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 UNITED STATES DEPARTMENT OF AGRICULTURE

 NATIONAL ORGANIC PROGRAM

 NATIONAL ORGANIC STANDARDS BOARD (NOSB)

 FALL 2023 ORAL COMMENT WEBINARS

 Tuesday,

 October 17, 2023, 12:00 p.m., EST

 Held via Zoom for Government Webinar 
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2

 National Organic Standards Board (NOSB) Members

 Nate Powell-Palm, NOSB Chair

 Mindee Jeffery, NOSB Vice Chair

 Amy Bruch, NOSB Secretary

 Brian Caldwell

 Jerry D'Amore

 Carolyn Dimitri

 Kim Huseman

 Allison Johnson

 Kyla Smith

 Nate Lewis

 Dilip Nandwani

 Logan Petrey

 Franklin Quarcoo

 Wood Turner

 Javier Zamora (absent) 
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3

 USDA/National Organic Program staff

 Michelle Arsenault, Advisory Committee Specialist

Erin Healy, Division Director of Standards

 Jared Clark, National List Manager, Standards

 Andrea Holm, Agricultural Marketing Specialist, Standards 

Johanna Mirenda, Agricultural Marketing Specialist,

 Standards

 Heather Kumar, NOSB Technical Support Staff

 Esu Obu, NOSB Technical Support Staff 
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 P R O C E E D I N G S

 (Time: 12:00 p.m.) 

MS. ARSENAULT: All right, I'm going to start the

 recording. 

All right, welcome everybody to the first day of the

 National Organic Standards Board Comment Webinars. I think

 everyone is in from the waiting room. I have about 61

 participants on the line. I imagine that number will increase

 in a bit. 

So, we're going to start off with a little

 housekeeping, and then I'm going to turn the mic over to Erin

 Healy, who's going to actually convene the meeting. 

And on the screen for those of you who are only on

 the phone with us, I'll read what's on the screen and for --

for those of you who are in the Zoom meeting, you can read

 along with me or see the slide projected on the screen. 

You're going to be on -- attendees will be in muted

 mode and unable to unmute themselves. For those of you who

 were with us for the last couple of meetings, we had some Zoom

 bombers, so now we have to keep everyone muted I'm afraid. The

 chat is enabled, so in the center of the Zoom taskbar --

 wherever yours is floating on your screen -- you can chat with

 each other or relay technical difficulties to NOP. Chats

 aren't part of the public record and are not a public comment;

 we won't be answering questions. The Board won't be answering 
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5

 questions in the chat. Closed Captioning is available in Zoom

 by clicking the "Live Transcript" button or sometimes it says

 "Close Caption" and "CC." You can adjust it to be on or off,

 and you can change the font size in it and so you can customize

 your personal view.

 You don't need to use the raise -- actually, please

 do not use the "Raise Hand" feature; all commenters registered

 ahead of time and the Chair of the Board will call on people on

 the order of the -- in the order of the schedule.

 You can customize your own Zoom view. You can

 rearrange what you see on your personal screen by going to the

 upper right corner and toggling between "Gallery View" and

 "Speaker View."

 Also, when we share slides, if you go to the View

 Screen and find "Exit Full Screen" when we share the -- the

 slide it will take over your screen, so if you Exit Full Screen

 it will minimize it and you can see other things that are on

 your -- your computer. And no worries; changing the view that

 you have on your screen doesn't affect anyone else's screen, so

 everyone won't see what you're seeing.

 If you're having technical problems, you can visit

 the zoomhelpdesk@support.zoom.ux. There's a number you can

 call. You can chat. You can e-mail them.

 The webinar is being recorded and we'll have a 

 transcript that will be posted on the NOP website as soon as 
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6

 it's available after the in-person meeting. 

All right, so next slide please, for speakers. There

 we go. Please make sure that your name is displayed in your

 video tile so we can locate you when it's your turn to speak.

 The NOP will send you a message; you'll probably get a pop up

 on screen that says, "The host has asked you to unmute

 yourself," then you will be able to turn your mic and camera on

 and off. You can also -- so, you can rename yourself by

 looking for -- either doing it in your Zoom tile in the upper

 right, or if you find yourself in the Participant List, there's

 a menu next to your name, you should be able to rename yourself

 from there. 

If you're scheduled to speak, and we can't find you

 in the list of participants, we may send you a note in the chat

 box. Sometimes if you're on the phone we can't see your name

 associated with your phone number, so we may be hunting for

 people along the way so just keep an eye on the chat box. 

When -- we will ask you to unmute yourself when

 you're called, so please unmute yourself. Turn your camera on

 if you want, that's optional, you don't have to be on camera.

 Both the mic and the camera, for folks who are new to Zoom, are

 in the lower left of the Zoom taskbar, and also next to your

 name in the Participant List. So, if you're on the phone only,

 and you don't have a mute button on your phone, you can use *6 

 to toggle between mute and unmute. 
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When you come to the mic -- so, the Board Chair will

 call your name. When you come to the mic we ask you state your

 name and affiliation for the record at the start of your

 comment. We have a transcriptionist on the line with us and

 she'll be recording that information. Each commenter will have

 three minutes to speak. We'll use a timer that will sound when

 your time is up. When you hear the beep, please finish your

 sentence and the timer will eventually be showing in my Zoom

 tile, and we're going to pin that on the screen so everybody

 will be able to see the -- the same -- the timer all the time. 

At the end of their comments -- at the end of your

 comment, the NOSB Chair is going to invite the NOSB members to

 ask questions, so don't immediately mute yourselves and turn

 your mic off; we may have questions afterward. 

Now, I'm going to turn the mic over to Erin Healy,

 who is the Director of the Standards Division at the National

 Organic Program, to call the meeting to order. 

Erin. 

MS. HEALY: Thank you, Michelle. 

Hello everybody. I am Erin Healy, the Standards

 Division Director in the National Organic Program. Welcome to

 all of our National Organic Standards board members and our

 audience. 

We continue to be grateful for our ability to engage 

 in these virtual sessions, which allow people to participate 
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 from wherever they are. To our public commenters, thank you

 again for engaging in this process to shape policy. I also

 thank our audience; you continue to be an important part of

 this public meeting process. 

This webinar opens two days of public webinars this

 week, and then we will reconvene next week in person in

 Providence, Rhode Island. We do plan to live stream that

 meeting, as we did last spring. Meeting access information for

 all meeting segments is posted on the NOSB web page on the USDA

 website. And transcripts for all segments will be posted once

 completed. 

This meeting, like other meetings of the National

 Organic Standards Board, will be run based on the Federal

 Advisory Committee Act, and the Board's policy and Procedures

 Manual. I will act as the Designated Federal Officer for these

 webinar segments. Nate Powell-Palm, our Board Chair, will take

 the helm for this session. 

We remind everyone that this is an open and

 transparent process, so mutual respect is critical. We ask you

 in advance to avoid personal attacks and disparagement. This

 extends also to any chats that you share. If you disagree with

 the speaker's position, please be sure to provide them the same

 respect and grace that you would want for yourself. 

And to close, I thank the members of the National 

 Organics Program with us today, so that includes Michelle 
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 Arsenault, Jared Clark, Andrea Holm, Joanna Miranda, and our

 two new NOSB technical support staff who will be helping the

 Board, Heather Kumar, and Esu Obu. This is a very impressive

 team. I am honored to work with them every day, and let's give

 them a big round of Zoom applause.

 (Zoom applause.)

 MS. HEALY: Thank you. I will now hand the mic back

 to Michelle, who will do a roll call of NOSB members and staff.

 MS. ARSENAULT: Thanks Erin.

 All right, NOSB members; Nate Powell-Palm.

 CHAIR POWELL-PALM: Present. Good morning.

 MS. ARSENAULT: Thank you. And for overcoming your

 computer challenges today.

 Mindee --

 CHAIR POWELL-PALM: That was the other Nate.

 MS. ARSENAULT: Mindee Jeffrey.

 VICE CHAIR JEFFREY: Good morning. Thank you

 everyone.

 MS. ARSENAULT: Amy Bruch.

 SECRETARY BRUCH: Good morning from the Midwest.

 MS. ARSENAULT: Good morning, Amy.

 Brian Caldwell.

 BD. MEM. CALDWELL: Glad to see everybody. Here.

 MS. ARSENAULT: Hi, Brian. Welcome.

 Jerry D'Amore. 
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BD. MEM. D'AMORE: Good morning from California. 

MS. ARSENAULT: Good morning, Jerry. 

Carolyn Dimitri. 

BD. MEM. DIMITRI: Morning everyone. I mean, good

 afternoon everyone. Excuse me; I forgot where I was. 

MS. ARSENAULT: Good afternoon, Carolyn. 

Kim Huseman. 

BD. MEM. HUSEMAN: Good morning. 

MS. ARSENAULT: Good morning. 

Allison Johnson. 

BD. MEM. JOHNSON: Here. Good morning. 

MS. ARSENAULT: Good morning, Allison. 

Kyla Smith. 

BD. MEM. SMITH: Here. Hello, everybody. 

MS. ARSENAULT: Hi, Kyla. 

Nate Lewis. 

BD. MEM. LEWIS: (No audible response.) 

MS. ARSENAULT: Uh oh, Nate, can you not unmute

 yourself? I will ask you to unmute yourself. Apologies for

 that. 

BD. MEM. LEWIS: Present. 

MS. ARSENAULT: Thank you, Nate. 

Dilip Nandwani. 

BD. MEM. NANDWANI: Good morning. Present. 

MS. ARSENAULT: Good morning. 
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 Logan Petrey. Lincoln --

 BD. MEM. PETREY: Good morning.

 MS. ARSENAULT: Good morning.

 Franklin Quarcoo.

 BD. MEM. QUARCOO: Morning.

 MS. ARSENAULT: Good morning

 Wood Turner.

 BD. MEM. TURNER: (No audible response.)

 MS. ARSENAULT: Oh, Wood can't unmute, either.

 Apologies. Let's see, this is why we're doing roll call this

 way, to mic test. I don't see you. All right.

 BD. MEM. TURNER: I'm here.

 MS. ARSENAULT: There we go. Thank you, Wood.

 And Javier Zamora.

 BD. MEM. ZAMORA: (No response.)

 MS. ARSENAULT: All right, I note that Javier is

 absent.

 All right, and Erin already introduced the NOP staff

 that are on the call for support. For speakers who have

 PowerPoint presentations, Jared Clark and Andrea Holm are going

 to be projecting slides, just so you know.

 And now I'm going to hand off the mic to Nate Powell-

 Palm, the Chair of the NOSB to start the webinar.

 CHAIR POWELL-PALM: Thank you, Michelle. 

 Gosh Dang, it is good to see all your faces. And to 
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 see -- I'm really looking forward to seeing you next week in

 person.

 We're in a special time in organics. Last week, we

 in Montana, had the immense privilege of hosting Under

 Secretary Jenny Lester Moffett to talk about TOPP and all of

 the incredible investments that are going on into our space

 right now, and so I hope we can both celebrate and work on the

 issues at hand today, and into next week, and I'm looking

 forward to hearing from everyone.

 A few reminders that there is a policy in the Policy

 and Procedures Manual about public comments, and I think we

 have a slide for that. all speakers who will be recognized

 signed up during the registration period. Persons must give

 their names and affiliations for the record at the beginning of

 their public comment. Proxy speakers are not permitted.

 Individuals providing public comment shall refrain from making

 any personal attacks or remarks that might malign the character

 of any individual. Members of the public are asked to define

 clearly and succinctly the issues they wish to present before

 the board. This will give NOSB members a comprehensible idea

 of the speaker's concerns. I will call on speakers in the

 order of the spool and will announce the next person or two so

 that they can prepare. Please remember to state your name and

 affiliation one more time, and then we'll start the timer. 

 Board members will indicate to me if they have any 
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 questions, and I will call on them. Only NOSB members are

 allowed to ask questions. 

All right, so our first speaker today is going to be

 Alan Lewis --

MS. ARSENAULT: Excuse me. 

CHAIR POWELL-PALM: -- followed by Mark Kastel. Oh

 yes. 

MS. ARSENAULT: Can I interrupt you? Can I practice

 the speaker timer, just to make --

CHAIR POWELL-PALM: Please do. 

MS. ARSENAULT: -- everyone can hear it? All right 

CHAIR POWELL-PALM: Yes. 

MS. ARSENAULT: Everyone can see it in my tile, I

 think. 

CHAIR POWELL-PALM: Two. One.

 (Timer test beep) 

MS. ARSENAULT: Was it loud enough? Is it? Zoom

 filters the noises in the background; I just want to make sure

 it's okay. 

CHAIR POWELL-PALM: I think it was good, yeah. 

MS. ARSENAULT: Good. Excellent. Thank you 

CHAIR POWELL-PALM: Thank you. 

All right. So first up, Alan Lewis, followed by Mark

 Kastel, Elizabeth Bell, and then John Foster. 

Alan, the floor is yours. 
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MS. ARSENAULT: Let's see if we can get --

MR. LEWIS: There we go. 

MS. ARSENAULT: Okay. 

MR. LEWIS: Thank you. Alan Lewis, I'm a member and

 active board member of a dozen organic and agricultural

 organizations, and as a sideline I work at Natural Grocers.

 And Chairman Powell-Palm, I'm much more comfortable going at

 the end of two days of speakers, but I ended up at the front,

 so let's start with an invocation: an invocation for the

 planet. 

The families whose lives we touch, the workers,

 animals, insects, and critters of the soil, and may we all

 remember as we advocate for our own needs and wishes and

 desires that we maintain our sacred obligations to uphold the

 rights and needs of others, which is a fancy way of saying what

 you all just said. 

I, in my travels, especially in the last few years,

 hear the -- the random comment "I don't need the USDA CO." "I

 don't need USDA organic. Organic doesn't matter." And I could

 push back against that, but as we start the day that has

 changed too "we," "We don't need the seal. We don't need the

 NOP." And please take this as a friendly challenge, but when

 core people across the world are not recognizing us as leaders

 in agriculture, leaders in social economic and personal 

 development, and in the climate change I think we have a deeper 
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 problem than maybe we want to admit, when you step outside the

 borders, and often inside our borders, the seal represents

 plantation agriculture. It stands for displacement of soil,

 communities' ecosystems across Mexico, Peru, and a good part of

 the rest of South America. That's a pretty big challenge for

 all of us and so as part of my invocation let's remember that

 we risk looking like Wiley Coyote; we've removed the soil under

 our feet, we've jumped off the cliff chasing this roadrunner of

 economic growth, and we have this oops look on our face and

 we're just trying to get back to soil-based organic and organic

 that's not just input oriented, and recognizes the people that

 agriculture touches 

I'm going to leave some extra time there, and I just

 want to thank everybody, the board members who put so much work

 into it. I know it's a slog. It takes focus. And really I

 want you to feel appreciated. Same to the USDA staff there. 

And Michelle doesn't get a thank you because she

 makes it all look so easy. I -- I think she does all of her

 work in a few hours a day and then goes home, which is a way to

 give you a big thanks. 

So, I look forward to hearing my colleagues, and I

 turn it back to you, Chairman Powell-Palm. 

CHAIR POWELL-PALM: Thank you so much for your

 comments. 

Questions for Alan Lewis? Mindee, please go ahead. 
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 VICE CHAIR JEFFREY: Thanks Alan for your

 perspective.

 I'm wondering if in your conversations, you think

 people recognize us as policy leaders and unique in America's

 democracy and regulatory framework.

 MR. LEWIS: Well, we'd have to define "we," and I

 don't want to test people's patience but no; we are driven by

 large corporate global interests and you -- we will hear the

 next two days calls for gene editing, calls for this, that, and

 the other that really benefit large plantation agriculture.

 So, if that's someone's frame of reference, and that's good for

 them, then yes, we're leaders. If you're Via Campesina, if

 you're the International Federation of Organic and Agriculture

 Movements, no. That's why there are so many groups rebuilding

 an ethic of organic that's not just input oriented.

 So, in the small places where we have an impact by

 somehow maintaining the National List, perhaps. For everything

 else that is out of scope, absolutely not.

 CHAIR POWELL-PALM: I have a quick question for you,

 Mr. Lewis.

 MR. LEWIS: Oh, no.

 CHAIR POWELL-PALM: And it's not -- I promise it's --

it's a little bit of a call out, but I was just Googling around

 the other day, and I saw someone say that Natural Grocers has a

 private label regenerative egg now, and so I went to look up 
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 this egg. And I was just so elated that it said, "Certified

 Organic Regenerative," and that you folks put as the foundation

 of regenerative that it's going to be certified organic. And I

 really can't -- can't thank you enough for that. I think when

 I called out how do we grow the organic market a few meetings

 ago, that's action right there.

 MR. LEWIS: We have built our entire business on the

 organic seal, which is why when it's threatened we feel it so

 severely, so everything we do, we try to start with the seal.

 When talk about regenerative, so people know, that's

 because we have a research team, and a video team, and a

 standards team that gets their boots on and goes out in the

 dirt every year and checks out what these practices really are.

 If they are actually regenerative, and we have that standard in

 place, that's great. But there are a lot of things about

 organic that really, really matter.

 CHAIR POWELL-PALM: Thank you. Thank you again. I

 would just throw -- if you could follow up possibly with the

 social groups that you think organic should be aligning with

 most closely to move the needle on this social production

 component. Obviously, is not built into our standards but I

 would be curious as to what alignments and what coalitions we

 can build with other groups that you think would be most

 effective towards moving the needle in the direction you see as

 the future of organic. Thank you. 
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 MR. LEWIS: Happy to do that. Thank you.

 CHAIR POWELL-PALM: All right. Next up -- oh, and

 thank you for that invocation. That was just a lovely way to

 start the day.

 Next up, we have Mark Kastel, followed by Elizabeth

 Bell, and then John Foster.

 Mark, please go ahead.

 MR. KASTEL: Thank you, Mr. Chair.

 My name is Mark Kastel. I'm the executive director

 of OrganicEye. We are best known as an organic industry

 watchdog. And I think to summarize Alan Lewis' talk, I'd say

 what are we doing in this basket and where are we going? The

 cash registers are ringing, though we might be on the road to

 hell.

 We built this movement, which has morphed into an

 industry around better food, a connection between -- loving

 connection between consumers and farmers, environmental

 stewardship, and economic justice for farmers. It's time for

 the NOSB to take back the regulatory reins from this betrayal

 that we're experiencing. We're seeing large scale fraud.

 We're seeing markets flooded with imports, livestock factories,

 CAFOs, squeezing out family scale farmers. We're losing family

 farmers. We're losing organic farmers and replacing them with

 industrial investor-owned operations. Loss of confidence that

 Alan talked about. Competing labels. These are really bad 
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 signs of bad times for the true working definition of organics,

 which has been eroded.

 Soon, you'll hear a few speakers from now from one of

 the OrganicEye farmers -- farmer members, Bruce Kaser, on a

 lawsuit that was filed today challenging uninspected illegal

 imports that have the USDA blessing and label on them. We've

 had damaged markets from this. We basically have U.S.

 commodities, which we're able to compete, we're -- we're able

 to produce in this country, we're not talking strictly bananas

 or chocolate, and our farmers can't compete. They can't

 survive in the marketplace.

 CAFOs with 10 or 20 cows, effectively stocking

 levels, in the desert when the last time we -- we interviewed

 or polled family farmers the average was one cow per acre;

 that's a bad joke.

 We have hogs, chickens; none of them are outdoors.

 The current rules require their ability to exhibit their

 natural instinctive behaviors. The current law -- forget about

 this new rule making a measly two-square feet for chicken. The

 current laws are being violated.

 Carcinogens in organic food, yes. Illegally there.

 If you want to know which ones, you can ask me a question.

 This is really undercutting consumer confidence.

 And Material Review Organizations, with no legal 

 oversight by the USDA; some portraying themselves as being 
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 nonprofit, multimillion-dollar organizations that get $1,000 or

 less per year of contributions, where the vast preponderance of

 funding comes from the corporate -- corporate entities they

 serve. So, we ask you to step back up, look at the policy and

 procedure manual, take back the ability to control your own

 agenda, and work plan. Thank you very much.

 CHAIR POWELL-PALM: Thank you, Mark.

 Logan, please go ahead.

 BD. MEM. PETREY: Hey, thank you, Mark. Yeah, so I

 got a question about the imports. Possibly a lot of them come

 across the border, so in the southeast here we actually do

 compete with that production window a lot.

 Curious about when you're saying they can undercut

 the farmer, because that happens a lot, we -- we see that a lot

 in labor costs because labor costs are so cheap in other

 countries, and organics can be such a high-labor input when it

 comes to veg, especially like weeding and hand-harvesting,

 things like that. Do you think it is tailored towards, you

 know, the -- the labor side? Or maybe the -- the fraudulent

 side, that they're actually using conventional product, you

 know, selling it organic? What -- what area were -- were you

 trying to imply in that, if that is one of the implications?

 MR. KASTEL: I would say the answer to that is yes,

 in -- in both regards and more. 

 So, we've got crops -- certain commodity crops like 
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 soybeans where the vast majority of what organic livestock in

 this country consume are produced offshore. We've had

 tremendous fraud, but we're the largest producer in the world

 of many of these crops. We're highly mechanized, very

 efficient, there's no reason we can't compete, excepting the

 structure is stacked against us.

 A number of years ago, when Dean Foods owned a

 leading soymilk manufacturer, they claimed there was a

 shortage. that's why they went to China for soybeans. At the

 same time, U.S. organic farmer cooperatives testified that they

 were dumped by Dean Foods for price. So, labor's a factor.

 Monetary exchange and fraud is a factor.

 And what Bruce Kaser will be talking about is group

 certification, which started out as a good idea with indigenous

 communities and cooperatives supervising, helping supervise

 their own small landholders. But it's (audio distortion)

 morphed a different system, so now we have corporate

 agribusinesses supervising their own suppliers as the quote

 "group," and so we basically have uninspected products coming

 into the country, some of which we can produce ourselves here.

 Some of us, we can't, and we need to, as organic consumers,

 depend on the integrity of that process. And I'll let Bruce

 speak more to that point.

 CHAIR POWELL-PALM: Amy, please go ahead.

 SECRETARY BRUCH: Sure. Thanks, Nate. 
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 Thanks, Mark. And thanks for extending invites to

 farmers to participate also in this process. We're looking

 forward to hearing from Bruce later on today or tomorrow -- or

 on Thursday when he's on the schedule.

 I wanted to, kind of, I guess in conjunction with

 Logan's question, fraud -- and dealing with fraud is really

 important to our board and the integrity of our seal. You had

 had a written comment in response to our residue testing and a

 global supply chain. It was just -- you mentioned that you had

 in the past created a petition for rulemaking in regards to

 this topic. I was just wondering if -- if you'd be willing to

 send that our way? I wasn't able to find it when I just did a

 quick Google search, it might be on the Internet, but if you

 could just send that to us for a review? I think, you know, we

 have that as a topic -- as a discussion document, so any

 supporting information that's been generated would be helpful

 to -- to review. Thank you.

 MR. KASTEL: Well, I'd be happy to. And let me just,

 in two sentences, summarize. Some of these legal petitions --

this is the lack of control you folks have of your agenda and

 work -- they go to the NOP and then they go into a black hole.

 So, one shipment of soy or corn from offshore bulk

 freighter, according to some of our members who run these

 organic cooperatives in the U.S., one shipment equals the 

 annual production of 40 or 50 average size U.S. grain farms. 
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 The cost to test every single shipment is inconsequential

 compared to the dollars that that is worth. So, if you compare

 the cost to certify 40 or 50 U.S. farms to the testing of these

 imports, we could be nipping this in the bud. 

The other petition that we offered was an alternative

 view of certification. Instead of inspecting every year honest

 farmers like Bruce, who you're going to hear just in a few

 minutes, by sometimes people fresh out of school that have gone

 through a minimal training and hired by a certify [sic] or

 sometimes a contractor, instead of doing that, taking a look at

 comparative risk and auditing the best farmers once every five

 years, but with people who have an experience in production

 agriculture forensic accounting, because the paperwork is just

 as important or more important than viewing the fields, et

 cetera. And -- and then taking the savings that we have from

 not doing this busy work every single year, and this would take

 legislative intervention to -- to facilitate, but taking that

 savings and really ramping up the random testing and the

 unannounced inspections, and -- because right now, most

 inspections, whether you have 20,000 cows on a dairy or you're

 Mom and Pop family farm, they have them my appointment, and so

 everybody knows when to expect the inspector. And -- and that

 inspector many times going toe-to-toe with the professional

 agriculturalist that if they really want to figure out how to

 do creative writing with the paperwork or show them the right 
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 scenes, it's all too easy to deceive people with lower levels

 of experience.

 So, I thank you for the question, and I will make

 sure the -- that we send that material to -- for distribution

 to the NOSB.

 SECRETARY BRUCH: Thank you, Mark.

 CHAIR POWELL-PALM: Keep things moving along, Kim,

 please go ahead.

 BD. MEM. HUSEMAN: Sure. I'll be quick here.

 Thank you, Mark, for all of your comments. You

 mentioned organic pork production. In just a very quick way,

 can you give us what you think would help to promote the

 organic pork industry here in the U.S.?

 MR. KASTEL: Well, one is obviously the integrity of

 the label, and I'm going to -- I'm going to throw pork and --

and poultry in both broilers and -- and layers because I've

 visited probably more of these industrial scale operations than

 probably anyone.

 BD. MEM. HUSEMAN: Okay, yeah, I was just asking

 about pork. If we could just kind of look at that operation

 from a growth perspective, as it is probably the most limited

 in the -- the livestock industry.

 MR. KASTEL: Sure. It --

 BD. MEM. HUSEMAN: Yeah, what would be your thoughts 

 on that? 
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 MR. KASTEL: Besides sausage, I don't see a lot of

 pork out there. And but there's an old axiom in marketing, and

 that's, you know, it's got to be different or better. And --

and if you can't differentiate your product, you're going to

 have a problem, and so we've applied the industrial model to

 organic livestock production.

 Quite frankly, if you go out to somebody who truly

 raises pastured pork, whether it's certified organic or not, --

and I don't eat non-organic livestock because the majority of

 what they consume is not grass, unless it's 100 percent grass

 finished beef or the rare 100 percent grass dairy -- it's

 great. And so, if it's not -- they could say pastured pork but

 if it's not certified organic it really isn't. So, but if --

 depending on the breeds of the hog, and the production model,

 there is a tremendous difference in the flavor, the taste, the

 quality, the nutrition in that product. And so, if we can't

 markedly distinguish organic, whether it's the root vegetables

 that taste like cardboard that were produced year round and

 California or Mexico, or that were produced by Elliot Coleman,

 who isn't certified, in Maine where his carrots and the ones I

 get from Harmony Valley here in Burning County, Western

 Wisconsin, whose certified organic, tastes like candy,

 especially after the first frost they just get better; if we

 can't differentiate our product and we charge more for it then

 we really are back to that input dynamic that Alan was talking 
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 about that organics just is what we avoid rather than coming up

 with a ecologically-based humane-based system that produces a

 better quality food that people can taste. And pork is where

 you can really, really taste the difference in both the breed

 selection and the outdoors and the diverse diet that they

 consume.

 BD. MEM. HUSEMAN: Thank you, Mark.

 CHAIR POWELL-PALM: Thank you, Mark.

 Next up, we have Elizabeth Bell, followed by John

 Foster, and then Mike Crotser.

 Elizabeth, the floor is yours.

 MS. BELL: Thank you, Nate. Can everyone hear me

 okay?

 CHAIR POWELL-PALM: Um-hum.

 MS. BELL: Great. Good morning or afternoon. I'm

 Liz Bell, and I'm here today representing CROPP

 Cooperative/Organic Valley. Thank you to the NOP and the board

 for giving me this opportunity today to provide comments on

 behalf of our co-option.

 I previously worked in organic certification and now

 in my role at OV, I work to consult our 1600 farmers and bridge

 the gaps between them and the 30 different certifiers we work

 with. I'd like to use this time today to highlight our

 comments on two CACS agenda items. 

 First off, CROPP Co-Op appreciates the proposal on 
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 consistent location identification and the intent in helping to

 deter fraud. A couple concerns we want to address include who

 will be responsible for providing this geolocation information

 and how this sensitive data will be stored. 

If farmers are obligated to provide these coordinates

 it could pose barriers for the plain community, which consists

 of over half our membership. We support certifiers or

 inspectors collecting such information themselves.

 Additionally, we are cautious of the privacy of this location

 data since it is often confidential, and farmers do not want to

 share it publicly. 

We support certifiers maintaining this information in

 the same manner as other confidential certification files. We

 support the use of geolocation information for certifiers to

 consider as a voluntary option, but not a mandatory

 requirement. In the case this proposal passes and moves

 forward in the regulatory process, we'd like to see further

 guidance by the NOP for certifiers regarding best practices in

 establishing collection methods, format, and privacy of this

 information. 

Regarding the discussion document on improving

 support for organic transition, we urge the board to

 communicate a ringing endorsement of the efforts of the

 greatest federal investment in organics history. CROPP Co-Op 

 would like to see more development of direction on organic 
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 transition from a consumer demand perspective. We believe that

 OMDG is the highest priority of the Organic Transition

 Initiative.

 Organic Valley is a marketing co-op. Our marketing

 department works closely with our customers and consumers for

 feedback, which in turn helps to make decisions for our

 business and down the supply chain for our farmers. We

 recognize that farmers need guidance driven by market demand,

 whether they're transitioning or already certified. The

 organic industry cannot be successful in this initiative

 without knowing what the marketplace demands and educating the

 public as to what organic really is. Demand side growth

 develops farmer focused opportunities.

 We at -- we at CROPP Cooperative offer to have more

 of a seat at the OTI table to provide our insights on this. We

 encourage the OSG to focus on marketplace demand and consumer

 education in order to successfully foster the growth of the

 organic industry.

 For over 30 years we've assisted thousands of farmers

 with their transition to organic. Buying organic feed at

 extremely inflated prices and not getting paid organic premium

 for at least a year can deter any farmer from making the

 decision to go organic at all. As a way to lessen this burden,

 Organic Valley offers a 12-month transition incentive premium

 to dairy farmers that are in their last year of transition. 
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 Our mission is to save as -- save as many small family farmers

 as possible. 

Thank you again for allowing me this opportunity to

 speak today. I especially look forward to providing comments

 in person in Milwaukee in April. I'm happy to answer any

 questions now. Thank you, 

CHAIR POWELL-PALM: Thank you, Liz. Amy has a

 question for you. 

SECRETARY BRUCH: Liz, hey, thanks for your time

 today. Thanks for all the written comments, too. I appreciate

 them and -- and reviewed them. I did have a question about

 your written comments, and this was on the residue testing in a

 global supply chain. 

There was just a comment in there that said there --

that your organization would have concerns if there would be an

 increase the testing across the global supply chain, and I just

 wanted you to unpackage that for me because, you know, we've

 heard through the written comments, not yet on the oral, you

 know, people were really pushing for increased number of

 testing through our imports, and then I saw your comment. I

 just wanted to understand that a Little better. 

MS. BELL: Yeah, Amy, thanks for your question. In

 two slots, Mike Crotser will be talking specifically on residue

 testing, so I'm gonna push this along to him, if that's okay

 for you to ask that to him? He's the -- he's the pro on that. 
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SECRETARY BRUCH: Okay, no problem. That sounds 

 good. I saw he was going to talk about handling, so I saved it

 for you. 

MS. BELL: Yeah. 

SECRETARY BRUCH: Yeah. 

MS. BELL: oh, yeah. 

SECRETARY BRUCH: I'll -- he'll know it's coming

 then. Okay, thank you. 

CHAIR POWELL-PALM: Allison, please go ahead. 

BD. MEM. JOHNSON: Thanks so much, Elizabeth. We

 really appreciate everything Organic Valley has been doing on

 organic transition and -- and helping keep our organic dairy

 sector up and rolling. 

I wonder if you could say a little bit more about two

 things. You mentioned operating from a consumer demand

 perspective, and I'm curious if you could speak to specific

 products or, you know, product areas where you think there is a

 lot of consumer demand that isn't yet being addressed

 adequately through the Organic Transition Initiative? 

And then I'm Excited to hear about the -- the 12-

 month kind of transition funding that you provide, and I'm

 curious if you have thoughts on how that could be kind of

 institutionalized or what our USDA and government could be

 doing to make that available to producers beyond Organic Valley 

 suppliers? 
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 MS. BELL: Um-hum, yeah. Thanks, Allison. In terms 

 of specifics on demand, I would need to sit down with our

 group. We can certainly follow up with -- with you all and

 touch base a little more so with our marketing group.

 I think it's -- I mean, we are part of the -- the

 puzzle so to speak. I think -- I mean, I think we have this --

 a perspective, but I think other industry members have great

 perspectives, as well, so kind of I envision almost like a -- a

 round table of industry, kind of discussing those sorts of

 things and putting together all of their marketing groups for

 something like that. So, I can't really speak on super

 specific things right now, but I think kind of getting the --

 maybe a ball rolling on -- on those discussions would be

 something we would love to see and love to have a seat at the

 table on.

 And then in terms of implementing a 12-month

 incentive kind of institutionalized, I would love to see that.

 Yeah. I don't know the systems in which to implement that on a

 large scale, but we could certainly be in discussions on how we

 do it and offer to provide any sort of insights on that, if

 that is something that would be developed, um-hmm. Yeah.

 BD. MEM. JOHNSON: Thanks, I really appreciate it.

 MS. BELL: Thanks, Allison.

 CHAIR POWELL-PALM: I have two quick questions for 

you, Elizabeth. 
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MS. BELL: Two quick questions, okay. 

CHAIR POWELL-PALM: Very quick. So, the first one

 is, if I heard you right you like the geolocation doc, but want

 to make sure that the caveats are held? 

MS. BELL: Yeah. Just a couple --

CHAIR POWELL-PALM: Okay. 

MS. BELL: -- concerns. Want to -- want to make sure

 that those are clear, and that the NOP can provide some -- some

 sort of best practice guidance's on -- on that for certifiers.

 You know consistency is good. 

CHAIR POWELL-PALM: Definitely. I -- we -- we know

 each other outside of just public comments, and I know you were

 an inspector who dealt with geolocation. 

How hard of a burden was it on you as an inspector,

 do you think, locking in these KMZ files? 

MS. BELL: Um-hum. Um-hum. Not -- it was -- it was

 challenging to some -- to some aspect. But I -- I would say

 the benefit very much outweighed the -- the challenge or the

 cumbersome aspect of it. 

So, Nate is referring to when I was inspecting and

 drawing up Google Earth KMZ files for every -- every field, and

 that was a great practice, I think for -- for us and -- and,

 you know, each certifier I worked for, and making sure that we

 were capturing exact boundaries every year and verifying that

 this is part of the OSV. So great confidential information to 
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 be had as part of the OSV.

 CHAIR POWELL-PALM: Absolutely. And the last one is,

 you mentioned Organic Marketing Development Grant. I know

 that, or I believe I saw that the -- that Organic Valley

 announced the Organic Marketing Act, and I was just wondering

 how much support from other groups have you gotten for this

 work, and kind of for the celebration of value-added on farms?

 Bringing more value to farms through processing capacity?

 MS. BELL: Mmm, that's a good question for Adam.

 CHAIR POWELL-PALM: Okay.

 MS. BELL: He's the --

 CHAIR POWELL-PALM: That's good. I'll follow-up.

 MS. BELL: He's the know-it-all. I'm sorry, I'm just

 pushing questions everywhere, but no, he's -- he's really been

 the master of this, so I'll -- I'll make a note for -- for him

 to follow-up with you, Nate.

 CHAIR POWELL-PALM: All right, I really appreciate

 your comments today. Thank you.

 MS. BELL: Yeah, thank you.

 CHAIR POWELL-PALM: Next up, we have John Foster,

 followed by Mike Crotser and then Bruce Kaser.

 MR. FOSTER: Well, good morning, everybody. Thank --

 thank you for your time. As usual, I look forward to seeing

 you all next week, as well. 

 My name is John Foster. I am with Wolfe & 
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 Associates. We're a consulting firm that specializes in

 organic; pretty much everything in the organic space. And I'm

 going to bring back a -- what's becoming a well-worn comment

 for you, with some new information though.

 Next slide, please.

 So, as usual, you'll recognize, you know, say it with

 me, you'll know -- you'll recognize these general comments

 here, "We believe in, directionally National List should be

 something that's inclusive, supportive, and accommodating for

 as many organic producers globally, as possible." I won't

 spend a Lot of time on it today, but I still believe that a --

 a unified commercial availability registry is really a good

 direction to move in. Even if it takes 10 years to get there,

 I'm going to keep harping on it every chance I get until then.

 But I'd like to focus most of my time on something I

 feel is very hopeful, actually is -- and that is application of

 commercial availability clauses in 605, Handling Materials.

 Next slide, please.

 So, there are many precedents here, building on

 flavors, yeast, collagen gel, and there are a couple others on

 605. The hope would be that this provides additional

 regulatory incentives to drive R&D, and but already R&D has

 provided very novel production methods and brought them to use

 in developing organic ingredients. Many of them flavors. 

 Another advantage is that this LOCA, lack of 
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 commercial availability, documentation is very familiar to ACS

 and handlers, so we're not doing a whole lot of new training on

 process here if -- if this were to go in effect. 

And most important to -- to me, and this is a big

 push for Bill, as well, is increase for demand of organic

 ingredients creates increased opportunity for organic crops,

 and that encourages, Nate, one of your favorite things getting

 more ground in organic production. 

Next slide, please. 

CHAIR POWELL-PALM: Sure. 

MR. FOSTER: So, some recent examples here, and this

 is pretty --this is fairly -- fairly new, as of like than a

 month ago, commercial availability. Annotation is not new on

 flavors, that's been on 605 for a while, but what the last few

 years have shown very clearly is that this drove significant

 innovation in organic flavor development over the last several

 years. 

What is recent is -- is two materials that sound

 horrible, okay, but you're -- if you're drinking red wine or

 you're eating cherry pie, my personal favorite, you are eating

 these things right now, right. Ethyl acetate and benzaldehyde.

 There's now sources of -- certified organic sources of each of

 these, and that was driven exclusively by the commercial

 availability clause for flavors, right. That's -- there's

 hard, hard evidence for that, hard data for that. What's 
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 particularly interesting is that, to me, is that ethyl acetate

 is not only a flavor you'd recognize this in like red wine

 flavor, most of those flavor keys you're tasting there are

 ethyl acetate, but it's also an excellent extractant that

 behaves very differently than ethyl ethanol but can serve to

 generate ever more extracts. I think that -- I think the

 ingredient opportunities that arise from that could be very

 positive. 

Next slide, please. 

I've -- I sent a list following last spring's

 meeting. I sent a longer list, but a few possibilities in

 organic innovation are in these materials that are on 605, both 

(a) and (b), and as the ability of our -- as our technology and

 food science advances, there are increasingly opportunities to

 develop new ingredients in organic forms. And we are looking

 for stakeholders for competitions in that direction. 

That's all I have I think. Next slide's, I think,

 just gravy. Yep. Thank you. 

CHAIR POWELL-PALM: All right. Amy has a question

 for you. 

SECRETARY BRUCH: Yeah, thanks, Nate. 

Thanks, John. Appreciate your time. And thanks for

 the inclusion of the -- of the list that you had in the written

 comments, kind of a follow-up from our spring meeting. 

 Definitely want to grow these organic markets like you alluded 
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 to.

 I see in your written comments you mentioned you did

 have a goal to generate a petition for the NOSB on this topic,

 and love attach timelines of goals so we can make them real,

 because I think this one would be a good opportunity here.

 Do you have kind of an idea on a timeline

 potentially?

 MR. FOSTER: Yeah. Well, yeah, there's a -- some

 low -- I -- I consider low-hanging fruit would be citric acid.

 Now, truth be told, I'd rather see a blanket

 commercial availability; just lay over the whole of 605, right.

 I under -- that's not our precedent though, right, it's

 itemized now. So, assuming that a blanket commercial

 availability clause just isn't in the cards for some reason, I

 don't know how you would create all the documentation required

 to hit every item on 605, like in terms of alternatives and all

 of that, so I think it's going to have to be individual.

 So low hanging fruit would be citric acid, which I --

 is already on the market as certified organic. Not easy to

 find, and it's not produced except to order. And that's --

 that's the rub there, is that they won't produce it unless it's

 ordered, but until there's a drive to get it ordered there's no

 incentive to produce it, so people don't know it's out there.

 Back to your question, it -- this is something that 

 could be in your hands to review, well, I'd love to say by the 
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 spring meeting, but certainly by the fall. We have a Lot of

 other things going on in the next six months, but I -- there's

 no doubt in my mind it could be in your hands for discussion at

 the fall meeting in Portland.

 SECRETARY BRUCH: Excellent.

 MR. FOSTER: I would love to see that. And whether

 it's citric acid or something else, I think there's a number of

 other opportunities, that's just the one that comes to mind --

 SECRETARY BRUCH: Um-hum.

 MR. FOSTER: -- that we've helped find so that people

 could hit that -- that 95 percent mark on a challenging

 formulation.

 SECRETARY BRUCH: Um-hum.

 MR. FOSTER: But, yeah, would -- would you -- can I

 ask; would you -- would You like to see that in the fall?

 SECRETARY BRUCH: Well, anything that can help, you

 know, drive innovation, and expand our markets, I --

 MR. FOSTER: Cool.

 SECRETARY BRUCH: -- think that that we're in favor

 of things like that. So --

 MR. FOSTER: Love it. Okay. Duly note.

 SECRETARY BRUCH: Okay, thank you.

 MR. FOSTER: Duly noted. Thank you.

 CHAIR POWELL-PALM: Nate Lewis, please go ahead. 

Then Logan. 
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BD. MEM. LEWIS: Thanks, John. Citric acid happens

 to be the -- my Sunset for next year, so duly noted about

 potential annotation there. 

And I -- I guess my question, just to sort of push

 this concept a little bit, it sort of makes sense to me why

 commercial availability is not included on 605 since either the

 non-agricultural products and organics designed for

 agricultural products and so these are kind of like anomalies

 that happen to meet composition and, you know, the processing

 requirements of organic. So, I guess what I'm trying to kind

 of get to the bottom of is, absent a 605 blanket commercial

 availability clause, what kind of structure can we put in place

 so that at Sunset a specific annotation can sort of

 automatically be considered and we cannot -- I mean I love

 hearing from you, but I would love for the board to just always

 assume that it's on the table every time we review a material

 going forward, so I'm just sort of trying to think about

 building in some mechanisms for the Sunset Review so that we

 can achieve the goal. 

MR. FOSTER: Mmm. So, I will avoid trying to get

 into my "Story Time with Uncle John" mode, but -- but there

 were, back on my term on the board, I believe it was the -- it

 was the time in which annotations being added during Sunset

 became verboten for really good reason. Times were different.

 Meetings, you know, meetings went much longer, decisions were 
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 made sometimes at 1:00 or 2:00 in the morning, but -- but it --

but the takeaway, I think it was biodegradable mulch, actually

 it might have lit the fuse to the end of this. But I don't

 think it's prudent to build in annotations as a part of Sunset

 Review, if -- because of that train -- those many train wrecks

 that happened up until whatever it was, 2012 or 2013. 2014

 maybe. 

However, I do feel like if the board would signal

 that it was open to a very straightforward petition to review

 those thing -- that recognizing their petition to add this

 clause doesn't necessarily require a full technical review, for

 example, or an updated TR, or -- yeah, TR now. That would be

 helpful because then it would -- that would make it easier for

 someone to say, well, actually there's a lot known about citric

 acid. It' s used everywhere. There's really no concerns, at

 least right now, no concerns about its use or how it's used.

 Maybe we could make it easier. Follow the petition process,

 because that is the process and we should follow it, but the

 depth of information that would be required to review that, to

 that -- to add a commercial availability clause, if -- if there

 could be a signal that said there well open to that, it may

 make it more encouraging for an operation who makes very little

 of a material, but could make more, it would -- could be

 encouraging for those folks. 

And the company like ours, we've got very, very --
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 we're very used to heavy lifting in petitions, and that would

 be something we could do much more -- we could facilitate that

 much more readily if we -- if we had a sense that they were --

 it was a welcome, open invitation to do so. And that's what

 I'm getting actually, from this moment, is that it -- perhaps

 it's more welcome than we thought it was. So -- so we -- we

 could certainly telegraph that to participants or manufacturers

 and -- and actually as a function of this question, Nate, I'm

 going to do that between now and spring.

 So, does that answer your question? Sorry. Okay,

 cool.

 CHAIR POWELL-PALM: Logan has a question for you.

 BD. MEM. PETREY: Yeah, just a quick question.

 There's two --because I have flavors and it -- it's good to

 hear that there are some that are increasing. The two that

 you're talking about, I don't even know where they -- where do

 they come from? What -- what are they? You said that organic

 production has increased.

 Do you know? I -- I don't know.

 MR. FOSTER: I'm not privy to the --

 BD. MEM. PETREY: Yeah, sure.

 MR. FOSTER: -- to the source materials, but --

 BD. MEM. PETREY: Okay.

 MR. FOSTER: -- I know that they were recently 

 recertified, I believe, four weeks ago. They're on --
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 BD. MEM. PETREY: Okay.

 MR. FOSTER: -- in the -- and they were immediately

 funneled to the OID.

 BD. MEM. PETREY: Okay.

 MR. FOSTER: And what's also interesting in

 communication I had at Expo East was from -- with the

 manufacturer, was that within three days of that posting on

 OID, they had inquiries from much larger flavor houses saying

 like, are you sure you've got organic ethyl acetate? Like how?

 Really? And it -- it took Literally 72 hours for the flavor

 community to recognize that and say, wow, like now this is here

 we need to use it.

 BD. MEM. PETREY: Okay.

 MR. FOSTER: That -- that's the -- the speed that

 these things can happen, is -- that astonished me. And it

 astonished the manufacturer because that manufacturer was

 unaware that global flavor houses monitor the OID so carefully.

 And clearly they do because there was zero advertising of this

 in the first 72 hours.

 BD. MEM. PETREY: Okay. Great. Thank you, John.

 MR. FOSTER: So, yeah. I -- it was wonderful.

 Actually, that also did -- it spoke very high, in my

 mind, it says a lot of positive things about the -- the role of

 OID in the marketplace and the power of it and I think we ought

 to harness -- harness the heck out of the -- the role of OID in 
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 the marketplace, and the power of it. And I think we ought to

 harness -- harness the -- the heck out of that. 

CHAIR POWELL-PALM: Absolutely. Thank you, John.

 Appreciate --

MR. FOSTER: You bet. 

CHAIR POWELL-PALM: -- your comments. And we'll see

 you next week. 

MR. FOSTER: That you will. Thank you. 

CHAIR POWELL-PALM: Next up, we have Mike Crotser,

 followed by Bruce Kaser, and then Terry Shistar. 

Mike, the floor is yours. 

MR. CROTSER: Oh, hey everyone, can you hear me? 

CHAIR POWELL-PALM: We can. Please go ahead. 

MR. CROTSER: Oh, thanks, Nate. 

I'm Mike Crotser, the certification director at CROPP

 Cooperative. We appreciate the work of the NOSB and the NOP to

 support organic agriculture. Thank you for the opportunity to

 speak. 

It's fall and harvest season is here for farmers.

 Before I get started I want to express my gratitude to all the

 members of the organic community, and especially thank the

 farmers for their work. My comments today will focus on the

 discussion document, oversight to deter fraud, residue testing

 in a global supply chain. The premises of this document was

 not to replace the sound organic system plan with metric based 
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 testing, this is good to know, but it's important to

 acknowledge that expanding testing will, at least, be a small

 shift from evaluating outcome-based production systems towards

 a metric driven process. In principle we support expanded

 testing; being said, the discussion document prompted several

 questions that should be addressed prior to proceeding.

 Targeting fumigants makes sense, especially because of

 fraudulent grain in our supply. We are less familiar with

 fraudulent use of hexane as an extractant.

 Do we have evidence that fumigants and hexane are

 problematic and present in organic crops? The threshold for

 hexane and how NOP 2613 relates to this threshold must be

 carefully thought out.

 Can results that exceed the threshold effectively

 differentiate between incidental, unintentional contamination

 when compared to adulteration? From our experience, resolving

 positive pesticide tests for compounds on NOP 2611-1 is

 difficult. Often, operators cannot convey how the pesticide

 contaminated their crops leaving certifiers with no resolution.

 Since the finalization of the Organic Periodic

 Residue Testing rule, where are we years later? Has this

 effort reduced fraud and improved integrity? Would a technical

 report that outlines the benefits and shortcomings of residue

 testing assist in the expansion of this program? Are 

 additional tools needed for certifiers to be successful? For 
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 example, with a classification tool that compared chemical

 common pesticide name with trade name or pesticidal class

 improve outcomes? Are there commonly used pesticides that

 should be tested but are not due to the limitations of the

 multi residue screen testing? 

I hope that our questions do not express that we

 don't support expanded testing for residue. We acknowledge the

 board seeks continued improvement and we support this goal.

 Our point is to convey the complexity of residue testing and

 encourage the organic industry to thoroughly think this out

 before implementing. 

I want to thank the NOSB, the NOP, and the organic

 industry for time to speak today. And I'm happy to address any

 questions from the board. Thank you. 

CHAIR POWELL-PALM: Thank you for your comments. Amy

 has a question for you. 

SECRETARY BRUCH: Yeah. Mike, thanks for

 participating in the process today. I appreciate the written

 comments you guys provided, also. And the questions you threw

 back at us. That's the beauty of these discussion documents;

 we love the community to mow them over and -- and, you know,

 let us know what -- what are some concerns about the written

 material that we provided, so thank you. 

I asked Elizabeth prior, and she deferred this 

 question to you, just about your written comments that stated 
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 in general you'd have concerns if -- if this testing would

 increase -- increase global supply chain testing, I think, as a

 whole, especially imports. It seemed like from -- from the

 written comments from your organization, there was concerns

 there versus some other folks through their written comments,

 they were really in support of expansion of testing, so I was

 just trying to unpackage the concerns a little bit more. 

MR. CROTSER: I -- I think on -- on two pieces of

 that of that is I allow -- my concerns were mostly addressed

 today, but specifically for inputs, sourcing ingredients can be

 a challenge and so this is maybe part of a bigger picture of

 having available ingredients that we need for production. And

 a good example of that, that is not related necessarily to

 residue testing, is organic sunflower lecithin, right. We use

 that and have used that to agglomerate whey protein

 concentrate. And then the war in Ukraine broke out, right,

 and -- and most of that comes from sunflower production in

 Ukraine, so that is just a risk that we look at generally

 across the business, and so how would testing play a role in

 availability of the materials is a concern. 

I don't want to imply to the NOSB that we are at all

 opposed to testing, but that could be an additional wrinkle

 that -- that -- that could affect availability of some of the

 ingredients that we're looking for in our supply chain. 

SECRETARY BRUCH: Um-hum. Um-hum. Okay, thank you, 
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 Mike. Appreciate that. 

CHAIR POWELL-PALM: Nate. Nate Lewis, please go

 ahead. 

BD. MEM. LEWIS: Yeah, this might end up being more

 of a comment, but just want to echo appreciation for your

 questions on the testing document and leading this up with Amy,

 so any input is great. 

And also want to acknowledge that I share the -- your

 view that, you know, organic is a process based standard and

 I'm certainly looking at testing as a effective verification

 and validation tool for certifiers to -- to verify and validate

 that process. So, I'm just sort of -- a call out; keep us in

 a -- keep us in that lane. So, if you see us drifting and the

 proposal getting to a point where it appears to be more of a

 metric in an outcome-based standard, give us -- give us a

 gentle nudge and get us back in our lane. So, thank you. 

MR. CROTSER: Yeah. Thanks, Nate. And I -- and

 that's why I kind of backed up like where are we today with

 residue testing. I -- I led that program within my previous

 certifier role, and -- and it's clunky. It's very clunky.

 Certifiers don't understand pesticides, they're not familiar

 with compounds on 2611, and then the challenges of when you get

 a positive test what the heck do you do? You know, how do you

 get this resolved? It's -- there's some challenges in there. 

And it's more so before you bite it off another chunk of 
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 residue testing, I think it would be good to reflect where we

 are today with that program. 

CHAIR POWELL-PALM: I just want to thank you, Mike,

 for how seriously you take giving us really helpful comments

 that address exactly what we're working on, so thank you for

 the time and the homework it takes to make those -- make those. 

Any other questions for Mike?

 (No response.) 

CHAIR POWELL-PALM: All right, we appreciate your

 comments today. 

MR. CROTSER: Thank you. And we'll see you next

 week. 

CHAIR POWELL-PALM: Next week. 

Next up we have Bruce Kaser, followed by Terry

 Shistar, and then Sydni Arnone. 

Bruce, the floor is yours. Please state your name

 and affiliation.

 MR. KASER: Thank you. I'm Bruce Kaser. I'm affiliated

 with Pratum Farm, LLC. I'm an old lawyer who turned into an

 organic hazelnut farmer, and as a matter of fact we're in the

 middle of harvesting out here. We're in -- when I'm done here,

 I got to go out and get my harvester greased up and ready to

 go. 

I'm here today to explain why we are filing a federal 

 court action that asks a judge to declare grower group 
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 certifications illegal. 

 The -- you know, the public's perception is that

 certified organic farmers are the ones who receive higher

 prices because organic farmers have certain challenges that

 conventional farmers do not face. Lower yields being one.

 And -- and basically, the public is willing to pay higher

 prices for food that hasn't been sprayed with chemicals.

 Now, buyers downstream from the farmers in the farm

 to table chain, and which in our industry, by the way, involves

 something called "shelling processors," those buyers pass on

 the farmers organic premium to their customers, along with

 their own added premium, that is attributable to their own

 certification costs, and -- and maybe a little profit as

 handles, and all of that creates an organic premium over

 conventional prices. So I was very, very surprised when I was

 told by a local shelling processor that imported Turkish

 organic hazelnut kernels are now reaching negligible wholesale

 price points, compared to imported Turkish conventional

 kernels, which begs the obvious question, well, how -- how can

 that be happening unless Turkish farmers are receiving no

 premium or -- or, you know, cheating is involved in some --

some fashion.

 I obtained evidence that confirmed what I had been

 told on the pricing issue, along with substantial evidence of 

 fraud in Turkey that is directly linked to grower group 
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 certifications. In one case, a Turkish processor's organic

 premium was about 3 percent. Now, we -- we have a small

 organic hazelnut industry in Oregon that can't compete with the

 USDA rule that creates a recipe for fraud by allowing foreign

 interests to avoid farm inspections. Just a couple of months

 ago, this started to drive down our local farm commodity prices

 for Oregon organic hazelnuts by about 30 percent. That's this

 year compared to last. That's ballpark. And all of this is

 the reason for taking court action. Thank you. 

CHAIR POWELL-PALM: Thank you very much for your

 comments. Nate Lewis has a question for you. 

BD. MEM. LEWIS: I actually have two questions.

 First one's quick; do you call them "hazelnuts" or "filberts"

 because I'm --

MR. KASER: Well, the industry changed the name.

 They're traditionally called -- old school people still called

 filberts, but it's -- they're an international commodity so the

 local Oregon industry decided to rebrand them to hazelnuts so

 that we would go along with the rest of the world and not

 getting them confused. But I guess you're still confused. 

BD. MEM. LEWIS: Well, yeah. And I'm -- I'm up in

 Olympia so I -- Olympia, Washington --

MR. KASER: Oh. 

BD. MEM. LEWIS: -- so we still call them filberts 

 up --
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 (Automated Message: Recording stopped.) 

BD. MEM. LEWIS: -- at least colloquially. 

My more serious question though has to do with

 residue testing and whether there are, as we kind of look at

 residue testing for a global supply chain, whether there are

 specific compounds that could help to root out at least the

 portion of those imports that may be truly fraudulently

 produced rather than produced organically, but without the

 oversight that you that -- you experienced as a certified

 producer here in the States. I'm kind of thinking, you know,

 glyphosate on the ground, and then does it -- you're harvesting

 from the ground, but I'm curious for your thoughts on --

 (Automated Message: Recording in progress.) 

BD. MEM. LEWIS: -- what sort of residue testing

 might be a practical deterrent? 

MR. KASER: You cut out a little bit, but I think

 that's a pretty easy question for me to answer; I have

 absolutely no idea. 

CHAIR POWELL-PALM: Fair enough. We have another

 question for you from Allison, followed by Jerry. 

BD. MEM. JOHNSON: Thank you. I appreciate you

 bringing this to our attention today, and I -- I have lots of

 questions, but I'll just pick one for the moment. 

I tend to think of grower groups as a useful tool to 

help smaller producers stay in the organic world, where costs 
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 of certification, the process can be particularly cumbersome

 for our smallest scale producers, but they're also some of

 the -- the producers that consumers, I think, most imagine when

 they're purchasing organic food. So, I'm curious if you think

 there is a role for grower groups generally, and there's a -- a

 more narrow way to get at the -- the concerns that you're

 raising? Or if you think grower groups as a -- a concept as an

 institution have to go completely? And if the latter is the

 case, I'm curious to hear any other ideas to make sure that

 certification is in reach for smaller producers?

 MR. CROTSER: I think that there may be a narrow

 window for the concept of Grower Group certifications if it's

 done the right way. But I think that the general concept of

 grower group certifications is 40 to 50 years out of date, and

 it's morphed into something completely different from what its

 original intent was, and it's just completely flipped over to

 the dark side of things. I don't think that the ideals of

 grower group certification are being implemented by and large

 or maybe some countries are different than others. But in

 Turkey, you cannot -- you cannot get onto -- on the USDA

 Integrity database and locate a single organic Turkish farmer,

 and that ought to tell you something.

 CHAIR POWELL-PALM: Jerry, please go ahead.

 BD. MEM. D'AMORE: Hello, and thanks for the 

 opportunity to address on what you said. And I'm going to 
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 probably cut myself short because I'm not sure how appropriate

 would I what I want to say is in terms of where we're trying to

 get to. 

I spent six years in Turkey and any concern that you

 might have about the false flagging of products is certainly

 demonstrated to be legitimate. Love the people there, though. 

My -- my one question of you would be, in terms of

 your lawsuit, is it the -- the lack of a price premium on the

 organic product that you were referring to as an underlying

 piece of that lawsuit? 

MR. KASER: No. That --

BD. MEM. D'AMORE: Okay. 

MR. KASER: -- that issue was the thing that started

 it all. That was the thing that got my attention. I think

 I -- I mentioned in my comments, as well. I heard this, how

 could that possibly be happening? I mean, you know, I -- I

 know -- you -- you folks wouldn't understand what "shell out"

 means in the -- in the -- in the nut industry, but anyone out

 here in Oregon that heard that Turkish processes are charging a

 3 percent organic premium in the U.S. market over convention

 prices, they'd immediately go what's going on with -- with

 that? So that was just the starting point. 

But the -- the issue of the lawsuit is going to be

 follow the statute. We have a statute that says all farms have 

 to be inspected every year by an accredited certifier. 
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BD. MEM. D'AMORE: Thank you very much. Do

 appreciate your response. 

MR. KASER: Thank you. 

CHAIR POWELL-PALM: Franklin, please go ahead. 

BD. MEM. QUARCOO: This is a follow-up on Allison's

 question actually. So, given how important this grower group

 certification is to farmers with limited resources, small

 scale, I'm interested in your idea of what grower group

 certification done right is? What -- what is your idea of it

 being done right? What would you want to see with the grower

 group certification to consider it being done right? 

MR. KASER: I think -- I'm going to repeat the

 question a little bit, just to make sure I've got it right.

 I -- I think what you're asking me is, what would be my idea of

 grower group certification being done right? 

For one thing, I think that it's not going to work

 unless it's cut down to a, you know, a smaller number of

 farmers. I don't think you can have grower groups that consist

 of 1,000 members. I don't think that's going to work at all.

 The original idea was that a grower group would be a small

 group of growers, maybe -- maybe in a -- a village, you know,

 where all their plots are next door to each other. And so, you

 know, I think that's a starting point. 

You know, organic certification to me is looking at 

 what's happening on the farm. And so, if you've got one small 
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 farmer with a plot next to another small farmer, you know, or

 three next to each other, then yeah, there might be a basis for

 certifying all three of those farmers together so that they

 can -- so that they can minimize their certification costs.

 Because the certifier -- and I have to say that for me going

 through the inspection process was highly educational. I

 really -- I liked it. I had the certifier there, we're walking

 around the farm, he's asking questions. And so, if you've got

 three plots right next to each other, it's awfully easy for the

 certifier to go through each one. And so, I think that's

 (audio distortion) have. We can't 1,000 have growers in

 different provinces or different towns or things like that; it

 just don't work. 

CHAIR POWELL-PALM: We have a question for you from

 Kyla. 

BD. MEM. SMITH: I have two; one will be quick. 

The first one, I just want to make sure I heard you

 correctly. Did you say in the OID that when you look up

 Turkey, as a country, there's no certified operations? Or were

 you speaking only about hazelnuts? 

MR. KASER: Hazelnuts. I'm sorry I'm not answering

 you. 

BD. MEM. SMITH: Okay. 

MR. KASER: I -- OID, I'm not connecting what that 

 acronym is. So, in the --
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BD. MEM. SMITH: Oh, the Organic -- oh, I'm sorry.

 So, can you just say what you said, maybe -- yeah I'm -- can

 you clarify --

MR. KASER: Okay. 

BD. MEM. SMITH: -- what you said there? 

MR. KASER: The USDA database called Integrity --

BD. MEM. SMITH: Yes. 

MR. KASER: -- right. And so that --

BD. MEM. SMITH: Correct. 

MR. KASER: -- enables the public to look up

 certified operations --

BD. MEM. SMITH: Right. 

MR. KASER: -- farmers, handlers, and so forth.

 You'll not find -- you'll not be able to use that database to

 find a Turkish organic hazelnut farm operation. They're all

 handlers. They're all processors. 

BD. MEM. SMITH: Got you. Okay, just clarifying. I,

 you know, think I maybe misheard you; I thought you -- I -- I

 knew what the database [sic], and I just was -- just anyway, I

 thought you said at all, no Turkish like certified organic

 operations at all, and I was like that can't be true, so I was

 confused. 

MR. KASER: Well, actually -- actually, you should --

you should look, it's -- it's quite fascinating. Once you

 start digging into looking at all certified operations, and 
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 then you look at the number of handlers that are certified

 versus the number of what appears to be solely crops

 operations, which you would think are farmers, and you'll see a

 huge difference. There's lots of certified handlers, and there

 are not very many certified farmers. Okay, that was the thing

 that really kind of leapt out at me when I started going down

 this path. You know, the first thing I heard was about this

 pricing problem, and then I started looking at the database and

 I thought, oh my goodness, look at this. 

BD. MEM. SMITH: Okay. And thanks. And my second

 question is, you know, for a long-time certifiers were

 operating off of an instruction document in the program

 handbook related to grow groups ,and now that the

 specifications have been codified in the Strengthening Organic

 Enforcement final rule, and I wonder if you think that that

 will help and move us in the right direction of certifying

 these types of groups in a more uniform way, and that

 certifiers might have a bit more oversight and enforcement

 because it's now codified versus being in the program handbook? 

MR. KASER: Absolutely not. I-- I think that I would

 ask that you read complaint when it goes out it. It outlines

 the entire history of the process and problems with it. I

 don't think -- I don't think the new rule is going to make a

 bit of difference. 

CHAIR POWELL-PALM: Well, we really appreciate your 
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 comments, and thanks for taking all these questions. 

Next up, we have Terry Shistar, followed by Sydni

 Arnone, and then Ellie Hudson. 

Terry, please go ahead. 

MS. SHISTAR: Okay. 

MS. ARSENAULT: Oh, there we go. Yeah, I was going

 to say, just hang on a sec while we get your slides up.

 Thanks. 

MS. SHISTAR: Okay, and I unmuted myself, so I just

 click on -- okay. 

My name is Terry Shistar, and I'm on the board of

 directors of Beyond Pesticides. We've submitted comments on

 all the issues before the board, but my comments today will

 address the so-called inert ingredients. More details are in

 our written comments and in our 2017 report called "Inert

 Ingredients in Organic Production." 

NOP has repeatedly tried to divert our attention from

 the crucial issue, one that has threatened the integrity of

 organic products for more than 20 years and continues to do so.

 The question that must be addressed is not whether these

 potentially toxic inputs should be individually evaluated, but

 how to do it. 

To dispense with the faults to issue first, the

 evaluation of so-called inert synthetic ingredients in products

 in -- used in organic production is not optional; it's required 
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 by law. NOP must allocate resources for this project. In

 addition, because of NOSB's intensive review of active

 ingredients, and the lack of oversight over other ingredients,

 the so-called inert ingredients pose greater risks than the

 active ingredients do.

 Inert ingredients make up the largest part of

 pesticide products, and here I have a few examples, kind of

 pulled at random, and inert ingredients are not generally

 listed on pesticide labels, so NOP and the NOSB have been

 allowing unknown toxic mixtures to be applied to organic crops

 and livestock.

 And now, on to the real issue of what we need to do.

 We estimate that there are 137 synthetic inerts currently used

 in organic production that must be evaluated. NOP must

 immediately publish the known list with a request that

 registrants of -- of products approved for use in organic

 production notify the NOP of the inert ingredients that are

 contained in their products.

 We propose that the NOSB first insist on the

 publication of that list. The NOSB has undisputed authority

 over allowed synthetics in organic production and should not

 shy away from taking a strong position.

 Second, we have proposed substitute language for

 these substances on the National List. On this slide, we just

 list categories of substances, as previously determined by the 
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 Inerts Working Group, but more details are in our written

 comments. The exact assignment of inert ingredients to the

 review groups can of course be adjusted to meet the convenience

 of the NOSB and contracted reviewers. The subs -- this

 substitute listing should be approved at the Spring 2024

 meeting.

 In short, the time to act is now. Thank you.

 CHAIR POWELL-PALM: Thank you for your comments. We

 have a question for you from Allison, followed by Nate.

 BD. MEM. JOHNSON: Thanks so much for your comments,

 Terry. I really appreciate it. I think we all agree that we

 need to tackle this issue, and having specific suggestions is

 going to be really helpful moving forward.

 One thing that stood out to me is that you were able

 to come up with numbers. I've -- I've heard a lot of comments

 that we don't really know how many of these materials are being

 used, and so I'm wondering if you could say a little bit more

 about how you came up with your list and the number of products

 that you think are in play here, as a guide for NOP in -- in

 figuring out what materials they're actually dealing with?

 MS. SHISTAR: Okay. I think that if you go back to

 that slide, it starts with the -- with the list of inert

 ingredients that are being used in products that are recognized

 by OMRI and -- WSCA and PCO. And then -- and then we looked at

 the 25(b), the materials on that list that are on EPA's 25(b) 
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 list, which are things that don't have to be registered in --

 they're used in products -- in pesticides that don't need to be

 registered. And then -- so we subtracted off those. And then

 we subtracted off the -- the natural ones because they don't

 need to be evaluated as synthetic inerts. And what we -- what

 we came up with was about 137. Now, it might be a little bit

 more, a little bit less, but it's nowhere near the thousands

 that AMS was estimating. 

BD. MEM. JOHNSON: Really helpful. Thank you. 

CHAIR POWELL-PALM: Nate, please go ahead. 

BD. MEM. LEWIS: Appreciate the -- sharing your

 opinion about the inerts needing to be listed individually. 

And my question relates to whether that -- your --

that opinion extends to the other lists that we have on the

 National List, like excipients and livestock drugs, vaccines?

 And -- and so I, what I'm trying to get to is, why are inerts

 unique in that folks want all of those listed individually but

 I'm not hearing the same call for particularly excipients is

 my -- I think the closest parallel in livestock drugs? Are --

 is there something unique about inerts that we're -- we're --

I'm not -- I'm sort of missing? 

MS. SHISTAR: Well, if you look at that slide that

 talks -- that that addresses the -- the toxicity of inerts

 versus the toxicity of the active ingredients, I mean

 personally this is coming from a group that's focused on 
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 pesticides, so that's why we are focused on it, and we've been

 focused on this for decades, okay. And I think that this is a

 high priority because of that, because of the fact that we've

 got so many, you know, toxic substances that are being used as

 inert ingredients. Maybe after we take care of the inert --

the inerts problem, we'll deal with the excipients, you know.

 It's just a priority. And I'd love to see what you have to say

 about the excipients.

 BD. MEM. LEWIS: Oh, well I'm -- I'm just trying to

 see if there's any sort of inherent distinctions we need to

 make between inerts and all of the other lists that are

 referenced on the National List, in terms of whether it needs

 to be treated differently or similarly, so that's sort of the

 root of the question.

 MS. SHISTAR: Yeah. Well, yeah. And I think that

 the biggest problem is the secrecy, and I -- I imagine that

 that's similar in -- in excipients but I haven't looked that

 closely at excipients.

 CHAIR POWELL-PALM: All right, we thank you for your

 comments, Terry. Actually, Dilip has a question for you.

 Please go ahead, Dilip.

 BD. MEM. NANDWANI: Thank you for your comment.

 The subcommittee in the board is really brainstorming

 on inerts, as probably you would know. I have little

 clarification, not really a big -- a question about the 
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 toxicity you mentioned; is this a list you got from the

 pesticide's company? Or can you tell us a little bit more

 about it on this topic? Thank you. 

MS. SHISTAR: Okay. In our -- in our report that we

 produced in 2017, we used a number of sources to identify the

 toxic -- the characteristics, you know, whether it's toxic or

 carcinogenic or whatever, of those chemicals, and that -- that

 summary slide that I presented was a summary of the ones that

 we -- that we could identify -- where we could identify the

 sources. And you'll find more information about where we

 actually went in that 2017 report. 

And if you have any more questions, then let me know

 and I'll try to dig it up. 

BD. MEM. NANDWANI: Thank you. 

MS. SHISTAR: Thank you. 

CHAIR POWELL-PALM: Brian, I saw your hand go up; did

 you have a question? 

BRIAN CALDWELL: No thanks, right -- right now, Nate. 

CHAIR POWELL-PALM: Okay, thank you. 

Thank you again, Terry. Appreciate your time and

 your comments. 

Next up, we have William Alberto Florez Calas. Are

 they on the line? 

MS. ARSENAULT: We're not seeing William on the line 

with us, Nate, so thanks for checking, though. 
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64

 CHAIR POWELL-PALM: Okay. Then we'll go to Sydni

 Arnone, then Ellie Hudson, and then Sarra Jahedi.

 Sydni, if you're there, the floor is yours.

 MS. ARNONE: Thank you. Good afternoon. My name is

 Sydni Arnone. I am the manager of Government Relations for the

 International Food Additives Council. IFAC is a global

 association representing manufacturers and end users of

 ingredients, including a number of substances permitted for use

 in organic handling.

 IFAC strongly supports the Handling Subcommittee's

 recommendation to relist the non-synthetic substances gellan

 gum and potassium chloride, with synthetic substances

 alginates, mono- and diglycerides, phosphoric acid, xanthan

 gum, and the nonorganic agricultural substances, water

 extracted gums, including Arabic, Guar, Locust bean, and Carob

 bean. And de-oiled lecithin. These ingredients are safe, used

 in alignment with organic principles, and lack of organic

 alternatives completely (audio distortion). Each one of these

 has unique properties and applications, they are therefore

 essential to meeting the needs of the organic community and

 should be retained on the National List.

 Today, I would like to emphasize the written comments

 as it pertains to potassium chloride and mono- and

 diglycerides. Potassium chloride is an important tool in

 reducing sodium content in food and helping support U.S. 
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 policies on sodium reduction. We would like to note the FDA's

 proposed rule, the use of salt substitutes to reduce sodium

 content and standardize food labels, which seeks to amend

 various standards of identity to allow for the use of salt

 substitutes in foods where salt is a required or actual

 ingredient. Public review and comment for the proposed rule

 closed on August 8th and the Final Rule has not yet been

 published; however, it illustrates the role ingredients like

 potassium chloride play in reducing sodium content. 

For mono- and diglycerides, I also would like to

 address the stakeholder questions posed in the Fall 2023

 meeting (audio distortion) document. 

The first question, what organic products are monoand diglycerides currently used in? 

The USDA's FoodData Central database of Branded Foods

 from April 2023 contained 1,048,575 total brands. Of those,

 12,212, or 1.16 percent, of the items had organic in their

 ingredient list. Of those, 542, or 4.4 percent, contained

 monoglycerides and/or diglycerides in their ingredient list.

 This number may be seem -- may seem small at first, but we

 remind you that while monoglycerides are permitted globally in

 a variety of applications, their use in organic food production

 is limited to drum drying the food. 

The second question was, have any other alternatives 

 emerged? 
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 We are not aware of any alternatives, which 

 reiterates the importance for this ingredient coming on the

 National List of this application.

 Thank you for your time and attention today. And I

 made it well under the time that I thought I was going to.

 CHAIR POWELL-PALM: Crushed it. Well done. Well

 done.

 Questions from the board?

 (No response.)

 CHAIR POWELL-PALM: All right, we really appreciate

 your comments, Sydni. Thank you.

 MS. ARNONE: Thank you.

 CHAIR POWELL-PALM: Next up, we have Ellie Hudson,

 followed by Sarra Jahedi, and then Mark Lipson.

 MS. HUDSON: Hi, Nate.

 CHAIR POWELL-PALM: Hi, Ellie.

 MS. HUDSON: Hi, everyone. I'm Ellie Hudson,

 executive director of the Accredited Certifiers Association, or

 ACA.

 ACA is a nonprofit that exists to benefit the

 accredited organic certifier community and the organic

 industry. Broadly, we look to develop certifier resources that

 can alleviate the pressure often germane to a regulatory

 environment, and we proactively seek ways to add, improve, and 

 innovate the value of ACA membership. 
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67 

We envision an environment where barriers and 

 implicit bias have been eliminated and where everyone has the

 resources they need to live up to their full potential in all

 aspects of our work. 

ACA has developed new certifier resources toward

 consistent implementation of the SOE rule. In pursuit of

 consistency, various collaborations and educational programs

 are available. Creating this environment of consistency among

 certifiers can generate a ripple effect that benefits everyone.

 These activities are provided free of charge to the

 certification community as part of a cooperative agreement

 between NOP and ACA. 

Also funded through our cooperative agreement, we are

 partnering with the international Organic Inspectors

 Association, or IOIA, around mentorship of aspiring organic

 inspectors. The data gathered in our 2023 mentor cohort will

 be analyzed and used to develop resources aimed at making

 mentoring more efficient, accessible, and enticing. 

ACA is also a partner in a project led by Organic

 Farmers Association in pursuit of racial equity and justice in

 organic. This project aims to provide continuing diversity

 education and concrete tools for organic professionals through

 a cohort learning model focusing on questions and challenges

 that are organizational in nature. Certifiers in the inaugural

 cohort have reported deep opportunities for growth and change 
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68

 in a supportive and constructive environment. Applications for

 the second racial equity cohort for certifiers will open on

 November first. 

The ACA board also identified a strategic need to

 better understand our supportive membership category, available

 for those who are not accredited certifiers but have an

 interest in supporting ACA's mission. As a result of the

 steering committee's survey of existing members, and soon

 prospective members, we are beginning to understand what you

 want from ACA and how we can deliver more value. 

I must also mention that 2024 will mark ACA's 20th

 anniversary. I am truly amazed and humbled that many of the

 founding certifiers who created ACA are still active in our

 community, and many of you are here today. We have some

 special things planned to recognize and thank you throughout

 the year. I feel like I'm standing on the shoulders of giants

 with this opportunity to offer these comments. 

Thank you for your work in getting us to this point

 and thank you to the board. 

CHAIR POWELL-PALM: Thank you for your comments,

 Ellie. 

Questions for Ellie? Amy, please go ahead. 

SECRETARY BRUCH: Yeah, Ellie, thank you so much.

 Congrats on the anniversary. And all of the best practices and

 resources that you provide certifiers, it's pretty impressive. 
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69 

You highlighted your -- some of the collaboration

 efforts that -- that your organization is doing, and that

 actually dovetails with my question about collaboration.

 Through other written comments in regards to our testing --

 residue testing in a global supply chain discussion document,

 there were comments from inspectors about the desire to

 collaborate with ACA in editing, enhancing the current risk

 management matrix that's out there. 

Would -- would that be something your organization

 would be open to because it does sound like you do cross-

 collaboration? 

MS. HUDSON: Definitely. Yeah, I think that's

 really helpful. I appreciate that you shared that. We're

 actively and -- and really intentionally trying to provide more

 opportunities to include not just staff inspectors, which are

 already part of certification agencies, but also really looking

 at cooperative or independent inspectors as part of the

 certifier ecosystem. So, this has manifested in many ways and

 we're always excited to find new ones, and I think that this is

 something we can definitely take up. So, I'll take a look. 

SECRETARY BRUCH: Okay. Excellent, Ellie. Thank you

 so much. 

CHAIR POWELL-PALM: Nate Lewis, please go ahead. 

BD. MEM. LEWIS: Can folks hear me? My Internet's a

 little unstable. Yeah? Okay. 
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 This is -- and I this -- well, common refrain that

 Amy made, testing tag team here. I noticed a comment from one

 of your members, I believe it was OFA, talking about the cost

 of residue testing which must be borne by the certifier, at

 least from the periodic residue sampling angle.

 I'm curious, and so this is inspired by your

 cooperative agreements and funding, have you approached NOP

 about a way to sort of help cost share that testing financial

 burden and whether there's some funds for SOE implementation

 that could go to that realm or reimbursement? I'm -- I'm just

 brainstorming but I'm curious if that's something you all would

 be willing or have already taken up?

 MS. HUDSON: Yeah. You know, we haven't had that

 conversation, but we definitely can. And I think, you know, we

 have some funding that's reserved and very generally for SOE

 support, especially around implementation, so I think that's

 certainly a conversation we can have. We meet with them

 monthly to just sort of gauge as things change out in the in

 the ecosystem, the certifier network, you know, that we can be

 a little bit more nimble with this cooperative agreement. So.

 BD. MEM. LEWIS: Let us know if a recommendation from

 the board could be helpful in those conversations.

 MS. HUDSON: Thanks. Yeah, I will.

 CHAIR POWELL-PALM: Quickly, just a question for you,

 Ellie. For those who are joining us next week in Providence, 
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 what's happening on Wednesday night?

 MS. HUDSON: Well, you're cordially invited to join

 ACA and an alphabet soup network of cohosts that I'm -- because

 I'm not reading it right now, I'm going to -- I don't want to

 skip anybody, but ACA and a number of cohost organizations

 invite you to join us at -- for a Happy Hour reception at

 Bayberry Beer Hall. So, we'll provide a couple of drinks, and

 lots of food. I'm always nervous doing Happy Hours, that you

 have to have a lot of food there because people haven't had

 dinner yet. So.

 CHAIR POWELL-PALM: Wow. Well, thank you for

 hosting.

 MS. HUDSON: Yeah.

 CHAIR POWELL-PALM: We're excited to join you.

 MS. HUDSON: You can see a link -- I don't know if

 it's -- if we actually put a link on the ACA website, but you

 can also e-mail me or any of the ACA team, if you want to

 register to attend. Thanks.

 CHAIR POWELL-PALM: Perfect. All right, thank you.

 See you next week.

 Next up, do we have Sarra Jahedi on the call? Are we

 seeing her, Michelle?

 MS. ARSENAULT: We are not seeing Sarra. Let me just

 double check once more. Nope, I don't see her, Nate.

 CHAIR POWELL-PALM: Okie doke. Then we're going to 
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 jump to Mark Lipson, followed by Jay Feldman Dan Langager, and

 then Brian Baker, and then we're going to break folks. And I

 never say we're behind because we are exactly where we should

 be with how good the conversation's been.

 But Mark, please go ahead.

 MR. LIPSON: Hi, Nate. Hi, everybody. Thank you for

 all your incredible -- incredibly hard work. I'm a member of

 Molino Creek Farm where I've been for 40 years. Molina Creek

 Farming Collective. I do have a consulting practice.

 Currently doing some work with CCOF, the Heartland Health

 Research Alliance, and the -- the Wolfpack Associates. I'm

 also a pro bono affiliate of the Center for Agroecology at

 University of California Santa Cruz, where I'm nurturing the

 seedlings of an organic agroecology policy program.

 I want to cover real quick inerts, residue testing,

 transition partnerships, Climate Smart Verification, and the

 status of my former job at USDA as the organic policy adviser

 to the Office of the Secretary.

 On inerts, I just think it's very, very clear all

 inerts have to be declared; cannot remain hidden behind

 proprietary confidential information and have to be reviewed by

 the board. So, I support the comments of NOC. I'll point you

 to the written comments recently from Dr. Charles Benbrook, Dr.

 Brian Baker, and others, and I support Terry Shistar's comments

 just presented. 
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 And just a week ago, EPA, you know, issued a denial

 of a petition from Center for Food Safety for review of all

 inerts. Made it very clear that they don't have any interest

 in holding up their end of the statutes that govern their

 responsibility for regulating inerts, and the USDA and NOP

 can't be hung up by EPA's failure. So, the obsolescence of

 List 4 is really kind of a red herring.

 On residue testing, I agree with the assertion that

 better -- a better system for the whole program is more

 important than increasing the amount of testing per se. What's

 needed is a unified system with bulk lab contracts to reduce

 the cost for everybody involved, create a common protocol, and

 in doing so create the ability to distinguish across the whole

 industry the hotspots of actual contamination from the small

 hotspots of increased ability to detect ever smaller amounts.

 So, I ran out of time, but I'll just very briefly

 say, there's nobody in the job that I previously held, and

 which was previously held by Marni Karlin at USDA. That's a

 big problem for Climate Smart Verification, for transition to

 organic, and a number of other things. Somebody --

 CHAIR POWELL-PALM: Thank you.

 MR. LIPSON: -- needs to step up and be willing to

 serve in D.C. and do that job. Thanks.

 CHAIR POWELL-PALM: Thank you, Mark. We've got some

 questions for you, so I don't mean to cut you off, but want to 
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 get -- get those here.

 MR. LIPSON: Yeah.

 CHAIR POWELL-PALM: Brian, go ahead.

 BRIAN CALDWELL: Yeah. Thanks so much, Mark. I was

 hoping that very briefly you could cover the rest of your

 topics because it seems like you were going to run out of time.

 MR. LIPSON: Well, what I wanted to say about

 transition to organic program is that it, you know, it's two

 orders of magnitude more resources than we ever had, you know,

 10 years ago for doing anything around our organic transition,

 but it doesn't have a goal. USDA has chosen to launch this

 program without actually having a goal, and I think that's

 problematic, and I think that, you know, maybe the NOSB could

 be a factor in getting the department to do that. Or

 engaging -- you know, creating a dialogue that would help the

 industry or the community create a goal.

 On the Climate Smart Verification, I think it's

 really, really highly problematic how that's being pursued, and

 we need to get organic, you know, integrated directly, not

 just, you know, sort of a secondary aspect of whatever Rube-

 Goldberg-counting-the-carbon-angels scheme is going to arrive.

 So, again, you know, maybe the NOSB can help conduct a dialogue

 that would communicate that directly to the high -- highest

 leadership at USDA.

 Thanks for the question, Brian. 
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 CHAIR POWELL-PALM: Allison.

 BD. MEM. JOHNSON: Thanks so much, Mark. I had a

 question already, and your answer just spurred another one, so

 bear with me.

 The first -- I really appreciate you bringing up

 inerts, and then the need to deal with this issue promptly and

 thoughtfully. And as someone who's worn a lot of different

 organic hats, I'm wondering if you have any advice or

 suggestions for us on how to deal with this sort of like

 cumbersome topic and the actual process of getting these

 materials reviewed?

 And then my second question is, what -- what should

 we set as the goal for TOPP?

 MR. LIPSON: I don't -- on the second question, yeah,

 I think it's -- there's a lot of different variables, and the,

 you know, the market development part of it, you know, which

 isn't well integrated with the partnerships program, it is

 really, really a key thing. I just think there's important

 economic analysis that could be done. ERS should be part of

 this process to establish a, you know, realistic but ambitious

 goal that's differentiated in different segments of the supply

 chain. And the emphasis absolutely needs to be on domestic

 production. You know, we're -- we're relying on imports;

 that's where the emphasis of the goal ought to be.

 And your first question, I'm sorry, Allison, on 
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 testing?

 BD. MEM. JOHNSON: Any advice for reviewing the

 inerts kind of process; how do we tackle getting these

 materials reviewed?

 MR. LIPSON: Well, I think Terri's suggestions were

 very constructive and totally plausible. I do think, you know,

 the number is -- is not astronomical.

 You know, to give the benefit of the doubt to

 program, the I saw the ANPR as a cry for help from the

 community to do something at the legislative level, you know,

 which they can't really mention or suggest, to get them the

 resources to do it and/or, you know, get them off the statutory

 hook of the obsolete EPA list. Does that make sense?

 BD. MEM. JOHNSON: Yeah. Thank you, sorry; I am

 furiously typing notes for me. Appreciate it.

 CHAIR POWELL-PALM: Amy, please go ahead.

 SECRETARY BRUCH: Yeah, Mark, thanks for joining us

 today.

 I just wanted to dive in deeper on something you

 mentioned in regards to residue testing. You mentioned we

 needed a better system as a whole, common protocols, a unified

 system with bulk lab contracts, and then you mentioned the

 ability to distinguish the hotspots of contamination.

 So, that last one, I wanted you to elaborate on that

 further; what -- what do you think are the best methods to 
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 distinguish these hotspots of contamination? 

 MR. LIPSON: Well, we saw in, I think it was 2018

 maybe, Consumer Reports using the work of Dr. Benbrook and the

 Dietary Risk Index that he compiles from the USDA residue

 testing programs, and fruits and vegetables, certain fungicides

 showing up on a lot of organic spinach. You know, that's an

 example.

 SECRETARY BRUCH: Um-hum.

 MR. LIPSON: Wasn't -- didn't appear to be a matter

 of fraud but, you know, a systemic problem of, you know,

 colocation of supply chains, you know, or something in the

 handling chain. That's very, very different from what I think

 a lot of certifiers are dealing with of these, you know, spot

 flashes of contamination that show up because the levels of

 detection are -- are constantly going down. And -- but we

 don't have a way, besides the analysis from, you know, USDA's

 market sampling program, that only, you know, includes a

 portion, you know, a fraction of the organic sector with it.

 We don't have a way of combining all the results from all the

 certifiers. I think this is part of what Bruce -- or excuse

 me, Michael Crotser was talking about, you know, where's the

 analysis of what the residue program -- residue testing program

 as a whole shows? What -- what are the patterns? We need to

 be able -- you know, we would be able to see those patterns.

 They would be illuminated if we had a combined program of all 
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 the certifiers, not necessarily dictating what they each have

 to test for, but where all the results were going into one

 common system. But right now, they use different labs, they

 use different protocols, the results can't be compared.

 So, that's the direction that it needs to go in.

 Does that make sense?

 SECRETARY BRUCH: Yes, it does. Thank you, Mark.

 Appreciate that.

 CHAIR POWELL-PALM: All right.

 MR. LIPSON: And I will be very happy to see you all

 next week.

 CHAIR POWELL-PALM: Looking forward to it. Thank

 you, Mark.

 MR. LIPSON: Thanks.

 CHAIR POWELL-PALM: Thank you for your comments.

 Next up, we have Jay Feldman, then Dan Langager,

 Brian Baker, and then we break. After the break, we have

 Kailey Williams, and then Julie Barton.

 Jay, please go ahead.

 MR. FELDMAN: (No audible response.)

 MS. ARSENAULT: Jay, you're on mute.

 MR. FELDMAN: oh, boy. Hi, I'm Jay Feldman,

 executive director of Beyond Pesticides, former NOSB member.

 Thank you for your service on the NOSB.

 Beyond Pesticides is bridging consumer, farmer, and 
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 environmental interest and taking on the challenges of our

 existential crises, and environmentally induced diseases,

 biodiversity collapse, and the climate emergency.

 We believe deeply in the value of organic land

 management, including food production, is key to meeting these

 challenges, but this is only the case if the NOSB is a steward

 of the USDA organic label, ensures the integrity of the NOSB's

 oversight role, and exerts its authority as intended by

 Congress. The NOSB decisions this session, National List

 management, and Standards guidance are key in the process that

 establishes organic integrity. This process by design was

 borne out of ineffective laws and standards governing clean air

 and water farmer protection and food safety; laws that have

 brought us to the brink of ecosystem collapse. Organic is the

 path forward to sustainability.

 With that said, there are critical issues before the

 board. Issues that intersect with the existential crises, and

 ones that define the future. Yes, organic is a small

 percentage of overall food production, but what this sector has

 established as a model for the path forward, so decisions that

 are now before the board are critical in that light. I'll

 highlight the critical intersections with several key issues

 before the board.

 You've heard and read our position on inerts. When I

 was an NOSB member, we reached a unanimous decision for 
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 streamlined -- a plan for review; this is now blocked by USDA

 and undermines integrity.

 OFA requires national listings "by specific use or

 application." Not enforced by USDA; undermines integrity.

 We must move away from petrochemical plastics as

 incompatible with organic and transition to alternative

 mulching cover and intercropping systems. No action undermines

 integrity.

 Reduce reliance on nonorganic ingredients, §205.606.

 The NOSB Hops decision nearly a decade ago taught us that

 organic supply is a function of demand. Similarly, organic

 guar gum, organic Locust bean gum are now used by a major

 organic processor. A failure to not relist -- a failure to not

 relist nonorganic versions undermines integrity.

 The liquid fish annotation adopted by this board is

 not being enforced by NOP with the comment, "Technical

 complexity of marine environment makes rulemaking on this topic

 problematic." This must be brought back to the board: NOP is

 undermining a critical ecosystem issue, board process, and

 integrity; an egregious failure that requires a board vote to

 not resist pending NOP compliance with process.

 Organic agriculture with deep farmer and consumer

 investment is cherished, as the leading edge of change required

 for a livable future. Please, don't let it be undermined.

 Thank you. And thank you again for your service. 
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 CHAIR POWELL-PALM: Thank you for your comments. All

 right, we appreciate you.

 MR. FELDMAN: Thank you.

 CHAIR POWELL-PALM: Next up, we have Dan Langager,

 followed by Brian Baker, and then we're going to take a five-

 minute break. After the break, we have Kailey Williams.

 Dan, the floor is yours.

 MR. LANGAGER: Great. Thank you so much. It's

 pronounced Long-au-ger (ph), but no worries.

 CHAIR POWELL-PALM: Thank you. I'm so sorry.

 MR. LANGAGER: Not the first time.

 Hello, everyone. My name is Dan Langager. I'm with

 the Northwest Horticultural Council, and we represent the

 growers, packers, and shippers of apples, pears, and cherries

 in the Pacific Northwest, who produce the majority of our

 country's organic palm fruit.

 I'd like to direct you to our extensive written

 comments, or the Pacific Northwest Tree Fruit Industry's

 perspective on the various Sunset materials before the board,

 as well as on the inert ingredients issue. But today I'll

 highlight some of the materials under crops that are of

 particular importance to organic tree fruit growers.

 Ethanol and isopropanol alcohols; these are critical

 tools for orchardists to decontaminate the lines of their

 irrigation systems, and to disinfect a variety of on-farm 
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 implements, like cooking.

 Lime sulfur and elemental sulfur are used by the vast

 majority of organic tree fruit growers. Lime sulfur helps

 control diseases, like blight, mildew and scab, and various

 orchard insect pests, especially any that may have over winter

 [sic].

 Elemental sulfur is an essential tool for organic

 tree fruit production for controlling pest mites that damage

 leaf tissue, disease pathogens like scab and brown rot. And

 it's the only material organic growers can use in their on-farm

 sulfur burners, which help us deal with the often alkaline

 waters here in the Pacific Northwest, adjusting the soil pH to

 ensure better nutrient uptake and water penetration.

 Plastic mulches and covers. All right, so these

 offer numerous tree fruit production benefits. We use them for

 bird nets, windscreens, shade cloths, weed materials. Leaf

 hopper pests in cherry orchards vector the causative pathogen

 of Little Cherry Disease, which is now epidemic in Washington

 State, but by covering the broad leaves and the other leaves,

 the weed maps have proven a significant useful deterrent,

 reducing leaf hopper numbers by 80 to 90 percent. Ground

 covers can be used to reflect light up into the tree canopy;

 this is done early in the season to help promote bloom, and

 then before harvest it helps the fruit gain some additional

 color and maturity. Drape Nets are deployed to keep the brown 
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 marmorated stink bug and other insect pests out of the Orchard.

 And netting and shade cloth can be used for protection from

 hail and sunburn.

 The cost to organic growers to set up these nets in

 their orchards is significant. An investment of hundreds of

 thousands of dollars in infrastructure and maintenance. And as

 the subcommittee has noted, removing plastic mulching covers

 from the National List would not actually prohibit their use.

 This annotation allows growers to work with their certifiers to

 ensure that their system meets OFA and best practices

 standards.

 And then finally on the inert ingredients, just to

 state that -- that their importance, it cannot be overstated,

 really, it's -- as they are part of every chemistry used in

 organic production. And so, we encourage the board to take a

 deliberative scientific approach to any changes to the listing

 of the inerts that does not add to the workload of the NOSB or

 put the availability of products critical to organic food

 production at risk.

 I just want to give a big thank you and huge kudos to

 all the board members at the NOSB. Thanks so much.

 CHAIR POWELL-PALM: Thank you for your comments. We

 have a question for you from Amy.

 SECRETARY BRUCH: Hi, Dan.

 MR. LANGAGER: Hi. 
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 SECRETARY BRUCH: Thank you for your time today. Hi.

 I just --

 MS. ARSENAULT: Amy, you just muted.

 SECRETARY BRUCH: Oh, goodness.

 MS. ARSENAULT: Okay.

 SECRETARY BRUCH: Not sure how that happened but,

 okay, we'll start over.

 Thank you, Dan, for your comments. I just wanted to

 confirm your organization's stance on the petition substance

 potassium sorbate.

 I saw that you provided comments in the spring in

 support of potassium sorbate as a disease control, as it's

 petitioned for disease control, but it didn't any comments this

 go-round submitted from your organization, so I just wanted to

 confirm that -- that you're still in support of that substance

 or if anything changed.

 MR. LANGAGER: We left it out of our comments this

 round because after going back to our growers and some of our

 other consultants, it might not be the right time for that. We

 didn't get a lot of feedback that it would provide a

 significant change or a significant benefit. We know that some

 of the subcommittee deliberations were pretty on the fence one

 way or the other and so in order to fully defend that, in order

 to -- to provide a -- a full scope and a full picture I think

 we would need to go back and do some more deliberation and --
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 and figuring out of what it -- exactly how it could affect --

how it could benefit the tree fruit industry.

 SECRETARY BRUCH: Okay, thank you. That's helpful.

 I -- I did see it more extensive. It seemed like comments

 surrounding powdery mildew on your elemental sulfur submission.

 MR. LANGAGER: There are other -- yes, there are

 other things like that we can depend on.

 SECRETARY BRUCH: My -- question then. Okay, great.

 Thank you so much.

 MR. LANGAGER: Thanks.

 CHAIR POWELL-PALM: Thank you, Dan. We hope to see

 you next week.

 MR. LANGAGER: We'll see you there. Can't wait.

 CHAIR POWELL-PALM: All right, take care.

 Last up before our break is going to be Brian Baker.

 after our break of minutes, we're going to have Kailey

 Williams, Julie Barton, and then Harold Austin.

 Brian, the floor is yours.

 MR. BAKER: Brian Baker, Belcairn Concerns.

 First, I want to thank the NOSB and NOP for the

 opportunity to comment and express gratitude for all your hard

 work. The opinions expressed are my own and do not necessarily

 reflect those of my clients or -- of any organizations for

 which I serve in a governance or policy setting capacity. My

 comments are on Sunset, and specifically on the request for 
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 comments on inert ingredients formulated in pesticides used for

 organic production; a subject on which I've worked since 1988.

 Please understand that every ingredient in a

 pesticide formulation has a function and serves a purpose. For

 any synthetic substance to be added to the National List, the

 OFA requires they must both be necessary for organic production

 and handling and meet the OFA criteria. The burden to prove

 necessity and compatibility is on those who seek to use these

 synthetic substances. The NOSB should not, and in my opinion

 cannot, proceed until there is full public disclosure of all

 substances that are allowed or proposed to be allowed in

 formulated pesticides for organic production.

 The OFA requires that synthetic substances be on the

 National List be necessary and -- and meet the OFA criteria.

 The NOSB's recommendations based on these requirements need to

 be taken into account: what formulants are necessary to

 deliver pesticide; what specific substances are needed; why

 they're needed; and how they meet the criteria. EPA clearance

 is a necessary, but not a sufficient condition, to put -- put

 the inserts on a -- on the National List.

 Many formulants have biological activity and toxicity

 profiles. The -- and greater toxicity than the actives

 themselves. They often work through synergy, through increased

 biological uptake by providing a longer window of biological 

 activity, increased persistence of -- of the active 
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 ingredients. Growing body of scientific evidence shows that

 formulated products are more toxic and have greater adverse

 effects on the environment than the active ingredients alone.

 Biological and chemical ecosystem are part of the 2119(m)

 criteria. We need to know what we're talking about before we

 can talk about it. The ANPR public comments showed a consensus

 that most of the formulants used for organic production are

 necessary and meet the criteria. A relatively small, in my

 opinion, manageable number should be the focus of Sunset. 

The NOSB has a statutory mandate to work with EPA and

 the manufacturers. Full public disclosure has legal precedents

 that show the public interest of knowing what's in pesticides

 outweighs the need for confidentiality. The USDA and EPA

 collaborated on implementation in the past. Please consider my

 written comments. And I call attention to Heartland Health

 Research Alliances' comments to the ANPR. 

I welcome your questions. 

CHAIR POWELL-PALM: Thank you. We have some

 questions for you. 

Brian Caldwell, please go ahead. 

BD. MEM. CALDWELL: Thanks, Brian. It's great to

 hear your comments. I'm very excited that we can address this

 issue which, is just so difficult, but so -- so important. And

 I guess I-- I'm very pleased to hear you strongly support the 

 disclosure of -- of inert ingredients. I think that makes 
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 sense.

 Do you think that they should -- that -- that that

 sort of disclosure should be -- needs to be tied to the actual

 product? Or can a company just ask for a, you know, sort of a

 put it on a blanket list and say we -- we would like this

 material -- or we disclose this this material, that we use it,

 but not tie it necessarily to a -- to a specific product? I'm

 just -- I'm curious about that, especially because I don't want

 companies to be just like disclosing a whole bunch of things

 that they would like to use but they're not necessarily using

 right now.

 MR. BAKER: Well, yeah. I -- I think they can be --

you -- you don't have to link the two, but I think that some

 form of justification is needed.

 I -- you know, ideally pesticide formulations would

 be like shampoo bottles; you know, you don't need to know the

 percentages, but you need to know what's in -- what -- what

 the -- chemicals are -- are in there. Add I -- I think that

 for the purpose of evaluating under the 2119(m) criteria that

 one needs to be able to at least assess some of these -- some

 of these questions, such as the interactions and what -- what

 synergistic effects there might be. What effects or impacts

 there might be on nontarget organisms. So, you know, I -- I

 think that -- the process will be self-limiting. 

I could be wrong. I mean, we've -- you know, we 
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 greatly underestimated the petition process in the past and we

 could find ourselves overwhelmed with petitions for people

 who -- who want to use things on speculation that they don't

 really need or, you know, they just want to experiment with,

 and they may not end up with in the final formulation.

 But I will say that manufacturers and formulators

 would like a larger list of substances to work with, and if

 they're formulating for the organic market, they don't want to

 go to the trouble of field testing and then find out oops, it's

 not going to -- it's not going to fly. So, I -- I think

 there's, you know, there's -- there needs to be give and take

 and -- and I'm -- what I'm asking for, really, is what's in --

 in the statute; that the NOSB needs to work with the

 manufacturers. It's -- it shouldn't be an adversarial process.

 It should be a collaborative process, open and transparent, and

 you know, a lot of these are are -- are intended to reduce the

 amount of active that's used. They -- they do have some

 beneficial effects, and that needs to be weighed in, as well.

 So, you know, it's -- it -- it's a matter of getting

 the information and -- and figuring out how to proceed from

 there.

 BD. MEM. CALDWELL: Yeah, thanks Brian.

 CHAIR POWELL-PALM: Allison, please go ahead.

 Followed by Nate. 

 BD. MEM. JOHNSON: Thanks for taking the time to be 
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 here, Brian, and for your comments, both written and oral. 

Picking up on the -- the to how many products are we

 dealing with question. Terry presented an estimate, sort of in

 the one to two hundred range earlier. 

Does that sound to you like the -- the ballpark that

 we're working with? And is there any way that you'd recommend

 prioritizing or, you know, spreading this over time to make the

 process manageable? 

MR. BAKER: I -- I think the key is really to look to

 EPA. I mean, it's not my job or Terry's job or your job to

 figure out how many substances we're talking about; it's the

 people who want to have those substances allowed for use.

 That -- it's their job to come forward and say, here's what

 we -- here's what we use, here's what we want to use, what do

 you think? 

I, you know, I came up with a smaller list than Terry

 did based on certain assumptions and based on perhaps an overly

 optimistic view of how the USDA and EPA could collaborate and

 find some common ground on taking certain things off the table

 and off of the NOSB's workload but, you know, I think -- I

 don't want to call it worst case scenario, but I think Terry is

 sort of at the top end of -- of what the list is. I -- I think

 we could be down to like 20 or 30. But yeah, I mean it's we --

 we need to know what we're talking about before we can come up

 with an estimate; otherwise, we're just, you know, whistling in 
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 the dark.

 CHAIR POWELL-PALM: Nate, please go ahead.

 BD. MEM. LEWIS: I asked Terry this question, and

 I'll ask it -- you, as well; is there anything unique about

 inerts, particularly in contrast to excipients that require

 their individual listing? I'm just -- I'm worried we're

 unleashing a beast, right --

 MR. BAKER: (Laughs).

 BD. MEM. LEWIS: -- and I know --

 MR. BAKER: The best is out. No. I mean, there - -

this is --look, I was -- you know, I was at CCOF in 1988, and

 that was -- that was like when the dam burst on inerts, okay.

 They are different. They're different for a lot of different

 reasons, and they're -- they're put in the statute in a unique

 way for a reason. Let's not forget that history. Let's not

 forget what has gone on with inerts since before there was an

 OFA. Since before there was an NOP. I mean, this is -- this

 is a thorny issue. This has a lot to do with the -- the way

 that so much of the OFA was driven by the Alar crisis and

 the -- the way that pesticides are regulated. And we have --

you know, I -- I want to echo what Mark Lipson said earlier,

 this is a cry for help. It's -- we're dealing with obsolete

 lists that the Food Quality Protection Act happened six years

 after OFA, okay, and that gave EPA a mandate to rereview all

 chemicals used in pesticides and do a risk assessment on using 
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 different models on the inerts that they had. You know, the --

the four list process came out of the 1980's when there were

 known carcinogens being used as inert ingredients in

 pesticides, and the EPA didn't -- didn't ban them, you know,

 willingly; they had to be dragged into it kicking and screaming

 so, you know, this is -- is a long complicated issue with a lot

 of history that is very different from the other things we see

 on the National List.

 And they are different from excipients in animal

 drugs. There's a lot more disclosure. Veterinarians have a

 lot more access to the information on excipients than pest

 control advisors have on the inert ingredients used in

 pesticide formulations, with ancillary ingredients and -- and

 food processing and food additives. There's also, because of

 allergens, because of other food safety issues, there's a lot

 more access. Inerts are -- are misnamed. Other than helium or

 argon, you -- you're not dealing with anything that's truly

 inert. They're -- they all are functional. They all are

 active. They all have a purpose, and they all need to be

 disclosed.

 CHAIR POWELL-PALM: And with that, we thank you for

 your comments, Brian.

 We're going to go to our break. We're going to come

 back at 15 minutes after the hour, and when we come back for

 [sic] our break, we're going to start with Kailey Williams. 
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 Kailey, if you're on the call, could you please just

 jump in the chat and let yourself be known. If Kailey's not

 here, then we'll go to Julia Barton, Harold Austin, and then

 Tracey Dion.

 All right, see you all back at 15 after the hour.

 (Whereupon, a brief recess was taken.)

 CHAIR POWELL-PALM: Julia, please go ahead

 MS. BARTON: Can you all hear me?

 CHAIR POWELL-PALM: We can.

 MS. BARTON: Okay. You're gonna have to give me just

 one moment of grace here. I am -- just pulled into the cell

 phone lot at the airport, but I am with you now.

 Good afternoon. My name is Julia Barton with the

 Organic Farmers Association, and I'd like to share comments

 today on three topics.

 First, crop insurance. OFA appreciates the board's

 work on this important topic. OFA farmer members have a wide

 range of experiences with crop insurance and are eager to make

 crop insurance work better for organic farmers.

 A few points we want to highlight here include

 farmers need a way to manage risk due to genetic and pesticide

 drift contamination. If these situations could be recognized

 as a qualifying event for crop insurance, farmers suffering

 from loss wouldn't be required to identify a source, which

 isn't always possible. More support from USDA to protect 
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 farmers from these types of contamination and to deter the

 practice of drift is necessary.

 Secondly, OFA has identified the need for risk

 management within the organic dairy industry.

 For the past year, OFA has facilitated a national

 organic dairy farmer working group to identify farmer-driven

 solutions to the national organic dairy economic crisis. This

 farmer-led group has identified a strong need for the creation

 of a safety net program specifically for organic dairy based on

 organic specific milk and input cost data.

 Also, OFA asks that USDA's National Organic Program

 increase enforcement of the organic standards, including access

 to pasture requirements and the updated origin of livestock

 rules to ensure that all organic dairy farmers are following

 the same rules so that farmers are operating on an equal

 playing field.

 Next, residue testing. OFA agrees with the board

 that residue testing is an important tool for fraud prevention;

 however, organic is a process based standard as we've heard

 others note and so testing for residue must not be the standard

 for proving organic practices.

 Here we'd also like to mention that OFA supports

 efforts by state and federal agencies to help farms cope with

 contamination of soil and water by PFOS chemicals, including

 assistance with soil and water testing, technical assistance 
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 for determining whether farm operations can safely continue,

 and compensation for lost production and lost farm value due --

due to contamination. MOFGA has provided outstanding guidance

 and support to the farmer community in this arena. We know

 that PFOS contamination exists across the country and urge the

 NOSB and NOP to get ahead of the problem with more proactive

 strategies and support for farmers dealing with contamination.

 And finally, oral comments. OFA members would like

 to see the board return to allowing public stakeholders to give

 comments in person at NOSB meetings, starting with the

 Milwaukee NOSB meeting.

 The point of moving the meetings was to get -- give

 each region an opportunity to speak directly to the NOSB back

 in the day when that practice began. While the online

 testimony is important, and we want you to please continue that

 mode of communication, OFA farmers also see value in in person

 testimony. In short, we need both.

 Thank you for the opportunity to comment and for your

 service.

 CHAIR POWELL-PALM: Thank you for your comments. Amy

 has a question for you.

 SECRETARY BRUCH: Hi, Julia. Thank you for making it

 work and participating in our oral comment process, while

 you're -- while you're sitting in the cell phone lot at the

 airport. 
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 I wanted to ask about crop insurance. There --

 there's been some comments about plant dates and that organic

 farmers are interested in RMA extending plant dates,

 specifically. I wanted to know; do you think this is a

 regional concern? Or do you think it's a nationwide concern by

 all organic farmers on the plant date?

 MS. BARTON: That's a great question. I -- I imagine

 that planting dates requirements would have regional variation

 and therefore farmers who have noted that it's a problem for

 them have asked for kind of a -- a broader window so that they

 can essentially do more management -- thought management to

 determine when planting makes the most sense for their organic

 crops.

 We've also had organic farmers note in the past that

 the -- the delayed planting date that they used the year before

 is already factored into their risk management calculations

 because they were already -- it's already part of the annual

 production history, if that makes sense.

 SECRETARY BRUCH: Um-hum.

 MS. BARTON: So --

 SECRETARY BRUCH: Yeah.

 MS. BARTON: -- we're essentially double-penalizing

 them. So, I think if -- if we were to check in -- I mean, I

 imagine there is regional variation in terms of when people

 want to plant, but I think if we were to check in nationally we 
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 would find that what farmers want to be able to do is to do

 more of the thought management of the systems management that's

 required of them and have more flexibility to be accountable to

 that, rather than like a one-size-fits-all plug-and-chug model,

 which is what they're held to currently.

 SECRETARY BRUCH: Um-hum. Yeah, that sounds good.

 If -- if you don't mind, on that particular question, the --

the farmer folks that have commented to you and your

 organization, if we could kind of get just a location area that

 would be helpful, for my opinion, just to make sure it's --

it's not an -- just to understand if it's national or regional.

 MS. BARTON: You know, we can work on that, Amy. And

 I'll just take this opportunity to note that we will be working

 on that this winter with OFA farmers in kind of a -- a work

 group format. So, we'll circle back with you on that.

 SECRETARY BRUCH: Okay, perfect. Thanks, Julia.

 CHAIR POWELL-PALM: Thank you, Julia.

 Next up, we have Harold Austin, followed by Tracey

 Dion, and then Rafael Clemente.

 Harold, the floor is yours.

 MR. AUSTIN: Okay. Did we get unmuted okay?

 CHAIR POWELL-PALM: Loud and clear.

 MR. AUSTIN: All right. Thanks Nate. Thanks

 everybody on the NOSB. My name is Harold Austin. I am a

 former member of the NOSB, as well as a lifelong member of the 
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 Tree Fruit Association and industry here in the Pacific

 Northwest.

 I'd like to thank you for the opportunity, not only

 to present my comments here this morning, but also to thank you

 for your service on behalf of the organic community and all of

 the organic stakeholders that comprise it. Thank you guys for

 all that you're doing for us.

 Please refer to my written comments that I've already

 submitted, as well as those of the Northwest Hort Council, for

 a more detailed list of our comments provided.

 For handling, I support the continued listing of

 phosphoric acid, nitrogen, and ethylene. For crops, I would

 like to take and -- froze up here -- I would like to voice my

 support for the continued listing of the two alcohols currently

 under review, the plastic mulches and covers, liquid fish

 products, ethylene, elemental sulfur, lime sulfur, sulfurous

 acid on-farm generated.

 As I mentioned in my written comments, and comments

 before, I can't stress enough the importance of lime sulfur in

 our organic tree fruit production. I do not support, as the

 crop subcommittee mentions in their document, the request for a

 work agenda item to establish an annotation for regulating the

 rates and timings of the use of lime sulfur in organic crop

 production. I've worked with this material for more than 40

 years and have firsthand experience with its impact on our 
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 beneficials, which I might point out is something that we work

 very hard and go out of our way to protect because it's our

 first line of defense in our farms against our -- the -- the

 invasive insects.

 We might see a slight knockdown after an application

 but nothing that is not completely recovered within a very

 short period of time. In fact, that -- I'll point out the fact

 that our -- all of our bee colonies, our hives are out there in

 the field when we make our applications, and our beekeepers are

 very well aware of this and they're quite comfortable with us

 leaving them there.

 Regulating the timings and the rates is the job of

 the EPA, and the label data packs that they receive; not that

 of the NOSB. You don't know the materials and how we use them,

 the rates, the timings, nor the thought process that goes into

 each application before -- and decision before we make an

 application. Please, let the EPA do their job.

 Also, in your subcommittee notes, and I do read those

 by the way, you raised concerns regarding on-farm sulfurous

 acid production. To reiterate previous comments, we treat the

 water via the use of onsite sulfur burners to both lower the pH

 of the water and ultimately that of the soil, and also to help

 remove the calcium carbonate particles from our fruit finish,

 as well as interfering with the capability of the leaves for

 photosynthesis. This is a safe product, and the only true 
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 alternative would be to use actual sulfurous acid and inject it

 into our water systems, and we really don't want to go there.

 I would also like to express the hope that a path

 forward on the inert ingredients will emerge in the near

 future. I would like to urge caution as you forge ahead so

 that there's not a disruption in the allowed use for other

 various materials that our crop production currently rely on.

 I have the utmost confidence that a solution will be figured

 out.

 Thank you for all that you do for us.

 CHAIR POWELL-PALM: Thank you for your comments.

 Any questions for Harold?

 (No response.)

 CHAIR POWELL-PALM: All right, we appreciate it

 Harold. Oh, actually sorry; Logan, please go ahead.

 BD. MEM. PETREY: I -- yeah, I was going to see how

 many comments because this actually not pertains [sic] to

 anything currently on the list, but just the -- about the --

 changing the pH in the water, because we were reviewing this --

the carbon dioxide, you know, for the irrigation use and didn't

 know if you ever had an interest in using that product instead

 of sulfur burners? Or, you know, looking for alternatives in

 that way?

 MR. AUSTIN: You know, we -- we use the sulfur 

 burners both -- you know, we're -- majority of our crop 
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 production is organic and there -- we've got a little bit

 that's still conventional, but we've used the sulfur burners

 onsite so long we've really got a lot of confidence in the

 capability of it. It's a safe -- it's a safe application use

 of 99 percent pure sulfur, and -- and our workforce are

 comfortable with it. I mean, they -- they know how to use it

 safely. They know how to -- you know, and we see the benefits

 of it. It's probably the most effective material we've seen

 for keeping the calcium carbonate off, you know, because this

 is more than just our lines, it's also about getting the

 calcium carbonate off of our fruit because in the -- here in

 the Pacific Northwest, we have a lot of high count -- calcium

 levels, and so if - if we don't treat for it, because we -- we

 have to cool our fruit to keep it overhead, to keep it from

 getting burnt when we -- we get hot in the summer, so it's --

 that's really one of the main functions that we're doing, is to

 keep the fruit from sunburning. But then the additional impact

 is we're reducing the pH of the water, which starts out as

 around 8.4, 8.5, and we're getting that down into the -- the

 low 7.2, sometimes maybe a little bit lower, so we're -- we're

 getting, you know, lower pH water. We're -- it's -- and it's

 helping with the penetration of everything else that we're

 using.

 There's so many benefits of using the -- the sulfur 

 burners in this application that it's not just a, you know, not 
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 narrow focus, but it's -- it's a pretty wide scope of the

 benefits that we see in our organic crop production.

 BD. MEM. PETREY: Thank you.

 MR. AUSTIN: You're welcome.

 CHAIR POWELL-PALM: Jerry, please go ahead.

 BD. MEM. D'AMORE: Thank you.

 Hey, hello, Austin -- Harold. How are you?

 MR. AUSTIN: I'm good. Yourself?

 BD. MEM. D'AMORE: Good. Appreciate that. Were I to

 characterize what I find to be the most consistent criticism of

 the sulfurous acid, it would be that it can be used to mask

 poor soil conditions and/or practices. Could you respond to

 that?

 MR. AUSTIN: Yeah. I -- we're working with poor

 soil. I mean, we're -- we're doing everything organically

 possible to increase our organic matter. We're dealing -- but,

 you know, the -- our -- our biggest problem is it's not the

 soil itself, but it's the irrigation water. The irrigation

 water is coming in. It'll start the season at 8.2. By the

 time we get to the end of the season, it's bounced up to about

 8.5. So, we're dealing with an extremely high pH water,you

 know, and we're -- we're talking not -- not just a couple

 acres; I mean this is that whole -- the whole geographic area

 out in the Columbia Basin. So, it it's not really poor soil,

 it's poor -- it's soil that's being impacted by the -- the pH 
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 of the water that we're putting on it. So, it's not masking

 anything, it's -- it's quite an improvement to the soil

 conditions and to the -- the soil beneficials that we find when

 we -- we start looking around. So, it's --

 You know, now I, you know, maybe there's areas but

 for our, you know, the areas that we work with, and I used to

 get a crop consultant, and I work with a lot of growers, you

 know, and a lot -- and thousands of acres, and it's -- it's

 beneficial to our -- our organic crop production. As well as

 conventional crop production, they also use it because of the

 safety of the process.

 BD. MEM. D'AMORE: Thank you. Thank you for the

 answer.

 MR. AUSTIN: You're very welcome.

 CHAIR POWELL-PALM: Thank you, as usual, Harold, for

 your wonderfully considered questions and answers, and we look

 forward to seeing you in the meeting next week, I hope.

 MR. AUSTIN: Thanks, Nate.

 CHAIR POWELL-PALM: All right, next up we have Tracey

 Dion, followed by Raphael Clemente, and Kestrel Burcham. If

 Raphael is on the phone, please make yourself known in the

 chat. I don't think we're seeing you yet.

 (No response.)

 CHAIR POWELL-PALM: Tracey, welcome. The floor is 

 yours. 
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MS. DION: Yes, thank you. Thank you. 

My name is Tracy Dion, and I, along with my family,

 proudly raise certified organic lambs, cattle, oats, corn, and

 alfalfa in the heart of Terri, Montana. I'm here today to

 address the Honorable Chair of the National Organic Standards

 Board and all of its esteemed members. It's truly an honor to

 have this opportunity to speak my mind. 

What makes this moment even more remarkable is the

 level playing field that the virtual platform provides. In

 today's NOSB world no monied organization can drown out the

 voices of hard-working individuals like me by paying to fly

 their people to give their comments in person. I really hope

 that the board keeps all public comments virtual in the future,

 ensuring equitable access to the board for all. 

Ten years ago, my husband Jackson and I took over our

 farm from my parents. Back then, it was a little more than

 dirt having been farmed heavily for conventional sugar beets

 for about 60 years. 

In 2017, we achieved certified organic status and

 since then our soil has undergone a miraculous transformation.

 We now have earthworms. We rotate nitrogen fixing crops that

 nourish the soil. We grow cover crops that lock carbon deep

 underground helping fight climate change. And we do it all

 without pesticides, antibiotics, GMOs, or herbicides. And

 after all that work we have buyers who will pay a premium for 
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 our crops. That is the miracle of the organic seal. But if

 our operation is going to grow, and other farmers are going to

 transition to organic, we need help spreading the message about

 organic to consumers.

 I raise some dang good tasting organic lamb on our

 farm. I don't use hormones or pour ons, and the manure from my

 livestock supports my crops. It's a great system and a great

 product, but the problem is I can't find a market for my lambs

 that cares about the organic status because of consumer

 confusion. I literally heard consumers ask does it even matter

 if it's organic?

 Organic farming represents the only refuge in our

 food system against harmful pesticides and herbicides. It's

 the only federally enforced standard that guarantees all

 growers are producing to standards written in rule. Moreover,

 it's the most climate smart production system. It's high time

 we start singing the praises of organic from every rooftop.

 I know most consumers would choose organic if they

 knew that every dollar they are buying clean food that's been

 inspected and that's better for the environment, but spreading

 this message to every American consumer is a big task. This is

 where we need the invaluable assistance of the USDA. I am so

 excited about the investments the USDA is making in the organic

 transition and -- Transition Initiative but we can't stop

 there; we need the USDA's agricultural marketing service to 
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 take the lead in educating consumers about what the organic

 seal means from grocery store shelves to the school lunchrooms.

 I imagine one day seeing the memorable "Got Milk?" placed right

 next to a poster explaining the attributes of organic to school

 kids throughout the country. Thank you.

 CHAIR POWELL-PALM: Thank you, Tracey. I so -- oh my

 gosh, I so appreciate you, and I think we all appreciate

 farmers. Thank you for taking the time and thank you for being

 able to make -- make it today. We have some questions for you.

 First up, Kim. Please go ahead.

 BD. MEM. HUSEMAN: Hi, Tracey. Thank you --

 MS. DION: Hi.

 BD. MEM. HUSEMAN: -- for joining us today. It's

 always good to hear from livestock producers, so I'm glad that

 you joined us, especially from the lamb front; I don't think we

 get -- we don't get that voice.

 Can you expand on what your outlets are, I'll use the

 sensitive word of "harvesting" your animals? And what are your

 current practices; are you doing direct to consumer? Or what

 are the outlets that you have available today?

 MS. DION: So, at this moment in time, there is a state

 inspected facility that's about 2-1/2 hours from me in Ekalaka,

 through the Montana Legacy Ranch. The -- the issue becomes

 finding the markets for organic lamb, and -- and when you sit

 down and do the math on it, it's a lot of work and you come 
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 back to the same sort of profit margin, so I'm working on it.

 I guess. I -- you know, it's something that I would really

 like to pursue more. I think that there's an opportunity

 there, but at this point, you know, it's -- it's getting the

 value of organic -- of the organic label on to that lamb that

 is going to make all the difference.

 BD. MEM. HUSEMAN: Okay, awesome. Thank you for your

 response and good luck.

 MS. DION: Thank you.

 BD. MEM. HUSEMAN: And then I'll send you my address

 because I'm interested in some of your products.

 MS. DION: Perfect. Okay, thank you.

 CHAIR POWELL-PALM: Allison, please go ahead.

 BD. MEM. JOHNSON: Thank you.

 Thanks so much, Tracey, for being here. Kim kind of

 asked my question, so I'll ask follow-up.

 It sounds like you do have access to processing

 that's reasonably workable, but it's the -- the market that is

 a challenge, and I'm curious if you have a sense of whether

 your costs are higher and make your price point challenging?

 And the -- the flip side, if there are practices that you're

 like competition in the sector use that make it sort of

 impossible for you to compete? I'm thinking about sort of

 antitrust and competitive market issues that USDA is taking on 

 separately from organic but that are really interrelated. 
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 MS. DION: I don't know that I've gotten that far into, you

 know, antitrust issues. I think what I see, as far as

 competition goes, I see a lot of people that direct mark -- use

 direct marketing for their lamb and so, I'm not -- I'm not

 sure. I think I might have just forgot your long question, I'm

 so sorry.

 BD. MEM. JOHNSON: I'll ask it more directly. I tend

 to go on.

 Do you think that there are practices that you're

 competing against that are not captured in the consumer price,

 whereas your costs are? Or you're taking on working cost that

 your competition is not?

 MS. DION: Well, I would say that anybody that's

 raising organic lambs has their hands absolutely full, and

 that's just the -- the amount of recordkeeping that goes into,

 you know, proving that something is organic, and sheep are not

 an easy market at all to deal with. So, you know, I think

 that -- that, you know, a higher price is definitely warranted

 for organic if someone's going to take on doing organic sheep

 production.

 Did that answer your question? 

 BD. MEM. JOHNSON: Yeah, it's helpful.

 MS. DION: Okay.

 BD. MEM. JOHNSON: Thank you. I appreciate it.

 CHAIR POWELL-PALM: I -- any other questions for 
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 Tracey?

 (No response.) 

 CHAIR POWELL-PALM: I have a question for you,

 Tracey.

 MS. DION: Okay.

 CHAIR POWELL-PALM: And thank you again for your

 comments.

 We have a document on CACS for geolocating and trying

 to make consistent how farmers turn in the information

 describing their fields. Now -- and Montana's interesting

 because they put the legal description of every field right on

 the certificate, and I was wondering how do you feel about

 that?

 MS. DION: I fully support that. And I would expect

 that on every organic certificate in the whole country.

 CHAIR POWELL-PALM: Amen. Thank you. Well, we

 really appreciate your time today. Thank you.

 MS. DION: Thank you. You guys are doing great work.

 Good job. Thank you very much.

 CHAIR POWELL-PALM: Thank you so much.

 Next up, we have Rafael Clemente; have we found him,

 Michelle?

 MS. ARSENAULT: We have not, Nate.

 CHAIR POWELL-PALM: Okay. We're going to jump to 

 Kestrel Burcham, followed by Becky Weed, if she's on the call, 
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 and then Casey Bailey. 

So, Kestrel, please go ahead. 

MS. BURCHAM: Hi. Hear me all right? 

CHAIR POWELL-PALM: We can. 

MS. BURCHAM: All right, thank you. 

Good afternoon, everyone, and also the NOP. My name

 is Kestrel Burcham. I am the policy director for the

 Cornucopia Institute. I'm here to report on what Cornucopia

 has been hearing from organic consumers on important policy

 issues. 

First and foremost, consumers are worried and

 confused about the lack of consistency in the organic

 marketplace. This lack of consistency leads to consumers

 questioning organic integrity as a whole. The specific areas

 this arises in most often include livestock animal centers and

 hydroponics. We hope that the organic livestock and production

 centers rulemaking will be finalized in -- soon. We believe

 this will cure a lot of the consumer confusion and lacking

 consistency in the organic livestock products, including eggs,

 poultry, and dairy, in particular. 

We do get questions from consumers about organic pork

 pretty frequently, as well, and we would like to see standards

 developed specifically for pork someday. 

Many consumers also see a distinct lack of

 consistency in organics because hydroponic production is 
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 allowed. The more educated a consumer is about the issues, the

 more concern they have for hydroponics, in general. The chief

 complaint we hear is that they understand organic produce is

 soil grown. When eaters hear "organic hydroponic production,"

 anything grown in soil -- without soil till the plant is

 harvested, exists and is growing in the marketplace, it calls

 into question their trust in the entire label. Cornucopia

 understands these consumers' concerns from a policy

 perspective. Organic hydroponics exists in a regulatory

 vacuum.

 From a legal standpoint, this is a precarious

 position to be in when the market relies on market distinction

 and transparency to exist. The NOSB has worked so hard to make

 multiple recommendations over the years concerning greenhouse

 and container production. This NOSB work was enriched by many

 years of deliberations, discussions, and efforts of public

 commenters; the NOP has thus far not enacted any of these

 recommendations.

 Consumer trust in the organic label, and they pay for

 an extra assurance that it provides a more healthful and

 environmentally friendly way of producing food, they also

 choose organic because it provides more benefits to -- to

 communities, including enhanced ecosystem services.

 Hydroponics does not improve ecosystem services and does not

 offer these same benefits. Despite the USDA's policy that the 
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 organic label is just a marketing term, the organic community

 is dedicated, and consumers know better. Research continues to

 back up the environmental and health benefits of organic food

 over conventional food. Hydroponics turns a lot of these

 benefits on its head. Just one reason consumers are concerned.

 Cornucopia does not believe this issue is settled.

 As it stands, the standards are not consistent. Maintaining

 consistencies is one of the main edicts of OFA. We urge the

 NOP, NOSB, and other stakeholders to review their organic

 agriculture soil-based position statement, which lays out these

 issues meticulously. To expand the organic marketplace, we

 need to improve integrity and transparency throughout the

 agricultural system. The whole organic system must commit to

 continuous improvement. We need the organic label to stand for

 true conservation agriculture, as an example for how all

 farming should be.

 Thank you so much, and good luck on your

 deliberations.

 CHAIR POWELL-PALM: Thank you so much for your

 comments.

 Amy, please go ahead.

 SECRETARY BRUCH: Hey, thank you.

 Kestrel, thank you so much for participating in our

 process, and the written comments you also provided.

 I wanted to refer to your written comments and just 
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 ask you a question, and this could be a follow-up that -- that

 perhaps you might need to do, so no worries on that. You

 mentioned for residue testing for a global supply chain that

 you really wanted to see testing conducted in two points -- two

 places; both at the point of origin and then upon arrival for

 bulk containers.

 I just had a question; do -- are you aware of any

 innovation that's happening in testing to, I guess on the rapid

 analysis front because sometimes there is a delay when testing

 is conducted ,it can take four or five days, and that's a lot

 of time when -- when ships might release their content, so in

 the private sector are you aware of any rapid analysis testing

 that's -- that's being conducted?

 MS. BURCHAM: I do believe there are some new

 technologies for rapid testing. My other policy staff member

 probably could give you more specifics on what those actual

 tests would be, but this is an area that seems to be expanding

 pretty rapidly, especially with SOE coming on.

 SECRETARY BRUCH: Um-hum.

 MS. BURCHAM: And I think it will keep expanding.

 So, yes, and I can get you more details, if needed.

 SECRETARY BRUCH: Perfect. I would love the followup. Thank you so much.

 CHAIR POWELL-PALM: Any other questions for Kestrel?

 (No response.) 
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 CHAIR POWELL-PALM: Because we don't see the next two

 commenters, I'm going to have a question for you, Kestral, real

 quick, and that is; is there a way in our communication -- we

 just heard from Tracey, the farmer in Montana, how we need to

 be shouting from the rooftops, in her words, the benefits of

 organic, building that consumer demand so we create more of a

 market. Is there a way, in your estimation, that we can

 celebrate all that is good, say that 90-plus percent of all the

 different crops that are grown using conservation practices in

 the soil, while still not losing sight of the points of

 improvement? How -- can we do both?

 MS. BURCHAM: Yeah, I would hope we can do both.

 I'm -- I'm someone who sees that there's no like black and

 white here, it's all shades of gray, and consumers do like to

 see it in black and white, and that's the constant struggle we

 have.

 CHAIR POWELL-PALM: Um-hum.

 MS. BURCHAM: For ,me I think for the end of

 celebrating what is good, we need to focus on the fact-based,

 science-based information we have coming out of research that

 shows the benefits of organic, both on the nutrition end

 because consumers really care about nutrition, on the

 environmental end, and the -- ends all of these, there's so

 much research coming out and continuing to come out that is

 just not accessible to consumers, and I think the USDA and 
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 stakeholders like ourselves, and the,, NOSB as well could help

 break that down into more, you know, bite sized ways that

 consumers can access that more heavy science. I think that's

 one of the big hurdles.

 And as far as the continuous improvement aspect, I

 think that is a challenge because consumers lose faith whenever

 we say, oh, well their organic is great but it has these

 problems. And I think we just need to make it clear that there

 are tools built into the system to have this continuous

 improvement, and any system is going to have issues. The world

 is messy. Food production is messy. And we need to -- like

 because like we said, celebrate the good while moving forward

 continuously. And maintaining those systems of continuous

 improvement are essential because otherwise you lose that

 integrity. As long as you can say, hey, we've got these

 systems in place to improve and we're trying to do that, I

 think that really comforts consumers. As soon as you lose that

 continuous improvement, though, you lose a lot of that.

 CHAIR POWELL-PALM: I so appreciate that. We have

 another question for you from Jerry.

 Jerry, please go ahead.

 BD. MEM. D'AMORE: (No audible response.)

 CHAIR POWELL-PALM: Oh, Jerry, I think you're muted.

 BD. MEM. D'AMORE: Thank you, Nate.

 I'm -- I'm very glad you got your -- your extra 
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 minute or so because I really appreciate the way you ended

 the -- your -- your thoughts on how one might cooperate and,

 you know, acknowledging that things are gray, and can be gray.

 I think the only thing that I would add in support of

 how do we do it without being disruptive, in other words, how

 do we find consensus, how do we engage in continuous

 improvement, would be to say that I find that unfortunately as

 we go about staking out our opposing positions, that we become

 home worst enemies. I don't think anybody makes the -- the

 organic consumer more confused than we ourselves. So, thanks.

 MS. BURCHAM: Yeah, thanks, Jerry. I agree.

 CHAIR POWELL-PALM: Well, if you -- I would -- I

 would say, if you have any great one-liners for why organic or

 what organic, Kestrel, that you want to shoot over to Michelle,

 we would be eager to see them.

 MS. BURCHAM: Oh, I can definitely do that.

 CHAIR POWELL-PALM: All right, thank you so much for

 your comments today.

 We're going to jump now to Joseph Brinkley, followed

 by Abby Youngblood, and then Scott Rice.

 Joseph, if you're there, the floor is yours.

 MR. BRINKLEY: Hello. Can you see me? Hear me?

 CHAIR POWELL-PALM: We can. Please go ahead.

 MR. BRINKLEY: All right. Thank you so much.

 My name is Joseph Brinkley. I'm the director of 
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 Regenerative Organic Development at Bonterra Organic Estates.

 We're based in Mendocino County, California. I'd like to start

 by thanking the board for the important work they do, and for

 taking the time to listen to me and my fellow commenters.

 I'm speaking to you today in support of maintaining

 sulfur dioxide on the list of allowable materials for wine

 making in the "Made with Organic" category. We at Bonterra

 Organic Estates find the use of sulfur dioxide critical to our

 business. We currently sell upwards of half a million cases of

 wine domestically and internationally; a volume that has

 doubled in the last handful of years. We have seen incredible

 interest and growth in our wines from consumers at home and

 abroad as the interest in organics continues to grow.

 The use of SO2 is indispensable for the consistent

 high-quality wines that we are known to produce. SO2 acts as

 both -- SO2 being sulfur dioxide -- acts as both a sterilant

 and an antioxidant serving two critical needs in the wine

 making process. Furthermore, to date, there are no viable

 alternatives to these two crucial needs served by this very

 important material.

 We pride ourselves on selling high-quality wines at

 an approachable price point made available to people all over

 the country and in many parts of the world. Without the

 limited use of SO2, this would not be possible. We maintain

 our usage of SO2 at or below the minimum allowable amounts per 
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 the NOP guidelines for wines made with organic grapes.

 Removing this material would be devastating to our brand and

 our business.

