on 

myself, which Emily just hit on everything I was 

going to say, but reiterate those groups: 

industry trade organizations, dairy trade 

organizations, please get meetings with the 

Secretary. We are doing what we can. Obviously 

resolutions from us aren't huge steps in the 

world, but we want to help you as best we can. 

And so wholeheartedly support this. 

Very quickly, Harriet. 

VICE CHAIR BEHAR: I also encourage 

certifiers that may have lost operations to also 

write and say -- so if there's certifier shopping 

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going on due to inconsistent implementation. 

MEMBER MORTENSEN: Quickly. 

MEMBER SWAFFAR: Really quick. 

MEMBER MORTENSEN: Quickly on the 

letter writing, when we heard from the farmers 

about grain problem integrity in La Crosse, 

Wisconsin last winter, I was watching the 

reaction of the politicians in room and it was 

clear that the most moving information were case 

studies where their own operation was affected in 

what way -- what was the economic hit on their 

operation so that people could actually see what 

-- how this translates on the ground. 

MEMBER SWAFFAR: Okay, guys. I think 

we'll cut discussion off. So we have a motion 

and a second on the floor. 

CHAIRMAN CHAPMAN: Could you remind me 

on who made the motion and the second? 

MEMBER SWAFFAR: I made the motion; 

Harriet seconded that motion. 

CHAIRMAN CHAPMAN: Thank you. 

So we have a motion and a second to 

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adopt this resolution. I am just going to read 

the resolved portion of it. "Therefore, be it 

resolved by unanimous vote," if that occurs, "the 

National Organic Standards Board as the USDA's 

Federal Advisory Board on Organic Issues and 

representing organic farmers, ranchers, 

processors, retailers and consumers urges the 

Secretary to directly issue a final rule for the 

origin of livestock that incorporates public 

comments submitted in response to the proposed 

rule, Docket No. AMS-NOP-11-0009." 

A yes vote is to adopt this 

resolution; a no vote is to reject it. The 

voting will start with Jesse. 

MEMBER BUIE: Yes. 

MEMBER SWAFFAR: Yes. 

SECRETARY RICE: Yes. 

VICE CHAIR BEHAR: Yes. 

MEMBER SEITZ: Yes. 

MEMBER MORTENSEN: Yes. 

MEMBER ELA: Yes. 

MEMBER BRADMAN: Yes. 

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MEMBER GREENWOOD: Yes. 

MEMBER DE LIMA: Yes. 

MEMBER SCHWARTZ: Yes. 

MEMBER ROMERO-BRIONES: Yes. 

MEMBER OAKLEY: Yes. 

MEMBER BAIRD: Yes. 

CHAIRMAN CHAPMAN: Chair votes yes. 

SECRETARY RICE: That's 15 yes; 0 no. 

CHAIRMAN CHAPMAN: The motion passes. 

Ashley? 

MEMBER SWAFFAR: That concludes 

everything that the Livestock Committee has. We 

were hoping to be done a little quicker 

yesterday, but Scott and his beard kept talking. 

(Laughter.) 

CHAIRMAN CHAPMAN: That beard always 

gets in the way. 

Okay. We're going to move onto the 

Handling Subcommittee. It's about 10:00. We'll 

start with the sunsets, I think, Lisa, and then 

at some point -- maybe we can get through the 

sunsets. If not, we'll take a break at some 

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point in there. 

So at this time handing it over to 

Lisa, Chair of the Handling Committee. 

MEMBER DE LIMA: All right. We're 

going to start off with sunsets. First up 

calcium carbonate. 

Clarissa? 

DR. MATHEWS: At Section 205.605, NonAgricultural, Non-Organic Substances Allowed as 

Ingredients in or on Processed Products Labeled 

as Organic or Made with Organic-Specified 

Ingredients or Food Groups. Paragraph (a), NonSynthetics Allowed. The listing is calcium 

carbonate. 

MEMBER DE LIMA: Scott? 

SECRETARY RICE: Thank you. Calcium 

carbonate is widely used as a dietary supplement, 

an antacid, dough conditioner, acidity regulator 

in wines, a stabilizer, anti-caking agent, 

gelling agent. There's quite a number of uses. 

And it is widely supported in public 

comments. And I wanted to highlight we had two 

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comments from certifiers expressing concern 

regarding the TR's reference to the purified 

version of this, which is precipitated calcium 

carbonate, or PCC. The TR referenced that as 

synthetic. 

As we heard during the discussion in 

public comments that reference does not align 

with the use of NOP guidance 5033-1, the decision 

tree for classification of materials as synthetic 

or non-synthetic, which finds PCC to be a nonsynthetic substance. 

The TR, as we also heard, serves as 

just one aid to the Subcommittee in its review of 

a material and should not be looked to as the 

definitive voice when making a determination a 

material status as synthetic or non-synthetic. 

And again, just reiterating widespread support of 

this across the community. Thank you. 

MEMBER DE LIMA: Any discussion? 

Tom? 

CHAIRMAN CHAPMAN: Yes, I just want to 

echo Scott's comments there, and I think we can 

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even potentially clarify that on the cover sheet 

for this item. Oftentimes we get comments in the 

technical reviews or submissions by those 

reviewers that still don't align with the 

findings that are made by the NOSB, and so the 

NOSB findings should definitely take precedence 

on that and not -- and the TR is just not -- it's 

a source of information just like public comment. 

MEMBER DE LIMA: All right. I guess 

we're ready for a vote. Tom? 

CHAIRMAN CHAPMAN: All right. This is 

a seconded motion from the Subcommittee. It's a 

motion to remove calcium carbonate from the 

National List. The motion was made by Lisa and 

seconded by Scott. And the voting will start 

with Ashley. A yes vote is to remove; a no vote 

is to remain. 

MEMBER SWAFFAR: No. 

SECRETARY RICE: No. 

VICE CHAIR BEHAR: No. 

MEMBER SEITZ: No. 

MEMBER MORTENSEN: No. 

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 MEMBER ELA: No. 

MEMBER BRADMAN: No. 

MEMBER GREENWOOD: No. 

MEMBER DE LIMA: No. 

MEMBER SCHWARTZ: No. 

MEMBER ROMERO-BRIONES: No. 

MEMBER OAKLEY: No. 

MEMBER BAIRD: No. 

MEMBER BUIE: No. 

CHAIRMAN CHAPMAN: Chair votes no. 

SECRETARY RICE: That's 0 yes; 15 no; 

0 absent. 

CHAIRMAN CHAPMAN: The motion fails. 

Lisa? 

MEMBER DE LIMA: Next up is flavors. 

DR. MATHEWS: At Section 205.605(a) 

the listing is flavors, non-synthetic sources 

only and must not be produced using synthetic 

solvents in carrier systems or any artificial 

preservative. 

MEMBER DE LIMA: Tom? 

CHAIRMAN CHAPMAN: Natural flavors are 

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compound substances derived from natural sources 

including plants, herbs, spices, botanicals and 

other substances. They're typically used in 

small amounts in food products. Some were from a 

0.05 to 0.4 percent of ingredients typically. 

And they're used in products that generally 

contain less than the optimal amount of flavor 

necessary to give finished products their desired 

flavor profile. Widely used throughout the 

industry and there are virtually all applications 

of any sort of processed products including baked 

goods, dairy products, jams, jellies, snack 

foods, juice products, dry-pack good products, 

cereals, anything that's not fresh. Natural 

flavors are often proprietary formulations 

developed specifically for intended purposes and 

functionalities as well as to withstand the 

manufacturing process of which they're subjected 

to. 

We received a large amount of support 

for flavors from trade associations, industry and 

interest groups, many speaking to their 

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criticality in product formulations. Certifiers 

reported about hundreds of their operations that 

utilize these materials. Several commenters also 

supported the 2015 NOSB recommendation to add 

commercial availability to this listing. I 

should note that this recommendation was part of 

a proposed rule that was published earlier this 

year and that we heard earlier from Dr. Paul 

Lewis was still in the process and being actively 

being worked by the program. 

A few commenters objected to the 

categorical listing of flavors and rather that 

individual -- that this item be removed and 

individual flavors be specifically listed in 

their place. 

Other commenters had concerns around 

the use of excluded methods in flavoring 

constituents, however, it should be noted that 

the big three exclusions do apply to natural 

flavors. This was even reiterated in the written 

comments by FEMA, who is recognized by the FDA to 

establish the GRAS status of flavoring 

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constituents. 

MEMBER DE LIMA: Any discussion? 

Emily? 

MEMBER OAKLEY: Just want to reiterate 

support for the 2015 annotation and hope that 

proceeds quickly. 

MEMBER DE LIMA: Harriet? 

VICE CHAIR BEHAR: Flavors are another 

area where fermentation occurs in the manufacture 

of some of these non-synthetic flavors. And so 

if the Handling Subcommittee was thinking -- I 

know that that was brought up by the public -- by 

numerous public commenter about a review of 

fermentation process. 

MEMBER DE LIMA: Any other discussion? 

(No audible response.) 

MEMBER DE LIMA: All right. Tom? 

CHAIRMAN CHAPMAN: Okay. This is a 

seconded motion from the Subcommittee. The 

motion was made by Tom Chapman and seconded by 

Scott Rice. The motion is to remove flavors from 

the National List. A yes vote is to retain; a no 

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is to remove and the voting will start with -- a 

yes vote is to remove; a no vote is to retain, 

and the voting will start with Scott. 

SECRETARY RICE: No. 

VICE CHAIR BEHAR: No. 

MEMBER SEITZ: No. 

MEMBER MORTENSEN: No. 

MEMBER ELA: No. 

MEMBER BRADMAN: No. 

MEMBER GREENWOOD: No. 

MEMBER DE LIMA: No. 

MEMBER SCHWARTZ: No. 

MEMBER ROMERO-BRIONES: No. 

MEMBER OAKLEY: No. 

MEMBER BAIRD: No. 

MEMBER BUIE: No. 

MEMBER SWAFFAR: No. 

CHAIRMAN CHAPMAN: Chair votes no. 

SECRETARY RICE: That's 0 yes; 15 no; 

0 absent. 

CHAIRMAN CHAPMAN: Motion fails. 

Lisa? 

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MEMBER DE LIMA: Next up is gellan 

gum. 

DR. MATHEWS: At Section 205.605(a) 

the listing is gellan gum, CAS No. 71010-52-1, 

high acyl form only. 

MEMBER DE LIMA: Gellan gum is useful 

as a thickening and gelling agent in food 

production. Uses include bakery fillings, 

confections, dairy products, personal care items. 

Typically use of gellan gum is at less than 0.5 

percent of a finished product. And some of the 

unique properties of gellan gum are that it has a 

high viscosity at low concentrations and forms a 

thermal reversible gel. 

So public comments. There were a 

number of manufacturers who wrote in in support 

of the material with multiple of them stating 

that they're using gellan gum as a carrageenan 

replacement due to customer concerns. Also one 

that said they were using it as a vegetarian 

option instead of gelatin. A couple different 

public commenters requested that the CBI from the 

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original petition be disclosed and requested that 

the material be delisted until that happens. 

There were also requests to take 

measures to ensure that handlers are verifying 

that the gums are produced without excluded 

methods. And one retailer that commented on 

reports from consumers of negative reactions and 

generally consumers wanting to avoid carrageenan 

and other stabilizers and emulsifiers. 

Discussion? Emily? 

MEMBER OAKLEY: I just had a question 

about the abstention. Was that a new member who 

didn't have information or was there concern 

among Subcommittee members? 

MEMBER DE LIMA: Who abstained? I 

don't know. Oh, it was a new member that just 

didn't -- wasn't up to speed yet. 

Ashley? 

MEMBER SWAFFAR: So this one --

obviously you could tell through public comment 

that it got me going a little bit because I was a 

member that voted to remove carrageenan. And the 

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dairy industry worked very hard to find a 

replacement for carrageenan and listening to 

their customers. And gellan gum is that 

replacement. 

And I said when I voted to remove I'm 

concerned that next people will go after these 

gums. And here's the new sunset process, and we 

are seeing people say they don't want these gums 

relisted. And I think that is a real disservice 

to that industry because they tried to remove an 

item that many consumers had an issue with and a 

lot of consumers don't have as much of as a 

reaction to this item. 

So I really want to say that we should 

protect this material because the dairy industry 

reformulated, and it takes a long time to do that 

and change labels and do all that. So I really 

support this item for relisting. 

MEMBER DE LIMA: Dave? 

MEMBER MORTENSEN: Yes, I have a 

concern about some of the comments that I read 

and things that I read in the report about the 

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fermentation process and what we know about 

what's being fermented. 

And so when I was reading through 

these that was a recurring concern of mine, where 

the content of the process that gives rise to the 

gum is clear, Lisa, just so that you understand 

my logic, I was very comfortable with it, but in 

this case and in one or two other cases that --

at least as far as I can tell, that's not clear. 

Is it arising from GMO sources, for example? 

There's one of these where sugar beets is the 

source. Well, no, sorry. That's another 

subject. 

Yes. So anyway, if anyone on the 

Committee could speak to that or what your 

thoughts are about that potential conflict of us 

not really wanting to be doing things with GMO 

crops, and on the other hand not being consistent 

throughout our food system. 

MEMBER DE LIMA: Tom? 

CHAIRMAN CHAPMAN: I mean, I guess I 

have a question back to you on that one, Dave, 

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around why this product as a product of 

fermentation rises above other products. We just 

voted on ethanol alcohol used in crop production 

and ethanol could come -- is a product of 

fermentation at some point, which also could have 

source materials from any sorts of original 

product. And so that concern applies to 

potentially every material that could be a 

product of fermentation on this list. What I can 

say is --

MEMBER MORTENSEN: Maybe to that 

point, just so that we get this out on the table, 

we don't eat the alcohol. So we're eating this 

thing and the drink that we're drinking. And so 

knowing what's in the ingredient I think is 

important when we consume it as opposed to when 

we use it to wash tables or some other process. 

CHAIRMAN CHAPMAN: So that concern is 

going to still extend to every single product of 

fermentation that's on the National List, even on 

the handling side. And so just to make sure that 

you're going to raise that objection everywhere, 

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and we have dozens of those materials that are on 

the list. Generally the exclusion has been 

applied to the excluded methods. It's still 

applied to these substances and the -- and is 

generally applied to the microorganisms used to 

actually convert whatever carbohydrate substance 

is being turned into the finished good product 

that is then put in as a food ingredient. And I 

don't know, I guess I'll look to the certifier to 

tell me if I'm correct or incorrect in that 

interpretation. 

SECRETARY RICE: That -- yes. 

(Laughter.) 

MEMBER MORTENSEN: Well, just -- I 

mean, so anyway, just to -- so that folks know 

when we vote on things, that's one of the 

criteria that's in my mind. The other criteria 

that's in my mind is that it's important to know 

the source of whatever it is that we're 

fermenting. I am not personally convinced that 

we have a pure system so that when we ferment 

something, we know for example that every 

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characteristic of wheat that someone might be 

allergic to is no longer in the resulting 

fermented product. And so that's a concern of 

mine. 

MEMBER DE LIMA: Harriet and then Tom? 

VICE CHAIR BEHAR: So this -- I 

understand that there are some issues in 

consumers, on retailers. Steve is stating why 

can't people just shake things if they want to 

keep them in suspension and why do we need these 

gums, but as we've seen with carrageenan the 

marketplace has done the work. This would be on 

the label. If consumers choose not to buy it, 

the manufacturers of the materials, of the 

finished product will take note that their sales 

are dropping and decide to change. 

But the reality of the marketplace is 

that -- at this time is that things move around. 

And they are in storage. And they're sitting on 

trucks and they're -- that basically you don't 

want your chocolate milk with all the chocolate 

in the bottom and that sort of thing. 

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 So I will be voting for this material 

and I see it very much as more benign than the 

carrageenan and allow the processors to put it 

out there and see what the market says. 

MEMBER DE LIMA: Tom and then Sue? 

CHAIRMAN CHAPMAN: Yes, I just want to 

point out that allergens are strictly regulated 

in the U.S. under the Food Allergen Labeling 

Consumer Protection Act of 2004 under the 

authority of the FDA, and if folks do have 

concerns around allergen, that would probably be 

the appropriate location to lodge those concerns. 

MEMBER DE LIMA: Sue? 

MEMBER BAIRD: I know a majority, and 

I would say all certifiers send out if it's a 

non-agricultural, non-organic substance they send 

out a manufacturer's affidavit that the 

manufacturer has to state that the non-organic, 

non-agricultural substance is not produced with 

genetic-modified organisms, genetic engineering 

and/or using solvents that are not allowed. 

So I think unless we've got blatant 

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liars, you can put your mind to rest that there's 

no GMs in the fermented products. 

MEMBER DE LIMA: Ashley? 

MEMBER SWAFFAR: And I just want to 

point out that question was asked of a commenter 

yesterday or the day before, a predominant 

manufacturer of the gellan gum, and they 

confirmed they did not use GMOs. So just want to 

remind folks of that comment. 

MEMBER DE LIMA: All right. Tom? 

CHAIRMAN CHAPMAN: Okay. We have a 

motion to remove gellan gum from the National 

List. The motion was made by Lisa and seconded 

by Steve. A yes vote is to remove; a no vote is 

to retain, and the voting will start with 

Harriet. 

VICE CHAIR BEHAR: No. 

MEMBER SEITZ: No. 

MEMBER MORTENSEN: Yes. 

MEMBER ELA: No. 

MEMBER BRADMAN: No. 

MEMBER GREENWOOD: No. 

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MEMBER DE LIMA: No. 

MEMBER SCHWARTZ: No. 

MEMBER ROMERO-BRIONES: No. 

MEMBER OAKLEY: No. 

MEMBER BAIRD: No. 

MEMBER BUIE: No. 

MEMBER SWAFFAR: No. 

SECRETARY RICE: No. 

CHAIRMAN CHAPMAN: Chair votes no. 

SECRETARY RICE: That's 1 yes; 14 no, 

0 absent. 

CHAIRMAN CHAPMAN: Motion fails. 

Lisa? 

MEMBER DE LIMA: Next up is oxygen. 

Clarissa? 

DR. MATHEWS: At Section 205.605(a) 

the listing is oxygen, oil-free grades. 

MEMBER DE LIMA: So according to 

public comment oxygen is used by wineries, 

breweries and manufacturers of carbonated 

beverages. Certifiers reported that it's listed 

on 17 OSPs. One winery commented that they use 

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it for micro-oxygenation, a process where oxygen 

is added into red wine at a controlled rate and 

flow to stabilize color, improve astringencies 

and aromatic components of the final wine. 

Any discussion about this 

controversial material? 

Harriet? 

VICE CHAIR BEHAR: I consider oxygen 

essential. 

(Laughter.) 

MEMBER DE LIMA: Ashley? 

MEMBER SWAFFAR: In previous meetings 

there was the discussion of that. One board 

member may or may not have considered it 

essential in the past, so thanks for clarifying 

that, Harriet. 

MEMBER DE LIMA: No, and I would say 

it was great to have folks writing in public 

comment because this is one of those materials 

we've done; when was that, in Stowe two or three 

years ago, and looking at it again as part of the 

reorganization. And that first time around I 

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think people just thought, oh, well, it's oxygen. 

We don't need to write in and give any support. 

And it was good to see this time around specific 

uses and how producers are using it. It's 

helpful for us and for that to be on the record. 

All right. Tom? 

CHAIRMAN CHAPMAN: Yes, and I think 

Scott's beard is taking up all the oxygen in this 

room. 

(Laughter.) 

SECRETARY RICE: Second. 

(Laughter.) 

CHAIRMAN CHAPMAN: All right. We have 

a motion to remove oxygen from 205.605. The 

motion was made by Lisa and seconded and Scott. 

A yes vote is to remove; a no vote is to retain, 

and the voting will start with Dan. 

MEMBER SEITZ: No. 

MEMBER MORTENSEN: Yes. 

MEMBER ELA: No. 

MEMBER BRADMAN: No. 

MEMBER GREENWOOD: No. 

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MEMBER DE LIMA: No. 

MEMBER SCHWARTZ: No. 

MEMBER ROMERO-BRIONES: No. 

MEMBER OAKLEY: No. 

MEMBER BAIRD: No. 

MEMBER BUIE: No. 

MEMBER SWAFFAR: No. 

SECRETARY RICE: No. 

VICE CHAIR BEHAR: No. 

CHAIRMAN CHAPMAN: Chair votes no. 

SECRETARY RICE: That's 0 yes; 15 no; 

0 absent. 

CHAIRMAN CHAPMAN: Motion fails. 

Lisa? 

MEMBER DE LIMA: Next up potassium 

chloride. 

DR. MATHEWS: At Section 205.605(a) 

the listing is potassium chloride. 

MEMBER DE LIMA: A-dae? 

MEMBER ROMERO-BRIONES: So affirmed 

uses of potassium chloride are in foods as a 

flavor enhancer, flavoring agent, nutrient 

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supplement, pH control agent and a stabilizer or 

thickener. It is also a salt substitute. 

Public comment was overwhelmingly in 

favor of relisting. Some commenters commented 

that it is used in infant and toddler formula and 

snacks. One commenter listed it as assisting in 

gelling of pectin as a sodium replacer and it's 

also used to stabilize yogurts. 

MEMBER DE LIMA: Discussion from the 

Board? 

(No audible response.) 

MEMBER DE LIMA: All right. Tom? 

CHAIRMAN CHAPMAN: Okay. The motion 

is to remove potassium chloride from the National 

List. The motion was made by A-dae and seconded 

by Steve. A yes vote is to relist; a no vote is 

to -- a yes vote is to remove; a no vote is to 

relist, and the voting will start with Dave. 

MEMBER MORTENSEN: No. 

MEMBER ELA: No. 

MEMBER BRADMAN: No. 

MEMBER GREENWOOD: No. 

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MEMBER DE LIMA: No. 

MEMBER SCHWARTZ: No. 

MEMBER ROMERO-BRIONES: No. 

MEMBER OAKLEY: No. 

MEMBER BAIRD: No. 

MEMBER BUIE: No. 

MEMBER SWAFFAR: No. 

SECRETARY RICE: No. 

VICE CHAIR BEHAR: No. 

MEMBER SEITZ: No. 

CHAIRMAN CHAPMAN: Chair votes no. 

SECRETARY RICE: That's 0 yes; 15 no; 

0 absent. 

CHAIRMAN CHAPMAN: Motion fails. 

MEMBER DE LIMA: Next up is alginates. 

DR. MATHEWS: At Section 205.605, 

paragraph (b), Synthetics Allowed. The listing 

is alginates. 

MEMBER DE LIMA: Steve? 

MEMBER ELA: Public comments received 

on this material for this meeting were 

essentially similar to the comments received in 

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the spring. Alginates are generally regarded as 

grass. They're used as thickening and gelling 

agents similar to some of the gums but with some 

significantly different properties. 

Basically manufacturers in the 

comments on this ranked them around an 8 out of 

10 on essentiality saying they're critical to the 

formulations of some of their products. And 

really the main objections to alginates comes 

back to the marine materials issue of sustainable 

harvesting of seaweeds or macroalgae; as I'm 

learning that describe them now, and listing of 

specific species that are used in the 

manufacturer of them. 

MEMBER DE LIMA: Any discussion? 

Emily? 

MEMBER OAKLEY: This is really a 

question about the feasibility of listing 

specific alginates, and I don't know how this --

I didn't do research to determine how this group 

has originally categorized and added to the list, 

but just in response to those public comments is 

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there any feasibility of that? Because I know 

this was part of the original discussion document 

and review in handling from the 2016 TR. Does 

anybody have more information about that? 

MEMBER ELA: I'm certainly not 

qualified to answer that. In public comments and 

things it was really just that general we should 

list them, but there really wasn't any further 

detail of how we would go about that. 

MEMBER DE LIMA: Tom? 

CHAIRMAN CHAPMAN: Did you see any 

specific alginates that were objected to in the 

public comments? 

MEMBER OAKLEY: No, and that's why I'm 

asking this question. I guess I would just put 

it back out there to stakeholders if there are 

any specific examples or criteria for ways that 

we might be able to do that. I think we would 

need that first before we could explore that 

issue in any more detail, and it would be helpful 

to get that from the stakeholder community if 

they have that information. 

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MEMBER DE LIMA: Harriet? 

VICE CHAIR BEHAR: Yes, I did see that 

public commenters wanted a breakdown, and perhaps 

we can work on that somewhat in the marine 

materials. And the other issue public comments 

had was about the environmental impact. The 

other side of it is that it is a very healthful 

food for humans and that it has all of these 

extra processing functionalities. So I see it as 

an important product and/or material on the 

National List. And we are dealing with some of 

the issues that the public has brought forward. 

MEMBER DE LIMA: Tom? Oh, Dave? 

MEMBER MORTENSEN: Yes, I had some of 

the same questions about -- it seems like we're 

going into more detail for harvesting maybe algae 

for fertilizer, which I'm guessing is a larger 

quantity than the amount that we would be using 

in alginates. So the question to Emily is us 

acting on this now without having our more fullyscoped thing that we voted on yesterday in place 

sensible or --

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 MEMBER DE LIMA: Okay. Emily? 

MEMBER OAKLEY: Yes. No, I mean, I 

don't think we -- that's what I was trying to say 

is I think this is something we should explore. 

And this is -- the topic of marine materials is 

now in the now in the Materials Subcommittee, so 

that allows for cross-pollination of these 

topics. And I think as Harriet just illustrated 

we will take this up in Materials. And just 

putting it out there to stakeholders, if you want 

to use the open docket to help us figure out to 

address this, that would be very helpful. 

MEMBER DE LIMA: Tom? 

CHAIRMAN CHAPMAN: All right. We have 

a motion to remove alginates, a seconded motion 

from the Subcommittee. The motion was made by 

Steve and seconded by Lisa. A yes vote is to 

remove; a no vote to relist and the voting will 

start with Steve. 

MEMBER ELA: No. 

MEMBER BRADMAN: No. 

MEMBER GREENWOOD: No. 

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 MEMBER DE LIMA: No. 

MEMBER SCHWARTZ: No. 

MEMBER ROMERO-BRIONES: No. 

MEMBER OAKLEY: No. 

MEMBER BAIRD: No. 

MEMBER BUIE: No. 

MEMBER SWAFFAR: No. 

SECRETARY RICE: No. 

VICE CHAIR BEHAR: No. 

MEMBER SEITZ: No. 

MEMBER MORTENSEN: No. 

CHAIRMAN CHAPMAN: Chair notes no. 

SECRETARY RICE: That's 0 yes; 15 no; 

0 absent. 

CHAIRMAN CHAPMAN: Motion fails. 

Lisa? 

MEMBER DE LIMA: Next up, calcium 

hydroxide. 

DR. MATHEWS: At Section 205.605(b) 

the listing is calcium hydroxide. 

MEMBER DE LIMA: A-dae? 

MEMBER ROMERO-BRIONES: Calcium 

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hydroxide is used as a component of aluminum-free 

baking powder, to clarify sugar from molasses and 

as a condition for corn tortillas. It's used as 

a pH buffer. It's also used to fortify foods 

with calcium, clarify sugarcane or beet juice, 

for making hominy and masa as a firming agent. 

Comments. The few comments suggested 

relisting. On commenter mentioned that it has 

been used for centuries to dissolve the outer 

coating of corn so that it's like a thick -- like 

it can stick together. And another comment said 

that we should clarify whether that's an 

acceptable use. 

MEMBER DE LIMA: Any discussion? 

Harriet? 

VICE CHAIR BEHAR: In the written 

proposal there's discussion about whether or not 

it's allowed as a firming agent. Did we ever 

receive any comment from the program, because 

obviously there's a manufacturer that wants to 

know. 

DR. MATHEWS: Regarding the uses of 

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firming agent? 

VICE CHAIR BEHAR: Using calcium 

hydroxide as a firming agent. I would think that 

since it's not annotated that it would be 

allowed, but there was a commenter who wanted to 

know. So maybe on the public record we could 

help them out. 

DR. MATHEWS: I think we probably need 

to take that back for consideration. 

CHAIRMAN CHAPMAN: Or that's something 

they can address to their certifier. 

MEMBER DE LIMA: Harriet? 

VICE CHAIR BEHAR: Just to point out 

that hydrated lime is on all three lists: Crops, 

Livestock and Handling. 

MEMBER DE LIMA: All right. Tom? 

CHAIRMAN CHAPMAN: And just to point 

out it's listed differently on all three lists. 

(Laughter.) 

CHAIRMAN CHAPMAN: Hydrated lime; 

Lime, hydrated; calcium hydroxide. 

Okay. We have a motion to remove 

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calcium hydroxide from the National List. The 

motion was made by A-dae and seconded by Lisa. A 

yes vote is to remove; a no vote is to retain, 

and the voting will start with Asa. 

MEMBER BRADMAN: No. 

MEMBER GREENWOOD: No. 

MEMBER DE LIMA: No. 

MEMBER SCHWARTZ: No. 

MEMBER ROMERO-BRIONES: No. 

MEMBER OAKLEY: No. 

MEMBER BAIRD: No. 

MEMBER BUIE: No. 

MEMBER SWAFFAR: No. 

SECRETARY RICE: No. 

VICE CHAIR BEHAR: No. 

MEMBER SEITZ: No. 

MEMBER MORTENSEN: No. 

MEMBER ELA: No. 

CHAIRMAN CHAPMAN: Chair votes no. 

SECRETARY RICE: That's 0 yes; 15 no; 

0 absent. 

CHAIRMAN CHAPMAN: Motion fails. 

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Lisa? 

MEMBER DE LIMA: Next up is ethylene. 

DR. MATHEWS: At Section 205.605(b) 

the listing is ethylene, allowed for post-harvest 

ripening of tropical fruit and degreening of 

citrus. 

MEMBER DE LIMA: Asa? 

MEMBER BRADMAN: Thank you. So 

ethylene -- we've had a number of discussions 

about this. Ethylene is a commonly-used 

material, a hormone essentially, growth regulator 

and it facilitates ripening in stored products. 

We've heard a lot about bananas. Also citrus 

fruit. Often the citrus fruit matures internally 

earlier than the outer color and so ethylene is 

used for greening, to bring the rind to an orange 

color, which is better for sales. 

There's a lot of support for ethylene 

across the board, both in terms of -- for 

tropical fruits, but also for citrus. I think 

one of the key comments that had an impact on me 

was the notion that it would -- you would -- we 

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would reduce the season for citrus if it wasn't 

available for organic citrus because it -- color 

is some important for sales during periods and we 

would -- there would be a loss of market. So I 

think there's a lot of support about this. 

There's been some concerns about the 

use of this as a growth regulator. That's not 

specifically necessary for production and 

processing. On a personal basis I think this is 

one of those materials where allowing it allows a 

broader market for organically produced 

materials. It helps enhance and grow the share 

of organic. 

Any discussion? 

MEMBER DE LIMA: Harriet? 

VICE CHAIR BEHAR: In review of 

distribution houses and produce handlers it 

appears that the infrastructure for handling this 

material is well maintained and there is really 

very little damage to human health or the 

environment. 

MEMBER DE LIMA: Steve? 

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MEMBER ELA: Well, and I'll just 

iterate that in the apple industry we actively 

remove ethylene from our storage houses, so it's 

ironic to be adding it. But it is -- I mean, it 

is a naturally -- I mean, even though this is a 

synthetic, it's naturally occurring in many 

fruits and so I don't see any big problem with 

this. 

MEMBER DE LIMA: Dave? 

MEMBER MORTENSEN: And I support this. 

I'll preface my statements by saying that, but I 

also -- as we go along the concern about the use 

of growth regulators continues to be something 

that's very much on my mind when we look at 

things like this and the decision that we made 

not to allow the compound for suppressing 

suckering in tobacco. 

In some ways to me that was a similar 

decision. We were thinking about growth 

regulators and how it affects the synchrony of 

plant development in the field. I thought the 

benefits that were laid about by the Costa Rican 

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farmers about the pest management benefits of 

synchrony of fruiting of pineapple was 

compelling. 

On the other hand it was also a large 

monoculture cropping practice that has its own 

set of pest problems. But all and all on the 

balance I think this -- the strengths of this 

outweigh some of these concerns. 

MEMBER DE LIMA: Tom? 

CHAIRMAN CHAPMAN: So this is for 

ethylene use in processing. We'll talk about it 

again and it's crop applications. 

I do want to say as one of the people 

who voted down the free fatty acids ethylene 

usage both here and on the Crop listing is quite 

constrained to a specific application. And on 

that free fatty acid petition when we voted it 

down, it was not constrained to a specific 

application for a need in a specific crop. 

MEMBER DE LIMA: All right. Tom? 

CHAIRMAN CHAPMAN: Motion is to remove 

ethylene from the National List. And I should I 

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guess specify on this one; I probably should have 

specified on the other one, because calcium 

hydroxide is in multiple spots, that it's for 

205-605(b) of the National List. The motion is 

made by Asa and seconded by Tom. A yes vote is 

to remove; a no vote is to retain, and the voting 

will start with Rick. 

MEMBER GREENWOOD: No. 

MEMBER DE LIMA: No. 

MEMBER SCHWARTZ: No. 

MEMBER ROMERO-BRIONES: No. 

MEMBER OAKLEY: No. 

MEMBER BAIRD: No. 

MEMBER BUIE: No. 

MEMBER SWAFFAR: No. 

SECRETARY RICE: No. 

VICE CHAIR BEHAR: No. 

MEMBER SEITZ: No. 

MEMBER MORTENSEN: No. 

MEMBER ELA: No. 

MEMBER BRADMAN: No. 

CHAIRMAN CHAPMAN: Chair votes no. 

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SECRETARY RICE: That's 0 yes; 15 no; 

0 absent. 

CHAIRMAN CHAPMAN: Motion fails. 

Lisa? 

MEMBER DE LIMA: Next is glycerides, 

mono and di. 

DR. MATHEWS: At Section 205.605(b) 

the listing is glycerides, mono and di for use 

only in drum drying of food. 

MEMBER DE LIMA: So glycerides, mono 

and di in drum drying. They act as an emulsifier 

and release agent. When mixed with food they 

help prevent sticking during processing and help 

to strip food from the cylinder walls once dried. 

As far as public comment there was 

support from two manufacturers. There was also a 

certifier and an organization that supported 

removal because of possible non-synthetic and 

organic alternatives that were suggested in the 

TR. 

It was also pointed out by an 

organization that in the 2015 review one 

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commenter stated that mono and diglycerides are 

important emulsifiers used in organic products to 

ensure there's no fat separation and the 

organization would like certifiers to be alerted 

to this possible misuse. 

Any discussion from the Board? 

(No audible response.) 

MEMBER DE LIMA: Tom? 

CHAIRMAN CHAPMAN: Motion is to remove 

mono and diglycerides from the National List. 

The motion was made by Lisa and seconded by 

Steve. A yes vote is to remove; a no vote is 

retain, and the voting will start with Lisa. 

MEMBER DE LIMA: No. 

MEMBER SCHWARTZ: No. 

MEMBER ROMERO-BRIONES: No. 

MEMBER OAKLEY: No. 

MEMBER BAIRD: No. 

MEMBER BUIE: No. 

MEMBER SWAFFAR: No. 

SECRETARY RICE: No. 

VICE CHAIR BEHAR: No. 

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MEMBER SEITZ: No. 

MEMBER MORTENSEN: No. 

MEMBER ELA: No. 

MEMBER BRADMAN: No. 

MEMBER GREENWOOD: No. 

CHAIRMAN CHAPMAN: Chair votes no. 

SECRETARY RICE: That's 0 yes; 15 no; 

0 absent. 

CHAIRMAN CHAPMAN: Motion fails. 

Lisa? 

MEMBER DE LIMA: Next is magnesium 

stearate. 

DR. MATHEWS: At Section 205.605(b) 

the listing is magnesium stearate for use only in 

agricultural products labeled made with organicspecified ingredients or food groups prohibited 

in agricultural products labeled organic. 

MEMBER DE LIMA: Asa? 

MEMBER BRADMAN: So magnesium stearate 

is a -- is used as an anti-caking agent salts. 

Also a flow agent for processing machines. And 

probably it seems like its dominant use based on 

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comments was as a binding material for 

nutritional supplements and things like that. 

It's --

PARTICIPANT: You might want to 

speak --

MEMBER BRADMAN: Okay. Should I 

repeat what I said? Everyone got it? 

Anyways, so magnesium stearate is a --

probably the dominant use that I've seen in the 

comments and users is that it's a binding agent 

for nutritional supplements. There's not really 

any big indications of significant human health 

concerns, although there were a few comments 

submitted a few references about some concerns of 

the material as a salt and possible impacts on 

renal health. 

It's -- because of its use as a -- and 

made with organic materials it's -- many --

there's actually relatively little concern with 

this material and its presence on the list. And 

among producers of nutritional supplements 

related materials -- related products they 

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thought this was a relatively important material, 

although it varied. Some people considered it 

very important. Others felt that there were 

alternatives, but it would add some costs. 

There was also one comment in -- well, 

a couple of comments that we should prohibit 

animal sources of material to manufacture this, 

that it should be limited to non-animal oils and 

other materials to produce it partly out of 

concerns of -- with the animals, GMO-related, but 

also to provide a source for vegan or other non 

-- vegetarian consumers. 

So any discussion? 

MEMBER DE LIMA: So I will say that 

there are supplemental companies that 

specifically call out that they're using 

vegetarian magnesium stearate on the label. 

MEMBER BRADMAN: And just to clarify, 

people were requesting that we actually limit the 

approval. too. I assume if we went that route, 

that would be done in an annotation. 

MEMBER DE LIMA: Tom? 

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 CHAIRMAN CHAPMAN: And also kosher 

certification is generally used as an information 

shortcut to determine if it was from an animal 

product or not. 

MEMBER MORTENSEN: Tom, I didn't hear 

that. Could you repeat that? 

CHAIRMAN CHAPMAN: Kosher 

certification is often used as an information 

shortcut to determine whether or not the origin 

product was from an animal or not. 

MEMBER MORTENSEN: Thanks. 

MEMBER DE LIMA: Harriet? 

VICE CHAIR BEHAR: Well, as Lisa 

mentioned, it could be mentioned in the 

marketplace if it's a vegetarian source or not, 

so the manufacturers can choose. I don't see any 

reason to constrain it on our National List. 

MEMBER BRADMAN: Right. One --

VICE CHAIR BEHAR: Unless the 

Subcommittee wants to look at it as a work agenda 

item. 

MEMBER BRADMAN: One producer actually 

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indicated they derived it from organic rice 

materials, so there's actually even an organic 

source for it. 

MEMBER DE LIMA: Tom? 

CHAIRMAN CHAPMAN: The motion is to 

remove magnesium stearate from the National List 

The motion was made by Asa and seconded by Tom 

Chapman. A yes vote is to remove; a no vote is 

to retain, and the voting will start with Eric. 

MEMBER SCHWARTZ: No. 

MEMBER ROMERO-BRIONES: No. 

MEMBER OAKLEY: No. 

MEMBER BAIRD: No. 

MEMBER BUIE: No. 

MEMBER SWAFFAR: No. 

SECRETARY RICE: No. 

VICE CHAIR BEHAR: No. 

MEMBER SEITZ: No. 

MEMBER MORTENSEN: No. 

MEMBER ELA: No. 

MEMBER BRADMAN: No. 

MEMBER GREENWOOD: No. 

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MEMBER DE LIMA: No. 

CHAIRMAN CHAPMAN: Chair votes no. 

SECRETARY RICE: That's 0 yes; 15 no; 

0 absent. 

CHAIRMAN CHAPMAN: Motion fails. 

Lisa? 

MEMBER DE LIMA: Next is phosphoric 

acid. 

DR. MATHEWS: At Section 205.605(b) 

the listing is phosphoric acid, cleaning of food 

contact surfaces and equipment only. 

MEMBER DE LIMA: A-dae? 

MEMBER ROMERO-BRIONES: Phosphoric 

acid is used in cleaning and removing encrusted 

surface matter and mineral scale found on metal 

equipment such as boilers and steam-producing 

equipment. We discussed this as part -- and 

including phosphoric acid in our larger 

discussion about sanitizers. 

We had quite a few comments. The 

majority was not -- if not all, suggested 

relisting. There was one comment that suggested 

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seeking safer alternatives because it may have 

some -- it does pose some environmental health 

hazards, but right now it is probably one of the 

most effective sanitizers for removing calcium 

and mineral deposits. 

MEMBER DE LIMA: Discussion from the 

Board? 

Harriet? 

VICE CHAIR BEHAR: One of the reasons 

why it's listed above as allowed as ingredients 

is it's one of the few sanitizers that we have 

that don't need a rinse off, which many process 

sees as an important aspect. 

MEMBER DE LIMA: Tom? 

CHAIRMAN CHAPMAN: We have a motion to 

remove phosphoric acid from the National List. 

The motion was made by A-dae and seconded by 

Scott. A yes vote is to remove; a no vote is to 

retain, and the voting will start with A-dae. 

MEMBER ROMERO-BRIONES: No. 

MEMBER OAKLEY: No. 

MEMBER BAIRD: No. 

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 MEMBER BUIE: No. 

MEMBER SWAFFAR: No. 

SECRETARY RICE: No. 

VICE CHAIR BEHAR: No. 

MEMBER SEITZ: No. 

MEMBER MORTENSEN: No. 

MEMBER ELA: No. 

MEMBER BRADMAN: I'm voting no. Can 

I have a slight signing statement about -- that 

we should recognize there may be concerns with 

phosphates and waterways and that's something to 

consider. We went to the resolution a bit before 

I had a chance to mention that comment in 

discussion. Thanks. So I'm voting no. 

MEMBER GREENWOOD: No. 

MEMBER DE LIMA: No. 

MEMBER SCHWARTZ: No. 

SECRETARY RICE: It's -- oh, Chair? 

CHAIRMAN CHAPMAN: Oh, Chair votes no. 

SECRETARY RICE: That's 0 yes; 15 no; 

0 absent. 

CHAIRMAN CHAPMAN: Motion fails. 

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MEMBER DE LIMA: Next is potassium 

carbonate. 

DR. MATHEWS: At Section 205.605(b) 

the listing is potassium carbonate. 

MEMBER DE LIMA: Scott? 

SECRETARY RICE: Thank you. Sorry. 

One moment. 

(Pause.) 

SECRETARY RICE: Just getting my 

voting in order. 

Potassium carbonate is commonly used 

in the Dutch alkali process for processing cocoa 

and chocolate to reduce the acidity. It's also 

used as a pH control. It's a leavening agent, 

boiler water additive and a number of other uses. 

Also notable, used in -- as a buffering agent in 

making wine and mead to reduce acidity. 

There was widespread support for the 

relisting of this material. And that's the 

summary. 

MEMBER DE LIMA: Any discussion? 

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VICE CHAIR BEHAR: Chocolate is 

essential. 

MEMBER DE LIMA: All right. Tom? 

CHAIRMAN CHAPMAN: Motion is to remove 

potassium carbonate from the National List. The 

motion was made by Lisa and seconded by Scott. A 

yes vote is to remove; a no vote is to retain, 

and the voting will start with Emily. 

MEMBER OAKLEY: No. 

MEMBER BAIRD: No. 

MEMBER BUIE: No. 

MEMBER SWAFFAR: No. 

SECRETARY RICE: No. 

VICE CHAIR BEHAR: No. 

MEMBER SEITZ: No. 

MEMBER MORTENSEN: No. 

MEMBER ELA: No. 

MEMBER BRADMAN: No. 

MEMBER GREENWOOD: No. 

MEMBER DE LIMA: No. 

MEMBER SCHWARTZ: No. 

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MEMBER ROMERO-BRIONES: No. 

CHAIRMAN CHAPMAN: Chair votes no. 

SECRETARY RICE: That's 0 yes; 15 no; 

0 absent. 

CHAIRMAN CHAPMAN: Motion fails. 

Lisa? 

MEMBER DE LIMA: Next is sulfur 

dioxide. 

DR. MATHEWS: At Section 205.605(b) 

the listing is sulfur dioxide for use only in 

wine labeled made with organic grapes provided 

that total sulfite concentration does not exceed 

100 ppm. 

MEMBER DE LIMA: Steve? 

MEMBER ELA: I think we should note 

the essentiality of wine, similar to chocolate; 

often used together, I've noticed. 

(Laughter.) 

MEMBER ELA: Again similar comments 

this fall as compared to the spring about the 

essentiality of this material for the use in wine 

making, especially to prevent spoilage and to 

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protect flavor and longstanding quality. 

Basically really no negative comments. 

I mean, we recognize people have sulfite 

allergies, but they're labeled. I think the only 

other comment from a couple people were that the 

100 parts per million was excessive and could be 

limited to a lower amount which would require an 

annotation change and a different work agenda 

item. 

And there was; I know it's come up in 

the past that it's currently for use only in wine 

made with organic grapes, but there are -- is the 

cider industry and the berry industry and such. 

So one commenter said it should be -- that should 

be loosened to be made with organic fruit rather 

than just organic grapes. But that's really out 

of our purview in the sunset review. So no 

negative comments and essential to the wine 

industry. 

MEMBER DE LIMA: Any discussion? 

Harriet? 

VICE CHAIR BEHAR: I remember, I think 

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it was two sunsets ago this was quite a 

controversial material. There were wine makers 

that wanted it to come off the list because you 

could make wine without it. I don't see them 

here clamoring for that because I believe in the 

marketplace they've been able to distinguish 

themselves as no sulfites, and so therefore --

and then declare their wine as organic wine. So 

I think that the annotation and listing as stands 

is working for everyone. 

MEMBER DE LIMA: Any other discussion? 

(No audible response.) 

MEMBER DE LIMA: Tom? 

CHAIRMAN CHAPMAN: Okay. We have a 

motion to remove sulfur dioxide from the National 

List. The motion was made by Steve and seconded 

by Eric. A yes vote is to remove; a no vote is 

to retain, and the voting will start with Sue. 

MEMBER BAIRD: Concur wine is 

essential. No. 

MEMBER BUIE: No. 

MEMBER SWAFFAR: No. 

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SECRETARY RICE: No. 

VICE CHAIR BEHAR: No. 

MEMBER SEITZ: No. 

MEMBER MORTENSEN: No. 

MEMBER ELA: No. 

MEMBER BRADMAN: No. 

MEMBER GREENWOOD: No. 

MEMBER DE LIMA: No. 

MEMBER SCHWARTZ: No. 

MEMBER ROMERO-BRIONES: No. 

MEMBER OAKLEY: No. 

CHAIRMAN CHAPMAN: Chair votes no. 

SECRETARY RICE: That's 0 yes; 15 no; 

0 absent. 

CHAIRMAN CHAPMAN: Motion fails. 

Lisa? 

MEMBER DE LIMA: Next is xanthan gum. 

DR. MATHEWS: At Section 205.605(b) 

the listing is xanthan gum. 

MEMBER DE LIMA: All right. So 

xanthan gum is used in numerous food products 

some of which include baked goods, beverages, 

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dairy products, dressings, nutritional 

supplements, frozen foods. Gum is used in small 

percentages of the finished product, usually less 

than 0.5 percent by weight. It disperses water 

giving a thickening and gelling effect. 

It's also often used with other gums 

to achieve desired viscosities and product 

structure. It's particularly effective in frozen 

and chilled products where it can impart 

thickness, freeze-thaw protection and stability 

during processing. Common gums that it's used 

along with are locust, guar and carrageenan. 

It's allowed for use in organics 

internationally in Canada, the EU, Japan and by 

IFOAM. And it's also commercially available to 

consumers to buy, often used in gluten-free 

baking and other recipes. 

As far as public comment a number of 

organizations, certifiers and manufacturers 

expressed support for the material with one large 

certifier stating that of the gums xanthan is the 

most commonly found in their OSPs. One 

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manufacturer stated that organic gums didn't have 

the same functionality in their organic baked 

goods as xanthan did. One organization commented 

that it should be removed from the National List 

unless it's listed for essential uses. And we 

heard from a retailer that thought it should be 

delisted as well due to consumer concerns. 

There were also comments around 

classification. The petitioner and an 

organization want to see it reclassified as a 

non-synthetic. And then others wrote in 

requesting that the NOSB come up with a policy 

that can be applied when evaluating products of 

fermentation as far as classification and 

compatibility with organics. 

I do want to point out that in 2016 

the Handling Subcommittee decided after reviewing 

an updated TR that xanthan gum could be produced 

by various methods that could result in both a 

non-synthetic or a synthetic and that we decided 

to not move forward with a reclassification. 

Any discussion? 

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 Dave? 

MEMBER MORTENSEN: So I have the same 

concerns here, and I will just raise one point 

and then be quiet. There is a possibility that a 

reason why the EU would see this differently is 

that they don't grow GM crops for the most part. 

So that concern would be less severe there since 

virtually no GM crops are grown in Europe, or at 

least not the ones that are used in the 

fermentation process. Thanks. 

MEMBER DE LIMA: All right. Tom? 

CHAIRMAN CHAPMAN: All right. We have 

a seconded motion from the Subcommittee. The 

motion is to remove xanthan gum. Motion was made 

by Lisa and seconded by Scott. A yes vote is to 

remove; a no vote is to retain the listing, and 

the voting will start with Jesse. 

MEMBER BUIE: No. 

MEMBER SWAFFAR: No. 

SECRETARY RICE: No. 

VICE CHAIR BEHAR: No. 

MEMBER SEITZ: No. 

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MEMBER MORTENSEN: Yes. 

MEMBER ELA: No. 

MEMBER BRADMAN: No. 

MEMBER GREENWOOD: No. 

MEMBER DE LIMA: No. 

MEMBER SCHWARTZ: No. 

MEMBER ROMERO-BRIONES: No. 

MEMBER OAKLEY: No. 

MEMBER BAIRD: No. 

CHAIRMAN CHAPMAN: Chair votes no. 

SECRETARY RICE: That's 1 yes; 14 no; 

0 absent. 

CHAIRMAN CHAPMAN: Motion fails. 

So it's now 10:55. That's the end of 

the 205.605 listings. I think we can break here. 

We'll come back to order at 11:10 and continue 

with sunset and then move onto the rest of the 

Handling Subcommittee meeting. Please be back 

promptly at 11:10 or we will have a late lunch. 

We're in recess. 

(Whereupon, the above-entitled matter 

went off the record at 10:55 a.m. and resumed at 

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11:10 a.m.) 

 MR. CHAPMAN: If board members could 

take their seats, we're about to get started. 

(Pause.) 

MR. CHAPMAN: All right. If the board 

members could take their seat we'll come back 

into order. All right, we'll come back into 

order. And a quorum of members is present. We 

will turn back to the Handling Subcommittee, 

Lisa. 

MR. RICE: All right. Next up is 

fructooligosaccarhides, FOS from here on out. 

MS. DE LIMA: Okay. We're moving into 

Section 205.606 on the National List, 

nonorganically produced agriculture products 

allowed as ingredients in or on processed 

products labeled as organic. 

At paragraph (e) we have the listing 

fructooligosaccarhides CAS No. 308066-66.2. 

MR. CHAPMAN: Fructooligosaccarhides 

is on the list as a nonorganically produced 

agricultural product allowed in organic products, 

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boxes, and nondigestible carbohydrate that's used 

a soluble prebiotic fiber, sweetening agent, 

flavor enhancer, bulking agent, and is used in 

many foods, including yogurts, infant foods, 

medical foods, baked goods, candies, soups, 

beverages, and other dairy products. 

Public comment from interest groups 

objected to its listing saying that it's highly 

processed and is not a necessary component of 

organic foods. Concerns were also raised around 

fermentation. 

Other commenters, particularly organic 

industry and some trade associations, as well as 

nutrition councils commented on its use as a 

prebiotic. It's widely used as an essential 

prebiotic in infant formulas in place of human 

milk oligosaccharides that would be found in 

breast milk. 

Historically -- this was not in public 

comment -- historically this was widely used in 

the, in the yogurt industry and in infant foods. 

The yogurt industry use seems to have declined, 

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but it is still an additive in almost every 

infant formula out there on the market. 

MS. DE LIMA: Discussion from the 

board? Harriet? 

MS. BEHAR: Usually I don't like 

voting to put something on the National List 

that's more than 15 to 20 letters but, or 

difficult to pronounce, but I realize we 

shouldn't be prejudiced and read the 

documentation. And so, I think this is a useful 

product, even though it might look to consumers 

who are looking for a clean label as something 

that they might not like. 

So we might need a little more 

education on it, but I think it's acceptable. 

MS. DE LIMA: And then I will say as 

a retailer, it's not a question I've seen come 

up as far as clean label and asking what it is. 

Emily and then Dave. 

MS. OAKLEY: Okay. Question for 

Harriet then. In terms of the public comment 

addressing this as a highly processed product, 

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so, and nonessential, I guess the one area of 

concern might be in infant formula, primarily for 

me. Could someone address that? 

MR. CHAPMAN: I heard, I heard that --

I didn't hear the connection to the question. 

Could you repeat that? 

MS. OAKLEY: Definitely wasn't very 

clear. 

MR. CHAPMAN: I just heard infant 

formula and highly processed, but. 

MS. OAKLEY: Yes. So that wasn't a 

clear question. You're right. 

Are there alternatives in infant 

formula? And I do have concerns and felt that 

the argument laid out by some of the public 

commenters about its highly processed nature were 

compelling. 

MR. CHAPMAN: From the public comment 

that I read, this is the accepted use material 

from American Medical Association and the 

American Pediatric Association for infant 

formulas. So, I am unaware of an alternative for 

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infant formulas. 

There is some mention of glucosuria 

saccharides, which is a similar compound, but 

it's extremely similar. So it's a, what's the 

saying, six of one, half dozen of the other. And 

I'm unaware of that product being available in an 

organic formula. 

MS. DE LIMA: Dan. 

MR. MORTENSEN: Could someone on the 

subcommittee give us a sense for there are two 

forms, inulin-derived and sucrose-derived. The 

sucrose-derived -- and I don't want to sound like 

a broken record, but sugar beets in the United 

States are almost entirely genetically modified 

these days. So if, if it's derived from sugar 

beets versus the proportion from inulin, I don't 

know anything about that. 

MR. CHAPMAN: So this is a 606 item. 

It's an agricultural item. And the exclusion on 

excluded methods would be fully applicable to 

this material. 

MR. MORTENSEN: Meaning that they 

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would source organic sugar beets some or non, or 

conventional non-transformed if that's the 

source? 

MR. CHAPMAN: I would believe -- I 

don't believe they would source organic sugar 

beets. I'm unaware of any of those in the U.S. 

But I do believe they would source convention 

non-genetically engineering sugar beets. But I 

don't know of the certifier on the board could 

speak more to that. 

MR. RICE: Yes. Like any agricultural 

product you would have an ingredient affidavit 

that would verify the non-GMO status of this 

product. 

MR. MORTENSEN: I'm having a hard time 

hearing some of this. Could you repeat that, 

please? 

MR. RICE: As an agricultural 

ingredient you would have an affidavit that the 

certifier would verify that is the suppli -- or, 

excuse me, the certified operation would submit 

verifying the source form a non-GMO source. 

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MR. MORTENSEN: Thank you. 

MS. DE LIMA: Dan. 

DR. SEITZ: So, several commenters 

said that this had just been more of a fad at 

some point and that there were certain health 

claims that could be made by virtue of having 

this. And that use had dropped off substantially 

and that, you know, there was some question 

around these various claims. 

So I'm curious to know from those of 

you who work with products that have this, what 

seems to be still essential about this in terms 

of processed foods? And can you speak up, Tom? 

MR. CHAPMAN: Yes. Can you hear me, 

Dan? 

DR. SEITZ: Yes. 

MR. CHAPMAN: Okay. So it's a 

prebiotic. And prebiotics have, you know, been 

around. We've seen them come and go as fads, 

prebiotics and probiotics. And as I mentioned in 

my opening comments, it was very common for a 

while to have prebiotics in yogurts because 

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you're also getting active cultures. And so you 

get both of those at the same time to promote 

health. 

That activity has seemed to have waned 

to some extent. But it's usage in infant 

formulas, and I was remiss in mentioning also 

medical foods so folks are fed intrally. It's 

use a prebiotic is still fairly essential in that 

application since there are not -- it doesn't 

come through the normal pathways that you would 

get that, so, human breast milk, for example. 

I understand people's concerns with 

infant formula. And I'm not here to debate them. 

But they are, you know, infant formulas strive to 

match a natural product and the constituents 

therein. And sometimes to get it to match you 

need to refer -- you need to use some highly 

processed products to get it as close to human 

breast milk as possible. 

Did that, did that answer your --

yeah. 

DR. SEITZ: Thanks. 

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 MS. DE LIMA: All right, I don't see 

any other discussion. Tom. 

MR. CHAPMAN: All right. We have a 

motion to remove fructooligosaccharides from 

205.606. The motion as made by Tom. It was 

seconded by Lisa. A yes vote is to remove, a no 

vote is to retain. 

And someone's mike is giving us 

feedback. 

The voting will start with Ashley. 

MR. SWAFFAR: No. 

MR. RICE: No. 

MS. BEHAR: No. 

DR. SEITZ: No. 

MR. MORTENSEN: No. 

MR. ELA: No. 

MR. BRADMAN: No. 

DR. GREENWOOD: No. 

MS. DE LIMA: No. 

MR. SCHWARTZ: No. 

MS. ROMERO-BRIONES: No. 

MS. OAKLEY: Yes. 

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MS. BAIRD: No. 

MR. BUIE: No. 

MR. CHAPMAN: Chair votes no. 

MR. RICE: There was one yes, 14 no, 

0 absent. 

MR. CHAPMAN: The motion fails. 

Lisa. 

MS. DE LIMA: Next up gums, arabic, 

guar, locust, and carob. It's Section 

205.606(g). The listing is gums -- water 

extracted only (Arabic, Guar, Locust bean, and 

Carob bean.) 

DR. MATHEWS: So all these gums are 

extracted from the endosperm of plants via water 

processing and then dried and milled. They are 

used in various food applications due to their 

ability to modify the viscosity of products 

through the binding of water and the generation 

of jelling effects, and also used as thickening 

agents. 

And due to the structure of the gums, 

each gum behaves slightly differently at 

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different temperatures, pH ranges, physical 

agitation, and so on. 

These gums are allowed for use in 

organics internationally, in Canada, the EU, 

Japan, and by IFOAM. 

During public comment I think all but 

one public comment was in support of relisting 

these gums. 

There were questions around the 

availability of organic versions. One 

manufacturer noted that they source organic guar 

and locust, but are in favor of retaining on the 

list because they don't know if the organic 

supply is adequate. 

Another said they were able to source 

organic arabic for the last two years, but due to 

weather extremes and political situations where 

the substance is grown there's been a long 

history of supply interruptions. 

One organization thought we should 

investigate whether there is gum arabic that 

could be certified as wild crafted organic, as 

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well as the availability of organic carob and 

locust bean gum. 

So we did -- I just want to update 

everyone -- we did discuss in subcommittee after 

the spring meeting where similar requests were 

made in public comment to list the gums 

separately so that individual gums could be 

delisted in the future. And we discussed it. 

And we discussed it with the program. 

He let us know that we could do that, 

but it's not really necessary because even though 

they're listed as a single line on 606(j), any 

one of them could be recommended for removal. An 

example of this was the board did something 

similar on the Crops Subcommittee last year. We 

delisted vitamins B, C and E. And they had two 

different motions which allowed them to remove 

one of the gums. 

So when we got to that point where we 

see that there is availability of one of these 

gums, organic commercially available, we can 

still go ahead and do that without having to go 

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through the process of listing them separately on 

the national list. Tom. 

MR. CHAPMAN: So in my role I do 

source organic gum arabic. We are not a large 

producer of the product, but we are able to 

successfully source it organically today. 

However, I also support the retaining of this 

listing. And I think the commercial availability 

exceptions are working out well here because I 

think a lot of folks are sourcing organic 

versions of these gums, where available. 

The big concern with a lot of these 

gums is they come from Sub-Saharan African from 

some countries that have a history of political 

instability. And so while they might be 

available for four years in a row, they will 

suddenly potentially dry up from time to time, 

depending on the political climate and what's 

going on in that region, or also weather events 

in that region as well. 

And so at that point, knowing the 

length of time it takes to get a product back on 

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the list, you know, you're looking at 18, 24, 36 

months, or even longer before you could do that. 

That's going to impact all those processed 

products and that soft serve ice cream you like 

so much, which is also essential. You know, just 

going to have to do something in the interim 

here. 

So in that regard, and knowing that 

there's a commercial availability here that's 

forcing folks to go out and source these 

products, there's not that many different forms 

of these products so it's quite clear cut, I 

think, from the certifier's perspective if 

someone truly tried to source this organic or 

not. I think it's important to retain the 

listings. 

MS. DE LIMA: Harriet. 

MS. BEHAR: So, I'm just wondering in 

the discussion with anyone who is already 

sourcing it, have they looked at trying to work 

in other areas of the world for production or 

not? I don't know if Tom wants to speak to that. 

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Because, you know, I would think that there would 

not only be one tiny place where it could grow. 

And there are many countries that would like to 

benefit from organic production. 

MR. CHAPMAN: We haven't tried to 

source from other regions because we're 

successfully sourcing organic at this time. I 

also, I don't know, I don't particularly want to 

pull a cash crop out of a developing country if I 

don't need to do that either. 

That being said, I mean, these aren't 

all created equally. And there's probably a 

greater availability for some than others. I'm 

aware of guar being successfully grown in a 

couple different climates. It's not a product I 

source, so I'm not actively involved in it. But 

there are some. 

I'm not close enough to these trees, 

but gum arabic's been a valuable commodity for an 

extremely long time. If it was newly grown in 

other areas other than Sudan, I think, I think 

people would have economically taken advantage of 

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it at this point. 

MS. DE LIMA: The only public comment 

I saw as far as domestic grown gums was guar gum. 

And that was not organic. 

MS. BEHAR: If it could be done in 

another developing country also. 

But I'm not necessarily saying that 

that's what we want to see is just for organic 

production to damage someone else, but especially 

when it's in a region where the production could 

be, you know, scarce or, you know, kind of up and 

down, that trying to have something more stable 

would also be to the benefit not just of the 

growers, because these are perennial crops, but 

also for the manufacturers that then want to work 

with those for the long term. 

MS. DE LIMA: All right, seeing no 

more discussion, Tom. 

MR. CHAPMAN: All right. So, we have 

a motion to remove gum arabic, locus bean gum, 

carob gum, and guar gum from the National List. 

The motion was made by Lisa and seconded by 

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Scott. 

to retain. 

absent. 

A yes vote is to remove. A no vote is 

And the voting will start with Scott. 

MR. RICE: No. 

MS. BEHAR: No. 

DR. SEITZ: No. 

MR. MORTENSEN: No. 

MR. ELA: No. 

MR. BRADMAN: No. 

DR. GREENWOOD: No. 

MS. DE LIMA: No. 

MR. SCHWARTZ: No. 

MS. ROMERO-BRIONES: No. 

MS. OAKLEY: No. 

MS. BAIRD: No. 

MR. BUIE: No. 

MR. SWAFFAR: No. 

MR. CHAPMAN: Chair votes no. 

MR. RICE: That's 0 yes, 15 no, 0 

MR. CHAPMAN: The motion fails. Lisa. 

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oiled. 

DR. MATHEWS: At Section 205.606(k). 

The listing is lecithin, de-oiled. 

MS. DE LIMA: A-dae. 

MS. ROMERO-BRIONES: So, lecithin is 

a substance isolated as a gum following hydration 

of solvent extracted soy, safflower or corn oils. 