 For sterilant purposes, while a limited number of

 materials are available for antimicrobial capabilities in wine,

 they are limited in scope, less effective than SO2, and all are

 synthetic, so none of these can be used in our production.

 Physical alternatives, such as microfiltration can be effective

 in removing unwanted microbes and are, in fact, used from time-

 to-time in situations where unwanted microbe blooms occur, but

 regular filtrations of all wines for microbial control is both

 impractical and also damaging to quality. The filtration

 process always exposes wines to oxygen, which has its own

 damaging effects, and many wine makers consider filtration a

 harsh process that can both add unwanted flavors to the wines,

 and strip out desired ones.

 As an antioxidant, there are no alternatives for SO2.

 In fact, wines are so susceptible to damage from oxygen

 exposure, wine makers already take great pains throughout the

 wine making process to limit this exposure. Our organic

 handling would be critically impacted if the use of SO2 was no

 longer allowed.

 Wines of good commercial quality and longevity that

 today's consumers demand are not possible without SO2. This is

 clearly evidenced by both the fact that every winery, except 
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 those desiring to claim organic status, in the U.S. and a few

 "natural" wine makers, use it in their winemaking and the fact

 that other countries allow it for use in organic wine making at

 conventional rates, as they recognize how critical it is in

 making quality commercial wines.

 Our ask is that NOSB vote to relist sulfur dioxide

 into the future for wine made with organic grapes. Thanks

 CHAIR POWELL-PALM: Thank you so much for your

 comments. We have a couple of questions for you, starting with

 Logan.

 BD. MEM. PETREY: Hi. Thanks for coming.

 MR. BRINKLEY: Hi.

 BD. MEM. PETREY: Well, a question about a previous

 comment from our commenter today, and he was talking about in

 the flavors category that ethyl acetate; are you -- are you

 familiar with that? And are you able to source it, you know,

 organically so that that -- you know, there was an uptake in

 that product availability. And I didn't know if you had any

 comment on that.

 MR. BRINKLEY: Yes. No, we -- we don't really

 necessarily need that. The -- the magic of wines is that

 they're kind of all-inclusive, minus a couple little adds, so

 yeah, the -- the fermentation with the sugar basically gets us

 to where we need on the alcohol side.

 BD. MEM. PETREY: Great, thanks. 
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 MR. BRINKLEY: Thank you.

 CHAIR POWELL-PALM: Allison, please go ahead.

 Followed by Nate.

 BD. MEM. JOHNSON: Thanks for being here, Joseph. We

 didn't have a lot of comments on this SO2 in the spring, so I'm

 really happy to see some wine producers showing up this time

 around.

 And I'm curious if you have any comments on how the

 Made with Organic annotation has impacted Bonterra, and in your

 view the growth of organic grape beverage?

 MR. BRINKLEY: Yeah, that's a great question. Thank

 you for that. How Much time do we have?

 BD. MEM. JOHNSON: Five years. Let's go.

 MR. BRINKLEY: We -- we've certainly -- so, I would

 say one of the limiting factors on the commercial expansion is

 the lack of consumer awareness, so we certainly find that

 there's a bit of confusion around the wine sector, specifically

 in the organic wine versus Made with Organic Grapes category.

 We've worked quite diligently, I'd say, and over many

 years now Bonterra's been a brand since the early 90's,

 organic, with organic grapes, so it -- it's been a bit of a --

 a challenge but we're -- we're still working in that direction.

 And I think, depending on the geography and demographic of the

 consumer, there's better or less understanding as far as those

 two different categories. It -- it certainly doesn't help that 
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 we're the only nation essentially with the two categories.

 Anywhere else our wines are consumed they're called organic

 wine, but I -- I do think there's a few of us now in the game

 and we're -- we're still working on trying to clarify some of

 that confusion.

 BD. MEM. JOHNSON: That's helpful. Thank you.

 CHAIR POWELL-PALM: Nate, please go ahead.

 BD. MEM. LEWIS: Do you have any opinions about the

 restrictions on sulfur dioxide, particularly as it is only

 limited to grape wine? And then also the -- the PPM

 restriction? I just want to get -- get all the issues on the

 table. I know you're a grape wine maker, but you may have

 other fruit wine makers that you could -- you've talked to

 about that, so the grape issue and then the 100/ppm issue.

 MR. BRINKLEY: Great. Yeah, thanks for the question.

 Again, I -- I cannot speak to other fruit wines. Really not

 our focus and -- and I haven't spoken to many folks in -- in

 that realm.

 As far as the ppm issue, I would advocate, continue

 to advocate for the levels to be maintained where they are.

 I -- I'd -- I'm not here to ask for any lowering of standard,

 but I do find that the limited use and the "Made with" with

 category is critical for us, to the point that I would say if

 it were removed, we would probably drop the cert, right. So,

 yeah. So, thanks. 
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 CHAIR POWELL-PALM: All right, thank you so much,

 Joseph --

 MR. BRINKLEY: Thank you.

 CHAIR POWELL-PALM: -- for taking the time to share

 those comments with us today. We appreciate it.

 Next up, we have Abby Youngblood, followed by Scott

 Rice, and then Stephanie Jerger.

 Abby, if you're there, please go ahead.

 MS. YOUNGBLOOD: Thank you, Nate.

 Good afternoon. I'm Abby Youngblood, executive

 director at the National Organic Coalition, or NOC, and I want

 to talk about NOC's work with Congress, in person oral

 comments, and advancing racial equity in the USDA Transition to

 Organic Partnership Program.

 We are in a tumultuous period in Congress right now

 with an unclear path forward for a new House Speaker, action to

 avert a government shutdown before the November 17th deadline,

 and renewal of the 2018 Farm Bill after it expired on September

 the 30th. I want to highlight two issues that pose a

 particular threat to the organic community.

 First, the Cost Share Program is especially

 vulnerable in an environment where Congress decides to extend

 the current Farm Bill. In the absence of a special provision,

 the Cost Share Program will expire leaving thousands of organic

 farmers with a huge net increase in their annual certification 
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 costs. 

 Second, amendments to agriculture appropriations

 legislation have been introduced in both the House and the

 Senate that would block forward movement on the organic

 livestock and poultry standards rule, so we'll need to fight in

 the coming weeks to both secure funding for the Cost Share

 Program and the Farm Bill extension, and to defend against

 these amendments to block the organic animal welfare rule from

 moving forward.

 Together with my partners -- with many partners, NOC

 is also advancing seven marker bills with specific provisions

 related to Organic Farm Bill priorities: certification cost

 share; continued transition support; organic integrity and

 continuous improvement; organic research; seeds and breeds;

 organic dairy; conservation priorities; and addressing Black

 farmer land loss. We refer you to our detailed written

 comments for some additional information about these marker

 bills.

 In person oral comments. We appreciate the

 discussion at the Atlanta board meeting and the comments today

 as well. We are strongly advocating that the board try in

 person oral comments for at least two meetings so that board

 members have a comparison to a meeting with only virtual

 comments. We ask the board to try in person oral comments at

 the Spring 2024 meeting in Milwaukee. 
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 In closing, I want to thank the board for your work

 to build a more diverse, equitable, and inclusive organic

 movement. And I want to encourage us as an organic community

 to consider ways that we can leverage USDA's Transition to

 Organic Partnership Program, TOPP, in that effort and echoing

 something Ellie said earlier, NOC is also a participant in one

 of the national TOPP projects, and as part of that work organic

 organizations have a chance to participate in an eight month

 long racial equity learning cohort that's offered free of

 charge. We think this is an incredible opportunity and we hope

 folks will take advantage of that.

 And thank you so much to the board for your service.

 CHAIR POWELL-PALM: Allison, please go ahead.

 BD. MEM. JOHNSON: Thanks Abby, both for your work

 here with the board, and at the federal level to protect cost

 share and try to grow resources more organic. We really need

 it.

 Your last point about the -- the training that you've

 done on racial equity, I'd love to hear more about -- I know

 NOC has commented a number of times about how racial equity

 training could benefit board members, and we're looking at ways

 that we could integrate that into our PPM updates in the new

 year. So, I'm curious if you could just speak a little bit

 more to what your experience has been? And how you think we

 would best be able to bring that type of training to the board? 
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 MS. YOUNGBLOOD: Thanks for the question, Allison.

 And the learning cohort that Ellie and I both mentioned in our

 comments is a very deep dive type of training opportunity, but

 I -- I wanted to flag it because many of our organizations are

 participating. The first cohort was for certifiers and

 inspectors. The second cohort that NOC is also part of is for

 education and advocacy groups. There's two more cohorts, so

 I -- you know, between these cohorts, I think there will be

 dozens of organic organizations that together are taking this

 deep dive through this eight-month long program, so I think

 that's a really exciting opportunity.

 I think many organic organizations also have

 trainings that their staff do, kind of as part of the

 onboarding process, and I think something like that might be

 more applicable to the National Organic Standards Board work.

 And I think it might also be interesting to think about how to

 institutionalize the board's commitment to equity and

 inclusion, possibly through integrating it into some of the

 officer roles that the board has or thinking about how it's

 part of the onboarding process for new board members, so that

 there's kind of a shared understanding or maybe a shared

 baseline on the board.

 And then lastly, I think the board has a really

 fantastic opportunity through the in-person meetings and

 through the speakers you invite to really continue building on 
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 the conversation that's happening around equity and inclusion.

 CHAIR POWELL-PALM: Amy, please go ahead, followed by

 Franklin.

 SECRETARY BRUCH: Yeah, thanks Nate.

 Abby, thanks for joining us today, and thanks for

 providing us with written comments and all the work you're

 doing on the Hill on behalf of organic producers.

 I just had kind of a general question, and I'll

 probably be asking this to other members that represent us on

 the Hill, but in 2018, you know, one of the top priorities was

 oversight and enforcement, and we were so fortunate to get

 funding for this -- for the SOE and I'm excited for that to be

 in the fruition, finally.

 I see though current Farm Bill priorities enforcement

 and oversight was absent. There wasn't that I know of, and

 correct me if I'm wrong, I don't see that as a top priority for

 an ask. And I know the ones that are on there are brilliant

 and wonderful, but I was just wondering where does that stack

 up, the oversight and enforcement and continuous improvement

 because, you know, we -- we just hear a lot of feedback from

 farmers that, you know, we need to do more. So, I was just

 kind of questioning where that's at in -- in your priorities?

 MS. YOUNGBLOOD: Thank you for that question. In my

 mind, the biggest linkage is around authorization of additional

 funding for the National Organic Program and that the funding 
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 for that program keep pace. That is a conversation we're

 having with members of Congress and we're hopeful that there is

 the opportunity to continue to increase the resources for the

 National Organic Program.

 In the last five years, there has been, I think,

 tremendous capabilities added, and part of that is the

 additional resources going from nine million, I believe, that

 was 2017, up to more than 22 million each year for the National

 Organic Program. A lot of that has gone into accreditation of

 certifiers and enforcement activities, building capabilities

 with Customs and Border Protection, and building more tools and

 cross-agency collaboration to crack down.

 So, I think that additional funding is important, but

 I'll just note that the actual funding level for the National

 Organic Program is determined through the annual appropriations

 legislation, so there's an authorization and then the money is

 appropriated annually. We have to keep fighting there, as

 well, to get additional increases. I think there are things

 that the administration, you know, has the ability to do and

 can continue to do without legislation. I think where we go to

 the Farm Bill is when we think we need that legislative tool to

 get our goals achieved, and I think if the board is seeing that

 we need that legislative tool in certain areas, I hope we can

 be in dialogue on that and figure out how to -- how to address

 that. 
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 SECRETARY BRUCH: Okay. Thank you, Abby. Appreciate

 it.

 CHAIR POWELL-PALM: Franklin, please go ahead.

 BD. MEM. QUARCOO: Yes, sir.

 Abby, I appreciate it if you can expand a little bit

 on the potential impact of the exploration of the Cost Share

 Program on the diversity of organic producers and their

 participation? And I'm talking about diversity in the broadest

 sense possible, especially those with limited resources, that

 that would be great.

 MS. YOUNGBLOOD: Yeah. Thank you so much for that

 question. And we do know from the survey that the Organic

 Farming Research Foundation did, that cost is a barrier for

 many farmers in getting certified, and especially for

 operations that maybe are more remote to where the certifier or

 the inspector is located. There are certain regions of the

 country that are underrepresented in terms of certification

 agencies where costs might be higher. We also know that for

 some small-scale diversified operations and some operations

 that have maybe both crops and livestock, that Cost Share

 Program makes a huge difference.

 We already have so many people in our movement who

 are using organic practices but are maybe not going through

 certification for good reasons, but taking the certification

 Cost Share Program away will exacerbate that problem of having 
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 more people fall out of certification. 

I know produce -- some producers that I've spoken

 with are frustrated because we've been on a roller coaster with

 the Cost Share Program, and so one of our biggest goals is to

 get some more stability for that program in the coming Farm

 Bill. An extension is very likely, so we'll be really working

 hard to get the Cost Share Program in that extension. It's not

 automatically assumed to be part of the extension, so it's

 an -- it's an extra lift to make sure we find money for it for

 2024.

 CHAIR POWELL-PALM: Any other questions for Abby?

 (No response.)

 CHAIR POWELL-PALM: All right, we appreciate your

 time Abby, thank you.

 Next up, we have Scott Rice, followed by Stephanie

 Jerger, and the Phil LaRocca.

 MR. RICE: Greetings everyone. Thank you for this

 opportunity to comment. My name is Scott Rice, and I am the

 regulatory director at the Organic Trade Association, a member-

 based organization representing nearly 10,000 organic

 businesses in North America from farmers to handlers, retailers

 to manufacturers. OTA's mission is to promote and protect

 organic with a unifying voice that serves and engages its

 diverse members from the farm to marketplace. I'm also a 

 former NOSB member and appreciate firsthand the hard work you 
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 all invest in this public process, so thanks for that.

 OTA submitted written comments on several areas of

 the fall agenda, and today I'd like to highlight a few points

 we made.

 First, we support CACS's inquiry into the expanding

 existing prohibited substance testing protocols to include

 targeted risk-based testing for substances known to be used on

 a particular commodity. We see this as a logical and sensible

 step forward in further protecting organic integrity. Using

 imported oil seeds aligns with that risk-based approach and we

 believe presents a good starting point.

 In response to the CACS's question of what else

 should -- should the NOSB consider to strengthen residue

 sampling, we point to the need for consistency. Consistency is

 something that I feel like I'm always a broken record on, both

 when I was on the board, and now at OTA. If responses to

 positive presence are to be truly consistent, there must also

 be consistent testing methodologies across the labs used by

 certifiers. Consistent practices across sampling testing and

 response steps of the residue program will make for an even

 playing field and how it's applied and produce consistent data.

 And importantly I think that data can then be used to inform a

 targeted risk assessment and aid greater efficacy in fraud

 detection. 

 Sampling procedures and how to respond to positive 
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 presence of residues is laid out via guidance in the NOP

 handbook; however, if the industry intends to increase reliance

 on testing as a tool for compliance, we encourage the NOP to

 update and highlight guidance to provide consistency on

 expectations and clear action plans in the event of residue

 detections.

 In closing, we're here to represent the trade and

 organic business. We need tools such as these proposed here to

 confront, respond to, and stop fraud, to protect organic

 integrity and the seal. As part of any initiative, we need to

 be mindful that these efforts are targeted and effective and

 not simply performative. In the lead up to implementation of

 strengthening organic enforcement, businesses are already doing

 this through a development of fraud prevention plans, as

 required by the rule. Let's take this opportunity to

 incorporate data from a consistent testing program and over

 time inform those plans to effectively target our efforts.

 Thanks very much.

 CHAIR POWELL-PALM: Thank you for your comments, and

 for your previous service.

 Questions for Scott?

 (No response.)

 CHAIR POWELL-PALM: I have a question for you. Scott.

 Oh, well go ahead, Nate, and then I'll follow with 

 mine. 
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BD. MEM. LEWIS: Appreciate the input on the residue

 sampling. I was curious if you all had had any discussion

 around whether there needs to be updates to the regulation, in

 addition to the guidance. And I'm mainly asking to try to like

 triage where we focus our work because regulations are

 heavier -- are a heavier lift. But anyway, just thoughts about

 regulation versus guidance. 

MR. RICE: Yeah. All -- always a tough one, I think.

 I would say having guidance codified in the regulation is

 always, I think, a best case, but as you know it's a hard lift.

 I -- I think we've got -- we've got solid guidance. I think

 it -- it's still just guidance. I think continued attention to

 the handbook where that lives, and I know that that also

 presents its difficulties in terms of updating that because

 that's sometimes seen as a regulatory action, so I -- I don't

 have a simple easy answer to your question. But I think the

 guidance still has its place. I think it's -- it's most

 important that the message get out to all certifiers that both

 domestic, international, that that is a -- as much a part of

 the regulation as the regulation itself so that we again drive

 that consistency and how it is applied. 

CHAIR POWELL-PALM: Kim, please go ahead. 

BD. MEM. HUSEMAN: Hi, Scott. Good to see you. 

MR. RICE: Hi. 

BD. MEM. HUSEMAN: On the note of consistency, we did 
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 hear from another commenter a suggestion about bulk lab

 testing. So, when you speak about consistency in -- in the

 testing procedures, is that in the form of the -- the companies

 allowed to do the testing? Would there be a -- like a list of

 companies that are approved? Or is it as long as testing

 procedures can be validated as such, then you can use whatever

 test? How would you define that from a consistency standpoint?

 MR. RICE: Yeah, I think it incorporates all of that.

 It -- it's from the way that those samples are collected, which

 I think certifiers are in a good place on, I think in terms of

 the labs we do have guidance from NOP that outlines sort of the

 minimum of -- of what is required for a lab to perform those --

 to conduct that sampling. I think there is still variation

 amongst the labs, there's variation in the list of what is

 sampled for.

 I think one thing I didn't note in my oral comments,

 but we have in our written, is the-- the list of -- of

 substances that NOP has -- has in the handbook is fairly, I

 think, outdated and much smaller than what a lot of labs use

 right now, and what -- what I think should be referenced and

 used. So, I think it's consistency across all of those areas.

 BD. MEM. HUSEMAN: Yeah, no thanks, Scott, because I

 do know, you know, working with labs in many different roles

 that I've had you'll have like -- you might have an internal

 result, and then you defer to a like a referee result, you 
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 know, to -- how do you -- you know, that's -- I guess that's

 where my mind is a little gray at the moment, is how to define

 those parameters and then what would constitute that for --

and -- and consistency is key for sure, so I appreciate your --

your thoughts on it. Thank you.

 CHAIR POWELL-PALM: All right, any other questions

 for Scott?

 (No response.)

 CHAIR POWELL-PALM: Scott, I'm going to put you in

 the same bucket as Elizabeth Bell now, as a former WSCA'er, and

 could you talk a little bit about the -- the burden and the

 benefit of having exact coordinates for certifiers of fields?

 You -- WSCA seems to do a fabulous job doing it, and it doesn't

 seem to be that big of a lift, so just wanted to get your take

 on it.

 MR. RICE: Yeah, I guess I'd echo Liz's comments; I

 think with any new practice that you bring in with the team,

 it's got its headaches at the front end to get everybody on

 board in terms of just the technology and the practice and the

 consistency and how we're doing it. But I think once you get

 there, the -- the resource, the -- the data outweighs any of

 those initial kind of front-end heartburn. So, I -- I would

 say it's a -- it's a positive place to move toward.

 CHAIR POWELL-PALM: Awesome. Appreciate your

 comments today. 
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 MR. RICE: You bet. I'll see you next week.

 CHAIR POWELL-PALM: All right, see you next week.

 Next up, we have Stephanie Jerger, followed by Phil

 LaRocca, and then Margaret Scoles.

 Stephanie, if you're there, please go ahead.

 MS. JERGER: Hi. I am here. Thank you.

 I am Stephanie Jerger. I'm the vice president of

 operations for the Organic Trade Association. We have

 submitted comments already for this topic, but I want to

 definitely talk about our diversity initiatives in regards to

 the transition and transitioning communities of colors and by

 Black farmers and growers.

 Based on our experiences and feedback from our

 members, we decided a few years ago to make a more intentional

 push towards making sure that organic does not effectuate

 social inequities, so while we have these opportunities to

 embed equity into the process and policy, we want to make them

 fruitful.

 The USDA has created a great opportunity in the

 Transition to Organic Partnership Program, and there's a great

 deal of opportunity in transitioning organic acreage in these

 communities that we're currently not reaching, but there are

 some barriers that I just want to highlight here.

 First one is communication. It's a very obvious

 literal translation like linguistic translation. But not only 
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 that, there's a cultural competent communication that appears

 to be lacking based on what we're hearing from our partners and

 the communities that we're talking to. Just plain language is

 already hard enough if it's not culturally competent, so having

 regulatory and technical language it makes it even harder for

 people to get past the hurdle of even understanding what the

 opportunity in organic is.

 Also, the certification process, the paperwork, it is

 a barrier to people who are in these communities to be able to

 get past, and to even get started for what they need to do to

 try to become certified organic. It can be a deterrent in

 most -- in most cases.

 Also, we want to better right size the expectations

 for the cost and the commitment of organic. It's not clear to

 these growers or these producers what is expected of them, and

 when they see it in the paperwork or in form or in a list, it

 can be very daunting.

 Also, we want to highlight as a barrier the

 demystifying of our organic resources, the National List,

 what's allowed, synthetic versus non synthetic, allowable

 prohibited, calculation formations; those things are all things

 that are not innate if you're not in this community, and

 they're absolutely becoming barriers to people being able to

 actually finish the process.

 And last, just the learning curve. They don't know 
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 what they don't know; there needs to be some better holistic

 way to like co -- have a cohesive place for people to

 understand what the process may be, what's there, what is

 available to them, and where they can find things. And just

 growing the organic market to prepare small scale growers who

 will be entering in the supply chain from this program. If

 TOPP is wildly successful, which we hope it will be, without

 addressing these issues upfront we will have created another

 issue.

 OTA is already working on, with -- partners all

 around the country, on these issues and we invite you all and

 go to our website and feel free to reach out to me directly.

 If you don't find something you need there, I'm happy to work

 with you all.

 And in closing, on behalf of members and staff, thank

 you to Organic Standards Board for the opportunity to comment.

 CHAIR POWELL-PALM: Well, thank you for your

 comments. We really appreciate them. Those are great.

 Let's go to Logan and then Allison.

 BD. MEM. PETREY: Hey, thank you.

 I couldn't help but notice the Florida A&M

 University, and yeah, okay, so Florida girl.

 Just curious, for some of those educational things

 you have like a nonprofit for organic growers in the state,

 didn't know if maybe that has become a resource? Or if that's 
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 lacking some information? Or, you know, if things like that

 could be better? Some of those local, you know, outreach --

 educational outreach programs? I am very familiar with thought

 action on the board with it, so if there is a need there, you

 know, for those local outreach programs, do you think that that

 is a good way to get some of that information to farmers that

 they can have more workshops, things like that? What -- what

 is your idea of -- of getting that to people?

 MS. JERGER: Absolutely, Logan. Thank you for that.

 I do think that having more information that's coming down from

 the USDA, or what we understand is organic, be better trickled

 into those community organizations would be more helpful. The

 communities already trust those organizations. They have an

 outreach that is already structured to be able to reach them in

 a way that they know works. But the information that we're

 putting out is not getting down to -- to those communities, so

 I would absolutely say maybe better educate and partner with

 more local entities, some, you know, community anchored

 organizations because they will be better to translate the

 information out, but they have to be better educated themselves

 on what organic is, what it does, the process, how it comes 

 through. So yeah, I think that would be a great place to

 start.

 BD. MEM. PETREY: Thank you.

 MS. JERGER: Um-hum. 
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 CHAIR POWELL-PALM: Allison, please go ahead.

 BD. MEM. JOHNSON: Thanks so much for being here,

 Stephanie. I really appreciate your comments, and the barriers

 that you named are the same things that I'm hearing coming up

 as I'm doing outreach on organic transition. And I'm curious

 if you could speak a little bit to what you see you working so

 far in the early stages of TOPP on how are people successfully

 overcoming these barriers? And especially you mentioned

 cultural competency is like a hard thing to teach, so if you

 see anything that has been particularly effective in that area?

 MS. JERGER: Absolutely, Allison. Thank you. One of

 the things that I clearly see as being helpful is more

 handholding, unfortunately, and I know no one has that much

 time, but unfortunately at OTA, I do. I put on a webinar once

 a month called "Ask Me Anything," where I bring in consultants,

 I bring in certifiers, I bring in people to just come to the

 people who are in my program and answer their questions. These

 are questions that they cannot look up. They're never going to

 find the answer to. There's no one that's going to answer this

 question. And then once they get into a certification process,

 it's absolutely not going to happen. So, that's what I found

 successful. And OTA's program, we -- we're two years in

 existence. We have seven people right now actively in

 transition and we've been able to get one person actually

 certified through this process. 
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 CHAIR POWELL-PALM: Fantastic. Franklin is up next.

 BD. MEM. QUARCOO: Hello, Stephanie. Can you --

 MS. JERGER: Hello.

 BD. MEM. QUARCOO: -- provide examples of the kind of

 language that puts people in a type of community off, their

 interest wains when people begin to use that kind of language,

 language that maybe sometimes for the person talking may sound

 like this is -- this is everyday language; can you give an

 example of the kind of language that can put type of farmers

 off --

 MS. JERGER: I can. I can, Franklin. Thank you.

 There are two words that I have to stop myself and explain or

 redirect every time I say them, and that is "regulatory" and

 "compliance." We use a lot of technical language in this

 community, and it is not used outside of this community. And

 not only is it not used as often, those words mean different

 things in these communities we're trying to penetrate, so they

 are terrifying to them. They will stop talking to me

 immediately so, I'm constantly redirecting that, but that's a

 part of like cultural competent communication. I have to be

 able to communicate to my audience. Technical language is all

 fine for understanding the rules, but they're not going to be

 able to understand them if they can't get past the literal

 words. So, those are two very, you know, two very alarming

 words but I think there are several words like that, and I 
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 think that we don't think about that because we're just writing

 technical language, we're just writing regulation, but those

 things do not translate well for the communities we're trying

 to reach.

 CHAIR POWELL-PALM: Other questions for Stephanie?

 (No response.)

 CHAIR POWELL-PALM: I just have a -- a little

 question for you, Stephanie. When we talk about handholding, I

 think that is just such a good way to put it, that farmers

 should be responsible for farming. The idea of having to have

 this, you know, deep regulatory knowledge to be able to be an

 organic farmer seems like an unnecessary burden. When I think

 about going into the FSA office, I get my hand held for how to

 fill out my proper boarding, how to access my crop insurance; I

 mean, they sit there, and they'll do that with every single

 farmer in my county. So, I don't know if you have any ideas

 for how we can just kind of like pass that process along and

 sort of replicate the USDA models we already have for making it

 so that you have a place to go to ask these questions and get

 your hand held?

 MS. JERGER: Nate, I'm so glad that you asked that

 question. That's -- that's exactly the -- the experience that

 they're not having sometimes in these places. Having an FSA

 office that can translate and understand and represent truly 

what the USDA has sent down to it, is -- it's excellent, but it 
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 does not always happen. And a lot of the communities I'm

 dealing with, they're rural, a lot of them are southern, in the

 southeast, and when they go into an organic -- you know, the

 office, I'm sorry, FSA office and mention that they're doing

 something in organic, just like glazed over. A lot of them

 will tell me they're not getting a response, they have no idea

 what they're talking about, they don't know what that form is,

 that doesn't exist; they don't know that language. They

 don't -- they're not competent in a lot of those offices

 because organic is not as deeply embedded in these communities

 where we're trying to embed it. So, I think we have to

 acknowledge first that in places where there is not a hot spot

 of organic, we need to be creating more education at the

 federal level, at the less local level for those agencies

 because that's where they're going to help, and they're being

 turned away, and again it's a deterrent for them.

 CHAIR POWELL-PALM: And so, sorry, just to clarify,

 would you say resources best deployed to go to those county

 level offices and try to put on organic trainings? Or would

 you say higher up is better use of our time right now?

 MS. JERGER: I would say resources in those places

 would be better used than higher up because the people who are

 in Tuscaloosa, Alabama are not going to get to D.C. to see how

 wonderful it is to walk ain the Independence Avenue office. 

 CHAIR POWELL-PALM: I'm hearing a thread here with a 
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 little of "What is organic?" Give that education. 

 So, let's jump to Kyla real quick. Kyla, please go

 ahead.

 BD. MEM. SMITH: Hi, Stephanie. Thanks for your

 comments.

 So, I say "regulatory" and "compliance" about 1,000

 times every day, so I know you said that OTA has a bunch of

 resources; is a lexicon of like better words one of those

 resources?

 MS. JERGER: It is not yet, but it is coming, Kyla,

 as a part of our Diversity Resource Library, which is an

 ongoing library that we keep on our website, it comes from our

 Diversity Council, that's one of the things we're going to be

 working on. We have a lot of output that we put out, but one

 of the things I'm focusing on next year for having is a

 resource for better words, better culturally competent language

 to use that will help you. So, it's coming Kyla, please stay

 tuned.

 BD. MEM. SMITH: Thank you.

 CHAIR POWELL-PALM: Thank you so much for your

 comments, Stephanie, and for joining us today. We really

 appreciate it.

 Next up, we have Phil LaRocca, then Margaret Scoles,

 filed -- followed by MonaRae Tuhy. 

 Phil, please go ahead. 
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MR. LAROCCA: (No audible response.) 

MS. ARSENAULT: We are getting Phil unmuted, I

 believe, Nate. 

MR. LAROCCA: How about that? 

CHAIR POWELL-PALM: Sounds good. 

MR. LAROCCA: Okay. Sorry about that. Anyway, my

 name is Phil LaRocca, good afternoon. And I'd like to thank

 the board members because I know you put a lot of volunteer

 time into this, and it takes a lot of effort to do that. 

I am owner and winemaker of LaRocca Vineyards. I'm

 chairman of the board for CCOF. I sit as vice chair for the

 California Organic Product Advisory Board. And I've been an

 organic farmer for pushing 56 years now, though I'm kind of in

 a semi-retirement mode since my farm took a pretty good burning

 in the California Camp Fire. 

I'm going to talk about organic wine and sulfur

 dioxide; a topic that I know very well because 22 years ago

 with this board I wrote the rules for organic wine and wines

 made with organic grapes. 

To start with a little history, sulfur dioxide is

 actually outlawed in the Food and Production act in any form of

 organic agriculture or production. Period. So, with that

 said, it would just open the door to other synthetic

 preservatives, so the board at that time, we came up with an

 organic wine to not have any synthetics, including sulfur 
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 dioxide.

 Now, we knew the California wine industry in

 particular was taking off and grapes we were be -- getting very

 popular so we had hundreds of acres of organic grapes coming in

 and, I realized that, so that another member of the board

 realized that, so we said we need to do something because

 fake -- for the sake of disclosure, I was one of the very first

 organic grape growers for the Montero Line, by the way.

 Anyway, so we said, well we got to do something, so we came up

 with the "Made with Organic" label. That was actually my idea.

 Now, to pull that off wasn't very easy because the

 Food and Production Act outlawed sulfur dioxide. So how did we

 do it? The help of four senators from two different states,

 and I don't remember the bill exactly, but it's something to

 the effect of let's allow senior citizens to buy generic drugs

 at half the price, oh, and by the way, wines made with organic

 grapes could have sulfur dioxide added to them, and that's

 where we're at today. So, I spent a lot of time working on

 that. I still endorse it to this day. I accept both the

 organic wine and I accept the "Made with Organic" label.

 But I do want to make a comment to what Joseph had to

 say early. Since that rule was passed, we've seen thousands of

 bottles of organic wine being produced. We have some organic

 wineries that are producing 50,000 cases of organic wine a

 year. When we were producing, we were in the 10 to 12 
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 thousand-case range, always using organic principles and

 growing and in processing our wine. To this day, we still have

 inventory that we're selling out of our tasting room, that age

 from five to 17, 18 years old. So, it took us a while but

 organic wine makers, we got it figured out, and you don't need

 sulfur dioxide to make a wine. But I'm not here to tell a wine

 maker how to make his wine; I am here to say I endorse the

 wines made with organic grapes, and I absolutely endorse

 organic wine as the way it is. Thank you very much.

 CHAIR POWELL-PALM: Thank you very much for your

 comments, and for joining us today. We have a question for you

 from Allison.

 MR. LAROCCA: Yes, Allison.

 BD. MEM. JOHNSON: Thanks, Phil. Really appreciate

 you being here and your many, many years of leadership. And

 I'm really sorry for the loss of your acreage in the fire.

 I'm curious, you know, with this long-term

 perspective that you have, and your experience as a organic

 wine producer without the use of sulfur dioxide, what you think

 the impact has been on the growth of the organic wine sector?

 I, you know, when I was in certification, was explaining the --

the labeling options to producers weekly, if not daily, and so

 I -- I'm at the point of sort of looking back and looking

 forward and -- and wondering where we should go from here? And

 if the current law is still working as it's written? 
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 MR. LAROCCA: Yeah. The industry has grown, there's

 no doubt about it, but what we're experiencing in the wine

 industry, because I still stay in touch and we still have some

 small production -- my son leased to small vineyard -- but what

 we are seeing and what I'm talking with other organic wineries,

 and I'm not sure about the "Made with" guys, but we are seeing

 sales there but they're not wanting to pay the premium for

 organic.

 So, one of the earlier speakers, and I'm really

 pushing this at CCOF, we need a major marketing campaign that

 shows that organic is better and it's worth paying the extra

 pennies for an organic product. That it's healthy for the

 environment. We personally think it's healthier for human

 beings, all the way around, and we need some marketing out

 there that pushes that because where we're -- even some of our

 big plum growers in California are saying, man, we're getting

 conventional prices and we're putting that extra dollar and --

 The thing about organic is when we say we're getting

 a premium, I think most of the farmers on this call, that

 premium is just the cost of doing business organically, but

 now -- so the growth is there, the market is there, we just

 need to stabilize it price wise and make it so that it's worth

 it for the farmer to make a profit.

 CHAIR POWELL-PALM: Other questions for Phil?

 (No response.) 
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 CHAIR POWELL-PALM: Phil, this has been a throughline

 for farmers across the calls today, that we need help in

 marketing and spreading the message about organic. And I was

 just wondering if you can envision, what would be your dream

 program, either with USDA as a partner, or as a private

 industry group, how do we get this message spread wide -- wide

 and far about what is organic and why it's worth the premium?

 MR. LAROCCA: Well, first of all, I think we need to

 do a marketing campaign just like they did back in remember --

 remember the old raisin commercials? That boast [sic] the

 raisin production like, you know, tenfold so we need something

 like that. And I know that the USDA will have a hard time with

 this, but I -- I think not only do we need to promote the fact

 that organic is healthy for the environment, I think we need to

 show that organic is actually better in your diet. Period.

 You know, we like to say pay the farmer, not the doctor, so we

 need -- we need some kind of campaign that -- that runs -- that

 runs like that. And you can see from the OTA's scientific

 department there, you can see how many new crops are coming

 out, organic crops showing that they actually have higher

 nutrients of value then its conventional counterpart, and we

 need to promote that.

 CHAIR POWELL-PALM: I'd love to follow up with you.

 Thank you so much with your call --

 MR. LAROCCA: I'll be -- I'll be there next week. 
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 CHAIR POWELL-PALM: Okay, let's talk. Thank you 

 again, Phil.

 MR. LAROCCA: You got it. Thank you.

 CHAIR POWELL-PALM: Next up, we have Margaret Scoles,

 followed by MonaRae Tuhy and then Alice Runde.

 Margaret, the floor is yours.

 MS. SCOLES: Thank you.

 Margaret Scoles, International Organic Inspectors

 Association, Montana. Hello NOSB members, NOP, and colleagues.

 This comment is mostly on the organic transition discussion

 document. IOIA gave written comments on residue testing in a

 global supply chain and on inerts.

 Quickly, Sunset Reviews keep materials on the

 National List. The review of vaccines was very good work.

 Vaccines are essential and organic livestock.

 Consistent location identification. As certifier, I

 work for -- this year decided that the crop acreage summary

 should show township section, range number for all fields. I

 was astounded at how much time it took for some fields I had

 inspected five to 10 years ago or more. The farmer shouldn't

 need to be present for the inspector to locate the fields. So,

 overall good work. Definitely needed. We commented last

 meeting on that topic.

 On improving support for organic transition

 discussion document, fantastic initiative and a few thoughts. 
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 One, you acknowledged that the formal public comment processes

 for OTI have been limited. Recognizing that the program had to

 be rolled out on a crushing timeline, that lack of opportunity

 was a dry -- drawback. What is working well? The synergy of

 TOPP funding, supporting building on existing transition

 efforts and regional organizations.

 IOIA is part of a pre-TOPP, an MCAT-funded project

 through NRCS. We are doing workshops in six states focusing on

 field crops and ruminant livestock. Complementing those with

 TOPP collaboration has improved marketing about the events and

 allowed adding other crops and livestock.

 The actual barriers to transition are not nearly as

 big as the perceived barriers. There are financial barriers.

 Yes, often some loss of production, some additional paperwork.

 A cost. We must protect cost share, and it takes time to

 maintain an organic system plan.

 The way to successful transition is to make sure

 everyone is engaged. Inspectors have been helping farmers

 transition since the beginning, as we are often the only people

 on site. One of the most rewarding aspects of my years in

 inspection is seeing the change in operations as producers try

 new crops, improve rotations, incorporate cover crops, find new

 markets, and discover that they can actually transition the

 whole farm. We have to be sure we're providing technical

 assistance not helping applicants overcome barriers to 
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 certification, and the NOP guidance document on technical

 assistance does a good job of explaining the difference.

 Inspectors have always worked hand-in-hand with

 certifiers and processes -- processors, and retailers have

 helped producers transition to.

 Five, transition must include development of an

 organic system plan, otherwise organic has perceived as no

 synthetic inputs. There's so much more to an organic system.

 I was last week at the TOPP-supported workshop with

 Undersecretary Jenny Lester Moffitt and organic producers. We

 talked about what has been helpful in Montana.

 And I am out of time. Many pieces are needed to

 create a support structure, and now we have funding for farmer

 mentors. Thank you.

 CHAIR POWELL-PALM: Thank you so much for your

 comments. Amy has a question for you.

 SECRETARY BRUCH: Yeah, Margaret, thanks for joining

 us today and providing your written comments. Also, thanks for

 reiterating your position on standardized location information,

 appreciate that. I wanted to ask on that.

 And also in your written comments, I appreciate

 your -- your wanting to be collaborative to help develop risk

 assessments. That is awesome. I think -- I think teams are

 really important to get good synergy there, so thanks for your

 willingness to -- to go above and beyond on that one. 
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 I wanted to ask you on the testing -- residue testing

 for global supply chain, your written comments. You mentioned

 that you would recommend that all bulk ships are met at port of

 entry for testing prior to offloading. And can you expand why

 that -- why you came up with that statement?

 MS. SCOLES: I think it's a matter of risk

 assessment. I mean, if it -- the quantity is so big, that's

 one of the points we listed. Several points in which we think

 testing can be useful and one is when you have really large

 volumes that the risk is so much higher if -- if the load is

 not organic.

 I think that's all I can say about that.

 SECRETARY BRUCH: Okay. Perfect. Thank you.

 Appreciate it.

 CHAIR POWELL-PALM: Allison, please go ahead.

 BD. MEM. JOHNSON: Thanks so much, Margaret. I

 really appreciated your comments on transition. And I recall

 being in certification just feeling so nervous about stepping

 over that line into advising versus providing technical

 assistance as you said.

 And I wonder if you have thoughts about how we can

 give really clear direction to inspectors? Like what more we

 can be doing to help producers get the benefit of the expertise

 that inspectors bring without crossing that line? You

 mentioned the written document, but I think like there may be 
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 other things that we can do to help people with that.

 MS. SCOLES: The guidance document is great, and we

 use it in our inspector trainings all the time, and we have

 exercises and we really try to focus on that, and get people to

 understanding the difference. I still see that it's a problem,

 though, that many inspectors are -- it's easier to say can't

 help you with anything. You know, I can't help you with that.

 And it's like you don't have to help people; you can have

 discussions. You know, I see there are no legumes in your

 rotation. That is not -- that's not overcoming a barrier. And

 I think -- so I think training is really important for

 inspectors and certifiers because both are bound by the same

 the -- the same part of the regulation.

 CHAIR POWELL-PALM: Let's go Nate, and then Amy.

 BD. MEM. LEWIS: Hey, Margaret. Good to see you.

 Here, I -- I appreciated IOIA's comments on the

 testing document, and kind of homing in on the dynamic that

 creates where inspectors, as the face and boots on the ground

 are, you know -- it's easy for a certifier to say, yeah, you

 look at -- you look risky, we're going to sample you, and then

 the inspectors there and it can become very tense. So I --

it's just something I haven't quite -- I -- I spent most of my

 certification time behind the desk, so it was easy for me to

 respond, you know, send out the samples and -- I'm -- and I

 appreciate the -- that you all offered some suggestions there. 
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 But I'm -- I don't know if, maybe it's just an acknowledgement

 that I have read that and I appreciate that, and if you've got

 more to build on there, I really want to hear it and get it

 into the record.

 MS. SCOLES: I think every -- almost every inspector would be

 so excited if -- if sampling wasn't part of the regular

 inspection, and that you just had certain inspectors who didn't

 mind doing it at all, or we're really good at it, or were

 specifically trained for it, and you sent them on a circuit,

 and they took all the samples. I mean, it doesn't have to be

 that way but certainly I think that there is some benefit to

 doing unannounced inspections and sampling at the same time.

 I think the oddest thing for me as an inspector when

 we had to do unannounced inspections, I'm like oh no, and I

 show up and I'd be all apologetic, I'm so sorry, you've been

 selected, and those ended up being often really good

 inspections. And I've had more than one person saying -- say I

 wish all the inspections were unannounced, and I'm like really?

 I wouldn't think they would think that. They don't have to

 stay up all night, lose sleep, and worry about everything, and

 you maybe don't expect everything to be as perfect. And -- and

 maybe residue sampling is one of those things, too, that just

 goes good with an unannounced inspection.

 Thanks, Nate. And thank everybody --

 CHAIR POWELL-PALM: I have a question. 
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 MS. SCOLES: -- for the questions.

 CHAIR POWELL-PALM: Margaret, I was just wondering if

 you could speak a little bit to the -- the DEI work that IOIA

 has been involved in.

 MS. SCOLES: Sure. It's been one of the most fun

 projects. Our partnerships, is that two years ago with the

 human capital we started -- the Human Capital Initiative, we

 started a project as a partner with Organic Farmers

 Association, ACA, IFOAM North America and National Organic

 Coalition, and then that led into the project that several

 people have been mentioning, like Ellie and Abby.

 One of the things we learned really early on is that

 we didn't spend enough talking to partners -- organized

 partner -- potential partner organizations about what they

 wanted. We made the mistake of assuming sort of that we

 knew -- we wanted to do stuff that would be helpful, and so

 over the last several months I've been part of several

 conversations that were super useful where our facilitators

 picked a potential roster of organizations that could be

 partners, and these were either BIPOC led or organizations that

 focused on BIPOC producers, and so I was able to sit in on some

 interviews with organizations and it was really good to listen

 to what they had to say. I don't know where that will go, but

 for sure there's a lot of organizations that are -- are really

 needing resources and help and don't realize that resources are 
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 available. So, it's fine if you create resources, but it was

 like -- I think it was Stephanie who said earlier you'd really

 have to start really local to get them to people. So, that's

 been one of the projects.

 We also did another project last year with an intern

 that was -- we had our first intern, and it was through that

 project, so that was good. Thank you for asking.

 CHAIR POWELL-PALM: Absolutely. Thank you. I'll say

 just anecdotally that it has been an amazing process to see

 after these efforts have been made that when we put on IOIA

 organic inspector training classes there are now folks becoming

 inspectors who were just not -- were not there before, and so

 folks from these communities that represent historically folks

 that didn't -- didn't get a chance to be inspectors, and so

 want to just thank you for the work that's gone into that. It

 has been tangibly effective.

 MS. SCOLES: I think the certifiers deserve a lot of

 credit for that, too, because I think everybody is thinking

 more about diversity, equity, and inclusion and I think that's

 really changing the policies. And -- and it is. The faces of

 our cohorts coming to training has completely changed, as you

 know, being a trainer.

 CHAIR POWELL-PALM: Yeah.

 MS. SCOLES: Thank you.

 CHAIR POWELL-PALM: Shout out to Ellie Hudson and the 
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 ACA folks because it's -- it's working. Thank you, Margaret,

 for your comments.

 Next up, we have MonaRae Tuhy, followed by Alice

 Runde, and then Doug Currier. After Doug, we have Ty O'Connor,

 John Wicks, and Joseph Kibiwott.

 MonaRae, if you are there, the floor is yours.

 MS. TUHY: Thank you, Nate. Sorry, I muted there.

 CHAIR POWELL-PALM: Yes.

 MS. TUHY: I'm MonaRae Tuhy from Bigfork, Montana,

 and I have sat on the MOA Board for about 10 years, and -- on

 the Montana Organic Association Board. I also was able to

 attend that session with Undersecretary Moffett last week. It

 was outstanding.

 I have been working with -- my whole life I've been

 an organic gardener and never using additives and was a

 consumer since organic in probably about the late 80's when we

 could find them other than just farmers markets.

 I work with school gardens locally, and we do

 everything organically, and we teach kids about the soil and

 what soil is, and how to build that. And that's -- that's

 probably what I love most about organics, is about soil

 building.

 We have a lot of orchards -- cherry orchardists in

 this area and many of them are afraid to go organic because of

 the expense, and the paperwork because it seems overwhelming to 
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 them. I would love to see a -- a campaign to educate people

 that it is not that difficult. It's not that expensive.

 I think organic is a one-stop-shop for consumers to

 get the cleanest food grown with the most environmentally

 friendly practice in a system that rewards farmers. We won't

 get very far though when we're just doing it locally; I think

 every person in the industry needs to be highlighting how

 incredible organic is to everyone we know around the country.

 It's going to take everything we've got in the industry to

 reach every consumer, to educate them as to what organics is,

 and I would love to see the help from USDA, AMS, and if AMS

 could launch a campaign to educate consumers as to what organic

 is. It's always non-geome -- GMO, excuse me. Always

 antibiotic free. Organic ruminants are required to have access

 to pasture. I think that would help consumers understand more

 about what it is and probably more people to transition into

 organic as part of the incredible TOPP program. I am very -- I

 would love to see that continue on for many years. And I -- I

 like the "Pay the farmer, not the doctor." And I'm an age

 group that I remember that raisin commercial and, so that's

 what it would take.

 And thank you, NOSB, for this opportunity to speak.

 CHAIR POWELL-PALM: Thank you so much for calling in

 today. It's -- I think it's an especially helpful voice to

 hear from someone who's a -- a consumer. Not necessarily even 
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 an active farmer, but who believes in organics so much that

 they'll dedicate the time that you've dedicated, so we really

 appreciate your comments today.

 Questions for MonaRae?

 (No response.)

 CHAIR POWELL-PALM: I have one quick question for

 you, MonRae. As you think about the -- the marketing campaign

 that would go into trying to inform folks as to what organic

 is, what do you think are some of the most common myths that

 you hear about organic, besides the cost and the complexity?

 What are other things that you would love to see busted on a

 good poster in the school lunchroom right next to that "Got

 Milk?" poster?

 MS. TUHY: Yeah, it -- it really is the cost. But

 it's also the dedication of the farmers in what they believe in

 and how they work with their soils and their land. Just

 keeping that, working that plan, you know, working that and

 getting people to understand the love of the planet and the

 land that farmers have.

 I -- I know this isn't really part of your question,

 but I'll tell you, I would love to see a Super Bowl halftime

 commercial on organics.

 CHAIR POWELL-PALM: Amen. Yes. Well, that sparked

 something; we've got a question from Amy for you know, so bear

 with us. 
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 SECRETARY BRUCH: Yeah, thank you. No, that was --

that was great. I love your thoughts on -- on marketing

 campaigns, MonaRae.

 What so your -- I'm just curious, what is your

 accessibility to organic products in the area you live in?

 MS. TUHY: Obviously, farmers markets, so we have the local

 CSA's et cetera.

 SECRETARY BRUCH: Uh-huh.

 MS. TUHY: Fortunately, we have a Costco in

 Kalispell, you know, 35 miles away. That's where I get a lot.

 We have Natural Grocers moved in about, oh, 15 years ago, so

 that's always been a good one. And then to the south we have

 Missoula, where we have several stores down there that we can

 get it.

 I -- that -- those are the big ones. And I really am

 glad to see Costco carrying more, but boy when I look at the

 cost of the 10-pound bag of carrots and how inexpensive it is,

 it really bothers me wondering what that farm was making on

 that. I love the availability and the large -- and large

 quantities, but there's also to me, there's an a disadvantage

 on that from an economic standpoint.

 SECRETARY BRUCH: Um-hum. Um-hum.

 CHAIR POWELL-PALM: Well, thank you, MonaRae, so much

 for joining us today and for your -- your dedication, educating

 and supporting all the farmers out there. We really appreciate 
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 your time today.

 MS. TUHY: Thank you.

 CHAIR POWELL-PALM: Next up, we have Alice Runde,

 followed by Doug Currier, and then Ty O'Connor. After Ty, we

 have John Wicks, Joseph Kibiwott, and then Jess Alger.

 Alice, please go ahead.

 MS. RUNDE: Thank you. Good afternoon. My name is

 Alice Runde, I'm the coalition manager for the National Organic

 Coalition, or NOC. I'd like to start by thanking all of the

 board members for their important work.

 There's increasing consensus among the organic

 community that racial equity needs to be centered in our

 movements, creating a more equitable food system as a core

 value for the organic community. We must create a more

 diverse, equitable, and inclusive movement to achieve our

 vision of transforming our food system to benefit people and

 the planet, and I'm so excited to hear the topic of diversity,

 equity, and inclusion come up so much today.

 More and more, research shows that BIPOC farmers

 experience the same challenges as White farmers, but at much

 higher rates. Addressing these challenges would help all

 farmers. We encourage the NOSB to interact with the USDA'S

 2023 Equity Commission Reports, which includes 32 actionable

 recommendations to modify programs, policies, practices,

 cultural systems, and structures to reduce disparities and 
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 advanced racial justice and equity for underserved communities.

 Many of these recommendations would be applicable to

 the NOSB. We also recommend that the NOSB encourage the NOP to

 engage with and address the recommendations listed in the

 report, as many of these are very applicable to the NOP.

 In previous comments, NOC has recommended that the

 NOSB include racial equity as part of the CACS Subcommittee

 work. We understand that the NOSB may not have the capacity or

 resources for a standalone committee, focused on racial equity;

 however, as Abby mentioned in our response to ask these

 questions, we encourage the NOSB to find other mechanisms to

 both embed racial equity into their processes, and help the

 NOSB stay accountable to these goals.

 We are excited to hear that the board is thinking

 about including equity training in the PPM. One way to have

 racial equity be a part of the NOSB processes would be to

 include racial equity as a standing agenda item in NOSB

 meetings.

 At the Spring 2023 NOSB meeting in Atlanta, Georgia

 Organics' presentation of the legacy of structural racism in

 Georgia agriculture was extremely educational and very well

 received.

 We commend the NOSB and the NOP for including this on

 the agenda. And are grateful for Georgia Organics for their 

work and presentation. Building on the success, NOC recommends 
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 that the NOSB consider including a topic on racial equity as a

 standing agenda item for all their public meetings/

 On crop insurance and transition, we appreciate the

 NOSB creating space for the organic community to discuss

 important topics like crop insurance and transition. On both

 of these topics, NOC emphasizes the importance of making sure

 that programs and resources are available, accessible, and

 relevant to all farmers, and the value of building on existing

 successful programs.

 We also need to acknowledge and address the impact of

 historical discrimination on the access to and trust of

 government programs and authentically partner with

 organizations who have served underserved communities to

 restart building that trust.

 And finally, on residue testing, NOC applauds the

 CACS for opening the discussion on residue testing and

 handling. And NOC supports the NOSB's proposal to require

 residue testing for handling operations.

 Thank you for your time.

 CHAIR POWELL-PALM: Thank you for your comments.

 Questions for Alice? Allison, please go ahead.

 BD. MEM. JOHNSON: Thanks so much, Alice. There's so

 much in your comments, I'm -- I'm trying to process it and

 there's still questions at the same time. 

I think the -- that the thing that stands out to me 
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 most from today, or one of the things is how much is happening

 on DEI in the organic community right now. We have several

 years of very conscious efforts, trainings that are -- that

 seem to really be facilitating progress and seeing the Equity

 Commission's report come up in comments in several places, I

 think it is very closely related to that. 

And so, I'm curious for your reflection from where

 you sit on what more we, as an organic community, can be doing

 to like push to change the culture at USDA? I'm hearing a lot

 of the stakeholder shifting and that we're still bumping up

 against a very entrenched and challenging discriminatory

 history, and that progress that's being made within USDA isn't

 being dispersed equitably across the country. So, thoughts

 about sort of a -- a call to action for the organic community

 in addition to what we -- the board can do. 

MS. RUNDE: Yeah, that's such a great question, and I

 wish we had a whole week to discuss it because I don't know

 that I know personally what the call to action should be. I

 think our first step as NOC and many of our partners has been a

 lot of education and trying to understand where we are today,

 how we got to where we are today, the discriminations that

 exist in our systems today, and I think we're approaching a

 phase where we might being -- be able to discuss how we

 dismantle those, how can -- how we can create a more equitable

 system as previous commenters have mentioned, rebuilding some 
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 trust and rebuilding some relationships that have been broken

 in the past or have never existed.

 I'm not sure I'm answering your question. I'd love

 for there to be a like this is the 32nd elevator spiel of how

 we will fix the system. I -- I don't have it personally. And

 I am looking forward to getting closer to it.

 CHAIR POWELL-PALM: All right, thank you, Allison -- Alice, I

 apologize.

 Let's take a break folks. Let's take five minutes,

 come back at the top of the hour. and we'll continue with Doug

 Currier after the break. All right, see you at top of the

 hour.

 (Whereupon, a brief recess was taken.)

 CHAIR POWELL-PALM: -- presentations. I echo all of

 the comments that have been applauding the hard work and

 serious consideration that our commenters have given to the

 process so far. And thank you to my fellow board members for

 slinging some great questions, so let's keep going.

 Doug, the floor is yours. After you, we're going to

 have Ty O'Connor, John Wicks, Joseph Kibiwott, and then Jess

 Alger. Thank you Doug. Go ahead.

 MR. CURRIER: Thanks, Nate. Hi, board members.

 My name is Doug Currier, I'm the technical director

 at OMRI. I'm going to talk about inerts, everyone's favorite

 topic, but I do want to just say a word about OMRI. 
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 So, OMRI is accredited by USDA Quality Assessment

 Division, and meets ISO-17065 quality standards. Within that

 standard, there's a non-discriminatory section, and our policy

 manual reflects that. And, you know, reliance on fee-for-

 service model is not unique to OMRI.

 So, inerts. So, we see that there are two options

 here for modernizing inert ingredient review. One is the sort

 of administrative approach, where specific sections of the EPA

 regulations are referenced, and we believe that approach sort

 of meets partial review of -- of OFA criteria.

 And in many ways an extension of what we have today

 is a second option, which is sort of a non-administrative

 approach, where individual substances are reviewed so that all

 criteria required by OFA is met. We support the second option,

 though we acknowledge, you know, that the burden on NOSB and

 NOP as far as capacity concerns go, but we believe this is the

 best option because it kind of resets the bar for inert

 ingredient review, and we believe that the NOP and NOSB should

 assert USDA statutory constraints and regulatory criteria at

 all times.

 So, OMRI provides TRs, technical reports, to the NOP,

 and I'm going to give you one example within the template that

 we use. There are specific focus questions that have OFA

 criteria as a citation. So, in other words, OFA is -- is cited

 within those -- those specific questions. 
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 So, Eval Question 7 says, "Describe any known 

 chemical interactions between the petitioned substance and

 other substances used in crop production or livestock

 production. Describe any environmental or human health effects

 from these -- these chemical interactions." So, the point here

 is that without individual review you can't -- you can't answer

 that question. Also, essentiality comes into it, too.

 I also just want to point out that toxicity studies

 that EPA publishes are cited often in these TRs, so it's not

 that we ignore everything that the EPA is doing, but there's

 just -- there's more that's expected, and now as an opportunity

 to -- to develop that system. That system, you know, there's

 value -- proven value into the rigidness of a system. So,

 we've seen the value with the current system, which is rigid,

 but we think that there needs to be some flexibility so this --

NOSB rescinding its moratorium on the individual review of

 inert ingredients is an important first step in -- in building

 that flexibility into the system.

 And I'll just close here by -- by saying that beyond

 pesticides, plan -- provides the urgency to set up this

 modernized system. It's just this concern about this deluge of

 of -- of interaction with -- with pesticides of manufacturers

 that is likely, you know, going to come, so I'll leave it at

 that. Thanks for -- for your attention.

 CHAIR POWELL-PALM: Thank you for your comments. 
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 Questions for Doug? Allison, and then Amy. Please

 go ahead.

 BD. MEM. JOHNSON: Thanks, Doug. It's really helpful

 to hear from you, and it does seem like at least in the

 comments we heard so far, that there is a pretty strong

 interest in consensus in taking a look at these materials, even

 though it's gonna be a heavy lift.

 And I'm curious for your take; I've asked the other

 few folks who've commented on inerts, how many products do you

 think we're dealing with? Or how many materials? Do you have

 a sense from where you sit about what this job is going to look

 like?

 MR. CURRIER: Yeah, so we did work with WSCA, PCO to

 put together a list of -- of inverts that we know are used in

 organic production now. Within that, there's that subset, you

 know, excluding non-synthetic materials that don't need the

 review. But I -- I don't have that figure in front of me, but

 I'm thinking in the 140, 150 range all-in-all because I think

 there's -- there is something like 340 or so used in organic

 production now. Again, there's a subset that is -- is not

 going to need, you know, to -- to go through a -- a review

 because they're non-synthetic and allowed.

 The classification system, I think that Beyond

 Pesticides has kind of put out there, too, is also helpful I

 think to think about, as far as category -- categorizing as a 
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 way to add to the National List.

 CHAIR POWELL-PALM: Amy, please go ahead.

 SECRETARY BRUCH: Yeah, Doug, thanks for your time

 today. Really appreciate it.

 In the past we've talked about final products and

 fortification that could take place, even in some of the

 National List items, too. We're reviewing a petition on

 potassium sorbate, and although that's the ingredient, the

 petition also includes a formulation for the final product.

 The NOSB is not evaluating the final product, but we do -- have

 had stakeholder comments on that final product, and I'm just

 curious, 55 percent of the final product is composed of inert

 ingredients, including urea and citric acid.

 I was just wondering, does OMRI have limits on urea

 if it's -- if it's in an inert form in a finished product, just

 so supplementation of synthetic fertilizers can't take place?

 Or can you walk me through that?

 MR. CURRIER: So, for fertilizer, that -- that would

 be prohibited to use a synthetic urea source. I think where

 urea comes in is this -- the list for inert. I believe it is a

 List 4. So, you know, the -- it's a different standard, the

 crop pesticide versus fertilizer. We do sometimes see

 pesticides that claim fertilizer, so there's like a dual use,

 and so we would -- we would definitely take a look at that

 because, you know, it's -- it's a prohibited nitrogen source. 
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 SECRETARY BRUCH: Um-hum.

 MR. CURRIER: And so, if they're claiming nitrogen,

 or -- or talking about it as a fertilizer, then it starts to

 become a concern I think.

 SECRETARY BRUCH: Um-hum.

 MR. CURRIER: The -- I guess we -- we do look at

 humic acid, you know, extraction, aquatic plant product

 extraction. It -- it's a struggle to kind of know when they're

 using too much and -- and then going towards fortification,

 because there's nothing like we have with liquid fish in the

 standard that kind of, you know, sets a limit.

 But those are two examples that I know of that --

that we do look at whenever we're looking at fortification or

 non-fortification. But that passing for everyone is

 interesting because it's -- it's -- again, it's a -- it's a

 prohibited nutrient -- plant nutrient source, and so if you

 start claiming it as a fertilizer, then it's -- then it becomes

 an issue.

 SECRETARY BRUCH: Okay. And just for clarification,

 it's not -- it's not -- it's not, I guess, the purpose isn't a

 fertilizer, the -- its petitioned for an insecticide or

 fungicide, but --

 MR. CURRIER: Yeah.

 SECRETARY BRUCH: -- that just -- I just was asking

 on behalf of the community because that was where the questions 
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 were on the final product seeing urea, so, okay.

 MR. CURRIER: Yeah. Yeah, it's tough because label

 claims and -- and intentional -- the intention of using the

 product comes into play, too. So, if it's a crop pesticide,

 you might have some plant nutrients that are allowed as an

 inert because they're -- they're a List 4.

 SECRETARY BRUCH: Um-hum. Okay, thank you, Doug.

 Appreciate it.

 MR. CURRIER: Sure.

 CHAIR POWELL-PALM: Another question for you from

 Nate.

 BD. MEM. LEWIS: Hey, Doug. Good to see you.

 Curious if you had an opinion on kind of the -- a

 little bit of a hybrid inerts approach where we would list --

 where there was -- I -- I just -- in the comments of the NPR

 suggested a solution of listing some EPA references with

 except -- so, it was like a -- an allowance with a prohibition

 and -- and it's a little bit of gymnastics there, I realize,

 but I'm curious if you had an opinion about that approach?

 Kind of sort of maybe in between?

 MR. CURRIER: Yeah. I -- I -- there's a -- there's

 a, you know, this -- this practicality element that -- that's

 been at play for -- for probably as long as we've been talking

 about this, and I think that the thing with -- with referencing

 those lists is that you bypass the -- the OFA review criteria, 
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 and so while a subset of the OFA criteria could be said to have

 been met, specifically like the toxicity concerns, you're not

 going to get at all. And so, you know, unless -- unless we

 have some sort of exception for inerts, which I don't think we

 have right now, you know, referencing bulk lists is practical

 and it -- and it certainly is in line with kind of our system

 that we have now, but we're -- I think we have an opportunity

 to do something different, which raises the confidence that --

that these -- these materials are meeting the OFA criteria.

 CHAIR POWELL-PALM: All right. We really appreciate

 your expertise and time. Thank you, Doug.

 MR. CURRIER: You're welcome.

 CHAIR POWELL-PALM: Next up, we have Ty O'Connor,

 followed by John Wicks, and then Joseph Kibiwott.

 Ty, if you're there, the floor is yours.

 MR. O'CONNOR: Hello. Thank you. My name is Ty

 O'Connor. My wife Sarina and I and our family operate O'Connor

 Crops and Cattle in Southeastern Montana. It's a 50,000-acre

 dry land farm and ranching operation. We've been certified

 organic since '08. It has been an incredible opportunity.

 The organic farming allows us to grow crops and raise

 cattle for premium markets while maximizing our land

 stewardship. One thing about growing these crops, is what

 we've noticed is, the cereal grain side, the farming side,

 we've been paid premiums where they're double or sometimes even 
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 triple of conventional products, but on the beef side we've

 never exceeded 10 to 15 percent of the conventional market.

 In 2020, we -- we've shipped cattle to California --

 organic fats to California for probably eight to 10 years, and

 in 2020, we -- our shut -- or our supply got cut back because

 they said that the plant had COVID and it was not operating;

 the plant was operating, they were just trying to shorten the

 supply chain to keep prices increased in the California market.

 At that point, we kind of were fed up with that, what

 they were doing to the consumer and to us, and so we invested

 about $5 million in constructing our own certified organic USDA

 slaughter facility on our ranch here. It's operational now,

 and we have a -- quite a large organic cattle supply that we --

that we've been processing and trying to sell in local markets,

 internet markets, and then trying to get on both coastlines.

 We've encountered an issue with the supply -- the

 supply line or trying to get it to the consumer. Bigger stores

 that, you know, including some represented on this call, claim

 to support organics but do not carry organic beef, despite

 offering competitive pricing -- pricing, they opt to sell

 natural. Well, we have -- we have a ready supply of certified

 organic products.

 Distributors and co-ops in the Seattle area refused

 to allow us to sell our certified organic grass-fed beef in a

 single store or restaurant, and that's any -- on their 
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 distribution chain out there in Seattle, we've tried different

 distributors. We did -- we've hired a salesman, paid him

 $21,000 that worked four months and had zero progress in

 getting in any stores in the Seattle area with our organic

 product, and it wasn't because of price.

 For organic, especially in the grass-fed sector,

 to -- to thrive, we need grocery stores to recognize the value

 of the organic seal. We must educate stores that don't

 currently carry a -- that --

 CHAIR POWELL-PALM: Go ahead and finish your comment.

 MR. O'CONNOR: Oh, sorry.

 CHAIR POWELL-PALM: No, you're good.

 MR. O'CONNOR: I mean, to basically wrap it up, I

 mean, we just need the USDA to be aware. Public awareness

 campaigns about organic farming so consumers can understand

 what the organic seal means. And to, you know, just continue

 to strengthen that organic seal is kind of what we're thinking,

 and to make the playing field level in the organic beef sector.

 CHAIR POWELL-PALM: Thank you very much for taking

 the time to talk to us today.

 Questions for Ty from the board? Amy, please go

 ahead.

 SECRETARY BRUCH: Hi. Thanks for joining us. I

 didn't have a question, I just wanted to say thank you. Thanks

 for bringing your story. I wish I could help, but I think this 
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 is the first step is, at least letting us know of the

 challenges and hopefully our organizations that work on the

 Hill can also hear your message and work on expanding markets

 for organic farmers. I'm just impressed with your

 entrepreneurship and your vertical integration; that's what we

 need in organics, so thank you.

 MR. O'CONNOR: Thank you.

 CHAIR POWELL-PALM: I -- I had a quick question for

 you, Ty. Or actually, I'll let Mindee go and then I'll go.

 Go ahead Mindee.

 VICE CHAIR JEFFREY: Yeah, thanks guys for your good

 work out there.

 I want to be careful and not disparage anyone in

 particular, but I do -- I am really curious if when your

 salespeople went to the retailers, what were the reasons they

 gave you for saying no?

 MR. O'CONNOR: Really never had a great reason. A

 lot of running around, and then just said, no, they didn't

 think the -- the grocery stores that they were distributing to

 would be interested in that product.

 We went to a lot of organic, you know, supposedly

 where, you know, they sell organic product and -- and we did

 witness it, and we had zero luck getting in there, into these

 stores, and this was -- these were co-op stores, so that --

that doesn't make a lot of sense to me. And we have, you 
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 know -- and supply wasn't the issue. You know, that's what we

 kind of thought they'd say is, you can't supply us with enough,

 and we guaranteed them whatever they wanted because our -- our

 beef herd is big enough to supply a pretty, pretty decent sized

 chunk of Seattle there.

 VICE CHAIR JEFFREY: Thank you for your good work,

 Ty.

 CHAIR POWELL-PALM: I have a quick question for you,

 Ty. So, these grocery stores -- I don't think we have the

 chance to talk about the -- the one step between the consumer

 for selling organic and that is a grocery store -- did they

 sell -- the grocery stores you were trying to work with, did

 they have any organic beef on shelf already?

 MR. O'CONNOR: Some did. And then some did not.

 CHAIR POWELL-PALM: Okay.

 MR. O'CONNOR: You know, some of the -- some of the

 stores actually had local products, but no organic products in

 those stores. And they were not interested in a local and

 organic product.

 And then, you know, some of the stores had, you know,

 somewhat of a variety but not a huge variety of organic

 products.

 So, yeah, they had -- they have -- they had product

 in the stores, some of them, yes.

 CHAIR POWELL-PALM: All right. 
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 MR. O'CONNOR: But, you know, that's -- you know, we

 kind of targeted that area. We had done our research. You

 know, one of the two biggest cities for buying organic meat is,

 I think it's San Francisco and Seattle on West Coast.

 CHAIR POWELL-PALM: Um-hum.

 MR. O'CONNOR: So, we targeted Seattle because we

 thought that would be a great market.

 Right now, we're -- we're doing a targeting,

 marketing campaign in the Seattle area for our internet sales,

 and we'll see how that works. The -- the Internet is a

 interesting sales machine trying to get the people that we have

 something unique and organic and that we're not Butcher Box,

 that were not, you know, all the big -- the bigger Internet

 meat stores. We're trying to pursue the angle that, you know,

 we -- this -- all of our product comes from our one ranch, and

 it's all processed here on the ranch, and there -- that we

 might be the only one organic certified USDA facility in the

 nation that can say it all comes from one location.

 CHAIR POWELL-PALM: Yeah. That is awesome. Well, I

 think that there's, you know, a big conversation to have here

 with how do we get retailers to be those storytellers of why

 organic is worth the premium. And, yeah -- yeah, please go

 ahead.

 MR. O'CONNOR: But one more -- one more comment. One

 thing out there that we heard a couple times is it takes nine 
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 months to start a new product, and it's a lot of work for the

 store manager and the and the meat store manager to promote and

 start another new meat product, and that was said a couple

 times, that it's really like, really? We're already making

 money, why do we need another one -- another product to try to

 make money on?

 CHAIR POWELL-PALM: Mmm. Well, I hope there's some

 folks on this call who can ideate on this, and we can all work

 on this together to figure it out. Really appreciate you

 calling in today and taking the time to talk to us.

 MR. O'CONNOR: Thank you.

 CHAIR POWELL-PALM: Next up, we have John Wicks,

 followed by Joseph Kibiwott, and then Jess Alger.

 John, if you're there, the floor is yours.

 MR. WICKS: All right. Thanks, Nate.

 Yeah, my name is John Wicks, I'm the owner of Tiber

 Ridge Organics. I'm at drylands grain, pulse, and forage

 operation located outside of Ledger, Montana. I'm a first-

 generation organic producer, and a fourth-generation farmer,

 and I'm pretty proud to be a steward of my family's

 multigenerational farm here.

 Been certified organic since 2016, and organic has

 been a big game changer for my farm, being able to get away

 from the toxic chemicals with herbicide and pesticides, and

 ultimately running a profitable business that allowed me to 
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 keep farming. 

 Organic has been like a great opportunity for my

 farm, for me to join a community of people that work hard to

 produce food under the strictest and best regulated food

 standard we have in the U.S. That might not be possible for

 transitioning farmers in the future unless we focus on

 increasing consumer demand.

 Demand for organic is directly linked to education.

 There are a ton of myths surrounding organic, and so much

 consumer confusion, and I think that if every consumer knew how

 incredible the standards are written and the power enforcement

 behind the seal of organic, I don't have any doubt that we'd

 have a massive increase in demand for organics. That sort of

 education that's been -- that's going to be necessary to make

 consumers aware of organic, and -- is bigger than any one

 farmer or any organic group can do. We need the strength and

 brilliance of the Agricultural Marketing Service to launch an

 education campaign across the U.S. to educate consumers about

 organic. We need you to help describe the soil building

 practices required by that rule. The fact that organic is

 always non-GMO, and the fact that organic is the only food

 grown without toxic herbicides and pesticides.

 Organic has been an incredible opportunity for me and

 many other farmers like me. I'm great [sic] for all the

 resources the USDA is putting into helping farmers transition 
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 to organic. And now we need the U.S. to get -- USDA to go one

 step further to help drive the demand. Any dollars spent

 helping educate consumers about organic, earn investment in the

 viability of a small and medium sized farm. A good investment

 in rural America and a good investment for the health of our

 environment and people. Thank you.

 CHAIR POWELL-PALM: Thank you. Really appreciate

 your comments today. Gosh Dang. I think -- well, I'll see if

 there's any other questions for you, John.

 Questions from the board?

 (No response.)

 CHAIR POWELL-PALM: I think the throughline that I've

 been seeing is this question of how do we get the message out?

 There are all these farmers, about to be a lot more

 transitioning farmers, who need a strong market and we need to

 be able to communicate across the board why organic is

 exceptional. Such a good buy. So worth your dollar. And I

 know a lot of folks on this call know that already, but telling

 your neighbor how -- how great it is, is a lift.

 What would you say, John, are your -- your absolute

 favorite attributes as you've gone to be an organic farmer from

 conventional, what are the things that really settle -- settle

 in your body as far as this is so this -- is the truth. This

 is the way it's supposed to be. This is why I'm here. 

 MR. WICKS: I really just -- I look at it more as a 
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 food product rather than a commodity. And that's been, you

 know, I see the importance of making a clean product for people

 to eat, you know, and the end product is the consumer.

 Before, I was -- I was growing, you know, a crop and,

 you know, I didn't care if there was whatever going through the

 auger, and it was just kind of, you know, free for all. And

 now that I care a little bit more about that, and I realize

 that this is food for people, like it's just been really

 empowering to really focus on that. And I think that, you

 know, some of my neighbors kind of don't understand that

 they're growing a food product and, you know, they'll spray

 pesticides or whatever on it and they just don't really

 understand that this is food.

 CHAIR POWELL-PALM: Yeah. This is -- that, I -- I

 couldn't agree more. I think that is absolutely incredible.

 Allison has another question for you.

 BD. MEM. JOHNSON: Thanks, John. You have just half

 answered the question I was going to ask you, anyways, but one

 of the challenges that I run into in messaging the benefits of

 organic is that there are a lot of operations that have some

 organic, some conventional, or for whatever reason sort of need

 to state good things about all farming systems and are

 reluctant to raise organic up above any other farming system.

 And I'm curious, since you've come from a range of 

 perspectives, if you have thoughts about how to nudge people in 
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 the -- in the direction of saying good things about organic?

 And if there are ways that we can do that without disparaging

 other types of farming?

 MR. WICKS: (No audible response.)

 CHAIR POWELL-PALM: Oh, I think you're muted, John.

 MR. WICKS: Sorry, my dogs were barking so I muted

 myself real quick.

 CHAIR POWELL-PALM: Oh, good.

 MR. WICKS: Yeah, I think -- I think the best thing

 to do is definitely education and, you know, like teaching

 people that there's different ways to do things, and I think

 people get caught up in just the same recipe of this is how

 it's done, and this is what I want to do, and that -- that's

 easy and they, you know, do A, B, and C, and then they don't

 worry about it. Like, really it's been pretty enjoyable to

 learn actually how to farm. and I enjoy sharing that with

 people. And when you kind of get them caught on that little

 bug of they get really interested, and I think that that's the

 thing, is just sharing positive, you know, perspectives and,

 you know, everybody's trying to do the best that they can, and

 if you get them interested in these like different practices,

 then it just -- it steamrolls and they just get caught up in

 it.

 CHAIR POWELL-PALM: One last question for you, John. 

When we talk about educating consumers, in my head it's not 
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 necessarily that we have to decide what's better, but just

 there's such a dearth of information about -- there's so many

 myths about organic.

 Do you think it's possible that we would -- it would

 be an effective deployment of resources if we got help from

 USDA for AMS to just like explain the rule to consumers in

 layman's terms, this is a soil building rule. This is the

 animal welfare component.

 MR. WICKS: Definitely.

 CHAIR POWELL-PALM: And not even need to go into,

 this is better than conventional necessarily. People can make

 their own conclusions.

 MR. WICKS: And that's definitely it. I mean, a lot

 of the myths that you hear are just, you know, so untrue and I

 think just like explaining that to consumers, and then knowing,

 just getting that message out there of what that is, I think

 would drive people. And to know how much work that goes into

 produce that food, and how much care goes into it, I think

 people would shift that way just knowing that. And so, so I

 think it is about educating, sharing that story of being a

 farmer.

 CHAIR POWELL-PALM: Awesome. All right. We can't

 thank you enough for joining us today.

 MR. WICKS: Thank you. 

 CHAIR POWELL-PALM: And I -- it's evidence that we're 
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 having all these farmers call in virtually, it's a busy time of

 year all the time, so thank you for making the time to give us

 your comments. Appreciate you. 

MR. WICKS: Thank you. 

CHAIR POWELL-PALM: Next up, we have Joseph Kibiwott,

 followed by Jess Alger and then Jordan O'Donnell. 

Joseph, please go ahead. 

MR. KIBIWOTT: Good evening -- Good afternoon,

 everybody. My name is Joseph Kibiwott, and I am the lead

 agronomist at Timeless Seeds. My -- I'm a certified crop

 advisor and my professional training is in soil science, with a

 strong focus on soil fertility management in organic cropping

 systems. 

A little bit about Timeless. So, Timeless is for the

 last 30 -- almost 37 years, Timeless has been working with

 growers sourcing and contracting with about four dozen growers

 in Montana, and the neighboring states, to produce organic

 lentils, chickpeas, and two ancient grains, that is Emmer and a

 Purple Barley, and we want to maintain that momentum. 

So, for me as an agronomist, my job is to go out,

 meet these growers, and give them agronomic advice on how to

 improve the production of these crops. We have to acknowledge

 that the demand for organic food is increasing. Organic

 generally is increasing, and that is evidenced by the amount of

 growth that has been shown. And to maintain that momentum, we 
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 need to ensure that farmers are supported to transition more

 land, and also to maintain that certification. And thanks to

 the TOPP program that is already in place. I think that's a

 great way that we can do this. But I feel that there's still

 more to be done.

 A lot is yet to be done, and from my own speaking

 about my interaction with all these farmers that I meet every

 day, some of the challenges that are impending the growth of

 organics is for our environment it's a dry land environment,

 and some of the challenges that our farmers see, is one is on

 crop insurance. I would feel that some of the crops that our

 farmers could grow can't because they are not insured in so

 many environments. And for those who grow pulse crops, they

 cannot maintain pulse crops in the rotation because it has to

 take four years between one pulse crop to the next. And in

 between you need another crop.

 So, some of the recommendations is probably have

 inter-cropping or relay cropping and ensure a crop to ensure

 that there is continuity. That way, they can also maintain

 that certification, control the weeds, and all that.

 The other thing that we are seeing is inadvertent

 pesticide contamination of some of the crops. When we

 experience this, it's not the problem -- it's the -- the

 organic farmer is not at fault, but that crop becomes

 decertified. Not only does it affect the farmer, it affects 
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 also the process of like Timeless because we cannot market that

 crop, and our markets are affected really bad.

 And the last one that I want to say is, how do we

 educate more growers? Maybe bring in more -- more growers --

 CHAIR POWELL-PALM: Go ahead and finish you -- yeah.

 MR. KIBIWOTT: Connect growers to talk amongst

 themselves, so that experienced growers can teach the young

 growers on how to transition and to maintain that

 certification. Well, thank you for your time.

 CHAIR POWELL-PALM: Thank you so much.

 MR. KIBIWOTT: Yeah.

 CHAIR POWELL-PALM: We have a question for you from

 Nate Lewis.

 MR. KIBIWOTT: Okay.

 BD. MEM. LEWIS: Yeah, thanks, Joseph.

 First of all, my household loves your Black Beluga

 Lentils, so please keep them coming. They're the best. We

 call it black gold, and we have it with halibut, and so we have

 white gold and black gold together; it's really delicious. But

 my question is related to your -- your comment around pesticide

 drift and the impacts on prices.

 Do you know if any of the crop insurance coverage

 would cover that kind of loss? Have you encountered that

 where, you know, someone loses their certification of their 

crop or their field and then there's an indemnity from RMA for 
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 that loss?

 MR. KIBIWOTT: Just to -- to this point, we -- there

 is none.

 BD. MEM. LEWIS: Okay.

 MR. KIBIWOTT: That we know of. Actually, a very --

 we are a classic example because we've had a grower who had

 pesticide drift that affected his product, and it was

 decertified, and he can't market it anywhere, and we lost the

 potential for a market that -- that's already there. So,

 that's one thing that I really feel the USDA should come in and

 maybe find a way to -- through RMA or other insurance options

 for such growers to be compensated for the loss of a crop.

 BD. MEM. LEWIS: Okay. Thank you for that.

 Appreciate it.

 MR. KIBIWOTT: Yeah.

 CHAIR POWELL-PALM: Allison has a question for you.

 BD. MEM. JOHNSON: Thanks so much for your comments,

 Joseph.

 I'm Curious to dig in a little bit more on market

 development. I know Timeless has been really successful in

 sort of creating markets for crops that didn't have much

 consumer interface when the company started. Black -- the

 lentils being a favorite in our house, as well, now thanks to

 you. And so, I'm curious how much you're kind of doing in-

 house as far as thinking about new consumer uses for pulses? 
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 And/or if there's a collaboration with the processing industry?

 My like daydream continues to be the -- the crop rotation

 burger that someone figures out a cute marketing scheme for.

 And so, I'm -- I'm interested in the types of resources that

 you need to support market development that's already

 happening.

 MR. KIBIWOTT: Thank you very much. That is

 incredible. I would say within just Timeless alone, we try to

 connect with researchers, food researchers, to -- who want to

 do value addition so that at least we can market our products

 through different channels. One is creating some products out

 of lentil flour, adding -- doing value addition, maybe creating

 some noodles from chickpeas, but we are limited because of the

 amount of resources that are required to facilitate, you know,

 to pay for all those research and development opportunities.

 And we want to do it within the country, not just allowing

 anybody from say shipping our products overseas and letting

 those people do it, and then we have to import it back. So, I

 think there are opportunities that could help us improve on

 that if we get more say funding, more resources.

 Opportunities to teach even our own marketing teams

 or give them an opportunity to go out on trade missions that

 are specifically focused on organic especially. That would

 really help us to not just go on these trade missions but go 

out on a specific mission that focuses specifically on 
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 organics.

 And I'll just, not to take much time, but I'll give

 an example. Europe, for example, they don't allow pesticide,

 you know, contaminants in most of the product that they import,

 and I'm yet to see a specialized focused mission to some of

 these European countries just to market organics, and I think

 we have an opportunity there.

 CHAIR POWELL-PALM: Well, thank you, Joseph. Really

 appreciate you taking the time to call in today. We were just

 lamenting how we need to hear from more handlers, more folks

 processing and buying these foods from farmers and making them

 into food for consumers, so thank you for taking the time to

 join us today. We appreciate it.

 MR. KIBIWOTT: Thank you.

 CHAIR POWELL-PALM: Next up, we have Jess Alger,

 Jordan O'Donnell cancelled, so Jess Alger, and then Emily

 Moyer, and then Lisa Wade.

 So, Jess, please go ahead.

 MR. ALGER: Hi, there. I'm Jeff Alger. I raise

 certified organic cattle and hay and wheat and peas and black

 Beluga lentils, and I live in Stanford, Montana. I have

 cow/calf operation; we have yearlings and two-year-olds, and I

 sell the two-year-olds as beef. I'm here today to comment on

 the fact that we need to help consumers understand how

 wonderful organic is, and to help grow this market. 
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You often hear folks say that there's no difference

 between conventional and organic; that grass-fed conventional

 is better. Well, I disagree. I'm either -- so I can't explain

 to everyone in the country all the great attributes about

 organic myself, but I know grass-fed organic has Omega-3s, and

 is healthier for you. We need USDA to explain what organic is

 and why it's excellent. Consumers would consistently choose

 organic if they weren't confused by all the other labels. I

 think only the USDA has a big enough budget; they help us

 educate consumers about the value of organic products. 

In addition to being a rancher, I'm also a mentor to

 two -- to two -- they're new ranchers. The TOPP money that's

 recently gone out is a great investment. The great investment

 in helping manner new -- mentor new folks to transition to

 organic, but there's not growing or consumer demand for organic

 if they don't have a strong market that will keep them growing

 organic. 

I recently learned that AMS spends $15 million a year

 helping promote ham. Organic is a $60 billion industry. So, I

 hope it makes sense to everyone that we need a -- a marketing

 budget that helps educate everyone about organic. 

I appreciate the investments so far, and let's say we

 now need the USDA to allocate funds to help create additional

 educational campaigns to explain what organic is and why it's 

 great to every consumer in the U.S. Thank you. 
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 CHAIR POWELL-PALM: Jess, thank you so much for your

 comments. Really appreciate it. And that mentorship component

 is absolutely essential. I've met some of your former mentees;

 they are ranchers themselves around the state now, and around

 the country, and it's really cool to -- to see all of the work

 you're doing to try to help new farmers get into the space.

 Any questions for Jess from the board?

 (No audible response.)

 CHAIR POWELL-PALM: I've got a question for you,

 Jess.

 Could you tell us if you were to come up with a -- a

 slogan or a piece, an attribute of organic, that you think is

 just the absolute bee's knees, the thing that every organic

 consumer should know, or every consumer should know about

 organic, what resonates most with you about why organic?

 MR. ALGER: Well, most organic production is more

 nutritional, has more vitamins and minerals, and it's just

 better for you. That -- I think that -- a lot of people don't

 understand that. I know my neighbors don't.

 CHAIR POWELL-PALM: We'll start with them and then

 we'll go across the whole country. Well, I really --

 MR. ALGER: Okay.

 CHAIR POWELL-PALM: -- appreciate you taking time to

 call in today, Jess. I'm really grateful we have this platform

 to hear from so many farmers, and to only take minutes of your 
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 day, not three days and a plane ride. So, thank you so much. 

MR. ALGER: You bet. Thank you. 

CHAIR POWELL-PALM: Talk to you soon. 

Next up, we have Emily Moyer, followed by Lisa Wade,

 and then Mark Smith. 

MS. MOYER: Yes, hello everyone. Good afternoon. My

 name is Emily Moyer, I am the vice president of regulatory

 compliance and global food safety standards at the

 International Fresh Produce Association. 

So, first, thank you to the NOSB for your time and

 efforts dedicated to this Sunset Review process. And also for

 the opportunity to provide comments today. 

IFPA represents over 2500 companies from every

 segment of the global fresh produce supply chain, including

 over 500 companies directly involved in the production and

 handling of organic fruits, vegetables and florals. My

 comments today are representative of our IFPA Organics

 Committee, who similarly represent a diversity of organic

 commodity and operation types, regions, and experience. Each

 of the materials being reviewed this year are of utmost

 importance to organic producers. I'll direct the board to our

 written comments for further explanation of each substance we

 supported. Today my comments will focus on ethylene gas and

 alcohols. My colleague, Sarah Nandu Reed, will be addressing

 our positioning on plastics and plastic mulch in her comments 
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 late Thursday afternoon. 

 So, first, IFPA supports the continued listing of

 ethylene gas as a plant growth regulator. Ethylene gas is

 essential for organic pineapple production to induce flowering,

 ensure uniform ripening, and facilitate the consistent

 availability of pineapple products. Along with the impact of

 pineapples, the continued listing of ethylene gas in handling

 is critical to continue its use in post-harvest ripening of

 tropical fruit and the degrading of citrus. For each of these

 commodities, ethylene gas is used to provide organic farmers

 the ability to harvest earlier in the growth cycle, when it can

 be more -- when the products can be more easily shipped without

 damage.

 IFPA has not identified non-synthetic alternatives,

 and without these alternatives, our growers anticipate there

 would be a sharp increase in waste due to damaged product, as

 well as a subsequent decrease in accessibility of organic

 products that rely on ethylene gas for handling.

 Second, IFPA supports the continued listing of

 ethanol and isopropanol alcohols on the National List. These

 products are critical to maintain irrigation systems and

 support effective sanitation programs for our fresh produce

 growers and handlers. We believe it is critical that all

 producers have the most effective products available to them to

 clean and sanitize their equipment, and to prevent cross-
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 contamination of both human and plant pathogens.

 Currently, we understand that the organic ethanol

 market is limited in terms of production facilities, and

 certain restrictions provide challenges in the handling

 requirements of organic ethanol. As a result, our membership

 has concerns about whether there are sufficient quantities and

 if it would be economically feasible to source ethanol

 organically.

 As mentioned, we encourage the continued listing of

 additional other substances as detailed in our written

 comments. Thank you again for the opportunity to present.

 CHAIR POWELL-PALM: Thank you so much for your

 comments today. We really appreciate it. Amy has a question

 for you.

 SECRETARY BRUCH: Thanks, Nate.

 Emily, thanks for being here today and supplying your

 written comments. I was just cross -- cross-referencing your

 comments from the spring to those in the fall, and I saw in the

 spring you were in support of potassium sorbate, and in the

 fall I didn't see any acknowledgement of potassium sorbate.

 Could you just let me know a little bit about your

 stance on that product?

 MS. MOYER: Yeah. So, actually I was -- I was

 listening earlier to the comments today and I think we're in a

 very similar position as -- as Dan Langager mentioned, with at 
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 Northwest Port, just that it's something we -- if we have the

 ability to I think dig a little bit deeper within our

 membership, that's certainly something we would do, but having

 not heard that at least over these few months since the spring

 comments, we also decided to -- to take those out of our fall

 comments.

 SECRETARY BRUCH: Thank you, Emily. Appreciate that.

 MS. MOYER: Thanks, Amy. 

 CHAIR POWELL-PALM: Other questions for Emily?

 (No response.)

 CHAIR POWELL-PALM: All right, we really appreciate

 your time today. Thank you.

 MS. MOYER: Thank you everyone.

 CHAIR POWELL-PALM: Next up, we have Lisa Wade,

 followed by Mark Smith, and then Bob Quinn bumped to Thursday,

 so we're going to go to Doug Crabtree after that.

 MS. WADE: Thank you, Nate.

 CHAIR POWELL-PALM: Yes. Please go ahead.

 MS. WADE: Thank you, Nate.

 My name is Lisa Wade, and I and my family raise

 certified organic beef, pastures and forages, in Kyla, Montana.

 We first became certified organic in 2004 and have been

 continuously certified since then. And we have built our

 business around the certified organic label, slowly building a

 local consumer base. 
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 We spend a lot of time educating our customers on

 what exactly it means to be organic. So, for codifying the

 most regenerative practices of any agricultural standard that

 requires us to build soil and raise our herds without hormones,

 GMO feed or antibiotics, organic is the gold standard.

 Besides being an organic beef producer, I'm also the

 administrator of the Morgan -- Montana Organic Producers

 Cooperative. While all of our co-op members have exceptional

 quality organic beef, a lack of consumer awareness has slowed

 our growth. Of our member ranchers, many of them end up

 selling their calves each year into the conventional supply

 chain despite being certified organic. The demand just isn't

 strong enough. We need to all gather around a common message

 and spread the word about all of organics amazing attributes.

 While everyone on the NOSB and on this call, we can

 all individually educate our community and our customers as to

 why organic is so great. It will take a bigger microphone to

 spread the message to every consumer in the USA. We need

 USDA's help to educate consumers about what organic is and why

 it's an exceptional label. From raising beef without any

 growth hormones, GMO feed, antibiotics, and raising our forages

 without synthetic fertilizer or herbicides, organic represents

 the most complete system for regenerative holistic management.

 It's also the only fully transparent system out there.

 So, given the power of USDA's agriculture marketing 
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 service. and the exceptional qualities of organic production, I

 hope that the Agricultural Marketing Service will launch a

 marketing campaign to help us, the producers, spread the word

 to all the consumers in the country as to what exactly

 certified organic means. We really need your help. If we want

 new ranchers to transition, we want existing ranchers to

 continue and to grow their operations, we are going to need to

 see increased demand. Consumers will definitely demand organic

 if they better -- better understand why exactly it is so

 incredible.

 CHAIR POWELL-PALM: Amen. We have a question for you

 from Logan.

 BD. MEM. PETREY: Hey, thank you, Lisa. All right,

 so this is something we're hearing a lot, and I guess more

 recently it's been with the cattle. So, I know cattle may have

 a -- a competitor in the grass-fed.

 Do you think that that is -- having those other

 options, is that -- is that -- does that hurt you as far as on

 the demand side?

 MS. WADE: You know, in our specific case, the

 Montana Organic Producers Cooperative, we are all grass fed and

 certified organic, so we definitely see -- I think the

 consumers could see that as like the double whammy, you know,

 because people are certainly interested in grass-fed over

 grain-fed. I don't think that is a competing factor; I think 
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 people get confused about other standards or different

 certifying agencies.

 BD. MEM. PETREY: Yeah, maybe -- seeing it --

 MS. WADE: Yeah.

 BD. MEM. PETREY: -- will see grass-fed and they

 might think organic or something like that, if it's -- if it's

 on the shelf next to it, for example?

 MS. WADE: Sure, sure. Or people will say, well, are

 you certified regenerative egg? Are you certified to treat

 your animals humane? And, you know, we always say, well,

 actually organic requires all of that, like it's all-

 encompassing, but I think sometimes people think organic is one

 thing and regenerative egg's another thing, and so I think it

 would be -- maybe, you know, I think everybody in general

 understands organic is good and it's healthy and people would

 like to consume less chemicals in their diet, but they think a

 little more simple, specific marketing assistance would be very

 helpful and useful to consumers and producers both.

 BD. MEM. PETREY: Okay. And -- and another question,

 follow-up question; so when you said that the growth was

 slowed, have you seen a decrease in demand? Or have you seen

 no increase in demand recently? What's the trajectory that you

 see?

 MS. WADE: You know, it's probably very specific to

 different farms and ranches because some farms and ranches live 
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 in a community where they can direct market and they have

 enough of a population to do that. But a lot of our producers

 live in rural communities where whoever they would market their

 beef to already has cows, you know, and so they need to get

 plugged into a little bit of a larger distribution market, and

 that's where we've struggled, I think, to get the word out and

 get the beef distributed beyond the the very small rural

 communities with too small of a population for much of a

 demand.

 BD. MEM. PETREY: Sure. Okay. Thank you. Yeah, and

 North Florida seems like every other person has a cow, so I

 mean it's just kind of --

 MS. WADE: Yeah.

 BD. MEM. PETREY: -- here all the time. So, it's

 kind of calm, so I understand. Thank you for your time.

 MS. WADE: Sure.

 CHAIR POWELL-PALM: No one in Chicago has a cow, and

 that's where we need to be sending in some organic beef.

 Kim, go ahead.

 BD. MEM. HUSEMAN: Thanks, Nate.

 Hi, Lisa. I'm curious, do you have any support from

 the Montana Beef Council?

 MS. WADE: I am not aware of that specifically with

 our co-op group, or myself as a producer, so I -- I hate to say

 they're not doing that, but I just don't see that or I'm not 
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 aware of that. 

 BD. MEM. HUSEMAN: Okay. No, that's good to know

 because I know in Colorado we -- I -- I work very closely with

 the Colorado Beef Council and actually know one of their lead

 nutritionists, they do promote that structure, and wonder if

 there wouldn't be if not dollars at least a voice in that space

 to help with beef production and in the organic space on -- on

 more of a statewide footprint. I think it -- it starts local,

 right, and, you know, wonder if there's a potential to tap a

 resource there, too?

 MS. WADE: That's a good suggestion. Thank you.

 CHAIR POWELL-PALM: Great suggestion. Well, thank

 you so much for making the time to talk to us today, Lisa. I

 really appreciate it. I'm glad -- I know you have an

 appointment at the top of the hour, so I'll let you go, but I

 think it's just an example of how great it is to be able to

 take, again, 10 to 20 minutes out of the day, rather than three

 days and a plane ticket, so thank you for making the time and

 being able to share your thoughts with us.

 MS. WADE: Thank you.

 CHAIR POWELL-PALM: Next up, we've got Mark Smith,

 and then we have a caller that we passed up before, Becky Weed

 is on -- the on the call, I think still, so let's go Mark

 Smith, jump to Becky Weed, and then we'll go to Doug Crabtree.

 Mark Smith, the floor is yours. 
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 MR. SMITH: Okay, I just had to get unmuted there.

 My name is Mark Smith, and I am a certified organic

 producer of beef cattle. My family and I moved up to Montana

 to do that very thing way back in 2006. We've been

 continuously certified since 2007. Since then, we have been

 able to raise a family doing the certified organic business in

 beef. And continuous during those -- during that time period,

 I continuously found that there is this gaping hole in the

 knowledge of what certified organic actually means.

 I find it to be very distressing, even today, and

 when my wife and I were just in the truck coming home from a

 delivery the other day, we heard this term come up "Better than

 organic," and I thought to myself it's just another way of

 trying to -- trying to diminish what organic actually is, when

 in fact there's no other explanation of what better than

 organic is. In my mind, there is nothing better than organic.

 And, indeed, since we started all those years ago with our

 program, we've kind of grown up with the program and that

 we've -- we've seen the rules change, we've seen the

 certification requirements change, and that has been a good

 thing that has come along, and the USDA has done a good job at

 putting in and clarifying a good program so that we can

 continue in the certification.

 But this thing about "natural," or "just as good as

 organic," or some of the other terms that fly around is very, 
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 very difficult. Even when I speak to non-certified organic

 ranchers, they have misconceptions about what it is and what it

 isn't. Chief of which, I think if I can recall, would be that

 they think for some reason we can't vaccinate. Well, health

 and welfare of animals as we know is in fact one of the chief

 concerns that goes into each of our system plans.

 So, I would just like the USDA, really, to go on an

 education rant, if you will, via some sort of -- of program to

 educate the public in general. Even our customers. Certainly,

 our prospective customers. I find I need to continually draw

 the comparison between what certified organic is and what this

 natural thing is. So, I would just like to reiterate that we

 need to -- to continue to help this organic market grow, even

 as it's grown for us, it has been a challenge continuously over

 our certification period, what 16 years, to bump our heads

 against these misconceptions. And frankly, some of them are

 even outright lies about what it is and what it isn't.

 Well, with that I would thank you for your time, and

 if you have any questions I'd certainly like to answer them.

 CHAIR POWELL-PALM: Questions for Mark?

 (No response.)

 CHAIR POWELL-PALM: Really appreciate your -- your

 taking the time today, Mark. I know you're probably out

 delivering beef somewhere, so doing the work, and isn't it

 incredible that we have this platform that allows you to call 
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 in and make your voice heard, and not need again --

 MR. SMITH: Yeah.

 CHAIR POWELL-PALM: -- take a plane.

 MR. SMITH: I -- I'm actually out in the middle of

 Montana parked, and I am going to do some deliveries, but I

 would like to add something to what Lisa Wade just had to say.

 CHAIR POWELL-PALM: Sure.

 MR. SMITH: With the -- yeah, with the Beef Council,

 here -- here's the deal. I was formerly the administrator for

 Montana Organic Producer Co-op. Lisa, I have handed those

 responsibilities off to her, but regarding the Beef Council

 thing, I am aware of zero effort on the Beef Council's part to

 promote organic.

 Furthermore, there is a mechanism for which organic

 producers can be exempt from the $1 per head check off, and

 that was instituted some time ago because and precisely because

 the Beef Council was reticent to do anything for certified

 organic. They're all about straight on, great big commercial

 production of animals.

 So, I just wanted to add that clarity because I

 happen to know that. And if there's any other questions I can

 take them.

 CHAIR POWELL-PALM: Thank you. Just speaking, I

 think Jess mentioned it briefly --

 Well actually, Allison, please go ahead. 
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 BD. MEM. JOHNSON: Thanks, Mark. Since you broke the

 ice, I haven't wanted to put anyone on the spot, but as

 everyone's been talking about marketing, the organic check off

 is what has come to mind, and I know there's a lot of concern

 with checkoff programs and they haven't worked well for a lot

 of organic producers, a lot of smaller producers, but they're

 also responsible for the raisin campaign and the "Got Milk?"

 campaign, like the things that people think of when they think

 of good marketing.

 So, I'm curious if you as an organic producer, would

 be open -- and you don't have to answer this but I'd love you

 to, if you're willing -- be willing to have money go into a

 shared marketing pot for organic if you see benefit in that?

 Because it's hard to imagine USDA funding it although, I think

 we should ask them to, so it's one other thing that has floated

 in the orbit and I know been controversial in the past.

 MR. SMITH: Well, I guess since I took the lid off,

 and you have to ask a question about it, I'll talk about that a

 little bit then.

 The Beef Council, as you may or may not know, has had

 some really egregious malfeasances, if you will, or misuse of

 such funds, and for that reason I'm reticent to institute any

 new check off that there might be.

 Having said that, if there is a way that that sort of

 misuse of funds could be, oh, ironclad guaranteed to not -- to 
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 not happen inside of an organic thing, I would be willing to

 consider it, but boy we'd have to have a lot of brains in the

 room and really scrutinize, and then put into place proper

 accounting audit features with responsibility in order to let

 that go through in my mind. So, that's my thoughts on that.

 BD. MEM. JOHNSON: Thank you for being put on the

 spot. Really helpful answer.

 CHAIR POWELL-PALM: Thanks for bringing that up --

 MR. SMITH: Okay.

 CHAIR POWELL-PALM: -- Allison.

 And I didn't think it was literally that you're

 delivering your beef today, so I'm grateful you're feeding --

 feeding our community with your great products, so thank you so

 much for making the time.

 MR. SMITH: All right. You're welcome.

 CHAIR POWELL-PALM: All right, take care.

 We have a couple of folks that we missed. We're

 going to go to Becky Weed, and then Jodi Manuel who's on the

 line now, and then to Doug Crabtree.

 So, Becky, if you're there, please go ahead.

 MS. WEED: Okay. Are you hearing me?

 CHAIR POWELL-PALM: We can. Yes.

 MS. WEED: Okay. Thank you. Sorry, I'm late, I'm on

 the road.

 You've been hearing from a lot of people who had a 
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 lot of really good specific suggestions, and that's vital. I

 want to step back a bit and look at promotion in a slightly

 different way. I have a dream; someday the right and the left

 hands of USDA will not be working cross-purposes, and that is

 not a partisan right and left that I'm referring to.

 Agriculture has always been a combination of ingenuity and

 error that transcends political lines, so that means I seek a

 unified vision, and I have no illusions; that doesn't happen

 overnight. But the North Star of continuous improvement is a

 legitimate target for all of agriculture and really needs to go

 beyond the organic terminology from people at USDA and the

 farmers that (audio distortion) have been trying to lay the

 foundation for this common ground for decades. The most recent

 expression of that effort is TOPP. The best foundation will

 not grow any structure or flesh if we and the USDA don't have

 the pride, the confidence, and humility to promote the

 principles of continuous improvement.

 So, can we agree to promote forms of agriculture that

 work with rather than against functional natural ecosystems to

 the extent possible? Can we aim towards economic systems

 sustainability over the long haul, and aim away from unhealthy

 dependence on governmental structures? Can we promote both

 food and habitat that is healthy for people and the countless

 species we share the earth with? Those are, by the way,

 organic principles. 
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 And it may be heresy to say this at an NOSB meeting,

 but I care less about the labels than I do about the vision. I

 can't help but note the irony of the timing of this NOSB

 meeting, despite the nonpartisan premise of my comments, I have

 to remind myself that we have always lived in an imperfect

 agricultural system, just as we have always lived in an

 imperfect democracy, that both agriculture and our democracy

 must seek a more perfect union and promotion for all the same

 reasons. Thank you.

 I farm with my husband Dave Tyler in southwest

 Montana in Belgrade. I also sit on the MOA Board, and I

 appreciate the opportunity.

 CHAIR POWELL-PALM: Thank you so much for making the

 time to call in today. MOA is showing up. Appreciate it. And

 I have to give a Chair's report next week, Becky, so if you

 wouldn't mind just writing that for me I don't think I could

 ever say it better than you just said it, so that'd be great.

 Really appreciate your time --

 MS. WEED: I'll try to get it to you.

 CHAIR POWELL-PALM: -- today.

 So, we have a few more folks. We are nearing the end

 of the day today, folks.

 And Michelle, is Dana Pearls on? I think we could --

 MS. ARSENAULT: So, Nate, I don't -- we didn't finish

 the list of speakers that were signed up, and Dana's on the 
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 Wait List. 

 CHAIR POWELL-PALM: Yeah, just -- just to kind of

 give folks a roadmap of going down, if we're gonna add her at

 the end.

 MS. ARSENAULT: Okay.

 CHAIR POWELL-PALM: Or bump to Thursday.

 MS. ARSENAULT: Thank you for that. Sorry.

 CHAIR POWELL-PALM: I think we're doing pretty well.

 MS. ARSENAULT: Dana is on the Wait List, yes.

 CHAIR POWELL-PALM: Okay, so we're going to finish

 today out with Jody, and then Doug, and then Paul, and then

 Dana.

 So, Jody Manuel, if you're there, please go ahead.

 MR. MANUEL: Hello, everyone. That's a pretty tough

 act to follow with Becky on the line, but I'm just going to

 read through some collective thoughts that I had wrote down for

 today.

 My wife Crystal and I are the owners of Progress

 Ranch near -- near Havre, Montana. We are a century old

 Montana farming ranch that has been certified organic since

 2009. We raise a multitude of crops, both annual and

 perennial, as well as maintaining a certified organic beef

 cattle herd.

 Our most recent endeavor has been the launch of new

 value-added company called Gruff, in which we seek to offer 
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 lightly processed food crops from our farm directly to

 consumers online, as well as through retail outlets nationwide.

 Gruff just became the recipient of the coveted NEXTY Award for

 best organic or regenerative product in terms of innovation at

 Expo East in Philadelphia. Receiving this award was due

 largely in part to the passion and commitment of its founder,

 my wife Crystal, regarding consumer education in terms of our

 human health as it relates to our food choices.

 At the core of this educational discussion is the

 illumination of the very real aspects of what it means to be

 certified organic. These educational efforts have clearly

 shown us that the vast majority of consumers have a very

 limited perspective pertaining to USDA organic. It seems to be

 a widely accepted notion that it is nothing other than a

 marketing ploy in order to justify a higher price on the store

 shelf. We have found great satisfaction in helping consumers

 to understand that there is a very real and meaningful

 difference for foods bearing the green and white USDA organic

 label.

 This consumer confusion around USDA organic may be at

 its highest level when it comes to beef and dairy products. In

 our opinion, there needs to be valiant effort put forth to

 promote and highlight the fact that USDA organic truly does go

 beyond anything that is labeled as natural, grass-fed, or even

 regenerative. It needs to be clearly understood that USDA 
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 organic always means GMO free. Consumers need to know that any

 animal raised under the NOP is: mandated ample access to

 pasture; is free from any non-organic feed, most significantly

 GMO feed; has never been given any type of antibiotic, growth

 hormone, pharmaceutical antiparasitic treatment; as well as

 being raised according to animal welfare standards contained

 within the NOP.

 In addition to the human and animal health aspects

 dictated by the NOP, there are also the numerous environmental

 benefits that come from livestock systems that use no synthetic

 fertilizer, and are often incorporated into organic crop

 rotations, thus building the soil, removing atmospheric carbon,

 and contributing to clean water supplies.

 As the thankful recipients of a recent substantial

 USDA grant to help launch our company, Gruff, we would humbly,

 yet urgently, appeal the USDA Egg Marketing Service to

 seriously consider initiating any new programs that would help

 to educate and bolster consumer confidence with products

 labeled USDA organic.

 I thank you for this opportunity.

 CHAIR POWELL-PALM: Thank you for the excellent

 timing on that speech. Gosh Dang.

 Questions for Jody?

 (No response.)

 CHAIR POWELL-PALM: Well, first off, I just want to 
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 say congratulations, Jody, on that NEXTY Award. I think when

 we say how do we get more food into organic mouths, having a

 Montana company make an organic cereal brand and win the NEXTY

 Award is exactly what we all can aspire to.

 MR. MANUEL: Right.

 CHAIR POWELL-PALM: You -- you already said it so

 well in -- in many ways for why organic, but when you think

 about the investment that you and your wife put into building

 your brand on organic, and raising your kids on an organic

 ranch, what would be that like take away that you want organic

 consumers to know why they should be looking to organic as

 worth their -- worth their premium, worth their attention?

 MR. MANUEL: Well, it -- it's funny because like -- I

 felt it was necessary to mention the things that my wife has

 been so passionate about over the years because you've --

 you've -- we've heard it already over and over just about from

 every --every commenter today, Mark just a few minutes ago and,

 you know, it's like the gang's all together again today, but

 we've been having these conversations for years about the

 frustrations, about the lack of education, and the lack of

 knowledge with what it means to be organic, and so that's --

 that's one thing we have set out to do with this new endeavor.

 And literally, you know, in our hometown it's just -- it's

 common, it's -- it's a common sentiment that USDA organic

 literally means nothing. It just means it's more expensive and 
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 that's -- that's it, and that's --

 So that, I guess, the first step is helping the

 people that -- that are basically at Ground Zero and don't know

 anything to understand that yes, it's -- it's free from all of

 the prohibited substance. I think you can get to a level of

 consumer that -- that has that -- that concept down, but they

 don't understand that also contained within -- within the NOP

 are all of the soil building practices and animal welfare

 practices that seem to be, I think it got earlier -- earlier

 mentioned today maybe by Lisa, that with all of these other

 certifications, it -- it promotes the idea that organic doesn't

 cover those things such as animal welfare and soil building

 practices. So, I guess the -- to answer your question, the one

 take away that I would like to -- to leave in people's minds is

 that -- that the National Organic Program does, in fact, cover

 all of these bases that that all of the other certifications

 individually seek to attain.

 CHAIR POWELL-PALM: Thank you. I love that, and I

 couldn't agree more. Allison has a question for you.

 BD. MEM. JOHNSON: Yeah. Thank you so much for being

 here, Jody.

 I'm curious to hear a little bit more about your

 product development process and what you found was available to

 help you develop this new product line and what resources you

 could have used or would have helped you through the process 
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 more easily? Kind of similar to the questions I was asking

 Timeless earlier.

 MR. MANUEL: Sure. Well, I -- I'm not sure how good

 of an answer I'll be able to give you today because we are

 literally at the ground level, just -- just getting started,

 and as I briefly mentioned in earlier comments, you know, we

 did apply for grant through the Rural Development Office for a

 Value-Added Producer Grant. That, of course, was instrumental.

 You know, I don't think we could have done it without that.

 So, in that process, if we were ever to do that

 again, I mean, we -- we've learned so much, not only in the --

 in the grant application, but post-award; just things that we

 would be able to do more efficiently next time for disbursement

 and things like that.

 As far as other tools and resources, like I said,

 we're -- we're -- well, there's an organization in Montana

 called Mission West, that's a nonprofit organization that --

that that helps businesses like ours with just like such a wide

 range of things, from packaging and processing to nutrition

 label design, and -- and requirements and, about I mean

 anything you can imagine.

 The Montana Department of Agriculture has been

 instrumental where we -- we just attended the Montana Food and

 Beverage Show in Missoula yesterday, and I just, you know, 

 they're -- they're bending over backwards to -- to help in any 
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 way that they can. Bear Paw Development in Havre has been

 really great, as has Snowy Mountain Development in Lewistown.

 You know, they're just local business development companies and

 we're really thankful to have them helping us along the way, as

 well.

 BD. MEM. JOHNSON: Thank you. And congratulations.

 Exciting.

 MR. MANUEL: Thank you. I hope I answered your

 question okay.

 BD. MEM. JOHNSON: Yeah, it was great. I appreciate

 it.

 CHAIR POWELL-PALM: Kim has a question for you, and

 then Jerry.

 BD. MEM. HUSEMAN: Thanks, Nate.

 And thank you, Jody, and congratulations. Very

 excited for -- for you and your wife, and that's -- that's an

 amazing award, so I want to start there.

 As we talked about marketing and the way to reach

 people, the Internet obviously has connected people outside of

 your local geographic region, outside of the state, et cetera,

 et cetera, and this might be a little elementary, maybe I just

 don't know, I'm just curious though, have you had any barriers

 to entry, like from a broad brush platform standpoint to sell

 your products? Or do you find like it has to be zoned into one 

 particular facility to not hamstring your operation? I --
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 what -- I'm just trying to open up that door to see if there's

 any -- anything from the -- the online marketing that could be

 done?

 MR. MANUEL: Oh my goodness. Oh --

 BD. MEM. HUSEMAN: What -- staying within a minute,

 so time.

 MR. MANUEL: So, the name of the company, Gruff, it's

 based on the folk tale of the three Billy Goats Gruff and the

 Troll, and we -- what we -- you know, what Crystal and I -- we

 just automatically assume that everyone would be as familiar

 with that story as the people are with Goldilocks and the Three

 Bears, and we found that's simply not true. It's --it's maybe

 half of people we come across, so there may be people on this

 call that don't know, have any idea what I'm talking about, but

 not having really time to go into the story, there's a troll

 that stands on this bridge and -- and you know, the goats want

 to get across to the other side where the good food is and they

 hatch this plan; that's the premise behind Gruff. And so, it's

 like this metaphor for so many things, but it -- it kind of

 comes down to this broken industrial food system and that's

 what we're -- we're wanting to be a small part of helping to --

 to fix or to get around. And -- and one of those things that

 I -- that I -- one of the things that's become the troll for us

 since we've jumped into this, not having a clue what we're 

 doing, it's this whole world of retail and distributors and --
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 and brokers and, you know box store chains. When we -- when we

 very first started the goal was to just do online direct to

 consumer, and we -- we weren't even thinking about anything

 else, but then through an unforeseen chain of events that had

 to do with another Montana company called Cream of the West,

 it -- it led us into that world of brokers and distributors and

 retailers, and so we're learning how to navigate that as we --

 as we go. 

So, I guess, I'm not sure If I can give you a great

 answer today, but I -- but I would like to say that we would

 love to be available in the future to -- to help anyone along

 the way with what we've learned through this process, and --

and we're hoping by the end of it all that -- that we're able

 to knock the troll off the bridge and -- and everyone can cross

 freely. 

BD. MEM. JOHNSON: I like your story. Thank you so

 much, Jody. 

MR. MANUEL: Thank you. 

CHAIR POWELL-PALM: Jerry, go ahead, and then we're

 going to actually finish up today with Doug, and then Paul, and

 then recess, and we'll reconvene on Thursday. 

So, Jerry, please go ahead. 

BD. MEM. D'AMORE: Okay. Well, Jody, I like the

 story, too, and yes, I -- I know that story and have known it

 for many, many years. I -- I'm -- I'm wrestling with the -- a 
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 number of the callers today that have a -- a very common theme.

 We've identified trends and themes, and -- and it strikes me

 that -- and I've heard it said for many of you, that -- does

 there have to be a comparison? Does there have to be better or

 worse? Is there, you know, what -- you know, how do we -- how

 do we grapple with our message, basically? And, you know, I've

 been look -- thinking about this since 1980, and -- and for me

 there -- there the label is first and foremost a guarantee.

 It's a guarantee and a contract between a producer that's

 willing to put more effort into it, and a consumer that's

 willing -- willing to pay a little bit more for that -- for

 that effort. And -- and I think the thing that frustrates me

 most in listening to all of you is when you try to tell your

 story you run into to roadblocks, and I think some of you run

 into moral roadblocks of not wanting to tear down something

 just to build yourself up. I hear that, too.

 So, I -- the story that I think is most compelling

 can be very, very gently told about this organic seal, which is

 it is the only thing that has the teeth in it for enforcement.

 It's the only thing that is regulated to a gnat's rearend,

 and -- and that can be quoted and demonstrated and -- and

 followed up upon.

 So, you -- in my mind it has a lot of value that does

 not have to start with better or worse; it just starts with

 a -- a contract that guarantees certain performance and that 
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 nobody else has. We talk regenerative, sustainable, on and on

 and on, nobody else; you just look at them and ask this very

 simple question, how do you guarantee that what you're

 representing can be enforced? And -- and so. And that's why

 there's so much of a -- of a coming together between the

 organic label and the other labels, because their coming into

 the organic label gives them the -- the teeth of the organic

 label for all that they do.

 So, again, I -- I'll stop with this; is it doesn't

 have to be in the face good and bad; it just has to be with

 performance, and -- and what's -- and what is actually real.

 MR. MANUEL: Amen.

 BD. MEM. D'AMORE: So, thank you. I've loved

 listening to all of you today.

 MR. MANUEL: I hope that I did not come across in

 that -- in a negative fashion that way, because like --

 BD. MEM. D'AMORE: Not -- not at all. You -- but

 there's a whole bunch of you that have the same frustrations.

 MR. MANUEL: Yeah.

 BD. MEM. D'AMORE: So, I'm -- I'm taking a collective

 frustration with what does this mean? Well, it literally means

 not much. It has a definition, but it has no enforcement

 capability. And I -- I don't want to -- you know, I don't want

 to be a pain in the neck on that, it's just that this organic

 this -- organic seal's got a long history and one that's been 
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 shepherded, I think, extremely well, and it does have a lot of

 value. You just have to know how to present it. So, thanks.

 MR. MANUEL: Okay, thank you.

 CHAIR POWELL-PALM: We really appreciate your time

 today, Jody. Thank you so much for joining us and for your

 good work.

 We're going to jump to Doug Crabtree, followed by

 Paul Neubauer.

 MR. CRABTREE: Okay, well it's -- it's great to see

 so many friends on this call, on both sides of the screen.

 So, my name's Doug Crabtree, and my wife Anna and I

 steward approximately 12,500 acres up here in North Central

 Montana. We have a diverse cropping operation. We grow to

 different crops any given year. Also, a little newer to us a

 small highland cattle fold, and a custom grazing enterprise

 that that Paul will tell you more about, but we're integrating

 cattle grazing into our cropping system. Our operation has

 been certified organic from the start, since we bought the

 first land in 2009.

 In addition to organic crop and livestock production,

 we also -- primarily my wife Anna, has started a nonprofit

 called the Bellicus Institute, that's dedicated to training and

 incubating new agrarians, developing associative economy around

 food and farming, promoting agroecological learning, and

 supporting the union of arts with agriculture. Through this 
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 institute, we've hosted more than a dozen apprentices over the

 past several years.

 Organic has grown to over a $60 billion industry,

 from starting at less than one billion when the standards were

 established. This is a great accomplishment considered that

 there has never been a check off program or any other

 significant promotion coming from USDA. I'm encouraged that

 the Transition Partnership Program will -- will help us

 transition additional farmers, hopefully a good number, and

 that there is some grants that are helping organic businesses

 improve processing infrastructure. We're -- we're proud to to

 be an applicant for those. But really the only way to ensure

 that -- that this industry continues to grow is to make sure

 that the demand keeps up, and to do that we need education and

 promotion.

 We would like to see the USDA launch some programs to

 help educate consumers as we've been discussing what organic

 really is, because as everyone has -- has said, and I see it as

 well, there's a lot of misinformation. I believe it's only

 fair that organic farmers receive our fair share of -- of USDA

 investment in marketing education. While we've grown the --

the organic movement without that kind of support, at this

 stage we need and deserve our share to move forward. All the

 great attributes of the seal need to be in every school, on

 every store shelf, and anywhere the USDA is helping folks be 
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 informed. So, thank you again for this opportunity.

 CHAIR POWELL-PALM: Thank you so much. I realize you

 are still in harvest, Doug. Lots of farmers are still

 harvesting, so again to be able to make your voice heard I

 really appreciate you taking the time out of your day. It's

 really, really important.

 Questions for Doug?

 (No response.)

 CHAIR POWELL-PALM: All right, we really appreciate

 your time today, Doug. We're going to jump to Paul and hear

 about this grazing business you mentioned.

 Paul Neubauer, if you're on, please go ahead.

 MR. NEUBAUER: I am here, thank you, Nate.

 So, Doug mentioned that we work together, and in fact

 we do. I serve as the assistant manager at Bellicus Farms in

 northern Montana, and I also have my own custom grazing

 business that's closely integrated with the farm operations

 called PN Custom Grazing.

 So, my name is Paul Neubauer, and I'm not from

 Montana originally; I actually grew up in Buffalo, New York and

 I'm a first-generation farmer and rancher. I have been working

 in organic farming and ranching from the very beginning of my

 experience more than a decade ago. So, I do not really know

 how to do what I do any other way than with organic methods,

 and with an organic philosophy in mind. And that's shaped a 
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 lot of the decisions I've made over my career and where I've

 gone and who I choose to assist with, Doug and his wife Anna,

 being chief among those people.

 I also have a bit of a sideline that isn't paid,

 unfortunately, comes mostly from my ethics and dedication to a

 better rural livelihood for myself and all of my neighbors. I

 have a bit of a sideline as the president of the Montana

 Premium Processing Cooperative, which is based here in Havre,

 and is a project created in close cooperation with the Montana

 Farmers Union. And then I also serve as president for my

 Montana Farmers Union Local, and many times now as a delegate

 to the National Farmers Union Convention.

 I think that my ability to enter agriculture as a

 first-generation producer is really closely linked to the

 existence of the certified organic label and the creation of

 the markets that certified organic production practices makes

 possible. Like I said, I've only ever been in organic

 operations and the ones that I see which have opportunities for

 new and aspiring agricultural producers to join in, to find a

 foothold in agriculture tend to be organic. I can't really

 speak to why that is exactly, except to say I suspect it's

 because there's greater opportunities because of the organic

 premium.

 I'm also here not just to talk about how much I love

 organic agriculture, or how important organic certification and 
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 the label is to me, but also to describe or rather point out

 that the organic community needs to build a wider network and

 keep its eye on the prize, which is that a rural America that

 works for everyone in a food system that heals the land is best

 for organic producers, as well as the consumers of organic.

 Geez, that beep is intimidating. I didn't hear that

 before.

 CHAIR POWELL-PALM: Go ahead and finish up if you got

 it.

 MR. NEUBAUER: Yeah, sure. Thank you, Nate.

 The point being, you know, my -- my involvement in my

 agricultural community is not just with organic producers with

 the Montana Organic Association, but also with the Farmers

 Union, which represents far more than just our organic

 producers. And organic can't just be an intellectual exercise

 that nonprofit employees debate to compete for donations;

 organic is a system that gives us all a shot at rural

 sovereignty. If we adhere to a well-considered written set of

 standards, and for which there is a premium market, organic

 represents the chance to reclaim the dream to farm and make a

 good living doing it, which is exactly the mission of the

 Farmers Union.

 And organic is just a piece of the puzzle. There's a

 few aspects of work happening right now in the agricultural

 sphere that organic producers can align with to build coalition 
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 politically and socially, and also to make these projects more

 possible. So, some specifics there would be the Right to

 Repair Movement, country of origin labeling, movements for

 cooperative marketing, and having -- finally having the USDA

 spend money educating consumers about what organic is.

 That's it. Okay, I've done it.

 CHAIR POWELL-PALM: Thank you so much, Doug and Paul,

 and all the farmers, top to bottom. I think this might be the

 most farmers we've ever heard from in a single day, and that's

 saying something, so thank you for taking the time and making

 your voices heard. Really appreciate it.

 And I'm excited about what -- what this throughline

 might mean; how do we get that -- the word out about organic

 and grow this demand to make opportunities for more farmers?

 That's it folks for the day. What a good day. We

 are going to do it again on Thursday.

 Michelle, any closing remarks or -- or logistics for

 the -- for everyone online?

 MS. ARSENAULT: Just that -- yeah, Andrea is getting the slide

 up. We are meeting in the same place, at the same time on

 Thursday. My -- I really want to say it, same Bat time, same

 Bat channel, on Thursday. The same link that you used today to

 log in will work on Thursday, as well. And thank you for

 joining us.

 Great job, Nate. Great job, Board. Thank you so 
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 much.

 CHAIR POWELL-PALM: Thank you everybody. Fantastic

 working with you. See you on Thursday. Take care.

 (Whereupon, at 5:28 p.m. the webinar was adjourned until

 Thursday, October 19, 2023, at 9:00 a.m.) 
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ished at the 

226

 CERTIFICATION

 This is to certify that the attached proceeding

 before the:

 NATIONAL ORGANIC STANDARDS BOARD

 IN THE MATTER OF: FALL 2023 ORAL COMMENT WEBINARS

 PLACE: Zoom for Government Webinar

 DATE: October 17, 2023

 was held according to the record, and that this is the

 original, complete, true and accurate transcript, which has

 been compared to the recording accompl hearing. 

 __________________________

 Elaine M. LaRosee,

 Official Reporter 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 1 

October 17, 2023 

117:13 

absence (1)

 122:23 

44:2;45:7;47:8;

 142:12;163:10;

 166:15;184:22 

60:20;62:20;63:11;

 69:3;71:16;74:12;

 83:8;100:15,17;

 82:12 

administration (1)

 127:19 $ 

$1 (1) absent (3) acknowledged (1) 136:24;139:24; administrative (1)

 203:15 11:17;39:11;126:15 150:1 144:21;145:10; 166:8 

$1,000 (1) absolute (2) acknowledgement (2) 148:15,20;150:23; administrator (2)

 20:1 180:20;191:13 154:1;194:20 175:9;176:17;182:16; 196:7;203:9 

$15 (1) absolutely (16) acknowledging (1) 187:5;194:23;198:11; admit (1)

 190:18 16:18;33:2;43:3; 116:3 200:4;201:9,14; 15:1 

$21,000 (1) 51:18;57:20;75:22; acre (1) 203:4,25;216:20; adopted (1)

 174:3 108:14;136:23;138:9, 19:14 218:11;221:20 80:15 

$5 (1) 17;139:11,21;146:8; acreage (3) Adam (1) adulteration (1)

 173:11 156:8;181:15;191:3 135:21;146:16; 33:9 44:16 

$60 (2) ACA (16) 149:17 add (11) advance (1)

 190:19;220:3 66:19,20,25;67:5,

 12,19;68:4,10,13;

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ACA's (2)

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accept (2)

 145:19,20 

accepted (1)

acres (4)

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acronym (1)

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across (18)

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 40:10,20;66:24;

 83:17;88:18;116:4;

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 20;208:3 

added (5)

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 127:6;145:17 

adding (2)

 150:11;188:12 

8:20 

advanced (1)

 162:1 

advances (1)

 36:14 

advancing (2)

 122:13;123:11 

advantage (2)

 34:25;124:11 

* 

*6 (1)

 6:24 

[ 

[sic] (7) 209:14 133:21;148:2;164:13; addition (8) adversarial (1)

 23:9;56:19;82:6; access (11) 179:18;180:16; 59:2;132:4;164:15; 89:14 

92:25;100:17;148:10; 8:8;92:11,16;94:12; 191:21;215:13,17; 188:10,12;190:11; adverse (1)

 179:24 104:14;107:17;115:3;

 141:14;158:14;

 163:11;210:2 

accessibility (2)

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accessible (3)

 67:18;114:25;163:7 

accommodating (1)

 34:9 

accomplishment (1)

 220:5 

according (2)

 22:23;210:6 

account (1)

 86:16 

accountable (2)

 97:3;162:13 

accounting (2)

 23:13;205:4 

accreditation (1)

 127:9 

accredited (5)

 53:25;66:18,21;

 68:6;166:1 

acetate (5)

 35:21;36:1,4;42:9;

 119:15 

achieve (2)

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achieved (2)

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acid (13)

 37:9,18;38:7;39:1;

 40:15;64:13;98:12,

 17;99:20;100:1;

 102:11;169:13;170:7 

acknowledge (7)

 218:15 

ACS (1)

 35:1 

Act (8)

 8:14,15;33:5;60:7;

 91:23;144:21;145:12;

 208:15 

action (10)

 17:6;48:25;50:9;

 80:7;122:16;131:5;

 132:15;138:4;164:14,

 18 

actionable (1)

 161:23 

active (10)

 14:5;59:2,5;61:24;

 68:13;86:25;87:3;

 89:17;92:19;159:1 

actively (2)

 69:14;139:23 

actives (1)

 86:22 

activities (2)

 67:10;127:10 

activity (2)

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acts (2)

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actual (8)

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actually (45)

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additional (14)

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 82:24;101:17;123:17;

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 150:14;190:23;

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Additionally (1)

 27:9 

Additives (3)

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address (12)

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addressed (4)

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addresses (1)

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addressing (4)

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adds (1)

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adequately (1)

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adhere (1)

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adjourned (1)

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adjust (1)

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adjusted (1)

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adjusting (1)

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advertising (1)

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advice (3)

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adviser (1)

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advising (1)

 152:19 

advisor (1)

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advisors (1)

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Advisory (2)

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advocacy (1)

 125:7 

advocate (3)

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advocating (1)

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affect (4)

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 185:25 

affected (2)

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affects (1)

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affiliate (1)

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affiliated (1)

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affiliation (3)

 7:3;12:24;48:17 

affiliations (1)

 12:14 

afraid (2) 

§ 

§205.606 (1)

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A 

A&M (1)

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Abby (12)

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 5;129:11,14;155:11;

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ability (11)

 7:24;19:17;20:5;

 36:13;73:13,15;

 76:23;127:19;193:11;

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able (34)

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 22:12;56:14;60:14;

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 139:24;140:21,23;

 141:11;155:21;

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 178:23;180:16;

 200:16,19;201:6;

 213:4,13;216:13;

 221:4 

above (2)

 151:25;181:23 

abroad (1)

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(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 1 

October 17, 2023 

4:20;157:24 agriculture (23) alarming (1) 7:25;46:9;65:4; 15:5;129:21;155:9;

afternoon (12) 14:24;15:3,12; 140:24 119:3;145:15;173:24; 180:5;223:3 

10:5,6;26:15;64:4; 16:10,13;23:13; Alberto (1) 189:3 American (1)

 93:13;110:6;122:10; 43:17;80:22;112:10, 63:22 allowable (3) 105:21 

144:7;161:7;184:8; 15;123:2;144:22; alcohol (1) 117:6,25;136:20 America's (1)

 192:6;193:1 162:21;196:25;206:6, 119:24 allowance (1) 16:4 

afterward (1) 10,18;207:7;213:22; alcohols (4) 171:17 among (3)

 7:14 219:25;222:13,20,25 81:23;98:14; allowed (14) 67:8;161:11;222:3 

again (22) agroecological (1) 192:24;193:20 13:2;59:21;86:11, amongst (2)

 8:2;17:17;29:3; 219:24 alfalfa (1) 11;90:12;100:6; 133:14;186:6 

63:20;74:22;80:25; Agroecology (2) 104:4 111:1;118:22;133:4; amount (5)

 109:6;121:16;132:20; 72:12,14 Alger (11) 136:20;150:11; 73:10;89:17;

 142:16;149:2;168:20; agronomic (1) 161:5;165:21; 168:22;171:5;178:25 108:15;184:24;

 170:15;194:11; 184:21 178:13;184:6;189:15, allowing (5) 188:14 

200:17;203:1;211:18; agronomist (2) 16,19,19;191:16,22; 29:3;50:4;59:10; amounts (2)

 213:11;218:9;221:1, 184:10,20 192:2 95:9;188:16 73:15;117:25 

4;224:16 ahead (69) alginates (1) allows (3) ample (1)

against (9) 5:8;15:25;18:7; 64:13 83:9;172:21;202:25 210:2 

14:20;21:6;99:3; 20:8;21:24;24:8;30:9; Alice (8) alluded (1) AMS (5)

 105:13;108:10;123:7; 38:24;43:13;47:3; 149:5;157:3;161:3, 36:25 61:8;158:11,11;

 164:11;202:16; 52:23;54:4;58:4; 6,8;163:21,22;165:7 almost (3) 183:6;190:18 

206:19 61:10;62:21;68:22; align (1) 31:8;154:5;184:15 Amy (25)

age (2) 69:23;72:5;74:3; 223:25 alone (2) 9:19,21;21:24;29:7,

 146:3;158:19 76:16;78:19;87:20; aligning (1) 87:3;188:8 22;36:19;45:15;47:6;

agencies (5) 89:23;91:2;93:7;95:6; 17:19 along (13) 68:22;70:2;76:16;

 69:16;94:23; 100:5,15;102:5; alignment (1) 4:16;6:17;24:7; 83:23;84:3;95:20;

 128:18;142:14;198:2 106:10;107:13;110:2; 64:17 29:24;49:11,24; 97:12;112:21;126:2;

agenda (8) 112:21;115:21; alignments (1) 50:19;104:2;141:17; 151:16;153:14;

 20:6;22:20;26:24; 116:23;120:2;121:7; 17:22 193:6;201:21;214:4; 159:24;168:1;169:2;

 98:22;130:3;162:17, 122:8;124:13;126:2; aligns (1) 216:11 174:21;194:13;195:8 

24;163:2 128:3;131:24;132:22; 130:10 alphabet (1) analysis (5)

agglomerate (1) 135:5;139:1;143:3, alkaline (1) 71:3 75:19;77:16,22;

 46:15 25;152:15;161:6; 82:11 alternative (3) 113:9,12 

ago (18) 163:21;165:21;168:2; all- (1) 23:5;80:6;100:1 analyzed (1)

 17:6;21:7;35:13; 169:2;174:10,22; 198:11 alternatives (10) 67:17 

41:25;50:6;73:1; 175:10;177:23;184:7; allergens (1) 37:16;64:18;65:24; anchored (1)

 74:10;80:10;104:15; 186:5;189:18;195:18; 92:15 66:1;100:22;117:19; 138:18 

135:14;144:17; 199:19;203:25; alleviate (1) 118:8,17;193:14,15 ancient (1)

 149:20;155:6;160:11; 205:20;208:13; 66:23 although (2) 184:18 

201:17;203:16; 216:19,22;221:12; Alliance (1) 169:8;204:14 ancillary (1)

 211:17;221:23 223:8 72:11 always (21) 92:13 

agrarians (1) aid (1) Alliances' (1) 39:15;69:19;71:8; and/or (4)

 219:23 130:23 87:16 93:25;106:14;118:13; 65:19;76:12;

agree (6) aim (2) all-in-all (1) 130:15;132:8,10; 102:12;188:1 

60:11;73:8;116:11; 206:20,21 168:18 142:1;146:1;151:3; Andrea (3)

 181:15;206:18; aimed (1) all-inclusive (1) 158:13,13;160:12; 9:1;11:20;224:19 

212:19 67:17 119:22 179:21;198:10;206:6; anecdotally (1)

agreement (3) aims (1) Allison (28) 207:5,6;210:1 156:9 

67:11,13;70:20 67:21 10:10,12;30:9;31:1, amazed (1) angle (2)

agreements (1) ain (1) 23;51:20;60:9;75:1, 68:12 70:5;177:14 

70:7 142:24 25;89:23;107:13; amazing (3) animal (9)

agrees (1) air (1) 120:2;124:13;125:1; 156:9;196:14; 92:9;110:15;123:8;

 94:17 79:12 137:19;139:1,11; 214:17 183:8;210:2,6,8;

agribusinesses (1) airport (2) 146:12,13;152:15; ambitious (1) 212:8,12 

21:18 93:12;95:25 163:21;165:7;168:1; 75:20 animals (5)

agricultural (12) Alabama (1) 181:16;187:16; Amen (4) 14:12;106:18;

 14:5;39:8;64:14; 142:23 203:25;205:10; 109:16;159:23; 198:10;202:5;203:19 

105:25;112:13; Alan (9) 212:19 197:11;218:12 Anna (3)

 179:17;196:3;197:2; 13:4,23,25;14:4; Allison's (1) amend (1) 219:11,21;222:2 

207:6;222:19;223:12, 15:25;16:1;18:11,25; 54:5 65:3 anniversary (2)

 24 25:25 allocate (2) amendments (2) 68:12,24 

agriculturalist (1) Alar (1) 59:1;190:23 123:2,8 Annotation (7)

 23:24 91:19 allow (7) America (5) 35:13;39:3,13; 

Min-U-Script® Burke Court Reporting & Transcription (2) afternoon - Annotation 

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October 17, 2023 

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 120:9 99:5,16,17;101:4,25; 59:16;60:5;133:5 67:15;222:19 71:18;157:12 

annotations (2) 213:12 approximately (1) assert (1) attended (1)

 39:23;40:4 applications (4) 219:12 166:19 213:23 

announce (1) 64:19;65:22;68:1; April (2) assertion (1) attendees (1)

 12:22 99:9 29:5;65:16 73:8 4:17 

announced (1) applied (4) aquatic (1) assess (1) attention (8)

 33:5 25:5;59:10;130:21; 170:7 88:20 51:22;53:14;58:17;

annual (5) 132:21 Arabic (1) assessment (4) 66:4;87:15;132:12;

 22:25;96:17; apply (1) 64:15 91:25;130:23; 167:24;211:12 

122:25;127:15; 213:7 area (11) 152:7;166:1 attributable (1)

 208:21 appointment (2) 20:21;97:9;102:23; assessments (1) 49:12 

annually (1) 23:21;200:15 113:17;139:10; 151:23 attribute (1)

 127:17 appreciate (76) 157:24;160:5;173:23; assignment (1) 191:12 

anomalies (1) 29:10;30:11;31:22; 174:4;177:2,9 60:2 attributes (5)

 39:8 33:17;36:22;43:4,16; areas (7) assist (2) 106:4;180:21;

ANPR (3) 45:18;47:1;48:9; 30:17;103:5,6; 44:24;222:2 190:4;196:14;220:24 

76:9;87:6,16 51:21;54:2;57:25; 110:14;127:23;130:2; assistance (7) audible (7)

answered (2) 60:11;61:11;63:20; 133:21 94:25,25;105:22; 10:17;11:8;78:20;

 181:18;214:8 66:10;69:13;75:5; arena (1) 150:25;151:2;152:20; 115:22;144:1;182:4;

antibiotic (2) 76:15;78:8;81:2; 95:4 198:17 191:8 

158:14;210:4 100:14;102:9;106:7, argon (1) assistant (1) audience (3)

antibiotics (3) 7;108:24;109:17; 92:17 221:15 7:23;8:3;140:21 

104:24;196:5,21 115:19;116:1;122:5; arise (1) assisted (1) audio (5)

anticipate (1) 123:19;128:1,5; 36:7 28:19 21:16;55:11;64:18;

 193:15 129:13,25;132:1; arises (1) associated (1) 65:12;206:12 

antimicrobial (1) 134:4,24;137:18; 110:15 6:16 audit (1)

 118:5 139:3;143:22;146:14; Arnone (6) Associates (2) 205:4 

antioxidant (2) 151:20,21;152:14; 48:15;58:3;64:2,4, 34:1;72:11 auditing (1)

 117:17;118:17 153:25;154:2;159:3; 5;66:12 association (13) 23:11 

antiparasitic (1) 160:25;163:3;169:4; around (26) 64:7;66:18;67:15, auger (1)

 210:5 171:8;172:10;178:9; 16:23;18:16;55:8; 20;93:14;98:1; 181:6 

antitrust (2) 180:7;184:3;187:14; 67:15;70:16;74:10; 129:19;135:8;149:9; August (1)

 107:24;108:2 189:9,13;190:22; 101:19;103:4;120:7, 155:9;157:11;192:9; 65:7 

anyways (1) 191:2,23;194:13; 17;126:1,24;132:3; 223:13 Austin (13)

 181:18 195:7,11;200:14; 137:11;147:14;158:8; associative (1) 85:17;93:3;97:18,

apologetic (1) 202:22;207:12,14,18; 175:18;186:20;191:4, 219:23 21,23,24;100:24;

 154:15 214:10;219:4;221:5, 4;195:24;196:13; assume (2) 102:4,7,8,14;103:14,

Apologies (2) 9;224:11 201:25;209:20; 39:16;215:10 18 

10:19;11:10 appreciated (3) 215:22;219:23 assumed (1) authentically (1)

apologize (1) 15:16;152:17; arrival (1) 129:8 163:12 

165:8 153:16 113:5 assuming (2) authority (2)

appeal (1) appreciates (2) arrive (1) 37:13;155:15 59:20;79:8 

210:16 26:25;93:16 74:21 assumptions (1) authorization (2)

appear (1) appreciation (1) ARSENAULT (42) 90:17 126:24;127:16 

77:9 47:5 4:3;9:1,9,12,16,19, assurance (1) Automated (2)

appears (3) apprentices (1) 21,24;10:2,6,9,12,15, 111:20 51:1,13 

47:14;57:2;136:1 220:1 18,22,25;11:3,6,9,13, astonished (2) automatically (3)

applauding (1) approach (7) 16;13:5,8,11,13,17, 42:15,16 39:14;129:8;215:10 

165:15 83:16;130:10; 21;14:1,3;58:6;63:24; astounded (1) availability (16)

applauds (1) 166:8,9,13;171:14,19 71:23;78:21;84:3,5; 149:19 34:12,17;35:1,13,

 163:15 approachable (1) 109:23;144:2;207:24; astronomical (1) 24;37:11,14;39:6,12;

applause (2) 117:22 208:5,7,9;224:19 76:7 40:20;46:20,23;

 9:5,6 approached (1) arts (1) Atlanta (2) 83:18;119:18;160:19;

apples (1) 70:7 219:25 123:20;162:19 193:6 

81:14 approaching (1) aspect (4) atmospheric (1) available (15)

applicable (3) 164:22 32:17,19;74:20; 210:12 5:1;6:1;30:24;

 125:15;162:2,5 appropriate (1) 115:5 attach (1) 46:12;67:8;68:5;

applicant (1) 53:1 aspects (5) 37:4 106:20;117:22;118:5;

 220:12 appropriated (1) 67:4;150:20; attacks (2) 137:4;156:1;163:7;

applicants (1) 127:17 209:10;210:8;223:24 8:20;12:17 193:24;212:23;

 150:25 appropriations (2) aspire (1) attain (1) 216:11 

application (9) 123:2;127:15 211:4 212:17 Avenue (1) 

Min-U-Script® Burke Court Reporting & Transcription (3) annotations - Avenue 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 1 

October 17, 2023 

142:24 

average (2)

 19:14;22:25 

avert (1)

 122:17 

avoid (4)

 8:20;26:1;39:20;

 50:5 

Award (5)

 209:3,5;211:1,4;

 214:17 

aware (9)

 66:1;99:10;113:7,

 12;174:14;179:15;

 199:23;200:1;203:12 

awareness (3)

 120:16;174:14;

 196:9 

away (9)

 59:22;80:5;128:25;

 142:16;160:10;

 178:23;206:21;

 211:10;212:14 

awesome (5)

 107:7;134:24;

 151:23;177:19;

 183:22 

awfully (1)

 55:9 

axiom (1)

 25:2 

31:13 

ballpark (2)

 50:8;90:5 

ban (1)

 92:4 

bananas (1)

 19:9 

bar (1)

 166:17 

barking (1)

 182:6 

Barley (1)

 184:19 

barrier (4)

 128:13;136:9,18;

 153:10 

barriers (11)

 27:6;67:1;135:23;

 136:23;139:3,8;

 150:12,13,13,25;

 214:22 

Barton (10)

 78:18;85:17;93:3,8,

 10,13;96:7,20,22;

 97:12 

base (2)

 31:4;195:25 

based (14)

 8:13;43:25;47:9;

 86:15;90:17,17;94:9,

 19;117:2;129:20;

 135:13;136:2;215:8;

 222:8 

baseline (1)

 63:14;69:24;70:21;

 75:2;76:2,14;87:21;

 89:22,25;91:3,9;

 100:16;102:3,6,9;

 103:12;106:11,13;

 107:7,10,14;108:7,22,

 24;115:22,24;119:11,

 13,25;120:4,13;121:6,

 8;124:14;128:4;

 132:1,23,25;133:22;

 137:20;138:24;139:2;

 140:2,4;143:4,19;

 146:14;152:16;

 153:15;163:22;168:3;

 171:12;181:17;

 186:15;187:4,13,17;

 197:13;198:3,5,19;

 199:10,14,20;200:2;

 204:1;205:6;212:20;

 214:6,10,14;215:5;

 216:16,23;218:13,17,

 20 

bean (3)

 64:15,16;80:12 

bear (3)

 75:4;159:24;214:1 

bearing (1)

 209:18 

Bears (1)

 215:12 

beast (1)

 91:7 

beauty (1)

 45:20 

7:7;13:16;223:6 

Beer (1)

 71:7 

bee's (1)

 191:13 

beets (1)

 104:17 

began (1)

 95:14 

begin (1)

 140:6 

beginning (4)

 12:14;68:9;150:19;

 221:22 

begs (1)

 49:19 

behalf (5)

 26:19;98:5;126:7;

 137:15;170:25 

behaves (1)

 36:5 

behaviors (1)

 19:18 

behind (5)

 72:3,20;153:23;

 179:12;215:18 

beings (1)

 147:14 

Belcairn (1)

 85:19 

Belgrade (1)

 207:11 

believes (1)

 159:1 

114:5,21;181:19;

 210:10 

benzaldehyde (1)

 35:21 

Besides (4)

 25:1;77:16;159:10;

 196:6 

best (19)

 18:10;23:11;27:18;

 32:9;68:24;76:25;

 83:10;91:10;124:25;

 132:10;142:18;

 166:17;179:4;182:9,

 20;186:17;206:14;

 209:4;223:4 

bet (3)

 43:5;135:1;192:2 

betrayal (1)

 18:19 

better (41)

 18:16;25:3,23;26:3;

 29:21;68:5;73:9,9;

 76:21;82:13;93:19;

 105:20;112:2;120:24;

 136:13;137:1;138:2,

 11,17,19,20;142:20,

 22;143:8,16,16;

 147:11;148:15;183:1,

 11;190:3;191:18;

 197:9,9;201:12,15,16;

 207:17;217:4,24;

 222:6 

beverage (2)

 120:10;213:24 

B 

back (32) 125:22 became (3) Bell (20) beyond (10)

 9:7;14:20;15:10,22; bases (1) 39:24;195:22;209:3 13:24;18:6;26:9,12, 30:24;58:12;78:23,

 18:19;20:4,5;25:25; 212:16 Becky (7) 15,16;29:22;30:4,6; 25;151:25;167:19;

 34:3;37:24;39:22; basically (7) 109:25;200:22,24; 31:1,23;32:1,5,7,16; 168:23;199:7;206:11;

 45:20;47:16;60:21; 19:7;21:19;49:6; 205:18,20;207:15; 33:9,11,13,19;134:10 209:24 

80:18;84:18,25; 119:23;174:13;212:3; 208:15 Bellicus (2) bias (1)

 92:24,24;93:5;95:13; 217:6 become (6) 219:22;221:15 67:2 

97:15;104:16;107:1; Basin (1) 116:8;136:11; below (1) big (20)

 112:3;146:23;148:9; 102:24 137:25;153:21;170:4; 117:25 9:5;15:5,20;35:4;

 165:10;173:5;188:18; basis (1) 215:23 Beluga (2) 62:25;73:19;83:20;

 201:4;206:2 55:2 becomes (3) 186:16;189:21 105:21;115:4;134:14;

backed (1) basket (1) 106:23;170:17; Benbrook (2) 147:16;150:13;152:7;

 47:18 18:12 185:24 72:23;77:3 160:15;176:4;177:13,

background (1) Bat (2) becoming (3) bending (1) 20;178:23;190:9;

 13:18 224:21,22 34:3;136:23;156:11 213:25 203:18 

backwards (1) Bayberry (1) bee (1) beneficial (2) Bigfork (1)

 213:25 71:7 99:8 89:18;103:9 157:9 

bad (5) BD (131) beef (29) beneficials (2) bigger (5)

 18:25;19:1,15; 9:23;10:1,4,8,11,14, 25:11;173:1,19,24; 99:1;103:3 46:11;173:17;

 186:2;218:10 17,21,24;11:2,5,8,12, 174:18;176:4,13; benefit (12) 177:13;179:15;

bag (1) 15;20:9;24:9,19,24; 189:23;195:21;196:6, 16:10;32:18;66:20; 196:17 

160:17 26:7;30:10;31:22; 9,20;199:4,7,18,22; 76:8;84:21;85:2; biggest (5)

Bailey (1) 39:1;41:13,21,23; 200:4,7;201:3,7; 124:21;134:12; 62:16;102:17;

 110:1 42:1,4,13,20;47:4; 202:24;203:8,11,12, 152:23;154:11; 126:24;129:4;177:3 

Baker (11) 50:12,21,24;51:2,14, 17;204:20;205:12; 161:16;204:13 Bill (9)

 72:2,24;78:17;81:5; 21;52:24;53:12;54:1, 208:22;209:21 benefits (14) 35:5;122:18,23;

 85:15,19,19;88:12; 5;55:16,23;56:1,5,7,9, beekeepers (1) 44:23;67:9;82:15; 123:7,12;126:14;

 90:9;91:8,10 12,17;57:10;60:10; 99:9 101:7,24;102:2; 127:21;129:6;145:14 

ball (1) 61:9,11;62:9,22; beep (3) 111:22,25;112:3,5; billion (3) 

Min-U-Script® Burke Court Reporting & Transcription (4) average - billion 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 1 

October 17, 2023 

190:19;220:3,4 

bills (2)

 123:11,18 

Billy (1)

 215:8 

biodegradable (1)

 40:2 

biodiversity (1)

 79:3 

biological (4)

 86:21,24,24;87:4 

BIPOC (3)

 155:20,21;161:19 

bird (1)

 82:16 

bit (37)

 4:9;16:23;30:14;

 39:5;46:7;51:16;

 54:13;57:18,24;

 60:17;61:6,7;63:2;

 70:20;101:1,20;

 120:17,21;124:23;

 128:5;134:11;139:6;

 155:3;171:14,18;

 181:7;184:14;187:19;

 194:21;195:2;199:5;

 204:19;206:2;212:22;

 217:11;222:4,7 

bite (2)

 47:25;115:2 

black (10)

 22:21;114:13,15;

 123:15;135:12;

 186:16,18,19;187:22;

 189:20 

blanket (4)

 37:10,13;39:11;

 88:5 

blessing (1)

 19:6 

blight (1)

 82:4 

block (2)

 123:4,8 

blocked (1)

 80:1 

bloom (1)

 82:23 

blooms (1)

 118:10 

Board (83)

 4:6,25;5:8;7:1,22;

 8:13,16;9:3;12:20,25;

 14:5;15:14;22:7;

 26:17;27:22;39:15,

 22;40:8;45:8,14;

 58:11,13;62:23;66:8;

 68:4,19;70:22;72:22;

 79:17,21,23;80:15,18,

 19,20;81:19;83:15,

 21;94:17;95:9;104:6,

 13,14;117:3;123:20,

 21,22,24;124:1,12,15,

 21,25;125:15,19,20,

 22,23;127:22;130:16;

 134:19;137:16;138:4;

 144:8,11,12,18,24;

 145:5;157:10,11;

 161:10;162:14;

 164:15;165:17,22;

 174:21;180:10,16;

 191:7;192:21;207:11;

 224:25 

boarding (1)

 141:14 

Board's (3)

 8:14;93:16;125:17 

boast (1)

 148:10 

Bob (1)

 195:15 

body (2)

 87:1;180:23 

bolster (1)

 210:18 

bombers (1)

 4:20 

bono (1)

 72:12 

Bonterra (3)

 117:1,7;120:9 

Bonterra's (1)

 120:20 

boots (2)

 17:12;153:18 

border (2)

 20:11;127:11 

borders (2)

 15:2,2 

borne (2)

 70:4;79:12 

Both (38)

 6:21;12:7;20:24;

 24:16;26:4;36:12;

 86:6;90:1;95:17;

 99:21;100:25;113:5;

 114:11,12,21;117:16,

 16;118:11,15,25;

 123:3,6;124:14;

 125:2;128:20;130:15;

 132:18;145:19;

 153:12;162:12;163:5;

 173:15;194:1;198:18;

 206:22;207:7;208:21;

 219:10 

bothers (1)

 160:18 

bottles (2)

 88:16;145:23 

bottom (2)

 39:11;224:8 

bought (1)

 219:18 

bounced (1)

 102:20 

bound (1)

 153:12 

boundaries (1)

 32:24 

Bowl (1)

 159:21 

box (4)

 6:15,17;177:12;

 216:1 

boy (3)

 78:22;160:16;205:2 

brains (1)

 205:2 

brainstorming (2)

 62:23;70:11 

brand (4)

 118:2;120:20;

 211:3,9 

Branded (1)

 65:15 

brands (1)

 65:16 

break (12)

 72:2;78:17,17;81:6,

 6;85:15,16;92:23,25;

 115:2;165:9,11 

breed (1)

 26:4 

breeds (2)

 25:14;123:14 

Brian (19)

 9:22,24;63:16,18;

 72:2,24;74:3,4,25;

 78:17;81:5;85:15,18,

 19;87:20,21;89:22;

 90:1;92:22 

bridge (3)

 26:21;215:16;

 216:14 

bridging (1)

 78:25 

brief (2)

 93:6;165:13 

briefly (4)

 73:16;74:5;203:24;

 213:6 

brilliance (1)

 179:17 

brilliant (1)

 126:17 

bring (8)

 34:3;124:25;

 134:17;139:15,16,16;

 152:24;186:4 

Bringing (5)

 33:8;51:22;75:5;

 174:25;205:8 

brink (1)

 79:14 

Brinkley (11)

 116:19,22,24,25;

 119:12,20;120:1,11,

 14;121:15;122:3 

broad (2)

 82:19;214:23 

broader (1)

 96:10 

broadest (1)

 128:8 

Broadly (1)

 66:22 

broilers (1)

 24:16 

broke (2)

 46:16;204:1 

broken (3)

 130:15;165:1;

 215:20 

brokers (2)

 216:1,6 

brought (3)

 34:23;79:14;80:18 

brown (2)

 82:9,25 

Bruce (11)

 19:4;21:13,22;22:3;

 23:7;33:21;43:10;

 48:14,16,18;77:20 

Bruch (52)

 9:19,20;21:25;24:6;

 29:9;30:1,5,7;36:21;

 38:5,9,13,16,19,22;

 45:17;46:25;68:23;

 69:21;76:17;77:8;

 78:7;83:24;84:1,4,6;

 85:3,8;95:22;96:19,

 21;97:6,16;112:22;

 113:19,22;126:4;

 128:1;151:17;152:13;

 160:1,8,22;169:3;

 170:1,5,19,24;171:7;

 174:23;194:15;195:7 

brush (1)

 214:23 

bucket (1)

 134:10 

bud (1)

 23:4 

budget (2)

 190:9,21 

Buffalo (1)

 221:20 

bug (2)

 83:1;182:18 

build (9)

 17:23;40:4;124:2;

 154:3;157:20;196:4;

 217:16;223:2,25 

building (19)

 34:19;39:18;114:6;

 125:25;127:10,11;

 150:5;157:22;162:25;

 163:8,14;167:17;

 179:19;183:7;195:24;

 210:12;211:8;212:8,

 12 

built (5)

 17:7,21;18:15;

 115:9;195:23 

bulk (7)

 22:22;73:11;76:22;

 113:6;133:1;152:3;

 172:5 

bump (2)

 202:15;208:6 

bumped (1)

 195:15 

bumping (1)

 164:10 

bunch (3)

 88:9;143:7;218:18 

Burcham (11)

 103:20;109:25;

 110:3,5,7;113:14,20;

 114:12,18;116:11,16 

burden (7)

 28:23;32:14;70:9;

 86:7;134:11;141:12;

 166:15 

burger (1)

 188:3 

burners (6)

 82:11;99:21;

 100:22,25;101:2,25 

Burning (2)

 25:21;144:14 

burnt (1)

 101:15 

burst (1)

 91:12 

business (13)

 17:7;28:7;46:19;

 117:9;118:3;131:8;

 147:20;178:25;

 195:24;201:6;214:3;

 221:11,17 

businesses (4)

 129:21;131:13;

 213:18;220:10 

busted (1)

 159:11 

busy (2)

 23:16;184:1 

Butcher (1)

 177:12 

button (2)

 5:2;6:24 

buy (2)

 145:15;180:17 

buyers (3)

 49:8,10;104:25 

Buying (4)

 28:20;105:19;

 177:3;189:11 

bypass (1)

 171:25 

C 

CACS (4) 

Min-U-Script® Burke Court Reporting & Transcription (5) bills - CACS 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 1 

October 17, 2023 

26:24;109:8;162:7; 147:10;148:9,17; capacity (4) category (6) 15,24;55:4;67:11;

 163:16 158:1,12;159:7; 33:8;85:24;162:8; 68:5;117:7;119:15; 69:16;122:25;123:12;

CACS's (2) 177:9;179:18;197:3; 166:16 120:18;121:23; 128:17,24,24;129:1;

 130:5,12 204:7,8 Capital (2) 168:25 136:8;139:20;146:21;

CAFOs (2) campaigns (3) 155:7,7 cattle (12) 151:1;152:18;153:23;

 18:22;19:12 160:3;174:15; Caption (1) 104:3;172:18,22; 185:2,20;186:9,24;

Calas (1) 190:24 5:3 173:3,13;189:20; 201:20,23;202:15;

 63:22 Campesina (1) Captioning (1) 197:15,15;201:3; 222:25 

calcium (4) 16:12 5:1 208:23;219:15,17 certifications (6)

 99:23;101:9,11,12 can (171) captured (1) caught (3) 49:1;50:1;52:12,14;

calculation (1) 4:15,22;5:3,4,4,10, 108:10 182:12,17,22 212:11,16 

136:21 10,17,21,22,23,23; capturing (1) causative (1) Certified (52)

calculations (1) 6:4,8,8,24;10:18;12:7, 32:24 82:17 17:1,3;25:8,13,20,

 96:16 23;13:8,8,11,13;14:1; carbon (3) caution (1) 22;28:9;35:22;37:19;

Caldwell (7) 17:23;19:22;20:13, 100:20;104:22; 100:5 49:3;51:9;55:19;

 9:22,23;63:18;74:4; 16;21:20;24:12;26:3, 210:12 cautious (1) 56:11,20,25;57:1,4,5;

 87:20,21;89:22 4,12;28:22;31:3;32:8; carbonate (3) 27:9 104:3,19;128:14;

California (11) 36:5;37:4;38:14,16; 99:23;101:9,11 caveats (1) 136:11;139:25;

 10:1;25:19;72:13; 39:12,13,19;42:15; carcinogenic (1) 32:4 172:19;173:11,21,24;

 117:2;144:12,15; 43:12,13;44:14; 63:7 CC (1) 177:17;178:22;

 145:2;147:16;173:3, 46:10;49:19;52:1; Carcinogens (2) 5:3 184:10;189:20;

 4,8 54:18;55:4,4;56:2,2; 19:21;92:3 CCOF (4) 195:21,22,23,24;

call (36) 60:3;63:2;66:23;67:9; cardboard (1) 72:10;91:11; 196:12;197:5,22;

 5:8,23;7:2,17;9:8; 68:10;69:20,24; 25:18 144:11;147:10 198:9,9;201:2,5,6,9;

 11:10,19;12:21;13:1; 70:14,17,19;71:15,17; cards (1) celebrate (3) 202:11;203:17;

 16:23;47:12;50:13, 74:22;82:10,22;83:2; 37:14 12:7;114:8;115:12 208:20,22;209:11;

 24;61:18;71:21; 85:7;87:6,22;88:4,12; care (9) celebrating (1) 219:18;222:15,16 

87:15;90:21;93:1; 90:24;93:8,9;95:1; 62:5;85:14;114:22; 114:19 certifier (15)

 109:25;147:19; 96:11;97:12;102:11; 181:5,7;183:18; celebration (1) 32:23;47:20;53:25;

 148:24;164:14,18; 104:10;106:17;110:4; 205:16;207:2;225:3 33:7 55:5,7,10;66:21,22;

 173:18;178:8;180:18; 113:10,21;114:7,11, career (1) cell (2) 67:5;69:18;70:4,19;

 184:1;186:18;189:9; 12;115:3,15;116:3,16, 222:1 93:11;95:24 128:15;149:16;

 191:24;196:15; 22,23;118:7,8,15; careful (1) center (3) 153:19 

200:23;202:25; 124:4;127:20,23; 175:13 4:21;72:12;73:2 certifiers (33)

 207:14;215:14; 128:5;130:22;133:6, carefully (2) centered (1) 26:22;27:7,12,14,

 219:10 6;136:11,17;137:4; 42:17;44:13 161:12 18;32:9;44:19,25;

called (14) 138:7;140:2,8,9,11, cares (1) centers (2) 47:11,21;57:11,18;

 6:19;17:5;49:10; 11;141:17,24;148:4, 105:9 110:15,17 66:18;67:9,24;68:2,6,

 50:16,16;56:6;58:15; 18,19;150:23;152:4,9, Carob (1) Central (2) 13,25;77:13,20;78:1;

 121:2;139:15;208:25; 12,21,23;153:1,8,21; 64:15 65:15;219:12 83:9;125:5;127:10;

 213:17;216:5;219:22; 160:13;164:8,15,24, Carolyn (2) century (1) 130:19;132:18;

 221:18 24;169:17;174:15; 10:3,6 208:19 133:10;134:12;

caller (1) 175:3;177:18;178:8, carrots (2) cereal (2) 139:16;151:4;153:12;

 200:22 8;179:16;182:2,20; 25:20;160:17 172:24;211:3 156:17 

callers (1) 183:11;185:4,19; carry (2) cert (1) certify (2)

 217:1 186:7;188:10;193:11, 173:19;174:9 121:24 23:3,9 

calling (2) 12;196:15;199:1; carrying (1) certain (10) certifying (3)

 158:23;178:10 201:22;202:3;203:15, 160:16 20:25;49:4;77:5; 55:3;57:16;198:2 

calls (4) 21;205:22;206:18,20, case (7) 90:17,19;127:23; cetera (4)

 16:9,9;111:6;148:2 22;211:4;212:5; 27:16;50:1;52:9; 128:16;154:7;194:4; 23:15;160:7;

calm (1) 213:21;214:1;216:9, 79:6;90:21;132:10; 217:25 214:20,21 

199:15 14;217:18,21;218:4; 197:20 certainly (16) chain (21)

calves (1) 223:25 cases (3) 31:3,19;38:1;41:7; 22:9;28:7;29:13,16;

 196:11 cancelled (1) 117:9;136:12; 47:10;53:5;70:17; 43:24;46:2,24;49:9;

came (7) 189:16 145:24 120:14,16,25;154:11; 51:5;69:5;75:22;

 60:18;61:6;90:16; candy (1) Casey (1) 172:6;195:3;197:24; 77:12;113:3;137:6;

 92:2;144:24;145:9; 25:22 110:1 202:9,19 149:12;152:2;173:8;

 152:5 canopy (1) cash (1) certificate (2) 174:1;192:14;196:12;

camera (4) 82:22 18:13 109:12,15 216:4 

6:7,19,20,21 capabilities (3) categories (3) certification (37) chains (2)

Camp (1) 118:5;127:6,10 59:25;120:25;121:1 21:14;23:6;26:20; 77:11;216:1 

144:15 capability (3) categorizing (1) 27:13;43:15;49:13; Chair (247)

campaign (11) 99:24;101:4;218:23 168:25 52:1,10,18;54:7,9,11, 5:8;7:1,12;8:16; 

Min-U-Script® Burke Court Reporting & Transcription (6) CACS's - Chair 

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NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 1 

October 17, 2023 

9:11,15,17;11:23,24; 221:2,9;223:8;224:7; check (7) citric (6) climate (7)

 13:6,10,12,15,20,22; 225:2 71:24;96:23,25; 37:9,18;38:7;39:1; 14:25;72:16;73:19;

 15:23;16:1,19,22; Chairman (3) 203:15;204:3,23; 40:14;169:13 74:17;79:3;104:23;

 17:17;18:2,8;20:7; 14:7;15:22;144:11 220:6 citrus (1) 105:16 

21:24;24:7;26:8,14; Chair's (1) checking (1) 193:9 Close (4)

 29:7;30:9;31:24;32:2, 207:15 63:25 claim (3) 5:3;8:24;167:19;

 6,11;33:2,10,12,17, challenge (8) checkoff (1) 119:1;169:23; 222:9 

20;35:10;36:19; 14:22;15:5;32:18; 204:5 173:18 Closed (2)

 38:24;41:12;43:3,6,9, 46:11;107:19;115:6; checks (1) claimed (1) 5:1;65:7 

13;45:15;47:2;48:3,9, 120:22;202:14 17:13 21:8 closely (7)

 13;50:10;51:19; challenges (14) chemical (4) claiming (2) 17:20;28:5;62:18;

 52:23;54:4;55:14; 9:13;47:22,24;49:4; 45:1;87:4;167:2,5 170:2,17 164:6;200:3;221:17;

 57:25;60:8;61:10; 67:23;79:1,6;161:20, chemicals (7) claims (1) 222:14 

62:19;63:16,19;64:1; 21;175:2;181:19; 49:7;63:7;88:18; 171:3 closer (1)

 66:6,10,13,16;68:20; 185:8,10;194:4 91:25;94:24;178:24; clarification (2) 165:6 

69:23;70:24;71:11, challenging (5) 198:16 62:25;170:19 closest (1)

 14,19,25;73:21,24; 19:5;32:17;38:11; chemistry (1) clarify (3) 61:19 

74:3;75:1;76:16;78:9, 107:20;164:11 83:14 56:3;121:4;142:17 closing (4)

 12,15;81:1,4,10; chance (5) cherished (1) clarifying (2) 124:1;131:7;

 83:22;85:11,14; 34:14;124:8; 80:23 56:17;201:22 137:15;224:17 

87:18;89:23;91:2; 156:14;176:10; cherries (1) clarity (1) cloth (1)

 92:21;93:7,9;95:20; 223:20 81:14 203:20 83:2 

97:17,22;100:11,14; change (11) cherry (4) Clark (2) cloths (1)

 102:5;103:15,19,24; 5:4;14:25;67:25; 35:20;82:17,18; 9:1;11:20 82:16 

104:5;106:6;107:13; 70:18;80:23;84:21; 157:23 class (1) clue (1)

 108:25;109:3,6,16,20, 104:23;150:21;164:9; Chicago (1) 45:2 215:24 

24;110:4;112:19; 201:19,20 199:17 classes (1) clunky (2)

 113:24;114:1,17; changed (4) chicken (1) 156:11 47:20,20 

115:19,23;116:12,17, 14:21;50:15;84:16; 19:19 classic (1) CO (2)

 23;119:8;120:2; 156:21 chickens (1) 187:6 14:18;137:2 

121:7;122:1,4; changer (1) 19:16 classification (2) Coalition (5)

 124:13;126:2;128:3; 178:23 chickpeas (2) 45:1;168:23 122:11;155:10;

 129:11,13;131:19,23; changes (1) 184:18;188:13 clause (5) 161:8,9;223:25 

132:22;134:6,9,24; 83:16 chief (4) 35:24;37:14;39:12; coalitions (1)

 135:2;137:17;139:1; changing (3) 111:2;202:3,5; 40:11,20 17:22 

140:1;141:5,7; 5:18;100:19;156:20 222:3 clauses (1) Coast (1)

 142:17,25;143:20; channel (1) China (1) 34:17 177:4 

144:5,11;146:10; 224:22 21:9 clean (5) coaster (1)

 147:24;148:1,23; channels (1) chloride (4) 79:12;105:19; 129:3 

149:1,4;151:15; 188:11 64:12,23,24;65:9 181:2;193:25;210:13 coastlines (1)

 152:15;153:14; character (1) chocolate (1) cleanest (1) 173:15 

154:25;155:2;156:8, 12:17 19:10 158:4 codified (3)

 23,25;157:8;158:23; characteristics (1) choices (1) clear (8) 57:14,19;132:9 

159:6,23;160:23; 63:6 209:8 32:8;72:19;73:3; codifying (1)

 161:3;163:20;165:7, characterize (1) choose (4) 97:22;115:8;131:5; 196:2 

14;167:25;169:2; 102:10 105:18;111:22; 136:14;152:22 cohesive (1)

 171:10;172:10,13; charge (3) 190:7;222:2 clearance (1) 137:2 

174:10,12,19;175:8, 25:24;67:10;124:10 chosen (1) 86:18 cohort (8)

 11;176:6,8,15,25; charging (1) 74:11 clearly (7) 67:16,23,25;68:2;

 177:5,19;178:7,12; 53:19 chunk (2) 12:19;35:15;42:18; 124:9;125:2,5,6 

180:7,12;181:14; Charles (1) 47:25;176:5 118:25;139:12; cohorts (3)

 182:5,8,24;183:10,22, 72:23 circle (1) 209:11,25 125:7,8;156:21 

25;184:5;186:5,10, chasing (1) 97:15 Clemente (3) cohost (1)

 12;187:16;189:8,15; 15:8 circuit (1) 97:19;103:20; 71:5 

191:1,9,20,23;192:3; chat (8) 154:9 109:21 cohosts (1)

 194:12;195:9,11,14, 4:21,22;5:1,23; citation (1) click (1) 71:3 

18;197:11;199:17; 6:14,17;93:2;103:22 166:24 58:10 Coleman (1)

 200:12,21;202:20,22; Chats (2) cited (2) clicking (1) 25:19 

203:3,7,23;205:8,10, 4:23;8:21 166:24;167:9 5:2 collaborate (2)

 16,22;207:13,20; cheap (1) cities (1) clients (1) 69:7;90:18 

208:2,6,8,10;210:21, 20:15 177:3 85:23 collaborated (1)

 25;211:6;212:18; cheating (1) citizens (1) cliff (1) 87:14 

214:12;216:19;219:4; 49:21 145:15 15:8 collaboration (6) 

Min-U-Script® Burke Court Reporting & Transcription (7) Chairman - collaboration 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 1 

October 17, 2023 

69:1,3,11;127:12; 23;119:14,19;129:18; 164:5 49:18;50:8;78:4 computer (2)

 150:10;188:1 137:16;145:21; commit (1) comparison (3) 5:18;9:13 

collaborations (1) 149:10;150:1;174:10; 112:13 123:23;202:11; concentrate (1)

 67:7 177:24;186:20; commitment (3) 217:4 46:16 

collaborative (2) 189:23 125:17;136:14; compatibility (1) concept (5)

 89:15;151:22 commented (4) 209:6 86:8 39:5;52:7,12,13;

collagen (1) 97:8;124:20; Committee (3) compelling (1) 212:6 

34:20 149:22;168:9 8:14;162:9;192:18 217:17 concern (8)

collapse (2) commenter (4) committee's (1) compensated (1) 46:20;53:4;96:5,5;

 79:3,14 7:5;119:14;133:1; 68:8 187:12 111:2;167:21;170:4;

colleague (1) 211:17 commodities (2) compensation (1) 204:4 

192:24 commenters (7) 19:8;193:10 95:2 concerned (1)

colleagues (2) 5:7;8:1;111:17; commodity (6) compete (7) 112:5 

15:21;149:9 114:2;117:4;164:25; 20:25;50:6,17; 19:8,10;20:12;21:5; concerning (1)

collected (1) 165:16 130:8;181:1;192:19 50:3;107:23;223:16 111:14 

133:9 comments (142) common (12) competency (1) concerns (19)

collecting (1) 7:11;12:11;15:24; 45:2;70:1;73:12; 139:9 12:21;27:2;29:15;

 27:8 24:10;26:18,24;29:4, 76:21;78:3;90:19; competent (5) 32:7;40:15,16;45:22;

collection (1) 10,12,18;32:12; 159:9;196:13;206:13; 136:1,4;140:20; 46:1,4,7,9;52:6;

 27:19 33:18;34:7;36:24; 211:24,24;217:1 142:9;143:16 85:19;99:19;111:8;

Collective (3) 37:2;43:6,22;45:15, commonly (1) Competing (3) 166:16;172:2;194:6;

 72:9;208:16;218:20 19,25;46:4,5;48:4,10; 45:3 18:25;108:10; 202:6 

colloquially (1) 50:11;53:15;58:1,12, communicate (4) 197:25 conclusions (1)

 51:2 13,15;60:2,8,10,15; 27:23;74:23; competition (3) 183:12 

colocation (1) 62:20;63:21;64:22; 140:21;180:16 107:22;108:3,12 concrete (1)

 77:11 66:11;68:17,20;69:4, communication (6) competitions (1) 67:22 

colonies (1) 6;72:22,23,24;78:15; 42:6;95:16;114:3; 36:16 condition (1)

 99:8 81:1,18;83:22;84:8, 135:24;136:1;140:20 competitive (2) 86:19 

color (1) 11,13,17;85:4,25; communities (17) 107:24;173:20 conditions (2)

 82:25 86:1;87:6,15,16,22; 21:15;111:23; competitor (1) 102:12;103:3 

Colorado (2) 90:1;92:22;93:14; 135:11,22;136:3,9; 197:16 conduct (2)

 200:3,4 95:8,10,20;96:2;98:4, 138:13,16;140:17; compiles (1) 74:22;133:13 

colors (1) 8,10,18,18;99:20; 141:3;142:1,10; 77:4 conducted (3)

 135:11 100:11,17;104:12,13; 156:13;162:1;163:13; complaint (2) 113:4,10,13 

Columbia (1) 109:7;112:20,24,25; 199:3,8 57:21;111:3 confidence (7)

 102:24 116:18;119:9;120:5, communities' (1) Complementing (1) 18:24;19:23;100:8;

combination (1) 8;122:5,13;123:17,19, 15:4 150:9 101:3;172:8;206:16;

 206:6 20,22,24,24;125:3; community (34) complete (1) 210:18 

combined (1) 126:6;130:2;131:19; 27:6;42:11;43:21; 196:23 confidential (4)

 77:25 133:16;134:16,25; 45:21;64:20;66:21; completed (1) 27:10,13;32:25;

combining (1) 135:9;137:18;139:3; 67:11;68:14;74:16; 8:11 72:21 

77:19 143:5,21;146:11; 76:10;95:4;98:5; completely (6) confidentiality (1)

comfortable (3) 149:11;151:16,18,21; 112:1;122:20;124:3; 52:8,15,16;64:18; 87:13 

14:7;99:10;101:6 152:2,17;153:16; 136:22;138:12,18; 99:6;156:21 confirm (2)

comforts (1) 157:2;159:3;162:6; 140:5,15,15;161:12, complexity (3) 84:9,15 

115:17 163:20,23;164:5; 14;163:4;164:2,8,14; 45:9;80:17;159:10 confirmed (1)

coming (24) 165:15;167:25;168:5; 170:25;179:3;196:16; compliance (5) 49:23 

21:19;26:1;30:7; 169:11;171:15;180:8; 199:1;205:13;223:2, 80:21;131:3; confront (1)

 61:25;66:2;102:19; 184:3;187:17;191:2; 12 140:14;143:6;192:8 131:9 

113:18;114:20,24; 192:12,17,22,23,25; companies (6) complicated (1) confused (7)

 119:11;123:6;129:5; 194:11,13,17,18,24; 88:9;133:3,5; 92:6 50:20,20;56:22;

 138:10;139:4;143:10, 195:5,6;207:4;213:6 192:13,15;214:3 component (3) 110:12;116:10;190:8;

 17;145:4;148:19; commercial (16) company (9) 17:21;183:8;191:2 198:1 

156:21;186:17; 34:12,17;35:1,13, 40:25;63:2;88:4; composed (1) confusion (6)

 201:11;218:5,6;220:7 23;37:11,13;39:6,11; 187:22;208:25; 169:12 105:10;110:18;

commend (1) 40:20;118:23;119:5; 210:15;211:3;215:7; composition (1) 120:17;121:5;179:10;

 162:23 120:15;158:20; 216:5 39:9 209:20 

Comment (30) 159:22;203:18 comparative (1) compounds (3) Congrats (1)

 4:6,24;7:4,12; commercials (1) 23:11 44:17;47:22;51:6 68:24 

12:15,16;14:18;22:8; 148:10 compare (1) comprehensible (1) congratulations (3)

 29:14,20;34:3;47:5; Commission (1) 23:2 12:20 211:1;214:6,15 

62:22;65:6;70:2; 161:23 compared (6) comprise (1) Congress (5)

 80:16;85:21;95:18, Commission's (1) 23:2;44:16;45:1; 98:6 79:9;122:12,15,22; 

Min-U-Script® Burke Court Reporting & Transcription (8) collaborations - Congress 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 1 

October 17, 2023 

127:2 consultants (2) 7:24;8:3;95:1,15; 70:14,17;126:1; Costco (2)

conjunction (1) 84:19;139:15 121:19;125:25;127:3, 127:1;177:20 160:9,16 

22:5 consulting (2) 20;158:18;165:10; conversations (4) costs (9)

Connect (2) 34:1;72:9 174:16;193:8;197:7; 16:3;70:22;155:18; 20:15,15;49:13;

 186:6;188:9 consume (4) 201:23;202:13 211:19 51:25;55:4;107:20;

connected (1) 21:2;25:10;26:6; continued (9) conversation's (1) 108:11;123:1;128:18 

214:19 198:16 45:8;98:11,14; 72:4 Council (10)

connecting (1) consumed (1) 123:13;132:12;193:2, convey (2) 64:6;81:13;98:9;

 55:24 121:2 7,19;194:9 44:18;45:9 143:13;199:22;200:4;

connection (2) consumer (44) continues (5) cooking (1) 203:8,11,17;204:20 

18:16,17 19:23;28:1,16; 58:19;112:2; 82:1 Council's (1)

conscious (1) 30:15,18;77:3;78:25; 117:13;188:2;220:13 Cool (4) 203:12 

164:3 80:22;105:9,21; continuing (2) 38:18;41:11; count (1)

consensus (4) 106:19;108:10; 67:21;114:24 101:14;191:5 101:12 

87:6;116:6;161:11; 110:18;111:1,19; continuity (1) Co-Op (7) counterpart (1)

 168:6 114:6;116:10;120:16, 185:19 26:25;27:24;28:4; 148:21 

conservation (3) 24;157:16;158:10,25; continuous (11) 175:24;196:8;199:24; countless (1)

 112:15;114:9; 173:10,17;176:10; 112:14;115:5,9,13, 203:10 206:23 

123:15 179:7,10,10;181:3; 18;116:6;123:14; cooperate (1) countries (4)

consider (10) 187:22,25;190:15,25; 126:19;201:7;206:9, 116:2 20:16;52:19;119:3;

 27:15;37:9;54:11; 191:14,14;195:25; 17 cooperation (1) 189:6 

87:14;118:14;124:4; 196:9,18;209:7,20; continuously (5) 222:9 country (18)

 130:13;163:1;205:2; 210:18;212:6;216:3; 115:13;195:23; Cooperative (11) 19:9;21:2,20;55:19;

 210:17 217:10 201:5,8;202:14 28:14;43:16;67:11, 95:5;106:5;109:15;

consideration (1) consumers (50) contract (2) 13;69:17;70:7,20; 117:23;128:17;

 165:16 18:17;21:21;28:5; 217:9,25 196:8;197:21;222:8; 137:11;158:8;164:13;

considered (3) 52:3;105:4,10,18; contracted (1) 224:4 188:16;190:4;191:5,

 39:14;103:16;220:5 106:1;110:9,11,13,21, 60:4 Cooperative/Organic (1) 21;197:4;224:3 

consist (1) 24;112:2,5;114:14,22, contracting (1) 26:17 country's (1)

 54:18 25;115:3,6,17; 184:16 cooperatives (3) 81:16 

consistencies (1) 117:12;118:24;158:3, contractor (1) 21:10,15;22:24 County (4)

 112:8 12,15;174:15;179:15, 23:10 co-ops (1) 25:21;117:2;

consistency (17) 18;180:3;182:25; contracts (2) 173:23 141:16;142:18 

32:10;67:7,8; 183:6,15;189:12,24; 73:11;76:22 co-option (1) couple (12)

 110:12,13,19,25; 190:7,10;196:19; contrast (1) 26:19 4:19;27:2;32:5;

 130:14,14;131:4; 197:4,8,23;198:18; 91:5 coordinates (2) 34:20;50:5;71:7;

 132:21,25;133:2,7,21; 209:2,12,16;210:1; contributing (1) 27:5;134:12 102:22;119:9,22;

 134:4,20 211:11;220:17;223:5; 210:13 cope (1) 177:25;178:3;205:17 

consistent (13) 224:5 contributions (1) 94:23 course (2)

 27:1;67:6;102:10; consumers' (1) 20:2 cordially (1) 60:3;213:8 

109:9;112:7;117:14; 111:8 control (8) 71:2 court (2)

 130:17,18,19,21; contained (5) 20:5;22:20;82:4; core (3) 48:25;50:9 

131:16;149:16;193:5 59:18;65:16,18; 84:12,13;92:12; 14:23;161:13;209:9 cover (8)

consistently (1) 210:6;212:7 118:11;185:20 corn (2) 72:15;74:5;80:7;

 190:7 container (1) controlling (1) 22:22;104:3 104:22;150:22;

consists (1) 111:15 82:8 corner (1) 186:23;212:12,15 

27:6 containers (1) controversial (1) 5:12 coverage (1)

constant (1) 113:6 204:16 Cornucopia (4) 186:22 

114:15 contaminants (1) convene (1) 110:8,8;111:7; covering (1)

constantly (2) 189:4 4:12 112:6 82:19 

77:15;140:19 contaminated (1) convenience (1) corporate (4) covers (4)

constitute (1) 44:19 60:3 16:8;20:3,3;21:17 82:14,22;83:7;

 134:3 contamination (13) convention (2) correctly (1) 98:15 

constraints (1) 44:15;73:14;76:23; 53:20;222:12 55:18 coveted (1)

 166:19 77:1,14;93:22;94:1, conventional (19) cost (26) 209:3 

constructing (1) 24;95:3,5,7;185:22; 20:20;49:5,15,18; 23:1,3;70:3,8; COVID (1)

 173:11 194:1 101:2;103:10;104:17; 73:12;83:4;94:10; 173:6 

constructive (2) content (4) 112:4;119:4;147:17; 108:11;122:21,24; cow (3)

 68:1;76:6 64:25;65:3,9; 148:21;173:1,2; 123:6,12;124:15; 19:14;199:11,17 

consult (1) 113:11 180:22;181:21; 128:6,13,20,25;129:4, cow/calf (1)

 26:21 continually (1) 183:11;190:2,2; 7;136:14;147:20; 189:22 

consultant (1) 202:10 196:11 150:15,15;159:10,14; cows (3)

 103:7 continue (15) conversation (5) 160:17 19:12;23:20;199:4 

Min-U-Script® Burke Court Reporting & Transcription (9) conjunction - cows 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 1 

October 17, 2023 

Coyote (1)

 15:7 

Crabtree (6)

 195:16;200:24;

 205:19;219:7,9,11 

crack (1)

 127:12 

Cream (1)

 216:5 

create (10)

 37:15;73:12,13;

 74:16;114:6;151:13;

 156:1;161:14;164:24;

 190:23 

created (5)

 22:10;68:13;

 135:19;137:8;222:9 

creates (4)

 35:6;49:14;50:4;

 153:18 

Creating (8)

 67:8;74:15;142:13;

 161:13;163:4;187:21;

 188:11,12 

creation (2)

 94:8;222:15 

creative (1)

 23:25 

credit (1)

 156:18 

Creek (2)

 72:8,8 

crises (2)

 79:2,17 

crisis (2)

 91:19;94:7 

criteria (13)

 86:7,14,18;87:5,8;

 88:19;166:10,14,19,

 24;171:25;172:1,9 

critical (14)

 8:19;79:16,21,22;

 28:14;43:15 

cropping (4)

 184:12;185:18;

 219:13,17 

crops (35)

 20:25,25;21:4;35:6;

 44:11,19;57:2;59:10;

 81:21;96:13;98:12;

 104:21,22;105:1,7;

 114:9;128:20;148:19,

 20;150:9,11,22,22;

 172:18,21,23;184:22;

 185:11,13,14,22;

 187:21;208:21;209:1;

 219:14 

cross (2)

 194:17;216:14 

cross- (2)

 69:10;193:25 

cross-agency (1)

 127:12 

crossing (1)

 152:24 

cross-purposes (1)

 206:4 

cross-referencing (1)

 194:17 

Crotser (12)

 26:10;29:23;33:21;

 43:9,12,14,15;46:8;

 47:17;48:11;52:11;

 77:21 

crucial (2)

 58:18;117:19 

Crushed (1)

 66:6 

crushing (1)

 150:3 

Cruz (1)

 72:13 

cry (2)

 76:9;91:22 

160:4;164:7;168:8;

 169:12;171:13,19;

 175:14;181:24;

 187:19,24;199:21;

 204:10;212:22;

 214:22 

current (9)

 19:17,18,20;69:7;

 106:19;122:23;

 126:14;146:25;

 167:14 

currently (11)

 59:13;65:14;72:10;

 97:5;98:14;100:7,18;

 117:9;135:22;174:9;

 194:2 

Currier (14)

 157:4;161:4;

 165:11,22,23;168:13;

 169:18;170:2,6,23;

 171:2,9,21;172:12 

curve (1)

 136:25 

custom (3)

 219:15;221:16,18 

customers (6)

 28:5;49:11;196:1,

 16;202:9,10 

customize (2)

 5:4,10 

Customs (1)

 127:11 

cut (5)

 51:16;53:1;54:17;

 73:25;173:5 

cute (1)

 188:3 

cycle (1)

 193:11 

72:1;78:16;81:4,7,

 12;83:24;84:8;85:11;

 194:25 

Dana (3)

 207:23;208:9,12 

Dana's (1)

 207:25 

Dang (4)

 11:25;105:5;180:8;

 210:22 

dark (2)

 52:17;91:1 

data (10)

 27:4,10;35:25;

 67:16;94:10;99:13;

 130:21,22;131:16;

 134:21 

database (6)

 52:21;56:6,14,19;

 57:8;65:15 

date (4)

 52:14;96:6,15;

 117:18 

dates (3)

 96:2,3,8 

daunting (1)

 136:17 

Dave (1)

 207:10 

day (20)

 4:5;9:4;14:20;

 15:19;16:24;18:4;

 95:14;106:3;143:7;

 145:19;146:2;185:8;

 192:1;200:17;201:12;

 207:22;221:5;224:9,

 15,15 

daydream (1)

 188:2 

days (7)

 8:5;14:8;16:9;42:7;

 113:10;192:1;200:18 

80:10;221:23 

decades (2)

 62:2;206:13 

deceive (1)

 24:1 

decent (1)

 176:4 

decertified (2)

 185:25;187:8 

decide (1)

 183:1 

decided (4)

 50:18;135:14;

 149:17;195:5 

decides (1)

 122:22 

decision (4)

 28:23;79:25;80:10;

 99:16 

decisions (5)

 28:6;39:25;79:9,20;

 222:1 

declare (1)

 48:25 

declared (1)

 72:20 

decontaminate (1)

 81:24 

decrease (2)

 193:17;198:21 

dedicate (1)

 159:2 

dedicated (4)

 112:2;159:2;

 192:11;219:22 

dedication (3)

 159:15;160:24;

 222:5 

deep (6)

 67:25;80:22;

 104:22;125:3,10;

 141:11 

D 

80:19;81:23;83:18; Crystal (3) daily (1) DC (2) deeper (3)

 117:8,17;119:4; 208:18;209:7;215:9 146:22 73:23;142:23 14:25;76:19;195:2 

121:23;193:8,21,23 CSA's (1) dairy (12) deadline (1) deeply (2)

critically (1) 160:7 23:20;25:11;28:25; 122:17 79:4;142:10 

118:21 cultural (4) 30:12;94:4,6,7,9,14; deal (7) defend (2)

criticism (1) 136:1;139:9; 110:20;123:15; 62:6;75:6,9;82:11; 84:23;123:7 

102:10 140:20;161:25 209:21 108:17;135:21;203:9 defense (1)

critters (1) culturally (2) dam (1) dealing (11) 99:3 

14:12 136:4;143:16 91:12 22:6;60:20;77:13; defer (1)

crop (34) culture (1) damage (3) 90:3;91:22;92:17; 133:25 

93:16,18,19,23; 164:9 82:8;118:18;193:13 95:7;102:16,21; deferred (1)

 96:1;98:21,23;100:7, cumbersome (3) damaged (2) 142:2;168:10 45:24 

25;102:2;103:7,9,10; 32:19;52:1;75:10 19:7;193:16 dealt (1) define (5)

 141:14;149:17;163:3, cure (1) damaging (2) 32:13 12:18;16:6;79:18;

 5;167:3;169:22; 110:18 118:12,14 Dean (2) 133:7;134:2 

171:4;181:4;184:10; curious (31) D'Amore (14) 21:7,11 Definitely (15)

 185:11,15,16,18,24; 17:22;20:13;30:16, 9:25;10:1;52:24; dearth (1) 32:11;36:25;69:12,

 186:2,22,25;187:12; 22;51:12;52:4,9;70:6, 53:12;54:1;102:6,9; 183:2 20;70:14;108:18;

 188:2;210:11;219:20 11;88:8;107:19; 103:12;115:22,24; debate (1) 116:16;135:10;

CROPP (5) 120:8;124:23;132:2; 216:23;218:13,17,20 223:16 149:22;169:24;

 26:16,25;27:24; 137:23;139:5;146:17; Dan (9) decade (2) 182:10;183:9,13; 

Min-U-Script® Burke Court Reporting & Transcription (10) Coyote - Definitely 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 1 

October 17, 2023 

197:8,22 deployed (2) 151:22;167:12; 201:14 discussing (2)

definition (2) 82:25;142:18 212:24 Dimitri (2) 31:9;220:17 

19:1;218:22 deployment (1) developed (3) 10:3,4 discussion (13)

degrading (1) 183:5 31:21;67:5;110:23 dinner (1) 22:15;27:21;38:3;

 193:9 depth (1) developing (2) 71:10 43:23;44:5;45:20;

DEI (2) 40:19 34:24;219:23 Dion (15) 69:5;123:20;132:2;

 155:3;164:2 Describe (4) development (16) 93:4;97:19;103:20; 149:10,25;163:16;

delay (1) 167:1,4;179:19; 14:25;27:25;33:3; 104:1,2;106:12,21; 209:9 

113:9 223:1 35:16;75:16;117:1; 107:9,12;108:1,13,23; discussions (4)

delayed (1) describing (1) 131:14;151:6;187:20; 109:5,14,18 31:13,19;111:16;

 96:15 109:10 188:5,15;212:23; dioxide (13) 153:9 

delegate (1) description (1) 213:7;214:1,2,3 100:20;117:6,8,16; disease (4)

 222:11 109:11 develops (1) 119:6;121:9;144:17, 82:9,18;84:12,13 

deliberation (1) desert (1) 28:13 20;145:1,12,17;146:6, diseases (2)

 84:25 19:13 dialogue (3) 19 79:2;82:4 

deliberations (3) deserve (2) 74:15,22;127:24 direct (7) disinfect (1)

 84:22;111:16; 156:17;220:23 dictated (1) 81:17;106:19; 81:25 

112:18 design (2) 210:9 108:3,4;192:21; dismantle (1)

deliberative (1) 79:11;213:20 dictating (1) 199:1;216:2 164:24 

83:16 Designated (1) 78:1 direction (9) disparage (1)

delicious (1) 8:15 diet (3) 17:24;27:25;34:13; 175:13 

186:19 designed (1) 26:5;148:15;198:16 36:16;57:16;78:5; disparagement (1)

deliver (2) 39:7 Dietary (1) 120:22;152:22;182:1 8:20 

68:10;86:17 desire (1) 77:4 directionally (1) disparaging (1)

deliveries (1) 69:6 difference (10) 34:8 182:2 

203:5 desired (1) 25:15;26:4;57:4,24; directly (9) disparities (1)

delivering (2) 118:16 107:6;128:21;151:2; 49:25;74:19,23; 161:25 

202:24;205:12 desires (1) 153:5;190:1;209:18 95:13;108:7;137:12; dispense (1)

delivery (1) 14:14 different (35) 179:8;192:15;209:1 58:23 

201:12 desiring (1) 21:17;25:3;26:22; Director (11) dispersed (1)

deluge (1) 119:1 39:24;52:15,19; 7:16,21;18:9;43:15; 164:13 

167:21 desk (1) 55:12,12;75:7,15,21; 66:18;78:23;110:7; displacement (1)

demand (26) 153:23 77:12;78:3,4;91:13, 116:25;122:11; 15:3 

28:1,8,12,16;30:15, Despite (4) 13,13;92:1,7,9;114:9; 129:19;165:23 displayed (1)

 18;31:2;35:5;80:11; 111:25;173:19; 120:25;133:23; directors (1) 6:3 

114:6;118:24;179:7, 196:12;207:4 140:16;145:13; 58:12 disruption (1)

 8,13;180:2;184:23; detailed (3) 169:21;172:8;174:1; dirt (2) 100:6 

190:15;196:12;197:8, 98:10;123:16; 182:11,21;188:11; 17:13;104:17 disruptive (1)

 8,19;198:21,22; 194:10 198:1,25;206:3; disadvantage (1) 116:5 

199:9;220:14;224:14 details (3) 219:14 160:20 distinct (1)

demands (1) 58:14;60:1;113:21 differentiate (3) disagree (2) 110:24 

28:11 detect (1) 25:4,24;44:15 8:21;190:3 distinction (1)

democracy (3) 73:15 differentiated (1) disbursement (1) 111:12 

16:5;207:7,7 detection (2) 75:21 213:13 distinctions (1)

demographic (1) 77:15;130:24 differently (2) disclose (1) 62:10 

120:23 detections (1) 36:5;62:13 88:6 distinguish (4)

demonstrated (2) 131:6 difficult (4) disclosed (1) 25:17;73:13;76:23;

 53:6;217:21 deter (4) 44:18;87:23;158:2; 92:20 77:1 

demystifying (1) 27:2;28:22;43:23; 202:1 disclosing (1) distortion (5)

 136:19 94:1 difficulties (2) 88:9 21:16;55:11;64:18;

denial (1) determine (1) 4:23;132:14 disclosure (6) 65:12;206:12 

73:1 96:12 dig (3) 86:10;87:11,25; distressing (1)

de-oiled (1) determined (2) 63:13;187:19;195:2 88:3;92:10;145:7 201:10 

64:16 59:25;127:15 digging (1) discover (1) distributed (1)

department (4) determining (1) 56:25 150:23 199:7 

28:5;74:14;148:19; 95:1 diglycerides (5) discrimination (1) distributing (1)

 213:22 deterrent (4) 64:13,24;65:10,14, 163:11 175:19 

depend (2) 51:15;82:20; 19 discriminations (1) distribution (3)

 21:22;85:7 136:11;142:16 diligently (1) 164:21 24:4;174:1;199:5 

dependence (1) devastating (1) 120:19 discriminatory (1) Distributors (4)

 206:22 118:2 Dilip (3) 164:11 173:23;174:2;

depending (2) develop (6) 10:23;62:20,21 discuss (3) 215:25;216:6 

25:14;120:23 36:15;66:22;67:17; diminish (1) 163:4;164:17,23 dive (3) 

Min-U-Script® Burke Court Reporting & Transcription (11) definition - dive 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 1 

October 17, 2023 

76:19;125:3,10 

diverse (5)

 26:5;124:2;129:24;

 161:15;219:13 

diversified (1)

 128:19 

diversity (9)

 67:21;128:7,8;

 135:10;143:11,13;

 156:19;161:17;

 192:18 

divert (1)

 58:17 

Division (3)

 7:16,21;166:2 

doc (1)

 32:3 

doctor (2)

 148:16;158:19 

document (17)

 22:15;27:21;43:23,

 24;44:5;47:6;57:12;

 65:12;69:5;98:21;

 109:8;149:11,25;

 151:1;152:25;153:2,

 17 

documentation (2)

 35:1;37:15 

38:3;76:8;147:2;

 179:12 

Doug (26)

 157:4,4;161:4;

 165:10,19,21,23;

 168:1,3;169:3;171:7,

 12;172:11;195:16;

 200:24;205:19;

 208:11;216:20;219:7,

 11;221:3,7,10,14;

 222:2;224:7 

dovetails (1)

 69:3 

down (20)

 28:7;31:2;50:6;

 54:17;57:6;77:15;

 90:23;101:19;106:25;

 115:2;127:12;138:10,

 16;141:25;160:13;

 208:3,16;212:6;

 215:20;217:15 

downstream (1)

 49:8 

dozen (3)

 14:5;184:16;220:1 

dozens (1)

 125:9 

Dr (3)

drugs (4)

 61:15,19;92:10;

 145:15 

drum (1)

 65:23 

dry (3)

 150:4;172:19;185:9 

drying (1)

 65:23 

drylands (1)

 178:17 

dual (1)

 169:23 

due (6)

 45:4;93:21;95:2,3;

 193:16;209:5 

Duly (3)

 38:21,23;39:2 

dumped (1)

 21:11 

during (4)

 12:13;39:23;201:7,

 7 

dynamic (2)

 25:25;153:17 

165:14 

echoing (1)

 124:5 

ecologically-based (1)

 26:2 

economic (7)

 14:24;15:9;18:18;

 75:19;94:7;160:21;

 206:20 

economically (1)

 194:7 

economy (1)

 219:23 

ecosystem (7)

 69:18;70:19;79:14;

 80:19;87:4;111:23,24 

ecosystems (2)

 15:4;206:19 

edge (1)

 80:23 

edicts (1)

 112:8 

editing (2)

 16:9;69:7 

educate (15)

 138:17;158:1,10,

 12;174:8;179:18;

 180:3;186:4;190:10,

 21:5;67:18 

efficiently (1)

 213:13 

effort (8)

 44:22;124:5;144:9;

 203:12;206:14;

 209:22;217:10,12 

efforts (11)

 27:23;69:2;94:23;

 111:16;131:11,17;

 150:6;156:10;164:3;

 192:11;209:11 

egg (4)

 16:25;17:1;198:9;

 210:16 

eggs (1)

 110:19 

egg's (1)

 198:13 

egregious (2)

 80:20;204:21 

eight (2)

 124:8;173:4 

eight-month (1)

 125:10 

either (6)

 6:9;11:9;39:6;

 148:5;155:20;190:3 

E 

documents (1) 72:23,23;77:3 eager (2) 21;196:16,19;202:9; Ekalaka (1)

 45:20 dragged (1) 93:18;116:15 210:18;220:17 106:22 

dogs (1) 92:5 earlier (11) educated (2) elaborate (1)

 182:6 Drape (1) 90:4;91:21;124:6; 111:1;138:20 76:24 

doke (1) 82:25 147:9;156:2;193:11; educating (7) elated (1)

 71:25 draw (1) 194:24;212:9,9; 28:11;106:1; 17:1 

dollar (3) 202:10 213:2,6 160:24;182:25; element (1)

 105:19;147:17; drawback (1) early (5) 183:20;196:1;224:5 171:22 

180:17 150:4 82:23;120:20; education (15) elemental (4)

dollars (4) drawing (1) 139:7;145:22;155:12 28:17;67:22;125:7; 82:2,7;85:5;98:16 

23:2;83:6;180:2; 32:21 earn (1) 142:13;143:1;164:20; elementary (1)

 200:6 dream (3) 180:3 179:8,14,18;182:10; 214:21 

domestic (2) 148:4;206:3;223:20 Earth (2) 202:8;209:7;211:20; elevator (1)

 75:22;132:19 drift (4) 32:21;206:24 220:14,21 165:4 

domestically (1) 93:22;94:2;186:21; earthworms (1) educational (8) eliminated (1)

 117:10 187:7 104:21 55:6;67:7;137:23; 67:2 

donations (1) drifting (1) easier (3) 138:3;162:21;190:24; Elizabeth (8)

 223:16 47:13 40:13,17;153:6 209:9,11 13:24;18:5;26:9,11;

done (19) drinking (1) easily (2) effect (3) 30:10;31:25;45:24;

 48:21;52:13;54:9, 35:19 193:12;213:1 35:3;67:9;145:15 134:10 

10,11,15;66:6,7; drinks (1) East (2) effective (11) Ellie (14)

 75:19;82:23;124:19; 71:7 42:6;209:5 17:24;47:10;101:8; 58:3;64:2;66:13,16,

 177:2;182:13;185:5, drive (7) easy (11) 118:6,8;131:11; 17;68:21,22,23;

 6;201:21;213:9; 34:22;37:22;38:17; 15:18;24:1;37:19; 139:10;156:16;183:5; 69:21;70:25;124:6;

 215:3;224:6 50:6;132:20;180:2; 51:17;55:9;108:17; 193:22,24 125:2;155:11;156:25 

door (3) 183:17 132:16;145:11; effectively (3) Elliot (1)

 54:22;144:23;215:1 driven (5) 153:19,23;182:14 19:12;44:14;131:17 25:19 

double (3) 16:7;28:8;35:23; eat (2) effects (6) else (8)

 71:24;172:25; 44:4;91:19 25:9;181:3 87:3;88:22,22; 16:18;38:7;101:22;

 197:23 drop (1) eaters (1) 89:18;118:14;167:4 121:2;130:12;216:4;

doubled (1) 121:24 111:4 effectuate (1) 218:1,2 

117:11 drove (1) eating (2) 135:15 else's (1)

double-penalizing (1) 35:15 35:20,20 efficacy (1) 5:19 

96:22 drown (1) echo (4) 130:23 e-mail (2)

doubt (4) 104:10 47:5;91:21;134:16; efficient (2) 5:23;71:17 

Min-U-Script® Burke Court Reporting & Transcription (12) diverse - e-mail 

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October 17, 2023 

embed (3) enemies (1) 148:14;180:6;185:9,9 75:20;98:22 everybody (17)

 135:17;142:11; 116:9 environmental (6) established (2) 4:5;7:9,20;9:23;

 162:12 enforced (4) 18:17;79:1;112:3; 79:20;220:5 10:14;15:14;23:22;

embedded (1) 80:4,16;105:14; 114:23;167:4;210:9 establishes (1) 33:22;72:6;73:12;

 142:10 218:4 environmentally (3) 79:11 97:24;134:18;154:24;

emerge (1) Enforcement (11) 79:2;111:21;158:4 establishing (1) 156:18;184:9;198:14;

 100:4 57:15,18;94:12; environments (1) 27:19 225:2 

emerged (1) 126:11,14,19;127:10; 185:13 Estates (2) everybody's (1)

 65:25 131:13;179:11; envision (3) 117:1,8 182:20 

emergency (1) 217:19;218:22 31:8;67:1;148:4 esteemed (1) everyday (1)

 79:3 engage (3) EPA (15) 104:6 140:8 

Emily (6) 7:24;116:6;162:4 73:1;76:13;86:18; estimate (3) everyone (33)

 189:16;192:4,7; engaged (1) 87:10,13;90:10,18; 59:13;90:3,25 4:7,20;5:20;8:18;

 194:16;195:7,9 150:18 91:24;92:4;99:13,17; estimating (1) 9:18;10:4,5;12:9;

Emmer (1) engages (1) 166:8;167:9,10; 61:8 13:11,13;26:12;

 184:18 129:23 171:16 estimation (1) 43:12;66:17;67:2,9;

emphasis (2) engaging (2) EPA's (2) 114:7 81:12;110:6;129:17;

 75:22,24 8:2;74:15 60:25;73:6 Esu (1) 150:18;158:8;170:14;

emphasize (1) enhanced (1) epidemic (1) 9:3 190:4,20,21;192:6;

 64:22 111:23 82:18 et (4) 195:13;196:15;

emphasizes (1) enhancing (1) equal (1) 23:14;160:7; 208:14;215:10;

 163:6 69:7 94:15 214:20,21 216:14;220:18;223:4;

employees (1) enjoy (1) equals (1) ethanol (6) 224:18 

223:16 182:16 22:24 36:5;81:23;193:20; everyone's (2)

empowering (1) enjoyable (1) equipment (1) 194:2,5,7 165:24;204:3 

181:9 182:15 193:25 ethic (1) everywhere (2)

enabled (1) enough (12) equitable (5) 16:15 33:14;40:15 

4:21 13:17;17:4;51:19; 104:14;124:2; ethics (1) evidence (6)

enables (1) 98:19;136:4;155:13; 161:13,15;164:24 222:5 35:25;44:10;49:23,

 56:10 176:2,4;183:23; equitably (1) Ethyl (6) 24;87:1;183:25 

enacted (1) 190:9;196:13;199:2 164:13 35:21;36:1,4,5; evidenced (2)

 111:17 enriched (1) equity (22) 42:9;119:15 118:25;184:24 

encompassing (1) 111:15 67:20;68:2;122:13; ethylene (8) exacerbate (1)

 198:12 ensure (8) 124:9,19,20;125:17; 98:12,16;192:23; 128:25 

encountered (2) 82:13;83:10;94:14; 126:1;135:17;156:19; 193:3,3,7,10,18 exact (3)

 173:16;186:23 185:1,18,18;193:5; 161:12,18,23;162:1,7, Europe (1) 32:24;60:2;134:12 

encourage (9) 220:12 9,12,15,16,17;163:1; 189:3 exactly (11)

 28:16;45:10;83:15; ensures (1) 164:4 European (1) 48:5;72:3;85:1;

 124:3;131:3;161:22; 79:7 Erin (6) 189:6 141:22;145:14;196:2;

 162:3,11;194:9 ensuring (1) 4:11;7:15,18,20; Eval (1) 197:4,9;211:4;

encouraged (1) 104:14 9:9;11:18 167:1 222:21;223:21 

220:7 enter (1) eroded (1) evaluated (3) example (12)

encourages (1) 222:13 19:2 58:21;59:14;61:5 40:12;45:1;46:13;

 35:7 entering (1) error (1) evaluating (3) 77:7;112:15;140:9;

encouraging (2) 137:6 206:7 44:3;88:19;169:10 166:22;187:6;189:3,

 40:22,24 enterprise (1) ERS (1) evaluation (1) 3;198:7;200:16 

end (19) 219:15 75:19 58:24 examples (4)

 7:11,11;14:8;40:3; enticing (1) especially (19) Even (22) 35:11;59:7;140:4;

 47:4;64:7;73:4;89:5; 67:18 14:17;20:17;25:23; 34:13;41:16;104:8; 170:12 

90:22;102:20;114:18, entire (3) 29:4;43:21;44:7;46:3; 105:10;130:20;136:5, exceed (1)

 21,23;134:18;181:3; 17:7;57:22;111:7 70:16;82:5;88:8; 6,10;147:15;158:25; 44:14 

196:10;207:21;208:4; entities (2) 106:15;113:18; 168:6;169:6;172:25; exceeded (1)

 216:13 20:3;138:18 122:21;128:9,14; 183:10;188:21; 173:2 

endeavor (2) entrenched (1) 139:8;158:24;174:6; 201:10;202:1,9,13,17; Excellent (7)

 208:24;211:22 164:11 188:23 209:24;216:3 13:21;36:4;38:5;

ended (3) entrepreneurship (1) essential (6) evening (1) 69:21;141:25;190:7;

 14:8;116:1;154:16 175:5 64:20;82:7;115:14; 184:8 210:21 

endorse (3) entry (2) 149:15;191:3;193:4 event (2) except (4)

 145:19;146:7,8 152:4;214:23 essentiality (1) 93:23;131:5 37:20;118:25;

endorsement (1) environment (13) 167:7 events (2) 171:17;222:21 

27:23 66:24;67:1,8;68:1; essentially (3) 150:10;216:4 excepting (1)

ends (1) 80:17;87:3;105:20; 96:11,22;121:1 eventually (1) 21:5 

114:23 122:22;147:13; establish (2) 7:8 exception (1) 

Min-U-Script® Burke Court Reporting & Transcription (13) embed - exception 

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NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 1 

October 17, 2023 

172:4 

exceptional (4)

 180:17;196:8,20;

 197:1 

exchange (1)

 21:12 

excipients (9)

 61:15,18;62:6,8,17,

 18;91:5;92:9,11 

Excited (11)

 30:20;69:19;71:14;

 87:22;105:23;126:12;

 154:6;161:17;162:14;

 214:16;224:12 

exciting (2)

 125:11;214:7 

excluding (1)

 168:16 

exclusively (1)

 35:23 

Excuse (4)

 10:5;13:5;77:20;

 158:13 

23:22;109:14;

 154:21 

expectations (2)

 131:5;136:13 

expected (2)

 136:15;167:11 

expense (1)

 157:25 

expensive (2)

 158:2;211:25 

experience (11)

 23:12;24:2;44:16;

 98:25;124:24;141:22;

 146:18;161:20;

 185:23;192:19;

 221:23 

experienced (2)

 51:9;186:7 

experiences (2)

 93:18;135:13 

experiencing (2)

 18:20;147:2 

experiment (1)

 81:17;85:4 

extent (1)

 206:20 

extra (6)

 15:13;111:20;

 115:25;129:9;147:11,

 17 

extractant (2)

 36:4;44:9 

extracted (1)

 64:15 

extraction (2)

 170:7,8 

extracts (1)

 36:6 

extremely (4)

 28:21;102:21;

 162:21;219:1 

eye (2)

 6:17;223:3 

73:6;80:13,13,20 

Fair (3)

 51:19;220:20,20 

fairly (3)

 35:12,12;133:18 

faith (1)

 115:6 

fake (1)

 145:7 

fall (10)

 38:1,4,15;43:19;

 65:11;129:1;130:3;

 194:18,20;195:5 

false (1)

 53:5 

familiar (6)

 35:1;44:8;47:21;

 119:16;138:3;215:10 

families (1)

 14:11 

family (10)

 18:22,22;19:14;

 23:21;29:1;104:2;

 151:13;158:19;159:1;

 178:19;179:16;

 180:21;183:21;

 185:24,25;221:21 

farmer-driven (1)

 94:6 

farmer-led (1)

 94:8 

farmers (101)

 18:17,18,22,23,23;

 19:4,10,14;22:2;23:7,

 11;26:21;27:5,10;

 28:7,8,19,25;29:1;

 43:19,22;49:3,4,5,8,

 11,20;54:7,18;55:3;

 56:13;57:3,5;67:20;

 93:14,19,21,23;94:1,

 14,15;95:7,16;96:3,6,

 9,14;97:1,14;105:2;

 106:8;109:9;122:25;

 126:21;128:14;

 129:21;135:12;138:6;

 140:9;141:9;147:19;

F 

executive (4) 89:4 fabulous (1) 172:17;195:20;201:3, 148:2;150:18;155:8;

 18:9;66:18;78:23; expertise (2) 134:13 6 157:17;158:5;159:15,

 122:10 152:23;172:11 face (4) family's (1) 19;160:6,25;161:19,

exempt (1) expire (1) 15:9;49:5;153:18; 178:20 20,22;163:8;175:4;

 203:15 122:24 218:10 fancy (1) 179:6,24,25;180:14,

exercise (1) expired (1) faces (2) 14:15 15;184:1;185:1,7,10,

 223:15 122:18 11:25;156:20 fantastic (4) 12;189:11;191:6,25;

exercises (1) explain (6) facilitate (4) 125:24;140:1; 193:10;206:12;220:9,

 153:4 48:24;140:12; 23:17;41:2;188:14; 149:25;225:2 20;221:3;222:10,11,

exerts (1) 183:6;190:3,6,24 193:5 far (19) 12;223:13,22;224:8,9,

 79:8 explaining (4) facilitated (1) 108:1,2;111:17; 14 

exhibit (1) 106:4;146:21; 94:5 115:5;120:24;121:19; Farming (15)

 19:17 151:2;183:15 facilitating (1) 139:7;148:7;158:6; 72:9;105:12;

exist (3) explanation (2) 164:4 165:17;166:16;168:5, 112:16;128:13;

 111:13;142:8; 192:22;201:15 facilitators (1) 25;180:23;187:25; 141:10;172:21,24;

 164:22 exploration (1) 155:18 190:22;197:18; 174:15;179:1;181:22,

existed (1) 128:6 facilities (1) 213:15;223:14 23;182:3;208:20;

 165:2 Expo (2) 194:3 farm (34) 219:24;221:22 

existence (2) 42:6;209:5 facility (4) 23:21;48:19;49:8; farms (10)

 139:23;222:15 exposes (1) 106:22;173:12; 50:5,6;54:25;55:8; 22:25;23:3;33:7,8;

existential (2) 118:13 177:17;214:25 56:15;72:8;95:1,2; 53:24;94:23;99:3;

 79:2,17 exposure (2) fact (17) 104:16;105:6;122:18, 198:25,25;221:15 

existing (5) 118:19,20 48:20;62:3;99:7,7; 23;123:7,12;126:14; fascinating (1)

 68:8;130:6;150:5; express (4) 118:9,18,25;119:2; 127:21;129:5,24; 56:24 

163:8;197:6 43:20;45:6;85:21; 148:13;179:20,21; 144:14;150:24; fashion (2)

exists (4) 100:3 189:24;201:15;202:5; 160:18;172:19; 49:22;218:16 

66:20;95:5;111:6,9 expressed (1) 209:23;212:15; 178:21,23;179:3; fats (1)

Exit (2) 85:22 221:14 180:4;182:16;207:10; 173:4 

5:15,16 expression (1) fact-based (1) 209:1;221:17;223:20 fault (1)

expand (5) 206:14 114:19 farmed (1) 185:24 

38:17;106:17; extend (1) factor (4) 104:17 faults (1)

 112:11;128:5;152:4 122:22 21:11,12;74:14; farmer (34) 58:23 

expanded (2) extending (2) 197:25 19:4;20:14;21:10; favor (1)

 44:4;45:7 22:1;96:3 factored (1) 28:13,22;48:20; 38:19 

expanding (5) extends (2) 96:16 52:21;55:1,1;78:25; favorite (5)

 44:2;113:17,20; 8:21;61:14 factories (1) 79:13;80:22;93:17; 35:7,20;165:24;

 130:5;175:3 extension (5) 18:21 94:6;95:4;97:8;114:4; 180:21;187:23 

expansion (3) 123:7;129:6,7,8; factors (1) 123:16;141:12,16; FDA's (1)

 44:24;46:6;120:15 166:11 120:15 144:13;147:23; 65:1 

expect (3) extensive (2) failure (4) 148:16;149:20; feasible (1) 

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NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 1 

October 17, 2023 

194:7 99:9;104:9;109:11; fine (2) flipped (1) followed (34)

feature (1) 130:21;150:9;174:18; 140:22;156:1 52:16 13:6,23;18:5;26:9;

 5:7 186:25 finish (9) floated (1) 33:21;43:10;48:14;

features (1) fields (6) 7:7;99:23;136:24; 204:15 51:20;58:2;60:9;

 205:4 23:14;109:10; 174:10;186:5;207:24; floating (1) 66:14;72:1;81:5;

fed (2) 134:12;149:18,19,21 208:10;216:20;223:8 4:22 89:24;97:18;103:20;

 173:9;197:21 fight (2) finished (2) flooded (1) 109:25;116:19;120:3;

Federal (7) 104:23;123:5 25:11;169:15 18:21 122:6;126:2;129:15;

 8:13,15;27:24; fighting (1) Fire (2) floor (16) 135:3;143:24;149:5;

 48:24;94:23;124:15; 127:17 144:15;146:16 13:25;26:11;43:11; 157:3;161:4;172:14;

 142:14 figure (5) firm (1) 48:16;64:3;81:7; 178:13;184:6;192:4;

federally (1) 23:24;90:11; 34:1 85:18;97:20;103:24; 195:15;217:22;219:7 

105:14 127:24;168:17;178:9 first (43) 116:21;149:6;157:6; following (2)

Federation (1) figured (2) 4:5;13:3,23;25:23; 165:19;172:15; 36:10;94:14 

16:13 100:8;146:5 26:25;32:2;42:19; 178:14;200:25 follow-up (7)

feed (5) figures (1) 50:13;55:17;57:7; florals (1) 33:12,16;36:24;

 28:20;196:5,21; 188:3 58:23;59:19;65:13, 192:16 54:5;107:16;113:1;

 210:3,4 figuring (3) 20;68:3;75:5,25; Florez (1) 198:20 

feedback (4) 60:20;85:1;89:20 81:11;85:20;93:16; 63:22 font (1)

 28:6;84:20;126:20; filberts (3) 99:3;106:10;110:11; Florida (3) 5:4 

135:13 50:13,17,24 122:21;125:5;130:5; 137:21,22;199:11 food (54)

feeding (2) filed (2) 135:24;142:12;145:7; flour (1) 18:16;19:21;26:3;

 205:12,13 19:5;143:24 148:8;156:6;164:19; 188:12 36:14;49:7;52:4;64:6,

fee-for- (1) files (3) 167:17;175:1;186:16; flowering (1) 25;65:3,22,23;71:8,9;

 166:4 27:13;32:15,21 192:10;193:2;195:22; 193:4 73:2;79:5,13,19;

feel (11) filing (1) 210:25;212:2;216:2; fly (3) 83:18;91:23;92:14,

 15:16;17:8;34:16; 48:24 217:8;219:19 89:10;104:11; 14,15;105:13,19;

 40:8;68:16;109:12; fill (1) first- (1) 201:25 111:21;112:3,4;

 130:15;137:12;185:4, 141:14 178:18 focus (15) 115:11;144:21;

 11;187:10 filters (1) first-generation (2) 15:15;28:16;34:15; 145:12;158:4;161:13,

feeling (1) 13:18 221:21;222:14 43:22;87:9;102:1; 16;179:4,4,21;181:1,

 152:18 filtration (2) firsthand (2) 114:19;121:17;132:5; 8,11,13;183:18;

feet (2) 118:12,14 98:25;129:25 153:4;166:23;179:6; 184:23;188:9;189:12;

 15:8;19:19 filtrations (1) fish (3) 181:9;184:12;192:23 192:8;206:23;209:1,

Feldman (6) 118:11 80:15;98:15;170:10 focused (8) 8;211:2;213:23;

 72:1;78:16,20,22, final (9) five (8) 28:13;61:25;62:1,2; 215:17,20;219:24;

 22;81:3 57:15;65:7;89:5; 23:11;113:10; 155:21;162:9;188:23; 223:4 

fellow (2) 169:5,9,10,11,12; 120:13;127:5;146:4; 189:5 FoodData (1)

 117:4;165:17 171:1 149:20;151:6;165:9 focuses (1) 65:15 

felt (1) finalization (1) five- (1) 188:25 Foods (6)

 211:14 44:20 81:5 focusing (3) 21:7,11;65:5,15;

fence (1) finalized (1) fix (2) 67:23;143:15;150:8 189:11;209:18 

84:22 110:17 165:5;215:22 fold (1) foothold (1)

fermentation (1) finally (5) fixing (1) 219:15 222:20 

119:23 83:12;95:8;126:13; 104:21 folk (1) footprint (1)

fertility (1) 163:15;224:4 flag (1) 215:8 200:8 

184:12 financial (2) 125:4 folks (30) forage (1)

fertilizer (8) 70:8;150:13 flagging (1) 6:21;17:2;22:20; 178:17 

169:18,22,23; find (34) 53:5 40:24;46:5;53:17; forages (2)

 170:3,17,21;196:22; 5:15;6:10,13;22:12; flashes (1) 61:17;69:24;72:2; 195:21;196:21 

210:11 37:20;38:10;56:14, 77:14 97:8;121:17;124:11; foreign (1)

fertilizers (1) 15;63:10;69:19;89:2, flavor (8) 156:11,13,13;157:1; 50:4 

169:16 9;90:19;97:1;102:10; 25:15;35:16;36:2,3, 159:8;165:9;168:9; foremost (2)

few (20) 103:3;105:8;116:6,7; 3;42:8,10,17 178:8;180:18;189:10; 110:11;217:8 

12:10;14:17;15:19; 117:8;120:16;121:22; flavors (7) 190:1,14;205:17; forensic (1)

 17:5;19:3;23:7;35:14; 129:9;137:4,13; 34:20,24;35:14,24; 207:21,22;208:3; 23:13 

36:11;59:7;93:20; 139:19;150:22; 41:14;118:15;119:15 220:25;224:15 forge (1)

 119:1;121:3;130:3; 157:17;162:11; flesh (1) follow (8) 100:5 

135:14;149:25;168:9; 187:11;201:10; 206:15 17:18;31:3;40:17, forget (3)

 195:4;207:21;211:17; 202:10;214:24; flexibility (3) 18;53:24;131:24; 19:18;91:15,16 

223:24 222:19 97:3;167:15,18 148:23;208:15 forgot (2)

field (10) finding (1) flip (1) follow- (1) 10:5;108:5 

32:21;89:9;94:16; 106:24 107:21 113:22 form (6) 

Min-U-Script® Burke Court Reporting & Transcription (15) feature - form 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 1 

October 17, 2023 

88:14;133:3;

 136:16;142:7;144:21;

 169:15 

formal (1)

 68:13 

four (7)

 41:25;92:2;113:10;

 145:13;174:3;184:16;

 135:18 

fruition (1)

 126:13 

fruits (2)

 179:6;216:11 geography (1)

 120:23 

geolocating (1)

 109:8 

G 

150:1 185:15 77:5;192:16 gain (1) geolocation (4)

format (2) fourth-generation (1) frustrated (1) 82:24 27:3,14;32:3,13 

27:19;97:15 178:19 129:3 Gallery (1) Georgia (3)

formations (1) fraction (1) frustrates (1) 5:12 162:19,21,24 

136:21 77:18 217:12 game (2) germane (1)

former (6) frame (1) frustration (1) 121:3;178:23 66:23 

72:17;78:23;97:25; 16:11 218:21 gang's (1) gets (2)

 129:25;134:10;191:3 framework (1) frustrations (2) 211:18 17:12;119:23 

formerly (1) 16:5 211:20;218:18 gaping (1) giants (1)

 203:9 Francisco (1) FSA (3) 201:8 68:16 

forms (2) 177:4 141:13,23;142:4 gaps (1) girl (1)

 36:15;206:18 Franklin (6) Full (9) 26:22 137:22 

formulants (3) 11:4;54:4;126:3; 5:15,16;40:11;67:3; gardener (1) given (5)

 86:16,21;87:7 128:3;140:1,11 84:24,24;86:10; 157:15 54:6;165:16;

formulated (3) frankly (2) 87:11;108:14 gardens (1) 196:25;210:4;219:14 

86:1,12;87:2 25:7;202:16 fully (3) 157:18 gives (2)

formulating (1) fraud (15) 84:23;109:14; gas (6) 218:7;223:17 

89:8 18:20;21:3,12;22:6, 196:24 192:23;193:3,3,7, giving (2)

formulation (4) 6;27:2;43:23;44:22; fumigants (2) 10,18 26:18;48:4 

38:12;86:4;89:5; 49:25;50:4;77:10; 44:7,10 gather (1) Glad (6)

 169:9 94:18;130:23;131:9, fun (1) 196:13 9:23;106:14;

formulations (2) 14 155:5 gathered (1) 115:25;141:21;

 88:15;92:13 fraudulent (3) function (3) 67:16 160:16;200:14 

formulators (1) 20:19;44:8,9 41:8;80:11;86:4 gauge (1) glazed (1)

 89:6 fraudulently (1) functional (2) 70:18 142:5 

forth (2) 51:7 92:18;206:19 gave (3) global (15)

 56:13;209:22 free (8) functions (1) 91:24;149:11; 16:8;22:9;29:13,16;

fortification (3) 67:10;124:9; 101:16 175:16 42:17;43:24;46:2;

 169:6;170:9,13 137:12;158:14;181:6; funded (1) Geez (1) 51:5;64:6;69:5;113:3;

fortunate (1) 210:1,3;212:4 67:13 223:6 149:12;152:2;192:8,

 126:11 freely (1) funding (14) gel (1) 14 

Fortunately (1) 216:15 20:3;30:21;70:7,15; 34:20 globally (2)

 160:9 freighter (1) 123:6;126:12,25,25; gellan (1) 34:10;65:21 

forward (23) 22:23 127:13,14;150:5; 64:11 glyphosate (1)

 12:1,9;15:21;22:3; frequently (1) 151:13;188:20; gene (1) 51:11 

27:17;29:4;33:23; 110:22 204:14 16:9 GMO (5)

 39:17;60:13;78:12; fresh (4) funds (4) general (7) 158:13;196:5,21;

 79:15,20;90:13; 23:8;192:9,14; 70:9;190:23; 34:7;46:1;52:13; 210:1,4 

100:4;103:17;115:12; 193:22 204:22,25 111:2;126:8;198:14; GMOs (1)

 122:16;123:4,9; friendly (3) fungicide (1) 202:9 104:24 

130:9;146:24;165:6; 14:22;111:21;158:5 170:22 generally (5) gnat's (1)

 220:23 friends (1) fungicides (1) 46:18;52:5;59:8; 217:20 

Foster (25) 219:10 77:5 70:15;184:24 goal (10)

 13:24;18:6;26:10; front (5) funneled (1) generate (3) 37:3;39:19;45:8;

 28:17;33:20,22,25; 14:8;106:15;113:9; 42:3 36:6;37:3;67:9 74:11,12,16;75:13,21,

 35:11;37:8;38:6,10, 134:18;168:17 funny (1) generated (2) 24;216:2 

14,18,21,23;39:20; front-end (1) 211:13 22:16;98:17 goals (4)

 41:20,22,24;42:2,5, 134:22 furiously (1) generation (1) 37:4;127:22;129:4;

 14,21;43:5,8 frost (1) 76:15 178:19 162:13 

found (6) 25:23 further (5) generic (1) Goats (2)

 109:21;139:21; froze (1) 27:17;76:25;130:9; 145:15 215:8,16 

201:8;209:16;212:23; 98:13 180:2;192:22 genetic (1) goes (10)

 215:12 fruit (19) Furthermore (2) 93:21 15:19;17:12;57:21;

foundation (4) 37:9,18;81:16,18, 117:18;203:14 gentle (1) 99:15;108:3,15;

 17:2;128:13; 22;82:3,8,15,24;85:2; fuse (1) 47:16 154:23;183:17,18;

 206:13,14 98:1,20;99:23; 40:3 gently (1) 202:6 

founder (1) 101:11,14,17;121:13, future (8) 217:18 gold (4)

 209:6 16;193:9 17:25;79:18;80:24; geographic (2) 186:18,19,19;196:5 

founding (1) fruitful (1) 100:5;104:13;119:7; 102:23;214:20 Goldberg-counting-the-carbon-angels (1) 

Min-U-Script® Burke Court Reporting & Transcription (16) formal - Goldberg-counting-the-carbon-angels 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 1 

October 17, 2023 

74:21 

Goldilocks (1)

 215:11 

gonna (4)

 29:24;93:10;168:7;

 208:3 

Good (104)

 9:11,17,20,21;10:1,

 2,4,6,8,9,11,12,24,25;

 11:2,3,6,25;13:20,21;

 15:4;16:11;21:14;

 26:15;30:2;32:10;

 33:9,12,22;34:12;

 37:5;39:24;41:14;

 44:1;46:13;48:1;64:4;

 72:4;93:13;97:6;

 102:8,9;105:5;

 106:14;107:8;109:19;

 110:6;112:17;114:8,

 19;115:12;118:23;

 122:10;128:24;

 130:11;132:23;

 133:10;138:6;141:9;

 144:5,7,14;149:14,22;

 151:2,24;153:15;

 154:8,16,23;155:22;

 156:7;159:12;160:12;

 161:7;171:12;174:12;

 175:11;176:6;180:4,

 5,17;181:22;182:1,8;

 184:8,8;192:6;

 198:15;200:2,11;

 201:20,21,22,24;

 204:9;206:1;213:3;

 215:17;218:10;219:6;

 220:9;223:21;224:15 

goodness (3)

 57:9;84:4;215:4 

Google (2)

 22:13;32:21 

Googling (1)

 16:23 

go-round (1)

 84:14 

Gosh (4)

 11:25;106:7;180:8;

grain-fed (1)

 197:25 

grains (1)

 184:18 

Grant (5)

 33:3;210:15;213:7,

 8,12 

grants (1)

 220:10 

grape (5)

 120:10;121:10,12,

 14;145:8 

grapes (9)

 118:1;119:7;

 120:18,21;144:19;

 145:3,4,17;146:8 

grapple (1)

 217:6 

grass (4)

 25:10,10,11;197:21 

grass-fed (8)

 173:24;174:6;

 190:2,5;197:16,24;

 198:5;209:24 

grateful (4)

 7:24;162:24;

 191:24;205:12 

gratitude (2)

 43:20;85:21 

gravy (1)

 36:18 

gray (4)

 114:14;116:3,3;

 134:2 

grazing (5)

 219:15,17;221:11,

 16,18 

greased (1)

 48:22 

great (55)

 17:15;25:12;26:15;

 31:7;32:22,25;42:20;

 47:7;81:8;85:8;87:21;

 96:7;105:7,7;109:18;

 115:7;116:13;118:19;

 119:25;120:11;

greatly (1)

 89:1 

green (1)

 209:18 

greenhouse (1)

 111:14 

Greetings (1)

 129:17 

grew (1)

 221:20 

Grocers (3)

 14:6;16:24;160:11 

grocery (6)

 106:2;174:7;

 175:19;176:9,11,12 

ground (9)

 35:8;51:11,12;

 82:21;90:19;153:18;

 206:13;212:3;213:5 

group (24)

 21:13,19;31:3,4;

 48:25;49:25;52:12,

 14,18;54:6,8,11,15,

 20,21;60:1;61:25;

 94:6,8;97:15;148:6;

 158:20;179:16;

 199:24 

groups (13)

 16:14;17:19,23;

 31:10;33:6;51:24;

 52:5,7;54:18;57:13,

 17;60:3;125:7 

grow (17)

 17:5;36:25;57:13;

 104:22;105:2;117:13;

 124:16;172:21;

 185:12,13;189:25;

 197:7;202:13;206:15;

 219:13;220:13;

 224:14 

grower (15)

 48:25;49:25;51:24;

 52:5,7,12,14,18;54:6,

 8,10,15,18,20;187:6 

growers (28)

 54:21;55:11;81:14,

 15:9;24:21;28:12,

 17;67:25;117:12;

 120:10;146:20;

 147:21;184:25;185:8;

 193:3,11;196:10,21;

 198:20;210:4 

Gruff (6)

 208:25;209:3;

 210:15;215:7,8,18 

Guar (2)

 64:15;80:12 

guarantee (3)

 217:8,9;218:3 

guaranteed (2)

 176:3;204:25 

guarantees (2)

 105:14;217:25 

guess (16)

 22:5;39:4,10;50:20;

 87:24;107:2;113:8;

 134:1,16;170:6,20;

 197:14;204:17;212:2,

 13;216:9 

guidance (15)

 27:18;28:8;79:10;

 95:3;131:1,4;132:4,7,

 9,11,12,17;133:11;

 151:1;153:2 

guidance's (1)

 32:9 

guide (1)

 60:19 

guidelines (1)

 118:1 

gum (4)

 64:12,14;80:12,12 

gums (1)

 64:15 

guys (5)

 45:19;98:6;109:18;

 147:6;175:11 

gymnastics (1)

 171:18 

Hand (7)

 5:7;9:7;11:22;12:8;

 63:16;141:13,20 

handbook (5)

 57:13,19;131:2;

 132:13;133:18 

handed (1)

 203:10 

handful (1)

 117:11 

hand-harvesting (1)

 20:17 

handholding (2)

 139:13;141:8 

hand-in-hand (1)

 151:3 

handlers (8)

 35:2;56:13,16;57:1,

 4;129:21;189:10;

 193:23 

handles (1)

 49:14 

handling (14)

 30:2;34:17;64:9,10;

 77:12;86:7;98:11;

 118:21;163:17,18;

 192:16;193:7,18;

 194:4 

hands (4)

 37:25;38:3;108:14;

 206:4 

hang (1)

 58:7 

hanging (1)

 37:18 

happen (7)

 39:9;42:15;139:21;

 142:1;203:21;205:1;

 206:8 

happened (3)

 40:6;84:6;91:23 

happening (9)

 49:20;53:16;54:25;

 71:1;113:8;126:1;

 164:1;188:6;223:24 

happens (2)

H 

210:22 121:15;128:10; 22;82:3,10;83:4,9; habitat (1) 20:14;39:1 

govern (1) 135:19,20;137:18; 84:18;103:7;105:15; 206:23 Happy (9)

 73:4 138:22;153:2;160:2; 135:12;136:15;137:5, hail (1) 18:1;22:18;29:5;

governance (1) 164:16;165:18; 24;145:8;147:16; 83:3 45:13;71:6,8;78:10;

 85:24 175:17;177:7;179:2, 184:16,16,21;186:4,4, half (5) 120:6;137:13 

governing (1) 24;180:19;185:4; 6,7,8;187:12;193:15, 27:7;117:9;145:16; hard (17)

 79:12 190:4,13,13,25; 23 181:17;215:13 32:14;35:25,25,25;

government (4) 196:17;200:12,16; Growing (9) halftime (1) 72:7;85:21;99:2;

 30:23;64:5;122:17; 203:18;205:13; 87:1;111:6;137:5; 159:21 111:13;129:7,25;

 163:12 207:17;209:16;214:2, 146:2;172:23;181:4, halibut (1) 132:10;136:4;139:9;

governmental (1) 10;216:9;219:9; 11;190:15,16 186:18 148:12;165:15;179:3;

 206:22 220:5,24;224:25,25 grown (10) Hall (1) 204:14 

grace (2) greater (5) 111:4,5;114:9; 71:7 harder (1)

 8:23;93:11 59:4;86:22;87:2; 147:1;158:4;179:22; ham (1) 136:5 

grain (4) 130:23;222:22 201:18;202:14;220:3, 190:19 hard-working (1)

 22:25;44:8;172:24; greatest (1) 21 hamstring (1) 104:11 

178:17 27:24 growth (17) 214:25 harmful (1) 

Min-U-Script® Burke Court Reporting & Transcription (17) Goldilocks - harmful 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 1 

October 17, 2023 

105:13 hear (38) 137:21;142:15; 174:23;189:19; 117:12;201:11 

Harmony (1) 7:7;13:11;14:18; 143:17;145:13;148:2; 199:21 hometown (1)

 25:21 16:8;19:3;23:7;26:12; 151:22;152:23;153:1, hidden (1) 211:23 

harness (4) 30:20;41:15;43:12; 7,7,8;155:25;158:11, 72:20 homework (1)

 42:25,25;43:2,2 52:9;69:24;87:22,24; 15;161:21;162:12; high (6) 48:6 

Harold (9) 93:8;106:14;110:3; 174:25;179:19;180:2; 42:22;62:3;74:23; homing (1)

 85:17;93:3;97:18, 111:3,4;116:22; 183:5;188:19,24; 101:12;102:21; 153:17 

20,24;100:12,15; 124:19;126:20;133:1; 189:24,25;190:9,23; 105:16 honest (1)

 102:7;103:15 154:3;158:25;159:10; 191:6;196:19;197:3, higher (11) 23:6 

harping (1) 161:17;162:14;168:4; 5;200:7;202:13; 49:3,6;107:20; honor (1)

 34:14 175:3;183:14;189:10; 207:3;210:15,17; 108:18;128:18; 104:6 

harsh (1) 190:1;191:25;212:22; 212:24;213:25; 142:20,22;148:20; Honorable (1)

 118:15 217:16;221:10;223:6 216:11;220:8,17 152:10;161:21; 104:5 

harvest (4) heard (21) helped (3) 209:15 honored (1)

 43:19;82:24; 29:18;32:3;53:15, 38:10;151:5;212:25 highest (3) 9:4 

193:11;221:3 19;55:17;57:7;60:15; helpful (20) 28:2;74:23;209:21 hook (1)

harvested (1) 79:24;94:19;105:10; 22:16;40:13;48:4; high-labor (1) 76:13 

111:6 114:4;168:5;177:25; 60:13;61:9;69:13; 20:16 hope (17)

harvester (1) 195:4;201:12;203:1; 70:22;85:3;97:10; highland (1) 12:7;34:21;45:6;

 48:22 211:16;217:3;221:4; 108:22;121:6;138:12; 219:15 85:11;100:3;103:17;

harvesting (4) 224:9,11 139:12;151:11; highlight (10) 104:12;110:16;

 48:21;51:11; hearing (13) 155:16;158:24;168:3, 26:23;79:22;81:21; 114:12;124:10;

 106:18;221:4 12:9;15:21;22:3; 24;198:18;205:7 93:20;122:19;130:3; 127:23;137:7;178:7;

hatch (1) 39:15;61:18;110:9; helping (19) 131:4;135:23;136:18; 190:20;197:2;214:8;

 215:18 136:2;139:4;142:25; 9:2;21:15;27:1; 209:23 218:15 

hate (1) 164:9;197:14;205:21, 30:12;64:25;101:22; highlighted (1) hopeful (2)

 199:24 25 104:23;150:18,25; 69:1 34:16;127:2 

hats (1) heart (1) 179:25;180:3;190:14, highlighting (1) hopefully (2)

 75:8 104:4 19;209:16;212:2; 158:7 175:2;220:9 

haul (1) heartburn (1) 214:4;215:21;220:10, highly (3) hoping (2)

 206:21 134:22 25 21:4;55:6;74:18 74:5;216:13 

Havre (3) Heartland (2) helps (5) high-quality (2) hopper (2)

 208:19;214:1;222:8 72:10;87:15 28:6;82:3,24; 117:15,21 82:17,21 

hay (1) Heather (1) 190:21;213:18 Hill (3) Hops (1)

 189:20 9:3 herbicide (1) 126:7,10;175:3 80:10 

hazelnut (4) heavier (2) 178:24 hired (2) hormone (1)

 48:20;49:17;50:3; 132:6,6 herbicides (4) 23:9;174:2 210:5 

56:15 heavily (1) 104:24;105:13; historical (1) hormones (3)

hazelnuts (5) 104:17 179:22;196:22 163:11 105:6;196:4,21 

50:7,13,18;55:20, heavy (3) herd (2) historically (1) horrible (1)

 21 41:1;115:3;168:7 176:4;208:23 156:13 35:19 

head (3) heck (3) herds (1) history (8) Hort (1)

 112:5;182:25; 42:25;43:2;47:23 196:4 27:24;57:22;91:15; 98:9 

203:15 held (6) here's (4) 92:7;96:18;144:20; Horticultural (1)

headaches (1) 32:4;73:17,18;97:5; 90:13,14,14;203:9 164:12;218:25 81:13 

134:18 141:13,20 heresy (1) hit (2) host (1)

heads (1) helium (1) 207:1 37:16;38:11 6:6 

202:15 92:16 herring (1) hives (1) hosted (1)

heals (1) hell (1) 73:7 99:8 220:1 

223:4 18:14 hexane (3) hog (1) hosting (2)

Health (8) Hello (12) 44:9,10,12 25:14 12:4;71:12 

72:10;87:15;112:3; 7:20;10:14;52:24; Hey (10) hogs (1) hot (2)

 167:4;180:5;202:4; 81:12;102:7;116:22; 20:9;29:9;43:12; 19:16 101:15;142:12 

209:8;210:8 140:2,3;149:9; 102:7;112:22;115:15; holding (1) hotspots (4)

healthful (1) 172:16;192:6;208:14 137:20;153:15; 73:4 73:14,15;76:23;

 111:20 helm (1) 171:12;197:13 hole (2) 77:1 

healthier (2) 8:17 Hi (25) 22:21;201:8 Hour (6)

 147:13;190:6 help (57) 9:24;10:15;66:15, holistic (2) 71:6;92:24;93:5;

healthy (4) 24:12;38:16;51:6, 16,17;72:6,6;78:22; 137:1;196:23 165:10,12;200:15 

147:12;148:14; 25;57:16;70:8;74:15, 83:24,25;84:1;95:22; Holm (2) hours (5)

 198:15;206:23 22;76:9;82:11,23; 106:11,12;110:3; 9:1;11:20 15:19;42:10,19;

Healy (5) 91:22;94:23;99:22; 119:11,12;132:23,24; home (4) 71:8;106:22 

4:12;7:15,19,20;9:7 105:3;115:1;120:25; 135:6;143:4;165:22; 15:19;116:9; House (4) 

Min-U-Script® Burke Court Reporting & Transcription (18) Harmony - House 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 1 

October 17, 2023 

122:16;123:3;

 187:23,25 

household (1)

 186:16 

housekeeping (1)

 4:11 

houses (2)

 42:8,17 

Hudson (13)

 58:3;64:2;66:13,15,

 17,17;69:12;70:13,

 23;71:2,13,15;156:25 

huge (5)

 57:4;83:20;122:25;

 128:21;176:21 

human (7)

 147:13;155:7,7;

 167:4;194:1;209:8;

 210:8 

humane (1)

 198:10 

humane-based (1)

 26:2 

humbled (1)

 68:12 

humbly (1)

 210:15 

humic (1)

 170:7 

humility (1)

 206:16 

hundred (1)

 90:4 

hundreds (2)

 83:5;145:4 

hung (1)

 73:6 

hunting (1)

 6:16 

hurdle (1)

 136:6 

hurdles (1)

 115:4 

hurt (1)

 197:18 

husband (2)

 104:15;207:10 

Huseman (17)

 10:7,8;24:9,19,24;

 26:7;106:11,13;

 107:7,10;132:23,25;

 133:22;199:20;200:2;

 214:14;215:5 

hybrid (1)

 171:14 

hydroponic (2)

 110:25;111:4 

hydroponics (5)

 110:16;111:2,9,24;

 112:4 

I- (2)

 57:20;87:24 

ice (1)

 204:2 

idea (14)

 12:20;21:14;37:6;

 51:18;54:8,9,14,20;

 138:8;141:10;142:6;

 145:10;212:11;

 215:14 

ideally (1)

 88:15 

ideals (1)

 52:17 

ideas (2)

 52:9;141:16 

ideate (1)

 178:8 

identification (2)

 27:1;149:16 

identified (5)

 68:4;94:3,8;193:14;

 217:2 

identify (5)

 63:5,9,9;93:24;94:6 

identity (1)

 65:4 

IFAC (2)

 64:6,10 

IFOAM (1)

 155:9 

IFPA (5)

 192:13,17;193:2,

 14,19 

ignore (1)

 167:10 

illegal (2)

 19:5;49:1 

Illegally (1)

 19:21 

illuminated (1)

 77:25 

illumination (1)

 209:10 

illusions (1)

 206:8 

illustrates (1)

 65:8 

imagine (8)

 4:8;52:3;62:16;

 96:7,24;106:3;

 204:14;213:21 

immediately (5)

 7:13;42:2;53:21;

 59:15;140:19 

immense (1)

 12:4 

impact (7)

 16:16;98:25;

 101:17;128:6;146:20;

 163:10;193:6 

impacted (3)

 102:25;118:21;

 120:9 

impacts (2)

 88:22;186:21 

impending (1)

 185:8 

imperfect (2)

 207:5,7 

implement (1)

 31:18 

implementation (5)

 67:6;70:9,16;87:14;

 131:12 

implemented (1)

 52:18 

implementing (2)

 31:16;45:11 

implements (1)

 82:1 

implications (1)

 20:22 

implicit (1)

 67:2 

imply (2)

 20:22;46:21 

import (2)

 188:18;189:4 

importance (7)

 66:2;81:22;83:13;

 98:19;163:6;181:2;

 192:21 

important (26)

 8:3;22:7;23:14,14;

 35:4;44:1;54:6;64:24;

 73:10;75:18;87:23;

 93:17;94:18;95:15;

 110:9;117:3,20;

 127:13;132:18;

 151:24;153:11;

 161:10;163:5;167:17;

 221:6;222:25 

importantly (1)

 130:22 

imported (3)

 49:16,18;130:10 

imports (8)

 18:21;19:6;20:10;

 23:4;29:20;46:3;51:7;

 75:23 

impossible (1)

 107:23 

impractical (1)

 118:12 

impressed (1)

 175:4 

impressive (2)

 9:3;68:25 

improve (9)

 45:3;66:24;111:24;

 112:12;115:16;

 150:22;184:22;

 188:19;220:11 

improved (2)

 44:22;150:10 

improvement (13)

 45:8;103:2;112:14;

 114:11;115:5,10,14,

 18;116:7;123:14;

 126:19;206:9,17 

improving (2)

 27:21;149:24 

in- (1)

 187:24 

inadvertent (1)

 185:21 

inaugural (1)

 67:24 

incentive (3)

 28:24;31:17;37:23 

incentives (1)

 34:22 

incidental (1)

 44:15 

include (8)

 27:2;69:15;93:20;

 110:15;130:6;151:6;

 162:7,17 

included (1)

 39:6 

includes (4)

 8:25;77:17;161:23;

 169:9 

including (14)

 64:8,15;79:5;94:12,

 24;110:19;111:23;

 144:25;162:15,23;

 163:1;169:13;173:18;

 192:14 

inclusion (5)

 36:23;125:18;

 126:1;156:19;161:18 

inclusive (3)

 34:9;124:2;161:15 

incompatible (1)

 80:6 

inconsequential (1)

 23:1 

incorporate (2)

 131:16;150:22 

incorporated (1)

 210:11 

incorporates (1)

 133:8 

increase (13)

 4:8;29:16;35:5;

 46:2,2;94:12;102:16;

 122:25;127:3;131:2;

 179:13;193:16;

 198:22 

increased (8)

 29:19;35:6;41:18;

 73:15;86:23,25;

 173:8;197:8 

increases (1)

 127:18 

increasing (6)

 41:15;73:10;

 161:11;179:7;184:23,

 24 

increasingly (1)

 36:14 

incredible (13)

 12:6;72:7;117:11;

 124:10;158:8,17;

 172:20;179:11,23;

 181:15;188:8;197:10;

 202:25 

incredibly (1)

 72:7 

incubating (1)

 219:23 

indeed (1)

 201:17 

indemnity (1)

 186:25 

Independence (1)

 142:24 

independent (1)

 69:17 

Index (1)

 77:4 

indicate (1)

 12:25 

indigenous (1)

 21:14 

indispensable (1)

 117:14 

individual (6)

 12:18;37:17;91:6;

 166:13;167:6,16 

individually (5)

 58:21;61:12,17;

 196:16;212:17 

Individuals (2)

 12:16;104:11 

induce (1)

 193:4 

induced (1)

 79:2 

industrial (4)

 18:24;24:17;25:5;

 215:20 

industry (32)

 18:10,16;24:13,22;

 28:10,18;31:7,9;

 45:10,13;49:9;50:3,

 15,18;53:18;66:22;

 73:14;74:16;85:2;

 94:4;98:1;131:2;

 145:2;147:1,3;148:6;

 158:7,9;188:1;

 190:19;220:3,13 

Industry's (1)

 81:18 

ineffective (1)

 79:12 

inequities (1)

 135:16 

inert (26)

 58:14,15,24;59:4,6, 

I 

Min-U-Script® Burke Court Reporting & Transcription (19) household - inert 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 1 

October 17, 2023 

8,17;60:2,22;62:5,5; innate (1) instituted (1) 13;140:6;168:6 175:23;179:25;

 81:20;83:12;86:1; 136:22 203:16 interested (9) 181:19;183:10,17,18;

 87:25;92:3,12,18; innovate (1) institution (1) 54:8;96:3;107:11; 189:12;191:6;196:11;

 100:4;166:7,17; 66:25 52:8 175:20;176:18; 199:5;202:6;204:12;

 167:17;169:12,15,20; innovation (5) institutionalize (1) 182:18,21;188:4; 205:3;210:11;211:2,

 171:6 35:16;36:12;38:17; 125:17 197:24 8;214:24;215:15,24;

inerts (30) 113:8;209:4 institutionalized (2) interesting (6) 216:6;217:10,14,15;

 59:13;60:1;61:5,12, in-person (2) 30:23;31:17 36:1;42:5;109:10; 218:6;219:17 

16,20,23;62:6,11,24; 6:1;125:24 instruction (1) 125:16;170:15; introduced (2)

 72:15,19,20;73:3,5; input (7) 57:12 177:11 11:18;123:3 

75:6;76:3;79:24; 15:11;16:15;20:16; instrumental (2) interests (2) invaluable (1)

 83:17;91:5,12,16; 25:25;47:7;94:10; 213:8,23 16:8;50:5 105:22 

92:1,16;149:12; 132:1 insurance (11) interface (1) invasive (1)

 165:24;166:6;168:9; inputs (3) 93:16,18,19,23; 187:22 99:4 

171:14;172:4 46:10;58:21;151:8 96:1;141:14;163:3,5; interfering (1) inventory (1)

inexpensive (1) inquiries (1) 185:11;186:22; 99:24 146:3 

160:17 42:8 187:11 intern (2) inverts (1)

inflated (1) inquiry (1) insured (1) 156:5,6 168:14 

28:21 130:5 185:12 internal (1) invest (1)

inform (3) insect (2) integrate (1) 133:24 130:1 

130:22;131:17; 82:5;83:1 124:22 International (7) invested (1)

 159:8 insecticide (1) integrated (3) 16:13;50:17;64:6; 173:10 

information (25) 170:21 74:19;75:17;221:17 67:14;132:19;149:8; investment (10)

 7:5;8:8;22:16;27:3, insects (2) integrating (2) 192:9 27:24;80:23;83:5;

 8,12,14,20;32:25; 14:12;99:4 125:18;219:16 internationally (1) 180:3,4,5;190:13,13;

 34:4;40:19;63:10; inserts (1) integration (1) 117:10 211:8;220:21 

72:21;89:20;92:11; 86:20 175:5 Internet (6) investments (3)

 109:9;114:20;123:17; inside (2) integrity (20) 22:13;173:15; 12:6;105:23;190:22 

138:1,6,10,15,20; 15:2;205:1 21:22;22:7;24:14; 177:9,10,13;214:19 investor-owned (1)

 151:19;183:2 insights (2) 44:22;52:21;56:6; Internet's (1) 18:24 

informed (1) 28:15;31:20 58:18;79:7,11;80:2,4, 69:24 invitation (1)

 221:1 insist (1) 8,14,20;110:14; interrelated (1) 41:4 

infrastructure (2) 59:19 112:12;115:15; 107:25 invite (4)

 83:6;220:11 inspected (4) 123:13;130:9;131:10 interrupt (1) 7:12;71:6;125:25;

ingenuity (1) 53:25;105:20; intellectual (1) 13:8 137:11 

206:6 106:22;149:20 223:15 intersect (1) invited (1)

ingredient (9) inspecting (2) intended (2) 79:17 71:2 

36:7;65:6,18,19; 23:6;32:20 79:8;89:16 intersections (1) invites (1)

 66:2;86:3;166:7,18; inspection (4) intends (1) 79:22 22:1 

169:8 55:6;150:21;154:7, 131:2 intervention (1) invocation (4)

ingredients (36) 23 intensive (1) 23:17 14:9,9;15:6;18:3 

34:24;35:6;36:15; inspections (7) 59:2 interviewed (1) involved (4)

 46:10,12,24;58:14,16, 23:19,20;50:5; intent (2) 19:13 49:21;73:12;155:4;

 24;59:3,3,4,5,6,8,17; 154:12,14,17,18 27:1;52:16 interviews (1) 192:15 

60:2,23;61:24;62:5; inspector (10) intention (1) 155:22 involvement (1)

 64:8,16;65:8;80:9; 23:22,23;32:13,14; 171:3 intimidating (1) 223:11 

81:20;83:12;86:1; 128:16;149:21;153:3; intentional (2) 223:6 involves (1)

 87:1,3,25;92:3,12,13; 154:5,13;156:11 135:14;171:3 into (72) 49:9 

100:4;167:17;169:13 inspectors (19) intentionally (1) 12:6,8;15:15;17:21; IOIA (5)

inherent (1) 27:8;67:14,16;69:6, 69:14 18:15;21:20;22:21; 67:15;149:11;

 62:10 15,17;125:6;149:8; interact (1) 39:21;48:19;52:15; 150:7;155:3;156:10 

initial (1) 150:18;151:3;152:22, 161:22 56:25;78:2;82:22; IOIA's (1)

 134:22 24;153:6,12,18,21; interaction (2) 86:16;92:5;93:11; 153:16 

initiating (1) 154:7;156:12,14 167:22;185:7 96:16;99:15;100:2; ironclad (1)

 210:17 inspired (1) interactions (3) 101:19;108:1,15; 204:25 

Initiative (7) 70:6 88:21;167:2,5 111:7;115:2,9;119:7; irony (1)

 28:3,10;30:19; Instead (3) intercropping (1) 124:22;125:18;127:9; 207:3 

105:24;131:10; 23:6,10;100:21 80:7 130:5;135:17;138:12; irrigation (5)

 149:25;155:7 instinctive (1) inter-cropping (1) 139:20;141:13;142:3; 81:25;100:20;

initiatives (1) 19:18 185:18 144:9;152:19;154:4; 102:18,18;193:21 

135:10 Institute (4) interest (9) 155:10;156:15; Island (1)

inject (1) 110:8;204:22; 68:7;73:3;79:1; 158:16;159:8;162:12; 8:7 

100:1 219:22;220:1 87:12;100:21;117:12, 167:7,13,18;171:4; ISO-17065 (1) 

Min-U-Script® Burke Court Reporting & Transcription (20) inerts - ISO-17065 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 1 

October 17, 2023 

166:2 

isopropanol (2)

 81:23;193:20 

issue (22)

 49:24;53:13,23;

 58:18,23;59:12;

 60:12;75:6;80:19;

 81:20;87:23;91:18;

 92:6;106:23;112:6;

 121:14,14,19;137:9;

 170:18;173:16;176:1 

issued (1)

 73:1 

issues (17)

 12:8,19;58:13;

 79:16,17,22;92:15;

 107:24;108:2;110:10;

 111:1;112:11;115:10;

 121:11;122:19;137:8,

 11 

It' (1)

 40:15 

item (4)

 37:16;98:22;

 162:17;163:2 

itemized (1)

 37:13 

items (3)

 26:24;65:17;169:7 

J 

178:13;184:6;189:15,

 16,18;191:1,7,10,24;

 203:24 

Joanna (1)

 9:1 

job (17)

 72:17;73:17,23;

 90:10,10,10,13;99:12,

 17;109:19;134:13;

 151:2;168:11;184:20;

 201:21;224:25,25 

Jodi (1)

 205:18 

Jody (9)

 208:11,13;210:23;

 211:1;212:21;214:15;

 216:17,23;219:5 

John (22)

 13:24;18:6;26:9;

 33:20,25;36:22;39:1,

 21;42:20;43:3;157:5;

 161:5;165:20;172:14;

 178:12,14,16;180:9,

 20;181:17;182:5,24 

Johnson (32)

 10:10,11;30:10;

 31:22;51:21;60:10;

 61:9;75:2;76:2,14;

 89:25;107:14;108:7,

 22,24;120:4,13;

 121:6;124:14;139:2;

 146:14;152:16;

Julie (2)

 78:18;85:17 

jump (8)

 72:1;93:2;109:24;

 116:19;143:2;200:24;

 219:7;221:10 

jumped (2)

 15:8;215:24 

justice (3)

 18:18;67:20;162:1 

justification (1)

 88:14 

justify (1)

 209:15 

157:5;161:5;

 165:20;172:14;

 178:13;184:5,8,9;

 186:6,11,14;187:2,5,

 15;188:7;189:14 

kicking (1)

 92:5 

kids (3)

 106:5;157:19;211:9 

Kim (7)

 10:7;24:7;106:10;

 107:15;132:22;

 199:19;214:12 

kind (61)

 22:5;24:20;30:21,

 22;31:8,9,12,17;33:7;

 36:24;37:6;39:8,10,

 12;47:18;51:4,10;

 57:6;59:7;73:7;76:3;

 96:10;97:9,14;

 107:15;119:22;

 125:13,21;126:8,22;

 134:22;140:4,6,9;

 141:17;144:13;

 148:17;153:17;

 166:17;168:24;170:8,

 11;171:13,20;172:6;

 173:9;174:17;176:2;

 177:2;181:6,10;

 182:17;186:23;

 187:24;199:12,15;

 201:18;208:2;213:1;

Kyla (8)

 10:13,15;55:15;

 143:2,2,10,17;195:21 

L 

lab (4)

 73:11;76:22;133:1,

 12 

label (23)

 16:25;19:6;24:15;

 79:7;99:13;107:5;

 111:7,19;112:1,14;

 145:10,20;171:2;

 195:24;196:20;

 209:19;213:20;217:8;

 218:6,7,8;222:15;

 223:1 

labeled (2)

 209:24;210:19 

labeling (2)

 146:22;224:3 

labels (6)

 18:25;59:9;65:3;

 190:8;207:2;218:6 

labor (3)

 20:15,15,19 

labor's (1)

 21:11 

labs (6)

 78:3;130:18;

 133:11,14,19,23 

K 

Kailey (5)

 78:18;81:6;85:16;

 92:25;93:1 

Kailey's (1)

 93:2 

Kalispell (1)

 160:10 

Karlin (1)

 73:18 

Kaser (23)

 19:4;21:13;33:21;

 43:10;48:14,18,18;

 50:15,23;51:16;

 53:11,13;54:3,12;

 55:21,24;56:4,6,8,10,

Jackson (1) 163:22;168:3;181:17; 13,23;57:20 215:19;220:22 lack (13)

 104:15 187:17;204:1;205:6; Kastel (10) KMZ (2) 22:20;34:25;53:8;

Jahedi (3) 212:20;214:6,10; 13:6,24;18:5,8,9; 32:15,21 59:3;64:17;110:12,

 64:2;66:14;71:21 216:16 20:23;22:18;24:14, knees (1) 13,24;120:16;150:3;

Jared (2) join (6) 23;25:1 191:13 196:9;211:20,20 

9:1;11:20 71:2,6,14;179:3; keep (22) knew (5) lacking (3)

Javier (2) 189:13;222:19 4:20;6:17;24:7; 56:19;105:19; 110:18;136:2;138:1 

11:14,16 joined (1) 30:12;34:14;47:12, 145:2;155:16;179:10 laid (1)

Jay (5) 106:15 13;82:25;101:14,14, knock (1) 131:1 

72:1;78:16,19,21, joining (12) 17;113:20;127:1,17; 216:14 lamb (5)

 22 70:25;76:17; 143:12;149:13; knockdown (1) 105:5;106:15,24;

Jeff (1) 106:13;126:5;143:21; 165:18;173:8;179:1; 99:5 107:5;108:4 

189:19 146:11;151:17; 186:17;190:16;223:3 knowing (4) lambs (3)

Jeffrey (5) 160:24;174:23; keeping (2) 28:11;87:12; 104:3;105:8;108:14 

9:16,17;16:1; 183:23;219:5;224:24 101:9;159:17 183:15,19 lamenting (1)

 175:11;176:6 joke (1) keeps (2) know-it-all (1) 189:10 

Jenny (2) 19:15 104:13;220:14 33:13 land (10)

 12:5;151:10 Jordan (2) kernels (2) knowledge (3) 79:4;123:16;

Jerger (13) 184:6;189:16 49:17,19 141:11;201:9; 159:16,19;172:19,22;

 122:7;129:16; Joseph (17) Kestral (1) 211:21 185:2,9;219:19;223:4 

135:3,6,7;138:9,25; 116:19,21,25; 114:2 known (10) landholders (1)

 139:11;140:3,11; 120:4;122:2;145:21; Kestrel (7) 18:10;40:14;59:15; 21:16 

141:21;142:21; 157:5;161:5;165:20; 103:20;109:25; 92:3;93:2;103:21; lane (2)

 143:10 172:14;178:13;184:5, 110:2,7;112:23; 117:15;130:7;167:1; 47:13,16 

Jerry (12) 7,9;186:15;187:18; 113:24;116:14 216:24 Langager (12)

 9:25;10:2;51:20; 189:8 key (6) knows (1) 72:1;78:16;81:4,8,

 52:23;102:5;115:20, judge (1) 75:18;79:5,10,22; 23:22 11,12;83:25;84:17;

 21,23;116:11;214:13; 48:25 90:9;134:4 kudos (1) 85:6,10,13;194:25 

216:19,22 Julia (6) keys (1) 83:20 language (13)

Jess (12) 93:3,7,13;95:22; 36:3 Kumar (1) 59:23;136:3,5;

 161:5;165:20; 97:16,17 Kibiwott (16) 9:3 140:5,6,7,8,9,14,21; 

Min-U-Script® Burke Court Reporting & Transcription (21) isopropanol - language 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 1 

October 17, 2023 

141:2;142:8;143:16 leading (3) 28:23 117:24;118:4,6; 60:5;83:16;91:6;

large (9) 21:8;47:6;80:23 Lester (2) 121:10,22;128:9; 98:11,14;171:16;

 16:8,10;18:20; leads (1) 12:5;151:10 150:2;188:13;194:3; 193:2,7,19;194:9 

31:19;52:18;152:9; 110:13 letting (2) 209:13 listings (1)

 160:19,19;173:13 leaf (3) 175:1;188:17 limiting (1) 80:3 

largely (1) 82:9,16,21 level (11) 120:15 lists (5)

 209:6 leapt (1) 76:10;104:9; limits (1) 61:14;62:11;91:23;

larger (3) 57:6 124:15;127:14; 169:14 171:25;172:5 

42:8;89:7;199:5 learn (1) 142:14,14,19;174:18; Lincoln (1) lit (1)

largest (2) 182:16 209:21;212:5;213:5 11:1 40:3 

21:3;59:6 learned (4) levels (5) line (13) literal (2)

LaRocca (13) 155:12;190:18; 19:13;24:1;77:14; 4:8;7:4;63:23,24; 135:25;140:23 

129:16;135:4; 213:11;216:12 101:13;121:20 99:3;145:8;152:19, Literally (7)

 143:23;144:1,4,6,7, learning (6) leverage (1) 24;172:6;173:17; 42:10;105:10;

 10;146:13;147:1; 67:23;124:9;125:2; 124:4 205:19;208:15; 205:11;211:23,25;

 148:8,25;149:3 136:25;216:7;219:24 Lewis (39) 212:24 213:5;218:21 

last (25) leased (1) 10:16,17,21;13:4, lines (3) little (47)

 4:19;8:8;12:3; 147:4 23;14:2,4,4;15:25; 81:24;101:10;206:7 4:10;16:23;29:21;

 14:17;19:13;28:25; least (13) 16:6,20,21;17:7;18:1; linguistic (1) 30:14;31:4;39:5;

 33:2;35:14,16;36:10; 28:22;40:16;44:2; 38:24;39:1;47:2,4; 135:25 40:22;46:7;49:13;

 50:8;76:24;85:15; 51:2,6;70:5;88:20; 50:11,12,21,24;51:2, link (4) 51:16;54:13;60:17;

 117:11;124:18;127:5; 123:22;168:4;175:1; 14;61:11;62:9;69:23, 71:15,16;88:13; 61:6,7;62:24;63:2;

 136:25;149:22;151:9; 188:10;195:4;200:6 24;70:21;91:3,9; 224:22 69:25;70:20;82:18;

 155:17;156:5;157:12; leave (3) 121:8;132:1;153:15; linkage (1) 101:1,20;104:16;

 182:24;184:15;186:3 15:13;167:23; 171:12;186:13,15; 126:24 119:22;124:23;128:5;

lastly (1) 212:14 187:4,13 linked (3) 134:2,11;139:6;

 125:23 leaves (3) Lewis' (1) 49:25;179:8;222:14 141:7;143:1;144:20;

late (3) 82:19,19;99:24 18:11 Lipson (13) 155:3;171:14,18;

 157:16;193:1; leaving (3) Lewistown (1) 66:14;72:1,6;73:22; 181:7;182:17;184:14;

 205:23 44:19;99:11;122:24 214:2 74:2,7;75:14;76:5; 187:19;194:21;195:2;

later (2) lecithin (2) lexicon (1) 77:2,9;78:10,14; 198:17;199:5;204:19;

 22:3;44:21 46:14;64:16 143:8 91:21 212:22;214:21;

latter (1) led (5) Library (2) liquid (3) 217:11;219:14 

52:8 47:19;67:19; 143:11,12 80:15;98:15;170:10 livable (1)

Laughs (1) 155:10,20;216:6 lid (1) Lisa (10) 80:24 

91:8 Ledger (1) 204:17 189:17;192:4; Live (7)

launch (7) 178:18 lies (1) 195:14,20;197:13; 5:2;8:7;67:3;160:5;

 74:11;158:12; left (4) 202:17 199:21;200:13;203:6, 189:21;198:25;199:3 

179:17;197:2;208:24; 6:22;84:17;206:3,5 life (1) 10;212:10 lived (2)

 210:15;220:16 Legacy (2) 157:14 List (56) 207:5,6 

law (3) 106:23;162:20 lifelong (1) 6:10,14,23;16:17; livelihood (1)

 19:18;59:1;146:25 legal (5) 97:25 34:8;36:10,11,23; 222:6 

laws (3) 19:24;22:19;87:11; lift (6) 59:15,20,24,25;60:18, lives (2)

 19:20;79:12,13 109:11;111:11 129:9;132:6,10; 22,25;61:1,15;62:12; 14:11;132:13 

lawsuit (4) legislation (3) 134:14;168:7;180:19 63:1;64:21;65:18,19; livestock (22)

 19:5;53:8,10,23 123:3;127:16,20 lifting (1) 66:3;73:7;76:13;79:9; 18:21;21:1;24:22;

lawyer (1) legislative (4) 41:1 83:8;86:5,14,20;88:5; 25:6,9;59:11;61:15,

 48:19 23:17;76:10; light (2) 89:7;90:16,22;92:2,8; 19;94:13;105:7;

lay (2) 127:21,23 79:21;82:22 98:10;100:18;117:6; 106:14;110:15,16,19;

 37:11;206:12 legitimate (2) lightly (1) 133:4,14,17;136:16, 123:5;128:20;149:15;

layers (1) 53:6;206:10 209:1 19;149:14;168:14; 150:9,11;167:3;

 24:16 legumes (1) liked (1) 169:1,7,20,21;171:6, 210:10;219:20 

layman's (1) 153:9 55:7 14;193:20;207:25; living (1)

 183:7 lentil (1) likely (2) 208:1,9 223:21 

lays (1) 188:12 129:6;167:23 listed (5) Liz (3)

 112:10 lentils (4) Lime (5) 59:9;61:12,17; 26:16;29:7,9 

lead (4) 184:18;186:17; 82:2,3;98:16,19,23 152:8;162:4 Liz's (1)

 106:1;131:12; 187:23;189:21 limit (2) listen (2) 134:16 

184:9;200:4 less (9) 118:20;170:11 117:4;155:22 LLC (1)

leaders (4) 20:2;44:8;61:7; limitations (1) listening (3) 48:19 

14:23,24;16:4,12 118:6;120:24;142:14; 45:4 194:24;217:13; load (1)

leadership (2) 198:16;207:2;220:4 limited (13) 218:14 152:10 

74:24;146:15 lessen (1) 24:21;54:7;65:23; listing (10) LOCA (1) 

Min-U-Script® Burke Court Reporting & Transcription (22) large - LOCA 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 1 