We also noted in the comments that it's also 

derived from sunflower oil. 

It has a wide range of applications, 

including emulsification, or these properties: 

wetting, dispersing, and texturization. It's 

included in a wide variety of products, from 

chocolates to margarines to powders to release 

sprays to baked goods. 

The comments were pretty split on 

whether to relist. The question is whether there 

is a commercial availability of non-soy lecithin. 

And based on conversations with certifiers in the 

stakeholder community here, there is some non-soy 

organic forms of lecithin de-oiled available. 

Organic soy lecithin is available. 

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One of the comments, or several of the 

commenters said that delisting this would allow 

the organic non-soy lecithin de-oiled products to 

become -- the market to expand. Keeping it on 

the list would chill the market. 

And the comments on the other side of 

the table said that non-soy lecithin de-oiled 

organic products are unstable and not in a 

consistent supply. And based on conversations 

with some of the stakeholders there are --

there's an increase in the availability of 

lecithin de-oiled products, both soy and non-soy, 

generally. 

MS. DE LIMA: Discussion? Emily. 

MS. OAKLEY: So, A-dae, what does that 

lead you to conclude? 

MS. ROMERO-BRIONES: That there is 

lecithin de-oiled organic products available, 

both soy and sunflower. 

MS. OAKLEY: So would you vote to 

remove, to increase the market? I know one 

commenter said the rulemaking process is lengthy 

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enough that within several years that market is 

very likely to have fully caught up. I mean, of 

course that's speculation. But what are your 

thoughts? 

MS. ROMERO-BRIONES: Absolutely. So 

it is speculation. I am going to vote to remove 

it just based on the conversations I have had 

with several certifiers that are in the room 

today. So I am going to vote to remove it. 

MS. DE LIMA: Sue, then Tom, then 

Ashley, then Harriet. 

MS. BAIRD: Given that there are other 

sources now available have the commenters 

submitted documentation that each of those types 

of lecithins would work the same in the products? 

Because sometimes that's an issue. 

MS. ROMERO-BRIONES: So currently --

so, some of the commenters mentioned that 

products are using both non-organic lecithin deoiled and organic lecithin de-oiled, depending on 

the supply and the consistency. So I think it's 

a question of supply as opposed to, like, 

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alternative products or differentiation of the 

lecithin. It's a matter of supply. 

MS. DE LIMA: Tom. 

MR. CHAPMAN: So, years ago fluid 

lecithin was also listed. It got delisted 

through a petition process by which, even with 

the product showing on the National List, someone 

was able to develop an organic market for fluid 

soy lecithin and petitioned the NOSB to remove 

it. 

It was a successful case of industry 

finding a market despite the material being on 

606, one that we've heard heralded several times, 

including with hops, the process right now in 

glycerin. And at the last meeting -- sorry, at 

the last 2017 sunset, which was what, 2015, in 

the 2014 sunset there were several agricultural 

items removed from 606, or recommended for 

removal from 606 that demonstrates that it is 

possible to build a market for this material when 

it's listed here. 

I would also say that soy de-oiled 

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lecithin is widely available now, and can also be 

sourced. 

The issue comes to non-allergenic 

forms of lecithin. And that's the area that is 

not as readily available, particularly in the 

fluid side but also in the de-oiled side. 

Generally you have a fluid market, and the deoiled market kind of falls behind it and requires 

a bit more processing. 

Sunflower is the primary nonallergenic form of lecithin on the market, 

although there is a couple others, canola, grape 

seed. So far we have not found sunflower oil 

lecithin to be readily available on a consistent 

basis. There's no manufacturers in the U.S. 

It's a derivative product of oil manufacturing. 

All these are deriv -- all lecithins are 

derivative products of oil manufacturing. 

And so, organic sunflower oil by and 

large comes out of the Ukraine. The Ukraine has 

been a semi-politically unstable country for the 

last three or four years given their conflicts 

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with Russia. And it hasn't always been 

available. It's developing. It is close. 

And I am aware of domestic 

manufacturers are putting in capabilities to be 

able to product this from the amount of sunflower 

oil that's -- organic sunflower oil that's 

refined here domestically. But that being said, 

it's not there right now. And a lot of things 

can change between now and then. 

You know, my vote and my 

recommendation here is going to be to relist it 

at this time. But, again, this market is 

developing with the 606 listing. Certifiers are 

able to go out and enforce 606 commercial 

availability quite, quite clearly on this 

material. And but I do encourage future if this 

does get relisted, I encourage future NOSBs to 

really take a critical eye to it because we're at 

the precipice of this becoming a standard 

available organic item. It's just not there 

right now. 

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 MR. SWAFFAR: Yes. So I just want to 

point out though, it's a comment. This spring 

that said our consumers avoid soy, so we 

primarily use sunflower lecithin. Most is 

organic, but we have had to use the non-organic 

at times due the supply availability. And that 

sunflower crop I know in the U.S., because 

chickens do use sunflower in seed also sometimes, 

is pretty unstable getting a harvest out of that 

crop every year. 

So that's why you can see supply come 

and go in an organic form. Some years it's 

there, some years it's not. 

And I just want to point 606 listing, 

for everybody that may not understand that 

language 100 percent, there if someone is going 

to use sunflower de-oiled lecithin they have to 

use organic if it's available. The certifier 

will make them do that. So, if that is 

available, they have to use that. If not, then 

they can drop down to the non-organic form. 

So I like retaining this material on 

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606 for those years that those sunflower crops do 

fail. I think that's critical because there may, 

there may be availability this year but not next 

year, depending on how the harvest is. So I 

think it's critical to keep this on the list. 

MS. DE LIMA: Harriet. 

MS. BEHAR: Two things. One is, when 

the certifier is asking if it is available, then 

you must use it. I have seen some manufacturers 

talk about the unstable production, so they say, 

well, I can't, I don't want to have -- I'd love 

to write "organic" on my label but I'm not going 

to. And then, therefore, I want to use the nonorganic. And some certifiers still mandate maybe 

the organic but others do not. 

And that does seem like a reasonable 

request from the processor. 

So I'm wondering if on the work agenda 

we could split out the various lecithins in the 

future because we can't annotate now. But if we 

had different lecithins then it would pave the 

way at the next sunset, or even before if 

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somebody petitioned, to take off the soybean 

lecithin de-oiled and retain the sunflower. 

And I'm not sure, I guess it would 

take a little bit more review because I think it 

could come from eggs and, I mean, there's other 

sources of lecithin. Do, just do a little bit of 

research on what is commercially used of lecithin 

de-oiled, and then split that out and then we 

would then be able to take the soybean oil off 

and encourage the growth of that industry and 

reward them for their activity in organic 

production, and keep the ones that we feel we 

strongly need. 

MS. DE LIMA: Steve. 

MR. ELA: It's fascinating to hear 

this debate because this is a world that I don't 

live in. And so, but I'm a little hesitant to, 

while I want to see the organic market expand I'm 

a little hesitant to delist it on the thought 

that by the time it gets through rulemaking it 

will ready, partly because we know, I mean we've 

seen from other substances that when it goes to 

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public comment for rulemaking some manufacturers 

are going to say this is going to cause me 

economic hardship, and then it's going to get 

derailed. 

And so I guess before we send it to 

the NOP for rulemaking to delist it, I'd like to 

have our case pretty solid and not speculative 

that, you know, this is, this is real. 

So I tend to fall on Tom's side that 

I'm leaning towards relisting it now, but the 

next go-round really giving it a, you know, 

really giving it a crucial eye and saying, okay, 

we should be there. 

MS. DE LIMA: Yes, I echo what Steve 

said. I'm definitely not at a place where I'm 

comfortable delisting. Scott. 

MR. RICE: Yeah, I'd just reiterate 

what's been said and reiterate again. But also 

just emphasize that, you know, part of the 

process in reviewing any product formulation 

would be around the material would be looking for 

some sort of evidence that that manufacturer made 

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an effort to source an organic source where an 

organic source would likely be found. 

MS. DE LIMA: Any other discussion? 

(No audible response.) 

MS. DE LIMA: All right. Tom. 

MR. CHAPMAN: Okay. We have a motion. 

MS. DE LIMA: Dave? 

MR. MORTENSEN: If we could, just for 

another two minutes. 

MS. DE LIMA: Yes. 

MR. MORTENSEN: So I'm just slightly 

confused exactly what we're voting on here. 

We're voting to keep this on. If this wasn't on, 

or even if it is on, on the list as written, 

would we, are we saying that there could be an 

organic soybean-derived only lecithin de-oiled 

that would be added to the list later? 

Is that what we're saying or not? I'm 

confused. 

MS. DE LIMA: So, right now we're 

simply voting on whether we're going to relist or 

not relist de-oiled lecithin. That includes all 

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forms: soy, sunflower, whatever. 

Later on the subcommittee could decide 

if they want to explore Harriet's suggestion of 

splitting the listing out into -- and we have to 

talk to the program, too -- into different 

sources so that it might be easier to take the 

soy off and leave the other forms that are 

unstable, availability-wise unstable on the list. 

MR. MORTENSEN: Thank you, Lisa. 

MS. DE LIMA: Ashley. 

MR. SWAFFAR: Yes. Dave, just to 

follow up on that, the 606 listing where it's at, 

they have to use an organic form if it's 

available. So they have to use organic soy if 

it's available. 

MR. CHAPMAN: Okay. So, we have a 

motion to remove lecithin de-oiled from the 

National List. The motion was made by A-dae and 

seconded by Eric. 

A yes vote is to remove. A no vote is 

to relist. And the voting will start with 

Harriet. 

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MS. BEHAR: No. 

DR. SEITZ: Yes. 

MR. MORTENSEN: No. 

MR. ELA: No. 

MR. BRADMAN: No. 

DR. GREENWOOD: No. 

MS. DE LIMA: No. 

MR. SCHWARTZ: No. 

MS. ROMERO-BRIONES: Yes. 

MS. OAKLEY: Yes. 

MS. BAIRD: No. 

MR. BUIE: No. 

MR. SWAFFAR: No. 

MR. RICE: No. 

MR. CHAPMAN: Chair votes no. 

MR. RICE: There's 3 yes, 12 no, 0 

absent. 

MR. CHAPMAN: Motion fails. Lisa. 

MS. DE LIMA: Emily. 

MS. OAKLEY: Sorry. Just a point of 

clarification. I think this vote will be helpful 

to future NOSB reviews and might augment the 

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level of scrutiny. 

MR. CHAPMAN: If I could add on that. 

I mean, it went through a high level of scrutiny, 

so I'm not sure if augmentation of that is 

necessary. But, you know, I'd really encourage 

future NOSBs to take a hard look at this and see 

if the market has developed further. 

MS. DE LIMA: Harriet. 

MS. BEHAR: I just want to encourage 

the subcommittee to consider a work agenda item 

to split this into numerous forms of lecithin deoiled. 

MS. DE LIMA: All right. Moving on to 

tragacanth gum. 

DR. MATHEWS: At Section 205.606(q) 

the listing is tragacanth gum, CAS No. 9000-65-1. 

MS. DE LIMA: All right. So, this gum 

is prepared from the sap of various species of 

legumes. It can form jells and be used as a 

thickener and emulsifier. It's effective at low 

pH and at many temperatures. And it's stability 

at low pH is one of its distinguishing 

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characteristics. 

Percentage used in the final product 

is usually low, below 1 percent. And this gum is 

allowed for use in organics internationally. 

So, this is one of those ones we 

reviewed a couple years ago in Stowe. And at 

that time we had one producer come forward in 

favor because they were using it. This time 

around, did not have any manufacturers come 

forward saying they were using it. And we had 

one organization point out there could be 

potential health effects and according to the 

Center for Public Science that people were having 

allergic reactions, and thought that needed to be 

taken into consideration. 

I will say that one manufacturer that 

came forward last time is still using it. So I'm 

not sure why they didn't come forward. But, 

again, an example of people sort of losing track 

or not paying attention necessarily to what we're 

doing because I do see it's still in that one 

product. Harriet. 

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 MS. BEHAR: It's noted here -- does 

somebody remember, I don't remember what the 

mitigation steps are to reduce the microbial 

load? 

MS. DE LIMA: Where are you reading 

that? 

MS. BEHAR: In the manufacture, in the 

powder. Just somebody could look at the TR. 

And then also was there any discussion 

about growing it organically? Astragalus is 

actually a native to North America. It's growing 

on my farm. 

MS. DE LIMA: There was no public 

comment about that being grown and processed 

organically. Dan. 

DR. SEITZ: On a couple of the 

substances that are under review commenters have 

made the point that when they were first approved 

information was withheld on the manufacturer 

based on, what is that, CBI --

MS. DE LIMA: Yes, CBI. 

DR. SEITZ: -- yeah, CBI, you know, of 

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proprietary information. 

And I just would like to suggest to us 

that if something has been approved in the past 

without the full information, that we may 

routinely want to get a TR the next time it comes 

up just so that when it comes to relisting we do 

have full information. I'm not saying, we don't 

have time to do that here, but I think it's just 

a good practice on our part. 

MS. DE LIMA: So I just want to 

clarify that that was not -- there was no public 

comment received about that for this particular 

gum because this gum is not a product of 

fermentation. This is on 606. So that was in 

reference to the gums that are on 605(b). 

DR. SEITZ: Great. So then I'll just 

apply my comment to those. 

MS. DE LIMA: Okay. 

DR. SEITZ: Okay. 

MR. CHAPMAN: If I can also note, we 

did get a TR on gums this round. 

MS. DE LIMA: Yes. 

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 MR. CHAPMAN: So if that's what you 

asked. 

DR. SEITZ: Sure. Okay, but just in 

general I've seen that point made, and I think 

that would be a good practice. 

MS. DE LIMA: Any other discussion? 

(No audible response.) 

MS. DE LIMA: All right, Tom. 

MR. CHAPMAN: Okay. We have a motion 

to remove tragacanth gum from the National List. 

The motion was made by Lisa and seconded by 

Steve, that motion to remove. 

So, a yes vote is to remove. A no 

vote is to retain. And the voting will start 

with Dan. 

DR. SEITZ: No. 

MR. MORTENSEN: No. 

MR. ELA: No. 

MR. BRADMAN: No. 

DR. GREENWOOD: No. 

MS. DE LIMA: No. 

MR. SCHWARTZ: No. 

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 MS. ROMERO-BRIONES: No. 

MS. OAKLEY: No. 

MS. BAIRD: No. 

MR. BUIE: No. 

MR. SWAFFAR: No. 

MR. RICE: No. 

MS. BEHAR: No. 

MR. CHAPMAN: Chair votes no. 

MR. RICE: That's 15 -- 0 yes, 15 no, 

0 absent. 

MR. CHAPMAN: The motion fails. Lisa. 

MS. DE LIMA: All right. I think 

that's it for sunset materials. The next step, 

we're moving into the proposals. And first up is 

sodium chlorite for the generation of chlorine 

dioxide gas. And Scott's gotten his beard. 

MR. RICE: Thank you. 

This is material petition in 2015 

initially. Petition for use as an antimicrobial, 

pesticide, sanitizer, or disinfectant for fruits 

and veggies. 

Chlorine dioxide, or CDO gas, is used 

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in post-harvest handling for the direct treatment 

of fruits, vegetables, and nuts during storage, 

transportation, and food preparation applications 

to reduce spoilage and pathogenic organisms. 

Chlorine dioxide acts as a killing agent of 

pathogenic organisms. 

It is, the chlorine dioxide gas is 

produced onsite at the handling facility by 

impregnating zeolite with a sodium chlorite and 

then activating the zeolite, which is then 

treated with a solid or liquid acid such as 

citric acid. 

If liquid acid is used, as in the 

product manufactured by the petition, a buffer is 

used to control the formation and release of the 

gas. 

In organic production, chlorine 

dioxide is currently allowed for use in liquid 

solution in crop production as a preharvest 

algaecide, disinfectant, and sanitizer, including 

in irrigation systems, cleaning systems, in 

organic livestock production for use in 

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disinfecting and sanitizing facilities and 

equipment, and in organic handling for 

disinfecting and sanitizing food contact 

surfaces. 

For these uses, the residual chlorine 

levels in the water cannot exceed the maximum 

residual disinfectant limit under the Safe Water 

Drinking Act. This petition is seeking to extend 

the use of chlorine dioxide in gaseous form for 

antimicrobial treatment. 

The proposed use is similar to 

acidified sodium chlorite. That's already listed 

at 605(b) for secondary direct antimicrobial food 

treatment and indirect food contact, sanitizing. 

That substance was petitioned and added as a 

solution, whereas this would be used as a 

fumigant gas for direct food contact. 

The subcommittee initially favorably 

viewed this. The petitioners claim that no posttreatment water rinse is necessary, and concerns 

regarding wastewater in other treatments were 

somewhat addressed because of that lack of use of 

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the water. 

Through the course of the review and 

comments from the public, that claim didn't seem 

quite as clear as we initially thought, the 

comments about which I'll touch in a moment. 

The subcommittee also initially saw 

this as having a potential for reduced exposure 

to those using chlorine dioxide as the substances 

reacted, and its use takes place in an enclosed 

space. However, the exposure at even lower 

levels presents some concerns. 

Had a number of comments on this both 

in this round and in previous rounds. Several 

commenters noted the material should be 

petitioned or listed as chlorine dioxide gas with 

an annotation restricting the form to generated 

from sodium chlorite. 

Commenters noted it was unclear how 

other precursors and activators other than sodium 

chlorite would be reviewed. I think it's 

important to note that the initial petition was 

submitted in this way. However, at the time, 

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there was a clarification from the program that 

the subcommittee, that the subcommittee followed 

it in making a determination since the material 

would not be sold or distributed as a finished 

product of chlorine dioxide gas, it be petitioned 

as stated. 

Comments from certifiers, material 

review organizations, and others again noted that 

for clarity and consistency in review, the 

alternative language was preferable. 

While the petitioner states the gas 

can be used without a subsequent potable water 

rinse, several comments noted the EPA requires 

that for chlorine dioxide fruit and vegetable 

treatment the label include a statement: "fruits 

and vegetables treated with chlorine dioxide must 

be blanched, cooked, or canned before consumption 

or distribution in commerce." That was based on 

a need to reduce residues below 3 parts per 

million. 

Several commenters pointed to the EPA 

conditional registration as cause for concern 

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given that with such registration not all 

essential environmental toxicity data is 

available. 

Some commenters noted the current 

limited label use of the petitioner's product for 

-- and I should say the only product that we're 

aware of for potatoes in storage. There does not 

appear to be a product in the market for which 

the label use allows a wider application at this 

time. 

Commenters pointed also to 

alternatives that are available. As in -- as we 

see in organic operations, preventative practices 

are the first line of defense and cornerstone of 

both field and post-harvest practices. There is 

a gaseous form for disinfectant for ozone gas 

with peracetic acid, and as well as other 

chlorine materials. 

Two commenters attested to successful 

results in non-organic facilities, but again 

limited to use on potatoes. 

We did not hear any comments from 

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organic processors or handlers to add this 

material to their practices. 

So I think while it appears this could 

be an effective tool, the concerns over potential 

impacts on human health and environment, the 

present limited availability or label use of this 

and availability of alternative materials and 

practices, and the lack of necessity in food 

safety compliance does not, you know, shifted 

thoughts on this in terms of adding it to the 

National List. 

I know that there was, again, support 

in the initial vote from the subcommittee. And 

wanted to go through that to explain what our 

thinking is at this point. Asa. 

MR. BRADMAN: I just want to make a 

few comments about this material as well. 

I think in the general category of 

chlorine compounds that there's a lot of -- boy, 

I seem to be mumbling today -- that the whole 

issue of chlorine compounds is challenging and 

something that does need a broader review. 

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Bleach also is a harsh material. 

I just want to kind of summarize, 

though, some of the health effects that are 

associated with chlorine dioxide. I actually 

reviewed this material and bleach earlier this 

year. And if we just look at, say, the NIOSH and 

ATSDR documents, there's been some other 

association of clinicians, environmental 

occupational commissions. Exposure to chlorine 

dioxide can produce irritation of the eyes, nose, 

throat, cough, wheezing, bronchitis, pulmonary 

edema, and chronic bronchitis and asthma. 

Under the global harmonization system 

for signaling materials it has a number of 

signals, including it's an oxidizer. It's 

corrosive. It's an acute poison. It's an 

irritant and has aquatic toxicity. So there's --

it's also considered an asthmogen, as is bleach. 

An asthmogen is basically a material that can 

cause asthma as opposed to triggering an 

asthmatic response in somebody who already has 

it. So this is a quite harsh material. 

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But though I look forward to 

discussion around this because of, you know, the 

notion if using -- I mean, I have problems with 

this material. I would vote this petition down. 

But if there is, you know, if there's 

ways of using it or other materials or, you know, 

a whole range of materials needed for sanitizing, 

then it could possibly reduce other exposures. 

And I think that's where there are some 

challenges and that's where we need to look at 

the big picture. And perhaps other people on the 

board can comment to that. 

But this is a powerful material, as 

are many of the chlorine compounds. And they're 

harsh, and there's a tradeoff with the 

environmental and human health effects and the 

food safety issues. 

One last thing I want to, point I want 

to make related to the human health effects is 

that there, I don't feel like there's been 

adequate monitoring for chlorine compounds in 

food processing environments. When I was 

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reviewing materials related to seafood 

processing, poultry processing, I could find very 

few studies just where somebody went into an 

occupational environment and just measured, you 

know, chlorine in the air, different forms of 

chlorine and interviewed workers. 

I know when we went into the Salinas 

area, workers, particularly in processing 

facilities, complained bitterly about exposures 

to bleach. In fact, they were more concerned 

about that in many cases than the more 

conventional pesticides being used in the fields. 

MS. DE LIMA: Emily. 

MS. OAKLEY: Dave, if you want to go 

first, I can go after you. 

MR. MORTENSEN: Yeah. I guess I 

would, I'd just echo Asa's concerns and the idea 

that it's -- that field workers, and greenhouse 

workers, and food processing folks in storage 

facilities would be potentially exposed to, to a 

gaseous form of this is really worrying to me. 

So my reaction to this is that it is 

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not a good thing for us to be thinking we would 

approve. 

MS. DE LIMA: Emily. 

MS. OAKLEY: I also think this really 

speaks to the question of how petitioners come to 

us and they express need for a material. And I 

don't feel like we received popular comment at 

all from industry and in support or in request of 

this material. 

So, weighing that with the concerns, 

I also don't support this. 

MS. DE LIMA: Harriet. 

MS. BEHAR: Not only did it not 

receive support, but the Organic Produce 

Wholesalers Coalition spoke very strongly against 

it. And I think they represent perhaps not every 

distributor of organic produce, but they do 

represent a significant portion of it. 

I think, too, that we are looking at 

sanitizers, and so if we vote this down it 

doesn't mean that in that review we might find a 

specific need for this or, you know, that there 

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could be a gap. And this is one of the reasons 

why we have the sanitizer review on our work 

agenda to look at these unique sanitizers and try 

to understand better where they fit. 

Because when we look at them in this 

way we see the human health and the environmental 

impact and all these things. And we see 

alternatives and yet we -- and we don't see a 

specific needs. 

So I'm hoping that I'm going to vote 

against this material and but keep my mind open 

when we are doing the sanitizer review. And 

include review of this material and materials 

like this that are in gaseous form for possible 

inclusion. And maybe we'll find a different one, 

whatever. 

But I'm sure that there are places 

where this type of sanitizer might be unique. 

But without that specific information or 

clamoring from our organic community for the 

material, and so I'm speaking very strongly 

against it. I think it doesn't look too good, at 

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least for my vote. 

MS. DE LIMA: Ashley. 

MR. SWAFFAR: Yes. So, on this team 

from the subcommittee unanimously suggesting to 

list this material. And it sounds like several 

on that subcommittee may have changed their mind. 

And I would just encourage those members to 

please tell us that for the public record and to 

be critical, to state your opinion. I am not on 

the subcommittee anymore. 

MS. DE LIMA: Steve. 

MR. ELA: I'll stick my neck out. So, 

although for a chicken producer, if I stick my 

neck out I don't want to --

MR. SWAFFAR: That's not humane, 

Steve. 

MR. ELA: Okay, fair enough. 

This is one I've really wrestled with. 

And I certainly voted for it in subcommittee. I 

personally react to chlorine pretty strongly so I 

have no love of it. But I also, since we run a 

farm and a processing facility, that is our, our 

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go-to sanitizer of choice as a very small 

facility. 

Certainly as we look at packing lines 

and fruit, and things that are not flat and 

easily sanitizable, and with FSMA compliance 

especially for very small processors that don't 

have large budgets for equipment, the 

attractiveness of a gas is strong, in the sense 

of being able to shroud something, fumigate it. 

You know, for example, we can shroud 

our packing line on Saturday evening, fumigate. 

Crews gone. Monday morning come back, get back 

to work and have a kill step in that, in that 

process. So that's very attractive without the 

having to spray everything down and trying to get 

in bearings and nooks and crannies. 

So I honestly am leaning towards it 

even though I totally agree with all the 

comments, you know, from Asa and the others. I 

have no love of chlorine materials. But that's 

my -- I think it's another tool in the toolbox 

that is different than the other chlorine 

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materials. 

So I'm torn with how I'll vote but I 

do want to put that 2 cents in as why I voted in 

favor of it originally. 

MS. DE LIMA: I voted in favor 

originally but I'll be changing my vote. 

MR. SCHWARTZ: I'm calling on myself 

and then I'll call on them. 

I'm changing my vote, you know, for 

all the reasons that Scott summarized: the lack 

of, lack of support in public comments, the 

health concerns. There were some folks that 

wrote in that I want to take their public comment 

into consideration. 

MS. ROMERO-BRIONES: So I voted to 

keep it. I certainly empathize with all the 

comments. I've spent a lot of time for the last 

ten years or so working with various sanitizers 

on the processed vegetable side, and there are so 

few tears available, I think it's very dangerous 

to start taking tools off until we've really 

vetted that. 

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Most folks are aware that we can't use 

caustic, we can't use heat, so the few tools that 

are out there, to start taking those away, I 

think that's, that's the challenge. 

MS. DE LIMA: A-dae. 

MS. ROMERO-BRIONES: So, I voted to, 

I voted for it partly because it's used by one of 

the only certified tribal operations, a potato 

farmer in Arizona owned by the Maricopa Indian 

Community. And they actually used this in their 

processing line. 

I do, I hear the concerns of Asa, so 

I'm reconsidering my vote. But I originally 

voted for it. 

MS. DE LIMA: Scott. 

MR. RICH: Just clarification on a 

couple things. This is not a material that's 

currently on the National List, so we would not 

be removing something that is presently available 

to an operation. And it may be -- and A-dae 

might clarify for me if it's maybe the operation 

is using it in the conventional side --

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MS. ROMERO-BRIONES: Yes. Yes. 

MR. RICH: -- and seen the success. 

MS. ROMERO-BRIONES: Yes. 

MR. RICH: So I just wanted to make 

sure that was clear for everyone. 

MS. ROMERO-BRIONES: Thank you. I 

misspoke. Yes, thank you for your clarification. 

MS. DE LIMA: Sue. 

MS. BAIRD: This is a question. And 

I appreciate everybody's input. It's been very 

helpful to me. 

I'm taken by Steve's comment that it 

would help small processing, maybe on-farm 

processing facilities. And small farms is where 

my heart's at. I'm wondering if, if we voted to 

add this to the list, perhaps based on Steve's 

comment that he would do it in the evening and 

then come back the next morning, gases would be 

dissipated, maybe we could put that kind of a 

time lapse annotation on it. 

I know there are on some other 

products or materials. 

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 MS. DE LIMA: Tom. 

MR. CHAPMAN: Just to answer the 

question about how people voted, I was the absent 

member. I was at camp with my daughter. So I'm 

going to have to keep you guessing on that one. 

MS. DE LIMA: Harriet. 

MS. BEHAR: I just want to say again 

that we will be doing this review of sanitizers. 

And that might help us identify other gaseous 

sanitizers that perhaps would be less problematic 

than this one. 

And so we put this one on. I just, I 

think it's a little bit of a rush. Do we 

absolutely need this right this minute? Or could 

we wait a year and have some better information 

available to us as far as the unique uses of this 

and what other uses there could be? So, just 

kind of a caution. 

MS. DE LIMA: I have a question for 

Steve. Put you on the spot. 

So, what do you do currently? 

MR. ELA: That's a hard one. I mean, 

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we're, we're really wrapped in a quandary around 

that in our operation. I mean, it's chlorine. 

It's a wash. But with FSMA and the requirement 

for swabs and everything, I mean, really where 

you're getting down to a whole different level of 

sanitation than small growers used to do. It's a 

new, it's a new thing. 

And we have spent a lot of hours 

scratching our heads of what the proper way to 

approach this is. So, and I'm not saying we 

would necessarily fumigate, but it puts in my 

head, well, here's an option. 

And I guess we keep as a committee, I 

totally -- I mean, it's so funny because I'm 

usually really conservative on these kind of 

things and vote against them. But the fact this 

intrigues me kind of worries me a little bit. 

But I see us kind of continuously 

mixing some of these post-harvest compounds 

because of rod spectrum. I mean, for good 

reasons. But at some point I think we do have to 

offer growers a choice for post-harvest 

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sanitation, both of equipment and of the fruit. 

And I'm not saying this is the right one for that 

necessarily, but I think we do need to be aware 

that there isn't some need out there. 

We do lose, you know, processors, 

people lose fruit to rot. We do have to sanitize 

lines. FSMA is a whole different ballgame than 

what it used to be, you know, where we're really 

going for complete sterility from, you know, from 

just good practices. And it's a challenge. 

So I don't know if that answers your 

question, but right now it's basically chlorine 

and water for us. 

MS. DE LIMA: Scott. 

MR. RICH: Just a follow up for you, 

Steve. Sorry to continue to put you on the spot. 

Have you considered or explored the 

idea of using ozone? 

MR. ELA: We are. I mean, it's a work 

in progress. I mean, that is, that is in the 

back of my head as well, so. And that may be the 

preferable way to go. 

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I guess it's one of those things that 

it's got us flummoxed for a while. And we don't 

have the capability. I mean, like many small 

farms we don't have a food safety officer. You 

know, my spouse is that. 

But, you know, and it's really hard --

and I think this is not related to this compound 

-- but it's really hard for small processors or 

growers to get that information. I mean, we're 

in touch, we're in close contact with CSU and the 

folks there. And they're great. But they don't 

actually have a lot of these answers either. 

You know, the big processors that have 

a Ph.D. on staff, it's a whole different story 

because they have somebody that can vouch for 

that. But for those of us that don't have a 

background in microbiology -- and I think many 

small growers are with that -- it's a challenge 

to figure out how to meet these regulations with 

due diligence. And, you know, none of us want a 

food safety incident, we want to do it right. 

But, you know, the information isn't readily 

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available. 

MS. DE LIMA: Dave, then Tom, then 

Rick. 

MR. MORTENSEN: I guess just a thought 

that, you know, farmer behavior in terms of 

stewardship of practices is a distribution curve. 

I think we have some super dooper careful folks 

that are working with their staff, and we have 

folks that are less careful. And when we're 

talking about something like chlorine gas, it 

just continues to concern me that it's not a 

static farm community, it's a distribution of 

behavior. Some pay more attention to some things 

than others. 

And this is a sort of use that's 

unforgiving with respect to human exposure. 

MS. DE LIMA: Tom. 

MR. CHAPMAN: I just want to note that 

the sanitizers work agenda item that was approved 

by the program is limited to -- and I'm going to 

read from it -- the goal of this initiative is to 

develop questions to examine the essentiality of 

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these materials, and to build upon criteria to 

evaluate substances on the Nation List per 

Sections 205.600 of the U.S.C. regulations. 

It's not a holistic review of all the 

sanitizers. And I don't know if some of the 

comments made about that work agenda item would 

yield gaps or knowledge gaps of where the 

sanitizer code could not provide some, some 

assistance in the needs of organic producers. 

So, if we, if that larger work agenda 

item were needed it would need to be asked from 

the program. 

The other thing, now that I have my 

opportunity to speak, of course I'm going to just 

but in here that we are running late on the 

Handling Subcommittee and we'll need to do Crops 

at some point. At some point we will need to 

wrap this conversation up and move to other 

items. 

MS. DE LIMA: Rick, go ahead. 

DR. GREENWOOD: Just a quick comment. 

I think most of you know there's about 900 major 

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food outbreaks a year in this country with 3,000 

deaths. And one of the best ways to prevent them 

is sanitation within a packing house or in the 

field. And to actually sanitize things, gases 

work very well because they can get into places 

that liquids can't. 

So I see this, again, as something 

that's very useful in an era where there's a lot 

of scrutiny. And I also get comments from 

people, well, aren't organics more susceptible to 

transmission of disease because of natural 

products and things like that? And people 

mention that. 

So I think it's important to have 

something that can be useful and really get into 

the cracks and crevices of these places. So I'm 

going to vote for it. 

MS. DE LIMA: Harriet, make it quick 

and then we'll go to vote. 

MS. BEHAR: Yes. There was a lot of 

public comment that the actual listing should be 

chlorine dioxide gas instead of sodium chlorite. 

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Was there any discussion within the subcommittee 

about possibly changing that? Because the actual 

material is chlorine dioxide gas, not sodium 

chlorite. 

MS. DE LIMA: Scott, you want to take 

that? 

MR. RICH: Yeah. I think if we were 

going to consider this I would want to have the -

- take into consideration that public commenters 

have given to have a listing that is more 

workable from a verification side. And if that 

is significant enough that it needs to go back to 

subcommittee, then I would prefer that than to 

have a listing that is not as workable. 

MS. DE LIMA: Jennie, can you comment 

on that, or can the program? 

DR. TUCKER: I'm sorry, can you repeat 

the question? 

MR. RICH: If we were to continue 

voting on this would changing the listing to --

let me get my language up in front of me --

changing the listing to, as commenters have 

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preferred, chlorine dioxide gas with an 

orientation generated from sodium chlorite. Is 

that something that would need to come back to 

subcommittee versus making that change here? 

DR. MATHEWS: The change would consist 

of the annotation? Just a point of clarification 

there. 

MR. RICH: It's not really an 

annotation. 

MR. CHAPMAN: Yeah, it's not. 

MR. RICH: It's the material as it was 

passed was the sodium chlorite for the generation 

of chlorine dioxide gas. And I think there was 

some comment about flip-flopping that kind of. 

And I'm going to also ask for a third 

alternative which is do we need to change it and 

send it back, or can this also just be handled by 

the program in the regulatory process here on 

out, given the clarity of the current motion? 

DR. MATHEWS: Certainly if it came 

through in the board's recommendations, the 

program would take those recommendations into 

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consideration if it got to the regulatory writing 

phase. 

MR. RICH: Thank you. 

MS. DE LIMA: Really quick from Steve. 

MR. ELA: I recall that you came on 

the board with us, Joelle. I wish she was here 

for this. But I remember her comments on the 

whole chlorine issue of it's like the gums, every 

chlorine product has a specific use and a 

specific place and is, you know, a specific 

thing. 

And so her comment really in reviewing 

all the chlorine products was it's so variable, 

depending on the manufacturer and the situation, 

that she was really hesitant to say that any of 

us or anybody could adequately say limiting the 

toolbox, because she really felt, like the gums, 

each one has a specific use. 

So, I just want to echo her, her 

thoughts before she went off the board. 

MS. DE LIMA: We have to move to a 

vote. I'm sorry, Emily. 

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MR. CHAPMAN: Okay. So we have two 

votes here. One is a classification motion. So 

this is a determination --

MR. RICH: Point of order. 

MR. CHAPMAN: Yes. Sorry. 

MR. RICH: That clarification --- the 

classification has already been completed. 

MR. CHAPMAN: Oh yes. That would also 

explain why the vote numbers are different. 

Okay, so this item does not need to be 

classified. It's already been classified by a 

previous NOSB who classified this material as 

non-agricultural synthetic in April of 2016. 

So the motion here is just the listing 

motion, the motion to add sodium chlorite for the 

generation of chlorine dioxide gas at 205.605(b). 

The motion was made by Scott and seconded by 

Lisa. 

A yes vote is to recommend this 

material for listing. So, different from the 

sunset. A yes vote is to recommend listing. A 

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no vote is to reject this petition, not recommend 

it for listing. The voting will start with Dave. 

MR. MORTENSEN: No. 

MR. ELA: Yes. 

MR. BRADMAN: No. 

DR. GREENWOOD: Yes. 

MS. DE LIMA: No. 

MR. SCHWARTZ: Yes. 

MS. ROMERO-BRIONES: No. 

MS. OAKLEY: No. 

MS. BAIRD: Yes. 

MR. BUIE: No. 

MS. SWAFFAR: Yes. 

MR. RICH: No. 

MS. BEHAR: No. 

DR. SEITZ: No. 

MR. CHAPMAN: Chair votes yes. 

MR. RICH: That's 6 yes, 9 no, 0 

absent. 

MR. CHAPMAN: Six yes, 9 no, 0 absent. 

The motion fails. 

MS. DE LIMA: All right. Next we have 

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silver dihydrogen citrate. Tom. 

MR. CHAPMAN: All right. Silver 

dihydrogen citrate is a petition that was brought 

forward to the NOSB, brought forward by Pure 

Bioscience, it's petitioned as a antimicrobial 

processing aid for poultry carcasses, and fruit 

and vegetables, excluding citrus for grapes --

citrus and grapes for wine making, and for use as 

a disinfectant or sanitizer for food contact 

surfaces and food processing equipment. 

As petitioned it was petitioned to be 

listed on 205.605(b) as a synthetic nonagricultural substance allowed in processed 

products labeled as organic or made with 

organics. 

The petition received in January of 

2017; amended in August of '17; and again an 

addenda was submitted in June of 2018. 

Technical review was requested and 

found sufficient by the subcommittee. It was 

found sufficient in May of 2018. 

The subcommittee also recommended 

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amending the petition to add an annotation that 

read "limited to particle size greater than 300 

nanometers." 

Based on information provided, SDC 

appeared to be a low risk to the environment and 

human health. The subcommittee found that it 

appeared to be a low risk to the environment and 

human health, both in use and in disposal. 

Alternative materials, natural and synthetic, are 

available. However, those substances have 

limited application and/or utilize a similar 

oxidated mode of action. 

There was a growing concern about the 

development of bacterial resistance by oxidated 

bacterial agents. And I do want to note that 

those oxidated agents were efficacious, are also 

used in hospitals and medical applications. 

This is the first time that the NOSB 

has brought this petition forward on our polished 

agenda, although we have received comment on it 

in previous meetings. 

The subcommittee, again, had interest 

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in this material given its alternative mode of 

action, limited toxicity in application, and a 

thought that we could mitigate the nanomaterial 

concern. 

We received a sizable amount of public 

comment on this material at this meeting and at 

some past meetings, some encouraging that we pass 

this item without the limitation. Some 

encouraging that we send it back to subcommittee 

for further review and consideration. And some 

asking that we fail this item. 

We did not receive any support for 

listing it the way we had proposed to list it. 

And we had questions raised and really 

I'm going to summarize them briefly in, I guess, 

four main areas. 

So, the first area was the use of 

nanotechnology. There's a debate around whether 

this material is a nanomaterial. I want to note 

that in the fall of 2010 the NOSB unanimously 

voted to prohibit engineered nanomaterials of 

sizes 1 to 300 nanometers in organic production 

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and handling. 

And that the NOP responded to the NOSB 

recommendation in a policy memorandum dated March 

of 2015, letting it be noted that nanomaterials 

are generally the size of 1 to 100 nanometers and 

that to be used in organic production they would 

need to be petitioned to the National List. To 

address the public concerns and to stay 

consistent with previous NOSB action, the NOSB 

did recommend limiting the use of this item to 

particle sizes less than 300 nanometers. But we 

failed to place the minimum size on that, the 1 

to 300 nanometer range. 

The petition also noted that this was 

ionic silver and, therefore, was less than the 

size of 1 nanometer, and in their arguments 

concluded that it was not a nanomaterial because 

it was not specifically engineered for that size 

and was below the lower threshold. 

Another area of concern was the use of 

an antimicrobial in food applications that was 

also used in medical applications. 

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There were some concerns around 

studies that were showing a level of resistance 

to silver compounds, bacterial resistance to 

silver compounds, and that their usage should be 

reserved for the medical environment, and that 

further usage of silver in organic applications 

could potentially speed up the development of 

microbial resistance to silver. 

The third area of concern was around 

our assessment on the toxicity of this substance, 

particular around environmental toxicity of 

silver and the water effluence. The petition, 

the petitioner, and the subcommittee noted as, as 

well as the technical re3view, that at the low 

levels of application the results of the spent 

water being much below background levels of 

silver in the environment and in waterways. 

However, we also received comments 

from the public directing our concern to toxicity 

of silver in general, as well as the use of this 

materials and restrictions of the use of this 

material already from the FDA or EPA, and 

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concerns of notifying municipal water sources, 

and how that would be handled if it was used in 

field applications or in applications of which 

the water did not result in being disposed of 

through a municipal setting. 

Another area was around the necessity 

of another sanitizing substance and the fact that 

there is the presence of other sanitizers, and 

the general request for a holistic review of 

sanitizers. 

We did hear support from industry. We 

heard support from a numerous number of 

antimicrobial distributors; some food safety 

scientists, including a former USDA 

undersecretary for food safety; and then also 

from industry, particularly to a --- one being a 

large organic leafy green processor located in 

California who uses this on their conventional 

leafy greens and noted the risks to food borne 

pathogens in that industry and the need for 

effective sanitizing substances to mitigate those 

concerns. 

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Those were the major areas. There's 

definitely other concerns as well, including the 

residuals on food. And the other one I want to 

note is the use of sodium lauryl sulfate, and 

whether or not that material needs to be reviewed 

or excluded, and if the way it was petitioned to 

us in usage was consistent with the way it was 

noted in the patent for this material. 

All summed in, I do want to open this 

up for public discussion here. But also note 

that no matter what our opinion here is, we 

probably deserve to send this back for the sense 

that we did not accurately describe the 

nanomaterial issues in our summation. And it 

definitely needs some revision to take into 

account some of these concerns that were raised 

here. 

And so we will be recommending, or I 

will be making a motion at some point to refer 

this back to the subcommittee for further review. 

But would also like to open it up here for some 

kind of brief comments on the use of this 

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material. 

MS. DE LIMA: Harriet. 

MS. BEHAR: there was also one 

commenter Richard Theuer who discussed the use of 

sodium lauryl sulfate. And will that be reviewed 

then in subcommittee as well? 

MR. CHAPMAN: Yeah, that was my -- on 

the more minor concerns, or not minor by any 

means, but the other concerns of note that not 

all the people noted was the residuals in food, 

on food services, as well as sodium lauryl 

sulfate and what source is used. What's the 

reason behind the presence of that material? 

MS. DE LIMA: Dave. 

MR. MORTENSEN: You know, I don't know 

if it goes back to committee or not, but I would 

just say that I have some concerns about this 

that, you know, that were raised in some of the 

public comment and just some concerns that I had 

when I initially read the proposal. 

I think there's pretty ample evidence 

that the silver, you know, when in solution will 

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likely precipitate to form larger size molecules 

that definitely approach, you know, the sort of 

size frames that we're concerned about in the 

legislation, Tom, that you, that you were citing. 

I also have concerns about introducing 

silver into the water stream in the way that this 

practice would. And I thought that the 

questioning that Steve Ela was pursuing with the 

speaker yesterday revealed that there's, in my 

opinion, not a lot of thought's been given to 

what is the fate of the silver in the wastewater, 

and particularly under conditions on the 

farmstead scale that would be maybe moderate size 

to smaller. 

Those are my two big concerns. 

MS. DE LIMA: Emily. 

MS. OAKLEY: I echo that. 

MS. DE LIMA: Tom, I don't see any 

other discussion. 

MR. CHAPMAN: Yeah. I do want to note 

that the nano subject is, it's a bit, it's a bit 

complex. I'm going to read the working 

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definition that the NOSB had proposed. Although, 

if you read that proposal, it also notes the need 

for further refinement and understanding of 

nanotechnology. 

But the working definition that the 

NOSB had tried to put in place was: 

Engineered nanomaterials: substances 

deliberately designed, engineered, and produced 

by human activity to be in the nanoscale range, 

approximately 1 to 300 nanometers because of very 

specific properties or compositions. For 

example, shape, surface properties or chemistry 

that result only in that nanoscale. Incidental 

particles in the nanoscale range created during 

traditional food processing such a 

homogenization, milling, churning, freezing, and 

naturally occurring particles in the nanoscale 

range are not to be included in this definition. 

All nanomaterials, without exception, containing 

capping agents and synthetic components are 

intended to be included in this definition. 

It's not clear to me if the only 

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concern is it reforming -- and I mean there might 

be other concerns -- but if the only concern was 

that reforming nanoparticles in solution, I don't 

know if that meets this definition that was put 

forward by previous NOSBs. 

MR. MORTENSEN: Yes. Not by the words 

that I was hearing you read. But certainly I 

think the concern is nanoparticles or just 

precipitated metal ions that we're introducing 

into cells and into the water stream just really 

concerns me. 

And during one of the public 

commenters' presentations about this where the 

person was advocating for this product I asked 

several questions about the fate in water, and 

the answers were just nonsensical. That, you 

know, silver would be, the concentration would be 

below the background level in the waste stream. 

I mean this, that just doesn't make sense. Or 

releasing silver ions into the water stream it's 

certainly going to be elevated. And I really am 

concerned about the state of that, you know. 

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And it's my, in my thinking this is 

not consistent with organic systems or organic 

management that we would be adding metal-based 

compounds to our management scheme. 

MR. CHAPMAN: So it's my understanding 

that that fate was from EPA and FDA's studies 

about background levels of contamination and not 

that you're releasing something in a lower level, 

lower than the background level that's already 

there. Do you have, like, studies or sources of 

information that you could refer to us about the 

background contaminations of silver to support? 

MR. MORTENSEN: Yeah, some has been 

exchanged through the course of all this 

discussion over the last month or two. I'd be 

happy to share it. 

But I mean, just on the face of it, 

for someone to say that we're going to be 

introducing a waste stream of water where the 

product that's being used contains silver, and 

that that waste stream won't have an elevated 

silver level, that just can't make sense to me. 

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MR. CHAPMAN: I don't think that's 

what's being said. 

MR. MORTENSEN: Well, that was said 

because I asked the speaker specifically on the 

phone when we had the public comments and he 

said, yes, it would be below the levels, the 

levels that the water was before the waste stream 

had been introduced. 

MR. CHAPMAN: So I think it, I think 

it depends on what -- how you're evaluating this 

at. If you're looking at water that did not 

contain silver being put into environmental water 

that's generally available out there versus water 

that had this material going to environmental 

places with some sort of silver background level, 

yes, it clearly is going to increase the amount 

of silver in the application potentially. 

MR. MORTENSEN: Yeah. 

MR. CHAPMAN: Because there's more 

silver on an absolute level going in there. 

However, if the concentration of that water going 

into the environmental water is at a lower 

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concentration level than what is already there, 

it would be diluting the environmental background 

levels. 

MR. MORTENSEN: If the waste stream 

going into the rest of the water body is? 

MR. CHAPMAN: Had less silver than --

MR. MORTENSEN: Has a lower 

concentration? 

MR. CHAPMAN: -- the silver that was 

already naturally present. 

MR. MORTENSEN: If that was the case, 

you would be current, Tom, and I just can't 

imagine that that's the case. 

MR. CHAPMAN: Okay, but that was the 

finding of the EPA and the FDA. So I'd be 

interested in seeing the scientific research that 

refuted that statement --

MR. MORTENSEN: Okay. 

MR. CHAPMAN: -- if you have it. 

MR. MORTENSEN: Does that make sense 

to you? I mean, we could -- I'll look for some 

data on that. But, I mean, I think we also have 

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to use some common sense here about introducing a 

waste stream that's high in concentration of 

something and into a surface body of water, into 

a septic tank that has a leach field with 

groundwater underlying it that we would think 

that the silver concentration would be lower 

after we introduced the waste stream that's high 

in silver. I just can't see how that could be. 

Unless we're at, like, you know, unless it's a 

very badly contaminated source of water or site. 

MR. CHAPMAN: Yeah. I mean there's, 

I think I can find a couple issues there. 

There's the issue around the waste streams and 

which applicable waste stream we're looking at. 

Are we looking at a septic system versus a 

municipal system? 

But the dilution issue is a question 

of math, it's not really a question of anything 

else. It's the math of the dilution levels and 

whether or not the effluent has a lower level of 

silver than the water it's being mixed into. 

MR. MORTENSEN: Yeah, I know it's 

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math. I just would say that it seems so 

improbable that I can't imagine that being the 

outcome. So I'll line it up. 

MS. DE LIMA: Emily. 

MS. OAKLEY: Just listening to you 

both, I mean I think there are two issues here 

with this use: one when it's used in the place 

where the water will divert to a municipal 

setting versus in cases where it will divert on 

farm, in ponds, in septic systems. 

And so I think we should analyze this 

material based on the knowledge that there will 

be times in which it is filtered through a 

municipal system, and times in which it will not 

be. 

MR. CHAPMAN: Definitely. I agree. 

MS. DE LIMA: Asa. 

MR. BRADMAN: I just want to say I 

thought that Steve's questioning yesterday and 

the concerns that you raised about the septic 

systems and on your own farm were really kind of 

revealing to me. And I know that it helped kind 

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of guide my thinking about this material. 

MR. CHAPMAN: And if I could just 

note, that, that was a discussion -- Steve's on 

the subcommittee with us -- this was new news 

that we received at this meeting, which is why we 

feel it needs to go back to the subcommittee -- I 

feel it needs to go back to the subcommittee for 

further review because that was not an area that 

we had considered when we were looking at this. 

And it wasn't until we received the public 

comment, the wonderful public comment from the 

Organic Wholesalers Produce Group -- I just 

butchered their name -- about concerns on this 

substance. 

MS. DE LIMA: Emily. 

MS. OAKLEY: Is it time to make a 

motion to send it back to subcommittee? 

MR. CHAPMAN: Yeah, probably. 

Okay. So, I will, as the lead on this 

material, take the lead on making a motion to 

refer back to the handling subcommittee for 

further review of the petition on silver 

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dihydrogen citrate. 

MS. BEHAR: I'll second. 

MR. CHAPMAN: And I have a second from 

Harriet. So I have a motion and a second. And 

we will lead to voting. The voting will start 

with Steve. 

A yes vote is to refer back to the 

subcommittee. A no vote is to fail. And this 

only requires a simple majority. 

Steve. 

MR. ELA: Yes. 

DR. TUCKER: Yes. 

DR. GREENWOOD: Yes. 

MR. SCHWARTZ: Yes. 

MS. ROMERO-BRIONES: Yes. 

MS. DE LIMA: Yes. 

MR. BRADMAN: Yes. 

MR. MORTENSEN: Yes. 

DR. SEITZ: Yes. 

MS. BEHAR: Yes. 

MR. RICH: Yes. 

MS. SWAFFAR: Yes. 

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MR. BUIE: Yes. 

MS. BAIRD: Yes. 

MS. OAKLEY: Yes. 

DR. MATHEWS: Yes. 

MR. PATTILLO: Yes. 

MR. CHAPMAN: Chair votes yes. 

MR. RICH: It's 15 yes, 0 noes, 0 

absent. 

MR. CHAPMAN: The motion passes. This 

is referred back to the Handling Subcommittee. 

Lisa. 

MS. DE LIMA: Next up is japones 

peppers. A-dae. 

MS. ROMERO-BRIONES: So japones 

peppers is a small pointed chile, very small, 2 

inches. It's a similar appearance to de arbol. 

It was petitioned by a producer of 

chile hot sauce. There were several -- this had 

been on our docket for quite a while because we, 

we were going back and forth with the petitioner 

with several questions about alternatives to the 

japones pepper. 

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A TR was not requested for this 

because this was --- the real, the only question 

that was really left to be answered was whether 

there was an organic supplier of japones peppers. 

The petitioner said that there wasn't enough 

organic quantity to fulfill their need. And 

there wasn't a suitable alternative because of 

the units that make this pepper hot. 

We had several commenters comment and 

really focus on the 606 category because really 

the question is about supply. And so the TR 

doesn't answer that so we're kind of back to our 

devices to figure out whether this can be 

supplied organically. 

Several board members did mention that 

there is a possibility that organic suppliers can 

be contracted to grow this pepper. All 

commenters suggested not listing it. 

MS. DE LIMA: Discussion, starting 

with Emily. 

MS. OAKLEY: Yes. I'm one of those 

board members that thought this is definitely 

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something that can be grown domestically. 

And to Tom's point as to whether or 

not it can be processed in the way that's needed, 

I mean there are USDA value added producer grants 

that people can apply for. I know that may not 

satisfy the situation, but I feel that the 

threshold for a product like this, especially on 

that is so easily grown domestically, should be 

very high. 

And I think that this is a unique 

category. I understand many of the products that 

are on 606, especially from historical reference, 

but I think adding materials especially in such a 

particular use needs a lot of scrutiny. 

I have more thoughts but I'll share 

them after others do. 

MS. DE LIMA: Tom. 

MR. CHAPMAN: Yes. On this one, I 

mean, I don't think the petitioner did the due 

diligence for me to support the listing of this 

material. I have seen some other items in 

response to our sunset petitions that show the 

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due diligence to prove to me that a product 

cannot be sourced organically. 

I do, I guess, want to emphasize, 

though, that sourcing small agricultural products 

is a lot more complex than finding a farmer or 

finding a farmer who's willing to get a small 

producer grant, I mean just to get qualified to 

produce a safe food product. 

You know, you'd need to get GFSI 

certified. You'd need to get compliant with 

FSMA. You would need to be able to 

scientifically back up that you can make a ready 

to eat statement on that. You would need a PCQI 

on site. You'd need a HACCP plan for critical 

control points. You'd need a foreign material 

program, potentially a five log, a validated five 

log production program. And all those things 

cost money and are hard to get. 

On top of all that you'd need to be 

able to work with someone who's out there, a 

small producer who is trying to get their product 

out in the marketplace and sell it and will not 

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know the quantity of product they need. 

So, I have a question whether that 

small farmer would be willing to produce 5,000 

pounds when they would potentially only be able 

to sell 5 pounds, depending on the market demand 

for this material. And if that wasn't there, 

then the manufacturer of this wouldn't be able to 

go out and sell it. And so there's this chicken 

and egg when you start launching new products. 

So, is this available in organic and 

is there a market for the product I'm trying to 

put it in? 

So, 606 is valuable and there's a lot 

of use for it but there is also a burden of proof 

to show that you need to go through those steps. 

And I wasn't fully satisfied with them going 

through those steps. There is a lot of 

processors of pepper products out there, some 

organic, and I would have liked to have seen this 

petitioner, you know, getting letters from those 

folks saying this was not available. Rather I 

saw stuff like an Amazon search. 

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And I understand that that's, you 

know, I'm looking for maybe a sophisticated level 

of sourcing. It is what I do for a living. But 

I just wasn't satisfied with the amount of 

sourcing that happened here to try to find an 

organic version of this, so I won't be supporting 

this. 

MS. DE LIMA: Emily. 

MS. OAKLEY: Yeah, I want to say that 

I went back and looked at all of the posted NOP 

materials about this material and thought that 

the search for Amazon is not sufficient. I don't 

think that this petition is adequate. And I 

think if you go back and look at it that, again, 

the threshold for these materials should be high. 

I think something like locust bean gum is used by 

many people. 

And I'm not saying that this material 

wouldn't be used by many people if it were added, 

but the USDA seal is a very important seal. And 

we also have to protect it. And that means doing 

due diligence when something is added. They can 

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live with the need, with organic category until 

they do more diligence to show that this really 

isn't possible. 

MS. DE LIMA: Ashley and then Scott. 

MS. SWAFFAR: Just want to thank Tom 

for a thorough explanation of why a whole lot of 

people in this room have a job with food safety. 

But I do have a question. 

Did the petitioners say how many 

pounds of processed product that they actually 

would be needing? Or was it that incomplete? 

MS. ROMERO-BRIONES: So I want to say 

no, they didn't give us an exact quantity. I 

think their references say things like there's 

not sufficient quantity. And when we asked more 

specific questions, the petitioner responded with 

simple one-sentence answers in the letters. 

MS. DE LIMA: Scott. 

MR. RICH: Yeah. I appreciated Tom's 

detail there to help everybody understand. And 

just to reiterate, we gave the petitioner an 

opportunity to come back to us with some of the 

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questions that we had. And it was very 

unenthusiastic and not -- didn't, didn't appear 

that there was a whole lot of effort. 

And then we did not hear from them in 

the public comment process. 

MS. DE LIMA: Dan. 

DR. SEITZ: My comment's just a little 

more general. Given the change in how we handle 

sunsets now, I think there should always be a 

high threshold for approving a new substance just 

because it's that much harder to remove the 

substance in a subsequent vote. 

MS. DE LIMA: I just want to add that 

I voted in favor of adding it but I'm going to 

change that vote to a no. And after going 

through public comment and seeing what some other 

petitioners of 606 items came forward with, but 

yeah, this is insufficient on their part. 

All right, Tom. 

MR. CHAPMAN: All right. So this time 

we do have the two motions. So the first motion 

is just the classification motion. It's a motion 

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to classify japones peppers as agricultural. The 

motion was made by Lisa and seconded by A-dae. 

A yes vote is to declare this material 

agricultural. A no vote is to make it something 

else. The voting will start with Asa. 

MR. BRADMAN: Yes, it is agricultural. 

DR. GREENWOOD: Yes. 

MS. DE LIMA: Yes. 

MR. SCHWARTZ: Yes. 

MS. ROMERO-BRIONES: Yes. 

MS. OAKLEY: Yes. 

MS. BAIRD: Yes. 

MR. BUIE: Yes. 

MS. SWAFFAR: Yes. 

MR. RICH: Yes. 

MS. BEHAR: Yes. 

DR. SEITZ: Yes. 

MR. MORTENSEN: Yes. 

MR. ELA: Yes. 

MR. CHAPMAN: Chair votes yes. That's 

15 yes, 0 no, 0 absent. 

All right. The next motion is a 

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listing motion. This is a motion to add japones 

peppers to 205.606. The motion was made by Lisa 

and seconded by Steve. 

A yes vote is to recommend this 

material for listing. A no vote is to not 

recommend this material for listing. The voting 

will start with Rick. 

DR. GREENWOOD: No. 

MS. DE LIMA: No. 

MR. SCHWARTZ: No. 

MS. ROMERO-BRIONES: No. 

MS. OAKLEY: No. 

MS. BAIRD: No. I actually do grow 

these. They're pretty cool to grow. 

MR. BUIE: No. 

MS. SWAFFAR: No. 

MR. RICH: No. 

MS. BEHAR: No. 

DR. SEITZ: No. 

MR. MORTENSEN: No. 

MR. ELA: No. 

MR. BRADMAN: No. 

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MR. CHAPMAN: Chair votes no. 

MR. RICH: That's fif -- excuse me, 0 

yes, 15 no, 0 absent. 

MR. CHAPMAN: Motion fails. 

Lisa. 

MS. DE LIMA: Next up, Ethiopian 

peppers. A-dae. 

MS. ROMERO-BRIONES: So this was 

petitioned by the same petitioner of japones 

peppers. The conversations were very similar. 

Ethiopian pepper differs from japones 

peppers because it is grown on a tree. So it's 

much harder to contract for those because it's a 

tree; it takes longer to grow. 

So, the tree grows in zones in Africa. 

We had several commenters suggest not listing 

this. And they honed in on the same issues that 

we discussed in the subcommittee, which is one of 

the statements made in the petition was that it 

was by nature de facto organic. And through that 

statement some of the subcommittee were 

questioning why it's not certified organic or 

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petitioned to be certified organic under the wild 

crop standard. 

When posed to, when this question was 

posed to the petitioner, the petition responded. 

The petitioner again just reiterated that it's de 

facto organic. So the subcommittee discussion 

around that issue was whether they understood 

what that meant. 

Or and then one commenter did actually 

say that the Handling Subcommittee should 

identify the methods by which it was grown. 

And so part of the discussion whether 

that was the Handling Subcommittee's 

responsibility or the petitioner's. 

MS. DE LIMA: Emily. 

MS. OAKLEY: I share a lot of the 

comments that I said earlier. Although I note 

that this is a very different product. And what 

that means to organic farming was actually 

international agriculture. And I still do that 

in my off season. 

And this is a very different type of 

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pepper and it's not something I could grow. And 

I understand that it is difficult to work with 

smaller scale producers to get things wild crop 

certified in terms of costs and organization of 

farmer groups. Nevertheless, I don't see that 

they need any efforts to do that, or contact 

anyone about doing that, or finding out if there 

was a supply to that regard. 

So I would like to see them go through 

that due diligence for this product as well. 

MS. DE LIMA: Tom. 

MR. CHAPMAN: Yeah, I mean I had 

similar concerns on this petition like I did on 

the last one. I think it would be a lower bar to 

prove that this was not available. But then 

again I still don't think that that occurred. 

And so without that being present in the petition 

and public comment I'm not convinced that this is 

an item we should list. 

I'm also not particularly a fan of 

hearing that it's de facto organic. I like 

living in the U.S. where we have the term 

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definitely rigorously defined and enforced under 

the National Organic Program. And I also like 

living in the state of California where when I 

used to go the farmer's market and someone who 

wasn't certified organic would tell me, Eh, it's 

basically the same thing but now I can put a CDFA 

agent on them, because that is not the case in my 

opinion. 

So absent that and the due diligence 

to truly prove that this item is not available in 

an organic form, I can't support it at this time. 

MS. DE LIMA: Steve. 

MR. ELA: I tend to agree with that. 

I guess to add things to the list I think it's 

more than submitting a petition and giving one 

word answers. I mean, public comment, I mean, 

the petition should comment. They should, you 

know, probably not necessarily appear, but this 

was pretty poorly supported. And it's pretty 

clearly for one product at this point. 

And I'm just hesitant. I mean, we 

don't certify products but we're, you know, we're 

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being asked to certify a pepper for a product 

versus a water use. So it, I mean, even though 

the criteria are the same, and if the petitioner 

had really come in and stated that said they 

could wild craft it, or this was critical to 

their business, or anything, I mean, I think 

there are alternatives. And made with organic is 

one. Another -- it's just hard to say it's 

essential. 

MS. DE LIMA: Tom. 

MR. CHAPMAN: I'm going to vote this 

down. I guess I will say, you know, there are 

small processors out there like there are small 

farmers that have various levels of 

sophistication. And, you know, I'm making an 

assumption from the responses and the 

communication we got from these people and the 

fact that I haven't seen a wide distribution of 

their products around that they're probably a 

fairly small producer that's focusing on just 

getting market share and potentially trying to 

make a product that might have some cultural or 

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ethnic significance to them or, you know, a 

passed down recipe to differentiate themselves. 

And there's a minimum bar and I don't 

think we -- we did not hit that here. 

MS. DE LIMA: Emily. And then we're 

going to wrap it up. 

MS. OAKLEY: I think that's a really 

important point, Tom, about the size of this 

producer. And I did consider that. But I agree 

with you, there is still a minimum bar, and that 

needs to be met. And it wasn't here, in my view. 

MS. DE LIMA: All right, we're going 

to move to a vote. 

MR. CHAPMAN: All right. So, we have 

two motions here again. A motion to classify. 

We have a second to the motion to classify 

Ethiopian peppers as agricultural. 

The motion was made by Lisa and 

seconded by A-dae. A yes vote is to say -- is to 

declare this is agricultural. And a no vote is 

to make no declaration. The voting will start 

with Lisa. 

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 MS. DE LIMA: Yes. 

MR. SCHWARTZ: Yes. 

MS. ROMERO-BRIONES: Yes. 

MS. OAKLEY: Yes. 

MS. BAIRD: Yes. 

MR. BUIE: Yes. 

MS. SWAFFAR: Yes. 

MR. RICH: Yes. 

MS. BEHAR: Yes. 

DR. SEITZ: Yes. 

MR. MORTENSEN: Yes. 

MR. ELA: Yes. 

MR. BRADMAN: Yes. 

DR. GREENWOOD: Yes. 

MR. CHAPMAN: Chair votes yes. 

MR. RICH: That's 15 yes, 0 no, 0 

absents. 

MR. CHAPMAN: The motion passes. 

The next motion is to add Ethiopian 

peppers to 205.606. The motion was made by Lisa 

and seconded by A-dae. 

A yes vote is to recommend this item 

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be listed. A no vote is to not make that 

recommendation. And the voting will start with 

Eric. 

MR. SCHWARTZ: No. 

MS. ROMERO-BRIONES: No. 

MS. OAKLEY: No. 

MS. BAIRD: No. 

MR. BUIE: No. 

MS. SWAFFAR: No. 

MR. RICH: No. 

MS. BEHAR: No. 

DR. SEITZ: No. 

MR. MORTENSEN: No. 

MR. ELA: No. 

MR. BRADMAN: No. 

DR. GREENWOOD: No. 

MS. DE LIMA: No. 

MR. CHAPMAN: Chair votes no. 

MR. RICH: That's 0 yes, 15 no, 0 

absent. 

MR. CHAPMAN: The motion fails. 

Lisa. 

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MS. DE LIMA: Next up, tamarind seed 

gum. Steve. 

MR. ELA: I'm going to be an expert in 

gums by the end of this whether I want to be or 

not. 

But tamarind seed gum is being 

petitioned as a non-organic agricultural 

ingredient allowed in processed products labeled 

as organic. It's a water soluble, high molecular 

weight polysaccharide. And the petition claims 

it has uses beyond what our current slate of gums 

has. 

One thing they say is that tamarind 

seed gum imparts a viscosity similar to that of 

starch, but it's viscosity does not deteriorate 

in the presence of acids, bases, salts, and heat 

like starch does. 

And while they note that other 

hydrocolloids may be used in products, they have 

different textures and mouth feels, very similar 

to what we heard about all the other gums, as 

each one has a special, special use. 

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Included in the write-up on it is a 

chart showing the comparisons between the various 

gums. And while we can't project that, it is in 

the meeting materials. 

One of the claims in terms of organic 

supply is that they said they have checked out 

various tamarind powder and the various tamarind 

fruit products but the tamarind seeds are not 

available in sufficient supply to then go through 

the processing process to make the tamarind seed 

gum. 

And they also note that many of the 

tamarind trees are wild, kind of similar to the 

previous petition, but there's not a sufficient 

system in place to certify those. 

So I think in this petition it really 

comes down to the question of is this a unique 

gum? Does it give properties to the National 

List that other gums do not? 

And then, also, in terms of the supply 

chain, the petitioner is basically just saying 

that small farmers collect the seeds, and the 

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preparation from the seed is completed in one 

location. But their research for this petition 

through the Organic Agricultural Certification 

Program in Thailand they were unable to find 

organic certified tamarind seeds. 

And on the NOP organic integrity 

database there is no source of organic tamarind 

seed gum or tamarind kernel powder. And so it 

does become a supply chain issue potentially for 

this. 

Conversely, we received public 

comments from other stakeholders, including, 

well, various stakeholders that is similar to 

these other things, that the hours spent 

submitting a petition and years spent for the 

petition to go through and potentially go through 

rulemaking, they could be spending that same 

amount of time and effort in developing an 

organic supply chain. 

So those are kind of the two sides of 

the coin. I'll leave it at that and open it up 

for discussion. 

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MS. DE LIMA: Emily. 

MS. OAKLEY: Thailand has a 

comparatively robust organic farming community. 

Farmers of various different sizes, including 

some of the smaller producers that we were 

referring to in the previous material that very 

conceivably could be engaged and allow costing of 

this product. And I'm not convinced even by 

their webinar testimony that they went to 

sufficient means to determine the feasibility of 

that. 

But if others have other thoughts I'd 

like to hear them. 

MS. DE LIMA: Tom. 

MR. CHAPMAN: I don't have a thought 

on that one off the top of my head. 

I did want to comment on the comment 

made about they could invest their time in 

developing an organic supply chain because that 

would take less time than petitioning the 

material. I would say those comments probably 

came from someone who doesn't do this for a 

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living. 

I can speak personally that it took 

myself at a previous company more than five years 

to source a simple Arabic dried black lime 

organically, single ingredient from small 

producers in a small quantity, to get that 

through, to get someone to make that product, to 

get it certified, to get it processed in an 

appropriate way, and then to bring it to market 

here in the U.S. 

And that was just for my own usage. 

That's before I tried to market it into other 

processed products. And I was so tired by them I 

quit that company and went to go to work for Clif 

Bar. So that statement is entirely overly 

simplistic for the difficulty in managing a 

supply chain as complex as the one described by 

the petition on this one. 

MS. DE LIMA: Steve. 

MR. ELA: You know, I try and read, 

you know, through all this and understand it. 

But it also sounds like a case I'm going to say 

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similar to casings where there's sourcing from a 

number of small suppliers, it's pretty 

distributed. By the time you start accumulating 

things and then processing it, you know, the 

minimum quantities are a little difficult to 

amass. 

I see this as potentially one where we 

put it on 606 and it encourages, again, if 

organic production is available they have to use 

it. So it gives another natural gum, even though 

it -- well, it's non-synthetic, puts something 

else on the list that then creates a market for 

it and then hopefully helps create a demand for 

an organic supply chain. 

We know there's organic tamarind pulp 

available so, you know, maybe, I tend to agree 

with Tom, I think those are very complex issues 

but maybe this is actually encouraging another 

natural gum supply. 

MS. DE LIMA: Tom. 

MR. CHAPMAN: I mean, at some level 

this gum is an alternative to some of the more 

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processed non-agricultural gums, like, gel and 

xanthan, clearly from a non-GMO source for folks 

who had those concerns. This would potentially 

create an alternative if formulators wanted to 

put the effort into the products. 

We also heard from a retailer speaking 

about supposedly the consumer reaction or lack of 

preference for a xanthan gum. Again, this would 

present a different alternative for those 

consumers if manufacturers were able to formulate 

products with it. 

MS. DE LIMA: Emily. 

MS. OAKLEY: I hear all of those 

points but I just really want to stress that the 

petitioner said that this comes from wild crafted 

tamarind in Thailand. And I really can't stress 

enough that there is a robust, a very 

comparatively robust organic farmer community in 

Thailand of different sizes. And so I really 

want to them first reach out in a more explicit 

way to the certifiers in Thailand and certified 

organic farm groups to see if there is a 

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possibility. Because it would just augment an 

already burgeoning organic farming community and 

supply chain in Thailand. 

I'm not going to say I'm an expert on 

this because I'm not, but I still will not be 

voting to list this material until I would see 

more evidence that it wasn't going to be possible 

to certify it wild craft organic in Thailand more 

robustly. 

MS. DE LIMA: Ashley and then Harriet. 

MS. SWAFFAR: So, back to my earlier 

comment before about 606 materials. You know, if 

these guys get certified then they have to use 

them as a supplier, and their quantities are 

sufficient. So, you know, and that's why look 

out on 606 materials, maybe the market's not 

there right now for an organic supply, but it 

could in a few years, and then they have to buy 

organic. 

So that on 606 materials I kind of 

lean that way on that. That's why I'll be voting 

to list. 

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MS. DE LIMA: Harriet. 

MS. BEHAR: So, we did have someone 

speak to this on the webinar. And I asked about, 

you know, how they were working at it. And they 

first said, well, we can't find tamarind seed in 

Thailand. And then I went on the integrity 

database, so I found tamarind seeds in Thailand. 

And he is getting now conventional 

tamarind seed from Thailand and somehow making it 

into a gum. I don't know in what country he's 

making it into a gum. But I think that if you 

could get organic tamarind seed in Thailand and -

- or non-organic and make it into a gum, had 

there is organic tamarind seed available in 

Thailand, there's not extra, perhaps it's too 

small an amount that he needs to justify an 

organic grown, I don't know. 

All of the -- you know, or maybe it 

doesn't keep very long so you can't make it. But 

that was not clear to me in the petition. But it 

just seems that they're so close that there is 

organic tamarind seed in Thailand. They're 

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making the conventional tamarind seed gum from a 

Thai source. And so it seems that putting it on 

606, right now if they want to use tamarind seed 

gum they have to get it organically. 

So I think it's a matter of do we want 

to encourage them more strongly and not put it on 

the list? Or put it on the list and do more of a 

nudge rather than a push? 

MS. DE LIMA: Sue. 

MS. BAIRD: I think I echo Ashley's. 

If there is organic and if it's on 606, they must 

obtain it. They have to do their due diligence. 

I've seen -- and I hear what you're 

saying, Harriet -- I've seen sometimes perhaps 

the opposite. If there's organic and if -- and 

their neighbors see it, wow, they're getting $20 

more per pound for organic than I'm getting from 

my conventional, sometimes that's a push for them 

to go organic. 

So, sometimes having it available and 

being able to put it on their not available in 

sufficient quantity now, but they see that 

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they're getting, their neighbors are getting good 

premiums, it pushes them, more people, to go 

organic. 

MS. DE LIMA: Tom. 

MR. CHAPMAN: Just for the sake of 

time, unless further debate is going to change 

someone's opinion or someone's un-made up and 

would want for the debate, I'm hoping we can wrap 

this up shortly. 

MR. BRADMAN: I just have one question 

for Harriet. 

In the letter from the petition they 

said that they were unable to find organic 

certified seed, no source of organic tamarind 

seed or organic tamarind kernel powder on the NOP 

Organic Integrity Database. Sounds like you 

found otherwise? 

MS. BEHAR: I did not actually try to 

buy it. But it was on the database. So perhaps 

that's an old listing or I don't know. I did not 

contact the manufacturer and say -- not tamarind 

seed gum but just tamarind seed. 

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entries for tamarind on the Organic Integrity 

Database for the country of Thailand. They also 

have what I would look at hundreds of other crops 

on their certificate. So it's really hard to 

quantify if they're truly a -- when I see that 

when I'm sourcing stuff, it generally means it's 

a smaller producer or background producer, but it 

could also be a grow group. So it's a little 

hard to quantify. 

I do want to note back, though, to the 

comments made by the petitioner on the phone that 

there's different applications for types of 

tamarind and that they're not looking for the 

entire tamarind product, the pulp, which is a 

common food ingredient. They're looking for the 

seeds, to make the seeds, the gum out of. And 

they also need a specific variety of tamarind 

that has white seeds. And none of that detail at 

all is apparent in the Organic Integrity 

Database. 

MR. ELA: Yeah, and I was going to say 

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the same thing. I think when you read the actual 

petition, and I didn't put it in the full writeup because it gets down in the weeds but, yeah, 

there were dark kernels and white kernels. And 

they're buying them at farmers' markets and 

accumulating. 

So I think there are some -- it's not 

quite as easy as just backing up the truck to the 

processing plant and loading all the seeds in it. 

So I did want to give them -- they did explain 

that fairly clearly in the petition and I, I 

mean, I think we can argue over due diligence, 

but at least compared to previous petitions this 

one felt like they actually did go through in 

fairly good detail and they did respond to our 

questions. 

MS. DE LIMA: All right. We're going 

to move to a vote. 

MR. CHAPMAN: Okay. So we have two 

motions again, a classification motion and then a 

listing motion. 

The first one is to classify tamarind 

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seed gum as agricultural non-synthetic. The 

motion was made by Steve and seconded by Lisa. 

And in the voting a yes vote is to 

classify as agricultural. A no vote's to not 

classify. And the voting will start with A-dae. 

MS. ROMERO-BRIONES: Yes. 

MS. OAKLEY: Yes. 

MS. BAIRD: Yes. 

MR. BUIE: Yes. 

MS. SWAFFAR: Yes. 

MR. RICH: Yes. 

MS. BEHAR: Yes. 

DR. SEITZ: Yes. 

MR. MORTENSEN: Yes. 

MR. ELA: Yes. 

MR. BRADMAN: Yes. 

DR. GREENWOOD: Yes. 

MS. DE LIMA: Yes. 

MR. SCHWARTZ: Yes. 

MR. CHAPMAN: Chair votes yes. 

MR. RICH: That's 15 yes, 0 no, 0 

absent. 

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 MR. CHAPMAN: The motion passes. 

The next motion is to recommend the 

addition of tamarind seed gum, limited to nonacid hydrolysis forms, at 205.606. 

The motion was made by Steve and 

seconded by Lisa. A yes vote is to recommend 

this listing. A no vote is to not recommend 

listing. And the voting will start with Emily. 

MS. OAKLEY: No. 

MS. BAIRD: Yes. 

MR. BUIE: Yes. 

MS. SWAFFAR: Yes. 

MR. RICH: Yes. 

MS. BEHAR: Yes, with a nudge. 

DR. SEITZ: No. 

MR. MORTENSEN: No. 

MR. ELA: Yes. 

MR. BRADMAN: Yes. 

DR. GREENWOOD: Yes. 

MS. DE LIMA: Yes. 

MR. SCHWARTZ: Yes. 

MS. ROMERO-BRIONES: No. 

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MR. CHAPMAN: Chair votes yes. 

MR. RICH: Eleven and 4 here. Excuse 

me. 11 yes and 4 no, 0 absent. 

MR. CHAPMAN: The motion passes. 

Lisa. 

MS. DE LIMA: Do we want to --

MR. CHAPMAN: No, we're going. 

MS. DE LIMA: You don't want to defer 

it to the end since it's not a -- it's a 

discussion document? 

MR. CHAPMAN: No. I just say we keep 

the discussion short. 

MS. DE LIMA: Okay. All right, so 

next, last item on the agenda is pullulan, 

pullulan. 

Let's see. So, this is a discussion 

document. We just got the TR back about a month 

ago so we didn't have time to bring this forward. 

We'll be bringing it forward at the spring 

meeting. So this is an opportunity to get 

additional -- to get a first round of public 

comment in and the board to get familiar with the 

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material. 

All right. So, this petition was 

submitted, and it was to add pullulan into the 

National List at 205.605(a) as an allowed 

agricultural non-synthetic ingredient for use in 

tablets and capsules for dietary supplements only 

allowed in the made with organic category. 

The petition was submitted by the OTA 

on behalf of its Nationalist Innovation Working 

Group. And they stated that the petition was 

twofold: 

One, it was to protect the continued 

production and availability of USDA NOP certified 

dietary supplements; and to continue to support 

the commercial development of organic pullulan. 

For dietary supplements the capsule is 

considered to be an ingredient, and must either 

be certified organic or made up of ingredients 

compliant with the NOP, with the National List. 

And since the early 2000s, certifying 

agents have been classifying pullulan as 

agricultural and allowing it in the dietary 

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supplements in the made with organic category. 

And then after the NOP's 

classification materials guidance came out in 

2016, there was a little bit of disagreement in 

the certifier world on whether pullulan should be 

classified as non-ag and a non-synthetic 

substance. So, under the classification of nonag and non-synthetic, pullulan would need to 

appear on the National List in order for it to be 

used in those dietary supplements in the made 

with organic category. 

Right now there are no other NOP 

compliant vegetarian options available for 

producing organic encapsulated supplements. 

Organic pullulan is currently not commercially 

available in the U.S. And according to the 

petition, the owner of the U.S. patents which 

cover the pullulan capsules are in the process of 

developing an organic pullulan. 

The only other alternative practice 

for supplement manufacturers would be to use 

gelatin capsules listed on 205.606, but this 

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would be problematic for those consumers looking 

for vegetarian product. 

The economic estimate is current 

manufacturers lost their organic certification 

because they wanted to continue to use pullulan 

was estimated at 825 million. 

So, like I said, we have got a TR. We 

just didn't deem it sufficient and will be 

bringing forward our proposal in the spring. 

With that -- oh, I will add we got a 

fair amount of public comment in favor of listing 

pullulan. And that came from manufacturers, as 

well as some certifiers. 

So, with that I want to open it up for 

a brief discussion from the board if folks have 

questions, comments. 

MR. CHAPMAN: I would just like to 

thank folks for the public comment. It's meant 

to help streamline these petition discussion 

documents, help streamline these processes. And 

if we had this for some of the petitions we had 

today I think we would have been probably in a 

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better spot to vote on them. So, thank you for 

helping us with the information earlier on in the 

process. 

MS. DE LIMA: Steve. 

MR. ELA: I would echo that. I think 

this discussion makes it much easier for the 

subcommittee then to go back and discuss it. And 

I also think that on controversial materials it 

gives a heads-up to the petition of what issues 

they might need to address before the 

subcommittee goes to a vote, which would make 

something like silver maybe hopefully clearer. 

So I think it's a good process. 

Thanks, Lisa. 

MS. DE LIMA: All right. I think that 

concludes the Handling Subcommittee. 

MR. CHAPMAN: Collagen? Collagen? 

MS. DE LIMA: Oh no, there's one more. 

(Laughter.) 

MR. CHAPMAN: Slim Jims, organic Slim 

Jims. Come on. 

MS. DE LIMA: But it's not mine. So, 

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Asa, collagen gel. 

MR. BRADMAN: This is a similar 

discussion document as the previous one to get 

the questions out there in the community. 

Collagen gel, I think it's a pretty interesting 

case here, is basically a material that's 

extracted from animal skins to produce a 

coextruded coating for sausage production. It 

seems like it's primarily for the fully cooked 

sausages. 

To kind of summarize some of the 

comments related to it from the manufacturer and 

one contract producer, there is a lot of, you 

know, clearly favorable support. Some of the 

benefits considered was that it provides more 

opportunity for single species sausages, so you 

don't have the use of mixed species, in 

particular hard casings being used on other 

sausage projects -- products. 

And according to their market, their 

understanding of the market, there's definitely 

some preference to avoid, to have less -- to have 

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more choice in that matter, particularly for 

chicken sausage, and materials that people don't 

want non-bird sources of sausage. 

You know, I think the issue with this 

material is that it's like the casings which 

we've already approved, it would be coming from 

animals that were not raised organically. And 

just to quote one comment from, I think this was 

from Alan Lewis, "this is one of the most 

dangerous petitions I can imagine for the 

integrity of the National Organic Program and the 

survival of organic livestock producers," kind of 

reflecting that concern about the use of nonorganic livestock as the source. 

And according to the petitioners there 

are not -- the scale of the market is such that 

there's not available organic source material to 

produce the coextruded collagen gels. 

In terms of materials that are already 

on the National List where there's some 

similarities, of course there's the casings that 

we've approved in the last year. And then also 

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gelatin, which is essentially a similar material. 

Chemically it's almost identical. But it's 

perhaps a little more processed than the collagen 

gel itself. 

I think that's kind of an 

introduction, overview of the issues. I don't 

know if you want to have any discussion or bring 

that forward in another study. 

MS. DE LIMA: Tom. 

MR. CHAPMAN: I mean, it seems to me 

that this material suffers from the same supply 

chain constraints that other similar materials 

suffer from. 

MS. DE LIMA: All right. I mean, I 

will add since there was that retailer comment, I 

don't share that view. I don't -- there's not a 

lot of certified organic meat products on the 

market. I mean, it's growing. It's grown over 

the last 20 years. But I don't see this being 

very different than the casings that are already 

on the market. And to me this just expands the 

consumer base for buying certified organic meat 

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products, which I would like to see more of, you 

know. 

MR. CHAPMAN: Yeah. And I guess, I 

don't know, the more you can build a market for 

that finished organic product, the more meat 

products that goes through those processing 

plants, and the higher likelihood you're going to 

be able to generate enough business to make an 

economic model to then turn these byproducts into 

value add organic products. 

MS. DE LIMA: All right. I think 

we're done. 

MR. CHAPMAN: All right. Thank you, 

Lisa, for that. I think we're just going to keep 

going. And I'm going to cancel -- No, I'm 

joking. 

(Laughter.) 

MR. CHAPMAN: We're going to take 

lunch and see how we get progressively more 

aggressive as we get more and more "hangry." 

All right. It's 1:15, 1:20 by my 

clock, but we're still coming back at 2:15. So 

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55 minutes for lunch. We'll start off with the 

Crop Subcommittee. 

Board members, don't run away, we're 

going to take a photo and then you can go get 

lunch. So, quickly, quickly take a photo. 

Quickly gather by the USDA logo. 

We're in recess until 2:15. 

(Whereupon, the above-entitled matter 

went off the record at 1:20 p.m. and resumed at 

2:15 p.m.) 

 MR. CHAPMAN: Okay, we're going to 

come to order. It looks like all Board members 

are present and we'll be moving into the crops 

section of the agenda and I'll hand the meeting 

over to the Crops Chair, Steve. 

MR. ELA: All right, we're about a 

half hour behind, so I'm going to encourage the 

Crops Committee when we present sunsets, just 

like we did before, you know, the materials were 

in the book, so present the controversial side of 

it or things that came up in public comment that 

were new so we can -- and I'll try and keep 

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things fairly tight so we can stay on schedule or 

gain a little time back since I'm one of the ones 

that has to leave tonight. 

So, we'll start with sunsets and the 

first on, Clarissa, we'll start with alcohols. 

DR. MATHEWS: Section 205.601 

Synthetic Substances Allowed for Use in Organic 

Crop Production. 

Paragraph A, as algaecide 

disinfectants and sanitizer including irrigation 

system cleaning systems, alcohols, the listing is 

ethanol. 

MR. ELA: Jesse? 

MR. BUIE: The NOP has allowed ethanol 

in organic crop production for over 20 years. 

Public comments were largely in favor of 

relisting ethanol because the material is a good 

example where there are several sanitizers and 

disinfectants listed for organic use in rotation 

to reduce disease resistance. 

The public comments were 

overwhelmingly for relisting. 

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 Are there any questions? 

MR. ELA: Discussion? 

Tom? 

MR. CHAPMAN: Yikes. Okay, so we have 

a motion to remove ethanol from the national 

list. This is a sunset item, so just remember a 

no vote is to retain the listing, a yes vote is 

to remove it. 

The motion was made by Jesse and 

seconded by Harriet. 

And the voting will start with Sue. 

MS. BAIRD: No. 

MR. BUIE: No. 

MS. SWAFFAR: No. 

MR. RICE: No. 

MS. BEHAR: No. 

DR. SEITZ: No. 

MR. MORTENSEN: No. 

MR. ELA: No. 

MR. BRADMAN: No. 

DR. GREENWOOD: No. 

MR. SCHWARTZ: No. 

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MS. ROMERO-BRIONES: No. 

MR. CHAPMAN: Chair votes no. 

MR. RICE: That's zero yes, 15 no's, 

zero absent. 

MR. CHAPMAN: Motion fails. 

Steve? 

MR. ELA: Sorry, alcohols? 

DR. MATHEWS: At Section 

205.601(a)(1), the listing is isopropanol. 

MR. BUIE: The NOP has allowed 

isopropanol alcohol use in crops for over 20 

years. The new -- there was no new scientific or 

significant information was presented to warrant 

removal of the material. 

Again, public comments were 

overwhelmingly in favor of relisting isopropanol. 

Are there any questions? 

MR. ELA: Tom? 

MR. CHAPMAN: We have a motion to 

remove isopropanol from the national list. 

The motion is made by Jesse and 

seconded by Emily. 

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 A yes vote is to remove, a no vote is 

to retain and the voting will start with Jesse. 

MR. BUIE: No. 

MS. SWAFFAR: No. 

MR. RICE: No. 

MS. BEHAR: No. 

DR. SEITZ: No. 

MR. MORTENSEN: No. 

MR. ELA: No. 

MR. BRADMAN: No. 

DR. GREENWOOD: No. 

MS. DE LIMA: No. 

MR. SCHWARTZ: No. 

MS. ROMERO-BRIONES: No. 

MS. OAKLEY: No. 

MS. BAIRD: No. 

MR. CHAPMAN: The Chair votes no. 

MR. RICE: That's zero yes, 15 no, 

zero absent. 

MR. CHAPMAN: Motion fails. 

Steve? 

MR. ELA: Okay, we'll move on to 

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sodium carbonate peroxyhydrate. 

DR. MATHEWS: At Section 

205.601(a)(8), sodium carbonate peroxyhydrate CAS 

Number 15630-89-4, federal law restricts the use 

of this substance in food crop production to 

approved food uses identified on the product 

label. 

MR. ELA: I actually don't know if 

Emily or Dave is doing this, it was split. 

MS. OAKLEY: It is actually me. 

MR. ELA: Okay. 

MS. OAKLEY: Yes. 

MR. ELA: Emily? 

MS. OAKLEY: So, this is used an 

algaecide in rice fields, ponds, ditches and 

irrigation lines. It was originally added to the 

national list in the hopes that it would be used 

as an alternative to copper sulfate in rice. 

It is highly toxic to bees which 

should be noted and was noted by a public 

commenter. 

And, we received some comments in the 

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spring in relation to this, but far fewer than we 

were hoping for. 

We received basically similar comments 

this time around as well in addition to one farm, 

Bolthouse Farms in California that grows carrots 

that uses it. 

I had additional conversations with 

CCOF via email about this because they are the 

certifier that has producers using this material. 

They have 49 people using it, of those, nine do 

grow rice. 

But, when they reached out to their 

members, only one person wrote back about using 

this in conjunction with copper sulfate. That 

doesn't mean that other people aren't doing it, 

that was just the response rate that they heard. 

I think the take-home message from 

this material is that, it was added in the hopes 

of replacing copper sulfate or at least 

minimizing some of its use. That probably has 

not happened to the extent that it was originally 

hoped for. 

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I underscore the value of farmer to 

farmer exchange, especially for the one producer 

that we know is using it and might be able to 

present that material and that innovation to 

other growers. 

We did have a split vote in the 

Subcommittee on this. I did vote to delist it at 

that time and so did Harriet, I believe. And so, 

I wanted to ask Harriet if you still felt that 

way or if I got that wrong, if it was someone 

else, sorry about that. 

MS. BEHAR: Well, I'm just kind of 

curious about the usage, how, you know, is it 

being used -- I don't have as much issue with 

allowing it, especially if it's not being in 

heavy use. 

You know, if it's being used in 

rotation with other things or whatever, I think 

maybe it's --

MS. OAKLEY: When it's used, I think 

it's predominantly used as an irrigation cleaner 

and as water treatment probably in ponds and 

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other ditches or other waterways. 

I think it isn't heavily used. I 

think it is a low toxicity chemical relatively 

speaking. Of course, as I noted, toxicity to 

bees. 

I am inclined to change my vote at 

this point. But, I also do think that it 

underscores the importance of recognizing the 

only added material with a certain intention that 

may not always be the case. That may not how be 

-- may not be how the material is adopted. 

And when it has a board classification 

as an algaecide, it's going to be used in other 

ways. 

That's my comment. Any comment or 

discussion? 

MR. ELA: Other discussion? 

MR. MORTENSEN: Yes, just quickly. 

With limited surface water, bees get their -- the 

water needs that they have from nectar and from 

pools of water. So, unfortunately, there's 

probably some degree of exposure here that will 

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happen. 

But, other than that, I have no 

comment. 

MR. ELA: Other discussion? 

I'll say that I was originally a 

little skeptical on renewing this one, hearing 

some of the public comment and that there are 

some uses for it. 

I'm more inclined to vote for it at 

this point. I guess that the case wasn't made 

that it should be taken off. I mean, I don't 

know if it was made to stay on, but in the 

absence of clear marker either way, it makes me 

lean towards leaving it on. Anybody else? 

Dave? 

MR. MORTENSEN: Yes, I was also struck 

by the comments we got on this and several other 

things that we did not have that information as 

recently as a month ago. 

So, we did hear a lot about this one, 

aqueous potassium silicate and others since we 

were voting on them. 

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MS. OAKLEY: Just in conclusion, I 

think an argument that Dave made in the 

Subcommittee should be repeated here that we 

don't want to remove a lower toxicity chemical, 

even if it isn't being used for that use right 

now. 

But, I do think we want to avidly 

encourage innovation and spreading of information 

where it might be being used. 

MR. ELA: Okay, anything else? 

Tom? 

MR. CHAPMAN: All right, we have a 

motion to remove sodium carbonate peroxyhydrate 

from the national list. 

The motion was made by Emily and 

seconded by Jesse. 

This is a yes vote will be to remove, 

a no vote to retain and the voting will start 

with Ashley. 

MS. SWAFFAR: No. 

MR. RICE: No. 

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MS. BEHAR: No. 

DR. SEITZ: No. 

MR. MORTENSEN: No. 

MR. ELA: No. 

MR. BRADMAN: No. 

DR. GREENWOOD: No. 

MS. DE LIMA: No. 

MR. SCHWARTZ: No. 

MS. ROMERO-BRIONES: No. 

MS. OAKLEY: No. 

MS. BAIRD: No. 

MR. BUIE: No. 

MR. CHAPMAN: The Chair votes no. 

MR. RICE: That's zero yes, 15 no, 

zero absent. 

MR. CHAPMAN: The motion fails. 

Steve? 

MR. ELA: All right, newspaper, 

Clarissa? 

DR. MATHEWS: This material appears at 

two listings within the national list, at 

205.601(b) Herbicides, Weed Barriers, as 

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applicable, Mulches. 

And then, also at 205.601(c) as 

compost feed stocks. 

And, the listing is newspaper or other 

recycled paper without glossy or colored inks. 

MR. ELA: Harriet? 

MS. BEHAR: So, we did get a new TR on 

newspaper and reviewed that in great depth. 

The public was universally in support, 

although except one organization. 

There was some discussion about using 

it in conjunction with plant-based materials. I 

know when I've used newspaper as a mulch, I put 

it underneath my straw or hay just to prevent 

that light from coming through. I believe that's 

what they're referring to. 

And, the one organization talked about 

that we should be encouraging more plant-based 

mulches. That's it. 

MS. ELA: Discussion? 

Emily? 

MS. OAKLEY: I do think it's worthy of 

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people to read the supplemental TR because it --

we were hoping that it would reveal fewer toxins 

in paper, but it actually reveals higher toxins 

in paper than probably were originally in the 

listing back in the day. 

And, the difficulty of removing glossy 

paper and ink paper from newspapers has also 

increased, but I don't think we can address them. 

I just want to reiterate that the 

level of exposure has probably increased, not 

decreased over time. 

MR. ELA: Other discussion? 

Tom? 

MR. CHAPMAN: So, we have a motion to 

remove newspaper and other recycled paper from 

the national list. 

The motion was made by Harriet and 

seconded by Asa. 

A yes vote is to retain, a no vote --

a yes vote is to remove, a no vote is to retain 

and the voting will start with Scott. 

MR. RICE: No. 

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MS. BEHAR: No. 

DR. SEITZ: No. 

MR. MORTENSEN: No. 

MR. ELA: No. 

MR. BRADMAN: No. 

DR. GREENWOOD: No. 

MS. DE LIMA: No. 

MR. SCHWARTZ: No. 

MS. ROMERO-BRIONES: No. 

MS. OAKLEY: No. 

MS. BAIRD: No. 

MR. BUIE: No. 

MS. SWAFFAR: No. 

MR. CHAPMAN: The Chair votes no. 

MR. RICE: That's zero yes, 15 no, 

zero absent. 

MR. CHAPMAN: The motion fails. 

MR. ELA: Plastic mulch and covers. 

Clarissa? 

DR. MATHEWS: At Section 205.601(b) as 

Herbicides, Weed Barriers, as applicable, 

Mulches. 

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The listing is plastic mulch and 

covers, petroleum based other than polyvinyl 

chloride (PVC). 

MR. ELA: Harriet? 

MS. BEHAR: Okay. So, there was 

pretty good support for this material discussing 

the way that it warms soil and controls weeds. 

And, many producers also wrote in and 

talked about that they could not farm or produce 

certain crops without it. 

There, in the discussion, we talked 

about burning of that plastic when it's removed 

from the soil, which is part of the annotation. 

And, one commenter stated that the 

annotation would be informative, but it is 

already covered by the Federal Clean Air Act and 

some state statutes. 

There was comment, too, by numerous 

certifiers and advocacy groups about wanting us 

to move forward with biodegradable, biobased 

mulch. But that does not really affect this 

listing. 

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And, there was one last comment, too, 

that we should be moving more towards plant-based 

mulches and away from petroleum. 

MR. ELA: Discussion? 

Emily? 

MS. OAKLEY: I was the abstention in 

the Subcommittee and I will be abstaining again 

because I'm a farmer representative. I could 

certainly not vote against this material, but I 

have reservations, great reservations about the 

widespread use and reliance on this both because 

of the waste output and the concern of growing 

with plastic touching your crops and soil. But, 

I understand its widespread use. 

MR. ELA: Yes, there is no doubt that 

there is heartburn over this issue and that we 

would all prefer alternatives. 

Other discussion? 

Harriet? 

MS BEHAR: And, I agree with Emily 

that there is actually a lot of concern at times 

of heavy rains that the water can't infiltrate if 

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you've got a whole field or say, many high 

tunnels in a row that there can be quite severe 

erosion from the water running off of plastic. 

But, it is an extremely useful 

production aid, as I said, for weed control and 

for warming soil and even for insect management 

when you use different colored mulches, silver 

and red and things like that. 

MR. ELA: Tom, do you have a comment? 

MR. CHAPMAN: Yes, I mean, I think we 

all know the alternative here is the 

biodegradable, biobased mulch. 

I notice in the public comment that 

there was a research project going on, I think a 

USDA funded research project that was at 

University of Tennessee about some other campuses 

including Washington State. 

And, I notice we're traveling to the 

State of Washington, so I don't know if there's 

an opportunity there to potentially get some 

update on that research and their, you know, 

early findings if they'd be willing to share it. 

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DR. TUCKER: I would also echo what 

Paul said yesterday about this topic of 

biodegradable mulches being of particular 

interest to the program given the current status 

of the listing and our policy memo on the topic. 

So, this is an area we plan to pay 

some attention to in the coming months. 

MR. ELA: Jenny, can I ask on that, so 

the program's paying attention to that. Is that 

something we need to consider for a work agenda 

item for the NOSB or should we just let you play 

it out? 

DR. TUCKER: I think the program may 

initiate a -- there has been requests from the 

Board to look at this. And so, I think that we 

could see this as an NOP initiated work agenda 

item to the Board to open that dialogue. 

MR. ELA: Great, that's -- I'm pleased 

to hear that. 

So, Emily, one last comment? 

MS. OAKLEY: Yes, I just I forgot to 

say that I'm growing strawberries on plastic 

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mulch right now, so, just some hypocrisy in my 

thinking. 

MR. ELA: Scott? 

MR. RICE: Just a quick note on the 

Washington trials, those are just north of 

Seattle in the Mount Vernon area and I'm sure 

that we could get the folks involved in that to 

address our meeting in the spring. 

But, I do know, at last check, the 

materials that they are using in their trials are 

not -- do not fit the current definition as was 

passed for biodegradable mulch. 

MR. ELA: Fair enough. 

Asa? 

MR. BRADMAN: Just one last comment. 

I just want to echo the heartburn and, if we can, 

figuratively, at least, bring in all of the prior 

comments related to concerns about plastic and 

waste and into the transcript, or at least refer 

it into the transcript for today's meeting. 

Because, there's really it's a 

tremendously challenging issue and also a 

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tremendous force of basically a toxic waste 

material directly from organic production and 

also related to the difficulties of recycling it 

because of its contamination by soil and other 

materials. 

MR. ELA: I think we can move to the 

vote, Tom. 

MR. CHAPMAN: Okay. We have a motion 

to remove plastic mulch and covers petroleum 

based other than polyvinyl chloride from the 

national list. 

The motion was made by Harriet and 

seconded by Dave. 

A yes vote is to remove, a no vote is 

to retain the listing and the voting will start 

with Harriet. 

MS. BEHAR: No. 

DR. SEITZ: No. 

MR. MORTENSEN: No. 

MR. ELA: No. 

MR. BRADMAN: No. 

DR. GREENWOOD: No. 

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 MS. DE LIMA: No. 

MR. SCHWARTZ: No. 

MS. ROMERO-BRIONES: No. 

MS. OAKLEY: Abstain. 

MS. BAIRD: No. 

MR. BUIE: No. 

MS. SWAFFAR: No. 

MR. CHAPMAN: Chair votes no. 

MR. RICE: No. 

That's one -- excuse me, zero yes, 14 

no, one abstention, zero absent. 

MR. CHAPMAN: Motion fails. 

Steve? 

MR. ELA: Aqueous potassium silicate, 

Clarissa? 

DR. MATHEWS: At Section 205.601(j), 

I'm sorry, (i), As Plant Disease Control, aqueous 

potassium silicate CAS Number 1312-76-1, the 

silica used in the manufacture of potassium 

silicate must be sourced from naturally occurring 

sand. 

MR. ELA: Dave? 

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MR. MORTENSEN: Yes, very quickly, 

this is -- this particular application is for 

insect and mite control. It would be sprayed on 

as a foliar application. 

And, the idea is that the silica that 

results from the application will either have 

direct effects on insects that would be feeding 

on the leaves or indirect effects by uptake of 

the silica tetrahedra across various cells on the 

leaf surface that would induce a plant defense 

where the plant then upregulates and produced 

defense compounds. 

At the time of our review when the 

Subcommittee voted on this, we had heard little 

from stakeholders on whether or not it's being 

used. And, we had a very limited data set or 

data sets on efficacy. 

The Subcommittee posted several 

questions asking for folks to get back to us and 

we heard from quite a few people. 

Their response on is it being used was 

highly regionally skewed with California 

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certified organic and several consultants from 

the Pacific Northwest responding that it is used 

for mite and spider suppression in veg crops. 

And, from my read on that, it was 

mostly an argument that having this tool in the 

toolbox adds another practice, another compound 

that could be used that would reduce selection 

for resistance and other problems as well as a 

replacement of things that we would like to see 

there be less used of, for example, copper 

sulfate, at least in the case of the disease 

management. 

So, we appreciated all that feedback. 

Interestingly, in the Midwest and in 

the East we had, you know, folks responding, 

Pennsylvania certified organic, for example, that 

they had no folks responding that they were using 

it. 

The Committee discussed for quite a 

bit about, and we saw this reflected in public 

comments, so the public comment was, you know, 

there are folks using it. 

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But, we were also interested in 

information on, you know, field worker and 

applicator exposure. 

And, the concern here is that the data 

that we had to go on that's, one, evaluating the 

mechanism of action of the compound is 

contradictory and thin. 

And, two, whether there would be an 

impact on the animals that would be feeding on 

plants that were sprayed including humans, would 

result in health effects. 

And, that was a concern. So, that 

would be my summary of this. 

When it was last relisted in fall of 

2014, the Crops Subcommittee voted 4-3 in favor 

of removal. And, the broader Committee Board 

voted 9-7 to retain the compound. 

MR. ELA: Discussion? 

Harriet? 

MS. BEHAR: Well, we did get quite a 

few -- quite a bit of feedback from producers, 

from the manufacturer giving us information on 

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the efficacy, because our questions were efficacy 

and essentiality. 

And, I was surprised to see the number 

of CCOF growers and the producers, including a 

former NOSB member, actually, I think more than 

one mentioning to see this material be retained. 

I don't really see that there is that 

much of an environmental issue. And, actually, 

in biodynamic farming, you do spray actually a 

silica as an insect control or, you know, to make 

the fibers in the plant less palatable to the 

insects. 

And, so, I'm probably going to change 

my vote on this seeing that there is a need for 

it and I would hate to take away that tool from 

all those producers. 

MR. ELA: I agree, Harriet, there was 

a very strong response and I continue to be 

concerned about the lack of data that helps us to 

assess that the safety of its use, that continues 

to be a concern of mine. 

But, there is no question that we 

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heard from folks that they are using it some in 

an integrated pest management program and on the 

West Coast for sure. 

Asa? 

MR. BRADMAN: One thing that raised 

concerns for me in terms of the Subcommittee 

discussions was the fact that it essentially acts 

as a systemic compound and it's going into the 

plant and then altering the plant. 

And, to me, that puts it in a slightly 

different category and raises concerns for me, 

just almost in principle philosophically. 

It's not like a systemic pesticide 

that, you know, the toxic material is there and, 

you know, you can't wash it out. 

At the same time, though, the 

mechanism here is just concerning to me and 

that's why I voted to not relist it. 

MR. ELA: Other comments? 

Emily? 

MS. OAKLEY: This is a question for 

Dave. If you are going to be changing your vote 

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or if you think you will stay with your original 

vote? 

MR. MORTENSEN: Because of the 

concerns I had about animal and human health 

effects of the systemic action of it, I will 

continue to be voting to delist. 

MR. ELA: Other comments? 

I will make one, but I'll defer. But, 

I think I voted to delist this in the 

Subcommittee, I'll be changing my vote just based 

on the public comment. 

My biggest worry was, essentiality and 

whether it was being used and that, to me, was 

adequately answered and I will just tell the 

stakeholders that this is where public comment 

really, I mean, the Subcommittee that voted 

unanimously against relisting this and now it's, 

you know, based on your comments, it does have an 

influence. 

So, anybody else have a comment before 

we vote? 

MR. MORTENSEN: I guess I would also 

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just like to say that when someone doesn't change 

their vote because of the additional information, 

it's not that we don't value the input, I 

continue to value the input and it actually 

pushed me much closer to being supportive of 

this. 

I was very negative about it 

initially, as effectively a synthetic 

insecticide. But, anyway, I'll leave it at that. 

MR. ELA: Tom? 

MR. CHAPMAN: We have a motion to 

remove aqueous potassium silicate from the 

national list. 

The motion was made by Dave and 

seconded by Harriet. 

A yes vote is to recommend removal, a 

no vote is to not recommend removal. 

And, the voting will start with Dan. 

DR. SEITZ: Yes. 

MR. MORTENSEN: Yes. 

MR. ELA: No. 

MR. BRADMAN: Yes. 

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 DR. GREENWOOD: No. 

MS. DE LIMA: No. 

MR. SCHWARTZ: No. 

MS. ROMERO-BRIONES: Yes. 

MS. OAKLEY: Yes. 

MS. BAIRD: No. 

MR. BUIE: No. 

MS. SWAFFAR: No. 

MS. BEHAR: No. 

MR. RICE: No. 

MR. CHAPMAN: Chair votes no. 

MR. RICE: That's 5 yes, 10 no, zero 

absent. 

MR. CHAPMAN: The motion fails. 

MR. ELA: Elemental sulfur. 

DR. MATHEWS: If I could just 

interject for a minute here, it appears that 

there are two listing of this substance. 

MR. ELA: Yes, there are two. 

DR. MATHEWS: At (i) and (e). 

MR. ELA: That's correct. 

DR. MATHEWS: Okay. 

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 MR. MORTENSEN: So, just very, very 

quickly, the first draft and the second draft are 

these two different -- it's exactly the same 

compound. The only difference here is that the 

compound is being targeted for use for fungal and 

plant disease management. 

And, here, the target is powdery 

mildew. And, Tom, you're wrinkling your brow. 

Is there a question or --

MR. CHAPMAN: I'm confused. For 

aqueous potassium silicate, there's only one 

listing, isn't there, in our books? 

MR. MORTENSEN: Well, the book -- I 

have it as two and we --

DR. TUCKER: There --

MR. MORTENSEN: -- voted --

DR. TUCKER: -- appears to be a 

listing at (e) as in insecticide, including 

acaricides or mite control. 

MR. MORTENSEN: Oh, you're right, and 

then (i). 

DR. TUCKER: And an additional listing 

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at (i) as a plant disease control. 

MR. ELA: so, for protocol --

DR. TUCKER: So, the current motion, 

the vote that just took place only addressed one 

of those. 

MR. ELA: So, for protocol, we should 

probably vote on the second one, as well, Tom, 

since they're listed twice. 

MR. CHAPMAN: Was that an error in the 

slide or the way we published the material? 

Because we only voted -- I thought we had moved 

them forward together as a grouping, it's a slide 

issue, yes. 

MR. ELA: We have, two, right? 

MR. PATTILLO: The proposals were 

done, you've completed two proposals, but we're 

missing one slide for Section (e). 

MR. CHAPMAN: Were the proposals 

forwarded separately or are they done together? 

MR. PATTILLO: They were done 

separately. 

DR. MATHEWS: They're separate. 

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MR. CHAPMAN: They're separate? Was 

that the case --

MR. ELA: Tom, I would propose we vote 

on the second one just to be clear. 

MR. CHAPMAN: Yes, I just want to make 

sure. Did we do separate ones for newspaper as 

well or was that a single? 

MS. SWAFFAR: There was one proposal 

for newspaper in our packet, but two for aqueous 

potassium silicate. 

MR. CHAPMAN: Okay. 

MR. ELA: And, newspaper was linked 

together for aqueous based --

(Simultaneous speaking.) 

MR. CHAPMAN: -- in mind of the two 

listings, okay. And, is that the case with the 

sulfurs as well? 

MR. ELA: Sulfur, we -- a sec here --

MR. MORTENSEN: I think this is the 

only one like that, as I recall. 

MR. ELA: Sulfur, we have them all 

grouped under one. 

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MR. CHAPMAN: And lime sulfur? 

MR. ELA: Lime sulfur, they are 

grouped under one. 

MR. CHAPMAN: Okay. So just --

MR. ELA: So, we just --

MR. CHAPMAN: Just so we're clear with 

the public, we have some level of flexibility to 

combine or not combine, but we're going to vote 

here based on how the Subcommittee forwarded it 

to us. So, I guess this was one that was just, 

unfortunately, overlooked. 

But, the newspaper was in two listing, 

we voted on once to recommend not sunsetting it 

for both listings. We are going to do the same 

for the three listings on elemental sulfur and 

the two listing for lime sulfur. 

But, aqueous potassium silicate came 

to us as two separate motions from the 

Subcommittee and so we will vote on both separate 

motions. 

So, I think we're clear now and, Dave, 

sorry, go ahead. 

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And so, the only difference is the 

target pest group. The target pest group here or 

plant pathogens, particularly, mildews on plants, 

powdery mildews which are a huge disease problem 

in all sorts of vegetables, fruits and fruit 

crops. 

And, really, everything else is the 

same. 

The comments that we received about, 

you know, having this tool in the toolbox there 

was specific language in a lot of the comments 

about mite and spiders as well as powdery mildew. 

So, the argument, again, was the same. 

MR. ELA: Emily? 

MS. OAKLEY: Just a point of 

clarification for Tom. I think the reason that 

we did this in two separate motions was because 

it came from the Subcommittee as a removal so we 

needed to specify both of those sections. 

MR. ELA: Okay. 

Are we ready for a vote? 

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MR. CHAPMAN: So, we're going to have 

-- the one we voted on last time was (i), that 

was what was read into the record. So, I'm going 

to give it to Clarissa before we vote to make 

sure we read in the (e) section. 

MR. ELA: That makes sense. 

MR. CHAPMAN: And, just so the public 

knows, we're broadcasting the wrong one because 

we don't have it up on the slide. But, we're 

talking about 205.601(e). 

MR. ELA: Well, Clarissa's going to 

read it. 

MR. CHAPMAN: Clarissa? 

DR. MATHEWS: So, this particular 

listing is at paragraph (e) as Insecticides 

including acaricides or mite control and the 

substance is aqueous potassium silicate CAS 

Number 1312-76-1. 

The silica used in the manufacture of 

potassium silicate must be from naturally 

occurring sand, sourced from naturally occurring 

sand. 

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 MR. CHAPMAN: So, just to be clear, we 

already voted on 205.601(i) and we're now voting 

on 205.601(e) aqueous potassium silicate. 

We are ready for a vote. 

MR. ELA: Ready for a vote. 

MR. CHAPMAN: So, the seconded motion 

from motion made by Dave, seconded by Harriet. 

A yes vote is to -- I'm sorry, I'm 

still reading the slide. 

MR. ELA: It was seconded by Asa. 

MR. CHAPMAN: The motion was made by 

Dave, seconded by Asa. 

A yes vote is to remove, a no vote is 

to not recommend removal and the voting will 

start with Dave. 

MR. MORTENSEN: Yes. 

MR. ELA: Yes. 

MR. BRADMAN: No. 

DR. GREENWOOD: Yes. 

MS. DE LIMA: No. 

MR. SCHWARTZ: No. 

MS. ROMERO-BRIONES: No. 

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MS. OAKLEY: Yes. 

MS. BAIRD: No. 

MR. BUIE: No. 

MS. SWAFFAR: No 

MR. RICE: No. 

MS. BEHAR: No. 

DR. SEITZ: Yes. 

MR. CHAPMAN: Chair votes no. 

MR. RICE: We have 4 yes, 11 no, zero 

absent. The motion fails. 

MR. CHAPMAN: Steve? 

MR. ELA: Thanks for that catch, Tom. 

I skipped on those pages, and Clarissa, sorry for 

the confusion. 

Elemental sulfur with all three 

listings this time. 

DR. MATHEWS: Yes, we'll do all three 

listings. At Section 205.601 paragraph (e) as 

Insecticides, including the acaroides or mite 

control, paragraph (i) is plant disease control 

and then, again, at paragraph (j) as plant or 

soil amendments. 

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And, the listing is elemental sulfur. 

MR. ELA: Asa? 

MR. BRADMAN: Thank you. And, I'll 

say, I'll try to brief but this is an issue 

that's dear to my heart. 

So, just to kind of review, sulfur is 

up for -- we have three listings here, both as a 

nutrient, as a plant disease control. 

And, we've had extensive public 

comments on sulfur I would say representing 

thousands of growers. And, across the board 

among producers, there's strong support for this 

and I think they've made a strong case for 

essentiality. 

I, you know, last spring, we talked 

about work that I've done looking at the 

relationship of sulfur and reduced lung function 

in children living nearby where the materials are 

applied. 

And then, also, there's an extensive 

history of sulfur causing respiratory, ocular, 

dermal and other illnesses in farm workers. 

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And, those concerns have been raised 

by myself and others in the community as, in some 

cases, reason to not relist sulfur or to at least 

encourage more controls and evaluations. 

One thing we considered last year with 

respect to our work was whether dust versus 

wettable applications. If dust could be reduced, 

that might reduce exposure. 

And, that partly came out of 

discussions with ag commissioners and NAPA and 

Sonoma County where especially kind of orchard 

blasting type applications cause a lot of drift 

and outreach and regulatory problems among 

neighbors. 

We've had some thoughtful comments 

from CCOF about use of the material and a number 

of growers have bought specialized equipment that 

is likely reducing the spread of especially dust 

applications versus wettable applications. 

Many growers talked about purchasing 

special equipment not for just say strawberries, 

but also for vineyards. And, often, water is not 

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available. 

And, this relates to a suggestion, a 

question that we posed to the organic community 

is whether they would consider -- we could 

consider an annotation that eliminated dust 

applications acceptable on organic. 

That annotation is a little bit beyond 

what we can do for this sunset, but the responses 

were kind of interesting. 

There were certainly people who said 

we absolutely support an annotation to eliminate 

dust. Whereas, especially, I think in the wine 

industry and in strawberries, there was like, no, 

we need this tool. 

I had thought about voting no on 

sulfur just as a voice for those concerns. 

Rather, I kind of view this as a signing 

statement about my concerns about the material. 

In some ways I think we should 

separate the use as a plant nutrient from uses of 

pesticide. It is the most heavily used pesticide 

in California and many regions of the world. And 

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we should evaluate that separately. 

I do think it's essential, but I think 

it's something we need to monitor. 

One suggestion by Beyond Pesticides is 

to include an annotation that really emphasizes 

the worker protection standards related to 

sulfur, the EPA worker protection standards. 

And, I think that's something we can 

-- should consider and maybe even for other 

materials to have maybe perhaps stronger 

recommendations on workers protections. 

I noticed that CCOF listed some of the 

protections that go into people in their 

certification that are using the material. And, 

one piece that I think was left out, although I'd 

like to clarify, is -- was lack of respiratory 

protection and whether that's specific to here. 

It might have been just left out. But, I know 

that's an issue. 

I do know growers in California who 

used, say dust applications and their workers 

were getting sick and they switched to a wettable 

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formulation with better protection and those 

problems in their workers just literally went 

away. 

So, I think I've covered all the 

ground on this review and perhaps we can have 

some discussion before voting. 

MR. ELA: Discussion? 

Harriet? 

MS. BEHAR: With so much pervasive use 

in California, has there been any resistance 

reported from, you know, from insects? 

MR. BRADMAN: Not that I know of. I 

mean, it's used as a miticide and, you know, 

acaricide and it's also used as a fungicide. I 

think the fungicide use actually predominates. 

MR. ELA: I can say that --

MS. BEHAR: And, plant disease as 

well? 

MR. ELA: Plant disease, it's multiaction and from my understanding, there's no 

disease -- there's never been documented 

resistance partly because it's not a single -- it 

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actually acts on multiple pathways. So, it's not 

a single point which is, I mean, given it's been 

used for thousands of years, it's pretty 

stunning. 

MR. BRADMAN: Yes. And, also just a 

reminder, that sulfur, I mean, one real benefit 

is that's it's not a systemic poison. You know, 

it's not going to kill people. 

MS. BEHAR: One other question. If we 

decide, perhaps in the future to annotate it to 

wettable powder only, would that take away some 

uses that we wish would -- we still had or --

MR. BRADMAN: It probably would. I 

think it would. Certainly, there -- and people 

in the community assert that strongly. And, like 

I said, I mean, there's some new machinery. 

In fact, I just had a side 

conversation with folks with a dust applicator 

for strawberries that, you know, is low to the 

ground and is unlikely to have the kind of 

community wide exposures that would result say 

from blasting a vineyard. 

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MR. ELA: I would also say if we 

actually like for soil application, if we limited 

it to wettable, that negates, because that's 

often put on as a granular form so I think we'd 

have to take that into account as well. 

I will personally say that I would not 

agree with annotating it for the worker 

protection standards for the very reason that 

that's the law. It's already the law, we don't 

need to annotate something that's already the 

law. 

If an employer is not following that, 

they should be taken to task under that. 

And, it also means that, as those 

standards change, we don't want to have to keep 

messing with the list. 

I mean, I'm not in favor of adding 

things that are already something somebody has to 

comply with. But I do -- I'm very sensitive to 

the human health concerns. 

MR. BRADMAN: Right. Yes, no, I 

understand that. And also, it would put 

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additional -- potentially put additional burdens 

on certifiers. 

MR. ELA: Other comments? 

(No audible response.) 

MR. ELA: Tom? 

MR. CHAPMAN: Okay, so, we have a 

motion to remove elemental sulfur from the 

national list and this motion does incorporate 

all three of the listings. 

The motion was made by Asa and 

seconded by Harriet. 

And a yes vote is to remove, a no vote 

is to retain and the voting will start with 

Steve. 

MR. ELA: No. 

MR. BRADMAN: No. 

DR. GREENWOOD: No. 

MS. DE LIMA: No. 

MR. SCHWARTZ: No. 

MS. ROMERO-BRIONES: No. 

MS. OAKLEY: No. 

MS. BAIRD: No. 

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MS. SWAFFAR: No. 

MR. RICE: No. 

MS. BEHAR: No. 

DR. SEITZ: No. 

MR. MORTENSEN: No. 

MR. CHAPMAN: The Chair votes no. 

MR. RICE: That's zero yes, 15 no, 

zero absent. 

MR. CHAPMAN: The motion fails. 

Steve? 

MR. ELA: Lime sulfur. 

Clarissa? 

DR. MATHEWS: We have two listings in 

Section 205.601. The first at paragraph (e) as 

Insecticides including acaricides or mite 

control. The listing is lime sulfur including 

calcium polysulfide. 

And, the second listing is at 

paragraph (i) as plant disease control. The 

listing is lime sulfur. 

MR. ELA: So, this is my material, 

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full disclosure, it's something we use a fair 

amount. 

Most of the public comments were 

readily in favor of lime sulfur noting it's 

widespread use for everything from as fungicide 

to acaricide to I think some thinning notes were 

made as well. 

So, there's definitely -- we heard 

from the community essentiality. The 

alternatives to lime sulfur are fixed copper and 

copper sulfate, but those pose more environmental 

risk than lime sulfur, so there may be a benefit 

to it. 

I think the one negative comment we 

received was that one group would be in favor of 

limiting the use of lime sulfur when that listing 

could be annotated for use only when beneficial 

arthropods are not present. 

They were considered about its broad 

spectrum side and that it might actually disrupt 

biological control. 

So, and there was a comment that prove 

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thinning cited in some comments might not be an 

allowed use. 

I think I'll just put my editorial 

comment on that. At that same time, it's being 

used for fire blight control and also for fungal 

control. So, it becomes a little -- that comment 

may be attributed there are alternate uses at 

that same time. 

Discussion? 

(No audible response.) 

MR. CHAPMAN: Okay, we have a motion 

to remove lime sulfur from the national list. 

The motion was made by Steve and 

seconded by Emily. 

A yes vote is to recommend removal, no 

vote to retain and the voting will start with 

Asa. 

MR. BRADMAN: No. 

DR. GREENWOOD: No. 

MS. DE LIMA: No. 

MR. SCHWARTZ: No. 

MS. ROMERO-BRIONES: No. 

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 MS. OAKLEY: No. 

MS. BAIRD: No. 

MR. BUIE: No. 

MS. SWAFFAR: No. 

MR. RICE: No. 

MS. BEHAR: No. 

DR. SEITZ: No. 

MR. ELA: No. 

MR. CHAPMAN: The Chair votes no. 

MR. RICE: That's zero yes, 15 no, 

zero absent. 

MR. CHAPMAN: Motion fails. 

Steve? 

MR. ELA: Sucrose octanoate esters. 

Clarissa? 

DR. MATHEWS: At Section 205.601(e) is 

insecticides, including acaricides or mite 

control. The listing is sucrose octanoate 

esters, CAS Number 42922-74-7 and 58064-47-4. 

In accordance with approved labeling. 

MR. ELA: Sue? 

MS. BAIRD: Yes, we had a pretty good 

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discussion on this for livestock. It is, though 

we are addressing it now for crops as an 

insecticide, it has been approved by EPA under 

registration two different numbers to control 

soft belly insects. 

It's permitted as a foliar spray, 

fields, greenhouses, nurseries and any type of 

agricultural crop. 

It biodegrades rapidly. It's not 

toxic to mammals or any targeted organisms. The 

amount used will not substantially increase the 

amounts of the esters in the environment. It's 

nontoxic to honeybees and many beneficial 

insects. There's no phytotoxicity in crops. 

We've got no comments this time for 

fall for the use or against the use of SOEs in 

crops. 

In spring, we did have four comments 

that said that they used it as effective tool for 

rotation with other pest control materials that 

are allowed in organic production. 

So, I'm not clear if, and this is a 

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Harriet question, when you said there was nothing 

-- no products registered if that was strictly 

for miticide for insects for bees or if this also 

for crop production. 

MS. BEHAR: No, and Clarissa did send 

me the deregistration determination. I don't 

know the exact form name but it has been 

deregistered for both livestock varroa and on 

crops. 

It was the same manufacturer and they 

removed their request for that. 

But, there was one public commenter 

that I -- the Organic Produce Wholesalers 

Coalition did support the use and both in this 

comment and the previous. 

And so, when I found out that both of 

the products were no longer registered, I went 

back to the public comments and just to be open 

and frank, I am friends with Lynn Coody and so I 

contacted her. And, we had a kind of back and 

forth of why did they support the use? 

And, she said that they had sent out a 

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survey to their producers, but that was for the 

previous sunset. It wasn't a new survey on that 

because it's been deregistered so they wouldn't 

be using it. Yes, they wouldn't be using it now. 

But, they just said for a tool. But 

it has a lot of the same issue with it's not EPA 

registered. 

I don't know, ESMA didn't do research 

into if they're using it internationally, but it 

is not on the EU list and I don't know about 

Canada. 

MR. ELA: Emily? 

MS. OAKLEY: There were also public 

comments from another commenter that refers to 

the EPA delisting. I just wanted to point that 

out. 

MR. ELA: Clarissa, do you have 

anything to add to that delisting? 

DR. MATHEWS: Only that I did also 

confirm directly with EPA. 

MR. ELA: So, if there -- so, there is 

no listing for it on crops? 

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clarification, there was no registered product. 

MR. ELA: Thank you for -- and thank 

you for checking on that. 

DR. MATHEWS: You're welcome. 

MR. ELA: That's really useful 

information. 

Other comments? 

MR. BRADMAN: Well, I just had a 

question, if it's not registered for EPA, I don't 

know if it's required to have a food tolerance. 

It seems to me like we shouldn't --

you can't even have it on our list if it's not 

registered. 

MR. ELA: I think that you see the 

vote on the Subcommittee was to not delist it, 

this information came out since we voted on it. 

And, I would at least I voted for it -- I voted 

to not delist it originally. My vote has changed 

based on that. I don't think we can have a 

material on the list that has no use. 

Emily? 

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MS. OAKLEY: Same here. 

MR. ELA: Harriet? 

MS. BEHAR: Having used this material, 

I will attest to it being completely miserable. 

(Laughter.) 

MR. ELA: Anybody else have comments? 

Lisa, you have a very quizzical look 

on your face. I don't mean to call on you, but 

you -- can we clarify something? 

MS. DE LIMA: So, is this same 

situation in livestock where it's the same exact 

situation? 

MR. ELA: Pretty much. 

MS. DE LIMA: Okay. 

MR. ELA: Does that help? 

MS. DE LIMA: I want to be consistent 

in my voting. 

MR. ELA: Yes. 

Any other discussion? 

(No audible response.) 

MR. ELA: Tom? We didn't give you as 

much time as you needed, did we? 

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research quickly online about tolerance levels 

for sucrose octanoate esters. I don't know if 

it's a true statement whether or not the 

tolerance has been removed from the --

MR. ELA: Okay. 

MR. CHAPMAN: So, just something to 

keep in mind, but I don't know if that's going to 

change the way anyone votes on this item. 

Don't use us as the record for making 

that determination, I guess. We never should use 

this for the record anyway. 

All right, so we have a motion to 

remove sucrose octanoate esters. It's a seconded 

motion from the Subcommittee. 

The motion was made by Sue and 

seconded by Jesse. 

A yes vote is to recommend delisting 

this material, a no vote is to recommend its 

listing remains and the voting will start with 

Rick. 

DR. GREENWOOD: Yes. 

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 MS. DE LIMA: No. 

MR. SCHWARTZ: No. 

MS. ROMERO-BRIONES: Yes. 

MS. OAKLEY: Yes. 

MS. BAIRD: I'm going to say no for 

the same reason I said, it may -- just because 

it's not currently got a product listed, maybe in 

the future it will be. 

MR. BUIE: No. 

MS. SWAFFAR: Yes. 

MR. RICE: Yes. 

MS. BEHAR: Yes. 

DR. SEITZ: Yes. 

MR. MORTENSEN: Yes. 

MR. ELA: Yes. 

MR. BRADMAN: Yes. 

MR. CHAPMAN: Chair votes yes. 

MR. RICE: That's 11 yes, 4 no, zero 

absent. 

MR. CHAPMAN: The motion passes. 

Steve? 

MR. ELA: Okay, hydrated lime. 