October 17, 2023 

34:25 

local (17)

 49:16;50:6,18;

 138:2,5,18;142:14;

 156:3;160:6;173:14;

 176:17,18;195:25;

 200:8;214:3,20;

 222:11 

locally (2)

 157:18;158:6 

locate (3)

 6:4;52:21;149:21 

located (2)

 128:16;178:18 

location (6)

 27:1,9;97:9;149:16;

 151:19;177:18 

lock (1)

 104:22 

locking (1)

 32:15 

Locust (2)

 64:15;80:12 

log (1)

 224:23 

Logan (9)

 11:1;20:8;38:25;

 41:12;100:15;119:10;

looked (2)

 60:24;62:17 

looking (21)

 6:9;12:1,8;15:7;

 22:2;36:15;46:24;

 47:10;54:24;56:25;

 57:8;69:16;78:12;

 100:22;103:4;124:21;

 146:23,23;165:6;

 170:13;211:11 

lose (5)

 115:6,14,17,18;

 154:20 

loses (1)

 186:24 

losing (3)

 18:22,23;114:10 

Loss (8)

 18:24;93:24;

 123:16;146:16;

 150:14;186:23;187:1,

 12 

lost (3)

 95:2,2;187:8 

lot (80)

 17:15;20:10,12,14,

 14;25:1;30:18;34:11;

 35:2;38:1;40:14;

 216:11;222:24 

loved (1)

 218:13 

lovely (1)

 18:3 

loves (1)

 186:16 

loving (1)

 18:16 

low (3)

 37:9,18;101:20 

lower (6)

 6:22;24:1;49:5;

 99:21;101:20,21 

lowering (1)

 121:21 

low-hanging (1)

 37:9 

luck (3)

 107:8;112:17;

 175:23 

lunchroom (1)

 159:12 

lunchrooms (1)

 106:2 

15:18;39:5;40:22;

 44:7;80:17;87:25;

 96:12,18;104:8;

 116:9;128:21;136:5;

 190:20;222:16 

making (25)

 12:16;19:19;28:22;

 32:23;67:17;95:22;

 105:23;117:7,18;

 118:20;119:3,5;

 135:15;141:18;

 160:18;163:6;178:4;

 181:2;184:2;189:11;

 200:13,18;205:14;

 207:13;224:10 

malfeasances (1)

 204:21 

malign (1)

 12:17 

man (1)

 147:16 

manage (1)

 93:21 

manageable (2)

 87:9;90:8 

management (11)

 69:8;79:5,10;94:4;

 96:11,11,16;97:2,2;

 68:12,14;69:18;

 86:21;90:2,11;

 100:17;101:24;

 110:24;111:15;

 117:23;118:14;

 120:19;121:17;

 123:10;125:4,12;

 128:14,22;133:23;

 146:15,15;148:19;

 151:12;153:6;157:24;

 158:18;162:2,5;

 164:19;166:11;168:9,

 10;179:24;183:2;

 185:13;191:25;

 196:10;211:7;215:19;

 216:25,25;217:3;

 219:10;222:11 

maps (1)

 82:20 

Margaret (10)

 135:4;143:23;

 149:4,6,8;151:17;

 152:16;153:15;155:2;

 157:1 

margin (1)

 107:1 

marine (1)

 80:17 

M 

137:19;138:9;197:12 42:23;60:15;71:9; machine (1) 184:12;196:23 Mark (35)

Logan's (1) 75:7,15;77:6,13; 177:11 manager (5) 13:6,23;18:5,7,9;

 22:6 84:20;89:16;91:13, magic (1) 64:5;161:8;178:2,2; 20:7,9;22:1;24:6,10;

logical (1) 18;92:6,10,11,15; 119:21 221:15 26:7,8;38:11;66:14;

 130:8 93:12;95:24;101:3, magnitude (1) mandate (2) 68:11;72:1,5;73:24;

logistics (1) 12;103:7,8;106:25; 74:9 87:10;91:24 74:4;75:2;76:17;78:7,

 224:17 108:3;110:18;112:4; main (2) mandated (1) 13;91:21;108:3;

long (10) 113:10;115:18;120:5; 101:16;112:8 210:2 192:5;195:15;200:21,

 92:6;101:3;108:5; 126:20;127:9;133:19; Maine (1) mandatory (1) 23,25;201:2;202:20,

 115:15;124:9;125:10; 140:14;142:1,2,5,9; 25:20 27:15 23;204:1;211:17 

133:5;171:23;206:21; 143:14;144:8,9; mainly (1) manifested (1) markedly (1)

 218:25 145:18;155:24; 132:4 69:18 25:17 

Long-au-ger (1) 156:17;157:23; maintain (10) manner (2) marker (2)

 81:9 160:10;164:9,20; 14:14;117:24; 27:13;190:14 123:11,17 

longer (4) 175:18,21,25;178:1; 150:16;184:19,25; Manual (4) market (35)

 36:11;39:25;86:24; 180:14,18;181:20; 185:2,14,19;186:8; 8:15;12:11;20:5; 17:5;28:8;37:19;

 118:22 183:13;185:6;191:18; 193:21 166:4 53:20;75:16;77:17;

longevity (1) 196:1;197:14;199:2; maintained (1) Manuel (14) 89:8;105:8;107:18,

 118:23 204:4,5,6;205:2,25; 121:20 205:18;208:13,14; 24;108:17;111:12,12;

long-term (1) 206:1;217:23;219:1; maintaining (6) 211:5,13;213:3; 114:7;137:5;147:21;

 146:17 220:19;222:1 16:17;27:12;112:7; 214:8;215:4,7; 173:2,8;177:7;

long-time (1) lots (4) 115:13;117:5;208:22 216:18;218:12,15,19; 180:15;186:1;187:8,

 57:11 51:22;57:4;71:8; maintenance (1) 219:3 9,19;188:5,10;189:6,

look (35) 221:3 83:6 manufacturer (4) 25;190:16;194:3;

 15:9,18,21;16:25; loud (2) major (2) 21:8;42:7,16,16 199:1,3,5;202:13;

 20:4;23:10;24:20; 13:17;97:22 80:12;147:10 manufacturers (7) 223:19 

29:4;33:23;46:18; love (29) majority (6) 41:7;64:7;87:11; marketing (35)

 51:4;55:18;56:10,24; 31:14,14,17;37:4, 21:1;25:9;81:15; 89:6,14;129:22; 25:2;28:4,4;31:4,

 57:1,9;61:22;66:22; 25;38:6,21;39:14,15; 82:3;100:25;209:12 167:22 10;33:3,5;105:25;

 69:20;90:9;91:11; 45:21;53:6;62:7; maker (2) manure (1) 108:4;112:1;147:10,

 103:16;139:18; 113:22;124:19; 121:12;146:7 105:6 14;148:3,9;150:10;

 153:20,20;160:16; 148:23;157:21;158:1, makers (5) many (56) 159:7;160:2;177:9;

 168:6,11;169:24; 11,18;159:11,18,21; 118:14,19;119:2; 16:14;21:4;23:23; 179:17;188:3,21;

 170:6,13;180:25; 160:2,19;165:3; 121:13;146:5 29:1;34:10,19,24; 190:20;196:25;197:2,

 206:2;217:7;218:2 204:11;212:18; makes (14) 40:5;57:5;60:16;62:4; 3;198:17;204:3,9,13; 

Min-U-Script® Burke Court Reporting & Transcription (23) local - marketing 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 1 

October 17, 2023 

209:15;210:16; 77:3;101:20;103:5; 17,21,24;11:2,5,8,12, 142:4;211:14 microbial (1)

 214:18;215:2;220:21; 125:21;128:15,20,23; 15;20:9;24:9,19,24; mentioned (25) 118:11 

224:4 137:25;138:17;140:7; 26:7;30:10;31:22; 22:9;24:11;30:15; microfiltration (1)

marketplace (9) 154:1,21,22;171:20; 39:1;41:13,21,23; 33:3;37:2;53:15;63:1; 118:8 

19:11;28:11,16; 186:4;187:11;188:12; 42:1,4,13,20;47:4; 76:20,20,22;98:18; microphone (1)

 42:24;43:1;110:13; 198:3,14;212:10; 50:12,21,24;51:2,14, 113:3;125:2;139:8; 196:17 

111:6;112:11;129:24 214:21;215:12 21;52:24;53:12;54:1, 152:2,25;162:10; middle (2)

markets (15) MCAT-funded (1) 5;55:16,23;56:1,5,7,9, 164:25;194:9,25; 48:21;203:4 

18:21;19:7;36:25; 150:7 12,17;57:10;60:10; 203:24;212:10;213:6; Midwest (1)

 38:17;106:24;150:23; mean (28) 61:9,11;62:9,22; 221:11,14 9:20 

157:17;160:6;172:22; 10:4;31:5,6;39:14; 63:14;69:24;70:21; mentioning (1) might (32)

 173:14,15;175:3; 53:16;61:24;73:25; 75:2;76:2,14;87:21; 155:11 12:17;18:13;22:13;

 186:2;187:21;222:16 88:25;90:10,23; 89:22,25;91:3,9; mentions (1) 40:3;47:4;51:15;53:5;

marmorated (1) 91:10,17;96:23; 100:16;102:3,6,9; 98:21 55:2;57:18;61:6;

 83:1 101:6;102:15,23; 103:12;106:11,13; mentor (3) 84:19;88:22,23;99:1,

Marni (1) 140:16;141:15;152:7; 107:7,10,14;108:7,22, 67:16;190:11,14 5;108:5;113:2,11;

 73:18 154:10;174:13,14; 24;115:22,24;119:11, mentoring (1) 116:2;125:14,16;

mask (1) 183:13;199:12; 13,25;120:4,13;121:6, 67:18 128:18;133:24;

 102:11 213:11,20;218:21; 8;124:14;128:4; mentors (1) 164:23;171:5;177:17;

masking (1) 224:13 132:1,23,25;133:22; 151:14 179:5;198:6;204:23;

 103:1 meaningful (1) 137:20;138:24;139:2; mentorship (2) 214:21;224:8,13 

massive (1) 209:17 140:2,4;143:4,19; 67:15;191:2 Mike (10)

 179:13 means (13) 146:14;152:16; menu (1) 26:10;29:23;33:21;

master (1) 53:18;106:2; 153:15;163:22;168:3; 6:11 43:9,11,15;45:17;

 33:15 174:16;196:2;197:5; 171:12;181:17; message (14) 47:1;48:3,7 

Material (12) 201:9;206:7;209:10; 186:15;187:4,13,17; 6:5;51:1,13;105:3, mildew (2)

 19:24;24:4;39:16; 210:1;211:21,25,25; 197:13;198:3,5,19; 21;132:18;148:3,6; 82:4;85:5 

40:23;45:23;82:10; 218:21 199:10,14,20;200:2; 175:3;180:13;183:16; miles (1)

 88:6,6;98:24;101:8; measly (1) 204:1;205:6;212:20; 196:13,18;217:6 160:10 

117:20;118:2 19:19 214:6,10,14;215:5; messaging (1) milk (4)

Materials (23) meat (4) 216:16,23;218:13,17, 181:19 94:10;106:3;

 34:17;35:18;36:12; 177:3,14;178:2,3 20 messy (2) 159:13;204:7 

41:22;46:20;60:16, mechanism (1) member (11) 115:11,11 million (5)

 20,25;75:11;76:4; 203:14 14:4,5;72:7;78:23; met (4) 117:9;127:7,8;

 81:19,21;82:16; mechanisms (2) 79:25;97:25,25; 152:3;166:14; 173:11;190:18 

99:14;100:7;117:6; 39:18;162:11 113:15;129:25;145:5; 172:2;191:3 Milwaukee (3)

 118:5;149:13;168:6, mechanized (1) 196:10 metaphor (1) 29:5;95:11;123:25 

10,16;172:9;192:20 21:4 member- (1) 215:19 mind (14)

math (1) medium (1) 129:19 methodologies (1) 38:3,8;42:23;97:7;

 106:25 180:4 members (36) 130:18 104:7;126:24;134:2;

matrix (1) meet (9) 7:12,22;8:24;9:8, methods (4) 154:8;201:16;204:4;

 69:8 39:9;60:3;70:17; 10;12:18,20,25;13:1; 27:19;34:23;76:25; 205:5;207:16;217:23;

matter (8) 86:7,14,18;87:8; 15:14;19:4;22:23; 221:24 221:25 

14:19;17:16;48:20; 184:21;185:7 31:7;43:21;54:19; meticulously (1) Mindee (5)

 77:9;89:19;102:16; meeting (28) 68:8,9;70:3;83:21; 112:11 9:14,16;15:25;

 105:10;152:6 4:12,15;6:1;7:17; 93:17;95:8;104:6; metric (3) 175:9,10 

maturity (1) 8:4,8,8,9,12;36:11,24; 123:23;124:21; 43:25;44:4;47:15 mindful (1)

 82:25 38:1,4;60:6;64:20; 125:20;126:9;127:2; Mexico (2) 131:11 

maximizing (1) 65:12;79:5;95:11; 129:24;135:14; 15:4;25:19 minds (1)

 172:22 103:17;123:20,23,25; 137:15;144:8;149:9; mic (10) 212:14 

may (22) 149:23;162:19;172:9; 161:10;165:17,22; 4:11;6:7,21;7:1,2, mine (1)

 6:14,16;7:14;14:12; 207:1,4;224:20 196:8 14,15;9:7;11:11,22 131:25 

40:21;51:7;52:11; meetings (10) membership (5) Michael (1) minerals (1)

 65:20,20;82:5;89:5; 4:19;8:12;17:5; 27:7;66:25;68:5; 77:21 191:17 

121:12;137:3;140:7; 39:25,25;95:10,12; 194:5;195:3 Michelle (10) minimal (1)

 152:25;162:8;197:15; 123:22;125:24; memorable (1) 7:19;8:25;9:8; 23:9 

204:20,20;207:1; 162:18 106:3 11:24;15:17;71:22; minimize (2)

 209:20;215:13 meetings/ (1) Mendocino (1) 109:22;116:14; 5:17;55:4 

maybe (37) 163:2 117:2 207:23;224:17 minimum (2)

 15:1;20:19;31:13; meets (3) mentees (1) microbe (1) 117:25;133:12 

40:7,17;46:11;49:13; 83:10;166:2,10 191:3 118:10 minus (1)

 52:19;54:21,21;56:2, MEM (131) mention (5) microbes (1) 119:22 

18;62:5;74:13,22; 9:23;10:1,4,8,11,14, 68:11;76:11;94:22; 118:9 minute (3) 

Min-U-Script® Burke Court Reporting & Transcription (24) marketplace - minute 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 1 

October 17, 2023 

81:6;116:1;215:5 

minutes (8)

 7:6;23:8;85:16;

 92:24;165:9;191:25;

 200:17;211:17 

miracle (1)

 105:1 

miraculous (1)

 104:20 

Miranda (1)

 9:1 

misconceptions (2)

 202:2,16 

misheard (1)

 56:18 

misinformation (1)

 220:19 

misnamed (1)

 92:16 

missed (1)

 205:17 

missing (1)

 61:21 

mission (7)

 29:1;68:7;129:22;

 188:25;189:5;213:17;

 223:21 

missions (2)

 188:22,24 

Missoula (2)

 160:13;213:24 

mistake (1)

Molina (1)

 72:8 

Molino (1)

 72:8 

Mom (1)

 23:21 

moment (6)

 41:5;51:23;93:11;

 104:8;106:21;134:2 

momentum (2)

 184:19,25 

MonaRae (8)

 143:24;149:5;

 157:3,6,9;159:4;

 160:3,23 

Monetary (1)

 21:12 

money (7)

 127:16;129:9;

 178:5,6;190:12;

 204:12;224:5 

monied (1)

 104:10 

monitor (1)

 42:17 

mono- (4)

 64:13,23;65:10,13 

monoglycerides (2)

 65:19,21 

MonRae (1)

 159:7 

Montana (34)

 30:14;31:4;33:8;35:8;

 36:6;40:22,23;41:2,3,

 6;46:7;47:4,14,25;

 51:3;52:6;57:17,18;

 58:14,19;60:1,17;

 61:7;63:2,10,12;

 67:18;68:10;69:14;

 70:20;71:24;73:9;

 74:9;84:25;85:4;87:2;

 92:10,11,16;93:25;

 95:6;96:11;97:2,3;

 98:10,24;101:10;

 104:8,16;107:3;

 108:7;111:1,2,20,22;

 113:16,21;114:6;

 115:2,3;116:10;

 124:2,16,19,24;125:7,

 15;126:21;127:8,11;

 128:15;129:1,5;

 135:14;138:7,10,12,

 18;139:12;142:13;

 149:20;151:8;152:22;

 154:3,17;156:19;

 158:15,16;160:16;

 161:13,14,19,19;

 164:8,24;167:11;

 177:24,24;180:14,25;

 181:7,15;185:1,5;

 186:4,4,4;187:19;

 188:20,20;189:10,10;

 191:16,17;193:12,12;

 197:14;198:17;200:8;

 46:9;149:10;222:5 

Mountain (1)

 214:2 

mouths (1)

 211:2 

move (6)

 17:20;34:13;57:16;

 80:5;134:23;220:23 

moved (2)

 160:11;201:3 

movement (7)

 18:15;123:4;124:3;

 128:22;161:15;

 220:22;224:3 

Movements (3)

 16:14;161:13;224:3 

moves (1)

 27:16 

moving (6)

 17:24;24:7;60:13;

 95:12;115:12;123:9 

mow (1)

 45:21 

Moyer (7)

 189:17;192:4,6,7;

 194:23;195:8,13 

much (88)

 14:7;15:14,23;20:6;

 30:10;32:18;33:6;

 34:2;39:25;41:2,3;

 42:8;50:10;54:1;

 60:10;68:23;69:22;

multigenerational (1)

 178:21 

multimillion-dollar (1)

 20:1 

multiple (1)

 111:14 

multitude (1)

 208:21 

must (19)

 12:13;44:12;58:20;

 59:1,14,14;68:11;

 70:4;80:5,18;86:6;

 94:20;112:13;130:17;

 150:15;151:6;161:14;

 174:8;207:8 

mute (4)

 6:24,25;7:13;78:21 

muted (7)

 4:17,20;84:3;

 115:23;157:7;182:5,6 

mutual (1)

 8:19 

myself (9)

 53:1;58:9;140:12;

 182:7;190:5;199:24;

 201:13;207:5;222:6 

myths (4)

 159:9;179:9;183:3,

 14 

N 

155:15 12:4;104:4;106:23; 207:8,21;211:2,25; 74:4;75:2;81:8;83:21; name (33)

misuse (2) 114:4;149:9;151:11; 212:19,22;213:1,13; 85:9;91:19;107:15; 6:3,11,15,23;7:2,3;

 204:21,25 157:9,11;172:18; 217:10,11;219:16; 109:19,20;112:17,19, 12:23;18:9;33:25;

mites (1) 178:18;184:17; 220:1;221:23;223:14; 23;113:23;114:24; 45:2,2;48:16;50:15;

 82:8 189:21;195:21;196:7; 224:1,14 116:17,24;119:8; 58:11;64:4;81:12;

mixtures (1) 197:21;199:22;201:3; Moreover (1) 120:12;122:1;124:12; 93:13;97:24;104:2;

 59:10 203:5,10;207:11; 105:15 128:11;131:18; 110:6;116:25;129:18;

Mmm (3) 208:19,20;211:3; Morgan (1) 132:19;133:19;139:2, 144:7;161:7;165:23;

 33:9;39:20;178:7 213:16,22,23;216:5; 196:7 13;143:20;146:9,10; 172:16;178:16;184:9;

MOA (3) 219:13;221:16,20; morning (21) 148:24;149:19;151:8, 192:7;195:20;201:2;

 157:10;207:11,14 222:7,9,11;223:13 9:11,17,20,21;10:1, 15;152:10,16;158:23; 215:7;221:19 

mode (4) Montana's (1) 2,4,8,9,11,12,24,25; 159:1;160:23;161:18, named (1)

 4:18;39:21;95:16; 109:10 11:2,3,5,6;26:15; 20;163:22,23;164:1; 139:4 

144:14 Montero (1) 33:22;40:1;98:4 170:9;174:19;179:9; names (1)

model (6) 145:8 morphed (3) 183:17,18;186:10; 12:14 

25:5,14;67:23; month (4) 18:15;21:17;52:15 187:17,21,24;188:7; name's (1)

 79:20;97:4;166:5 30:21;35:13;124:8; most (39) 189:2;191:1;192:1; 219:11 

models (2) 139:15 17:20,23;23:19; 194:12;199:8;200:13; Nandu (1)

 92:1;141:18 monthly (1) 24:21;34:15;35:4; 205:14;207:13; 192:24 

modernized (1) 70:18 36:3;46:17;52:3;87:7; 212:20;213:11; Nandwani (4)

 167:21 months (6) 96:12;101:8;102:10; 216:17;218:5,22; 10:23,24;62:22;

modernizing (1) 38:2;50:5;155:17; 105:16,18;110:15; 219:5;221:2;222:24; 63:14 

166:7 174:3;178:1;195:4 132:17;136:12,12; 224:7;225:1 narrow (3)

modify (1) moral (1) 147:19;150:20; mulch (2) 52:6,11;102:1 

161:24 217:15 153:22;155:5;157:21; 40:2;192:25 Nate (57)

Moffett (2) moratorium (1) 158:4;159:9;164:1; mulches (2) 8:16;9:10,15;10:16,

 12:5;157:12 167:16 189:4;191:15,16; 82:14;98:15 18,22;11:22;21:25;

Moffitt (1) more (144) 193:24;196:3,23; mulching (2) 26:12;32:20;33:16;

 151:10 12:24;14:7;20:24; 206:13;208:24;210:3; 80:7;83:7 35:7;36:21;38:24;

MOFGA (1) 21:23;23:14;24:17; 217:13,17;224:9 multi (1) 41:8;43:14;47:2,2,17;

 95:3 25:24;27:25;28:14; mostly (3) 45:5 50:11;60:9;61:10; 

Min-U-Script® Burke Court Reporting & Transcription (25) minutes - Nate 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 1 

October 17, 2023 

63:18,25;66:15; need (106) nets (3) 123:10;124:6,20; 129:21;155:9;

 69:23;71:24;72:6; 5:6;14:18,19,21,21; 82:16,25;83:4 125:6;161:9;162:6, 199:11;206:9;219:12 

89:24;91:2;97:23; 21:21;28:8;31:2; netting (1) 25;163:6,15,17; northern (1)

 103:18;109:23; 42:12;46:12;59:12; 83:2 164:19 221:16 

115:24;120:3;121:7; 60:12;61:2,5;62:10; network (3) NOC's (1) Northwest (8)

 122:9;126:4;131:24; 67:3;68:4;74:19;75:6; 70:19;71:3;223:2 122:12 81:13,15,18;82:12;

 141:21;144:3;153:14; 77:23;84:25;86:15; Neubauer (5) noises (1) 98:2,9;101:12;195:1 

154:24;157:7;165:22; 87:5,13;88:16,17; 219:8;221:12,13, 13:18 NOSB (71)

 171:11;178:15; 89:4;90:24;92:19; 19;223:10 non (1) 7:12,12;8:9;9:2,8,

 186:13;194:15; 93:21;94:3,8;95:17; new (35) 136:20 10;11:23;12:20;13:1;

 195:17,19;199:20; 105:3,22,25;112:12, 6:21;9:2;19:19; non-administrative (1) 18:19;24:5;37:3;

 207:24;214:14; 14;113:2;114:4,19; 34:4;35:2,12,13; 166:12 43:16;45:12;46:21;

 221:13;223:10; 115:8,11;119:21,24; 36:15;57:23;67:5; non-agricultural (1) 59:9,19,20;60:4;

 224:25 123:5;124:16;126:21; 69:19;113:14;122:16; 39:7 74:13,22;78:23,24;

nation (2) 127:21,23;130:14; 124:22;125:20; non-certified (1) 79:6,9,25;80:10;

 121:1;177:18 131:8,10;136:10; 134:17;148:19; 202:1 83:17,21;85:20;86:9;

National (41) 137:13;138:4;142:13; 150:22,22;178:1,3; non-discriminatory (1) 87:10;89:13;95:6,10,

 4:6;7:16,21,22; 145:6;146:5;147:10, 187:25;190:12,14,14; 166:3 11,13;97:24,25;

 8:12,24;16:17;34:8; 14,22;148:2,8,11,13, 191:6;197:6;204:23; none (3) 99:14;104:10;111:13,

 59:24;61:15;62:12; 14,17,17,22;149:21; 208:24;210:17; 19:16;118:7;187:3 15;112:9;115:1;

 64:21;66:3;79:9;80:3; 163:10;168:16,21; 211:22;212:24; non-fortification (1) 119:6;129:25;130:13;

 83:8;86:5,14,20;92:8; 174:7,14;175:6; 219:23;221:20; 170:14 149:9;158:22;161:22;

 94:5,7,11;97:11; 178:5;179:16,19; 222:19 non-geome (1) 162:3,3,7,8,11,13,16,

 104:5;122:11;124:7; 180:1,15,15;181:21; newer (1) 158:13 17,19,23;163:1,4;

 125:15;126:25;127:4, 183:10;185:1,16; 219:14 non-GMO (1) 166:15,18;167:16;

 8,14;136:19;149:14; 188:5;189:10,24; next (70) 179:21 169:10;192:10;

 155:9;161:8;169:1,7; 190:6,20,23;196:13, 6:2,11,22;8:6;12:1, nonorganic (3) 196:15;207:1,3 

193:20;212:15; 18;197:5,7;199:4,18; 8,22;16:9;18:2,5; 64:14;80:9,14 NOSB's (5)

 222:12 202:10,13;203:1; 26:9;33:20,24;34:5, non-organic (2) 59:2;79:7;86:15;

nationally (1) 210:1;220:14,23,24 18;35:9;36:9,17;38:2; 25:9;210:3 90:20;163:17 

96:25 needed (9) 39:2;43:7,9;48:11,13, nonpartisan (1) note (12)

nationwide (2) 44:25;73:11;76:21; 14;54:22;55:1,2,9; 207:4 6:14;11:16;33:15;

 96:5;209:2 86:17,18;88:14; 58:2;63:22;66:13; nonprofit (6) 38:21;65:1;94:20;

Natural (11) 113:21;149:22; 70:25;71:20,21; 20:1;66:20;137:24; 96:14;97:13;127:14;

 14:6;16:24;19:18; 151:12 78:11,16;81:4;85:12; 213:17;219:21; 132:25;133:16;207:3 

61:4;119:2;160:11; needing (2) 94:17;97:18;103:17, 223:16 noted (4)

 173:21;201:24; 61:12;155:25 19;106:4;109:21; non-synthetic (4) 38:23;39:2;83:7;

 202:12;206:19; needle (2) 114:1;122:6;129:15; 64:11;168:16,22; 96:9 

209:24 17:20,24 135:1,2,3;140:1; 193:14 notes (2)

nature (1) needs (23) 143:15,23;148:25; nontarget (1) 76:15;99:18 

67:24 14:13,15;62:12; 149:4;157:3;159:12; 88:23 notice (1)

navigate (1) 64:20;73:22;75:22; 161:3;172:13;178:12; noodles (1) 137:21 

216:7 78:5;88:3,20;89:11, 184:5;185:15;189:15; 188:13 noticed (2)

near (4) 13,18;117:17,19; 192:4;195:14;198:7; NOP (48) 70:2;172:24 

61:7;100:4;208:19, 132:3;137:1;158:7; 200:21;207:15; 4:23;5:25;6:5; notify (1)

 19 161:12;167:15; 213:13 11:18;14:22;22:21; 59:17 

nearing (1) 206:10;209:22,25; NEXTY (3) 26:17;27:18;32:8; notion (1)

 207:21 223:2 209:3;211:1,3 43:16;44:12,17; 209:14 

nearly (3) negative (1) night (2) 45:12;58:17;59:1,9, nourish (1)

 80:10;129:20; 218:16 71:1;154:20 14,17;60:19;67:12; 104:22 

150:12 negligible (1) nimble (1) 70:7;73:5;80:16,18, novel (1)

necessarily (10) 49:17 70:20 21;85:20;91:17;95:6; 34:23 

40:11;46:13;78:1; neighbor (1) nine (2) 110:6;111:17;112:9; November (2)

 85:22;88:7,10; 180:19 127:7;177:25 118:1;131:1,3; 68:3;122:17 

119:21;158:25;183:1, neighboring (1) nipping (1) 133:11,18;149:9; nowhere (1)

 11 184:17 23:4 151:1;162:3,5,23; 61:7 

necessary (8) neighbors (3) nitrogen (4) 166:16,18,21;210:2,7, NPR (1)

 86:6,14,16,19;87:8; 181:10;191:19; 98:12;104:21; 9;212:7 171:15 

94:2;179:14;211:14 222:6 169:25;170:2 Nope (1) NRCS (1)

necessity (1) nervous (2) nobody (3) 71:24 150:8 

86:8 71:8;152:18 73:17;218:1,2 nor (1) nudge (2)

neck (1) net (2) NOC (13) 99:15 47:16;181:25 

218:24 94:9;122:25 72:22;122:11; North (5) number (22) 

Min-U-Script® Burke Court Reporting & Transcription (26) nation - number 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 1 

October 17, 2023 

4:8;5:22;6:16;21:7;

 29:19;38:7;54:17;

 57:1,2;60:18;63:5;

 64:8;65:20;71:5;

 73:20;76:7;87:9;

 118:4;124:20;149:18;

 217:1;220:9 

numbers (2)

 60:15;82:21 

numerous (2)

 82:15;210:9 

nurturing (1)

 72:13 

nut (1)

 53:18 

nutrient (3)

 82:13;170:16,16 

nutrients (2)

 148:21;171:5 

nutrition (4)

 25:16;114:21,22;

 213:19 

nutritional (1)

 191:17 

nutritionists (1)

 200:5 

70:3;80:3;83:10;

 86:6,7,13,14;91:17,

 19,24;93:16,17;94:3,

 5,11,17,22;95:8,16;

 97:14;112:8;166:10,

 14,23,24;171:25;

 172:1,9 

off (29)

 4:10;5:3;6:8;7:14;

 11:22;15:8;26:25;

 47:25;57:12;61:3,4;

 73:25;76:12;90:19,

 20;101:9,11;140:5,

 10;145:3,11;203:11,

 15;204:3,17,23;

 210:25;216:14;220:6 

offer (6)

 28:14;31:20;68:17;

 82:15;111:25;208:25 

offered (3)

 23:5;124:9;153:25 

offering (1)

 173:20 

offers (1)

 28:24 

Office (7)

 72:18;141:13,24;

 142:4,4,24;213:7 

Officer (2)

once (7)

 8:10;23:11;56:24;

 71:24;134:20;139:14,

 20 

one (102)

 12:24;13:15;19:3,

 14;20:22;22:22,24;

 24:14;32:2;33:2;35:7;

 37:5;38:8;49:5;50:1;

 51:23;53:7;54:16,25;

 55:10,16,17;58:18;

 60:14;64:18;70:2;

 75:3;76:24;78:2;

 84:22;88:20;90:4;

 93:11;101:16;106:3;

 112:5,8;115:4;116:2;

 120:15;124:6;126:10;

 129:4;132:8;133:16;

 135:24;139:11,13,19,

 24;143:8,13,14;

 145:7;147:9;150:1,

 20;151:25;152:8,9;

 154:17,22;155:5,12;

 156:4;159:6;160:12;

 162:15;164:1;166:7,

 22;172:23;176:10;

 177:3,15,17,18,24,24,

 24;178:5;179:15;

 180:1;181:18;182:24;

 123:23;135:25;

 140:16;148:13;

 150:19;177:17;

 179:21;185:25;190:9;

 191:25;196:24;

 213:11;217:19,20;

 220:12,19;222:17 

ons (1)

 105:6 

onsite (2)

 99:21;101:3 

onto (1)

 52:20 

oops (2)

 15:9;89:9 

open (10)

 8:18;40:9,21;41:4;

 68:2;69:10;89:15;

 144:23;204:11;215:1 

opening (1)

 163:16 

opens (1)

 8:5 

operate (1)

 172:17 

operating (5)

 30:15;57:12;94:15;

 173:6,7 

operation (11)

 136:7;137:16;150:3;

 158:22;167:11;172:7,

 20;179:2,23;188:22;

 189:7;192:12;194:11;

 207:12;210:20;221:1 

opposed (1)

 46:22 

opposing (1)

 116:8 

opt (1)

 173:20 

optimistic (1)

 90:18 

option (4)

 27:15;166:12,14,17 

optional (2)

 6:20;58:25 

options (4)

 146:22;166:6;

 187:11;197:18 

oral (9)

 29:18;90:1;95:8,23;

 122:12;123:19,22,24;

 133:16 

orbit (1)

 204:16 

orchard (2)

 82:5;83:1 

orchardists (2)

O 

oats (1) 8:15;125:19 185:10,15;186:3; 24:20;40:22;56:15; 81:24;157:23 

104:3 offices (2) 187:10;188:11; 105:2;172:19;178:18; orchards (3)

obligated (1) 142:9,19 198:12;199:17;200:4; 189:22;192:19; 82:17;83:5;157:23 

27:5 offloading (1) 202:5;204:15;211:22; 214:25;219:13,17 order (10)

obligations (1) 152:4 212:13;214:24; operational (1) 5:9,9;7:17;12:22;

 14:14 offshore (2) 215:22,23;218:25; 173:12 28:17;37:20;84:23,

obsolescence (1) 21:2;22:22 220:4 operations (18) 23;205:4;209:15 

73:6 often (14) one-liners (1) 18:24;24:17;55:19; ordered (2)

obsolete (2) 15:2;27:10;44:18; 116:13 56:11,21,25;57:3; 37:22,22 

76:13;91:22 66:23;82:11;86:23; ones (11) 95:1;128:15,19,19; orders (1)

obtained (1) 110:15;140:16; 19:22;25:20;49:3; 135:8;150:21;163:18; 74:9 

49:23 150:14,19;154:16; 61:4;63:8;69:19; 181:20;197:7;221:17; Oregon (4)

Obu (1) 167:9;190:1;210:11 79:18;118:16;126:17; 222:18 50:3,7,18;53:19 

9:3 OID (7) 160:15;222:18 operators (1) Organic (546)

obvious (2) 42:3,8,17,24,25; one's (1) 44:18 4:6;7:17,21,22;

 49:19;135:24 55:18,24 50:13 opinion (8) 8:13;14:5,19,19;

Obviously (4) oil (1) one-size-fits-all (1) 61:12,14;86:9;87:9; 15:10,10;16:13,15;

 17:21;24:14;160:6; 130:10 97:4 97:10;171:13,19; 17:2,3,5,8,16,19,25;

 214:19 Okie (1) one-stop-shop (1) 209:22 18:10,23;19:21;

occur (1) 71:25 158:3 opinions (2) 20:21;21:1,10,21;

 118:10 old (6) on-farm (4) 85:22;121:8 22:24;24:11,13;25:6,

O'Connor (17) 25:2;48:19;50:16; 81:25;82:10;98:17; opportunities (13) 8,13,17,22;26:20;

 157:4;161:4; 146:4;148:10;208:19 99:19 28:13;36:7,14;38:8; 27:22,25;28:2,4,10,

 165:20;172:13,16,17, Olympia (2) ongoing (1) 67:25;69:15;135:16; 12,18,20,20,21,23,24;

 17;174:11,13;175:7, 50:22,22 143:12 188:15,19,21;222:18, 30:11,12,12,19,24;

 17;176:14,16;177:1,6, OMDG (1) online (5) 22;224:14 33:3,4,5;34:2,2,10,24;

 24;178:11 28:2 95:14;209:2;215:2; opportunity (39) 35:5,6,8,16,22;36:12,

October (1) Omega-3s (1) 216:2;224:18 26:18;29:3;35:6; 15,25;37:19;39:10;

 225:5 190:5 only (32) 37:5;43:17;52:25; 41:17;42:9;43:17,21,

oddest (1) OMRI (7) 4:13;6:23;13:1; 68:17;85:21;95:13, 25;44:11,20;45:10,

 154:13 60:24;165:24,25; 36:2;55:20;77:17; 18;97:13;98:3;104:7; 12;46:14;47:9;48:20;

O'Donnell (2) 166:1,5,21;169:14 79:6;82:10;98:3; 107:3;124:10;125:3, 49:3,4,11,14,17;50:1,

 184:6;189:16 onboarding (2) 99:25;105:12,14; 11,24;127:3;129:18; 3,7;51:25;52:4,21;

OFA (28) 125:14,20 116:4;121:1,9; 131:15;135:19,21; 53:9,20;54:24;56:1, 

Min-U-Script® Burke Court Reporting & Transcription (27) numbers - Organic 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 1 

October 17, 2023 

15,20;57:14;58:16,19,

 25;59:10,14,16,21;

 64:9,17,17,20;65:13,

 17,22;66:21,21;67:14,

 15,19,21,22;72:14,17;

 73:20;74:8,10,19;

 75:8;77:6,18;79:4,7,

 11,14,18;80:6,11,11,

 12,13,22;81:16,22;

 82:3,7,10;83:4,15,18;

 86:2,6,12;87:7;89:8;

 93:14,19;94:4,6,7,9,

 10,11,12,14,19,21;

 96:2,6,12,14;98:5,6,

 20,23;101:1;102:2,

 16;103:9;104:3,5,19;

 105:1,3,4,5,9,11,12,

 17,18,23;106:1,4,24;

 107:5,5,25;108:14,16,

 19,19;109:15;110:9,

 12,14,16,19,21;111:3,

 4,9,19,22;112:1,1,3,9,

 11,13,14;114:6,21;

 189:20,25;190:2,5,5,

 6,8,10,15,15,17,19,21,

 24;191:12,13,15,15,

 16;192:16,18,21;

 193:4,10,17;194:2,5;

 195:21,22,24;196:2,5,

 6,7,9,12,17,19,22;

 197:1,5,8,21,22;

 198:6,11,12,15;

 199:18;200:7;201:2,

 6,9,13,14,16,16,25;

 202:1,11,13;203:10,

 13,14,18;204:3,6,10,

 13;205:1;206:11,25;

 208:20,22;209:4,11,

 13,18,20,23;210:1,11,

 19;211:2,3,7,9,9,10,

 11,21,24;212:11,15;

 217:18;218:6,7,7,24,

 25;219:18,20;220:3,

 10,17,20,22;221:22,

 24,25;222:15,16,17,

 20,22,25,25;223:2,5,

origin (3)

 94:13;113:5;224:3 

original (2)

 52:16;54:20 

originally (1)

 221:20 

OSG (1)

 28:16 

OSV (2)

 32:25;33:1 

OTA (5)

 130:2,16;137:10;

 139:14;143:7 

OTA's (3)

 129:22;139:22;

 148:18 

others (5)

 14:15;34:20;52:19;

 72:24;94:20 

otherwise (3)

 90:25;115:14;151:7 

OTI (2)

 28:15;150:2 

outcome-based (2)

 44:3;47:15 

outcomes (1)

 45:3 

outdated (1)

 133:19 

outdoors (2)

 19:16;26:5 

outlawed (2)

 144:21;145:12 

outlets (3)

 106:17,20;209:2 

outlines (3)

 44:23;57:21;133:11 

output (1)

 143:14 

outreach (5)

 138:2,3,5,14;139:5 

outright (1)

 202:17 

outside (6)

 15:1;32:12;140:15;

 178:18;214:19,20 

overstated (1)

 83:13 

overwhelmed (1)

 89:2 

overwhelming (1)

 157:25 

own (14)

 5:10;14:13;20:5;

 21:16,18;49:12,12;

 85:22;118:13;173:11;

 183:12;185:6;188:21;

 221:16 

owned (1)

 21:7 

owner (2)

 144:10;178:16 

owners (1)

 208:18 

oxygen (2)

 118:13,18 

P 

115:7;116:10,13,14; 5,12,13,14,15,17,19, ought (4) outstanding (2) pace (1)

 117:1,1,7,8;118:1,20; 23,25;224:5,13 42:24;43:1;52:22; 95:3;157:13 127:1 

119:1,3,7;120:9,10, organically (6) 75:24 outweighed (1) Pacific (5)

 18,18,21,21;121:2; 51:8;102:15; ours (2) 32:18 81:15,18;82:12;

 122:11,14,20,24; 119:17;147:20; 40:25;213:18 outweighs (2) 98:1;101:12 

123:4,8,12,13,14,15; 157:19;194:8 ourselves (5) 87:13;134:21 packaging (1)

 124:2,3,5,7,16;125:9, OrganicEye (2) 21:20;89:2;115:1; OV (1) 213:19 

12,15;126:7,25;127:4, 18:10;19:4 116:10;117:21 26:21 packers (1)

 9,15;128:7,12,23; Organics (23) out (100) over (39) 81:14 

129:19,20,23;130:9; 8:25;12:3;19:1; 16:18,23;17:5,12, 4:11;5:16;7:15; packs (1)

 131:8,9,13;135:8,15, 20:16;26:1;27:24; 13;18:22;21:14;23:8, 27:7;28:19;35:16; 99:13 

20,21;136:7,11,14,19; 39:7;110:25;117:13; 24;25:2,7;37:23; 37:11;45:21;49:14; page (1)

 137:5,16,24;138:11, 157:21;158:10;159:1, 42:25;43:2;44:13; 52:16;53:20;59:3,21; 8:9 

21;139:5;141:12; 22;162:24;173:19; 45:10;46:16;47:12; 82:5;84:7;90:7; paid (4)

 142:3,5,10,13,19; 175:6;178:17;179:13; 48:21,22;51:6,16; 104:15;111:14;112:4; 28:21;172:25;

 143:1;144:12,13,16, 185:9;189:1,6; 52:14;53:17,18;57:6, 116:14;117:22; 174:2;222:4 

18,19,22,25;145:4,8, 192:17;196:14 21;60:14,20;69:8; 120:19;131:16;142:5; pain (1)

 10,16,20,20,23,23,24; Organics' (1) 70:18;73:16;74:6; 152:19;155:17; 218:24 

146:1,5,8,9,18,20; 162:20 79:12;83:1;84:17; 192:13,15;195:4; pains (1)

 147:5,8,11,12,18; organisms (1) 85:1;89:9,20;90:11; 197:24;202:14; 118:19 

148:3,7,14,15,20; 88:23 91:10;92:2;99:1,2,7, 206:21;211:15,16,16; Palm (2)

 149:8,10,15,24; organization (10) 8;100:9;101:18; 213:25;220:1,3;222:1 11:23;81:16 

150:16;151:7,7,8,10; 29:15;46:4;69:2,9; 102:24;104:10; overall (2) paperwork (6)

 152:11;155:8,9; 84:14;97:9;104:10; 112:10;114:20,24,24; 79:19;149:22 23:13,25;136:8,16;

 156:11;157:11,15,16, 129:20;213:16,17 116:8;118:16;127:24; overcome (1) 150:14;157:25 

24;158:3,8,12,14,17; organizational (1) 129:1;131:1;132:18; 150:25 parallel (1)

 159:8,10;160:5; 67:24 137:12;138:16,20; overcoming (3) 61:19 

161:8,11,14;163:4; organizations (20) 141:14;143:14;146:3, 9:12;139:8;153:10 parameters (1)

 164:2,8,14;168:15,19; 14:6;19:24;20:1; 5;147:14;148:20; overhead (1) 134:3 

172:20,21;173:4,11, 71:5;85:23;124:8; 150:3;151:12;153:24; 101:14 parents (1)

 13,19,22,24;174:4,6, 125:4,9,12;138:12,13, 156:25;160:25; overly (1) 104:16 

8,15,16,17,18;175:4, 19;150:6;155:14,19, 163:25;167:8;168:24; 90:17 parked (1)

 21,22;176:11,13,17, 20,22,24;163:13; 174:1;175:12;177:25; overnight (1) 203:5 

19,21;177:3,12,17,22; 175:2 178:9;180:13;183:16; 206:9 part (40)

 178:19,22,22;179:2,8, organization's (1) 184:20;188:3,11,22, overseas (1) 4:24;8:3;15:4,6;

 9,12,15,16,19,20,21, 84:9 25;190:13;195:5; 188:17 31:5;32:25;33:1;40:4;

 23;180:1,3,16,21; organized (1) 196:24;199:6;200:17; oversight (9) 46:11;59:6;67:11;

 181:20,21,23;182:1; 155:13 202:23;203:4;208:11; 19:25;43:23;51:9; 69:16,17;75:16,19;

 183:3;184:12,17,23, oriented (2) 211:22;221:5;223:1; 57:18;59:3;79:8; 77:20;83:14;87:4;

 23;185:24;188:23; 15:11;16:15 224:13 126:11,15,19 96:17;124:7;125:6, 

Min-U-Script® Burke Court Reporting & Transcription (28) organically - part 

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NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 1 

October 17, 2023 

13,20;127:6;129:8; 140:23;165:2;169:5; 177:11;179:3;180:6; Persons (1) 164:23 

131:10;132:19; 204:16;220:2 181:2,8,25;182:11,12, 12:13 Phil (10)

 140:20;143:11;150:7; pasture (3) 17;183:11,17,19; perspective (9) 129:16;135:3;

 153:13;154:6;155:17; 94:13;158:15;210:3 188:18;191:18; 16:2;24:21;28:1; 143:23,25;144:2,7;

 158:17;159:20;162:7, pastured (2) 197:24;198:1,8,12,15; 30:16;31:7;81:19; 146:14;147:24;148:1;

 16;203:12;209:6; 25:8,12 204:8;205:25;206:11, 111:9;146:18;209:13 149:2 

215:21 pastures (1) 23;212:3;214:19,19; perspectives (3) Philadelphia (1)

partial (1) 195:21 215:11,13,13;222:3 31:8;181:25;182:19 209:5 

166:10 path (5) people's (2) pertaining (1) philosophy (1)

Participant (3) 57:7;79:15,20; 16:7;212:14 209:13 221:25 

6:10,23;124:6 100:3;122:16 per (5) pertains (2) phone (8)

participants (3) pathogen (1) 19:14;20:2;73:10; 64:23;100:17 4:14;6:15,16,23,24;

 4:8;6:14;41:7 82:17 117:25;203:15 Peru (1) 93:12;95:24;103:21 

participate (3) pathogens (2) perceived (2) 15:4 phosphoric (2)

 7:25;22:2;124:8 82:9;194:1 150:13;151:7 pest (2) 64:13;98:12 

participating (4) patience (1) percent (13) 82:8;92:11 photosynthesis (1)

 45:18;95:23; 16:7 25:10,11;38:11; pesticidal (1) 99:25 

112:23;125:5 patterns (2) 50:2,7;53:20;65:17, 45:2 Physical (1)

participation (1) 77:23,24 18;82:21;101:5; pesticide (16) 118:8 

128:8 Paul (8) 114:8;169:12;173:2 44:17,18;45:2;59:7, pick (1)

particles (1) 208:11;216:20; percentage (1) 9;86:4,17;88:15; 51:23 

99:23 219:8,16;221:10,12, 79:19 92:13;93:21;169:22; picked (1)

particular (8) 19;224:7 percentages (1) 171:4;185:22;186:20; 155:19 

81:22;97:7;110:20; Paw (1) 88:17 187:7;189:3 Picking (1)

 122:20;130:8;145:3; 214:1 perception (1) pesticides (22) 90:2 

175:14;214:25 pay (8) 49:2 45:3;47:21;58:12; picture (2)

particularly (6) 49:6;104:25; perennial (1) 61:2;62:1;78:23,25; 46:11;84:24 

36:1;52:1;61:18; 111:19;147:7;148:16; 208:22 86:1,12;87:12;91:20, pie (1)

 91:5;121:9;139:10 158:19;188:15; Perfect (7) 25;92:4;104:24; 35:20 

partisan (1) 217:11 71:19;97:16; 105:13;167:20,22; piece (3)

 206:5 paying (2) 107:12;113:22; 168:24;169:23; 53:10;191:12;

partner (7) 104:11;147:11 152:13;154:21;207:8 178:24;179:22; 223:23 

67:19;138:17; PCO (2) perform (1) 181:12 pieces (2)

 148:5;155:8,14,14; 60:24;168:13 133:12 pesticide's (1) 46:8;151:12 

163:12 Pearls (1) performance (2) 63:2 pin (1)

partnering (1) 207:23 217:25;218:11 pests (3) 7:9 

67:14 pears (1) performative (1) 82:5,17;83:1 pineapple (2)

partners (7) 81:14 131:12 petition (11) 193:4,6 

123:10,10;136:2; peas (1) perhaps (4) 22:10;23:5;37:3; pineapples (1)

 137:10;155:13,20; 189:20 16:17;41:5;90:17; 40:9,10,17;73:2;84:9; 193:7 

164:19 pending (1) 113:2 89:1;169:7,9 place (14)

Partnership (4) 80:21 period (7) petitioned (3) 17:15;39:12;

 122:14;124:5; penetrate (1) 12:13;99:7;122:15; 84:13;167:2;170:21 115:16;132:17;

 135:20;220:8 140:17 144:22;148:15;201:7; petitions (3) 133:10;134:23;137:2;

partnerships (3) penetration (2) 202:15 22:19;41:1;89:2 138:22;141:19;169:6,

 72:16;75:17;155:6 82:13;101:22 Periodic (2) Petrey (23) 16;185:3;205:3;

parts (1) pennies (1) 44:20;70:5 11:1,2;20:9;41:13, 224:20 

117:23 147:12 permitted (3) 21,23;42:1,4,13,20; placed (1)

pass (2) people (77) 12:15;64:8;65:21 100:16;102:3;119:11, 106:3 

49:10;141:17 5:8;6:17;7:25; persistence (1) 13,25;137:20;138:24; places (6)

passed (2) 14:23;15:11;16:4; 86:25 197:13;198:3,5,19; 16:16;113:5;

 145:22;200:22 17:10;23:8,12;24:1; person (16) 199:10,14 141:23;142:12,21;

passes (1) 26:3;29:19;37:23; 8:6;12:2,22;29:5; petrochemical (1) 164:5 

27:16 38:10;50:16;53:6; 95:10,16;104:12; 80:5 plain (2)

passing (1) 71:9;89:2;90:12; 122:12;123:19,22,24; PFOS (2) 27:6;136:3 

170:14 96:24;104:12;108:3; 139:24;140:7;154:17; 94:24;95:5 plan (9)

passion (1) 117:22;128:22;129:1; 158:7;199:11 ph (8) 8:7;20:6;43:25;

 209:6 136:6,9,23;137:2; personal (6) 81:9;82:12;99:21; 80:1;150:16;151:7;

passionate (1) 138:8;139:7,16,17,23; 5:5,11;8:20;12:17; 100:19;101:18,21; 159:17;167:20;

 211:15 140:5,6;142:22; 14:24;35:20 102:21,25 215:18 

past (12) 150:19;153:1,4,8; personally (4) pharmaceutical (1) plane (3)

 22:10;87:14;89:1; 155:11;156:3;158:1, 61:25;147:13; 210:5 192:1;200:18;203:3 

94:5;96:14;136:6,10; 16;159:18;161:16; 164:18;165:5 phase (1) planet (3) 

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NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 1 

October 17, 2023 

14:10;159:18; ploy (1) 8:22;59:22;79:24; 13;50:10;51:19; practicality (1)

 161:17 209:15 111:12;112:10; 52:23;54:4;55:14; 171:22 

planned (1) plug-and-chug (1) 151:19;194:25 57:25;60:8;61:10; practice (9)

 68:15 97:4 positioning (1) 62:19;63:16,19;64:1; 13:8;32:9,22;72:9;

plans (4) plugged (1) 192:25 66:6,10,13,16;68:20; 94:2;95:14;134:17,

 131:5,14,17;202:6 199:5 positions (1) 69:23;70:24;71:11, 19;158:5 

plant (12) plum (1) 116:8 14,19,25;73:21,24; practices (20)

 96:2,3,6,25;111:5; 147:16 positive (8) 74:3;75:1;76:16;78:9, 17:13;27:18;68:24;

 170:7,16;171:5; pm (2) 36:8;42:23;44:17; 12,15;81:1,4,10; 83:10;94:21;102:12;

 173:6,7;193:3;194:1 4:2;225:4 47:23;130:17,25; 83:22;85:11,14; 106:19;107:21;108:9;

plantation (2) PN (1) 134:23;182:19 87:18;89:23;91:2; 114:9;128:23;130:19;

 15:3;16:10 221:18 possibilities (1) 92:21;93:7,9;95:20; 161:24;179:20;

planting (3) point (25) 36:11 97:17,22;100:11,14; 182:21;196:3;212:8,

 96:8,12,15 21:23;45:9;47:14; possible (12) 102:5;103:15,19,24; 9,13;222:16 

Plastic (4) 53:22;54:23;68:18; 29:2;34:10;93:25; 106:6;107:13;108:25; praises (1)

 82:14;83:7;98:15; 72:22;95:12;99:1,7; 102:16;117:24; 109:3,6,16,20,24; 105:17 

192:25 107:4,20;113:5; 118:24;128:9;179:5; 110:4;112:19;113:24; Pratum (1)

plastics (2) 117:22;121:23; 183:4;206:20;222:17; 114:1,17;115:19,23; 48:19 

80:5;192:25 124:18;130:11,14; 224:2 116:12,17,23;119:8; precarious (1)

platform (4) 146:23;167:5,8; possibly (4) 120:2;121:7;122:1,4; 111:11 

104:9;191:24; 173:9;187:2;223:1,11 17:18;20:10;53:16; 124:13;126:2;128:3; precedent (1)

 202:25;214:23 points (7) 125:18 129:11,13;131:19,23; 37:12 

plausible (1) 49:18;93:20;113:4; post-award (1) 132:22;134:6,9,24; precedents (2)

 76:6 114:10;130:3;152:8,8 213:12 135:2;137:17;139:1; 34:19;87:11 

play (5) policies (3) posted (3) 140:1;141:5,7; precisely (1)

 46:19;60:19;65:9; 65:1;156:20;161:24 5:25;8:9,10 142:17,25;143:20; 203:16 

171:4,23 policy (16) poster (3) 144:5;146:10;147:24; premise (2)

playing (4) 8:2,14;12:10,10; 106:4;159:12,13 148:1,23;149:1,4; 207:4;215:18 

94:16;104:9; 16:4;20:4;72:14,17; post-harvest (1) 151:15;152:15; premises (1)

 130:21;174:18 85:24;110:7,9;111:8, 193:8 153:14;154:25;155:2; 43:24 

please (81) 25;113:15;135:17; posting (1) 156:8,23,25;157:8; premium (20)

 5:6;6:2,3,19;7:7; 166:3 42:7 158:23;159:6,23; 28:21,24;49:11,12,

 8:22;12:23;13:10; political (1) pot (1) 160:23;161:3;163:20; 14,21;50:2;53:8,20;

 14:22;15:25;18:7; 206:7 204:13 165:7,14;167:25; 104:25;147:7,19,20;

 20:8;21:24;24:8;30:9; politically (1) potassium (9) 169:2;171:10;172:10, 148:7;172:22;177:22;

 34:5,18;35:9;36:9; 224:1 64:12,23,24;65:9; 13;174:10,12,19; 211:12;222:8,23;

 38:24;43:13;47:2; polled (1) 84:10,12;169:8; 175:8;176:8,15,25; 223:19 

48:16;52:23;54:4; 19:14 194:19,20 177:5,19;178:7,12; premiums (1)

 58:4;61:10;62:21; poor (4) potential (7) 180:7,12;181:14; 172:25 

68:22;69:23;72:5; 102:12,14,24,25 39:3;67:3;128:6; 182:5,8,24;183:10,22, prepare (2)

 76:16;78:19;80:24; pop (2) 155:14,19;187:9; 25;184:5;186:5,10, 12:23;137:5 

86:3;87:14,20;89:23; 6:5;23:21 200:9 12;187:16;189:8,15; preponderance (1)

 91:2;93:1,7;95:15; popular (1) potentially (2) 191:1,9,20,23;192:3; 20:2 

98:8;99:17;100:15; 145:4 37:7;58:21 194:12;195:9,11,14, presence (2)

 102:5;103:21;106:10; population (2) poultry (3) 18;197:11;199:17; 130:17;131:1 

107:13;110:2;112:21; 199:2,8 24:16;110:20;123:5 200:12,21;202:20,22; Present (9)

 115:21;116:23;120:2; pork (10) pour (1) 203:3,7,23;205:8,10, 9:11;10:21,24;

 121:7;122:8;124:13; 24:11,13,15,20; 105:6 16,22;207:13,20; 12:19;44:11;98:4;

 126:2;128:3;132:22; 25:2,8,12;26:3; powdery (1) 208:2,6,8,10;210:21, 149:21;194:11;219:2 

135:5;139:1;143:2, 110:21,23 85:5 25;211:6;212:18; presentation (2)

 17,25;152:15;161:6; port (2) Powell- (1) 214:12;216:19;219:4; 162:20,25 

163:21;168:1;169:2; 152:3;195:1 11:22 221:2,9;223:8;224:7; presentations (2)

 174:21;177:22;184:7; portion (2) Powell-Palm (239) 225:2 11:20;165:14 

186:17;189:18; 51:7;77:18 8:16;9:10,11,15; power (4) presented (3)

 195:18;203:25; Portland (1) 11:24;13:6,10,12,15, 42:24;43:1;179:11; 63:8;72:25;90:3 

205:20;208:13; 38:4 20,22;14:7;15:22,23; 196:25 presents (2)

 216:22;221:12 portraying (1) 16:19,22;17:17;18:2; PowerPoint (1) 130:11;132:14 

pleased (1) 19:25 20:7;21:24;24:7;26:8, 11:20 preservatives (1)

 87:24 pose (3) 14;29:7;30:9;31:24; PPM (4) 144:24 

plot (1) 27:6;59:4;122:19 32:2,6,11;33:2,10,12, 121:10,19;124:22; president (4)

 55:1 posed (1) 17,20;35:10;36:19; 162:15 135:7;192:7;222:7,

plots (2) 65:11 38:24;41:12;43:3,6,9, practical (2) 10 

54:22;55:9 position (7) 13;45:15;47:2;48:3,9, 51:15;172:5 pressure (1) 

Min-U-Script® Burke Court Reporting & Transcription (30) planned - pressure 

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NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 1 

October 17, 2023 

66:23 proactive (1) 49:10;56:16;151:4 22;145:12;147:4; 150:7;155:8,10;

pre-TOPP (1) 95:6 processor's (1) 148:11;150:14;167:3, 156:5,7;222:9 

150:7 proactively (1) 50:1 4;168:15,20;184:22; projected (1)

pretty (17) 66:24 produce (15) 191:16;192:15;193:4; 4:16 

15:5;34:2;35:12; probably (18) 19:9;21:20;37:21, 194:3;197:1;200:7; projecting (1)

 51:17;68:25;84:22; 6:5;24:17,18,21; 23;81:15;111:3; 203:19;219:20; 11:21 

102:1;110:22;113:18; 53:1;62:24;101:8; 117:15;129:2;130:21; 222:16 projects (4)

 144:14;168:5;176:4, 113:16;121:24;126:9; 179:4;183:18;184:17; products (41) 124:7;155:6;156:4;

 4;178:20;182:15; 157:16,21;158:16; 192:9,14;193:22 21:19;30:17;39:7,8; 224:1 

208:8,14 171:23;173:4;185:17; produced (8) 53:5;58:19,24;59:7, promise (1)

prevent (1) 198:24;202:23 21:2;25:18,19; 16,18;60:18,23;61:2; 16:22 

193:25 problem (15) 37:20;51:8,8;63:5; 65:13;83:18;87:2; promote (13)

prevention (2) 15:1;25:5;30:1; 145:23 90:2;98:16;107:11; 24:12;82:23;

 94:18;131:14 57:8;62:6,16;73:19; producer (12) 110:19;160:5;168:9; 129:22;148:13,22;

previous (6) 77:10;95:6;96:9; 21:3;51:10;146:19; 169:5;173:1,22; 178:2;190:19;200:5;

 47:19;99:20; 102:17;105:8;128:25; 178:19;196:6;199:24; 176:17,17,22;188:10, 203:13;206:16,18,22;

 119:13;131:20;162:6; 153:5;185:23 201:3;203:10;204:10; 11,17;190:10;193:6, 209:23 

164:25 problematic (4) 213:8;217:9;222:14 12,18,21,24;205:13; promotes (1)

previously (4) 44:11;74:13,18; producers (33) 209:21;210:18; 212:11 

26:20;59:25;73:17, 80:18 30:24;34:10;51:25; 214:24 promoting (1)

 18 problems (3) 52:2,3,10;106:14; professional (2) 219:24 

price (11) 5:21;57:22;115:8 120:6;126:7;128:7; 23:23;184:11 promotion (4)

 21:11;49:18;53:8; procedure (1) 129:2;136:15;146:22; professionals (1) 206:2;207:8;220:7,

 107:20;108:10,18; 20:5 150:21;151:5,10; 67:22 15 

117:22;145:16; Procedures (5) 152:23;155:21; profiles (1) prompted (1)

 147:22;174:5;209:15 8:14;12:11;130:25; 192:21;193:24;196:7; 86:22 44:5 

prices (9) 133:3,6 197:3,21;198:18; profit (3) promptly (1)

 28:21;49:4,7,15; proceed (2) 199:2;203:15;204:6, 49:13;107:1;147:23 75:6 

50:6;53:21;147:17; 86:10;89:20 6;222:19;223:5,12,15, profitable (1) pronounced (1)

 173:8;186:21 proceeding (1) 25 178:25 81:9 

pricing (4) 44:6 produces (1) Program (54) proper (2)

 49:24;57:8;173:20, process (58) 26:2 7:17,21;8:25;44:24; 141:14;205:3 

20 8:2,4,19;21:22; producing (4) 47:19;48:2;57:12,19; properties (1)

pride (2) 22:2;27:17;35:3; 105:15;111:21; 72:14;73:9;74:8,12; 64:19 

117:21;206:16 40:17,18;44:4;45:18; 145:24,25 75:17;76:9;77:17,22, proposal (4)

primarily (1) 47:9,12;52:1;55:6; product (42) 22,25;94:9,11;122:14, 26:25;27:16;47:14;

 219:21 57:22;75:10,20;76:3; 20:20;25:4,16,24; 21,24;123:7;124:5; 163:17 

principle (1) 79:10,11;80:19,21; 30:17;53:9;88:4,7; 125:10;126:25;127:1, propose (1)

 44:4 88:24;89:1,14,15; 99:25;100:21;105:8; 4,9,15;128:7,21,25; 59:19 

principles (4) 90:8;92:2;94:19; 119:18;144:12; 129:4,5,7;130:20; proposed (5)

 64:17;146:1; 95:23;99:15;103:11; 147:12;169:9,10,11, 131:16;135:20;137:6; 59:23;65:2,6;86:11;

 206:17,25 112:24;117:18; 12,15;170:7;171:1,4; 139:17,22;148:5; 131:8 

prior (3) 118:13,15,20;125:14, 174:5;175:20,22; 150:2;158:17;185:3; proprietary (1)

 44:6;45:24;152:4 20;130:1;135:17; 176:19,23;177:15; 201:18,18,22;202:8; 72:21 

priorities (5) 136:8,24;137:3; 178:1,3,5;181:1,2,3, 212:15;220:6,8 prospective (2)

 123:12,15;126:10, 138:21;139:20,25; 11;187:7;189:4; programs (12) 68:9;202:10 

14,22 141:17;156:9;163:23; 193:16;194:22;209:4; 67:7;77:5;138:3,5; protect (6)

prioritizing (1) 165:17;186:1;192:11; 212:23,24 161:24;163:7,9,12; 93:25;99:2;124:15;

 90:7 212:23,25;213:10; production (68) 193:22;204:5;210:17; 129:22;131:9;150:15 

priority (4) 216:12 17:20;20:12;22:25; 220:16 protecting (1)

 28:2;62:3,7;126:16 processed (2) 23:12;24:11;25:6,14; progress (5) 130:9 

privacy (2) 177:16;209:1 34:23;35:8;41:18; 51:13;164:4,12; protection (4)

 27:9,19 processes (5) 44:3;46:12,17;58:16, 174:3;208:18 79:13;83:2;91:23;

private (3) 53:19;150:1;151:4; 25;59:14,17,21; prohibit (1) 127:11 

16:25;113:12;148:5 162:12,16 65:22;75:23;79:5,19; 83:8 protein (1)

privilege (1) processing (11) 82:8,15;83:15,19; prohibited (6) 46:15 

12:4 33:8;39:9;92:14; 86:2,6,12;87:7;95:2; 130:6;136:21; protocol (1)

privy (1) 107:17;146:2;173:14; 96:18;98:20,24; 169:19,25;170:16; 73:12 

41:20 188:1;189:11;213:19; 99:20;100:7;101:1; 212:5 protocols (3)

prize (1) 220:11;222:8 102:2;103:9,10; prohibition (1) 76:21;78:4;130:6 

223:3 processor (2) 105:16;108:20; 171:17 proud (2)

pro (2) 49:16;80:13 110:16,25;111:4,15; project (9) 178:20;220:11 

29:25;72:12 processors (3) 115:11;118:7;144:21, 59:1;67:19,21; proudly (1) 

Min-U-Script® Burke Court Reporting & Transcription (31) pre-TOPP - proudly 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 1 

October 17, 2023 

104:3 

prove (1)

 86:7 

proven (2)

 82:20;167:13 

provide (18)

 8:22;26:18;27:5;

 28:15;30:21;31:20;

 32:8;67:21;68:25;

 69:14;71:7;84:20,24;

 131:4;140:4;192:12;

 193:10;194:4 

provided (8)

 34:23;45:19,23;

 67:10;84:11;95:3;

 98:10;112:24 

Providence (2)

 8:7;70:25 

provides (6)

 34:21;104:9;

 111:20,22;166:21;

 167:20 

providing (8)

 12:16;27:3;29:4;

 178:17;185:13,14,

 15 

pulses (1)

 187:25 

purchasing (1)

 52:4 

pure (1)

 101:5 

Purple (1)

 184:19 

purpose (4)

 86:4;88:19;92:19;

 170:20 

purposes (1)

 118:4 

pursue (2)

 107:3;177:14 

pursued (1)

 74:18 

pursuit (2)

 67:6,20 

push (6)

 14:20;29:24;35:5;

 39:4;135:15;164:9 

11:4,5;54:5;128:4;

 140:2,4 

quick (17)

 16:19;22:13;24:9,

 11;31:24;32:1,2;

 41:13;50:13;55:16;

 72:15;114:3;143:2;

 159:6;175:8;176:8;

 182:7 

Quickly (2)

 70:24;149:13 

Quinn (1)

 195:15 

Quite (7)

 25:7;56:24;99:10;

 103:2;120:19;153:22;

 173:13 

quote (1)

 21:18 

quoted (1)

 217:21 

ranches (2)

 198:25,25 

ranching (2)

 172:19;221:22 

random (3)

 14:18;23:18;59:8 

range (7)

 90:4;93:18;146:1;

 149:18;168:18;

 181:24;213:19 

rant (1)

 202:8 

Raphael (2)

 103:20,21 

rapid (3)

 113:8,12,15 

rapidly (1)

 113:18 

rare (1)

 25:11 

rates (5)

 98:23;99:12,15;

 119:4;161:21 

rather (8)

 34:12;39:24;40:15;

 42:10;46:6;48:4;55:7;

 57:6,25;60:11,13,16;

 61:9;62:23,25;66:10;

 69:13,14,16;73:7;

 74:18,18;75:5,18,18;

 76:11;83:14;89:4,12;

 90:9;100:2;101:3,16;

 102:24;104:12;107:2,

 25;109:17;113:4;

 114:22;115:17;116:1;

 119:20;120:6;121:16;

 124:16;125:11,23,25;

 129:6;137:18;139:3;

 143:21;146:14,16;

 147:9;151:24;152:9,

 17,22;153:4,11;154:3,

 8,16,18;155:12,22,24;

 156:2,3,20;159:2,14,

 20;160:15,18,25;

 164:4;168:3;169:4;

 172:10;175:14,17;

 178:4,4,9;180:7,22,

 25;181:8,9,12;182:15,

R 

86:24;126:6;150:24; pushes (1) R&D (2) 26:1;37:10;51:8; 18;186:2,19;187:10,

 151:18;152:19 147:15 34:22,22 97:4;181:1;200:17; 20;188:24;189:8;

provinces (1) pushing (4) racial (14) 206:19;223:1 191:2,5,21,24;194:13;

 55:12 29:19;33:14; 67:20;68:2;122:13; reach (6) 195:11;197:5;200:14;

proving (2) 144:13;147:10 124:9,19,20;161:12; 52:10;137:12; 202:7,22;204:21;

 94:21;108:16 put (26) 162:1,7,9,12,16,17; 138:14;141:4;158:10; 205:3,7;206:1,10;

provision (1) 15:14;17:2;39:12; 163:1 214:18 207:18;214:2,4;

 122:23 71:16;83:18;86:19, racism (1) reached (1) 215:15;219:4;220:12,

provisions (1) 19;88:5;91:14; 162:20 79:25 18;221:5,6,6,9,23;

 123:11 109:11;134:9;139:14; Rafael (2) reaching (2) 222:14,20;224:11,21 

Proxy (1) 140:9;141:9;142:19; 97:19;109:21 49:17;135:22 realm (2)

 12:15 143:14;144:8;156:10; raise (11) read (7) 70:10;121:18 

prudent (1) 168:14,24;204:2; 5:6,7;104:3;105:5; 4:14,15;57:21; rearend (1)

 40:4 205:3,6;209:22; 172:21;181:23; 79:24;99:18;154:2; 217:20 

public (26) 211:8;217:10 189:19;195:20;196:4; 208:16 rearrange (1)

 4:24,24;8:1,4,5; puts (1) 201:6;208:21 readily (1) 5:11 

12:11,15,16,18;28:12; 140:5 raised (3) 41:3 reason (10)

 32:12;49:6;56:10; putting (6) 99:19;210:2,6 reading (1) 21:5;37:14;39:24;

 65:6;86:10;87:6,11, 31:10;103:1; raises (2) 71:4 50:9;91:15;112:5;

 12;95:9;104:13; 138:16;147:17; 25:8;172:8 ready (2) 175:17;181:21;202:4;

 111:16;130:1;150:1; 179:25;201:22 raisin (4) 48:22;173:21 204:22 

163:2;174:14;202:9 puzzle (2) 148:10,11;158:20; real (9) reasonably (1)

publication (1) 31:6;223:23 204:7 37:4;59:12;72:15; 107:18 

59:20 raising (5) 114:2;143:2;182:7; reasons (4)

publicly (1) Q 52:7;108:14; 209:10,17;218:11 91:14;128:24;

 27:11 196:20,21;211:9 realistic (1) 175:15;207:9 

public's (1) qualifying (1) ramping (1) 75:20 rebrand (1)

 49:2 93:23 23:18 realize (4) 50:18 

publish (1) qualities (1) ran (1) 155:25;171:18; rebuilding (3)

 59:15 197:1 73:16 181:7;221:2 16:14;164:25;165:1 

published (1) quality (9) Ranch (7) realized (2) recall (2)

 65:8 25:16;26:3;91:23; 106:23;173:12; 145:5,6 152:17;202:3 

publishes (1) 118:12,23;119:5; 177:15,16;208:19,20; really (155) receive (3)

 167:9 166:1,2;196:9 211:10 12:1;15:15;16:10; 49:3;99:13;220:20 

pull (1) quantities (2) rancher (2) 17:4,13,16,16;18:25; received (1)

 145:11 160:20;194:6 190:11;221:21 19:23;22:6;23:18,24; 162:22 

pulled (2) quantity (1) ranchers (6) 25:13,25;26:4,4; receiving (2)

 59:8;93:11 152:7 190:12;191:4; 28:12;29:19;30:11; 49:20;209:5 

pulse (4) Quarcoo (6) 196:10;197:6,6;202:2 31:11,22;33:14,17; recent (5) 

Min-U-Script® Burke Court Reporting & Transcription (32) prove - recent 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 1 

October 17, 2023 

35:11,18;206:13; 89:16;161:25 12:13 72:20 require (4)

 208:24;210:14 reduced (1) registry (1) remarkable (1) 19:17;40:11;91:5;

recently (6) 44:22 34:12 104:8 163:17 

41:24;72:23; reducing (4) regular (2) remarks (2) required (13)

 190:13,18;197:15; 64:25;65:9;82:21; 118:11;154:6 12:17;224:17 37:15;40:19;58:25;

 198:22 101:18 regulated (3) remember (7) 65:5;80:23;93:24;

reception (1) reduction (1) 91:20;179:4;217:20 12:23;14:13;15:6; 97:3;131:15;133:12;

 71:6 65:1 regulating (3) 145:14;148:9,10; 158:14;166:14;

recertified (1) Reed (1) 73:5;98:22;99:12 158:20 179:20;188:14 

41:25 192:24 regulation (7) remind (3) requirement (1)

recess (3) refer (3) 132:3,7,9,20,20; 8:18;65:21;207:5 27:16 

93:6;165:13;216:21 98:8;112:25;123:16 141:2;153:13 reminders (1) requirements (7)

recipe (2) referee (1) regulations (2) 12:10 39:10;86:15;94:13;

 50:4;182:12 133:25 132:5;166:9 remote (1) 96:8;194:5;201:20;

recipient (1) reference (1) regulator (1) 128:15 213:20 

209:3 16:11 193:3 remove (1) requires (6)

recipients (1) referenced (3) regulatory (14) 99:23 80:3,20;86:6,13;

 210:14 62:12;133:20;166:9 16:5;18:19;27:17; removed (2) 196:4;198:11 

reclaim (1) references (1) 34:22;66:23;111:9; 15:7;121:24 rereview (1)

 223:20 171:16 129:19;132:15;136:5; removing (4) 91:24 

recognize (9) referencing (2) 140:13;141:11;143:6; 83:7;118:2,9; rescinding (1)

 16:4;28:8;34:6,7; 171:24;172:5 166:19;192:7 210:12 167:16 

36:2;42:11;68:15; referring (3) reimbursement (1) rename (2) research (11)

 119:4;174:7 32:20;53:9;206:5 70:10 6:8,11 17:11;72:11;87:16;

recognized (3) reflect (3) reins (1) renewal (1) 112:2;114:20,24;

 12:12;60:23;93:22 48:1;82:22;85:23 18:19 122:18 123:14;128:13;

recognizes (1) reflection (1) reiterate (2) Repair (1) 161:19;177:2;188:15 

15:11 164:7 99:20;202:12 224:3 researchers (2)

recognizing (3) reflects (1) reiterates (1) repeat (1) 188:9,9 

14:23;40:10;150:2 166:4 66:2 54:12 reserved (1)

recommend (3) refrain (2) reiterating (1) repeatedly (1) 70:15 

90:6;152:3;162:3 12:16;70:1 151:19 58:17 resets (1)

recommendation (2) refuge (1) related (5) replace (1) 166:17 

64:11;70:21 105:12 46:13;57:13; 43:25 residue (38)

recommendations (7) refused (1) 123:12;164:6;186:20 replacing (1) 22:8;29:12,23;

 86:15;111:14,18; 173:23 relates (3) 18:23 43:23;44:21,23;45:5,

 161:24;162:2,4; regarding (5) 44:12;61:13;209:8 replicate (1) 7,9;46:14;47:19;48:1;

 185:17 27:18,21;99:19; Relations (1) 141:18 51:4,5,14;69:5;70:4,

recommended (1) 203:11;209:7 64:5 report (8) 5;72:15;73:8;76:20;

 162:6 regards (5) relationships (1) 44:23;58:15;63:4, 77:4,22,22;94:17,18,

recommends (1) 20:24;22:10;69:4; 165:1 11;110:8;162:5; 20;113:3;130:13,20;

 162:25 76:20;135:10 relatively (1) 164:5;207:15 131:5;132:1;149:11;

reconvene (2) regenerative (13) 87:8 reported (1) 152:1;154:22;163:15,

 8:6;216:21 16:25;17:2,3,10,14; relay (2) 67:25 16,18 

record (5) 117:1;196:3,23; 4:23;185:18 Reports (3) residues (1)

 4:24;7:3;12:14; 198:9,13;209:4,25; release (1) 77:3;161:23;166:21 131:1 

130:15;154:4 218:1 113:11 represent (6) resist (1)

recorded (1) region (2) relevant (1) 81:13;126:9;131:7; 80:21 

5:24 95:13;214:20 163:8 141:24;156:13; resolution (1)

recording (4) regional (5) reliance (3) 192:18 44:19 

4:4;7:5;51:1,13 96:5,8,24;97:11; 80:9;131:2;166:4 representative (1) resolved (1)

recordkeeping (1) 150:6 relies (1) 192:17 47:24 

108:15 regions (2) 111:12 represented (1) resolving (1)

recovered (1) 128:16;192:19 relist (4) 173:18 44:16 

99:6 register (1) 64:11;80:13,14; representing (4) resonates (1)

red (3) 71:18 119:6 26:16;64:7;129:20; 191:15 

35:19;36:2;73:7 registered (3) reluctant (1) 218:4 resource (5)

redirect (1) 5:7;61:1,3 181:23 represents (6) 134:21;137:25;

 140:13 registers (1) rely (2) 15:2;105:12; 143:11,16;200:10 

redirecting (1) 18:13 100:7;193:18 192:13;196:22; resources (30)

 140:19 registrants (1) relying (1) 223:14,20 54:7;59:1;66:22;

reduce (5) 59:16 75:23 request (3) 67:3,5,17;68:25;74:9;

 65:2;73:11;80:9; registration (1) remain (1) 59:15;85:25;98:21 76:12;124:16;127:3, 

Min-U-Script® Burke Court Reporting & Transcription (33) recently - resources 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 1 

October 17, 2023 

7;128:9;136:19;

 142:18,21;143:8,9;

 155:25,25;156:1;

 162:9;163:7;179:25;

 183:5;188:4,14,20;

 212:24;213:15 

respect (2)

 8:19,23 

respond (4)

 102:12;130:25;

 131:9;153:24 

response (32)

 10:17;11:8,15;22:8;

 48:8;54:2;66:9;78:20;

 100:13;103:23;107:8;

 109:2;113:25;115:22;

 129:12;130:12,20;

 131:22;134:8;141:6;

 142:6;144:1;147:25;

 159:5;162:10;180:11;

 182:4;191:8;195:10;

 202:21;210:24;221:8 

responses (1)

 130:16 

responsibilities (1)

 203:11 

responsibility (2)

 73:5;205:4 

responsible (3)

 27:3;141:10;204:7 

rest (3)

 15:5;50:19;74:5 

restart (1)

 163:14 

restaurant (1)

 168:17,21;171:25;

 192:11 

reviewed (6)

 29:11;72:21;75:11;

 76:4;166:13;192:20 

reviewers (1)

 60:4 

reviewing (3)

 76:2;100:19;169:7 

Reviews (1)

 149:13 

rewarding (1)

 150:20 

rewards (1)

 158:5 

Rhode (1)

 8:7 

Rice (10)

 116:20;122:7;

 129:15,17,18;132:8,

 24;133:8;134:16;

 135:1 

ride (1)

 192:1 

Ridge (1)

 178:17 

right (95)

 4:3,5;5:12;6:2,10;

 9:10;11:11,16,18;

 12:7;13:3,11,23;17:6;

 18:2;23:19,25;31:12;

 32:3;33:17;35:21,21,

 24;36:19;37:11,12;

 40:16;46:14,16;48:9;

 52:13;54:9,10,11,13,

 193:5,8 

ripple (1)

 67:9 

risk (14)

 15:7;23:11;46:18;

 69:7;77:4;83:19;

 91:25;93:21;94:3;

 96:16;130:23;151:22;

 152:6,10 

risk-based (2)

 130:7,10 

risks (1)

 59:4 

risky (1)

 153:20 

RMA (3)

 96:3;186:25;187:11 

road (2)

 18:13;205:24 

roadblocks (2)

 217:14,15 

roadmap (1)

 208:3 

roadrunner (1)

 15:8 

role (8)

 26:21;42:23,25;

 46:19;47:20;52:5;

 65:8;79:8 

roles (2)

 125:19;133:23 

roll (2)

 9:8;11:10 

rolled (1)

 150:3 

Rube- (1)

 74:20 

rule (17)

 19:19;44:21;50:4;

 57:15,23;65:2,6,7;

 67:6;105:15;123:5,8;

 131:15;145:22;

 179:20;183:6,7 

rulemaking (3)

 22:10;80:17;110:17 

rules (6)

 19:17;94:14,15;

 140:22;144:18;

 201:19 

ruminant (1)

 150:9 

ruminants (1)

 158:14 

run (6)

 8:13;22:23;74:6;

 181:19;217:14,14 

Runde (6)

 149:5;157:4;161:3,

 7,8;164:16 

running (2)

 175:18;178:25 

runs (2)

 148:17,18 

rural (8)

 142:2;180:5;199:3,

 7;213:7;222:6;223:3,

 17 

21,22 

sample (1)

 153:20 

sampled (1)

 133:15 

samples (3)

 133:9;153:24;

 154:10 

sampling (10)

 70:5;77:17;130:14,

 19,25;132:2;133:13;

 154:6,12,22 

San (1)

 177:4 

sanitation (1)

 193:22 

sanitize (1)

 193:25 

Santa (1)

 72:13 

Sarah (1)

 192:24 

Sarina (1)

 172:17 

Sarra (4)

 64:2;66:14;71:21,

 23 

sat (1)

 157:10 

satisfaction (1)

 209:16 

sausage (1)

 25:1 

save (2)

 29:1,1 

S 

173:25 15;55:9;56:8,12; roller (1) sacred (1) saved (1)

restriction (1) 57:16;62:19;63:18, 129:3 14:14 30:2 

121:11 18;66:10;71:4,19; rolling (2) safe (4) savings (2)

restrictions (2) 78:3,9;81:2;82:14; 30:13;31:13 64:16;99:25;101:4, 23:15,18 

121:9;194:4 84:19;85:14;88:11; rooftop (1) 4 saw (9)

result (4) 91:7;93:5;97:23; 105:17 safely (2) 16:24;29:20;30:2;

 68:7;133:25,25; 100:14;103:19;106:3; rooftops (1) 95:1;101:7 33:4;63:16;76:9;77:2;

 194:5 109:11;110:3,5; 114:5 Safety (6) 84:11;194:18 

results (4) 116:17,24;121:24; room (3) 73:2;79:13;92:15; saying (9)

 44:14;77:19;78:2,4 122:1,15;129:13; 4:7;146:3;205:3 94:9;103:11;192:8 14:15;20:13;42:8;

retail (2) 133:20;134:6;135:2; root (3) sake (1) 147:16;154:17;

 209:2;215:25 136:13;139:23; 25:17;51:6;62:14 145:7 167:19;175:16;182:1;

retailers (5) 142:20;159:12;164:2; roster (1) sales (3) 224:10 

129:21;151:4; 165:7,11;172:5,10; 155:19 147:7;177:9,11 scab (2)

 175:15;177:21;216:7 176:25;177:8;178:15; rot (1) salesman (1) 82:4,9 

retained (1) 183:22;195:11; 82:9 174:2 scale (7)

 64:21 197:13;200:9;205:15, rotate (1) salespeople (1) 18:20,22;24:17;

reticent (2) 16;206:3,5;211:5; 104:21 175:15 31:19;52:2;54:8;

 203:17;204:22 221:9;223:24;224:2 rotation (3) salt (3) 137:5 

return (1) rights (1) 153:10;185:14; 65:2,4,5 scenario (1)

 95:9 14:15 188:2 same (24) 90:21 

Review (27) rigid (1) rotations (2) 7:10;8:22;15:16; scenes (1)

 19:24;22:14,17; 167:14 150:22;210:12 21:10;27:13;61:18; 24:1 

37:25;39:16,18;40:5, rigidness (1) round (4) 94:15;107:1;111:25; schedule (2)

 9,11,19;59:2;60:3; 167:13 9:5;25:18;31:9; 134:10;139:4;153:12, 5:9;22:4 

65:6;73:2;80:1;98:15; ringing (2) 84:18 13;154:12;161:20; scheduled (1)

 112:9;149:14;166:7, 18:13;27:23 rub (1) 163:24;182:12;207:8; 6:13 

10,18;167:6,16; ripening (2) 37:21 218:18;224:20,20,21, scheme (2) 

Min-U-Script® Burke Court Reporting & Transcription (34) respect - scheme 

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NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 1 

October 17, 2023 

74:21;188:3 secrecy (1) selection (1) services (2) shelling (2)

school (7) 62:16 26:5 111:23,24 49:10,16 

23:8;50:16;106:2,4; SECRETARY (53) self-limiting (1) serving (1) shelves (1)

 157:18;159:12; 9:20;12:5;21:25; 88:24 117:17 106:2 

220:24 24:6;29:9;30:1,5,7; sell (8) session (3) shepherded (1)

science (3) 36:21;38:5,9,13,16, 117:9;173:14,20, 8:17;79:9;157:12 219:1 

36:14;115:3;184:11 19,22;45:17;46:25; 24;175:22;176:12; sessions (1) shift (2)

science-based (1) 68:23;69:21;72:18; 189:23;214:23 7:25 44:3;183:19 

114:20 76:17;77:8;78:7; selling (5) set (5) shifting (1)

scientific (3) 83:24;84:1,4,6;85:3, 20:21;117:21; 75:13;83:4;167:20; 164:10 

83:16;87:1;148:18 8;95:22;96:19,21; 146:3;176:11;196:11 211:22;223:18 shipment (3)

Scoles (12) 97:6,16;112:22; semi-retirement (1) sets (1) 22:22,24;23:1 

135:4;143:23; 113:19,22;126:4; 144:14 170:11 shipped (2)

 149:4,7,8;152:6; 128:1;151:17;152:13; Senate (1) setting (1) 173:3;193:12 

153:2;154:5;155:1,5; 160:1,8,22;169:3; 123:4 85:24 shippers (1)

 156:17,24 170:1,5,19,24;171:7; senators (1) settle (2) 81:14 

scope (4) 174:23;194:15;195:7 145:13 180:22,22 shipping (1)

 16:18;84:24;102:1; section (2) send (7) settled (1) 188:17 

118:6 149:18;166:3 6:5,14;22:12,14; 112:6 ships (2)

Scott (10) sections (1) 24:4;107:10;153:24 seven (2) 113:11;152:3 

116:20;122:6; 166:8 sending (1) 123:11;139:23 Shistar (11)

 129:15,18;131:21,23; sector (9) 199:18 several (13) 43:10;48:15;58:2,5,

 132:23;133:22;134:7, 30:13;77:18;79:19; senior (1) 35:16;44:5;79:22; 9,11;60:21;61:22;

 9 107:22;113:12; 145:15 130:2;140:25;152:8; 62:15;63:4,15 

screaming (1) 120:17;146:20;174:6, sense (13) 155:10,17,17;160:13; Shistar's (1)

 92:5 18 39:5;41:3;44:7; 164:2,5;220:2 72:24 

screen (15) secure (1) 76:13;78:6;88:1; severely (1) shoot (1)

 4:13,14,16,22;5:11, 123:6 96:12,18;107:19; 17:9 116:14 

15,15,16,16,19,19; seedlings (1) 128:9;168:11;175:25; shade (2) short (4)

 6:6;7:9;45:5;219:10 72:14 190:20 82:16;83:2 53:1;60:7;95:17;

scrutinize (1) seeds (3) sensible (1) shades (1) 99:7 

205:3 123:14;130:10; 130:8 114:14 shortage (1)

se (1) 184:10 sensitive (2) shall (1) 21:9 

73:10 seeing (20) 27:4;106:18 12:16 shortcomings (1)

seal (14) 5:20;12:1;18:20,21; sent (4) shampoo (1) 44:23 

14:21;15:2;17:8,9; 33:23;63:24;71:22, 36:10,11;141:25; 88:16 shorten (1)

 22:7;105:1;106:2; 23;103:17,22;106:3; 154:9 shape (1) 173:7 

131:10;174:8,16,17; 127:22;147:5,6; sentence (1) 8:2 shot (1)

 179:12;217:18; 150:21;164:4;171:1; 7:8 shaped (1) 223:17 

220:24 180:13;185:21;198:3 sentences (1) 221:25 shoulders (1)

seal's (1) seek (6) 22:19 share (23) 68:16 

218:25 66:24;86:8;206:7; sentiment (1) 5:14,15;8:21;27:11; Shout (1)

search (1) 207:8;208:25;212:17 211:24 47:8;70:8;93:14; 156:25 

22:13 seeks (2) separately (1) 122:4,21,24;123:6,13; shouting (1)

season (4) 45:8;65:3 107:25 124:16;128:6,20,25; 114:5 

43:19;82:23; seem (6) September (1) 129:4,7;150:15; show (7)

 102:19,20 65:20,20;134:14; 122:18 200:19;206:24; 23:25;77:14;87:12;

seat (2) 164:4;168:4;212:9 serious (2) 220:20,23 148:15;149:18;

 28:15;31:14 seemed (2) 51:3;165:16 shared (4) 154:15;213:24 

Seattle (7) 46:3;85:4 seriously (2) 69:13;125:21,21; showed (1)

 173:23;174:1,4; seems (7) 48:4;210:17 204:13 87:6 

176:5;177:4,6,9 74:6;113:17; serve (6) sharing (4) showing (5)

sec (1) 134:13;141:12; 20:4;36:5;73:23; 61:11;182:16,19; 7:8;77:6;120:6;

 58:7 157:25;199:11; 85:24;221:15;222:10 183:20 148:20;207:14 

second (11) 209:13 served (2) sharp (1) shown (3)

 57:10;59:23;65:24; sees (1) 117:19;163:13 193:16 35:15;184:25;

 68:2;75:12,14;123:2; 114:13 serves (2) sheep (2) 209:12 

125:6;166:12,14; segment (1) 86:4;129:23 108:16,19 shows (5)

 193:19 192:14 service (12) shelf (4) 77:23;87:1;114:21;

secondary (1) segments (4) 78:24;80:25;95:19; 176:13;198:7; 147:11;161:19 

74:20 8:9,10,16;75:21 98:5;105:25;124:12; 209:16;220:25 shut (1)

Secondly (1) selected (1) 131:20;166:5;179:17; shell (1) 173:5 

94:3 154:16 197:1,2;210:16 53:17 shutdown (1) 

Min-U-Script® Burke Court Reporting & Transcription (35) school - shutdown 

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NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 1 

October 17, 2023 

122:17 slide (13) 64:25;65:1,2,9 208:7 speakers (10)

shy (1) 4:16;5:16;6:2; SOE (5) sort (37) 6:2;11:19;12:12,15,

 59:22 12:12;34:5,18;35:9; 67:6;70:9,15; 31:20;32:9;39:4,5, 21;14:8;19:3;125:25;

side (11) 36:9;59:24;60:22; 113:18;126:12 13,17;47:12;51:14; 147:9;207:25 

20:19,20;28:12; 61:22;63:8;224:19 soil (31) 61:21;62:10,13;70:8, speaker's (2)

 52:17;107:21;119:24; slides (3) 14:12;15:3,7;82:12; 18;74:20;75:9;88:3,4; 8:22;12:21 

172:24,24;173:1; 5:14;11:21;58:7 94:24,25;99:22; 90:3,22;107:1,22,23; speaking (4)

 197:19;215:17 slide's (1) 102:12,15,18,24,25; 133:11;141:18; 55:20;117:5;185:6;

sideline (3) 36:17 103:2,3;104:20,22; 146:23;155:15; 203:23 

14:6;222:4,7 slight (1) 111:4,5,5;114:10; 164:14;166:7,9,12; special (3)

sides (1) 99:5 157:19,20,21;179:19; 171:20;172:4;179:13; 12:3;68:15;122:23 

219:10 slightly (1) 183:7;184:11,12; 181:21;187:21;202:8; specialized (1)

sight (1) 206:2 196:4;210:12;212:8, 204:24 189:5 

114:10 slinging (1) 12 sorts (1) specializes (1)

signal (2) 165:18 soil-based (2) 31:9 34:1 

40:8,21 slog (1) 15:10;112:10 sound (6) species (1)

signed (2) 15:15 soils (1) 7:6;35:18;43:25; 206:24 

12:13;207:25 slogan (1) 159:16 69:10;90:5;140:7 specific (19)

significant (6) 191:12 solely (1) sounds (4) 30:16;31:12;39:13;

 35:15;82:20;83:5; slots (1) 57:2 30:1;97:6;107:17; 51:6;60:12;80:3;

 84:21,21;220:7 29:23 solid (1) 144:5 86:17;88:7;94:10;

significantly (1) slowed (2) 132:11 soup (1) 110:14;123:11;166:8,

 210:3 196:9;198:21 solution (2) 71:3 23,25;188:25;197:20;

signs (1) slowly (1) 100:8;171:16 source (7) 198:17,24;206:1 

19:1 195:24 solutions (1) 41:22;93:24; specifically (12)

similar (3) small (21) 94:7 119:16;169:19,25; 29:23;46:10;85:25;

 62:17;194:25;213:1 16:16;21:16;29:1; somebody (2) 170:16;194:7 94:9;96:4;110:23;

similarly (3) 44:2;50:2;54:7,20,25; 25:7;73:20 sources (4) 120:17;154:9;172:2;

 62:13;80:11;192:18 55:1;65:20;73:14; someday (2) 35:22,22;63:5,10 188:23,25;199:23 

simple (3) 79:18;87:8;137:5; 110:23;206:3 sourcing (2) specifications (1)

 132:16;198:17; 147:4,4;180:4;199:7, somehow (1) 46:10;184:16 57:14 

218:3 8;215:21;219:15 16:17 South (2) specifics (3)

simply (2) smaller (7) someone (7) 15:5;160:12 31:2;113:16;224:2 

131:12;215:12 51:25;52:10;54:17; 16:24;40:14;75:7; southeast (2) speculation (1)

singing (1) 73:15;90:16;133:19; 114:13;158:25; 20:11;142:3 89:3 

105:17 204:6 186:24;188:3 Southeastern (1) speech (1)

single (6) smallest (1) someone's (2) 172:18 210:22 

23:1,16;52:21; 52:2 16:11;108:19 southern (1) speed (1)

 141:15;173:25;224:9 small-scale (1) sometimes (13) 142:2 42:14 

sit (8) 128:19 5:2;6:15;23:8,10; southwest (1) spend (4)

 31:2;106:24; Smart (4) 40:1;101:20;113:9; 207:10 34:11;155:13;

 141:15;144:11; 72:16;73:19;74:17; 132:15;140:7;141:23; sovereignty (1) 196:1;224:5 

155:21;164:8;168:11; 105:16 169:22;172:25; 223:18 spends (1)

 207:11 Smith (26) 198:12 soy (1) 190:18 

site (1) 10:13,14;55:16,23; somewhat (1) 22:22 spent (4)

 150:20 56:1,5,7,9,12,17; 176:21 soybeans (2) 53:4;145:18;

sitting (1) 57:10;143:4,19; somewhere (1) 21:1,9 153:22;180:2 

95:24 192:5;195:15;200:21, 202:24 soymilk (1) sphere (1)

situations (2) 24,25;201:1,2;203:2, son (1) 21:8 223:25 

93:22;118:10 4,8;204:17;205:9,15 147:4 space (6) spiel (1)

six (4) Snowy (1) soon (6) 12:6;34:2;163:4; 165:4 

38:2;53:4;91:23; 214:2 5:25;19:3;68:8; 191:6;200:6,7 spinach (1)

 150:8 SO2 (10) 110:17;115:17;192:3 sparked (1) 77:6 

size (3) 117:14,15,16,24,25; sorbate (5) 159:23 spoke (1)

 5:4;22:25;136:13 118:6,17,21,24;120:5 84:10,12;169:8; speak (20) 42:22 

sized (3) so-called (3) 194:19,20 6:4,13;7:6;21:23; spoken (2)

 115:2;176:4;180:4 58:14,24;59:4 sorry (19) 29:4;30:16;31:6,11; 121:17;129:2 

skip (1) social (4) 33:13;41:10;55:21; 43:18;45:13;95:13; spool (1)

 71:5 14:24;17:19,20; 56:1;75:25;76:14; 104:7;121:16;124:23; 12:22 

slaughter (1) 135:16 81:10;100:15;108:6; 133:2;139:6;155:3; spot (4)

 173:12 socially (1) 142:4,17;144:6; 158:22;202:1;222:21 77:13;142:12;

sleep (1) 224:1 146:16;154:15;157:7; Speaker (4) 204:2;205:7 

154:20 sodium (4) 174:11;182:6;205:23; 5:13;13:3,9;122:16 spray (1) 

Min-U-Script® Burke Court Reporting & Transcription (36) shy - spray 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 1 

October 17, 2023 

181:11 94:12;104:5;105:15; stay (5) 216:16,24,24;217:14, 85:5 

sprayed (1) 110:22;112:7;123:5; 51:25;143:17; 17 submitted (5)

 49:7 125:15;137:16;166:2; 147:3;154:20;162:13 storytellers (1) 58:12;84:14;98:9;

spread (4) 179:11;192:8;198:1; staying (1) 177:21 130:2;135:9 

148:6;196:14,18; 210:6;220:4;223:19 215:5 straight (1) subs (1)

 197:3 standing (3) steamrolls (1) 203:18 60:4 

spreading (4) 68:16;162:17;163:2 182:22 straightforward (1) subsequent (1)

 90:7;105:3,20; standpoint (4) steering (1) 40:9 193:17 

148:3 111:11;133:7; 68:8 strategic (1) subset (3)

spring (12) 160:21;214:23 step (11) 68:4 168:15,20;172:1 

8:8;36:24;38:1; stands (4) 15:1;20:4;73:22; strategies (1) substance (7)

 41:9;60:5;84:11; 15:3;112:7;163:25; 130:9;164:19;167:17; 95:7 84:9,15;86:5;130:6;

 120:5;123:25;162:19; 215:16 175:1;176:10;180:2; stream (1) 167:2;192:22;212:5 

194:18,19;195:4 Stanford (1) 206:2;212:2 8:7 substances (19)

spring's (1) 189:21 Stephanie (12) streamlined (1) 59:24,25;62:4;64:8,

 36:10 Star (1) 122:7;129:15; 80:1 11,12,14;86:9,11,13,

spurred (1) 206:9 135:3,5,7;139:3; strength (1) 17;89:7;90:11,12;

 75:3 start (27) 140:2;141:5,8;143:4, 179:16 130:7;133:18;166:13;

squeezing (1) 4:3,10;7:3;11:23; 21;156:2 strengthen (2) 167:3;194:10 

18:22 12:24;14:9,20;17:9; stepping (1) 130:13;174:17 substantial (2)

stability (1) 18:4;56:25;84:7; 152:18 Strengthening (2) 49:24;210:14 

129:5 92:25;102:19;103:4; steps (1) 57:14;131:13 substitute (2)

stabilize (1) 105:17;117:2;138:23; 130:20 stress (1) 59:23;60:5 

147:22 144:20;156:3;161:9; sterilant (2) 98:19 substitutes (2)

stack (1) 170:17;178:1,3; 117:16;118:4 strictest (1) 65:2,5 

126:18 191:20;214:17; steward (3) 179:4 subtracted (2)

stacked (1) 217:24;219:18 79:6;178:20;219:12 strictly (1) 61:3,4 

21:6 started (14) stewardship (2) 19:9 success (1)

staff (8) 21:14;43:20;50:6; 18:18;172:23 strikes (1) 162:25 

9:2,8;11:18;15:16; 53:13;57:6,8;136:10; still (25) 217:2 successful (7)

 69:15;113:15;125:13; 155:7,8;187:22; 34:11;50:16,20,24; strip (1) 28:10;44:25;137:7;

 137:15 201:17;213:5;216:2; 68:13;84:15;101:2; 118:16 139:22;150:17;163:9;

stage (1) 219:21 114:10;120:22;121:4; strong (7) 187:20 

220:23 starting (6) 132:12,17;133:13; 59:22;94:8;168:5; successfully (2)

stages (1) 53:22;54:23;95:10; 145:19;146:2,25; 180:15;184:12; 28:17;139:7 

139:7 119:9;130:11;220:4 147:3,3;153:5; 190:16;196:13 succinctly (1)

stakeholder (3) starts (5) 163:24;164:10;185:4; strongly (3) 12:19 

65:11;164:10; 60:22;101:18; 200:23;221:3,3 64:10;87:24;123:21 suffering (1)

 169:11 170:3;200:8;217:24 stink (1) structural (1) 93:23 

stakeholders (5) state (11) 83:1 162:20 sufficient (2)

 36:16;95:9;98:6; 7:2;12:23;48:16; stocking (1) structure (5) 86:19;194:6 

112:9;115:1 82:19;83:13;94:23; 19:12 21:6;39:12;151:13; sugar (2)

staking (1) 106:21;137:24; stood (1) 200:5;206:15 104:17;119:23 

116:8 181:22;191:4;214:20 60:14 structured (1) suggest (1)

stance (2) stated (1) stop (5) 138:14 76:11 

84:9;194:22 45:25 105:24;131:9; structures (2) suggested (1)

stand (1) statement (2) 140:12,18;218:9 161:25;206:22 171:16 

112:14 112:10;152:5 stopped (1) struggle (2) suggestion (3)

standalone (1) States (4) 51:1 114:15;170:8 133:1;200:11,12 

162:9 51:10;145:13; store (8) struggled (1) suggestions (5)

standard (13) 150:8;184:17 106:2;173:25; 199:6 60:12;75:9;76:5;

 17:14;47:9,15; statewide (1) 176:11;178:2,2; studies (1) 153:25;206:1 

94:19,20;105:14; 200:8 209:15;216:1;220:25 167:8 sulfur (28)

 121:21;166:3;169:21; status (4) stored (1) stuff (1) 82:2,2,3,7,11;85:5;

 170:11;179:5;196:3,5 72:17;104:19; 27:4 155:16 98:16,16,19,23;99:21;

standardize (1) 105:9;119:1 stores (15) subcommittee (6) 100:22,24;101:2,5,24;

 65:3 statute (4) 160:13;173:17; 62:23;83:7;84:22; 117:6,8,16;119:6;

standardized (1) 53:24,24;89:13; 174:4,7,8;175:19,24, 98:21;99:18;162:7 121:9;144:16,20,25;

 151:19 91:14 24;176:9,12,17,18,20, Subcommittee's (1) 145:12,17;146:6,19 

Standards (26) statutes (1) 24;177:14 64:10 sulfurous (4)

 4:6;7:16,20,22; 73:4 Story (10) subject (1) 98:16;99:19;100:1;

 8:13;17:12,21;65:4; statutory (3) 39:21;174:25; 86:2 102:11 

79:10,12;83:11; 76:12;87:10;166:19 183:20;215:11,15; submission (1) summarize (2) 

Min-U-Script® Burke Court Reporting & Transcription (37) sprayed - summarize 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 1 

October 17, 2023 

18:11;22:19 

summary (3)

 63:8,8;149:17 

summer (1)

 101:15 

sunburn (1)

 83:3 

sunburning (1)

 101:17 

180:24 

supposedly (1)

 175:21 

sure (41)

 6:3;8:22;13:18;

 21:25;24:4,9,23;32:4,

 7,23;35:10;41:21;

 42:9;52:9;53:1;54:13;

 55:17;84:6;97:10;

 31:18;44:3;80:7;

 81:25;97:2;100:2;

 115:13,16;161:25;

 164:22;181:22;

 184:13;193:21;

 206:20;210:10 

tastes (1)

 25:22 

tasting (3)

 36:3;105:5;146:3 

taught (1)

 80:10 

teach (4)

 139:9;157:19;

 186:7;188:21 

11;60:11;62:20;

 63:20;72:24;90:3,16,

 21;91:3 

Terry's (1)

 90:10 

test (7)

 11:11;13:16;16:7;

 23:1;47:23;78:2;

 133:7 

T 

sunflower (2) 108:5;129:9;134:4; table (7) teaching (1) tested (1)

 46:14,17 135:15;147:6;150:17, 28:15;31:9,15; 182:10 45:4 

Sunset (10) 24;155:5,24;163:6; 39:16;49:9;90:19; team (7) testified (1)

 39:2,13,18,23;40:4; 165:3;171:9;198:8,8; 121:12 9:4;17:11,11,12; 21:10 

81:19;85:25;87:9; 199:10,16;203:7; tackle (2) 70:2;71:17;134:17 testimony (2)

 149:13;192:11 213:3,3;216:9; 60:12;76:3 teams (2) 95:15,17 

super (3) 220:13;223:10 tag (1) 151:23;188:21 testing (71)

 31:11;155:18; surprised (1) 70:2 tear (1) 22:8;23:3,18;29:12,

 159:21 49:15 tailored (1) 217:15 16,20,24;43:23;44:1,

supervise (1) surrounding (2) 20:18 technical (16) 2,5,21,24;45:5,7,9;

 21:15 85:5;179:9 takeaway (1) 4:23;5:21;9:2; 46:1,2,6,14,19,22;

supervising (2) survey (2) 40:2 40:11;44:22;80:16; 47:6,10,19;48:1;51:4,

 21:15,18 68:8;128:12 tale (1) 94:25;136:5;140:14, 5,14;69:4,5;70:2,4,8;

supplementation (1) survive (1) 215:8 21;141:2;150:24; 72:15;73:8,10;76:1,

 169:16 19:11 talk (22) 151:1;152:19;165:23; 20;77:5,22;89:9;

suppliers (2) susceptible (1) 12:5;17:10;18:11; 166:21 94:17,18,20,25;113:3,

 21:18;30:25 118:18 30:2;87:6;122:12; technologies (1) 4,8,9,12,15;130:6,7,

supplies (1) suspect (1) 134:11;135:10;141:8; 113:15 18,19;131:3,16;133:2,

 210:13 222:21 144:16;149:1;165:24; technology (2) 3,4,5;149:11;152:1,1,

supply (28) sustainability (2) 174:20;176:10; 36:13;134:19 4,9;153:17;163:15,16,

 22:9;28:7;29:13,16; 79:15;206:21 178:10;182:25;186:6; teeth (2) 18 

43:24;44:8;46:2,24; sustainable (1) 192:3;200:13;204:18; 217:19;218:7 tests (2)

 51:5;69:5;75:21; 218:1 218:1;222:24 telegraph (1) 44:17;113:17 

77:11;80:11;113:3; Sydni (6) talked (5) 41:7 thankful (2)

 137:6;149:12;152:2; 48:15;58:2;64:1,3, 18:25;121:13; telling (1) 210:14;214:4 

173:5,8,13,16,17,21; 5;66:11 151:11;169:5;214:18 180:18 thanking (2)

 176:1,2,4;192:14; synergistic (1) talking (23) template (1) 117:3;161:9 

196:11 88:22 19:9;21:13;25:25; 166:22 Thanks (91)

supplying (1) synergy (3) 29:23;41:16;70:3; Ten (1) 9:9;15:20;16:1;

 194:16 86:23;150:4;151:24 77:21;87:5;90:11,24; 104:15 21:25;22:1,1;29:9,10,

support (39) synthetic (16) 102:22;119:14;128:8; tend (3) 22;30:10;31:1,22,23;

 9:2;11:19;27:7,12, 58:24;59:13;61:5; 136:3;140:7,18; 51:24;108:7;222:20 36:21,22,22;39:1;

 14,22;33:6;43:17; 64:12;86:5,9,13; 142:7;147:5;155:13; tenfold (1) 43:14;45:17;47:17;

 44:4;45:7,8;46:6; 118:7;136:20,20; 170:3;171:23;204:3; 148:11 52:24;57:10;58:1,8;

 64:25;70:16;72:22, 144:23;151:8;169:16, 215:14 tense (1) 60:10;63:18,25;

 24;84:12,15;87:24; 19;196:22;210:10 talks (1) 153:21 70:23;71:18;73:23;

 93:25;95:4,7;98:11, synthetics (2) 61:23 term (3) 74:4,25;75:2;76:17;

 14,20;109:14;116:4; 59:21;144:25 tangibly (1) 39:22;112:1;201:12 78:14;83:21;85:10;

 117:5;123:13;130:5; system (41) 156:16 terminology (1) 87:21;89:22,25;

 149:24;151:13; 21:17;26:2;43:25; tap (1) 206:11 97:16,23,23;103:18;

 166:14;173:19;188:5; 73:9,11;76:21,22; 200:9 terms (16) 107:15;116:10,11;

 193:22;194:19; 78:3;83:10;105:7,13, target (2) 31:1,16;37:16;53:2, 119:7,11,25;120:4;

 199:21;220:22 16;112:13,13;115:9, 131:17;206:10 7;62:12;96:24; 121:15,25;124:14;

supported (2) 10;150:16;151:7,8; targeted (5) 128:17;132:14; 125:1;126:4,5,5;

 185:1;192:23 158:5;161:13,16; 130:7,23;131:11; 133:10;134:19;183:7; 130:1;131:18;133:22;

supporting (5) 164:25;165:5;167:12, 177:2,6 194:3;201:25;209:4,7 139:2;143:4;146:14;

 22:16;68:7;150:5; 12,13,14,18,21; Targeting (2) Terri (1) 151:17,18,24;152:16;

 160:25;219:25 168:23;172:6;181:23; 44:7;177:8 104:4 154:24;163:22;

supportive (3) 196:23,24;202:6; task (1) terrifying (1) 165:22;167:24;168:3;

 34:9;68:1,5 207:6;215:20;219:17; 105:21 140:18 169:3;174:23,24;

supports (6) 223:4,17 taskbar (2) Terri's (1) 175:11;178:15;

 64:10;94:22;105:7; systemic (1) 4:21;6:22 76:5 181:17;185:2;186:15;

 163:17;193:2,19 77:10 taste (4) Terry (13) 187:17,23;194:15,16;

supposed (1) systems (15) 25:15,18;26:3,4 43:10;48:14;58:2,4, 195:8;199:20;204:1; 

Min-U-Script® Burke Court Reporting & Transcription (38) summary - Thanks 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 1 

October 17, 2023 

205:8;214:14;219:2 224:12 160:24;161:1,18; total (1) transcripts (1)

that'd (1) throughout (4) 164:1,20,21,22; 65:16 8:10 

207:17 68:15;106:5; 166:11;169:4;174:20; totally (1) transformation (1)

the- (1) 112:12;118:19 178:10;180:8;183:23; 76:6 104:20 

133:17 throw (2) 189:9,13,23;191:24; to-time (1) transforming (1)

theme (1) 17:18;24:15 192:12,17,23;194:13, 118:10 161:16 

217:1 Thursday (11) 16,24;195:12;200:13; touch (3) transition (44)

themes (1) 22:4;193:1;195:15; 201:10;202:23; 14:11;31:4;147:3 27:22;28:1,2,20,24,

 217:2 208:6;216:21;224:16, 205:12;207:14,20,22; touches (1) 25;30:12,19,21;

therefore (2) 21,22,23;225:3,5 208:11,17;211:17,18; 15:12 72:16;73:19;74:8,10;

 64:19;96:9 thus (2) 212:10;213:4;216:10, tough (3) 80:6;105:3,24,24;

thinking (10) 111:17;210:12 20;217:1;218:14; 132:8;171:2;208:14 122:13;123:13;124:4;

 51:10;107:23; Tiber (1) 219:5;221:10;224:22 toward (2) 135:11,20;139:5,24;

 125:19;156:18; 178:16 today's (2) 67:5;134:23 149:10,24;150:5,12,

 162:14;168:18; ticket (1) 104:10;118:24 towards (6) 17,19,23;151:5,6;

 174:17;187:25;216:3; 200:18 toe-to-toe (1) 17:24;20:18;44:3; 152:17;158:16;163:3,

 217:7 tie (1) 23:23 135:15;170:9;206:20 5;179:25;185:1;

thorny (1) 88:7 together (10) towns (1) 186:8;190:14;197:6;

 91:18 tied (1) 31:10;55:3;123:10; 55:12 220:8,9 

thoroughly (1) 88:3 125:9;168:14;178:9; township (1) transitioning (5)

 45:10 tile (4) 186:19;211:18;218:5; 149:18 28:9;135:11,21;

though (14) 6:4,9;7:9;13:13 221:14 toxic (8) 179:6;180:15 

18:13;34:4;37:12; till (1) toggle (1) 58:21;59:10;62:4; translate (3)

 51:3;53:6;63:25; 111:5 6:25 63:6,6;87:2;178:24; 138:19;141:3,24 

115:18;126:14; time- (1) toggling (1) 179:22 translation (2)

 144:13;153:6;158:6; 118:9 5:12 toxicity (7) 135:25,25 

166:15;168:7;214:22 Timeless (8) told (4) 61:23,24;63:1; transparency (2)

thought (13) 184:10,14,14,15; 37:10;49:16,24; 86:21,22;167:8;172:2 111:13;112:12 

41:6;44:13;56:18, 186:1;187:20;188:8; 217:18 TR (2) transparent (3)

 20;57:9;66:5;96:11; 213:2 tomorrow (1) 40:12,12 8:19;89:15;196:24 

97:2;99:15;138:3; timeline (2) 22:3 Tracey (10) travels (1)

 176:2;177:7;201:13 37:6;150:3 ton (1) 93:4;97:18;103:19, 14:17 

thoughtfully (1) timelines (1) 179:9 24;106:6,11;107:15; treat (3)

 75:7 37:4 took (7) 109:1,4;114:4 99:20;101:13;198:9 

thoughts (14) timer (6) 42:10;104:15; Tracy (1) treated (1)

 24:24;30:22;51:12; 7:6,8,10;12:24; 144:14;146:4;149:19; 104:2 62:13 

116:2;132:6;134:5; 13:9,16 154:10;204:17 trade (6) treatment (1)

 149:25;152:21;160:2; times (9) tool (9) 45:2;129:19;131:7; 210:5 

164:13;181:25; 19:1;23:23;39:24; 45:1;47:11;51:24; 135:8;188:22,24 Tree (9)

 200:19;205:5;208:16 124:20;143:7;166:20; 64:24;82:7;94:18; traditionally (1) 81:18,22;82:3,8,15,

thousand-case (1) 177:25;178:4;222:11 127:21,23;131:3 50:16 22;85:2;98:1,20 

146:1 timing (2) tools (7) train (2) tremendous (3)

thousands (6) 207:3;210:22 44:25;67:22;81:24; 40:5,5 21:3;25:15;127:6 

28:19;61:7;83:6; timings (3) 115:9;127:11;131:8; trained (1) trends (1)

 103:8;122:24;145:22 98:23;99:12,15 213:15 154:9 217:2 

thread (1) tissue (1) top (7) trainer (1) triage (1)

 142:25 82:9 90:22;126:10,16; 156:22 132:5 

threat (1) today (94) 165:10,11;200:15; training (12) trickled (1)

 122:20 8:25;9:13;12:8; 224:8 23:9;35:2;124:18, 138:11 

threatened (2) 13:3;19:5;22:3;26:16, topic (13) 21,25;125:3;153:11; tried (2)

 17:8;58:18 18,23;29:4,10;33:18; 22:11,15;37:3;63:3; 156:11,21;162:15; 58:17;174:1 

three (10) 34:11;43:22;45:13, 75:10;80:17;93:17; 184:11;219:22 triple (1)

 7:6;42:7;55:2,3,9; 18;46:10;47:18;48:2, 135:9;144:17;149:23; trainings (4) 173:1 

93:15;192:1;200:17; 10,24;51:22;58:13; 161:17;163:1;165:25 125:13;142:19; Troll (4)

 215:8,11 64:22;66:4;68:14; topics (4) 153:3;164:3 215:9,15,23;216:14 

threshold (3) 76:18;81:20;84:1; 74:6;93:15;163:5,6 trajectory (1) tropical (1)

 44:11,12,14 93:15;104:4;106:9, TOPP (12) 198:22 193:9 

threw (1) 13,20;109:17;116:18; 12:5;75:13;124:5,7; transcends (1) trouble (1)

 45:19 117:5;119:14;122:5; 137:7;139:7;150:5, 206:7 89:9 

thrive (1) 123:20;126:5;130:3; 10;158:17;185:3; Transcript (2) TRs (2)

 174:7 134:25;143:21; 190:12;206:14 5:2,25 166:21;167:9 

throughline (3) 145:18;146:11;148:2; TOPP-supported (1) transcriptionist (1) truck (1)

 148:1;180:12; 151:18;158:24;159:3; 151:9 7:4 201:11 

Min-U-Script® Burke Court Reporting & Transcription (39) that'd - truck 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 1 

October 17, 2023 

true (5)

 19:1;56:21;99:25;

 112:15;215:12 

truly (8)

 25:7;51:7;68:12;

 92:17;104:6;130:17;

 141:24;209:23 

trust (6)

 111:7,19;138:13;

 163:11,14;165:1 

truth (2)

 37:10;180:23 

try (15)

 17:9;63:13;123:21,

 24;124:16;132:4;

 136:11;142:19;

 150:21;153:4;178:5;

 188:8;191:6;207:19;

 217:13 

trying (31)

 15:10;20:22;39:10,

 17,20;46:7;53:2;

 61:16;62:9;69:14;

 109:8;115:16;121:4;

 140:17;141:3;142:11;

 159:8;163:23;164:20;

 173:7,14,15,17;

 176:12;177:11,14;

 113:4,4;114:1;

 117:17,19;120:25;

 121:1;122:19;123:22;

 125:7;139:22;140:12,

 24,24;145:13;155:6;

 166:6;170:12;177:3;

 184:18;190:12,12 

two-square (1)

 19:19 

two-year-olds (2)

 189:22,23 

Ty (11)

 157:4;161:4,4;

 165:20;172:13,15,16;

 174:21;175:9;176:7,9 

Tyler (1)

 207:10 

type (5)

 124:25;125:3;

 140:5,9;210:4 

types (5)

 57:17;94:1;182:3;

 188:4;192:19 

typing (1)

 76:15 

19:23 

underestimated (1)

 89:1 

undergone (1)

 104:20 

underground (1)

 104:23 

underlying (1)

 53:9 

undermined (1)

 80:24 

undermines (4)

 80:2,4,7,14 

undermining (1)

 80:19 

underrepresented (1)

 128:17 

Undersecretary (2)

 151:10;157:12 

underserved (2)

 162:1;163:13 

understands (2)

 111:8;198:15 

understood (1)

 209:25 

undisputed (1)

 59:20 

unforeseen (1)

 4:18;6:6,18,19,25;

 10:18,19;11:9 

unmuted (4)

 58:9;97:21;144:2;

 201:1 

unnecessary (1)

 141:12 

unpackage (2)

 29:17;46:7 

unstable (1)

 69:25 

untrue (1)

 183:14 

unwanted (3)

 118:9,10,15 

up (122)

 6:5;7:7;12:13;

 13:23;14:8;16:25;

 17:18;18:2,5;20:4;

 23:18;26:1,9;30:13;

 31:3;32:21;33:20;

 40:6;43:9;47:4,6,18;

 48:14,22;50:21,25;

 55:18;56:10;58:2,7;

 59:6;60:15,18;61:6;

 63:13,16,22;66:13;

 67:3;69:20;70:12;

 71:21;73:4,6,22;75:5;

 14:14 

upon (2)

 113:5;217:22 

upper (2)

 5:12;6:9 

uptake (3)

 82:13;86:24;119:17 

upwards (1)

 117:9 

urea (5)

 169:13,14,19,20;

 171:1 

urge (4)

 27:22;95:5;100:5;

 112:8 

urgency (1)

 167:20 

urgently (1)

 210:16 

USA (1)

 196:18 

usage (1)

 117:25 

USDA (68)

 8:9;14:18,19;15:16;

 19:6,25;30:23;50:4;

 52:20;56:6;72:17;

 73:5,18;74:11,24;

U 

182:20;201:14,14; Uh (1) 216:4 77:6,14;78:16;81:4; 77:4;79:7;80:1,4;

 206:12;215:1 10:18 unfortunately (4) 82:22;83:4;85:15; 87:13;90:18;93:25;

Tuhy (10) Ukraine (2) 116:7;139:13,14; 89:5;90:2,16,24; 105:22,23;107:24;

 143:24;149:5; 46:16,18 222:5 97:18;98:13;102:20; 114:25;122:13;

 157:3,7,9,9;159:14; ultimately (2) unhealthy (1) 103:19;106:10; 135:19;138:11;

 160:6,9;161:2 99:22;178:25 206:21 109:21;112:3;113:23; 141:18,25;148:5,12;

tumultuous (1) um-hmm (1) unified (4) 120:6;122:6;126:19; 158:11;164:9,12;

 122:15 31:21 34:12;73:11;76:21; 127:8;129:15;131:12; 166:1,19;173:11;

tuned (1) Um-hum (20) 206:8 135:3;139:4,18; 174:14;177:17;

 143:18 26:14;31:1;32:16, uniform (2) 140:1;142:20,22; 179:25;180:1;183:6;

Turkey (4) 16;38:9,13;46:25,25; 57:17;193:5 143:23;144:24;145:9; 187:10;190:6,9,23;

 49:25;52:20;53:4; 77:8;96:19;97:6; unifying (1) 148:23;149:4;152:5; 201:21;202:7;204:14;

 55:19 113:19;114:17; 129:23 154:15,16,20;157:3; 206:4,11,15;209:13,

Turkish (8) 138:25;160:22,22; uninspected (2) 161:3,18;164:5,10; 18,20,23,25;210:15,

 49:16,18,20;50:1; 170:1,5;171:7;177:5 19:5;21:19 167:20;172:13;173:9; 16,19;211:24;220:7,

 52:21;53:19;56:15,20 unable (1) unintentional (1) 174:13;178:12; 16,20,25;224:4 

turn (9) 4:18 44:15 181:23;182:12,22; USDA's (9)

 4:11;6:4,7,19;7:13, unanimous (1) union (7) 184:5;189:15;191:11; 65:15;77:16;94:11;

 15;15:22;28:6;109:9 79:25 207:8;219:25; 192:4;195:14;196:10; 105:25;111:25;124:4;

turned (2) unannounced (5) 222:10,11,12;223:14, 200:21,22;201:3,12, 161:22;196:19,25 

48:19;142:16 23:19;154:12,14, 22 18;205:8;207:14,25; use (64)

Turner (3) 18,23 unique (8) 215:1;216:20;217:16, 5:6,7;6:24;7:6;

 11:7,8,12 unaware (1) 16:4;61:17,20; 22;219:12;220:14; 26:23;27:14;34:23;

turns (1) 42:17 64:19;91:4,14;166:5; 221:20;223:8;224:20 40:16;42:12;44:9;

 112:4 Uncle (1) 177:12 update (1) 46:14;56:14;59:16;

Tuscaloosa (1) 39:21 University (2) 131:4 64:8;65:2,4,22;78:3,

 142:23 unclear (1) 72:13;137:22 updated (2) 4;80:3;82:10,15;83:8;

two (44) 122:16 unknown (1) 40:12;94:13 86:8;88:6,10;89:3;

 8:5;9:2;12:22; Under (9) 59:10 updates (2) 90:12,14,14;98:23;

 13:15;14:8;16:9; 12:4;15:7;37:12; unleashing (1) 124:22;132:3 99:14,21;100:1,6,20,

 22:19;26:24;29:23; 66:5;81:21;88:19; 91:7 updating (1) 24;101:4,6;103:10;

 30:14;31:24;32:1; 98:15;179:4;210:2 unless (7) 132:14 105:6;106:17;107:22;

 35:18;41:14,15;46:8; undercut (1) 25:10;37:21;49:20; upfront (1) 108:3;117:8,14,24;

 50:12;55:16;74:8; 20:13 54:17;172:3,3;179:6 137:8 118:21;119:2,3;

 88:13;90:4;98:14; undercutting (1) unmute (8) uphold (1) 121:22;133:6,19; 

Min-U-Script® Burke Court Reporting & Transcription (40) true - use 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 1 

October 17, 2023 

140:6,14;142:20;

 143:17;146:19;153:3;

 166:23;169:19,23;

 193:8;210:10 

used (45)

 40:15,16;41:1;45:3;

 46:15;58:25;59:13;

 60:17,23;61:2;62:4;

 63:5;64:16;65:14;

 67:17;80:12;82:2,22;

 83:2,14;86:1;87:7;

 89:17;91:25;92:3,12;

 96:15;101:2;102:11;

 103:6;118:7,9;130:7,

 18,22;133:21;140:15,

 16;142:22;167:3;

 168:14,19;193:10;

 212:25;224:22 

useful (5)

 51:24;82:20;152:9;

 155:18;198:18 

users (1)

 64:7 

uses (1)

 187:25 

using (14)

 20:20;77:3;88:10;

 91:25;100:21;101:23,

 24;114:9;128:23;

 130:9;146:1;157:15;

 170:9;171:3 

usual (3)

 33:23;34:6;103:15 

utmost (2)

 100:8;192:20 

33:7;208:25;213:8 

variables (1)

 75:15 

variation (4)

 96:8,24;133:13,14 

variety (4)

 65:22;81:25;

 176:21,21 

various (5)

 65:4;67:7;81:19;

 82:4;100:7 

vast (4)

 20:2;21:1;82:2;

 209:12 

vector (1)

 82:17 

veg (1)

 20:17 

vegetables (3)

 25:17;77:5;192:16 

verboten (1)

 39:24 

verification (4)

 47:10;72:16;73:19;

 74:17 

verify (1)

 47:11 

verifying (1)

 32:24 

versions (1)

 80:14 

versus (9)

 46:5;57:2,19;61:24;

 120:18;132:7;136:20;

 152:19;169:22 

vertical (1)

 175:5 

Veterinarians (1)

 92:10 

144:10 

violated (1)

 19:20 

virtual (4)

 7:25;104:9,13;

 123:23 

virtually (1)

 184:1 

vision (3)

 161:16;206:8;207:2 

visit (1)

 5:21 

visited (1)

 24:17 

vital (1)

 206:1 

vitamins (1)

 191:17 

voice (7)

 98:13;106:16;

 129:23;158:24;200:6;

 203:1;221:4 

voices (2)

 104:11;224:11 

volume (1)

 117:10 

volumes (1)

 152:10 

voluntary (1)

 27:15 

volunteer (1)

 144:8 

vote (2)

 80:20;119:6 

vulnerable (1)

 122:22 

watchdog (1)

 18:11 

water (15)

 64:14;79:13;82:13;

 94:24,25;99:21,22;

 100:2,19;101:18,21;

 102:18,19;103:1;

 210:13 

waters (1)

 82:12 

wateryou (1)

 102:21 

way (58)

 6:17;11:11;14:15;

 15:19;18:3;22:12;

 24:11;28:23;49:9;

 52:6,13;57:17;70:8;

 77:16,19;84:23;90:6;

 91:15,18,20;93:21;

 99:2,19;100:23;

 111:21;114:3,7;

 116:1;133:9;137:2;

 138:6,15;141:9;

 145:8,16;146:9;

 147:14;150:17;

 154:11;162:15;169:1;

 180:24;183:19;185:4,

 19;187:11;201:4,13;

 204:24;206:3,24;

 214:1,4,18;216:12;

 218:16;220:12;

 221:24 

ways (9)

 66:24;69:18;115:2;

 124:4,21;166:11;

 182:2,11;211:7 

web (1)

 8:9 

webinar (6)

 207:15 

weekly (1)

 146:22 

weeks (2)

 41:25;123:6 

weighed (1)

 89:18 

welcome (11)

 4:5;7:21;9:24;41:4,

 6;87:17;102:4;

 103:14,24;172:12;

 205:15 

welfare (6)

 123:8;183:8;202:5;

 210:6;212:8,12 

well-considered (1)

 223:18 

well-worn (1)

 34:3 

weren't (2)

 190:8;216:3 

West (3)

 177:4;213:17;216:5 

Western (1)

 25:21 

whammy (1)

 197:23 

what's (16)

 4:14;34:3;35:25;

 42:5;53:21;54:25;

 71:1;73:10;87:12;

 88:17;89:12;136:20;

 137:3;183:1;198:22;

 218:11 

wheat (1)

 189:20 

whenever (2)

 115:6;170:13 

whereas (1)

V 

W 

vaccinate (1)

 202:4 Via (4) Wade (16) 5:24;8:5,16;11:23; 108:11 

vaccines (3) 16:12;99:21;131:1; 189:17;192:4; 139:14;225:4 where's (1)

 61:15;149:14,15 202:8 195:14,17,19,20; Webinars (2) 77:21 

vacuum (1) viability (1) 197:20;198:4,8,24; 4:6;8:5 Whereupon (3)

 111:10 180:4 199:13,16,23;200:11, website (5) 93:6;165:13;225:4 

valiant (1) viable (1) 20;203:6 5:25;8:10;71:16; wherever (2)

 209:22 117:18 wains (1) 137:12;143:12 4:22;8:1 

validate (1) VICE (7) 140:6 Wednesday (1) whey (1)

 47:11 9:17;16:1;135:7; wait (3) 71:1 46:15 

validated (1) 144:11;175:11;176:6; 85:13;208:1,9 weed (9) whistling (1)

 133:6 192:7 waiting (1) 82:16,20;109:25; 90:25 

validation (1) video (2) 4:7 200:22,24;205:18,21, white (5)

 47:11 6:4;17:11 walk (2) 23;207:19 114:14,15;161:20;

Valley (7) view (10) 142:24;169:17 weeding (1) 186:19;209:18 

25:21;26:17;28:4, 5:5,10,12,13,14,18; walking (1) 20:17 whole (19)

 24;30:11,24;33:4 23:6;47:9;90:18; 55:7 weeds (1) 35:2;37:11;46:3;

value (19) 120:10 war (1) 185:20 73:9,13;76:21;77:23;

 33:8;66:25;68:10; viewing (1) 46:16 week (22) 88:9;102:23,23;

 79:4;95:2,16;107:5; 23:14 warranted (1) 8:6,6;12:1,3,8; 109:15;110:14;

 148:21;161:14;163:8; village (1) 108:18 33:24;43:7;48:12,13; 112:13;150:24;

 167:13,13,14;174:7; 54:21 Washington (2) 70:25;71:20;73:1; 157:14;164:17;

 188:10,12;190:10; vineyard (1) 50:22;82:18 78:11;85:12;103:17; 191:21;215:25;

 217:23;219:2 147:4 waste (1) 135:1,2;148:25; 218:18 

value-added (3) Vineyards (1) 193:16 151:9;157:12;164:17; wholesale (1) 

Min-U-Script® Burke Court Reporting & Transcription (41) used - wholesale 

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October 17, 2023 

49:17 

who's (4)

 4:12;75:7;158:25;

 205:18 

whose (2)

 14:11;25:22 

who've (1)

 168:9 

Wicks (15)

 157:5;161:5;

 165:20;172:14;

 178:12,15,16;180:25;

 182:4,6,9;183:9,13,

 24;184:4 

wide (5)

 93:17;102:1;148:6,

 6;213:18 

widely (1)

 209:14 

wider (1)

 223:2 

wife (10)

 172:17;201:11;

 208:18;209:7;211:8,

 14;214:16;219:11,21;

 222:2 

wildly (1)

 137:7 

Wiley (1)

 15:7 

William (2)

 63:22,24 

Williams (4)

 78:18;81:6;85:17;

 92:25 

willing (10)

 22:11;49:6;70:12;

 73:22;204:12,12;

 205:1;217:10,11,11 

willingly (1)

 92:5 

willingness (1)

 151:25 

win (1)

 211:3 

window (4)

 20:12;52:12;86:24;

 96:10 

windscreens (1)

 82:16 

wine (35)

 35:19;36:2;117:6,

 10,17;118:5,14,19,20;

 119:2,3,7;120:6,17,

 18;121:3,10,12,13;

 144:16,18,25;145:2,

 20,23,24;146:2,5,6,6,

 7,9,19,20;147:2 

winemaker (1)

 145:24;147:5 

winery (1)

 118:25 

wines (16)

 117:12,15,21;

 118:1,11,13,15,18,23;

 119:5,21;121:2,16;

 144:18;145:16;146:8 

winter (2)

 82:5;97:14 

Wisconsin (1)

 25:22 

wise (1)

 147:22 

wish (4)

 12:19;154:18;

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wishes (1)

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within (16)

 42:7;47:19;94:4;

 99:6;164:12;166:2,

 22,25;168:15;188:8,

 16;195:2;210:7;

 212:7,7;215:5 

without (22)

 28:11;51:8;74:12;

 104:24;111:5;116:5;

 117:23;118:24;

 127:20;137:7;146:19;

 152:24;167:6;179:22;

 182:2;193:12,15;

 196:4,20,22;213:9;

 220:22 

witness (1)

 175:23 

Wolfe (1)

 33:25 

Wolfpack (1)

 72:11 

wonder (5)

 30:14;57:15;

 152:21;200:5,9 

wonderful (4)

 42:21;126:18;

 142:24;189:25 

wonderfully (1)

 103:16 

wondering (12)

 16:3;22:11;33:5;

 60:17;75:8;109:12;

 126:18;146:24;148:4;

 155:2;160:18;169:14 

Wood (3)

 11:7,9,13 

word (6)

 106:18;165:25;

 196:14;197:3;199:6;

 224:13 

work (79)

 9:4;12:7;14:6;

 15:14,19;20:6;22:21;

 23:16;26:21,22;33:7;

 43:16,22;54:16,19;

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 72:7,10;77:3;83:9;

 85:22;86:23;87:10;

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 95:23;97:12,14;

 98:22;99:1;103:6,7;

 104:25;106:25;

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 17,22;155:3;156:15;

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 8;179:3;183:17;

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workable (1)

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worked (9)

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workers (1)

 14:11 

workforce (1)

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working (27)

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workload (2)

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works (4)

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workshop (1)

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workshops (2)

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world (9)

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worn (1)

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worry (2)

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worse (2)

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worst (2)

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worth (9)

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wow (2)

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wrap (1)

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wrecks (1)

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wrestling (1)

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wrinkle (1)

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writing (4)

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written (39)

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 64:22;69:4;72:23;

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 98:8,18;105:15;

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 179:11;192:22;

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wrong (2)

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wrote (2)

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WSCA (3)

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WSCA'er (1)

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196:11;219:14 

yearlings (1)

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years (45)

 14:17;21:7;23:12;

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 17;44:21;52:14;53:4;

 58:19;72:8;74:10;

 91:23;98:25;104:15,

 18;111:14,16;117:11;

 120:13,20;127:5;

 135:14;139:22;

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 157:10;158:18;

 160:11;164:3;173:4;

 184:15;185:15;

 201:17;202:15;

 211:15,19;216:25;

 220:2 

yeast (1)

 34:20 

Yep (1)

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yesterday (1)

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yields (1)

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York (1)

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young (1)

 186:7 

Youngblood (7)

 116:20;122:6,9,10;

 125:1;126:23;128:11 

Z 

Zamora (2)

 11:14,15 

zero (5)

 42:18;174:3;

 175:23;203:12;212:3 

zoned (1)

 214:24 

Zoom (12)

 4:15,19,21;5:1,10;

 6:9,21,22;7:8;9:5,6;

 13:17 

zoomhelpdesk@supportzoomux (1)

 5:22 

X 

xanthan (1)

 64:13 

Y 0 

year (25)

 17:13;20:2;23:6,16;

 25:18;28:22,25;

 32:24;39:2;50:8;

 53:25;68:16;94:5;

08 (1)

 172:20 

1 

144:10 words (10) 75:7 96:15;124:23;127:8; 1,000 (3)

winemaking (1) 114:5;116:5; worried (2) 143:15;145:25; 54:19;55:11;143:6 

119:2 140:12,16,24,25,25; 91:6;110:11 149:17;156:5;184:2; 1,048,575 (1)

wineries (2) 143:8,16;166:24 worries (3) 190:18;192:20; 65:16 

Min-U-Script® Burke Court Reporting & Transcription (42) who's - 1,048,575 

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1.16 (1)

 65:17 

1:00 (1)

 40:1 

10 (9)

 19:12;34:13;74:10;

 145:25;149:20;

 157:10;173:2,4;

 200:17 

10,000 (1)

 129:20 

100 (2)

 25:10,11 

100/ppm (1)

 121:14 

10-pound (1)

 160:17 

12 (1)

 145:25 

12- (1)

 30:20 

12,212 (1)

 65:17 

12,500 (1)

 219:12 

12:00 (1)

 4:2 

12-month (2)

 28:24;31:16 

137 (2)

 59:13;61:6 

140 (1)

 168:18 

15 (4)

 92:24;93:5;160:11;

 173:2 

150 (1)

 168:18 

16 (1)

 202:15 

1600 (1)

 26:21 

17 (1)

 146:4 

17th (1)

 122:17 

18 (1)

 146:4 

19 (1)

 225:5 

1980 (1)

 217:7 

1980's (1)

 92:2 

1988 (2)

 86:2;91:11 

200:17 

20,000 (1)

 23:20 

2004 (1)

 195:22 

2006 (1)

 201:4 

2007 (1)

 201:5 

2009 (2)

 208:21;219:19 

2012 (1)

 40:6 

2013 (1)

 40:6 

2014 (1)

 40:6 

2016 (1)

 178:22 

2017 (5)

 58:15;63:5,11;

 104:19;127:8 

2018 (3)

 77:2;122:18;126:10 

2020 (2)

 173:3,5 

2023 (6)

 65:11,16;67:16;

 161:23;162:19;225:5 

2024 (4)

 60:5;68:11;123:25;

 129:10 

20th (1)

 68:11 

2-1/2 (1)

 106:22 

2119m (2)

 87:4;88:19 

22 (2)

 127:8;144:17 

2500 (1)

 192:13 

25b (2)

 60:25,25 

2611 (1)

 47:22 

2611-1 (1)

 44:17 

2613 (1)

 44:12 

3 

3 (2)

 50:2;53:20 

30 (5)

 26:22;28:19;50:7;

 90:23;184:15 

30th (1)

 122:19 

32 (1)

 161:23 

32nd (1)

 165:4 

340 (1)

 168:19 

35 (1)

 160:10 

37 (1)

 184:15 

8.5 (2)

 101:19;102:21 

80 (1)

 82:21 

80's (1)

 157:16 

8th (1)

 65:7 

9 

9:00 (1)

 225:5 

90 (1)

 82:21 

90-plus (1)

 114:8 

90's (1)

 120:20 

95 (1)

 38:11 

99 (1)

 101:5 

4 

4 (3)

 73:7;169:21;171:6 

4.4 (1)

 65:18 

40 (5)

 22:25;23:3;52:14;

 72:8;98:24 

5 

5:28 (1)

 225:4 

50 (3)

 22:25;23:3;52:14 

50,000 (1)

 145:24 

50,000-acre (1)

 172:18 

500 (1)

 192:15 

542 (1)

 65:18 

55 (1)

 169:12 

56 (1)

 144:13 

6 

60 (1)

 104:18 

605 (8)

 34:17,21;35:14;

 36:12;37:11,16;39:6,

 11 

61 (1)

 4:7 

7 

7 (1)

 167:1 

7.2 (1)

 101:20 

72 (2)

 42:10,19 

2 8 

2:00 (1)

 40:1 

20 (4)

 19:12;58:19;90:23;

8.2 (1)

 102:19 

8.4 (1)

 101:19 

Min-U-Script® Burke Court Reporting & Transcription (43) 1.16 - 99 

(973) 692-0660 
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 UNITED STATES DEPARTMENT OF AGRICULTURE

 NATIONAL ORGANIC PROGRAM

 NATIONAL ORGANIC STANDARDS BOARD (NOSB)

 FALL 2023 ORAL COMMENT WEBINARS

 Thursday,

 October 19, 2023, 12:00 p.m., EST

 Held via Zoom for Government Webinar 
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2

 National Organic Standards Board (NOSB) Members

 Nate Powell-Palm, NOSB Chair

 Mindee Jeffery, NOSB Vice Chair

 Amy Bruch, NOSB Secretary

 Brian Caldwell

 Jerry D’Amore

 Carolyn Dimitri

 Kim Huseman

 Allison Johnson

 Kyla Smith

 Nate Lewis

 Dilip Nandwani

 Logan Petrey

 Franklin Quarcoo

 Wood Turner

 Javier Zamora (absent) 
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3

 USDA/National Organic Program staff 

Michelle Arsenault, Advisory Committee Specialist

Erin Healy, Division Director of Standards

 Jared Clark, National List Manager, Standards

 Andrea Holm, Agricultural Marketing Specialist, Standards 

Johanna Mirenda, Agricultural Marketing Specialist, 

Standards

 Heather Kumar, NOSB Technical Support Staff

 Esu Obu, NOSB Technical Support Staff 
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 P R O C E E D I N G S

 (Time: 12:00 p.m.) 