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 DR. MATHEWS: Section 205.601(i) as 

plant disease control. The listing is hydrated 

lime. 

MR. ELA: Dave? 

MR. MORTENSEN: Okay, hydrated lime, 

yes, this has been around for a long time. It's 

centrally important for its use as a foliar 

application for disease management in all sorts 

of vegetable and fruit crops. 

It is necessary, or a central 

ingredient in something called the Bordeaux mix 

where it's mixed with copper sulfate for 

applications. 

There has been strong support. It's 

widely used. 

During the course of the Subcommittee 

discussions, I think we collectively saw this as 

something that is a widely used quite safe 

product. 

And, the comments that we received by 

and large supported that. 

MR. ELA: Discussion? Comments? 

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 (No audible response.) 

MR. ELA: Tom? 

MR. CHAPMAN: So, we have a motion to 

remove hydrated lime from the national list. 

The motion was made by Dave and 

seconded by Jesse. 

A yes vote is to remove, a no vote is 

to retain and the voting will start with Lisa. 

MS. DE LIMA: No. 

MR. SCHWARTZ: No. 

MS. ROMERO-BRIONES: No. 

MS. OAKLEY: No. 

MS. BAIRD: No. 

MR. BUIE: No. 

MS. SWAFFAR: No. 

MR. RICE: No. 

MS. BEHAR: No. 

DR. SEITZ: No. 

MR. MORTENSEN: No. 

MR. ELA: No. 

MR. BRADMAN: No. 

DR. GREENWOOD: No. 

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MR. CHAPMAN: The Chair votes no. 

MR. RICE: That's zero yes, 15 no, 

zero absent. 

MR. CHAPMAN: The motion fails. 

Steve? 

MR. ELA: Liquid fish products. 

Clarissa? 

DR. MATHEWS: Section 205.601(j) is 

plant or soil amendments, the listing is liquid 

fish products. Can be pH adjusted with sulfuric, 

citric or phosphoric acid. 

The amount of acid used shall not 

exceed the minimum needed to lower the pH to 3.5. 

RM. ELA: Dave? 

MR. BRADMAN: So, liquid fish 

products, I think really the comments and input 

we have is this fall really reflects some of the 

discussions that we had last spring. 

There's vast support for relisting of 

liquid products. 

Based on my review of comments and 

users, we probably have thousands represented 

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just related to organizations and individuals 

that submitted comments. 

There was also expression of concern 

about the issue that came up last year or last 

spring about the use of wild fish stock as sole 

source material for production of liquid fish 

products and support for a work agenda and a 

review of that, perhaps not as complicated but 

similar to the issues that are going on around 

marine materials. 

You know, my sense is that this is an 

essential and important material and that I know 

I will be supporting its relisting. But, I would 

like to participate in, and I hope that, as a 

Board, that we can all participate in a work 

agenda from the program to review the use of the 

source fish stocks for this material. 

MR. ELA: And, I would like to 

clarify, the program has approved that work 

agenda for the Committee. So, it is on our list. 

Emily? 

MS. OAKLEY: Just to clarify, I was 

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the abstention and that was before we knew that 

this material would be -- or this item would be 

added to our work agenda. 

So, it was sort of waiting for that. 

So, my abstention will be a no vote. And I thank 

the program for allowing us to work on this 

issue, I'm looking forward to it. 

MR. ELA: Harriet? 

MS. BEHAR: There was also some 

discussion by a manufacturer about the pH and 

wanting some clarification about where the 

process, and so I'm not sure, you know, if we'll 

work on that or not. But I just wanted to 

recognize that that was brought to our attention. 

MR. ELA: So, at the Tucson meeting, 

we received a large amount of public comment. 

The NOP had asked us to clarify about the pH 

requirement of 3.5, whether that was throughout 

the whole process as the fish product is being 

made or it was a final process. 

We heard a fair amount of public 

testimony from that in Tucson, and the take-away, 

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we haven't talked about it extensively in the 

Committee, but that to minimize the use of 

phosphoric acid in that product, the best way was 

to have a final pH of 3.5. And that also makes 

the certification easier because the certifier 

doesn't have to be there through the whole 

process. 

I think the manufacturer, we discussed 

that at the meeting, but the manufacturer was 

asking for some clarification on that. 

The Crops Committee will be making --

will forward a note to the NOP that that is our 

opinion. We'll put it in writing and then the 

NOP can act on it as such to the manufacturer. 

But at least we'll make that clearer rather than 

just letting that drop. 

Other discussion? Ashley? 

MS. SWAFFAR: I just want to say that 

I think this is a very critical material for a 

lot of smaller farms, especially vegetable farms. 

So I highly support this item. 

MR. ELA: All right. Tom? 

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motion to remove liquid fish products from the 

national list. The motion was made by Asa and 

seconded by Jesse. 

A yes vote is to remove, a no vote to 

relist, and the voting will start with Eric. 

MR. SCHWARTZ: No. 

MS. ROMERO-BRIONES: No. 

MS. OAKLEY: No. 

MS. BAIRD: No. 

MR. BUIE: No. 

MS. SWAFFAR: No. 

MR. RICE: No. 

MS. BEHAR: No. 

DR. SEITZ: No. 

MR. MORTENSEN: No. 

MR. ELA: No. 

MR. BRADMAN: No. 

DR. GREENWOOD: No. 

MS. DE LIMA: No. 

MR. CHAPMAN: Chair votes no. 

MR. RICE: That's zero yes, 15 no, 

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zero absent. 

MR. CHAPMAN: The motion fails. 

Steve? 

MR. ELA: Sulfurous acid. Clarissa? 

DR. MATHEWS: That's Section 

205.601(j) as plant or soil amendments. The 

listing is sulfurous acid, CAS Number 7782-99-2 

for on-farm generation of substance utilizing 99 

percent purity elemental sulfur per paragraph 

(j)(2) of this section. 

MR. ELA: All right, this is my lead. 

Basically, sulfur is burned to create an acid to 

acidify the irrigation water and is used on farms 

with high pH soils. 

Almost everybody wrote in to support 

it, noting that if irrigation water has a high 

pH, if it's left untreated it causes calcium 

carbonate buildup on the leaf and fruit surface. 

Lowering that pH helps reduce that buildup and 

gives better nutrient uptake in the soils. 

The one negative comment that opposed 

the relisting of this saying that the 

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accumulation of carbonates and bicarbonates 

through irrigation water is in more arid regions 

and that actually is just farmland that should 

not be farmed to start with. 

But, in general, with the exception of 

that comment, the comments were in favor that 

this benefitted growers in having to reduce some 

of their nutrient applications because of 

adjusting the pH. 

Discussion? Harriet, do you have a 

comment? 

MS. BEHAR: I was surprised to see 

that there were only 12 CCOF members that listed 

this product, but I'm not sure that -- I think 

most people who are running it in irrigation are 

probably using the elemental sulfur or doing it 

as a powder in the soil. But I will vote to keep 

this on the National List, but it did surprise me 

that it wasn't more in use. 

MR. ELA: Dave? 

MR. MORTENSEN: Steve, I was just 

curious if, in looking at this, you came across 

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how the sulfurous acid is actually introduced 

into the water stream? 

And the reason I ask is, where I 

worked in Nebraska, it was always a concern about 

backflow where you tap in whatever you're 

applying and that it could actually go the other 

way by mistake with faulty equipment. 

MR. ELA: So, in answer to that 

question, the acid is created by spraying water 

through the smoke when you burn the sulfur, and 

then that is pumped into the -- or injected into 

the pipeline. 

So I think your concerns with 

backflow, one usually only reduces the pH to 

something around 6, so we're not talking highly 

acidified water after it's injected. So it's, 

you know, essentially safe; it's not like 

injecting a pesticide into it. 

So I don't know if that answers your 

question but --

MR. MORTENSEN: It does. Thanks, 

Steve. 

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 MR. ELA: And, in response to 

Harriet's questions, I know we have a number of 

growers in our area that use them that we would 

not have seen, organic growers, and it makes a 

significant difference in their like iron 

chlorosis, for example. 

It's actually, full disclosure, 

something I may install next year, assuming it's 

still on the list. For those growers that use 

it, it seems to be very effective and reduces 

their other nutrient problems. 

Scott? 

MR. RICE: Yeah, I just echo that. 

It's a wide use in the tree fruit industry in the 

northwest and elsewhere. 

MR. ELA: Any other discussion? 

Tom? 

MR. CHAPMAN: All right, we have a 

motion to remove sulfurous acid from the National 

List. The motion was made by Steve and seconded 

by Harriet. 

A yes vote is to remove, a no vote is 

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to retain, and the voting will start with A-dae. 

MS. ROMERO-BRIONES: No. 

MS. OAKLEY: No. 

MS. BAIRD: No. 

MR. BUIE: No. 

MS. BEHAR: No. 

DR. SEITZ: No. 

MR. MORTENSEN: No. 

MR. ELA; No. 

MR. BRADMAN: No. 

DR. GREENWOOD: No. 

MS. DE LIMA: No. 

MR. SCHWARTZ: No. 

MR. CHAPMAN: Chair votes no. 

MR. RICE: That's zero yes, 15 no, and 

zero absent. 

MR. CHAPMAN: The motion fails. 

Steve? 

MR. ELA: All right, a vote we've had 

international interest in, ethylene. Clarissa? 

DR. MATHEWS: Section 205.601(k) as 

plant growth regulators. The listing is ethylene 

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gas for regulation of pineapple flowering. 

MR. ELA: Emily? 

MS. OAKLEY: Yep, so, it's used to 

induce uniform flowering in pineapples. And it's 

important to note this is pineapple only. 

It's an essential tool for commercial 

production of pineapples for the export market, 

as we've heard from the numerous producers and 

producer groups and others, both on the webinar, 

in person, and in the written comments. 

Commenters stated that no viable 

alternatives exist and that without it it would 

be impossible to achieve the uniform ripening 

necessary for timing the harvest for food 

shipment. 

We heard both in the spring, and was 

also heard in the 2015 review in Stowe, and again 

this time, that, by one commenter at least, that 

the material does not fit an OFPA criteria and it 

is not essential for the production of the crop, 

but rather is employed for economic reasons. 

I would say that I think that it is a 

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tricky material and that it is truly being 

applied for economic purposes. However, this 

time around, we did hear public comment and 

received significant written comment suggesting 

that flowering reduction reduces pest damage by 

allowing for uniform application of pesticides 

and minimizes worker entry into the field, which 

thereby also reduces disease introduction and 

damage to the crop. 

Are there any questions or comments? 

MR. ELA: Harriet? 

MS. BEHAR: So, that was very 

important to me when we did hear the public 

comment that when you have a flowering, you know, 

intermittently throughout the field, it attracts 

the pests and damages the younger pineapple. And 

so it's not just being able to send the product 

to market, but actually help save the crop. 

I do say I have some concern about the 

monoculture of that crop, that it's pineapple 

after pineapple after pineapple. But it does 

appear that the growers are doing a good cover 

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crop, and a nitrogen fixing one at that, in 

between. 

But, for just kind of longer term 

sustainability, I hope that they think about 

doing a little bit more rotation, because I don't 

know that much about pineapple, but I do know 

that if you grow the same crop in a field year 

after year after year, even with a three to six 

month break, something will probably come in, an 

insect that will over -- you know, they live in 

the soil, or disease or whatever. 

So, that has nothing to do with 

ethylene, it just has to do with pineapple. One 

of the essential food groups, along with 

chocolate and wine. 

MR. ELA: Other comments? I do want 

to reiterate thank you to the Costa Rican 

contingent for making the long trip. Your 

testimony is very important, just like any grower 

and any other stakeholder. And I hope to heck 

that you get to do something fun here beside sit 

in a convention room for three days. So, please 

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enjoy your time in our country. 

Vote? 

MR. CHAPMAN: Please enjoy the fine 

warm weather in the state of Minnesota in 

October. 

All right, we have a motion to remove 

ethylene gas from the National List. The motion 

was made by Emily and seconded by Harriet. 

A yes vote is to remove, a no vote is 

to retain. And the voting will start with Emily. 

MS. OAKLEY: No. 

MS. BAIRD: No. 

MR. BAIRD: No. 

MS. SWAFFAR: No. 

MR. RICE: No. 

MS. BEHAR: No. 

DR. SEITZ: No. 

MR. MORTENSEN: No. 

MR. ELA: No. 

MR. BRADMAN: No. 

DR. GREENWOOD: No. 

MS. DE LIMA: No. 

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MR. SCHWARTZ: No. 

MS. ROMERO-BRIONES: No. 

MR. CHAPMAN: Chair votes no. 

MR. RICE: That's zero yes, 15 no, 

zero absent. 

MR. CHAPMAN: The motion fails. The 

Costa Ricans are happy. 

(Laughter.) 

(Applause.) 

MR. CHAPMAN: Steve? 

MR. ELA: Microcrystalline cheesewax. 

Clarissa? 

DR. MATHEWS: Section 205.601(o) as 

production aids. The listing is microcrystalline 

cheesewax, CAS Number 64742-42-3, 80090-03-08, 

and 8002-74-2 for use in log-grown mushroom 

production, must be made without either ethylene, 

propylene, copolymer, or synthetic colors. 

MR. ELA: Sue? 

MS. BAIRD: Yes, microcrystalline wax 

is a type of wax that's derived from refining 

heavy petroleum distillates during the petroleum 

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refining process. It's recovered from crude oil 

through a series of filtration and on and on. 

And it's used in mushroom production 

to seal the plug holes in shiitake logs in which 

the spawn is actually inserted. It is petroleumbased, and even though used in small quantities, 

it does not biodegrade in the environment. 

We had heard, in the spring, public 

comments that there were natural soy waxes from 

domestically produced non-GMO soybeans that was 

now available. And, based on that information, 

and because that survey was done with a larger, 

more commercial mushroom production, there was 

some suggestion that perhaps it was no longer 

needed. 

But, since that point, we've heard 

from smaller shiitake mushroom growers who're 

saying, yes, we absolutely do use it, and, in 

fact, QCS said that they disagreed with the 

subcommittee's statement that there were 

alternatives such as natural soy-based wax that 

were available to replace this material. 

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And their statement was that every 

soy-based wax that they've reviewed for use in 

organic production comes from hydrogenated soy 

oil, which is synthetic and prohibited in organic 

production. They said that their certified 

mushroom producers that are growing on shiitakes 

are, in fact, using microcrystalline cheesewaxes. 

And they said they'd conducted internal review 

for three separate microcrystalline cheesewax 

products and they've found that they were 

compliant to 601. 

MR. ELA: Discussion? Harriet? 

MS. BEHAR: So, there was a producer 

who wrote quite extensively in favor of this 

material. It actually happens to be someone that 

I know and someone that I inspected. 

He mentioned he sells a lot to 

mushroom growers, and he said that he sells, on 

average, four tons of clear cheesewax to growers 

each year. This represents 80,000 logs a year 

that are being treated with this microcrystalline 

cheesewax. 

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And probably you've heard that I was 

not that favorable to this material, because I 

disagree with the TR in how rapidly it 

biodegrades, because I have seen it out on the 

forest floor when it looks like it's been there 

for at least three to four years, because the 

logs that it was in are just about gone and they 

get all this wax. But I don't want to take away 

a tool. 

He also talks about the fact that it's 

a clear wax and that you can then see underneath 

how the spawn is growing and you can kind of 

manage your production that way. So I am going 

to vote for this material. 

MR. ELA: Emily? 

MS. OAKLEY: I can't remember if I'm 

one of the yeses or the abstain, but I just 

wanted to clarify my change of position. 

We did not receive public comment to 

the extent that we did this time around in the 

spring, which underscores the benefit of having 

these materials before stakeholders for two 

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meetings. So, thanks to those who reached out to 

their growers and submitted comment to us. 

MR. ELA: Asa? 

MR. BRADMAN: I just have a question 

for clarification about the soy wax option. I 

understand that's hydrogenated, it would be 

synthetic, and would need to be on the list. 

If it were to be on the list, and I 

think there's some history I might not be fully 

versed on, but it looks like there may have been 

or could be a petition to list it. And then 

would that provide an alternative to the 

microcrystalline cheesewax? 

MS. BAIRD: Yeah, according to QCS. 

And I have not researched this, but they said 

that everyone that they had researched, they were 

a synthetic-based soy. And, therefore, it would 

have to be petitioned to be on the list. 

MR. ELA: Emily? 

MS. OAKLEY: Yeah, we did have this 

petition before us in 2016, and that was a very 

painful, painful meeting for many reasons. And 

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that vote was actually, I thought, not the 

awesomest, and so we did not successfully vote to 

add that to the list. 

MR. ELA: Tom? 

MR. CHAPMAN: Yeah, I want to remind 

folks that just being bio-based doesn't mean 

biodegradable. And on the other material, I 

don't think there was sufficient research done on 

it to come to that conclusion at the time it was 

brought forward before the full Board. 

MR. ELA: Emily? 

MS. OAKLEY: Yeah, to elaborate on 

Tom's point, I think there were some concerns 

that a TR wasn't received. Perhaps it's time to 

re-petition that and request a TR. 

MR. ELA: Other discussion? I mean, 

we can always talk FDA wants a five log reduction 

and if we keep this product on we have a no log 

reduction. 

Anybody else? Tom? 

MR. CHAPMAN: Who doesn't like log 

reduction jokes? 

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 All right, the motion to remove 

microcrystalline cheesewax from the national 

list. The motion was made by Sue and seconded by 

Emily. 

This is a motion to remove so a yes 

vote is to remove, a no vote is to retain. And 

the voting will start with Sue. 

MS. BAIRD: No. 

MR. BUIE: No. 

MS. SWAFFAR: No. 

MR. RICE: No. 

MS. BEHAR: No. 

DR. SEITZ: No. 

MR. MORTENSEN: No. 

MR. ELA: No. 

MR. BRADMAN: No. 

DR. GREENWOOD: No. 

MS. DE LIMA: No. 

MR. SCHWARTZ: No. 

MS. ROMERO-BRIONES: No. 

MS. OAKLEY: No. 

MR. CHAPMAN: Chair votes no. 

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MR. RICE: That's zero yes, 15 no, 

zero absent. 

MR. CHAPMAN: I swore I heard 17 no's. 

(Laughter.) 

MR. CHAPMAN: The motion fails. 

Steve? 

MR. ELA: Potassium chloride. 

Clarissa? 

DR. MATHEWS: In Section 205.602, nonsynthetic substances prohibited for use in 

organic crop production. At paragraph (e) the 

listing is potassium chloride unless derived from 

a mined source and applied in a manner that 

minimizes chloride accumulation in the soil. 

MR. ELA: Harriet? 

MS. BEHAR: So, this is a prohibited 

natural, just so people understand that. 

There was public comment. The 

certifiers stated that the annotation, which is 

an important one, is verified at inspection and 

during review. Many see it as necessary but feel 

that that annotation is important. 

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 In the first round of comments, one 

certifier noted that it's difficult to find 

potassium sulfate, which is not this material, 

but that there's issue with dust suppressants and 

that some certifiers allow all dust suppressants 

and others look at them and don't allow them. So 

they thought that that should be looked at. 

CCOF said that there were close to 50 

producers using it, and there was strong support 

by public comment just to relist the material on 

205.602. 

MR. ELA: Discussion? Tom? 

MR. CHAPMAN: All right, so this is a 

motion to remove potassium chloride from the 

national list. The motion was made by Harriet 

and seconded by Emily. 

A yes vote is to remove, a no vote is 

to retain the listing. And the voting with start 

with Jesse. 

MR. BUIE: No. 

MR. RICE: No. 

MS. BEHAR: No. 

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DR. SEITZ: No. 

MR. MORTENSEN: No. 

MR. ELA: No. 

MR. BRADMAN: No. 

DR. GREENWOOD: No. 

MS. DE LIMA: No. 

MR. SCHWARTZ: No. 

MS. ROMERO-BRIONES: No. 

MS. OAKLEY; No. 

MS. BAIRD: No. 

MS. SWAFFAR: No. 

MR. CHAPMAN: Chair votes no. 

MR. RICE: That was zero yes, 15 no, 

zero absent. 

MR. CHAPMAN: The motion fails. And 

that concludes 2020 sunset. 

(Applause.) 

MR. CHAPMAN: I would propose that we 

go through a couple of these and then we'll 

break. 

MR. ELA: Yeah, as a note to the 

Board, it's 3:35 and you can pay attention to 

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your agendas where that puts us. So, obviously, 

on these proposals, we want to have a robust 

discussion, but we'll see if we can keep it 

focused while at the same time getting the 

information out that needs to be brought out. 

So, if we could start with allyl 

isothiocyanate, also known as AITC. That is 

Jesse's material. 

MR. BUIE: Allyl isothiocyanate -- and 

heretofore we'll call it AITC -- we received an 

addendum to this particular material after we had 

voted. The vote was zero yes and six to not list 

it. And I would like to send this back to the 

subcommittee for further deliberation for the 

following reasons. 

After reviewing the addendum that was 

submitted, many of the issues that we were 

concerned about have been dealt with. And I 

think that we, as a subcommittee, ought to look 

further into that. 

For an example, TR lines 607-608 

discusses AITC drip would therefore be 

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problematic for both the beneficial soil fungi 

and associated plants. The addendum has 

information that would deal with that particular 

concern that we have. 

Also, another one was lines 451 and 

452, inhalation toxicology data for AITC and its 

degradance are not available. Well, that 

information has been provided in the response. 

And also another response -- and there 

were 16 of these that were submitted that I feel 

that we should look further into before making a 

decision on this particular material. 

TR 459 to 460 states that the physical 

properties of AITC are similar to those of the 

conventional soil fumigant MITC, and indicates 

much of the TR referred to MITC for its data. 

And the respondent showed that this comparison, 

that MITC was really four times higher than AITC. 

And there are 16 of these. So, as a 

result of this new information that we received, 

I'd like to make a motion to send this back. 

Any discussion? 

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MR. ELA: I think that goes to the 

Chair if there's a motion, doesn't it? 

MR. CHAPMAN: There is a motion, is 

there a second? There's a second from Asa, and 

we can discuss the motion. 

MR. ELA: Now we can have discussion; 

we couldn't before. So, Emily? 

MS. OAKLEY: Thank you, Jesse. I hear 

what you're saying but I don't share your 

concerns about the petition addendum changing my 

position on this material. 

I rely on the technical report more 

than I would rely on the petitioner's differing 

information from the technical report, simply 

because the technical report is coming from an 

unbiased third-party, whereas the addendum is 

coming from the petitioner who has an interest in 

seeing the material approved. 

That being said, I don't think that 

the concerns that I had to originally reject this 

material would be changed by sending this back to 

the Committee. So I would like to proceed with 

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the vote and urge those here to vote to keep it 

on our list and vote to remove it. 

MR. ELA: Tom? 

MR. CHAPMAN: I was swayed by some of 

the public comment here to potentially review 

this substance as a treatment for nursery stock. 

And I know that once we've reviewed that my vote 

may not, you know, turn to approving this 

substance. 

But I would like to at least have a 

chance to explore that as an option and get 

further information so I support sending this 

back to the subcommittee. 

MR. ELA: Lisa? 

MS. DE LIMA: I was going to ask the 

same question the rest of the folks on Crops, 

because I wouldn't want to send it back for the 

reasons that Jesse had said, agreeing with Emily. 

But I was interested in other people on Crops and 

what they were thinking as far as considering it 

for the nursery stock. 

MR. ELA: I can answer that. Scott, 

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you had your hand up, too, and I want to respect 

what you want to say, and then we'll definitely 

answer that. 

MR. RICE: I express my interest in 

seeing it have that limited use as well if it's 

potentially beneficial to the nursery stock 

industry, because we see a lot of non-organic 

perennial tree fruit and it'd be great, if this 

were a resource, to have it as a tool. 

MR. ELA: So, I'll put my two cents 

in. I tend to follow more with Emily on this 

one. While I agree, we desperately need a 

phytosanitary material for the production of 

nursery stock, I don't agree that we should use a 

broad scale, broad spectrum fumigant. You know, 

that's a very magic bullet conventional approach. 

And just because it's naturally occurring does 

mean that it does not still have dramatic effects 

on the soil. 

As I become more versed as an organic 

grower, I mean, I switched from conventional. 

When we first switched, we tended to look, you 

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know, for those bullets, like it's the 

progression that goes in. Now, I look at it very 

much as a systems approach. 

And I believe that when we apply these 

broad spectrum things, we really damage, 

permanently damage they system. Or maybe I 

shouldn't say permanently, but more than just a 

while. 

And so I guess I'm personally not in 

favor, even though it means that we may not have 

that phytosanitary restriction. But I'd rather 

call a spade a spade. If we're going to do a 

broad scale fumigation, call it conventional and 

go ahead and use those conventional ones, versus 

putting the organic material in that really is 

doing the same thing and, to me, causing harm to 

that soil, biota, and ecosystem. 

And I don't like calling that organic 

because I don't think it's in that -- I don't 

think it's in the spirit or in the belief. So, I 

don't know if that makes sense, but that's my two 

cents. 

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 Asa, and then I'll go to Sue. 

MR. BRADMAN: I guess I would like a 

little clarification. If this were one of the 

materials used for phytosanitary purposes for 

nursery stock, is that still an application to 

soil? Or is that, say, after harvest and before 

shipping or something like that? 

Because what I'm interested in is -- I 

don't know if this is the material, but maybe 

this also opens up a discussion on even the 

concept of, you know, an organic approach to 

producing nursery stock from ground zero. It's 

almost like the day-old chick issue: can we take 

this and go back? 

And I don't know if this is the 

material for that, but, if it's not used in the 

soil, is there an opportunity here to have a 

discussion that might move that issue forward? 

MR. ELA: Sue? 

MR. BRADMAN: That's a question to 

everyone. 

MS. BAIRD: I guess my -- and I truly 

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second the concerns of fumigants. I just don't 

like them. But if we don't bring this back and 

at least explore it for nursery stock -- and I 

would be open to just limiting to nursery -- if 

we don't do that, are we going to stop the 

prevailing methobromide and some of those broad 

spectrums that we have today? 

MR. ELA: Dave? 

MR. MORTENSEN: Yeah, and I guess 

because I think Tom asked what the subcommittee 

thought -- or Lisa did, sorry. My view aligns 

very closely with Steve's and Emily's on this. I 

really would like to see us be moving in the 

direction of a systems approach to this kind of 

management, which led me to ask some questions 

about the cover crop use in fields. There are 

cover crops actually that produce a very similar 

compound to this one. 

That's not addressing the nursery part 

of this, but I just think that we really need to 

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by-chemical solutions to the problem. 

MR. ELA: Emily? 

MS. OAKLEY: Yeah, I want to echo 

that, especially in terms of the cover crops. I 

mean, that is the beauty of organic. We are 

looking at the whole agro ecosystem and we are 

taking approaches that avoid the use of 

chemicals. 

And so I just want to read to you the 

first paragraph on the last page of this. 

Mustard seed, meals, mustard green, manures, 

plowed under cover crops, Regalia, an approved 

OMRI material, are biopesticides that are 

available; SoilGard, a fungal biocontrol 

material; Serenade and bionematicide MeloCon are 

also feasible alternative materials available for 

use in organic crop production systems. 

So I don't think there is a lack of 

other ways of addressing this in a spirit that is 

more in keeping with OFPA and our rules and the 

spirit of organic. 

I really don't think sending this back 

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is going to create an organic nursery stock 

industry based on this material. And I think it, 

frankly, won't change the ultimate outcome. 

That's just my personal view on this. 

MR. ELA: Harriet? 

MS. BEHAR: So, I'm fairly torn on 

this material. And my mucus membranes are 

burning; having made horseradish in a food 

processor, I'm very familiar with this allyl 

isothiocyanate. 

So, but I feel we would be a little 

bit remiss in not at least exploring it for 

nursery stock, because, having done the piece on 

organic seed and nursery stock in strengthening 

that, I'm painfully aware of how little organic 

there is. Which means that the nursery stock, 

not only has it been treated with prohibited 

fumigants, but it's been treated with pesticides 

and has not been grown in organic soil and all of 

those other wonderful things that happen to 

plants when they are being treated organically. 

So, I guess I would like to see it go 

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back to subcommittee. And all the points that 

you're making now could then be brought forward, 

and perhaps we'll vote it down based on that, but 

at least we would have given the nursery stock 

people the due diligence in reviewing it for 

their special use. 

MR. ELA: Asa? 

MR. BRADMAN: I just want to follow up 

and say I really respect Dave and Emily, the 

direction you're coming from. And if I were to 

vote on this petition as presented, I would vote 

no on it. I would vote it down. 

I guess, again, I want to repeat my 

question. And maybe we can't answer that right 

now, but when we talk about phytosanitation, 

we're using that word sanitizer again, which, you 

know, in terms of the processing and food safety, 

we use these broad spectrum, nasty chemicals that 

are as bad as, you know, almost anything out 

there. 

And for nursery stock, again, I'm not 

clear, if you were growing it in a nursery stock 

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environment, using it in nursery stock 

environment, would this be still something you 

would put in the soil and you would be, you know, 

raising root stocks in the soil and then, you 

know, grafting them out? Or is this some sort of 

post-use that would be more contained? 

I just want to understand that 

distinction, because I agree with what you're 

saying about soil and systems. And I guess, is 

there a systems approach to phytosanitation? And 

that's what I don't understand and that's just my 

kind of agronomic ignorance right now. 

MR. ELA: So, I think the TR notes 

that these are soil-borne pathogens and 

nematodes. And not all nursery stock is sold as 

bare root. Oftentimes, nursery stock may or may 

not be sold in containers from plant out. 

I mean, in fact, many nurseries are 

going more in that direction away from bare root. 

So, I don't think you would -- I don't think 

there's a clear answer to your question. 

I mean, theoretically, it could be 

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applied to bare root plants, I suppose, and I 

don't really know the answer to that. But it's 

still soil-borne diseases that we're looking at. 

We need to keep moving on. I know I 

can see confounding looks, but I don't know that 

more discussion necessarily will help with it. 

Are we ready to vote on whether to 

send it back? So, Tom. 

MR. CHAPMAN: Okay. So, we have a 

motion to refer allyl isothiocyanate, or AITC, 

back to the Crops Subcommittee. The motion was 

made by Jesse and seconded by Asa. 

This is a simple majority vote and the 

voting will start with Ashley. 

MS. SWAFFAR: Yes. 

MR. RICE: Yes. 

MS. BEHAR: Yes. 

DR. SEITZ: No. 

MR. MORTENSEN: No. 

MR. ELA: No. 

MR. BRADMAN: Yes. 

DR. GREENWOOD: Yes. 

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MS. DE LIMA: Yes. 

MR. SCHWARTZ: Yes. 

MS. ROMERO-BRIONES: No. 

MS. OAKLEY: No. 

MS. BAIRD: Yes. 

MR. BUIE: Yes. 

MR. CHAPMAN: The Chair votes yes. 

MR. RICE: That is 10 yes, 5 no, zero 

absent. 

MR. CHAPMAN: All right, it's 10 yes, 

so that's a majority and the motion prevails. So 

this item is referred back to the Crops 

Subcommittee. 

MR. ELA: Emily, do you have a point 

of order? 

MS. OAKLEY: I just want to note that 

the Crops Subcommittee has a couple of pressing 

issues on our agenda, so this may not come up as 

quickly as we might like, but we do have other 

issues that are before us as well. 

MR. CHAPMAN: Yeah, I'm going to refer 

us to the policies and procedures manuals that 

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rank the order of precedence of materials, and 

petition items are up there with sunset 

materials. So petitions and sunset materials 

need to be prioritized by the Subcommittee and 

then following items from there on out. 

MR. ELA: All right, do you want us to 

continue? 

MR. CHAPMAN: Yeah, let's take break. 

It is -- what time is it? It is 3:50, so let's 

plan to do a quick break and come back at 4 

o'clock for the remainder of the Crops 

Subcommittee and the closing items. 

(Whereupon, the above-entitled matter 

went off the record at 3:51 p.m. and resumed at 

4:05 p.m.) 

 MR. CHAPMAN: All right, we're back in 

order. It's 4:05. I'm optimistic we might still 

be done by 5 o'clock, but some say I'm too 

optimistic on these things. 

MR. ELA: So, you'll buy me a beer if 

we are? 

(Laughter.) 

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MR. CHAPMAN: I'm going to hand it 

back over to Steve and we'll resume the crops 

section. 

MR. ELA: All right. Another 

proposal, sodium citrate, which is one of 

Harriet's materials, proposals. Just as a Chair 

note, this is a little odd, so, go ahead Harriet 

and we'll talk about this. 

MS. BEHAR: Who is a little odd? The 

proposal or me? 

MR. ELA: I'm talking about myself. 

(Laughter.) 

MS. BEHAR: Okay, so we did receive 

this petition in July of 2016, and because of its 

oddness it's taken us until now to really bring 

it forward. 

Sodium citrate is a salt derivative of 

citric acid. It appears on the National List as 

an approved ingredient in organic processed 

foods. It's a synthetic. 

However, the petition was for sodium 

citrate to be used as an anticoagulant in blood 

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meal. Blood meal does not appear on the National 

List because it's an approved non-synthetic. 

We typically do not review processing 

aids or secondary ingredients in crop inputs. 

So, we did talk to the National Organic Program 

about this and they said that we were petitioned 

and, in order to do our due diligence, we should 

move forward with a review. 

So, we put it out for public comment 

and we did get quite a few responses like why are 

you reviewing a processing aid in a crop input? 

There was quite a few commenters who 

stated that the National Organic Program's 

Guidance Number 5034-1 should be amended to 

address the use of processing aids. 

And, of course, we could work with the 

program on that. 

So, we did vote in Subcommittee. We 

didn't see any reason why it was a problem since 

it's a allowed in organic food. 

Other public commenters stated that 

when we have a natural product or even a 

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synthetic that's a crop input, we should have 

some overriding determination of what it is, what 

its standard of identity and then any processing 

aids would then be approved as part of that 

standard of identity. 

The other thing that this opens the 

door to is that if we approve this, and it is --

first of all, we're not really sure where it 

would be placed on the National List. 

And, second, would it then cause other 

materials to either come off the list or not be 

approved by certifiers because they have not had 

the processing aids or secondary ingredients 

reviewed. 

There was some good public comment 

about how to maybe review these processing aids, 

things like if they're allowed in organic food 

that those should be allowed. 

If they didn't -- if they just barely 

had a technical or functional effect in the final 

product, you know, it wasn't like say a 

fertilizer that this pumped up the technical 

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effect of that fertilizer. 

So, there was that type of activity in 

the public comment. 

In addition, others warned us against 

approving it all together because of the 

precedent that it would add an additional level 

of review for inputs to farm and crop materials. 

Where we're not really sure, too, if 

this is a rare occurrence or if we put this on 

the list would we get a flood of processing aids 

or not? We really didn't have the time to go 

through every material that's both natural and 

allowed as well as synthetic and on the national 

list to see if any of them had processing aids 

that would then perhaps went by the approval this 

be put on the National List. 

Lastly, we did discuss this with the 

program and we will probably have a cover letter 

either way discussing this issue with them and 

that they could deal with it on their own as far 

as deciding to not put it on the National List or 

work on guidance and update it to deal with this 

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issue. 

The other thing, too, is I have been 

referring to this as a quote, unquote, processing 

aid. But, that is really a term for food and not 

for inputs, but not really knowing how else to 

call it, I'm calling it that. 

But, technically, processing aids are 

reserved and on the definition of our regulation 

are for food or livestock feed. 

MR. ELA: And so, Harriet, I think 

that probably gives a good background. We --

I'll just add in that it, as Committee Chair, we 

brought this issue up to the Executive Committee. 

It was decided Executive Committee to 

go ahead and work on it. And, at this point, 

even though it's a bit of a quagmire, I feel 

like, as a Chair, it's my prerogative -- that we 

should not -- we should act on a petition that's 

before us and move it along. 

So, my sense is that pass it and then 

put it -- pass it on NOP and it's then their 

choice as to how they wish to deal with something 

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that isn't clear where it goes on the list and 

probably is a processing aid. 

MS. BEHAR: Right. And then, just 

making it clear that the program has heard our 

concerns that even, if and when, we do pass this, 

that they understand why we're passing it and 

that the -- and the implications of its passing. 

MR. ELA: And, that, yes, and that 

we're not necessarily advocating that it -- well, 

that we're cognizant that it's part of a natural 

material and a processing aid. 

Discussion? 

Tom? 

MR. CHAPMAN: Just to echo that the --

I am supportive of this petition but have those 

same concerns and really ask the program to 

review the precedence and repercussions of this 

type of petition before they act on our proposal. 

MR. ELA: Yes, and I will be putting a 

recommendation to that effect with the proposal 

saying that we feel this an awkward situation 

that we're really not, even though we have no 

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problem with the material, we don't want to set 

this is a disallowance of what had been natural 

materials. 

All right, if there's no further 

discussion, I think we could, certainly don't 

want to cut anybody off, but we can move to a 

vote. 

MR. CHAPMAN: Okay, so there's two 

motions, do we need -- there's two motions, I 

question whether we need this first motion, to be 

honest, Because it's goes back to the handling 

listing, but we'll do it for clarity's sake. 

So, there's a classification motion, 

motion to classify sodium citrate as a synthetic 

substance. 

The motion was made by Harriet and 

seconded by Emily. 

A yes vote is to classify the 

substance as a synthetic, a no vote is to not 

classify it. The voting will start with Scott. 

MR. RICE: Sorry, catching up a bit. 

Yes. 

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MS. BEHAR: Yes. 

DR. SEITZ: Yes. 

MR. MORTENSEN: Yes. 

MR. ELA: Yes. 

MR. BRADMAN: Yes. 

DR. GREENWOOD: Yes. 

MS. DE LIMA: Yes. 

MR. SCHWARTZ: Yes. 

MS. ROMERO-BRIONES: Yes. 

MS. OAKLEY: Yes. 

MS. BAIRD: Yes. 

MR. BUIE: Yes. 

MS. SWAFFAR: Yes. 

MR. CHAPMAN: Chair votes yes. 

MR. RICE: That's 15 yes, zero no, 

zero absent. 

MR. CHAPMAN: And, now we have a 

motion to add sodium citrate to 205.601 with the 

annotation for use as an anticoagulant in the 

production of blood meal. 

The motion was made by Harriet and 

seconded by Emily. 

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 A yes vote is to adopt this motion and 

annotation, a no vote is to reject this 

recommendation for the listing. And, the voting 

will start with Harriet. 

MS. BEHAR: Just wanted to say that it 

is currently being used and the answer is yes. 

DR. SEITZ: Yes. 

MR. MORTENSEN: Yes. 

DR. GREENWOOD: Yes. 

MS. DE LIMA: Yes. 

MR. SCHWARTZ: Yes. 

MS. ROMERO-BRIONES: Yes. 

MS. OAKLEY: Yes. 

MS. BAIRD: Yes. 

MR. BUIE: Yes. 

MS. SWAFFAR: Yes. 

MR. CHAPMAN: Chair votes yes. 

MR. RICE: Yes. 

That's 15 yes, zero no, zero absent. 

MR. CHAPMAN: The motion passes. 

Steve? 

MR. ELA: All right, our next petition 

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proposal is natamycin and I'll turn that back 

over to Harriet. 

MS. BEHAR: So, another tricky 

material. The petition was for the National 

Organic Standards Board to declare this material 

non-synthetic and then it would be allowed in 

both crops and livestock. 

However, we requested a technical 

review and found that, yes, we agree that it is a 

non-synthetic, but we're concerned by the use of 

natamycin as a human health product. 

There -- it's used in food as a mold 

inhibitor. It's used in human health to control 

fungal problems, usually in the eye and yeasts. 

There has been some resistance 

according to the technical review of candida to 

natamycin Because it is used fairly regularly in 

both breads, especially high moisture bread like 

English muffins and in things like cold packed 

cheese food and other cheeses, sliced cheeses and 

things like that. 

So, it -- and yogurt. So, it is used 

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a lot in the food supply and there has been shown 

to be some effect on human biology and bacteria -

- I'm sorry, yeast getting resistant to it. 

 So, we decided that we would then 

accept it as a non-synthetic and put a proposal 

forward to put it on the National List of 

prohibited non-synthetics. And so that is our 

proposal. 

Public comments, there were quite a 

few public advocacy groups that absolutely agreed 

that it should be both on the crops and livestock 

lists. 

Most, the Organic Produce Wholesale 

Coalition again stated they did not wish to have 

it added to the list -- I mean, to approved. 

They liked it on the prohibited non-synthetic 

list. 

There was discussion about that it 

could kill beneficial fungi in the environment. 

And there -- also, that I also reached out, 

because part of the petitioner's public written 

comment was some letters from mushroom growers 

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that find it very useful in the control of dry 

bubble disease. 

So, I may sound like I know a lot 

about a lot of things, well, I don't know 

anything about dry bubble disease in mushrooms. 

But, I did reach out to Tina Ellor who 

is a former member of the National Organic 

Standards Board, a mycologist and knows quite a 

bit and is in contact with many organic mushroom 

growers, especially on the East Coast. 

And, she stated that in their 

conventional side, they do use natamycin, but 

they have been able to get by quite well without 

it on their organic side and that she did not 

consider it a necessary material for their 

organic mushroom production. 

She stated that it's been a 

challenging couple of years for flies and 

diseases and that she interviewed some of her 

growers and it came back that there was not any 

issue. 

She said the only products we use 

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fairly routinely are oxidate and a couple of 

different fly control products that they rotate. 

They make good management and 

exclusion their front line defense. And, that's 

a quote from her email. 

So, that's where we sit with natamycin 

with the Subcommittee did discuss this over 

numerous conference calls and I believe it was a 

unanimous motion to list it both as a nonsynthetic and then put it on 602 as a prohibited 

non-synthetic substance in crop production. 

And, as I said before, there were 

quite a few public commenters that said that we 

should also add it to the livestock prohibited 

list because it is used in control of yeasts and 

molds in livestock feed. 

MR. ELA: Discussion? 

Emily? 

MS. OAKLEY: Yes, I did talk to some 

organic mushroom growers in my region and they 

had never heard of this product. 

The petition did approach me 

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privately, but I can't remember everything that 

they said. I know that they approached many 

other people as well. 

But, I did not hear from those 

mushroom growers although it was a small sample, 

any need for this. 

MR. ELA: Ashley? 

MS. SWAFFAR: Yes, so I was just 

looking at the petition. They didn't classify 

where they would want this petition to, but 

obviously, they submitted this petition hoping to 

use it in organic production. 

What is the precedence of this Board 

receiving a petition and then putting it on the 

restricted list? Has it ever been done before, 

Tom? 

MR. ELA: Tom? 

MR. CHAPMAN: I can't answer that 

directly. What I can say is we often receive 

petitions and change where we list it or how we 

list it. 

An example while we were on the Board 

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was glycerin was petitioned to be removed and 

then we recommended its placement on 606 with a 

different annotation. 

So, that's an example of it comes to 

us, but then, once it's kind of in our purview, 

we decide how to handle the substance. 

MR. ELA: And, I think this one was 

unique in the sense of -- well, I mean, 

everything's unique, but interesting in the sense 

that once we vote that it's non-synthetic, it's 

out of our purview. 

I mean, it can be used, because it's a 

crop substance, it's non-synthetic then it's open 

field. So, it's a little different than a 

handling or another substance. So, that -- I 

think that's where we decided to take kind of the 

unusual, you know, I don't know if it's rare, but 

unusual step. 

Harriet? 

MS. BEHAR: A couple things. So, I 

neglected to state, in cheese and breads which 

are retail packaged. It will appear on the 

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label. So, a consumer will see that natamycin 

typically with parentheses, a natural mold 

inhibitor is what's written. 

However, for what they had asked for 

used in mushroom production or post-harvest 

handling of fruits, that would be -- would not 

appear on any label that a consumer would see. 

We did ask the petitioner on the 

webinar and he stated that, if you're in Japan, 

there'd be a sign, but nothing is required here. 

And, I think that transparency is 

extremely important and we don't have that. 

MR. ELA: Tom? 

MR. CHAPMAN: I'm going to put Lisa on 

the spot here in a second, she can decline to 

answer, but I'm curious to know if MOM's allows 

this substance in food products and, if not, what 

was the reasoning behind that ban? 

MS. DE LIMA: I don't have the 

reasoning in front of me, but we don't allow it. 

So, where we would see it crop up are the places 

that Harriet said, cheese and bread. 

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And, I'm not going to say any names, 

but I don't think we're the only retailer that 

does that. I think that's pretty common 

throughout all the natural --

MR. CHAPMAN: Pretty common for the 

retailers to have the list, but you don't. I 

cared less about that, I cared more about the 

reasoning and you don't know that off the top of 

your head? Okay. 

MR. ELA: I reached out to another 

retailer as well. I mean, I asked Lisa first, but 

I am aware that disallow it in processed foods. 

And, said, you know, so what would 

your policy be and, you know, if you don't allow 

it over here, would you allow it over there? 

And, they didn't give me a definitive answer. 

The answer was essentially, it's 

unlikely we would like it, you know, if we're not 

allowing it one spot, we're probably not going to 

allow it in the other spot. 

MR. CHAPMAN: But, do you know why 

they're not allowing it? 

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MR. ELA: I could not -- I mean, they 

didn't give me that answer. It was more just a 

matter of, you know, even just basic protocol if 

you don't like it one place, they don't want to 

get caught in a double standard. 

So, Harriet? 

MS. BEHAR: I just want to reiterate, 

if it's approved as being requested for use, a 

retailer, unless they reached out to every grower 

would not be aware and every mushroom producer 

that it had been used or not. 

And, of course, it may not be used on 

every lot every time. So, there would have to be 

continuous interaction with the suppliers to find 

out if it had been used. 

Or, I suppose retailers could just say 

we don't want you to but there would be no way of 

checking or verifying that. 

MR. ELA: And, I'll just say one final 

comment as a fruit grower who stores fruit and 

that is up on the list. I mean, I was personally 

conflicted by this because there are times I 

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could really see it. 

It would be very useful in my 

operation. The human health side, though, is 

even though it may be a very small use, there's 

precedent on this Board for not using antibiotics 

that have potential in human use such as some of 

the light ones, so I feel to be consistent, I 

have to kind of go with that, even though, from a 

personal standpoint, this is attractive. 

One last comment, Tom? 

MR. CHAPMAN: Yes, I mean, I do want 

to note that we had that one comment from the 

pickle producer. It was unclear from those 

comments where in the supply chain he was looking 

to have natamycin used. 

I mean, it was potentially he was 

looking at a post-harvest application. But, he 

also talked about the potential of using it in a 

processing application which, if that was a 

methodology that he wanted to us it would need to 

be also on 205.605(a) I believe. It would need 

to be on one of the lists or it would need to be 

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organic natamycin. 

So, just to note that that wasn't a 

full usage if they're using it in the processing 

portion of their operation. 

MR. ELA: Yes, it depends where they 

use it. 

All right, I think we -- if there's no 

further substantial discussion, we should move 

towards the vote. 

MR. CHAPMAN: All right, so we have a 

motion to classify natamycin as a non-synthetic 

substance. 

The motion is -- comes from the 

Subcommittee from Harriet and seconded by Emily. 

A yes vote is to classify natamycin as 

non-synthetic, a no vote is to not classify the 

material and the voting will start with Dan. 

DR. SEITZ: Yes. 

MR. MORTENSEN: Yes. 

MR. ELA: Yes. 

MR. BRADMAN: Yes. 

DR. GREENWOOD: Yes. 

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MS. DE LIMA: Yes. 

MR. SCHWARTZ: Yes. 

MS. ROMERO-BRIONES: Yes. 

MS. OAKLEY: Yes. 

MS. BAIRD: Yes. 

MR. BUIE: Yes. 

MS. SWAFFAR: Yes. 

MR. RICE: Yes. 

MS. BEHAR: Yes. 

MR. CHAPMAN: The Chair votes yes. 

MR. RICE: That's 15 yes, zero no, 

zero absent. 

MR. CHAPMAN: Motion passes. 

We also have a motion to add natamycin 

to 205.602, non-synthetic substances prohibited 

for use in organic crop production. 

The motion is -- was made by Harriet 

and seconded by Emily. 

So, a vote here would be to recommend 

the addition of this substance to the prohibited 

list to prohibit its use in crop production, a no 

vote would be to not list it which would allow 

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its use in crop production and given the 

classification. 

The voting will start with Dave. 

MR. MORTENSEN: Yes. 

MR. ELA: Yes. 

MR. BRADMAN: Yes. 

DR. GREENWOOD: Yes. 

MS. DE LIMA: Yes. 

MR. SCHWARTZ: Yes. 

MS. ROMERO-BRIONES: Yes. 

MS. OAKLEY: Yes. 

MS. BAIRD: Yes. 

MR. BUIE: Yes. 

MS. SWAFFAR: Yes. 

MR. RICE: Yes. 

MS. BEHAR: Yes. 

DR. SEITZ: Yes. 

MR. CHAPMAN: Chair votes yes. 

MR. RICE: That's 15 yes, zero no, 

zero absent. 

MR. CHAPMAN: The motion passes. 

Steve? 

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 MR. ELA: all right, next up, a 

proposal strengthening the organic seed guidance 

of October 2018. 

I'll let Harriet go in to review the 

public comment. But, there are some changes to 

this proposal. 

MS. BEHAR: So, this -- there was many 

comments on the proposed guidance and many of 

them did not agree with each other. So, there's 

still not consensus in the public on the 

guidance. 

So, we're going to bring forward those 

sections of the proposal have been removed. 

However, there was almost universal public 

agreement with moving forward on the regulatory 

language which can be done on its own. 

So, again, I encourage you to, in the 

public docket, start writing up your comments so 

as soon as it's open, because it'll only be for 

two weeks or so to get us some information on 

that. 

I know we're a little pressed for 

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time, but I just want to answer a few of the 

points that public commenters made. 

There was some comment about adding, 

that we timely ordering of seed. And, I 

specifically did not put that in there because 

while it's a good practice to order organic seeds 

as early as possible, there are times when other 

constraints might prevent that from happening 

such as many farmers use operating loans obtained 

in the spring and so they wouldn't have the funds 

to purchase their seed until spring. 

In addition, farmers are now being 

very cautious based upon the extreme weather 

conditions that we are now facing and they want 

the flexibility to purchase seed that would then 

they'd be able to assess their current conditions 

before they plant. 

There was concern that the allowance 

for horticultural growers to review seed 

catalogues for characteristics that they're 

looking for was not necessary, that that there 

was a discussion about you could use variety 

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trials or horticultural growers could be looking 

at catalogues. 

The reason for that was is that many 

horticultural growers could grow 50 to 200 

varieties like I do on my farm and, if I'm using 

60 percent non-organic seed, then I would have a 

heck of a lot of -- I would have to basically 

have my whole farm be variety trials. 

So, I was trying to give some 

allowance to people who are doing small amounts 

of a whole variety of different things. 

So, might change that wording a little 

bit but I just want to be able to -- but the 

point was is to have them be looking at the 

characteristics that they are seeking out so they 

can actually be judging whether or not the 

organic varieties that are out there are 

equivalent because they need to be not just 

looking at the actual variety name, but the 

equivalency to what they want to grow. 

There was concern about the number of 

five seed suppliers need to be found and 

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discussed if they had organic seed or not versus 

three. 

There was strong support for up to get 

five. There was strong support for having none. 

So, I don't know, we'll find the middle ground on 

that, but I don't think it will be four. 

And, I'll see what the best and also 

the Subcommittee to see if we can find some kind 

of common ground to encourage the growers to be 

really seeking out more. 

And, we have learned out over time --

learned over time that requesting organic seed 

from non-organic seed suppliers does stimulate 

the production and availability of more organic 

seed as those suppliers learn that there is a 

market for it. 

There was, lastly, you'll be happy to 

know, there was discussion about how to help 

certifiers really understand what improvement is 

when seeking out organic seed. And so, I made a 

note of that, that in the next guidance we'll try 

to be giving --

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 And, some certifiers did give some 

activities that could be used for actually 

saying, yes, there has been improvement or there 

has not. 

Be assured that all the comments that 

are current -- that have been given will be taken 

into account and that's not just from this 

proposal but I will keep going back to the 

previous ones and feel free, of course, to submit 

further comments. 

MR. ELA: All right, comments? 

Tom? 

MR. CHAPMAN: Just a note that we'll 

need to make a motion on that -- on those 

amendments. 

MR. ELA: Yes. 

MS. BEHAR: Yes, we'll be -- so, we're 

just going to come forward with the regulatory 

change. 

MR. ELA: Right, you'll need to make a 

motion to do that. 

MS. BEHAR: Oh okay. Okay. 

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MR. ELA: Do you want -- as point of 

order, do you want that motion and then 

discussion? 

MR. CHAPMAN: I think we can discuss 

it and then we can make the series of motions. 

MR. ELA: Okay. 

Emily? 

MS. OAKLEY: I think one of the 

greatest keys to success in vegetable crop 

production is variety selection. I think that 

most, if not all, vegetable producers are doing 

extensive on farm trials. 

There's a limit to the number that you 

can do in a growing season and be successful and 

keep track of them effectively to determine your 

results. 

But, I also want to say that while 

we're all striving for continuous improvement, we 

also rely on the varieties that we've chosen over 

many years of production because they are 

successful for us. And, I appreciate the work 

that you've done on this. 

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mean, on the horticultural side, too, it gets 

complicated especially in perennials because 

we're dealing with a root stock and a variety, so 

it's not just a variety selection. 

The characteristics of the root stock 

often affect, I mean, a gala tastes like a gala 

regardless, but the whole tree is very different, 

depending on the bottom. So, it gets a little 

more complicated in terms of access and choices. 

I mean, essentially, there is very 

little organic perennial material out there for 

reasons we've already talked about. 

But, it's not an easy nut to crack. 

Conversely, you're planting a perennial so you're 

talking about a non-organic thing that's out 

there for a year and then is the next 20 or 30 

years is organic. So, it's not quite the same as 

rotating a crop every year, either. 

I think it does -- I think it is a 

different -- there are different issues there. 

Other discussion? 

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 (No audible response.) 

MR. ELA: It seems like we should have 

a motion to amend the document that was sent 

forward. 

MS. BEHAR: Yes, so I would like to 

make a motion that the guidance be removed from 

the document and from the proposal to be sent 

back to Subcommittee. 

MS. OAKLEY: I'll second. 

MR. CHAPMAN: We have a motion and a 

second. 

The motion to remove the guidance 

references and to look at that, it's magic, it 

shows up on the screen. 

And then, just for the sake of 

clarity, we also have the full proposal, can you 

project that, Michelle? 

Well, yes, we'll be voting on a motion 

to amend and then we'll be motioning, if that 

motion passes, then we'll be putting on the 

amended proposal. 

All right, so, and if you could just 

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slowly scroll down? 

You'll see we removed the sections 

referring to -- keep scrolling -- we removed the 

sections related -- keep scrolling -- related to 

-- keep going, just keep, yes, yes -- related to 

guidance and we left the sections that were 

related to -- keep going -- that were related to 

the -- is it all showing up -- it's coming, all 

right -- there we go, all the cuts out related to 

guidance -- so keep going down, keep going, go 

until we reach the bottom. 

And there we are, so the motion as 

amended, we can go back to the --

MR. ELA: I'm glad we left the title 

in there. 

MS. BEHAR: Yes, so, I just want to 

say that I had hoped to get this over the finish 

line, but this is obviously an area that the 

community is very passionate about and very 

passionate about if it's a comma or a period or 

an and or an or. And so, we want to get it 

right. 

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MR. CHAPMAN: Yes, we'll probably take 

a prerogative to fix the title in the back end. 

But, the motion is what we're looking 

at right now. 

So, it's the motion -- the amendment 

before us is to delete certain words to make the 

motion read motion to accept all the additions as 

described in the proposal section above to the 

National Organic Program regulation. 

The motion -- the amendment was made 

by Harriet and seconded by --

MR. ELA: Emily. 

MR. CHAPMAN: -- Emily. 

MR. ELA: Emily. 

MR. CHAPMAN: Emily, Dave, Emily, 

Emily? 

MR. ELA: No, the amendment was 

seconded by -- wasn't it? 

MR. CHAPMAN: Emily, yes. Seconded by 

Emily. 

A motion to amend is a simple, only 

requires a simple majority and a yes vote is to 

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accept this amendment, a no vote is to reject the 

amendment and the voting will start with Steve. 

MR. ELA: Yes. 

MR. BRADMAN: Yes. 

DR. GREENWOOD: Yes. 

MS. DE LIMA: Yes. 

MR. SCHWARTZ: Yes. 

MS. ROMERO-BRIONES: Yes. 

MS. OAKLEY: Yes. 

MS. BAIRD: Yes. 

MR. BUIE: Yes. 

MS. SWAFFAR: Yes. 

MR. RICE: Yes. 

MS. BEHAR: Yes. 

DR. SEITZ: Yes. 

MR. MORTENSEN: Yes. 

MR. CHAPMAN: Chair votes yes. 

MR. RICE: That's 15 yes, zero no, 

zero absent. 

MR. CHAPMAN: The motion passes and 

the main motion is now amended. 

Any further discussion on the main 

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motion? 

(No audible response.) 

MR. CHAPMAN: Otherwise, we'll proceed 

to a vote. So, the motion? Yes. Do you want to 

read it, want me to read it? 

MS. BEHAR: I just wanted to read it 

that the --

MR. CHAPMAN: The motion is to accept 

all additions described in the proposal sections 

above to the National Organic Program regulation. 

(Off microphone comments.) 

MR. CHAPMAN: Okay, so the amended 

motion was originally -- the main motion was 

presented by Harriet and seconded by Dave. 

And the voting will start with Asa, a 

yes vote is to adopt the amended motion. 

MR. BRADMAN: Yes. 

DR. GREENWOOD: Yes. 

MS. DE LIMA: Yes. 

MR. SCHWARTZ: Yes. 

MS. ROMERO-BRIONES: Yes. 

MS. OAKLEY: Yes. 

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MS. BAIRD: Yes. 

MR. BUIE: Yes. 

MS. SWAFFAR: Yes. 

MR. RICE: Yes. 

MS. BEHAR: Yes. 

DR. SEITZ: Yes. 

MR. MORTENSEN: Yes. 

MR. ELA: Yes. 

MR. CHAPMAN: Chair votes yes. 

MR. RICE: That's 15 yes, zero no, 

zero absent. 

MR. CHAPMAN: Motion passes. 

Steve? 

MR. ELA: That concludes the proposal 

section -- voting section. 

So, we have three discussion documents 

which are petitions that are before us but which 

we haven't yet received TRs or haven't made a 

formal proposal. 

The first one is a discussion document 

on ammonium citrate and ammonium gycinate. Dave 

and Emily are co-working on this. 

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Dave, do you want to take it? 

MR. MORTENSEN: Yes, so, these two 

compounds manufactured by a company by the name 

of Alpha Chelates, they submitted these two 

compounds for us to consider in the Subcommittee 

as agents that would help deliver micro nutrients 

to the soil for plant uptake. 

They -- these chelates, then, which is 

the micro nutrient and the compound that this 

company was applying for addition to the national 

list at 205.601, this dates back to 2016. 

The Board concluded that alternatives 

existed back in the fall of 2016 and the 

applicant pursued several, well four now, addenda 

to have -- in which they pointed out that the 

Board didn't understand our inorganic chemistry 

basically. 

And, was pleading for us to take a 

more critical look at this on these two 

compounds. 

And, they were pointing to other 

compounds, one of which we had said was the 

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alternative and were basically making an argument 

that we were misapplying language about what is a 

chelating agent and what is a chelated compound, 

the combination of the micro nutrient and the 

chelating agent. 

We spent a good bit of time, actually, 

a great deal of time, and Emily was spearheading 

this and I agreed to help co-spearhead it. 

And most recently, we requested a 

technical report on this to help sort out the 

chemistry. 

A number of us also consulted some 

chemists in our local work spaces and we are now 

at a point where a proposal will be developed 

that will be three-staged. 

The first stage of the proposal will 

be to clarify ambiguous language around chelating 

agents and chelated materials. 

And the technical report, we just 

received will be very helpful in forming that 

first stage. 

The second stage is that future sunset 

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reviews and new additions to the list, we would 

be applying this clarified language about 

chelating agents and chelants. 

And, in the third phase, we will 

complete the review of these two compounds, 

ammonium citrate and ammonium glycinate. 

And, that is what I've got for now. 

MR. ELA: Discussion among the Board? 

A somewhat technical discussion 

document, but one that we've received a fair 

amount of information from the petitioner, so 

we're hoping to move that forward. 

All right, if there's no other 

discussion on that, the next discussion document 

is calcium acetate. 

Calcium acetate is basically being 

petitioned for use as a nutritional supplement. 

While a number of other calcium products exist on 

the market, calcium acetate acts more -- much 

more quickly and may actually help with plant 

nutritional disorders. 

So, the other thing that it can be 

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used for is to prevent sun scald, so it can be 

sprayed on top of plastic to reduce heat load or 

in other uses to help reduce sunburn on plants. 

Basically, we -- the public comments 

from it kind of echoed those items, that it can 

be used as a plant or soil amendment, that it can 

protect crops against sun damage. 

Basically, one comment was that if we 

do add it, it should be annotated for use as a 

foliar spray to treat a physiological disorder 

associated with calcium uptake. 

Another comment was though -- although 

calcium acetate is a synthetic, it's production 

from non-synthetic vinegar and natural calcium 

carbonate aligns closely with other crop inputs 

currently on the national list. 

So, it's synthetic, but it's very 

similar to some of the natural materials. 

And then, another comment was 

essentially that it made no sense to use a sun 

scald protection if you're applying black plastic 

which is a synthetic material and then you need 

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another synthetic material to reduce the effects 

of the first synthetic material, that that's --

they didn't say it, but that's called a 

treadmill. 

So, just that pointing out that we 

shouldn't be approving materials that -- we may 

might want to look at the original material to 

start with. 

So, that's that in a nutshell. I 

don't know if there's any discussion, but it will 

probably be appearing next meeting as a proposal 

as well. 

Any discussion? 

(No audible response.) 

MR. ELA: Okay, and finally, this is 

the easy on to end on, you know, not much public 

comment, the paper pots. 

And that, I'll turn over to Harriet. 

MS. BEHAR: So, I did make extensive 

notes of all the public comments, but I think 

we've all heard quite a bit of public comments on 

this about, you know, comparing it to newspaper 

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and recycled paper and virgin paper and adding to 

the list, adding and expanding it to include 

other paper-based production aids. 

We did hear from a second manufacturer 

which is one of the questions that we did ask on 

the petition, although it's not a paper chain 

pot, but the Ellepot is another type of paper 

made in Denmark. 

I was actually very impressed with the 

number of personal letters that were sent in, 

testimonials from farmers on the importance of 

this material. 

Also, the numerous certifiers who do 

not allow its use but were in favor of allowing 

the grace period for use until the National 

Organic Standards Board has its chance to review 

it. 

So, we're going to go right to a 

resolution and I will read it. The NOSB thanks 

the NOP for enforcing the national list and for 

its close review of this issue. 

Paper pots are not explicitly listed 

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on the national list and, therefore, its usage as 

a production aid can be confusing. 

Different certifiers have viewed this 

differently with decisions made in good faith and 

with equally compelling perspectives. 

In the opinion of the NOSB, paper pots 

that may include virgin paper and adhesives are 

used as a nursery production aid like many other 

types of pots. 

At the time of field planting, the 

paper should be considered used and, therefore, 

recycled since they have been used in the 

nursery. 

If this paper material is applied to 

the field, it could then be considered a recycled 

paper for use as a mulch. 

Based on comments received at the fall 

2018 NOSB meeting, we have heard universal 

support for this material and this application. 

Its moratorium on usage will create a substantial 

financial burden on those growers who have used 

this system in good faith with the consent of 

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their certifiers. 

We understand that the national list 

could be clearer in this regard and the National 

Organic Standards Board is in the process of 

considering a petition on paper pots. 

Be it resolved, by unanimous vote, to 

ensure a full and timely review of paper pots, we 

request the National Organic Program allow the 

continued use of paper pot usage while this 

review and potential rulemaking proceed. 

We believe the interpretation offered 

in this resolution allows the program to take 

this path while maintaining fidelity to the 

existing regulations that the program is charged 

with protecting. 

MR. CHAPMAN: I have a motion for a 

resolution. Is there a second? 

MR. ELA: Dave. 

MR. CHAPMAN: I'm waiting for somebody 

here to say second. 

MR. MORTENSEN: Second. 

MR. CHAPMAN: Thank you, Dave. 

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We've got a motion and second, is 

there any further discussion on this item? 

MS. OAKLEY: I would just still 

encourage those who would like to elevate this 

issue to the Secretary and Undersecretary level 

to go ahead as needed with letters. 

Thank you. 

MR. MORTENSEN: I would also just like 

to thank all the folks that have reached out to 

the Board and also to the Board itself for 

collaborating on the resolution. 

MR. ELA: And, I will echo what Emily 

says, I think it's been very unclear to me of the 

farmers out there along with others that it feels 

like when we submit comments to the NOSB that we 

have done our due diligence. 

The reality is that the NOP does not 

read those comments, we do. And so, I would echo 

Emily saying the comments you made to the NOSB as 

growers and especially about the financial burden 

of this do send those letters to the Secretary 

and Undersecretary. 

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It's a stamp or an email and I can't 

reiterate how important those could be to helping 

you with this process. 

With that, I think we should vote on 

the -- go ahead, Tom. 

MR. CHAPMAN: Before we vote, I had my 

hand up to say something else. 

MR. ELA: Yes. 

MR. CHAPMAN: I also appreciate that 

this resolution acknowledges the NOP's role in 

strict interpretation of enforcement and that's 

something we like. 

But, sometimes, there are confusion --

there is confusion in the standards. That's 

happened more often that we would like it to, 

particularly in the complex interpretation of 

materials. 

And so, I do think this flexibility is 

prudent. So I hope this can potentially lead a 

path forward on this item. 

MR. ELA: Yes, and I think we do 

applaud, we want strict enforcement of the list 

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and this is such a gray area, depending on how 

you look at it. 

To me, the universal acceptance of 

people making comments, including those 

certifiers that didn't necessarily approve it is 

telling. 

MR. CHAPMAN: Seeing no further 

discussion, we'll proceed to a vote on the 

resolution and the motion at hand. 

The motion is before you, and a yes 

vote would be to adopt this resolution, a no vote 

would be to not adopt this resolution. The 

voting will start with Rick. 

DR. GREENWOOD: Yes. 

MS. DE LIMA: Yes. 

MR. SCHWARTZ: Yes. 

MS. ROMERO-BRIONES: yes. 

MS. OAKLEY: Yes. 

MS. BAIRD: Yes. 

MR. BUIE: Yes. 

MS. SWAFFAR: Yes. 

MR. RICE: Yes. 

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 MS. BEHAR: Yes. 

DR. SEITZ: Yes. 

MR. MORTENSEN: Yes. 

MR. ELA: Yes. 

MR. BRADMAN: Yes. 

MR. CHAPMAN: Chair votes yes. 

MR. RICE: That's 15 yes, zero no, 

zero absent. 

MR. CHAPMAN: The motion passes. 

MR. ELA: Tom, I'd like to add in just 

on the final comments on this that we did listen 

carefully to one of these issues as we cannot 

approve a product, we are approving materials. 

And, I think the comments of paper in general as 

a planting aid, whether it's the seed strips or 

whatever, that we take those -- that actually 

that as we look at it, we may look at that 

broader use of paper as a planting aid. 

And, that may actually help us kind of 

proceed on this topic so that we're thinking 

broader based. 

My one concern is I really wrestle 

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with the adhesives, especially added after the 

paper is made. And so, I would really appreciate 

any feedback as stakeholders on the open docket 

or to the Committee somehow of how we can make 

sure that we allow a very appropriate use of this 

technology and whatever form. 

And also, don't make it so broad that 

we end up with unintended consequences of 

allowing materials we -- none of us really want 

on our soils. 

MR. CHAPMAN: And, to echo on that, 

just I also hope that if the NOP does take action 

like we're asking on this, it would actually 

potentially free up the Subcommittee to put the 

sufficient time and thought into this instead of 

trying to rush through to protect the one 

application that we may appreciate without 

thinking of all the potential applications of 

this material. 

MR. ELA: If there is no other 

discussion, then that finishes the Crops 

Subcommittee section of the program. 

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 Thank you to the Crops Subcommittee, 

it was a long docket this time. You guys did a 

great job. 

And, it's before 5:00. 

MR. CHAPMAN: All right, thank you, 

Steve. That concludes the Subcommittee portions 

of the agenda. 

And, looking at the agenda, it's the 

next section is deferred proposals and final 

votes. We have no deferred proposals or final 

votes, so we'll proceed to the work agenda item 

and I am going to sit over by Michelle's desk to 

run through the work agendas. 

We will be publishing this later, so 

okay, so first up on the upcoming work agenda 

will be 2021 sunsets. This is the last year of 

the sunset reorganizations. 

The sunset reorganizations are quite 

long, so it is here, it's also published in the 

proposal on the reorganization of sunset 

materials. 

Okay, we're now going to run through 

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non-sunset items by Subcommittee. 

So, first up is CACS and we continue 

to have the import oversight item on our work 

agenda. Definitely the update from the spring 

2018 public comments will be planning to come 

forward. 

Scott, do you have any other ideas off 

the top of your head putting on the top of what 

the Subcommittee might take this agenda item 

further? 

MR. RICE: We're still I think on the 

heels of what we've just worked on in this 

meeting. Might take a look at what just in 

general what other aspects we can dive into 

whether it's building on further risk factors or 

there was some mention of developing something 

similar as risk factors for certifiers and 

certified operations. So, that's an idea as well. 

MR. CHAPMAN: And, after the last 

meeting, we regrouped with the program and 

identified the best areas for us to work on for -

- on this subject area in the last semester and I 

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think we'll do probably the same here as well to 

get there. 

Thinking on where NOSB work would be 

most helpful. 

Up next is Crops and so, all the 

materials discussion documents, we are expecting 

that those will come forward as petitions for 

votes including the AITC that was pushed back. 

We also have a work agenda item to 

review the annotation -- to review a 

recommendation for an annotation on liquid fish 

products. 

The biodegradable based mulch is still 

on there as a TBD and then we sent the guidance 

portion of the genetic integrity of seed grown on 

organic land back as well. 

Up next is Handling. So, Handling has 

the silver dihydrogen citrate petition that was 

sent back to it as well as the two petition 

discussions that we discussed, pullulan and 

collagen. 

Livestock Subcommittee has one 

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petition for oxalic acid. That was also a 

petition discussion here. 

MS. SWAFFAR: Tom, can I say something? 

MR. CHAPMAN: Yes. 

MS. SWAFFAR: so, also we do have a 

work agenda request in for vaccines made from 

excluded methods. So, hopefully, we might be 

adding that to our work agenda. 

But, we have some pretty hefty sunset 

items including my favorite material, methionine. 

MR. CHAPMAN: Okay. And then, on 

Materials Subcommittee, we have the marine 

materials item that may or may not come forward 

for a vote at the next meeting. 

We have the excluded methods ongoing 

work. We have research priorities that we 

discussed bring forward as a discussion document 

to get feedback at an earlier stage, the genetic 

integrity transparency that was sent back as well 

as the sanitizers work agenda item. 

The sanitizers item is still in its 

initial stages, so I -- we don't expect to have 

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something at the spring meeting in terms of a 

discussion document or a vote, is that correct? 

MS. BEHAR: Yes, I think by then we 

will have decided what we want in the TR and will 

have probably initiated it, but probably won't be 

back by spring. 

MR. CHAPMAN: Then we have been 

collecting some minor changes that we've made 

related to the policies and procedures manual, 

best practice of petition discussion documents 

being one. 

We've also assigned some petition 

responsibilities to the role of the Secretary, 

namely to monitor the open docket and notify the 

rest of the Board if something comes forward. 

So, I think we have enough parking lot 

items that we'll probably reconvene the Policy 

Subcommittee to bring forward those changes in 

the policies and procedures manuals as well as 

fix up some conflicting sections that are in 

there currently. 

And, that is the totality of the --

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what we expect to bring forward at the spring 

meeting. 

Any questions from the Board? 

(No audible response.) 

MR. CHAPMAN: Then, I believe this 

document gets published after the executive 

calls, is that correct? Yes, so, look for that 

for updates as this changes. 

Clearly, this is our best thinking on 

what will happen. But as we proceed through the 

year, you know, time will tell what we can 

actually bring forward or what information we 

have for the spring meeting. 

Okay, so up next, we have officer 

elections. And, I'm going to ask Michelle to put 

up some slides of the officer elections sections 

of our policies and procedures manual. 

So, I'm just going to read through 

this briefly. 

So, in the election of officers, we 

first start with nominations. Any NOSB member is 

eligible for consideration for any officer 

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position. 

And, members may self-nominate or be 

nominated by another member of the NOSB. Members 

are also able to serve more than one term in any 

officer position, but I think it's missing here 

that you can't serve for three years or more. 

Officers will be elected to a one year 

term by a majority vote. 

Newly elected officers assume their 

positions at the conclusion of the fall meeting 

and assume all the responsibilities thereof at 

that time. 

I was unaware of this, but I guess 

outgoing NOSB officers will assist incoming 

officers with the transition through their new 

roles to be completed no later than January 23rd 

of the following year. Man, did I think I was 

out. 

Votes will be by secret ballot. We 

start with the Chair then proceed to the Vice 

Chair and the Secretary. 

The secret ballot that we use are 

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these handy dandy cards. 

Ballots will be counted for one office 

at the time and it's generally done with the 

Secretary and the Vice Chair, although, if those 

members are nominated for the office, then we 

will select from other members of the Executive 

Subcommittee just to prevent conflicts of 

interest. 

We do require a majority vote, so the 

first nominee that receives the majority of the 

votes will be elected. But, if there's a 

plurality then the candidate receiving the least 

number of votes will be removed from running and 

we will re-vote for that position until a nominee 

receives the majority. 

In the event of a tie, there will be a 

re-vote and re-vote and a re-vote and a re-vote 

until someone finally gets a majority. 

The votes will remain confidential and 

the ballots will be disposed of and a nominee, 

unfortunately, may withdraw their name at any 

time, but not once you're in office. 

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And, in the event of only one nominee, 

then we won't need to use the cards, we will just 

vote by acclamation. 

Are there any questions from Board 

members about the procedures? 

Okay, at this time, then I am going to 

pass down the blue cards. Please take one and 

pass it along. And, these will be for Chair. 

So, at this time, we will open it up 

for nominations for Chair. 

Emily? 

MS. OAKLEY: I nominate Harriet for 

Chair. 

MR. CHAPMAN: All right, we have one 

nominee for Chair. 

Need to speak into the mic, Eric. 

MR. SCHWARTZ: Sorry, I nominate Scott 

for Chair. 

MR. CHAPMAN: All right, we have two 

nominees for Chair. 

Do the nominees want to keep their 

names in? 

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anyone can withdraw at any time? 

MS. BEHAR: I guess I want to clarify 

that I did not offer the pies as bribery. 

MR. BRADMAN: Do the nominees want to 

say anything? 

MR. CHAPMAN: We don't normally have 

the nominees speak, but if they want to, we can. 

Otherwise, we'll just proceed to a vote since the 

Chair -- since the Vice Chair and the Secretary 

are both running, I'm going to ask Steve, the 

Crops Chair, if you don't mind, counting the 

votes with me and collecting the votes. 

(Off microphone comments.) 

MR. CHAPMAN: Okay, so, write down the 

votes and then we'll pick them up. Steve, maybe 

you can get that side, I'll get this side. 

(Voting by secret ballot.) 

MR. CHAPMAN: All right, we have a new 

Chair, Harriet. 

(Applause.) 

MR. CHAPMAN: Okay, next up is Vice 

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Chair, nominees for Vice Chair? 

Harriet? 

MS. BEHAR: Steve. 

(Off microphone comments.) 

MS. SWAFFAR: I'd like to nominate 

Scott. 

MR. CHAPMAN: We got a nomination for 

Scott. 

Oh, I need to pass out the cards. 

MR. CHAPMAN: Okay, anyone else? 

Sorry, I had to pass the cards. 

(No audible response.) 

MR. CHAPMAN: No? All right, so, on 

this one, I'm going to ask Harriet to count the 

votes with me. 

So, it's Scott and Steve. 

(Voting by secret ballot.) 

MR. CHAPMAN: And we have a new Vice 

Chair, Steve. 

(Applause.) 

MR. CHAPMAN: And, up last, the 

position of Secretary. 

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Oh, come on. 

Yes? 

MS. SWAFFAR: I would like to nominate 

Scott. 

(Laughter.) 

MR. CHAPMAN: We've got Scott, anyone 

else? 

All right, seeing no one, I think we 

can do this one by the good old fashioned 

acclamation. 

Here, here. So, let's give a round of 

applause for our new officers, Harriet as Chair, 

Steve as Vice Chair and Scott as Secretary. 

(Applause.) 

MR. CHAPMAN: We will now move on to 

other business. 

(No audible response.) 

MR. CHAPMAN: Seeing none, then I 

think we can move to adjournment, 5:16 enough for 

you? 

MS. BEHAR: I would like to say 

something. 

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MR. CHAPMAN: All right, I guess we've 

got some things to be said. I guess I'll start 

with Harriet and then --

MS. BEHAR: Well, I would like to very 

much thank Tom for his two years of leadership. 

It's going to be difficult, I'm going to study 

the transcripts on how you've run the meeting to 

try to run them as smoothly and evenly and really 

encourage interaction and a lot of good debates. 

So, I really appreciate your time as 

Chair, thank you very much, Tom. 

MR. CHAPMAN: Thank you, Harriet. 

(Applause.) 

MR. CHAPMAN: And I look forward to 

sitting down in the cheap seats at the end. 

So, Emily or A-dae, you're going to 

have a new person chatting your ear off. 

Jenny? 

DR. TUCKER: So, a couple of closing 

comments. I want to first welcome our new 

officers to their new roles. So, congratulations 

to all of you, we look forward to working with 

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you, so thank you very, very much in advance for 

your service and for all your service to date. 

So, let's give them another round. 

(Applause.) 

DR. TUCKER: I'd like to thank the 

entire Board. Obviously, this is a very intense 

time of your lives in addition to these three 

days, the dedication and devotion and time that 

you put into this work is just tremendous. 

So, let's give a round to the Board. 

(Applause.) 

DR. TUCKER: Let us thank the audience 

for being here, sticking it through. Woo hoo. 

(Applause.) 

DR. TUCKER: And, of course, I want to 

thank the NOP staff who are -- who remain 

completely focused through this event. So, of 

course, Michelle, who runs the place, thank you, 

Michelle. 

(Applause.) 

DR. TUCKER: Clarissa, you did a nice 

job at my side hand, thank you very much. 

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 (Applause.) 

DR. TUCKER: Devon, you're fabulous. 

And then, of course, let me 

acknowledge Paul, even though he had to leave a 

little bit early. He's a tremendous help in 

supporting all the Board's work. 

And then, finally, I want to say a 

thank you, a special thank you to Tom. So, in 

the National Organic Program, we have awards 

called "kudos" and we give them when people have 

gone above and beyond in service to our 

stakeholders and to others in the program. 

And, Tom gets two "kudos" for his two 

years on the Board, so he gets a travel mug with 

the organic seal on the sleeve and he gets a 

thermos with the organic seal. 

And so, you don't have to take the box 

on the plane if you don't want to, but this is 

for you to thank you for everything that you have 

done. 

I've enjoyed working with you. 

(Applause.) 

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10 

11 

12

13

14 

15 

16

17

18 

19 

20

21

22 

MR. CHAPMAN: Thank you. 

DR. TUCKER: Tom has played just a 

vital role during a transition period. He opened 

the meeting by talking about how we went from 

having really not a complete USDA leadership line 

to here we are with all the positions filled 

except for mine, the Associate, which will be 

next. 

And so, Tom, you've provided a voice 

of stability, of support, of friendship and it's 

just a true honor to know you. So, thank you. 

(Applause.) 

MR. CHAPMAN: Thank you, Jenny, and 

thank you for this nice thermos, it will do great 

at keeping my beer cold. 

(Laughter.) 

MR. CHAPMAN: With that, if Harriet 

could do the honors with hitting the gavel, I 

think we will consider this meeting adjourned. 

MS. BEHAR: Meeting adjourned. 

(Whereupon, the above-entitled matter 

went off the record at 5:20 p.m.) 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
429 

A

A-dae 1:18 44:5 46:8,10 

47:14 50:18 107:19 

108:15 114:21 117:2 

130:12 131:17,19 

160:4 161:15 171:18 

193:5,20 225:13 

233:2 235:7 240:19 

241:21 256:5 335:1 

425:16 

a.m 1:10 6:2 142:22 

143:1 

ability 60:3 152:17 

able 11:20 13:3,4,8 20:1 

56:4,19 57:6 70:22 

111:18 137:6 153:15 

155:5 163:8 165:5,14 

168:9 191:9 228:11 

228:20 229:4,7 

249:10 252:21 266:8 

274:3 337:17 376:13 

388:16 389:13 419:4 

above-entitled 142:21 

267:8 364:13 428:21 

abroad 61:14 

absence 59:22 60:1 

64:10 276:13 

absent 25:6 27:6 29:10 

35:16 37:16 40:13 

43:15 47:5 51:15 68:3 

90:12 94:20 104:11 

107:12 109:13 114:14 

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411:8 

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375:10 

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abstention 96:12 283:6 

288:11 328:1,5 

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302:16 313:16 316:17 

acaroides 304:19 

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396:7 397:1 398:8 

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145:15 307:6 

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393:10 

accessible 72:4 

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424:10 

account 81:18 213:16 

311:5 391:7 

accumulating 248:3 

255:6 

accumulation 332:1 

347:14 

accurately 213:13 

acetate 5:10 402:15,16 

402:19 403:13 

aches 27:16 

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336:13 

acid 3:7,9,16 4:17 40:17 

40:20 41:4 42:17 52:7 

52:8 53:17 57:15 65:6 

68:9 69:16,16,17 70:1 

71:4 121:17 130:8,10 

130:14,18 131:16 

179:11,12,13 183:17 

257:4 326:11,12 

329:3 331:4,7,12 

333:1,9 334:19 

365:18 416:1 

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actions 6:19 7:6 8:16 

8:17 9:9 14:2 16:17 

16:18 75:4 

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activators 181:19 

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120:2 157:16 

activities 6:13 391:2 

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216:9 368:2 

actors 18:17 21:10 

acts 47:16 179:5 293:7 

310:1 402:19 

actual 201:21 202:2 

255:1 389:19 

acute 185:16 

acyl 95:5 

add 32:22 80:4 92:4 

127:4 173:2 184:1 

194:16 205:16 208:1 

232:13 234:1 238:14 

241:19 259:3 261:10 

265:15 266:10 319:18 

345:3 368:6 369:12 

372:18 377:14 385:14 

403:9 411:10 

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110:21 170:17 180:15 

227:4 230:19,22 

272:16 273:18 275:9 

328:3 375:15 412:1 

addenda 207:18 400:14 

addendum 350:11,16 

351:2 352:10,16 

adding 30:20,20 31:3 

120:4 184:10 218:3 

227:13 232:14 311:17 

388:3 405:1,2 416:8 

addition 29:21 55:4 

257:3 273:4 368:4 

385:20 388:12 400:10 

426:7 

additional 14:2 22:22 

74:21 258:21 273:7 

295:2 297:22 312:1,1 

368:6 

additions 396:7 398:9 

402:1 

additive 22:14 133:16 

145:1 

address 32:2 113:12 

116:11 146:3 210:8 

262:10 280:8 286:8 

366:15 

addressed 38:17 52:11 

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addressing 52:10 

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358:19 

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adequate 153:14 

186:21 230:13 

adequately 204:16 

294:14 

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Adjourn 5:21 

adjourned 428:19,20 

adjournment 424:19 

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adjusting 332:9 

administration 78:8 

81:9,13,21 

administration's 82:7 

administrator 2:9,16 

76:17 

adopt 85:1,12 373:1 

398:16 410:11,12 

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85:5 

advocacy 30:16 36:7 

282:19 375:10 

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370:9 

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affidavit 102:17 148:12 

148:19 

affirmed 107:20 

afraid 59:10 

Africa 235:15 

African 155:13 

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19:4 260:8 306:10 

agencies 57:19 

agency 15:3 53:4 78:16 

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29:21 30:19,20 31:3,6 

31:9,19 32:2 33:1,9 

33:18 34:1 75:3 78:7 

78:17 128:20 136:8 

167:18 173:10 189:3 

199:19 200:6,10 

208:20 258:14 267:14 

285:10,16 327:7,16 

327:20 328:3 363:18 

413:7,8,11,15 414:4,9 

415:9 416:6,8,20 

agendas 350:1 413:13 

agendas/Materials 5:15 

agent 87:19,20 95:7 

107:22 108:1 115:6 

115:18 116:1,3 

123:12 125:20,21 

126:10 133:15,17 

144:2,3 179:5 238:7 

401:3,5 

agents 74:16 110:3 

152:20 208:15,16 

Neal R. Gross and Co., Inc. Neal R. Gross and Co., Inc. 

(202) 234-4433 (202) 234-4433 Washington DC Washington DC www.nealrgross.com www.nealrgross.com 
430 