MS. ARSENAULT: All right. Welcome, folks. I have

 the top of the hour. 12 o'clock. Welcome to Day 2 of the

 National Organic Standards Board public comment webinars. 

If you're online with us, you should see an

 instruction slide with some instructions for attendees and

 speakers. If you're only on the phone with us, I'm going to

 summarize the slides so you can know what's going on over here. 

The chat is enabled. You'll find that in the center

 of your Zoom task bar, so you can chat with each other or relay

 technical difficulties. But the chats are not part of the

 public record, and are not a public comment, the board members

 will not be answering questions in the chat, nor will the

 program unless it's technical in nature. 

The closed captioning is available in Zoom by

 clicking the live transcript button, which is on your Zoom

 taskbar, somewhere in the middle. You can control your own

 view and font size. You can turn it off or on if you didn't

 want to see it either. 

Please do not use the raised hand feature. All

 commenters registered ahead of time and will be called on in

 turn. You can customize your own view in Zoom. So you can

 rearrange what you see on your personal screen. If you go to

 your -- the upper-right corner, you'll see a view button. You 
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5

 can usually toggle between gallery view and speaker view.

 And also a little tip when we share a PowerPoint

 slide. If you click exit full screen, it will minimize the

 Zoom window so you can actually get to other things on your

 desktop. It won't take over your entire screen.

 And don't worry, changing your screen isn't going to

 affect anyone else's. We won't be able to see what you're

 doing over there.

 We're going to spotlight the speaker timer for

 everyone on the screen. That will be in my Zoom tile. So that

 should remain on your screen no matter what view you're using.

 If you're having technical problems, please visit

 support.Zoom.US. You can chat with them, call them, email them

 to get things taken care of. Generally, if you log out of Zoom

 and back in, it fixes all the problems that you may be

 experiencing.

 The webinar is being recorded, and I'll start the

 recording shortly. Actually, why don't I just start it now

 while I'm thinking about it.

 All right. So we are recording. And we'll also have

 transcripts after the in-person meeting ends next week and we

 need a couple weeks to get the transcripts. We'll post them on

 the NOP website for you.

 All right. Slide 2 for speakers. Please make sure 

that the name displayed in your video tile is correct so we can 
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 locate you when it's your turn to speak. You should be able to

 rename yourself by clicking the participant's list. There's

 three dots next to your name under more. And do keep an eye on

 the chat box. If you're scheduled to speak and we can't find

 you in those participants, we may chat to make sure -- so you

 can confirm for us that you're on the line. 

Sometimes if you call in on the phone, it doesn't

 connect your name to your phone number, so we may have

 difficulty finding you if you didn't give me your phone number

 when you registered. 

We'll ask each commenter to unmute when you're called

 upon so you can -- you'll get a pop-up message on the screen

 that says the host has asked you to unmute yourself. So please

 unmute yourself, turn your camera on if you want. That's

 optional. You don't have to be on camera. Both the mic and

 the camera are in your Zoom task bar in the lower left side, if

 you have trouble finding it. 

If you're on the phone only and you don't have a mute

 button on your phone, you can hit star 6, and that will toggle

 between mute and unmute. When you come to the mic after Nate

 calls your name, and we get you unmuted, you're going to state

 your name and affiliation for the record at the start of your

 comment so the transcriptionist who is on the line with us can

 capture that. 

Each commenter will have three minutes to speak, and 
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 we'll use a timer that will sound when your time is up. When

 you hear the beep, please finish your sentence. The timer,

 again, will be visible in my video tile on the screen at all

 times.

 I'm going to test the timer here for you guys, see if

 you can hear it. I know you can't see it at the moment, but

 did everyone hear that beep? Okay. I got mixed reviews

 yesterday -- on Tuesday. Some people could hear it and some

 people didn't hear it at all.

 All right. Now I'm going to turn the mic over to

 Erin Healy, who is the director of the Standards Division at

 the National Organic Program to officially call the meeting to

 order. Erin.

 MS. HEALY: Thank you, Michelle. Hello.

 Today is a continuation of our two-day public comment

 webinars. So welcome back to those who attended on Tuesday.

 And welcome to those who are attending for the first time

 today.

 We are very grateful to be able to hold these

 sessions virtually. It allows for people to attend from

 wherever they are. To our public commenters, thank you for

 engaging in this process that shapes policy. It's always

 exciting to see democracy in action. I also thank our

 audience. You are an important part of the public meeting 

 process. 
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After today's webinar, we will meet in person next

 week in Providence, Rhode Island. We do plan to livestream

 that meeting, as we did last spring. Meeting access

 information for all meeting segments is posted on the NOSB

 meeting page on the USDA website. And transcripts for all

 segments will be posted once completed. 

This meeting, like all meetings of the National

 Organic Standards Board, will be run based on the Federal

 Advisory Committee Act, as well as the Board's policy and

 procedures manual. I will act as the designated federal

 officer for these webinar segments. And Nate Powell-Palm, our

 Board Chair, will facilitate the session. 

We remind everyone that this is an open and

 transparent process, so please do be respectful of each other

 and avoid any personal attacks. This extends to the chat

 messages as well. So even if you disagree with a speaker's

 position, please be sure to provide them the same respect and

 grace that you would like for yourself. 

And to close, I do want to thank the NOP team and

 acknowledge all of the hard work that goes into these webinars

 and the meeting. So if we could give a Zoom round of applause

 to Michelle Arsenault, Jared Clark, Andrea Holm, Joanna

 Miranda, and our two new NOSB technical support staff members,

 Esu Obu and Heather Kumar. 

I am always impressed by this team. It's very smart 
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 folks who really care about the organic program, and I'm

 grateful to work with them every day.

 So I will now hand the mic back over to you,

 Michelle, to do a roll call of the Board members.

 MS. ARSENAULT: Thank you, Erin. All right. Nate

 Powell-Palm.

 CHAIR POWELL-PALM: Present. Good morning.

 MS. ARSENAULT: Good morning. Mindee Jeffery.

 VICE CHAIR JEFFERY: Good morning.

 MS. ARSENAULT: Good morning, Mindee. Amy Bruch?

 BD. MEM. BRUCH: Good morning from the Midwest.

 MS. ARSENAULT: Good morning, Amy. Brian Caldwell?

 BD. MEM. CALDWELL: Hi, everybody.

 MS. ARSENAULT: Excellent. Good morning, Brian.

 Gerard -- Jerry D'Amore.

 BD. MEM. D'AMORE: Greetings from California.

 MS. ARSENAULT: Hello, Jerry. Carolyn Dimitri.

 BD. MEM. DIMITRI: Hi everyone.

 MS. ARSENAULT: Good morning, Carolyn. Kim Huseman.

 BD. MEM. HUSEMAN: Present.

 MS. ARSENAULT: Thanks, Kim. Allison Johnson.

 BD. MEM. JOHNSON: Hello. Good morning.

 MS. ARSENAULT: Hello, Allison. Kyla Smith.

 BD. MEM. SMITH: I'm here. Hi, everybody. 

 MS. ARSENAULT: Good morning, Kyla. Nate Lewis. 
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 BD. MEM. LEWIS: Present.

 MS. ARSENAULT: It was very low volume there, Nate.

 There you go. But I see you and I kind of heard you. Dilip

 Nandwani.

 BD. MEM. NANDWANI: Good morning.

 MS. ARSENAULT: Good morning, Dilip. Logan Petrey?

 BD. MEM. PETREY: Good afternoon.

 MS. ARSENAULT: Hello, Logan. Franklin Quarcoo.

 BD. MEM. QUARCOO: Present.

 MS. ARSENAULT: Hello, Franklin. Welcome. Wood

 Turner.

 BD. MEM. TURNER: Hey there, good morning.

 MS. ARSENAULT: Hello, Wood. And Javier Zamora.

 (No response.)

 MS. ARSENAULT: All right. I note Javier is absent.

 And, Nate, I think that conducts all of the administrative

 duties, and I will hand the mic off to you now.

 CHAIR POWELL-PALM: And it is with great joy that I

 will take said mic. Thank you, Michelle.

 Gosh, I tell you. After last call on Tuesday, I had

 to sit for a minute and just reflect on how in this format we

 got more farmers to call in in a single day than from what I

 hear ever in the history of the Board. And that is just really

 cool to think we're moving in that direction, where we have a

 platform. We have a format where we are hearing from the folks 
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 who are in that supply chain, doing the good work every day.

 So I am just so grateful for everyone who called in on Tuesday.

 Really looking forward to our speakers to day.

 And with that, let's just run through a little

 housekeeping. So a reminder that there is a policy in the

 policy and procedures manual about public comment. Here's your

 slide. All speakers who will be recognized signed up during

 the registration period. Persons must give their names and

 affiliations for the record at the beginning of the public

 comment. Proxy speakers are not permitted.

 Individuals providing public comment shall refrain

 from making any personal attacks or remarks that might malign

 the character of any individual. I would say we did a fabulous

 job of that Tuesday. I don't think we had a minute of

 hesitation to really keep it classy. So thank you, everybody.

 Members of the public are asked to define clearly and

 succinctly the issues they wish to present before the Board.

 This will give NOSB members a comprehensible understanding of

 the speaker's concerns.

 I will call on speakers in the order of the schedule

 and will announce the next person or two so they can prepare.

 Please remember to state your name and affiliation and then

 we'll start the timer.

 Board members will indicate to me if they have any 

 questions, and I will call on them. Only NOSB members are 
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 allowed to ask questions. 

So our first speaker of today is going to be Mike

 Dill. Mike, if you are there, thank you for kicking us off

 today. 

MR. DILL: Yeah. And I'm excited to be first and

 being the one to kick us off. So good morning, good afternoon,

 organic community. My name is Mike Dill and I'm representing

 the Organic Produce Wholesalers Coalition, otherwise known as

 OPWC. 

My comments today are on oversight improvements to

 deter fraud and supporting transition. With regard to the GPS

 proposal, OPWC does not thing this proposal creates a strong

 fraud prevention practice, but we will not oppose the

 recommendation that it be implemented via guidance if the

 organic community collectively agrees that it will be helpful. 

As explained in our prior comments, we assert that in

 the fresh produce supply chain, the proposal will do very

 little to aid in attracting and verification of organic status

 for purchase if it fails, even if the GPS coordinates of

 certified fields are made public. 

If the NOP is to provide guidance to certifiers,

 please consider the following perspective, which we elaborate

 in our written comment. One, collection of GPS data should be

 the responsibility of certifiers, not growers. GPS information

 should be recorded via -- or should not be recorded via the 
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 organic system plan. Do not use the center of the field as the

 marker. Take readings of an identifiable location that is

 accessible at all times. Have trained inspectors take GPS

 reading on approved devices. And lastly, requires certifiers

 to the record field's -- the inspector's visit during their

 audit.

 Related to the discussion about improving support for

 transition, we'd like to summarize a few suggestions which are

 further explained in our written comments. We suggest defining

 the term "transitional land" to differentiate land that is

 eligible for certification from land that is in a state of

 transition. That is the land that's undergoing biological

 changes, such as from an extractive to regenerative state, or

 from a sterile soil to microbiologically active soil.

 Specific to land and crop production, both the Alpha

 and NOP regulation only focus on eligibility of land and crops,

 whereas the organic community has historically used the concept

 of transition to refer to both eligibility and a change in the

 agro-ecology of the land through organic management.

 Second, let's not forget about the early leaders of

 the organic movement when we're talking about transition

 programs. For more than 50 years, these producers have been

 transitioning land, developing organic systems, and producing

 organic crops. They forged forward without mentors, federal

 grants, technical assistants, and at times without even market 
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 support.

 As these growers begin to step aside or are forced

 aside as the market adjusts to an influx of new organic

 producers, we suggest that there be technical assistance

 related to succession planning, transfer of ownership, and

 financial pathways to help them as they transition out of

 farming or pass-through operations on new farmers.

 And last, OPWC asserts that training, mentorship

 programs, and technical assistants also be specifically focused

 in preparing farmers to take over existing organic farms and

 create a system for transitioning farmers themselves, not just

 land, as this can help prevent the loss of acres to

 conventional management or development. Sorry for going over.

 Thank you.

 CHAIR POWELL-PALM: Nice --

 MR. DILL: -- logo. Organic is the answer. I love

 it.

 CHAIR POWELL-PALM: I wonder who came up with that.

 We'll talk about it just in a second. But, Logan, please kick

 us off.

 BD. MEM. PETREY: Hey. Thanks, Mike. I've got a

 question about the transition. Do you -- I'm glad we're

 excited about it. We've had a lot of farmers in the previous

 day talk about the demand manning an issue. Do you see that as

 an issue more on the -- you know, on your side of things? If 
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 we expand a lot of growers, we're adding to the supply. What's

 your thoughts on demand?

 MR. DILL: We are very concerned about it, actually.

 I'm all for transition support. I'm all for increasing organic

 acreage. But I am concerned that we are going to transition

 growers and they're not going to have market for those

 products.

 We did a survey of our growers, and remember, we're

 talking about fresh produce, specialty crop growers only. But

 we surveyed our supply chain last year, and a vast majority --

 I mean, we're talking like 40 -- it was like 40, 50 percent

 said that they could already grow more than what they're doing,

 but the market -- they didn't have markets for it. And then we

 also asked --

 BD. MEM. PETREY: So the current --

 MR. DILL: Oh, go ahead.

 BD. MEM. PETREY: So the current organic farmers

 would expand their current production if the demand was easily

 there?

 MR. DILL: Yes. They said they're already in a

 position where they could produce more. And then a lot of --

 we also ask if growers would be interested in expanding their

 operations and they said -- it was kind of a mixed bag. Some

 said yes, they'd like to. Others said not, they're not

 interested. And again, it came back to not having that market 
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 to support their, you know, expansion.

 BD. MEM. PETREY: So the current growth in organics

 right now is limited not because of supply, necessarily, but

 because of the demand, you would say?

 MR. DILL: Absolutely. Yeah.

 BD. MEM. PETREY: Okay.

 MR. DILL: In produce.

 BD. MEM. PETREY: Yeah. In produce, okay. Thank

 you.

 CHAIR POWELL-PALM: Great starting with your

 question, Logan. Thank you.

 Amy, please go ahead.

 BD. MEM. BRUCH: Mike, thanks for your time today.

 Thanks for that awesome website. I'm glad Nate is posting that

 graphic. That's awesome. And thanks for all of your extensive

 written comments. Appreciate the ones on the geo codes. I had

 a question on crop insurance. Just to unpackage, you know,

 what fruit and veggie growers are experiencing in your area,

 you made a written comment about reasons why crop insurance is

 not attractive to growers in your region.

 And you gave two examples. One was diversification

 with geographical region. So if one area fails, at least they

 have the other, essentially, to fall back on. And then the

 other example you mentioned was multiple crops. Again, if one

 crop fails, they have an opportunity to grow another crop. 
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 You know. I think that's great. The

 diversification's great. But do you think if there were

 policies that could protect both regions, for example, that

 growers would be interested in taking on crop insurance, or if

 there was a policy that would cover all the crops that were

 grown by your fruit and veggie producers that they'd be

 interested? Is it the quality of offerings that's the problem

 then that they're self-insuring?

 MR. DILL: I honestly wish I had more information to

 give you. The growers we spoke with had zero knowledge of crop

 insurance. It just wasn't something that they dealt with. I

 mean, they're really familiar with commercial liability

 insurance, and what it takes to get in to work with retailers

 and wholesalers, but when it came to crop insurance, they just

 -- they weren't familiar with it.

 And so -- and the feedback we got is, you know, they

 are -- they've diversified to kind of hedge their bets and make

 sure that they have -- like you said, if something failed, they

 have something to fall back on. They have other crops.

 I did hear two of the growers I spoke with did say

 that they would be interested if they knew more, and if it

 seemed like it would be more helpful. But I think they just

 hear the rumors that it, you know, is not working and so they

 just don't even, like, bother with it.

 So we're in support. We love the direction that 
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 you're going. We're really thrilled that you're, you know,

 taking this seriously and, you know, have it on the agenda, and

 we want to see the conversation to continue. And I'm going to

 try even harder in the next, you know, cycle to get some more

 information and maybe reach out to less diversified growers

 that we're working with.

 BD. MEM. BRUCH: Uh-huh. Thank you so much.

 Appreciate that, Mike.

 CHAIR POWELL-PALM: Allison, please go ahead.

 BD. MEM. JOHNSON: Thanks for your comments, Mike.

 And, Logan, thanks for leading with that question. Mine is a

 follow-up about what we should do to create more markets. I've

 heard similar things that organic producers are actually

 selling into conventional markets because the buyers don't want

 to buy more organic. So I'm curious what you see as

 opportunities to grow that demand?

 MR. DILL: I think food service and institutional

 purchasing is an area that we need to get into. Our feedback

 for the OMDG, the organic market development grant, when they

 did the townhall was to look at institutions and contract, and

 see if there's ways to, you know, increase or create some kind

 of added fund and budget to, you know, have premium products

 such as organic.

 Retailers, I think we -- they're -- they hold the key

 to a lot of this, you know, and I understand from their 
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 perspective, they're, you know, promoting conventional and

 they're promoting organic. They can't -- you know, they

 probably don't want to kill their conventional market by saying

 that organic is the answer and you should be buying organic. I

 wish they would do that, but I think, you know, it's going to

 be hard to grow retail sales. So we're left with institution,

 food service, restaurants, and then direct to consumer.

 But yet, without the retailer support, it's going to

 be tough. But I do believe that we need to put more emphasis

 on this and really try to educate consumers so that they can be

 the ones to pressure the retailers to add more, you know,

 organic. Because the retailers will pretty much only respond

 to the consumer.

 CHAIR POWELL-PALM: Other questions for Mike?

 I'm going to try to be brief because I'll -- I'm sure

 we'll talk about this in Providence next week, Mike, but who do

 you think -- like where do you think the best consumer

 education occurs? When we think about educating consumers on

 organic, is it grocery store shelves? Is it school lunch

 programs? Where do folks, you know, learn the best about this

 and where could we target our energies?

 MR. DILL: Oh, man. I think we have to hit them

 everywhere. I think we need to be in the stores if the

 retailers will, you know, allow it. I think packaging is a

 good, you know, marketing tool. Unfortunately, you know, 
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 produce doesn't have a lot of packaging to do marketing. And

 then I just think of, like, the -- kind of the old school

 approach of painting trucks, billboards on highways. You know,

 some of the basic things that we've walked away from.

 I heard yesterday they talked about, you know,

 bringing back the raisin guy, but I think -- and then Super

 Bowl ads. Whatever. I think we just have to -- we have to be

 creative. We have to be simple. And we have to look at what's

 looking for other folks. And if I look at what the

 regenerative community is doing right now, what Jason Momoa and

 Woody Harrelson, and all these folks, I mean, I -- we have to

 find a spokesperson. We have to find an influencer. You know,

 that's -- that's an approach we need to hit up because it seems

 to be working for them, and we haven't done it yet.

 So whoever the next organic influencer is going to

 be, I think we need to find them. That should be the next

 agenda topic for the NOSB.

 CHAIR POWELL-PALM: Absolutely. Absolutely.

 One less exciting question for you. If I heard you

 right, you like the GEODOC. And we just need to make sure that

 we keep it so that it's all on the certifiers, which it is.

 This has nothing to do with farmers. And if we have to make

 sure that -- and like all privacy data, it's kept exactly like

 we keep all location data now, with the certifier, nowhere

 public. 
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 MR. DILL: I'm totally fine with that. Yeah. Just

 don’t go tromping around in the middle of our fields to find

 the data point still.

 CHAIR POWELL-PALM: All right. Well, we really

 appreciate your comments today. Thank you so much for heeding

 the call of the last many meetings that we need to grow these

 things.

 So the website awesome, Organic is the Answer.

 Thanks so much for all your work.

 MR. DILL: Absolutely. Thank you, Nate. And that's

 OPA for all the information that helped us create Organic is

 the Answer.

 CHAIR POWELL-PALM: And I just want to give a shout

 out to Mindee's background right now too, because there's some

 swag. There's some swag out there that everyone should get.

 All right. Next up -- thanks, Mike. Appreciate you.

 Next up we have Phil Vavercek, and then Bryce

 Irlbeck, followed by Byron Weimer. Phil, if you are there, the

 floor is yours.

 MS. ARSENAULT: Phil is on the phone -- there we go.

 MR. VAVERCEK: Can you hear me?

 MS. ARSENAULT: We can hear you.

 MR. VAVERCEK: Okay. All right. Yeah. My name is

 Phil Vavercek, and I'm a farmer/producer here in eastern

 Nebraska, corn, soybeans, and alfalfa is what I'm producing, 
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 and I'm going through transition and getting into my first

 certified organic crops. This year, we've got a field of corn

 that -- I guess I want to talk about insurance is where I'm

 kind of going with this, and proving our yields.

 This year, we had a really good-looking corn crop and

 like two, two-and-a-half weeks ago, we had a wind storm come

 through, 70, 75 mile an hour reported winds. So obviously,

 that -- most of that is down and will be lost. And our county

 averages -- like, I apologize if I don't have that in front of

 me what they are -- the T-yields that I'll have to be using for

 insurance, but it's going to be considerably less than probably

 what I need and what I was going to produce.

 You know, I guess that's kind of holding me back from

 transitioning more acres. And it takes so many years to

 produce these yields. So many years of corn, and so many years

 of soybeans. And I guess part of my concern or frustration is

 so this year, the yield is going to be poor, which isn't going

 to help me going forward. Next year, I might -- I'll probably

 take that field to soybeans, and then I like to yield alfalfa

 is what I'm thinking in my rotation.

 So you know, it's going to be two, three years before

 I get back to a corn crop and hopefully can produce a good one

 to start proving some yields. And like I said, that's kind of

 holding me back from transitioning some other acres that are

 conventional right now because I do have such good proven 
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 yields and a good insurance base there.

 And I guess my other concern is using alfalfa. Right

 now, I'm just putting hale on that, and it would be nice if

 somehow we could, you know, protect the tons that we're

 producing year in and year out. I am under irrigation. That

 does help. But I do have one farm that is metered and

 restricted to nine inches of water per year. That was alfalfa

 this year. So the first cute cuttings were good. I'd say the

 first and third. The second, fourth, not so good because we

 were in a drought area and I had to watch the amount of water

 that I was using being limited there.

 But again, just -- the insurance part of it, trying

 to prove those years and -- to have a good base level to go off

 of for insurance purposes.

 CHAIR POWELL-PALM: Thank you. Thank you so much for

 your comments. We -- this is a through line. This is a

 problem.

 I'm going to hand off the question first to Amy

 Bruch.

 BD. MEM. BRUCH: Yeah. Phil, thanks for joining us

 today. I know you're super busy in the Midwest with harvests

 this time of year. Sorry to hear about the wind storm that

 happened to you, and sharing the real-life example of what that

 means when our insurance doesn't match our output. It really

 is impactful. 
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 So you mentioned that it's going to deter you from

 potentially transitioning acres. Is that mainly due to kind of

 the revenue that you were expecting on the farm or what was --

 what's the deterrent there for growing your transition?

 MR. VAVERCEK: Yeah. Exactly. My gross revenue,

 exactly. You know, the farms that we're in now, I have good

 insurance levels. Obviously, everything that we farm has been

 affected by the wind -- our corn, I should say. Soybeans were

 done. But yeah, it just -- it makes you think, as you're going

 through these fields, you know, it's -- you always want to get

 the most you can and you know -- most of these fields were

 insured pretty good, but when it comes to the organic, I feel

 that I -- you know, I probably would've been better if it was

 in conventional, if that makes sense. Just with the county T-

 yield being much lower on the organic.

 BD. MEM. BRUCH: Uh-huh. And what would be your

 ideal to transition? How many acres are you still looking to

 maybe add in if -- you know, over time?

 MR. VAVERCEK: Sure. No. I'm at 500 now, you know.

 And ideally, it'd be nice to double that, to do another 500 in

 the near future. But it makes you think, going through a

 process like this right now.

 BD. MEM. BRUCH: Yeah. Sorry, Phil. Sorry to hear

 that. Thanks for sharing your comments, though. I appreciate

 that. 
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 MR. VAVERCEK: Yeah. No. Thank you for the time,

 and listening, and yeah, I appreciate everything that you

 members do on the Board and the support. So thank you

 CHAIR POWELL-PALM: Thank you. We are working on

 this. So really appreciate you taking the time to talk to us

 today. We're inching towards some solutions. SO please keep

 calling in and sharing your stories with us because this is how

 we make change. Thank you, Phil.

 MR. VAVERCEK: Sure. Thank you. Have a good day.

 CHAIR POWELL-PALM: Next up, we have -- thank you.

 Have a good day.

 Next up, we have Bryce Irlbeck, followed by Byron

 Wiemer, and then Bill Wolf.

 MR. IRLBECK: Thank you, Nate. Yes. My name is

 Bryce Irlbeck, and I farm organically in Iowa, and I run an

 organic certification process with the software that we

 developed.

 I've spoken on here a few times, so I want to say

 thank you to everyone that is doing this because I know it's a

 lot of time. It's a lot of commitment. And you're most likely

 doing it for free. So thank you.

 Today, I want to talk about two things. Number one,

 being the imports that are coming in; and number two, just

 being -- talking through the investments into organic and what

 we're doing as a collective group. So as mentioned probably by 
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 future speakers and prior speakers, the suspected fraudulent

 imports allowed by essentially us, because we're not doing

 enough to stop it as a group, or to understand what's going on,

 have real life effects on the farmers. And this comes from a

 lack of oversight. If you want to find the ports with the most

 lax regulations, and they're all different regulations, you're

 going to go to the ones that organic are coming in.

 The lack of control, as an organic farmer, I have to

 bring back my grain all the way to the end user, and it's very

 hard to even find where a lot of this grain is coming from,

 countries of origin, and then just a lack of common sense for

 us.

 It's -- we're importing millions of bushels of Brazil

 over the last couple of months, and nobody's really asking

 questions about it, it seems, from our level. So it's all of

 us as a collective, organic group that need to step up and do

 that. Or we are and will lose more farmers in the organic

 space. It's costing a lot of money to about break even to lose

 money too, for a lot of hard work for the Midwest farmers, and

 I speak for grain farmers because that's what I am. I don't

 know the veggie space or anything else like that.

 So it is severely impacting people, and they are

 taking a hard look at being able to produce this for people to

 eat. So as a farmer, then as a processor, as we're selling

 grains, it is becoming evidence the processors are bearing a 
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 lot of this too, and I worry about processing staying open,

 staying viable in the long run with a lot of this stuff that's

 coming in through the ports. They have been told by a few it's

 easier to idle them. They lose less money just idling them and

 not running any organic in the Midwest than it is running the

 few that they can.

 Imports is a very near and dear to our hearts, and

 it's something that I think we should all take seriously as a

 group, and the NOSB Board help take the lead on that.

 The last two things that I have, or the last thing is

 the investments into organic. And I read lately that the hemp

 industry has about $15 billion from the USDA that goes into the

 -- helping the hemp industry, and that's a $5 billion industry.

 We have a $7 billion industry in organic and we get roughly 15

 to $20 million.

 So as a group, and as an NOSB Board, I think you

 know, looking at the cost-share programs at $750 an acre,

 again, I don't want to put down the $750, but we need to be

 effectively using our money better and our time better to get

 more of those resources that should be out there for the

 organic producer, and the organic standards, and the organic

 enforcement.

 So take broad overall strokes, but that is what I'm

 feeling today and the about 50 growers I work with sentiments

 too are feeling. 
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 CHAIR POWELL-PALM: Thank you very much for your

 comments and taking the time to talk to us today. We realize

 it's a busy time of year for you.

 Questions for Bryce? Logan's got one, followed by

 Amy.

 BD. MEM. PETREY: Thank you, Bryce. Sorry for all

 the struggles and question.

 So you know, there is a lot of money going into the

 transition for a lot of growers. Do you think that it's

 necessary that we really tackle the inputs, you know, for -- or

 the imports, excuse me, not inputs to make that successful? To

 me, it seems like we're missing a lot of demand. That's what

 you hear from a lot of people. But maybe this whole import

 thing really can open the door for a lot of demand. That would

 make that possible.

 What do you think would make that possible for a lot

 of growers to come on board and to move into the organic space?

 MR. IRLBECK: Right. Where I speak, it's just

 specifically on the grain space because I don't know the

 vegetables and the specialty products.

 BD. MEM. PETREY: Right. No. Just asking for the

 grains.

 MR. IRLBECK: Yeah. It's -- the lack of demand is

 not there in the grain space. I think from talking to the end

 users, talking to people in the grain and small grains and corn 
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 and soybeans, the demand is actually growing. We are just

 importing faster than the demand is actually growing. And

 we're actually going to see a decrease of acres in the U.S. So

 I think we're going to see less come from the U.S. and more

 come from imports. And that's really going to hurt in the

 short -- it's going to be okay in the short-term for the

 industry, but the long term is what happens when the imports go

 away. We see $40 soybeans. We see $15 corn. And then we see

 a destruction of demand. So it's just big waves that we see

 happening all the time that we need to level out.

 And I'm not saying 100 percent of everything coming

 across seas is fraudulent. But there's a lot of common sense

 we can use, and a lot of things that we can do that are simple.

 We're testing a very small amount of grain coming into the

 United States organically. I think conventional actually beats

 us on testing. And so -- like there's just a lot of things

 that it screws up demand in the short term. It really degrades

 the foundation of organic in the U.S.

 BD. MEM. PETREY: Okay. So with -- you said there is

 an increase in demand, but there may be an increase in imports

 and decrease in supply -- national supply. Why is that? Is

 that price? Is -- you know, why would we be producing less

 when we have a lot of availability? Is it the price points

 that imports are coming in or --

 MR. IRLBECK: So for me, it's psychological. It's a 
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 little bit different of an answer. We go through a very timely

 process to become organic certified, which is great. I don't

 mind that. And we do it. We try to do as well as we can, and

 we get 50 questions that are different every year. So it

 becomes difficult and frustrating.

 And then we see these imports come in, and we call

 buyers, and the buyers say, well, this is the import that's

 coming in this week from this country, and you know, this is

 the price that it's set at right now.

 And so -- and psychologically, it is very difficult

 to stay in the organic space when we are getting pillaged, and

 these imports are coming in seemingly by the boatload. So and

 pricing is pricing. It is what it is. But the psychological

 factor of knowing that's happening feels very difficult to the

 long hours of organic production.

 BD. MEM. PETREY: Yeah. Okay. Thank you.

 CHAIR POWELL-PALM: Amy, please go ahead.

 BD. MEM. BRUCH: Bryce, thank you for your time today

 and lending your voice to these issues that you guys are

 experiencing. Two questions real quick. You talked about the

 farmer point of view, and then in your comments, you mentioned

 the processor point of view, and you said that some processors

 think that -- some U.S. processors think that idling their

 systems this year might be more cost beneficial than trying to

 compete. 
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 Can you expand on that just a little bit more?

 What's happening on a processor level?

 MR. IRLBECK: Yes. So I won't use names, so I'll go

 into specific situations. We were going to sell beans, and I

 got into a good conversation, a very stout processor, a very

 reputable, long-term organic in the industry. And I don't

 think they import very much, if any at all. And they bought a

 lot from the U.S. farmer. And now that the imports are flowing

 in faster than you can even count, then they say, look, we

 might not even be able to run the plant this winter. It might

 be cheaper for us to just put it idle and keep the fee to keep

 it heated.

 BD. MEM. BRUCH: That's concerning. Okay. Thanks

 for that. And I just have one quick question just diverting

 directions.

 I know in the Midwest, land is expensive. Do you

 lease some land that you convert to organic that was

 conventional?

 MR. IRLBECK: Yes. Yes. We lease quite a bit of

 land. And actually, that's how we've been able to grow our

 farm. There's a lot of landowners that wanted to go into

 organic. And we do it in five-year terms. So we go through

 the transition. We do two years of organic and then we -- most

 of the times, we re-lease it after that. So it is a five-year

 commitment, and it is a relationship with the landowners, and 
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 most of them wanted organic.

 So we are seeing a demand from the landowners, the

 ones that are organic and that side. So --

 BD. MEM. BRUCH: Uh-huh. And then why did you pick

 five years? Again, can you mention that? Sorry.

 MR. IRLBECK: Yes. Because we go through three years

 of transition. And then we want to have a guarantee to operate

 the land for two years with an organic crop that we put so much

 time and effort to get to that organic crop.

 BD. MEM. BRUCH: Okay. Thank you, Bryce. Appreciate

 it.

 CHAIR POWELL-PALM: Jerry, and then Kim, please.

 BD. MEM. D'AMORE: Yeah. Bryce, thanks for all your

 work and coming to talk to us. I, for one, have zero doubt

 that your concerns are valid and urgent. I think it's

 interesting that at this point in time, you know, part of your

 -- or a significant part of your solution might already be in

 process through SOE. We'll see how that plays out. But I

 believe that that will give relief.

 My one question is, and you've spent a lot of time

 thinking about it, and it's just one simple question. Were you

 in charge of inspections from overseas sources, where would you

 inspect?

 MR. IRLBECK: Yes. I think the biggest thing is

 getting back to the origin country of where this stuff is 
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 coming from, and understanding the origin of it. Which I don't

 know for fact, but it seems likely we don't even know the

 origin of most of this grain. We're shipping through countries

 that, you know, raise a vast majority of this grain, and

 shipping vast bushels through this country.

 And so if we can get back to the origin to the farms

 of where it's coming from, and verify those as a U.S.-based

 certifier, I think that closes the loophole. I've lived in

 Africa. I've lived in Brazil. I farmed in both places. The

 people there will do fraud if it's easy. If it becomes a tad

 bit difficult, they'll move on to the next thing.

 And it appears to me, again, this isn't fact. It's

 my opinion. It appears to me that it's so easy that they just

 keep doing it.

 BD. MEM. D'AMORE: Well, between the two of us, we

 can talk about Ukraine and Turkey as well.

 MR. IRLBECK: Yeah.

 BD. MEM. D'AMORE: But I'm going to try to lead the

 witness on this just a little bit and tell you why I ask that.

 I -- the idea of -- and we've all said it. You just said it a

 moment ago. The idea of trying to find the people at source is

 very difficult. And having boots on the ground to get it done,

 the ability to change the flag, if you will, you know, the

 certificate of origin is easy.

 What are your thoughts about all of the inspection, 
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 or the majority of the inspections being done on a risk

 analysis and at our ports where the cost of -- first of all,

 the cost to get that done for the inspecting side would be

 less. Second of all, the penalty for a turned around product

 at that point would be at its maximum. Does that resonate with

 you at all?

 MR. IRLBECK: Yes, it does. I think the big numbers

 that I think are very important is, I'll pay for it, but -- I'm

 paying for it anyway in the tunes of hundreds of millions to

 billions of dollars. The farmers are already paying for it.

 And so why don't we actually just pay for it to be as fully as

 we can. We already are paying for it by loss of revenue and

 profits in what we're doing, and loss of acres.

 And so I'd look at it that way. Do it -- and then at

 the port of origin, I think that's a step -- or the port in the

 United States is a great step of upping the testing, upping the

 requirements of knowing where this came from. And I guess they

 get to switch their things and do it through a couple other

 countries. Why do we have to accept it then? Why can't we

 just accept it from the country it's supposed to come from?

 The end user can't accept my grain if we don't know

 which field it comes from. I have to put it on my thing

 already. Why are we any different for the countries bringing

 it in. Why can't they go through five different people to get

 it here. 
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 So I mean, just enforcing the same laws we already

 enforced would be a great step forward.

 BD. MEM. D'AMORE: Thank you, Bryce.

 CHAIR POWELL-PALM: Kim, please, go ahead.

 BD. MEM. HUSEMAN: Hi, Bryce. You had mentioned kind

 of a whipsaw effect of pricing, where $40 soybeans and $15

 soybeans, neither one of those make sense, right, that there's

 got to be a market available for everyone through the food

 chain, we'll call it. What kind of financial risk management

 tools do you have available today to hedge your risk?

 MR. IRLBECK: Yes. So there are crop insurance.

 It's not great. It's definitely a step behind all the

 conventional of the crop insurance. But the only real way is

 by having crop rotations and being able to have multiple crops

 to market that are harvested at multiple times that hedge risk

 between just the conventional corn and the soybeans.

 So I think there's a biological factor, which organic

 was made for, and the reason why we do a lot of it.

 The crop insurance one is -- I mean, you kind of fit

 into the conventional space and if you don't, it's good luck to

 the grower. So there isn't very much and that's why I think

 you see a certain set of growers that are just able to do this,

 and a certain set of growers that can't take that risk and do

 it. So --

 BD. MEM. HUSEMAN: Do you think the market would 
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 benefit from having a tool, not identical to, but maybe -- you

 know, we're talking parallels to conventional, let's call it,

 there's really not like a board of trade for the organic market

 that I'm aware of. But I mean, it sounds like maybe the

 market's lacking of financial risk management tool.

 MR. IRLBECK: Yes, it is. You know, the Board of

 Trade's hard because we don't trade enough volume to make

 something like that work is what my understanding. You know,

 just taking the conventional crop insurance, and making for

 organic, actually, and not trying to make organic work for

 conventional would be a huge step.

 BD. MEM. HUSEMAN: Thank you, Bryce.

 MR. IRLBECK: Yeah.

 CHAIR POWELL-PALM: Thank you, Bryce. We really

 appreciate you calling in today. I just have a quick question

 for you.

 I think you are familiar with the GEODOC that's going

 to CACS about geolocating. I just wanted to see if you had an

 opinion on that.

 MR. IRLBECK: Yeah. So I fully support the geo

 location of fields. I think here and abroad, again, a tad bit

 of preventive maintenance, and a lot of people that don't want

 to work hard and commit fraud both here and the U.S. will not

 do that. With just a little bit of this tracking and

 accountability that the whole organic standard was built on. 
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 And I think georeferencing is one of those things that can be

 implemented without -- with very little nuisance to the grower

 and to the whole process and system.

 CHAIR POWELL-PALM: I really appreciate your thoughts

 on that. Thank you so much for calling in today and taking the

 time out of your harvest. I appreciate you.

 MR. IRLBECK: Thank you.

 CHAIR POWELL-PALM: Next up, we have Byron Wiemer and

 then Bill Wolf, followed by Kylie Mausser.

 Byron, please go ahead.

 MR. WIEMER: yeah, welcome. I guess it's still

 morning. I apologize. I'm speaking from my pickup. I'm at

 some meetings today, but I basically sort of wanted -- was

 asked to sort of touch on, and you talked a little earlier, you

 know, the risk management side for organic, you know, and I'm

 just going to touch on TDLs again.

 You know, we talked about this earlier this spring.

 And, you know, I'm an agent -- crop insurance agent in Utica,

 Nebraska. I'm in eastern Nebraska. York and Seward County

 would be my primary counties, but we -- you know, we write

 pretty much the eastern half of Nebraska.

 But using York County as an example, you know, on

 irrigated corn, if you're a conventional farmer, your T yield

 is 223 bushels. You know, if you're going into organic

 transitional, that goes to 156. So you know you're 67 bushels 
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 short, and you know the big hit is for that producer that's in

 that transitional because, you know, you start out with a 156-

 bushel yield, but you also use the crop insurance price, which

 this year was 591. So you're automatically -- right away,

 you're $297 an acre less coverage than what you peers have

 raising regular corn.

 And I guess the biggest problem we've seen is the

 last two years in my area, we've had two very severe hail

 storms where these producers -- this is two years -- you know,

 we had one last year, 2022. Again, 2023. Producers produced

 nothing. And so, you know, if you're that person trying to get

 established in organic and you're in that transitional phase,

 you know, that's a pretty big hit.

 You know, last year, yes. Guys were able to --

 people were able to replant, and that worked. You know, this

 year, the storms hit later date. You know, replanting was not

 an option. They're going to live on their insurance money.

 And so like I said, you know, with corn, you know,

 you're starting out with 67 bushels less. You know, on

 soybeans, you'd actually lose -- you're losing 20 bushels. You

 go from a 67-bushel yield for conventional beans to 47 bushels

 on organic. And at 13.76, which is the price this year, that's

 $206.

 So you know, when you're in that transitional phase,

 you know, it's a huge financial hit. Yes. Once you get the 
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 organic certified, you know the yield doesn't change, but yet,

 your price does so. They're helping make it up a little bit,

 you know, in price, but you're still -- you know, you're still

 at a disadvantage.

 And like I said, you know, it's really come to light

 for me, for the organic clients we have, you know, with the

 hail storms the last two years, you know, it's -- you know, you

 buy crop insurance as a risk management tool and it's -- we're

 not -- it's hard to get it covered.

 CHAIR POWELL-PALM: Really appreciate you calling in

 today. This is huge. Questions from the Board? Amy, please

 go ahead. You're muted, Amy.

 BD. MEM. BRUCH: Sorry about that. Sorry, Byron.

 Thanks for your time today. Unfortunate stories to hear, but

 it's real life and we've got to deal with it. I was just

 wondering, we have a discussion document on crop insurance this

 year. I appreciate your contributions, just your oral comments

 on this. Do you think it would be beneficial for RMA, Risk

 Management Agency, to consider if you did have history as a

 conventional farmer, consider some of that history when they're

 determining your T yields potentially for transition?

 MR. WIEMER: I think it definitely would help. You

 know, because I mean -- if you've got conventional yield

 history, which most people -- well, everybody does because

 that's how they started, I mean, yes. You know, we know going 
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 organic's different. But yes, I do believe, you know, there

 should be a system there where you -- you know, if you've got

 yield history, you should be able to use, you know, a

 percentage of that, or have an equation to help bump up that

 proven yield. Because, you know, like I said, whether you're

 certified or transitional, the yield's the same right now. But

 the really big hit for people is those three years of

 transitional because we're using crop insurance price versus,

 you know, organic does have a prior price which helps once you

 get certified, but you have to get there first. So --

 BD. MEM. BRUCH: Uh-huh. Okay. Thank you, Byron.

 CHAIR POWELL-PALM: Other questions from the Board?

 Kim, please, go ahead.

 BD. MEM. HUSEMAN: Hi Byron. Can you tell me how is

 the crop insurance price per acre determined for organic versus

 -- for organic crops?

 MR. WIEMER: Well, I mean, basically, I know, like,

 for conventional corn, you know, like corn -- they use December

 corn during the month of February. That's how that price is

 established. Soybeans is November beans on the Board of Trade,

 you know, during the month of February. Then they do that

 again in the fall. But as far as the organic price, I believe

 that is set by RMA. And I guess I don't really have the -- I

 don't have a good answer for you on that how they come up with

 that. 
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 You know, this year, like I said, for organic

 certified, your price is $11.10 for corn and $28.29 for

 soybeans. So but I -- if you ask me how they came up with

 that, I honestly don't have a good answer for that.

 BD. MEM. HUSEMAN: Thank you, Byron.

 CHAIR POWELL-PALM: Carolyn, please go ahead.

 BD. MEM. DIMITRI: I just -- I wanted to talk --

 speak to Kim's question about how the prices are determined and

 I -- I don't know, like looking at crop insurance, and grain,

 and organic, and imports, it's so very complicated. And it

 seems like organic grain farmers face a lot of risks that they

 haven't been able to diversify their way out of the way

 specialty crop producers do.

 And I think maybe the fact that no one really knows

 how those prices are determined makes it, I think, even more

 problematic for grain farmers. So I guess I was just saying --

kind of responding to what Kim said and what Byron said, which

 is no one -- there's no transparency about that particular

 price calculation.

 MR. WIEMER: And, I mean, I can share -- to be real

 honest with you, I'm actually at a crop insurance workshop

 today where RMA is here. So that'll be a great question. I

 don't have the answer for you now, but that is a question I'm

 going to ask them before I leave today, you know, how that --

 because I do not know that right now. 
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 BD. MEM. DIMITRI: Let us know what they say.

 CHAIR POWELL-PALM: Yeah. Really appreciate you

 calling in, Byron, and being --

 MR. WIEMER: Well, I appreciate being asked, so --

 CHAIR POWELL-PALM: Please do follow up with whatever

 information you find. We'd love to include it in our research.

 Thank you again.

 MR. WIEMER: I will be glad to do that. Thank you

 again for the opportunity.

 CHAIR POWELL-PALM: And thank you for calling in from

 the road. I love seeing farmers in tractors, farmers in cars,

 taking the time and this platform allowing you to call in very

 easily. So thanks very much.

 MR. WIEMER: You're very welcome. Have a good day.

 CHAIR POWELL-PALM: You too.

 Next up, we have Bill Wolf, followed by Kylie

 Mausser. And we're not seeing Zach Porter on the line. Zach,

 if you're there, please just let us know. Otherwise, we'll go

 to Frank Austin after Kylie.

 Bill, the floor is yours.

 MR. WOLF: Can you hear me?

 CHAIR POWELL-PALM: We can.

 MS. ARSENAULT: Hang on a beat, Bill. We're going to

 get the slides up. There we go.

 MR. WOLF: Thank you. I'm Bill Wolf with Wolf & 
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 Associates, and Second Star Farm. My comments are about

 increasing U.S. organic acreage with integrity.

 First, I want to thank you NOSB members for all your

 work. Slide 2.

 For 50 years, I farmed organically, launched organic

 businesses, served as president of OMRI and OTA, and helped

 hundreds of growers and handlers. There's progress, but we

 need even more. Please note our written comments, including

 that essentiality applies even when only needed by a few. Thus

 assuring that the national list is a robust toolbox.

 Slide 3. Some suggestions I'd like to provide to

 increase U.S. organic acreage, organic pet food standards,

 Organics and the Farm Bill, and getting five percent of the

 USDA R&D money. And support -- I ask that you all support the

 two new organic bills before the house. An organic marketing

 order. An in-transition label. Those are a few ideas.

 Slide 4. We really need to work together to

 communicate the value -- the true value of organic: healthy

 soil, healthy plants, healthy animals, people and planet.

 Slide 5. Some new comments about residue testing.

 We need updated guidance to help certifiers effectively focus

 and coordinate testing costs and catalog the findings. About

 inerts. Having no inerts policy has stalled better pest

 control choices for growers. See our comments on how to move

 forward. 
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 Finally, we're all working to implement SOE and stop

 fraud. We've put a countdown clock on our

 organicspecialists.com website in order to help, 151 days to

 mandatory compliance. We've got work to do.

 Slide 6. I'd like to clarify our plastic -- comment.

 We do support re-listing it, but only for now. Eleven years

 ago in providence, this is kind of an anniversary moment next

 week, the NOSB voted to approve biodegradable mulch film, a

 better choice than plastic. Annotations added in violation of

 the now current procedures at the meeting were added and then

 misinterpreted. This --

 CHAIR POWELL-PALM: Please go ahead and finish up.

 MR. WOLF: This poisoned pill requiring a higher

 biobased content than the USDA biobased labeling program has

 been a disaster. During this decade without its use, thousands

 of tons of polyethylene have been used and sent to landfills.

 Slide 7. Earthworms are a de facto mascot of organic

 agriculture. Let's make their jobs easier with a robust

 national list and more organic acreage. And I am humbled by

 the awesome comments from the many amazing organic farmers who

 spoke on Tuesday and before me today.

 If there's any questions, I may want to go back to

 those previous slides. So if you can leave that up for a

 moment, that would be great. Thank you.

 CHAIR POWELL-PALM: All right. Questions from the 
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 Board. Sorry, I'm -- as I see this -- let's go with Logan, and

 then Jerry, and then Dilip.

 BD. MEM. PETREY: Good to see you, Bill. Okay. So I

 actually have a question on the transition label. So part of

 the getting more acres to organic. I'm nervous about a

 transition label. Anything that -- we have already heard, you

 know, especially speaking from, like, a specialty crops or a

 vegetable producer, we've already heard the challenges with

 demand and the oversupply of certain commodities. Now, the

 transition label, again, makes me nervous at where is that

 demand itself going to come from if it's educated on what

 transition is. So if you're educating the consumer that

 transition is grown like organics, it's just not quite, you

 know, in organic soil yet, but it's going to be there soon, I

 feel like that's going to not pull from the conventional

 consumer so to speak, but it's going to pull from the organic

 consumer and then make demand actually less in the organic

 sector.

 What do you think to that? Or are you concerned with

 that or do you think that's going to be a problem?

 MR. WOLF: Logan, you're on target. That is an

 important issue to watch and figure out how to implement a

 limited use of the transition label. It's focused on U.S.

 acreage of crops that can go into -- go in and truly compete

 with what's now taking over the market, uninspected products, 
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 non-GMO. And we -- there has been, before the NOP program was

 fully implemented, there was use of the in-transition label.

 And in fact, the first draft of the rule started to allow it.

 But you're absolutely right. We have to be careful not to

 simply steal away from it. But the economics of transition --

 first of all, the new transition funding is a great start, and

 it will help address that three-year cost to growers, but it

 doesn't solve the problem completely.

 I've seen some companies commit to paying a premium

 during that three years. Over the years, that's been pretty

 effective, and I can think of a number of examples where that's

 happened. But it's not really -- it didn't cover the real

 farmers' cost during that period.

 BD. MEM. PETREY: Right. And it is costly. And so I

 do understand that, but I -- as a girl who has transitioned

 land, now granted this is not -- I work for a large company,

 right, this is not my own finances, so -- but on the agronomy

 side or on the science side, the three-year transition period,

 what I found to be economically the best is doing covers,

 building that soil up, because we have very sandy soils here.

 We actually heard, compared from conventional, we have a lot of

 -- the soil has been kind of sterilized and the nematodes are

 just awful here. I mean a conventional grower can't grow

 without Telom (ph.) added. We don't use any nematicides in 

 organic farming because our microbiology is so good, so robust, 
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 but it takes time to get there. And so -- and covers seem to

 do that the fastest. You know, there's a lot of biomass added

 in, and it's lower cost. I mean, really you're paying for the

 seed. Now, you're paying for land rent and the loss of revenue

 on those acres.

 So it is complex, but as far as, you know, getting to

 that success in those three years, it seems like the cover

 crops that -- you know, continuously cover cropping and adding

 what cover crops are needed, whether it's the turn of nematodes

 or, you know, it has biofumigant properties or weed-control

 properties, it seems like that is actually really helpful.

 And so yes, the funding maybe to cover some of those

 expenses, which are relatively low compared to growing a crop,

 which requires organic inputs at a very high cost for a lower

 return because it takes a while to get to those yields. And so

 maybe that -- like you were saying, the funding might be a

 better long-term choice. I don't know. But I can't speak from

 a grower side, who's actually put their own money to do that.

 So I'm sure that's very burdensome. So thanks for that point.

 MR. WOLF: And you've really spoken to the -- to why

 the three years. The original three years. People say, why

 was it? It really was to create and reestablish the biological

 diversity that makes the crop healthier.

 BD. MEM. PETREY: Yeah.

 MR. WOLF: Thank you. 
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 CHAIR POWELL-PALM: We're going to jump to Jerry,

 then Dilip, then Nate Lewis. And I will remind everyone, we

 are probably going to see Bill next week, so we'll have a

 chance for lots of conversations. So please keep your

 questions focused. Go ahead.

 BD. MEM. D'AMORE: Bill, good to see you.

 I almost put my hand down once Logan got going, but

 she took a good, hard shift the agricultural side, and I'll

 bounce over to the go to market side, if I may, or the market

 pull.

 Twice in my career, two years in the early 2000s --

2002 to 2004, and then somewhat later, I literally broke my

 teeth on trying to make that work, to find how transition could

 be funded. And the only thing I can really guarantee this

 group by real experience is the consumer doesn't understand it

 well enough to pay for it. And to the question of who's going

 to take -- where is that -- what pile will these transitional

 acres be taken? My experience is from either one. It just

 didn't work from a go to market side. Thank you.

 CHAIR POWELL-PALM: Thank you. All right. Dilip,

 did you want to -- did you have a question?

 BD. MEM. NANDWANI: Well, he answered my question on

 funding, very quick, if you can clarify about this five percent

 funding for research and education, is it from the farm, Bill,

 are you suggesting, or can you clarify a little bit on that? 
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 Thank you.

 MR. WOLF: Sure. In Slide 3, what I was trying to

 point out was that the USDA research and education dollars are

 not really allocated properly. They're not directed to the

 part of agriculture that's really growing well. If you were

 just running a business and one segment of your business was

 growing by 10 percent every year, you'd be putting your

 research and education dollars there. And the USDA isn't even

 close to that, and we've been saying this for now 20 years, and

 we're still not -- but we're not saying it loud enough anymore.

 So really, ask Secretary Vilsack to change how they

 allocate funds for research and education. We need the

 knowledge of how to manage weeds, how to really look at our

 pest-management techniques, how to reduce tillage in organic

 systems, and how to put more carbon in the soil. And carbon --

this whole question of carbon sequestration, my gosh, that's

 the biggest answer to our climate situation is actually in our

 soils. And there's some good data to show organic farming

 practices produced more humid complexes that are more stable

 than any other farming method. So we need to be screaming this

 out, get that five percent. We're at less than one percent

 right now, and yet we're the market that's growing well. That

 was my point.

 CHAIR POWELL-PALM: Thank you, Bill. Nate, please go 

 ahead. 
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BD. MEM. NANDWANI: Thank you. Thank you for your

 comments. 

BD. MEM. LEWIS: Thanks, Bill. 

We heard a few commenters yesterday share their

 opinion that OPA and the National List criteria requires inerts

 to be listed individually. And I'll note your comments were in

 support of an option for inerts that was a broad list with some

 exceptions when those fail the National List criteria. So I'm

 curious if you can elaborate on your opinion about how that

 approach would also meet OPA and the National List criteria. 

MR. WOLF: Sure. Well, first the road block has been

 devastating. I've worked with companies who have withdrawn

 from researching for organic, and then taken their pest control

 products into the conventional market or even shut down and

 gone out of business because they couldn't know what the future

 looked like, so they couldn't rely on List for -- EPA List for

 inerts. 

So and I've been watching that happen for over ten

 years, and we've lost -- we just lost a huge amount of ground

 there. Basically, I mean, it really is a mess and I understand

 it's not an easy solution. But the bottom line, when I'm

 saying rather than single products, start by allowing specific

 groups, in our case -– our comments that allow -- and the two

 options in the June '23 memo to the NOSB, we think getting

 started by allowing the inerts, that the EPA allows the 
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 minimalist pesticide products and allowing inert ingredients

 that EPA allows in passive pheromone dispensers is a good

 start.

 It's also possible that there are categories. I

 mean, we have substances on the National Lists that are listed

 as groups and there are -- it's possible that once you get down

 into the reviewing process, there are groups that we can

 document as complying with the criteria rather than listing

 every individual in that group. And that was where we started

 to go with the smarter -- you know, the safer list, the EPA

 safe compounds. But they don't use the same criteria, so I

 understand you're -- that didn't flow.

 But moving forward on this as quickly as possible,

 even in chunks would be a good start. Does that help answer

 your question? Thanks.

 CHAIR POWELL-PALM: All right. We really thank you

 for your time and input, Bill.

 MR. WOLF: I've got to apologize for one thing. We

 have three associates who are going to be at the meeting next

 week, but I am unable to attend. I'm really sorry. If there's

 any chance I can just suddenly hop on a plane, I will, but I am

 going to miss being there in person, but I'll be watching the

 proceeds, and thank you all for your good work.

 CHAIR POWELL-PALM: Thank you. 

 All right. Next, we have Kylie Mausser, followed by 
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 Frank Austin -- and then, Michelle, we don't have Justin Raikes

 on the line, correct?

 MS. ARSENAULT: He's not at the moment, but we'll

 keep checking for him closer to his time.

 CHAIR POWELL-PALM: Justin, if you're there, please

 make yourself known, but Kylie, please go ahead.

 MS. MAUSSER: Hi. Can you guys hear me?

 CHAIR POWELL-PALM: We can.

 MS. MAUSSER: Okay. Hi. I'm Kylie Mausser, and I am

 just calling in as a measly consumer, after hearing all of

 these farmers talk, it's awesome to hear all the things you

 guys are doing, and I know the Board does so much. So thank

 you. I'm really grateful for that.

 So I am from Iowa, and I'm also just calling to ask

 you guys to look at the next generation for what's going on

 with organics. So I homeschool my four kids, and I started

 becoming interested in organics when I was a senior in high

 school when my mom got very sick. She was like most Americans,

 eating the standard American diet. And then with the help of

 some holistic people in her life, she started changing her ways

 and started caring about the food she was ingesting. And

 through that, the food healed her.

 Since then, I've been educating myself on things that

 make our bodies heal, including organics, herbs, and natural

 healing remedies. Organics is honestly the area that I still 
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 continue to need the most education on because I find that it's

 really difficult to find accurate factual information. I have

 to hunt for legitimate facts, and what I do find is

 unbelievable.

 The most outrageous fact that I find, though, is the

 fact that it's so difficult to find information at all, and

 it's also surprising that most of the population doesn't know

 anything about it.

 We're missing the opportunity to give every American

 consumer what they deserve: the right to learn what organics

 means. The USDA organic food label is literally the only food

 label that guarantees a refuge from toxic pesticides and

 herbicides. It's the only food label that guarantees

 traceability and transparency. I still actually have friends

 who think that non-GMO is better than organic, or at least

 compatible.

 Unfortunately, people believe what they hear on TV,

 and what they hear on TV is largely funded by companies that

 profit from unhealthy consumers, like big pharma. The money

 isn't in organics and I know that. We don't hear the truth as

 consumers. Education would help the consumer, whether it's a

 curriculum, like I could teach my kids, which I try to do that

 on a daily basis in our home, or the labels at the grocery

 store that everyone can read and see the difference between the

 foods and the fake food that they are actually eating most of 
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 the time.

 Can we go as far as offering commercials at the Super

 Bowl to display the truth, or is that too controversial? I'm

 really grateful that through my life, I've been aware of the

 benefits of organics and have been able to see through the

 propaganda and the green washing. I would love to see

 organizations and people become more educated and aware of what

 is truly going on in regards to food in our country.

 And that's all I have.

 CHAIR POWELL-PALM: We so appreciate you calling in.

 Thank you.

 MS. MAUSSER: We don't get to hear from consumers

 enough. And we've got a question for you from Mindee. So stay

 on the line one second. Mindee, go ahead.

 VICE CHAIR JEFFERY: Yeah. I just wanted to say

 thank you so much for showing up in democracy, and telling us

 who you are and what you're struggling with as a consumer.

 I just want to let you know that if people like you

 hadn't showed up in the grocery store and asked me hard

 questions, I wouldn't know as much as I know about what's going

 on in the food system. So I just want to express my

 appreciation to you.

 MS. MAUSSER: Thank you.

 CHAIR POWELL-PALM: Logan, please go ahead. 

 BD. MEM. PETREY: Man, I am so glad you came on. 
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 That was exciting. And I really think it does show that we are

 not marketing very well, and this is probably a huge

 opportunity to get to people. What do you -- as a consumer, as

 a mom, as somebody who cares, you have friends, how do we do

 that? What would -- do you think -- I know you mentioned the

 Super Bowl. That's very expensive. But what are some other

 things you thought would be good because, you know, I mean, I

 think that there are opportunities and they may be smaller. Is

 it podcasts? Like, would somebody listen to a podcase?

 Because a lot of health things that I've listened to are from

 people on YouTube, you know, that have -- that are influencers,

 things like that. What would you -- help you? 

MS. MAUSSER: I think that definitely helps. I mean,

 I think that -- I don't know. I feel like in the homeschool

 community, it's really small and big at the same time. Like a

 lot of us think the same, so we all talk about it. But I have

 a lot of friends in other areas as well, and you know, I talk

 to them about it. But so even public education would be huge.

 But I feel like there -- I just can't believe the amount of

 people -- my parents also have a feed and grain business and we

 sell regular chicken feed and non-GMO feed. And again, I know

 non-GMO is not the same as organics at all, but people don't

 even know what non-GMO sometimes. And like, I just can't

 believe that they don't even -- and I -- I don't know, I feel

 like most people are getting information from TV, which 
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 obviously the Super Bowl is go big or go home, but --

 BD. MEM. PETREY: Sure. But do you think if we had

 like a quick website that said this is what organic is, you

 could share that, or maybe that's a QR code that somebody could

 go to and it's just like a fun information page that does that.

 Would that -- that may help --

 MS. MAUSSER: Yeah.

 BD. MEM. PETREY: That may help me hearing something

 else.

 MS. MAUSSER: Not to mention if people could post

 that on social media, and share it, or even --

 BD. MEM. PETREY: Okay.

 MS. MAUSSER: That would be great. That would be

 awesome.

 BD. MEM. PETREY: Okay. Great. Thank you so much.

 Appreciate it. Liked hearing from you.

 CHAIR POWELL-PALM: We've got a question for you from

 Amy. Amy, please go ahead.

 BD. MEM. BRUCH: Thanks, Nate. Thanks, Kylie, for

 lending your voice to our process today. I think there might

 be one small correction. I thought you introduced yourself as

 a measly consumer, and I'm sorry, you're very powerful. We

 need you guys -- farmers need you guys and I love it because we

 learned on Tuesday, farmers want more markets. And it's cool

 to learn that consumers want our products. We just need to 
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 educate a little bit more. So thank you for sharing that.

 That's really inspiring.

 MS. MAUSSER: Yes. And I do feel like people don't

 -- some people don't know that they need the products, but I

 feel like so many people are sick and they don't know why

 they're sick. And I think that it's kind of the root of the

 problem. You know, so it's like they don't know what they're

 missing.

 CHAIR POWELL-PALM: Well, thank you for joining us.

 Thank you for bringing your voice. And I just reiterate what

 Amy said, we're only here because of you. I mean, this

 industry only exists because of consumers and demanding that --

and paying for the premium for organics. So thank you so much

 for, you know, joining us and making your voice heard. I

 really appreciate. I look forward to that homeschool

 curriculum for the day when I have kids, and we have a whole

 class on what is organic for K through 12. I really like that

 idea. So thank you.

 MS. MAUSSER: Thank you for all that you guys do.

 CHAIR POWELL-PALM: Take care.

 Next up we have -- thank you. Next up we have Zach

 Porter, followed by Frank Austin, and then Justin Raikes if

 he's on the line.

 So Zach, please go ahead.

 MS. ARSENAULT: Zach if you are on the -- there we 
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 go. He got unmuted.

 MR. PORTER: Can you hear me?

 CHAIR POWELL-PALM: We can. Loud and clear.

 MR. PORTER: All right. How are y'all doing today?

 CHAIR POWELL-PALM: Doing well, thank you.

 MR. PORTER: First off, appreciate everything that

 you guys are doing here to help, you know, move the industry

 forward. I farm out in western Nebraska. I'm in the process

 of converting about 5,000 acres to organic at the moment out

 that way. And as a relatively new entrant from a production

 standpoint into the organic marketplace, and after having

 traveled the world, helping investment fund about a decade ago,

 looking at food and ag opportunities, there are two things that

 have really kind of struck me as particularly interesting.

 The first is that from a paperwork management

 standpoint, particularly as it relates to getting and

 maintaining organic certifications, I've been pretty surprised

 by the lack of digitization and geotagging of fields, to

 actually say yes, you know, this is where this field is. It

 goes with this paperwork. Especially as we're looking at

 growing and potentially taking on additional acres that have

 already been converted, the lack of access to something digital

 and potentially geotagged seems like just a massive area of

 inefficiency in the process.

 And I'm not sure what could be done or is going on 
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 yet on that front, but I do want to raise this as an issue for

 discussion.

 And then secondly, kind of as an extension of that

 digitization here, one of the things that I found after frankly

 investing in Central and South America, Southeast Asia, West

 Africa, Eastern Europe, across the agricultural value chain is

 that it astounded me to learn how much product is fraudulently

 being labeled as organic and shipped into the country. Whether

 it was corn that was cracked and therefore was evading a lot of

 oversight and checking at the ports because it was labeled as

 feed rather than something for human consumption, or I'd be

 happy to dive into more specifics around that, it strikes me

 that this is something that may also benefit from either a

 geotagging or digital track and trace type of innovation, which

 I've seen in other sectors and would love to support however

 possible rolling those things out here.

 So appreciate the time.

 CHAIR POWELL-PALM: We really appreciate your

 comment. Thank you for making the time to call in today.

 Questions from the Board? I just have a quick

 question for you, Zach. We have this document Georeferencing.

 It's basically a guidance, saying that for best practice,

 certifiers would collect the legal coordinates or geocoordinate

 for each field. Do you feel like that's a small step in the

 direction you're envisioning for the industry? 
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 MR. PORTER: Massively so.

 CHAIR POWELL-PALM: We really appreciate that.

 MR. PORTER: The amount of paper headache that exists

 from something like that not happening is asinine.

 CHAIR POWELL-PALM: Thank you. We do appreciate

 that. All right. Take care. Thank you.

 MR. PORTER: Thank you.

 CHAIR POWELL-PALM: Next up, we have Frank Austin,

 followed by Justin Raikes, and then Ginny Olson.

 And I will remind folks, if you could when you start

 your comments, please just state your name and affiliation. Go

 ahead, Frank. The floor is yours.

 MR. AUSTIN: Sure. All right. Well, good afternoon,

 NOSB. My name is Frank Austin and I'm from Clear Fronteer Ag

 Management. We are an organic and sustainable farmland fund.

 And then here today to speak about the critical need for

 stronger measures to prevent fraud in the organic supply chain.

 So in the last 12 months, we've imported 170,000 tons

 of cracked corn, all from Turkey; 57,000 tons of whole corn;

 338,000 tons of soybeans; and 293,000 tons of soybean meal.

 If we look a little bit more closely at an example,

 specifically let's take Ghana, for instance, in the last 12

 months, they've represented 16 percent of organic soybean, you

 know, imports that we've received to U.S. ports. But if we

 step back, and we look at likely certified organic acres in 
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 Ghana for 2022, or 2021, we would need roughly 65 percent of

 the certified organic acres in Ghana to be planted to soybeans

 to hit the actual quantifies that we're receiving in our ports.

 So you don't necessarily have to pick apart the

 organic standard, but just do some basic fact-checking on the

 available data, and you'd see that it's very unlikely that all

 of those soybeans are actually coming from Ghana, right?

 So American farmers work very hard to uphold the

 integrity of the organic label, but their livelihoods are being

 threatened when bad actors cut corners and fraudulently label

 products as organic. This unfair competition drives down

 prices and misleads consumers. The NOP must take steps to

 close loopholes that allow organic fraud to persist. A key

 priority should be requiring certifiers to collect GPS

 locations. As we know from the example I just walked us

 through, you know, GPS locations would be very, very helpful

 for us to actually calculate accurate numbers here.

 So again, this would be GPS locations across the

 entire organic supply chain for brokers, handlers, and farmers.

 Another critical step that you have to consider is stricter HS

 codes. So all of the import codes that we actually have, and

 the way these import codes are labeled, and the cross-labeling.

 This is how the bills of lading are ultimately doctored or

 altered. And it's also oftentimes how a lot of fraud gets

 under the radar. So we do need more detailed HS codes, and 
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 that's going to obviously help us actually track real volume.

 As I've been listening to people speak today, I've heard a lot

 of different growers, you know, talk about how they don't

 really know what's going on in the market. Well, of course

 not. Because we don't have HS codes that are allowing us to

 track the actual volumes that are coming in.

 You know, we shouldn't sit around and debate about

 funding a flood department when the house is on fire. This is

 of the utmost importance of us and -- you didn't cut me off.

 Thank you.

 CHAIR POWELL-PALM: No, no. Go ahead.

 MR. AUSTIN: The utmost importance for us that we,

 you know, follow through on this, because this is fraud that is

 happening today. This is not, you know, it might, or we don't

 have any evidence. If I'm pulling data, all of these bills of

 lading, right, from every U.S. port, and I'm getting to a rough

 estimate of 65 percent of the acres in Ghana have to be planted

 to soybeans. An incredibly difficult crop to grow, right, you

 know, organically. Think about this. This is right in front

 of us. This is looking us right in the eyes. And I'll be

 honest with you. That is -- the example I walked you through,

 I don't have rock solid data to say that that's 100 percent

 correct. It's a best estimate. But that estimate alone should

 scare us, and it should be a call to action.

 We have a question for you from Kyla. Kyla, please 
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 go ahead.

 BD. MEM. SMITH: Hi, there. So call to action sort

 of taken here, one of the provisions in the strengthening

 organic enforcement final rule is the requirement that

 certifiers perform supply chain traceability audits. And that

 can -- those audits can have different objectives. But what

 the requirements indicate are that certifiers are going to need

 to work with each other, you know, across the supply chain

 because a certifier may only certify a portion of the supply

 chain.

 And so do you -- with the data that you presented and

 the problem, do you think that that will help, at least, to try

 to, like, uncover where the potential fraud might be in that

 supply chain to be able to have certifiers work together to

 perform that supply chain traceability audit from the importer

 or the end -- wherever the grain ends up in the U.S., all the

 way back to the country of origin, which right now is not

 widely happening but will be required.

 MR. AUSTIN: No, it's a good question. And if you

 had asked me this question at the beginning of the year, I

 probably would have said, yes, I think this sounds very

 effective. But given where grain prices are today, I want to

 step back and I want to just kind of think about what do we do

 -- like when we think about NOSB, what is NOSB here for? It is

 here, it functions to protect the integrity of the American 
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 organic supply chain. And from what I can tell, the red tape

 that we get with regulation, it just isn't working. It's not

 cutting it. And so what I would say is it would be wise for

 NOSB to consider cutting the head off the snake.

 We don't have time, because margins are getting

 thinner and thinner, and as they increasingly get thing; and we

 all know inflation is not slowing down, right? Ask any grower

 on the phone today. They'll tell you, it's awful. You know,

 so how many people can we really expect to still be organic and

 it's a wonderful plan. I think supply chain audits, I move

 forward with them. I'm very supportive of it. But I don't

 think you have the time for an audit. I think you have -- you

 do have bills of lading that come in. You do have data from,

 you know, the trade commission. There needs to be, like, an

 emergency call to action. You need to pull together a task

 force. You need to do -- you know, go agency to agency,

 collect all the data you possibly can that might shed some

 light on this.

 You have to go after the buyers. Buyers today, and

 I'll just be honest with you. You know, I buy farmland for my

 investors and I work with farmers. I love grain buyers. But

 I'll tell you, the system is set up for buyers to basically be

 a black box if they want to be. And I know most don't. But

 the issue is that they can be.

 And when you have that volume of cracked corn coming 
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 out of Turkey, all of it out of Turkey, all of it, and then you

 see what's going on in our grain prices. And then you know

 earlier someone was talking about soybean prices and, you know,

 should they be $20 or $40, you know, who knows because you're

 not dealing with a real market with 20, 30, 40, 50, 60 percent

 of what your supply is is potentially contaminated. And people

 are talking about moving to options. No financial institution

 will want to touch that.

 If you don't have stricter regulations in place, if

 you're not actually enforcing the law, and keep in mind, these

 countries, they don't have criminal penalties for passing

 something off as organic when it's not. They don't go to jail.

 You don't even get a ticket. It's just like putting a sticker

 on a box and shipping it over to the Americans, who don't

 check. And they're making a fortune, and our growers are

 losing money. So there's no time.

 I mean, I think you have to move forward with the

 supply chain audits, but I'm actually saying there needs to be

 additional action because it's not about -- you can't fund the

 fire department when the house is burning down. That sort of

 thing. But a great question. Thank you so much for asking me

 that. I appreciate it.

 CHAIR POWELL-PALM: Amy's got a question for you.

 BD. MEM. BRUCH: Frank, thanks for lending your voice

 to the process today. I really appreciate it. 
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 I had a question. Can you talk about the challenges

 that foreign trans shipments provide to tracking and

 understanding imports? Because right now, the SOE is requiring

 point of department import certificates. So can you talk about

 -- you kind of talked about the black box, or you eluded to it,

 can you talk and open that up just a little bit?

 MR. AUSTIN: Yeah. Before regulations are written,

 you need to think about the financial instruments that are

 going to be used in these transactions. So if you think about

 commodity trade finance, and the way these notes are

 structured, you can put the institution that is, you know,

 underwriting this as sort of a receipt address. So there's a

 way -- there are work arounds here that you have to be very,

 very cognizant of.

 The other thing, too, is you know, where did those

 soybeans come from? They didn't come from Ghana, you know, in

 this example, suppose the acres are correct on it. We know

 that a very large percentage of organic acres in Ghana must

 have been planted to soybeans, if in fact those are organic

 soybeans. But back to the point, so stepping back and thinking

 about this, you know, it's obvious that -- to me, at least,

 that there must have been soybeans coming from elsewhere and

 being shipped out of Ghana.

 So they go to Ghana. They're relabeled. And then

 they're shipped. And that's a very, very difficult thing to 
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 track. I've only ever been able to kind of get real data on

 that with respect to the cracked corn coming in to Turkey from

 -- you know, like Tajikistan, etcetera, Central Asian, you

 know, the flow of conventional cracked corn. And it flows out

 of Central Asia, and into Turkey, and suddenly it's organic,

 right? And then into the U.S., right to the U.S., destroying

 organic corn prices.

 You know, look at the spread between conventional and

 organic corn in the last five years. It's terrible. It's

 terrible. And you have all of these families that have

 invested their life savings, their future, everything into this

 label that the USDA has said, look, this is our seal of

 approval, right, on your operation. But then, you know,

 there's nothing but five million different administrative

 processes, and sit around and wait, when we've identified fraud

 in the market. It's very disappointing. It's very, very

 disappointing, because at the end of the day, if the job of

 NOSB, or NOP, or whomever, I don't know, is to protect the

 integrity of the supply chain, it's just not happening. And

 it's just not happening.

 CHAIR POWELL-PALM: I mean, it's -- I'm going to kick

 it over to Franklin real quick for another question.

 MR. AUSTIN: Sure.

 BD. MEM. QUARCOO: Two quick questions for you. One

 of them is what kind of yield per acres estimates did you use 
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 for the estimates for the acreage that is needed? Did you use

 yield pay estimates from here in the United States or from the

 location you were referencing? I'm also particularly

 interested in your import data that is cited. And finally,

 what is the main loophole that accounts for basing coming in

 when they may not be what they say they are? What is the main

 loophole that needs to be closed?

 CHAIR POWELL-PALM: And I know there's going to be

 follow-up here, Frank, so if you can keep your answer kind of

 short, and make sure to send your info to everyone to follow up

 with you.

 MR. AUSTIN: Yeah. Guys, so for anyone who wants --

I'm happy to go through all of the specifics of the data here

 in this example, and I could run a bajillion examples for you

 if you want. So just give me a call, shoot me a text or an

 email. That's totally fine. Happy to get on a call with you

 there.

 I don't really know what the main loophole is. If I

 knew, I would have made a whole pitch book and emailed it to

 you two weeks ago when I should have, and I would've had slides

 and all of that. I really don't know -- it seems to be -- we

 need to figure out a way to make them less agile. You know

 what I mean? So if you can restrict the agility of these

 people who are committing fraud, then they're not necessarily

 going to be able to bounce from one thing to another. Because 
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 in India, Post the anti-soybean dumping investigation is an

 excellent case study of that. Right? Because what we saw was

 this gap in the market where, like, suddenly all of these, you

 know, certified organic soybeans that were coming in

 consistently at a great price for everyone, they just

 disappeared when India went offline. But then a few months

 later, they reemerged. Suddenly, Canada's got it. And then

 just on that, I always used the same -- to keep it a one to

 one, I use 60 bushels an acre. That's a Midwest. You know,

 and that might be too gracious. It might be too light. But

 what it does do is it allows me to say how -- what is the

 percentage of U.S. acres planted to soybeans and what is the --

you know, in organic, and then what is the percentage of, you

 know, acres in Ghana planted to organic based on the data I

 have, right?

 And so in estimating those certified organic acres is

 incredibly difficult, but you know, what is NOSB's preferred

 margin of error. You know, would you prefer 10 percent of the

 soybeans to be fraudulent, 65 percent, 20 percent, zero? You

 know, I mean, that's a decision that USDA has to make. Does it

 really matter if it's 65 percent, or 10 percent, or 1 percent?

 It should be zero always. Because fraud just destroys a

 market. You can't have a real market when any percentage of

 the market is fraudulent. 

 CHAIR POWELL-PALM: We really appreciate this. We 
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 would love as much of this data as you can share with us. So

 we're going to pass around your info to the rest of the Board

 and we'll be in touch. Thank you, Frank. We appreciate it.

 MR. AUSTIN: Thank you so much. All right, guys.

 Have a great day.

 CHAIR POWELL-PALM: Michelle, is Justin Raikes on?

 MS. ARSENAULT: Justin is with us.

 CHAIR POWELL-PALM: All right. Justin, perfect.

 MR. RAIKES: Hello. Can you hear me?

 CHAIR POWELL-PALM: Yes, we can. Please go ahead.

 MR. RAIKES: All right. Thanks to the Board.

 Appreciate everything you guys do. My name is Justin Raikes.

 We're in eastern Nebraska. I'm a fifth-generation family

 farmer. We have been certified organic for I believe six year

 -- or five years now.

 Our operation employs about 20 people, a bunch more

 all in -- excuse me, a bunch more part-timers included. I just

 want to speak to the fraud issues fully. Fully appreciate

 support what Frank is saying and we agree. Just in the case of

 the 2022 crop year alone, you know, our price moved from 36 to

 21 in organic beans. To us -- cost us at least $225,000 in

 losses. I mean, it's -- it's a big number. The fraud is a big

 problem.

 We work very, very hard. Our whole team works very, 

very hard to follow the rules, not just the letter of the law, 
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 but the spirit of the law, work with our certifiers, and try to

 do everything we possibly can to protect the integrity of what

 we're doing, and of the program, and of the label.

 The other thing I would say is that we have a

 relationship -- we also sale retail beef. It's not organic,

 but we have a retail beef business and got some wholesale as

 well. And I would say through our retail relationships there,

 as well as some other ones that I'm privy to of large, well-

 known, national retailers, I can tell you that retailers are

 not -- are also not interested in carrying fraudulent products.

 They're very concerned with, you know, this issue. They're

 looking for guidance from NOSB, and from USDA, and so I know

 there have been a number of good ideas discussed at this point

 in time, including geotagging. But there's been a bunch of

 good ideas. I support all of them. I would encourage the

 Board to do everything it can to move forward to clamp down on

 the integrity of the program.

 And I'm happy to give the rest of my time to Frank or

 anybody else that's got something good to say. Thank you.

 CHAIR POWELL-PALM: All right. We really appreciate

 you calling in today. This is the theme. We are hearing it

 loud and clear, and we were are here for that action right now

 as necessary. So we're putting our heads together on that.

 Any questions for Justin from the Board? All right, 

 Justin, we really appreciate your time. Thank you for calling 
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 in during harvest, and thanks for all of your good work out

 there. 

Next up, we've got Ginny Olson, followed by Aaron

 Hobbs, and then Emily Musgrave. 

MS. OLSON: Hi. My name is Ginny Olson and I'm a

 crop insurance agent. I primarily work with organic growers.

 One of the most challenging questions I receive every year is

 what's considered a good farming practice. So, for example,

 can I plant my soybeans into rye, and then roller -- crimp it

 at end pieces? 

And so this question came to me probably about six

 years ago. And so the first year I asked my insurance company

 and it was given written approval that yeah, that's a good

 farming practice. Fast forward to the next year, I reached out

 to three different insurance companies, asked them the same

 question, including the insurance company that approved it the

 year before, all three of them said no, that's not considered a

 good farming practice. 

I took my letters that I received from experts and I

 emailed it directly to RMA and RMA came back and said, yeah,

 that's a good farming practice. You do not have to do a

 written agreement. 

So I sent my response from RMA to the three insurance

 companies and then they all said yes, we'll approve it. 

Here's my concern. If there's agents that are not 
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 getting pre-approval, there's farmers that are not being paid

 claims. And I know this for a fact because every year, I get

 calls from different farmers that I don't even insure that say, 

hey, should this be paid. They're being told during claim time

 that they're out of luck. They're not going to be paid a

 claim.

 So two years ago, I had five different farmers call

 me. All of them had different farming practices that played

 different scenarios. Fortunately, I was able to help three of

 those farmers. I didn't insure them, but I was able to help

 them by providing them the documentation I had on good farming

 practices for each different scenario.

 So three out of the five did get their claims paid,

 but the other two did not. And so my concern is the lack of

 consistency or no consistency at all. You know, farmers are

 doing what they think they should be doing. They're following

 what the expert advice is, but then coming -- at claim time,

 they're probably not getting paid a claim.

 I have reached out to many different experts, so

 extension offices, professors, you name it. And sometimes it's

 crickets on my end. I'll call them. I'll email them. And I

 won't get a response. One extension office told me directly,

 hey, we can see that this is a benefit, and we do agree with

 this good farming practice, but I can't put it in writing

 because we don't have enough data to support it. 
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 So even if your extension office does agree with you

 doesn't mean you're going to get a letter. Thank you.

 CHAIR POWELL-PALM: Thank you so much for your

 comments. Wood as a question for you.

 BD. MEM. TURNER: Thanks, Ginny. I'm really

 struggling to understand this issue, and I really appreciate

 all the comments we've heard about it. But I'm wondering --

are you saying that we're dealing with human error, human

 subjectivity, bias against organic. Tell me what you're saying

 because I'm -- really, I'm struggling with this.

 MS. OLSON: I think it's lack of education possibly.

 So for example, I have really good adjusters that want to do

 right, but when they're calling back in and saying, hey, you

 know, is this approved? The insurance company will shut them

 down faster. So I'm not sure that it's a thing against

 organics. I think it's just lack of understanding that hey,

 you can do different farming practices that may not be the norm

 -- that are not the norm for conventional.

 Because, you know, right, wrong, or indifferent. I

 could get in trouble for this, but I will -- I will talk to the

 insurance companies quite extensively and say, hey, could you

 provide the said adjuster training? Could you let them know

 that this is a common practice? Now, whether or not they do

 that instruction, I don't know.

 BD. MEM. TURNER: Thanks, Ginny. I appreciate the 
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 candor. I really do.

 CHAIR POWELL-PALM: Thank you so much, Ginny. This

 is very useful information, and we're going to keep working on

 it.

 MS. OLSON: Thank you, guys.

 CHAIR POWELL-PALM: Thank you.

 Next up we have Aaron Hobbs, followed by Emily

 Musgrave, and then Harriet Behar.

 Aaron, the floor is yours.

 MR. HOBBS: Thank you. Good afternoon.

 My name is Aaron Hobbs. I have the pleasure of being

 the executive director for the North American Coalition for

 Insect Agriculture, and it's a pleasure to be with all of you

 this morning. I'll admit, this is my first time to be with all

 of you, and I have certainly learned a lot. I'm excited to be

 here and excited to be a part of this conversation going

 forward.

 I come to you with really -- you could call it two,

 maybe three goals. Goal number one is to introduce our

 industry to all of you that are here, and at least an initial

 introduction about who we are, and then what it is that we're

 doing, and the work that we look to do with NOSB, as well as

 with the organic sector overall.

 So we are a traditional trade association

 representing folks that are growing insects. Primarily, three 
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 insects here in North America: crickets, mealworms, and the

 larva black soldier fly. And then providing those insects as

 ingredients into food and feed.

 And our membership is growing. Our industry is

 growing. We have an exciting role as part of circular

 agriculture. It's a really fun and interesting business that

 we're in. And our two areas of focus, at least initially, as

 we start to work with all of you, and as we start to understand

 this process, is number one, around our frass. Our byproduct

 from the rearing of our insects is frass, and we are looking to

 create a more consistent and hopefully more efficient process

 to have our frass certified as organic.

 Today, the way that frass is referred to, is only

 referred to in the negative in NOSB -- in documentation of the

 USDA, and it's created a lot of confusion around how we

 register our frass, and it's made that process very time

 consuming and very difficult.

 And so we're looking, number one, is to create a more

 consistent and efficient process for that. And number two,

 again, this is a very short-term goal as we look at the future

 of our industry. And that is getting our products able to be

 used up to that five percent inclusion rate for processed

 foods.

 So we -- for example, we sell our meal and oil into

 petfood, and to be able to include our products in an organic 
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 petfood, as one example, is something that we are looking to do

 here in the short term.

 Again, as we look at everyone that's on this call,

 the organic sector as a whole, this is a long-term investment

 and partnership that we are looking to start. But again, these

 are our first two priorities.

 So again, Aaron Hobbs. And we're excited to be here.

 We'll look to meet many of you hopefully in person in Rhode

 Island next week. And with that, I'd be happy to see what

 questions you all have.

 CHAIR POWELL-PALM: Thank you, Aaron. We appreciate

 your comments. Questions for Aaron.

 All right. We really appreciate you. See you next

 week.

 MR. HOBBS: The first guy with no questions. Tough.

 CHAIR POWELL-PALM: Nate Lewis has got you. Nate, go

 ahead.

 MR. HOBBS: Man, I really appreciate it. You saved

 me.

 BD. MEM. LEWIS: I had a question about the frass

 products. Are you looking to get those registered and approved

 for -- like as a crop input or --

 MR. HOBBS: Yes.

 BD. MEM. LEWIS: Yeah, okay. And then in that vein,

 livestock manure, there's a couple of different ways to reduce 
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 pathogens so you can compost it or you can process it. What's

 the typical process in the insect frass industry for reducing

 pathogenicity on those inputs?

 MR. HOBBS: Great question. So -- and for clarity,

 we do have some of our members today that already have an OMRI

 certification, for example. That process is just not one that

 is repeatable for many of our members, due to the feed stock

 that they're providing to their insects. Right? And because

 of the ability for inspects to process so many things, and have

 a safe and healthy product at the other end, it's just the

 process that currently exists is just not -- it's not going to

 work, or it would certainly limit our ability to participate in

 regenerative or circular agriculture. It would limit our feed

 stocks, etcetera.

 And so the -- as far as what are the processes? We

 have a variety of processes for how the frass is handled. The

 three insects, their frass is slightly different. And so the

 processes are slightly different as well. But we have some

 products that don't require any additional processing. They're

 below the toxicity levels, or below the detectable levels, and

 so there's no additional processing necessary. Others, it's

 heat. There's a variety of ways to do it.

 BD. MEM. LEWIS: I look forward to talking frass next

 week with you.

 MR. HOBBS: All right. Great. I'll be there. 
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 CHAIR POWELL-PALM: Kim, please go ahead.

 BD. MEM. HUSEMAN: Yeah. Quick question here for

 you, Aaron. Thank you for your comments today.

 You mentioned that from a protein standpoint, going

 into the petfood industry is kind of the market entry that

 you're looking to go into. Is that correct?

 MR. HOBBS: We are looking at providing our products

 into all food and feed. That was just the example that I've

 given. We have a lot of interest as of late in that sector,

 but it is across all food and feed.

 BD. MEM. HUSEMAN: Okay. And that's where I was

 going to go. Could you see this as a potential offset for a

 protein alternative into livestock feed?

 MR. HOBBS: Absolutely. Absolutely. One of the

 largest livestock companies in this country, Tyson Food, just

 made a big announcement in a partnership with one of our

 members two days ago. So yes. We are working on that as well.

 Working through the AFCO process, the ingredient definition

 approval process. Really excited about where that's going and

 the momentum we have there. So --

 BD. MEM. HUSEMAN: That is -- that's wonderful news.

 I think as we look at some of the barriers that we face in the

 livestock feeding aspect, and alternate protein sources, this

 has a lot of room for growth. So I look forward to chatting

 with you more, and hearing more about your progress too. 
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 MR. HOBBS: I agree 100 percent. So thank you.

 CHAIR POWELL-PALM: All right, Aaron. Appreciate it.

 MR. HOBBS: Thank you.

 CHAIR POWELL-PALM: Next up we have Emily Musgrave,

 followed by Harriet Behar.

 We are going to take a break for five minutes, and do

 -- get some rest, get something to drink, and then after the

 break, we're going to come back with Nicole Dehne, followed by

 Maddie Kempner.

 So Emily, the floor is yours. Please go ahead.

 MS. MUSGRAVE: Good morning. My name is Emily

 Musgrave. And an organic regulatory manager at Driscoll's. As

 always, I would like to thank the NOSB for their tremendous

 commitment by serving on the Board. Before starting, I wanted

 to say what a treat it was to hear from so many cattle ranchers

 on Tuesday. I really appreciated their comments and the

 questions for them by the Board.

 Although the organic community has many differences

 and great discussions that come from those differing opinions,

 we are a community with a common goal to advance and promote

 organic food and farming practices. And it's nice to remember

 and celebrate that.

 Though there's always room for constant improvement,

 I appreciate the positivity coming from the Board, and the

 inclusivity that is being shown in these meetings. I have to 
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 say the cattle ranchers upped the ante for clever comments, so

 we'll have to see if organic produce growers can match those.

 Now, my comments today focus on the continued

 allowance of plastic mulch and covers, but I will state that

 Driscoll's supports the relisting of elemental sulfur, liquid

 fish products, lime sulfur, and sulfuric acid on the National

 List as well.

 Additionally, I am voluntary member of the

 International Fresh Produce Association's organic committee,

 and Driscoll's supports the comments made by IFPA.

 Plastic mulch is an essential tool for organic

 cultural control of weeds and disease, while aiding moisture

 retention and increasing water use efficiency. Plastic mulch

 is widely used by Driscoll's organic growers across all berry

 types, but particularly used by organic strawberry growers.

 Driscoll's is actively working towards reducing our

 plastic footprint, and we know others in the agricultural

 industry are working towards the same goal. However, removing

 plastic mulch as a tool for organic growers without a viable

 alternative would be catastrophic for organic growers, who

 depend on plastic mulch to grow their crops, including organic

 strawberry growers.

 Although plastic mulch is not currently being widely

 recycled throughout the industry, we are starting to see more

 options available and anticipate the recycling of plastic mulch 
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 to keep increasing. This was not the case a short two or three

 years ago.

 Recycling companies are using innovative technologies

 to come up with solutions for this problem. Driscoll's is

 working on recycling pilot programs of plastic mulch in

 California and Baja that have had success.

 The widespread practice of recycling plastic mulch

 throughout the industry is a few years away, but there is hope

 on the horizon. Driscoll's will continue to partner with

 leaders on this issue to develop innovative ways to push the

 recycling of plastic mulch forward to become an industry-wide

 practice. In the meantime, the loss of plastic mulch as a tool

 would be catastrophic for the organic berry industry, and we

 urge the NOSB to relist it.

 Driscoll's thanks the National Organics Standards

 Board for the opportunity to comment and their commitment to

 protecting the integrity of the program.

 CHAIR POWELL-PALM: Thank you so much for your

 comments and for joining us today. Jerry has a question for

 you.

 BD. MEM. D'AMORE: Emily, hello. How are you?

 MS. MUSGRAVE: Good. Hello, Jerry.

 BD. MEM. D'AMORE: Nice job. I just have one

 question and it's not a trick question. It's what leads a lot

 of my thinking and perhaps the thinking of others in terms of 
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 how effective we can be in getting some movement on this topic.

 And the question would be what percentage of your

 strawberries are organically grown?

 MS. MUSGRAVE: That is a good question. So it does

 depend on which region you're talking about, right? Because we

 grow throughout California. We grow in Baja. We grow in

 Central Mexico. I will say, it's the highest in Baja, for

 sure. I think in Baja, actually, 100 percent of our

 strawberries are organically grown in Baja, but probably across

 the board, if you averaged it out, don't quote me for sure, but

 I want to say it's probably like 20-ish percent of our -- of

 all of Driscoll's strawberries are organic.

 BD. MEM. D'AMORE: Thank you for that number. It's

 bigger than I would have guessed, and I would then have to say

 that your organization is probably much higher in that

 percentage than most. And the reason for the question is that

 it becomes a question to you is what are the chances that we

 can really move this needle as organic when conventional is

 right there.

 And so the question I have is how much of your time

 do you spend with the conventional side, working on exactly

 this issue?

 MS. MUSGRAVE: That is a really good question. So

 and speaking just to talking about plastic mulch, right?

 BD. MEM. D'AMORE: Yes, ma'am. Yeah. 
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 MS. MUSGRAVE: Yes. So actually, there's plenty. I 

 mean, none of our -- none of the growers want to see the

 plastic mulch going to the landfill, right, whether you're

 organic or conventional. So I know we have plenty of growers,

 conventional and organic, plenty of conventional that were

 looking, you know, into biodegradable biobased mulch, plenty

 that want to do the trials in conventional to not have this

 mulch going to the landfill. So it's across the board.

 I don't see any -- I mean, all the growers do not

 want this mulch going to the landfill. I mean, we work with

 organic and conventional across the board. And many of our

 organic growers also have conventional. So they'll -- you

 know, they both -- it goes both ways.

 BD. MEM. D'AMORE: Emily, that's a great answer

 because my personal opinion is we will not move the needle

 unless we're all in this together.

 MS. MUSGRAVE: Exactly.

 BD. MEM. D'AMORE: Thank you.

 MS. MUSGRAVE: Thank you.

 CHAIR POWELL-PALM: Nate, please go ahead.

 BD. MEM. LEWIS: Thanks, Emily. The question is as

 you kind of mentioned, there's a growth in availability

 recycling capacity. Do you envision there -- I mean, I'm

 trying -- do you think there's an open door to perhaps making

 recycling a requirement for use of plastic mulch sort of into 
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 the future? Or is there some parameter there. Not trying to

 sort of pigeonhole you on that one, but more just trying to

 think about how we can encourage that practice.

 MS. MUSGRAVE: That's a good question. The

 requirement -- I mean, maybe -- I don't think we're quite there

 yet on the requirement just simply because there's still not

 the facilities around to take it to. So I mean, I think that

 would be really tricky if you made the requirement and then

 growers were like, there's nowhere in the area that is going to

 take it. So that is a really good thought. And I think that's

 the right direction. I think we just need to make sure that we

 would be there, right, with enough facilities before you make a

 requirement, because otherwise, it would be a requirement and

 then, you know, growers couldn't meet it because there's not

 the recycling available. So but getting there, and a good

 though.

 CHAIR POWELL-PALM: Jerry, please go ahead.

 BD. MEM. D'AMORE: This is for Nate, if I may. As

 you ask that question, Nate, were you asking Emily a

 requirement into the organic program or a requirement into the

 overall conventional and organic program?

 BD. MEM. LEWIS: Well, we don't really have much

 control over conventional ag, so --

 BD. MEM. D'AMORE: But the answer, I think, drives a

 lot of our thinking; does it not? 
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 BD. MEM. LEWIS: Sure. Yeah.

 BD. MEM. D'AMORE: Okay. Thank you. Thank you very

 much.

 CHAIR POWELL-PALM: All right. Thank you very much,

 Emily.

 Next up we have Harriet. And then we're going to

 break for five minutes. And then Nicole Dehne, Maddie Katner,

 and Jaydee Hanson after the break.

 So Harriet, if you are there, the floor is yours.

 MS. DEHNE: Hi. I am Harriet Behar with the Organic

 Farmers Association. I'm a past NOSB chair and a certified

 organic farmer, and a longtime advocate for organic integrity.

 Please refer to my written comments, as well as those of the

 Organic Farmers Association and the National Organic Coalition

 for more detail on these issues.

 Vaccines. The current rule mandates a GMO vaccine --

 in order for a GMO vaccine to be allowed in organic, it must be

 reviewed, approved, and placed on the National List. The

 National Organic Program is allowing accredited certifiers to

 ignore this part of the rule, and some allow GMO vaccines or do

 not even inquire what is the GMO status of vaccines used on

 organic livestock.

 It is a dangerous precedent to allow the section of

 the rule to be arbitrarily ignored. The previous NOSB

 recommendation to allow GMO vaccines if there is no 
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87

 commercially available, non-GMO vaccine, is a workable solution

 to this issue, and the current NOSB should pressure the NOP to

 implement this as soon as possible.

 Consistent location identification. The proposal has

 some merit, but organic farming is very diverse, with producers

 having various knowledge and willingness to engage with

 technology, as well as a variety of ways of farming their

 various fields. The current proposal mandates the use of GMOs

 coordinate -- GPS coordinates for all organic locations. And

 this proposal should go back to subcommittee and remove the

 mandate.

 This should be seen as one of the many ways to locate

 organic production. There are many scenarios for both small

 and large farms where this mandate would put a significant

 burden on farmers.

 Excluded methods. The recent secure rule by APHIS,

 which does not require -- does not, excuse me, recognize gene

 editing, such as crisper, as genetic engineering. The USDA has

 not required a marker to be put in these gene-edited seeds. So

 use of testing to determine if there has been gene editing is

 impossible.

 The developer of the seed does not need to inform

 their buyers that the crop was gene edited. Our organic

 friends in Canada have a similar rule, and we and they are

 concerned that protecting organic from this form of genetic 
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 engineering will become very difficult.

 Please pressure the NOP to adopt the NOSB

 recommendation on excluded methods, which state gene editing is

 considered genetic engineering in organic. The CACS

 subcommittee needs to have a gene-editing issue on their work

 agenda.

 Hydroponic. The members of the Organic Farmers

 Association have consistently identified the false organic

 certification of hydroponic as a priority issue. If you noted,

 many of the written public comments also expressed this same

 concern without even being on the agenda. This is not a

 settled issue.

 Thank you very much.

 CHAIR POWELL-PALM: Questions for Harriet? Amy,

 please go ahead.

 BD. MEM. BRUCH: Yeah, thanks, Nate. Harriet, thank

 you for your time today. Appreciate the written comments you

 represented, and you submitted, and your oral comments also,

 and your last service as Board chair.

 I have a question just to unpackage a little bit

 about, you talked about the consistent or standardized location

 information document that we have for CACS, the proposal. In

 terms of GPS coordinates, we also mentioned that it could be

 street addresses, parcel numbers, and legal addresses because

 those could eventually lead to geocodes. And when we heard 
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 from the plain's community last public comment process, parcel

 numbers seemed to be something that farmers were knowledgeable

 about and worked with, just because you have to pay your

 property tax.

 Do you think those are acceptable also? The street

 addresses, parcel numbers, or legal addresses like the Township

 range section?

 MS. BEHAR: Yes, I do. Especially in concert with

 more than one. I mean, just obviously a street address

 doesn't, you know, for 1,000-acre farm is not going to tell you

 which field grew soybeans. But a group of those -- but this

 mandate of having GPS location be part of the mix, I'm not

 against it being part of a larger mix, but to have it be the

 one mandate, I think that has gone a little bit too far.

 And actually, even in a larger field, you can stand

 in one part of a field and get at GPS coordinate, and then

 stand in the south side of the field and have a totally

 different GPS coordinate. And then farmers, as you know, they

 break up their fields. And one year, it's 5A, and then the

 next year, you know, it's now 5A(1). And so there's a lot of

 little issues, having been an organic inspector, that I can see

 having the GPS coordinate being a mandate be -- just become

 kind of a nightmare in tracking those numbers.

 BD. MEM. BRUCH: Okay. Thank you.

 CHAIR POWELL-PALM: I just have a quick question for 
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 you, Harriet. What language would you like to see in this

 document to clarify that this had nothing to do with members'

 burden, it is only on certifiers?

 MS. BEHAR: Well, I am a little bit concerned too

 that people in the Plain community may not want that. I've

 even had them tell me they don't want aerial photographs of

 their farm.

 So I just think that having it be a mandate -- I

 mean, the certifiers can say if this is working for you, we

 would like it. But to mandate it of every single farmer in

 every single field and every single location, I think will be a

 big burden not just only on farmers, but on certifiers too.

 So I'm not against it. I just don't think it should

 be a mandate.

 CHAIR POWELL-PALM: All right. Mindee, please go

 ahead.

 VICE CHAIR JEFFERY: Thank you, Harriet. Did I hear

 you say that CACS should have gene editing on their work

 agenda? And if you did, would you mind saying a little bit

 more about what the outcome would be there?

 MS. BEHAR: Yes. So APHIS, the Animal Plant Health

 Inspection Service of the USDA two years ago, or maybe it was

 just a year ago, has approved gene editing to not be labeled,

 and they've kind of said that that basically -- if it was not a

 plant pest, or if the developer determined that it could have 
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 been accomplished through natural hybridization or natural

 mutation, that the USDA does not consider it genetic

 engineering.

 And since the NOP is under the USDA, if we want to

 maintain gene editing as an excluded method in organic, we need

 to have the NOP accept that NOSB recommendation, which

 recognizing gene editing as organic.

 I became first aware of this because someone from

 Canada contacted me because they just recently had this happen

 to them as well, that there will be no knowledge of people

 buying basically non-organic seed. I don't even know if those

 who were growing organic seed would know if their foundation

 seed had been gene edited, because it would not be considered

 genetically engineered.

 And the USDA, they could have said that there would

 have had to have been a marker in there so it could've been

 tracked, but they did not mandate that. And so therefore,

 there was no way to test to find out if it's been gene edited.

 Right now, the only commercially available crop is

 mustard greens. They gene edited it to make it less bitter.

 But wheat, corn, rice are all in the pipeline. So this is

 something that will come to the forefront fairly quickly that

 right now the U.S. Department of Agriculture recognizes gene

 editing as not genetic engineering if it met those first

 criteria. 
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 VICE CHAIR JEFFERY: Yeah. Thank you. So do you

 think that there's something very specific CACS can do to help

 prescribe our ability to find those things through the

 certification and inspection process? Or you didn't have

 another more specific suggestion there? Honest question.

 MS. BEHAR: Well, I think you need to look into the

 issue. I think you need to talk to people in Canada, who are

 dealing with the same issue, very concerned, especially that

 their wheat will be gene edited, and that maybe what's going to

 happen in their marketplace is that the EU may say, since we

 can't track whether your wheat was gene edited, we're not going

 to accept any organic wheat out of Canada. This is what their

 concern is. And I really do think that the National Organic

 Program needs to stand up and say that under organic, we

 consider gene editing a genetic engineering practice.

 This is when the gene is just edited. No other gene

 is inserted from a different species or breed. And it -- you

 know, basically, they said if someone determines that it could

 have been done naturally -- it could have happened naturally,

 that it's not considered genetic engineering.

 CHAIR POWELL-PALM: Allison, please go ahead.

 BD. MEM. JOHNSON: Thanks for your commentary and

 your leadership in organic. We really appreciate you.

 Back to locations, I take seriously your concern

 about really causing problems unnecessarily, and having been in 
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 the certifier seat, I can think of instances where, you know,

 very minor requirements spiral into something that was messy,

 and it didn't need to go that way.

 So I'm wondering if there's language that we could

 add to the recommendation that provides a little room for a

 religious exemption, or in those rare circumstances where it's

 not appropriate to have a GPS location, that let certifiers

 know that they can find some other reasonable accommodation.

 The generally, the expectation is GPS locations, but create

 some sort of little caveat there to provide comfort and

 flexibility. Would something like that address your concerns?

 MS. BEHAR: Yes, it would. And I think you just have

 kind of a menu of the various items that can be used, and it's

 really up -- if the certifier can't figure out where the field

 is, that is a problem. And so it could be a mix of aerial

 photographs, GPS or not, parcel number, section and town. I

 mean, addresses. All of those things. And that's a menu. And

 then if you only need three of the five to be able to locate

 it, then that's sufficient. But if for some reason you can't

 find it, you know, then you have to add more in that menu.

 BD. MEM. JOHNSON: Yeah. I think what we're going

 for is like simplicity and consistency. And so I'm trying to

 figure out if there's some narrow addition that we could add

 there that gets at religious concerns, cultural concerns. Like

 I wouldn't want this requirement to be the deal breaker for any 
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 farm. So what can we do to make sure that it's not, and still

 get at that simplicity and consistency goal.

 MS. BEHAR: Well, I think just having it be a

 mandate, you know, moves it to this higher -- because there's

 no mandate that the township and parcel number has to be there.

 There's no mandate, you know, for an aerial photograph even.

 But now you've made GPS the way of finding organic locations.

 And I think that's a problem. It should be part of a suite of

 options for the certifiers to use and for the farmers to

 provide.

 BD. MEM. JOHNSON: Okay. Thank you for clarifying.

 CHAIR POWELL-PALM: Other questions? All right.

 We're going to go on break. Thank you, Harriet. We're going

 to go on break for five minutes.

 MS. BEHAR: You're welcome.

 CHAIR POWELL-PALM: Let's come back at 18 after. And

 after the break, we're going to have Nicoe Dehne, Maddie

 Kempner, and Jaydee Hanson.

 (Off the record at 2:13 p.m.)

 CHAIR POWELL-PALM: And we are back, folks. I hope

 you had a good break.

 First up, we're going to start with Nicole Dehne,

 followed by Maddie Kempner, and then Jaydee Hanson. Nicole, if

 you're there, the floor is yours.

 MS. DEHNE: Nate, thank you. Can you all hear me? 
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 MS. ARSENAULT: Can I have you pause just for one

 second because I don't see all of the Board members back yet.

 Nate runs faster than everyone.

 MS. DEHNE: He was very accurate. He was back at

 2:18.

 MS. ARSENAULT: Nate, just FYI, Maddie Kempner was

 unable to join, so you can skip her comment.

 CHAIR POWELL-PALM: Okay. Thank you. Just give me

 the thumbs up, Michelle, when we're ready.

 (Pause.)

 MS. ARSENAULT: Five minutes is not very long, Nate,

 I have to say.

 CHAIR POWELL-PALM: It's not. No. I just wish the

 comments weren't so dang good this round. Gosh, this is some

 good conversation, but it takes time. So we're not late.

 We're right where we should be, but we're running fast.

 All right. We've got Logan, and Dilip, and Carolyn,

 and Allison. Allison said she's here. Okay.

 MS. ARSENAULT: All right. Thanks, Nate. Thanks.

 CHAIR POWELL-PALM: All right. Nicole, please go

 ahead.

 MS. DEHNE: Okay. Sorry. It took a little bit to

 unmute there. So my name is Nicole Dehne. I'm the

 certification director for Vermont Organic Farmers, LLC. We're

 the certification agency that's owned by NOFA Vermont. We 
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 represent close to 750 organic producers in the State of

 Vermont. And I do want to thank the NOSB and the NOP for all

 of your hard work. We all appreciate it.

 So I'd like to comment today not on any specific

 agenda item, but to discuss a broader topic of concern that

 we're noting in Vermont, but I believe is also felt beyond our

 state, and this is the increased record keeping and paperwork

 burden on certified producers.

 So over the decade, all the comments here today,

 right, we're really focusing on working hard to reduce fraud

 and improve enforcement of the organic regulations. And I

 certainly don't want my comments to be misconstrued as not in

 support of that.

 Obviously, this work as culminated in the recent SOE

 rule, but we are now at a crossroads for how we implement and

 interpret this rule. So I'm concerned that if we use this rule

 to require more records and paperwork, we are going to be

 discouraging small farmers and processors from getting

 certified, and that we're likely going to see currently

 certified producers drop their certification.

 So the vast majority of our farmers in Vermont

 wholeheartedly believe in organic farming practices. So

 whether, you know, certification existed or not, they would be

 using these practices on their farms and in their processing

 facilities, but many of them are struggling with keeping up 
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 with the record keeping requirements that we're demanding of

 them, and ironically, we could lose these growers, despite

 their alignment with the practices.

 And I think it's really important to keep in mind

 that records are clearly important. Records and audits are

 important. I'm not saying that. But they're not the whole

 story, right? Records and paperwork can be falsified.

 We recently had our NOP audit, and I had our auditor,

 you know, somewhat in jest say to me, you know, Nicole, if it

 isn't written down, then it didn't happen. But like the

 absurdity of that idea also really struck me, because obviously

 things can be written down that don't happen.

 So putting too much of an emphasis on the paperwork

 means that we could be missing what's actually occurring on the

 farm. And I'm imagining an inspector furiously calculating dry

 matter intake from pasture, but you know, not looking up at the

 actual pasture to determine if there's enough grass on the

 ground to meet that number, right?

 So my point is that paperwork and audits can tell you

 some things, but they can't tell you everything. So I do have

 suggestions. I think we need to invest in education. I think

 our producers are going to be most successful when they adopt

 organic practices because they believe in them, because they

 see that they work versus that they're just seeing the benefit

 of a higher price. The top is a great start in this direction. 
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 But we also need to have a sound and sensible approach when

 we're using record keeping, noting that it is a tool and that

 we can overuse a tool. So we don't want to only depend on

 records to prove compliance. We want to have a 30,000-foot

 view on why we're asking for the record and what we're trying

 to verify, right?

 And then most --

 CHAIR POWELL-PALM: Go ahead and finish up.

 MS. DEHNE: Okay. Thank you.

 Most importantly, I really want to stress, I think we

 need to start treating operations differently. So I feel like

 SOE is giving us an opportunity to assess each farm and their

 processing facility, that they're at a different risk level,

 right? And we use that risk level to determine what proof we

 need to verify their practices.

 So yes, some operations that are commodity operations

 that are complex supply chains, they're going to be required to

 provide more proof and paperwork, while those farms selling

 direct to consumers will provide less.

 And I'm happy to talk about the GPS requirement

 proposal, and how it kind of relates to this too. Thank you.

 CHAIR POWELL-PALM: All right. Thank you. Questions

 from the Board?

 I'm going to ask you a very -- go ahead, Kim.

 BD. MEM. HUSEMAN: I'm going to open the floor, 
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99

 Nicole, for you to go ahead and talk about your suggestions on

 GPS.

 MS. DEHNE: Thank you, Kim.

 Well, I was just thinking as we were talking about

 this, as this was being discussed, that, you know, we don't

 have that problem in Vermont of locating fields. Like, that is

 just not something that we're dealing with as an issue. And I

 was sitting here wondering why.

 I think partly, we're a little bit more developed

 here in the east, in Vermont, so there's going to be less of

 residential areas. The maps that we're asking for are getting

 us, you know, the intersections of roads and we can easily find

 them, both for unannounced inspections if we needed to do that,

 but most of the time during our inspections, the producer is

 driving us to all the fields.

 So, like, that's a good example of how, like, we're

 not actually going to catch fraud in Vermont by requiring that,

 and it might just be an additional burden that doesn't actually

 solve the problem.

 So my real point is like we -- I think we need to

 stop thinking that every operation needs to be treated in the

 same way and really evaluate the risk and say, like, hey, this

 is the record keeping required for this particular operation

 because their risk is low.

 CHAIR POWELL-PALM: Kyla has a question for you. 
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 BD. MEM. SMITH: Hi, Nicole. Thanks so much for your

 comments. I'm like steeped in SOE myself, so they're really

 resonating with me. I'm like forming this thought as I'm,

 like, speaking so bear with me if it's a little clunky.

 You are speaking about the requirements more so in

 how they might -- how we might see attrition from certified

 farmers. Also, within CACS, we have that transition document.

 And so I've been thinking about this throughout the comment

 webinars this week, but you know, I do a lot of the mediation,

 informal mediation that PCO and they almost all of them are

 because of record keeping.

 And so it's a real -- seeming like a real challenge

 for those who are certified and I know that it is a barrier for

 certification. And so I guess I'm just, like, wondering about,

 like how -- like I think someone's also talked about like

 transitioning farmers. I think maybe that was Mike Dill.

 Anyway, he was like talking about transitioning farmers versus

 transitioning land. And so I guess I'm just wondering about

 what does that -- how does record keeping and having better

 record keeping systems come into play to not let that be a

 barrier to transition?

 MS. DEHNE: This is transition. I think -- I mean,

 all of this transition work, I think, is going to benefit our

 certified producers too. So I think we do need, as an

 industry, since we're increasing the level of record keeping 
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 requirements, and we are. In the old days, we used to say, do

 you have records that we can audit? You know, like are they

 auditable. And now we're actually doing the audits. And I

 think those are good improvements, but we have to admit that

 they have changed.

 And so I think really helping our producers to

 understand the requirements, and have a better understanding of

 what to expect at inspections, you know, so they can be

 prepared. Anything that we prepare for transitioning producers

 is going to help our certified producers too. But I really

 think that it's very easy for us as certifiers and inspectors

 to just require a record because it's easier to say that it's

 needed than it's not needed, right?

 But if -- but like an example would be -- we have a

 lot of producers who harvest for a specific market. So they

 might say, like, I've got an order from the co-op for carrots,

 so I'm going to harvest for that market, right? So their sales

 records, then, are essentially their harvest record because it

 shows what they've harvested.

 So like we need to not say, you also need a harvest

 record. We can say, sales records can be the information that

 we need to verify your harvest. Listed the date that you

 harvested it, listing the amount you harvested, just -- is it

 the same date you sold it.

 So taking that 30,000-level foot view to say hey, 
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 this makes sense. And I think part of the way we're going to

 have to do that is to say what are we trying to verify here,

 and then ask ourselves whether we -- what we need to see.

 CHAIR POWELL-PALM: I just wish we could dedicate the

 rest of the day to this topic because I have so many ideas and

 questions right now. So we will follow up. Will you be in

 Providence, Nicole?

 MS. DEHNE: Yes. And I'm happy to talk more.

 CHAIR POWELL-PALM: Okay. We should grab a coffee.

 I would just throw out there this question -- I mean,

 these are the questions. So just thank you for bringing this.

 I think this is really where we're at right now is how do we

 not let perfect be the enemy to the good. How do we really

 make sure that we're actually getting at, you know, integrity.

 And I think I would just throw out there, what is the

 role of consultants here. Are we putting too much on farmers

 for them to even be managers of their own OSBs, or should there

 be more push of consultants to take that burden off. Not sure.

 But I would love to explore that with you at some time.

 Thank you again for your comments. Appreciate you.

 Next up we've got Jaydee Hanson, followed by Steve

 Ela, and then Anne Ross. Jaydee, if you're there, the floor is

 yours.

 MR. HANSON: Thank you. I always have to unmute

 first. 
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103

 It's nice to see you again, and nice to see the whole

 board, and thank you all for your long hours of work.

 We've -- the Center for Food Safety has been closely

 involved with the National Organic Coalition comments, and we

 want to support those in addition to some add-ons that we've

 made.

 We're focused on three things. My colleague, Sylivia

 Woo, is going to talk about inerts in pesticides and I'm going

 to talk plastics and GMO vaccines.

 The Center encourages the NOSB to initiate

 discussions on setting priorities for reducing plastic used in

 organic production and handling, and suggests you start the

 process by breaking the discussion into two parts. First,

 plastic use and production, and second plastics used in

 packaging.

 Within those two areas, need to identify which

 plastic uses are essential and which can be moved away from.

 For right now, plastic pipe, and greenhouse trays, and maybe

 plastic mulch are essential, but I would be careful about

 assuming how much of any plastic is recyclable. In communities

 across the U.S. and across the world have found that the

 plastic manufacturers were misrepresenting the market for

 recycling their plastic.

 The other area that should be looked at is the fate 

 of micro and nanoplastics on farms. We need to understand what 
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 these plastics are doing to our soils. We already don't allow

 composts made from biodegradable compostable plastics, but

 other sources of plastics and soils that we should be aware of

 and assess.

 We've talked to you before on problems of PFAS (ph)

 and our organization is pushing the EPA and the Food and Drug

 Administration to greatly curtail the use of ortho phthalates,

 PFAS, and bisphenols. We have worked a lot on that, and I'll

 just urge you to read our things.

 We think the 2019 recommendation on vaccines needs to

 be implemented, and I second what Harriet Behar said on other

 excluded methods.

 CHAIR POWELL-PALM: Thank you for your comments.

 Questions from the Board?

 All right. Thank you very much, Jaydee.

 MR. HANSON: Thank you very much, and unfortunately,

 we're going to be talking about plastics and excludes methods

 for a long time. And I'll look forward to seeing you in

 Providence. Bye.

 CHAIR POWELL-PALM: All right. Take care. Thank

 you.

 Next up, we have Steve Ela, followed by Anne Ross,

 and then Linley Dixon.

 Steve, I have just been waiting for that background. 

 Oh my gosh, good to see you. 
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 MR. ELA: Good to see you as well. And I just want

 to say, it is a pleasure and a privilege as always to see you

 all. It's great to see all the familiar faces.

 So good afternoon. I'm Steve Ela with the National

 Organic Coalition, NOSB specialist, and organic fruit grower

 here in western Colorado, as well as a former NOSB member.

 NOC appreciates the work of the Board that

 distributed a document on inert materials for public comment,

 despite the fact that it could not be included in the formal

 NOSB material packet for the fall. The Board's diligence and

 work on this topic is noted and appreciated.

 Inerts should be individually listed on the National

 List. OFTArequires that materials be listed individually. The

 National List is inherently a positive list, meaning that

 synthetics must be listed in order to be used. So accept a

 broad category listing and then expect the organic community to

 petition for prohibition of certain materials turns the list

 into a negative list, something that runs against the basic

 principles of the use of synthetics and organics.

 It also puts the onus on the organic community to

 petition to keep endocrine disrupters and carcinogens out of

 organic production, when in fact, the onus should be on the

 user to show that the synthetic is needed.

 Furthermore, if only a reference to a broad EPA 

 category is used, the organic community has no way of even 
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 knowing what materials are being used, since only a material

 review organization would have that information.

 If we simply move from list 4 to a reference to

 another EPA category, we are taking proverbial frog in the pot

 of boiling water, and simply moving it to another pot of

 boiling water, rather than rescuing the frog. I'd be happy to

 talk more about this if you have questions.

 NOC recognizes that individual listings will take

 work, but we have provided ideas for reducing the Board

 workload in our written comments. For example, materials could

 be grouped into classes, and reviewed as a class, similar to

 how the Board treats coppers and flooring materials. Each

 material is specifically listed on the list, but the Board does

 one sentence write up for the group, and then makes any

 specific notes upon materials slightly different.

 On a separate note, NOC urges the Board to ask for a

 work agenda on organic slime management. Slime were primarily

 admitted from the OLPS and should be covered in similar ways.

 NOC also urges the Board to start work on the use of

 excluded methods and fermentation. This is a rapidly expanding

 field, and one that we must get a handle on before we

 inadvertently start allowing excluded methods in organics

 because we simply don't know where and when they are being

 used. 

A prime example is the work agenda item on 
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107

 biodegradable, biobased mulch film, where it is acknowledged

 that excluded methods are being used to make the films. If we

 don't establish a policy on the use of excluded methods on

 permutations soon, we risk losing control of the whole topic. 

Finally, NOC will continue to raise the issue of the

 potential environmental damage on marine ecosystems from

 harvesting of marine materials for use on organic farms. This

 applies specifically to liquid fish and alginates, but also

 more broadly to any marine materials used in organic products.

 We support the use of these alginates and liquid fish, we just

 don't support marine degradation and their use. 

Since National Organic Coalition is known as NOC, I

 will finish with a knock knock joke. So, Nate, knock knock? 

CHAIR POWELL-PALM: I wanted to make sure I was

 unmuted. Who's there? 

MR. ELA: Gum. 

CHAIR POWELL-PALM: Gum who? 

MR. ELA: Gump-tion. The Board should have the

 gumption to add annotations to all the gums and other materials

 on 605, requiring the use of organic materials when they are

 commercially available. We have seen organic gums used in a

 variety of dairy products from major producers, showing that

 they are certainly commercially available. Thank you. 

CHAIR POWELL-PALM: You know, if we required a knock

 knock joke after every single comment, I just only imagine the 
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 wonderful world we would live in. So thank you, Steve. 

 MS. ELA: Well, I'm inspired by Kim's Dad jokes.

 CHAIR POWELL-PALM: Dilip, please go ahead.

 BD. MEM. NANDWANI: Thanks, Steve, for your wonderful

 comments. I really appreciate that.

 I'm just wondering about NOC's position on gene

 editing, since you had mentioned excluded methods. I heard

 earlier that gene editing, it might be considered as a genetic

 engineering. I don't know it's in Canada or elsewhere also.

 So could you please just a little bit elaborate on that gene

 editing, NOC's position, thank you.

 MR. ELA: Yes. I think NOC is very concerned about

 the use of gene editing, not following traditional breeding

 techniques, and certainly crisper is of concern and something

 we're talking a lot about, and especially we'll have some calls

 scheduled here shortly with talking about the Canadian side of

 things.

 I think one of the things that -- like Jaydee Hanson

 and Michael Hanson have mentioned, or didn't mention is that

 we're seeing more issues with the crisper technology as not

 being quite as clean as it was originally made out to be. And

 so we're seeing some kind of mutagenic, carcinogenic effects

 within the plants or animals where that's been used.

 And so that raises concerns for us that while it has

 been touted to be very clean, very precise, maybe it's not 
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 quite true that way. So it's something we certainly want to

 keep an eye on. And we certainly don't want to have

 inadvertent use of some of these gene edited plants or seeds in

 organic production without people knowing that it's happening.

 BD. MEM. NANDWANI: Yeah. Thanks. I think the gene

 adding or removing, it's genetic engineering. Just a thought

 very quick. Thanks again.

 MR. ELA: Agree.

 CHAIR POWELL-PALM: Nate, please go ahead.

 BD. MEM. LEWIS: Thanks, Steve. I continue to hear

 commenters share their opinion that OPA and National List

 criteria require inerts to be listed individually. And I'm

 curious what your thoughts are on how that contrasts with all

 the other lists that we have on the National List, and whether

 those are just the next -- it's not target, but those are the

 next things we'll need to unpack.

 Because we have lots of classes of materials

 reference -- I mean, even in 601, we've got dormant oils,

 pheromones, micronutrients, right? And so we do use the list a

 lot -- the concept of list a lot. So what's unique about

 inerts for why we need to list those ones individually?

 MR. ELA: I guess I would disagree somewhat. I think

 the National List is primarily of specific materials and that

 the exception is referencing to a list. And I would even say

 dormant oil is fairly specific. I mean, there are -- that is a 
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 fairly tight category. It's not as broad as maybe you say. 

 So I would say, you know, we -- those are the

 exceptions and that, you know, they were often used as a

 shorthand to get things done early on when resources were

 scarce. So I don't think that we should let the fact that

 there are still other lists on the National List deter us from

 doing better at what we're doing now, and especially given the

 inert situation where it's a defunct list, I think we need to

 move ahead on that.

 And I think it would be wrong to say that, well,

 we're going to ignore OFTA yet again. You know, we can chip

 away at these things, and now is the time for inerts.

 I also think -- you know, I've heard a lot about

 essentiality and the question of confidential business

 information, like how would the Board decide if an inert is

 essential if it's confidential. The reverse happens though.

 If a stakeholder is submitting a petition to prohibit

 an inert, how are they going to know about essentiality? I

 mean, it's -- that's going to be a problem whichever side we

 look at it, whether they're listed or not listed. So I think

 NOC's push is let's have more transparency. We want to be able

 to know what materials are being used in organics, because you

 can't submit a petition on a material that only an MRO knows is

 being used.

 So we -- it's just very difficult to be able to track 
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 it. And we thank OMRI for putting together the list that we're

 all referencing of what materials are being used. Otherwise,

 we -- none of us would be able to even talk about this.

 CHAIR POWELL-PALM: Amy, please go ahead.

 BD. MEM. BRUCH: Yeah, thanks, Nate. Steve, hi.

 Good to see you again. Thanks for your prior service as Board

 Chair, and for all the comments you helped write this go

 around.

 Anyway, I wanted to ask you on risk, so this is

 regarding NOC's comments on residue testing for global supply

 chain. A lot of certifiers point to using the matrix -- to

 certify our matrix for risk and there's many points about it,

 depending on crop, region.

 There's a point in it that says about split or

 parallel operations. One trend that I'm noticing is that

 operations are organizing, for various reasons, conventional

 production under one company name, and organic production under

 another. And I believe you mentioned, you know, maybe

 expanding this to handlers. I think they're organized and can

 be organized.

 Similarly, if that circumvents them being included in

 the risk umbrella assessment, do you have ideas on how to

 evaluate these mixed production operations, even if they aren't

 declaring that they're mixed production?

 MR. ELA: I think that's a great question. And I 
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 think the first thing is, you know, the inspection. When you

 go in and the company is organized under two different names to

 avoid being split or parallel, and you go into the warehouse,

 and it's obvious that there is not segregation or that the --

you know, the two things are being run simultaneously in the

 same warehouse, then I think the inspector has to raise some

 questions and say, well, you know, how are you keeping these

 things separate, even if it is from a different company, you

 still need to designate and show how this is separate.

 And that might -- you know, the inspector should

 raise a risk flag and say, you know, this is an operation that

 is in a -- you know, in a split facility, and you know, that

 risk should be, you know, rated higher.

 I mean, I will say we rent some warehouse space from

 a food hub that has -- you know, that deals with conventional

 and organic products, and it's going to be a challenge for them

 to certify, but it's going to be a good thing because it's

 going to guarantee that organic integrity. And I think that's

 really important.

 BD. MEM. BRUCH: Okay. Thanks, Steve. Appreciate

 it.

 MR. ELA: I think the inspection is going to be real

 key in that, in identifying are there things next to each other

 that may be contaminated or commingled, or are they physically

 -- are there physical barriers keeping them separate. 
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 CHAIR POWELL-PALM: Brian, please go ahead.

 BD. MEM. CALDWELL: Yeah. Hi, Steve. Glad that

 you're here. Looking forward to hopefully talking with you

 quite a bit next week. But I'm wondering if you could share

 with the group some of your insights from all your past work.

 And I realize that -- I haven't let you know about this at all,

 so this -- if you can't answer it, it's fine.