216:20 259:21 400:6 

401:18 402:3 

aggressive 266:20 

agitation 153:2 

ago 19:6 105:21 137:1 

163:4 174:6 258:18 

276:19 

agree 69:5 80:2 191:18 

222:16 238:13 240:9 

248:16 283:20 292:17 

311:7 354:12,14 

361:8 374:9 387:9 

agreed 375:10 401:8 

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87:9 125:15,17 

143:22 147:19 148:11 

148:18 163:17 207:13 

228:4 233:1,4,6 

240:17,20 243:7 

245:3 256:1,4 259:5 

259:22 317:8 

agriculture 1:1 64:9 

82:20 143:15 236:20 

agro 358:6 

agronomic 361:12 

ahead 10:10 21:15,16 

154:22 200:20 300:22 

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408:6 409:5 

aid 88:13 207:6 284:5 

366:11 369:4 370:2 

370:11 406:2,8 

411:15,18 

aids 340:14 366:4,15 

367:4,13,16 368:10 

368:14 369:7 405:3 

air 187:5 282:16 

AITC 5:3 350:7,10,22 

351:6,14,18 362:10 

415:8 

Alan 264:9 

alcohol 22:3 25:17 99:3 

99:13 270:11 

alcohols 3:4 4:9 22:4 

22:12 25:14 268:5,11 

270:7 

alerted 124:4 

algae 112:16 

algaecide 179:20 268:9 

272:15 275:13 

alginates 3:14 109:15 

109:18 110:1,9,19 

111:12 112:19 113:15 

align 88:7 89:4 

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alive 30:13 

alkali 133:13 

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120:16 161:2 246:7 

348:5,6 380:20 

381:14,15,20 385:22 

405:14 407:8 412:5 

allowance 388:18 

389:10 

allowed 22:10,17 23:6 

25:16 30:3 38:1 40:20 

41:5 48:15,22 49:5 

57:8 87:9,13 102:21 

109:17 115:18 116:5 

118:4 131:10 139:13 

143:16,22 153:3 

154:17 174:4 179:18 

207:13 243:8 259:4,7 

268:7,14 270:10 

315:2 317:21 366:20 

367:17,18 368:13 

374:6 

allowing 13:16 119:10 

259:22 274:15 328:6 

337:6 381:19,22 

405:14 412:9 

allows 10:15 113:7 

119:10 183:9 380:16 

407:12 

alluded 6:21 7:7 

allyl 5:3 350:6,9 359:9 

362:10 

Alpha 400:4 

alterations 44:4,9 

altering 293:9 

alternate 315:7 

alternative 146:22 

163:1 182:10 184:7 

203:16 208:9 209:1 

226:7 248:22 249:4,9 

260:20 272:18 284:11 

344:12 358:16 401:1 

alternatives 22:20 32:9 

32:17 123:19 127:4 

131:1 146:13 183:12 

189:8 225:21 239:7 

283:17 314:10 336:12 

341:21 400:12 

aluminum-free 115:1 

amass 248:6 

Amazon 61:20 229:22 

230:12 

ambiguous 401:17 

amend 394:3,19 396:21 

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366:14 394:21 395:13 

397:21 398:12,16 

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326:9 331:6 391:15 

America 20:9 175:11 

American 56:16 146:20 

146:21 

ammonium 5:8,9 

399:21,21 402:6,6 

amount 91:7,20 112:18 

136:7 165:5 209:5 

219:16 230:4 245:18 

251:16 261:11 314:2 

317:11 326:12 328:16 

328:21 402:11 

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389:10 

ample 214:21 

AMS 11:5 

AMS-NOP-11-0009

85:11 

analysis 13:2 17:18 

analyze 13:6 17:19 

222:11 

analyzing 17:17 

and/or 102:21 112:10 

208:11 

Anesthetic 44:1 

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294:4 

animals 27:22 30:11,12 

47:17 127:10 264:7 

291:9 

annotate 167:20 310:10 

311:10 

annotated 116:4 314:17 

403:9 

annotating 311:7 

annotation 38:10 41:20 

44:13,20 45:8 93:5 

127:21 136:8 137:9 

181:16 194:20 203:6 

203:9 208:1 282:13 

282:15 307:5,7,11 

308:5 347:19,22 

372:19 373:2 379:3 

415:10,11 

answer 33:4,7 111:6 

150:20 195:2 226:12 

333:8 353:22 354:3 

360:14 361:21 362:2 

373:6 378:18 380:16 

381:16,17 382:2 

388:1 

answered 226:3 294:14 

answers 197:11 198:12 

217:16 231:17 238:16 

333:19 

antacid 87:18 

anti-caking 87:19 

125:20 

anti-inflammatory

27:15 

antibiotics 36:1 383:5 

anticipate 33:10 

anticoagulant 365:22 

372:19 

antimicrobial 178:19 

180:10,13 207:5 

210:21 212:13 

anybody 23:11 28:6 

60:15 111:4 204:16 

276:14 294:20 321:6 

345:20 371:6 

anymore 190:10 

anyone's 57:5 

anyway 98:14 100:15 

295:9 322:12 

Anyways 126:8 

APHIS 7:21 11:1,10,11 

12:3,6 

apiary 62:2 

apiculture 64:22 69:4 

apicultures 73:10 

apparent 254:20 

apparently 73:3 

appeal 9:22 

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238:18 260:9 337:22 

366:1 379:22 380:7 

appearance 225:16 

appeared 208:5,7 

appearing 404:11 

appears 56:1 119:18 

184:3 278:20 296:17 

297:17 365:18 

applaud 409:22 

applause 340:9 349:17 

422:21 423:20 424:12 

424:14 425:13 426:4 

426:11,14,20 427:1 

427:22 428:12 

apple 120:2 

applicable 22:12 44:1 

147:20 221:14 279:1 

281:21 

applicant 400:14 

application 74:21 

121:16,19 150:9 

183:9 208:11 209:2 

211:15 219:17 289:2 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
431 

289:4,6 311:2 324:8 

337:6 356:5 383:17 

383:19 406:19 412:17 

applications 91:10 

121:12 152:16 160:10 

179:3 208:17 210:21 

210:22 211:6 212:3,3 

254:13 306:7,12,19 

306:19 307:6 308:21 

324:13 332:8 412:18 

applicator 291:3 310:18 

applied 47:16 69:18 

100:3,4,5 140:13 

305:19 337:2 347:13 

362:1 406:14 

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176:17 227:5 355:4 

applying 333:6 400:10 

402:2 403:21 

appreciate 19:19 71:19 

194:10 392:21 409:9 

412:2,17 425:10 

appreciated 21:3 

231:19 290:13 

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78:12 80:13 196:10 

215:2 354:16 355:3 

356:11 357:14 361:10 

377:22 

approached 378:2 

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63:10 357:22 358:7 

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102:12 247:9 412:5 

appropriately 13:19 

approval 48:1,2 49:8 

50:1 127:20 368:15 

approve 48:11 188:2 

367:7 410:5 411:13 

approved 27:12 48:14 

49:19 52:2 53:4,6 

57:1 175:18 176:3 

199:19 264:6,22 

272:6 316:20 317:3 

327:19 352:18 358:12 

365:19 366:2 367:4 

367:12 375:15 382:8 

approving 232:10 

353:8 368:5 404:6 

411:13 

approximately 14:22 

216:10 

April 205:14 

aquatic 185:17 

aqueous 4:11 276:21 

288:14,17 295:12 

297:11 299:9,13 

300:17 302:17 303:3 

arabic 3:19 152:8,11 

153:16,21 155:4 

158:20 247:4 

arabic's 157:19 

arbol 225:16 

area 6:20 7:13 8:11 

10:8 18:21 28:4 42:3 

62:8 93:9 146:1 164:4 

187:8 209:17 210:20 

211:9 212:6 223:8 

285:6 286:6 334:3 

395:18 410:1 414:22 

areas 20:12 45:22 46:1 

48:9 61:21,22 156:21 

157:21 209:16 213:1 

414:21 

Argentina 13:11 

argue 255:12 

argument 59:7 61:6,7,9 

146:15 277:3 290:5 

301:14 401:1 

arguments 61:6 210:16 

arid 332:2 

arising 98:10 

Arizona 193:9 

arm 50:10 

aromatic 105:4 

arrive 70:17 

ARSENAULT 2:7 

arthropods 314:18 

artificial 50:9 90:19 

Asa 1:14 34:21 117:4 

118:7 122:5 125:18 

129:7 184:15 191:19 

193:12 222:17 233:5 

263:1 280:18 286:14 

293:4 303:10,12 

305:2 312:10 315:17 

330:3 344:3 352:4 

356:1 360:7 362:12 

398:15 

Asa's 187:17 

Ashley 1:21 21:22 25:9 

27:9 28:12 29:12 32:7 

35:18 37:18 40:15 

43:17 47:7 51:17 55:8 

68:5 69:8 86:10 89:16 

96:18 103:3 105:11 

151:10 162:11 165:22 

171:10 190:2 231:4 

250:10 277:20 329:17 

362:14 378:7 

Ashley's 252:10 

asked 10:5 55:8,9,11 

56:10 103:5 177:2 

200:11 217:14 219:4 

231:15 239:1 251:3 

328:17 357:10 380:4 

381:11 

asking 14:9 31:21,21 

77:14 111:15 145:18 

167:8 209:11 289:19 

329:10 412:13 

aspect 36:9 131:13 

aspects 414:14 

aspirin 3:5 27:10,12,15 

28:11 

assert 310:15 

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assessment 7:21 

211:10 

assigned 417:12 

assist 419:14 

assistance 200:9 

assisting 108:6 

Associate 428:7 

associated 23:5 185:4 

351:2 403:11 

association 146:20,21 

185:8 

associations 91:21 

144:13 

assume 127:20 419:9 

419:11 

assuming 334:8 

assumption 239:16 

assure 79:8 

assured 391:5 

asthma 185:12,20 

asthmatic 185:21 

asthmogen 185:18,19 

Astragalus 175:10 

astringencies 105:3 

ATSDR 185:7 

attention 66:6 74:5 

174:20 199:13 285:7 

285:9 328:14 349:22 

attest 321:4 

attested 183:19 

attractive 21:12 191:14 

383:9 

attractiveness 191:8 

attracts 337:15 

attributed 315:7 

audible 23:12 26:4 28:8 

31:13 34:15 36:13 

39:8 42:9 44:18 66:20 

73:7 93:16 108:11 

124:7 137:12 170:4 

177:7 312:4 315:10 

321:20 325:1 394:1 

398:2 404:14 418:4 

423:12 424:17 

audience 426:12 

audit 74:15 

augment 172:22 250:1 

augmentation 173:4 

August 9:4 11:11 

207:17 

authority 102:10 

authorized 81:15 

availability 92:5 153:10 

154:1,20 155:8 156:9 

157:13 160:18 161:11 

165:15 166:6 167:3 

184:6,7 259:13 

390:14 

availability-wise 171:8 

available 54:11,17,18 

70:12 119:2 139:15 

147:6 154:21 155:11 

155:16 160:21,22 

161:18 162:13 164:1 

164:5,14 165:2,20 

166:18,20 167:8 

171:14,15 183:3,12 

192:20 193:19 195:16 

199:1 208:10 219:13 

229:10,21 237:15 

238:10 244:9 248:9 

248:16 251:14 252:20 

252:21 260:13,16 

264:17 307:1 341:11 

341:22 351:7 358:14 

358:16 

average 342:19 

avidly 277:8 

avoid 96:8 166:3 

263:22 358:7 

awards 427:9 

aware 157:14 165:3 

183:7 193:1 197:3 

359:15 381:12 382:10 

awareness 11:2 

awesomest 345:2 

awkward 370:21 

axis 18:6 

B

b 43:22 109:17 154:16 

back 6:4 20:19 21:20 

25:10 42:14 50:14 

70:7 72:12 76:11 

98:22 110:10 111:16 

116:9 142:16,18 

143:6,7,9 155:22 

191:12,12 194:18 

197:21 202:12 203:3 

203:17 209:9 213:12 

213:20 214:16 223:6 

223:7,17,21 224:7 

225:10,20 226:12 

228:12 230:10,14 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
432 

231:22 250:11 254:11 

258:17 262:7 266:22 

268:2 273:13 280:5 

289:19 318:18,20 

350:13 351:21 352:21 

353:13,17 356:14 

357:2 358:22 360:1 

362:8,11 363:12 

364:10,16 365:2 

371:11 374:1 376:20 

391:8 394:8 395:13 

396:2 400:11,13 

415:8,16,19 416:19 

417:6 

backflow 333:5,14 

background 198:17 

211:16 217:18 218:7 

218:9,12 219:15 

220:2 254:8 369:11 

backing 255:8 

bacteria 375:2 

bacterial 23:2 208:14 

208:15 211:3 

bad 18:17 21:10 360:19 

badly 221:10 

BAIRD 1:14 24:21 

26:20 29:1 35:6 37:5 

38:6 40:2 43:2 46:13 

50:22 52:5 58:1,20 

67:7 86:6 90:8 94:15 

102:14 104:5 107:5 

109:5 114:5 117:11 

122:13 124:18 129:13 

131:22 134:11 137:19 

142:9 152:1 159:15 

162:12 172:11 178:3 

194:9 206:11 225:2 

233:12 234:13 241:5 

242:7 252:10 256:8 

257:10 269:12 271:16 

278:11 281:11 288:5 

296:6 304:2 312:22 

316:2,22 323:5 

325:13 330:10 335:4 

339:12,13 340:20 

344:14 346:8 349:10 

356:22 363:5 372:11 

373:14 385:5 386:12 

397:10 399:1 410:19 

baked 91:11 138:22 

140:2 144:5 160:15 

bakery 95:8 

baking 115:2 139:17 

balance 17:12,16 20:5 

121:7 

ballgame 197:7 

ballot 419:19,22 422:18 

423:17 

ballots 420:2,20 

Ballrooms 1:8 

ban 380:18 

bananas 118:13 

bar 237:14 240:3,10 

247:15 

bare 361:16,19 362:1 

barely 367:19 

Barriers 278:22 281:21 

base 265:22 

based 13:19 74:10 

125:22 160:19 161:9 

162:7 175:20 182:18 

194:16 208:4 222:12 

282:2 287:10 294:10 

294:18 299:13 300:9 

320:20 326:21 341:6 

341:11 359:2 360:3 

388:13 406:17 411:21 

415:13 

bases 243:16 

basic 382:3 

basically 36:9 70:19 

101:20 110:5 136:2 

185:19 197:12 238:6 

244:21 263:6 273:3 

287:1 331:12 389:7 

400:17 401:1 402:16 

403:4,8 

basis 119:9 164:15 

bean 3:19,19 152:11,12 

154:2 158:20 230:16 

beard 86:14,16 106:8 

178:16 

bearings 191:16 

beauty 358:5 

becoming 165:19 

bedding 45:1,5,14,16 

bee 58:11 65:7,10,15 

71:21 

beehive 58:11 70:1 

beekeeper 53:14 64:2 

70:5 72:17 

beekeepers 52:19,22 

64:3,13 69:10,14,21 

70:14 71:12 72:1 

beekeeping 68:10 

beer 364:20 428:15 

bees 54:21 55:1 58:14 

58:15 59:1 60:20 

61:22 63:14 70:4,13 

70:14,15 71:1 72:22 

73:2 272:19 275:5,19 

318:3 

beet 115:5 

beets 98:11 147:13,16 

148:1,6,8 

beginning 21:2 

behalf 64:4 259:9 

behaves 152:22 

behavior 17:1 199:5,13 

belief 355:20 

believe 48:21 49:4,7 

55:17 60:19 62:15 

63:4 137:5 148:4,5,7 

274:8 279:15 355:4 

377:8 383:21 407:11 

418:5 

belly 317:5 

belong 52:5 

belongs 63:8 

beneficial 314:17 

317:13 351:1 354:6 

375:19 

benefit 157:4 158:13 

310:6 314:12 343:21 

benefits 120:22 121:1 

263:15 

benefitted 332:7 

benign 54:8 59:1,1 

102:2 

berry 136:13 

best 83:17 201:2 329:3 

390:7 414:21 417:10 

418:9 

better 11:8 13:2 57:12 

118:17 189:4 195:15 

262:1 309:1 331:20 

beverages 104:21 

138:22 144:6 

beyond 38:15 52:16 

243:11 307:7 308:4 

427:11 

bicarbonates 332:1 

big 62:13 92:19 120:7 

126:12 155:12 186:11 

198:13 215:15 

biggest 64:22 294:12 

billion 12:20 

binding 126:1,10 

152:18 

bio-based 345:6 

biobased 282:20 

284:12 

biocontrol 358:14 

biodegradable 282:20 

284:12 285:3 286:12 

345:7 415:13 

biodegrade 341:7 

biodegrades 317:9 

343:4 

biodynamic 292:9 

biological 314:21 

biologics 3:5 29:17 

34:18 

biology 375:2 

bionematicide 358:15 

biopesticide 52:9 

biopesticides 358:13 

Bioscience 207:5 

biota 355:17 

birds 32:14 

bit 6:9,14,18 7:9 17:12 

17:15 81:19 96:21 

132:12 164:9 168:4,6 

195:13 196:17 215:21 

215:21 260:4 290:20 

291:21 307:7 338:5 

359:12 369:16 371:21 

376:9 389:13 401:6 

404:21 427:5 

bitterly 187:9 

black 7:13 9:15 20:8 

247:4 403:21 

blanched 182:17 

blasting 306:12 310:22 

blatant 102:22 

bleach 185:1,5,18 

187:10 

bleaching 71:4 

blight 315:5 

block 21:14 

blocked 11:22 12:4,7 

blood 365:22 366:1 

372:20 

blue 421:7 

blueberry 12:8 

board 1:3,8 2:7 53:15 

58:4 61:10 68:16 70:6 

74:5 75:12,12 77:6,7 

85:4,5 105:13 108:10 

118:19 124:6 131:7 

143:2,5 145:4 148:9 

154:14 186:12 204:6 

204:20 226:15,22 

258:22 261:15 267:3 

267:12 275:12 285:15 

285:17 291:16 305:11 

327:15 345:10 349:22 

374:5 376:8 378:13 

378:22 383:5 400:12 

400:16 402:8 405:16 

407:4 408:10,10 

417:15 418:3 421:4 

426:6,10 427:14 

board's 14:1 203:21 

427:6 

body 220:5 221:3 

boiler 133:16 

boilers 130:16 

Bolthouse 273:5 

bonding 52:6 

book 267:20 297:13 

books 297:12 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
433 

Bordeaux 324:11 

border 8:7 

borders 69:9,14 

borne 212:19 

botanicals 91:2 

bottom 70:2,5 101:22 

393:9 395:11 

bought 306:17 

Boulevard 1:9 

box 70:16 427:17 

boxes 144:1 

boy 184:19 

BRADMAN 1:14 24:15 

26:14 28:17 34:22 

37:13 40:10 43:10 

46:21 51:8 67:16 

85:22 90:2 94:9 

103:21 106:21 108:21 

113:21 117:5 118:8 

122:21 125:4,19 

126:6 127:18 128:18 

128:22 129:21 132:8 

134:19 138:6 142:3 

151:17 159:9 172:5 

177:19 184:16 206:5 

222:18 224:17 233:6 

234:22 241:13 242:15 

253:10 256:16 257:18 

263:2 269:20 271:10 

278:5 281:5 286:15 

287:21 293:5 295:22 

303:18 305:3 309:12 

310:5,13 311:21 

312:16 315:18 320:9 

323:16 325:21 326:15 

330:18 335:10 339:20 

344:4 346:16 349:4 

356:2,20 360:8 

362:21 372:5 384:21 

386:6 397:4 398:17 

411:5 422:5 

Brazil 55:14 56:2,3,14 

56:18,20 57:2 59:21 

60:14,20 61:18 65:11 

71:17 

Brazilian 56:10 66:11 

bread 374:18 380:22 

breads 374:18 379:21 

break 86:22 142:15 

338:9 349:20 364:8 

364:10 

breakdown 112:3 

breast 144:18 150:11 

150:19 

breweries 104:20 

bribery 422:4 

bridges 11:13 

brief 20:19 76:11 78:5 

213:22 261:15 305:4 

briefing 76:16 83:9 

briefly 6:13 209:15 

418:19 

bring 34:6 68:17 78:2 

118:16 247:9 258:18 

265:7 286:17 357:2 

365:15 387:12 416:17 

417:18 418:1,12 

bringing 258:19 261:9 

broad 16:9 17:21 

314:19 354:15,15 

355:5,13 357:6 

360:18 412:7 

broadcasting 302:8 

broader 12:12 21:3 

119:11 184:22 291:16 

411:18,21 

broken 147:13 

bronchitis 185:11,12 

brought 66:5 79:17 

93:12 112:12 207:3,4 

208:19 328:14 345:10 

350:5 360:2 369:13 

brow 297:8 

bubble 376:2,5 

budgets 191:7 

buffer 115:4 179:14 

buffering 133:17 

BUIE 1:15 22:17 24:22 

25:16 26:21 29:2 35:7 

37:6 40:3 43:3 46:14 

51:1 67:9 85:15 90:9 

94:16 104:6 107:6 

109:6 114:6 117:12 

122:14 124:19 129:14 

132:1 134:12 137:21 

141:18 152:2 159:16 

172:12 178:4 206:12 

225:1 233:13 234:15 

241:6 242:8 256:9 

257:11 268:14 269:13 

270:10 271:3 278:12 

281:12 288:6 296:7 

304:3 313:1 316:3 

323:9 325:14 330:11 

335:5 346:9 348:20 

350:9 363:6 372:12 

373:15 385:6 386:13 

397:11 399:2 410:20 

build 163:20 200:1 

266:4 

building 8:1 414:15 

buildup 331:18,19 

built 11:10 

bulking 144:3 

bullet 354:16 

bullets 355:1 

burden 229:14 406:21 

408:20 

burdens 312:1 

burgeoning 250:2 

burn 333:10 

burned 331:12 

burning 282:12 359:8 

business 5:19 73:17 

75:19 239:6 266:8 

424:16 

businesses 15:7 

butchered 223:13 

buy 101:13 139:16 

250:18 253:19 364:20 

buyers 36:8 

buying 54:5 63:5 70:18 

71:1 255:5 265:22 

by-chemical 358:1 

byproduct 38:6 

byproducts 266:9 

C

C 154:16 

CACS 414:2 

calcium 3:11,14 5:10 

87:6,13,16 88:3 89:13 

114:17,20,22 115:5 

116:2,21 117:1 122:2 

131:4 313:18 331:17 

402:15,16,18,19 

403:11,13,14 

California 212:18 238:3 

273:5 289:22 307:22 

308:20 309:10 

call 15:7 31:15 58:2 

64:14,15 83:10 

127:16 192:8 321:8 

350:10 355:12,13 

369:6 

called 56:7 324:11 

404:3 427:10 

calling 192:7 355:18 

369:6 

calls 55:5 377:8 418:7 

camp 195:4 

campuses 284:16 

Canada 139:14 153:4 

319:11 

cancel 266:15 

candida 374:16 

candidate 420:12 

candies 144:5 

canned 182:17 

canola 164:12 

capabilities 19:5 165:4 

capability 9:11 11:14 

16:12 198:3 

capping 216:20 

capsule 259:16 

capsules 259:6 260:18 

260:22 

carbohydrate 100:6 

144:1 

carbonate 3:11,17 4:9 

87:6,14,17 88:4 89:13 

133:3,5,12 134:6 

272:1,3 277:14 

331:18 403:15 

carbonated 104:20 

carbonates 332:1 

carcasses 207:6 

cards 420:1 421:2,7 

423:9,11 

care 27:12 30:8 82:16 

95:9 

cared 381:7,7 

careful 81:9 199:7,9 

carefully 411:12 

carob 3:19 152:9,12 

154:1 158:21 

carrageenan 95:18 

96:8,22 97:2 101:11 

102:3 139:12 

carrier 90:19 

carrots 273:5 

CAS 51:22 95:4 143:19 

173:16 272:3 288:18 

302:17 316:19 331:7 

340:15 

case 10:14 13:12 15:19 

20:7,9 79:11 84:9 

98:8 163:11 169:7 

220:11,13 238:7 

247:22 263:6 275:10 

276:10 290:11 299:2 

299:16 305:13 

cases 98:8 187:11 

222:9 306:3 

cash 157:9 

casing 4:6 

casings 248:1 263:18 

264:5,21 265:20 

catalogues 388:20 

389:2 

catch 304:12 

catching 371:21 

categorical 92:12 

categorized 71:3 

110:21 

category 184:18 226:10 

227:11 231:1 259:7 

260:1,11 293:11 

caught 162:2 382:5 

cause 169:2 182:22 

185:20 306:12 367:10 

caused 16:16 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
434 

causes 70:4 331:17 

causing 305:21 355:16 

caustic 193:2 

cauterize 44:3,9 

caution 195:18 

cautious 388:13 

CBI 95:22 175:20,21,22 

CBP 11:17 

CCOF 273:8 292:4 

306:16 308:12 332:13 

348:8 

CDFA 238:6 

CDO 178:22 

cells 217:10 289:9 

Center 174:13 

central 324:10 

centrally 324:7 

cents 192:3 354:10 

355:22 

centuries 115:9 

cereals 91:14 

certain 32:13 49:6 

53:16 149:5 275:9 

282:10 396:6 

certainly 7:13 64:11 

80:22 111:5 190:19 

191:3 192:16 203:20 

217:7,21 283:9 

307:10 310:14 371:5 

certificate 254:5 

certification 8:10 15:13 

75:8 128:2,8 245:3 

261:4 308:14 329:5 

certified 8:12,12 10:9 

15:7 56:18 75:9 

148:21 153:22 193:8 

228:10 235:22 236:1 

237:4 238:5 245:5 

247:8 249:21 250:13 

253:14 259:13,18 

265:17,22 290:1,16 

342:5 414:18 

certifier 8:15 10:5,7 

15:18,19 45:3 55:8 

83:22 100:9 116:11 

123:17 139:21 148:9 

148:20 166:18 167:8 

260:5 273:9 329:5 

348:2 

certifier's 9:22 156:13 

certifiers 8:18 9:7,21 

10:5 16:5,10,16 30:4 

30:15 31:20 32:4 34:3 

36:7 41:14 44:21 55:7 

56:3,5 66:15 69:12 

83:21 88:1 92:1 

102:15 104:21 124:4 

139:19 160:19 162:8 

165:13 167:14 182:7 

249:21 261:13 282:19 

312:2 347:19 348:5 

367:12 390:19 391:1 

405:13 406:3 407:1 

410:5 414:17 

certify 238:22 239:1 

244:15 250:8 

certifying 15:3 66:12 

73:13 74:16 259:20 

chain 9:18 21:14 39:1 

76:16 77:7 78:5 

244:21 245:9,19 

246:19 247:17 248:14 

250:3 265:12 383:14 

405:6 

chains 7:12 

challenge 9:10 81:20 

193:4 197:10 198:18 

challenges 186:10 

challenging 184:21 

286:22 376:18 

chance 132:13 353:11 

405:16 

chances 23:1 

change 14:17 16:17 

97:17 101:16 136:8 

165:9 203:4,5,16 

232:8,15 253:6 275:6 

292:13 295:1 311:15 

322:9 343:18 359:3 

378:20 389:12 391:19 

changed 58:21 190:6 

320:19 352:21 

changes 13:19 387:5 

417:8,18 418:8 

changing 192:6,9 202:2 

202:20,22 293:22 

294:10 352:10 

characteristic 101:1 

characteristics 174:1 

388:20 389:15 393:6 

charged 407:14 

chart 13:9 244:2 

chatting 425:17 

cheap 425:15 

check 286:9 

checked 244:6 

checking 320:4 382:18 

checks 10:19 

cheese 374:20 379:21 

380:22 

cheeses 374:20,20 

cheesewax 4:19 340:11 

340:15 342:9,19,22 

344:13 346:2 

cheesewaxes 342:7 

chelants 402:3 

chelated 401:3,18 

chelates 400:4,8 

chelating 401:3,5,17 

402:3 

chemical 52:6 275:3 

277:5 

chemical- 357:22 

Chemically 265:2 

chemicals 358:8 

360:18 

chemistry 216:12 

400:16 401:11 

chemists 401:13 

chick 356:13 

chicken 190:13 229:8 

264:2 

chickens 166:8 

chickpeas 12:8 

children 305:18 

chile 12:9 225:15,18 

chill 161:5 

chilled 139:9 

chlorhexidine 38:12 

chloride 3:13 4:20 

107:16,18,21 108:14 

282:3 287:10 347:7 

347:12,14 348:14 

chlorine 4:3 178:15,22 

179:5,7,17 180:5,9 

181:8,15 182:5,14,16 

183:18 184:19,21 

185:4,9 186:14,21 

187:5,6 190:20 

191:20,22 196:2 

197:12 199:10 201:22 

202:3 203:1,13 204:8 

204:9,13 205:17 

chlorite 4:3 178:15 

179:9 180:12 181:17 

181:20 201:22 202:4 

203:2,12 205:16 

chlorosis 334:6 

chocolate 101:21,21 

133:14 134:2 135:16 

338:15 

chocolates 160:14 

choice 191:1 196:22 

264:1 369:22 

choices 393:10 

choose 63:6 101:13 

128:16 

chosen 392:19 

chronic 185:12 

churning 216:16 

cider 136:13 

circumstances 49:7 

cited 66:15 315:1 

citing 215:4 

citrate 4:4 5:4,8 207:1,3 

224:1 365:5,17,22 

371:14 372:18 399:21 

402:6 415:18 

citric 179:12 326:11 

365:18 

citrus 118:6,13,14,20 

119:1,2 207:7,8 

claim 180:19 181:3 

claims 149:6,9 243:10 

244:5 

clamoring 69:9 137:5 

189:20 

clarification 38:16 

47:21 49:11,16 

172:21 182:1 193:16 

194:7 203:6 205:7 

301:17 320:2 328:11 

329:10 344:5 356:3 

422:1 

clarified 402:2 

clarify 33:17 89:1 115:2 

115:5,12 127:18 

176:11 193:21 308:16 

321:9 327:19,22 

328:17 343:18 401:17 

422:3 

clarifying 14:14 105:15 

Clarissa 2:12 25:12 

29:15 33:5 35:21 

37:21 40:18 43:20 

47:10 51:20 87:7 

104:15 268:5 278:19 

281:19 288:15 302:4 

302:13 304:13 313:13 

316:15 318:5 319:17 

326:7 331:4 335:20 

340:12 347:8 426:21 

Clarissa's 302:11 

clarity 74:21 79:17 

182:9 203:19 394:16 

clarity's 371:12 

classification 88:9 

140:9,14 205:3,8 

232:22 255:20 260:3 

260:7 275:12 371:13 

386:2 

classified 205:12,12,13 

260:6 

classify 233:1 240:15 

240:16 255:22 256:4 

256:5 371:14,18,20 

378:9 384:11,15,16 

classifying 259:21 

clean 145:12,18 282:16 

cleaner 41:5 70:22 

274:21 

cleaning 40:21 130:10 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
435 

130:14 179:21 268:11 

clear 49:18 81:22 82:1 

84:9 98:6,9 146:8,12 

156:12 181:4 194:5 

216:22 251:20 276:13 

299:4 300:6,21 303:1 

317:22 342:19 343:11 

360:22 361:21 370:1 

370:4 

clearer 262:12 329:15 

407:3 

clearly 76:13 165:15 

219:16 238:20 249:2 

255:11 263:14 418:9 

clients 31:22 

Clif 247:14 

climate 62:16 155:18 

climates 157:15 

clinicians 185:8 

clock 266:22 

close 8:3 150:18 157:18 

165:2 198:10 251:21 

348:8 405:21 

closely 357:12 403:15 

closer 295:5 

closing 5:19 364:12 

425:19 

club 71:21 

clunky 73:2 

co-spearhead 401:8 

co-working 399:22 

Coalition 188:15 

318:14 375:14 

Coast 293:3 376:10 

coating 115:10 263:8 

cocoa 133:13 

code 200:8 

codes 12:19,20 

coextruded 263:8 

264:18 

cognizant 370:10 

coin 245:21 

cold 58:8 374:19 

428:15 

collaborating 408:11 

collagen 4:6 262:17,17 

263:1,5 264:18 265:3 

415:21 

collect 244:22 

collecting 417:8 422:13 

collective 17:3,4 

collectively 324:17 

color 105:3 118:15,17 

119:2 

colored 279:5 284:7 

colors 340:18 

combination 401:4 

combine 300:8,8 

come 6:4 7:3 56:2 63:2 

72:12 74:4 81:5 99:4 

136:10 137:3 140:12 

142:16 143:6,7 

145:17 149:19 150:10 

155:13 166:11 168:5 

174:7,9,18 188:5 

191:12 194:18 203:3 

231:22 239:4 262:21 

267:12 338:9 345:9 

363:18 364:10 367:11 

391:18 414:5 415:7 

416:13 424:1 

comes 39:12,13,13 

41:16 46:6 50:2 62:3 

65:11 77:15 79:12 

110:9 164:3,20 176:5 

176:6 244:17 249:15 

342:3 379:4 384:13 

417:15 

comfortable 98:7 

169:16 

coming 12:1,1,4 13:17 

18:11 23:17 55:13 

63:22 68:21 76:13 

264:6 266:22 279:15 

285:7 352:15,17 

360:10 395:8 

comma 395:20 

command 77:7 

comment's 232:7 

commented 30:7 96:6 

104:22 108:4 140:3 

144:14 

commenter 44:13 

47:20 93:13 103:5 

108:6 115:8 116:5 

124:1 136:14 161:22 

214:4 236:9 272:21 

282:14 318:12 319:14 

336:18 

commenters 30:21 

31:7 41:12,13,19 

47:19 92:3,11,16 

95:22 108:4 112:3 

144:12 146:16 149:3 

161:2 162:13,18 

175:17 181:14,18 

182:21 183:4,11,19 

202:9,22 226:9,18 

235:16 336:11 366:12 

366:21 377:13 388:2 

commenters' 217:13 

commerce 182:18 

commercial 92:5 155:8 

156:9 160:18 165:14 

259:15 336:6 341:13 

commercially 139:15 

154:21 168:7 260:15 

commissioners 306:10 

commissions 185:9 

committee 22:2 42:11 

73:16 86:12 87:3 

98:15 196:13 214:16 

267:18 290:19 291:16 

327:20 329:2,11 

352:22 369:12,13,14 

412:4 

commodity 11:4 20:3,6 

157:19 

common 139:11 149:21 

221:1 254:16 381:3,5 

390:9 

commonly 30:8 133:12 

139:22 

commonly-used

118:10 

communicate 77:4 

communicated 76:15 

communicates 9:5 

communicating 11:12 

communication 8:3 

239:17 

community 11:7 21:4 

36:9 58:12 61:12 

79:15 88:18 111:21 

160:20 189:20 193:10 

199:12 246:3 249:18 

250:2 263:4 306:2 

307:3 310:15,21 

314:9 395:19 

companies 127:15 

company 56:7,16 64:3 

247:3,14 400:3,10 

comparatively 246:3 

249:18 

compare 62:21 

compared 135:20 

255:13 

comparing 404:22 

comparison 351:17 

comparisons 244:2 

compatibility 140:15 

compelling 60:8 64:12 

121:3 146:17 406:5 

complained 187:9 

complaint 7:17 

complete 197:9 402:5 

428:5 

completed 205:8 245:1 

298:16 419:16 

completely 321:4 

426:17 

complex 215:22 228:5 

247:17 248:17 409:16 

compliance 184:9 

191:5 

compliant 228:10 

259:19 260:13 342:11 

complicated 327:8 

393:3,10 

comply 61:20 311:19 

component 38:11 

115:1 144:9 

components 105:4 

216:20 

compositions 216:11 

compost 279:3 

compound 72:17 91:1 

120:16 147:3 198:7 

290:6 291:6,17 293:8 

297:4,5 357:18 400:9 

401:3 

compounds 58:9 

184:19,21 186:14,21 

196:19 211:3,4 218:4 

289:12 400:3,5,20,22 

402:5 

conceivably 246:7 

concentration 135:12 

217:17 219:21 220:1 

220:8 221:2,6 

concentrations 95:13 

concept 356:11 

concern 32:21 60:22 

71:2 88:1 96:13 97:21 

98:4 99:7,18 101:3 

120:12 126:19 141:7 

146:2 155:12 182:22 

199:11 208:13 209:4 

210:20 211:9,19 

217:1,2,8 264:13 

283:12,21 291:4,12 

292:21 327:3 333:4 

337:19 351:4 388:18 

389:21 411:22 

concerned 97:6 187:10 

215:3 217:22 292:19 

350:18 374:10 

concerning 293:17 

concerns 92:16 95:19 

102:11,12 119:6 

121:8 126:13,14 

127:10 132:10 140:7 

141:3 144:10 146:14 

150:12 180:20 181:11 

184:4 187:17 188:10 

192:12 193:12 210:8 

211:1 212:1,22 213:2 

213:16 214:8,9,17,19 

215:5,15 217:2,11 

222:20 223:13 237:13 

249:3 286:18 293:6 

293:11 294:4 306:1 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
436 

307:16,18 311:20 

333:13 345:13 352:10 

352:20 357:1 370:5 

370:16 

conclude 161:16 

concluded 210:17 

400:12 

concludes 86:11 

262:16 349:16 399:14 

413:6 

conclusion 277:2 345:9 

419:10 

Concur 137:19 

condition 115:3 

conditional 182:22 

conditioner 87:18 

conditions 215:12 

388:14,16 

conducted 342:8 

confections 95:9 

conference 377:8 

confidential 420:19 

confirm 319:20 

confirmed 103:8 

conflict 98:16 

conflicted 382:22 

conflicting 417:20 

conflicts 164:22 420:7 

confounding 362:5 

confused 170:12,19 

297:10 

confusing 406:2 

confusion 304:14 

409:13,14 

congratulations 425:21 

Congress 81:14 

conjunction 63:13 

273:14 279:12 

connection 146:5 

consensus 387:10 

consent 406:22 

consequences 412:8 

conservative 196:15 

consider 78:8 105:8 

132:12 173:10 202:8 

240:9 285:10 307:4,5 

308:9 376:15 400:5 

428:19 

consideration 82:7 

116:9 174:15 192:14 

202:9 204:1 209:10 

418:22 

considered 41:12 54:7 

78:16 105:14 127:2 

185:18 197:17 223:9 

259:17 263:15 306:5 

314:19 406:11,15 

considering 353:20 

407:5 

consist 203:5 

consistency 32:3 34:7 

57:17 77:13,14 78:1 

162:21 182:9 

consistent 74:19 75:7 

79:9 81:3 98:18 161:9 

164:14 210:9 213:7 

218:2 321:16 383:7 

constipation 48:14 

constituents 92:18 

93:1 150:15 

constrain 128:17 

constrained 121:16,18 

constraints 265:12 

388:8 

consultants 290:1 

consulted 401:12 

consume 99:16 

consumer 102:9 140:7 

249:7 265:22 380:1,7 

consumers 53:3 75:14 

77:12 85:7 96:7,8 

97:11,12 101:8,13 

127:12 139:16 145:11 

166:3 249:10 261:1 

consumption 182:17 

contact 16:10 40:22 

41:6 130:11 180:3,14 

180:17 198:10 207:9 

237:6 253:21 376:9 

contacted 318:20 

contacts 71:19 

contain 91:7 219:12 

contained 361:6 

containers 361:17 

containing 216:19 

contains 218:20 

contaminated 221:10 

contamination 218:7 

287:4 

contaminations 23:6 

218:12 

content 98:5 

CONTENTS 3:1 4:1 5:1 

context 14:2 15:22 77:6 

contingent 61:16 

338:18 

continually 21:13 

continue 7:11 78:4 

142:16 197:16 202:19 

259:14 261:5 292:18 

294:6 295:4 364:7 

414:2 

continued 12:14 41:9 

74:6 259:12 407:9 

continues 120:13 

199:11 292:20 

continuing 52:17 

continuous 382:14 

392:18 

continuously 72:3 

196:18 

contract 11:17 235:13 

263:13 

contracted 226:17 

contradictory 291:7 

control 44:3,7 52:11 

53:20 57:12 63:3,10 

63:13,15 71:7 108:1 

133:15 179:15 228:15 

284:5 288:17 289:3 

292:10 297:19 298:1 

302:16 304:20,20 

305:8 313:17,20 

314:21 315:5,6 

316:18 317:4,20 

324:2 374:13 376:1 

377:2,15 

controlled 105:2 

controlling 52:21 54:1 

controls 282:7 306:4 

controversial 105:6 

137:2 262:8 267:20 

convention 148:7 

338:22 

conventional 61:22 

148:2 187:12 193:22 

212:18 251:8 252:1 

252:18 351:15 354:16 

354:21 355:13,14 

376:12 

conversation 200:18 

310:18 

conversations 78:11 

160:19 161:9 162:7 

235:10 273:7 

Conversely 245:11 

393:15 

convert 100:6 

convinced 100:20 

237:18 246:8 

Coody 318:19 

cooked 182:17 263:9 

cool 16:22 234:14 

cooperation 7:19 

copolymer 340:18 

copper 272:18 273:14 

273:19 290:10 314:10 

314:11 324:12 

corn 8:22 11:22 12:1,4 

12:5 13:10 115:3,10 

160:7 

cornerstone 183:14 

correct 34:13 100:10 

296:21 417:2 418:7 

corrosive 185:16 

cost 228:18 

Costa 61:16,16 120:22 

338:17 340:7 

costing 246:7 

costs 127:4 237:4 

cough 185:11 

councils 144:14 

count 423:14 

counted 420:2 

counting 422:12 

countries 12:19,21 

18:18 55:5,12 155:14 

157:3 

country 20:4,5,13 63:22 

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201:1 251:10 254:3 

339:1 

County 306:11 

couple 14:22 41:13,18 

71:9 80:16 95:21 

127:6 136:5 157:15 

164:12 174:6 175:16 

193:17 221:12 349:19 

363:17 376:18 377:1 

379:20 425:19 

course 69:15 162:3 

181:2 200:14 218:14 

264:21 275:4 324:16 

366:16 382:12 391:9 

426:15,18 427:3 

cover 89:1 260:18 

337:22 357:16,17 

358:4,12 368:18 

coverage 11:7 16:9 

covered 282:16 309:4 

covers 4:10 281:18 

282:2 287:9 

cow 50:10 

crack 393:14 

cracks 201:16 

craft 239:5 250:8 

crafted 153:22 249:15 

crannies 191:16 

crawl 70:7,9 

cream 156:4 

create 248:13 249:4 

331:12 359:1 406:20 

created 157:12 216:14 

333:9 

creates 248:12 

creating 74:8 75:8 

crevices 201:16 

Crews 191:12 

criteria 59:9 100:17,17 

111:17 200:1 239:3 

336:19 

critical 110:7 165:18 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
437 

167:2,5 190:9 228:14 

239:5 329:19 400:19 

criticality 92:1 

critically 27:21 31:16 

crop 23:17 99:3 121:12 

121:15,19 157:9 

166:7,10 179:19 

236:2 237:3 254:1 

267:2 268:8,15 272:5 

317:8 318:4 336:20 

337:9,18,20 338:1,7 

347:11 357:16 358:17 

366:4,11 367:1 368:7 

377:11 379:13 380:21 

385:16,21 386:1 

392:9 393:19 403:15 

cropping 121:5 

crops 2:10 4:7 5:2 6:7 

12:2 18:11 45:15,20 

98:18 116:14 141:6,8 

154:15 158:14 167:1 

200:16 254:4 267:13 

267:15,18 270:11 

282:10 283:13 290:3 

291:15 301:7 317:2 

317:14,17 318:9 

319:22 324:9 329:11 

353:16,19 357:17 

358:4,12 362:11 

363:12,17 364:11 

365:2 374:7 375:11 

403:7 412:21 413:1 

415:5 422:12 

cross-pollination 113:7 

Crosse 84:6 

crucial 169:12 

crude 341:1 

CSU 198:10 

cultural 239:22 

cultures 150:1 

curious 149:10 274:13 

332:22 380:16 

current 183:4 203:19 

220:12 243:11 261:3 

285:4 286:11 298:3 

388:16 391:6 

currently 33:9 53:5 

136:11 162:17 179:18 

193:18 195:21 260:15 

323:7 373:6 403:16 

417:21 

curve 199:6 

curves 13:20 

customer 95:19 

customers 97:3 

cut 84:15 156:12 371:6 

cuts 395:9 

cylinder 123:14 

D

dairy 42:3 74:22 77:19 

83:13 91:12 95:9 97:1 

97:15 139:1 144:6 

damage 119:20 158:9 

337:5,9 355:5,6 403:7 

damages 337:16 

Dan 1:20 24:9,11 36:20 

41:3,3 42:18 79:19 

106:17 147:8 149:2 

149:15 175:15 177:15 

232:6 295:18 384:17 

dandy 420:1 

dangerous 192:20 

264:10 

dark 255:4 

data 8:20 9:3 13:7 17:1 

17:8,11 21:1 56:1,16 

60:16 66:15 183:2 

220:22 289:16,17 

291:4 292:19 351:6 

351:16 

database 15:9,21 66:16 

245:7 251:7 253:16 

253:19 254:3,21 

date 10:6,8 426:2 

dated 210:3 

dates 400:11 

daughter 195:4 

Dave 1:17 6:11 14:7 

26:11 58:3,6 63:17 

72:14 97:19 98:22 

108:18 112:13 120:9 

141:1 145:19 170:7 

171:11 187:14 199:2 

206:2 214:14 272:9 

276:15 277:3 287:13 

288:22 293:22 295:14 

300:21 303:7,12,15 

324:4 325:5 326:14 

332:20 357:8 360:9 

386:3 396:15 398:14 

399:21 400:1 407:18 

407:22 

day 6:5 38:22 103:6 

280:5 

day-old 356:13 

days 147:15 338:22 

426:8 

de- 159:22 162:19 

164:7 173:11 

de-oiled 3:20 160:3,21 

161:3,7,12,18 162:20 

163:22 164:6 166:17 

168:2,8 170:16,22 

171:17 

deal 30:1 32:11 351:3 

368:20,22 369:22 

401:7 

dealing 112:11 393:4 

dealt 350:18 

dear 305:5 

deaths 201:2 

debate 23:14 64:5 

150:13 168:16 209:18 

253:6,8 

debates 425:9 

decide 101:16 171:2 

310:10 379:6 

decided 68:13 140:17 

140:20 369:14 375:4 

379:16 417:4 

deciding 368:21 

decision 88:8 120:15 

120:19 351:12 

decisions 406:4 

declaration 240:21 

declare 137:8 233:3 

240:20 374:5 

decline 380:15 

declined 144:22 

decreased 280:11 

dedication 426:8 

deduce 54:3 

deem 261:8 

deeply 82:16 

defense 183:14 289:10 

289:12 377:4 

defer 258:8 294:8 

deferred 5:13 413:9,10 

defined 238:1 

definitely 82:13 89:6 

146:7 169:15 213:2 

213:15 215:2 222:16 

226:22 238:1 263:21 

314:8 354:2 414:4 

definition 216:1,5,18,21 

217:4 286:11 369:8 

definitive 88:15 381:16 

degradance 351:7 

degree 275:22 

degreening 118:5 

delete 396:6 

deliberately 216:8 

deliberation 350:14 

deliberations 33:20 

54:14 62:17 

delist 65:19 168:19 

169:6 274:7 294:6,9 

320:16,19 

delisted 96:2 140:7 

154:8,16 163:5 

delisting 61:8 161:2 

169:16 319:15,18 

322:18 

deliver 400:6 

delivered 76:22 77:1 

delivery 76:7 

demand 71:16 229:5 

248:13 

demonstrates 163:19 

Denmark 405:8 

deodorize 44:4,9 

deodorizing 45:1,6 

department 1:1 78:16 

depending 155:18 

162:20 167:4 204:14 

229:5 393:9 410:1 

depends 219:10 384:5 

deploy 20:13 

deployed 18:12 

deposits 131:5 

depth 279:8 

Deputy 2:9,15 

derailed 169:4 

deregistered 318:8 

319:3 

deregistration 318:6 

Deregulatory 75:3 

deriv 164:17 

derivative 164:16,18 

365:17 

derived 91:1 129:1 

147:15 160:9 340:21 

347:12 

dermal 305:22 

describe 110:12 213:13 

described 247:17 396:8 

398:9 

deserve 213:12 

Designated 2:17 

designed 216:8 

desired 91:8 139:7 

desk 413:12 

desperately 354:12 

despite 163:12 

destined 8:6 

destroyed 12:10 

detail 111:9,20 112:16 

231:20 254:19 255:15 

deter 21:10 

deteriorate 243:15 

determination 88:15 

182:3 205:4 318:6 

322:11 367:2 

determine 110:20 128:3 

128:9 246:10 392:15 

develop 163:8 199:22 

developed 10:18 91:16 

173:7 401:14 

developing 23:1 78:17 

157:9 158:6 165:2,13 

245:18 246:19 260:19 

414:16 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
438 

development 9:11 

16:12 21:14 120:21 

208:14 211:7 259:15 

devices 226:13 

Devon 2:13 48:17 49:22 

427:2 

devotion 426:8 

di 3:15 123:6,8,11 

dialogue 285:17 

die 70:19 

dietary 87:17 259:6,14 

259:16,22 260:10 

difference 9:1 297:4 

301:2 334:5 

different 11:5 15:15,16 

31:20 32:4 60:13,20 

62:11 71:5 80:12,13 

80:19 95:21 110:4 

136:8 153:1 154:17 

156:11 157:15 167:21 

171:5 187:5 189:15 

191:22 196:5 197:7 

198:14 205:10,21 

236:18,22 243:20 

246:4 249:9,19 

254:13 265:20 284:7 

293:11 297:3 317:4 

377:2 379:3,14 

389:11 393:8,21,21 

406:3 

differentiate 240:2 

differentiation 163:1 

differently 74:17 

116:18 141:5 152:22 

406:4 

differing 352:13 

differs 235:11 

difficult 54:22 61:11 

145:8 237:2 248:5 

348:2 425:6 

difficulties 68:2 287:3 

difficulty 247:16 280:6 

diglycerides 124:1,10 

dihydrogen 4:4 207:1,3 

224:1 415:18 

diligence 198:20 

227:20 228:1 230:22 

231:2 237:10 238:9 

252:12 255:12 360:5 

366:7 408:16 

diluting 220:2 

dilution 221:17,19 

dioxide 3:17 4:3 135:8 

135:10 137:15 178:16 

178:22 179:5,7,18 

180:9 181:8,15 182:5 

182:14,16 185:4,10 

201:22 202:3 203:1 

203:13 205:17 

dip 38:2 

dips 38:10 62:20 

direct 40:21 41:6 179:1 

180:13,17 289:7 

directing 211:19 

direction 357:14 360:10 

361:19 

directly 9:18 33:4 75:15 

77:2 81:7 85:8 287:2 

319:20 378:19 

disagree 343:3 

disagreed 341:19 

disagreement 260:4 

disallow 381:12 

disallowance 371:2 

disappointed 52:18 

disclosed 96:1 

disclosure 314:1 334:7 

discretion 49:1 

discuss 34:2 154:4 

262:7 352:5 368:17 

377:7 392:4 

discussed 44:12 57:21 

71:21 82:15 130:17 

154:8,9 214:4 235:18 

290:19 329:8 390:1 

415:20 416:17 

discusses 350:22 

discussing 72:11 282:6 

368:19 

discussions 118:9 

293:7 306:10 324:17 

326:18 415:20 

disease 201:11 268:20 

288:17 290:11 297:6 

298:1 301:5 304:20 

305:8 309:17,19,21 

313:20 324:2,8 337:8 

338:11 376:2,5 

diseases 362:3 376:19 

disinfectant 22:11,13 

22:22 23:7 25:15,18 

178:20 179:20 180:7 

183:16 207:9 

disinfectants 268:10,19 

disinfecting 180:1,3 

disorder 403:10 

disorders 402:21 

disperses 139:4 

dispersing 160:12 

disposal 208:8 

disposed 212:4 420:20 

disrupt 314:20 

disservice 97:9 

dissipated 194:19 

dissolve 115:9 

distillates 340:22 

distinction 361:8 

distinguish 137:6 

distinguishing 173:22 

distributed 182:4 248:3 

distribution 119:17 

182:18 199:6,12 

239:18 

distributor 188:17 

distributors 212:13 

ditches 272:15 275:1 

dive 414:14 

divert 222:8,9 

diverted 9:17 

docket 85:11 113:11 

225:19 387:18 412:3 

413:2 417:14 

document 3:9 4:6,6 5:8 

5:10,11 68:18 111:2 

258:10,17 263:3 

394:3,7 399:20 

402:10,14 416:17 

417:2 418:6 

documentation 145:10 

162:14 

documented 309:21 

documents 185:7 

261:20 399:16 415:6 

417:10 

doing 9:12 10:11 11:8 

16:12,13 19:3 20:15 

50:8 55:1,17 58:8 

83:15 98:17 174:21 

189:12 195:8 230:21 

237:7 272:9 273:15 

332:16 337:22 338:5 

355:16 389:10 392:11 

domestic 55:19 158:3 

165:3 

domestically 165:7 

227:1,8 341:10 

dominant 125:22 126:9 

dooper 199:7 

door 367:7 

double 382:5 

double-check 31:22 

doubt 283:15 

dough 87:18 

dozen 147:5 

dozens 100:1 

draft 297:2,2 

dramatic 354:18 

dressings 139:1 

dried 123:14 152:15 

247:4 

drift 306:12 

drink 99:14 

drinking 99:14 180:8 

drip 350:22 

drop 8:13,22 9:4 166:21 

329:16 

dropped 13:16 149:7 

dropping 101:16 

drug 27:16 48:1 

drum 123:9,11 

dry 155:17 376:1,5 

dry-pack 91:13 

drying 123:9,11 

due 84:1 95:19 140:7 

152:16,21 153:16 

166:6 198:20 227:19 

228:1 230:22 237:10 

238:9 252:12 255:12 

360:5 366:7 408:16 

dust 306:6,7,18 307:5 

307:12 308:21 310:18 

348:4,5 

Dutch 133:13 

E

e 143:18 154:16 296:20 

297:18 298:17 302:5 

302:15 304:18 313:15 

347:11 

ear 425:17 

earlier 73:9 92:7,8 

118:15 185:5 236:17 

250:11 262:2 416:18 

early 19:15 75:1 259:20 

284:22 388:7 427:5 

easier 171:6 262:6 

329:5 

easily 191:5 227:8 

East 1:9 72:17 290:15 

376:10 

easy 255:8 393:14 

404:16 

eat 99:13 228:13 

eating 99:13 

echo 33:17 73:8 79:5 

88:22 169:14 187:17 

204:19 215:17 252:10 

262:5 285:1 286:16 

334:13 358:3 370:14 

408:12,18 412:11 

echoed 403:5 

echoes 58:12 

ecologist 58:12 

economic 84:11 169:3 

261:3 266:9 336:21 

337:2 

economically 157:22 

economist 13:4 

ecosystem 355:17 

358:6 

edema 185:12 

edification 32:6 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
439 

editorial 315:3 

education 145:15 

effect 45:16 139:5 

367:20 368:1 370:20 

375:2 

effective 58:15 62:6 

63:3 72:2,4 73:4 

76:22 77:4 131:4 

139:8 173:20 184:4 

212:21 317:19 334:10 

effectively 295:8 

392:15 

effectiveness 60:4 

76:21 

effects 152:19 174:12 

185:3 186:16,19 

289:7,8 291:11 294:5 

354:18 404:1 

efficacious 208:16 

efficacy 52:20 60:13,19 

60:21 61:6 62:11 

289:17 292:1,1 

effluence 211:12 

effluent 221:20 

effort 170:1 232:3 

245:18 249:5 

efforts 237:6 

egg 229:9 

eggs 168:5 

Eh 238:5 

either 34:4 38:8,11 

55:19 57:6 69:22 

157:10 198:12 259:17 

276:13 289:6 340:17 

367:11 368:19 393:19 

elaborate 345:12 

elected 419:7,9 420:11 

election 418:20 

elections 5:17 6:8 

418:15,16 

electrolytes 3:6 35:20 

36:1,3,10,18 

elemental 4:12 296:15 

300:15 304:15 305:1 

312:7 331:9 332:16 

elevate 408:4 

elevated 78:9 217:21 

218:21 

Eleven 258:2 

eligible 418:22 

eliminate 307:11 

eliminated 307:5 

Ellepot 405:7 

Ellor 376:6 

email 273:8 377:5 409:1 

emailed 55:11 

Emily 1:17 20:21 32:20 

50:20 59:19 76:3,19 

82:10 83:11 93:3 

96:10 110:16 112:19 

113:1 134:9 145:19 

161:14 172:19 187:13 

188:3 204:22 215:16 

222:4 223:15 226:20 

230:8 236:15 240:5 

246:1 249:12 257:8 

270:22 272:9,13 

277:1,16 279:21 

283:5,20 285:20 

293:20 301:15 315:14 

319:12 320:22 327:21 

336:2 339:8,10 

343:15 344:19 345:11 

346:4 348:16 352:7 

353:18 354:11 358:2 

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372:22 377:18 384:14 

385:18 392:7 396:12 

396:13,14,15,15,16 

396:19,20 399:22 

401:7 408:12,19 

421:11 425:16 

Emily's 357:12 

empathize 192:16 

emphasize 44:8 169:19 

228:3 

emphasizes 308:5 

employed 336:21 

employer 311:12 

emulsification 160:11 

emulsifier 123:11 

173:20 

emulsifiers 96:9 124:2 

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enclosed 181:9 

encourage 31:18 78:1 

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165:17 168:10 173:5 

173:9 190:7 252:6 

267:17 277:9 306:4 

387:17 390:9 408:4 

425:9 

encourages 248:8 

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209:7,9 248:18 

279:18 

encrusted 130:14 

endeavor 82:13 

ended 22:3 

endosperm 152:14 

enforce 165:14 

enforced 238:1 

enforcement 6:12 

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409:22 

enforcing 82:3 405:20 

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engineered 209:21 

210:18 216:7,8 

engineering 102:20 

148:8 

English 374:19 

enhance 119:12 

enhancer 107:22 144:3 

enjoy 339:1,3 

enjoyed 427:21 

ensure 23:22 74:18 

96:4 124:3 407:7 

enteritidis 32:15 

enthusiastically 75:21 

76:5 78:2 

entire 68:14 80:15 

254:15 426:6 

entirely 80:13 147:14 

247:15 

entrance 70:2 

entries 254:2 

entry 12:3 337:7 

environment 41:11 

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187:4 208:5,7 211:5 

211:17 317:12 341:7 

361:1,2 375:19 

environmental 23:5 

53:3 112:6 131:2 

183:2 185:8 186:16 

189:6 211:11 219:12 

219:14,22 220:2 

292:8 314:11 

environments 186:22 

EPA 52:13 53:21,22 

54:10 57:19 59:13,14 

59:14 63:7 65:14 71:3 

182:13,21 211:22 

218:6 220:15 308:7 

317:3 319:6,15,20 

320:10 

equally 157:12 406:5 

equipment 40:21 41:5 

72:1 130:11,16,17 

180:2 191:7 197:1 

207:10 306:17,21 

333:7 

equivalency 389:20 

equivalent 389:18 

era 201:8 

Eric 1:19 42:20 129:9 

137:17 171:19 242:3 

330:6 421:16 

erosion 284:3 

error 298:9 

ERS 55:22 

ESMA 319:8 

especially 21:9 80:17 

135:22 158:9 191:6 

227:7,12,13 274:2,15 

306:11,18 307:12 

329:20 358:4 374:18 

376:10 393:3 408:20 

412:1 

essential 41:12 42:3 

55:18 75:7 105:9,15 

134:3 136:18 137:20 

140:5 144:15 149:12 

150:8 156:5 183:2 

239:9 308:2 327:12 

336:6,20 338:14 

essentiality 110:7 

135:16,21 199:22 

292:2 294:12 305:14 

314:9 

essentially 82:14 

109:22 118:11 265:1 

293:7 333:17 381:17 

393:11 403:20 

establish 92:22 

esters 3:8 4:14 51:19 

51:22 52:7,8 57:15 

67:1 78:21 316:14,19 

317:12 322:3,14 

estimate 261:3 

estimated 261:6 

ethanol 3:4 4:9 22:13 

22:18,21 23:4,7 99:3 

99:4 268:12,14,17 

269:5 

ethanol-based 23:19 

Ethiopian 4:5 235:6,11 

240:17 241:19 

ethnic 240:1 

ethylene 3:15 4:18 

63:20 118:2,4,9,10,15 

118:18 120:3 121:11 

121:14,22 335:20,22 

338:13 339:7 340:17 

EU 57:5 139:14 141:5 

153:4 319:10 

Europe 9:8 141:8 

European 57:1,3 

evaluate 200:2 308:1 

evaluated 78:15 

evaluating 140:13 

219:10 291:5 

evaluations 306:4 

evening 22:3 191:11 

194:17 

evenly 425:8 

event 420:16 421:1 

426:17 

events 155:19 

eventually 57:9 

everybody 166:15 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
440 

231:20 331:15 

everybody's 194:10 

everything's 379:9 

evidence 169:22 

214:21 250:7 

exact 231:13 318:7 

321:11 

exactly 170:12 297:3 

examine 199:22 

example 13:9 16:20 

18:4 60:2,8 98:10 

100:22 150:11 154:14 

174:19 191:10 216:12 

268:18 290:10,16 

334:6 350:21 378:22 

379:4 

examples 11:22 111:17 

exceed 135:12 180:6 

326:13 

excellent 63:19 

exception 63:21 216:19 

332:5 

exceptions 155:9 

excessive 136:6 

exchange 274:2 

exchanged 218:14 

excluded 32:1,9,16 

34:10 92:17 96:5 

100:3 147:20 213:6 

416:7,15 

excluding 207:7 

exclusion 100:2 147:19 

377:4 

exclusions 92:19 

excuse 148:21 235:2 

258:2 288:10 

executive 369:13,14 

418:6 420:6 

exist 336:12 402:18 

existed 400:13 

existing 407:14 

expand 161:4 168:18 

expanding 405:2 

expands 265:21 

expect 416:22 418:1 

expecting 415:6 

experience 50:11 57:11 

expert 243:3 250:4 

explain 184:14 205:10 

255:10 

explanation 231:6 

explicit 249:20 

explicitly 405:22 

explore 111:19 113:4 

171:3 353:11 357:3 

explored 197:17 

exploring 359:12 

export 336:7 

exposed 187:20 

exposure 181:7,10 

185:9 199:16 275:22 

280:10 291:3 306:8 

exposures 186:8 187:9 

310:21 

express 33:21 188:6 

354:4 

expressed 75:5 139:20 

expressing 88:1 

expression 327:3 

extend 99:19 180:8 

extending 11:14 

extensive 305:9,20 

392:12 404:19 

extensively 36:4 38:10 

71:22 329:1 342:14 

extent 150:5 273:21 

343:20 

external 43:22 44:2 

47:16 48:2 

externally 49:19 

extra 112:9 251:15 

extracted 152:11,14 

160:7 263:7 

extraordinary 63:21 

extreme 388:13 

extremely 21:12 62:14 

147:4 157:20 284:4 

380:12 

extremes 153:17 

eye 165:18 169:12 

374:14 

eyes 185:10 

F

fabulous 427:2 

face 218:17 321:8 

face-to-face 9:7 

facilitates 118:12 

facilities 180:1 183:20 

187:9,20 194:14 

facility 179:8 190:22 

191:2 

facing 388:14 

fact 41:16 59:1 61:11 

62:20 187:10 196:16 

212:7 239:18 293:7 

310:17 341:19 342:7 

343:10 361:18 

facto 235:20 236:6 

237:21 

factors 414:15,17 

fad 149:4 

fads 149:19 

fail 167:2 209:11 224:8 

failed 210:12 

fails 25:8 27:8 29:11 

35:17 37:17 40:14 

43:16 47:6 51:16 

90:13 94:21 104:12 

107:13 109:14 114:15 

117:22 123:3 125:9 

130:5 132:22 135:5 

138:15 142:13 152:6 

159:21 172:18 178:11 

206:21 235:4 242:21 

270:5 271:20 278:16 

281:17 288:12 296:14 

304:10 313:10 316:12 

326:4 331:2 335:17 

340:6 347:5 349:15 

fair 75:7 190:17 261:11 

286:13 314:1 328:21 

402:10 

fairly 33:10 63:14 66:3 

72:6 150:8 239:20 

255:11,15 268:1 

359:6 374:17 377:1 

faith 406:4,22 

fall 1:5 70:4,6 72:13 

135:20 169:9 209:20 

291:14 317:16 326:17 

400:13 406:17 419:10 

falls 164:8 

familiar 258:22 359:9 

family 52:6 

fan 237:20 

far 30:10 61:20 62:2 

69:2 98:9 123:15 

139:18 140:14 145:18 

158:3 164:13 195:16 

273:1 353:20 368:20 

farm 15:2,3 42:4 175:12 

190:22 199:12 222:10 

222:21 249:22 273:4 

282:9 305:22 368:7 

389:5,8 392:12 

farmed 332:4 

farmer 36:7 193:9 199:5 

228:5,6 229:3 237:5 

249:18 274:1,2 283:8 

farmer's 238:4 

farmers 61:13,13 75:13 

82:17 84:5 85:6 121:1 

239:14 244:22 246:4 

388:9,12 405:11 

408:14 

farmers' 255:5 

farming 236:19 246:3 

250:2 292:9 

farmland 332:3 

farms 15:6 77:19 

194:14 198:4 273:5 

329:20,20 331:13 

farmstead 215:13 

fascinating 168:15 

fashioned 424:9 

fat 124:3 

fate 215:11 217:15 

218:6 

fats 38:3 

fatty 52:7 121:14,17 

faulty 333:7 

favor 23:4 26:1 41:9 

44:11 108:4 153:12 

174:8 192:4,5 232:14 

261:11 268:16 270:16 

291:15 311:17 314:4 

314:15 332:6 342:14 

355:10 405:14 

favorable 263:14 343:2 

favorably 180:18 

favorite 416:10 

FDA 32:13 47:21 48:1,9 

48:15 49:4,8,19 50:2 

92:21 102:10 211:22 

220:15 345:17 

FDA's 218:6 

feasibility 110:18 111:1 

246:10 

feasible 358:16 

fed 150:7 

federal 2:17 7:20 48:10 

75:6,12 85:5 272:4 

282:16 

federally 32:13 

federally-mandated

34:4 

feed 22:14 279:3 369:9 

377:16 

feedback 61:12 79:10 

151:9 290:13 291:21 

412:3 416:18 

feeding 289:7 291:9 

feel 65:17 72:2 168:12 

186:20 188:7 223:6,7 

227:6 347:21 351:10 

359:11 369:16 370:21 

383:7 391:9 

feels 243:20 408:14 

felt 127:3 146:14 

204:17 255:14 274:9 

FEMA 92:21 

ferment 100:21 

fermentation 38:17 

39:1,4 93:9,14 98:1 

99:2,5,9,20 140:14 

141:10 144:11 176:14 

fermented 98:2 101:3 

103:2 

fermenting 100:20 

fertilizer 112:17 367:22 

368:1 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
441 

fewer 273:1 280:2 

fiber 144:2 

fibers 292:11 

fidelity 407:13 

field 20:11 75:9 120:21 

183:15 187:18 201:4 

212:3 221:4 284:1 

291:2 337:7,15 338:7 

379:14 406:10,15 

fields 187:12 272:15 

317:7 357:16 

fif 235:2 

Fifteen 25:7 27:7 

figuratively 286:17 

figure 10:16 113:11 

198:19 226:13 

filled 428:6 

fillings 95:8 

filtered 222:13 

filtration 341:2 

final 7:14 19:21 75:15 

85:8 105:4 174:2 

328:20 329:4 367:20 

382:19 411:11 413:9 

413:10 

finally 404:15 420:18 

427:7 

financial 406:21 408:20 

find 97:1 187:2 188:21 

189:15 221:12 230:5 

245:4 251:5 253:13 

348:2 376:1 382:14 

390:5,8 

finding 163:12 220:15 

228:5,6 237:7 

findings 74:13 89:5,6 

284:22 

finds 88:10 

fine 339:3 

finish 395:17 

finished 91:8 95:11 

100:7 101:15 139:3 

182:4 266:5 

finishes 412:21 

fire 315:5 

firming 115:6,18 116:1 

116:3 

first 6:17 22:6 68:11 

76:17 79:21 87:5 

105:22 111:19 175:18 

178:14 183:14 187:15 

208:18 209:17 232:21 

249:20 251:5 255:22 

258:21 268:5 297:2 

313:15 348:1 354:22 

358:10 367:8 371:10 

381:11 399:20 401:16 

401:21 404:2 413:15 

414:2 418:21 420:10 

425:20 

fiscal 11:19 20:1 

fish 4:16 326:6,10,15 

327:5,6,17 328:19 

330:2 415:11 

fit 189:4 286:11 336:19 

five 62:20 82:21 228:16 

228:16 247:3 345:17 

389:22 390:4 

fix 396:2 417:20 

fixed 314:10 

fixing 338:1 

flag 18:12 

flat 191:4 

flavor 91:7,9 107:22 

136:1 144:3 

flavoring 92:17,22 

107:22 

flavors 3:12 90:15,17 

90:22 91:15,21 92:12 

92:14,20 93:8,10,21 

flexibility 300:7 388:15 

409:18 

flies 376:18 

flip-flopping 203:14 

flood 368:10 

floor 84:16 343:5 

flow 105:3 125:21 

flowering 336:1,4 337:5 

337:14 

fluid 163:4,8 164:6,7 

flummoxed 198:2 

fly 377:2 

focal 20:3 

focus 7:14 82:2 226:10 

focused 10:2 81:13 

350:4 426:17 

focusing 239:20 

foliar 289:4 317:6 324:7 

403:10 

folks 6:16 11:12 20:18 

23:21 62:7 65:12 

80:20,21 100:15 

102:10 103:9 105:18 

150:7 155:10 156:10 

187:19 192:12 193:1 

198:11 199:7,9 

229:21 249:2 261:15 

261:18 286:7 289:19 

290:15,17,22 293:1 

310:18 345:6 353:16 

408:9 

follow 6:11 171:12 

197:15 354:11 360:8 

follow-up 76:20 

followed 182:2 

following 160:6 311:12 

350:15 364:5 419:17 

food 87:12 91:4 95:7 

98:19 100:8 102:8 

112:8 123:9,12,14 

125:16 130:10 138:21 

152:16 179:3 180:3 

180:13,14,17 184:8 

186:17,22 187:19 

198:4,21 201:1 207:9 

207:10 210:21 212:13 

212:15,19 213:3 

214:10,11 216:15 

228:8 231:7 254:16 

272:5,6 320:11 

336:14 338:14 359:8 

360:17 366:20 367:17 

369:4,9 374:12,20 

375:1 380:17 

foods 81:8 91:13 

107:21 115:4 139:2 

144:4,4,5,10,21 

149:13 150:7 365:20 

381:12 

forage 62:1 

force 287:1 

forcing 156:10 

foreign 7:12 11:13 13:5 

18:13 19:4 228:15 

forest 343:5 

forgot 285:21 

form 95:5 148:22 

164:11 166:12,21 

171:13 173:19 180:9 

181:16 183:16 187:21 

189:14 215:1 238:11 

311:4 318:7 412:6 

formal 399:19 

formation 179:15 

former 212:14 292:5 

376:7 

formerly 8:11 

formic 57:15 69:17 

forming 401:20 

forms 95:13 147:11 

156:11 160:21 164:4 

171:1,7 173:11 187:5 

257:4 

formula 108:5 145:2 

146:2,10,14 147:7 

150:13 

formulas 144:16 146:22 

147:1 150:6,14 

formulate 249:10 

formulation 71:6 

169:20 309:1 

formulations 91:15 

92:1 110:8 

formulators 249:4 

forth 225:20 318:21 

fortify 115:4 

forward 11:20 29:22 

63:2 66:5 68:17,21 

69:6 73:13,22 74:3 

78:2 79:17 112:12 

140:21 174:7,10,17 

174:18 186:1 207:4,4 

208:19 217:5 232:17 

258:18,19 261:9 

265:8 282:20 298:12 

328:7 329:12 345:10 

356:18 360:2 365:16 

366:8 375:6 387:12 

387:15 391:18 394:4 

402:12 409:20 414:6 

415:7 416:13,17 

417:15,18 418:1,12 

425:14,22 

forwarded 298:19 

300:9 

FOS 3:18 143:12 

foster 19:3 

fought 65:5 

found 70:10 130:15 

139:22 144:17 164:13 

170:2 207:20,21 

208:6 251:7 253:17 

318:16 342:10 374:9 

389:22 

four 6:16 62:20 155:16 

164:22 209:16 317:18 

342:19 343:6 351:18 

390:6 400:14 

fourth 7:17 

frame 83:4 

frames 69:19 215:3 

framework 77:6 

frank 318:19 

frankly 359:3 

free 121:14,17 391:9 

412:14 

freeze-thaw 139:10 

freezing 216:16 

fresh 91:14 

FRIDAY 1:7 

friends 318:19 

friendship 428:10 

front 202:21 377:4 

380:20 

frozen 139:2,8 

fructooligosaccarhid...

143:12,19,20 

fructooligosaccharid...

3:18 151:4 

fruit 118:5,14,14 136:15 

182:14 191:4 197:1,6 

207:6 244:8 301:6 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
442 

324:9 331:18 334:14 

354:8 382:20,20 

fruiting 121:2 

fruits 118:20 120:7 

178:20 179:2 182:15 

301:6 380:6 

FSMA 191:5 196:3 

197:7 228:11 

fulfill 226:6 

full 68:16 70:17 176:4,7 

255:2 314:1 334:7 

345:10 384:3 394:16 

407:7 

fully 12:13 147:20 

162:2 229:16 263:9 

344:9 

fully- 112:20 

fumigant 180:17 351:15 

354:15 

fumigants 357:1 359:18 

fumigate 191:9,11 

196:11 

fumigation 8:5 355:13 

fun 338:21 

function 305:17 

functional 367:20 

functionalities 91:17 

112:9 

functionality 140:2 

funded 284:15 

funding 19:21 20:2 

funds 388:10 

fungal 297:5 315:5 

358:14 374:14 

fungi 351:1 375:19 

fungicide 309:14,15 

314:5 

funny 196:14 

further 23:13 34:14 

39:7 42:7 46:2 66:18 

111:8 173:7 209:10 

211:6 213:20 216:3 

223:8,22 253:6 

350:14,20 351:11 

353:12 371:4 384:8 

391:10 397:22 408:2 

410:7 414:10,15 

future 41:20 60:6 154:8 

165:16,17 167:20 

172:22 173:6 310:10 

323:8 401:22 

G

gain 268:2 

gala 393:7,7 

game 16:8 80:7,8 

gap 189:1 

gaps 200:7,7 

gas 4:3 178:16,22 179:7 

179:16 180:17 181:15 

182:5,11 183:16 

191:8 199:10 201:22 

202:3 203:1,13 

205:17 336:1 339:7 

gaseous 180:9 183:16 

187:21 189:14 195:9 

gases 194:18 201:4 

gather 267:6 

gavel 428:18 

gear 72:20 

gel 4:6 95:14 249:1 

263:1,5 265:4 

gelatin 95:21 260:22 

265:1 

gellan 3:12 95:1,4,6,10 

95:12,18 97:3 103:7 

103:12 

gelling 87:20 95:7 

108:7 110:2 139:5 

gels 264:18 

general 74:15 111:7 

177:4 184:18 211:20 

212:9 232:8 332:5 

411:14 414:14 

generally 91:6 96:8 

100:2,5 110:1 128:2 

161:13 164:7 210:5 

219:13 254:7 420:3 

generate 266:8 

generated 181:16 203:2 

generation 4:3 152:18 

178:15 203:12 205:17 

331:8 

genetic 30:11 102:20 

415:15 416:18 

genetic-modified

102:20 

genetically 30:3 147:14 

getting 16:7,9 21:9 

64:19 133:10 150:1 

166:9 196:5 229:20 

239:21 251:8 252:16 

252:17 253:1,1 

308:22 350:4 375:3 

GFSI 228:9 

give 13:22 15:11 20:10 

32:13 91:8 106:2 

147:10 231:13 244:18 

255:10 302:4 321:21 

381:16 382:2 389:9 

391:1 424:11 426:3 

426:10 427:10 

given 32:18 62:6 

162:12 164:22 183:1 

202:10 203:19 209:1 

215:10 232:8 285:4 

310:2 360:4 386:1 

391:6 

gives 98:5 248:10 262:9 

331:20 369:11 

giving 68:20 139:5 

151:8 169:11,12 

238:15 291:22 390:22 

glad 395:14 

global 12:14 185:13 

glossy 279:5 280:6 

glucosuria 147:2 

gluten-free 139:16 

glycerides 3:15 123:5,8 

123:10 

glycerin 3:6 37:20 38:1 

38:6,15,22 39:1,15,17 

163:15 379:1 

glycinate 5:9 402:6 

GM 141:6,8 

GMO 34:8,9 98:10,17 

GMO-related 127:10 

GMOs 103:8 

GMs 103:2 

go-round 169:11 

go-to 191:1 

goal 6:17 13:22 82:4 

199:21 

goods 91:12 138:22 

140:3 144:5 160:15 

Googling 58:8 

gosh 19:10 

gotten 11:6 178:16 

government 10:11 

18:14 19:2 48:10 

Government's 75:2 

grace 405:15 

grades 104:17 

grafting 361:5 

grain 9:14 18:5 84:6 

grant 228:7 

grants 227:4 

granular 311:4 

grape 164:12 

grapes 135:11 136:12 

136:16 207:7,8 

graph 18:5 

GRAS 92:22 

grass 110:2 

gray 410:1 

greater 157:13 208:2 

greatest 392:9 

green 212:17 358:11 

greenhouse 187:18 

greenhouses 317:7 

greening 118:16 

greens 212:19 

GREENWOOD 1:16 

24:16 26:15 28:18 

35:1 36:22 40:11 

43:11 46:22 51:9 

67:17 86:1 90:3 94:10 

103:22 106:22 108:22 

113:22 117:6 122:8 

125:5 129:22 132:15 

134:20 138:7 142:4 

151:18 159:10 172:6 

177:20 200:21 206:6 

224:13 233:7 234:8 

241:14 242:16 256:17 

257:19 269:21 271:11 

278:6 281:6 287:22 

296:1 303:19 312:17 

315:19 322:22 325:22 

330:19 335:11 339:21 

346:17 349:5 362:22 

372:6 373:9 384:22 

386:7 397:5 398:18 

410:14 

ground 16:11,14 18:13 

19:4 84:13 309:5 

310:20 356:12 390:5 

390:9 

ground-level 20:14 

groundwater 221:5 

group 82:2 110:20 

223:12 254:9 259:10 

301:3,3 314:15 

grouped 299:22 300:3 

grouping 298:12 

groups 30:16 36:7 

83:12 87:12 91:22 

125:16 144:7 237:5 

249:22 282:19 336:9 

338:14 375:10 

grow 119:12 141:6 

157:2 226:17 234:13 

234:14 235:14 237:1 

254:9 273:11 338:7 

389:4,20 

grower 338:19 354:21 

382:9,20 

growers 64:5 66:12 

158:14 196:6,22 

198:9,18 274:5 292:4 

305:11 306:17,20 

308:20 332:7 334:3,4 

334:9 337:22 341:17 

342:18,19 344:2 

375:22 376:10,20 

377:20 378:5 388:19 

389:1,4 390:9 406:21 

408:20 

growing 175:10,11 

208:13 265:18 283:12 

285:22 342:6 343:12 

360:22 392:14 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
443 

grown 12:2 141:8 

153:18 157:14,20 

158:3 175:14 227:1,8 

235:12 236:11 251:17 

265:18 359:19 415:15 

grows 235:15 273:5 

growth 12:17,22 13:15 

18:21 19:3 118:11 

119:7 120:13,19 

168:10 335:22 

guar 3:19 139:12 152:9 

152:11 153:11 157:14 

158:3,21 

guess 33:17 49:9 61:9 

63:18 72:22 89:9 

98:21 100:9 111:15 

122:1 146:1 168:3 

169:5 187:16 196:13 

198:1 199:4 209:15 

228:3 238:14 239:12 

266:3 276:10 294:22 

300:10 322:11 355:9 

356:2,22 357:9 

359:22 360:13 361:9 

419:13 422:3 425:1,2 

guessing 112:17 195:5 

guidance 5:6 88:8 

260:3 366:14 368:22 

387:2,8,11 390:21 

394:6,12 395:6,10 

415:14 

guide 223:1 

gum 3:12,18,21 4:5 

95:2,4,6,10,12,18 

97:3 98:6 103:7,12 

138:17,19,21 139:2 

140:18 141:14 152:22 

153:21 154:2 155:4 

157:19 158:3,20,20 

158:21,21 160:6 

173:14,16,17 174:3 

176:13,13 177:10 

230:16 243:2,6,14 

244:11,18 245:8 

248:10,19,22 249:8 

251:10,11,13 252:1,4 

253:22 254:17 256:1 

257:3 

gums 3:19 96:5 97:7,8 

101:11 110:3 139:6 

139:11,21 140:1 

152:8,10,13,21 153:3 

153:8 154:6,7,18,21 

155:11,13 158:3 

176:15,21 204:8,17 

243:4,11,21 244:3,19 

249:1 

gycinate 399:21 

H

HACCP 228:14 

half 19:6 147:5 267:17 

hand 6:13 21:21 98:18 

121:4 267:14 354:1 

365:1 409:7 410:9 

426:22 

handing 87:2 

handle 232:8 379:6 

handled 203:17 212:2 

handlers 96:4 119:17 

184:1 

handling 3:10 4:2 6:6 

86:19 87:3 93:11 

99:21 111:3 116:15 

119:18 140:17 142:18 

143:9 179:1,8 180:2 

200:16 210:1 223:21 

225:10 236:10,13 

262:16 371:11 379:15 

380:6 415:17,17 

handy 420:1 

hangry 266:20 

happen 77:17 276:1 

359:20 418:10 

happened 13:17 15:16 

76:12 230:5 273:21 

409:15 

happening 8:2,9 10:16 

388:8 

happens 72:22 96:2 

342:15 

happy 21:13 218:16 

340:7 390:17 

hard 53:1 54:21 58:13 

58:15 59:5 62:14 67:7 

83:1 97:1 148:15 

173:6 195:22 198:6,8 

228:18 239:8 254:5 

254:10 263:18 

harder 232:11 235:13 

hardship 77:19 169:3 

harm 55:17 355:16 

harmful 41:10 

harmless 22:21 

harmonization 185:13 

Harriet's 59:6 171:3 

334:2 365:6 

harsh 185:1,22 186:15 

harvest 166:9 167:4 

336:14 356:6 

harvesting 110:11 

112:16 

hate 59:16 72:9 292:15 

Hawaii 66:4,8 

hay 279:14 

hazard 52:20 

hazardous 71:3 

hazards 131:3 

head 196:12 197:21 

246:16 381:9 414:8 

heads 196:9 

heads-up 262:9 

health 27:12 30:8 36:4 

41:11 119:20 126:12 

126:16 131:2 149:5 

150:3 174:12 184:5 

185:3 186:16,19 

189:6 192:12 208:6,8 

291:11 294:4 311:20 

374:11,13 383:3 

healthful 112:7 

healthy 30:13 63:14 

hear 33:15 66:2 128:5 

146:5 149:14 168:15 

183:22 193:12 212:11 

232:4 246:13 249:13 

252:13 276:20 285:19 

337:3,13 352:8 378:4 

405:4 

heard 18:10 31:16 

52:22 60:21 73:19 

79:10 84:5 88:6,12 

92:8 118:13 140:6 

146:4,4,9 163:13 

212:12 243:21 249:6 

273:16 289:14,20 

293:1 314:8 328:21 

336:8,16,17 341:8,16 

343:1 347:3 370:4 

377:21 404:21 406:18 

hearing 7:17 64:19 65:8 

148:16 217:7 237:21 

276:6 

hearings 8:17 

hears 79:15 

heart 305:5 

heart's 194:15 

heartburn 283:16 

286:16 

heat 193:2 243:16 

403:2 

heavily 62:5 275:2 

307:21 

heavy 274:16 283:22 

340:22 

heck 338:20 389:7 

heels 414:12 

hefty 416:9 

help 7:10 32:3 45:5 

71:18 82:13 83:17 

113:11 116:7 123:13 

123:13 194:13 195:9 

231:20 261:19,20 

321:15 337:18 362:6 

390:18 400:6 401:8 

401:10 402:20 403:3 

411:19 427:5 

helped 222:22 

helpful 19:18 21:1 

33:20 106:5 111:20 

113:12 172:21 194:11 

401:20 415:4 

helping 13:6 262:2 

409:2 

helps 13:13 17:6 63:11 

119:12 248:13 292:19 

331:19 

heralded 163:13 

Herbicides 278:22 

281:21 

herbs 91:2 

herd 30:10 

heretofore 350:10 

hesitant 73:10 168:17 

168:19 204:15 238:21 

hesitate 59:6 

high 95:5,13 173:3 

221:2,7 227:9 230:15 

232:10 243:9 284:1 

331:14,16 374:18 

higher 266:7 280:3 

351:18 

highest 9:2 

highlight 87:22 

highly 144:8 145:22 

146:10,16 150:17 

272:19 289:22 329:21 

333:15 

historical 227:12 

historically 144:19,20 

history 153:19 155:14 

305:21 344:9 

hit 83:11 84:11 240:4 

hitting 428:18 

hive 69:18 70:7 72:19 

73:5 

hives 70:17 71:8 

holes 341:4 

holistic 200:4 212:9 

homemade 72:5 

hominy 115:6 

homogenization

216:16 

honed 235:17 

honest 371:11 

honestly 16:4 17:19 

191:17 

honey 55:13 56:1,3,14 

56:17 61:17 62:3 64:3 

64:20 66:3,7 73:14 

honeybee 55:19 71:7 

honeybees 52:12 

317:13 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
444 

honor 428:11 

honors 428:18 

hoo 426:13 

hope 79:14 93:5 327:14 

338:4,20 409:19 

412:12 

hoped 273:22 395:17 

hopefully 9:5 42:11 

248:13 262:12 416:7 

hopes 272:17 273:18 

hoping 86:13 189:10 

253:8 273:2 280:2 

378:11 402:12 

hops 163:14 

hormone 118:11 

horseradish 359:8 

horticultural 388:19 

389:1,4 393:2 

hospitals 208:17 

hot 16:22 17:13 33:6 

225:18 226:8 

Hotel 1:9 

hour 267:17 

hours 196:8 245:14 

house 201:3 

houses 119:17 120:3 

HS 12:18 

huge 83:16 301:5 

human 119:20 126:12 

144:16 150:11,18 

184:5 186:16,19 

189:6 199:16 208:6,8 

216:9 294:4 311:20 

374:11,13 375:2 

383:3,6 

humane 27:21 190:15 

humans 112:8 291:10 

hundreds 92:2 254:4 

husband 63:11 

hydrated 3:7 4:15 43:19 

44:2,6,22 45:4,19 

46:7 116:14,20,21 

323:22 324:2,5 325:4 

hydration 160:6 

hydrocolloids 243:19 

hydrogenated 342:3 

344:6 

hydrolysis 38:2,9 257:4 

hydroxide 3:14 114:18 

114:20 115:1 116:3 

116:21 117:1 122:3 

hypocrisy 286:1 

I

Ibach 81:22 

IBD 56:18,19 

ice 156:4 

idea 80:2 187:17 197:18 

289:5 414:18 

ideas 414:7 

identical 265:2 

identified 272:6 414:21 

identify 45:22 195:9 

236:11 

identity 367:3,5 

IFOAM 139:15 153:5 

ignorance 361:12 

illnesses 305:22 

illustrated 10:12 113:8 

illustration 48:8 

image 50:13 

imagine 220:13 222:2 

264:10 

imagining 72:21 

imbedded 77:13 

immediately 17:11 

18:10,12 20:12 

impact 17:18 112:6 

118:21 156:3 189:7 

291:9 

impaction 49:13,20 

impacts 10:22 126:15 

184:5 

impart 139:9 

imparts 243:14 

implementation 30:2 

84:1 

implications 370:7 

import 13:10 56:1,13 

414:3 

importance 275:8 

405:11 

important 7:22 27:21 

28:5 31:16 34:5 99:16 

100:18 112:10 119:3 

124:2 127:1,3 131:13 

156:15 181:21 201:14 

230:20 240:8 324:7 

327:12 336:5 337:13 

338:19 347:20,22 

380:12 409:2 

imported 9:2 

importers 8:4 

imports 6:19 7:7 10:13 

10:17 11:1,9 12:14 

impossible 336:13 

impregnating 179:9 

impressed 405:9 

impression 58:16 

improbable 222:2 

improve 105:3 

improvement 30:10,12 

390:19 391:3 392:18 

improving 21:13 

inches 225:16 

incident 198:21 

Incidental 216:13 

inclined 275:6 276:9 

include 95:8 138:22 

182:15 189:13 308:5 

405:2 406:7 

included 41:18 160:13 

216:18,21 244:1 

includes 15:6 170:22 

including 38:12 91:2,11 

130:18 144:4 160:11 

163:14 179:20 185:15 

212:14 213:2 245:12 

246:4 268:10 284:17 

291:10 292:4 297:18 

302:16 304:19 313:16 

313:17 316:17 410:4 

415:8 416:10 

inclusion 189:15 

incoming 9:15 419:14 

incomplete 231:11 

inconsistency 34:2 

41:14,16 

inconsistent 30:2 84:1 

incorporate 312:8 

incorporates 75:16 

85:9 

incorrect 100:10 

increase 12:15 161:11 

161:21 219:16 317:11 

increased 8:4 12:19 

280:8,10 

Indian 193:9 

indicated 129:1 

indicates 351:15 

indications 126:12 

indicator 19:2 

indices 7:21 

indirect 180:14 289:8 

individual 30:16 92:13 

92:14 154:7 

individuals 327:1 

induce 289:10 336:4 

industries 39:3 

industry 11:2 39:3 66:3 

74:21 79:15 80:15 

83:13 91:10,21 97:1 

97:10,15 120:2 

136:13,13,19 144:13 

144:21,22 163:11 

168:10 188:8 212:11 

212:16,20 307:13 

334:14 354:7 359:2 

ineffective 54:1,6,12 

57:9 

inert 41:17 

inexpensive 72:6 

infant 108:5 144:4,16 

144:21 145:2 146:2,9 

146:13,21 147:1 

150:5,13,14 

infested 47:17 70:17 

infiltrate 283:22 

inflammation 27:13 

influence 294:19 

informally 52:22 

information 6:12 8:4 

11:9 16:3 25:19 53:17 

84:9 89:8 96:13 111:4 

111:22 128:2,8 

175:19 176:1,4,7 

189:19 195:15 198:9 

198:22 208:4 218:11 

262:2 270:13 276:18 

277:9 291:2,22 295:2 

320:7,17 341:11 

350:5 351:3,8,20 

352:14 353:12 387:20 

402:11 418:12 

informative 282:15 

informed 47:22 

infrastructure 119:18 

ingredient 38:11 42:4 

99:15 100:8 148:12 

148:19 243:8 247:5 

254:16 259:5,17 

324:11 365:19 

ingredients 41:17 

87:10,12 91:5 125:16 

131:10 143:16 259:18 

366:4 367:13 

inhalation 351:6 

inhibitor 374:13 380:3 

initial 181:21 184:13 

416:22 

initially 178:19 180:18 

181:4,6 214:20 295:8 

initiate 11:17 285:14 

initiated 285:16 417:5 

initiative 199:21 

injected 333:11,16 

injecting 333:18 

ink 280:7 

inks 279:5 

innovation 259:9 274:4 

277:9 

inorganic 400:16 

input 68:20 194:10 

295:3,4 326:16 

366:11 367:1 

inputs 366:4 368:7 

369:5 403:15 

insect 63:16 284:6 

289:3 292:10 338:10 

insecticide 295:9 

297:18 317:3 

insecticides 302:15 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
445 

304:19 313:16 316:17 

insects 289:7 292:12 

309:11 317:5,14 

318:3 

insemination 50:9 

inserted 341:5 

insight 15:11 

insignificant 82:21 

inspect 77:20 

inspected 342:16 

inspection 347:20 

inspections 9:13 

Inspector 74:14 

inspectors 55:11 

instability 74:9 155:15 

install 334:8 

instance 57:16 

insufficient 232:18 

integrated 12:13 73:4 

293:2 

integrity 15:8,21 66:16 

77:22 84:6 245:6 

251:6 253:16 254:2 

254:20 264:11 415:15 

416:19 

intended 91:16 216:21 

intense 426:6 

intention 34:4 275:9 

interaction 382:14 

425:9 

Intercontinental 1:9 

interest 91:22 144:7 

208:22 285:4 335:20 

352:17 354:4 420:8 

interested 16:7 220:16 

291:1 353:19 356:8 

interesting 17:1 70:11 

263:5 307:9 379:9 

Interestingly 290:14 

interim 156:6 

interject 296:17 

intermittently 337:15 

internal 342:8 

internally 74:2 118:14 

international 55:19 

236:20 335:20 

internationally 139:14 

153:4 174:4 319:9 

interpretation 74:19 

100:11 407:11 409:11 

409:16 

interpretations 74:7 

interpreting 74:16 

interruptions 74:6 

153:19 

interviewed 187:6 

376:19 

intrally 150:7 

intrigues 196:17 

introduced 219:8 221:7 

333:1 

introducing 12:16 

215:5 217:9 218:19 

221:1 

introduction 68:7 265:6 

337:8 

inulin 147:16 

inulin-derived 147:11 

invest 246:18 

investigate 7:12 153:21 

investigated 10:20 

investigating 8:5 

investigation 15:22 

investigations 7:18 

investigative 16:6 

investing 18:15,18 

involved 65:12 157:16 

286:7 

ionic 210:15 

ions 217:9,20 

iron 334:5 

ironic 120:4 

irrigation 179:21 

268:10 272:16 274:21 

331:13,16 332:2,15 

irritant 185:17 

irritation 185:10 

isolated 160:6 

isopropanol 3:4 4:9 

25:11,15,17 26:1,7 

270:9,11,16,20 

isothiocyanate 5:3 

350:7,9 359:10 

362:10 

issue 75:15 82:16 83:9 

85:8 97:11 110:10 

111:20 112:5 162:16 

164:3 184:21 204:8 

221:13,17 236:7 

245:9 264:4 274:14 

283:16 286:22 292:8 

298:13 305:4 308:19 

319:6 327:4 328:7 

348:4 356:13,18 

368:19 369:1,13 

376:21 405:21 408:5 

issued 7:14 9:20 11:6 

16:14 

issues 31:10 75:13 

76:13 85:5 101:7 

112:12 186:17 213:14 

221:12 222:6 235:17 

248:17 262:9 265:6 

327:9 350:17 363:18 

363:20 393:21 411:12 

it'd 354:8 

it'll 387:19 

item 22:6 29:22 30:19 

31:19 33:9,18 34:1 

68:22 82:8 89:2 92:13 

97:11,13,18 128:21 

136:9 147:18,19 

165:20 173:10 199:19 

200:6,11 205:11 

209:8,11 210:10 

237:19 238:10 241:22 

258:14 269:6 285:11 

285:17 322:9 328:2 

329:21 363:12 408:2 

409:20 413:11 414:3 

414:9 415:9 416:13 

416:20,21 

items 20:20 62:18 65:3 

73:10 78:8 95:9 

163:18 200:19 227:21 

232:17 364:2,5,12 

403:5 414:1 416:10 

417:17 

iterate 120:2 

J

j 304:21 331:10 

jams 91:12 

Janeiro 61:19 

January 9:3 78:10 83:3 

83:8 207:16 419:16 

Japan 139:14 153:5 

380:9 

japones 4:4 225:12,14 

225:22 226:4 233:1 

234:1 235:9,11 

jellies 91:12 

jelling 152:19 

jells 173:19 

Jennie 202:15 

JENNIFER 2:15 

Jenny 6:14 14:6,8 

19:17 21:18 76:9 79:3 

79:21 80:1 285:8 

425:18 428:13 

Jesse 1:15 22:16 23:10 

23:18 25:11 26:8 

34:20 46:8 67:4 85:14 

141:17 268:13 269:9 

270:21 271:2 277:17 

322:17 325:6 330:4 

348:19 352:8 353:18 

362:12 

Jesse's 350:8 

JIMENEZ 2:9 

Jims 262:20,21 

job 11:8 13:6 38:22 

231:7 413:3 426:22 

Joelle 204:6 

joint 11:6 

jokes 345:22 

joking 266:16 

judging 389:16 

juice 91:13 115:5 

July 74:14 365:14 

June 207:18 

justify 251:16 

K

Kazakhstan 12:3,5 

keep 12:11 14:19 20:18 

52:17 58:17 81:4 

101:10 167:5 168:12 

170:13 189:11 192:16 

195:5 196:13 251:19 

258:11 266:14 267:22 

311:15 322:8 332:17 

345:18 350:3 353:1 

362:4 391:8 392:15 

395:3,4,5,5,7,10,10 

421:21 

keeping 10:6 30:12 

31:7 161:4 358:20 

428:15 

Kellogg 1:9 

kept 63:14 86:14 

kernel 245:8 253:15 

kernels 255:4,4 

key 76:12 118:21 

keys 392:9 

kill 191:13 310:8 375:19 

killing 179:5 

kills 55:1 

knew 328:1 

knowing 99:15 155:21 

156:8 369:5 

knowledge 32:16 60:6 

200:7 222:12 

known 350:7 

knows 68:13 302:8 

376:8 

kosher 128:1,7 

kudos 427:10,13 

L

La 84:6 

label 48:2 77:12,22 

101:13 127:17 145:12 

145:18 167:12 182:15 

183:5,9 184:6 272:7 

380:1,7 

labeled 87:10 125:15 

125:17 135:11 136:4 

143:17 207:14 243:8 

labeling 52:2 102:8 

316:20 

labels 97:17 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
446 

lack 180:22 184:8 

192:10,11 249:7 

292:19 308:16 358:18 

ladder 76:18 

laid 120:22 146:15 

land 41:1,7 45:17,19 

415:16 

language 166:16 

182:10 202:21 301:12 

387:16 401:2,17 

402:2 

lapse 194:20 

large 61:21 91:20 121:4 

139:20 155:4 164:20 

191:7 212:17 324:21 

328:16 

large-scale 23:5 

largely 268:16 

larger 112:17 130:18 

200:10 215:1 341:12 

lastly 63:9 368:17 

390:17 

late 142:19 200:15 

laughing 79:4 

Laughter 79:2 86:15 

100:13 105:10 106:10 

106:12 116:19 135:18 

262:19 266:17 321:5 

340:8 347:4 364:22 

365:12 424:5 428:16 

launching 229:9 

lauryl 213:4 214:5,11 

law 272:4 311:9,9,11 

lay 79:7 

leach 221:4 

lead 71:13 161:16 

223:19,20 224:5 

331:11 409:19 

leadership 76:11 80:11 

425:5 428:5 

leads 17:4,5 

leaf 289:10 331:18 

leafy 212:17,19 

lean 250:21 276:14 

leaning 169:10 191:17 

learn 390:15 

learned 390:11,12 

learning 110:12 

leave 50:12 171:7 

245:21 268:3 295:9 

427:4 

leavening 133:15 

leaves 289:8 

leaving 276:14 

lecithin 3:20 159:22 

160:3,5,18,21,22 

161:3,7,12,18 162:19 

162:20 163:2,5,9 

164:1,4,11,14 166:4 

166:17 168:2,6,7 

170:16,22 171:17 

173:11 

lecithins 162:15 164:17 

167:19,21 

led 16:1,6,17 357:15 

left 58:16 64:11 72:17 

226:3 308:15,18 

331:17 395:6,14 

legislation 215:4 

legumes 173:19 

length 155:22 

lengthy 161:22 

let's 7:6 9:6 10:10 12:11 

20:13 30:15 68:10 

258:16 364:8,9 

424:11 426:3,10 

let's-go-to-the-next-h...

17:21 

letter 11:6 64:8 82:19 

84:5 253:12 368:18 

letters 82:19,21,22 83:5 

83:8 145:7 229:20 

231:17 375:22 405:10 

408:6,21 

letting 210:4 329:16 

level 10:11 15:18 20:5 

64:8 75:8 173:1,3 

196:5 211:2 217:18 

218:8,9,22 219:15,20 

220:1 221:20 230:2 

248:21 280:10 300:7 

368:6 408:5 

levels 180:6 181:11 

211:15,16 218:7 

219:6,7 220:3 221:19 

239:14 322:2 

Lewis 92:9 264:9 

liars 103:1 

lice 47:17 

licensed 48:3 

licenses 11:4 

light 279:15 383:7 

liked 229:19 375:16 

likelihood 266:7 

lime 3:7 4:13,15 43:19 

44:2,6,22 45:4,19 

46:7 116:14,20,21 

247:4 300:1,2,16 

313:12,17,21 314:4 

314:10,12,16 315:12 

323:22 324:3,5 325:4 

limit 127:19 180:7 

392:13 

limitation 209:8 

limited 60:21 127:8 

136:7 183:5,21 184:6 

199:20 208:2,11 

209:2 257:3 275:19 

289:16 311:2 354:5 

limiting 204:16 210:10 

314:16 357:4 

line 154:12 183:14 

191:11 193:11 222:3 

377:4 395:18 428:5 

lines 13:14 191:3 197:7 

272:16 350:21 351:5 

linked 81:7 299:12 

liquid 4:16 179:11,13 

179:18 326:6,9,15,20 

327:6 330:2 415:11 

liquids 201:6 

Lisa 1:15 39:19 86:20 

87:3 89:14 90:14 

94:22 98:6 103:13 

104:13 106:15 107:14 

113:17 114:16 117:2 

118:1 123:4 124:11 

124:13 125:10 128:13 

130:6 133:1 134:7 

135:6 138:16 141:15 

143:10 151:6 152:7 

158:22 159:21 171:9 

172:18 177:11 178:11 

205:19 225:11 233:2 

234:2 235:5 240:18 

240:22 241:20 242:22 

256:2 257:6 258:5 

262:14 266:14 321:7 

325:8 353:14 357:11 

380:14 381:11 

listed 52:12,13 53:5 

59:14 92:14 104:21 

108:6 116:18 131:10 

140:5 154:12 163:5 

163:21 180:12 181:15 

207:12 242:1 260:22 

268:19 298:8 308:12 

323:7 332:13 405:22 

listen 411:11 

listening 14:4 97:2 

222:5 

listing 22:13 25:14 

27:11 29:17 31:20 

36:1 38:1 40:20 41:9 

44:2 47:12,21 51:22 

87:13 90:17 92:5,12 

95:4 104:17 107:18 

109:17 110:12,18 

114:20 118:4 121:15 

123:8 125:14 130:10 

133:5 135:10 137:9 

138:19 141:16 143:18 

144:8 152:10 155:1,8 

160:3 165:13 166:14 

171:4,12 173:16 

201:21 202:10,14,20 

202:22 205:15,21,22 

206:2 209:13 226:18 

227:20 234:1,5,6 

235:16 253:20 255:21 

257:7,8 261:11 

268:11 269:7 270:9 

279:4 280:5 282:1,22 

285:5 287:15 296:18 

297:12,18,22 300:12 

300:16 302:15 305:1 

313:17,19,21 314:16 

316:18 319:22 322:20 

324:2 326:9 331:7 

335:22 340:14 347:12 

348:18 371:12 373:3 

listings 15:8 142:15 

156:16 278:21 299:16 

300:14,15 304:16,18 

305:7 312:9 313:14 

lists 116:14,18 375:12 

383:22 

literally 309:2 

little 64:16 65:7 71:20 

72:19 86:13 96:21 

119:20 126:19 145:14 

168:4,6,17,19 195:13 

196:17 232:7 248:5 

254:9 260:4 265:3 

268:2 276:6 289:14 

307:7 315:6 338:5 

356:3 359:11,15 

365:7,9 379:14 

387:22 389:12 393:9 

393:12 427:5 

live 28:3 42:2 77:20 

168:17 231:1 338:10 

lives 426:7 

livestock 3:3 6:6 21:22 

22:2,10,18 23:8 25:17 

28:4,4 30:16 32:7 

38:1 40:22 41:6 45:20 

52:11 62:18 65:5 

73:16,21 74:8,10,17 

74:20 75:1,16 76:15 

79:12 81:6,10,19 85:9 

86:12 116:15 179:22 

264:12,14 317:1 

318:8 321:11 369:9 

374:7 375:11 377:14 

377:16 415:22 

living 230:3 237:22 

238:3 247:1 305:18 

load 175:4 403:2 

loading 255:9 

loans 388:9 

local 44:1 401:13 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
447 

located 212:17 

location 102:12 245:2 

locus 158:20 

locust 3:19 139:12 

152:9,11 153:12 

154:2 230:16 

lodge 102:12 

log 228:16,17 345:17 

345:18,21 

log-grown 340:16 

logged 15:20 

logic 98:7 

logo 267:6 

logs 341:4 342:20 

343:7 

long 72:9 97:16 153:18 

157:20 158:16 251:19 

324:6 338:18 413:2 

413:19 

long-term 30:11 

longer 53:20 101:2 

156:2 235:14 318:17 

338:3 341:14 

longstanding 136:1 

look 12:17 13:8 31:18 

42:11 54:16 55:22 

62:17,22 81:9 100:9 

120:14 128:20 145:11 

173:6 175:8 185:6 

186:1,10 189:3,5,22 

191:3 220:21 230:14 

250:15 254:4 285:15 

321:7 348:6 350:19 

351:11 354:22 355:2 

394:13 400:19 404:7 

410:2 411:17,17 

414:13 418:7 425:14 

425:22 

looked 13:7 62:19 

88:14 156:20 230:10 

348:7 

looking 13:10 17:16 

21:10 45:2 105:21 

145:12 156:1 169:21 

188:19 219:11 221:14 

221:15 223:9 230:2 

254:14,16 261:1 

305:16 328:7 332:22 

357:21 358:6 362:3 

378:9 383:14,17 

388:21 389:1,14,19 

396:3 413:8 

looks 267:12 343:5 

344:10 362:5 

loosened 136:15 

lose 197:5,6 

losing 30:10 174:19 

loss 119:4 

lost 83:21 261:4 

lot 7:7 11:6 15:17 17:12 

59:4 80:19 81:1 82:22 

97:12 118:13,18 

119:5 155:10,12 

165:8 184:19 192:17 

196:8 198:12 201:8 

201:20 215:10 227:14 

228:5 229:13,17 

231:6 232:3 236:16 

263:13 265:17 276:20 

283:21 301:12 306:12 

319:6 329:20 342:17 

354:7 375:1 376:3,4 

382:13 389:7 417:16 

425:9 

lots 64:6,6 73:19 

love 167:11 190:21 

191:20 

low 18:5 95:13 173:20 

173:22 174:3 208:5,7 

211:14 275:3 310:19 

lower 136:7 181:10 

210:19 218:8,9 

219:22 220:7 221:6 

221:20 237:14 277:5 

326:13 

Lowering 331:19 

lubricant 47:13 

lubrication 50:5,7 

lunch 142:19 266:19 

267:1,5 

lung 305:17 

Lynn 318:19 

M

machinery 310:16 

machines 125:21 

macroalgae 110:11 

magic 354:16 394:13 

magnesium 3:16 

125:11,14,19 126:8 

127:17 129:6 

main 110:9 209:16 

397:21,22 398:13 

maintained 119:19 

maintaining 407:13 

major 200:22 213:1 

majority 44:11,15 47:19 

48:3 56:1 62:3 75:5 

102:14 130:21 224:9 

362:13 363:11 396:22 

419:8 420:9,10,15,18 

makers 137:2 

making 16:8 88:15 

115:6 133:18 135:22 

182:3 203:4 207:8 

213:19 223:20 239:15 

251:9,11 252:1 

322:10 329:11 338:18 

351:11 360:2 370:4 

401:1 410:4 

mammals 317:10 

Man 419:17 

manage 12:16 343:13 

management 72:18 

73:3,5,5 121:1 218:3 

218:4 284:6 290:12 

293:2 297:6 324:8 

357:15 377:3 

manager 2:12 58:11 

managing 247:16 

mandate 167:14 

mandated 32:13 

manner 347:13 

manual 417:9 418:17 

manuals 363:22 417:19 

manufacture 93:9 

127:7 175:7 288:19 

302:19 

manufactured 52:7 

179:14 400:3 

manufacturer 102:18 

103:7 110:14 115:20 

140:1 153:11 169:22 

174:16 175:19 204:14 

229:7 253:21 263:12 

291:22 318:10 328:10 

329:8,9,14 405:4 

manufacturer's 102:17 

manufacturers 95:16 

101:14 104:20 110:5 

123:16 128:16 139:19 

158:15 164:15 165:4 

167:9 169:1 174:9 

249:10 260:21 261:4 

261:12 

manufacturing 38:7 

91:18 164:16,18 

manures 358:11 

March 210:3 

margarines 160:14 

Maricopa 193:9 

marine 110:10 112:4 

113:5 327:10 416:12 

mark 49:21 

marker 276:13 

market 8:7 12:22 13:15 

21:8,11 64:12 69:15 

74:8 102:4 119:4,11 

145:2 161:4,5,21 

162:1 163:8,12,20 

164:7,8,11 165:12 

168:18 173:7 183:8 

229:5,11 238:4 

239:21 247:9,12 

248:12 263:20,21 

264:16 265:18,21 

266:4 336:7 337:18 

390:16 402:19 

market's 250:16 

marketing 2:10 80:18 

marketplace 12:14 

101:12,17 128:15 

137:6 228:22 

markets 255:5 

Marla 58:9 

masa 115:6 

mass 20:4 

match 150:15,16 

materials 2:13 41:17 

42:11 60:3 63:2,13,15 

68:18 88:9 92:3 99:6 

100:1 101:14 105:19 

110:10 112:5 113:5,6 

113:9 119:10,12 

126:18,22 127:9 

129:2 178:13 183:18 

184:7 185:14 186:6,7 

187:1 189:13 191:20 

192:1 194:22 200:1 

208:9 211:21 227:13 

230:11,15 244:4 

250:12,16,20 260:3 

262:8 264:2,19 

265:12 267:19 279:12 

286:10 287:5 305:18 

308:10 317:20 327:10 

343:22 356:4 358:16 

364:1,3,3 365:6 

367:11 368:7 371:3 

401:18 403:18 404:6 

409:17 411:13 412:9 

413:21 415:6 416:12 

416:13 

math 221:18,19 222:1 

MATHEWS 2:12 22:7 

25:13 27:11 29:16 

33:8 35:22 37:22 

40:19 43:21 47:11 

51:21 87:8 90:16 95:3 

104:16 107:17 109:16 

114:19 115:22 116:8 

118:3 123:7 125:13 

130:9 133:4 135:9 

138:18 152:13 160:2 

173:15 203:5,20 

225:4 268:6 270:8 

272:2 278:20 281:20 

288:16 296:16,20,22 

298:22 302:14 304:17 

313:14 316:16 319:19 

320:1,5 324:1 326:8 

331:5 335:21 340:13 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
448 

347:9 

matter 82:19 130:15 

142:21 163:2 213:11 

252:5 264:1 267:8 

364:13 382:3 428:21 

matures 118:14 

maximum 180:6 

mead 133:18 

meal 366:1,1 372:20 

meals 358:11 

mean 16:4 18:17 22:22 

38:21 45:19 56:4,17 

61:3,5 63:21 66:11,14 

98:21 100:15 113:2 

120:4,5 136:3 157:11 

162:2 168:5,21 173:3 

186:3 188:21 195:22 

196:2,4,14,20 197:19 

197:20 198:3,9 217:1 

217:19 218:17 220:21 

220:22 221:11 222:6 

227:4,19 228:7 

237:12 238:16,16,21 

239:2,6 248:21 

255:12 265:10,14,18 

273:15 276:11 284:10 

294:16 309:13 310:2 

310:6,16 311:17 

321:8 345:6,16 

354:18,21 358:5 

361:18,22 375:15 

379:8,12 381:11 

382:1,21 383:11,16 

393:2,7,11 

Meaning 147:22 

means 214:9 230:21 

236:19 246:10 254:7 

311:14 355:10 359:16 

meant 236:8 261:18 

measured 187:4 

measures 96:4 

meat 265:17,22 266:5 

mechanism 291:6 

293:17 

medical 22:12 144:5 

146:20 150:7 208:17 

210:22 211:5 

medication 28:1 

meet 79:9 198:19 

meeting 1:5 6:5 73:20 

76:11,12,14 82:15 

109:21 142:18 154:5 

163:15 209:6 223:5 

244:4 258:20 267:14 

286:8,20 328:15 

329:9 344:22 404:11 

406:18 414:13,20 

416:14 417:1 418:2 

418:13 419:10 425:7 

428:4,19,20 

meetings 73:21 83:14 

105:12 208:21 209:7 

344:1 

meets 217:4 

MeloCon 358:15 

members 58:4 61:10,12 

96:14 143:2,6,8 190:7 

226:15,22 267:3,12 

273:13 332:13 419:2 

419:3 420:5,6 421:5 

membranes 359:7 

memo 285:5 

memorandum 210:3 

memos 10:21 

mention 132:13 147:2 

201:13 226:15 414:16 

mentioned 9:19 10:22 

11:16 13:3 19:22 83:3 

115:8 128:14,14 

149:20 162:18 342:17 

mentioning 150:6 

292:6 

mess 54:22 

message 11:18 273:17 

messing 311:16 

met 1:8 240:11 

metal 130:15 217:9 

metal-based 218:3 

metaphor 82:4 

methionine 416:10 

methobromide 357:6 

methodology 383:20 

methods 32:1,9,16 

34:10 92:17 96:6 

100:3 140:19 147:20 

236:11 416:7,15 

metric 13:13 

Miami 11:11 

mic 33:15 421:16 

Michelle 2:7 394:17 

418:15 426:18,19 

Michelle's 413:12 

micro 400:6,9 401:4 

micro-oxygenation

105:1 

microbial 175:3 211:8 

microbiology 198:17 

microcrystalline 4:19 

340:11,14,20 342:7,9 

342:21 344:13 346:2 

microorganisms 100:5 

microphone 49:2 

398:11 422:14 423:4 

mics 58:5 

middle 390:5 

Midwest 290:14 

mike 151:8 

mildew 297:8 301:13 

mildews 301:4,5 

milk 36:8 42:5 74:15 

101:21 144:17,18 

150:11,19 

milled 152:15 

milling 216:16 

million 12:18 136:6 

182:20 261:6 

mind 52:15 58:16,21 

81:4 100:17,18 103:1 

120:14 189:11 190:6 

299:15 322:8 422:12 

mine 60:22 65:8 98:4 

101:4 262:22 292:21 

428:7 

mined 17:2 347:13 

mineral 3:8 47:8,12,15 

47:22 48:19 49:16 

50:16 57:22 130:15 

131:5 

minerals 36:5 

minimize 329:2 

minimizes 337:7 

347:14 

minimizing 273:20 

minimum 210:12 240:3 

240:10 248:5 326:13 

Minnesota 1:10 58:10 

339:4 

minor 27:16 214:8,8 

417:8 

minute 195:14 296:17 

minutes 170:9 267:1 

misapplying 401:2 

miserable 321:4 

missing 298:17 419:5 

misspoke 194:7 

mistake 333:7 

misuse 124:5 

MITC 351:15,16,18 

mite 52:11 54:2 57:13 

63:2,11,12 72:18 

289:3 290:3 297:19 

301:13 302:16 304:19 

313:16 316:17 

mites 47:17 52:21 

53:20 70:4,6,9,18,22 

71:7 

miticide 309:13 318:3 

mitigate 209:3 212:21 

mitigation 175:3 

mix 324:11 

mixed 123:12 221:21 

263:17 324:12 

mixing 196:19 

mode 208:12 209:1 

model 266:9 

modeling 16:21 

moderate 215:13 

modified 30:3 147:14 

modify 152:17 

moisture 374:18 

molasses 115:2 

mold 374:12 380:2 

Moldova 12:2 

molds 377:16 

molecular 243:9 

molecules 215:1 

MOM's 380:16 

moment 133:8 181:5 

Monday 191:12 

money 228:18 

monitor 308:3 417:14 

monitoring 8:9 186:21 

mono 3:15 123:6,8,10 

124:1,10 

monoculture 121:5 

337:20 

month 218:15 258:17 

276:19 338:9 

months 20:16 156:2 

285:7 

moratorium 406:20 

morning 22:1,4,5 

191:12 194:18 

motioning 394:19 

motions 24:2 154:17 

232:21 240:15 255:20 

300:18,20 301:18 

371:9,9 392:5 

Mount 286:6 

mouth 243:20 

move 11:20 21:20 

68:14 73:12,17 86:18 

101:18 140:21 142:17 

200:18 204:21 240:13 

255:18 271:22 282:20 

287:6 356:18 366:8 

369:19 371:6 384:8 

402:12 424:15,19 

moved 298:11 

moves 70:3 

moving 27:10 35:19 

37:19 38:4 40:16 41:2 

43:18 47:8 51:18 52:4 

68:6 69:6 73:22 82:4 

84:9 143:13 173:13 

178:14 267:13 283:2 

357:13 362:4 387:15 

mucus 359:7 

muffins 374:19 

mug 427:14 

mulch 4:10 279:13 

281:18 282:1,21 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
449 

284:12 286:1,12 

287:9 406:16 415:13 

mulches 279:1,19 

281:22 283:3 284:7 

285:3 

multi- 309:19 

multiple 7:18 10:20 

95:17 122:3 310:1 

mumbling 184:20 

municipal 212:1,5 

221:16 222:8,14 

mushroom 340:16 

341:3,13,17 342:6,18 

375:22 376:9,16 

377:20 378:5 380:5 

382:10 

mushrooms 376:5 

mustard 358:11,11 

mute 30:21 

mycologist 376:8 

N

name 223:13 318:7 

389:19 400:3 420:21 

names 381:1 421:22 

nano 215:21 

nanomaterial 209:3,19 

210:17 213:14 

nanomaterials 209:21 

210:4 216:7,19 

nanometer 210:13,16 

nanometers 208:3 

209:22 210:5,11 

216:10 

nanoparticles 217:3,8 

nanoscale 216:9,13,14 

216:17 

nanotechnology

209:18 216:4 

NAPA 306:10 

nasty 360:18 

natamycin 5:5 374:1,11 

374:17 376:12 377:6 

380:1 383:15 384:1 

384:11,15 385:14 

Nation 200:2 

Nationalist 259:9 

nationally 58:11 

native 175:11 

natural 38:8 90:22 91:1 

91:14 92:19 150:15 

201:11 208:9 248:10 

248:19 341:9,21 

347:17 366:22 368:12 

370:10 371:2 380:2 

381:4 403:14,18 

naturally 120:5,6 

216:17 220:10 288:20 

302:20,21 354:17 

nature 146:16 235:20 

nearby 305:18 

Nebraska 333:4 

necessarily 59:21 63:8 

83:1 158:7 174:20 

196:11 197:3 238:18 

362:6 370:9 410:5 

necessary 74:18 91:8 

119:8 144:9 154:11 

173:5 180:20 324:10 

336:14 347:21 376:15 

388:21 

necessity 184:8 212:6 

neck 190:12,14 

nectar 275:20 

need 19:11 21:12,15 

30:17 57:16 59:17 

69:4 70:14 78:22 

79:16 81:7 101:10 

106:2 111:19 116:8 

121:19 131:12 145:14 

150:17,17 157:10 

168:13 182:19 184:22 

186:10 188:6,22 

195:14 197:3,4 

200:11,16,17 203:3 

203:16 205:11 210:7 

212:20 216:2 226:6 

228:9,10,11,13,14,15 

228:19 229:1,15 

231:1 237:6 254:18 

260:8 262:10 285:10 

292:14 307:14 308:3 

311:10 344:7 354:12 

357:20 362:4 364:4 

371:9,10 378:6 

383:20,21,22 389:18 

389:22 391:14,20 

403:22 421:2,16 

423:9 

needed 62:22 174:14 

186:7 200:11 227:3 

301:20 321:22 326:13 

341:15 408:6 

needing 231:11 

needs 12:11 81:17 

189:9 200:9 202:12 

213:5,15 223:6,7 

227:14 240:11 251:16 

275:20 350:5 

negates 311:3 

negative 96:7 136:2,18 

295:7 314:14 331:21 

neglected 379:21 

neighbors 77:21 

252:16 253:1 306:14 

nematodes 361:15 

never 14:19 50:10 

309:21 322:11 377:21 

Nevertheless 237:5 

new 11:14,19 12:16 

19:15 50:3 54:15 65:1 

80:3 96:12,16 97:7 

196:7,7 223:4 229:9 

232:10 267:22 270:12 

270:12 279:7 310:16 

319:2 351:20 402:1 

419:15 422:19 423:18 

424:12 425:17,20,21 

newly 157:20 419:9 

news 223:4 

newspaper 4:10 278:18 

279:4,8,13 280:15 

299:6,9,12 300:12 

404:22 

newspapers 280:7 

nice 13:6 70:8 426:21 

428:14 

night 58:8 

nine 273:10 

NIOSH 185:6 

nitrogen 338:1 

no's 51:22 270:3 347:3 

NOC 53:2 

noes 225:7 

nominate 421:12,17 

423:5 424:3 

nominated 419:3 420:5 

nomination 423:7 

nominations 418:21 

421:10 

nominee 420:10,14,20 

421:1,15 

nominees 421:20,21 

422:5,8 423:1 

non 127:11 148:1 

non- 61:21 87:8,12 

88:10 164:10 167:13 

207:12 257:3 260:7 

264:13 347:9 377:9 

non-ag 260:6 

non-agricultural

102:16,19 205:14 

249:1 

non-allergenic 164:3 

non-animal 127:8 

non-bird 264:3 

non-compliance 16:22 

non-compliances 9:20 

16:15,16 

non-existent 39:2 

non-farm 42:5 

non-genetically 148:8 

non-GMO 148:13,22 

249:2 341:10 

non-organic 87:9 

102:16,18 162:19 

166:5,21 183:20 

243:7 251:13 354:7 

389:6 390:13 393:16 

non-production 61:21 

non-soy 160:18,20 

161:3,7,12 

non-sunset 414:1 

non-synthetic 88:10,16 

90:17 93:10 123:18 

140:11,20 248:11 

256:1 259:5 260:6,8 

366:2 374:6,10 375:5 

375:16 377:11 379:10 

379:13 384:11,16 

385:15 403:14 

non-synthetics 375:7 

non-transformed 148:2 

non-usage 56:5 

nondigestible 144:1 

nonessential 146:1 

nonorganically 143:15 

143:21 

nonsensical 217:16 

nontoxic 317:13 

nooks 191:16 

NOP 6:16 22:17 25:16 

47:21 80:4 88:8 169:6 

210:2 230:10 245:6 

253:15 259:13,19 

260:12 268:14 270:10 

285:16 328:17 329:12 

329:14 369:21 405:20 

408:17 412:12 426:16 

NOP's 77:11 260:2 

409:10 

normal 150:10 

normally 422:7 

north 175:11 286:5 

northwest 290:2 334:15 

NOSB 2:7 5:15 6:5 21:3 

48:8,12 74:11 76:10 

77:2 79:13 80:4 82:14 

89:5,6 92:4 140:12 

163:9 172:22 205:13 

207:4 208:18 209:20 

210:2,9,9 216:1,6 

285:11 292:5 405:19 

406:6,18 408:15,19 

415:3 418:21 419:3 

419:14 

NOSBs 165:17 173:6 

217:5 

nose 185:10 

notable 133:17 

notation 53:18 

note 92:6 101:15 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
450 

135:15 176:20 181:21 

199:18 208:15 209:19 

213:4,10 214:9 

215:20 223:3 236:17 

243:18 244:12 254:11 

286:4 329:12 336:5 

349:21 363:16 365:7 

383:12 384:2 390:21 

391:13 

noted 30:9 41:13 92:18 

153:11 160:8 175:1 

181:14,18 182:8,13 

183:4 210:4,14 

211:13 212:19 213:8 

214:10 272:20,20 

275:4 348:2 

notes 114:12 216:2 

314:6 361:13 404:20 

notice 21:19 284:13,18 

noticed 135:17 308:12 

notices 8:6 16:15 

notify 417:14 

notifying 212:1 

noting 314:4 331:16 

notion 118:22 186:3 

nudge 252:8 257:14 

number 87:20 95:16 

118:9 133:16 139:18 

181:12 185:14 212:12 

248:2 272:4 288:18 

292:3 302:18 306:16 

316:19 331:7 334:2 

340:15 366:14 389:21 

392:13 401:12 402:18 

405:10 420:13 

numbers 205:10 317:4 

numerous 30:15 93:13 

138:21 173:11 212:12 

282:18 336:8 377:8 

405:13 

nurseries 317:7 361:18 

nursery 353:6,21 354:6 

354:14 356:5,12 

357:3,4,19 359:1,13 

359:14,16 360:4,21 

360:22 361:1,15,16 

406:8,13 

nursing 58:8 

nut 393:14 

nutrient 107:22 305:8 

307:20 331:20 332:8 

334:11 400:9 401:4 

nutrients 400:6 

nutrition 144:14 

nutritional 126:2,11,21 

139:1 402:17,21 

nuts 179:2 

nutshell 404:9 

O

o'clock 364:11,18 

objected 92:11 111:12 

144:8 

objection 99:22 

objections 110:9 

obtain 252:12 

obtained 388:9 

obviously 32:12 83:15 

96:20 115:20 350:1 

378:11 395:18 426:6 

occupational 185:9 

187:4 

occur 23:6 78:11 

occurred 15:22 60:17 

81:16 237:16 

occurrence 368:9 

occurring 120:6 216:17 

288:20 302:21,21 

354:17 

occurs 41:1,7 85:3 93:9 

octanoate 3:8 4:14 

51:19,22 57:15 67:1 

78:21 316:14,18 

322:3,14 

octanoic 52:8 

October 1:7 5:7 78:6 

339:5 387:3 

ocular 305:21 

odd 365:7,9 

oddness 365:15 

off-label 48:22 49:6 

50:1 

offer 196:22 422:4 

offered 407:11 

office 9:22 74:14 420:2 

420:5,22 

officer 5:17 6:8 198:4 

418:14,16,22 419:5 

officers 418:20 419:7,9 

419:14,15 424:12 

425:21 

Official 2:17 

OFPA 79:6,8 81:10,18 

336:19 358:20 

Oftentimes 89:2 361:16 

OID 56:17 

OIG 7:21 

oil 3:8 9:14 47:9,12,15 

47:22 48:19 49:16 

50:16 57:22 160:9 

164:13,16,18,19 

165:6,6 168:9 341:1 

342:4 

oil-free 104:17 

oiled 160:1 162:20 

164:8 173:12 

oils 38:3 127:8 160:7 

old 253:20 424:9 

oligosaccharides

144:17 

OMRI 358:13 

on-farm 194:13 331:8 

on-the-ground 11:12 

once 54:20 71:14 

123:14 300:13 353:7 

379:5,10 420:22 

one-sentence 231:17 

OneCert 55:9 

ones 32:15 141:9 

168:12 174:5 268:2 

299:6 355:14 383:7 

391:9 

ongoing 416:15 

online 322:2 

onsite 179:8 

OP 8:17 

open 23:11 28:1 31:1 

36:12 44:16 53:9 76:1 

113:11 189:11 213:9 

213:21 245:21 261:14 

285:17 318:18 357:4 

379:13 387:19 412:3 

417:14 421:9 

opened 428:3 

opening 3:2 38:19 

41:21 149:21 

opens 356:10 367:6 

operating 388:9 

operation 15:2,4,6 17:3 

17:5 84:10,12 148:21 

193:20,21 196:2 

383:3 384:4 

operations 7:16 8:11 

10:3,7 15:1,8 16:18 

17:7 34:8 45:3 74:15 

75:9 77:8 83:21 92:2 

183:13 193:8 414:18 

operators 30:17 

opinion 190:9 213:11 

215:10 238:8 253:7 

329:13 406:6 

opportunity 200:14 

231:22 258:20 263:16 

284:20 356:17 

opposed 99:16 162:22 

185:20 331:21 

opposite 252:15 

optimal 91:7 

optimistic 364:17,19 

option 95:21 196:12 

344:5 353:11 

options 65:17 260:13 

oral 49:12 

orange 118:16 

orchard 306:11 

order 6:4 23:22 48:11 

133:11 142:16 143:7 

143:8 205:5 260:9 

267:12 363:15 364:1 

364:17 366:7 388:6 

392:2 

ordering 388:4 

organic- 125:15 

Organic-Specified

87:11 

organically 119:11 

155:6 175:10,15 

226:14 228:2 247:5 

252:4 264:7 359:21 

organically-managed

40:22 41:6 

organics 139:13 140:15 

153:4 174:4 201:10 

207:15 

organisms 102:20 

179:4,6 317:10 

organization 61:15 

123:17,22 124:4 

140:3,10 153:20 

174:11 237:4 279:10 

279:17 

organizations 36:7 

83:13,14 139:19 

182:8 327:1 

organized 23:8 

orientation 203:2 

origin 73:21 74:7,10,17 

74:20 75:1,16 76:14 

79:12 81:5,10,19 85:9 

128:9 

original 96:1 99:6 111:2 

294:1 404:7 

originally 110:21 192:4 

192:6 193:13 272:16 

273:21 276:5 280:4 

320:19 352:20 398:13 

OSPs 104:22 139:22 

OTA 259:8 

ought 350:19 

outbreaks 201:1 

outcome 8:21 16:1 

222:3 359:3 

outcomes 8:8 14:16 

outer 115:9 118:15 

outgoing 419:14 

output 283:12 

outreach 306:13 

outside 44:14 

outweigh 121:8 

overlooked 300:11 

overly 247:15 

overriding 367:2 

overseas 11:15 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
451 

oversight 10:2 13:19 

75:7 414:3 

overview 265:6 

overwhelming 23:3 

27:19 

overwhelmingly 25:22 

31:17 108:3 268:22 

270:16 

owned 193:9 

owner 260:17 

oxalic 3:9 53:17 57:16 

65:6 68:9 69:16,22 

416:1 

oxidate 377:1 

oxidated 208:12,14,16 

oxidizer 185:15 

oxygen 3:13 104:14,17 

104:19 105:1,8 106:1 

106:8,14 

ozone 183:16 197:18 

P

P-R-O-C-E-E-D-I-N-G-S

6:1 

p.m 267:9,10 364:14,15 

428:22 

Pacific 290:2 

package 70:15,19,20 

packaged 70:13 379:22 

packages 70:18,21 

packed 374:19 

packet 299:9 

packing 191:3,11 201:3 

page 358:10 

pages 304:13 

painful 344:22,22 

painfully 359:15 

pains 27:17 

palatable 292:11 

paper 4:10 5:11 64:6 

76:14 279:5 280:3,4,7 

280:7,15 404:17 

405:1,1,6,7,22 406:6 

406:7,11,14,16 407:5 

407:7,9 411:14,18 

412:2 

paper-based 405:3 

paragraph 22:11 25:14 

43:22 87:12 109:17 

143:18 268:9 302:15 

304:18,20,21 313:15 

313:20 331:9 347:11 

358:10 

parasites 47:18 

parasiticide 44:1 47:16 

parentheses 380:2 

parking 417:16 

part 44:20 62:13 66:4 

92:6 105:21 111:2 

130:17 141:6 169:19 

176:9 232:18 236:12 

282:13 357:19 367:4 

370:10 375:21 

partially 69:7 

PARTICIPANT 49:2 

126:4 

participate 327:14,15 

particle 208:2 210:11 

particles 216:14,17 

particular 52:10 176:12 

211:11 227:14 263:18 

285:3 289:2 302:14 

350:11 351:3,12 

particularly 139:8 

144:12 157:8 164:5 

187:8 212:16 215:12 

237:20 264:1 301:4 

409:16 

partly 127:9 168:21 

193:7 306:9 309:22 

partner 12:6 

partnering 11:3 

partners 7:20,22 

parts 136:6 182:19 

pass 209:7 369:20,21 

370:5 421:7,8 423:9 

423:11 

passed 203:12 240:2 

286:12 

passes 68:4 86:9 225:9 

241:18 257:1 258:4 

323:20 373:20 385:13 

386:21 394:20 397:20 

399:12 411:9 

passing 370:6,7 

passionate 395:19,20 

patent 213:8 

patents 260:17 

path 407:13 409:20 

pathogenic 179:4,6 

pathogens 212:20 

301:4 361:14 

pathways 150:10 310:1 

PATTILLO 2:13 48:19 

49:4 225:5 298:15,20 

Paul 1:9,9 92:8 285:2 

427:4 

Paulo 61:18 

Pause 133:9 143:4 

pave 167:21 

pay 199:13 285:6 

349:22 

paying 66:6 174:20 

285:9 

PCC 88:4,10 

PCQI 228:13 

pectin 108:7 

Pediatric 146:21 

peeve 65:1,7 

Pennsylvania 290:16 

people 30:9 53:13 

55:10 57:10 63:22 

65:2 68:18 70:21 

73:13 80:7 82:16 

84:12 97:6,8 101:9 

106:1 121:13 127:2 

127:19 136:3,5 

157:22 174:13,19 

186:11 195:3 197:6 

201:10,12 214:10 

227:5 230:17,19 

231:7 239:17 253:2 

264:2 273:10,15 

280:1 289:20 307:10 

308:13 310:8,14 

332:15 347:17 353:19 

360:5 378:3 389:10 

410:4 427:10 

people's 150:12 

pepper 4:4,5 225:22 

226:8,17 229:18 

235:11 237:1 239:1 

peppers 225:13,15 

226:4 233:1 234:2 

235:7,10,12 240:17 

241:20 

peracetic 183:17 

percent 8:22 9:4 56:17 

91:5 95:11 139:4 

166:16 174:3 331:9 

389:6 

Percentage 174:2 

percentages 139:3 

perennial 158:14 354:8 

393:12,15 

perennials 393:3 

period 15:14 62:7 66:2 

81:16 395:20 405:15 

428:3 

periods 119:3 

perishable 11:4 

permanently 355:6,7 

permitted 44:3,8 317:6 

peroxyhydrate 4:9 

272:1,3 277:14 

person 32:7 70:18 

217:14 273:13 336:10 

425:17 

personal 95:9 119:9 

359:4 383:9 405:10 

personally 100:20 

190:20 247:2 311:6 

355:9 382:21 

perspective 49:9 

156:13 

perspectives 406:5 

pertinent 52:15 

pervasive 309:9 

pest 44:2 63:16 73:4 

121:1,6 293:2 301:3,3 

317:20 337:5 

pesticide 178:20 

293:13 307:21,21 

333:18 

pesticides 38:15 52:16 

187:12 308:4 337:6 

359:18 

pests 44:7 337:16 

pet 64:22 65:7 

petition 65:1,6 68:14,21 

96:1 121:17 163:6 

178:18,19 179:14 

180:8 181:21 186:4 

206:1 207:3,16 208:1 

208:19 210:14 211:12 

223:22 230:13 235:19 

236:4 237:13,17 

238:15,17 243:10 

244:14,16 245:2,15 

245:16 247:18 251:20 

253:12 255:2,11 

259:2,8,10 260:17 

261:19 262:9 344:11 

344:21 352:10 360:11 

364:2 365:14,21 

369:18 370:15,18 

373:22 374:4 377:22 

378:9,10,11,14 405:6 

407:5 415:18,19 

416:1,2 417:10,12 

petitioned 68:7 163:9 

168:1 180:15 181:15 

182:5 207:5,11,11 

210:7 213:6 225:17 

235:9 236:1 243:7 

344:18 366:6 379:1 

402:17 

petitioner 140:9 182:11 

211:13 225:20 226:5 

227:19 229:20 231:16 

231:21 235:9 236:4,5 

239:3 244:21 249:15 

254:12 352:17 380:8 

402:11 

petitioner's 183:5 

236:14 352:13 375:21 

petitioners 180:19 

188:5 231:9 232:17 

264:15 

petitioning 65:3 246:20 

petitions 66:5 227:22 

255:13 261:21 264:10 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
452 

364:3 378:20 399:17 

415:7 

petroleum 49:16 282:2 

283:3 287:9 340:22 

340:22 

petroleum- 341:5 

pH 108:1 115:4 133:15 

153:1 173:21,22 

326:10,13 328:10,17 

329:4 331:14,17,19 

332:9 333:14 

Ph.D 2:12,15 198:14 

phase 204:2 402:4 

philosophic 80:2 

philosophically 293:12 

phone 219:5 254:12 

phosphates 132:11 

phosphoric 3:7,16 

40:17,20 41:4 42:17 

130:7,10,13,18 

131:16 326:11 329:3 

phosphorous 41:17 

photo 267:4,5 

physical 44:3,9 153:1 

351:13 

physiological 403:10 

phytosanitary 354:13 

355:11 356:4 

phytosanitation 360:15 

361:10 

phytotoxicity 317:14 

pick 422:16 

pickle 383:13 

picture 186:11 

pictures 13:2 

piece 308:15 359:13 

pies 422:4 

pilot 20:3 

pineapple 121:2 336:1 

336:5 337:16,20,21 

337:21 338:6,13 

pineapples 336:4,7 

pipeline 333:12 

pipelines 42:6 

place 7:1,9 20:1 76:8 

92:15 112:21 144:16 

157:2 169:15 181:9 

204:10 210:12 216:6 

222:7 244:15 298:4 

382:4 426:18 

placed 367:9 

placement 379:2 

places 17:8 189:17 

201:5,16 219:15 

380:21 

plan 228:14 285:6 

364:10 

plane 427:18 

planning 55:2 414:5 

plant 120:21 255:9 

288:17 289:10,11 

292:11 293:9,9 297:6 

298:1 301:4 304:20 

304:21 305:8 307:20 

309:17,19 313:20 

324:2 326:9 331:6 

335:22 361:17 388:17 

400:7 402:20 403:6 

plant-based 279:12,18 

283:2 

planting 393:15 406:10 

411:15,18 

plants 91:2 152:14 

266:7 291:10 301:4 

351:2 359:21 362:1 

403:3 

plastic 4:10 281:18 

282:1,12 283:13 

284:3 285:22 286:18 

287:9 403:2,21 

play 80:7 82:7 285:11 

played 428:2 

playing 75:8 

pleading 400:18 

please 58:4 73:12 83:14 

142:18 148:17 190:8 

338:22 339:3 421:7 

pleased 285:18 

plowed 358:12 

plug 341:4 

plurality 420:12 

point 9:4 16:10 53:3 

58:21 59:5,15 61:10 

63:19 65:11 73:3 79:6 

79:6 86:21 87:1 99:5 

99:12 102:7 103:5 

116:13,17 140:16 

141:3 149:5 154:19 

155:21 158:1 166:2 

166:14 172:20 174:11 

175:18 177:4 184:15 

186:18 196:21 200:17 

200:17 203:6 205:5 

213:19 227:2 238:20 

240:8 275:7 276:10 

301:16 310:2 319:15 

341:16 345:13 363:14 

369:15 389:14 392:1 

401:14 

pointed 61:11 123:21 

182:21 183:11 225:15 

400:15 

pointing 400:21 404:5 

points 228:15 249:14 

360:1 388:2 

poison 185:16 310:7 

policies 363:22 417:9 

417:19 418:17 

policy 10:21 140:12 

210:3 285:5 381:14 

417:17 

polished 208:19 

political 153:17 155:14 

155:18 

politicians 84:8 

polysaccharide 243:10 

polysulfide 313:18 

polyvinyl 282:2 287:10 

ponds 222:10 272:15 

274:22 

pools 275:21 

poorly 238:19 

popular 188:7 

portion 85:2 188:18 

384:4 415:15 

portions 413:6 

pose 131:2 314:11 

posed 236:3,4 307:3 

position 343:18 352:11 

419:1,5 420:14 

423:22 

positions 419:10 428:6 

possibility 76:6 141:4 

226:16 250:1 

possible 17:8 44:13 

123:18 124:5 126:15 

150:19 163:20 189:14 

231:3 250:7 388:7 

possibly 54:3 186:8 

202:2 

post 82:4 

post- 180:19 

post-harvest 118:4 

179:1 183:15 196:19 

196:22 380:5 383:17 

post-use 361:6 

posted 230:10 289:18 

pot 405:7 407:9 

potable 182:12 

potassium 3:13,17 4:11 

4:20 107:15,18,21 

108:14 133:2,5,12 

134:6 276:21 288:14 

288:18,19 295:12 

297:11 299:10 300:17 

302:17,20 303:3 

347:7,12 348:3,14 

potato 193:8 

potatoes 183:7,21 

potential 98:16 174:12 

181:7 184:4 383:6,18 

407:10 412:18 

potentially 61:8 89:1 

99:8 155:17 187:20 

211:7 219:17 228:16 

229:4 239:21 245:9 

245:16 248:7 249:3 

284:20 312:1 353:5 

354:6 383:16 409:19 

412:14 

pots 5:11 64:6 76:14 

404:17 405:22 406:6 

406:9 407:5,7 

poultry 32:12,18 187:2 

207:6 

pound 252:17 

pounds 229:4,5 231:10 

powder 115:2 175:8 

244:7 245:8 253:15 

310:11 332:17 

powders 160:14 

powdery 297:7 301:5 

301:13 

powerful 186:13 

ppm 135:13 

practice 121:5 176:9 

177:5 215:7 260:20 

290:6 388:6 417:10 

practices 74:7 183:13 

183:15 184:2,8 

197:10 199:6 

prebiotic 144:2,15,16 

149:18 150:8 

prebiotics 149:18,20,22 

precedence 89:6 364:1 

370:17 378:13 

precedent 368:6 383:5 

precedents 76:21 

precipice 165:19 

precipitate 215:1 

precipitated 88:3 217:9 

precursors 181:19 

predominant 103:6 

predominantly 274:21 

predominates 309:15 

preface 120:11 

prefer 202:13 283:17 

preferable 182:10 

197:22 

preference 249:8 

263:22 

preferred 203:1 

preharvest 179:19 

prejudiced 145:9 

premiums 253:2 

preparation 179:3 

245:1 

prepared 173:18 

prerogative 369:17 

396:2 

presence 126:20 212:8 

214:13 243:16 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
453 

present 1:11 2:5 77:5 

143:8 184:6 220:10 

237:17 249:9 267:13 

267:18,20 274:4 

314:18 

presentation 7:8 13:22 

presentations 217:13 

presented 25:20 270:13 

360:11 398:14 

presently 193:19 

presents 181:11 

preservative 90:20 

presiding 1:10 

pressed 387:22 

pressing 363:17 

pretty 10:15 20:3 53:14 

58:12 160:16 166:9 

169:7 190:20 214:21 

234:14 238:19,19 

248:2 263:5 282:6 

310:3 316:22 321:13 

381:3,5 416:9 

prevailing 357:6 

prevails 363:11 

prevent 32:14 123:13 

135:22 201:2 279:14 

388:8 403:1 420:7 

preventative 30:8,13 

183:13 

previous 66:1 105:12 

181:13 205:13 208:21 

210:9 217:5 244:14 

246:6 247:3 255:13 

263:3 318:15 319:2 

391:9 

previously 82:15 

primarily 44:7 146:2 

166:4 263:9 

primary 82:2 164:10 

principle 293:12 

principles 78:14 

prior 73:20 286:17 

priorities 6:17 416:16 

prioritization 82:3 

prioritized 364:4 

priority 69:7 

private 7:19 

privately 378:1 

probably 33:19 45:14 

57:10 68:20 102:11 

116:8 122:1 125:22 

126:9 131:3 157:12 

213:12 223:18 238:18 

239:19 246:21 261:22 

273:20 274:22 275:22 

280:4,10 292:13 

298:7 310:13 326:22 

332:16 338:9 343:1 

368:18 369:11 370:2 

381:19 396:1 404:11 

415:1 417:5,5,17 

probiotics 149:20 

problem 73:22 84:6 

120:7 301:5 358:1 

366:19 371:1 

problematic 195:10 

261:1 351:1 

problems 17:20 41:10 

121:6 186:3 290:8 

306:13 309:2 334:11 

374:14 

procedures 363:22 

417:9,19 418:17 

421:5 

proceed 352:22 398:3 

407:10 410:8 411:20 

413:11 418:10 419:20 

422:9 

proceeds 93:6 

process 10:19 20:11,15 

38:7,16 48:2 60:3 

65:12 68:15 76:16 

80:9 91:18 92:9 93:14 

97:7 98:1,5 99:17 

105:1 131:12 133:13 

141:10 155:1 161:22 

163:6,14 169:20 

191:14 203:18 232:5 

244:10 260:18 262:3 

262:13 328:12,19,20 

329:7 341:1 407:4 

409:3 

processed 87:10 91:11 

143:16 144:9 145:22 

146:10,16 149:13 

150:18 156:3 175:14 

192:19 207:13 227:3 

231:10 243:8 247:8 

247:13 249:1 265:3 

365:19 381:12 

processes 261:20 

processing 42:4,5 

112:9 119:9 121:11 

123:13 125:21 133:13 

139:11 152:15 164:9 

186:22 187:2,2,8,19 

190:22 193:11 194:13 

194:14 207:6,10 

216:15 244:10 248:4 

255:9 266:6 360:17 

366:3,11,15 367:3,13 

367:16 368:10,14 

369:3,7 370:2,11 

383:19 384:3 

processor 167:17 

212:17 359:9 

processors 75:14 

79:16 85:7 102:3 

184:1 191:6 197:5 

198:8,13 229:18 

239:13 

procurer 38:22 

produce 11:7 64:20 

119:17 127:9 185:10 

188:14,17 223:12 

228:8 229:3 263:7 

264:18 282:9 318:13 

357:17 375:13 

produced 38:2 61:17 

61:18,19,20 79:9 

90:18 96:5 102:19 

119:11 140:18 143:15 

143:21 179:8 216:8 

289:11 341:10 

producer 48:13 128:22 

155:5 174:7 190:13 

225:17 227:4 228:7 

228:21 239:20 240:9 

254:8,8 263:13 274:2 

336:9 342:13 382:10 

383:13 

producers 34:6 44:22 

56:17 60:1 65:9,15 

66:8 74:9 82:21 106:4 

126:21 200:9 237:3 

246:5 247:6 264:12 

273:9 282:8 291:21 

292:4,16 305:12 

319:1 336:8 342:6 

348:9 392:11 

producing 260:14 

356:12 

product 9:17 30:17 

39:3 49:16 53:13,15 

53:18,21 54:1,7,17 

55:3 59:13 62:12 

64:12 66:7 70:12 71:1 

71:13 92:1 95:11 99:1 

99:1,4,7,9,19 100:7 

101:3,15 112:10 

128:4,10 139:3,7 

143:22 145:11,22 

147:6 148:12,14 

150:15 155:5,22 

157:15 163:7 164:16 

165:5 169:20 174:2 

174:22 176:13 179:14 

182:5 183:5,6,8 204:9 

217:14 218:20 227:7 

228:1,8,21 229:1,11 

231:10 236:18 237:10 

238:20 239:1,22 

246:8 247:7 254:15 

261:2 266:5 272:6 

320:2 323:7 324:19 

328:19 329:3 332:14 

337:17 345:18 366:22 

367:21 374:11 377:21 

411:13 

production 18:15 22:10 

22:18 23:8 25:17 

48:12 55:20 57:6 

61:22 62:2 65:10 81:8 

95:8 99:3 119:8 

156:21 157:4 158:9 

158:10 167:10 168:12 

179:17,19,22 209:22 

210:6 228:17 248:9 

259:13 263:8 268:8 

268:15 272:5 284:5 

287:2 317:21 318:4 

327:6 336:7,20 

340:14,17 341:3,13 

342:3,5 343:13 

347:11 354:13 358:17 

372:20 376:16 377:11 

378:12 380:5 385:16 

385:21 386:1 390:14 

392:10,20 403:13 

405:3 406:2,8 

products 4:16 8:6 

23:19 53:6,19 54:4,9 

54:11,15,16 57:1,12 

59:12 79:8 87:10 91:4 

91:6,8,11,12,13,13 

95:9 99:2 103:2 110:8 

118:12 124:2 125:15 

125:17 126:22 138:21 

139:1,9 140:13 

143:15,17,22 144:6 

149:11 150:18 152:17 

156:4,11,12 160:13 

161:3,8,12,18 162:15 

162:19 163:1 164:18 

194:22 201:12 204:13 

207:14 227:11 228:4 

229:9,18 238:22 

239:19 243:8,19 

244:8 247:13 249:5 

249:11 263:19 265:17 

266:1,6,10 318:2,17 

326:6,10,16,20 327:7 

330:2 342:10 376:22 

377:2 380:17 402:18 

415:12 

profile 91:9 

program 2:8,10,14,16 

11:5 22:6 30:1 31:18 

32:22 33:4,20 69:5 

73:5,11,12,22 77:4 

92:10 115:19 154:9 

171:5 182:1 199:20 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
454 

200:12 202:16 203:18 

203:22 228:16,17 

238:2 245:4 264:11 

285:4,13 293:2 

327:16,19 328:6 

366:5,17 368:18 

370:4,16 396:9 

398:10 407:8,12,14 

412:22 414:20 427:9 

427:12 

program's 285:9 

366:13 

programming 11:18 

21:21 

programs 78:9,10 

progress 7:19 9:5 

14:16,18 197:20 

progression 355:2 

progressively 266:19 

prohibit 46:1 127:6 

209:21 385:21 

prohibited 22:14 

125:16 342:4 347:10 

347:16 359:17 375:7 

375:16 377:10,14 

385:15,20 

project 11:20 19:21 

20:3 244:3 284:14,15 

394:17 

projects 263:19 

promote 150:2 

promotion 36:4 

promptly 142:19 

pronounce 145:8 

proof 229:14 

proper 196:9 

properties 95:12 110:4 

160:11 216:11,12 

244:18 351:14 

proportion 147:16 

proposal 4:3,4,4,5,5 5:3 

5:4,5,6 68:21 115:17 

214:20 216:2 261:9 

299:8 365:5,10 

370:18,20 374:1 

375:5,8 387:2,6,13 

391:8 394:7,16,21 

396:8 398:9 399:14 

399:19 401:14,16 

404:11 413:20 

proposals 178:14 

298:15,16,18 350:2 

365:6 413:9,10 

Proposals/Final 5:13 

propose 299:3 349:18 

proposed 7:14 9:21 

48:20 49:7 74:10,13 

75:2,18 78:9 85:10 

92:7 180:11 209:13 

216:1 387:8 

proprietary 91:15 176:1 

propylene 340:18 

protect 97:15 136:1 

230:21 259:12 403:7 

412:16 

protected 73:1 

protecting 407:15 

protection 53:4 77:21 

102:9 139:10 308:6,7 

308:17 309:1 311:8 

403:21 

protections 308:11,13 

protective 72:20 

protocol 298:2,6 382:3 

prove 228:1 237:15 

238:10 314:22 

provide 6:18 74:20 

127:11 200:8 344:12 

provided 40:21 41:5 

135:11 208:4 351:8 

428:9 

provides 22:22 263:15 

prudent 409:19 

published 10:21 92:7 

298:10 413:19 418:6 

publishing 413:14 

pull 157:9 

pulling 14:11 19:18 

21:18 56:16 

pullulan 4:6 258:14,15 

259:3,15,21 260:5,8 

260:15,18,19 261:5 

261:12 415:20 

pulmonary 185:11 

pulp 248:15 254:15 

pumped 333:11 367:22 

purchase 69:22 70:15 

388:11,15 

purchased 64:4 

purchasing 306:20 

pure 100:21 207:4 

purified 88:2 

purity 331:9 

purpose 79:7 

purposes 79:7 91:16 

337:2 356:4 

pursue 81:12 

pursued 400:14 

pursuing 7:16 215:8 

purview 44:14 136:17 

379:5,11 

push 252:8,18 

pushed 295:5 415:8 

pushes 253:2 

pushing 357:21 

put 6:22 29:22 33:5 

54:15 59:9 70:2,12 

74:3 83:2 100:8 102:3 

103:1 111:15 145:6 

192:3 194:19 195:12 

195:20 197:16 216:6 

217:4 219:12 229:12 

238:6 248:8 249:5 

252:6,7,21 255:2 

279:13 311:4,22 

312:1 315:3 329:13 

354:10 361:3 366:9 

368:9,16,21 369:21 

375:5,6 377:10 

380:14 388:5 412:14 

418:15 426:9 

puts 196:11 248:11 

293:10 350:1 

putting 81:6 113:10 

165:4 252:2 355:15 

370:19 378:14 394:20 

414:8 

PVC 282:3 

Q

QCS 341:19 344:14 

quagmire 369:16 

qualified 111:6 228:7 

qualities 17:3,5 

quality 82:9 136:1 

quandary 196:1 

quantify 59:21 254:6,10 

quantities 248:5 250:14 

341:6 

quantity 112:18 226:6 

229:1 231:13,15 

247:6 252:22 

queen 70:15 

question 8:20 14:13 

15:6 18:4 49:21 54:6 

66:10 76:6 79:20 

82:12 96:11 98:22 

103:5 110:18 111:15 

112:19 145:17,20 

146:5,12 149:8 

160:17 162:22 188:5 

194:9 195:3,19 

197:12 202:18 221:17 

221:18 226:2,11 

229:2 231:8 236:3 

244:17 253:10 292:22 

293:21 297:9 307:3 

310:9 318:1 320:10 

333:9,20 344:4 

353:16 356:20 360:14 

361:21 371:10 

questionable 10:13,17 

11:9 

questioning 215:8 

222:19 235:22 

questions 14:5,22 

20:19 23:9 26:2 71:9 

71:11,15 112:15 

153:9 199:22 209:14 

217:15 225:21 231:16 

232:1 255:16 261:16 

263:4 269:1 270:17 

289:19 292:1 334:2 

337:10 357:15 405:5 

418:3 421:4 

quick 84:3 200:21 

201:18 204:4 286:4 

364:10 

quicker 86:13 

quickly 10:16 11:20 

13:3 20:11 83:19 84:2 

84:4 93:6 267:5,5,6 

275:18 289:1 297:2 

322:2 363:19 402:20 

quiet 141:4 

quit 247:14 

quite 6:9 50:10 70:11 

87:20 121:15 130:20 

137:1 156:12 165:15 

165:15 181:4 185:22 

225:19 255:8 284:2 

289:20 290:19 291:20 

291:21 324:18 342:14 

366:10,12 375:9 

376:8,13 377:13 

393:18 404:21 413:18 

quizzical 321:7 

quorum 143:8 

quote 264:8 369:3 

377:5 

R

rains 283:22 

raise 99:22 141:3 

raised 11:2 13:12 

144:10 209:14 213:16 

214:18 222:20 264:7 

293:5 306:1 

raises 293:11 

raising 14:12 361:4 

ranchers 75:14 79:16 

85:6 

range 160:10 186:7 

210:13 216:9,14,18 

ranges 153:1 

rank 364:1 

ranked 110:6 

rapid 10:12,15 

rapidly 317:9 343:3 

rare 368:9 379:17 

rate 105:2 273:16 

re- 63:6 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
455 

re-petition 345:15 

re-petitioned 60:7 

re-vote 420:14,17,17,17 

420:17 

re3view 211:14 

reach 56:19 71:14,17 

249:20 376:6 395:11 

reached 55:7,10 273:12 

344:1 375:20 381:10 

382:9 408:9 

react 190:20 

reacted 181:9 

reaction 84:8 97:13 

187:22 249:7 

reactions 96:7 174:14 

read 25:12 49:19 61:4 

85:1 97:21,22 145:9 

146:19 199:21 208:2 

214:20 215:22 216:2 

217:7 247:20 255:1 

280:1 290:4 302:3,5 

302:12 358:9 396:7 

398:5,5,6 405:19 

408:18 418:18 

readily 164:5,14 198:22 

314:4 

reading 22:6 58:9 72:15 

81:13 98:3 175:5 

303:9 

ready 11:16 89:10 

168:21 228:12 301:22 

303:4,5 362:7 

real 97:9 169:8 226:2 

310:6 

reality 101:17 408:17 

realize 63:20 145:8 

reapply 10:4 

reason 38:9 54:4 60:8 

60:13,19 62:5,13 

128:17 141:5 214:13 

301:17 306:3 311:8 

323:6 333:3 366:19 

389:3 

reasonable 167:16 

reasoning 380:18,20 

381:8 

reasons 15:17 45:18 

55:3 131:9 189:1 

192:10 196:21 336:21 

344:22 350:15 353:18 

393:13 

recall 204:5 299:20 

recalled 12:10 

receive 68:13,22 72:12 

115:19 188:14 209:12 

343:19 365:13 378:19 

received 47:22 48:1 

69:3 91:20 109:20,22 

176:12 188:7 207:16 

208:20 209:5 211:18 

223:5,10 245:11 

272:22 273:3 301:10 

314:15 324:20 328:16 

337:4 345:14 350:10 

351:20 399:18 401:20 

402:10 406:17 

receives 420:10,15 

receiving 378:14 

420:12 

recess 142:20 267:7 

recipe 240:2 

recipes 139:17 

reclassification 140:21 

reclassified 140:10 

recognize 132:10 136:3 

328:14 

recognized 92:21 

recognizing 275:8 

recommend 205:20,22 

206:1 210:10 234:4,6 

241:22 257:2,6,7 

295:16,17 300:13 

303:14 315:15 322:18 

322:19 385:19 

recommendation 92:4 

92:6 165:11 210:3 

242:2 370:20 373:3 

415:11 

recommendations

74:11 203:21,22 

308:11 

recommended 154:13 

163:18 207:22 379:2 

recommending 213:18 

reconsidering 193:13 

reconvene 417:17 

record 106:5 116:6 

142:22 147:13 190:8 

267:9 302:3 322:10 

322:12 364:14 428:22 

recorded 9:3 

records 16:6 

recovered 341:1 

recruit 13:4 

recurring 98:4 

recycled 4:10 279:5 

280:15 405:1 406:12 

406:15 

recycling 287:3 

red 105:2 284:8 

reduce 27:13 119:1 

133:14,18 175:3 

179:4 182:19 186:8 

268:20 290:7 306:8 

331:19 332:7 403:2,3 

404:1 

reduced 181:7 305:17 

306:7 

reduces 333:14 334:10 

337:5,8 

reducing 23:1 306:18 

reduction 337:5 345:17 

345:19,22 

refer 150:17 213:19 

218:11 223:21 224:7 

286:19 362:10 363:21 

reference 88:2,7 176:15 

227:12 

referenced 88:4 

references 126:14 

231:14 394:13 

referred 225:10 351:16 

363:12 

referring 246:6 279:16 

369:3 395:3 

refers 319:14 

refined 165:7 

refinement 216:3 

refining 340:21 341:1 

reflected 290:20 

reflecting 264:13 

reflects 326:17 

reforming 217:1,3 

reformulated 97:16 

refused 12:3 

refuted 220:17 

Regalia 358:12 

regard 156:8 237:8 

407:3 

regarded 110:1 

regarding 41:14 52:20 

88:2 115:22 180:21 

regardless 393:8 

region 7:13 8:10 9:16 

20:8 62:12 155:19,20 

158:10 377:20 

regionally 289:22 

regions 157:6 307:22 

332:2 

register 63:7 

registered 52:9 53:21 

53:22 54:5,10 57:20 

59:12,14 63:5 65:14 

318:2,17 319:7 320:2 

320:10,14 

registration 182:22 

183:1 317:4 

regrouped 414:20 

regular 21:21 

regularly 374:17 

regulated 80:20,21 

102:7 

regulation 78:14 80:3 

80:13 81:2 336:1 

369:8 396:9 398:10 

regulations 49:5 78:13 

80:3,5,14 81:7,12 

198:19 200:3 407:14 

regulations-based 80:9 

regulator 87:18 118:11 

119:7 

regulators 120:13,20 

335:22 

regulatory 57:18 75:3 

78:7,12,17 203:18 

204:1 306:13 387:15 

391:18 

reiterate 21:8 82:12 

83:12 93:4 169:17,18 

231:21 280:9 338:17 

382:7 409:2 

reiterated 92:20 236:5 

reiterating 88:17 

reject 85:13 206:1 

352:20 373:2 397:1 

related 78:14 126:22,22 

186:19 187:1 198:7 

263:12 286:18 287:3 

308:6 327:1 395:4,4,5 

395:7,7,9 417:9 

relates 307:2 

relation 273:1 

relationship 8:1 305:17 

relationships 11:10 

relatively 22:21 58:22 

126:19 127:1 275:3 

release 48:14 123:12 

160:14 179:15 

releasing 217:20 218:8 

reliance 63:15 283:11 

relief 27:16 

relist 27:20 63:6 64:17 

65:19 108:16,18 

113:18 160:17 165:11 

170:21,22 171:21 

293:18 306:3 330:6 

348:10 

relisted 97:9 165:17 

291:14 

relisting 23:4 26:1 

29:20 36:10 38:14 

44:12,15 47:20 48:4 

97:18 108:4 115:8 

130:22 133:20 153:7 

169:10 176:6 268:17 

268:22 270:16 294:17 

326:19 327:13 331:22 

rely 352:12,13 392:19 

remain 8:12 30:6 89:17 

420:19 426:16 

remainder 364:11 

remains 78:13 322:20 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
456 

remarks 3:2 5:19 

remedial 357:22 

remember 18:16 

136:22 175:2,2 204:7 

269:6 343:16 378:1 

remind 23:21 58:4 

65:22 72:10 84:17 

103:9 345:5 

reminder 310:6 

reminding 6:16 

remiss 150:6 359:12 

removal 25:20 42:5 

55:3 123:18 154:13 

163:19 270:14 291:16 

295:16,17 301:19 

303:14 315:15 

removed 53:8 75:2 

92:13 140:4 163:18 

282:12 318:11 322:5 

379:1 387:13 394:6 

395:2,3 420:13 

removing 55:17 61:1 

80:2 130:14 131:4 

193:19 280:6 

renal 126:16 

renewing 276:6 

renowned 58:11 

reorganization 105:22 

413:20 

reorganizations 413:17 

413:18 

repeat 126:7 128:6 

146:6 148:16 202:17 

360:13 

repeatable 20:11,15 

repeated 277:4 

repercussions 370:17 

replace 70:14 341:22 

replacement 36:5 71:1 

95:19 97:2,4 290:9 

replacer 108:7 

replacing 273:19 

report 74:15 97:22 

352:12,14,15 401:10 

401:19 

reported 9:9 92:2 

104:21 309:11 

reports 96:7 

represent 188:16,18 

representative 283:8 

represented 326:22 

representing 75:13 

85:6 305:10 

represents 342:20 

request 6:11 14:1 31:19 

32:3 33:9 45:4 167:17 

188:8 212:9 318:11 

345:15 407:8 416:6 

requested 71:6 95:22 

96:1 207:19 226:1 

374:8 382:8 401:9 

requesting 127:19 

140:12 390:12 

requests 48:13 96:3 

154:5 285:14 

require 136:7 420:9 

required 9:13 320:11 

380:10 

requirement 196:3 

328:18 

requirements 11:1 

74:17 

requires 48:8 164:8 

182:13 224:9 396:22 

research 110:20 168:7 

220:16 245:2 284:14 

284:15,21 319:8 

322:2 345:8 416:16 

researched 344:15,16 

reservations 283:10,10 

reserved 211:5 369:8 

residual 180:5,7 

residuals 213:3 214:10 

residues 182:19 

resistance 23:2 208:14 

211:2,3,8 268:20 

290:8 309:10,22 

374:15 

resistant 375:3 

resolution 74:3,4 76:5 

85:1,13 132:12 

405:19 407:12,17 

408:11 409:10 410:9 

410:11,12 

resolutions 83:16 

resolved 75:10 85:2,3 

407:6 

resource 354:9 

respect 81:5 199:16 

306:6 354:1 360:9 

respiratory 305:21 

308:16 

respond 14:1 62:10 

255:15 

responded 210:2 

231:16 236:4 

respondent 351:17 

responding 290:2,15 

290:17 

responds 74:13 

response 10:12,15 

23:12 26:4 28:8 31:13 

33:10,11 34:15 36:13 

39:8 42:9 44:18 48:13 

66:20 71:10 73:7 

75:17 85:10 93:16 

108:11 110:22 124:7 

137:12 170:4 177:7 

185:21 227:22 273:16 

289:21 292:18 312:4 

315:10 321:20 325:1 

334:1 351:8,9 394:1 

398:2 404:14 418:4 

423:12 424:17 

responses 239:16 

307:8 366:10 

responsibilities 417:13 

419:11 

responsibility 236:14 

responsibly 19:3 

rest 57:18 103:1 142:17 

220:5 353:16 417:15 

restricted 378:15 

restricting 181:16 

restriction 355:11 

restrictions 211:21 

restricts 272:4 

result 140:19 212:4 

216:13 291:11 310:21 

351:20 

resulted 9:16,18 15:12 

resulting 101:2 

results 183:20 211:15 

289:6 392:16 

resume 365:2 

resumed 142:22 267:9 

364:14 

retail 379:22 

retailer 96:6 140:6 