 But I'm wondering what do you think is the potential

 for NOSB and the NOP program to make requirements that sort of

 go beyond the other governmental requirements, like

 specifically. Could we do things like require that inert

 ingredients be publicly disclosed in organically approved

 pesticides, even though that's sort of, you know, privileged

 knowledge in other uses; or could we require for instance that

 any plastics used in organics be verified by the manufacturer

 to not include PFAS and, you know, BPA and phthalates, that

 sort of thing, things that we know are dangerous components?

 So just again, I apologize for just kind of springing

 this on you, but I'd love to hear your thoughts.

 MR. ELA: No. It's a great question, Brian. And I

 think -- I mean, I think it's complex. You know, I don't think

 the program has the authority to usurp EPA on pesticide

 labeling. That is not within our jurisdiction. But we do have

 the authority to say that synthetics used in organics have to

 be on the National List. That is very clearly within OPA. So 
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 we can't change the pesticide labels, but we can say if an

 inert is being used in organic and it is a synthetic, it needs

 to appear on the National List and it needs to be reviewed.

 So we may not know where that inert or what product

 that is being used in as an end user, you know, if I'm spraying

 copper, or virus, or whatever. But I would at least know the

 subset of inerts that are being -- that are potentially there,

 and I would be able to, you know, assess risk as an end user.

 I mean, I -- you know, I love being an organic

 grower. We transitioned from conventional because I don't have

 to wear all the stuff. But -- and I look at the active

 ingredients, and I assess risk when I spray them of

 environmental risk, and personal risk, and health risk, and I

 tell my consumers that. That if I -- if there's an inert in

 that product that's a carcinogen, I don't know. And if it was

 on the National List, at least I would know it's somewhere in

 some product, and we might be able to inquire further.

 So I think it's -- just as a consumer or an end user

 of pesticides, I'd like to know what I'm spraying.

 BD. MEM. CALDWELL: And just very quickly, any

 thoughts about the plastic example that I gave as well?

 MR. ELA: Yeah. Plastic is kind of similar. I

 think, there again, we have some authority. We can't usurp FDA

 overall, except that we still do have authority over

 contamination of organic products. And so, you know, if we see 
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 a PFAS or some kind of product that's going to be a problem on

 organic soils or in organic packaging, yeah, I think we do have

 authority over that to say, no, we're going to prevent

 contamination, and that's where OFTA does kick in.

 BD. MEM. CALDWELL: Great. Thank you so much, Steve.

 CHAIR POWELL-PALM: Other questions for Steve?

 Mindee, please go ahead.

 VICE CHAIR JEFFERY: Thanks, Steve. Pardon me if I'm

 wrong, you do a lot of farmers markets?

 MR. ELA: Just a few.

 VICE CHAIR JEFFERY: Yeah. So in your conversations

 with consumers when they ask you why organic, what do you --

how does that land for you, and how do you inspire them?

 Because I mean, I hear this question from farmers a lot, and

 I've dealt with that question a lot as a retailer. So I've

 tried a lot of different strategies. So I'm just curious.

 What happens for you out there?

 MR. ELA: That's a great question. Yeah. I spend

 every weekend at farmers markets, and we do multiple ones. So

 yeah, I think -- it's a great question. It's one I've

 struggled with over the years. And my answer now is that, you

 know, why organic? Why is it higher priced? And my answer is

 because we're internalizing externalities. And to put that in

 simpler words, I'm saying we are trying to keep soil on our

 farms so you're not having to dredge the Mississippi or repair 
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 gullies. We're trying to prevent nitrate contamination of

 water so you're not having to treat the water in Des Moines for

 nitrates.

 We're trying to keep all the nutrients where they're

 supposed to be so we don't have the dead zone in the Gulf of

 Mexico. And I just basically look them in the eye and say your

 tax dollars are subsidizing what agriculture externalizes

 through water treatment, and pollution control, and climate

 change.

 And so as an organic grower, why organic is because

 we're keeping those on the farm. And we're spending the money

 and spending the time and the thought process to try and

 mitigate those so that your taxpayer dollars don't have to do

 that.

 VICE CHAIR JEFFERY: Great. Thank you.

 CHAIR POWELL-PALM: Appreciate you as always, Steve.

 Thank you.

 MR. ELA: Good to see you all.

 CHAIR POWELL-PALM: Next up we have Anne Ross,

 followed by Linley Dixon, and then Tony Michaels.

 Anne, the floor is yours.

 MS. ROSS: Good afternoon, everyone. My name is Anne

 Ross and I'm an organic investigator for the Cornucopia

 Institute, and also a member of the policy team. I'd like to

 thank the NOSB for their time here today. 
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 I'll briefly address three issues. The first is the

 consistency in parcel identification. We support the baseline

 requirement of using GPS coordinates to obtain consistent

 location information, unless the certifier can articulate with

 specificity why an exception is appropriate.

 As noted in some of the comments, a one size fits all

 approach may not be appropriate for some operations. For those

 operations, we urge the NOP to issue guidance specifically

 articulating the circumstances in which an exception to

 providing GPS coordinates would be acceptable. Clearly, the

 goal is to establish an accurate means of identification so

 inspectors can do their jobs. If it's not GPS, then a

 verifiable alternative for that operation should be required,

 and the guidance should clearly articulate the standards for

 exceptions.

 Second, we support building on the SOE framework of

 additional residue testing. We have long supported tested of

 bulk imports. We know thousands of metric tons of fraudulent

 grain have been imported into the U.S. after being treated with

 prohibited fumigants. We called for consistent, unannounced

 testing at that time, and continue to do so. But to identify

 the non-compliant product before distribution, and when

 possible, before it travels through the supply chain.

 At the very least, testing is a deterrent for bad

 actors, strengthening periodic and unannounced residue testing 
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 will stop non-compliant product from entering the supply chain

 or help identify where it is.

 Finally, we must join together in dispelling anti-

 organic propaganda. Consumers often ask about information they

 see from sources like social media. A look at social media

 content, for example, shows there is an increasing amount of

 misleading information about food labels generally, often

 hailing the virtues of some that carried no legal or generally

 agreed upon definition, and others that outright disparage

 organic.

 Transparency in organic helps ensure there remains

 some baseline consensus about the facts. We must insure

 authentic organic is not redefined by misinformation campaigns,

 the disastrous impact and influence of factory farming, and the

 unchecked power of monopolies in our food system.

 When a few mega companies consolidate and control the

 good system and messaging, consumer choice is nothing more than

 an illusion. A food system where several corporate giants

 dictate what we eat, what we grow, and what farmers get paid is

 without a doubt a threat to the organic movement, and to

 anything that does not serve their profit motive. These few

 should not define, dictate, or dilute what organic means.

 Thank you for your time.

 CHAIR POWELL-PALM: Thank you for your comments.

 Questions for Anne? 
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 I just want to say, Anne, thank you so much for three

 of your points there, but thank you also and I have only been

 on NOSB for a few years, but the tenor of Cornucopia is so

 helpful and so serious, and I just really appreciate the

 partnership you all are -- and the example you all are setting

 for how to spread the good message around organic. So thank

 you for the work and your team. I really appreciate it.

 MS. ROSS: Thank you all.

 CHAIR POWELL-PALM: Next up we have Linley Dixon,

 followed by Tony Michaels, and then Dustin Ploeger.

 Linley, the floor is yours.

 MS. DIXON: Hi. I'm Linley Dixon. I'm an organic

 vegetable farmer from southwest Colorado, and the co-director

 of the Real Organic Project.

 Last spring, I got to go to Washington, D.C. with the

 Organic Farmers Association and my goal was to talk to our

 representatives about climate smart farming, and how organic,

 obviously, is climate smart because of our soil health

 practices, and our pasturing requirements, all of these are

 written into law. And the quick response of many of the

 Congressmembers, all of the ones that I met, it was almost on

 autopilot, it was organic can never be climate smart because

 organic farmers till.

 I don't know how many of you have hear that as well

 in Washington. So I was completed taken aback, because this 
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 conventional no-till farming is what they're talking about, and

 that uses herbicide termination and synthetic fertilizers, and

 now those are actually running off the land -- the synthetic

 fertilizers are running off the land even more, because they're

 service applied. There's all these cracks in the soil, and

 those fertilizers go straight down, you know, to the drainage

 tiles.

 So we've never seen eutrophication in the waterways

 as bad as it's been right now. And so I think we need a new

 term. I think it's called real climate smart farming.

 So this is the low input farming that organic farmers

 grow their own fertility for the next crop. They may or may

 not incorporate or till that organic matter in. Actually, to

 answer, I think it was Mindee asked Steve, what is the best

 definition of organic farming? It's the incorporation of

 organic matter into the soil. That's what gets rid of the need

 for anything synthetic to even be sprayed in the first place.

 I understand that organic is always going to be up

 against these kinds of misinformation campaigns, generated by

 the chemical industry for the most part. The CEO of Syngenta

 recently called for an end to organic farming because we have

 50 percent lower yields, he said. And because of that, people

 are, "Starving in Africa," because we're eating more organic

 food.

 We all know we have global overproduction. So it's a 
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 lack of distribution. So I understand that we're up against a

 huge chemical lobby that rewrites the story of organic. And

 the natural response to that is to stick together, right, and

 be stronger. Be bigger organic. Use words like a bigger tent

 and inclusivity, and commonality, so we can fight the chemical

 lobby.

 And I feel this at the NOSB right now. But I want to

 caution that we should be aware of who is encouraging us to

 have a big tent, because that same subsidized chemical soybean

 production that's getting, you know, all of the climate smart

 funding, that's what's being used for fertility on the organic

 hydroponic industry. They use it in the form of hydrolyzed

 soybeans, which are allowed to be conventionally farmed.

 So the hydroponic industry benefits from subsidized

 conventional soybeans. So everyone in this big tent has very

 different interests. The organic hydroponic industry is now so

 powerful that they set the price point and control the shelf

 space for the most profitable crops there are. I have one take

 home point from this -- am I allowed to say it, my take home

 point?

 CHAIR POWELL-PALM: Sure. Go ahead.

 MS. DIXON: In the EU, where there's higher integrity

 under the organic program, they do not certify CAPOs, they do

 not certify hydroponic as organic. And organic is growing ten

 times faster, ten percent of the land there is organic. 
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 So it's just a really important point that actually

 organic growth is faster where there's integrity, and people

 trust the label, and they don't go running around looking for

 pastured, or grass fed, or comes from family farms, or all

 these other labels.

 Higher integrity, faster growth. Thank you.

 CHAIR POWELL-PALM: Any questions for Linley? All

 right, Linley, we appreciate your comments.

 Mindee has a question for you.

 VICE CHAIR JEFFERY: Thanks, Linley. No, I was

 asking Steve about messaging because I think about it all the

 time. In the grand scheme of life, how best can we position

 organic with the positives.

 And so for me, it's a lot about politics. And I'm

 wondering if y'all ever position organic in the politics of

 democracy, and how our regulations sit, and the power of that

 for individuals and individual farmers in your messaging.

 MS. DIXON: That's a great question. We just had

 Zaffer Teach out at our conference at Churchtown Dairy.

 Everybody should watch it. I'll send the link around. Zaffer

 talks about how we're losing our democracy because of the

 consolidation everywhere, right? And that's happening -- the

 same thing is happening in the organic industry. And we are

 losing our power and our choices.

 CHAIR POWELL-PALM: Allison, please go ahead. 
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 BD. MEM. JOHNSON: Yeah. Thanks for your comments,

 Linley. I want to go back to the beginning and the no till

 issue because I really strongly agree with you that it's a

 challenge.

 The solution that I've been struggling with is if we

 do more research to show that organic farms are successfully

 sequestering carbon at equivalent or higher rights than no

 till, herbicide dependent farms, it -- my understanding is it's

 challenging for smaller-scale producers to participate in that

 type of research and that having research requirements or

 frameworks may actually be excluding some of the farmers that

 we think are using among the best practices.

 So I'm curious if that's something that you've

 thought about and how data and research can help us make the

 case for organic, or whether we need a different framework

 entirely, and to kind of like reject that approach.

 MS. DIXON: Yeah. A challenge -- I think it's been

 shown that the no till chemical farming actually might

 sequester more in the upper layers, just because that's where

 the organic matter hasn't even gotten into the soil. So at

 deeper layers, I think -- so I guess I'm frustrated that we're

 having to even prove this. That if you just look at the

 synthetic fertilizer production, that that carbon footprint is

 so massive, and the fact that we're not using those synthetic

 fertilizers or any of those herbicides, just the production of 
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 them alone, should be able to put this to rest.

 The farmers that use those inputs are -- can never be

 climate smart, simply because they use those inputs. So we

 need to rewrite the story here. I think they're telling us

 what climate smart is, and we're defending ourselves. I think

 we need to go after the inputs.

 CHAIR POWELL-PALM: Amy, please go ahead.

 BD. MEM. BRUCH: Yeah. Quick question, Nate.

 Linley, thanks for your time today.

 I just want to know, have you run across different

 definitions for no till? I heard that sometimes no till is

 being classified as four inches or less of tillage. So I just

 wondered, have you been hearing that?

 MS. DIXON: Yeah. I think some farmers just

 incorporate a little bit of compost into the upper couple

 inches, and you know, might call that no till as well. But

 yeah, I think it's okay to have different definitions for these

 terms. In general, no till -- because very few farmers have

 figured out how to do the roller crimper in organic systems.

 In general, no till is chemical farmed.

 So when most people say no till, without saying

 conventional no till, for the vast majority, unless it's a

 large farm adding lots of compost, there's tillage involved if

 it's organic, and no till is chemical.

 BD. MEM. BRUCH: Okay. Thank you, Linley. 
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 Appreciate your time.

 CHAIR POWELL-PALM: All right. Next up, we have Tony

 Michaels, followed by Dustin Ploeger, and the BJ McNeil.

 MR. MICHAELS: Thank you very much. Thank you very

 much to the Board and staff for all the great work you do on

 behalf of this community.

 I'm Tony Michaels. We're transitioning a bunch of

 acres in Western Nebraska right now. Our team has been farming

 organic in a variety of locations in the Midwest for the last

 20 years. And we primarily do row crops of grains and alfalfa

 as the centerpiece of the farming that we do.

 What I'd like to talk a little bit about is crop

 insurance, and previous speakers have talked about the problems

 with crop insurance, the conventional crop insurance market

 being applied to organic. I'd like to talk a little bit about

 a solution to this.

 I had a weird little sidelight in insurance in a

 previous life, and it was, I think, relevant to this case. The

 problem with insurance is that the history of insurance is that

 you use your past experience, your actuarial history, to guide

 the pricing of your future risk. And that's a good approach

 when you've got past experience.

 The problem is when you do something new, by

 definition, you don't have past experience. And whether it's

 you doing something new, or the industry adding something new 
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 into the options set for what we do, we instantly move out of

 the typical paradigm. And so what the insurance industry does

 is it closes different things in, like T yields and other stuff

 to solve that.

 This has happened many other times in the insurance

 industry where new practices come on board, and the industry

 has an approach -- parametric modeling kind of approach, that

 really tries to use other tools to forecast the risk through to

 the period where you then have enough actuarial history to use

 the more traditional approach.

 And I think we just need to do this. Somebody's got

 to bite the bullet and put together a parametric modeling

 approaches, in partnership with the insurance industry, so they

 can get the same comfort with this as -- you know, they'll

 insure the first time a new rocket blasts off to launch a

 satellite into space. It's insured, and there's no experience

 there.

 We're a lot more knowledgeable and less risk than

 that kind of behavior. So we just have to take this industry

 and actually embrace it for the other tools that it can bring

 to bear.

 Part of our thing is that insurance is the primary

 subsidy that's brough into agriculture. And so it's heavily

 regulated. It's heavily government influenced. And that is

 the other piece that ensures that the more market-type insurers 
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 that would do these approaches worry about when they engage

 with us.

 I think if we do this correctly, we can come up with

 products. Those products can be new practices. They can be

 multi-annual. They can me transition insurance products. They

 can be built specifically so the banks can engage with them,

 and it can be part of how banks comfortably loan in both annual

 and multi-annual operating lines.

 We could even take this kind of insurance model and

 apply it to the forgeries that are coming over in these ships,

 and just require that those folks have an insurance product

 that certifies -- that insures that what's being on that ship

 is real. And then that adds the price for all the fraudulent

 activity to the people that are doing this importing, unless

 they can prove it and simplify this process.

 So anyway, I talked too long.

 CHAIR POWELL-PALM: If you've got more, you keep

 going. This is the best thing I have heard in years. Oh my

 gosh. That was great. Thank you.

 MR. MICHAELS: No. This is --

 CHAIR POWELL-PALM: Could you repeat just one second,

 repeat that rocket ship piece one more time.

 MR. MICHAELS: So the first time a new rocket

 launches a new satellite into space, it is actually insured,

 even though it's never ever been used before. It's not even 
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 ever tested for real, right? And but you can't do a launch

 without putting something on it that has some value.

 And so I had this weird little side lighting global

 catastrophe insurance in Bermuda 25, 30 years ago, so I was in

 the nascent part of this industry. But this industry exists.

 They need a big enough market. And so our problem is that we

 segment ourselves up so that we're so niche that it's just, you

 know, Tony showing up with a few acres, trying to ask for a

 product that's going to take some work. But it's not that

 expensive if it's an industry that's asking for it.

 We just have an industry that has never gone into

 this heavily government subsidizing. It's like -- you know,

 flood insurance is also heavily federally subsidized. And so

 it's just a pass-through for the insurers. They don't do any

 modeling on it.

 I think we could engage this industry -- I think

 they're looking -- they're always looking for new markets. I

 think the knowledge that they would apply would also then mesh

 with the practices we want to encourage. So we would be

 letting people make choices among transition practices that

 they want to try, or have best practices because those are the

 ones the insurers will write you the best policy for because

 it's a good thing.

 And by the way, we ought to have a good insurance

 policy for alfalfa after it's been established. You know, so 
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 just to be practical. So anyway, I can talk forever. I'm not

 a person of few words. So you've got me going.

 CHAIR POWELL-PALM: Thank you so much for that. As

 we talked about how do you message organic, I'm just imagining

 that YouTube video saying it's easier to get a rocket that's

 never flown before insured than corn that we've grown for the

 last 10,000 years. So thank you for that very much.

 Questions from the Board? All right. Well, you

 knocked it out of the park. We really appreciate you coming in

 to taking your time. I realize it's harvest. You're busy. So

 thanks so much for taking the time to call in today.

 MR. MICHAELS: Sounds good. Thank you again for

 everything you do.

 CHAIR POWELL-PALM: Appreciate it.

 Next up, we have Dustin Ploeger, followed by BJ

 McNeil, and then Zach Gazzaniga, if Zach is on the call. I'm

 not sure if we've got him yet.

 But let's go to Dustin.

 MR. PLOEGER: Hi, can you hear me okay?

 CHAIR POWELL-PALM: We can. Please go ahead.

 MR. PLOEGER: Okay. Well, as you said, I'm Dustin

 Ploeger. I'm an organic grain merchant with the Scoular

 Company. Currently coming up on four years of trading the

 organic market. Scoular's been around much longer. We've been

 in the organic market for about 25 years. So I want to thank 
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 the National Organic Standards Board for the work that they do,

 and the opportunity you've given to us and others for public

 comment. Appreciate everything.

 At Scoular, we represent a blended view of the

 market, and being both buyers and sellers of the trade. So we

 have obviously customers who want to buy the lowest cost feed

 ingredient and customers who want to sell the highest cost feed

 ingredient. Organic corn, soybean, soybean meal, feed, wheat.

 And it's a balancing act, and our approach to that risk

 management takes into consideration those two forces from

 customers we look to service to the best of our ability.

 And there's no true hedging mechanism that we found

 is an effective tool in this effort, and at the end of the day,

 we're flat-priced traders in a highly volatile market.

 And the organic grain market, in particular, is

 unfortunately ripe with several high-profile bankruptcies, and

 that's, to me, a testament of the difficulty of the trade

 environment we operate in.

 And circling back to Scoular, I think it's my belief

 that a large part of our success in this industry is because

 we've centered and focused by serving the domestic market, U.S.

 based growers and end users. But that said, we're not immune

 from the shockwaves felt by the global trade for organic

 grains.

 And the U.S., as we've all heard here, relies heavily 
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 on those imports, and in particular organic soybean, soybean

 meal, and participants in this type of trade absorb tremendous

 risk, and while doing so, they're directly impacted by the

 decisions this Board makes and other governing bodies.

 Now, we at Scoular, having a different focus, we

 champion this enforcement, the testing requirements, the

 geotracking, supply chain audits. We want to see more of that

 and level the playing field. And that these products coming

 into the United States are handled under the same governances

 required by U.S. standards.

 That said, we would ask the committee for

 recommendations on reporting any instances of non-compliance

 for imported feed ingredients. Given our vantage point working

 for both buyers and sellers, we see the negative and positive

 effects of price movement. But better communication on issues

 of non-compliance, in essence, immediate reporting of fraud,

 for example, would allow markets more time to react and tamp

 down price shockwaves that are highly disruptive to healthy

 markets.

 Thank you.

 CHAIR POWELL-PALM: Thank you for your comments very

 much.

 Nate has a question for you.

 BD. MEM. LEWIS: Yeah. Thanks for your comments. A

 couple of questions related to testing and the document that 
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 CACS was working on.

 MR. PLOEGER: Yes.

 BD. MEM. LEWIS: One is related to organic solvent --

 organic meaning carbon-base, not certified organic, but

 methanol and various other organic solvents as a testing tool

 for deterring fraud in the seed meal world. I'm curious what

 your thoughts are on that. And then secondly, the organic

 standards already require certifiers to make available to the

 public all of their period residue testing. And I'm curious if

 you have thoughts for how that could potentially be compiled

 and made a productive resource for the trade as you suggest in

 terms of targeting certain regions.

 So first, granularly soybean meal or seed meals, and

 then secondly, the data question.

 MR. PLOEGER: Yeah. There are more ways to slice

 that, you know, trace hexane obviously, but trace other

 solvents so methane, ethanol, those are all things that I think

 should be done at ports of entry.

 If there's a great way to go about it, I think it

 would be enlisting custom's border patrol to rapid run those

 tests at ports of entry. And then in particular to my ask to

 the committee is if something is found, how does that get

 communicated back into the market?

 As we try to trade the market, a lot of what we're 

 forced with is the rumor mill of, you know, so-and-so had 
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 containers trip at the port. Well, did it, did it not? And

 it's those type of price shockwaves that impact the market, and

 negatively impact the end users, the demand side of the market.

 If prices run, obviously, the same scenario would happen to

 growers if those imports just continue to come in.

 So yes, I think right now, standard would be asking

 for those types of tests run third part at ports of origin. I

 think they should also be done at the ports of entry.

 CHAIR POWELL-PALM: Amy has a question for you. Yes.

 BD. MEM. BRUCH: Yeah. Nate, thanks. Appreciate it.

 Yeah, Dustin, thanks for your time today and lending

 your voice. This is an important conversation. Your

 perspective is really interesting and we're thankful to have

 it, because we don't hear from a lot of people that you're

 representing. So this is really critical, especially now on

 these instances of imports and just where they stand.

 I was just wondering have you seen any changes since

 you trade -- I appreciate, one, the focus on domestic, but I

 wanted to see -- have you seen any interaction since you do,

 and you're aware of trading on the global market, just

 interactions with international brokers? Are they reaching

 out, or is there more interaction there? Do you see more

 conversations happening?

 MR. PLOEGER: Yeah. A lot of it is not necessarily 

 solicited, but our name's out there, among others, and we get 
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 international inquiries all the time as to our interest in

 purchasing African, Turkish-origin, Indian-origin, Chinese-

 origin. We've always treated with a little bit of reluctance,

 primarily because of the trust in the supply chain.

 That's obviously reduced our ability to gain market

 share because the U.S. does import that. We've taken an active

 pass on a lot of business. But we have to feel good about

 what's coming in.

 And again, to the communication piece on reporting, I

 think the net effect obviously is to stabilize the market,

 avoid price bubbles that may burst, but also let others know

 who to stay away from, who to do business with, who not to do

 business, who's doing their due diligence to vet out the supply

 chain on their own. And again, looking for recommendations as

 to how, if customs border patrol is enlisted, how they can

 communicate to an effective body so that us, as buyers,

 potential buyers could be aware who to avoid and yeah, buyer

 beware essentially.

 BD. MEM. BRUCH: Uh-huh. Good points. Thank you.

 Appreciate it.

 CHAIR POWELL-PALM: Kim as a question for you.

 BD. MEM. HUSEMAN: Thanks, Nate. Thanks. I really

 appreciate your points, Dustin, and appreciate your voice as,

 you know, a leading ag business in both the conventional and in 

the organic space to be present today. 
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 As you know, the lack of transparency in the market

 does tend to create that hearsay without the factual components

 behind it, and having that space of the facts behind it would

 be extremely helpful. Hopefully, in a transparency aspect, I'm

 not getting into proprietary information, but do you guys

 currently do both international and domestic trading at all?

 MR. PLOEGER: Yeah. As a company, we do. Obviously,

 Scoular is a much larger presence than just our organic

 business. We have --

 BD. MEM. HUSEMAN: I'm sorry, in the organic space.

 MR. PLOEGER: Yeah. In the organic space, we have,

 but it's been very, very minimal, primarily for the same reason

 of not fully trusting the supply chain. So I want to say --

this has probably -- like I said, I've been with the company

 four years ago. Probably 10 to 15 years ago, Scoular had a

 much larger footprint in that aspect, and I want to say

 timeline wise, it was before I arrived say five to six years

 ago. That footprint had shrunk back considerably because of

 what we were seeing, because of what we were experiencing.

 BD. MEM. HUSEMAN: Yeah. Got you. No, I appreciate

 that. And my question to you, then, would be we talk about --

and this is more of a -- from a business standpoint, and we

 talk about mitigating risk. If Scoular were to go out and --

 or list the name of the company in this global market, buy 

 product from origin, have product tested, tested product comes 
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 back clean, product gets to the states, and product doesn't

 test clean, who then becomes financially liable for that

 product? 

MR. PLOEGER: Yeah. That's a good question. Those

 type of trades are usually negotiated at the onset of whether

 you're buying FOB, CIF, DDP, all being trade terms to where

 that risk transfer happens, where the true ownership transfer

 would happen. 

BD. MEM. HUSEMAN: Okay. 

MR. PLOEGER: So DDP, for instance, would be delivery

 duties paid, and that is by the seller. So in that instance,

 that has actually grown in popularity from those that do

 heavily trade that market because the risk is then transferred

 back to the port of origin, or the seller of origin. 

BD. MEM. HUSEMAN: Right. And that transparency can

 -- again, to me, it goes back to transparency, right? 

MR. PLOEGER: Right. 

BD. MEM. HUSEMAN: It can get lost and then these are

 not -- you know, we talk either look at the top three leading

 by dollars imported products, I think one of the written

 comments had data from 2019. You know, it's -- it was coffee,

 soybeans, and bananas. But at the end of the day, that's a lot

 -- that's a large figure, and when you start talking risk and

 risk assessment, and you know, where then does that financial

 burden lie. And when you start talking international partners, 
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 you hope that you have ones that are of high integrity for

 sure, right?

 MR. PLOEGER: Absolutely. Absolutely. And again, to

 zero back to the ask of the committee is to think of ways

 creatively and collectively to increase the communication

 around any bad actors that might be out there so that the,

 again, price stabilization, obviously we want good, healthy

 prices, but we don't need -- I think I was hearing from a

 grower earlier, you know, just the extreme volatility in

 soybean prices. Ultimately, it's not healthy for one, the

 grower, and the end user. And so I think that can be minimized

 with just better understanding of the whole supply chain and

 the communication around it.

 BD. MEM. HUSEMAN: Right. Facts, not assumptions.

 Awesome. Hey, thanks so much for your time, Dustin.

 MR. PLOEGER: Thank you.

 CHAIR POWELL-PALM: We really appreciate your

 comments today, Dustin. Thank you so much for joining us.

 Next up we have BJ McNeil, followed by Kristopher

 Klokkenga, and then Peter Gunther.

 MR. MCNEIL: Yes, can you hear me?

 CHAIR POWELL-PALM: Yes, we can. Go ahead.

 MR. MCNEIL: Can you hear me? Okay. I may have bad

 cell reception. I'm in my combine right now.

 I want to basically just kind of expand what's been 
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 talked about. It was a great intro. I want to discuss, or

 thank him for doing that and thank you all for listening.

 But the impact of the import on organic is --

 especially for our farm, has been quite severe, especially over

 the last 12 months. I have sunflowers from 2022 that there's

 literally no market for because the imported sunflower market

 has just crushed demand for local. Of course, we all know the

 story on soybeans and everything else.

 But this also caused us to move a lot of acres out of

 organic because there's just not reliable markets. We're just

 not finding them. We've had even trouble collecting on some

 delivered goods this year because we had barely above current

 market contracts, and people, you know, were either trying to

 get out of them, couldn't afford to pay it at the time because

 they were having competition from somebody else that was buying

 beans cheaper, then their product was competitive, and so on

 down the road like it goes.

 But anyway, I just -- I really want to reiterate what

 Dustin said on that. The -- it seems to me that, and even

 listening to the majority of people that -- I've been listening

 for about an hour here, and the majority of people that have

 spoken, that there's quite an emphasis on worrying about

 whether an acre is certified organic or not, but we don't put

 anywhere near enough emphasis on guaranteeing the products in

 the food chain are organic. 
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 And I think that's something that needs to be stepped

 back by the Board, and maybe organic as a whole and looked at.

 You know? What's more important? To verify every acre in the

 U.S. is organic or verify the U.S. organic food chain is truly

 organic and chemical free. And that's -- I think that takes a

 different mindset, and different priorities than where a lot of

 the mindset priorities are currently.

 The second thing I guess I wanted to discuss was the

 approval of some products to be used in organic. I think we

 don't use enough common sense sometimes, for lack of better

 terms. A good example is this year, we were low on molybdenum

 on soybean fields so wanted to but moly out. The one product

 we found that actually worked, and there was actually data that

 showed it got into the plant, we couldn't use because one of

 the products in it was selenium, and we couldn't prove that our

 soil needed selenium.

 Now, mind you, we were putting out three ounces of

 this product per acre. The amount of selenium going out

 would've been parts per million. I mean, minute. But yet, we

 couldn't put that out because we couldn't prove that we needed

 selenium.

 CHAIR POWELL-PALM: If you have a quick finish up

 there, Dustin (sic).

 MR. MCNEIL: Well, because -- but yet we allow five

 tons of poultry litter to go out on a field that's putting out, 
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 you know, according to (indiscernible), there's many pounds of

 selenium that are being applied when you put out five tons of

 poultry litter, but yet that's fine. But if you're trying to

 not put fertilizer out, and do it biologically, and foliar feed

 your plant, and not put all of those nutrients out there, then

 you're penalized. That's all.

 CHAIR POWELL-PALM: Yeah. Thank you. We really

 appreciate your comments. Questions for BJ from the Board?

 All right. BJ, we hear you loud and clear, and when

 folks said that this was a bad time of year to have a meeting,

 it sounds like you're making it work, this platform. So we

 really appreciate you calling in from the combine and making

 your voice heard. Thank you very much.

 MR. MCNEIL: Thank you.

 CHAIR POWELL-PALM: All right. Next up we have

 Kristopher Klokkenga, followed by Peter Gunther, and then Aaron

 Zimmerman.

 Kristopher, if you're there, the floor is yours.

 MR. KLOKKENGA: Hi. My name is Kristopher Klokkenga.

 I'm a fourth-generation farmer from Central Illinois. And I

 started converting my farm over to organic in 2015.

 I wanted to speak with you today about insurance and

 some things that maybe I think you could improve on. The first

 one is your T yields. This is the first year that I've ever

 had an insurance claim on a field, and just to give you an 
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 idea, my conventional T yields are in the 70s for soybean

 yield. My T yield for -- in general off a farm in Mason

 County, Illinois is at like 25. My T yield is 36 because I've

 had one year of 50-bushel soybeans on that.

 And so I just wanted to tell you that I think that

 the T yields discourage farmers from getting into organic

 because they're not able to -- I mean, the backstop here is the

 yield that -- in our insurance that we can use. I understand

 that 2017, the conventional T yields were no longer allowed,

 and therefore, they were like dropped in half.

 I think maybe a little -- this goes back to the

 gentleman who talked earlier, I think his name was Tony, just

 about the fact that the rocket -- you know, insuring the

 rocket. And so it's like, okay. If I know that I can produce

 50-bushel beans, is there not a way that we could raise that to

 make it more attractive for me to grow that.

 The other thing that I wanted to speak with you about

 is whole farm insurance. I've been -- I've started a new

 organic entity. I started transitioning '15 -- I started an

 organic entity in '19, and what happened was I need five years

 of taxes in order to be able to justify whole farm insurance.

 And so I don't -- as of today, like in 2023, I don't have five

 years. I won't have five years of organic records until next

 year, at which time I'd be able to apply for it in, like, 2025.

 And the problem with that is that I came in under a 
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 previous entity, which was my family's. I converted my family

 farm over to organic. So therefore, since I had conventional

 yields, if I pulled those in, then it's saying, okay, let's say

 you sold a million dollars' worth of grain under a conventional

 entity, but then you move over and you're selling now organic,

 and you're selling $2 million, how do you bridge that gap?

 And I would just like to -- it's just a little bit

 hard with the history. I'm a multi-generational farm here,

 trying to exist in central Illinois, and want to try to be able

 to compete, and continue to grow things the way I want to. I

 enjoy growing organic. It's hard work, but we do it. And I

 would just like to make sure that there are some things in

 place that probably other people get to benefit from, but since

 I'm an organic farmer in the stage that I am, I'm just not

 there yet.

 CHAIR POWELL-PALM: We really appreciate thoughts on

 this subject. This is definitely top of mind for our CACS

 subcommittee, and we're trying to get as much information as we

 can to make crop insurance work for organic farmers. So thank

 you for bringing your story and making your voice heard,

 especially during the busy harvest time. Really appreciate it.

 MR. KLOKKENGA: Thank you.

 CHAIR POWELL-PALM: Any questions for Kris?

 All right. You're off the hook. Thank you so much.

 Appreciate it. 
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 Next up we have Peter Gunther, followed by Aaron 

 Zimmerman, and then Matthew Keegan.

 MR. GUNTHER: Yes. Can you guys hear me?

 CHAIR POWELL-PALM: We can. Please go ahead.

 MR. GUNTHER: All right. I'm Peter Gunther. I'm a

 farmer here in West Texas. I've been growing organically for

 18 years. I do a lot of different crops over here. But the

 main thing I wanted to visit with you guys about was the

 organic peanuts. We do have a lot of organic peanuts being

 imported. And the concern I have with that is I don't think

 that -- well, from what I've heard, and I need to do a little

 bit more research on this to prove it 100 percent, but that

 they don't test the crops that are coming in from overseas, and

 if they do, it's a very small amount.

 I know that there has been some crops that come in

 from overseas that have been tested by independent companies

 and has come back, you know, bad. And so I'm afraid of that

 hurting the integrity of the organic market here. And not only

 that, but they can grow them so much cheaper, and we just can't

 -- we're just not on a level playing field. You know? It

 costs us farmers so much to grow these crops organically in our

 country, and to do it all, you know, 100 percent, and it's just

 not sustainable for us.

 You know, we spend tens of millions of dollars, I do,

 personally, buying new land, raw land, to grow these crops 
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 because of disease and weed pressure. And you know, after a

 while, the crops, they just don't produce anymore, so -- or

 they don't produce as much. And so therefore, the profit

 margin is, you know, way lower.

 And so our labor, everything costs so much, and we're

 just not on a level playing field with these guys that are

 importing peanuts from other countries into our country. And I

 don't know what needs to be done about that, or who you know,

 to talk to about that, but that was the major concern that I

 have as far as on the peanut side. And so that's what I wanted

 to address you guys with today.

 CHAIR POWELL-PALM: Thank you very much for calling

 in, and we hear your concern. Any questions from the Board?

 Amy, please go ahead.

 BD. MEM. BRUCH: Yeah, thanks, Nate. Thanks, Peter,

 for lending your voice to this process. Good to have Texas

 representation, farmer representation on this call.

 We've heard some farmers from the Midwest talk about

 how grain imports have impacted them, and some have taken land

 out of transition. Do you know from the peanut perspective in

 your area, you yourself, how have imports impacted you?

 MR. GUNTHER: Yeah. Well, we've had to take some of

 ours out of organic also just because of -- it's just not cost

 effective. You know, the price that these guys can get these

 peanuts shipped in is quite a bit cheaper than what we can grow 
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 them for here.

 The only way we can have a fighting chance is like I

 said, with the new ground that produces more and takes less

 input cost, you know, as far as labor. And that's the only

 thing, but that's just not sustainable. Like we're going to

 run out of new ground to develop because eventually it just --

 you're going to run out.

 And so I'm afraid that this organic peanut market is

 going to take a huge hit here in America because we just don't

 have -- well, I mean, we just don't have the resources to stay

 compared to what's coming in overseas.

 And also, what I'd like to add too is in 2011, we had

 a major drought here, and we -- there was a major shortage of

 peanuts. And so I know there was a lot of Chinese peanuts

 imported to fill that gap. And ever since then, it just seems

 like they've -- that's kind of opened the floodgates of

 everybody just kind of going overseas. So there's not really a

 big incentive to, you know, give us farmers what our crop is

 worth when they can go overseas and get it for, you know, 30 to

 40 percent cheaper than we can grow it for here.

 CHAIR POWELL-PALM: Logan has a question for you.

 BD. MEM. PETREY: Yeah. Hey, thank you, Peter.

 Question, what do you rotate with? So you have peanuts. Do

 you have anything else in rotation as a cash crop?

 MR. GUNTHER: Yeah. We do wheat and corn. Wheat and 
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 corn is kind of the better rotation that we have for peanuts,

 and there's just no market for organic corn here either. I

 mean, there's a few organic dairies that we can sell to, but

 that's very few.

 So that's why organic peanuts is kind of the main

 thing that actually makes any kind of money worth growing any

 crop around here. It's just not -- corn around here just

 doesn't pay enough to where it's worth it. You know? That's

 our issues here too.

 BD. MEM. PETREY: Yeah. And your product is in the

 ground, and so rotation is extremely important for you, and a

 lot of covers actually are in the peanut family. And so I can

 see where that is difficult, and so you do probably rely --

need to rely on that corn, and wheat, and other things to

 protect your cash crops. So I can see where that's

 complicated.

 Okay. Thank you, Peter. Appreciate that.

 MR. GUNTHER: Thank you.

 CHAIR POWELL-PALM: The -- Kim, please go ahead.

 BD. MEM. HUSEMAN: I'll keep it quick, Nate. Thank

 you.

 And thank you so much for your comment, Peter, and

 the lens in which you present how your farm is competing in the

 market space, and the challenges that, you know, become very

 margin-based. 
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 You know, and I think that there's some examples

 historically of how that can be challenged, and how U.S.

 farmers have been able to try to level that playing field, but

 it's very exhausting, and it's a very complicated process. And

 you know, I appreciate you bringing this to the Board too,

 because you've given me more insight as well from just that

 margin aspect, and the different inputs, labor, cost of land,

 and the different struggles that you're having that might not

 be the same as another place that gives some market

 competitiveness.

 So I wish you well in all of your crops, and again, I

 just really appreciate you coming on today. So it was more of

 a comment than a questions, but wanted to make that known.

 CHAIR POWELL-PALM: I would echo that. We don't get

 to hear from Texas enough. So thank you so much for your time

 --

 BD. MEM. HUSEMAN: That's right.

 CHAIR POWELL-PALM: -- and joining us, and please

 join us again, all the farmers. We want to hear from you every

 meeting. Thank you for bringing what's going on out in the

 world to our attention. Appreciate you.

 MR. GUNTHER: Thank you, guys.

 CHAIR POWELL-PALM: Next up we have Aaron Zimmerman,

 followed by Matthew Keegan, and then Jack Fehr.

 MR. ZIMMERMAN: Hi everybody. Thanks for taking my 
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 Zoom here.

 Real quick, I just have kind of two topics, one very

 brief -- you know, the crop insured side of things. And

 forgive me if I'm being redundant or echoing what other people

 have already said, because I just logged in now, but I wanted

 to touch on things that are important to me as a cash grain

 producer here in the Midwest.

 I guess a little bit about me. Northeast Nebraska.

 We're approximately 2,500 acres of -- it's all certified

 organic. We grow corn, soybeans, wheat, barley, buckwheat,

 yellow peas, alfalfa, and then some covers also. So we try to

 stay pretty diverse.

 So the two topics I wanted to talk about are crop

 insurance and then I guess the other side of it would be

 imports and the subsequent fraud.

 Crop insurance real quick, you know, I think a lot of

 people have touched on it, but one of the things that's

 probably bothered me the most was you know, when you start

 transitioning, obviously, you use the county T yield at that

 point. And then -- I mean, and you're doing it organically,

 and then when you actually get to being certified organic, you

 start back over with that county T yield, but nothing has

 changed in your practice technically.

 So that's kind of -- that's something that definitely

 needs addressed. And I suppose that's the main thing I wanted 
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 to talk about with crop insurance. Probably the biggest thing

 and probably the biggest challenge for, aside from growing the

 crops, is just the imports that are from -- what I keep hearing

 over and over again is they're not necessarily organic, and

 they are competing with us United States producers who are

 organic, and it makes it very hard to compete on a world

 market, and even the national market because they can do it for

 a lot cheaper than us, and they're flooding our markets, and

 it's definitely squeezing our margins.

 You know, I've heard talk about this standard

 location information concept. I am in favor of that, and I

 urge you if you vote yes for that, and then I also like the

 idea of testing on all imported grains. Everything that comes

 in has to be tested. And I don't know if that 100 percent cure

 all because I'm sure there's a lot of things that can happen

 that don't necessarily show up in the grain, but it's just --

 we just need to kind of keep putting little road blocks to keep

 these bad players out, and hopefully we can start seeing a more

 equitable market that works for our -- the United States

 producers.

 So that is basically all I wanted to say. I can't

 hear you, Nate.

 CHAIR POWELL-PALM: All right. We really appreciate

 it. Are you in harvest right now?

 MR. ZIMMERMAN: Yeah. I had to -- I kind of blew in 
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 here, and I wanted to sit down, and get in front of a Zoom

 camera for you, but yeah, out the door I go here real quick and

 --

 CHAIR POWELL-PALM: We really appreciate it. Like

 can't express enough. Thank you for making the time to bring

 this to our attention.

 Amy's got a question for you.

 BD. MEM. BRUCH: Yeah. Hi, Aaron. Thanks for

 joining us today. I really appreciate your comments, and

 appreciate the support on some of the initiatives that we're

 working on with oversight to deter fraud. I want to ask you on

 the crop insurance piece. So you mentioned all sorts of crops

 that you grow, which is amazing that you're that diverse. How

 many of those crops are insurable actually through our federal

 program?

 MR. ZIMMERMAN: You know what, I probably should have

 gone into it in a little more depth. I apologize because we --

 we could probably spend quite a bit of time on that. Honestly

 two: corn and soybeans. And even that isn't very good. You

 know, I could insure the wheat, but it's just -- I guess the

 juice isn't worth the squeeze, I guess, to put it bluntly.

 So this year and last year, I have not taken

 insurance on the wheat side either. But, you know, the

 buckwheat, the barley, you know, all these other things, and

 alfalfa, which is a forage, you know, you're pretty much flying 
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 naked and it's kind of uncomfortable.

 So it would be nice if we could address that as well.

 Thanks for bringing that up because that is important.

 BD. MEM. BRUCH: Thank you. I appreciate that,

 Aaron.

 CHAIR POWELL-PALM: Really appreciate the through

 lines here. Thank you, Aaron, for reaffirming that this is a

 problem. That to get organic to be something that folks can

 reasonably go into without taking on a lot of risk, we need

 better products out there. So appreciate that.

 MR. ZIMMERMAN: And I should have added, you know,

 there's more to it than my profitability on my farm. There

 really is. This has everything to do with the American

 consumer being able to trust this brand, because if they don't,

 it's not work a dang thing and then it's all for nought.

 So this is incredibly important. This goes way above

 me. So --

 CHAIR POWELL-PALM: Absolutely. Thank you very much

 again.

 MR. ZIMMERMAN: Thank you, everybody.

 CHAIR POWELL-PALM: Good luck for the rest of your

 harvest.

 MR. ZIMMERMAN: Yeah. You bet. I'll need it.

 CHAIR POWELL-PALM: Michelle, do we have Matthew

 Keegan or Jack Fehr on the Zoom? 
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 MS. ARSENAULT: Matthew is with us.

 CHAIR POWELL-PALM: Okay. Matthew, the floor is

 yours.

 MR. KEEGAN: This is Matt Keegan. Can you guys hear

 me okay?

 CHAIR POWELL-PALM: We can. Please go ahead.

 MR. KEEGAN: Great. Well, thanks. Matt Keegan.

 I've been involved in this organic industry, I guess, for going

 on 20 years on the supply side. Predominantly on the feed

 side. Also worked quite a bit on the food side, but really the

 focus during my career has been on the animal feed segment, and

 really a global supply chain. So experience of both domestic

 crops, imports.

 And so you know, I just kind of wanted to chime in

 here because as the previous speaker had just said, I think

 underlined this very well. There's a lot of concerns that if

 the consumer knew what actually was really going on, we have a

 lot of problems in this industry. And I got involved in this

 industry because I really believed in it.

 There's a tremendous amount of fraud, as everybody

 knows. We've seen it on the domestic side. We've seen it on

 the import side. And I think that in a lot of ways when you

 look at an efficiency standpoint, we're kind of stepping over

 dollars to pick up dimes in a lot of ways. 

 And when you look at, say, imports. You know, the 
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 imports like to be picked on, and rightly so. I mean, there's

 a lot of stuff going on on the import side that's very

 problematic. Now, as we all know, the organic program is a

 process-based system, right? We like to use that terminology,

 especially with some of these certifiers. Whether it's

 pesticide residue that we find in crops, or GMO, and you know,

 we talk about, well, you know, it was grown organically. They

 have a cert. We see their seed receipts. You know, this stuff

 ties out, wind drift, etcetera is how we kind of explain this.

 Well, there is deliberate fraud that's going on and I

 would say north of 50 percent of -- say for example the organic

 soybean meal coming into the United States. I would say north

 of 50 percent of this stuff is fraudulent, blended with

 solvent-extracted meals.

 And the shifty thing about this is they're blending

 with other than hexane. Everybody in the U.S., you know, most

 of these producers do hexane. Hexane meal on the solvent side.

 But when you look at, say, the African countries, they're using

 methanol, acetone. Nobody's testing for this stuff.

 And there's precedence at the import side, at CDP,

 USDA, NOP, working together. There's precedence to test this

 cargo when it comes in. So I'm not really sure why we're not

 doing that.

 If you guys recall, what was this -- in early 2000s, 

'05, '06, '07, somewhere around that time period, we had the 
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 big melamine issue out of China. And in fairness, all that

 melamine is really centric to the conventional products, but

 the FDA got involved and said, no, we're going to apply this to

 all meals out of China.

 So when the product came in, you got a nastygram

 letter from the FDA that said, hey, this product is adultered

 (sic), and you need to either destroy it or re-export it. And

 if you re-export it, then okay, or prove to us that it's still

 organic.

 So the point is you had to hire a lab, have the

 product tested, and then prove to the FDA that it was not

 adultered with melamine.

 We have the test knowledge, the labs, and everything

 to have this -- to put this back on the importers, have this

 product tested at the port. You can have these tests turned

 around pretty quickly and prove that the product is actually

 what it is. And I think that we have a tremendous issue and

 huge risk right now specific just to that. You know, we can

 put this in lots of different buckets. But you know, if we

 just want to talk about -- you know, we pick on -- like I said,

 pick on imports here for a second. This is an easy solution,

 and something that I think needs to be done.

 CHAIR POWELL-PALM: And I apologize, for time, we're

 going to have to keep moving. But that is -- we absolutely 

hear you. We've got a question for you from Kim. 
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 BD. MEM. HUSEMAN: Hi, Matt. In your current

 business, can you tell me what you do as an importer to

 validate your supply chain?

 MR. KEEGAN: Every single shipment that comes in goes

 to three labs. We do a feed analysis so we know that what

 we're committing to to the customer is accurate. You know,

 just feed profile, moisture, protein, fat, fiber, etcetera.

 Okay? Then there's sample that goes off to another lab, where

 we do all pesticide residue. And then thirdly, another lab

 where we do all the solvents.

 So it's about three pages of just solvents. There's

 a whole profile of a bunch of them, and it's very clear. And

 it sticks out like a sore thumb when you see the analysis.

 So the request of the lab is a full solvent profile.

 It's not tested for hexane. And so people that are just

 testing for hexane, they're not getting the whole big picture.

 BD. MEM. HUSEMAN: So two follow-up questions I have

 for you real quick. One is -- one would be how do you make

 this information transparent. And then secondly, as an

 importer, if you're testing at origin, and the product tests

 clean, and then you test at destination and something flags,

 how do you handle that and who becomes responsible financially?

 MR. KEEGAN: The shipper, 100 percent. And I've had

 those situations. And I have to say I'm extremely disappointed

 with the certifiers and how they've handled these things. And 
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 I know you guys need to move on, but that's a whole other

 topic. I will tell you this, 60 to 90 days ago, I sent a

 request to our certifier with specific data, test reports,

 organic cert, contract, all the details and said, "Listen, this

 is fraudulent material." There's no, oh whoops, there's wind

 drifts, we have solvents in the meal. That is -- somebody's

 actually blending that. 

Now, the pesticides, the GMOs, okay fine, yeah.

 There can be wind drift, whatever. But when we're talking

 specifically about these solvents, this is a purpose --

 somebody's doing this on purpose. 

We had a supplier who wanted to sell us some product.

 I said great. Send me a sample. I had them send it directly

 to the labs because I knew exactly what was going to happen if

 it came back positive for anything, and I was going to be

 questioned about the chain of custody with the sample. So I

 didn't even touch it. It went directly from supplier straight

 to the labs. We got the test report. I submitted to the

 certifier. The certifier, their first question was, "Well,

 what's the chain of custody?" And I said, well, I told you the

 chain of custody. It went straight to the lab. Basically,

 well, we don't believe you. I said okay, fine. I got the bill

 of lading, the tracking number. I said, here you go. There's

 the proof. They said, okay, great. 

Then there was some kind of noise follow up, but they 
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 didn't do anything. Still to this day, I have not received a

 response from it. And my direction to them was, listen,

 somebody in this marketplace is going to buy this cargo. I am

 not going to buy this cargo, but somebody is. And the price is

 cheap, so then that has implications on domestic crush. It has

 implications for domestic farmers. All the way down the line.

 So the fact the certifiers are not even stepping up,

 because I don't think they even know what to do, frankly.

 BD. MEM. HUSEMAN: Thank you, Matt. Sorry. We are a

 little short on time. I'm going to let Nate ask his questions.

 I kind of stepped in with three. But I really appreciate your

 information.

 MR. KEEGAN: Sure.

 CHAIR POWELL-PALM: Go ahead, Nate.

 BD. MEM. LEWIS: Yeah. Could you provide us what you

 use for solvent screens? That would be tremendously helpful to

 see what the industry is testing for. I just didn't see any

 written comments on the -- and we don't need to go -- we are

 behind time, but if you could just, like, email us a cop of

 your screen or something like that, I would really, really

 appreciate it.

 MR. KEEGAN: Sure. Sure.

 BD. MEM. LEWIS: That'd be great. Thanks.

 MR. KEEGAN: I'd be happy -- I'll send some profiles

 in and I'll -- I want to forward you guys the email chain too 
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 with the certifier, because you're going to fall out of your

 chair a little bit when you see this.

 CHAIR POWELL-PALM: We really appreciate the info,

 Matt, and thank you for commenting today, and we'll look

 forward to those communications.

 MR. KEEGAN: Absolutely. Thank you.

 CHAIR POWELL-PALM: Thank you. Jack Fehr. Do we

 have Jack Fehr on Zoom, Michelle?

 MS. ARSENAULT: Jack is with us. He's on the phone.

 CHAIR POWELL-PALM: All right. Fantastic. Please

 state your name and affiliation, Jack. The floor is yours.

 MR. FEHR: Jack Fehr, organic farmer in northwest

 Iowa. We farm organic corn, soybeans, and oats.

 I'm not as knowledgeable or educated as the last guy,

 but organic certification is important to me. The imports,

 obviously, that's all been talked about. I'd like to just talk

 about the certification here domestically, especially

 inspectors. I feel like a lot of the inspectors we've had on

 our farm or have dealt with just don't understand large grow

 crops organic farms. Maybe that's just a string of bad luck of

 inspectors on our parts. But we've been doing it 25 years, and

 never felt like any of them have been comparable or really

 knowing what they're looking for on a large organic farm.

 And yeah, I don't know how that gets fixed. I think 

you guys probably have lots of good ideas. 
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 CHAIR POWELL-PALM: You are not the first person to

 raise this concern, so we really appreciate it being brought

 back around. And there's a lot of investment right now going

 out for human capital improvement in the inspector space, and

 we heard some folks doing good work yesterday on that front.

 Amy's got a question for you.

 BD. MEM. BRUCH: Yeah, Jack, thanks for joining us

 today. I know you're busy with harvest as well. I appreciate

 your comments. I wanted to -- see, I know you and your family

 have been organically farming since the '90s. Have you had

 other experiences with selling products internationally and

 getting other inspections as well that you could highlight for

 us?

 MR. FEHR: Yeah. So we went -- our oats, through

 grain millers, we have -- we're certified through a Chinese

 certification. We -- so we've had Chinese inspectors come over

 to certify our oat field. And they do a better job and know

 more about certifying organic crops not –- I mean on those on

 their own crop. But just large-scale farms. We felt like -- I

 mean, they do a better job certifying than the inspectors that

 we have domestically. And so then that causes an issue with

 how we think a lot of imports are fraudulent when our

 experience has been they've probably -- the inspectors, anyway,

 that they send over do a better job than our domestic

 inspectors. 
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 BD. MEM. BRUCH: Could you just unpackage when you

 say better job. Are they asking tougher questions, or how you

 think it's better.

 MR. FEHR: Yeah. Definitely. And asking the right

 questions. I'm trying to think of an example here. Like I

 said, I'm not super well-prepared. You know, I guess --

 there's a good way of putting it is it feels like the

 inspectors that we've had here domestically have not -- don't

 deal with a lot of large acreages and maybe these do, and so

 the numbers make sense to them. Where the inspectors that we

 have, have a hard time grasping the numbers otherwise.

 BD. MEM. BRUCH: Thank you. Appreciate it, Jack.

 CHAIR POWELL-PALM: We really appreciate your

 comments. Thanks very much for calling in today, especially

 during harvest. So thank you for making the time.

 MR. FEHR: Yeah. Thank you, guys.

 CHAIR POWELL-PALM: I know a lot of people are

 working on this issue. So hopefully we'll have some good

 updates for you in the meetings to come. Next up, we have

 Rhoades Yepsen, followed by Charlotte Vallaeys. We're going to

 take a five-minute break after Charlotte Vallaeys. And after

 our break, we're going to go to Heather Spalding.

 Rhoades, the floor is yours.

 MR. YEPSEN: Great. Thank you so much. 

 My name is Rhoades Yepsen. I'm executive director of 
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161

 BPI. My comments today are focused on the importance of

 compost for organic agriculture and the importance of compost

 -- that compost has in our collective efforts to combat climate

 change.

 Compost is both a verb and a noun. As a verb,

 compost describes the biological process of transforming

 organic material that otherwise would have been a waste stream

 into something of value. This includes climactic and societal

 benefits with methane avoidance from landfills, communities

 able to participate in the circular economy rather than the

 linear status quo.

 As a noun, compost is the result of that process.

 It's a stable soil amendment that provides climate benefits

 related to carbon sequestration, water retention, disease

 resistance, slow-release nutrients and more.

 For the National Organic Program to participate and

 support the compost movement, changes are needed. The NOP

 definition of compost was written when compost was primarily an

 on-farm activity. And since then, we've seen the rise of a

 global movement around compost and climate change that

 necessitates updated definitions.

 BPI recently petitions USCA to update the NOP compost

 rules, and we're happy to see that our request for the NOSB to

 be consulted was included in the announcement of the petition 

last week. 
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Like you all, BPI does not want to see synthetics

 allowed in finished compost, which is why we seek to address

 this by adding a definition of compost feed stock to the

 regulation, rather than looking at it through the lens of the

 National List. 

I welcome your questions. I look forward to seeing

 you next week in Providence, and BPI is open to organizing a

 meeting once the Board has had a chance to evaluate the

 petition. Thank you. 

CHAIR POWELL-PALM: Thank you very much. Allison has

 a question for you. 

BD. MEM. JOHNSON: Yeah. Thanks for being here,

 Rhoades. 

PFAS is a concern in compost, and I wonder if you can

 speak a little bit to BPI's approach to excluding PFAS and also

 any sort of development in detection of PFAS since your

 standards were created. 

MR. YEPSEN: Yes. Thank you. PFAS is certainly very

 concerning. BPI identified this back in 2017 and established a

 rule prohibiting the use of PFAS in compostable products. So

 way ahead of the state regulations. 

Many states are also tackling this through

 requirements modeled after BPI's rules, so prohibiting the use

 of PFAS in all types of packaging, not just compostables. And

 there have been a lot of advancements in testing, both on the 
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 packaging side, as well as on soil and compost. But it remains

 a challenge, you know, for test methods, the sensitivity of

 tests, identifying specific chemical compounds.

 BPI's approach to think has been through a multi-

 tired mechanism. So we have a total organic fluorine test as a

 proxy. This is one way to conduct screens to cast a wide net,

 rather than focusing on individual chemical compounds because

 there are so many. But then we've also established rules

 around screenings for all ingredients used, regardless of how

 small. That's been probably the most effective means for BPI

 to be able to screen for PFAS. So looking at all of the

 ingredients used, and then going far enough through the supply

 chain to identify the chemical compounds.

 We're hopeful that there will be more federal action

 around PFAS. We think that, you know, really it's the

 production and use of them further upstream that needs to be

 taken into consideration because, you know, as we've seen with

 EPA, it's really going down into the parts for trilling and

 drinking water. So this really signals the importance of

 tackling this, looking at the production of these chemicals.

 CHAIR POWELL-PALM: Nate, please go ahead.

 BD. MEM. LEWIS: Yeah. As we kind of start engaging

 on the topic and response to the petition, and a general

 interest on the Board to update the compost regulation, we

 welcome input on who needs to be at the table and what that 
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 partnership map looks like. I think that's kind of the stage

 we're at right now. So, you know, we don't need to make the

 list right now on this webinar because we're already like an

 hour and a half behind, but just keep in mind that that's the

 kind of information that I'm particularly intrigued to get.

 So obviously, the petitioner, the compost industry,

 there's some clear players, but if we can help -- if you can

 help us paint that partnership map, I would be tremendously

 grateful.

 MR. YEPSEN: Yes. I'd be happy to. Thanks.

 CHAIR POWELL-PALM: Thank you very much for your

 comments today.

 MR. YEPSEN: Yeah. Thank you.

 CHAIR POWELL-PALM: Next up, we have Charlotte

 Vallaeys. After Charlotte, we'll take a five-minute break.

 After our break, we'll go to Heather Spalding, Greg, Schreiner,

 and Francis Thicke.

 Charlotte, the floor is yours.

 MS. VALLAEYS: All right. Thank you. Hi, everyone.

 My name is Charlotte Vallaeys. I am the organic expert at

 General Mills. First, thank you all -- to the Board members

 for your time and dedication to organic.

 General Mills is a 155-year-old company and a leading

 producer of certified organic packaged food in the United

 States. We are a proud member of the Organic Trade 
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 Association. So please refer to their comments on other topics

 that are on the agenda that I will not be speaking out.

 But I would like to just give a general comment on

 the discussion document on opportunities in organic, and

 specifically on expanding opportunities for organic farmers

 with a consumer basing promotion initiative.

 At General Mills, we've long-recognized the value of

 organic practices for consumers, farmers, and the planet. As a

 global food industry leader, we understand that organic is an

 approach to food production with many positive environmental

 and social outcomes. The potential for growth in organics is

 significant. And we recognize the important role that our

 company plays in assisting organic farmers and expanding their

 businesses. Specifically, by increasing their access to

 organic markets.

 To succeed in producing and selling more organic

 food, it is crucial for consumers to fully understand the

 benefits of the USDA organic seal. We are doing our part to

 help educate consumers about organic benefits in several ways.

 We were part of the OTA task force that created a

 data-driven tool kit on the organic wheel of sustainability,

 which highlights the many ways that organic is good for the

 planet, people and animals, and business. We recently updated

 the back of pack for our Cascading Farms cereal boxes to

 highlight some of the aspects of that organic label 
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 sustainability, and we call out that organic is good for the

 planet. And specifically with several benefits, including that

 organic agriculture regenerates soil health, reduces chemical

 pollution, and promotes ecological balance.

 We also support non-profits that OFRF, Organic

 Voices, and the Organic Center that do critical work to raise

 awareness of the many ways in which organic is good for people

 and planet. We appreciate recent investments from the USDA and

 supporting the transition to organic farming, and building on

 this momentum, we are asking for consideration of a consumer

 facing organic promotion initiative, which would further

 support public and private sector investments in organic

 agriculture and practices. Thank you.

 CHAIR POWELL-PALM: Thank you very much for your

 comments. Questions for Charlotte from the Board. Amy has a

 question for you.

 BD. MEM. BRUCH: Yeah. Thanks, Nate. Charlotte,

 thanks for participating in our process and for just what --

 everything that General Mills is doing. I don't necessarily

 have a question. I just have just a comment to kind of take to

 heart today, and on Tuesday, our public commenters from farmers

 really wanted help in expanding markets, especially for

 domestic grown organic products. And then consumers we heard

 from, they wanted more education because I think there's -- the

 opportunity to grow organic is a lot bigger than it is. We 
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 just need to have more education to our consumers so they know

 exactly what the label represents.

 So any help you can do in those two categories, and

 continued help, would be greatly appreciated. Thank you.

 MS. VALLAEYS: Thank you.

 CHAIR POWELL-PALM: Nate has a question for you.

 BD. MEM. LEWIS: Not a question. Just to celebrate

 the relationship with Rodel (ph), a Cascadian home farm close

 to my home. Really appreciate your all's attention to that.

 It's a fantastic birthplace of kind of larger scale veg and the

 Cascadian brand. So that's really great, and I really hope the

 ice cream shop opens up again soon.

 MS. VALLAEYS: Very well, thank you. If I may just

 respond to that comment in case others aren't aware. But

 General Mills donated the Cascadian Farm, home farm, that was

 founded over 50 years ago by Gene Kahn to the Rodel Institute,

 and it will now be -- or it is already a research and education

 center, a regional center for Rodel.

 CHAIR POWELL-PALM: Allison has a question for you.

 BD. MEM. JOHNSON: Thanks. At the risk of being the

 one that keeps us from our break for another minute, I

 appreciate you being here, Charlotte, and all of your

 leadership.

 Are you seeing much connection with the TOP program,

 the Transition to Organic Partnerships program from where you 
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 sit, or are you getting connected with producers or getting

 integrated into the partnership web that is growing out of that

 initiative?

 MS. VALLAEYS: Not directly integrated. I mean, love

 to see what's happening and we actually created our own --

 again, with Rodel partnership, to put more consultants in our

 own supply chain. So we're really kind of linking it to our

 own growers to help them transition, not just to organic

 because they already are, but keep improving their practices,

 especially the earlier conversation about no till and organic

 can't be, you know, climate smart if they till. And so it's

 just getting that kind of agronomic advice in our own supply

 chain is what we're focusing on.

 And just for the record, I completely agree that, you

 know, that there's a lot of misinformation about no till and

 its impact. Yeah, I just wanted to clarify that.

 CHAIR POWELL-PALM: Thank you very much for your

 comments. And I would echo everyone who said, it's pretty cool

 to see the investment General Mills is making in organic. So

 thank you very much. And we're excited to tackle these

 questions of how do we spread the word from General Mills down

 to five-acre farmers, everyone seems to be saying the same

 thing that this is too good a secret to keep. So thank you

 again for joining us today.

 MS. VALLAEYS: Thank you. Bye. 
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 CHAIR POWELL-PALM: All right. Folks, it is six

 minutes past the hour. Lets come back at 11 minutes past the

 hour for the break. After the break, we'll go to Heather

 Spalding, Greg Schreiner, and then Francis Thicke.

 (Break 4:06 p.m. to 4:11 p.m.)

 CHAIR POWELL-PALM: If you could state your name and

 affiliation, the floor is yours.

 MS. SPALDING: Thank you so much. Good afternoon,

 Chairman Powell-Palm and members of the NOSB. I'm Heather

 Spalding, deputy director of the Maine Organic Farmers and

 Gardeners Association, MOFGA.

 We're a broad-based community, working to create a

 food system that's healthy and fair for all of us. Through

 education, training, and advocacy, we're helping farmers

 thrive, making more local organic food available, and building

 sustainable communities. We certify 535 organic farms and

 processing operations, representing roughly 90 million in sales

 and we have roughly 15,000 members, many of whom are organic

 gardeners and homesteaders, and all of whom are organic food

 consumers, depending on us to uphold the integrity of the

 National Organic Program rule.

 I'd like to briefly highlight a few of the items in

 our written comments that we sent to you. We urge you to adopt

 a rigorous review process for inert ingredients to ensure that

 toxic materials that otherwise would not be permitted on the 
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 National List are kept out of products approved for organic

 management. The revision to the National List regarding inerts

 must include a full evaluation of human health effects,

 including endocrine disruption, environmental impacts, whether

 there are suitable non-synthetic alternatives, and

 compatibility with a system of organic agriculture.

 Regarding consistency in parcel location

 identification, we agree that certifiers should know the

 locations of all operations. Our staff and contract inspectors

 feel good about the systems we use. GPS is just one tool in

 the toolbox, but should not be mandated to be used by all.

 Regarding residue testing, we support NOSB's proposal

 to require testing for handling operations. And thank you so

 much for starting that work. Regarding racial equity, we hope

 you'll apply USDA's 2023 equity commission recommendations and

 embed racial equity in NOSB programs.

 We continue to oppose the use of the organic label by

 hydroponic operations. In our written comments, we've provided

 a copy of the organic agriculture is soil-based position

 statement, which we helped draft, and which is endorsed by

 certifying agencies and businesses across the country.

 And finally, we'd like to highlight the urgent need

 for coordinated action at the federal level to address the

 escalating crisis of PFAS contamination in our food and ag

 system. This isn't a Maine issue. It's ubiquitous. PFAS is 
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 everywhere and lasts forever. More than 4,100 farms across the

 country recently have been, notified by the Department of

 Defense about the threat of PFAS contamination from nearby DOD

 training exercises. We hope that all participants in the

 meeting, the NOSB members, speakers, viewers, everyone

 attending will reach out to their members of Congress and

 encourage them to cosponsor the Relief for Farmers Hit with

 PFAS Act.

 Thank you so much for your tireless efforts as NOSB

 members.

 CHAIR POWELL-PALM: We really appreciate your

 comments. Thank you for joining us. Questions from the Board?

 All right. Thank you so much, Heather.

 MS. SPALDING: See you next week.

 CHAIR POWELL-PALM: See you next week. Next up we

 have Greg Schreiner, followed by Francis Thicke, and then Dave

 Chapman.

 MR. SCHREINER: Good afternoon, everybody.

 CHAIR POWELL-PALM: Good afternoon.

 MR. SCHREINER: My name is Greg Schreiner. And I

 want to start my comments by thanking the National Organic

 Standards Board for the work you've all done in the organic

 industry. So thank you.

 Again, my name is Greg Schreiner, and I've been an

 organic farmer for over a decade. I own Silver Reef Organic 
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 Farms that rotates between beans, corn, and small grains.

 When I first bought the farm, my financial

 institution required crop insurance to protect the loan. I

 soon learned that made the difference in keeping the farm over

 the last decade. First, let me say that I do not believe that

 the National Organic Standards Board document is missing any

 important problems, factors, and topics. I also believe that

 this document accurately reflects the challenges that organic

 farmers face regarding crop insurance.

 As stated in the NOSB report, crop insurance works

 well for some farmers, and my comments will address how we get

 crop insurance to work well for more organic farmers.

 There is a need for a robust marketing campaign to

 educated farmers on the opportunities to use crop insurance to

 mitigate risk. I have read and used all of the amazing

 informative tools on the United States Department of

 Agriculture risk management website. Yet until this request

 for comment was introduced, I really didn't know that this

 information was available.

 I can appreciate why RMA promotes its website through

 its webinars, university extension offices, and other

 trainings, but there is still a disconnect between farmers

 knowing and using the tools available.

 When I reached out to other farmers, none of them

 actually knew about this website. Direct marketing could be 
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 sent to specific organic groups, trade associations, beginning

 farmer associations, and more specifically to the certifiers.

 As the NOSB noted, the T yield is not liked by anyone

 and for good reason. This contributes to many farmers not

 adopting crop insurance because their coverage level will not

 sufficiently mitigate risk versus cost.

 I have not been able to find any data on how T yields

 are discovered and established. We need a better data that can

 accurately reflect organic T-yields. In the meantime, my

 suggestion is a 20 percent reduction against conventional T

 yields for an organic farmer per county. Based on the thoughts

 and the comments earlier, which are a good conventional farmer

 comes a good organic farmer.

 More farmers will buy crop insurance, insurance with

 payouts better reflect organic pricing and production. I would

 suggest that the USDA collect organic pricing by region, as

 this data could also be used to help establish better and more

 accurate crop insurance protection. I also believe that most

 farmers would adopt federal crop insurance if the premium due

 date was scheduled within 30 days after harvest. This would

 allow the farmer to harvest, deliver, and receive payment for

 the crop and cover any premiums due.

 Operational costs often take priority over the

 insurance premiums in the growing season and allowing the

 farmers to pay post-harvest with reduced financial obstacles. 
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 In closing, that you all for the opportunity to give you my

 solutions to some of the issues facing organic farmers. Thank

 you.

 CHAIR POWELL-PALM: Thank you very much. Questions

 for Greg? I think that's just a fantastic idea, Greg. I

 really appreciate that timing question for just regular cash

 flow. How do we help farmers keep the business going. So

 appreciate you joining us today and thank you for making the

 time. I know it's a busy time of year.

 MR. SCHREINER: All right. Thank you very much.

 CHAIR POWELL-PALM: Next up we have Francis Thicke,

 followed by Dave Chapman, and then Kirsten Novak.

 Francis, the floor is yours. And I -- we don't have

 you unmuted yet. There we go.

 MR. THICKE: All right. My name is Francis Thicke.

 I'm an organic dairy and crop farmer from Iowa.

 I first started farming organically in 1975. And

 what I'd like to do is look at from that perspective some of

 the problems from today. Back then, the pioneer organic

 farmers did it for principle, not profit. We didn't really

 have a market. But I think we were doing real organic farming

 with crop rotations, cover crops, compost, manure, and such.

 And it was real regenerative.

 As a matter of fact the Rodel Institute had a

 magazine out called the New Farm, the magazine of regenerative 
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 agriculture. But that term regenerative kind of disappeared

 for 40 years.

 Now, I'll fast forward to the late '90s and the early

 2000s. As organic became a multi-billion-dollar industry, the

 big food organizations saw that, and they wanted a piece of the

 pie. Actually, in many cases, they wanted the whole pie, and

 things like organic blueberries, organic tomatoes, and other

 fruits and vegetables, they -- what did they do? They scaled

 up. They industrialized it.

 And how did they do it? Things like hydroponics,

 like cows in caypols (ph.) chickens in big warehouses. And so

 it was an industrialization of organic. And USDA has never

 really been able to combat that. And really it's because the

 food industry has a huge lobbying wing. I understand there are

 1,200 lobbyists for food and agriculture, lobbying Congress,

 and lobbying USDA, frankly. And so we've not been able to make

 progress on trying to eliminate hydroponics, or even the big

 caypols, or the chicken warehouses.

 So the Real Organic Project became critical and

 necessary. And I'm happy to be Real Organic Project certified.

 My customers know that we are doing real organic. But now

 today, we have a new thing coming on, regenerative agriculture

 and climate smart. And the industry has been really smart at

 co-oping organic, and they've been very quick to try to co-op

 regenerative agriculture and climate smart agriculture. They 
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 can see that if they can put that on their Cheerios box and

 their Wheaties box, that's going to be a real plus for them.

 But they want to make it again, like with organic, as cheaply

 as possible. They want to take business as usual, and label it

 as regenerative or climate smart. And we have to watch out for

 that.

 And so no till and round up are considered climate

 smart for many people. And we know that's not -- that most

 people wound up with a short-term cover crop does not really

 regenerate the soil. We need to have more robust cover crops

 in rotations to make that happen.

 And so I think we can do that with real organic, and

 to me, real organic is real regenerative. Thank you.

 CHAIR POWELL-PALM: Thank you for your comments.

 Questions from the Board? We appreciate it, Francis. Thank

 you for joining us today.

 MR. THICKE: Thank you.

 CHAIR POWELL-PALM: Next up we have Dave Chapman,

 followed by Kirsten Novak, and then Adele Durfey.

 Dave, the floor is yours. Welcome.

 MR. CHAPMAN: Hey. Thank you, Nate. I'm Dave

 Chapman, farmer and co-director at the Real Organic Project.

 I want to address some recent efforts at reform with

 the NOP. $300 million are dedicated to the new organic

 transition initiative. That could be a very hopeful sign. 
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 Strengthening organic enforcement could be a very hopeful sign.

 But it appears to me that the SOE is creating a huge burden on

 the very farms that are the backbone of organic. And I wonder

 what massive fraud it is preventing.

 What huge CAFO will be closed down by the updated

 OLPS. I suspect none. We have to distinguish between new

 regulations that create actual reform and those that just check

 off a box, but don't change reality. The $300 million is an

 attempt to address the plummeting rate of farmers who

 transition to organic. It is down 70 percent from the

 transition rate in 2008. But wouldn't it be vastly better to

 actually enforce the law? Prohibit ruminants living in

 confinement from being certified as organic? Prohibit

 hydroponic from being certified as organic? Then let the

 market reward farmers who are doing it right. Build it and the

 farmers will come, and so will the eaters.

 The complicated part is why is this failing? We all

 agree that real organic is based on soil health, not on

 processed fertilizers. We all agree that we want to eat real

 organic eggs that come from hens that go outside and scratch in

 the soil. None of us want those CAFO eggs. We all agree that

 we want to drink milk coming from cows who graze in a diverse

 pasture.

 Organic in the EU follows the principles of organic. 

 Hydro is prohibited. And sales there are growing faster than 
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 USDA organic in the marketplace. Right now, the are a billion

 dollars ahead of U.S. organic food sales. The U.S. has about

 20,000 farms certified as organic. There are 350,000 certified

 organic producers in the EU.

 The U.S. has 9 million acres of certified organic

 farmland. The EU has 40 million acres. Is it possible that

 maintaining integrity and transparency is a better strategy for

 the growth of organic than building a so-called big tent to

 welcome multi-nationals, who will twist the meaning of organic.

 The NOSB has known this in the past. Francis Thicke

 who just spoke organized a letter to Secretary Vilsack in 2021.

 It called out the disintegration of the National Organic

 Program. It was signed by 43 of your predecessors. They wrote

 that, "The integrity of the National Organic Standards has

 eroded significantly over the years."

 None of this is a settled issue. It will never be

 settled until it is made right. I call on you to follow in the

 footsteps of those 43 former NOSB members. We need all hands

 on deck to fix organic before we lose it. There's a real

 danger. It will not be easy. Thank you very much.

 CHAIR POWELL-PALM: Questions for Dave from the

 Board? All right. We appreciate your time, Dave. Thank you.

 MR. CHAPMAN: You bet, Nate.

 CHAIR POWELL-PALM: Next up -- we do have Kirsten, 

 Michelle? Kirsten Novak? 
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 MS. ARSENAULT: Yeah. She's on.

 CHAIR POWELL-PALM: All right. Fabulous. Kirsten,

 the floor is yours.

 MS. ARSENAULT: She's on mute. Hold on one second.

 CHAIR POWELL-PALM: And you're on mute. Let's see --

 it should prompt you to unmute, if you want to self-unmute.

 MS. ARSENAULT: Let me do it again. Hold on.

 No.

 CHAIR POWELL-PALM: Not yet.

 MS. ARSENAULT: I'm not getting --

 CHAIR POWELL-PALM: Kirsten, are you able to try to

 just hit the unmute button on your end?

 MS. ARSENAULT: It won't let her because -- so,

 Kirsten, are you getting a pop-up message on your screen that

 says the host has asked you to unmute? And it didn't work.

 CHAIR POWELL-PALM: Are you on a cell phone, Kirsten?

 Okay.

 UNIDENTIFIED SPEAKER: Hit star 6.

 CHAIR POWELL-PALM: Hit star 6. See if that works.

 I'm not sure if that works with the app versus calling in.

 MS. ARSENAULT: Didn't work. All right. We can work

 on getting you unmuted. Nate, if you want to move to the next

 person.

 CHAIR POWELL-PALM: We'll jump to the next person, 

 Kirsten. Stand by and we'll figure it out. Thank you. 
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 All right. Let's jump to Adele Durfey next. Adele,

 if you're there.

 MS. ARSENAULT: We see an unknown phone number on the

 list, but I don't know if it's Adele, so we don't know who to

 unmute. All right. Got it. I'm asking Adele to unmute now.

 And, Adele, if you are only on the phone, you may have to hit

 -- there were go, star 6.

 MS. DURFEY: Hi, there. It looks like I'm unmuted.

 I heard the issues with the person right before me. So hello.

 My name is Adele Durfey and I am the director of sustainability

 at Clear Frontier Ag Management, which is an organical ed fund.

 I only had just a couple of bits that I wanted to

 cover today, but I think it might take the full three minutes,

 so I'll just dive in.

 I think the first piece that is very important is

 that we have standardized location information. It's very

 important for certifiers and inspectors to have consistency

 when receiving information about the whereabouts of certified

 operations. And it's especially important since the NOP is a

 global program, receiving imports from countries certified to

 the NOP, but have no comparable standards in their country.

 So that could take form -- that could take the form

 of a GPS location, or similarly, a section, township, range

 location information that could then be translated into a GPS

 geo-locations, but I feel like it's very important to track 
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181

 information across different regions and different geographies. 

Excuse me. So the second issue I wanted to touch on

 is the testing of important products both on the quantity being

 tested and the breadth of chemicals in which they are being

 tested for. So as far as I understand, only five percent of

 imports are being tested currently. And I spent quite a bit of

 time abroad in the country of Ukraine, and we're talking eight

 plus years, and helping to manage 130,000 acres. At that point

 in time, an organic production was almost non-existent. 

And so even today, some years later, if those farms

 have multiplied or that percentage has gone up, I would really

 doubt that the farms would not get the volume of exports that

 are tagged as originating from the country as organic. 

So I can only speak from my personal experience on

 Ukraine, but I think that any third world country or any close

 to third world country that does not have repercussions for not

 adhering to a standard, will just simply not adhere to these

 standards. 

But I also wanted to mention in addition to this,

 similarly, the lack of organic production that was prevalent in

 Ukraine was actually the prevalence of GMO production. So

 although Ukraine is a non-GMO country and prohibits all GMO

 products, even to the extent that they might put a non-GMO

 sticker on their water bottle, it was actually a rare

 occurrence for me to see, particularly on large-scale farms, 
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 farms that did not have some GMO crops in their field. 

 So there does exist an under-shadow market of GMO

 products being imported and exported, but Ukraine currently

 does not have the mechanisms or the control mechanisms in place

 to even manage their own legislature.

 So I'm not just speaking specifically about Ukraine.

 What I'm trying to do is use Ukraine as an example and draw

 parallels as to why more rigorous testing needs to be

 implemented both in volume and with an updated and completed

 list of herbicides, insecticides, fumigants, because the

 reality is that we are being charged for products that we are

 likely -- that are likely not legit USDA organic. That's all I

 have. Thank you.

 CHAIR POWELL-PALM: All right. We really appreciate

 your calling in today. Questions from the Board? Many many

 thanks for making the attempt to make your voice heard today.

 Thank you very much.

 MS. DURFEY: Thank you.

 CHAIR POWELL-PALM: We're going to jump back to

 Kirsten. I think we've got the mute issue figured out.

 MS. NOVAK: Yes. Can y'all hear me now?

 CHAIR POWELL-PALM: We can. Please go ahead.

 MS. NOVAK: All right. Perfect. All right. Well,

 I'm Kirsten Novak and I'm a proud mother of five children. And

 my husband and I currently are in process of actually 
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 transitioning our small little farm from a conventional

 operation to organic, and I wanted to share with you the

 importance of why I feel like proper labeling and why organic

 is so vitally important.

 About three years -- or about a year ago, three out

 of my five children became very sick with many different

 diagnoses. And when we had sought out as much medical help as

 we possibly could through the conventional medical system and

 when they failed us, we reached out and found a holistic

 doctor.

 Well, she was very smart and she actually tested our

 kids for glyphosate. Once we were able to do the testing, we

 found out that all of our children, including us, had extremely

 high levels of glyphosate. Now, let me just tell you that yes,

 we are surrounded by farms around us that use glyphosate, but

 our small operation hasn't used glyphosate in quite some time.

 And we have ten acres that is completely organic.

 However, we eat 90 percent organic because we really

 believe strongly in that. Yet our kids still became very ill.

 And so we are very passionate about the labeling and education

 of organic, especially for parents and not just for parents,

 but really for farmers. Because if we can't get farmers in

 America to understand the process of transitioning to organic

 in their farms and being able to understand completely what

 this does for them and our environment, and for our food 
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 source, then we are not going to be able to produce the amount

 of organic foods necessary in America, as I know many of them

 are imported.

 I feel strongly that finding the truth in organic is

 so vitally important, and we know that organic truly does give

 us the best standard. I would also add to the gentleman that

 spoke a few minutes before me about region rate of farming, and

 I would love to see some sort of labeling that allows organic

 and region rated farms to have a joint label of some sort.

 As a mother and as a farmer, I believe that that is

 our best standard. And so if we can come along side of the

 regenerative farm, you know, practices and really let the

 consumer know what that actually means, I feel like organic

 will truly rise to the top and why we need funding to be able

 to do that.

 CHAIR POWELL-PALM: Well, we are so glad we were able

 to get you off mute. Thank you for making your comment today.

 We've got a question for you from Brian.

 BD. MEM. CALDWELL: Thanks, Kirsten. Just two quick

 questions. First of all, where are you located, and second of

 all, do you have any idea where the source of your family's

 glyphosate ingestion or exposure might have been?

 MS. NOVAK: Yes, I do actually. So great question.

 So I'm from Iowa. And so in Iowa, we have nothing but farm

 fields around us everywhere. And so even though our small 
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 little operation, we do -- we're actually transitioning our

 farm. But we have well water and we actually had our well

 tested, and sure enough, our water had glyphosate in the water.

 As you remember with COVID, we would never drink our

 water because I was always fearful of that, being that there

 was a field next to us where our well resides, thinking that

 maybe there could be some glyphosate there. And so we ended up

 having our water testing when our kids were -- we were off the

 charts in glyphosate. And sure enough, our water was extremely

 high.

 Now, it's so unfortunate because, you know, FDA, and

 our water supply, and all of that in America does not test for

 glyphosate. And we actually had to go through a third party to

 get that water tested. And then, of course, eating anything

 that is not organic, ideally you know regenerative processed

 based, you know, glyphosate and other farm chemicals can still

 get into organic products through operation. So -- yes.

 BD. MEM. CALDWELL: Great. Thank you very much.

 MS. NOVAK: Any other questions?

 CHAIR POWELL-PALM: Well, we really appreciate your

 time today. Thank you so much for calling in and sharing that

 story. And I think we're hearing the theme. We need more

 education, and it's, again, a big lift on all of us to try to

 get the word out there. So thank you very much for sharing

 that with us. 
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 MS. NOVAK: Can I add one quick thing about education

 too, I'm sorry.

 CHAIR POWELL-PALM: Sure. Go ahead.

 MS. NOVAK: I will say, as we're coming from a

 conventional farm practice, my husband is the one who was

 farming all of this life. And the farmer in the '70s and '80s

 believed that, you know, sprays were kind of the answer to

 efficiency, right? So it's really hard to get that older

 farmer into an organic type of practice.

 However, the new farmers that are coming up really

 want to do what is right for the community. And I will say,

 when we go to feed events and different things like that, the

 GMO producers and the chemical companies are really knocking

 down organic because they're saying it's just a labeling

 gimmick. It's just something that people are labeling, but

 it's not truly organic.

 And I think that's where we need to really focus our

 education, and it's to the farmers. So that that way, they

 truly understand what's in it for them financially to go

 organic, what's in it for the environment, and what's in it for

 the health and safety of this next generation.

 So unfortunately, Monsanto and Bayer are hitting it

 pretty hard against organic, and I think that's where we have

 to fight back and give truth, and give great education to

 farmers. 
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 CHAIR POWELL-PALM: I couldn't agree more. Really

 appreciate the specific examples and stay in touch with us. We

 want those ideas. We want to figure out how to build out these

 campaigns. So thank you.

 MS. NOVAK: Yes. Thank you so much.

 CHAIR POWELL-PALM: Next up we have Rob Peters,

 followed by Sylvia Wu, and then Anais Beddard.

 Rob, if you're there, the floor is yours.

 MR. PETERS: Good afternoon, how is everybody today?

 CHAIR POWELL-PALM: Doing well. Thank you.

 MR. PETERS: Excellent. Okay. I don't want to take

 up more than three minutes, so I'll get started right away.

 So Rob Peters with Nature Fresh Farms. We are a

 conventional and organic greenhouse located in Delta, Ohio,

 with over 90 acres, including North America's first organic

 strawberries under glass. So heavily invested in the organic

 area.

 But today, I'm speaking on behalf of the Organic

 Produce Association. We are one of the original members of

 that association, so I'm here to speak on behalf of the other

 members in the entire group.

 So the OPA is the only organization solely

 representing the organic produce industry. We strongly support

 the work of the NOSB in the National Organic Program. As you

 continue to support a growing and changing organic industry. 
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 This means leaning into technological advances as appropriate,

 while continuing to ensure that growing methods are adhering to

 the USDA's gold standard organic requirements.

 The OPA supports the USDA's efforts to assist

 producers as they transition into organics. The OPA members

 have grown organic produce both in ground and in controlled

 environments for decades.

 As you know, currently produce operations wishing to

 transition from conventional to organic production must undergo

 the three-year transition period to ensure the absence of

 prohibited substances. As technological advances continue,

 this three-year transition period is not reflective of all the

 production methods, some of which inherently have never been

 introduced -- has never used prohibited substances before.

 In addition to providing all other types of support

 for growers wishing to transition to organic, we believe that

 the time has come to discuss an alternative to the three-year

 transition period. It is undoubtedly a barrier into organic

 transition and we know that that is something that everybody on

 this call is really pushing for.

 So we believe that all growers should have -- should

 be provided an option to test out of the three-year

 requirement, if all other applicable requirements have been

 met. To that end, we support an option for all growers to be

 allowed to -- to apply for and receive an organic certificate 
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 with no waiting period if they can demonstrate adequate organic

 soil heath certification, be an approved soil testing standard,

 or in the alternative, if another growing media is used.

 This test should be carried out by a USDA accredited

 certifying agent, and show not substance prohibited by the

 USDA's national list of allowed and prohibited substances. As

 a precursor to this, the USDA should begin work with

 accrediting certifying agents to provide guidance on soil

 testing procedures to certify that no substances that are

 banned on the list are actually present.

 While the OPA understands that this proposal would be

 a significant shift within the National Organic Program, we

 also believe that to truly foster a more inclusive, diverse,

 and equitable organic sector, the NOP should consider ways to

 break down all barriers to organic transition, including this

 three-year transitional period, where appropriate.

 Again, the OPA would like to thank the NOSB, as well

 as the NOP, for your dedication and work on behalf of all

 organic producers. We really look forward to continuing to

 work together to address all barriers to organic transition and

 production, including any future work on container standards

 and other issues. Thank you.

 CHAIR POWELL-PALM: Thank you. Jerry has a question

 for you. 

 BD. MEM. D'AMORE: Good afternoon, Robert. You used 
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 the term CEA, controlled environment agriculture?

 MR. PETERS: That's correct.

 BD. MEM. D'AMORE: Yeah. That does not speak to the

 delivery system, to the plant. So what -- so you've got the

 structure. How -- are you in hydroponics? Are you in NFT

 hydroponics? Are you in soil?

 MR. PETERS: In soil.

 BD. MEM. D'AMORE: In what, please?

 MR. PETERS: Cocoa bags.

 BD. MEM. D'AMORE: Okay.

 MR. PETERS: Like Grodan bags, slats, different

 things like that.

 BD. MEM. D'AMORE: Okay. Those two terms don't mix

 with me very well, but we can just go offline on that, if it's 

all right with you.

 MR. PETERS: Okay. Yeah. It's a soil. It's a

 growing medium.

 BD. MEM. D'AMORE: Inert?

 MR. PETERS: Yes.

 BD. MEM. D'AMORE: Okay. It's hydroponics. From my

 perspective, now we know where we can start. Thank you very

 much.

 MR. PETERS: My apologies.

 BD. MEM. D'AMORE: No, no, no. Maybe mine.

 CHAIR POWELL-PALM: Nate, please go ahead. 
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 BD. MEM. LEWIS: Appreciate your comments. Just to

 reference the law that we all operate from, that is what is the

 -- that's what states the three-year transition requirement.

 So a better forum might be your congressperson and Senator for

 promoting that change, because it would take, at least my

 understanding, an act of Congress to remove that barrier. So

 -- but I appreciate your comments.

 MR. PETERS: Thank you. I appreciate the advice.

 CHAIR POWELL-PALM: All right. Thank you for joining

 us today.

 MR. PETERS: Thank you very much for your time, guys.

 CHAIR POWELL-PALM: Next up we have Sylvia Wu,

 followed by Anais Beddard, and then Gwendolyn Wyard.

 Sylvia, if you are there, the floor is yours.

 MS. WU: Hi. Good afternoon, everyone. My name is

 Sylvia Wu, and I'm an attorney with the public interest

 organization Center for Food Safety. The Center for Food

 Safety is dedicated to protecting people in the environment

 from the negative impacts of industrial agriculture. And in

 that same vein, we've been a long-time supporter of organic

 food production and protecting and defending organic integrity.

 I like to you a little -- just my time today, and

 hopefully not take up too much of your time, on the issue of

 inert ingredients and pesticides for organic production. 

 building on a lot of the comments that you guys have already 
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 heard today. 

The main point that I want to make is that as the

 Board continues to address the issue of inert ingredients in

 organic pesticides, that the Board must not accept any blanket

 allowance of inert ingredients based on EPA's classifications.

 Instead, to comply with OFBA, inert ingredients and pesticides

 for organic production must be specifically petitioned,

 reviewed, and approved by the Board under the National List

 process. 

This is because the EPA's review process and

 authorities are entirely different from the NOPs under OFBA.

 OFBA was written to specifically limit synthetic materials to

 only those absolutely necessary. And the EPA's review is

 entirely lacking in that prohibition. 

It is critical that NOSB review each new inert

 ingredient in pesticides for organic production separately.

 Such an individualized approach is mandated by OFBA's statutory

 and regulatory language. 

So I urge that the Board move away from the question

 of whether inerts should be individually evaluated. They have

 to be under OFBA. Inert ingredients and pesticides for organic

 production must comply with all of OFBA's requirements for the

 National List. There must be a demonstrated need for each

 synthetic inert ingredient in organic pesticides in order for

 it to be used. 
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 Such an individualized review is also necessary to

 provide full transparency so that growers, certifiers, and

 consumers will continue to have faith in organic integrity, and

 know what's being applied to their farms and their foods.

 Thank you for your time today.

 CHAIR POWELL-PALM: Thank you very much for joining

 us and for your comments. Nate Lewis has a question for you.

 BD. MEM. LEWIS: So I've asked this question a bunch

 of times today, but I appreciate your opinion around OFBA and

 the National List criteria meeting -- sort of requiring that

 individual listing. But my question relates to all the other

 classes of substances and lists that we reference on the

 National List. Does that imply those are not okay, or what's

 unique about inters that requires them? I'm just trying to,

 like, get to the bottom of that.

 MS. WU: Yeah. That I would say is -- I think it

 depends on the individual approaches to the adoption of the

 list, those referenced lists. And I can't say that I'm an

 expert on all of them. You know, I think there could be

 memorandums of understanding or other ways of establishing an

 individualized review or group reviews. But I think just to

 say, as long as it's on this list, without any specification of

 the Board having conducted some understanding of what that

 other list process entails, is insufficient, especially here.

 We're relating to inerts where I think there is a known 
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 difference between the EPA's review versus OFBA's statutory

 mandate.

 BD. MEM. LEWIS: That is super helpful. Thank you

 very much.

 CHAIR POWELL-PALM: All right. We really appreciate

 your comments today. Thank you.

 MS. WU: Thank you.

 CHAIR POWELL-PALM: Next up we have Anais Beddard,

 followed by Gwendolyn Wyard, and then Jackie DeMinter.

 MS. BEDDARD: All right. Hi. Thank you for

 pronouncing my name right. My name is Anais Beddard and I'm

 the second generation now running Lady Moon Farms. My parents

 founded the farm in the late '80s, and were part of the

 founding farmers of the modern organic movement in this

 country.

 Our Pennsylvania farm was the seventh certified

 organic farm in the state. We grew over the years, alongside

 the industry, and now have nearly 3,000 acres, with farms in

 Florida and Georgia. We're a fully diversified farm, growing

 upwards of 40 different commodities, ranging from leafy greens,

 to lettuce, to tomatoes. And we've been committed to the

 organic program for over three decades.

 We have believed deeply that program, while not

 perfect, was the gold standard for producing healthy food for 

our communities, while leaving the land better than how we 
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 found it.

 It is our belief that the organic program no longer

 is the gold standard. There have been many issues plaguing the

 program, but the one that we have seen significantly impact our

 business is the allowance of hydroponics into the program.

 There have been a handful of certifiers who refuse to

 certify these operations. And we believe that this is not only

 right, but it is necessary. Improving soil health was written

 into the law, as it is integral to the organic system model.

 Lady Moon participated in that conversation when it happened

 back in the '80s. We do not need special circumstances to farm

 competitively, yet that is exactly what these farms are

 receiving.

 The standards are not the same, the audits are not

 the same. The quality of the produce is not the same. The

 consumer deserves better, as many believe they're buying the

 gold standard in veg production when they buy the organic seal.

 While we haven't thought that add-on labels are the

 best choice to differentiate in the marketplace, we are given

 no choice when the organic seal no longer fully represents what

 we do. Being one of the original certified organic farms in

 the country, it hurts to admit that the program has lost its

 way.

 We believe programs like the Real Organic Project are 

 necessary to provide transparency and integrity to the end 
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 consumer. If we lose the consumer's trust, then we really have

 lost it all. With the allowance of varying types of production

 methods, it is critically important that we are all treated

 equally. There are already barriers in place for soil-grown

 food that are not in place for hydroponic.

 I know the crop subcommittee discussed the use of

 plastic mulch in organic production, and I wanted to touch on

 our view with this tool. While we try to minimize our plastic

 use across the farm, the use of mulch is critical to successful

 production, particularly in Florida. There are many benefits

 with weed, fertility, all of that. But growing in southwest

 Florida means that we grow in incredibly sandy soil. If we did

 not use mulch, we would not be able to maintain our beds

 physically. One heavy rain of four inches and the entire bed

 would wash away, along with the fertility we laid out.

 And it's not unusual to get this kind of rain in

 southwest Florida. In fact, it's quite frequent during the

 beginning of our season. And when you compare other

 operations, and you see the plastic used, the plastic laid out

 on the ground, the plastic buckets. I mean, there is ten-fold

 the amount of plastic than what is used on our soil operation.

 Farmers were incredibly resilient, optimistic group

 of people. I think organic farmers more so. So I want to say

 that my perspective has changed completely running the farm,

 even having growing up on it, and I recognize the incredibly 
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 hard work that this group does, showing up constantly. So I

 wanted to thank the NOSB for all of your dedication to the

 program as well.

 CHAIR POWELL-PALM: Thank you for your comments. And

 as we give a shout out to every farmer, it is not light task to

 show up and make sure your voice heard. So thank you very much

 for the time to join us today.

 We have a question for you from Jerry.

 BD. MEM. D'AMORE: Yeah. The question would normally

 center around hydroponics specifically, but I don't think we

 need to do that. I would just ask you, do you not believe that

 the entire organic program is built around exceptions, and the

 maintaining, and scrutiny of those exceptions?

 MR. BEDDARD: Yes and no. I would say the entire

 organic program starts with the soil and the ground beneath our

 feet. And that is built into every single thing we do. And I

 think with the addition of the exceptions, and this, and that,

 and you know -- the guy a few days -- he's talking about the

 transition period. Okay. So you're going to test cocoa quire

 while I'm going to test soil in the ground, that is not the

 same thing.

 So I'm asking for an even playing field. We're

 already competing with other countries, where it's not, you

 know, level, and we've heard a lot about that today. And I

 think that there are plenty of exceptions but you can't lose 
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 the original intent. 

BD. MEM. D'AMORE: Okay. Just one last question,

 then. In the reading of OFBA and reviewing hydroponics and

 what they say at the end of that, and then reviewing plastic

 mulches and covers, the same reading is there, except -- not

 allowed, except for. So in your own description in Florida, in

 what you need, you are using an exception in order to succeed;

 is that okay to say? 

MR. BEDDARD: Yes. I would say it's necessary. 

BD. MEM. D'AMORE: Thanks. You know, I'm just

 looking for common ground. That's all I want. So thank you. 

MR. BEDDARD: Well, I would ask this then. You know,

 where all of these hydroponic farms are, are they unable to

 farm the land where they are? Because I think that the answer

 probably is not the same. 

BD. MEM. D'AMORE: Okay. Well, the answer to that

 might be --

CHAIR POWELL-PALM: I'm going to jump in here real

 quick just to keep it fair. Anais, I totally understand your

 question. We keep it to Board members asking the questions.

 But really appreciate you joining us today. I think that

 there's usually a consistent narrative with the criticism of

 hydroponic and I think you brought a really nuanced perspective

 so -- as an economic threat to your business. I'm hearing you. 

Real quick, could you speak to what produce 
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 categories or products in particular you have experienced the

 most competition from hydroponics on?

 MR. BEDDARD: Definitely tomatoes. We also do a lot

 of lettuce, but we have found that the competition from field

 grown and hydroponic lettuce is different. Often the lettuce,

 hydroponic, as you know, much smaller, and it's going much more

 hyper local, whereas the hydroponic tomatoes are coming from

 much farther away, and flooding the market at a much lower rate

 than we can compete with.

 CHAIR POWELL-PALM: Okay. That's really helpful.

 Mindee has a question for you.

 VICE CHAIR JEFFERY: Thank you so much. I joke

 around sometimes that I'm the first generation in my family not

 raised on the farm, so I -- and I'm still mad. So thank you so

 much for staying there, and doing what you're doing. And as

 Board member, I don't know if I've ever experienced so much

 pain in the compromise as I do while we do this work. And for

 me, like something that really helps is that this is democracy.

 This is democracy in America.

 And for me, it's one of the few places that I see in

 this country where someone like yourself could have direct

 agency in the narrative.

 And I wonder if that helps you in how you look at

 participating in organic, and whether or not that helps you

 find your way to staying inside this community when you think 
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 about your choice of moving forward.

 MS. BEDDARD: You know, I would answer differently if

 it was six years ago, because I came to these meetings very

 regularly then, and I spoke. And I felt like the outcome

 wasn't heard by the farmers, who were out here doing the

 farming.

 So I might be a little more jaded now, unfortunately.

 But at the end of the day, like I can say all I want about addons, but I at my skill need the USDA organic label. And that's

 just part of it. If I didn't need that anymore, I don't know

 that we would keep it. But I need it.

 So I'm going to keep the USDA organic. And I'm going

 to continue to let our voices be heard as much as possible. I

 don't know that I have faith that it will change anything, but

 like you said, at least, you know, I can be heard, which is

 more than many other people.

 VICE CHAIR JEFFERY: Well, I appreciate you showing

 up.

 MS. BEDDARD: Thank you.

 CHAIR POWELL-PALM: Yes. Please stay in touch.

 Please come to the next meeting. We really appreciate your

 voice?

 MS. BEDDARD: Thank you, guys.

 CHAIR POWELL-PALM: Next up, we have Gwendolyn Wyard,

 followed by Jackie DeMinter, and then Kim Dietz. 
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 MS. WYARD: Okay. Sound check.

 CHAIR POWELL-PALM: Sound check's good. We can't see

 your face yet.

 MS. WYARD: You can't see my face?

 CHAIR POWELL-PALM: No. Never mind. I've got you.

 MS. WYARD: Okay. All right. Great. Great. Great.

 All right. Well, good afternoon, NOSB members, NOP staff, and

 everyone in the virtual gallery. My name is Gwendolyn Wyard,

 and I am a founding partner of the newest organic advising firm

 on the block, and the only one dedicated entirely to organic

 fraud prevention and supply chain integrity.

 We are strengthening organic systems, and we are here

 to SOS your OSP to comply with SOE.

 My business partner Kim Dietz is going to say more

 about our business in just a bit. But given all of the

 discussion around elevating organic, I thought I would start

 out with a few of my thoughts and how it relates to our

 decision to start this business. And for the record, my

 comments today are my own. I'm not representing any of our

 clients.

 Next slide. Ladies and gentlemen, feast your eyes on

 the organic wheel of sustainability. I spearheaded the

 development of this wheel when I was at the Organic Trade

 Association, and it continues to live as a key visual aid to

 OTA's data driven communications tool kit on the benefits of 
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 organic. 

 So Nate, if you were to ask me why organic is the

 answer, I would say it is not because of any one attribute,

 it's the sum of all of its parts. And it's unique, to Jerry's

 point on Tuesday, it is the only eco label in the marketplace

 that is federally defined, third-party certified, and enforced

 by a government agency. And it's backed by data.

 Each attribute around this wheel connects to a

 requirement in the regulation that you can look up, and an

 associated practice that fulfills that requirement and an

 outcome that is supported by reputable science and data that

 can be found in the wheels corresponding reference guide, which

 is a living, breathing guide that we will continue to develop

 and grow over time.

 SOS is passionate about organic, sum of all of its

 parts, and we created our business to help deliver the

 guarantee.

 And so with that, I'll turn to the next slide. SOS

 strongly supports an update to NOP's residue testing program.

 The work is clearly an OFBA responsibility of the Board. It's

 timely for effective SOE implementation because it will

 strengthen testing. Not only is it a tool for detecting fraud,

 but for monitoring the effectiveness of fraud mitigation

 measures, and identifying high-risk crops.

 So I have three important points that I want to end 
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 on about updating the residue program. Number one, focus first

 on updating the guidance and instruction in the NOP handbook.

 You heard this on Tuesday. Substances, methods currently used,

 responding to results, labs, everything that will prove clarity

 and consistency in testing and response practices. That's the

 first stop.

 Along these same lines, note that the guidance and

 instruction consistently referenced pesticide residue testing.

 But we know that it's more than pesticides. The preamble to

 the 2013 rule clarifies that testing includes GMOs,

 antibiotics, heavy metals, and other prohibited substances.

 Finally, keep in mind that the updates to the program

 will serve certified operations just as much as the ACAs.

 Testing is a critical tool that certified operations currently

 use, and will use even more as an impactful part of their fraud

 mitigation plan and monitoring procedures.

 Industry and labs look to this guidance and, as it

 stands, it's noticeably out of date. So thank you so much for

 your service. And turn to the next slide and I'm happy to

 answer any questions you might have.

 CHAIR POWELL-PALM: All right. We really appreciate

 your comments and your good work. Questions from the Board.

 Jerry has a question for you.

 BD. MEM. D'AMORE: Thank you. Good to see you there.

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 BD. MEM. D'AMORE: We've heard a lot in the last two

 days about SOE, and there's one piece of SOE that I haven't

 even heard the concept mentioned, which is in terms of

 protection, is randomness as a tool. How would your respond to

 randomness as a tool in identifying fraud?

 MS. WYARD: Randomness as in terms of testing?

 BD. MEM. D'AMORE: Okay. Right. In other words, as

 it was being discussed some time ago at the subcommittee,

 etcetera, you know, it's -- and as was put forward maybe a half

 dozen times in the last two days, you know, how do we stop

 these -- both bad actors? And there's one thing that I would

 be very, very strongly in favor of, which is recognizing that

 these folks are at least as smart as we are, and they're

 probably more nimble than we are. And if we take randomness as

 a central element of our detection and then future enforcement,

 then we would lose a lot.

 MS. WYARD: Yeah. Absolutely. I think, you know,

 unannounced inspections, the SOE rule codifies the requirement

 for unannounced inspections. It's always been a practice, but

 there it is in the regulation, and I think that testing is the

 most impactful, the most effective part of unannounced

 inspections.

 If you're going in and you're performing random

 testing, that's going to keep everybody on their toes. And I

 think, you know, that is why my comment about increased testing 
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 from industry, and right now, I think industry is testing far

 above and beyond the five percent that certifiers are testing.

 That's good. They're doing it for their own business purposes,

 for the quality of their products. But as everybody is

 conducting their vulnerability assessments and putting their

 mitigation plans in place, and being prepared for their

 inspections, their annual on-sights, as well as their

 unannounced, they're going to start doing more of their own

 routine testing, right, to make sure that they're good in

 preparation for the unannounced inspection.

 You know, we heard it earlier. Right now, you've got

 to make it difficult for the fraudsters, right? Fraudsters

 will go where it's easy. And so keeping everyone on their

 toes, making it hard, this concept of target hardening, right?

 So everybody comes together and they put up -- you know,

 everybody connects arms, and they make it very difficult for

 the fraudster to penetrate.

 And so the more that the criminal behaviors -- the

 criminals are out there, hearing about the unannounced

 inspecting. That makes it difficult. So I think that

 randomness, and specifically testing attached to unannounced is

 really, really important.

 BD. MEM. D'AMORE: Difficult and painful. Thank you.

 MS. WYARD: Difficult and painful. Thanks, Jerry.

 Nice to see you. 
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 CHAIR POWELL-PALM: Amy, please go ahead.

 BD. MEM. BRUCH: Gwendolyn, thanks for being here

 today. Thanks for focusing in on fraud prevention. I really

 appreciate it.

 You mention and you kind of alluded to it just now

 through that comment, and then in your written comments about

 there's room to increase the testing from five percent. And

 since you're representing your own opinion today, I'd like to

 put you on the spot and ask, how far can we go up? We've heard

 from people that need to go 100 percent of imports. Where

 would you rank yourself on that scale?

 MS. WYARD: Oh, boy. In terms of a number, I'm not

 sure. I think five percent is small. I will say that there

 are many certifiers that are above and beyond that five

 percent. So that's a little-known important fact, that it's

 not like everybody's holding right there at that five percent.

 Five percent is not enough. I think we could see it go up to

 ten percent. You know, again, we want to take -- you know,

 take –- even the full -– the amount that industry is also

 testing. But I think, you know, before we start increasing

 that percentage, again, back to the instruction, back to the

 handbook, we really need to look at where we're at right now,

 and do some improvements to make sure that the consistency, the

 response, and all of that is in place. There's a lot of

 training and educations that's needed before you start 
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 increasing the amount of testing. 

 So you know, I don't want to put a number out. I

 just know that it can and should be increased. What we want to

 also avoid is making that become, you know, the answer, right.

 It's a tool. We want to make sure that it's a tool. I'm very

 much in support of organic certification as a process, but you

 have to use testing as a tool to understand how well that

 process is working.

 So you don't want to go so high that it becomes a

 testing standard.

 BD. MEM. BRUCH: Thank you.

 CHAIR POWELL-PALM: Kim, please go ahead.

 BD. MEM. HUSEMAN: Hi Gwendolyn. Appreciate your

 comments and congratulations on your business.

 MS. WYARD: Thank you.

 BD. MEM. HUSEMAN: My question -- it was mentioned

 earlier about a lot of the fraud that is detected is

 transmitted via the rumor mill. There's places to go to find

 it, but it's not maybe as transparent. Would you have any

 suggestions for how to increase the transparency when an entity

 is -- you know, when they are found to be committed a fraud?

 MS. WYARD: How to commit the transparency to make it

 public information so people can go and look it up. I think

 there's -- is that -- am I understanding you correctly?

 BD. MEM. HUSEMAN: Yes. But as a -- maybe more as a 
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 stand-alone versus buried within another designed purpose. 

 MS. WYARD: Well, you know, I think this is

 important. It's a big part of the issue. I mean, even the

 amount of information that's available now, right, that you can

 go and look up. How many people know you can go and look up

 the most recent fraudulent certificates on the NOP website?

 And a lot of times, by the time the information

 becomes publicly available, it's like years after. It's

 already gone through all of the -- everything. So you know, I

 think this is something that we're looking at as a business

 too. We think it's really important to help people report

 fraud, and for there to be some sort of an early detection,

 early form of communication so folks can know where to apply

 additional scrutiny and due diligence, right?

 And it's tricky, though, because there's a lot of

 liability. There's a lot of responsibility. There's a lot of

 legalities. Everybody's a little spooked, a little bit scared

 of it.

 So I think like anything else right now, we have to

 increase our communication. We have to increase our education

 about where you can go now to find out what is happening, where

 the fraud occurs, and then we can build on it from there. But

 I think it has to come from a private entity that holds a lot

 of that information. I think that's how we're going to get,

 you know, further faster. So that is certainly something that 
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 we're looking at in terms of a core function of our business. 

 BD. MEM. HUSEMAN: Got you. Thanks so much.

 MS. WYARD: You bet.

 CHAIR POWELL-PALM: Kyla, please go ahead.

 BD. MEM. SMITH: Hi Gwendolyn.

 MS. WYARD: Hi Kyla.

 BD. MEM. SMITH: So, you know, we've been hearing

 lots of comments about imports still being a real challenge.

 And so I've been getting, like, really jazzed up to do the

 supply chain audits. Surprisingly. Because I guess maybe it's

 like a little bit of both. Like a little bit of fear and

 excitement, but anyway.

 I guess I'm just like -- I feel hopeful that we're

 going to -- like this is going to be a useful tool, and that we

 are going to get at something that certifiers haven't been able

 to get at before in a much more widespread way.

 And so I guess I'm just like -- and then, you know, I

 did ask someone else about that, and like got a little bit shot

 down. And so from your perspective, do you think that's going

 to help and be this -- as useful as a tool as I think that it's

 going to be, or like, am I just like off in crazy town?

 MS. WYARD: I do. I think that we are going to be

 shocked at the visibility that we're going to have, you know.

 And even in a year. And I can say this just even from the

 early start that we have in working with businesses that are 
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 just getting certified for the first time, right, following in

 that -- the area of exemptions, the distributors, the brokers.

 Right there, right, the information that's going to start with

 the operations first doing their supply chain map, right, as

 part of their fraud prevention plan, as part of that

 vulnerability assessment, this certified operations -- new

 certified operations now in the fold, they are going to be

 doing supply chain mapping. And they're going to be putting

 information into the Organic Systems Plan that you probably

 have never seen before, right?

 So right there, you're going to -- you know, landing

 on your desk, you're going to have increased visibility about

 where these products are coming from and where they're going.

 And then U.S. certifiers are going to be working

 together to connect those dots, and to have that full chain

 visibility from farm to marketplace. And that is critical,

 right, to make it work. Because the certified operations,

 hopefully they will be doing more than just one up and one

 back, right, but that's the requirement right now as to the

 last certified entity.

 But I think as this mapping happens, and as everybody

 is digging into their supply chain to figure out who's

 certified and who's not certified, who needs to get certified,

 what we're going to see, I think, surface in this next year as

 everybody is, you know, scrambling to meet this March 19th, 
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 2024 date, just right there, there's going to be huge increased

 visibility.

 I think the real challenge is going to be how to make

 the information work as fast as it needs to work, and not get

 bogged down, particularly as certifiers are communicating to

 each other, and how to, you know, connect all those dots.

 Because right now, the -- I'm not saying that people are using

 a paper file system, but in some ways, it's not far from that.

 So you know, that central database, and figuring out

 the technology piece of it, funding into the integrity

 database, so important, growing that database, figuring out how

 to work that communication.

 I feel hopeful, but it's going to take a lot of work.

 I'm glad you're hopeful.

 CHAIR POWELL-PALM: Other questions for Gwen.

 MS. WYARD: All right.

 CHAIR POWELL-PALM: I don't think it's an

 understatement to just highlight how useful that sustainability

 wheel is as a visual communication aid. So thank you for

 helping develop that. I'm really glad it's out there to help

 everyone describe what organics is.

 Could you, you know, ideate with me for a second on

 where and who you think are the best messengers for educating

 the world about what organic is?

 MS. WYARD: Absolutely. Absolutely. The best 
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 messenger -- I think -- I mean, Mike did a great job in saying

 we all play a part, right? It takes everyone. But I am a

 strong believer that it is at the point of sale that the

 shopper is going to be best educated. It is at that point of

 making a decision, and it's that point when they are reading,

 and looking, and deciding what to buy.

 So I think that the champions in all of this are the

 retailers. I think it takes everybody to help get the

 information and the resources to support the retailers, but I

 think it is absolutely the retailers that are the champion.

 And I think that if we look. I mean, really, if you -- I know

 we've got to go, right. We're running out of time. But if you

 look at that wheel, the reason that wheel was created was to

 educate retailers, the large retailers, because we found when

 we went online, and all this -- you know, there's a handful

 that I -- to get people kind of in the mood, I'm going to say

 Amazon, Walmart, Kroger, right, large retailers that have

 sustainability programs, that have climate-friendly, climate

 pledge programs. And then they had these screening filters,

 where they would decide who would make it into that program

 that would get their stamp.

 USDA organic is not making it. You can go on right

 now and look at the Built for Better program, good for the

 planet, good for the people, and through one large retailer

 that we know, and you will see 30-something seals, 
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 certification seals, and USDA organic is not on there.

 So it's kind of hard road -- if you've got some of

 the largest retailers and they're not accepting USDA organic as

 a certification that meets their sustainability and climate

 standards, and they're right -- putting information out on

 products and in stores to help shoppers, to help guide shoppers

 and their choices for purchases that support the environment,

 and USDA organic is not in there, that is a real problem.

 So educating the retailers and getting information

 into those stores at the point of sale, I think that is really

 where it's at. That's my opinion.

 CHAIR POWELL-PALM: So appreciate that. I love it.

 Yes. Thank you very much.

 MS. WYARD: All right. Well, thank you, Nate. And

 thanks to everybody. I appreciate it. All right. Have a

 great afternoon and have a great meeting next week.

 CHAIR POWELL-PALM: Thank you. Next up we have

 Jackie DeMinter, followed by Kim Dietz, and then Lily Hawkins.

 Jackie, the floor is yours.

 MS. DEMINTER: Good afternoon. My name is Jackie

 DeMinter. I am the certification policy manager at MOSA

 Certified Organic.

 Thank you for the opportunity to comment. We certify

 about 1,850 organic operations in the U.S. I'm commenting

 today primarily on geolocations and reducing regulatory burden, 
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 which are tied together. Before I get to those, we have a

 request for the NOP regarding use of the organic integrity

 database certificate and addenda. Please provide guidance on

 future data requirements so we can effectively implement SOE.

 It looks like the OID certificate only shows scopes,

 making an addendum with product details necessary. The addenda

 can be provided from the OID or not, though the information is

 still visible in the public search, MOSA intends to provide our

 clients with a more detailed product listing. If we provide

 this as an addendum, is it required to be made public. As to

 geolocations and regulatory burden, a blanket requirement to

 record geocodes for sites that already have a clear physical

 address would be an added burden.

 If we were to find we couldn't locate an off-site

 field for an unannounced inspection without the client, a non-

 compliance can be issued and a GPS location gathered. For

 fields we identify as difficult to locate at the application

 stage, we could record the geocode when onsite. This minimizes

 the burden in collecting verifying and maintaining the

 information for all clients.

 Recording GPS locations as a risk based best practice

 provides and sound and sensible path to increases compliance

 without excessive burden. We encourage NOSB to find creative

 ways to reduce any unnecessary burden for organic certifiers,

 as well as farmers and handlers, especially compliant, low-risk 
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 operations. Increased oversight targeting high-risk operations

 also affects operations that have low to no risk to organic

 integrity when the same requirements are applied to everyone.

 Let's focus our attention on impactful areas. We

 could increase residue testing for bulk imports as part of our

 current residue testing program without an added requirement

 for more residue tests overall. We have the ability to be more

 impactful by continuing to keep our efforts focused on

 livestock. So our eligibility compliant, additional

 requirements impact clients.

 Inspections this year have effectively doubled in

 time and cost, with small dairies taking the biggest hit. It

 isn't feasible to continue to absorb additional inspection

 expenses, and we can't solve the inspector capacity issue

 without relieving pressure in other areas.

 There's a strong second to Nicole Dehne's articulate

 comments and answers to the Board's questions. Thanks, Nicole.

 You said what we're thinking in such an effective way.

 Thank you, NOSB, for the work you do.

 CHAIR POWELL-PALM: Thank you very much for your

 comments. Questions from the Board? I just want to give MOSA

 a huge shoutout. You're doing a great job as a regional top

 lead. You're killing it. So thank you very much for all that

 work, and healthy farmers get organic.

 All right. Next up we have Kim Dietz, followed by 
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 Lily Hawkins, then Kate Mendenhall.

 MS. DIETZ: Hi, everybody.

 CHAIR POWELL-PALM: Hello.

 MS. DIETZ: My name is Kim Dietz.

 MS. ARSENAULT: Hey, Kim. Just me. Hang on one

 second so your slide's here. There we go. Thanks.

 MS. DIETZ: Thank you. All right. My name is Kim

 Dietz, and I am the founding partner of Strengthening Organic

 Systems. For the record, today, I'm speaking on behalf of

 myself and not a paid advisor. I served on the NOSB from 2000

 to 2005 in the handlers. Chaired the materials committee and

 served as Board Secretary. So I deeply thank all of you for

 doing what you do. It takes a lot of dedication and service,

 and I do appreciate all of your time.

 So a few fun facts related to what I'm going to talk

 about today. I had oversight of the very first certified

 organic facility in the United States, so in early 2000s, the

 company I worked for voluntarily certified as a handler

 facility. And I also was the very first company to create an

 organic flavor.

 So topic of the day. After graduating law school in

 2019, I left a 30-year career with that original organic

 company and led the flavor division of an organic flavor

 division for one of the largest global flavor manufacturers.

 So quite a bit of extensive experience there. 
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 Next slide, please. In June, Gwendolyn Wyard and I 

 co-founded Strengthening Organic Systems. We are organic

 experts with 65 years of combined experience. So you see a

 little bit about us here on this screen.

 Next slide. Today, I'd like to speak on nature

 flavors, Sunset, SOE implementation, and if I have time, a

 comment about the organic check off.

 As I mentioned earlier, I developed and certified the

 very first certified organic flavor in 2002. At that time, my

 company made a business decision to only use organic flavors in

 all of their products, exclamation point. This ethical

 decision helps stimulate where we are today with thousands of

 organic flavors in the market. In 2015, Gwendolyn and I co-

 chaired the OTA organic flavors task force, and brought forward

 the petition to add the current annotation on commercial

 availability. My message to you today is that we need to

 continue with the current listing of natural flavors on the

 National List.

 I would also like to say that the commercial

 availability clause is flawed and not working. I know the

 good, bad, and ugly of natural and organic flavors. Many

 companies are not following the intent of commercial

 availability, which was to require the use of organic flavors.

 I urge the NOSB to endorse a working group or a task

 force bring me in again, bring forward recommendations on the 
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 listing of natural flavors prior to the next Sunset. We have

 to move the needle again. I have many ideas and suggestions on

 the topic, so you can ask me about those anytime.

 A little bit about the SOE rule, we are committed to

 doing that. I think it's important that we uphold consistent

 and enforceable procedures around SOE. So that is our goal.

 And check off, ask me if you want to know any more about that.

 CHAIR POWELL-PALM: All right. I've got a question

 for you. Thank you, Kim, for your comments. We have a

 question for you, Amy Bruch.

 BD. MEM. BRUCH: Hi, Kim. Thanks for joining us

 today, and thanks for your past service on the Board, and for

 the organic community.

 I wanted to take your question about learning more

 about the check off. I'd love to hear your thought on that,

 please.

 MS. DIETZ: Yeah. So I was actually quite amazed at

 the comments on Tuesday coming from folks. And I'm glad to

 hear that we're rekindling that topic again. In 2010, I

 chaired the OTA committee that worked to bring forward a

 national research and promotion program. So I just want to

 make sure people know that -- we've gone down this road before.

 We actually had a proposed role that was taken off the table in

 2018. So there's been a lot of work in this area.

 The program -- the intention of the program was to 
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 bring about $30 million to promotion at the time. So that was

 my comment. I mainly want to just remind everybody that we've

 done this. We've got -- I think there was about 12,000 public

 comments at the proposed rule before it came out. So we've got

 a lot of data. We've got a lot of research. We know what the

 consumer is looking for. We just have to get the message to

 them. And that was the main thing is that the consumers need

 to be educated about organic. They just have no idea and

 they're confused.

 BD. MEM. BRUCH: Okay. Thank you, Kim. I know a lot

 of dollars are coming out of our paychecks for organic farmers

 for these check off programs, and our voices aren't being

 represented. Groups are taking the dollars. We can file 

 exemptions, but yeah. That's helpful to learn. Thank you,

 Kim.

 MS. DIETZ: Yes.

 CHAIR POWELL-PALM: Please go ahead, Allison.

 BD. MEM. JOHNSON: Thanks. Amy got my first

 question, but that means I've got to follow up. Thanks for

 being here, Kim.

 My understanding is that some of the concerns around

 a check off were related to -- so the general corruption issues

 with the check off programs, and their history and also

 concerns about the scale of operations, and who would benefit

 most. 
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 I think we've heard from a pretty wide range of 

 operations. We're looking for some help with marketing, and so

 I'm curious if you have thoughts about how to address those

 concerns specifically.

 MS. DIETZ: Yeah. I mean, it was a tough five years.

 You know, it was a very controversial topic. Not everybody

 likes check offs, and many of them have failed. But then

 there's been some very good ones like the Incredible Edible

 Egg, and the pistachio. But at the end of the day, you know,

 we need funding to get the marketing and the messaging out, and

 how are we going to do it?

 We have been challenged as an industry. You know,

 we're 30 years old, and we still haven't got that message out

 in the right way. So we need something to work. It's not

 perfect, and it wasn't perfect, but we tried. So you know, I

 guess to answer your question, it's not going to please

 everybody, but you know, if this Board, and this -- and now is

 the time to do it again, we should try it.

 CHAIR POWELL-PALM: Really appreciate both the

 historic work on that effort, Kim. I don't mean to minimize

 that for a minute. I realize there's a lot of folks who have

 been trying to figure this out for a long time.

 MS. DIETZ: Yeah.

 CHAIR POWELL-PALM: And it seems like -- you know, if

 it's not a check off, something to spread the good word about 
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 organic. That's what we were hearing from producers. So

 putting it all out on the table. Thank you again for your

 comments. We really appreciate them.

 MS. DIETZ: You're welcome.

 CHAIR POWELL-PALM: Next up, we're going to have Lily

 Hawkins, followed by Kate Mendenhall, and then Erin Meschke.

 Unfortunately, today folks, we are not going to get

 to the folks on the waitlist. I really appreciate everyone

 holding on with us. This has been one of the most fantastic

 meetings, tele-comments has just been great, really good

 conversations. But unfortunately, good conversations take

 time, and we are running out of it.

 So we are going to move to Lily Hawkins, then Kate

 Mendenhall, and Erin Meschke. We're going to finish out the

 day with Sal Pinkham, Sam Welsh, Sara Neagu-Reed, and then Bob

 Quinn to close out the day.

 Lily, the floor is yours.

 MS. HAWKINS: Thank you. Hi everyone. My name's

 Lily Hawkins, and I'm speaking today on behalf of Organic

 Farmers Association. And I'd like to share comments on three

 topics. The first one will be quick. In regards to the work

 agenda request on biobased mulch film, I'd just like to share

 that this issue is consistently a fairly low priority for OFA

 farmer members. There is no biobased mulch film currently

 available that meets the standards. And we feel that this 
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 issue has been adequately discussed and addressed.

 So OFA urges the NOSB to prioritize the many other

 issues of more importance to organic growers. Thank you. And

 secondly, we would like to urge you to add organic swine

 management as an agenda topic. We are eagerly awaiting the

 publication of the final OLPS standard. And we would just like

 to mention that OLPS does lack detail when it comes to many

 areas of swine management that are typically covered in humane

 standards and in other national organic standards.

 In order to expand the organic pork industry and to

 better serve consumers and producers of organic pork, more

 clarity is needed to promote animal welfare for swine on

 organic farms and to clearly communicate to consumers how

 organic pork is differentiated from other labels.

 Since these issues have not been fully discussed with

 all stakeholders, we are hoping that the NOP and the NOSB will

 place this issue on the NOSB work agenda. And we'd like to

 mention that Milwaukee is a great location for convening

 organic swine producers, and an organic swine producer panel at

 the spring NOSB meeting would be a great start to addressing

 the issue. OFA would be happy to help you find producers for

 this panel if you should choose to go in that direction.

 And then finally, another agenda item we would like

 to see added is Greenhouse and container production standards.

 OFA supports organic certification of crop production, where 
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 typical terrestrial plants are grown to maturity in the ground

 with no barriers between the topsoil, subsoil, and bedrock.

 The plants must obtain the majority of their nutrients from

 that soil rather than from highly soluble fertilizers, and OFA

 opposes organic certification of hydroponic production and

 other production systems which do not meet the preceding

 requirement.

 And we urge the NOP to revoke the organic

 certification of such operations. Current standards for the

 organic production of crops and containers in and outside of

 greenhouses are very limited, which has led to widespread

 certifier inconsistency in this area. As these production

 methods proliferate, strong standards are urgently needed to

 create a level playing field for organic producers and ensure

 that all certified organic production is climate smart.

 We urge to you resume work on the agenda item, field

 and greenhouse container production. Thanks for your time and

 for the opportunity to comment. Look forward to seeing you all

 next week.

 CHAIR POWELL-PALM: Thank you very much for your

 comments. Questions for Lily.

 Thank you, Lily. I have a comment just to the group.

 For this idea of swine, I would really appreciate if we could

 get some more specifics. Right now, I see no market for swine. 

And so figuring out how do we get that pull would make me 
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 create that demand. I'd be dying to know from everybody how we

 can make sure that -- if we're encouraging folks to transition,

 we have a market identified. So thank you for your comments.

 CHAIR POWELL-PALM: Next up, Kate Mendenhall,

 followed by Erin Mischke, and then Sal Pinkham.

 MS. MENDENHALL: Good afternoon, everyone. Thank

 you, NOSB members, for the opportunity to speak before you

 today. My name is Kate Mendenhall, I'm the executive director

 of the Organic Farmers Association.

 OFA is a strong national voice, advocating for

 domestic certified organic farmers. Today, I will be

 addressing racial equity and strengthening organic enforcement.

 For racial equity, when OFA was founded, farmers wrote race and

 gender mattered as one of our guiding principles. OFA believes

 that the ways in which we work with each other and in

 organizations and movements, must reflect the values we hold

 for the world.

 We also -- I'm sorry. We're hitting like right when

 the school bus is arriving. I'm sorry. All right. I'm just

 going too have to start over that sentence.

 We also understand that the conditions that limit or

 support leadership, organizational and movement success are

 directly impacted by structural racism, sexism, and inequality.

 Thus, OFA is committed to addressing issues of race, gender, 

and equity in our work. 
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We ask that the NOSB and NOP also make this a 

 priority by centering racial equity in the processes of the

 Board. The USDA's equity commission is impressive and provides

 recent recommendations that can guide how the Board embed

 racial equity into its processes, discussion documents, and

 public meetings. We hope to hear more about how the Board will

 specifically address work on racial equity in Milwaukee. 

For strengthening organic enforcement implementation.

 OFA supports the SOE rule. However, we understood that its

 implementation would not impact fall to mid-size farmers,

 focusing rather on handlers, hirers, farms, and the import

 arena. 

Regretfully, we have started to receive calls from

 small farmers directly impacted by SOE implementation. Farms

 are being asked to monitor and provide documentation, noting

 their sold organic product -- where their sold organic product

 goes after it leaves the farm gate, and how it's handled. 

Record keeping requirements have increased to this

 effect as well. Farmers are concerned that they will: one,

 lose small markets who do not deal with this; and number two,

 be unfairly burdened by increased record keeping intended for

 higher risk operations. 

We understand that certifiers are working to

 interpret and implement SOE with certified operators. While

 that's taking place, we strongly urge attention be paid to 
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 paperwork burden and risk and SOE implementation, putting the

 increase in enforcement where it's most needed.

 We also ask for consistency and SOE implementation

 among certifiers, and more guidance and clarity from the NOP,

 paying specific attention to shielding negative impact from

 small farms.

 We should not lose small to mid-size farmers from the

 certification program because of SOE. OFA requests that you

 continue to work with NOP on this issue. And I was really

 pleased to hear some of the comments from DOF and MOSA about

 the same. I just think there's a lot to focus on and really

 protect small and mid-size farmers.

 CHAIR POWELL-PALM: Thank you very much.

 MS. MENDENHALL: Apologies. For the --

 BD. MEM. TURNER: Do not apologize.

 CHAIR POWELL-PALM: It is for them who we meet.

 Wood, please go ahead.

 BD. MEM. TURNER: Nate I was just going to just jump

 in there and say, I love seeing your kids on the screen. And

 you know, this is -- to me, what Nate has said several times

 over the last couple of days about this virtual format, and

 giving people an opportunity to participate. I think it also

 extends beyond farmers to people who are able to work from home

 and raise their families while we're doing this work.

 And I just think our grace in understanding that and 
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 recognizing that is really, really important. So thank you

 very much and don't sweat it in the slightest. Thank you for

 your poise as you were going through that -- through your

 remarks.

 MS. MENDENHALL: Perfect timing.

 BD. MEM. SMITH: I'm going to jump in and just say --

 I was going to say nice recovery. And as tele-Board members

 know, my kids interrupt during Board calls all the time. Lots

 of visitors from my kids during Board calls.

 MS. HAWKINS: Thank you for being so understanding.

 CHAIR POWELL-PALM: Allison, please go ahead.

 BD. MEM. JOHNSON: Thank you. Yeah. Echoing the

 appreciation for the best kind of Zoom bomber, and for your

 patience as we're running over time and bleeding into your

 evening.

 I want to appreciate your comments on racial equity

 and just preview that we are trying to think about what we can

 bring forward in Milwaukee, especially looking at the Equity

 Commission's report, and anything you can do to keep the

 information flowing towards us from all of the outreach and

 work that you've been doing. We really appreciate it and need

 your insights.

 I'm going to put you on the spot with a question

 about the checkoffs since it's been coming up and you are such

 a strong voice for small farmers. We've heard from a number of 
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 folks over the last two days who are really looking for help

 marketing. And I'm curious if you have ideas in the cooker, or

 are interested in thinking through what that support could look

 like, whether it's a checkoff or some other options.

 MS. MENDENHALL: Yeah. I mean, I do think that

 marketing is something that is needed. I'm really excited to

 see the organic marketing program come out on top. And then

 there's a farm bill -- marker bill focused on organic

 marketing. I think that's a great direction to go.

 I just want to provide some caution to the avenue of

 an organic checkoff. One, because it was so divisive when it

 was attempted last, and really created a lot of distraction

 from positive organic methods, and things that we need to work

 on as an organic community. And secondly, what I heard from

 farmers across the country was that they have had many -- I'm

 sorry, just a second.

 (Pause.)

 MS. MENDENHALL: Sorry. So farmers have experienced

 just a lot of -- not a lot of benefit from checkoff programs

 historically, while industry -- industrial agriculture has

 really grown. So I just want to provide some caution.

 And the organic community is so creative. So I think

 maybe using the things that are good about that concept of a

 checkoff, but creating a program that's going to be really

 healthy for the full spectrum of our organic community today 
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 would be a more positive route to go down.

 But you know, I think definitely marketing is a key

 priority.

 CHAIR POWELL-PALM: Amy, please go ahead.

 BD. MEM. BRUCH: Okay. Thanks, Nate. Thanks, Kate,

 for being here, impressive management of distraction. You're

 doing awesome. Quick clarifier and then I have a question.