145:17 249:6 265:15 

381:2,11 382:9 

retailers 75:14 79:15 

85:7 101:8 381:6 

382:16 

retain 24:10 26:9 28:14 

34:20 36:21 39:18 

42:20 46:9 50:19 67:5 

93:22 94:2 103:15 

106:16 117:3 122:6 

124:13 129:9 131:19 

134:8 137:18 141:16 

151:7 156:15 159:3 

168:2 177:14 269:7 

271:2 277:19 280:19 

280:20 287:15 291:17 

312:13 315:16 325:8 

335:1 339:10 346:6 

348:18 

retained 292:6 

retaining 153:12 155:7 

166:22 

reveal 280:2 

revealed 215:9 

revealing 222:22 

reveals 280:3 

reversible 95:14 

review 3:4,11 4:8 6:7 

7:6 33:9 42:12 53:17 

58:22 60:3 66:1 68:15 

68:19 69:1 88:13 

93:13 111:3 119:16 

123:22 136:17 168:4 

175:17 181:2 182:8,9 

184:22 188:21 189:2 

189:12,13 195:8 

200:4 207:19 209:10 

212:9 213:20 223:8 

223:22 289:13 305:6 

309:5 326:21 327:8 

327:16 336:17 342:8 

347:21 353:5 366:3,8 

367:16 368:7 370:17 

374:9,16 387:4 

388:19 402:5 405:16 

405:21 407:7,10 

415:10,10 

reviewed 174:6 181:20 

185:5 213:5 214:5 

279:8 342:2 353:7 

367:14 

reviewers 89:4 

reviewing 140:17 

169:20 187:1 204:12 

350:16 360:5 366:11 

reviews 22:8 89:3 

172:22 402:1 

revision 213:15 

revocations 7:15 8:17 

15:16 

revoked 7:15 8:15 

15:13 

reward 168:11 

Rica 61:17 

Rican 61:16 120:22 

338:17 

Ricans 340:7 

RICH 193:16 194:2,4 

197:15 202:7,19 

203:8,11 204:3 205:5 

205:7 206:14,18 

224:21 225:7 231:19 

233:15 234:17 235:2 

241:8,16 242:10,19 

256:11,21 257:13 

258:2 

Richard 214:4 

Rick 1:16 36:21 122:7 

199:3 200:20 234:7 

322:21 410:13 

rigorously 238:1 

rind 118:16 

rinse 41:15 131:12 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
457 

180:20 182:13 

Rio 61:19 

ripening 118:5,12 

336:13 

rise 64:7 98:5 

rises 99:2 

risk 7:20 12:12 20:12 

208:5,7 314:12 

414:15,17 

risk-based 13:18 16:21 

18:8 

risks 212:19 

River 1:8 

Riverfront 1:9 

RM 326:14 

robust 246:3 249:17,18 

350:2 

robustly 250:9 

rod 196:20 

role 155:3 409:10 

417:13 428:3 

roles 419:16 425:21 

ROMERO-BRIONES

1:18 24:19 26:18 

28:21 35:4 37:3 39:22 

42:22 44:6 46:11 

47:15 51:12 67:20 

86:4 90:6 94:13 104:3 

107:3,20 109:3 114:3 

114:22 117:9 122:11 

124:16 129:11 130:13 

131:20 135:1 138:10 

142:7 151:21 159:13 

160:5 161:17 162:5 

162:17 172:9 178:1 

192:15 193:6 194:1,3 

194:6 206:9 224:15 

225:14 231:12 233:10 

234:11 235:8 241:3 

242:5 256:6 257:22 

270:1 271:14 278:9 

281:9 288:3 296:4 

303:22 312:20 315:22 

323:3 325:11 330:8 

335:2 340:2 346:20 

349:8 363:3 372:9 

373:12 385:3 386:10 

397:8 398:21 410:17 

room 84:8 106:9 162:8 

231:7 338:22 

root 361:4,16,19 362:1 

393:4,6 

rot 197:6 

rotate 377:2 

rotating 393:19 

rotation 268:19 274:18 

317:20 338:5 

round 176:21 181:13 

258:21 348:1 424:11 

426:3,10 

rounds 181:13 

route 127:20 

routinely 176:5 377:1 

row 155:16 284:2 

rule 48:20 49:7 74:10 

74:13 75:2,4,16,18 

78:14 85:8,11 92:7 

rulemaking 50:3 74:18 

77:15 81:16 161:22 

168:20 169:1,6 

245:17 407:10 

rules 78:15 358:20 

run 11:4 190:21 267:3 

413:13,22 425:7,8 

running 200:15 284:3 

332:15 420:13 422:11 

runs 426:18 

rural 62:1,8 

rush 195:13 412:16 

Russia 7:16 12:2 165:1 

S

saccharides 147:3 

safe 180:7 228:8 324:18 

333:17 

safer 131:1 

safety 184:9 186:17 

198:4,21 212:13,15 

231:7 292:20 360:17 

safflower 160:7 

Saint 1:9 

sake 253:5 371:12 

394:15 

sales 101:15 118:17 

119:3 

Salinas 187:7 

Salmonella 32:14 

salt 108:2 126:15 

365:17 

salts 125:20 243:16 

Sam 55:9 

sample 378:5 

sand 288:21 302:21,22 

sanitation 196:6 197:1 

201:3 

sanitizable 191:5 

sanitize 197:6 201:4 

sanitizer 22:11,13 23:7 

42:12 178:20 179:20 

189:2,12,18 191:1 

200:8 207:9 268:10 

360:16 

sanitizers 130:19 131:4 

131:11 188:20 189:3 

192:18 195:8,10 

199:19 200:5 212:8 

212:10 268:18 416:20 

416:21 

sanitizing 180:1,3,14 

186:7 212:7,21 

Sao 61:18 

sap 173:18 

SAT 11:18 

satellite 9:22 

satisfied 229:16 230:4 

satisfy 227:6 

Saturday 191:11 

sauce 225:18 

sausage 263:8,19 

264:2,3 

sausages 263:10,16 

save 337:18 

saw 18:10 31:4 61:15 

69:3 158:3 181:6 

229:22 290:20 324:17 

saying 27:20 33:17 

57:14 59:2 110:7 

120:11 144:8 147:5 

158:7 169:12 170:15 

170:18 174:10 176:7 

196:10 197:2 229:21 

230:18 244:21 252:14 

331:22 341:18 352:9 

361:9 370:21 391:3 

408:19 

says 59:2 81:10,14,18 

102:4 408:13 

scald 403:1,21 

scale 130:15 215:13 

237:3 264:16 354:15 

355:13 

scarce 158:11 

schedule 268:1 

scheduled 21:21 

scheme 218:4 

SCHWARTZ 1:19 24:18 

26:17 28:20 35:3 37:2 

39:21 42:21 47:2 

51:11 67:19 86:3 90:5 

94:12 104:2 107:2 

109:2 114:2 117:8 

122:10 124:15 129:10 

132:17 134:22 138:9 

142:6 151:20 159:12 

172:8 177:22 192:7 

206:8 224:14 233:9 

234:10 241:2 242:4 

256:19 257:21 269:22 

271:13 278:8 281:8 

288:2 296:3 303:21 

312:19 315:21 323:2 

325:10 330:7 335:13 

340:1 346:19 349:7 

363:2 372:8 373:11 

385:2 386:9 397:7 

398:20 410:16 421:17 

science 59:2 174:13 

scientific 220:16 

270:12 

scientifically 228:12 

scientists 212:14 

scope 12:15 

scoped 112:21 

Scott 1:13 60:11 62:10 

86:14 87:15 89:15 

93:21 94:3 106:15 

131:18 133:6 134:7 

141:15 159:1,3 

169:16 192:10 193:15 

197:14 202:5 205:18 

231:4,18 280:21 

286:3 334:12 353:22 

371:20 414:7 421:17 

423:6,8,16 424:4,6,13 

Scott's 88:22 106:8 

178:16 

scratching 196:9 

screen 394:14 

screened 70:5,16 

scroll 395:1 

scrolling 395:3,4 

scrutiny 173:1,3 201:9 

227:14 

SDC 208:4 

Sea 7:13 9:15 20:8 

seafood 187:1 

seal 230:20,20 341:4 

427:15,16 

search 229:22 230:12 

season 119:1 236:21 

392:14 

seat 33:6 143:6 

seats 143:3 425:15 

Seattle 286:6 

seaweeds 110:11 

sec 299:18 

second 75:22 84:16,18 

84:22 106:11 224:2,3 

224:4 240:16 297:2 

298:7 299:4 313:19 

352:4,4 357:1 367:10 

380:15 394:9,11 

401:22 405:4 407:17 

407:20,21 408:1 

secondary 180:13 

366:4 367:13 

seconded 23:18 26:8 

28:12 34:19 36:17,19 

39:12,13,16 42:16,18 

46:8 50:16,18 67:2,4 

84:20 89:12,15 93:19 

93:20 103:13 106:15 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
458 

108:15 113:15,17 

117:2 122:5 124:11 

129:7 131:17 134:7 

137:16 141:13,15 

151:6 158:22 171:19 

177:11 205:18 233:2 

234:3 240:19 241:21 

256:2 257:6 269:10 

270:22 277:17 280:18 

287:13 295:15 303:6 

303:7,10,12 312:11 

315:14 322:14,17 

325:6 330:4 334:20 

339:8 346:3 348:16 

362:12 371:17 372:22 

384:14 385:18 396:11 

396:18,19 398:14 

secret 419:19,22 

422:18 423:17 

Secretary 1:13 25:2,5 

27:1,5 29:4,9 35:9,15 

37:8,15 40:5,12 43:5 

43:14 46:16 47:4 51:3 

51:14 60:12 64:8 

67:11 68:1 75:15 76:7 

77:2,11 82:20,22 

83:15 85:8,17 86:8 

87:16 89:19 90:11 

94:4,19 100:12 104:8 

104:10 106:11 107:8 

107:11 109:8,12 

114:8,13 117:14,20 

122:16 123:1 124:21 

125:7 129:16 130:3 

132:3,18,20 133:7,10 

134:14 135:3 138:1 

138:13 141:20 142:11 

408:5,21 417:13 

419:21 420:4 422:10 

423:22 424:13 

section 22:8 25:13 

29:16 35:22 37:22 

40:19 43:21 47:11 

51:21 79:18 87:8 

90:16 95:3 104:16 

107:17 109:16 114:19 

118:3 123:7 125:13 

130:9 133:4 135:9 

138:18 143:14 152:9 

160:2 173:15 267:14 

268:6 270:8 272:2 

281:20 288:16 298:17 

302:5 304:18 313:15 

316:16 324:1 326:8 

331:5,10 335:21 

340:13 347:9 365:3 

396:8 399:15,15 

412:22 413:9 

sections 200:3 301:20 

387:13 395:2,4,6 

398:9 417:20 418:16 

sector 12:13 

sectors 80:19 81:1 

seed 4:5 5:6 9:14 

164:13 166:8 243:1,6 

243:14 244:10 245:1 

245:8 251:5,9,12,14 

251:22 252:1,3 

253:14,15,22,22 

256:1 257:3 358:11 

359:14 387:2 388:4 

388:11,15,19 389:6 

389:22 390:1,12,13 

390:15,20 411:15 

415:15 

seeds 244:8,22 245:5 

251:7 254:17,17,19 

255:9 388:6 

seeing 10:17 97:8 

158:17 220:16 232:16 

292:14 352:18 354:5 

410:7 424:8,18 

seeking 131:1 180:8 

389:15 390:10,20 

seen 52:19 55:12 70:1 

71:22 81:15 101:11 

126:9 145:17 149:19 

167:9 168:22 177:4 

194:2 227:21 229:19 

239:18 252:13,14 

334:4 343:4 

sees 80:11 131:13 

segment 39:1 

SEITZ 1:20 24:12 27:3 

29:6 35:11 37:10 40:7 

41:4 43:7 46:18 51:5 

67:13 79:20 85:19 

89:21 94:6 103:18 

106:18 109:10 114:10 

117:16 122:18 125:1 

129:18 132:5 134:16 

138:3 141:22 149:3 

149:16 150:22 151:14 

159:6 172:2 175:16 

175:22 176:16,19 

177:3,16 206:16 

224:19 232:7 233:17 

234:19 241:10 242:12 

256:13 257:15 269:17 

271:7 278:2 281:2 

287:18 295:19 304:7 

313:5 316:7 323:13 

325:18 330:15 335:7 

339:17 346:13 349:1 

362:18 372:2 373:7 

384:18 386:17 397:15 

399:6 411:2 

select 420:6 

selection 290:7 392:10 

393:5 

self-nominate 419:2 

sell 69:15 70:22 228:22 

229:5,8 

seller 55:13 

sellers 36:8 

selling 57:5 70:21 

73:14 

sells 64:3 342:17,18 

semester 414:22 

semi-politically 164:21 

send 102:15,16 169:5 

203:17 209:9 213:12 

223:17 318:5 337:17 

350:13 351:21 353:17 

362:8 408:21 

sending 352:21 353:12 

358:22 

sense 17:2 147:10 

191:8 213:12 217:19 

218:22 220:20 221:1 

302:6 327:11 355:21 

369:20 379:8,9 

403:20 

sensible 112:22 

sensitive 311:19 

sent 318:22 394:3,7 

405:10 415:14,19 

416:19 

separate 298:22 299:1 

299:6 300:18,19 

301:18 307:20 342:9 

separately 154:7 155:1 

298:19,21 308:1 

separation 124:3 

septic 221:4,15 222:10 

222:20 

Serbia 13:11,11 17:7 

Serbian 10:14 18:5 

Serenade 358:15 

series 341:2 392:5 

Seriously 31:12 

serve 156:4 419:4,6 

serves 88:12 

service 2:11 11:13 13:5 

19:4 80:18 426:2,2 

427:11 

services 18:13 214:11 

set 18:7 50:3 78:13 

121:6 289:16 371:1 

sets 289:17 

setting 212:5 222:9 

seven 52:14 

severe 141:7 284:2 

shake 101:9 

shape 216:12 

share 56:4 119:12 

218:16 227:15 236:16 

239:21 265:16 284:22 

352:9 

sharing 8:5 11:9 

sheet 89:1 

shifted 184:9 

shiitake 341:4,17 

shiitakes 342:6 

ship-specific 10:19 

shipment 12:8 336:15 

shipments 10:20 11:22 

12:7 

shipping 356:7 

shopping 10:7 83:22 

short 15:14 21:19 72:8 

258:12 

shortcut 128:3,9 

shortly 253:9 

shot 68:19 

show 227:22 229:15 

231:2 

showed 351:17 

showing 163:7 211:2 

244:2 395:8 

shown 76:17 375:1 

shows 394:14 

shroud 191:9,10 

sick 308:22 

side 50:1 99:21 112:7 

161:6 164:6,6 169:9 

192:19 193:22 202:11 

267:20 310:17 314:20 

376:12,14 383:3 

393:2 422:17,17 

426:22 

sides 245:20 

sign 380:10 

signaling 185:14 

signals 185:15 

significance 240:1 

significant 8:13 25:19 

126:12 188:18 202:12 

270:13 334:5 337:4 

significantly 110:4 

signing 132:9 307:17 

silica 288:19 289:5,9 

292:10 302:19 

silicate 4:11 276:21 

288:14,18,20 295:12 

297:11 299:10 300:17 

302:17,20 303:3 

silver 4:4 207:1,2 

210:15 211:3,4,6,8,12 

211:17,20 214:22 

215:6,11 217:17,20 

218:12,20,22 219:12 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
459 

219:15,17,20 220:6,9 

221:6,8,21 223:22 

262:12 284:7 415:18 

similar 57:21 69:16 

109:22 110:3 120:18 

135:16,19 147:3,4 

154:5,15 180:11 

208:11 225:16 235:10 

237:13 243:14,20 

244:13 245:13 248:1 

263:2 265:1,12 273:3 

327:9 351:14 357:17 

403:18 414:17 

similarities 264:21 

simple 224:9 231:17 

247:4 362:13 396:21 

396:22 

simplistic 247:16 

simply 170:21 352:14 

Simultaneous 299:14 

single 99:19 154:12 

247:5 263:16 299:7 

309:22 310:2 

sit 338:21 377:6 413:12 

site 221:10 228:14 

sitting 101:19 425:15 

situation 80:5 204:14 

227:6 321:11,12 

370:21 

situations 153:17 

six 12:21 20:16 24:8 

74:11 147:5 206:20 

338:8 350:12 

sizable 209:5 

size 12:15 208:2 210:5 

210:12,16,18 215:1,3 

215:13 240:8 

sizes 209:22 210:11 

246:4 249:19 

skeptical 276:6 

skewed 289:22 

skins 263:7 

skipped 304:13 

slate 243:11 

sleeve 427:15 

sliced 374:20 

slide 6:17 9:6 11:21 

73:18 298:10,12,17 

302:9 303:9 

slides 7:4 418:16 

slight 132:9 

slightly 152:22 170:11 

293:10 

Slim 262:20,20 

slogan 77:11 

slowly 395:1 

small 39:2,4 61:13,13 

62:2 70:2 91:4 139:2 

191:1,6 194:13,14 

196:6 198:3,8,18 

225:15,15 228:4,6,21 

229:3 239:13,13,20 

244:22 247:5,6 248:2 

251:16 341:6 378:5 

383:4 389:10 

smaller 215:14 237:3 

246:5 254:8 329:20 

341:17 

smoke 333:10 

smoothly 425:8 

snack 91:12 

snacks 108:6 

soap 38:7 39:3 

sodium 4:3,9 5:4 108:7 

178:15 179:9 180:12 

181:17,19 201:22 

202:3 203:2,12 

205:16 213:4 214:5 

214:11 272:1,3 

277:14 365:5,17,21 

371:14 372:18 

SOEs 51:19 52:5,20 

53:20 56:22 73:9 

317:16 

soft 156:4 317:5 

soil 282:7,13 283:13 

284:6 287:4 304:22 

311:2 326:9 331:6 

332:17 338:11 347:14 

351:1,15 354:19 

355:17 356:6,17 

359:19 361:3,4,9 

400:7 403:6 

soil-borne 361:14 

362:3 

SoilGard 358:14 

soils 331:14,20 412:10 

sold 182:4 361:15,17 

sole 38:11 327:5 

solid 169:7 179:11 

soluble 144:2 243:9 

solution 179:19 180:16 

214:22 217:3 

solutions 358:1 

solvent 160:7 

solvents 90:19 102:21 

somebody 15:19 168:1 

175:2,8 185:21 187:3 

198:15 311:18 407:19 

someday 59:16,17 

someone's 151:8 253:7 

253:7 

somewhat 30:1 54:8 

71:5 112:4 180:22 

402:9 

SONIA 2:9 

Sonoma 306:11 

soon 33:10 387:19 

sophisticated 230:2 

sophistication 239:15 

sorry 25:12 28:13 58:2 

65:21 98:12 133:7 

163:15 172:20 197:16 

202:17 204:22 205:6 

270:7 274:11 288:17 

300:22 303:8 304:13 

357:11 371:21 375:3 

421:17 423:11 

sort 6:21 8:8 10:11 19:9 

77:5 78:3 80:11 82:1 

91:11 101:22 169:22 

174:19 199:15 215:2 

219:15 328:4 361:5 

401:10 

sorts 99:6 301:6 324:8 

sound 65:15 147:12 

376:3 

sounds 60:15 73:2 

190:5 247:22 253:16 

soups 144:5 

source 89:8 98:12 99:6 

100:19 127:11 128:15 

129:3 148:1,3,5,7,22 

148:22 153:11,15 

155:4,6 156:10,14 

157:6,16 170:1,1,2 

214:12 221:10 245:7 

247:4 249:2 252:2 

253:14 264:14,17 

327:6,17 347:13 

sourced 164:2 228:2 

288:20 302:21 

sources 13:7 90:17 

91:1 98:10 127:7 

162:13 168:6 171:6 

212:1 218:10 264:3 

sourcing 155:10 156:20 

157:7 228:4 230:3,5 

248:1 254:7 

South 20:9 

Southwest 71:21 

soy 160:7,22 161:12,19 

163:9,22 166:3 171:1 

171:7,14 341:9 342:3 

344:5,17 

soy-based 341:21 

342:2 

soybean 168:1,9 

soybean-derived

170:16 

soybeans 12:4 341:10 

space 54:12 181:10 

spaces 401:13 

spade 355:12,12 

spawn 341:5 343:12 

speak 33:14 63:22 69:5 

80:7 98:15 126:5 

148:10 149:13 156:22 

200:14 247:2 251:3 

421:16 422:8 

speaker 215:9 219:4 

speaking 31:6 91:22 

189:21 249:6 275:4 

299:14 

speaks 188:5 

spearheading 401:7 

special 80:22 81:1 

243:22,22 306:21 

360:6 427:8 

Specialist 2:8,13 

specialized 306:17 

Specialty 2:9 

species 110:13 173:18 

263:16,17 

specific 7:6 9:7 20:5,15 

25:19 45:20,22 56:5 

59:13 71:15 106:3 

110:13,19 111:12,17 

121:16,18,19 188:22 

189:9,19 204:9,10,10 

204:18 216:11 231:16 

254:18 301:12 308:17 

specifically 34:2 91:16 

92:14 119:8 127:16 

210:18 219:4 388:5 

specificity 6:18 7:9 

specified 122:2 125:16 

specify 122:1 301:20 

spectrum 196:20 

314:20 354:15 355:5 

360:18 

spectrums 357:7 

speculation 162:3,6 

speculative 169:7 

speed 96:17 211:7 

spend 19:11 

spending 245:17 

spent 70:19 192:17 

196:8 211:15 245:14 

245:15 401:6 

spices 91:2 

spider 290:3 

spiders 301:13 

spike 18:4,17 19:10 

spills 23:5 

spirit 355:20 358:19,21 

Spivak 58:9 

split 160:16 167:19 

168:8 173:11 272:9 

274:6 

splitting 171:4 

spoilage 135:22 179:4 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
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spoke 8:16 30:17,18 

31:7,9 55:4,10,13 

56:5 188:15 

spot 195:20 197:16 

262:1 380:15 381:19 

381:20 

spots 16:22,22 17:13 

122:3 

spouse 198:5 

spray 191:15 292:9 

317:6 403:10 

sprayed 70:13 289:3 

291:10 403:2 

spraying 333:9 

sprays 160:15 

spread 306:18 

spreading 277:9 

spring 19:22 66:2 68:21 

72:13 78:18 110:1 

135:20 154:5 166:2 

258:19 261:9 273:1 

286:8 305:15 317:18 

326:18 327:5 336:16 

341:8 343:21 388:10 

388:11 414:4 417:1,6 

418:1,13 

St 1:9 

stability 139:10 173:21 

428:10 

stabilize 105:3 108:8 

stabilizer 87:19 108:1 

stabilizers 96:9 

stable 158:12 

staff 2:5 198:14 199:8 

426:16 

stage 401:16,21,22 

416:18 

stages 416:22 

stakeholder 21:4 

111:21 160:20 338:20 

stakeholders 75:6 

82:12 83:1 111:16 

113:10 161:10 245:12 

245:13 289:15 294:15 

343:22 412:3 427:12 

stamp 409:1 

standard 76:16 79:9,18 

165:19 236:2 367:3,5 

382:5 

standardized 10:18 

standards 1:3 64:22 

65:2,4,7 66:13 69:4 

69:11,12 73:11,14 

74:5,8,20,22 75:11 

82:3 85:4 308:6,7 

311:8,15 374:5 376:8 

405:16 407:4 409:14 

standpoint 80:14 383:9 

stands 137:9 

starch 243:15,17 

start 10:16 22:4,5,8 

24:9 26:10 28:15 

34:21 36:21 39:19 

42:20 46:10 50:20 

67:5 78:8 85:14 86:20 

87:5 89:15 94:1,3 

103:15 106:17 108:18 

113:19 117:4 122:7 

124:13 129:9 131:19 

134:9 137:18 141:17 

151:10 159:3 171:21 

177:14 192:21 193:3 

206:2 224:5 229:9 

233:5 234:7 240:21 

242:2 248:3 256:5 

257:8 267:1 268:4,5 

269:11 271:2 277:19 

280:21 287:15 295:18 

303:15 312:13 315:16 

322:20 325:8 330:6 

332:4 335:1 339:10 

346:7 348:18 350:6 

362:14 371:20 373:4 

384:17 386:3 387:18 

397:2 398:15 404:8 

410:13 418:21 419:20 

425:2 

started 143:3 

starting 6:16 226:19 

state 74:6 102:18 190:9 

217:22 238:3 282:17 

284:17,19 339:4 

379:21 

stated 124:1 140:1 

182:6 239:4 259:10 

282:14 336:11 347:19 

366:13,21 375:14 

376:11,17 380:9 

statement 132:9 182:15 

220:17 228:13 235:21 

247:15 307:18 322:4 

341:20 342:1 

statements 120:11 

235:19 

states 1:1 54:9 66:4 

69:10 74:4 147:14 

182:11 351:13 

static 199:12 

stating 74:16 95:17 

101:8 139:21 

status 88:16 92:22 

148:13 285:4 

statutes 282:17 

stay 21:15 68:10 210:8 

268:1 276:12 294:1 

steam-producing

130:16 

stearate 3:16 125:12,14 

125:19 126:8 127:17 

129:6 

step 78:4 178:13 

191:13 379:18 

steps 14:16 83:16 

175:3 229:15,17 

sterility 197:9 

Steve 1:16 28:15 32:5 

49:17 66:9 101:8 

103:14 108:16 109:19 

113:17,19 119:22 

124:12 135:14 137:16 

168:14 169:14 177:12 

190:11,16 195:20 

197:16 204:4 215:8 

224:6,10 234:3 

238:12 243:2 247:19 

256:2 257:5 262:4 

267:15 270:6 271:21 

278:17 288:13 304:11 

312:14 313:11 315:13 

316:13 323:21 326:5 

331:3 332:21 333:22 

334:20 335:18 340:10 

347:6 365:2 373:21 

386:22 397:2 399:13 

413:6 422:11,16 

423:3,16,19 424:13 

Steve's 194:12,16 

222:19 223:3 357:12 

stewardship 199:6 

stick 115:11 190:12,13 

sticking 123:13 426:13 

sticky 62:14,15 

stimulate 390:13 

stock 327:5 353:6,21 

354:6,14 356:5,12 

357:3 359:1,13,14,16 

360:4,21,22 361:1,15 

361:16 393:4,6 

stocks 279:3 327:17 

361:4 

stone 42:6 

stop 57:11 357:5 

stopped 12:9 

storage 101:19 120:3 

179:2 183:7 187:19 

stored 118:12 

stores 382:20 

story 198:14 

Stowe 105:20 174:6 

336:17 

strategic 83:4 

straw 279:14 

strawberries 285:22 

306:21 307:13 310:19 

stream 215:6 217:10,18 

217:20 218:19,21 

219:7 220:4 221:2,7 

221:14 333:2 

streamline 261:19,20 

streams 221:13 

strength 45:21 

strengthening 5:6 

359:14 387:2 

strengths 45:12 121:7 

stress 249:14,16 

strict 409:11,22 

strictly 102:7 318:2 

strip 123:14 

strips 411:15 

strive 150:14 

striving 392:18 

strong 75:6 191:8 

292:18 305:12,13 

324:14 348:9 390:3,4 

stronger 308:10 

strongly 168:13 188:15 

189:21 190:20 252:6 

310:15 

struck 276:16 

structurally 80:12 

structure 139:8 152:21 

stuck 50:10 

studies 20:4,7,9 84:10 

187:3 211:2 218:6,10 

study 10:14 13:12 

265:8 425:6 

stuff 50:3 229:22 254:7 

stunning 310:4 

Sub-Saharan 155:13 

subcommittee's 236:13 

341:20 

subject 98:13 215:21 

414:22 

subjected 91:18 

submissions 89:3 

submit 83:5,8 148:21 

391:9 408:15 

submitted 75:17 85:10 

126:14 162:14 181:22 

207:18 259:3,8 327:2 

344:2 350:17 351:10 

378:11 400:4 

submitting 238:15 

245:15 

subsection 39:5 

subsequent 182:12 

232:12 

substance 3:4 24:3,4,5 

27:17 35:20 41:9,20 

88:11 100:6 102:16 

102:19 153:18 160:6 

180:15 207:13 211:10 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
461 

212:7 223:14 232:10 

232:12 260:7 272:5 

296:18 302:17 331:8 

353:6,9 371:15,19 

377:11 379:6,13,15 

380:17 384:12 385:20 

substances 3:11 4:8 

22:9 48:20 49:6 87:9 

91:1,3 100:4 168:22 

175:17 181:8 200:2 

208:10 212:21 216:7 

268:7 347:10 385:15 

substantial 384:8 

406:20 

substantially 149:7 

317:11 

substitute 108:2 

success 194:2 392:9 

successes 6:20 14:3 

successful 163:11 

183:19 392:14,21 

successfully 7:15 

155:6 157:7,14 345:2 

suckering 120:17 

sucrose 3:8 4:14 51:18 

51:22 52:6,8 57:15 

67:1 78:21 316:14,18 

322:3,14 

sucrose-derived

147:11,12 

Sudan 157:21 

suddenly 155:17 

Sue 1:14 38:5,18 39:15 

50:18 52:4 55:6 58:19 

67:3,6 102:5,13 

137:18 162:10 194:8 

252:9 269:11 316:21 

322:16 340:19 346:3 

346:7 356:1,19 

suffer 265:13 

suffers 265:11 

sufficient 207:20,21 

230:12 231:15 244:9 

244:14 246:10 250:15 

252:22 261:8 345:8 

412:15 

sugar 52:8 69:18 70:13 

98:11 115:2 147:13 

147:15 148:1,5,8 

sugarcane 115:5 

suggest 176:2 235:16 

suggested 41:19 44:13 

44:15 47:19 48:4 

115:7 123:19 130:21 

130:22 226:18 

suggesting 190:4 337:4 

suggestion 171:3 307:2 

308:4 341:14 

suitable 226:7 

sulfate 213:4 214:5,12 

272:18 273:14,19 

290:11 314:11 324:12 

348:3 

sulfite 135:12 136:3 

sulfites 137:7 

sulfur 3:17 4:12,13 

135:7,10 137:15 

296:15 299:18,21 

300:1,2,15,16 304:15 

305:1,6,10,17,21 

306:3 307:16 308:7 

310:6 312:7 313:12 

313:17,21 314:4,10 

314:12,16 315:12 

331:9,12 332:16 

333:10 

sulfuric 326:10 

sulfurous 4:17 331:4,7 

333:1 334:19 

sulfurs 299:17 

summarize 185:2 

209:15 263:11 

summarized 192:10 

summary 133:21 

291:13 

summation 213:14 

summed 213:9 

sun 403:1,7,20 

sunburn 403:3 

sunflower 160:9 161:19 

164:10,13,19 165:5,6 

166:4,7,8,17 167:1 

168:2 171:1 

sunset 3:4,11 4:8 22:8 

23:21,22 24:4,5 25:21 

60:2 97:7 136:17 

142:17 163:16,17 

167:22 178:13 205:22 

227:22 269:6 307:8 

319:2 349:16 364:2,3 

401:22 413:17,18,20 

416:9 

sunsets 86:20,22 87:5 

137:1 232:9 267:18 

268:4 413:16 

sunsetting 300:13 

super 199:7 

supplement 87:17 

108:1 260:21 402:17 

supplemental 127:15 

280:1 

supplements 126:2,11 

126:21 139:2 259:6 

259:14,16 260:1,10 

260:14 

suppli 148:20 

supplied 226:14 

supplier 226:4 250:14 

suppliers 9:14 55:15 

226:16 248:2 382:14 

389:22 390:13,15 

supply 7:12 9:17 39:1 

153:14,19 161:9 

162:21,22 163:2 

166:6,11 226:11 

237:8 244:6,9,20 

245:9,19 246:19 

247:17 248:14,19 

250:3,17 265:11 

375:1 383:14 

support 27:19 30:18 

31:10 33:18 36:6 

38:14 66:7 75:4 76:5 

79:5,21 83:18 88:17 

91:20 93:5 95:16 

97:18 106:2 118:18 

119:5 120:10 123:16 

133:19 139:20 153:7 

155:7 184:12 188:8 

188:11,14 192:11 

209:12 212:11,12 

218:12 227:20 238:11 

259:14 263:14 279:9 

282:6 305:12 307:11 

318:14,21 324:14 

326:19 327:7 329:21 

331:15 348:9 353:12 

390:3,4 406:19 

428:10 

supported 36:10 52:17 

87:21 92:4 123:17 

238:19 324:21 

supporting 230:6 

327:13 427:6 

supportive 295:5 

370:15 

suppose 362:1 382:16 

supposedly 249:7 

suppressants 348:4,5 

suppressing 120:16 

suppression 290:3 

Suranda 56:7,15 

surface 130:15 216:12 

221:3 275:19 289:10 

331:18 

surfaces 130:11 180:4 

207:10 

surprise 332:18 

surprised 292:3 332:12 

surrendered 8:14 10:3 

10:7 

surrenders 9:19 15:20 

survey 319:1,2 341:12 

survival 264:12 

susceptible 201:10 

suspect 16:15 

suspended 8:15 

suspends 15:19 

suspension 9:21 16:6 

101:10 

suspensions 15:15 

sustainability 338:4 

sustainable 110:10 

swabs 196:4 

swayed 353:4 

sweet 72:9 

sweetening 144:2 

switched 308:22 

354:21,22 

switching 65:18 

swore 347:3 

synchrony 120:20 

121:2 

synthetic 22:9 88:5,9 

88:11,16 90:18 120:6 

140:20 205:14 207:12 

208:9 216:20 268:7 

295:8 340:18 342:4 

344:7 347:10 365:20 

367:1 368:13 371:14 

371:19 377:10 403:13 

403:17,22 404:1,2 

synthetic-based 344:17 

synthetically 38:8 

Synthetics 87:13 

109:17 

syrup 69:19 70:13 

system 19:15 30:14 

98:19 100:21 185:13 

221:15,16 222:14 

244:15 268:11 355:6 

406:22 

systemic 293:8,13 

294:5 310:7 

systems 90:19 179:21 

179:21 218:2 222:10 

222:21 268:11 355:3 

357:14,21 358:17 

361:9,10 

systems-based 63:10 

T

table 52:8 81:6 99:12 

161:7 

tables 99:17 

tablets 259:6 

take-away 328:22 

take-home 273:17 

taken 6:19 8:18 59:15 

81:18 157:22 174:15 

194:12 276:11 311:13 

365:15 391:6 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
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takes 76:7 97:16 155:22 

181:9 235:14 

talk 6:14 9:6 33:13 45:6 

58:5 72:16 121:11 

167:10 171:5 345:17 

360:15 365:8 366:5 

377:19 

talked 10:11 56:6 72:1 

73:19 74:2 279:17 

282:9,11 305:15 

306:20 329:1 383:18 

393:13 

talking 7:22 62:1 86:14 

199:10 302:10 333:15 

365:11 393:16 428:4 

talks 343:10 

tamarind 4:5 243:1,6,13 

244:7,7,8,10,13 245:5 

245:7,8 248:15 

249:16 251:5,7,9,12 

251:14,22 252:1,3 

253:14,15,21,22 

254:2,14,15,18 

255:22 257:3 

tank 221:4 

tap 333:5 

target 17:6 297:7 301:3 

301:3 

targeted 297:5 317:10 

task 311:13 

tastes 393:7 

TBD 415:14 

team 20:13 190:3 

tears 192:20 

teat 38:1,10 62:19 

technical 53:17 68:2,15 

69:1 89:3 207:19 

211:14 352:12,14,15 

367:20,22 374:8,16 

401:10,19 402:9 

technically 369:7 

technicians 50:8 

technology 7:20 412:6 

tell 19:10 54:20 96:20 

98:9 100:10 190:8 

238:5 294:14 418:11 

telling 410:6 

temperatures 153:1 

173:21 

temporary 27:16 

ten 192:18 

tend 169:9 238:13 

248:16 354:11 

tended 354:22 

Tennessee 284:16 

tension 81:3 

term 158:16 237:22 

338:3 369:4 419:4,8 

terminology 34:13 

terms 8:16 9:10 60:22 

118:19 145:21 149:12 

184:10 199:5 237:4 

244:5,20 264:19 

293:6 358:4 360:17 

393:10 417:1 

testimonials 405:11 

testimony 246:9 328:22 

338:19 

testing 9:13,16 

tetrahedra 289:9 

textures 243:20 

texturization 160:12 

Thai 252:2 

Thailand 245:4 246:2 

249:16,19,21 250:3,8 

251:6,7,9,12,15,22 

254:3 

thank 7:5 14:8,10,12,15 

19:17,20 20:22 21:5,7 

21:17 22:7,15 29:18 

30:22 36:2,11 37:19 

38:18 39:6 41:2 43:18 

44:5 46:2 47:14 52:3 

58:18 60:10 84:21 

87:16 88:18 118:8 

133:7 149:1 171:9 

178:17 194:6,7 204:3 

231:5 261:18 262:1 

266:13 305:3 320:3,3 

328:5 338:17 352:8 

407:22 408:7,9 413:1 

413:5 425:5,11,12 

426:1,5,12,16,18,22 

427:8,8,19 428:1,11 

428:13,14 

thanking 21:8 

thanks 14:4 15:5 23:10 

28:6 29:13 38:4 72:7 

105:15 128:11 132:14 

141:10 150:22 262:14 

301:1 304:12 333:21 

344:1 405:19 

thee 81:14 

theoretically 361:22 

thereof 419:11 

thermal 95:14 

thermos 427:16 428:14 

Theuer 214:4 

they'd 52:22 284:22 

342:8 388:16 

thick 115:10 

thickener 108:2 173:20 

thickening 95:7 110:2 

139:5 152:19 

thickness 139:10 

thin 291:7 

things 16:14 33:14 

58:14 59:7,16 64:18 

81:4 97:22 98:17 

100:16 101:9,18 

111:7 120:15 126:2 

165:8 167:7 189:7 

191:4 193:17 196:16 

198:1 199:13 201:4 

201:12 228:17 231:14 

237:3 238:14 245:14 

248:4 267:21 268:1 

274:18 276:18 284:8 

290:9 311:18 355:5 

359:20 364:19 367:17 

374:19,21 376:4 

379:20 389:11 425:2 

thinning 314:6 315:1 

third 81:22 203:15 

211:9 402:4 

third-party 352:16 

thorough 231:6 

thoroughly 13:8 

thought 31:4 53:7,7 

59:4 60:18 68:16 

106:1 120:21 127:1 

140:6 153:20 168:19 

174:14 181:4 199:4 

209:3 215:7 222:19 

226:22 230:11 246:15 

298:11 307:15 345:1 

348:7 357:11 412:15 

thought's 215:10 

thoughtful 306:15 

thoughts 98:16 162:4 

184:10 204:20 227:15 

246:12 

thousands 305:11 

310:3 326:22 

three 7:15 63:1 92:19 

105:20 116:14,18 

164:22 254:1 300:15 

304:15,17 305:7 

312:9 338:8,22 342:9 

343:6 390:2 399:16 

419:6 426:7 

three-staged 401:15 

threshold 210:19 227:7 

230:15 232:10 

throat 185:11 

tie 420:16 

ties 13:4 

tight 13:4 268:1 

timely 388:4 407:7 

times 70:14,16 163:13 

166:6 222:13,14 

283:21 351:18 382:22 

388:7 

timing 336:14 

Tina 376:6 

tiny 157:2 

tired 247:13 

title 395:14 396:2 

tobacco 120:17 

today 6:5,9 21:5 155:6 

162:9 184:20 261:22 

357:7 

today's 286:20 

toddler 108:5 

told 72:8 

tolerance 320:11 322:2 

322:5 

Tom's 63:19 65:11 

169:9 227:2 231:19 

345:13 

tonight 268:3 

tons 13:13 342:19 

tool 28:5 30:8 61:1 

184:4 191:21 290:5 

292:15 301:11 307:14 

317:19 319:5 336:6 

343:9 354:9 

toolbox 59:11 191:21 

204:17 290:6 301:11 

tools 34:5 69:21 192:21 

193:2 

top 228:19 246:16 

381:8 403:2 414:8,8 

topic 113:5 285:2,5 

411:20 

topical 43:22 47:12 

topically 47:17 

topics 3:3,10 4:2,8 5:2 

113:8 

torn 64:16 65:13 192:2 

359:6 

tortillas 115:3 

total 54:22 135:12 

totality 417:22 

totally 191:18 196:14 

touch 181:5 198:10 

touching 283:13 

toxic 272:19 287:1 

293:14 317:10 

toxicity 183:2 185:17 

209:2 211:10,11,19 

275:3,4 277:5 

toxicology 351:6 

toxins 280:2,3 

TR 71:14 72:12 88:4,12 

89:7 111:3 123:20 

140:18 175:8 176:5 

176:21 226:1,11 

258:17 261:7 279:7 

280:1 343:3 345:14 

345:15 350:21 351:13 

351:16 361:13 417:4 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
463 

TR's 88:2 

track 174:19 392:15 

trade 8:20 12:19,20 

18:5 83:13,13 91:21 

144:13 

tradeoff 186:15 

traditional 216:15 

tragacanth 3:21 173:14 

173:16 177:10 

training 9:8 

transcript 286:19,20 

transcripts 425:7 

transition 419:15 428:3 

translates 84:13 

transmission 201:11 

transparency 380:11 

416:19 

transportation 179:3 

travel 427:14 

traveling 284:18 

treadmill 404:4 

treat 403:10 

treated 8:7 179:11 

182:16 342:21 359:17 

359:18,21 

treatment 22:12 27:21 

43:22 69:20 179:1 

180:10,14,20 182:15 

274:22 353:6 

treatments 180:21 

tree 88:9 235:12,14,15 

334:14 354:8 393:8 

trees 157:18 244:13 

tremendous 12:22 

287:1 426:9 427:5 

tremendously 286:22 

trend 13:14 

trials 286:5,10 389:1,8 

392:12 

tribal 193:8 

trickles 69:19 

tricky 337:1 374:3 

tried 69:5 97:10 156:14 

157:5 216:6 247:12 

trigger 18:8 

triggering 185:20 

trip 338:18 

tropical 62:15 118:5,20 

trouble 14:10 

TRs 399:18 

truck 255:8 

trucks 101:20 

true 18:14 59:2 77:18 

322:4 428:11 

truly 156:14 238:10 

254:6 337:1 356:22 

trust 77:12,13 

try 62:21 189:3 230:5 

247:20 253:18 267:22 

305:4 390:21 425:8 

trying 113:3 156:20 

158:12 191:15 228:21 

229:11 239:21 322:1 

389:9 412:16 

TUCKER 2:15 6:15 

14:12,18 15:5,15 16:4 

17:10,15 18:2,9,21 

19:1,8,14,20 76:10 

77:3 78:3 80:16 83:7 

202:17 224:12 285:1 

285:13 297:15,17,22 

298:3 425:19 426:5 

426:12,15,21 427:2 

428:2 

Tucson 328:15,22 

tunnels 284:2 

Turkey 7:16 9:1,14 12:2 

12:5 13:11,12,15 17:7 

turn 143:9 266:9 353:8 

374:1 404:18 

turned 100:7 

Turning 42:14 

twice 298:8 

two 10:21 52:15 61:5 

63:1 69:18 76:13 

78:13 80:3 87:22 98:8 

105:20 123:16 137:1 

147:10 153:16 154:16 

167:7 170:9 183:19 

205:2 215:15 218:15 

222:6 232:21 240:15 

245:20 255:19 278:21 

291:8 296:18,19 

297:3,14 298:14,16 

299:9,15 300:12,16 

300:18 301:18 313:14 

317:4 343:22 354:10 

355:21 371:8,9 

387:20 400:2,4,19 

402:5 415:19 421:19 

425:5 427:13,13 

twofold 259:11 

type 13:2 189:18 

236:22 306:12 317:7 

340:21 368:2 370:18 

405:7 

types 63:12 162:14 

254:13 406:9 

typically 50:8 70:5 91:3 

91:5 95:10 366:3 

380:2 

U

U.S 8:4 9:8 12:13 57:18 

60:15 61:13 64:21 

65:10,16 66:12 102:8 

148:6 164:15 166:7 

237:22 247:10 260:16 

260:17 

U.S.C 200:3 

Ukraine 164:20,20 

ultimate 359:3 

un-made 253:7 

unable 56:18 245:4 

253:13 

unanimous 75:11 85:3 

377:9 407:6 

unanimously 190:4 

209:20 294:17 

unannounced 9:12 

unaware 146:22 147:6 

148:6 419:13 

unbiased 352:16 

unclear 181:18 383:13 

408:13 

underlying 221:5 

underneath 70:7 

279:14 343:11 

underscore 274:1 

underscores 275:8 

343:21 

undersecretary 82:5 

212:15 408:5,22 

understand 32:12 59:6 

80:1 98:6 101:7 

150:12 166:15 189:4 

227:11 230:1 231:20 

237:2 247:21 283:14 

311:22 344:6 347:17 

361:7,11 370:6 

390:19 400:16 407:2 

understanding 12:12 

216:3 218:5 263:21 

309:20 

understood 236:7 

unenthusiastic 232:2 

unforgiving 199:16 

unfortunately 275:21 

300:11 420:21 

Unified 75:3 78:7 

uniform 336:4,13 337:6 

unintended 412:8 

Union 57:1,3 

unique 80:5 95:12 

189:3,18 195:16 

227:10 244:17 379:8 

379:9 

United 1:1 54:9 66:4 

69:10 147:13 

units 18:7 226:8 

universal 30:5 36:6 

387:14 406:18 410:3 

universally 279:9 

University 58:10 

284:16 

unquote 369:3 

unstable 161:8 164:21 

166:9 167:10 171:8,8 

untreated 331:17 

unusual 379:17,18 

upcoming 413:15 

update 5:15 154:3 

284:21 368:22 414:4 

updated 140:18 

updates 418:8 

upregulates 289:11 

uptake 289:8 331:20 

400:7 403:11 

urge 353:1 

urges 75:15 85:7 

usage 121:15 150:5 

211:4,6 213:7 247:11 

274:13 384:3 406:1 

406:20 407:9 

USDA 7:11 48:10 74:9 

74:14 79:14 80:11 

212:14 227:4 230:20 

259:13 267:6 284:15 

428:5 

USDA's 75:12 85:4 

useful 19:16 30:14 

69:14 72:18 95:6 

145:10 201:8,15 

284:4 320:6 376:1 

383:2 

users 126:10 326:22 

uses 45:21 48:22 49:6 

49:10,12 50:5 87:20 

95:8 106:4 107:21 

115:22 133:16 140:5 

180:5 195:16,17 

212:18 243:11 272:6 

273:6 276:8 307:20 

310:12 315:7 403:3 

usually 70:16 139:3 

145:5 174:3 196:15 

333:14 374:14 

utilize 92:3 208:11 

utilizing 331:8 

V

vaccines 3:5 29:14,17 

30:3 31:8,15,21,22 

32:8,12,14 34:5,8,18 

416:6 

valid 61:7 

validated 228:16 

valuable 12:6 157:19 

229:13 

value 227:4 266:10 

274:1 295:3,4 

vapor 69:20 70:3 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
464 

vaporize 69:22 

vaporizer 70:3 72:5 

vaporizing 71:22 

variable 204:13 

variables 82:6 

varied 127:2 

varieties 389:5,17 

392:19 

variety 62:19 160:13 

254:18 388:22 389:8 

389:11,19 392:10 

393:4,5 

various 50:5 55:7 62:19 

63:12 140:19 149:9 

152:16 167:19 173:18 

192:18 239:14 244:2 

244:7,7 245:13 246:4 

289:9 

varroa 52:11,21 53:20 

54:2 57:13 63:2,10,12 

71:7 72:18 318:8 

varying 74:6 

vast 56:1 326:19 

veg 290:3 

vegan 127:11 

vegetable 182:14 

192:19 324:9 329:20 

392:9,11 

vegetables 179:2 

182:16 207:7 301:6 

vegetarian 95:20 

127:12,17 128:15 

260:13 261:2 

veggies 178:21 

verification 202:11 

verified 347:20 

verify 56:19 148:13,20 

verifying 9:9 96:4 

148:22 382:18 

Vernon 286:6 

versed 344:10 354:20 

version 88:3 230:6 

versions 153:10 155:11 

versus 147:16 203:4 

219:13 221:15 222:9 

239:2 306:6,19 

355:14 390:1 

vessels 9:15 

veterinarian 48:22 

veterinarians 48:3 49:5 

50:2 

vetted 192:22 

viable 336:11 

Vice 1:13 21:7 25:3 

27:2 28:3 29:5,19 

31:5 34:1,12 35:10 

36:3 37:9 40:6 42:2 

43:6 45:11 46:17 48:7 

49:15 50:7 51:4 53:12 

56:6,9,13,22 57:4 

62:10 65:22 67:12 

68:9 75:21 77:10 

83:20 85:18 89:20 

93:8 94:5 101:6 

103:17 105:8 107:9 

109:9 112:2 114:9 

115:16 116:2,13 

117:15 119:16 122:17 

124:22 128:13,19 

129:17 131:9 132:4 

134:2,15 136:22 

138:2 141:21 419:20 

420:4 422:10,22 

423:1,18 424:13 

view 73:3 240:11 

265:16 307:17 357:11 

359:4 

viewed 180:19 406:3 

vinegar 403:14 

vineyard 310:22 

vineyards 306:22 

virgin 405:1 406:7 

virtually 91:10 141:8 

virtue 149:6 

viscosities 139:7 

viscosity 95:13 152:17 

243:14,15 

visited 82:1 

vital 428:3 

vitamins 36:5 154:16 

voice 88:15 307:16 

428:9 

volume 8:22 9:2 13:10 

vote's 256:4 

voted 48:13 53:13 

65:19 78:21 96:22 

97:5 99:3 112:21 

121:14,17 190:19 

192:3,5,15 193:6,7,14 

194:15 195:3 209:21 

232:14 289:14 291:15 

291:17 293:18 294:9 

294:16 297:16 298:11 

300:13 302:2 303:2 

320:17,18,18 350:12 

votes 5:13 24:8 25:4 

27:4 29:8 35:14 37:14 

43:13 47:3 51:13 

67:22 86:7 90:10 

94:18 104:9 107:10 

109:11 117:19 122:22 

125:6 130:2 132:19 

135:2 138:12 142:10 

152:3 159:18 172:15 

178:8 205:3 206:17 

225:6 233:20 235:1 

241:15 242:18 256:20 

258:1 270:2 271:17 

278:13 281:14 288:8 

296:11 304:8 313:7 

316:9 322:9 323:17 

326:1 330:21 335:14 

340:3 346:22 349:12 

363:7 372:14 373:17 

385:10 386:18 397:17 

399:9 411:6 413:10 

413:11 415:8 419:19 

420:11,13,19 422:13 

422:13,16 423:15 

voting 23:21,22 24:8 

26:10 28:15 29:20 

34:21 36:21 39:19 

42:20 46:9 50:19 

53:16 55:2 65:19 67:5 

72:11 85:14 89:15 

94:1,3 102:1 103:15 

106:17 108:18 113:18 

117:4 122:6 124:13 

129:9 131:19 132:8 

132:14 133:11 134:9 

137:18 141:17 145:6 

151:10 159:3 170:12 

170:13,21 171:21 

177:14 202:20 206:2 

224:5,5 233:5 234:6 

240:21 242:2 250:6 

250:21 256:3,5 257:8 

269:11 271:2 276:22 

277:19 280:21 287:15 

294:6 295:18 303:2 

303:14 307:15 309:6 

312:13 315:16 321:17 

322:20 325:8 330:6 

335:1 339:10 346:7 

348:18 362:14 371:20 

373:3 384:17 386:3 

394:18 397:2 398:15 

399:15 410:13 422:18 

423:17 

vouch 198:15 

W

wait 195:15 

waiting 328:4 407:19 

walked 10:13 63:11 

walls 123:14 

waned 150:4 

wanted 6:22 31:14 

47:20 87:22 112:3 

116:5 137:3 184:14 

194:4 249:4 261:5 

274:9 319:15 328:13 

343:18 373:5 383:20 

398:6 

wanting 96:8 98:17 

282:19 328:11 

wants 115:20 128:20 

156:22 345:17 

warm 339:4 

warming 284:6 

warms 282:7 

warn 62:4 

warned 368:4 

warning 19:15 

warrant 270:13 

warranted 25:20 

wash 99:17 196:3 

293:15 

Washington 284:17,19 

286:5 

wasn't 96:17 111:8 

119:1 146:7,11 

170:13 223:10 226:5 

226:7 229:6,16 230:4 

238:5 240:11 250:7 

276:10 319:2 332:19 

345:14 367:21 384:2 

396:18 

waste 45:1,6 217:18 

218:19,21 219:7 

220:4 221:2,7,13,14 

283:12 286:19 287:1 

wastes 44:4,10 

wastewater 180:21 

215:11 

watching 84:7 

water 133:16 139:4 

152:10,14,18 180:6,7 

180:20 181:1 182:12 

197:13 211:12,16 

212:1,4 215:6 217:10 

217:15,20 218:19 

219:7,11,12,13,21,22 

220:5 221:3,10,21 

222:8 239:2 243:9 

274:22 275:19,20,21 

283:22 284:3 306:22 

331:13,16 332:2 

333:2,9,16 

waterways 132:11 

211:17 275:1 

wax 340:20,21 341:21 

342:2 343:8,11 344:5 

waxes 341:9 

way 10:20 17:2 70:21 

77:15 84:11 86:17 

167:22 181:22 189:6 

196:9 197:22 209:13 

213:6,7 215:6 227:3 

247:9 249:21 250:21 

274:10 276:13 282:7 

298:10 322:9 329:3 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
465 

333:7 343:13 368:19 

382:17 

ways 69:18 111:17 

120:18 186:6 201:2 

275:14 307:19 358:19 

wearing 72:20 

weather 153:17 155:19 

339:4 388:13 

webinar 246:9 251:3 

336:9 380:9 

webinars 9:9 

Wednesday 10:14,22 

11:17 

Wednesday's 7:8 

weed 278:22 281:21 

284:5 

weeds 255:3 282:7 

weeks 387:20 

weigh 81:11 

weighing 62:5 188:10 

weight 139:4 243:10 

welcome 22:2 320:5 

425:20 

Welsch 55:9 

went 61:15 127:20 

132:12 142:22 173:3 

187:3,7 204:20 

230:10 246:9 247:14 

251:6 267:9 309:2 

318:17 364:14 368:15 

428:4,22 

weren't 19:22 

West 293:3 

wettable 306:7,19 

308:22 310:11 311:3 

wetting 160:12 

wheat 101:1 

wheezing 185:11 

white 254:19 255:4 

whitewash 45:5 

who're 341:17 

wholeheartedly 69:4 

83:18 

Wholesale 375:13 

Wholesalers 188:15 

223:12 318:13 

wide 160:10,13 239:18 

310:21 334:14 

widely 87:17,21 91:9 

144:15,20 164:1 

324:15,18 

widely-available 27:22 

wider 183:9 

widespread 60:5 88:17 

133:19 283:11,14 

314:5 

wild 153:22 236:1 237:3 

239:5 244:13 249:15 

250:8 327:5 

willing 228:6 229:3 

284:22 

willingness 81:11 

window 78:6 

wine 105:2,4 133:18 

135:11,16,21 136:11 

136:18 137:2,4,8,8,19 

207:8 307:12 338:15 

wineries 104:19 

winery 104:22 

wines 87:19 

winter 84:7 

Wisconsin 71:21 84:7 

wish 204:6 310:12 

369:22 375:14 

withdraw 420:21 422:2 

withheld 175:19 

withstand 91:17 

wonder 33:13 

wonderful 223:11 

359:20 

wondering 80:10 83:4 

156:18 167:18 194:15 

Woo 426:13 

wood 71:5 

word 15:1 238:16 

360:16 

wording 389:12 

words 217:6 396:6 

work 5:15 6:8 12:7 

14:18 20:14 28:4 

29:21 30:18,20 31:3,6 

31:9,18 32:2,22 33:8 

33:18 34:1 45:3,7 

55:6 63:12 77:5 79:13 

82:18 101:12 112:4 

128:20 136:8 149:11 

156:20 158:15 162:15 

167:18 173:10 189:2 

191:13 197:19 199:19 

200:6,10 201:5 

228:20 237:2 247:14 

285:10,16 305:16 

306:6 327:7,15,19 

328:3,6,13 366:16 

368:22 369:15 392:21 

401:13 413:11,13,15 

414:3,21 415:3,9 

416:6,8,16,20 426:9 

427:6 

workable 202:11,14 

worked 92:10 97:1 

333:4 414:12 

worker 291:2 308:6,7 

311:7 337:7 

workers 187:6,8,18,19 

305:22 308:11,21 

309:2 

working 30:20 61:1 

72:21 73:1,10 137:10 

155:9 192:18 199:8 

215:22 216:5 251:4 

259:9 425:22 427:21 

works 65:15 

world 68:10 83:17 

156:21 168:16 260:5 

307:22 

worried 73:1 

worries 196:17 

worry 294:12 

worrying 72:19 187:21 

worthy 279:22 

wouldn't 16:2 62:4 

229:7 230:19 319:3,4 

353:17 388:10 

wow 252:16 

wrap 200:18 240:6 

253:8 

wrapped 196:1 

wrestle 411:22 

wrestled 190:18 

wrinkling 297:8 

write 82:17,17 83:22 

106:2 167:12 422:15 

write- 255:2 

write-up 244:1 

writing 84:5 105:18 

204:1 329:13 387:18 

written 31:4 44:21 

92:20 115:16 170:14 

336:10 337:4 375:21 

380:3 

wrong 274:10 302:8 

wrote 95:16 140:11 

192:13 273:13 282:8 

331:15 342:14 

X

xanthan 3:18 138:17,19 

138:21 139:21 140:3 

140:18 141:14 249:2 

249:8 

Y

Y 18:6 

year 11:19 14:4 19:22 

20:2 92:8 154:15 

166:10 167:3,4 185:6 

195:15 201:1 264:22 

306:5 327:4 334:8 

338:7,8,8 342:20,20 

393:17,19 413:16 

418:11 419:7,17 

year-and-a- 19:5 

years 12:21 22:19 

25:18 72:3 105:21 

153:16 155:16 162:1 

163:4 164:22 166:12 

166:13 167:1 174:6 

192:18 245:15 247:3 

250:18 265:19 268:15 

270:12 310:3 343:6 

376:18 392:20 393:18 

419:6 425:5 427:14 

yeast 375:3 

yeasts 374:14 377:15 

yeses 343:17 

yesterday 6:22 16:21 

86:14 103:6 112:21 

215:9 222:19 285:2 

yield 200:7 

yields 9:10 

Yikes 269:4 

yogurt 144:21,22 

374:22 

yogurts 108:8 144:4 

149:22 

younger 337:16 

Z

zeolite 179:9,10 

zero 270:3,4 271:18,19 

278:14,15 281:15,16 

288:10,11 296:12 

304:9 313:8,9 316:10 

316:11 323:18 326:2 

326:3 330:22 331:1 

335:15,16 340:4,5 

347:1,2 349:13,14 

350:12 356:12 363:8 

372:15,16 373:19,19 

385:11,12 386:19,20 

397:18,19 399:10,11 

411:7,8 

zones 235:15 

0

0 25:5,5 27:5,6 29:9,10 

35:15,16 37:15,16 

40:12,13 43:14,15 

47:4,5 51:14,15 68:3 

86:8 90:11,12 94:19 

94:20 104:11 107:11 

107:12 109:12,13 

114:13,14 117:20,21 

123:1,2 125:7,8 130:3 

130:4 132:20,21 

135:3,4 138:13,14 

142:12 152:5 159:19 

159:19 172:16 178:9 

178:10 206:18,20 

225:7,7 233:21,21 

235:2,3 241:16,16 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
466 

242:19,19 256:21,21 

258:3 

0.05 91:5 

0.4 91:5 

0.5 95:10 139:4 

1

1&4 1:9 

1,200 8:10 15:12 

1.9 12:20 

1:15 266:21 

1:20 266:21 267:9 

10 63:21 68:2 110:7 

296:12 363:8,10 

10:00 86:19 

10:55 142:14,22 

100 135:13 136:6 

166:16 210:5 

104 3:13 

107 3:13 

109 3:14 

11 1:9 258:3 304:9 

323:18 

11:10 142:16,19 143:1 

114 3:14 

118 3:15 

12 172:16 332:13 

120 70:20 

123 3:15 

125 3:16 

130 3:16 

1312-76-1 288:18 

302:18 

133 3:17 

135 3:17 

138 3:18 

14 104:10 142:11 152:4 

288:10 

143 3:18 

15 25:5 27:5 29:9 35:15 

37:15 40:12 41:8 

43:14 47:4 51:14 86:8 

90:11 94:19 107:11 

109:12 114:13 117:20 

123:1 125:7 130:3 

132:20 135:3 138:13 

145:7 159:19 178:9,9 

225:7 233:21 235:3 

241:16 242:19 256:21 

270:3 271:18 278:14 

281:15 313:8 316:10 

326:2 330:22 335:15 

340:4 347:1 349:13 

372:15 373:19 385:11 

386:19 397:18 399:10 

411:7 

152 3:19 

15630-89-4 272:4 

159 3:20 

16 351:10,19 

16-day 62:6 

17 104:22 207:17 347:3 

173 3:21 

178 4:3 

18 38:13 156:1 

1994 74:11 

2

2 192:3 225:15 331:10 

2:15 266:22 267:7,10 

20 12:18 22:19 25:18 

145:7 252:16 265:19 

268:15 270:11 393:17 

20,000 18:7 

200 389:4 

2000s 259:20 

2004 102:9 

2006 74:12 

2010 209:20 

2011 12:17 

2013 74:14 

2014 163:17 291:15 

2015 74:9 92:4 93:5 

123:22 163:16 178:18 

210:4 336:17 

2016 9:3 111:3 140:16 

205:14 260:4 344:21 

365:14 400:11,13 

2017 12:18 25:21 75:1 

163:16 207:17 

2018 1:5,7 5:7 9:4 18:7 

207:18,21 387:3 

406:18 414:5 

2020 3:4,11 4:8 349:16 

2021 413:16 

205 22:8 25:13 

205-605(b) 122:4 

205.600 200:3 

205.601 268:6 304:18 

313:15 372:18 400:11 

205.601(a)(1) 270:9 

205.601(a)(8) 272:3 

205.601(b) 278:22 

281:20 

205.601(c) 279:2 

205.601(e) 302:10 

303:3 316:16 

205.601(i) 303:2 324:1 

205.601(j) 288:16 326:8 

331:6 

205.601(k) 335:21 

205.601(o) 340:13 

205.602 347:9 348:11 

385:15 

205.603 43:21 

205.603(a) 27:11 29:16 

35:22 37:22 40:19 

205.603(b) 47:11 51:21 

205.605 87:8 106:14 

109:16 142:15 

205.605(a) 90:16 95:3 

104:16 107:17 259:4 

383:21 

205.605(b) 114:19 

118:3 123:7 125:13 

130:9 133:4 135:9 

138:18 205:17 207:12 

205.606 143:14 151:5 

234:2 241:20 257:4 

260:22 

205.606(g) 152:10 

205.606(k) 160:2 

205.606(q) 173:15 

207 4:4 

22 3:4 

225 4:4 

235 4:5 

23rd 419:16 

24 156:1 

243 4:5 

258 4:6 

26 1:7 

262 4:6 

268 4:9 

27 3:5 

272 4:9 

278 4:10 

281 4:10 

288 4:11 

29 3:5 

296 4:12 

3

3 172:16 182:19 

3,000 201:1 

3.5 326:13 328:18 329:4 

3:35 349:22 

3:50 364:9 

3:51 364:14 

30 393:17 

300 4:13 208:2 209:22 

210:11,13 216:10 

308066-66.2 143:19 

316 4:14 

323 4:15 

326 4:16 

331 4:17 

335 4:18 

340 4:19 

347 4:20 

35 3:6 

350 5:3 

36 156:1 

365 5:4 

37 3:6 

374 5:5 

387 5:7 

399 5:9 

4

4 3:2 258:2,3 304:9 

323:18 364:10 

4-3 291:15 

4:05 364:15,17 

40 3:7 

402 5:10 

404 5:11 

413 5:13,15 

418 5:17 

424 5:19 

428 5:21 

42922-74-7 52:1 316:19 

43 3:7 

451 351:5 

452 351:6 

459 351:13 

460 351:13 

47 3:8 

49 273:10 

5

5 68:1,3 229:5 296:12 

363:8 364:18 

5,000 229:3 

5:00 413:4 

5:16 424:19 

5:20 428:22 

50 348:8 389:4 

500 14:22 15:12 17:4 

5033-1 88:8 

5034-1 366:14 

51 3:8 

53 3:9 

55 267:1 

57 12:20 

58064-47-4 52:1 316:19 

6

6 206:18 333:15 

60 389:6 

601 342:11 

602 377:10 

603 22:9 25:14 

605(b) 176:15 180:13 

606 147:18 163:13,18 

163:19 165:13,14 

166:14 167:1 171:12 

176:14 226:10 227:12 

229:13 232:17 248:8 

250:12,16,20 252:3 

252:11 379:2 

606(j) 154:12 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
467 

607-608 350:21 

64742-42-3 340:15 

667 12:18 

7

700 8:12 17:6 

71010-52-1 95:4 

72 12:19 

7782-99-2 331:7 

8

8 110:6 

8:30 1:10 

8:35 6:2,4 

80,000 342:20 

8002-74-2 340:16 

80090-03-08 340:15 

825 261:6 

85 56:17 

87 3:11 

89 12:20 

9

9 68:1 206:18,20 

9-7 291:17 

90 3:12 

900 200:22 

9000-65-1 173:16 

95 3:12 8:22 9:4 

99 331:8 

Neal R. Gross and Co., Inc. 

(202) 234-4433 Washington DC www.nealrgross.com 
 

468

C E R T I F I C A T E 

This is to certify that the foregoing transcript 

In the matter of: National Organic Standards Board

Fall 2018 Meeting

Before: USDA

Date: 10-26-18

Place: St. Paul, MN

was duly recorded and accurately transcribed under 

my direction; further, that said transcript is a 

true and accurate record of the proceedings. 

-----------------------

Court Reporter 

NEAL R. GROSS 

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com