 But the clarifier, when you mentioned farmers and

 were such a basket of goods in the organic industry, are these

 grain farmers, primarily, when you say farmers? Are these

 fruit and veggies? Or what angle when you say farmers? Or

 maybe it's all of them -- all of the above.

 MS. MENDENHALL: Are you talking about checkoff?

 BD. MEM. BRUCH: For the checkoff, yeah. Just on

 your previous comments to Allison.

 MS. MENDENHALL: Yeah. Well, you know, I live in

 northwest Iowa, and I can say I grew up during the farm crisis

 of the '80s, and there were loads of small pork producers. And

 the pork checkoff is one that just, like, brings tears to your

 eyes about how over the course of that checkoff program, we

 lost local auction opportunities, small farmers went out of

 business, and they attributed it to the pork checkoff in a

 large part. The market was really focused to a more industrial

 model. And that is the way that the market went. 

 They tried to overturn the checkoff, and it went all 
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 the way to the Supreme Court, and they weren't able to do that.

 So that causes a lot of concern from that particular piece.

 And then when I was talking to farmers, and at the

 time, I was at NOVA New York in New York State, and a lot of

 produce farmers were not really participating in checkoffs, but

 concerned with -- even if they were going to become exempt with

 the last proposal. The amount of paperwork they were going to

 have to do annually to prove that they were exempt.

 And then you come up with the same problems about,

 well, how do you define net profit or gross income, when you

 have such big first commodities? You have organic dairy farms

 that have a really high gross low net. You have vegetable

 farms with, you know, sometimes the opposite problem. And so

 it's just really hard to make a rubber stamp checkoff program

 when -- with all of these commodities. Typically, it's one

 commodity, and farmers are farming in a very similar system.

 So there are just a lot of challenges to applying that model in

 -- for a full organic industry that we hadn't seen before. And

 I don't think it was really cracked correctly.

 BD. MEM. BRUCH: Yeah. Okay. Thanks for that

 insight. Sorry, my real question -- this one's probably going

 to be quicker actually, your answer, just because appreciate

 forward. So I've seen in 2018 farm bill priorities captured

 this thing that was in your written comments, but we didn't get

 it over the finish line, and it was organic price elections for 
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 storage loans offered by SFA, so that if we want a storage loan

 and we're not using conventional commodity prices, we're using

 the organic prices that RMA recognizes.

 It didn't get over the finish line. What's the best

 method or avenue to position this? You had it in the crop

 insurance dialogue discussion, but I'm wondering is there a

 different avenue. Is it Farmville? Back to Farmville for

 that?

 MS. MENDENHALL: I mean, I think there are some good

 crop insurance Farmville suggestions. We're going to be doing

 a lot more work over the next two years with farmer crop

 insurance, focus groups, to try and nail down the best farmer-

 driven solutions for some of these, as well -- and I really

 appreciate all the work that the NOSB is doing.

 I'm probably not the best person to, like, directly

 answer your question, but I would be happy to ask the rest of

 my team and get back to you.

 BD. MEM. BRUCH: Yeah. That sounds good, because I

 want to just nail placement so we can hopefully get that over

 the finish line.

 MS. MENDENHALL: Okay. Thanks.

 CHAIR POWELL-PALM: Kyla, please go ahead.

 BD. MEM. SMITH: I'm breaking the no comments, just

 ask questions rule. So sorry. But anyway, I just wanted to 

make a comment just based -- to you and to, you know, the other 
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 commenters who spoke about SOE's impact on small and mid-size

 farmers, and just wanted you to know that certifiers -- some

 certifiers spoke on that. I know PCO is taking that issue

 quite seriously as well. 

And so work is being done. Certifiers are

 collaborating together through the ACA. We're not -- again,

 we're not going to get it perfect. And so I do appreciate,

 like, this getting raised up so that we can continue to, like,

 how would this be at the forefront, and try to find ways to

 navigate this. But -- and the NOP continues to drop trainings

 in the learning center. I haven't watched those all yet. 

So anyway, I just want to recognize the comments and

 just say that things are moving along, and it sounds like we

 need to do a better job of working together because the message

 isn't staying consistent. And so I just appreciate that, and

 we can try to work through that with, you know, some future ACA

 working groups, so thanks. 

MS. MENDENHALL: Can I just make a quick comment to

 that? 

CHAIR POWELL-PALM: Very quick, please. 

MS. MENDENHALL: Yeah. I would just say that we're

 already hearing -- we're getting calls from farmers who are

 hearing -- feeling the stress on that. So maybe there's, like,

 a little more dialogue maybe that we can also bring that

 feedback to ACS, the working group, so that just gets part of 
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 the discussion. Thank you.

 CHAIR POWELL-PALM: Thank you, Katie, for your

 comments. Thank you, Kyla.

 Michelle, do we have Erin on the phone?

 MS. ARSENAULT: It looks -- Erin's not with us, Nate.

 CHAIR POWELL-PALM: Okay. We're going to jump to Sal

 Pinkham, then Sam Welsh, Sara Neagu-Reed, and I did say at the

 beginning I'm an equal opportunity butcher of names, so

 apologies if I get yours wrong, and then finish up with Bob

 Quinn. Sal, please go ahead.

 MS. PINKHAM: Good afternoon. I'm Sal Pinkham,

 certification program manager at OEFFA. We certify about 1,100

 organic farmers and food processors in a 12-state region. I

 appreciate the opportunity to comment today on behalf of our

 certification program and our farmers, many of whom were unable

 to join this meeting due to harvest timing.

 We were disappointed by some of the comments made to

 our farmers by the Board at the spring meeting. We hope that

 moving forward, the Board will treat public commenters with the

 same respect that you wish for yourselves.

 Regarding tax topics. We appreciate the Board's

 elevation of organic as climate smart farming. We suggest

 ensuring that that NOSB research recommendations, always

 include direction USDA to study carbon sequestration and

 greenhouse gas emissions across a wide variety of organic and 
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 conventional farming systems, conducting a panel discussion

 with soil health and climate scientists to inform the Board,

 and developing principles for the NOP to use in conversation

 with others at USDA to illustrate the multifaceted nature of

 the organic systems approach.

 We thank the Board for delving into the critical

 topic of risk protection for organic farmers, and conducting

 such a comprehensive evaluation of the subject matter. This

 topic is too large to do justice in a three-minute comment, so

 I urge the Board to read OEFFA's written comment and

 recommendations in our crop insurance platform, which were

 developed by our farmers and addressed those subcommittees

 questions in detail.

 Certifiers absolutely need to know the locations we

 certify. However, we offered a nuanced perspective on the

 spring discussion document that appears to have been foregone

 in this proposal, which we strongly oppose. This would be an

 unfunded mandate for certifiers, with neutral to negative

 effects on farmers. It will fall hardest on certifiers like

 OEFFA, who certify operations that do not use digital

 technology. And perhaps most crucially, it will not help us

 prevent fraud to support farmers or improve the most

 consequential inconsistencies among certifiers.

 A fundamental inconsistency is the certification of

 hydroponic and aeroponic crops. We ask the Board to call for a 
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 moratorium on the certification of new operations that grow

 crops to maturity in containers and to add field and greenhouse

 container production back to your work agenda.

 We fully support broadening the net for residue

 testing to better encompass the entire global organic supply

 chain. Residue testing is costly and we would love guidance on

 how to use it most effectively. We support the proposed

 framework for evaluating residue testing with a few nuances

 mentioned in their written comments. And we suggest that NOP

 aggregate positive test results from certifiers and share that

 data with certifiers, so that we can continually adjust our

 sampling efforts to focus on areas of highest risk.

 Finally, we appreciate the Board's interest in

 organic transition support. While a lot of the organic

 transition initiative has been less than ideal, but the

 program's objectives are extremely important. In future, we

 ask that the USDA develop such programs by first seeking

 partners among BIPOC organizations and those that are already

 doing the work so that resources can be used most effectively

 and support those who are most in need.

 Thank you for your service to the organic community

 and for taking the time to listen to my comments.

 CHAIR POWELL-PALM: Questions for Sal. Amy, please

 go ahead.

 BD. MEM. BRUCH: Yeah. Sal, thank you so much for 
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 joining us today and representing OEFFA and your members with

 your comments. I just -- maybe I didn't hear you correctly on

 the geocodes. I just wanted to understand -- or sorry,

 standardized location information, is the official name of that

 topic, the proposal. I just wanted to understand that better

 because there was effort to be made to encompass the feedback

 that we heard, especially from the plain's community about the

 parcel post and that that's kind of a common thing that, you

 know, folks are knowledgeable on and then legal addresses or

 street addresses that could lead to the geocodes. Is that

 helpful or is there something more that could be beneficial

 there?

 MS. PINKHAM: Yeah. So first of all, thank you for

 incorporating that. I think Joel Kerts (ph.) was one of our

 members who spoke, and he had some really good feedback for

 you, and I know you listen to that.

 BD. MEM. BRUCH: Awesome.

 MS. PINKHAM: I will say, though, that -- the fact

 that some plain farmers are able to provide geocodes does not

 address the bigger problem, which is that not all of them can.

 And certifiers, such as OEFFA, are going to have place stuff on

 hundreds of operations, either at inspections or at review

 time, to try to get all of those entered into a consistent

 system.

 The bigger problem with the current proposal is that 
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 it's really focused on database consistency, and I'm a wonk. I

 like database consistency, but that by itself is not an

 important enough aim to increase the burden on small certifiers

 or small farmers. We need to focus on what it really

 accomplishes.

 And the proposal in spring to have really specific

 geocodes, like the center of the field, would have had a slew

 of problems that you've avoided with the new proposal, but it's

 now broad enough that it won't have the benefits to fraud

 prevention that you're looking for. It's not going to help us

 with mass balance audits. It's not going to help us with

 traceability. It's not specific enough because it's not tied

 to crops being grown in those fields for us to do any useful

 analyses of the things that this would exist to be useful for.

 Like the only benefit to the GPS pins that everything

 would be converted to under this current proposal is being sure

 that we can find everything for inspections. But that's

 already a requirement. We already can issue non-compliance if

 operations don't give us enough information. NOP can issue us

 a non-compliance if we're not collecting appropriate

 information. Does that make sense?

 BD. MEM. BRUCH: Yeah. Thank you. I appreciate your

 additional information.

 CHAIR POWELL-PALM: Carolyn, please go ahead.

 BD. MEM. DIMITRI: So I just wanted to thank you and 
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 your entire organization for all of that great information you

 provided on crop insurance. It really was extremely helpful to

 us in crafting that document. So thank you.

 MS. PINKHAM: Well, thank you for all of your efforts

 on it. Your care and thoroughness really showed.

 BD. MEM. DIMITRI: Yeah. Thank you.

 CHAIR POWELL-PALM: All right. Thank you very much.

 Next up we have Sam Welsh, followed by Sara Neagu-

 Reed, and then Bob Quinn finishing us out for the day.

 Sam, the floor is yours. Good to see you.

 MR. WELSH: Hi Nate and everyone. I'm Sam Welsh.

 I'm founder of One Cert and One Cert International. Together,

 we certify about 1,300 operations. OEFFA's first purpose is to

 establish national standards for organic products. And the

 second is to assure consumers that organic products meet a

 consistent standard.

 OEFFA is unambiguous when it requires the OSP to

 include provisions that foster soil fertility, primarily

 through the management of the organic content of the soil.

 Based on this requirement, the USDA organic

 regulations contain many specific requirements for soil and

 organic crop production. Unfortunately, the USDA does

 tremendous damage to organic integrity when it arbitrarily says

 that this requirement for soil is only applicable to operations

 that grow crops and soil. Such a disregard for its own 
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 regulations damages organic integrity. 

 The regulations contain the word except 53 times.

 All exceptions must be in the regulations. Otherwise, the USDA

 fails to achieve the purposes of OEFFA. As the NOP works to

 implement the many good provisions in the SOE, they need to

 start with enforcing the law on the regulations as currently

 written.

 The success and effectiveness of the SOE will be

 determined by how it is implemented. We've already heard many

 comments about the additional record keeping requirements for

 small farmers.

 I want to contrast that with an example that reduces

 the paperwork burden for large exporters, importers, and their

 certifiers. The NOP import certificate would have been a great

 idea if implemented as a transaction certificate.

 Unfortunately, some certifiers successfully lobbied for a

 single import certificate to be valid for 12 to 18 months. It

 makes it virtually worthless for verification of the organic

 status of any single shipment. It's no better than what we

 currently have with annual certificates.

 It also creates a competitive advantage for

 certifiers who choose to issue an import certificate that will

 be valid for a year or more. Obviously, their expenses will be

 much lower than those certifiers, like who cert who verify each

 shipment and issue import certificates for each of those 
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 shipments.

 Interestingly, hydroponic producers who are exporting

 to the U.S. are major beneficiary of import certificates that

 are valid for a year or more, instead of a certificate for each

 shipment. Issuing a 12-month certificate to organic grain or

 soybean meal exporters also fails to improve organic

 verification and integrity.

 Maybe I spoke too fast. I think I'm done. What's

 that?

 CHAIR POWELL-PALM: You did great. Questions from

 the Board?

 All right, Sam. We really appreciate you joining us

 and for your time and expertise. Thank you. Next up is Sara

 Neagu-Reed, and please just correct me so I can learn how to

 say that right, and then Bob Quinn finishes up for the day.

 MS. NEAGU-REED: No worries. It's Neagu. I tend to

 tell people to think of Ragu, the tomato sauce and that's how

 you can pronounce it.

 CHAIR POWELL-PALM: You need to comment again just so

 I don't forget that and I get the chance to do it right next

 time.

 MS. NEAGU-REED: Okay. And I'm not sure if Ragu

 sauce is organic, so maybe that's not the best reference point.

 But anyways, my name is Sara Neagu-Reed, and I serve as the

 director of production and environmental policy at the 
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 International Fresh Produce Association.

 I want to thank you for the opportunity to provide

 these remarks as the National Organic Standards Board conducts

 it sunset review of organic materials. My colleague, Emily

 Moyer, shared oral comments on behalf of IFPA Tuesday, and

 provided a brief overview of our organization. In the interest

 of time, my oral comments will solely focus on plastic mulch

 and covers.

 IFPA supports the continued listing of plastic mulch

 and covers. The use of plastic mulch and covers are necessary

 to produce a wide variety of fresh organic produce because

 there's limited availability of alternative products providing

 the same production benefits. Plastic mulch and covers are

 used extensively to control weeds, conserve soil moisture,

 increase soil temperature, and improve crop yield and quality.

 They also are readily available at a relatively low

 cost. This past August, IFPA conducted a survey of its members

 on the use of plastic mulch and covers in organic production.

 I want to provide you a summary of key findings of that survey.

 First, 60 percent of large growers and 100 percent of

 small growers indicated that the primary reason they use

 plastic mulch in production is that it provides better weed

 control than other options. Growers also indicated that the

 product is more affordable, readily available, and easier to

 use than alternatives. 
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 One hundred percent of large growers and 71 percent

 of small growers indicated that there would be additional labor

 costs and required resources if they were forced to implement

 and maintain alternative mulching methods.

 Members noted that each of the alternatives were

 overwhelmingly deemed to be too expensive and difficult to

 implement. We recognize the subcommittees concerns related to

 the environmental impact of plastic mulch and covers.

 However, given the necessity of these products and

 the lack of non-synthetic alternatives, the removal of plastic

 mulch from the National List would have extremely damaging

 impacts on growers yields and economic viability.

 IFPA supports the continued use of objective science-

 based decision making as NOSB considered proposed changes to

 the full National List. We encourage the continued listing of

 plastic mulch and covers and other substances, as discussed in

 detail in our written comments.

 And if interested, happy to also pass along the

 survey that I referenced early and we conducted in August on

 plastic mulch and covers. Thanks for the opportunity to

 present oral comments.

 CHAIR POWELL-PALM: Thank you. We have a question

 for you from Jerry.

 BD. MEM. D'AMORE: Thank you for your comments and a

 solid yes to wanting to have the surveys if you would, please. 
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 And if I could summarize what you said and see if you agree

 with it, plastic mulch and covers do their job so well at such

 an effective price that they're indispensable. And that's part

 of the problem.

 For me, the problem is they do do everything very,

 very well. And the -- it doesn't negate the need to address it

 and stay with it. And I would venture to say, listening to

 you, that there is going to be some time in the future where we

 can do -- we can have an equitable solution to that issue.

 MS. NEAGU-REED: Yes, I agree.

 BD. MEM. D'AMORE: Thank you.

 CHAIR POWELL-PALM: Other questions for Sara. All

 right, Sara, we really appreciate you taking the time to speak

 with us today.

 MS. NEAGU-REED: Thank you.

 CHAIR POWELL-PALM: Last, but certainly not least, is

 going to be Bob Quinn. The floor is yours, sir. We've got you

 on mute still. We can hear you.

 MR. QUINN: Okay. Great. Well, hello, folks. My

 name is Bob Quinn. You know, in 1986, I started -- I first

 experimented with regenerative organic systems on our farm in

 Montana, and I was so impressed that I converted my entire farm

 to organic in 1988.

 I was an instant convert to regenerative organic

 agriculture and since then have promoted that system in 
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 Montana, the United States, and throughout the world, and I

 served on the NOSB, its very first Board, in fact. So I know

 what you guys are going through and I appreciate very much your

 effort and your diligence and all you do.

 Over the last 35 years, our organic market has gone

 from near zero to about six percent of the total national foods

 sold in America. At its current growth rate, we'll reach 100

 percent in the next 35 years. There are three areas that I

 would like you to help achieve this noble goal. They are

 marketing, country of origin labeling, and research.

 First, more marketing of organic foods will help

 shoppers understand the investment they are making in improving

 their own health by buying nutrient-dense food, grown without

 poisonous chemical pesticides and healthy soils. The

 contribution they are making to help farmers and their workers

 have a fair return for their labor, reduction they are making

 to contamination of the earth and the mediation of climate

 change by increasing carbon sequestration, reduction of

 greenhouse gases from the production of nitrate fertilizer.

 Let's help them understand the high cost of cheap

 food. If USDA can contribute $15 million in marketing to a

 tiny hemp industry, surely the organic market, worth over $60

 billion, is worthy of a similar amount or more. Even though

 six percent of the foods sold in America is organic, only about

 one percent of the farmers are currently organic. The 
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 shortfall is end supply is being made up by cheap imports which

 are stealing markets from American farmers.

 Shoppers could choose to support American farmers if

 they knew which products were from here. Why not give them an

 opportunity by promoting country of origin labeling. In the

 past few years of craziness when long supply chains failed to

 keep our store shelves stocked, I'm sure no one doubts the fact

 that a robust local and regional food supply is key to food

 security.

 And finally research. Many of my neighbors are going

 broke, buying expensive chemical inputs. They are told they

 are necessary for high yields, that they must produce and pay

 for these inputs. Many would like to change, but don't know

 where to start.

 Right now, 99 percent of the USDA research dollars

 are going into research chemical agriculture. A significant

 amount of that is focused on problems created by chemical

 agriculture itself, seeking chemical answers for chemical

 problems, like chemical-resistant weeds, chemical drifts,

 chemical contamination of our water and our soil, and even our

 rain. Why not divert some of that money to research organic

 systems.

 I wonder if the same percent of money the USDA spends

 for organic research would be allocated as we see in the food

 market. That would increase the current research allowance of 
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 one percent to nearly six percent of the total. Organic is the

 future, and I hope you can help me promote it in market, in

 country of origin and labeling, and in research. Thank you

 very much.

 CHAIR POWELL-PALM: That's some good timing. One

 second to spare. Wood's got a question for you.

 BD. MEM. TURNER: Bob, thanks for that. Thanks for

 your comments. You said something that really got my attention

 and I'm just curious. Have you ever had a conversation locally

 with your neighbors who are farming conventionally about the

 difference in your cost versus their costs? You mentioned

 they're going broke buying chemical inputs, and I just found

 that compelling because I feel like that's the opposite of

 sometimes what we hear.

 MR. QUINN: Yes, I have. And you know what, the

 biggest challenge is, and many would like to have a different

 way of farming and really jump in for organic, but they don't

 know where to start. Their back's up against a wall

 financially in most cases. I mean, they're in debt clear up to

 their eyebrows. They're afraid of making a mistake. And

 that's why if we had research to help them with weed

 management, for example, that challenges many -- a lot of

 organic farmers, at least in the west and the upper great

 plains, if we had help with other -- with rotations and things

 that were really worth -- and successful for them. If they had 
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 more help with counting extension, holding their hand, as it

 were, just to get them started, we would have a lot more

 interest and see a lot more jumping into organic, I believe.

 CHAIR POWELL-PALM: Other questions for Bob? Well,

 Bob, I heard the call is we need to promote organic. We need

 to do some better research. And we need to give our neighbors

 and our domestic farmers a fair shake at these markets.

 And then I think if we had one summary of the last

 two days, that might be just about as good as it gets. So

 really appreciate you hanging on all the way to the end with

 us. Thank you so much for the time to comment and take time

 out of your harvest. And thank you for your leadership and for

 making NOSB what we're all doing here today. So appreciate

 your service.

 MR. QUINN: Thanks, guys. Keep up the good work. I

 really appreciate what you all do.

 CHAIR POWELL-PALM: All right, everybody. That's a

 wrap for Fall 2023 public comments. We are going to be meeting

 next week in Rhode Island. Thank you everyone for all of the

 fantastic discussion, the great questions from the Board, and

 for sticking with us until the end.

 We'll reconvene on October 24th in Providence, Rhode

 Island. And until then, be well. Thanks, everybody.

 (Whereupon, at 6:01 p.m. the webinar was concluded.) 
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 at the heari

248

 CERTIFICATION

 This is to certify that the attached proceeding

 before the:

 NATIONAL ORGANIC STANDARDS BOARD 

 IN THE MATTER OF: FALL 2023 ORFAL COMMENT WEBINARS

 PLACE: Zoom for Government Webinar

 DATE: October 19, 2023

 was held according to the record, and that this is the

 original, complete, true and accurate transcript which has been 

 compared to the recording accomplished ng.

 __________________________

 Elaine M. LaRosee,

 Official Reporter 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 2 

October 19, 2023 

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October 19, 2023 

anyways (1) 191:1,7,8;193:9; 153:25;154:16;159:3; 75:24;86:11,14; 63:5,6;64:10;65:18;

 240:24 194:5;198:21;200:17, 161:20;163:9,15; 88:8;119:16;165:1; 97:5,19;101:3;131:7;

apart (1) 21;203:21;206:4; 183:15;184:25;193:9; 169:11;187:19,20; 195:14;209:10;

 61:4 207:13;213:12,15; 197:10,12;199:13; 201:24;221:20;224:9; 237:11 

APHIS (2) 216:14;220:19;221:3, 201:16;202:8;218:6; 241:1 August (2)

 87:16;90:21 8;223:23;227:16,21; 219:21 associations (2) 241:17;242:19 

apologies (3) 230:22;231:14;232:7, arounds (1) 173:1,2 Austin (12)

 190:23;226:14; 15;233:14,21;235:13; 66:13 Association's (1) 42:19;52:1;57:22;

 233:9 237:22;240:12; arrived (1) 81:9 60:8,13,14;62:12;

apologize (7) 243:13;244:3;247:10, 135:17 assuming (1) 63:19;66:7;67:23;

 22:9;37:12;51:18; 13,16 arriving (1) 103:20 68:12;70:4 

113:18;150:17; appreciated (3) 224:19 assumptions (1) authentic (1)

 154:23;226:15 80:16;105:11;167:4 ARSENAULT (39) 137:14 118:13 

app (1) appreciates (1) 4:3;8:22;9:5,8,10, assure (1) authorities (1)

 179:20 105:7 12,14,17,19,21,23,25; 238:15 192:11 

appear (1) appreciation (2) 10:2,6,8,10,13,15; assuring (1) authority (5)

 114:3 54:22;227:13 21:20,22;42:23;52:3; 43:10 113:22,24;114:23,

appears (4) approach (16) 57:25;70:7;95:1,6,11, astounded (1) 24;115:3 

33:12,13;177:2; 20:3,13;50:10;98:1; 19;152:1;158:9; 59:7 automatically (1)

 234:16 117:7;123:16;125:21; 179:1,4,7,10,13,21; attached (1) 38:4 

applause (1) 126:7,7,10;130:9; 180:3;216:5;233:5 205:21 autopilot (1)

 8:21 162:15;163:4;165:10; articulate (3) attacks (2) 119:22 

applicable (2) 192:17;234:5 117:4,14;215:16 8:15;11:12 availability (6)

 188:23;238:24 approaches (3) articulating (1) attempt (2) 29:23;84:22;

application (1) 126:13;127:1; 117:9 177:9;182:16 217:16,20,23;241:12 

214:17 193:17 Asia (2) attempted (1) available (19)

applied (5) appropriate (6) 59:5;67:5 228:12 4:16;35:8,10;61:6;

 120:5;125:15; 93:7;117:5,7;188:1; Asian (1) attend (2) 81:25;85:15;87:1;

 140:2;193:4;215:3 189:16;237:20 67:3 7:20;51:20 91:19;107:21,23;

applies (2) approval (4) aside (3) attended (1) 132:8;169:15;172:19,

 43:9;107:8 67:13;72:13;79:19; 14:2,3;149:2 7:16 23;208:4,8;221:25;

apply (7) 139:9 asinine (1) attendees (1) 241:16,24 

127:10;128:18; approve (2) 60:4 4:7 avenue (3)

 141:24;154:3;170:15; 44:8;72:24 aspect (4) attending (2) 228:10;231:5,7 

188:25;208:13 approved (10) 79:23;135:4,16; 7:17;171:6 averaged (1)

applying (1) 13:4;72:16;74:14; 147:7 attention (7) 83:10 

230:17 77:21;86:18;90:23; aspects (1) 147:21;150:6; averages (1)

Appreciate (128) 113:12;170:1;189:2; 165:25 167:9;215:4;225:25; 22:9 

16:16;18:8;21:5,16; 192:8 assert (1) 226:5;246:8 avoid (5)

 24:24;25:2,5;32:10; approximately (1) 12:16 attorney (1) 8:15;112:3;134:11,

 36:15;37:4,6;39:10, 148:9 asserts (1) 191:16 17;207:4 

17;42:2,4;54:10; arbitrarily (2) 14:8 attracting (1) avoidance (1)

 56:16;57:15;58:6; 86:24;238:23 assess (4) 12:18 161:9 

59:17,18;60:2,5; area (14) 98:12;104:4;114:8, attractive (2) avoided (1)

 65:22,25;69:25;70:3, 16:18,22;18:18; 12 16:20;141:16 237:8 

12,18;71:20,25;74:6, 23:10;38:8;52:25; assessment (3) attribute (2) awaiting (1)

 25;77:11,13,18;80:2, 58:23;85:9;103:24; 111:22;136:24; 202:3,8 222:5 

24;88:17;92:23;96:3; 144:21;187:17;210:2; 210:6 attributed (1) aware (9)

 102:20;108:5;112:20; 218:24;223:12 assessments (1) 229:22 36:4;54:4,7;91:8;

 116:16;119:4,7; areas (9) 205:5 attrition (1) 104:3;121:8;133:20;

 122:8;125:1;129:9, 55:17;76:7;99:11; assist (1) 100:6 134:17;167:14 

14;130:3;133:10,18; 103:16;215:4,15; 188:4 auction (1) awareness (1)

 134:20,23,23;135:20; 222:8;235:12;244:8 assistance (1) 229:21 166:7 

137:17;140:8,12; arena (1) 14:4 audience (1) away (12)

 142:16,21,25;146:17; 225:12 assistants (2) 7:24 20:4;29:8;38:4;

 147:5,12,21;149:23; arms (1) 13:25;14:9 audit (5) 46:5;82:8;103:17;

 150:4,9,10;151:4,6, 205:16 assisting (1) 13:6;63:15;64:12; 110:12;134:12;

 10;157:11,21;158:3; around (34) 165:13 97:8;101:2 187:12;192:19;

 159:2,8;160:12,13; 21:2;34:4;59:12; associated (1) auditable (1) 196:15;199:8 

166:8;167:9,22; 62:7;67:15;70:2;76:9, 202:10 101:3 awesome (9)

 171:11;172:20;174:6, 15;85:7;111:8;119:6; Associates (2) auditor (1) 16:14,15;21:8;

 8;176:15;178:22; 122:3,20;129:24; 43:1;51:19 97:8 44:20;52:11;56:14;

 182:14;185:20;187:2; 137:6,13;146:7,7; association (13) audits (11) 137:15;229:7;236:17 

Min-U-Script® Burke Court Reporting & Transcription (3) anyways - awesome 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 2 

October 19, 2023 

awful (2)

 46:23;64:8 

barely (1)

 138:12 

barley (2)

 148:10;150:24 

barrier (4)

 22;135:10,20;136:9,

 15,18;137:14;144:15;

 145:22;146:10,20;

 147:17;150:8;151:4;

 155:1,17;157:9,15,23;

 14:2;189:7 

beginning (6)

 11:9;63:20;123:2;

 173:1;196:18;233:8 

behalf (8)

 43:23;44:9;47:17;

 53:15;100:19;101:7;

 110:7;131:15;137:12;

 139:10;146:1;151:10;

 159:17,20,24;160:2,3;

B 

back (56) 100:13,21;188:18; 159:7;160:1,12; 125:6;187:18,20; 173:8,15,17;177:11;

 5:15;7:16;9:3; 191:6 162:12;163:22; 189:18;216:9;221:19; 178:7;191:4;194:25;

 15:25;16:23;17:19; barriers (6) 166:17;167:7,20; 233:14;241:5 195:16;212:23;

 20:6;22:13,22,24; 79:22;112:25; 184:19;185:18; Behar (11) 222:11;232:14;235:5;

 26:9;32:25;33:6; 189:15,20;196:4; 189:25;190:3,8,10,13, 75:8;80:5;86:10; 236:5;239:19;241:22;

 44:22;60:25;63:17, 223:2 18,20,24;191:1; 89:8;90:4,21;92:6; 247:6 

23;66:20,20;72:20; base (2) 193:8;194:3;197:9; 93:12;94:3,15;104:11 beware (1)

 74:13;80:8;87:10; 23:1,13 198:2,10,16;203:24; behavior (1) 134:18 

92:24;94:16,20;95:2, based (11) 204:1,7;205:23; 126:19 beyond (5)

 4;123:2;130:19; 8:8;69:14;130:22; 206:2;207:11,13,16, behaviors (1) 96:6;113:10;205:2;

 132:23;135:18;136:1, 173:11;177:18; 25;209:2,5,7;218:11; 205:18 206:14;226:23 

14,16;137:4;139:2; 185:16;192:5;214:21; 219:10,18;226:15,18; behind (5) bias (1)

 141:11;143:17; 231:25;238:20; 227:6,12;229:5,14; 35:12;135:3,3; 74:9 

148:22;154:14; 242:14 230:20;231:18,23; 157:19;164:4 big (25)

 156:15;159:3;162:19; baseline (2) 235:25;236:17; belief (2) 29:9;34:7;38:1,13;

 165:24;169:2;174:19; 117:2;118:12 237:22,25;238:6; 130:19;195:2 40:7;53:19;55:15;

 182:19;186:24; basic (3) 242:24;243:11;246:7 believer (1) 56:1;70:22,22;79:16;

 195:11;206:21,21; 20:4;61:5;105:18 beans (7) 212:3 90:12;121:9,15;

 210:19;231:7,17; basically (12) 31:4;38:21;40:20; believes (1) 128:6;145:18;154:1;

 235:3 37:13;40:17;50:20; 70:21;138:16;141:15; 224:14 155:16;175:5,11,17;

backbone (1) 59:22;64:22;90:24; 172:1 below (2) 178:8;185:23;208:3;

 177:3 91:11;92:18;116:6; bear (2) 78:20,20 230:11 

backed (1) 137:25;149:21; 100:4;126:21 beneath (1) bigger (6)

 202:7 156:21 bearing (1) 197:15 83:14;121:4,4;

background (2) basing (2) 26:25 beneficial (3) 166:25;236:20,25 

21:14;104:24 68:5;165:6 beat (1) 30:24;39:18;236:11 biggest (7)

back's (1) basis (1) 42:23 beneficiary (1) 32:24;38:7;49:17;

 246:18 53:23 beats (1) 240:3 149:1,2;215:12;

backstop (1) basket (1) 29:15 benefit (9) 246:16 

141:7 229:9 became (5) 36:1;59:13;73:23; Bill (18)

bad (11) Bayer (1) 91:8;175:4,19; 97:24;100:23;142:13; 25:13;37:9;42:16,

 61:10;117:24; 186:22 183:6,19 219:24;228:19; 20,23,25;43:13;45:3;

 120:9;137:6,23; BD (179) become (8) 237:15 48:3,6,24;49:24;50:3;

 140:10;143:17; 9:11,13,16,18,20, 30:2;54:7;82:11; benefits (11) 51:17;156:22;228:8,

 149:18;158:20; 22,24;10:1,5,7,9,12; 88:1;89:22;146:24; 54:5;121:14;161:9, 8;230:23 

204:11;217:21 14:21;15:15,17;16:2, 207:4;230:6 13;165:18,19;166:2; billboards (1)

bag (1) 6,8,13;18:7,10;23:20; becomes (7) 196:10;201:25;237:9; 20:3 

15:23 24:16,23;28:6,21; 30:5;33:10;83:17; 241:13 billion (5)

bags (2) 29:19;30:16,18; 136:2;155:22;207:9; Bermuda (1) 27:12,13,14;178:1;

 190:9,11 31:13;32:4,10,13; 208:8 128:4 244:23 

Baja (5) 33:15,18;35:3,5,25; becoming (2) berry (2) billions (1)

 82:6;83:6,7,8,9 36:12;39:13;40:11, 26:25;52:17 81:14;82:13 34:10 

bajillion (1) 14;41:5,7;42:1;45:3; bed (1) best (24) bills (4)

 68:14 46:14;47:24;48:6,22; 196:14 19:17,20;46:19; 43:15;61:23;62:15;

balance (2) 50:1,3;54:25;56:2,8, Beddard (12) 59:22;62:23;120:14; 64:13 

166:4;237:11 12,15,19;63:2;65:24; 187:7;191:13; 122:12;123:12; biobased (6)

balancing (1) 67:24;74:5,25;77:20, 194:8,10,11;197:14; 127:18;128:21,22; 44:14,14;84:6;

 130:9 24;78:23;79:2,11,21; 198:9,12;199:3; 130:11;184:6,11; 107:1;221:22,24 

bananas (1) 82:21,23;83:13,25; 200:2,19,23 195:19;211:23,25; biodegradable (4)

 136:22 84:14,18,21;85:18,22, bedrock (1) 212:4;214:21;227:13; 44:8;84:6;104:2;

bankruptcies (1) 24;86:1,2;88:16; 223:2 231:4,12,15;240:23 107:1 

130:16 89:24;92:22;93:21; beds (1) bet (3) biofumigant (1)

banks (2) 94:11;98:25;100:1; 196:13 151:23;178:23; 47:10 

127:6,7 108:4;109:5,10; beef (2) 209:3 biological (4)

banned (1) 111:5;112:20;113:2; 71:5,6 bets (1) 13:12;35:17;47:22;

 189:10 114:20;115:5;123:1; beep (2) 17:17 161:6 

bar (2) 124:8,25;131:24; 7:2,7 better (36) biologically (1)

 4:11;6:16 132:3;133:10;134:19, begin (2) 24:13;27:19,19; 140:4 

Min-U-Script® Burke Court Reporting & Transcription (4) awful - biologically 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 2 

October 19, 2023 

biomass (1) 106:9,12,13,16,19; Bowl (4) broadening (1) 87:15;90:3,12;96:8;

 47:2 107:18;110:15;111:6; 20:7;54:3;55:6; 235:4 99:18;102:18;136:25;

BIPOC (1) 125:5;126:6;129:8; 56:1 broader (1) 177:2;213:25;214:11,

 235:18 130:1;131:4;139:2; box (7) 96:5 13,19,23,24;226:1;

birthplace (1) 140:8;144:13;147:5; 6:4;64:23;65:14; broadly (1) 237:3;239:13 

167:10 162:8;163:24;164:21; 66:5;176:1,2;177:8 107:9 burdened (1)

bisphenols (1) 166:15;171:12,22; boxes (1) broke (3) 225:21 

104:8 172:6;176:15;178:22; 165:24 48:12;245:11; burdensome (1)

bit (41) 182:15;192:3,4,8,19; boy (1) 246:12 47:19 

30:1;31:1,19;33:11, 193:23;198:20; 206:12 brokers (3) buried (1)

 19;36:21,24;39:2; 199:16;202:20; BPA (1) 61:19;133:21;210:2 208:1 

48:25;57:1;60:21; 203:22;215:21; 113:16 brough (1) burning (1)

 66:6;88:20;89:14; 216:12;218:12; BPI (6) 126:23 65:20 

90:4,19;95:22;99:9; 220:17;225:3,4,6; 161:1,22;162:1,7, brought (3) burst (1)

 108:10;113:4;124:15; 227:8,9;233:18,19; 19;163:10 159:2;198:23; 134:11 

125:12,15;134:3; 234:2,6,10,25;240:11; BPI's (3) 217:14 bus (1)

 142:7;143:12;144:25; 241:3;244:2;247:20 162:15,23;163:4 Bruch (43) 224:19 

148:8;150:18;152:10; Board's (5) brand (2) 9:10,11;16:13;18:7; bushel (1)

 158:2;162:15;181:6; 8:9;105:10;215:17; 151:14;167:11 23:19,20;24:16,23; 38:3 

201:15;208:17; 233:21;235:13 Brazil (2) 30:18;31:13;32:4,10; bushels (8)

 209:11,11,18;216:25; boatload (1) 26:13;33:9 39:13;40:11;56:19; 26:13;33:5;37:24,

 217:4;218:4 30:12 breadth (1) 65:24;88:16;89:24; 25;38:19,20,21;69:9 

bite (1) Bob (9) 181:4 111:5;112:20;124:8, business (29)

 126:12 221:15;233:9; break (19) 25;133:10;134:19; 49:6,6;50:15;55:20;

bits (1) 238:9;240:15;243:17, 26:18;80:6,8;86:7, 144:15;150:8;151:4; 71:6;76:6;110:14;

 180:12 20;246:7;247:4,5 8;89:19;94:13,14,17, 159:7;160:1,12; 134:7,12,13,24;135:9,

bitter (1) bodies (2) 21;160:21,22;164:15, 166:17;206:2;207:11; 22;155:2;165:23;

 91:20 52:24;131:4 16;167:21;169:3,3,5; 218:10,11;219:10; 174:7;176:4;195:5;

BJ (5) body (1) 189:15 229:5,14;230:20; 198:24;201:14,15,18;

 125:3;129:15; 134:16 breaker (1) 231:18;235:25; 202:16;205:3;207:14;

 137:19;140:8,9 bogged (1) 93:25 236:17;237:22 208:10;209:1;217:10;

black (3) 211:5 breaking (2) Bryce (12) 229:22 

64:23;66:5;76:2 boiling (2) 103:13;231:23 21:17;25:12,15; businesses (4)

blanket (2) 106:5,6 breathing (1) 28:4,6;30:18;32:10, 43:6;165:14;

 192:4;214:11 bomber (1) 202:13 13;35:3,5;36:12,14 170:21;209:25 

blasts (1) 227:13 breed (1) bubbles (1) busy (6)

 126:15 book (1) 92:17 134:11 23:21;28:3;129:10;

bleeding (1) 68:19 breeding (1) buckets (2) 142:21;159:8;174:9 

227:14 boots (1) 108:13 154:19;196:20 butcher (1)

blended (2) 33:22 Brian (5) buckwheat (2) 233:8 

130:4;153:13 border (2) 9:12,14;113:1,20; 148:10;150:24 button (4)

blending (2) 132:20;134:15 184:18 budget (1) 4:17,25;6:19;

 153:15;156:7 Both (24) bridge (1) 18:22 179:12 

blew (1) 6:15;13:15,18;17:3; 142:6 Build (3) buy (10)

 149:25 33:9;36:23;84:13,13; brief (3) 177:15;187:3; 18:15;39:8;64:20;

block (2) 87:13;99:13;127:7; 19:15;148:3;241:6 208:22 130:6;135:24;157:3,

 50:11;201:10 130:5;131:14;134:24; briefly (2) building (6) 4;173:14;195:17;

blocks (1) 135:6;152:12;161:5; 117:1;169:22 46:20;117:16; 212:6 

149:17 162:25;181:3;182:9; bring (9) 166:9;169:15;178:8; buyer (1)

blueberries (1) 188:6;204:11;209:11; 26:9;126:20;150:5; 191:25 134:17 

175:7 220:19 217:25,25;218:20; built (5) buyers (12)

bluntly (1) bother (1) 219:1;227:18;232:24 36:25;127:6; 18:14;30:7,7;64:19,

 150:21 17:24 bringing (8) 197:12,16;212:23 19,21,22;87:23;

Board (92) bothered (1) 20:6;34:23;57:10; bulk (2) 130:5;131:14;134:16,

 4:5,13;8:8,12;9:4; 148:18 102:11;142:20;147:5, 117:18;215:5 17 

10:23;11:17,24;25:3; bottle (1) 20;151:3 bullet (1) buying (9)

 27:9,16;28:17;36:3,6; 181:24 brings (1) 126:12 19:4;91:11;136:6;

 39:11;40:12,20;45:1; bottom (2) 229:19 bump (1) 138:15;143:25;

 52:12;59:20;70:2,11; 50:21;193:15 broad (6) 40:4 195:16;244:13;

 71:16,24;80:14,17,24; bought (2) 27:23;50:7;105:16, bunch (6) 245:11;246:12 

82:16;83:10;84:8,11; 31:7;172:2 24;110:1;237:9 70:16,17;71:14; Bye (2)

 88:19;95:2;98:23; bounce (2) broad-based (1) 125:7;155:12;193:8 104:19;168:25 

103:2;104:14;105:7; 48:9;68:25 169:12 burden (17) byproduct (1) 

Min-U-Script® Burke Court Reporting & Transcription (5) biomass - byproduct 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 2 

October 19, 2023 

76:9 

Byron (10)

 21:18;25:12;37:8,

 10;39:13;40:11,14;

 41:5,17;42:3 

187:4 

can (218)

 4:9,11,18,19,23,23;

 5:1,4,13,25;6:6,12,19,

 23;7:6;11:21;14:12;

 19:10;21:21,22;

 22:22;24:11;27:6;

 28:14;29:13,13;30:3;

 108:16 

candor (1)

 75:1 

capacity (2)

 84:23;215:14 

capital (1)

 159:4 

CAPOs (1)

 145:24;146:15;

 148:6;174:6 

cast (1)

 163:6 

catalog (1)

 43:22 

catastrophe (1)

 128:4 

certain (5)

 35:22,23;45:9;

 105:17;132:12 

certainly (10)

 75:15;78:12;96:12;

 107:23;108:14;109:1,

 2;162:18;208:25;

 243:16 

C 

CACS (8) 31:1,9;32:5;33:6,16; 121:23 catastrophic (2) certificate (10)

 36:18;88:4,22; 34:12;37:1;40:14; captioning (1) 81:20;82:13 33:24;188:25;

 90:18;92:2;100:7; 41:20;42:21,22; 4:16 catch (1) 214:3,5;239:14,15,17,

 132:1;142:17 44:23;45:24;46:11; capture (1) 99:17 22;240:4,5 

CAFO (2) 48:14,23,25;50:9; 6:24 categories (3) certificates (5)

 177:5,21 51:7,21;52:7,8;53:24; captured (1) 51:4;167:3;199:1 66:4;208:6;239:20,

calculate (1) 54:2;58:2,3;63:6,6; 230:23 category (4) 25;240:3 

61:17 64:1,9,17,24;66:1,4,6, carbon (8) 105:16,25;106:4; certification (26)

calculating (1) 11;68:9,23;70:1,9,10; 49:15,15,16;123:7, 110:1 13:11;25:16;78:6;

 97:15 71:2,9,16;72:9;73:23; 23;161:14;233:24; cattle (2) 88:9;92:4;95:24,25;

calculation (1) 74:17;78:1,1;81:2; 244:18 80:15;81:1 96:20,23;100:14;

 41:19 83:1,18;85:3;89:15, carbon-base (1) caused (1) 158:15,17;159:16;

Caldwell (7) 21;90:9;92:2;93:1,8, 132:4 138:9 189:2;207:6;213:1,4,

 9:12,13;113:2; 13;94:1,25;95:1,7; carcinogen (1) causes (2) 21;222:25;223:5,9;

 114:20;115:5;184:19; 97:7,12,19;98:3; 114:15 159:21;230:2 226:8;233:12,15;

 185:18 99:12;101:2,8,21,21; carcinogenic (1) causing (1) 234:24;235:1 

California (3) 103:17;110:11; 108:22 92:25 certifications (1)

 9:16;82:6;83:6 111:19;114:1;117:4, carcinogens (1) caution (3) 58:17 

call (32) 12;119:22;121:5; 105:21 121:8;228:10,21 certified (56)

 5:13;6:7;7:12;9:4; 122:12;123:14;124:2; care (6) caveat (1) 12:20;22:2;30:2;

 10:20,22;11:20,25; 126:14,20;127:3,4,4, 5:14;9:1;57:20; 93:10 39:1;40:6,10;41:2;

 21:6;30:6;35:9;36:2; 5,6,6,7,15;129:1,19, 60:6;104:20;238:5 caypols (2) 60:25;61:2;69:4,16;

 42:12;59:19;62:24; 20;134:15;136:15,18; career (3) 175:11,18 70:14;76:12;86:11;

 63:2;64:15;68:15,16; 137:11,21,22,23; 48:11;152:11; CDP (1) 96:8,19,20;100:6,13,

 73:7,21;75:18;77:3; 141:8,14;142:19; 216:22 153:20 24;101:10;132:4;

 124:16;129:11,16; 143:3,4,19;144:24,25; careful (2) CEA (1) 138:23;148:9,21;

 144:17;166:1;178:17; 145:2,19,20;146:3,12, 46:4;103:19 190:1 159:15;164:24;

 188:20;234:25;247:5 15;147:2;149:7,15, cares (1) celebrate (2) 175:20;177:13,14;

called (8) 18;151:8;152:4,6; 55:4 80:22;167:7 178:3,3,5;180:18,20;

 4:22;6:11;11:2; 154:15,18;155:2; cargo (3) cell (2) 194:16;195:21;202:6;

 117:20;120:10,21; 156:9;162:14;164:7, 153:22;157:3,4 137:24;179:16 203:13,14;210:1,6,7,

 174:25;178:12 7;167:3;172:20; caring (1) center (12) 17,20,23,23,23;

calling (18) 173:8;176:1,1,12; 52:21 4:10;13:1;103:3,10; 213:22;216:16,18;

 25:7;36:15;37:5; 179:21;181:14; Carolyn (5) 166:6;167:18,18; 217:8,9;223:15;

 39:10;42:3,10;52:10, 182:21,22;184:11; 9:17,19;41:6;95:17; 191:17,17;197:10; 224:11;225:24 

14;54:10;71:21,25; 185:16;186:1;189:1; 237:24 232:11;237:7 certifier (11)

 74:13;140:12;144:12; 190:14,21;199:9; carried (2) centered (1) 20:24;33:8;63:9;

 160:14;179:20; 200:8,15;202:9,12; 118:8;189:4 130:21 93:1,14;117:4;156:3,

 182:15;185:21 206:9;207:3,23; carrots (1) centering (1) 19,19;158:1;223:12 

calls (7) 208:4,5,13,21,22; 101:16 225:2 certifiers (51)

 6:21;73:3;108:15; 209:24;212:22;214:4, carrying (1) centerpiece (1) 12:21,24;13:4;

 225:13;227:8,9; 7,16;218:3;219:13; 71:10 125:11 20:21;43:21;59:23;

 232:22 224:2;225:4;227:17, cars (1) Central (8) 61:14;63:5,7,14;71:1;

came (13) 19;229:17;231:19; 42:11 59:5;67:3,5;83:7; 86:19;90:3,9,12;93:7;

 14:18;15:25;17:14; 232:8,16,18,24; Cascadian (3) 140:20;142:9;204:15; 94:9;101:11;111:11;

 34:17;41:3;54:25; 235:11,19;236:20; 167:8,11,15 211:9 132:8;153:5;155:25;

 72:11,20;141:25; 237:17,18,19;240:14, Cascading (1) centric (1) 157:7;170:8;173:2;

 154:5;156:15;200:3; 18;243:9,9,18; 165:24 154:2 180:17;193:2;195:6;

 219:4 244:21;246:2 case (7) CEO (1) 205:2;206:14;209:15;

camera (4) Canada (5) 50:23;69:2;70:19; 120:20 210:14;211:5;214:24;

 6:14,15,16;150:2 87:24;91:9;92:7,12; 82:1;123:15;125:18; cereal (1) 225:23;226:4;232:2,

campaign (1) 108:9 167:14 165:24 3,5;234:14,18,19,23;

 172:13 Canada's (1) cases (2) cert (5) 235:10,11;236:21;

campaigns (3) 69:7 175:6;246:19 153:8;156:4; 237:3;239:14,16,22,

 118:13;120:19; Canadian (1) cash (4) 238:12,12;239:24 24 

Min-U-Script® Burke Court Reporting & Transcription (6) Byron - certifiers 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 2 

October 19, 2023 

certifies (1) 154:23;157:14;158:2, 13:13;133:17; chicken (2) 57:17;106:11 

127:12 3,7,10;159:1;160:13, 161:17;242:14 55:21;175:18 classes (3)

certify (14) 17;162:10;163:21; changing (3) chickens (1) 106:11;109:17;

 63:9;111:12; 164:11,14;166:14; 5:6;52:20;187:25 175:11 193:12 

112:17;121:23,24; 167:6,19;168:17; Chapman (6) children (3) classifications (1)

 159:17;169:16;189:9; 169:1,6;171:11,15,19; 171:17;174:12; 182:24;183:6,13 192:5 

195:7;213:23;233:12; 174:4,11;176:14,18; 176:18,21,22;178:23 chime (1) classified (1)

 234:15,20;238:13 178:21,24;179:2,5,9, character (1) 152:14 124:12 

certifying (5) 11,16,19,24;182:14, 11:13 China (2) classy (1)

 159:18,20;170:21; 19,22;184:16;185:20; charge (1) 154:1,4 11:15 

189:5,8 186:3;187:1,6,10; 32:22 Chinese (3) clause (1)

chain (42) 189:23;190:25;191:9, charged (1) 145:14;159:15,16 217:20 

11:1;12:17;15:10; 12;193:6;194:5,8; 182:11 Chinese- (1) clean (5)

 35:9;59:6;60:17; 197:4;198:18;199:10, Charlotte (9) 134:2 108:21,25;136:1,2;

 61:19;63:5,8,10,14, 12;200:17,20,24; 160:20,21;164:14, chip (1) 155:21 

15;64:1,10;65:18; 201:2,5;203:21; 15,18,20;166:15,17; 110:11 clear (9)

 67:19;111:11;117:23; 206:1;207:12;209:4; 167:22 choice (6) 58:3;60:14;71:22;

 118:1;131:7;134:4, 211:15,17;213:12,17; charts (1) 44:9;47:17;118:17; 140:9;155:12;164:7;

 14;135:13;137:12; 215:20;216:3;218:8; 185:9 195:19,20;200:1 180:11;214:12;

 138:25;139:4;152:12; 219:17;220:19,24; chat (7) choices (4) 246:19 

155:3;156:16,20,21; 221:5;223:20;224:4; 4:10,11,14;5:13; 43:24;122:24; clearly (7)

 157:25;163:13;168:7, 226:13,16;227:11; 6:4,5;8:15 128:20;213:7 11:16;97:5;113:25;

 13;201:11;209:10; 229:4;231:22;232:20; chats (1) choose (3) 117:10,14;202:20;

 210:4,8,15,22;235:6 233:2,6;235:23; 4:12 222:22;239:22; 222:13 

chains (2) 237:24;238:7;240:10, chatting (1) 245:3 clever (1)

 98:17;245:6 19;242:22;243:12,16; 79:24 chunks (1) 81:1 

Chair (241) 246:5;247:4,17 cheap (3) 51:14 click (1)

 8:12;9:7,9;10:18; Chaired (3) 157:5;244:20;245:1 Churchtown (1) 5:3 

14:15,18;16:10;18:9; 216:11;217:14; cheaper (6) 122:19 clicking (2)

 19:14;20:18;21:4,13; 218:20 31:11;138:16; CIF (1) 4:17;6:2 

23:15;25:4,10;28:1; Chairman (1) 143:19;144:25; 136:6 client (1)

 30:17;32:12;35:4; 169:9 145:20;149:8 circling (1) 214:15 

36:14;37:4,8;39:10; challenge (9) cheaply (1) 130:19 clients (5)

 40:12;41:6;42:2,5,10, 100:12;112:16; 176:3 circular (3) 39:6;201:20;214:9,

 15,22;44:12,25;48:1, 123:4,17;149:2; check (11) 76:5;78:13;161:10 20;215:10 

20;49:24;51:16,24; 163:2;209:8;211:3; 65:15;177:7;201:1; circumstances (3) climactic (1)

 52:5,8;54:10,15,24; 246:16 217:7;218:7,15; 93:6;117:9;195:11 161:8 

56:17;57:9,20;58:3,5; challenged (2) 219:12,22,23;220:7, circumvents (1) climate (23)

 59:18;60:2,5,8;62:11; 147:2;220:12 25 111:21 49:17;116:8;

 65:23;67:21;68:8; challenges (6) checking (2) cited (1) 119:17,18,22;120:10;

 69:25;70:6,8,10; 45:8;66:1;146:24; 52:4;59:10 68:4 121:10;124:3,5;

 71:20;74:3;75:2,6; 172:8;230:17;246:22 checkoff (11) claim (5) 161:3,13,20;168:11;

 77:11,16;79:1;80:2,4; challenging (2) 228:4,11,19,24; 73:4,6,17,18; 175:23,25;176:5,7;

 82:18;84:20;85:17; 72:7;123:9 229:13,14,19,20,22, 140:25 212:18;213:4;223:15;

 86:4,11;88:14,19; champion (2) 25;230:14 claims (2) 233:22;234:2;244:17 

89:25;90:15,17;92:1, 131:6;212:10 checkoffs (2) 73:2,13 climate-friendly (1)

 21;94:12,16,20;95:8, champions (1) 227:24;230:5 clamp (1) 212:18 

13,20;98:8,22;99:25; 212:7 check's (1) 71:16 clock (1)

 102:4,9;104:13,20; chance (5) 201:2 clarifier (2) 44:2 

107:14,17,24;108:3; 48:4;51:21;145:2; Cheerios (1) 229:7,8 close (7)

 109:9;111:4,7;113:1; 162:8;240:20 176:1 clarifies (1) 8:19;49:9;61:13;

 115:6,8,11;116:15,16, chances (1) chemical (22) 203:10 96:1;167:8;181:15;

 19;118:24;119:9; 83:17 120:20;121:2,5,9; clarify (5) 221:16 

121:21;122:7,10,25; change (14) 123:18;124:20,24; 44:5;48:23,25;90:2; closed (3)

 124:7;125:2;127:17, 13:18;25:8;33:23; 139:5;163:3,7,13; 168:16 4:16;68:7;177:5 

21;129:3,14,20; 39:1;49:11;114:1; 166:3;186:13;244:14; clarifying (1) closely (2)

 131:21;133:9;134:21; 116:9;161:4,20; 245:11,16,17,18,18, 94:11 60:21;103:3 

137:17,22;139:22; 177:8;191:5;200:14; 19,20;246:12 clarity (4) closer (1)

 140:7,15;142:16,23; 244:18;245:13 chemical-resistant (1) 78:4;203:4;222:12; 52:4 

143:4;144:12;145:21; changed (3) 245:19 226:4 closes (2)

 146:19;147:14,18,23; 101:5;148:23; chemicals (3) Clark (1) 33:8;126:3 

149:23;150:4;151:6, 196:24 163:20;181:4; 8:22 closing (1)

 18,21,24;152:2,6; changes (4) 185:16 class (2) 174:1 

Min-U-Script® Burke Court Reporting & Transcription (7) certifies - closing 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 2 

October 19, 2023 

clunky (1) 10;199:7;210:13; 17:12;217:15,19,22 46:9;50:12;53:18; compost (21)

 100:4 218:18;219:11; commercially (4) 72:15,24;74:21; 78:1;124:15,23;

co- (1) 227:24 87:1;91:19;107:21, 79:15;82:3;118:16; 161:2,2,3,5,6,12,17,

 217:13 comment (40) 23 143:16;186:13; 18,18,20,22;162:2,3,

Coalition (6) 4:5,13;6:23;7:15; commercials (1) 217:22 14;163:1,24;164:6;

 12:8;75:12;86:14; 11:6,10,11;12:23; 54:2 company (17) 174:22 

103:4;105:5;107:12 16:19;44:5;59:19; commingled (1) 46:16;72:12,16; compostable (2)

Cocoa (2) 82:16;89:1;95:7;96:4; 112:24 74:14;111:17;112:2, 104:2;162:20 

190:9;197:19 100:8;105:8;107:25; commission (3) 8;129:23;135:7,14, compostables (1)

code (1) 130:3;146:22;147:13; 64:14;170:15;225:3 24;164:23;165:13; 162:24 

56:4 165:3;166:20;167:14; Commission's (1) 216:18,19,23;217:10 composts (1)

codes (6) 172:18;184:17; 227:19 comparable (2) 104:2 

16:16;61:21,21,22, 204:25;206:6;213:23; commit (3) 158:22;180:21 compounds (4)

 25;62:5 217:7;219:2;223:18, 36:23;46:9;207:22 compare (1) 51:11;163:3,7,13 

codifies (1) 22;231:25;232:18; commitment (4) 196:18 comprehensible (1)

 204:18 233:14;234:9,10; 25:20;31:25;80:14; compared (3) 11:18 

co-director (2) 240:19;247:11 82:16 46:21;47:13;145:11 comprehensive (1)

 119:13;176:22 commentary (1) committed (4) compatibility (1) 234:8 

coffee (2) 92:22 194:21;207:21; 170:6 compromise (1)

 102:9;136:21 commenter (2) 218:4;224:24 compatible (1) 199:17 

co-founded (1) 6:11,25 Committee (7) 53:16 concept (6)

 217:2 commenters (7) 8:9;81:9;131:11; compelling (1) 13:17;109:20;

cognizant (1) 4:22;7:21;50:4; 132:22;137:4;216:11; 246:13 149:11;204:3;205:14;

 66:14 109:11;166:21;232:1; 218:20 compete (5) 228:23 

collaborating (1) 233:19 committing (2) 30:25;45:24; concern (15)

 232:6 commenting (2) 68:24;155:6 142:10;149:6;199:9 22:16;23:2;72:25;

colleague (2) 158:4;213:24 commodities (4) competing (3) 73:14;88:11;92:13,

 103:7;241:4 comments (108) 45:9;194:20; 146:23;149:5; 24;96:5;108:14;

collect (4) 12:10,16;13:9; 230:11,15 197:23 143:10;144:9,13;

 59:23;61:14;64:17; 16:16;18:10;21:5; commodity (4) competition (4) 159:2;162:14;230:2 

173:16 23:16;24:24;28:2; 66:10;98:16; 61:11;138:15; concerned (11)

collecting (3) 30:21;39:17;43:1,8, 230:16;231:2 199:2,4 15:3,5;45:19;71:11;

 138:11;214:19; 20,24;44:20;50:2,6, common (7) competitive (2) 87:25;90:4;92:8;

 237:20 23;60:11;74:4,7; 26:11;29:12;74:23; 138:16;239:21 96:16;108:12;225:19;

collection (1) 77:12;79:3;80:16; 80:20;139:10;198:11; competitively (1) 230:6 

12:23 81:1,3,10;82:19; 236:8 195:12 concerning (2)

collective (3) 86:13;88:10,17,18; commonality (1) competitiveness (1) 31:13;162:19 

25:25;26:16;161:3 95:14;96:9,12;100:2; 121:5 147:10 concerns (11)

collectively (2) 102:20;103:4;104:13; communicate (3) compiled (1) 11:19;32:15;93:11,

 12:15;137:5 106:10;108:5;111:7, 43:18;134:16; 132:10 24,24;108:24;152:16;

Colorado (2) 10;117:6;118:24; 222:13 completed (3) 219:21,24;220:4;

 105:6;119:13 122:8;123:1;131:21, communicated (1) 8:6;119:25;182:9 242:7 

combat (2) 24;136:21;137:18; 132:23 completely (5) concert (1)

 161:3;175:13 140:8;150:9;157:18; communicating (1) 46:8;168:14; 89:8 

combine (2) 159:9;160:14;161:1; 211:5 183:17,24;196:24 concluded (1)

 137:24;140:12 164:12;165:1;166:15; communication (8) complex (3) 247:24 

combined (1) 168:18;169:23; 131:15;134:9; 47:6;98:17;113:21 conditions (1)

 217:3 170:18;171:12,21; 137:5,13;208:13,20; complexes (1) 224:21 

comfort (2) 172:11;173:12; 211:12,19 49:19 conduct (1)

 93:10;126:14 176:14;191:1,7,25; communications (2) compliance (4) 163:6 

comfortably (1) 193:7;194:6;197:4; 158:5;201:25 44:4;98:4;214:16, conducted (3)

 127:7 201:19;203:22;206:6; communities (4) 22 193:23;241:17;

coming (39) 207:14;209:8;215:17, 103:20;161:9; compliant (2) 242:19 

25:23;26:7,10;27:3; 21;218:9,18;219:4; 169:16;194:25 214:25;215:9 conducting (3)

 29:11,14,24;30:8,12; 221:3,20;223:21; community (22) complicated (4) 205:5;234:1,7 

32:14;33:1,7;61:7; 224:3;226:10;227:16; 12:7,15;13:17; 41:10;146:16; conducts (2)

 62:6;64:25;66:22; 229:15;230:24; 20:10;55:15;80:18, 147:4;177:17 10:16;241:3 

67:2;68:5;69:4;73:17; 231:23;232:12;233:3, 20;89:1;90:5;105:16, comply (3) conference (1)

 80:24;127:10;129:9, 17;235:9,22;236:2; 20,25;125:6;169:12; 192:6,22;201:13 122:19 

23;131:8;134:8; 239:10;241:5,7; 186:11;199:25; complying (1) confidential (2)

 143:13;145:11; 242:17,21,24;246:8; 218:13;228:14,22,25; 51:8 110:14,16 

147:12;153:12; 247:18 235:21;236:7 components (2) confinement (1)

 175:22;177:22;186:4, commercial (4) companies (12) 113:17;135:2 177:13 

Min-U-Script® Burke Court Reporting & Transcription (8) clunky - confinement 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 2 

October 19, 2023 

confirm (1) 102:16,18;168:6 47:8 cooker (1) 26:18 

6:6 consulted (1) contract (3) 228:2 costly (2)

confused (1) 161:24 18:20;156:4;170:9 cool (3) 46:14;235:6 

219:9 consumer (23) contracts (1) 10:24;56:24;168:18 costs (6)

confusion (1) 19:7,13,17;45:12, 138:13 co-op (2) 43:22;143:21;

 76:15 16,17;48:15;52:10; contrast (1) 101:16;175:24 144:5;173:23;242:3;

congratulations (1) 53:10,21;54:17;55:3; 239:12 co-oping (1) 246:11 

207:14 56:22;114:18;118:17; contrasts (1) 175:24 cost-share (1)

Congress (3) 151:14;152:17;165:6; 109:13 coordinate (5) 27:17 

171:6;175:15;191:6 166:10;184:13; contribute (1) 43:22;87:9;89:16, count (1)

Congressmembers (1) 195:16;196:1;219:6 244:21 18,22 31:9 

119:21 consumers (23) contributes (1) coordinated (1) countdown (1)

congressperson (1) 19:10,18;53:19,21; 173:4 170:23 44:2 

191:4 54:12;56:25;57:12; contribution (1) coordinates (6) counties (1)

connect (3) 61:12;98:19;114:14; 244:15 12:19;59:23;87:9; 37:20 

6:8;210:15;211:6 115:12;118:4;165:8, contributions (1) 88:23;117:3,10 counting (1)

connected (1) 17,19;166:23;167:1; 39:17 cop (1) 247:1 

168:1 169:20;193:3;219:7; control (13) 157:19 countries (9)

connection (1) 222:11,13;238:15 4:18;26:8;43:24; copper (1) 26:11;33:3;34:19,

 167:24 consumer's (1) 50:13;81:12;85:23; 114:6 23;65:11;144:7;

connects (2) 196:1 107:4;116:8;118:16; coppers (1) 153:18;180:20;

 202:8;205:16 consuming (1) 121:17;182:4;241:14, 106:12 197:23 

consensus (1) 76:17 23 copy (1) country (25)

 118:12 consumption (1) controlled (2) 170:19 30:8;32:25;33:5;

consequential (1) 59:11 188:6;190:1 core (1) 34:20;54:8;59:8;

 234:23 contacted (1) controversial (2) 209:1 63:17;79:15;143:22;

conserve (1) 91:9 54:3;220:6 corn (36) 144:7;170:21;171:2;

 241:14 contain (2) convening (1) 21:25;22:2,5,15,22; 180:21;181:7,13,15,

consider (8) 238:21;239:2 222:18 24:8;28:25;29:8; 16,22;194:15;195:22;

 12:22;39:19,20; container (4) conventional (58) 35:16;37:23;38:6,18; 199:21;228:15;

 61:20;64:4;91:2; 189:21;222:24; 14:13;18:14;19:1,3; 40:18,18,19;41:2; 244:10;245:5;246:3 

92:15;189:14 223:17;235:3 22:25;24:14;29:15; 59:9;60:19,19;64:25; county (8)

considerably (2) containers (3) 31:18;35:13,16,20; 67:2,4,7,9;91:21; 22:8;24:14;37:19,

 22:11;135:18 133:1;223:10;235:2 36:2,9,11;37:23; 129:6;130:8;145:25; 22;141:3;148:19,22;

consideration (3) contaminated (2) 38:21;39:20,23; 146:1,2,7,14;148:10; 173:11 

130:10;163:17; 65:6;112:24 40:18;45:15;46:21, 150:19;158:13;172:1 couple (8)

 166:10 contamination (7) 23;50:14;67:4,8; corner (1) 5:22;26:14;34:18;

considered (8) 114:25;115:4; 74:18;83:18,21;84:4, 4:25 77:25;124:15;131:25;

 72:8,17;88:4;91:13; 116:1;170:24;171:3; 5,5,7,11,12;85:21,23; corners (1) 180:12;226:21 

92:20;108:8;176:7; 244:17;245:20 111:16;112:15; 61:10 course (4)

 242:14 content (3) 114:10;120:1;121:15; Cornucopia (2) 62:4;138:7;185:14;

consistency (12) 44:14;118:6;238:19 124:22;125:14; 116:23;119:3 229:20 

73:15,15;93:22; continually (1) 134:24;141:1,9; corporate (1) Court (1)

 94:2;117:2;170:7; 235:11 142:2,4;154:2; 118:18 230:1 

180:17;203:5;206:23; continuation (1) 173:10,12;183:1,8; correction (1) cover (11)

 226:3;237:1,2 7:15 186:5;187:14;188:9; 56:21 17:5;46:12;47:7,8,

consistent (11) continue (18) 231:2;234:1 correctly (4) 9,12;173:22;174:22;

 76:11,19;87:4; 18:3;53:1;82:9; conventionally (2) 127:3;207:24; 176:9,10;180:13 

88:21;117:3,20; 107:5;109:10;117:21; 121:13;246:10 230:19;236:2 coverage (2)

 198:22;218:5;232:15; 133:5;142:10;170:17; conversation (9) corresponding (1) 38:5;173:5 

236:23;238:16 187:25;188:11;193:3; 18:3;31:5;75:16; 202:12 covered (3)

consistently (4) 200:13;202:13; 95:15;133:12;168:10; corruption (1) 39:9;106:18;222:8 

69:5;88:8;203:8; 215:13;217:17;226:9; 195:10;234:3;246:9 219:22 covers (15)

 221:23 232:8 conversations (5) cosponsor (1) 46:19;47:1;81:4;

consolidate (1) continued (5) 48:4;115:11; 171:7 146:12;148:11;198:5;

 118:16 81:3;167:4;241:9; 133:23;221:11,11 cost (18) 241:8,10,10,13,18;

consolidation (1) 242:13,15 convert (2) 30:24;34:2,3;46:7, 242:8,16,20;243:2 

122:22 continues (3) 31:17;243:24 13;47:3,14;70:21; COVID (1)

constant (1) 192:3;201:24; converted (4) 130:6,7;144:23; 185:4 

80:23 232:10 58:22;142:1; 145:4;147:7;173:6; cows (2)

constantly (1) continuing (3) 237:16;243:22 215:12;241:17; 175:11;177:22 

197:1 188:2;189:19;215:8 converting (2) 244:20;246:11 cracked (6)

consultants (3) continuously (1) 58:9;140:21 costing (1) 59:9;60:19;64:25; 

Min-U-Script® Burke Court Reporting & Transcription (9) confirm - cracked 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 2 

October 19, 2023 

67:2,4;230:19 

cracks (1)

 120:5 

crafting (1)

 238:3 

craziness (1)

 245:6 

crazy (1)

 209:21 

cream (1)

 167:12 

create (14)

 14:11;18:12,21;

 21:11;47:22;76:11,

 18;93:9;135:2;

 169:12;177:7;216:19;

 223:14;224:1 

created (8)

 76:15;162:17;

 165:20;168:5;202:16;

 212:13;228:12;

 245:17 

creates (2)

 12:12;239:21 

creating (2)

 177:2;228:24 

creative (3)

 20:8;214:23;228:22 

creatively (1)

 62:18;70:20;72:6;

 77:22;87:23;91:19;

 111:13;120:12;

 125:12,14,14;142:19;

 145:18,24;146:7;

 148:3,13,16;149:1;

 150:12;159:19;172:3,

 9,10,12,14;173:5,14,

 18,19,22;174:16,22;

 176:9;196:6;222:25;

 231:5,10,11;234:11;

 238:2,22;241:15 

cropping (1)

 47:8 

crops (39)

 13:16,24;16:24;

 17:5,19;22:2;35:14;

 40:16;45:7,24;47:8,9;

 81:21;121:18;125:10;

 143:7,13,15,21,25;

 144:2;146:15;147:11;

 149:3;150:12,14;

 152:13;153:6;158:20;

 159:18;174:22;

 176:10;182:1;202:24;

 223:10;234:25;235:2;

 237:13;238:25 

cross-labeling (1)

 61:22 

curriculum (2)

 53:22;57:16 

curtail (1)

 104:7 

custody (3)

 156:16,20,21 

customer (1)

 155:6 

customers (4)

 130:6,7,11;175:21 

customize (1)

 4:23 

customs (1)

 134:15 

custom's (1)

 132:20 

cut (2)

 61:10;62:9 

cute (1)

 23:8 

cutting (2)

 64:3,4 

cuttings (1)

 23:8 

cycle (1)

 18:4 

62:15,22;63:11;

 64:13,17;67:1;68:4,

 13;69:14;70:1;73:25;

 123:14;132:14;

 136:21;139:13;156:3;

 173:7,8,17;201:25;

 202:7,11;214:4;

 219:5;235:11 

database (6)

 211:9,11,11;214:3;

 237:1,2 

data-driven (1)

 165:21 

date (6)

 38:16;101:22,24;

 173:20;203:18;211:1 

Dave (7)

 171:16;174:12;

 176:18,20,21;178:21,

 22 

Day (23)

 4:4;9:2;10:22;11:1,

 3;14:24;25:9,11;

 42:14;57:16;67:17;

 70:5;102:5;130:13;

 136:22;157:1;200:8;

 216:21;220:9;221:15,

 16;238:9;240:15 

days (11)

December (1)

 40:18 

decide (2)

 110:15;212:20 

deciding (1)

 212:6 

decision (6)

 69:20;201:18;

 212:5;217:10,12;

 242:14 

decisions (1)

 131:4 

deck (1)

 178:19 

declaring (1)

 111:24 

decrease (2)

 29:3,21 

dedicate (1)

 102:4 

dedicated (3)

 176:24;191:18;

 201:10 

dedication (4)

 164:22;189:18;

 197:2;216:13 

deemed (1)

 242:6 

deeper (1)

D 

137:5 crossroads (1) Dad (1) 44:3;79:17;101:1; 123:21 

crickets (2) 96:15 108:2 156:2;173:20;197:18; deeply (2)

 73:21;76:1 crucial (1) daily (1) 204:2,10;226:21; 194:23;216:12 

criminal (2) 165:17 53:23 228:1;247:9 defending (2)

 65:11;205:18 crucially (1) dairies (2) DC (1) 124:5;191:21 

criminals (1) 234:21 146:3;215:12 119:15 Defense (1)

 205:19 crush (1) dairy (4) DDP (2) 171:3 

crimp (1) 157:5 107:22;122:19; 136:6,10 define (3)

 72:9 crushed (1) 174:16;230:11 de (1) 11:16;118:22;

crimper (1) 138:7 damage (2) 44:17 230:10 

124:19 culminated (1) 107:6;238:23 dead (1) defined (1)

crisis (2) 96:14 damages (1) 116:5 202:6 

170:24;229:17 cultural (2) 239:1 deal (4) defining (1)

crisper (3) 81:12;93:24 damaging (1) 39:15;93:25;160:9; 13:9 

87:18;108:14,20 cure (1) 242:11 225:20 definitely (9)

criteria (8) 149:14 D'Amore (34) dealing (4) 35:12;39:22;55:13;

 50:5,8,10;51:8,11; curious (10) 9:15,16;32:13; 65:5;74:8;92:8; 142:17;148:24;149:9;

 91:25;109:12;193:10 18:15;50:9;109:13; 33:15,18;35:3;48:6; 99:7 160:4;199:3;229:2 

critical (10) 115:16;123:13;132:6, 82:21,23;83:13,25; deals (1) definition (6)

 60:16;61:20; 9;220:3;228:2;246:9 84:14,18;85:18,24; 112:15 79:18;118:9;

 133:15;166:6;175:19; current (18) 86:2;189:25;190:3,8, dealt (3) 120:15;125:24;

 192:15;196:9;203:14; 15:15,17,18;16:2; 10,13,18,20,24;197:9; 17:11;115:15; 161:18;162:3 

210:16;234:6 44:10;86:16;87:2,8; 198:2,10,16;203:24; 158:19 definitions (3)

critically (1) 138:12;155:1;215:6; 204:1,7;205:23; dear (1) 124:11,17;161:21 

196:3 217:15,17;223:9; 242:24;243:11 27:7 defunct (1)

criticism (1) 236:25;237:16;244:7; dang (2) debate (1) 110:8 

198:22 245:25 95:14;151:15 62:7 degradation (1)

crop (72) currently (16) danger (1) debt (1) 107:11 

13:15;15:9;16:17, 78:11;81:23;96:19; 178:20 246:19 degrades (1)

 19,25,25;17:4,10,14; 129:23;135:6;139:7; dangerous (2) decade (5) 29:17 

22:5,22;32:8,9;35:11, 181:6;182:3,25; 86:23;113:17 44:15;58:12;96:9; Dehne (13)

 13,14,19;36:9;37:18; 188:8;203:3,14; data (31) 171:25;172:5 80:8;86:7,10;94:17,

 38:3;39:8,16;40:8,15; 221:24;239:6,20; 12:23;20:23,24; decades (2) 22,25;95:4,22,23;

 41:9,13,21;47:13,23; 244:25 21:3;49:18;61:6; 188:7;194:22 98:9;99:3;100:22; 

Min-U-Script® Burke Court Reporting & Transcription (10) cracks - Dehne 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 2 

October 19, 2023 

102:8 8:10 13:23;234:3 58:22;59:14;234:20 discovered (1)

Dehne's (1) designed (1) development (4) digitization (2) 173:8 

215:16 208:1 14:13;18:19; 58:18;59:4 discuss (4)

deliberate (1) desk (1) 162:16;201:23 diligence (4) 96:5;138:1;139:8;

 153:10 210:12 devices (1) 105:10;134:13; 188:17 

deliver (2) desktop (1) 13:4 208:14;244:4 discussed (7)

 173:21;202:16 5:5 diagnoses (1) Dilip (7) 71:13;99:5;196:6;

delivered (1) despite (2) 183:7 10:3,6;45:2;48:2, 204:8;222:1,15;

 138:12 97:2;105:9 dialogue (2) 20;95:17;108:3 242:16 

delivery (2) destination (1) 231:6;232:24 Dill (15) discussion (12)

 136:10;190:4 155:21 dictate (2) 12:3,5,7;14:16; 13:7;39:16;59:2;

Delta (1) destroy (1) 118:19,22 15:3,16,20;16:5,7; 103:13;165:4;201:16;

 187:14 154:7 diet (1) 17:9;18:17;19:22; 225:5;231:6;233:1;

delving (1) destroying (1) 52:19 21:1,10;100:16 234:1,16;247:20 

234:6 67:6 Dietz (14) dilute (1) discussions (2)

demand (20) destroys (1) 200:25;201:14; 118:22 80:19;103:11 

14:24;15:2,18;16:4; 69:22 213:18;215:25;216:2, dimes (1) disease (3)

 18:16;28:12,14,23; destruction (1) 4,4,7,8;218:17; 152:24 81:12;144:1;161:14 

29:1,2,9,17,20;32:2; 29:9 219:16;220:5,23; Dimitri (6) disintegration (1)

 45:9,11,17;133:3; detail (4) 221:4 9:17,18;41:7;42:1; 178:12 

138:7;224:1 86:15;222:7; difference (4) 237:25;238:6 disparage (1)

demanding (2) 234:13;242:17 53:24;172:4;194:1; direct (4) 118:9 

57:12;97:1 detailed (2) 246:11 19:7;98:19;172:25; dispelling (1)

DeMinter (5) 61:25;214:9 differences (1) 199:21 118:3 

194:9;200:25; details (2) 80:18 directed (1) dispensers (1)

 213:18,20,21 156:4;214:6 different (49) 49:4 51:2 

democracy (6) detectable (1) 26:6;30:1,4;34:23, direction (9) display (1)

 7:23;54:16;122:16, 78:20 24;40:1;62:3;63:6; 10:24;17:25;59:25; 54:3 

21;199:18,19 detected (1) 67:14;72:15;73:3,7,8, 85:11;97:25;157:2; displayed (1)

demonstrate (1) 207:17 9,12,19;74:17;77:25; 222:22;228:9;233:24 5:25 

189:1 detecting (1) 78:17,18;89:18; directions (1) disregard (1)

demonstrated (1) 202:22 92:17;98:13;106:15; 31:15 238:25 

192:23 detection (3) 112:2,8;115:16; directly (9) disrupters (1)

department (6) 162:16;204:15; 121:16;123:15; 72:20;73:22;131:3; 105:21 

62:8;65:20;66:4; 208:12 124:10,17;126:3; 156:13,17;168:4; disruption (1)

 91:23;171:2;172:16 deter (4) 131:5;139:6,6;143:7; 224:23;225:14; 170:4 

depend (3) 12:11;24:1;110:6; 147:7,8;154:19; 231:15 disruptive (1)

 81:21;83:5;98:3 150:11 181:1,1;183:6; director (8) 131:18 

dependent (1) determine (3) 186:12;190:11; 7:11;75:12;95:24; distinguish (1)

 123:8 87:20;97:17;98:14 192:11;194:20;199:5; 160:25;169:10; 177:6 

depending (2) determined (5) 231:7;246:16 180:10;224:8;240:25 distraction (2)

 111:13;169:20 40:15;41:8,15; differentiate (2) disadvantage (1) 228:12;229:6 

depends (1) 90:25;239:9 13:10;195:19 39:4 distributed (1)

 193:17 determines (1) differentiated (1) disagree (2) 105:8 

depth (1) 92:18 222:14 8:16;109:22 distribution (2)

 150:17 determining (1) differently (2) disappeared (2) 117:22;121:1 

deputy (1) 39:21 98:11;200:2 69:6;175:1 distributors (1)

 169:10 deterrent (2) differing (1) disappointed (2) 210:2 

Des (1) 24:4;117:24 80:19 155:24;233:17 dive (2)

 116:2 deterring (1) difficult (21) disappointing (2) 59:12;180:14 

describe (1) 132:6 30:5,10,14;33:11, 67:16,17 diverse (5)

 211:21 devastating (1) 22;53:2,6;62:18; disaster (1) 87:5;148:12;

describes (1) 50:12 66:25;69:17;76:17; 44:15 150:13;177:22;

 161:6 develop (5) 88:1;110:25;146:13; disastrous (1) 189:13 

description (1) 82:10;145:6; 205:12,16,20,23,24; 118:14 diversification (1)

 198:6 202:13;211:20; 214:17;242:6 disclosed (1) 16:21 

deserve (1) 235:17 difficulties (1) 113:12 diversification's (1)

 53:10 developed (4) 4:12 disconnect (1) 17:2 

deserves (1) 25:17;99:9;217:8; difficulty (2) 172:22 diversified (3)

 195:16 234:12 6:9;130:17 discourage (1) 17:17;18:5;194:19 

designate (1) developer (2) digging (1) 141:6 diversify (1)

 112:9 87:22;90:25 210:22 discouraging (1) 41:12 

designated (1) developing (2) digital (3) 96:18 diversity (1) 

Min-U-Script® Burke Court Reporting & Transcription (11) Dehne's - diversity 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 2 

October 19, 2023 

47:23 

divert (1)

 245:21 

diverting (1)

 31:14 

Division (3)

 7:11;216:23,24 

divisive (1)

 228:11 

Dixon (9)

 104:23;116:20;

 119:9,12,12;121:22;

 122:18;123:17;

 124:14 

doctor (1)

 183:10 

doctored (1)

 61:23 

document (13)

 39:16;51:8;59:21;

 88:22;90:2;100:7;

 24:20 

doubled (1)

 215:11 

doubt (3)

 32:14;118:20;

 181:12 

doubts (1)

 245:7 

down (28)

 22:8;27:18;48:7;

 50:14;51:6;61:11;

 64:7;65:20;71:16;

 74:15;97:10,12;

 120:6;131:18;138:17;

 150:1;157:6;163:18;

 168:21;177:5,10;

 186:14;189:15;

 209:19;211:5;218:22;

 229:1;231:12 

dozen (1)

 204:10 

176:19;180:1,8,10;

 182:18 

during (17)

 11:7;13:5;40:19,21;

 44:15;46:10,13;72:1;

 73:4;99:14;142:21;

 152:11;160:15;

 196:17;227:8,9;

 229:17 

Dustin (11)

 119:10;125:3;

 129:15,18,21;133:11;

 134:23;137:15,18;

 138:19;139:23 

duties (2)

 10:17;136:11 

dying (1)

 224:1 

eco (1)

 202:5 

ecological (1)

 166:4 

economic (2)

 198:24;242:12 

economically (1)

 46:19 

economics (1)

 46:5 

economy (1)

 161:10 

ecosystems (1)

 107:6 

ed (1)

 180:11 

Edible (1)

 220:8 

edited (8)

 87:23;91:13,18,20;

 92:9,11,16;109:3 

effort (5)

 32:9;130:13;

 220:20;236:6;244:4 

efforts (7)

 161:3;171:9;

 176:23;188:4;215:8;

 235:12;238:4 

Egg (1)

 220:9 

eggs (2)

 177:20,21 

eight (1)

 181:7 

either (9)

 4:20;48:18;59:13;

 136:19;138:13;146:2;

 150:23;154:7;236:22 

Ela (17)

 102:22;104:22;

 105:1,4;107:16,18;

 108:2,12;109:8,22;

E 

105:8;131:25;165:4; draft (2) eagerly (1) editing (13) 111:25;112:22;

 172:6,8;234:16;238:3 46:3;170:20 222:5 87:18,20;88:3; 113:20;114:22;

documentation (3) drainage (1) earlier (11) 90:18,23;91:5,7,24; 115:10,18;116:18 

73:11;76:14;225:15 120:6 37:14,17;65:3; 92:15;108:7,8,11,13 elaborate (3)

documents (1) draw (1) 108:8;137:9;141:12; educate (4) 12:22;50:9;108:10 

225:5 182:7 168:10;173:12; 19:10;57:1;165:19; elections (1)

DOD (1) dredge (1) 205:11;207:17;217:8 212:14 230:25 

171:3 115:25 early (10) educated (6) element (1)

DOF (1) drift (2) 13:20;48:11;110:4; 45:11;54:7;158:14; 204:15 

226:10 153:9;156:9 153:24;175:3;208:12, 172:14;212:4;219:8 elemental (1)

dollars (12) drifts (2) 13;209:25;216:17; educating (5) 81:5 

34:10;49:3,8;116:7, 156:6;245:19 242:19 19:18;45:12;52:23; elevating (1)

 13;136:20;143:24; drink (3) earth (1) 211:23;213:9 201:16 

152:24;178:2;219:11, 80:7;177:22;185:4 244:17 education (20) elevation (1)

 13;245:15 drinking (1) Earthworms (1) 19:18;48:24;49:3,8, 233:22 

dollars' (1) 163:19 44:17 12;53:1,21;55:18; Eleven (1)

 142:4 Driscoll's (9) easier (5) 74:11;97:21;166:24; 44:6 

domestic (11) 80:12;81:5,10,14, 27:4;44:18;101:12; 167:1,17;169:14; eligibility (3)

 130:21;133:18; 16;82:4,9,15;83:12 129:5;241:24 183:20;185:23;186:1, 13:16,18;215:9 

135:6;152:12,21; driven (2) easily (3) 18,24;208:20 eligible (1)

 157:5,6;159:24; 201:25;231:13 15:18;42:13;99:12 educations (1) 13:11 

166:23;224:11;247:7 drives (2) east (1) 206:25 eliminate (1)

domestically (3) 61:11;85:24 99:10 effect (3) 175:17 

158:17;159:21; driving (1) eastern (5) 35:6;134:10;225:19 else (8)

 160:8 99:15 21:24;37:19,21; effective (11) 26:21;56:9;71:19;

don’t (1) drop (2) 59:6;70:13 46:11;63:22;83:1; 138:8,15;145:24;

 21:2 96:20;232:10 easy (8) 130:13;134:16; 208:19;209:18 

donated (1) dropped (1) 33:10,13,24;50:21; 144:24;163:10; else's (1)

 167:15 141:10 101:11;154:21; 202:21;204:21; 5:7 

done (16) drought (2) 178:20;205:13 215:18;243:3 elsewhere (2)

 20:14;24:9;33:22; 23:10;145:13 eat (4) effectively (6) 66:22;108:9 

34:1,3;58:25;92:19; Drug (1) 26:24;118:19; 27:19;43:21;214:4; eluded (1)

 110:4;132:18;133:8; 104:6 177:19;183:18 215:11;235:7,19 66:5 

144:8;154:22;171:22; dry (1) eaters (1) effectiveness (2) email (5)

 219:3;232:5;240:8 97:15 177:16 202:23;239:8 5:13;68:16;73:21;

door (3) due (7) eating (4) effects (5) 157:19,25 

28:14;84:24;150:2 24:2;78:7;134:13; 52:19;53:25; 26:4;108:22; emailed (2)

dormant (2) 173:19,22;208:14; 120:23;185:14 131:15;170:3;234:19 68:19;72:20 

109:18,25 233:16 echo (2) efficiency (3) embed (2)

dots (3) dumping (1) 147:14;168:18 81:13;152:23;186:8 170:16;225:4 

6:3;210:15;211:6 69:1 echoing (2) efficient (2) embrace (1)

double (1) Durfey (5) 148:4;227:12 76:11,19 126:20 

Min-U-Script® Burke Court Reporting & Transcription (12) divert - embrace 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 2 

October 19, 2023 

emergency (1) engaging (2) envisioning (1) 62:17,23,23 152:20;153:16;

 64:15 7:22;163:22 59:25 estimates (3) 171:18;187:9;188:19;

Emily (11) engineered (1) EPA (9) 67:25;68:1,2 204:24;205:4,15,16;

 72:4;75:7;80:4,10, 91:14 50:16,25;51:2,10; estimating (1) 210:21,25;212:8;

 11;82:21;84:14,21; engineering (9) 104:6;105:24;106:4; 69:16 213:15;216:2;219:2;

 85:19;86:5;241:4 87:18;88:1,4;91:3, 113:22;163:18 Esu (1) 220:6,17;224:1;

emissions (1) 24;92:15,20;108:9; EPA's (4) 8:24 247:17,23 

233:25 109:6 192:5,10,13;194:1 etcetera (5) everybody's (2)

emphasis (4) enjoy (1) equal (1) 67:3;78:14;153:9; 206:16;208:17 

19:9;97:13;138:22, 142:11 233:8 155:7;204:9 everyone (31)

 24 enlisted (1) equally (1) ethanol (1) 5:10;7:7;8:13;9:18;

employs (1) 134:15 196:4 132:17 11:2;21:15;25:19;

 70:16 enlisting (1) equation (1) ethical (1) 35:8;48:2;53:24;

enabled (1) 132:20 40:4 217:11 68:10;69:5;77:3;95:3;

 4:10 enough (23) equitable (3) EU (5) 116:22;121:15;

encompass (2) 26:3;36:7;48:16; 149:19;189:14; 92:10;121:22; 164:19;168:18,22;

 235:5;236:6 49:10;54:13;73:25; 243:9 177:24;178:4,6 171:5;191:15;201:8;

encourage (6) 85:12;97:17;126:9; equity (12) Europe (1) 205:13;211:21;212:2;

 71:15;85:3;128:19; 128:6;138:24;139:10; 170:14,15,16; 59:6 215:3;221:8,18;

 171:7;214:23;242:15 146:8;147:15;150:5; 224:12,13,25;225:2,3, eutrophication (1) 224:6;238:11;247:19 

encourages (1) 163:12;185:3,9; 5,7;227:16,18 120:8 everywhere (4)

 103:10 206:17;237:3,9,12,19 equivalent (1) evading (1) 19:23;122:22;

encouraging (2) ensure (5) 123:7 59:9 171:1;184:25 

121:8;224:2 118:11;169:24; Erin (7) evaluate (3) evidence (2)

end (27) 188:2,10;223:14 7:11,13;9:5;221:6, 99:22;111:23;162:8 26:25;62:15 

26:9;28:24;34:21; ensures (1) 14;224:5;233:4 evaluated (1) exactly (8)

 63:16;67:17;72:10; 126:25 Erin's (1) 192:20 20:23;24:5,6;83:21;

 73:21;78:10;114:5,8, ensuring (1) 233:5 evaluating (1) 84:17;156:14;167:2;

 18;120:21;130:13,22; 233:23 eroded (1) 235:8 195:12 

133:3;136:22;137:11; entails (1) 178:15 evaluation (2) example (29)

 179:12;188:24; 193:24 error (2) 170:3;234:8 16:24;17:3;23:23;

 195:25;198:4;200:8; entered (1) 69:18;74:8 even (67) 37:22;60:21;61:15;

 202:25;220:9;245:1; 236:23 escalating (1) 8:16;12:19;13:25; 62:21;66:17;68:14;

 247:10,21 entering (1) 170:24 17:24;18:4;26:10,18; 72:8;74:12;76:24;

ended (1) 118:1 especially (21) 31:9,10;33:2;41:15; 77:1;78:6;79:8;99:16;

 185:7 entire (9) 45:7;58:20;89:8; 43:8,9;49:8;50:14; 101:14;106:10,25;

endocrine (2) 5:5;61:19;187:21; 92:8;108:15;110:7; 51:14;55:18,23,24; 114:21;118:6;119:5;

 105:21;170:4 196:14;197:12,14; 133:15;138:4,4; 56:11;65:13;73:3; 131:17;139:11;

endorse (1) 235:5;238:1;243:22 142:21;153:5;158:17; 74:1;86:21;88:11; 153:11;160:5;182:7;

 217:24 entirely (4) 160:14;166:22; 89:15;90:6;91:11; 239:12;246:22 

endorsed (1) 123:16;192:11,14; 168:10;180:19; 94:6;102:17;105:25; examples (5)

 170:20 201:10 183:21;193:24; 109:18,24;111:3,23; 16:21;46:11;68:14;

ends (2) entity (7) 214:25;227:18;236:7 112:8;113:13;120:4, 147:1;187:2 

5:21;63:16 141:19,20;142:1,5; essence (1) 17;123:20,22;127:9, Excellent (3)

enemy (1) 207:20;208:23; 131:16 25,25;138:11,19; 9:14;69:2;187:11 

102:13 210:20 essential (4) 149:7;150:19;156:17; except (4)

energies (1) entrant (1) 81:11;103:17,19; 157:7,8;175:17; 114:24;198:5,6;

 19:21 58:10 110:16 181:10,23;182:5; 239:2 

enforce (1) entry (4) essentiality (3) 184:25;196:25; exception (4)

 177:12 79:5;132:18,21; 43:9;110:14,18 197:22;203:15;204:3; 109:24;117:5,9;

enforceable (1) 133:8 essentially (4) 206:19;208:3;209:24, 198:7 

218:6 environment (6) 16:23;26:2;101:18; 24;230:6;244:23; exceptions (8)

enforced (2) 130:18;183:25; 134:18 245:20 50:8;110:3;117:15;

 35:2;202:6 186:20;190:1;191:18; establish (4) evening (1) 197:12,13,17,25;

enforcement (9) 213:7 107:3;117:11; 227:15 239:3 

27:22;63:4;96:11; environmental (6) 173:17;238:14 events (1) excessive (1)

 131:6;177:1;204:15; 107:6;114:13; established (6) 186:12 214:23 

224:12;225:8;226:2 165:10;170:4;240:25; 38:12;40:20; eventually (2) excited (8)

enforcing (3) 242:8 128:25;162:19;163:8; 88:25;145:6 12:5;14:23;75:15,

 35:1;65:10;239:6 environments (1) 173:8 everybody (28) 16;77:7;79:19;

engage (4) 188:7 establishing (1) 9:13,24;11:15; 168:20;228:6 

87:6;127:1,6; envision (1) 193:20 39:24;122:20;145:17; excitement (1)

 128:16 84:23 estimate (3) 147:25;151:20; 209:12 

Min-U-Script® Burke Court Reporting & Transcription (13) emergency - excitement 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 2 

October 19, 2023 

exciting (4)

 7:23;20:19;55:1;

 76:5 

exclamation (1)

 217:11 

Excluded (9)

 87:16;88:3;91:5;

 104:12;106:20,22;

 159:23;181:14;

 216:25;217:3 

experienced (3)

 199:1,16;228:18 

experiences (1)

 159:11 

experiencing (4)

 5:16;16:18;30:20;

eyebrows (1)

 246:20 

eyes (3)

 62:20;201:21;

 229:20 

fairness (1)

 154:1 

faith (2)

 193:3;200:14 

fake (1)

 53:25 

fall (8)

 16:23;17:19;40:22;

farmer- (1)

 231:12 

farmer/producer (1)

 21:24 

farmers (138)

 10:22;14:7,10,11,

 23;15:17;20:22;26:4,

 17,19,20;34:10;41:11,

F 

107:2,3;108:7 135:19 fabulous (2) 105:10;158:1;225:10; 16;42:11,11;44:20;

excludes (1) experimented (1) 11:13;179:2 234:19;247:18 52:11;56:23,24;61:8,

 104:17 243:21 face (5) false (1) 19;64:21;73:1,3,7,10,

excluding (2) expert (3) 41:11;79:22;172:9; 88:8 15;86:11,14;87:15;

 123:11;162:15 73:17;164:20; 201:3,4 falsified (1) 88:7;89:2,18;90:12;

excuse (4) 193:19 faces (1) 97:7 94:9;95:24;96:18,21;

 28:11;70:17;87:17; expertise (1) 105:3 familiar (4) 100:7,16,17;102:16;

 181:2 240:13 facilitate (1) 17:12,15;36:17; 115:9,14,19;118:19;

executive (3) experts (3) 8:12 105:3 119:16,23;120:11;

 75:12;160:25;224:8 72:19;73:19;217:3 facilities (3) families (2) 122:17;123:11;124:2,

exempt (2) explain (1) 85:7,12;96:25 67:10;226:24 14,18;141:6;142:19;

 230:6,8 153:9 facility (4) family (6) 143:21;144:18;

exemption (1) explained (2) 98:13;112:12; 70:13;122:4;142:1; 145:18;147:3,19;

 93:6 12:16;13:9 216:17,19 146:12;159:9;199:13 157:6;165:5,8,13;

exemptions (2) explore (1) facing (2) family's (2) 166:21;168:22;

 210:2;219:14 102:19 166:11;174:2 142:1;184:21 169:10,14;171:7;

exercises (1) exported (1) fact (20) Fantastic (5) 172:9,11,12,14,22,24;

 171:4 182:3 33:2,12;41:14;46:3; 158:10;167:10; 173:4,14,19,25;174:2,

exhausting (1) exporters (2) 53:5,6;66:19;73:2; 174:5;221:9;247:20 7,20;177:9,15,16;

 147:4 239:13;240:6 105:9,22;110:5; far (12) 183:22,22;186:10,18,

exist (3) exporting (1) 123:24;141:13;157:7; 40:22;47:6;54:2; 25;194:14;196:22,23;

 142:9;182:2;237:14 240:2 174:24;196:17; 78:15;89:14;144:10; 200:5;214:25;215:24;

existed (1) exports (1) 206:15;236:18;244:2; 145:4;163:12;181:5; 219:11;221:20;224:9,

 96:23 181:12 245:7 205:1;206:9;211:8 11,13;225:10,14,19;

existing (1) exposure (1) fact-checking (1) farm (56) 226:7,12,23;227:25;

 14:10 184:22 61:5 23:6;24:3,7;25:15; 228:15,18;229:8,10,

exists (4) express (2) facto (1) 31:21;43:1,13;48:24; 10,11,21;230:3,5,16;

 57:12;60:3;78:11; 54:21;150:5 44:17 58:8;89:10;90:7;94:1; 232:2,22;233:13,15,

 128:5 expressed (1) factor (2) 97:15;98:12;116:11; 18;234:7,12,19,22;

exit (1) 88:10 30:14;35:17 124:23;138:4;140:21; 236:19;237:4;239:11;

 5:3 extends (2) factors (1) 141:2,18,21;142:2,8; 244:15,25;245:2,3;

expand (5) 8:15;226:23 172:7 146:23;151:12; 246:23;247:7 

15:1,18;31:1; extension (6) factory (1) 158:13,19,23;167:8, farmers' (1)

 137:25;222:10 59:3;73:20,22;74:1; 118:14 15,15;172:2,4; 46:13 

expanding (6) 172:21;247:1 facts (5) 174:25;183:1;184:12, farming (38)

 15:22;106:20; extensive (2) 53:3;118:12;135:3; 24;185:2,16;186:5; 14:7;46:25;49:18,

 111:19;165:5,13; 16:15;216:25 137:14;216:15 194:13,16,17,19; 20;72:8,14,18,21;

 166:22 extensively (2) factual (2) 195:11;196:9,24; 73:8,11,24;74:17;

expansion (1) 74:21;241:14 53:2;135:2 198:14;199:14; 80:21;87:5,7;96:22;

 16:1 extent (1) fail (1) 210:16;225:17;228:8; 118:14;119:17;120:1,

expect (3) 181:23 50:8 229:17;230:23; 10,11,15,21;123:18;

 64:9;101:8;105:16 externalities (1) failed (4) 243:21,22 125:8,11;159:10;

expectation (1) 115:23 17:18;183:9;220:7; farmed (4) 166:9;174:17,21;

 93:9 externalizes (1) 245:6 33:9;43:5;121:13; 184:7;186:6;200:6;

expecting (1) 116:7 failing (1) 124:20 230:16;233:22;234:1;

 24:3 extractive (1) 177:17 farmer (29) 246:10,17 

expenses (3) 13:13 fails (5) 26:8,24;30:21;31:8; farmland (3)

 47:13;215:14; extreme (1) 12:19;16:22,25; 37:23;39:20;70:14; 60:15;64:20;178:6 

239:23 137:9 239:4;240:6 86:12;90:10;119:13; farms (40)

expensive (5) extremely (8) fair (4) 140:20;142:14;143:6; 14:10;24:6;33:6;

 31:16;55:6;128:10; 135:4;146:11; 169:13;198:19; 144:17;158:12; 87:14;96:24;98:18;

 242:6;245:11 155:24;183:13;185:9; 244:16;247:7 171:25;173:2,11,12, 103:25;107:7;115:25;

experience (11) 235:16;238:2;242:11 fairly (4) 13,21;174:16;176:22; 122:4;123:6,8;

 48:15,18;125:20, eye (3) 91:22;109:25; 184:10;186:6,9; 158:20;159:19;

 22,24;126:16;152:12; 6:3;109:2;116:6 110:1;221:23 197:5;221:24;231:11 165:24;169:16;171:1; 

Min-U-Script® Burke Court Reporting & Transcription (14) exciting - farms 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 2 

October 19, 2023 

172:1;177:3;178:3; 24:12;45:15;55:14, fight (2) 20;233:9 flat-priced (1)

 181:10,12,25;182:1; 19,24;57:3,5;59:24; 121:5;186:24 finished (1) 130:14 

183:15,24;184:9; 98:11;121:7;134:7; fighting (1) 162:2 flavor (5)

 187:13;193:4;194:12, 158:18;170:10; 145:2 finishes (1) 216:20,23,23,24;

 18;195:12,21;198:13; 180:25;183:3;184:4, figure (9) 240:15 217:9 

222:13;225:11,14; 13;209:13;211:13; 45:22;68:22;93:14, finishing (1) flavors (8)

 226:6;230:11,13 221:25;246:13 23;136:23;179:25; 238:9 217:6,10,13,14,17,

Farmville (3) feeling (3) 187:3;210:22;220:22 fire (2) 21,23;218:1 

231:7,7,10 27:24,25;232:23 figured (2) 62:8;65:20 flawed (1)

farther (1) feels (2) 124:19;182:20 firm (1) 217:20 

199:8 30:14;160:7 figuring (3) 201:9 flexibility (1)

Fast (5) feet (1) 211:9,11;223:25 first (59) 93:11 

72:14;95:16;175:3; 197:16 file (2) 7:17;12:2,5;22:1; flood (2)

 211:4;240:8 Fehr (9) 211:8;219:13 23:8,9,18;34:2;40:10; 62:8;128:13 

faster (9) 147:24;151:25; fill (1) 43:3;46:3,6;50:11; floodgates (1)

 29:2;31:9;74:15; 158:7,8,12,12;159:14; 145:15 58:6,15;72:12;75:14; 145:16 

95:3;121:25;122:2,6; 160:4,16 film (4) 77:6,15;91:8,24; flooding (2)

 177:25;208:25 felt (5) 44:8;107:1;221:22, 94:22;102:25;103:13; 149:8;199:8 

fastest (1) 96:6;130:23; 24 112:1;117:1;120:17; floor (26)

 47:2 158:22;159:19;200:4 films (1) 126:15;127:23; 21:19;42:20;60:12;

fat (1) fermentation (1) 107:2 132:13;140:23,24; 75:9;80:10;86:9;

 155:7 106:20 filters (1) 156:19;159:1;164:21; 94:24;98:25;102:22;

fate (1) fertility (5) 212:19 172:2,5;174:17; 116:21;119:11;

 103:24 120:12;121:11; final (2) 180:15;184:20; 140:18;152:2;158:11;

favor (2) 196:11,15;238:18 63:4;222:6 187:15;199:13;203:1, 160:23;164:18;169:7;

 149:11;204:12 fertilizer (3) Finally (9) 6;210:1,4;216:16,19; 174:13;176:20;179:3;

FDA (5) 123:23;140:4; 44:1;68:4;107:5; 217:9;219:18;221:21; 187:8;191:14;213:19;

 114:23;154:3,6,11; 244:19 118:3;170:22;203:12; 230:11;235:17; 221:17;238:10;

 185:11 fertilizers (6) 222:23;235:13; 236:13;238:13; 243:17 

fear (1) 120:2,4,6;123:25; 245:10 241:20;243:20;244:2, flooring (1)

 209:11 177:19;223:4 finance (1) 11 106:12 

fearful (1) few (26) 66:10 fish (3) Florida (5)

 185:5 13:8;25:18;27:3,6; finances (1) 81:6;107:8,10 194:19;196:10,12,

feasible (1) 43:9,16;50:4;69:6; 46:17 fit (1) 17;198:6 

215:13 82:8;115:10;118:16, financial (9) 35:19 flow (3)

feast (1) 21;119:3;124:18; 14:6;35:9;36:5; fits (1) 51:12;67:4;174:7 

201:21 128:8;129:2;146:3,4; 38:25;65:7;66:8; 117:6 flowing (2)

feature (1) 169:22;184:7;197:18; 136:24;172:2;173:25 five (32) 31:8;227:20 

4:21 199:20;201:17; financially (4) 32:5;34:24;43:13; flown (1)

February (2) 216:15;235:8;245:6 136:2;155:22; 48:23;49:21;67:9,14; 129:6 

40:19,21 fiber (1) 186:19;246:19 70:15;73:7,13;76:22; flows (1)

fed (1) 155:7 find (31) 80:6;86:7;93:18; 67:4 

122:4 field (29) 4:10;6:4;20:12,12, 94:14;95:11;135:17; fluorine (1)

Federal (7) 13:1;22:2,19;34:22; 16;21:2;26:5,10; 139:24;140:2;141:20, 163:5 

8:8,10;13:24; 58:19;59:24;89:11, 33:21;42:6;48:13; 22,23;181:5;182:24; fly (1)

 150:14;163:14; 15,16,17;90:11; 53:1,2,3,5,6;91:18; 183:6;205:2;206:7, 76:2 

170:23;173:19 93:14;106:21;131:8; 92:3;93:8,20;99:12; 13,14,16,17;220:5 flying (1)

federally (2) 139:25;140:25; 153:6;173:7;199:25; five-acre (1) 150:25 

128:13;202:6 143:20;144:6;147:3; 207:18;208:21; 168:22 FOB (1)

fee (1) 159:17;182:1;185:6; 214:14,23;222:21; five-minute (2) 136:6 

31:11 197:22;199:4;214:15; 232:9;237:17 160:21;164:15 focus (15)

feed (21) 223:14,16;235:2; finding (5) five-year (2) 13:16;43:21;76:7;

 55:20,21,21;59:11; 237:7 6:9,17;94:7;138:11; 31:22,24 81:3;131:5;133:18;

 76:3;78:7,13;79:8,10, fields (14) 184:4 fix (1) 152:11;186:17;203:1;

 13;130:6,7,8;131:13; 12:20;21:2;24:10, findings (2) 178:19 215:4;226:11;231:12;

 140:4;152:9,11; 11;36:21;58:18;87:8; 43:22;241:19 fixed (1) 235:12;237:4;241:7 

155:5,7;162:3;186:12 89:19;99:6,15; fine (6) 158:24 focused (11)

feedback (5) 139:12;184:25; 21:1;68:16;113:7; fixes (1) 14:9;45:23;48:5;

 17:16;18:18; 214:17;237:13 140:3;156:8,22 5:15 103:7;130:21;161:1;

 232:25;236:6,15 field's (1) finish (10) flag (2) 215:8;228:8;229:23;

feeding (1) 13:5 7:2;44:12;98:8; 33:23;112:11 237:1;245:17 

79:23 fifth-generation (1) 107:13;139:22; flags (1) focusing (5)

feel (21) 70:13 221:14;230:25;231:4, 155:21 96:10;163:7; 

Min-U-Script® Burke Court Reporting & Transcription (15) Farmville - focusing 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 2 

October 19, 2023 

168:13;206:3;225:11 

fold (1)

 210:7 

foliar (1)

 140:4 

folks (24)

 4:3;9:1;10:25;

 19:20;20:9,11;60:10;

 75:25;94:20;127:11;

 140:10;151:8;159:5;

 169:1;204:13;208:13;

 218:18;220:21;221:7,

 8;224:2;228:1;236:9;

 243:19 

follow (8)

 42:5;62:13;68:10;

 70:25;102:6;156:25;

 178:17;219:19 

followed (36)

 21:18;25:12;28:4;

 37:9;42:16;51:25;

 57:22;60:9;72:3;75:7;

 80:5,8;94:23;102:21;

 104:22;116:20;

 135:16,18 

footsteps (1)

 178:18 

forage (1)

 150:25 

force (4)

 64:16;165:20;

 217:14,25 

forced (3)

 14:2;132:25;242:3 

forces (1)

 130:10 

forecast (1)

 126:8 

forefront (2)

 91:22;232:9 

foregone (1)

 234:16 

foreign (1)

 66:2 

forever (2)

 129:1;171:1 

forged (1)

 13:24 

46:19;59:4;103:21;

 130:12;132:22;

 139:13;183:9,13;

 195:1;199:4;202:12;

 207:21;212:14;

 246:12 

foundation (2)

 29:18;91:12 

founded (3)

 167:16;194:13;

 224:13 

founder (1)

 238:12 

founding (3)

 194:14;201:9;216:8 

four (5)

 52:16;124:12;

 129:23;135:15;

 196:14 

fourth (1)

 23:9 

fourth-generation (1)

 140:20 

framework (3)

 127:13;153:13;156:5;

 159:22;208:6 

fraudulently (2)

 59:7;61:10 

free (2)

 25:21;139:5 

frequent (1)

 196:17 

fresh (6)

 12:17;15:9;81:9;

 187:13;241:1,11 

friends (4)

 53:14;55:4,17;

 87:24 

frog (2)

 106:4,6 

front (5)

 22:9;59:1;62:19;

 150:1;159:5 

Fronteer (1)

 60:14 

Frontier (1)

 180:11 

fruit (4)

 48:23,24;62:8;

 121:11;184:14;

 211:10;220:10 

funds (1)

 49:12 

furiously (1)

 97:15 

further (5)

 13:9;114:17;

 163:16;166:11;

 208:25 

Furthermore (1)

 105:24 

future (14)

 24:21;26:1;50:15;

 67:11;76:20;85:1;

 125:21;189:21;

 204:15;214:4;232:16;

 235:16;243:8;246:2 

FYI (1)

 95:6 

G 

119:10;125:3;129:15; forgeries (1) 117:16;123:15; 16:18;17:6;105:5; gain (1)

 137:19;140:16;143:1; 127:10 235:8 229:11 134:5 

147:24;160:20; forget (2) frameworks (1) fruits (1) gallery (2)

 171:16;174:12; 13:20;240:20 123:11 175:8 5:1;201:8 

176:19;187:7;191:13; forgive (1) Francis (8) frustrated (1) gap (3)

 194:9;200:25;213:18; 148:4 164:17;169:4; 123:21 69:3;142:6;145:15 

215:25;221:6;224:5; form (5) 171:16;174:11,13,15; frustrating (1) Gardeners (2)

 238:8 87:25;121:12; 176:15;178:10 30:5 169:11,19 

following (5) 180:22,22;208:13 Frank (11) frustration (1) gas (1)

 12:22;73:16; formal (1) 42:19;52:1;57:22; 22:16 233:25 

108:13;210:1;217:22 105:9 60:8,12,14;65:24; fulfills (1) gases (1)

follows (1) format (3) 68:9;70:3,19;71:18 202:10 244:19 

177:24 10:21,25;226:21 Franklin (3) full (10) gate (1)

follow-up (3) former (2) 10:8,10;67:22 5:3;155:14;170:3; 225:17 

18:12;68:9;155:17 105:6;178:18 frankly (3) 180:13;193:2;206:19; gathered (1)

font (1) forming (1) 59:4;157:8;175:16 210:15;228:25; 214:16 

4:19 100:3 frass (10) 230:18;242:15 gave (2)

food (52) Fortunately (1) 76:9,10,12,13,16; fully (11) 16:21;114:21 

18:17;19:7;35:8; 73:9 77:20;78:2,16,17,23 34:11;36:20;46:2; Gazzaniga (1)

 43:12;52:21,22; fortune (1) fraud (37) 70:18,18;135:13; 129:16 

53:11,11,13,25;54:8, 65:15 12:11,13;33:10; 165:17;194:19; gender (2)

 21;58:13;76:3;79:8, forum (1) 36:23;44:2;60:17; 195:20;222:15;235:4 224:14,24 

10,15;80:21;103:3; 191:4 61:13,24;62:13; fumigants (2) gene (24)

 104:6;112:15;118:7, forward (32) 63:13;67:15;68:24; 117:20;182:10 87:17,20,23;88:3;

 15,18;120:24;138:25; 11:3;13:24;22:18; 69:22;70:18,22; fun (3) 90:18,23;91:5,7,13,

 139:4;152:10;164:24; 35:2;43:25;51:13; 96:10;99:17;131:16; 56:5;76:6;216:15 18,20,23;92:9,11,15,

 165:9,10,17;169:13, 57:15;58:8;64:11; 132:6;148:15;150:11; function (1) 16,16;108:6,8,10,13;

 15,19;170:24;175:5, 65:17;71:16;72:14; 152:20;153:10;177:4; 209:1 109:3,5;167:16 

14,15;178:2;183:25; 75:17;78:23;79:24; 201:11;202:22,23; functions (1) gene-edited (1)

 191:17,17,21;194:24; 82:11;104:18;113:3; 203:15;204:5;206:3; 63:25 87:19 

196:5;233:13;244:13, 157:25;158:5;162:6; 207:17,21;208:12,22; fund (5) gene-editing (1)

 21;245:8,8,24 175:3;189:19;200:1; 210:5;234:22;237:9 18:22;58:12;60:15; 88:5 

foods (7) 204:9;217:14,25; fraudster (1) 65:19;180:11 general (13)

 53:25;76:23;184:2; 218:20;223:18; 205:17 fundamental (1) 124:18,20;141:2;

 193:4;244:6,11,24 227:18;230:23; fraudsters (2) 234:24 163:23;164:21,23;

foot (1) 233:19 205:12,12 funded (2) 165:3,7;166:19;

 101:25 foster (2) fraudulent (11) 48:14;53:18 167:15;168:19,21;

footprint (4) 189:13;238:18 26:1;29:12;69:19, funding (10) 219:22 

81:17;123:23; found (14) 24;71:10;117:18; 46:6;47:12,16; Generally (4) 

Min-U-Script® Burke Court Reporting & Transcription (16) fold - Generally 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 2 

October 19, 2023 

5:14;93:9;118:7,8 25;75:2 10,15;94:21;95:14, 159:15;229:10;240:5 grew (3)

generated (1) girl (1) 15;99:16;101:4; grains (7) 89:11;194:17;

 120:19 46:15 102:13;104:25;105:1, 26:25;28:22,25; 229:17 

generation (4) given (10) 4;111:6;112:17; 125:10;130:24; grocery (3)

 52:15;186:21; 63:22;72:13;79:9; 116:18,22;118:17; 149:13;172:1 19:19;53:23;54:19 

194:12;199:13 110:7;130:2;131:13; 119:6;125:21;128:23, grand (1) Grodan (1)

genetic (9) 147:6;195:19;201:15; 24;129:12;134:7,19; 122:12 190:11 

87:18,25;88:4;91:2, 242:9 136:4;137:7;139:11; grant (1) gross (3)

 24;92:15,20;108:8; gives (1) 144:16;150:19; 18:19 24:5;230:10,12 

109:6 147:9 151:21;158:25;159:5; granted (1) ground (12)

genetically (1) giving (2) 160:7,18;165:22; 46:16 33:22;50:19;97:18;

 91:14 98:12;226:22 166:1,7;168:23; grants (1) 145:3,6;146:11;

gentleman (2) glad (9) 169:8;170:10;171:18, 13:25 188:6;196:20;197:15,

 141:12;184:6 14:22;16:14;42:8; 19;173:4,12,13; granularly (1) 20;198:11;223:1 

gentlemen (1) 54:25;113:2;184:16; 187:9;189:25;191:15; 132:13 group (17)

 201:21 211:14,20;218:18 201:2,7;203:22,24; graphic (1) 25:25;26:3,16;27:9,

geo (2) glass (1) 205:3,9;212:23,24; 16:15 16;48:15;51:9;89:11;

 16:16;36:20 187:16 213:20;217:21;220:8, grasping (1) 106:14;113:5;187:21;

geocode (1) global (12) 25;221:10,11;224:6; 160:11 193:21;196:22;197:1;

 214:18 111:10;120:25; 228:23;231:9,18; grass (2) 217:24;223:22;

geocodes (6) 128:3;130:23;133:20; 233:11;236:15; 97:17;122:4 232:25 

88:25;214:12; 135:24;152:12; 238:10;239:5;246:5; grateful (6) grouped (1)

 236:3,10,19;237:7 161:20;165:9;180:20; 247:9,15 7:19;9:2;11:2; 106:11 

geocoordinate (1) 216:24;235:5 good-looking (1) 52:13;54:4;164:9 groups (7)

 59:23 glyphosate (10) 22:5 graze (1) 50:23;51:6,7;173:1;

GEODOC (2) 183:12,14,15,16; goods (2) 177:22 219:13;231:12;

 20:20;36:17 184:22;185:3,7,9,13, 138:12;229:9 great (59) 232:17 

geographical (1) 16 Gosh (5) 10:18;16:10;17:1,2; grow (29)

 16:22 GMO (12) 10:20;49:16;95:14; 30:2;34:16;35:2,12; 15:12;16:25;18:16;

geographies (1) 86:16,17,20,21,25; 104:25;127:19 41:22;44:24;46:6; 19:6;21:6;31:20;

 181:1 103:9;153:6;181:21, governances (1) 56:13,15;65:21;69:5; 46:23;62:18;81:21;

geolocating (1) 22;182:1,2;186:13 131:9 70:5;78:4,25;80:19; 83:6,6,6;118:19;

 36:18 GMOs (3) governing (1) 84:14;97:25;105:3; 120:12;141:16;

geolocations (2) 87:8;156:8;203:10 131:4 111:25;113:20;115:5, 142:10;143:19,21,25;

 213:25;214:11 Goal (9) government (3) 18,20;116:15;122:18; 144:25;145:20;

geo-locations (1) 75:19;76:20;80:20; 126:24;128:12; 125:5;127:19;132:19; 148:10;150:13;

 180:25 81:18;94:2;117:11; 202:7 138:1;152:7;156:13, 158:19;166:25;

georeferencing (2) 119:16;218:6;244:9 governmental (1) 24;157:23;160:24; 196:12;202:14;235:1;

 37:1;59:21 goals (1) 113:10 167:11;184:23; 238:25 

Georgia (1) 75:19 GPS (29) 185:18;186:24;201:6, grower (10)

 194:19 goes (12) 12:11,19,23,24; 6,6;212:1;213:16,16; 35:21;37:2;46:23;

geotagged (1) 8:20;27:12;37:25; 13:3;61:14,16,18; 215:22;221:10; 47:18;64:7;105:5;

 58:23 58:20;84:13;136:16; 87:9;88:23;89:12,16, 222:18,20;228:9; 114:10;116:10;137:9,

geotagging (3) 138:17;141:11; 18,22;93:7,9,16;94:7; 238:1;239:14;240:10; 11 

58:18;59:14;71:14 151:16;155:4,8; 98:20;99:2;117:3,10, 243:19;246:23; growers (51)

geotracking (1) 225:17 12;170:10;180:23,24; 247:20 12:24;14:2;15:1,6,

 131:7 gold (4) 214:16,21;237:15 greatly (2) 8,9,22;16:18,20;17:4,

Gerard (1) 188:3;194:24; grab (1) 104:7;167:4 10,20;18:5;27:24;

 9:15 195:3,17 102:9 green (1) 28:9,17;35:22,23;

gets (7) Good (133) grace (2) 54:6 43:7,24;46:7;62:3;

 61:24;93:24; 9:7,8,9,10,11,12,14, 8:18;226:25 greenhouse (7) 65:15;72:6;81:2,14,

 120:16;136:1;158:24; 19,22,25;10:5,6,7,12; gracious (1) 103:18;187:14; 15,19,20,22;84:2,4,9,

 232:25;247:9 11:1;12:6,6;19:25; 69:10 222:24;223:17; 12;85:9,14;97:2;

Ghana (10) 22:22,25;23:1,8,9,13; graduating (1) 233:25;235:2;244:19 130:22;133:5;168:8;

 60:22;61:1,2,7; 24:6,12;25:9,11;31:5; 216:21 greenhouses (1) 188:16,21,24;193:2;

 62:17;66:16,18,23,24; 35:20;40:24;41:4; grain (28) 223:11 222:3;241:20,21,23;

 69:14 42:14;45:3;46:25; 26:9,10,20;28:19, greens (2) 242:1,2,12 

giants (1) 48:6,8;49:18;51:2,14, 24,25;29:14;33:3,4; 91:20;194:20 growing (28)

 118:18 23;55:7;60:13;63:19; 34:21;41:9,11,16; Greetings (1) 24:4;29:1,2;47:13;

gimmick (1) 71:13,15,19;72:1,8, 55:20;63:16,22; 9:16 49:5,7,22;58:21;

 186:15 13,18,21;73:11,24; 64:21;65:2;117:19; Greg (7) 75:25;76:4,5;91:12;

Ginny (6) 74:12;75:10;80:11; 129:22;130:15;142:4; 164:16;169:4; 121:24;142:11;143:6;

 60:9;72:3,5;74:5, 82:22;83:4,23;85:4, 144:19;148:6;149:16; 171:16,20,24;174:5,5 146:6;149:2;168:2; 

Min-U-Script® Burke Court Reporting & Transcription (17) generated - growing 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 2 

October 19, 2023 

173:24;177:25;

 187:25;188:2;189:3;

 190:17;194:19;

 196:11,25;211:11 

grown (14)

 17:6;45:13;83:3,9;

 129:6;136:12;153:7;

 166:23;188:6;199:5;

 223:1;228:21;237:13;

 244:13 

growth (8)

 16:2;79:24;84:22;

 122:2,6;165:11;

 178:8;244:7 

guarantee (4)

 32:7;48:14;112:18;

 202:17 

guaranteeing (1)

 138:24 

7:5;30:19;38:14;

 52:7,12,15;56:23,23;

 57:19;58:7;68:12;

 70:4,12;75:5;135:5;

 143:3,8;144:6,11,24;

 147:22;152:4;153:24;

 156:1;157:25;158:25;

 160:16;191:11,25;

 200:23;244:3;247:15 

Gwen (1)

 211:15 

Gwendolyn (9)

 191:13;194:9;

 200:24;201:8;206:2;

 207:13;209:5;217:1,

 13 

happened (6)

 23:23;46:12;92:19;

 126:5;141:20;195:10 

happening (14)

 29:10;30:14;31:2;

 60:4;62:14;63:18;

 67:19,20;109:4;

 122:22,23;133:23;

 168:5;208:21 

happens (5)

 29:7;110:16;

 115:17;136:7;210:21 

happy (16)

 59:12;68:13,16;

 71:18;77:9;98:20;

 102:8;106:6;157:24;

 161:23;164:10;

 175:20;203:19;

 222:21;231:16;

heal (1)

 52:24 

healed (1)

 52:22 

healing (1)

 52:25 

health (11)

 55:10;90:21;

 114:13;119:18;166:3;

 170:3;177:18;186:21;

 195:8;234:2;244:13 

healthier (1)

 47:23 

healthy (12)

 43:18,19,19;78:10;

 131:18;137:7,10;

 169:13;194:24;

 215:24;228:25;

 244:14 

heart (1)

 166:21 

hearts (1)

 27:7 

heat (1)

 78:22 

heated (1)

 31:12 

heath (1)

 189:2 

Heather (6)

 8:24;160:22;

 164:16;169:3,9;

 171:13 

heavily (7)

 126:23,24;128:12,

 13;130:25;136:13;

 187:16 

heavy (2)

H 

guarantees (2) hail (2) 242:18 Healy (2) 196:14;203:11 

53:12,13 38:8;39:7 hard (25) 7:11,14 hedge (3)

guess (24) hailing (1) 8:20;19:6;26:10,19, hear (50) 17:17;35:10,15 

22:3,13,16;23:2; 118:8 23;36:7,23;39:9;48:8; 7:2,6,7,8,9;10:23; hedging (1)

 34:17;37:11;38:7; hale (1) 54:19;61:8;70:24,25; 17:20,23;21:21,22; 130:12 

40:23;41:16;100:14, 23:3 96:3,10;142:8,11; 23:22;24:23;28:13; heeding (1)

 18;109:22;123:21; half (4) 149:6;160:11;186:8, 39:14;42:21;52:7,11; 21:5 

139:8;148:8,14; 37:21;141:10; 23;197:1;205:14; 53:17,18,20;54:12; Hello (13)

 150:20,21;152:8; 164:4;204:9 213:2;230:14 58:2;70:9;80:15; 7:14;9:17,22,23;

 160:6;209:10,13,17; hand (6) hardening (1) 90:17;94:25;109:10; 10:8,10,13;70:9;

 220:16 4:21;9:3;10:17; 205:14 113:19;115:14; 82:21,22;180:9;

guessed (1) 23:18;48:7;247:1 harder (1) 119:24;129:19; 216:3;243:19 

83:14 handbook (2) 18:4 133:14;137:21,23; help (56)

guidance (14) 203:2;206:22 hardest (1) 140:9;143:3;144:13; 14:6,12;22:18;23:6;

 12:14,21;43:21; handful (2) 234:19 147:15,19;149:22; 27:9;39:22;40:4;

 59:22;71:12;117:8, 195:6;212:15 Harrelson (1) 152:4;154:25;182:21; 43:21;44:3;46:7;

 14;189:8;203:2,7,17; handle (2) 20:11 218:15,19;225:6; 51:14;52:19;53:21;

 214:3;226:4;235:6 106:21;155:22 Harriet (11) 226:10;236:2;243:18; 55:12;56:6,8;58:7;

guide (5) handled (4) 75:8;80:5;86:6,9, 246:14 62:1;63:12;73:9,10;

 125:20;202:12,13; 78:16;131:9; 10;88:14,16;90:1,17; heard (43) 92:2;101:10;118:2;

 213:6;225:4 155:25;225:17 94:13;104:11 10:3;18:13;20:5,19; 123:14;164:7,8;

guiding (1) handler (1) harvest (17) 45:6,8;46:21;50:4; 165:19;166:22;167:3,

 224:14 216:18 37:6;72:1;101:15, 57:14;62:2;74:7; 4;168:8;173:17;

Gulf (1) handlers (6) 17,18,20,22;129:10; 88:25;108:7;110:13; 174:7;183:7;202:16;

 116:5 43:7;61:19;111:19; 142:21;149:24; 124:11;127:18; 208:11;209:20;

gullies (1) 214:25;216:11; 151:22;159:8;160:15; 130:25;140:13; 211:20;212:8;213:6,

 116:1 225:11 173:20,21;233:16; 142:20;143:11; 6;220:2;222:21;

Gum (2) handling (2) 247:12 144:18;149:10;159:5; 228:1;234:21;237:10,

 107:16,17 103:12;170:13 harvested (4) 166:23;180:9;182:16; 11;244:9,11,15,20;

gumption (1) hands (1) 35:15;101:19,23,23 192:1;197:6,24; 246:2,21,24;247:1 

107:19 178:18 harvesting (1) 200:5,13,15;203:3; helped (4)

Gump-tion (1) Hang (2) 107:7 204:1,3;205:11; 21:11;43:6;111:7;

 107:18 42:23;216:5 harvests (1) 206:9;220:1;227:25; 170:20 

gums (2) hanging (1) 23:21 228:14;236:7;239:9; helpful (12)

 107:19,21 247:10 Hawkins (7) 247:5 12:15;17:22;47:11;

Gunther (10) Hanson (8) 213:18;216:1; hearing (16) 61:16;119:4;135:4;

 137:20;140:16; 86:8;94:18,23; 221:6,13,18,19; 10:25;52:10;56:8, 157:16;194:3;199:10;

 143:1,3,5,5;144:22; 102:21,24;104:16; 227:10 16;71:21;79:25; 219:14;236:11;238:2 

145:25;146:18; 108:18,19 head (1) 124:13;137:8;149:3; helping (7)

 147:22 happen (10) 64:4 185:22;198:24; 27:13;39:2;58:12;

guy (4) 50:18;91:9;92:10; headache (1) 205:19;209:7;221:1; 101:6;169:14;181:8;

 20:6;77:15;158:14; 97:10,12;133:4; 60:3 232:22,23 211:20 

197:18 136:8;149:15;156:14; heads (1) hearsay (1) helps (7)

guys (32) 176:11 71:23 135:2 40:9;55:13;118:11; 

Min-U-Script® Burke Court Reporting & Transcription (18) grown - helps 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 2 

October 19, 2023 

199:18,23,24;217:12 

hemp (3)

 27:11,13;244:22 

hens (1)

 177:20 

herbicide (2)

 120:2;123:8 

herbicides (3)

 53:13;123:25;

 182:10 

herbs (1)

 52:24 

Here's (2)

 11:6;72:25 

hesitation (1)

 11:15 

hexane (6)

 132:16;153:16,17,

 20:3 

hire (1)

 154:10 

hirers (1)

 225:11 

historic (1)

 220:20 

historically (3)

 13:17;147:2;228:20 

history (10)

 10:23;39:19,20,24;

 40:3;125:19,20;

 126:9;142:8;219:23 

hit (16)

 6:19;19:22;20:13;

 38:1,13,16,25;40:7;

 61:3;145:9;171:7;

 179:12,18,19;180:6;

 22:22;76:11;77:8;

 113:3;135:4;149:18;

 160:18;191:23;

 210:18;231:19 

hoping (1)

 222:16 

horizon (1)

 82:9 

host (2)

 6:13;179:15 

hour (6)

 4:4;22:7;138:21;

 164:4;169:2,3 

hours (2)

 30:15;103:2 

house (3)

 43:15;62:8;65:20 

housekeeping (1)

 177:25 

hydrolyzed (1)

 121:12 

Hydroponic (17)

 88:7,9;121:12,14,

 16,24;170:18;177:14;

 196:5;198:13,23;

 199:5,6,7;223:5;

 234:25;240:2 

hydroponics (9)

 175:10,17;190:5,6,

 20;195:5;197:10;

 198:3;199:2 

hyper (1)

 199:7 

ill (1)

 183:19 

Illinois (3)

 140:20;141:3;142:9 

illusion (1)

 118:18 

illustrate (1)

 234:4 

imagine (1)

 107:25 

imagining (2)

 97:15;129:4 

immediate (1)

 131:16 

immune (1)

 130:22 

impact (11)

 118:14;133:2,3;

I 

17;155:15,16 215:12 11:5 ice (1) 138:3;168:16;195:4;

Hey (14) hitting (2) HS (3) 167:12 215:10;225:10;226:5;

 10:12;14:21;73:4, 186:22;224:18 61:20,25;62:5 idea (11) 232:1;242:8 

23;74:13,16,21; Hobbs (14) hub (1) 33:20,21;57:18; impacted (5)

 99:22;101:25;137:15; 72:4;75:7,10,11; 112:15 97:11;141:1;149:13; 131:3;144:19,21;

 145:22;154:6;176:21; 77:7,15,18,23;78:4, huge (14) 174:5;184:21;219:8; 224:23;225:14 

216:5 25;79:7,14;80:1,3 36:11;38:25;39:11; 223:23;239:15 impactful (5)

Hi (31) hold (5) 50:19;55:2,18;121:2; ideal (2) 23:25;203:15;

 9:13,18,24;35:5; 7:19;18:24;179:4,7; 145:9;154:18;175:14; 24:17;235:15 204:21;215:4,8 

40:14;52:7,9;63:2; 224:16 177:2,5;211:1;215:22 ideally (2) impacting (1)

 72:5;86:10;100:1; holding (5) human (5) 24:20;185:15 26:22 

111:5;113:2;119:12; 22:13,24;206:16; 59:11;74:8,8;159:4; ideas (10) impacts (3)

 129:19;140:19; 221:9;247:1 170:3 43:16;71:13,15; 170:4;191:19;

 147:25;150:8;155:1; holds (1) humane (1) 102:5;106:9;111:22; 242:12 

164:19;180:8;191:15; 208:23 222:8 158:25;187:3;218:2; implement (9)

 194:10;203:25; holistic (2) humbled (1) 228:2 44:1;45:22;87:3;

 207:13;209:5,6; 52:20;183:9 44:19 ideate (1) 96:15;214:4;225:24;

 216:2;218:11;221:18; Holm (1) humid (1) 211:22 239:5;242:3,7 

238:11 8:22 49:19 identical (1) implementation (7)

high (9) home (8) hundred (1) 36:1 202:21;217:6;

 47:14;52:17;137:1; 53:23;56:1;121:19, 242:1 identifiable (1) 225:8,10,14;226:1,3 

183:14;185:10;207:9; 19;167:8,9,15;226:23 hundreds (3) 13:2 implemented (7)

 230:12;244:20; homeschool (3) 34:9;43:7;236:22 identification (4) 12:14;37:2;46:2;

 245:12 52:16;55:14;57:15 hunt (1) 87:4;117:2,11; 104:11;182:9;239:9,

higher (10) homesteaders (1) 53:3 170:8 15 

44:13;83:15;94:4; 169:19 hurt (1) identified (4) implications (2)

 97:25;112:13;115:22; honest (4) 29:5 67:15;88:8;162:19; 157:5,6 

121:22;122:6;123:7; 41:21;62:21;64:20; hurting (1) 224:3 imply (1)

 225:22 92:5 143:18 identify (5) 193:13 

highest (3) honestly (4) hurts (1) 103:16;117:21; import (18)

 83:7;130:7;235:12 17:9;41:4;52:25; 195:22 118:2;163:13;214:17 28:13;30:7;31:7;

highlight (5) 150:18 husband (2) identifying (4) 61:21,22;66:4;68:4;

 159:12;165:25; hook (1) 182:25;186:5 112:23;163:3; 134:6;138:3;152:22;

 169:22;170:22; 142:24 Huseman (27) 202:24;204:5 153:2,20;225:11;

 211:18 hop (1) 9:19,20;35:5,25; idle (2) 239:14,17,22,25;

highlights (1) 51:21 36:12;40:14;41:5; 27:4;31:11 240:3 

165:22 hope (9) 79:2,11,21;98:25; idling (2) importance (7)

highly (3) 82:8;94:20;137:1; 134:22;135:10,20; 27:4;30:23 62:9,12;161:1,2;

 130:14;131:18; 167:11;170:14;171:4; 136:9,15,18;137:14; IFPA (5) 163:19;183:3;222:3 

223:4 225:6;233:18;246:2 146:20;147:17;155:1, 81:10;241:5,9,17; important (35)

high-profile (1) hopeful (6) 17;157:9;207:13,16, 242:13 7:24;34:8;45:22;

 130:16 163:14;176:25; 25;209:2 ignore (2) 97:4,5,6;112:19;

high-risk (2) 177:1;209:13;211:13, hybridization (1) 86:20;110:11 122:1;133:12;139:3;

 202:24;215:1 14 91:1 ignored (1) 146:11;148:6;151:3,

highways (1) hopefully (10) Hydro (1) 86:24 16;158:15;165:12; 

Min-U-Script® Burke Court Reporting & Transcription (19) hemp - important 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 2 

October 19, 2023 

172:7;180:15,17,19, 70:17;105:9; indiscernible (1) influencer (2) inputs (11)

 25;181:3;183:4; 111:21;161:24 140:1 20:12,15 28:10,11;47:14;

 184:5;196:3;202:25; includes (2) indispensable (1) influencers (1) 78:3;124:2,3,6;147:7;

 205:22;206:15;208:3, 161:8;203:10 243:3 55:11 245:11,13;246:12 

11;211:11;218:5; including (11) individual (7) influx (1) inquire (2)

 227:1;235:16;237:3 43:8;52:24;71:14; 11:13;51:9;106:8; 14:3 86:21;114:17 

importantly (1) 72:16;81:21;166:2; 122:17;163:7;193:11, info (3) inquiries (1)

 98:10 170:4;183:13;187:15; 17 68:10;70:2;158:3 134:1 

imported (10) 189:15,21 individualized (3) inform (2) Insect (2)

 60:18;117:19; inclusion (1) 192:17;193:1,21 87:22;234:2 75:13;78:2 

131:13;136:20;138:6; 76:22 individually (6) informal (1) insecticides (1)

 143:10;145:15; inclusive (1) 50:6;105:12,13; 100:10 182:10 

149:13;182:3;184:3 189:13 109:12,21;192:20 information (47) insects (6)

importer (3) inclusivity (2) Individuals (2) 8:4;12:24;17:9; 75:25;76:1,2,10;

 63:15;155:2,20 80:25;121:5 11:11;122:17 18:5;21:11;42:6;53:2, 78:8,17 

importers (2) income (1) industrial (3) 6;55:25;56:5;75:3; inserted (1)

 154:14;239:13 230:10 191:19;228:20; 88:22;101:21;106:2; 92:17 

importing (4) inconsistencies (1) 229:23 110:15;117:4;118:4, inside (1)

 26:13;29:2;127:14; 234:23 industrialization (1) 7;135:5;142:18; 199:25 

144:7 inconsistency (2) 175:12 149:11;155:19; insight (2)

imports (34) 223:12;234:24 industrialized (1) 157:12;164:5;172:19; 147:6;230:21 

25:23;26:2;27:7; incorporate (2) 175:9 180:16,18,24;181:1; insights (2)

 28:11;29:5,7,20,24; 120:13;124:15 industry (59) 207:23;208:4,7,24; 113:5;227:22 

30:6,12;31:8;41:10; incorporating (1) 27:12,13,13,14; 210:3,9;211:4;212:9; inspect (1)

 60:24;66:3;117:18; 236:14 29:7;31:6;57:12;58:7; 213:5,9;214:7,20; 32:23 

131:1;133:5,16; incorporation (1) 59:25;75:20;76:4,21; 227:20;236:4;237:19, inspecting (2)

 144:19,21;148:15; 120:15 78:2;79:5;81:18,24; 21,23;238:1 34:3;205:20 

149:3;152:13,25; increase (14) 82:8,13;100:25; informative (1) inspection (8)

 153:1;154:21;158:15; 18:21;29:20,20; 120:20;121:12,14,16; 172:16 33:25;90:22;92:4;

 159:22;180:20;181:6; 43:12;137:5;206:7; 122:23;125:25;126:2, ingesting (1) 112:1,22;205:10;

 206:10;209:8;215:5; 207:20;208:20,20; 6,6,13,19;128:5,5,10, 52:21 214:15;215:13 

245:1 215:5;226:2;237:3; 11,16;130:20;152:8, ingestion (1) inspections (13)

impossible (1) 241:15;245:25 18,19;157:17;164:6; 184:22 32:22;34:1;99:13,

 87:21 increased (8) 165:9;171:23;175:4, ingredient (5) 14;101:8;159:12;

impressed (2) 96:7;204:25;207:3; 14,23;187:23,25; 79:18;130:7,8; 204:18,19,22;205:7;

 8:25;243:22 210:12;211:1;215:1; 194:18;203:17;205:1, 192:16,24 215:11;236:22;

impressive (2) 225:18,21 1;206:19;220:12; ingredients (13) 237:17 

225:3;229:6 increases (1) 222:10;228:20;229:9; 51:1;76:3;113:12; inspector (6)

improve (5) 214:22 230:18;244:22 114:12;131:13;163:9, 89:21;97:15;112:6,

 96:11;140:23; increasing (10) industry-wide (1) 12;169:24;191:24; 10;159:4;215:14 

234:22;240:6;241:15 15:4;43:2;81:13; 82:11 192:3,5,6,21 inspectors (14)

improvement (2) 82:1;100:25;118:6; inefficiency (1) inherently (2) 13:3;101:11;

 80:23;159:4 165:14;206:20;207:1; 58:24 105:14;188:13 117:12;158:18,18,21;

improvements (3) 244:18 inequality (1) initial (1) 159:16,20,23,25;

 12:10;101:4;206:23 increasingly (1) 224:23 75:20 160:8,10;170:9;

improving (4) 64:6 inert (18) initially (1) 180:17 

13:7;168:9;195:8; Incredible (1) 51:1;105:8;110:8, 76:7 inspector's (1)

 244:12 220:8 15,18;113:11;114:2,4, initiate (1) 13:5 

inadvertent (1) incredibly (6) 14;169:24;190:18; 103:10 inspects (1)

 109:3 62:18;69:17; 191:24;192:3,5,6,15, initiative (5) 78:9 

inadvertently (1) 151:16;196:12,22,25 21,24 165:6;166:11; inspire (1)

 106:22 independent (1) inerts (15) 168:3;176:25;235:15 115:13 

incentive (1) 143:16 43:23,23;50:5,7,17, initiatives (1) inspired (1)

 145:18 India (2) 25;103:8;105:12; 150:10 108:2 

inches (4) 69:1,6 109:12,21;110:12; innovation (1) inspiring (1)

 23:7;124:12,16; Indian-origin (1) 114:7;170:2;192:20; 59:14 57:2 

196:14 134:2 193:25 innovative (2) instance (4)

inching (1) indicate (2) inflation (1) 82:3,10 60:22;113:14;

 25:6 11:24;63:7 64:7 in-person (1) 136:10,11 

include (6) indicated (3) influence (1) 5:21 instances (3)

 42:6;76:25;113:16; 241:21,23;242:2 118:14 input (5) 93:1;131:12;133:16 

170:3;233:24;238:18 indifferent (1) influenced (1) 51:17;77:22; instant (1)

included (4) 74:19 126:24 120:11;145:4;163:25 243:24 

Min-U-Script® Burke Court Reporting & Transcription (20) importantly - instant 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 2 

October 19, 2023 

instantly (1)

 126:1 

Instead (2)

 192:6;240:4 

Institute (3)

 116:24;167:16;

 174:24 

institution (4)

 19:6;65:7;66:11;

 172:3 

institutional (1)

 18:17 

institutions (1)

 18:20 

instruction (5)

 4:7;74:24;203:2,8;

 206:21 

instructions (1)

 4:7 

instruments (1)

 66:8 

insufficient (1)

 193:24 

insurable (1)

 150:14 

insurance (76)

 16:17,19;17:4,11,

 13,14;22:3,11;23:1,

 12,14,24;24:7;35:11,

 13,19;36:9;37:18;

 38:3,17;39:8,16;40:8,

 15;41:9,21;72:6,12,

 15,16,23;74:14,21;

 125:13,14,14,17,19,

 19;126:2,5,13,22;

 127:5,9,11;128:4,13,

 67:19;71:2,17;82:17;

 86:12;102:14;112:18;

 121:22;122:2,6;

 137:1;143:18;169:20;

 178:7,14;191:21;

 193:3;195:25;201:11;

 211:10;214:2;215:3;

 238:23;239:1;240:7 

intended (1)

 225:21 

intends (1)

 214:8 

intent (2)

 198:1;217:22 

intention (1)

 218:25 

interaction (2)

 133:19,22 

interactions (1)

 133:21 

interest (7)

 79:9;134:1;163:24;

 191:16;235:13;241:6;

 247:3 

interested (10)

 15:22,25;17:4,7,21;

 52:17;68:4;71:10;

 228:3;242:18 

interesting (4)

 32:16;58:14;76:6;

 133:13 

Interestingly (1)

 240:2 

interests (1)

 121:16 

internalizing (1)

 119:20;120:16;

 123:20;124:15;126:1,

 16,23;127:24;128:11;

 130:10;131:9;132:23;

 135:5;139:14;141:6;

 144:7;150:17;151:9;

 153:12;161:8;163:17,

 18;168:2;180:24;

 185:17;186:9;188:1,

 5,18;195:5,9;197:16;

 210:9,22;211:10;

 212:20;213:10;225:5;

 227:14;234:6;236:23;

 245:16;247:3 

in-transition (2)

 43:16;46:2 

intrigued (1)

 164:5 

intro (1)

 138:1 

introduce (1)

 75:19 

introduced (3)

 56:21;172:18;

 188:14 

introduction (1)

 75:21 

invest (1)

 97:21 

invested (2)

 67:11;187:16 

investigation (1)

 69:1 

investigator (1)

 116:23 

investing (1)

 23:5 

Island (4)

 8:2;77:9;247:19,23 

issue (42)

 14:24,25;45:22;

 59:1;64:24;71:11;

 74:6;82:10;83:22;

 87:2;88:5,9,12;92:7,

 8;99:7;107:5;117:8;

 123:3;154:1,17;

 159:21;160:18;

 170:25;178:16;181:2;

 182:20;191:23;192:3;

 208:3;215:14;221:23;

 222:1,17,21;226:9;

 232:3;237:18,19;

 239:22,25;243:9 

issued (1)

 214:16 

issues (17)

 11:17;30:19;70:18;

 86:15;89:21;108:20;

 117:1;131:15;146:9;

 174:2;180:9;189:22;

 195:3;219:22;222:3,

 15;224:24 

Issuing (1)

 240:5 

item (4)

 96:5;106:25;

 222:23;223:16 

items (2)

 93:13;169:22 

199:12;200:17 

Jerry (14)

 9:15,17;32:12;45:2;

 48:1;82:19,22;85:17;

 189:23;197:8;203:23,

 25;205:24;242:23 

Jerry's (1)

 202:4 

jest (1)

 97:9 

Joanna (1)

 8:22 

job (11)

 11:14;67:17;82:23;

 159:17,20,24;160:2;

 212:1;215:22;232:14;

 243:2 

jobs (2)

 44:18;117:12 

Joel (1)

 236:14 

Johnson (11)

 9:21,22;18:10;

 92:22;93:21;94:11;

 123:1;162:12;167:20;

 219:18;227:12 

join (5)

 95:7;118:3;147:19;

 197:7;233:16 

joining (18)

 23:20;57:9,14;

 82:19;137:18;147:18;

 150:9;159:7;168:24;

 171:12;174:8;176:16;

 191:9;193:6;198:21;

 218:11;236:1;240:12 

J 

24;140:22,25;141:8, 115:23 59:5 Jack (9) joint (1)

 18,21;142:19;148:14, International (7) investment (5) 147:24;151:25; 184:9 

16;149:1;150:12,23; 81:9;133:21;134:1; 58:12;77:4;159:3; 158:7,8,9,11,12; joke (3)

 172:3,9,10,12,14; 135:6;136:25;238:12; 168:19;244:12 159:7;160:12 107:13,25;199:12 

173:5,14,14,18,19,24; 241:1 investments (4) Jackie (5) jokes (1)

 231:6,10,12;234:11; internationally (1) 25:24;27:11;166:8, 194:9;200:25; 108:2 

238:2 159:11 12 213:18,19,20 joy (1)

insure (5) interpret (2) investors (1) jaded (1) 10:18 

73:3,10;118:12; 96:16;225:24 64:21 200:7 juice (1)

 126:15;150:20 interrupt (1) involved (5) jail (1) 150:21 

insured (5) 227:8 103:4;124:23; 65:12 jump (9)

 24:12;126:16; inters (1) 152:8,18;154:3 Jared (1) 48:1;179:24;180:1;

 127:24;129:6;148:3 193:14 Iowa (7) 8:22 182:19;198:18;

insurers (3) intersections (1) 25:15;52:14; Jason (1) 226:18;227:6;233:6;

 126:25;128:14,22 99:12 158:13;174:16; 20:10 246:17 

insures (1) into (86) 184:24,24;229:17 Javier (2) jumping (1)

 127:12 8:20;18:14,18;22:1; Irlbeck (18) 10:13,15 247:3 

insuring (1) 25:24;27:11,12;28:8, 21:18;25:12,14,15; Jaydee (7) June (2)

 141:13 17;29:14;31:4,5,21; 28:18,23;29:25;31:3, 86:8;94:18,23; 50:24;217:1 

intake (1) 35:20;37:24;45:24; 19;32:6,24;33:17; 102:21,22;104:15; jurisdiction (1)

 97:16 50:14;51:7;58:11; 34:7;35:11;36:6,13, 108:18 113:23 

integral (1) 59:8,12;67:5,6,11; 20;37:7 jazzed (1) justice (1)

 195:9 72:9;76:3,24;79:5,6,8, ironically (1) 209:9 234:9 

integrated (2) 13;84:6,25;85:20,20; 97:2 Jeffery (11) justify (1)

 168:2,4 92:6;93:2;100:20; irrigated (1) 9:8,9;54:15;90:17; 141:21 

integrity (28) 103:13;105:18; 37:23 92:1;115:8,11; Justin (10)

 43:2;61:9;63:25; 106:11;112:3;117:19; irrigation (1) 116:15;122:10; 52:1,5;57:22;60:9; 

Min-U-Script® Burke Court Reporting & Transcription (21) instantly - Justin 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 2 

October 19, 2023 

70:6,7,8,12;71:24,25 

K 

9:19,21;32:12;35:4;

 40:13;41:17;79:1;

 98:24;99:3;134:21;

 146:19;154:25;

 200:25;201:14;

 207:12;213:18;

 215:25;216:4,5,7;

 218:9,11;219:10,15,

 20;220:20 

Kim's (2)

 41:8;108:2 

kind (68)

 10:3;15:23;17:17;

 18:21;20:2;22:4,13,

 23;24:2;35:5,9,19;

 41:17;44:7;46:22;

 57:6;58:14;59:3;

 63:23;66:5;67:1,25;

 68:9;79:5;84:22;

 89:23;90:24;93:13;

 98:21;108:22;113:18;

 114:22;115:1;123:16;

 126:7,19;127:9;

 137:25;145:16,17;

 146:1,5,6;148:2,24;

 149:17,25;151:1;

 152:14,23;153:9;

 156:25;157:11;

 163:22;164:1,5;

knowledgeable (4)

 89:2;126:18;

 158:14;236:9 

known (7)

 12:8;52:6;71:9;

 107:12;147:13;

 178:10;193:25 

knows (4)

 41:14;65:4;110:23;

 152:21 

Kris (1)

 142:23 

Kristopher (4)

 137:19;140:16,18,

 19 

Kroger (1)

 212:17 

Kumar (1)

 8:24 

Kyla (9)

 9:23,25;62:25,25;

 99:25;209:4,6;

 231:22;233:3 

Kylie (7)

 37:9;42:16,19;

 51:25;52:6,9;56:19 

36:5;192:14 

Ladies (1)

 201:21 

lading (4)

 61:23;62:16;64:13;

 156:23 

Lady (2)

 194:12;195:10 

laid (2)

 196:15,19 

land (26)

 13:10,10,11,12,15,

 16,19,23;14:12;31:16,

 17,20;32:8;46:16;

 47:4;100:18;115:13;

 120:3,4;121:25;

 143:25,25;144:19;

 147:7;194:25;198:14 

landfill (3)

 84:3,8,10 

landfills (2)

 44:16;161:9 

landing (1)

 210:11 

landowners (3)

 31:21,25;32:2 

language (3)

 90:1;93:4;192:18 

large (18)

late (4)

 79:9;95:15;175:3;

 194:13 

lately (1)

 27:11 

later (4)

 38:16;48:12;69:7;

 181:10 

launch (2)

 126:15;128:1 

launched (1)

 43:5 

launches (1)

 127:24 

law (9)

 65:10;70:25;71:1;

 119:20;177:12;191:2;

 195:9;216:21;239:6 

laws (1)

 35:1 

lax (1)

 26:6 

layers (2)

 123:19,21 

lead (5)

 27:9;33:18;88:25;

 215:23;236:10 

leader (1)

 165:9 

Kahn (1)

 167:16 

Kate (6)

 216:1;221:6,13;

 224:4,8;229:5 

Katie (1)

 233:2 

Katner (1)

 86:7 

Keegan (13)

 143:2;147:24;

 151:25;152:4,4,7,7;

 155:4,23;157:13,22,

 24;158:6 

keep (40)

 6:3;11:15;20:21,24;

 25:6;31:11,11;33:14;

 48:4;52:4;65:10;68:9;

 69:8;75:3;82:1;97:4;

 105:21;109:2;115:24;

 116:4;127:17;146:20;

 149:3,17,17;154:24;

 164:4;168:9,23;

 174:7;198:19,20;

 200:11,12;203:12;

L 

204:24;215:8;227:19; 166:20;167:10;168:7, lab (5) 46:16;66:18;71:8; leaders (2)

 245:7;247:15 12;175:1;186:7; 154:10;155:8,9,14; 87:14;124:23;130:20; 13:20;82:10 

keeping (17) 196:16;206:5;212:16; 156:21 136:23;158:19,23; leadership (4)

 96:7,25;97:1;98:2; 213:2;227:13;236:8 label (21) 160:9;212:14,17,24; 92:23;167:23;

 99:23;100:11,19,20, kinds (1) 43:16;45:4,6,10,23; 229:23;234:9;239:13; 224:22;247:12 

25;112:7,25;116:11; 120:19 46:2;53:11,12,13; 241:20;242:1 leading (4)

 172:4;205:13;225:18, Kirsten (12) 61:9,10;67:12;71:3; largely (1) 18:11;134:24;

 21;239:10 174:12;176:19; 122:3;165:25;167:2; 53:18 136:19;164:23 

keeps (1) 178:24,25;179:2,11, 170:17;176:4;184:9; larger (5) leads (1)

 167:21 14,16,25;182:20,24; 200:9;202:5 89:13,15;135:8,16; 82:24 

Kempner (4) 184:19 labeled (4) 167:10 leafy (1)

 80:9;94:18,23;95:6 kit (2) 59:8,10;61:22; large-scale (2) 194:20 

kept (2) 165:21;201:25 90:23 159:19;181:25 leaning (1)

 20:23;170:1 Klokkenga (5) labeling (10) largest (3) 188:1 

Kerts (1) 137:20;140:16,19, 44:14;113:23; 79:15;213:3;216:24 learn (6)

 236:14 19;142:22 183:3,20;184:8; larva (1) 19:20;53:10;56:25;

key (7) knew (6) 186:14,15;244:10; 76:2 59:7;219:14;240:14 

18:24;61:13; 17:21;68:19; 245:5;246:3 last (36) learned (3)

 112:23;201:24;229:2; 152:17;156:14; labels (6) 8:3;10:20;14:8; 56:24;75:15;172:4 

241:19;245:8 172:25;245:4 53:23;114:1;118:7; 15:10;21:6;26:14; learning (2)

kick (4) knock (6) 122:5;195:18;222:14 27:10,10;38:8,10,14; 218:14;232:11 

12:6;14:19;67:21; 107:13,13,13,13,24, labor (5) 39:7;60:18,22;67:9; lease (2)

 115:4 25 144:5;145:4;147:7; 88:19;89:1;119:15; 31:17,19 

kicking (1) knocked (1) 242:2;244:16 125:9;129:7;138:5; least (15)

 12:3 129:9 labs (6) 150:22;158:14; 16:22;53:15;63:12;

kids (9) knocking (1) 154:13;155:5; 161:25;172:5;198:2; 66:21;70:21;75:20;

 52:16;53:22;57:16; 186:13 156:14,18;203:4,17 204:1,10;210:20; 76:7;114:6,16;

 183:12,19;185:8; knowing (6) lack (15) 226:21;228:1,12; 117:24;191:5;200:15;

 226:19;227:8,9 30:14;34:17;106:1; 26:5,8,11;28:23; 230:7;243:16;244:5; 204:13;243:16;

kill (1) 109:4;158:23;172:23 58:18,22;73:14; 247:8 246:23 

19:3 knowledge (7) 74:11,16;121:1; lastly (1) leave (2)

killing (1) 17:10;49:13;87:6; 135:1;139:10;181:20; 13:4 41:24;44:23 

215:23 91:10;113:14;128:18; 222:7;242:10 lasts (1) leaves (1)

Kim (26) 154:13 lacking (2) 171:1 225:17 

Min-U-Script® Burke Court Reporting & Transcription (22) Kahn - leaves 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 2 

October 19, 2023 

leaving (1) life (8) listed (10) loan (3) 191:20 

194:25 26:4;39:15;52:20; 50:6;51:5;101:22; 127:7;172:3;231:1 look (48)

led (2) 54:4;67:11;122:12; 105:12,13,15;106:13; loans (1) 18:20;20:8,9;26:23;

 216:23;223:11 125:18;186:6 109:12;110:20,20 231:1 31:9;34:14;49:13;

left (3) lift (1) listen (5) lobbied (1) 52:15;57:15;60:21,

 6:16;19:6;216:22 185:23 55:9;156:4;157:2; 239:16 25;67:8,12;75:22;

legal (5) light (4) 235:22;236:16 lobby (2) 76:20;77:3,8;78:23;

 59:23;88:24;89:6; 39:5;64:18;69:10; listened (1) 121:2,6 79:22,24;92:6;

 118:8;236:9 197:5 55:10 lobbying (3) 104:18;110:20;

legalities (1) lighting (1) listening (6) 175:14,15,16 114:11;116:6;118:5;

 208:17 128:3 25:2;62:2;138:2,20, lobbyists (1) 123:22;130:11;

legislature (1) Liked (2) 20;243:7 175:15 136:19;152:23,25;

 182:5 56:16;173:3 listing (9) local (5) 153:18;158:4;162:6;

legit (1) likely (6) 51:8;101:23; 138:7;169:15; 174:18;189:19;

 182:12 25:20;33:2;60:25; 105:16;193:11;214:9; 199:7;229:21;245:8 199:23;202:9;203:17;

legitimate (1) 96:19;182:12,12 217:17;218:1;241:9; locally (1) 206:22;207:23;208:5,

 53:3 likes (1) 242:15 246:9 5;212:11,13,23;

lending (5) 220:7 listings (1) locate (5) 223:18;228:3 

30:19;56:20;65:24; Lily (8) 106:8 6:1;87:12;93:18; looked (3)

 133:11;144:16 213:18;216:1; Lists (5) 214:14,17 50:16;103:24;139:2 

lens (2) 221:5,13,17,19; 51:5;109:14;110:6; located (2) looking (36)

 146:23;162:4 223:21,22 193:12,18 184:20;187:14 11:3;20:9;24:17;

less (19) lime (1) literally (3) locating (1) 27:17;41:9;58:13,20;

 18:5;20:19;22:11; 81:6 48:12;53:11;138:6 99:6 62:20;71:12;76:10,

 27:4;29:4,22;34:4; limit (4) litter (2) location (18) 18;77:1,5,21;79:6,7;

 38:5,19;45:17;49:21; 78:12,13;192:12; 139:25;140:3 13:2;20:24;36:21; 84:6;97:16;113:3;

 68:22;91:20;98:19; 224:21 little (52) 68:3;87:4;88:21; 122:3;128:17,17;

 99:10;124:12;126:18; limited (5) 5:2;11:4;12:18; 89:12;90:11;93:7; 134:14;158:23;162:4;

 145:3;235:15 16:3;23:11;45:23; 30:1;31:1;33:19; 117:4;149:11;170:7; 163:11,20;198:11;

Lets (1) 223:11;241:12 36:24;37:2,14;39:2; 180:16,23,24;214:16; 208:10;209:1;212:6;

 169:2 line (12) 48:25;57:1;60:21; 222:18;236:4 219:6;220:2;227:18;

letter (4) 6:6,23;23:16;42:17; 66:6;88:20;89:14,21; locations (11) 228:1;237:10 

70:25;74:2;154:6; 50:21;52:2;54:14; 90:4,19;93:5,10; 61:15,16,18;87:9; looks (4)

 178:11 57:23;157:6;230:25; 95:22;99:9;100:4; 92:24;93:9;94:7; 164:1;180:8;214:5;

letters (1) 231:4,20 108:10;124:15; 125:9;170:9;214:21; 233:5 

72:19 linear (1) 125:12,15,17;128:3; 234:14 loophole (4)

letting (1) 161:11 134:3;141:11;142:7; log (1) 33:8;68:5,7,18 

128:20 lines (3) 143:11;148:8;149:17; 5:14 loopholes (1)

lettuce (4) 127:8;151:7;203:7 150:17;157:10;158:2; Logan (11) 61:13 

194:21;199:4,5,5 link (1) 162:15;183:1;185:1; 10:6,8;14:19;16:11; lose (11)

level (15) 122:20 191:22;200:7;208:17, 18:11;45:1,21;48:7; 26:17,18;27:4;

 23:13;26:15;29:10; linking (1) 17;209:11,11,18; 54:24;95:17;145:21 38:20;97:2;178:19;

 31:2;98:13,14; 168:7 217:4;218:4;232:24 Logan's (1) 196:1;197:25;204:16;

 100:25;131:8;143:20; Linley (11) little-known (1) 28:4 225:20;226:7 

144:6;147:3;170:23; 104:23;116:20; 206:15 logged (1) losing (5)

 173:5;197:24;223:14 119:9,11,12;122:7,8, live (5) 148:5 38:20;65:16;107:4;

levels (4) 10;123:2;124:9,25 4:17;38:17;108:1; logo (1) 122:21,24 

24:7;78:20,20; liquid (3) 201:24;229:16 14:16 loss (5)

 183:14 81:5;107:8,10 lived (2) long (11) 14:12;34:12,13;

Lewis (22) list (51) 33:8,9 27:2;29:7;30:15; 47:4;82:12 

9:25;10:1;48:2; 6:2;43:10;44:19; livelihoods (1) 95:11;103:2;104:18; losses (1)

 50:3;77:16,20,24; 50:5,7,8,10,16,16; 61:9 117:17;127:16; 70:22 

78:23;84:21;85:22; 51:10;81:7;86:18; livestock (6) 193:22;220:22;245:6 lost (7)

 86:1;109:10;131:24; 105:13,14,14,17,18; 77:25;79:13,15,23; longer (4) 22:8;50:19,19;

 132:3;157:15,23; 106:3,13;109:11,14, 86:22;215:9 129:24;141:9; 136:18;195:22;196:2;

 163:22;167:7;191:1; 19,20,21,23,24;110:6, livestream (1) 195:2,20 229:21 

193:7,8;194:3 8;111:1;113:25; 8:2 long-recognized (1) lot (116)

liability (2) 114:3,16;135:24; living (2) 165:7 14:23;15:1,21;

 17:12;208:16 162:5;164:3;170:1,2; 177:12;202:13 long-term (3) 18:25;20:1;25:20,20;

liable (1) 180:4;182:10;189:6, LLC (1) 31:6;47:17;77:4 26:10,18,19;27:1,2;

 136:2 10;192:8,23;193:10, 95:24 longtime (1) 28:8,9,12,13,14,16;

lie (1) 13,18,22,24;217:18; loads (1) 86:12 29:12,13,16,23;31:8,

 136:25 242:11,15 229:18 long-time (1) 21;32:20;35:18; 

Min-U-Script® Burke Court Reporting & Transcription (23) leaving - lot 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 2 

October 19, 2023 

36:22;41:11;46:21;

 47:2;55:10,16,17;

 59:9;61:24;62:2;

 75:15;76:15;79:9,24;

 82:24;85:25;89:20;

 100:9;101:15;104:8;

 108:15;109:20,20;

 110:13;111:11;115:9,

 14,15,16;122:14;

 126:18;132:24;

 133:14,24;134:7;

 136:22;138:9;139:6;

 143:7,9;145:14;

 146:12;148:16;149:8,

 15;151:9;152:16,18,

 22,24;153:2;158:18;

 159:3,22;160:9,17;

 162:25;166:25;

 168:15;191:25;

 197:24;199:3;204:1,

 16;206:24;207:17;

 208:7,15,16,16,23;

 211:13;216:13;

 218:24;219:5,5,10;

 220:21;226:11;

 228:12,19,19;230:2,4,

 17;231:11;235:14;

 246:22;247:2,3 

lots (7)

 48:4;109:17;

 124:23;154:19;

 158:25;209:8;227:8 

loud (4)

 49:10;58:3;71:22;

 140:9 

love (18)

 14:16;17:25;42:6,

 11;54:6;56:23;59:15;

 64:21;70:1;102:19;

 113:19;114:9;168:4;

 184:8;213:12;218:15;

 226:19;235:6 

low (9)

 10:2;47:13;99:24;

 120:11;139:11;215:2;

 221:23;230:12;

 241:16 

lower (8)

 6:16;24:15;47:3,14;

 120:22;144:4;199:8;

 239:24 

lowest (1)

 130:6 

low-risk (1)

 214:25 

luck (4)

 35:20;73:5;151:21;

 158:20 

lunch (1)

 19:19 

ma'am (1)

 83:25 

mad (1)

 199:14 

Maddie (5)

 80:9;86:7;94:17,23;

 95:6 

magazine (2)

 174:25,25 

main (8)

 68:5,6,18;143:8;

 146:5;148:25;192:2;

 219:7 

Maine (2)

 169:10;170:25 

mainly (2)

 24:2;219:2 

maintain (3)

 91:5;196:13;242:4 

maintaining (4)

 58:17;178:7;

 197:13;214:19 

maintenance (1)

 36:22 

major (5)

 107:22;144:9;

 145:13,13;240:3 

majority (8)

 15:10;33:4;34:1;

 96:21;124:22;138:20,

 21;223:3 

makes (13)

 24:9,14,21;41:15;

 45:10;47:23;102:1;

 106:14;131:4;146:6;

 149:6;205:20;239:18 

making (27)

 11:12;36:9;57:14;

 59:19;65:15;84:24;

 140:11,12;142:20;

 150:5;160:15;168:19;

 169:15;174:8;182:16;

 184:17;205:14;207:4;

 212:5,22;214:6;

 242:14;244:12,15,16;

 246:20;247:13 

malign (1)

 11:12 

man (3)

 19:22;54:25;77:18 

manage (3)

 49:13;181:8;182:5 

management (19)

 13:19;14:13;35:9;

 36:5;37:15;39:8,19;

 58:15;60:15;106:17;

 130:10;170:2;172:17;

 180:11;222:5,8;

 229:6;238:19;246:22 

manager (3)

 80:12;213:21;

 233:12 

managers (1)

 102:17 

mandate (14)

 87:11,14;89:12,14,

 22;90:8,10,14;91:17;

 94:4,5,6;194:2;

 234:18 

mandated (2)

 170:11;192:17 

mandates (2)

 86:16;87:8 

mandatory (1)

 44:4 

manning (1)

 14:24 

manual (2)

 8:10;11:6 

manufacturer (1)

 113:15 

manufacturers (2)

 103:22;216:24 

manure (2)

 77:25;174:22 

many (59)

 21:6;22:14,15,15;

 24:17;44:20;57:5;

 64:9;73:19;77:8;78:7,

 9;80:15,18;84:11;

 87:12,13;88:10;

 96:25;102:5;111:12;

 119:20,24;126:5;

 140:1;150:14;162:22;

 163:8;165:10,22;

 166:7;169:18;173:4;

 175:6;176:8;182:15,

 15;183:6;184:2;

 195:3,16;196:10;

 200:16;206:14;208:5;

 217:21;218:2;220:7;

 222:2,7;228:15;

 233:15;238:21;239:5,

 9;245:10,13;246:16,

 22 

map (3)

 164:1,8;210:4 

mapping (2)

 210:8,21 

maps (1)

 99:11 

March (1)

 210:25 

margin (3)

 69:18;144:4;147:7 

margin-based (1)

 146:25 

margins (2)

 64:5;149:9 

marine (4)

 107:6,7,9,11 

marker (4)

 13:2;87:19;91:16;

 228:8 

market (70)

 13:25;14:3;15:6,13,

 25;18:19;19:3;35:8,

 15,25;36:3;45:25;

 48:9,9,19;49:22;

 50:14;62:4;65:5;

 67:16;69:3,23,23,24;

 79:5;101:15,17;

 103:22;125:14;128:6;

 129:24,25;130:5,14,

 15,21;132:23,24;

 133:2,3,20;134:5,10;

 135:1,24;136:13;

 138:6,6,13;143:18;

 145:8;146:2,24;

 147:9;149:7,7,19;

 174:21;177:15;182:2;

 199:8;217:13;223:24;

 224:3;229:23,24;

 244:5,22;245:25;

 246:2 

marketing (16)

 19:25;20:1;43:15;

 55:2;172:13,25;

 220:2,10;228:2,6,7,9;

 229:2;244:10,11,21 

marketplace (7)

 58:11;92:10;157:3;

 178:1;195:19;202:5;

 210:16 

markets (16)

 15:13;18:12,14;

 56:24;115:9,19;

 128:17;131:17,19;

 138:10;149:8;165:15;

 166:22;225:20;245:2;

 247:7 

market's (1)

 36:5 

market-type (1)

 126:25 

mascot (1)

 44:17 

Mason (1)

 141:2 

mass (1)

 237:11 

massive (3)

 58:23;123:24;177:4 

Massively (1)

 60:1 

match (2)

 23:24;81:2 

material (6)

 105:10;106:1,13;

 110:23;156:5;161:7 

materials (19)

 105:8,13,17;106:1,

 10,12,15;107:7,9,19,

 20;109:17,23;110:22;

 111:2;169:25;192:12;

 216:11;241:4 

matrix (2)

 111:11,12 

Matt (5)

 152:4,7;155:1;

 157:9;158:4 

matter (8)

 5:11;69:21;97:16;

 120:13,16;123:20;

 174:24;234:8 

mattered (1)

 224:14 

Matthew (5)

 143:2;147:24;

 151:24;152:1,2 

maturity (2)

 223:1;235:2 

Mausser (14)

 37:9;42:17;51:25;

 52:7,9,9;54:12,23;

 55:13;56:7,10,13;

 57:3,19 

maximum (1)

 34:5 

may (26)

 5:15;6:5,8;29:20;

 44:22;48:9;55:8;56:6,

 8;59:13;63:9;68:6;

 74:17;85:18;90:5;

 92:10;112:24;114:4;

 117:7;120:12,12;

 123:11;134:11;

 137:23;167:13;180:6 

maybe (36)

 18:5;24:18;28:13;

 36:1,4;41:14;47:12,

 16;56:4;75:19;85:5;

 90:22;92:9;100:16;

 103:18;108:25;110:1;

 111:18;139:2;140:23;

 141:11;158:20;160:9;

 185:7;190:24;204:9;

 207:19,25;209:10;

 228:23;229:12;

 232:23,24;236:2;

 240:8,23 

McNeil (7)

 125:3;129:16;

 137:19,21,23;139:24;

 140:14 

meal (10)

 60:20;76:24;130:8;

 131:2;132:6,13;

 153:12,17;156:6;

 240:6 

meals (3)

 132:13;153:14;

 154:4 

mealworms (1)

 76:1 

mean (59)

 15:11;17:12;20:11;

 35:1,19;36:4;39:23,

 25;40:17;41:20;

 46:23;47:3;50:20;

 51:5;55:7,13;57:11;

 65:17;67:21;68:23; 

M 

Min-U-Script® Burke Court Reporting & Transcription (24) lots - mean 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 2 

October 19, 2023 

69:20;70:22;74:2; 6,8,13;18:7,10;23:20; 50:24 49:20;91:5;231:5 mill (2)

 84:2,9,10,23;85:5,7; 24:16,23;28:6,21; memorandums (1) methods (17) 132:25;207:18 

89:9;90:9;93:17; 29:19;30:16,18; 193:20 87:16;88:3;104:12, millers (1)

 100:22;102:10; 31:13;32:4,10,13; Mendenhall (16) 17;106:20,22;107:2, 159:15 

109:18,25;110:19; 33:15,18;35:3,5,25; 216:1;221:6,14; 3;108:7;163:2;188:2, million (12)

 112:14;113:21;114:9; 36:12;39:13;40:11, 224:4,6,8;226:14; 13;196:3;203:3; 27:15;67:14;

 115:14;139:19;141:7; 14;41:5,7;42:1;45:3; 227:5;228:5,18; 223:13;228:13;242:4 139:19;142:4,6;

 145:10;146:3;148:20; 46:14;47:24;48:6,22; 229:13,16;231:9,21; metric (1) 169:17;176:24;177:8;

 153:1;159:18,20; 50:1,3;54:25;56:2,8, 232:18,21 117:18 178:5,6;219:1;244:21 

168:4;196:20;208:3; 12,15,19;63:2;65:24; mention (7) Mexico (2) millions (3)

 212:1,11;220:5,20; 67:24;74:5,25;77:20, 32:5;56:10;108:19; 83:7;116:6 26:13;34:9;143:24 

228:5;231:9;246:19 24;78:23;79:2,11,21; 181:19;206:5;222:7, mic (6) Mills (7)

meaning (3) 82:21,23;83:13,25; 18 6:15,20;7:10;9:3; 164:21,23;165:7;

 105:14;132:4;178:9 84:14,18,21;85:18,22, mentioned (19) 10:17,19 166:19;167:15;

means (10) 24;86:1,2;88:16; 16:24;24:1;25:25; Michael (1) 168:19,21 

23:24;53:11;97:14; 89:24;92:22;93:21; 30:21;35:5;55:5;79:4; 108:19 Milwaukee (3)

 117:11;118:22; 94:11;98:25;100:1; 84:22;88:23;108:7, Michaels (8) 222:18;225:7;

 163:10;184:13;188:1; 108:4;109:5,10; 19;111:18;150:12; 116:20;119:10; 227:18 

196:12;219:19 111:5;112:20;113:2; 204:3;207:16;217:8; 125:3,4,7;127:20,23; mind (9)

meantime (2) 114:20;115:5;123:1; 229:8;235:9;246:11 129:12 30:3;65:10;90:19;

 82:12;173:9 124:8,25;131:24; mentors (1) Michelle (11) 97:4;139:17;142:17;

measly (2) 132:3;133:10;134:19, 13:24 7:14;8:22;9:4; 164:4;201:5;203:12 

52:10;56:22 22;135:10,20;136:9, mentorship (1) 10:19;52:1;70:6;95:9; Mindee (9)

measures (2) 15,18;137:14;144:15; 14:8 151:24;158:8;178:25; 9:8,10;54:13,14;

 60:17;202:24 145:22;146:10,20; menu (3) 233:4 90:15;115:7;120:14;

mechanism (2) 147:17;150:8;151:4; 93:13,17,20 micro (1) 122:9;199:11 

130:12;163:5 155:1,17;157:9,15,23; merchant (1) 103:25 Mindee's (1)

mechanisms (2) 159:7;160:1,12; 129:22 microbiologically (1) 21:14 

182:4,4 162:12;163:22; merit (1) 13:14 mindset (2)

media (4) 166:17;167:7,20; 87:5 microbiology (1) 139:6,7 

56:11;118:5,5; 184:19;185:18; Meschke (2) 46:25 Mine (2)

 189:3 189:25;190:3,8,10,13, 221:6,14 micronutrients (1) 18:11;190:24 

mediation (3) 18,20,24;191:1; mesh (1) 109:19 minimal (1)

 100:9,10;244:17 193:8;194:3;197:9; 128:18 middle (2) 135:12 

medical (2) 198:2,10,16;203:24; mess (1) 4:18;21:2 minimalist (1)

 183:7,8 204:1,7;205:23; 50:20 mid-size (4) 51:1 

medium (1) 206:2;207:11,13,16, message (8) 225:10;226:7,12; minimize (3)

 190:17 25;209:2,5,7;218:11; 6:12;119:6;129:4; 232:1 5:3;196:8;220:20 

meet (9) 219:10,18;226:15,18; 179:14;217:16;219:6; Midwest (9) minimized (1)

 8:1;50:10;77:8; 227:6,12;229:5,14; 220:13;232:14 9:11;23:21;26:19; 137:11 

85:14;97:18;210:25; 230:20;231:18,23; messages (1) 27:5;31:16;69:9; minimizes (1)

 223:6;226:16;238:15 235:25;236:17; 8:16 125:9;144:18;148:7 214:18 

meeting (22) 237:22,25;238:6; messaging (4) might (32) minor (1)

 5:21;7:12,24;8:3,3, 242:24;243:11;246:7 118:17;122:11,17; 11:12;22:18;30:24; 93:2 

4,5,7,21;44:10;51:19; member (5) 220:10 31:10,10;32:17; minute (5)

 140:10;147:20;162:8; 81:8;105:6;116:24; messenger (1) 47:16;56:20;62:14; 10:21;11:14;

 171:5;193:10;200:21; 164:25;199:16 212:1 63:13;64:17;69:10, 139:19;167:21;

 213:16;222:20; members (33) messengers (1) 10;99:18;100:6,6; 220:21 

233:16,18;247:18 4:13;8:23;9:4; 211:23 101:16;108:8;112:10; minutes (10)

meetings (8) 11:16,18,24,25;25:3; messy (1) 114:17;123:18; 6:25;80:6;86:7;

 8:7;21:6;37:13; 43:3;78:5,7;79:17; 93:2 124:16;137:6;147:8; 94:14;95:11;169:2,2;

 80:25;160:19;200:3; 88:7;95:2;164:21; met (3) 180:13;181:23; 180:13;184:7;187:12 

221:10;225:6 169:9,18;171:5,6,10; 91:24;119:21; 184:22;191:4;198:17; Miranda (1)

meets (2) 178:18;187:19,21; 188:24 200:7;203:20;247:9 8:23 

213:4;221:25 188:5;198:20;201:7; metals (1) Mike (12) Mischke (1)

mega (1) 221:24;224:7;227:7; 203:11 12:2,3,7;14:21; 224:5 

118:16 236:1,15;241:17; metered (1) 16:13;18:8,10;19:14, misconstrued (1)

melamine (3) 242:5 23:6 16;21:16;100:16; 96:12 

154:1,2,12 members' (1) methane (2) 212:1 misinformation (3)

MEM (179) 90:2 132:17;161:9 mile (1) 118:13;120:19;

 9:11,13,16,18,20, membership (1) methanol (2) 22:7 168:15 

22,24;10:1,5,7,9,12; 76:4 132:5;153:19 milk (1) misinterpreted (1)

 14:21;15:15,17;16:2, memo (1) method (3) 177:22 44:11 

Min-U-Script® Burke Court Reporting & Transcription (25) meaning - misinterpreted 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 2 

October 19, 2023 

misleading (1)

 118:7 

misleads (1)

 61:12 

misrepresenting (1)

 103:22 

miss (1)

 51:22 

missing (5)

 28:12;53:9;57:8;

 97:14;172:6 

Mississippi (1)

 115:25 

mistake (1)

 246:20 

mitigate (3)

 116:13;172:15;

 173:6 

mitigating (1)

monitor (1)

 225:15 

monitoring (2)

 202:23;203:16 

monopolies (1)

 118:15 

Monsanto (1)

 186:22 

Montana (2)

 243:22;244:1 

month (2)

 40:19,21 

months (6)

 26:14;60:18,23;

 69:6;138:5;239:17 

mood (1)

 212:16 

Moon (2)

 194:12;195:10 

morning (17)

 9:7,8,9,10,11,12,14,

 19,22,25;10:5,6,12;

 12:6;37:12;75:14;

 80:11 

MOSA (4)

 213:21;214:8;

 215:21;226:10 

most (43)

 22:8;24:11,11;

 25:20;26:5;31:23;

 32:1;33:3;39:24;

 52:18;53:1,5,7,25;

 55:25;64:23;72:7;

 83:16;97:22;98:7,10;

 99:14;120:20;121:18;

 124:21;148:18;

 153:16;163:10;

 173:18;176:8;199:2;

 97:13;100:1;102:16;

 103:20;104:15,16;

 115:5;119:1;125:4,5;

 129:3,7,11,24;131:22;

 135:8,16;137:15,18;

 140:13;142:18,24;

 143:19,21;144:3,5,12;

 146:22;147:15;

 150:25;151:18;

 160:14,24;162:10;

 164:11;166:14;

 167:24;168:17,20;

 169:8;170:14;171:9,

 13;174:4,10;178:20;

 182:17;183:7;185:18,

 21,24;187:5;190:22;

 191:11,23;193:6;

 194:4;197:6;199:6,6,

 8,8,12,15,16;200:13;

 22,23;223:3;224:16;

 239:3;245:12 

mustard (1)

 91:20 

mutagenic (1)

 108:22 

mutation (1)

 91:2 

mute (7)

 6:18,20;179:4,5;

 182:20;184:17;

 243:18 

muted (1)

 39:12 

myself (3)

 52:23;100:2;216:10 

N 

135:23 moratorium (1) 204:21,21;208:6; 203:13,18;207:6; nail (2)

mitigation (3) 235:1 219:25;221:9;226:2; 209:2,16;213:13; 231:12,19 

202:23;203:16; more (137) 234:21,22;235:7,19, 215:20,23;223:20; naked (1)

 205:6 6:3;10:22;13:22; 20;246:19 226:13;227:2;235:25; 151:1 

mix (4) 14:25;15:12,21;17:9, mother (2) 238:7;239:24;244:3; name (41)

 89:12,13;93:15; 21,22;18:4,12,15; 182:24;184:10 246:4;247:11 5:25;6:3,8,21,22;

 190:13 19:9,11;22:14;26:17; motive (1) mulch (36) 11:22;12:7;21:23;

mixed (4) 27:20;29:4;30:24; 118:21 44:8;81:4,11,13,19, 25:14;60:11,14;

 7:7;15:23;111:23, 31:1;41:15;43:8; move (19) 21,23,25;82:5,7,11, 70:12;72:5;73:20;

 24 44:19;45:5;49:15,19, 28:17;33:11;43:24; 12;83:24;84:3,6,8,10, 75:11;80:11;95:23;

model (4) 19;54:7;56:24;57:1; 58:7;64:10;65:17; 25;103:19;107:1; 111:17;116:22;

 127:9;195:9; 59:12;60:21;61:25; 71:16;83:18;84:15; 196:7,9,13;221:22,24; 135:24;140:19;

 229:24;230:17 70:16,17;76:11,11,18; 106:3;110:9;126:1; 241:7,9,10,13,18,22; 141:12;158:11;

modeled (1) 79:25,25;81:24;85:2; 138:9;142:5;156:1; 242:8,11,16,20;243:2 160:25;164:20;169:6;

 162:23 86:15;89:9;90:20; 179:22;192:19;218:2; mulches (1) 171:20,24;174:15;

modeling (3) 92:5;93:20;96:17; 221:13 198:5 180:10;191:15;

 126:7,12;128:15 98:18;99:9;100:5; moved (2) mulching (1) 194:11,11;201:8;

modern (1) 102:8,18;106:7; 70:20;103:17 242:4 213:20;216:4,7;

 194:14 107:9;108:20;110:21; movement (8) multi- (1) 224:8;236:4;240:24;

MOFGA (1) 118:17;120:4,23; 13:21;83:1;118:20; 163:4 243:20 

169:11 123:6,19;126:10,18, 131:15;161:17,20; multi-annual (2) names (4)

Moines (1) 25;127:17,22;131:7, 194:14;224:22 127:5,8 11:8;31:3;112:2;

 116:2 17;132:15;133:22,22; movements (1) multi-billion-dollar (1) 233:8 

moisture (3) 135:22;139:3;141:16; 224:16 175:4 name's (2)

 81:12;155:7;241:14 143:12;145:3;147:6, moves (1) multifaceted (1) 133:25;221:18 

moly (1) 12;149:18;150:17; 94:4 234:4 Nandwani (6)

 139:12 151:12;159:18; moving (8) multi-generational (1) 10:4,5;48:22;50:1;

molybdenum (1) 161:15;163:14; 10:24;51:13;65:7; 142:8 108:4;109:5 

139:11 165:16;166:24;167:1; 106:5;154:24;200:1; multi-nationals (1) nanoplastics (1)

mom (2) 168:6;169:15;171:1; 232:13;233:19 178:9 103:25 

52:18;55:4 172:12;173:2,14,17; Moyer (1) multiple (4) narrative (2)

moment (6) 176:10;182:8;185:22; 241:5 16:24;35:14,15; 198:22;199:22 

7:6;33:21;44:7,24; 187:1,12;189:13; MRO (1) 115:19 narrow (1)

 52:3;58:9 196:23;199:6;200:7, 110:23 multiplied (1) 93:23 

momentum (2) 16;201:14;203:9,15; much (114) 181:11 nascent (1)

 79:20;166:10 204:14;205:8,18; 18:7;19:12;21:5,9; Musgrave (12) 128:5 

Momoa (1) 207:25;209:16; 23:15;24:15;28:1; 72:4;75:8;80:4,11, nastygram (1)

 20:10 210:18;214:9;215:7, 31:7;32:8;35:21;37:5, 12;82:22;83:4,23; 154:5 

money (14) 7;218:7,14;222:3,11; 21;42:13;52:12; 84:1,17,19;85:4 Nate (50)

 26:18,19;27:4,19; 223:24;225:6;226:4; 54:16,20;56:15; must (19) 6:20;8:11;9:5,25;

 28:8;38:17;43:14; 229:1,23;231:11; 57:13;59:7;65:21; 11:8;61:12;66:18, 10:2,16;16:14;21:10;

 47:18;53:19;65:16; 232:24;236:11; 70:1,4;74:3;75:2; 22;86:17;105:15; 25:14;48:2;49:24;

 116:11;146:6;245:21, 239:23;240:4;241:24; 82:18;83:15,20; 106:21;118:3,12; 56:19;77:16,16;

 23 244:11,23;247:1,2,3 85:22;86:3,4;88:13; 170:3;188:9;192:4,7, 84:20;85:18,19; 

Min-U-Script® Burke Court Reporting & Transcription (26) misleading - Nate 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 2 

October 19, 2023 

88:16;94:25;95:3,6, 28:10;71:23;78:21; 234:18 238:8;240:13,20; NOP (38)

 11,19;107:13;109:9; 175:20;184:2;192:13; negatively (1) 244:8;247:19 5:23;8:19;12:21;

 111:5;124:8;131:23; 193:1;195:8,25; 133:3 NFT (1) 13:16;46:1;61:12;

 133:10;134:22; 198:9;214:6;241:10; negotiated (1) 190:5 67:18;87:2;88:2;91:4,

 144:15;146:20; 245:12 136:5 Nice (10) 6;96:2;97:8;113:9;

 149:22;157:10,14; necessitates (1) neighbors (3) 14:15;23:3;24:20; 117:8;153:21;161:17,

 163:21;166:17;167:6; 161:21 245:10;246:10; 80:21;82:23;103:1,1; 22;176:24;180:19,21;

 176:21;178:23; necessity (1) 247:6 151:2;205:25;227:7 189:14,18;201:7;

 179:22;190:25;193:7; 242:9 neither (1) niche (1) 203:2;208:6;214:2;

 202:2;213:14;226:18, need (105) 35:7 128:7 222:16;223:8;225:1;

 20;229:5;233:5; 5:22;18:18;19:9,23; nematicides (1) Nicoe (1) 226:4,9;232:10;

 238:11 20:13,16,20;21:6; 46:24 94:17 234:3;235:9;237:19;

National (56) 22:12;26:16;27:18; nematodes (2) Nicole (12) 239:4,14 

4:5;7:12;8:7;29:21; 29:10;43:8,17,21; 46:22;47:9 80:8;86:7;94:22,23; NOPs (1)

 43:10;44:19;50:5,8, 49:12,20;53:1;56:23, nervous (2) 95:20,23;97:9;99:1; 192:11 

10;51:5;71:9;81:6; 23,25;57:4;60:16; 45:5,10 100:1;102:7;215:16, NOP's (1)

 82:15;86:14,18,19; 61:1,25;63:7;64:15, net (5) 17 202:19 

92:13;103:4;105:4, 16;66:8;68:22;85:11; 134:10;163:6; nightmare (1) nor (1)

 12,14;107:12;109:11, 87:22;91:5;92:6,7; 230:10,12;235:4 89:23 4:14 

14,23;110:6;113:25; 93:3,18;97:21;98:1, neutral (1) nimble (1) norm (2)

 114:3,16;130:1; 11,15;99:20;100:24; 234:18 204:14 74:17,18 

149:7;161:16;162:5; 101:20,20,22;102:3; new (32) nine (1) normally (1)

 169:21;170:1,2; 103:16,25;109:16,21; 8:23;14:3,7;43:15, 23:7 197:9 

171:21;172:6;178:12, 110:8;112:9;120:9, 20;46:6;58:10;120:9; nitrate (2) North (5)

 14;187:24;189:6,12; 16;123:15;124:4,6; 125:23,25,25;126:6, 116:1;244:19 75:12;76:1;153:11,

 192:8,23;193:10,13; 126:11;128:6;137:8; 15;127:4,23,24; nitrates (1) 12;187:15 

217:18;218:21;222:9; 141:20;143:11; 128:17;141:18; 116:3 Northeast (1)

 224:10;238:14;241:3; 146:14;149:17;151:9, 143:25;145:3,6; noble (1) 148:8 

242:11,15;244:6 23;154:7;156:1; 174:25;175:22; 244:9 northwest (2)

natural (7) 157:18;164:2;167:1; 176:24;177:6;186:10; nobody's (2) 158:12;229:17 

52:24;91:1,1;121:3; 170:22;172:13;173:8; 192:15;210:6;230:4, 26:14;153:19 NOSB (63)

 217:17,21;218:1 176:10;178:18; 4;235:1;237:8 NOC (7) 8:4,23;11:18,25;

naturally (2) 184:14;185:22; newest (1) 105:7;106:8,16,19; 20:17;27:9,16;43:3;

 92:19,19 186:17;192:23; 201:9 107:5,12;108:12 44:8;50:24;60:14;

nature (4) 195:11;197:11;198:7; news (1) NOC's (4) 63:24,24;64:4;67:18;

 4:15;187:13;217:5; 200:9,10,11;206:10, 79:21 108:6,11;110:21; 71:12;75:22;76:14;

 234:4 22;217:16;219:7; next (87) 111:10 80:13;82:14;86:11,

navigate (1) 220:10,14;227:21; 5:21;6:3;8:1;11:21; NOFA (1) 24;87:2;88:2;91:6;

 232:10 228:13;232:14; 18:4;19:16;20:15,16; 95:25 96:2;103:10;105:5,6,

Neagu (1) 234:14;235:20;237:4; 21:16,17;22:18; noise (1) 10;113:9;116:25;

 240:16 239:5;240:19;243:6; 25:10,12;33:11;37:8; 156:25 119:3;121:7;161:23;

Neagu- (1) 247:5,5,6 42:16;44:7;48:3; non- (1) 169:9;170:16;171:5,

 238:8 needed (15) 51:19,25;52:15; 214:15 9;172:10;173:3;

Neagu-Reed (8) 43:9;47:9;68:1; 57:21,21;60:8;72:3, non-compliance (4) 178:10,18;187:24;

 221:15;233:7; 99:13;101:13,13; 14;75:7;77:9,13; 131:12,16;237:18, 189:17;192:15;197:2;

 240:14,16,22,24; 105:23;139:16,20; 78:23;80:4;86:6; 20 201:7;214:23;215:19;

 243:10,15 161:17;206:25; 89:20;102:21;104:22; non-compliant (2) 216:10;217:24;222:2,

near (4) 222:12;223:13;226:2; 109:15,16;112:23; 117:22;118:1 16,17,20;224:7;

 24:21;27:7;138:24; 228:6 113:4;116:19;119:9; none (7) 225:1;231:14;233:23;

 244:6 needle (3) 120:12;125:2;129:15; 84:2,2;111:3; 242:14;244:2;247:13 

nearby (1) 83:18;84:15;218:2 137:19;140:15; 172:24;177:6,21; NOSB's (2)

 171:3 needs (18) 141:23;143:1;147:23; 178:16 69:17;170:12 

nearly (2) 64:14;65:18;68:7; 160:19;162:7;164:14; non-existent (1) note (5)

 194:18;246:1 88:5;92:14;99:21; 171:14,15,15;174:11; 181:9 10:15;43:8;50:6;

Nebraska (8) 104:10;114:2,3; 176:18;178:24; non-GMO (8) 106:16;203:7 

21:25;37:19,19,21; 139:1;144:8;148:25; 179:22,24;180:1; 46:1;53:15;55:21, noted (5)

 58:8;70:13;125:8; 154:22;163:16,25; 185:6;186:21;187:6; 22,23;87:1;181:22,23 88:9;105:11;117:6;

 148:8 182:8;210:23;211:4 191:12;194:8;200:21, non-organic (1) 173:3;242:5 

necessarily (7) negate (1) 24;201:21;202:18; 91:11 notes (2)

 16:3;61:4;68:24; 243:6 203:19;210:24; non-profits (1) 66:10;106:15 

133:24;149:4,16; negative (6) 213:16,17;215:25; 166:5 noticeably (1)

 166:19 76:14;105:18; 217:1,5;218:1;221:5; non-synthetic (2) 203:18 

necessary (13) 131:14;191:19;226:5; 223:19;224:4;231:11; 170:5;242:10 noticing (1) 

Min-U-Script® Burke Court Reporting & Transcription (27) National - noticing 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 2 

October 19, 2023 

111:15 

notified (1)

 171:2 

no-till (1)

 120:1 

noting (3)

 96:6;98:2;225:15 

nought (1)

 151:15 

noun (2)

 161:5,12 

NOVA (1)

 230:4 

Novak (11)

 174:12;176:19;

 178:25;182:21,23,24;

 184:23;185:19;186:1,

 4;187:5 

November (1)

 40:20 

nowhere (2)

 20:24;85:9 

nuanced (2)

 198:23;234:15 

nuances (1)

 235:8 

nuisance (1)

 37:2 

number (22)

 6:8,9;25:22,23;

 46:11;70:22;71:13;

 75:19;76:9,18,19;

 83:13;93:16;94:5;

 97:18;156:23;180:3;

 203:1;206:12;207:2;

 225:20;227:25 

numbers (8)

 34:7;61:17;88:24;

 89:2,6,23;160:10,11 

nutrient-dense (1)

 244:13 

nutrients (4)

 116:4;140:5;

 161:15;223:3 

obviously (19)

 22:7;24:7;56:1;

 62:1;89:9;96:14;

 97:11;119:18;130:6;

 132:16;133:4;134:5,

 10;135:7;137:7;

 148:19;158:16;164:6;

 239:23 

occurrence (1)

 181:25 

occurring (1)

 97:14 

occurs (2)

 19:18;208:22 

o'clock (1)

 4:4 

October (1)

 247:22 

OEFFA (6)

 233:12;234:20;

 236:1,21;238:17;

 239:4 

OEFFA's (2)

 234:10;238:13 

OFA (11)

 221:23;222:2,21,

 25;223:4;224:10,13,

 14,24;225:9;226:8 

OFBA (7)

 192:6,11,12,21;

 193:9;198:3;202:20 

OFBA's (3)

 192:17,22;194:1 

off (31)

 4:19;10:17;12:3,6;

 14:20;23:13,18;58:6;

 62:9;64:4;65:12;

 94:19;102:18;120:3,

 4;126:15;141:2;

 142:24;155:8;177:8;

 184:17;185:8;209:21;

 217:7;218:7,15,23;

 219:12,22,23;220:25 

offered (2)

 231:1;234:15 

offering (1)

 54:2 

offset (1)

 79:12 

off-site (1)

 214:14 

OFRF (1)

 166:5 

OFTA (2)

 110:11;115:4 

OFTArequires (1)

 105:13 

often (5)

 110:3;118:4,7;

 173:23;199:5 

oftentimes (1)

 61:24 

Ohio (1)

 187:14 

OID (2)

 214:5,7 

oil (2)

 76:24;109:25 

oils (1)

 109:18 

old (3)

 20:2;101:1;220:13 

older (1)

 186:8 

OLPS (4)

 106:18;177:6;

 222:6,7 

Olson (6)

 60:9;72:3,5,5;

 74:11;75:5 

OMDG (1)

 18:19 

OMRI (3)

 43:6;78:5;111:1 

once (7)

 8:6;38:25;40:9;

 48:7;51:6;162:8;

 183:12 

one (109)

 12:6,23;16:21,22,

 24;20:19;22:22;23:6;

 25:22;28:4;31:14;

 32:14,20,21;35:7,19;

 37:1;38:10;41:14,18;

 186:1,5;187:19;

 195:4,21;196:14;

 198:2;199:20;201:10;

 202:3;203:1;204:2,

 11;210:18,18;212:24;

 216:5,24;221:9,21;

 224:14;225:19;

 228:11;229:19;

 230:15;236:14;

 238:12,12;242:1;

 244:25;245:7;246:1,

 5;247:8 

ones (11)

 16:16;19:11;26:7;

 32:3;71:8;109:21;

 115:19;119:21;

 128:22;137:1;220:8 

one's (1)

 230:21 

on-farm (1)

 161:19 

online (2)

 4:6;212:15 

only (45)

 4:8;6:18;11:25;

 13:16;15:9;19:12;

 35:13;43:9;44:6;

 48:14;53:11,13;

 57:11,12;63:9;67:1;

 76:13;90:3,12;91:19;

 93:18;98:3;105:24;

 106:1;107:25;110:23;

 119:2;143:18;145:2,

 4;180:6,12;181:5,14;

 187:22;192:13;195:7;

 201:10;202:5,22;

 214:5;217:10;237:15;

 238:24;244:24 

ons (1)

 200:9 

onset (1)

 136:5 

on-sights (1)

 205:7 

onsite (1)

 214:18 

onus (2)

operating (1)

 127:8 

operation (11)

 67:13;70:16;99:21,

 23;112:11;117:13;

 183:2,16;185:1,17;

 196:21 

Operational (1)

 173:23 

operations (38)

 14:7;15:23;98:11,

 16,16;111:15,16,23;

 117:7,8;169:17;

 170:9,13,18;180:19;

 188:8;195:7;196:19;

 203:13,14;210:4,6,7,

 17;213:24;215:1,1,2;

 219:24;220:2;223:9;

 225:22;234:20;235:1;

 236:22;237:19;

 238:13,24 

operators (1)

 225:24 

opinion (9)

 33:13;36:19;50:5,9;

 84:15;109:11;193:9;

 206:8;213:11 

opinions (1)

 80:19 

opportunities (7)

 18:16;55:8;58:13;

 165:4,5;172:14;

 229:21 

opportunity (18)

 16:25;42:9;53:9;

 55:3;82:16;98:12;

 130:2;166:25;174:1;

 213:23;223:18;224:7;

 226:22;233:8,14;

 241:2;242:20;245:5 

oppose (3)

 12:13;170:17;

 234:17 

opposes (1)

 223:5 

opposite (2)

 230:13;246:13 

O 

oat (1) offerings (1) 48:18;49:6,21;51:18; 105:20,22 optimistic (1)

 159:17 17:7 54:14;56:21;59:4; OPA (10) 196:22 

oats (2) office (2) 63:3;67:24;68:25; 21:11;50:5,10; option (4)

 158:13;159:14 73:22;74:1 69:8,9;72:7;73:22; 109:11;113:25; 38:17;50:7;188:22,

objective (1) officer (1) 75:19;76:9,18;77:1; 187:22;188:4,5; 24 

242:13 8:11 78:6;79:14,16;82:23; 189:11,17 optional (1)

objectives (2) offices (2) 85:2;87:12;89:9,14, open (7) 6:15 

63:6;235:16 73:20;172:21 16,19;95:1;106:14, 8:13;27:1;28:14; options (7)

obstacles (1) official (1) 21;108:18;111:15,17; 66:6;84:24;98:25; 50:24;65:7;81:25;

 173:25 236:4 115:20;117:6;121:18; 162:7 94:9;126:1;228:4;

obtain (2) officially (1) 127:21,22;132:3; opened (1) 241:23 

117:3;223:3 7:12 133:18;136:20; 145:16 OPWC (3)

Obu (1) offline (2) 137:10;139:12,14; opens (1) 12:9,12;14:8 

8:24 69:6;190:14 140:24;141:4;148:2, 167:12 oral (5)

obvious (2) offs (1) 17;155:18,18;163:6; operate (3) 39:17;88:18;241:5,

 66:21;112:4 220:7 167:21;170:10;179:4; 32:7;130:18;191:2 7;242:21 

Min-U-Script® Burke Court Reporting & Transcription (28) notified - oral 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 2 

October 19, 2023 

order (11)

 7:13;11:20;43:16;

 44:3;86:17;101:16;

 105:15;141:21;

 192:24;198:7;222:10 

Organic (586)

 4:5;7:12;8:8;9:1;

 12:7,8,15,18;13:1,17,

 19,21,23,24;14:3,10,

 16;15:4,17;18:13,15,

 19,23;19:2,4,4,12,19;

 20:15;21:8,11;22:2;

 24:12,15;25:16,24;

 26:7,8,16,17;27:5,11,

 14,21,21,21;28:17;

 29:18;30:2,11,15;

 31:6,17,22,23;32:1,3,

 8,9;35:17;36:3,10,10,

 25;37:15,24;38:12,

 22;39:1,6;40:9,15,16,

 22;41:1,10,11;43:2,5,

 12,12,15,15,18;44:17,

 19,20;45:5,14,16,17;

 46:25;47:14;49:14,

 18;50:13;53:11,15;

 56:3;57:17;58:9,11,

 17;59:8;60:15,17,23,

 25;61:2,5,9,11,13,19;

 63:4;64:1,9;65:12;

 66:18,19;67:5,7,9;

 69:4,13,14,16;70:14,

 21;71:5;72:6;74:9;

 75:23;76:12,25;77:4;

 80:12,18,21;81:2,9,

 11,14,15,19,20,21;

 82:13;83:12,18;84:4,

 5,11,12;85:20,21;

 86:10,12,12,14,14,17,

 19,22;87:5,9,13,23,

 25;88:4,7,8;89:21;

 91:5,7,12;92:12,13,

 14,23;94:7;95:24;

 96:1,11,22;97:23;

 103:4,12;105:5,5,16,

 20,22,25;106:17;

 107:7,9,12,20,21;

 109:4;111:17;112:16,

 18;144:23;145:8;

 146:2,3,5;148:10,21;

 149:4,6;151:8;152:8;

 153:3,11;154:9;

 156:4;158:12,13,15,

 20,23;159:18;161:2,7,

 16;163:5;164:20,22,

 24,25;165:4,5,8,9,13,

 15,16,18,19,21,22,25;

 166:1,3,5,6,7,9,11,12,

 23,25;167:25;168:8,

 10,19;169:10,15,16,

 18,19,21;170:1,6,17,

 19;171:21,22,25,25;

 172:6,8,12;173:1,9,

 11,13,15,16;174:2,16,

 19,21;175:4,7,7,12,

 19,20,21,24;176:3,12,

 13,22,24;177:1,3,10,

 13,14,18,20,24,24;

 178:1,2,3,4,5,8,9,12,

 14,19;181:9,13,20;

 182:12;183:2,3,17,18,

 21,23;184:2,4,5,8,13;

 185:15,17;186:9,14,

 16,20,23;187:14,15,

 16,18,23,24,25;188:3,

 6,9,16,18,25;189:1,

 12,14,15,19,20;

 191:20,21,24;192:4,7,

 16,21,24;193:3;

 194:14,17,22;195:2,9,

 17,20,21,24;196:7,23;

 197:12,15;199:24;

 200:9,12;201:9,10,12,

 16,22,23;202:1,2,15;

 207:6;210:9;211:24;

 212:22;213:1,3,8,22,

 24;214:2,24;215:2,

 24;216:8,17,20,22,23;

 217:2,2,7,9,10,13,14,

 21,23;218:13;219:8,

 11;221:1,19;222:3,4,

 9,10,11,13,14,19,19,

 25;223:5,8,10,14,15;

 224:9,11,12;225:8,16,

 16;228:7,8,11,13,14,

 153:7;159:10;174:17 

organics (22)

 16:2;43:13;45:13;

 52:16,17,24,25;53:10,

 20;54:5;55:22;57:13;

 74:16;82:15;105:19;

 106:22;110:22;

 113:15,24;165:11;

 188:5;211:21 

organic's (1)

 40:1 

organicspecialistscom (1)

 44:3 

organization (7)

 83:15;104:6;106:2;

 187:22;191:17;238:1;

 241:6 

organizational (1)

 224:22 

organizations (4)

 54:7;175:5;224:16;

 235:18 

organized (4)

 111:19,20;112:2;

 178:11 

organizing (2)

 111:16;162:7 

origin (17)

 26:11;32:25;33:1,3,

 6,24;34:15;63:17;

 133:7;134:3;135:25;

 136:14,14;155:20;

 244:10;245:5;246:3 

original (5)

 47:21;187:19;

 195:21;198:1;216:22 

originally (1)

 108:21 

originating (1)

 181:13 

ortho (1)

 104:7 

OSBs (1)

 102:17 

OSP (2)

 201:13;238:17 

OTA (4)

 139:17 

ours (1)

 144:23 

ourselves (3)

 102:3;124:5;128:7 

out (123)

 5:14;14:6;18:5;

 21:14,15;23:5;27:20;

 29:10;32:18;37:6;

 38:2,19;41:12;45:22;

 49:3,21;50:15;58:8,9;

 59:16;65:1,1;66:23;

 67:4;68:22;72:1,14;

 73:5,13,19;83:10;

 91:18;92:12;93:14,

 23;102:10,15;105:21;

 108:21;115:17;

 122:19;124:19;126:1;

 129:9;133:22,25;

 134:13;135:23;137:6;

 138:9,14;139:12,17,

 18,20,25,25;140:2,4,

 5;144:20,23;145:6,7;

 147:20;149:18;150:2;

 151:10;153:9;154:1,

 4;155:13;158:1;

 159:4;165:2;166:1;

 168:2;170:1;171:6;

 172:24;174:25;176:5;

 178:12;179:25;

 182:20;183:5,7,9,13;

 185:24;187:3,3;

 188:22;189:4;196:15,

 19;197:5;200:5;

 201:17;203:18;

 205:19;207:2;208:21;

 210:22;211:9,11,20;

 212:12;213:5;219:4,

 11;220:10,13,22;

 221:2,12,14,16;

 223:25;228:7;229:21;

 238:9;247:12 

outcome (3)

 90:20;200:4;202:11 

outcomes (1)

 165:11 

output (1)

 127:10;138:4;140:21;

 142:2,5;143:7;

 148:22;149:4,4;

 152:23;159:16,24;

 167:16;171:25;172:4;

 173:23;178:15;

 187:15;194:17,22;

 202:14;224:20;

 226:21;227:14;228:1;

 229:20;230:25;231:4,

 11,19;244:5,22 

overall (5)

 27:23;75:23;85:21;

 114:24;215:7 

overproduction (1)

 120:25 

overseas (6)

 32:22;143:13,16;

 145:11,17,19 

oversight (6)

 12:10;26:5;59:10;

 150:11;215:1;216:16 

oversupply (1)

 45:9 

overturn (1)

 229:25 

overuse (1)

 98:3 

overview (1)

 241:6 

overwhelmingly (1)

 242:6 

own (21)

 4:18,23;46:17;

 47:18;102:17;120:12;

 134:14;159:19;168:5,

 7,8,12;171:25;182:5;

 198:6;201:19;205:3,

 8;206:8;238:25;

 244:13 

owned (1)

 95:25 

ownership (2)

 14:5;136:7 

P 

18;114:2,9,25;115:2, 22,25;229:9;230:11, 43:6;165:20; 23:24 pack (1)

 2,12,22;116:10,10,23; 18,25;231:3;233:13, 217:14;218:20 outrageous (1) 165:24 

118:4,10,11,13,20,22; 22,25;234:5,7;235:5, OTA's (1) 53:5 packaged (1)

 119:6,12,14,16,17,22, 14,14,21;238:14,15, 201:25 outreach (1) 164:24 

23;120:11,13,15,16, 19,20,22,23;239:1,18; Others (10) 227:20 packaging (6)

 18,21,23;121:2,4,11, 240:5,6,23;241:3,4, 15:24;78:21;81:17; outright (1) 19:24;20:1;103:15;

 16,23,24,24,25;122:2, 11,18;243:21,23,24; 82:25;118:9;130:2; 118:9 115:2;162:24;163:1 

13,15,23;123:6,15,20; 244:5,11,22,24,25; 133:25;134:11; outside (2) packet (1)

 124:19,24;125:9,15; 245:21,24;246:1,17, 167:14;234:4 177:20;223:10 105:10 

129:4,22,24,25;130:1, 23;247:3,5 otherwise (8) over (52) page (2)

 8,15,23;131:1;132:3, organical (1) 12:8;42:18;85:13; 4:9;5:5,8;7:10;9:3; 8:5;56:5 

4,4,5,7;134:25;135:8, 180:11 111:2;160:11;161:7; 14:10,13;24:18; pages (1)

 10,11;138:3,10,23,25; organically (13) 169:25;239:3 26:14;45:25;46:10; 155:11 

139:2,4,4,5,9;140:21; 25:15;29:15;43:5; ought (1) 48:9;50:18;65:14; paid (9)

 141:6,19,20,23;142:2, 62:19;83:3,9;113:12; 128:24 67:22;85:23;96:9; 73:1,4,5,13,18;

 5,11,14,19;143:9,9, 143:6,21;148:20; ounces (1) 114:24;115:3,21; 118:19;136:11; 

Min-U-Script® Burke Court Reporting & Transcription (29) order - paid 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 2 

October 19, 2023 

216:10;225:25 particular (7) 95:1,10;228:17 15:11;29:11;43:13; pesticide (6)

pain (1) 41:18;99:23; pay (9) 48:23;49:7,21,21; 51:1;113:22;114:1;

 199:17 130:15;131:1;132:21; 34:8,11;48:16;68:2; 60:23;61:1;62:17,22; 153:6;155:9;203:8 

painful (2) 199:1;230:2 89:3;138:14;146:8; 65:5;69:18,19,19,21, pesticides (13)

 205:23,24 particularly (8) 173:25;245:12 21,21;76:22;80:1; 53:12;103:8;

paint (1) 58:14,16;68:3; paychecks (1) 83:8,11;120:22; 113:13;114:19;156:8;

 164:8 81:15;164:5;181:25; 219:11 121:25;143:12,22; 191:24;192:4,6,16,21,

painting (1) 196:10;211:5 paying (8) 145:20;149:14; 24;203:9;244:14 

20:3 partly (1) 34:9,10,12;46:9; 153:11,13;155:23; pest-management (1)

panel (3) 99:9 47:3,4;57:13;226:5 173:10;177:10;181:5; 49:14 

222:19,22;234:1 partner (4) payment (1) 183:18;205:2;206:7, pet (1)

paper (2) 82:9;201:9,14; 173:21 10,13,15,16,17,18; 43:12 

60:3;211:8 216:8 payouts (1) 241:20,20;242:1,1; Peter (8)

paperwork (11) partners (2) 173:15 244:6,8,24,25;245:15, 137:20;140:16;

 58:15,20;96:7,17; 136:25;235:18 PCO (2) 23;246:1,1 143:1,5;144:15;

 97:7,13,19;98:18; partnership (8) 100:10;232:3 percentage (9) 145:22;146:17,22 

226:1;230:7;239:13 77:5;79:16;119:5; peanut (4) 40:4;66:18;69:12, Peters (13)

paradigm (1) 126:13;164:1,8; 144:10,20;145:8; 13,23;83:2,16; 187:6,9,11,13;

 126:2 168:2,6 146:12 181:11;206:21 190:2,7,9,11,16,19,

parallel (2) Partnerships (1) peanuts (9) perfect (8) 23;191:8,11 

111:15;112:3 167:25 143:9,9;144:7,25; 70:8;102:13; petfood (3)

parallels (2) parts (6) 145:14,14,23;146:1,5 182:23;194:24; 76:25;77:1;79:5 

36:2;182:8 103:13;139:19; peas (1) 220:15,15;227:5; petition (8)

parameter (1) 158:21;163:18;202:4, 148:11 232:7 105:17,21;110:17,

 85:1 16 peers (1) perform (2) 23;161:24;162:9;

parametric (2) part-timers (1) 38:5 63:5,15 163:23;217:15 

126:7,12 70:17 penalized (1) performing (1) petitioned (1)

parcel (8) party (1) 140:6 204:23 192:7 

88:24;89:1,6;93:16; 185:13 penalties (1) perhaps (3) petitioner (1)

 94:5;117:2;170:7; pass (3) 65:11 82:25;84:24;234:21 164:6 

236:8 70:2;134:7;242:18 penalty (1) period (12) petitions (1)

Pardon (1) passing (1) 34:4 11:8;46:13,18; 161:22 

115:8 65:11 penetrate (1) 126:9;132:9;153:25; Petrey (22)

parents (4) passionate (2) 205:17 188:10,12,18;189:1, 10:6,7;14:21;15:15,

 55:20;183:21,21; 183:20;202:15 Pennsylvania (1) 16;197:19 17;16:2,6,8;28:6,21;

 194:12 passive (1) 194:16 periodic (1) 29:19;30:16;45:3;

park (1) 51:2 people (71) 117:25 46:14;47:24;54:25;

 129:9 pass-through (2) 7:8,9,20;26:22,23; permitted (2) 56:2,8,12,15;145:22;

part (37) 14:7;128:14 28:13,25;33:10,21; 11:10;169:25 146:10 

4:12;7:24;22:16; past (11) 34:24;36:22;38:15; permutations (1) PFAS (16)

 23:12;32:16,17;45:4; 86:11;113:5; 39:24;40:7;43:19; 107:4 104:5,8;113:16;

 49:5;75:16;76:5; 125:20,22,24;169:2,2; 47:21;52:20;53:17; persist (1) 115:1;162:14,15,16,

 86:20;89:12,13,16; 178:10;218:12; 54:7,18;55:3,11,20, 61:13 18,20,24;163:11,15;

 94:8;102:1;120:20; 241:17;245:6 22,25;56:10;57:3,4,5; person (11) 170:24,25;171:3,8 

126:22;127:7;128:5; pasture (3) 62:2;64:9;65:6;68:24; 8:1;11:21;38:11; ph (5)

 130:20;133:7;165:18, 97:16,17;177:23 70:16;90:5;91:10; 51:22;77:8;129:2; 46:24;104:5;167:8;

 20;177:17;194:13; pastured (1) 92:7;109:4;120:22; 159:1;179:23,24; 175:11;236:14 

200:10;203:15; 122:4 122:2;124:21;127:14; 180:9;231:15 pharma (1)

 204:21;208:3;210:5, pasturing (1) 128:20;133:14; personal (6) 53:19 

5;212:2;215:5; 119:19 138:13,20,21;142:13; 4:24;8:15;11:12; phase (2)

 229:23;232:25;243:3 path (1) 148:4,17;155:15; 84:15;114:13;181:14 38:12,24 

participants (3) 214:22 160:17;165:23;166:7; personally (1) pheromone (1)

 6:5;131:2;171:4 pathogenicity (1) 176:8,9;186:15; 143:25 51:2 

participant's (1) 78:3 191:18;196:23; Persons (1) pheromones (1)

 6:2 pathogens (1) 200:16;206:10; 11:8 109:19 

participate (5) 78:1 207:23;208:5,11; perspective (10) Phil (7)

 78:12;123:9; pathways (1) 211:7;212:16,24; 12:22;19:1;133:13; 21:17,18,20,24;

 161:10,16;226:22 14:6 218:22;226:22,23; 144:20;174:18; 23:20;24:23;25:8 

participated (1) patience (1) 240:17 190:21;196:24; phone (13)

 195:10 227:14 per (6) 198:23;209:19; 4:8;6:7,8,9,18,19;

participating (3) patrol (2) 23:7;40:15;67:25; 234:15 21:20;64:8;158:9;

 166:18;199:24; 132:20;134:15 139:18,19;173:11 pest (3) 179:16;180:3,6;233:4 

230:5 pause (3) percent (55) 43:23;50:13;90:25 photograph (1) 

Min-U-Script® Burke Court Reporting & Transcription (30) pain - photograph 

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94:6 places (3) 12:22;14:19;16:12; 29:23;111:12; 183:8 

photographs (2) 33:9;199:20;207:18 18:9;25:6;30:17; 119:2;134:19,23; post (4)

 90:6;93:16 plaguing (1) 32:12;35:4;37:10; 202:25 5:22;56:10;69:1;

phthalates (2) 195:3 39:11;40:13;41:6; poise (1) 236:8 

104:7;113:16 Plain (2) 42:5,18;43:8;44:12; 227:3 posted (2)

physical (2) 90:5;236:19 48:4;49:24;52:5,6; poisoned (1) 8:4,6 

112:25;214:12 plains (1) 54:24;56:18;57:24; 44:13 post-harvest (1)

physically (2) 246:24 60:11;62:25;70:10; poisonous (1) 173:25 

112:24;196:14 plain's (2) 79:1;80:10;84:20; 244:14 posting (1)

pick (5) 89:1;236:7 85:17;86:13;88:2,15; policies (1) 16:14 

32:4;61:4;152:24; plan (6) 90:15;92:21;95:20; 17:3 pot (2)

 154:20,21 8:2;13:1;64:10; 108:3,10;109:9; policy (12) 106:4,5 

picked (1) 203:16;210:5,9 111:4;113:1;115:7; 7:22;8:9;11:5,6; potential (6)

 153:1 plane (1) 122:25;124:7;129:20; 17:5;43:23;107:3; 63:13;79:12;107:6;

pickup (1) 51:21 143:4;144:14;146:19; 116:24;128:22,25; 113:8;134:17;165:11 

37:12 planet (6) 147:18;152:6;158:10; 213:21;240:25 potentially (7)

picture (1) 43:19;165:8,23; 163:21;165:1;182:22; politics (2) 24:2;39:21;58:21,

 155:16 166:2,8;212:24 190:8,25;200:20,21; 122:14,15 23;65:6;114:7;132:10 

pie (2) planning (1) 206:1;207:12;209:4; pollution (2) poultry (2)

 175:6,6 14:5 214:3;217:1;218:16; 116:8;166:4 139:25;140:3 

piece (9) plans (1) 219:17;220:16; polyethylene (1) pounds (1)

 126:25;127:22; 205:6 226:17;227:11;229:4; 44:16 140:1 

134:9;150:12;175:5; plant (7) 231:22;232:20; poor (1) Powell-Palm (229)

 180:15;204:2;211:10; 31:10;72:9;90:21, 233:10;235:23; 22:17 8:11;9:6,7;10:18;

 230:2 25;139:14;140:5; 237:24;240:14; popularity (1) 14:15,18;16:10;18:9;

pieces (1) 190:4 242:25 136:12 19:14;20:18;21:4,13;

 72:10 planted (5) pleased (1) population (1) 23:15;25:4,10;28:1;

pigeonhole (1) 61:2;62:17;66:19; 226:10 53:7 30:17;32:12;35:4;

 85:2 69:12,14 pleasure (3) pop-up (2) 36:14;37:4,8;39:10;

pile (1) plants (5) 75:11,13;105:2 6:12;179:14 40:12;41:6;42:2,5,10,

 48:17 43:19;108:23; pledge (1) pork (6) 15,22;44:12,25;48:1,

pill (1) 109:3;223:1,3 212:19 222:10,11,14; 20;49:24;51:16,24;

 44:13 plastic (45) plenty (5) 229:18,19,22 52:5,8;54:10,24;

pillaged (1) 44:5,9;81:4,11,13, 84:1,4,5,6;197:25 port (6) 56:17;57:9,20;58:3,5;

 30:11 17,19,21,23,25;82:5, Ploeger (16) 34:15,15;62:16; 59:18;60:2,5,8;62:11;

pilot (1) 7,11,12;83:24;84:3, 119:10;125:3; 133:1;136:14;154:15 65:23;67:21;68:8;

 82:5 25;103:11,14,17,18, 129:15,19,21,22; Porter (8) 69:25;70:6,8,10;

Pinkham (8) 19,20,22,23;114:21, 132:2,15;133:24; 42:17;57:22;58:2,4, 71:20;74:3;75:2,6;

 221:15;224:5; 22;196:7,8,19,19,20, 135:7,11;136:4,10,17; 6;60:1,3,7 77:11,16;79:1;80:2,4;

 233:7,11,11;236:13, 21;198:4;241:7,9,10, 137:3,16 portion (1) 82:18;84:20;85:17;

 18;238:4 13,18,22;242:8,10,16, plummeting (1) 63:9 86:4;88:14;89:25;

pins (1) 20;243:2 177:9 ports (10) 90:15;92:21;94:12,

 237:15 plastics (7) plus (2) 26:5;27:3;34:2; 16,20;95:8,13,20;

pioneer (1) 103:9,14;104:1,2,3, 176:2;181:8 59:10;60:24;61:3; 98:8,22;99:25;102:4,

 174:19 17;113:15 pm (5) 132:18,21;133:7,8 9;104:13,20;107:14,

pipe (1) platform (4) 4:2;94:19;169:5,5; position (8) 17,24;108:3;109:9;

 103:18 10:25;42:12; 247:24 8:17;15:21;108:6, 111:4;113:1;115:6;

pipeline (1) 140:11;234:11 podcase (1) 11;122:12,15;170:19; 116:16,19;118:24;

 91:21 play (2) 55:9 231:5 119:9;121:21;122:7,

pistachio (1) 100:20;212:2 podcasts (1) positive (7) 25;124:7;125:2;

 220:9 played (1) 55:9 105:14;131:14; 127:17,21;129:3,14,

pitch (1) 73:8 point (31) 156:15;165:10; 20;131:21;133:9;

 68:19 players (2) 21:3;30:21,22; 228:13;229:1;235:10 134:21;137:17,22;

place (12) 149:18;164:7 32:16;34:5;47:19; positives (1) 139:22;140:7,15;

 65:9;120:17; playing (6) 49:3,23;66:4,20; 122:13 142:16,23;143:4;

 142:13;147:9;182:4; 131:8;143:20; 71:13;97:19;99:20; positivity (1) 144:12;145:21;

 196:4,5;205:6; 144:6;147:3;197:22; 111:11,14;121:17,19, 80:24 146:19;147:14,18,23;

 206:24;222:17; 223:14 20;122:1;131:13; possible (11) 149:23;150:4;151:6,

 225:25;236:21 plays (2) 148:20;154:10;181:8; 28:15,16;51:4,6,13; 18,21,24;152:2,6;

placed (1) 32:18;165:13 192:2;202:5;212:3,4, 59:16;87:3;117:23; 154:23;157:14;158:3,

 86:18 Please (84) 5;213:10;217:11; 176:4;178:6;200:13 7,10;159:1;160:13,

placement (1) 4:21;5:12,24;6:13; 240:23 possibly (4) 17;162:10;163:21;

 231:19 7:2;8:14,17;11:22; points (6) 64:17;71:2;74:11; 164:11,14;166:14; 

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October 19, 2023 

167:6,19;168:17; 152:9 70:20;97:25;121:17; problem (26) 99:14;148:7;164:24;

 169:1,6,9;171:11,15, prefer (1) 127:13;131:15,18; 17:7;23:17;38:7; 222:19 

19;174:4,11;176:14, 69:18 133:2;134:11;137:7; 45:20;46:8;57:7; producers (34)

 18;178:21,24;179:2,5, preferred (1) 144:24;157:4;230:25; 63:12;70:23;82:4; 13:22;14:4;17:6;

 9,11,16,19,24;182:14, 69:17 243:3 93:15;94:8;99:6,19; 18:13;38:9,10;41:13;

 19,22;184:16;185:20; premium (4) priced (1) 110:19;115:1;125:19, 87:5;96:1,8,20;97:22;

 186:3;187:1,6,10; 18:22;46:9;57:13; 115:22 23;128:6;141:25; 100:24;101:6,9,10,15;

 189:23;190:25;191:9, 173:19 prices (12) 151:8;213:8;230:13; 107:22;123:9;149:5,

 12;193:6;194:5,8; premiums (2) 41:8,15;61:12; 236:20,25;243:4,5 20;153:17;168:1;

 197:4;198:18;199:10; 173:22,24 63:22;65:2,3;67:7; problematic (2) 178:4;186:13;188:5;

 200:20,24;201:2,5; preparation (1) 133:4;137:8,10; 41:16;153:3 189:19;221:1;222:11,

 203:21;206:1;207:12; 205:10 231:2,3 problems (12) 19,21;223:14;229:18;

 209:4;211:15,17; prepare (2) pricing (6) 5:12,15;92:25; 240:2 

213:12,17;215:20; 11:21;101:9 30:13,13;35:6; 104:5;125:13;152:18; produces (1)

 216:3;218:8;219:17; prepared (2) 125:21;173:15,16 172:7;174:19;230:9; 145:3 

220:19,24;221:5; 101:9;205:6 primarily (11) 237:8;245:17,19 producing (6)

 223:20;224:4;226:13, preparing (1) 72:6;75:25;106:17; procedures (6) 13:23;21:25;23:5;

 16;227:11;229:4; 14:10 109:23;125:10;134:4; 8:10;11:6;44:10; 29:22;165:16;194:24 

231:22;232:20;233:2, prescribe (1) 135:12;161:18; 189:9;203:16;218:6 product (33)

 6;235:23;237:24; 92:3 213:25;229:10; proceeds (1) 34:4;59:7;78:10;

 238:7;240:10,19; presence (1) 238:18 51:23 114:4,15,17;115:1;

 242:22;243:12,16; 135:8 primary (3) process (42) 117:22;118:1;127:11;

 246:5;247:4,17 Present (9) 37:20;126:22; 7:22,25;8:14;24:22; 128:9;135:25,25,25;

power (3) 9:7,20;10:1,9; 241:21 25:16;30:2;32:18; 136:1,1,3;138:16;

 118:15;122:16,24 11:17;134:25;146:23; prime (1) 37:3;51:7;56:20;58:8, 139:12,18;146:10;

powerful (2) 189:10;242:21 106:25 24;65:25;76:9,11,16, 154:5,6,11,15,16;

 56:22;121:17 presented (1) principle (1) 19;78:1,2,6,9,11; 155:20;156:12;214:6,

PowerPoint (1) 63:11 174:20 79:18,19;89:1;92:4; 9;225:16,16;241:24 

5:2 president (1) principles (4) 103:13;116:12; production (50)

practical (1) 43:6 105:19;177:24; 127:15;144:16;147:4; 13:15;15:18;30:15;

 129:1 pressure (5) 224:14;234:3 161:6,12;166:18; 58:10;87:13;103:12,

practice (18) 19:11;87:2;88:2; prior (5) 169:24;182:25; 14;105:22;109:4;

 12:13;59:22;72:8, 144:1;215:15 12:16;26:1;40:9; 183:23;192:9,10; 111:17,17,23,24;

 14,18,21;73:24; pretty (12) 111:6;218:1 193:24;207:6,8 121:10;123:23,25;

 74:23;82:7,12;85:3; 19:12;24:12;37:21; priorities (5) process-based (1) 163:16,20;165:10;

 92:15;148:23;186:5, 38:13;46:10;58:17; 77:6;103:11;139:6, 153:4 173:15;181:9,20,21;

 9;202:10;204:19; 148:12;150:25; 7;230:23 processed (3) 188:9,13;189:21;

 214:21 154:16;168:18; prioritize (1) 76:22;177:19; 191:21,24;192:7,16,

practices (22) 186:23;220:1 222:2 185:15 22;195:17;196:2,7,

 49:19;73:8,12; prevalence (1) priority (6) processes (6) 10;222:24,25;223:5,6,

 74:17;80:21;96:22, 181:21 61:14;88:9;173:23; 67:15;78:15,16,18; 10,12,15,17;235:3;

 24;97:3,23;98:15; prevalent (1) 221:23;225:2;229:3 225:2,5 238:22;240:25;

 119:19;123:12;126:6; 181:20 privacy (1) processing (6) 241:13,18,22;244:19 

127:4;128:19,20,21; prevent (5) 20:23 27:1;78:19,21; productive (1)

 165:8;166:13;168:9; 14:12;60:17;115:3; private (2) 96:24;98:13;169:17 132:11 

184:12;203:5 116:1;234:22 166:12;208:23 processor (4) products (50)

preamble (1) preventing (1) privilege (1) 26:24;30:22;31:2,5 15:7;18:22;28:20;

 203:9 177:4 105:2 processors (5) 45:25;50:14,22;51:1;

pre-approval (1) prevention (5) privileged (1) 26:25;30:22,23; 56:25;57:4;61:11;

 73:1 12:13;201:11; 113:13 96:18;233:13 71:10;76:21,25;

precedence (2) 206:3;210:5;237:10 privy (1) Produce (28) 77:21;78:19;79:7;

 153:20,21 preventive (1) 71:8 12:8,17;15:9,21; 81:6;107:9,22;

precedent (1) 36:22 probably (30) 16:7,8;20:1;22:12,15, 112:16;114:25;127:4,

 86:23 preview (1) 19:3;22:11,18; 22;26:23;81:2,9; 4,5;131:8;136:20;

preceding (1) 227:17 24:13;25:25;48:3; 141:14;144:2,3; 138:24;139:9,15;

 223:6 previous (8) 55:2;63:21;72:11; 184:1;187:19,23; 151:10;154:2;159:11;

precise (1) 14:23;44:23;86:24; 73:18;83:9,11,15; 188:6,8;195:15; 162:20;166:23;170:1;

 108:25 125:13,18;142:1; 135:14,15;142:13; 198:25;230:5;241:1, 181:3,23;182:3,11;

precursor (1) 152:15;229:15 146:13;148:18;149:1, 11,11;245:12 185:17;199:1;205:4;

 189:7 price (28) 2;150:16,18;158:25; produced (2) 210:13;213:6;217:11;

predecessors (1) 29:22,23;30:9;38:3, 159:23;163:10; 38:10;49:19 238:14,15;241:12;

 178:13 22;39:2,3;40:8,9,15, 198:15;204:14;210:9; producer (7) 242:9;245:4 

Predominantly (1) 19,22;41:2,19;69:5; 230:21;231:15 27:21;38:1;45:8; professors (1) 

Min-U-Script® Burke Court Reporting & Transcription (32) power - professors 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 2 

October 19, 2023 

73:20 

profile (3)

 155:7,12,14 

profiles (1)

 157:24 

profit (5)

 53:19;118:21;

 144:3;174:20;230:10 

profitability (1)

 151:12 

profitable (1)

 121:18 

profits (1)

 34:13 

program (50)

 4:15;7:12;9:1;

 44:14;46:1;71:3,17;

 82:17;85:20,21;

 86:19;92:14;113:9,

 22;121:23;150:15;

 153:3;161:16;167:24,

 25;169:21;178:13;

 180:20;187:24;

 189:12;194:22,23;

 166:4;172:20 

promoting (4)

 19:1,2;191:5;245:5 

promotion (4)

 165:6;166:11;

 218:21;219:1 

prompt (1)

 179:6 

pronounce (1)

 240:18 

pronouncing (1)

 194:11 

proof (3)

 98:14,18;156:24 

propaganda (2)

 54:6;118:4 

proper (1)

 183:3 

properly (1)

 49:4 

properties (2)

 47:10,11 

property (1)

 89:4 

225:15;228:10,21;

 236:19;241:2,19 

provided (6)

 106:9;170:18;

 188:22;214:7;238:2;

 241:6 

Providence (7)

 8:2;19:16;44:7;

 102:7;104:19;162:7;

 247:22 

provides (5)

 93:5;161:13;

 214:22;225:3;241:22 

providing (8)

 11:11;73:11;76:2;

 78:8;79:7;117:10;

 188:15;241:12 

proving (2)

 22:4,23 

provisions (3)

 63:3;238:18;239:5 

Proxy (2)

 11:10;163:6 

psychological (2)

put (32)

 19:9;27:18;31:11;

 32:8;34:22;44:2;

 47:18;48:7;49:15;

 66:11;73:24;87:14,

 19;115:23;124:1;

 126:12;138:23;

 139:20;140:2,4,5;

 150:21;154:14,19;

 168:6;176:1;181:23;

 204:9;205:15;206:9;

 207:2;227:23 

puts (1)

 105:20 

putting (17)

 23:3;49:7;65:13;

 71:23;97:13;102:16;

 111:1;128:2;139:17,

 25;149:17;160:7;

 205:5;210:8;213:5;

 221:2;226:1 

218:17;232:4 

quo (1)

 161:11 

quote (1)

 83:10 

R 

R&D (1)

 43:14 

race (2)

 224:13,24 

racial (8)

 170:14,16;224:12,

 13;225:2,5,7;227:16 

racism (1)

 224:23 

radar (1)

 61:25 

Ragu (2)

 240:17,22 

Raikes (7)

 52:1;57:22;60:9;

 70:6,9,11,12 

Q 

195:2,4,5,22;197:3, proposal (17) 29:25;30:13 QR (1) rain (3)

 12,15;202:19;203:1, 12:12,12,17;87:4,8, psychologically (1) 56:4 196:14,16;245:21 

12;212:20,23;215:6; 10;88:22;98:21; 30:10 quality (4) raise (9)

 218:21,25,25;226:8; 170:12;189:11;230:7; public (28) 17:7;195:15;205:4; 33:4;59:1;107:5;

 228:7,24;229:20; 234:17;236:5,25; 4:5,13,13;7:15,21, 241:15 112:6,11;141:15;

 230:14;233:12,15 237:6,8,16 24;11:6,9,11,16; quantifies (1) 159:2;166:6;226:24 

programs (13) proposed (4) 12:20;20:25;55:18; 61:3 raised (3)

 13:22;14:9;19:20; 218:23;219:4; 88:10;89:1;105:8; quantity (1) 4:21;199:14;232:8 

27:17;82:5;170:16; 235:7;242:14 130:2;132:9;166:12, 181:3 raises (1)

 195:24;212:18,19; proprietary (1) 21;191:16;207:23; Quarcoo (3) 108:24 

219:12,23;228:19; 135:5 214:8,10;219:3; 10:8,9;67:24 raisin (1)

 235:17 protect (8) 225:6;233:19;247:18 quick (28) 20:6 

program's (1) 17:3;23:4;63:25; publication (1) 30:20;31:14;36:15; raising (1)

 235:16 67:18;71:2;146:15; 222:6 48:23;56:3;59:20; 38:6 

progress (3) 172:3;226:12 publicly (2) 67:22,24;79:2;89:25; ranchers (2)

 43:7;79:25;175:17 protecting (4) 113:12;208:8 109:7;119:20;124:8; 80:15;81:1 

prohibit (3) 82:17;87:25; pull (5) 139:22;146:20;148:2, random (1)

 110:17;177:12,13 191:18,21 45:15,16;48:10; 16;150:2;155:18; 204:23 

prohibited (7) protection (3) 64:15;223:25 175:24;184:19;186:1; randomness (5)

 117:20;177:25; 173:18;204:4;234:7 pulled (1) 198:19,25;221:21; 204:4,5,6,14;

 188:11,14;189:5,6; protein (4) 142:3 229:7;232:18,20 205:21 

203:11 79:4,13,23;155:7 pulling (1) quicker (1) range (3)

prohibiting (2) proud (2) 62:15 230:22 89:7;180:23;220:1 

162:20,23 164:25;182:24 purchase (1) quickly (4) ranging (1)

prohibition (2) prove (12) 12:19 51:13;91:22; 194:20 

105:17;192:14 23:13;98:4;123:22; purchases (1) 114:20;154:16 rank (1)

prohibits (1) 127:15;139:15,20; 213:7 Quinn (9) 206:11 

181:22 143:12;154:8,11,16; purchasing (2) 221:16;233:10; rapid (1)

Project (5) 203:4;230:8 18:18;134:2 238:9;240:15;243:17, 132:20 

119:14;175:19,20; proven (2) purpose (4) 19,20;246:15;247:15 rapidly (1)

 176:22;195:24 22:25;40:5 156:10,11;208:1; quire (1) 106:20 

proliferate (1) proverbial (1) 238:13 197:19 rare (2)

 223:13 106:4 purposes (3) quite (18) 93:6;181:24 

promote (4) provide (22) 23:14;205:3;239:4 31:19;45:13;74:21; rate (6)

 80:20;222:12; 8:17;12:21;43:11; push (3) 85:5;108:21;109:1; 76:22;177:9,11;

 246:2;247:5 66:2;74:22;93:10; 82:10;102:18; 113:4;138:4,22; 184:7;199:8;244:7 

promoted (1) 94:10;98:18,19; 110:21 144:25;150:18; rated (2)

 243:25 157:15;189:8;193:2; pushing (2) 152:10;181:6;183:16; 112:13;184:9 

promotes (2) 195:25;214:3,8,9; 104:6;188:20 196:17;216:25; rather (9) 

Min-U-Script® Burke Court Reporting & Transcription (33) profile - rather 

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NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 2 

October 19, 2023 

50:22;51:8;59:11; 68:18,21;69:21,25; receive (4) 118:13 regenerate (1)

 106:6;161:10;162:4; 71:20,25;74:5,6,10, 72:7;173:21; reduce (4) 176:10 

163:7;223:4;225:11 12;75:1,18;76:6; 188:25;225:13 49:14;77:25;96:10; regenerates (1)

raw (1) 77:13,18;79:19; received (3) 214:24 166:3 

143:25 80:16;83:18,23;85:8, 60:24;72:19;157:1 reduced (2) regenerative (14)

reach (3) 10,22;92:13,23,25; receiving (4) 134:5;173:25 13:13;20:10;78:13;

 18:5;171:6;244:7 93:14;96:10;97:4,11; 61:3;180:18,20; reduces (2) 174:23,25;175:1,22,

reached (4) 98:10;99:22;100:2; 195:13 166:3;239:12 25;176:5,13;184:12;

 72:14;73:19; 101:6,10;102:12,13; recent (6) reducing (5) 185:15;243:21,24 

172:24;183:9 108:5;112:19;119:4, 87:16;96:14;166:8; 78:2;81:16;103:11; region (8)

reaching (1) 7;122:1;123:3;126:8; 176:23;208:6;225:4 106:9;213:25 16:20,22;83:5;

 133:21 129:9;133:13,15; recently (6) reduction (3) 111:13;173:16;184:7,

react (1) 134:22;137:17; 91:9;97:8;120:21; 173:10;244:16,18 9;233:13 

131:17 138:18;140:7,12; 161:22;165:23;171:2 redundant (1) regional (3)

read (5) 142:16,21;145:17; reception (1) 148:4 167:18;215:22;

 27:11;53:24;104:9; 147:12;149:23;150:4, 137:24 Reed (1) 245:8 

172:15;234:10 9;151:6,13;152:10,12, recognize (5) 238:9 regions (3)

readily (2) 17,19;153:22;154:2; 87:17;165:12; Reef (1) 17:3;132:12;181:1 

241:16,24 157:11,20,20;158:3, 196:25;232:12;242:7 171:25 register (1)

reading (4) 22;159:2;160:13; recognized (1) reemerged (1) 76:16 

13:4;198:3,5;212:5 163:15,18,19;166:22; 11:7 69:7 registered (3)

readings (1) 167:9,11,11;168:7; recognizes (3) reestablish (1) 4:22;6:10;77:21 

13:2 171:11;172:18;174:6, 91:23;106:8;231:3 47:22 registration (1)

ready (1) 20;175:13,13,23; recognizing (3) re-export (2) 11:8 

95:9 176:9;181:11;182:14; 91:7;204:12;227:1 154:7,8 Regretfully (1)

reaffirming (1) 183:18,22;184:12; recommendation (6) refer (3) 225:13 

151:7 185:20;186:8,10,13, 12:14;86:25;88:3; 13:18;86:13;165:1 regular (3)

real (44) 17;187:1;188:20; 91:6;93:5;104:10 reference (7) 38:6;55:21;174:6 

26:4;30:20;35:13; 189:19;194:5;196:1; recommendations (7) 105:24;106:3; regularly (1)

 39:15;41:20;46:12; 198:21,23;199:10,18; 131:12;134:14; 109:18;191:2;193:12; 200:4 

48:15;62:1;65:5;67:1, 200:21;203:21; 170:15;217:25;225:4; 202:12;240:23 regulated (1)

 22;69:23;99:20; 205:22,22;206:3,22; 233:23;234:11 referenced (3) 126:24 

100:12,12;112:22; 208:11;209:9;211:20; reconvene (1) 193:18;203:8; regulation (6)

 119:14;120:10; 212:11;213:10; 247:22 242:19 13:16;64:2;162:4;

 127:13;128:1;148:2, 220:19;221:3,8,10; record (25) referencing (3) 163:24;202:9;204:20 

16;150:2;155:18; 223:23;226:9,11; 4:13;6:22;11:9; 68:3;109:24;111:2 regulations (13)

 174:21,23;175:19,20, 227:1,1,21;228:1,6, 13:5;94:19;96:7;97:1; referred (2) 26:6,6;65:9;66:7;

 21;176:2,12,13,13,22; 12,21,24;229:23; 98:2,5;99:23;100:11, 76:13,14 96:11;122:16;162:21;

 177:18,19;178:19; 230:5,12,14,19; 19,20,25;101:12,18, reflect (4) 177:7;238:21;239:1,

 195:24;198:18,25; 231:13;236:15;237:1, 21;168:14;201:18; 10:21;173:9,15; 2,3,6 

209:8;211:3;213:8; 4,6;238:2,5;240:12; 214:12,18;216:9; 224:16 regulatory (4)

 230:21 243:13;246:8,17,25; 225:18,21;239:10 reflective (1) 80:12;192:18;

reality (2) 247:10,16 recorded (3) 188:12 213:25;214:11 

177:8;182:11 rearing (1) 5:17;12:25,25 reflects (1) reiterate (2)

realize (4) 76:10 recording (3) 172:8 57:10;138:18 

28:2;113:6;129:10; rearrange (1) 5:18,20;214:21 reform (2) reject (1)

 220:21 4:24 records (9) 176:23;177:7 123:16 

real-life (1) reason (7) 96:17;97:5,5,7; refrain (1) rekindling (1)

 23:23 35:18;83:16;93:19; 98:4;101:2,18,21; 11:11 218:19 

really (206) 135:12;173:4;212:13; 141:23 refuge (1) relabeled (1)

 9:1;10:23;11:3,15; 241:21 recovery (1) 53:12 66:24 

17:12;18:1;19:10; reasonable (1) 227:7 refuse (1) Related (8)

 21:4;22:5;23:24;25:5; 93:8 recyclable (1) 195:6 13:7;14:5;131:25;

 26:14;28:10,14;29:5, reasonably (1) 103:20 regard (1) 132:3;161:14;216:15;

 17;36:3,14;37:4;39:5, 151:9 recycled (1) 12:11 219:22;242:7 

10;40:7,23;41:14; reasons (2) 81:24 regarding (8) relates (4)

 42:2;43:17;46:12; 16:19;111:16 recycling (9) 111:10;170:2,7,12, 58:16;98:21;

 47:3,11,20,22;48:14; recall (1) 81:25;82:3,5,7,11; 14;172:9;214:2; 193:11;201:17 

49:4,5,11,13;50:20; 153:24 84:23,25;85:15; 233:21 relating (1)

 51:16,20;52:13;53:2; receipt (1) 103:23 regardless (1) 193:25 

54:4;55:1,15;57:2,15, 66:12 red (1) 163:9 relationship (3)

 17;58:14;59:18;60:2; receipts (1) 64:1 regards (2) 31:25;71:5;167:8 

62:4;64:9;65:25; 153:8 redefined (1) 54:8;221:21 relationships (1) 

Min-U-Script® Burke Court Reporting & Transcription (34) raw - relationships 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 2 

October 19, 2023 

71:7 replant (1) 13:4;47:14;50:5; 19:7 28:18,21;30:9;35:7;

relatively (3) 38:15 193:14;238:17 restrict (1) 38:4;40:6;41:25;

 47:13;58:10;241:16 replanting (1) requiring (6) 68:23 44:25;46:4,14,17;

relay (1) 38:16 44:13;61:14;66:3; restricted (1) 48:20;49:22;51:16,

 4:11 report (4) 99:17;107:20;193:10 23:7 25;53:10;58:4;60:6,

re-lease (1) 156:18;172:10; rescuing (1) result (1) 13;61:7;62:16,18,19,

 31:24 208:11;227:19 106:6 161:12 20;63:17;64:7;66:3;

relevant (1) reported (1) research (24) results (2) 67:6,6,13;69:2,15;

 125:18 22:7 42:6;48:24;49:3,8, 203:4;235:10 70:4,8,11;71:20,22,

reliable (1) reporting (3) 12;123:6,10,10,14; resume (1) 24;74:13,19;77:13;

 138:10 131:12,16;134:9 143:12;167:17; 223:16 78:8,25;80:2;83:5,19,

relief (2) reports (1) 218:21;219:5;233:23; retail (4) 24;84:3;85:11,12;

 32:19;171:7 156:3 244:10;245:10,15,16, 19:6;71:5,6,7 86:4;90:15;91:19,23;

relies (1) represent (2) 21,24,25;246:3,21; retailer (3) 94:12;95:16,17,19,20;

 130:25 96:1;130:4 247:6 19:8;115:15;212:24 96:10;97:7,18;98:6,

relieving (1) representation (2) researching (1) retailers (15) 14,22;101:13,17;

 215:15 144:17,17 50:13 17:13;18:24;19:11, 102:6,12;103:18;

religious (2) representatives (1) residential (1) 12,24;71:9,9;212:8,9, 104:15,20;109:19;

 93:6,24 119:17 99:11 10,14,14,17;213:3,9 120:9;121:3,7;122:8,

relist (1) represented (3) resides (1) retention (2) 22;125:2,8;128:1;

 82:14 60:23;88:18;219:13 185:6 81:13;161:14 129:8;133:6;136:15,

relisting (1) representing (8) residue (17) return (2) 16,17;137:2,14,24;

 81:5 12:7;75:25;133:15; 43:20;111:10; 47:15;244:16 140:9,15;142:24;

re-listing (1) 169:17;187:23; 117:17,25;132:9; revenue (4) 143:5;147:17;149:23,

 44:6 201:19;206:8;236:1 153:6;155:9;170:12; 24:3,5;34:12;47:4 24;153:4;154:18;

reluctance (1) represents (2) 202:19;203:1,8; reverse (1) 158:10;159:3;160:4;

 134:3 167:2;195:20 215:5,6,7;235:4,6,8 110:16 164:2,3,19;169:1;

rely (3) reputable (2) resilient (1) review (10) 171:13;174:10,15;

 50:16;146:13,14 31:6;202:11 196:22 106:2;169:24; 177:15;178:1,17,22;

remain (1) request (6) resistance (1) 192:10,13,15;193:1, 179:2,21;180:1,5,9;

 5:11 155:14;156:3; 161:15 21;194:1;236:22; 182:14,23,23;186:8,

remains (2) 161:23;172:17;214:2; resonate (1) 241:4 11;187:12;190:15;

 118:11;163:1 221:22 34:5 reviewed (4) 191:9;194:5,10,11;

remarks (3) requests (1) resonating (1) 86:18;106:11; 195:8;201:6,7;

 11:12;227:4;241:3 226:8 100:3 114:3;192:8 203:21;204:7;205:1,

remedies (1) require (11) resource (1) reviewing (3) 9,11,12,14;206:16,22;

 52:25 78:19;87:17;96:17; 132:11 51:7;198:3,4 207:4;208:4,14,19;

remember (4) 101:12;109:12; resources (6) reviews (2) 210:1,3,3,4,10,11,17,

 11:22;15:8;80:21; 113:11,14;127:11; 27:20;110:4; 7:7;193:21 19,19;211:1,7,16;

 185:4 132:8;170:13;217:23 145:10;212:9;235:19; revision (1) 212:2,12,17,22;213:5,

remind (4) required (10) 242:3 170:2 14,15;215:25;216:7;

 8:13;48:2;60:10; 63:18;87:19;98:17; respect (3) revoke (1) 218:8;220:14;223:24;

 219:2 99:23;107:24;117:13; 8:17;67:2;233:20 223:8 224:18,19;238:7;

reminder (1) 131:10;172:3;214:10; respectful (1) reward (1) 240:12,15,20;243:13;

 11:5 242:3 8:14 177:15 245:15;247:17 

removal (1) requirement (24) respond (3) rewrite (1) rightly (1)

 242:10 63:4;84:25;85:5,6, 19:12;167:14;204:4 124:4 153:1 

remove (2) 8,13,13,20,20;93:25; responding (2) rewrites (1) rights (1)

 87:10;191:6 98:20;117:3;188:23; 41:17;203:4 121:2 123:7 

removing (2) 191:3;202:9,10; response (9) Rhoades (4) rigorous (2)

 81:18;109:6 204:18;210:19; 10:14;72:23;73:22; 160:20,23,25; 169:24;182:8 

rename (1) 214:11;215:6;223:7; 119:20;121:3;157:2; 162:13 ripe (1)

 6:2 237:18;238:20,24 163:23;203:5;206:24 Rhode (4) 130:16 

rent (2) requirements (22) responsibility (3) 8:2;77:8;247:19,22 rise (2)

 47:4;112:14 34:17;63:7;93:2; 12:24;202:20; rice (1) 161:19;184:14 

repair (1) 97:1;100:5;101:1,7; 208:16 91:21 risk (46)

 115:25 113:9,10;119:19; responsible (1) rid (1) 34:1;35:9,10,15,23;

repeat (2) 123:10;131:6;162:23; 155:22 120:16 36:5;37:15;39:8,18;

 127:21,22 188:3,23;192:22; rest (7) right (193) 98:13,14;99:22,24;

repeatable (1) 214:4;215:3,10; 70:2;71:18;80:7; 4:3;5:20,24;7:10; 107:4;111:9,12,22;

 78:7 225:18;238:21; 102:5;124:1;151:21; 9:5;10:15;16:3;20:10, 112:11,13;114:8,12,

repercussions (1) 239:10 231:16 20;21:4,14,16,23; 13,13,13;125:21;

 181:16 requires (5) restaurants (1) 22:25;23:2;24:22; 126:8,18;130:9; 

Min-U-Script® Burke Court Reporting & Transcription (35) relatively - risk 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 2 

October 19, 2023 

131:3;135:23;136:7,

 13,23,24;151:9;

 154:18;167:20;

 172:15,17;173:6;

 214:21;215:2;225:22;

 226:1;234:7;235:12 

risks (1)

 41:11 

RMA (8)

 39:18;40:23;41:22;

 72:20,20,23;172:20;

 231:3 

road (6)

 42:11;50:11;

 138:17;149:17;213:2;

 218:22 

roads (1)

 99:12 

Rob (3)

 187:6,8,13 

Robert (1)

 189:25 

robust (6)

 43:10;44:18;46:25;

 172:13;176:10;245:8 

rock (1)

 62:22 

rocket (6)

 126:15;127:22,23;

 129:5;141:13,14 

Rodel (5)

 167:8,16,18;168:6;

 174:24 

role (4)

 76:5;102:16;

 165:12;218:23 

roll (1)

 9:4 

roller (2)

 72:9;124:19 

rolling (1)

 59:16 

room (4)

 79:24;80:23;93:5;

 206:7 

27:14;61:1;169:17,

 18 

round (3)

 8:21;95:14;176:7 

route (1)

 229:1 

routine (1)

 205:9 

row (1)

 125:10 

rubber (1)

 230:14 

rule (18)

 46:3;63:4;86:16,20,

 24;87:16,24;96:15,16,

 16;162:20;169:21;

 203:10;204:18;218:4;

 219:4;225:9;231:24 

rules (4)

 70:25;161:23;

 162:23;163:8 

ruminants (1)

 177:12 

rumor (2)

 132:25;207:18 

rumors (1)

 17:23 

run (13)

 8:8;11:4;25:15;

 27:2;31:10;68:14;

 112:5;124:10;132:20;

 133:4,7;145:6,7 

running (12)

 27:5,5;49:6;95:16;

 120:3,4;122:3;

 194:12;196:24;

 212:12;221:12;

 227:14 

runs (2)

 95:3;105:18 

rye (1)

 72:9 

238:8,10,11;240:12 

same (37)

 8:17;35:1;40:6;

 51:11;55:15,16,22;

 69:8;72:15;81:18;

 88:10;92:8;99:22;

 101:24;112:6;121:9;

 122:23;126:14;131:9;

 133:4;135:12;147:9;

 168:22;191:20;

 195:14,15,15;197:21;

 198:5,15;203:7;

 215:3;226:11;230:9;

 233:20;241:13;

 245:23 

sample (3)

 155:8;156:13,16 

sampling (1)

 235:12 

sandy (2)

 46:20;196:12 

Sara (7)

 221:15;233:7;

 238:8;240:13,24;

 243:12,13 

satellite (2)

 126:16;127:24 

sauce (2)

 240:17,23 

saved (1)

 77:18 

savings (1)

 67:11 

saw (2)

 69:2;175:5 

saying (23)

 19:3;29:11;41:16;

 47:16;49:9,10;50:22;

 59:22;65:18;70:19;

 74:8,9,13;90:19;97:6;

 115:24;124:21;129:5;

 142:3;168:22;186:14;

 211:7;212:1 

scale (3)

 167:10;206:11;

 122:12 

school (5)

 19:19;20:2;52:18;

 216:21;224:19 

Schreiner (8)

 164:16;169:4;

 171:16,18,20,20,24;

 174:10 

science (2)

 46:18;202:11 

science- (1)

 242:13 

scientists (1)

 234:2 

scopes (1)

 214:5 

Scoular (7)

 129:22;130:4,19;

 131:5;135:8,15,23 

Scoular's (1)

 129:24 

scrambling (1)

 210:25 

scratch (1)

 177:20 

screaming (1)

 49:20 

screen (13)

 4:24;5:3,5,6,10,11;

 6:12;7:3;157:20;

 163:11;179:14;217:4;

 226:19 

screening (1)

 212:19 

screenings (1)

 163:9 

screens (2)

 157:16;163:6 

screws (1)

 29:17 

scrutiny (2)

 197:13;208:14 

seal (4)

 67:12;165:18;

 195:17,20 

228:16;238:15;246:6 

secondly (6)

 59:3;132:7,14;

 155:19;222:4;228:14 

secret (1)

 168:23 

Secretary (3)

 49:11;178:11;

 216:12 

section (4)

 86:23;89:7;93:16;

 180:23 

sector (6)

 45:18;75:23;77:4;

 79:9;166:12;189:14 

sectors (1)

 59:15 

secure (1)

 87:16 

security (1)

 245:9 

seed (8)

 47:4;87:22;91:11,

 12,13;132:6,13;153:8 

seeds (2)

 87:19;109:3 

seeing (13)

 32:2;42:11,17;

 97:24;104:18;108:20,

 22;135:19;149:18;

 162:6;167:24;223:18;

 226:19 

seek (1)

 162:2 

seeking (2)

 235:17;245:18 

seem (1)

 47:1 

seemed (2)

 17:22;89:2 

seeming (1)

 100:12 

seemingly (1)

 30:12 

seems (13)

S 

root (1) safe (2) 219:24 seals (2) 20:13;26:15;28:12;

 57:6 51:11;78:10 scaled (1) 212:25;213:1 33:2;41:11;47:7,11;

Ross (6) safer (1) 175:8 search (1) 58:23;68:21;138:19;

 102:22;104:22; 51:10 scarce (1) 214:8 145:15;168:22;

 116:19,22,23;119:8 Safety (4) 110:5 seas (1) 220:24 

rotate (1) 103:3;186:21; scare (1) 29:12 segment (3)

 145:23 191:17,18 62:24 season (2) 49:6;128:7;152:11 

rotates (1) Sal (7) scared (1) 173:24;196:18 segments (3)

 172:1 221:15;224:5; 208:17 seat (1) 8:4,6,11 

rotation (4) 233:6,10,11;235:23, scenario (2) 93:1 segregation (1)

 22:20;145:24; 25 73:12;133:4 Second (23) 112:4 

146:1,11 sale (3) scenarios (2) 13:20;14:19;23:9; selenium (5)

rotations (4) 71:5;212:3;213:10 73:9;87:13 34:4;43:1;54:14;95:2; 139:15,16,18,21;

 35:14;174:22; sales (6) schedule (1) 103:14;104:11; 140:2 

176:11;246:24 19:6;101:17,21; 11:20 117:16;127:21;139:8; self-insuring (1)

rough (1) 169:17;177:25;178:2 scheduled (3) 154:21;179:4;181:2; 17:8 

62:16 Sam (6) 6:4;108:16;173:20 184:20;194:12; self-unmute (1)

roughly (4) 221:15;233:7; scheme (1) 211:22;215:16;216:6; 179:6 

Min-U-Script® Burke Court Reporting & Transcription (36) risks - self-unmute 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 2 

October 19, 2023 

sell (6) 80:14;130:21 shipped (4) side (31) 135:17;169:1;200:3;

 31:4;55:21;76:24; session (1) 59:8;66:23,25; 6:16;14:25;32:3; 244:6,24;246:1 

130:7;146:3;156:12 8:12 144:25 34:3;37:15;46:18,18; size (2)

seller (2) sessions (1) shipper (1) 47:18;48:8,9,19; 4:19;117:6 

136:11,14 7:20 155:23 83:21;89:17;108:16; skill (1)

sellers (2) set (7) shipping (3) 110:19;128:3;133:3; 200:9 

130:5;131:14 30:9;35:22,23; 33:3,5;65:14 144:10;148:3,14; skip (1)

selling (7) 40:23;64:22;121:17; ships (1) 150:23;152:9,10,10, 95:7 

18:14;26:24;98:18; 126:1 127:10 21,22;153:2,17,20; slats (1)

 142:5,6;159:11; setting (2) shocked (1) 163:1;184:11 190:11 

165:16 103:11;119:5 209:23 sidelight (1) slew (1)

Senator (1) settled (3) shockwaves (3) 125:17 237:7 

191:4 88:12;178:16,17 130:23;131:18; sign (2) slice (1)

send (6) seventh (1) 133:2 176:25;177:1 132:15 

68:10;122:20; 194:16 shoot (1) signals (1) slide (16)

 156:13,13;157:24; several (5) 68:15 163:19 4:7;5:3,24;11:7;

 159:24 118:18;130:16; shop (1) signed (2) 43:4,11,17,20;44:5,

senior (1) 165:19;166:2;226:20 167:12 11:7;178:13 17;49:2;201:21;

 52:17 severe (2) shopper (1) significant (5) 202:18;203:19;217:1,

sense (8) 38:8;138:4 212:4 32:17;87:14; 5 

24:14;26:11;29:12; severely (1) shoppers (4) 165:12;189:12; slides (4)

 35:7;102:1;139:10; 26:22 213:6,6;244:12; 245:16 4:9;42:24;44:23;

 160:10;237:21 Seward (1) 245:3 significantly (2) 68:20 

sensible (2) 37:19 short (7) 178:15;195:4 slide's (1)

 98:1;214:22 sexism (1) 29:6,17;38:1;68:10; Silver (1) 216:6 

sensitivity (1) 224:23 77:2;82:1;157:10 171:25 slightest (1)

 163:2 SFA (1) shortage (1) similar (7) 227:2 

sent (5) 231:1 145:13 18:13;87:24; slightly (3)

 44:16;72:23;156:2; shake (1) shortfall (1) 106:11,18;114:22; 78:17,18;106:15 

169:23;173:1 247:7 245:1 230:16;244:23 slime (2)

sentence (3) shall (1) shorthand (1) Similarly (3) 106:17,17 

7:2;106:14;224:20 11:11 110:4 111:21;180:23; slowing (1)

sentiments (1) shapes (1) shortly (2) 181:20 64:7 

27:24 7:22 5:18;108:16 simple (3) slow-release (1)

separate (4) share (13) short-term (3) 20:8;29:13;32:21 161:15 

106:16;112:8,9,25 5:2;41:20;50:4; 29:6;76:20;176:9 simpler (1) small (29)

separately (1) 56:4,11;70:1;109:11; shot (1) 115:24 28:25;29:14;55:15;

 192:16 113:4;134:6;183:2; 209:18 simplicity (2) 56:21;59:24;87:13;

sequester (1) 221:20,22;235:10 shout (2) 93:22;94:2 96:18;143:14;163:10;

 123:19 shared (1) 21:13;197:5 simplify (1) 172:1;183:1,16;

sequestering (1) 241:5 shoutout (1) 127:15 184:25;206:13;

 123:7 sharing (6) 215:22 simply (7) 215:12;225:14,20;

sequestration (4) 23:23;24:24;25:7; show (8) 46:5;85:6;106:3,5, 226:6,7,12;227:25;

 49:16;161:14; 57:1;185:21,24 49:18;55:1;105:23; 23;124:3;181:17 229:18,21;232:1;

 233:24;244:18 shed (1) 112:9;123:6;149:16; simultaneously (1) 237:3,4;239:11;

serious (1) 64:17 189:5;197:6 112:5 241:21;242:2 

119:4 shelf (1) showed (3) single (10) smaller (2)

seriously (4) 121:17 54:19;139:14;238:5 10:22;50:22;90:10, 55:8;199:6 

18:2;27:8;92:24; shelves (2) showing (5) 11,11;107:25;155:4; smaller-scale (1)

 232:4 19:19;245:7 54:16;107:22; 197:16;239:17,19 123:9 

serve (4) shielding (1) 128:8;197:1;200:17 sit (6) smart (18)

 118:21;203:13; 226:5 shown (2) 10:21;62:7;67:15; 8:25;119:17,18,22;

 222:11;240:24 shift (2) 80:25;123:18 122:16;150:1;168:1 120:10;121:10;124:3,

served (4) 48:8;189:12 shows (3) sites (1) 5;168:11;175:23,23,

 43:6;216:10,12; shifty (1) 101:19;118:6;214:5 214:12 25;176:5,8;183:11;

 244:2 153:15 shrunk (1) sitting (1) 204:13;223:15;

service (12) ship (2) 135:18 99:8 233:22 

18:17;19:7;88:19; 127:12,22 shut (2) situation (2) smarter (1)

 90:22;111:6;120:5; shipment (4) 50:14;74:14 49:17;110:8 51:10 

130:11;203:19; 155:4;239:19,25; sic (2) situations (2) Smith (8)

 216:13;218:12; 240:5 139:23;154:7 31:4;155:24 9:23,24;63:2;100:1;

 235:21;247:14 shipments (2) sick (4) six (8) 209:5,7;227:6;231:23 

serving (2) 66:2;240:1 52:18;57:5,6;183:6 70:14;72:11; snake (1) 

Min-U-Script® Burke Court Reporting & Transcription (37) sell - snake 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 2 

October 19, 2023 

64:4 46:8;99:19;126:4; source (3) 195:11 120:17 

so-and-so (1) 215:14 33:21;184:1,21 specialist (1) spraying (2)

 132:25 solvent (4) sources (4) 105:5 114:5,19 

so-called (1) 132:3;153:17; 32:22;79:23;104:3; specialty (4) sprays (1)

 178:8 155:14;157:16 118:5 15:9;28:20;41:13; 186:7 

social (4) solvent-extracted (1) South (2) 45:7 spread (4)

 56:11;118:5,5; 153:14 59:5;89:17 species (1) 67:8;119:6;168:21;

 165:11 solvents (6) Southeast (1) 92:17 220:25 

societal (1) 132:5,17;155:10, 59:5 Specific (19) spring (7)

 161:8 11;156:6,10 southwest (3) 13:15;31:4;50:22; 8:3;37:17;119:15;

SOE (25) somebody (6) 119:13;196:11,17 92:2,5;96:4;101:15; 222:20;233:18;

 32:18;44:1;66:3; 55:4,9;56:4;138:15; soybean (14) 106:15;109:23,25; 234:16;237:6 

96:14;98:12;100:2; 157:3,4 60:20,23;65:3; 154:18;156:3;163:3; springing (1)

 117:16;177:2;201:13; Somebody's (3) 121:9;130:8,8;131:1, 173:1;187:2;226:5; 113:18 

202:21;204:2,2,18; 126:11;156:6,11 1;132:13;137:10; 237:6,12;238:21 squeeze (1)

 214:4;217:6;218:4,6; somehow (1) 139:12;141:1;153:12; specifically (20) 150:21 

225:9,14,24;226:1,3, 23:4 240:6 14:9;28:19;60:22; squeezing (1)

 8;239:5,8 someone (5) soybeans (33) 106:13;107:8;113:11; 149:9 

SOE's (1) 65:3;91:8;92:18; 21:25;22:16,19; 117:8;127:6;156:10; stabilization (1)

 232:1 199:21;209:18 24:8;29:1,8;35:6,7, 165:5,14;166:2; 137:7 

software (1) someone's (1) 16;38:20;40:20;41:3; 173:2;182:6;192:7, stabilize (1)

 25:16 100:15 60:20;61:2,7;62:18; 12;197:10;205:21; 134:10 

soil (40) Sometimes (8) 66:16,19,20,22;69:4, 220:4;225:7 stable (2)

 13:14,14;43:19; 6:7;55:23;73:20; 12,19;72:9;89:11; specification (1) 49:19;161:13 

45:14;46:20,22; 124:11;139:10; 121:13,15;136:22; 193:22 staff (4)

 49:15;115:24;119:18; 199:13;230:13; 138:8;141:4;148:10; specificity (1) 8:23;125:5;170:9;

 120:5,16;123:20; 246:14 150:19;158:13 117:5 201:7 

139:16;161:13;163:1; somewhat (3) space (17) specifics (3) stage (3)

 166:3;176:10;177:18, 48:12;97:9;109:22 26:18,21;28:17,19, 59:12;68:13;223:24 142:14;164:1;

 21;189:2,2,8;190:6,7, somewhere (3) 24;30:11;35:20; spectrum (1) 214:18 

16;195:8;196:12,21; 4:18;114:16;153:25 112:14;121:18; 228:25 stakeholder (1)

 197:15,20;223:4; soon (5) 126:16;127:24; spend (4) 110:17 

234:2;238:18,19,21, 45:14;87:3;107:4; 134:25;135:3,10,11; 83:21;115:18; stakeholders (1)

 24,25;241:14,15; 167:12;172:4 146:24;159:4 143:24;150:18 222:16 

245:20 sore (1) Spalding (6) spending (2) stalled (1)

soil-based (1) 155:13 160:22;164:16; 116:11,12 43:23 

170:19 Sorry (22) 169:4,8,10;171:14 spends (1) stamp (2)

soil-grown (1) 14:13;23:22;24:23, spare (1) 245:23 212:21;230:14 

196:4 23;28:6;32:5;39:13, 246:6 spent (2) stand (5)

soils (6) 13;45:1;51:20;56:22; speak (21) 32:20;181:6 89:15,17;92:14;

 46:20;49:18;104:1, 95:22;135:10;157:9; 6:1,4,25;26:20; spiral (1) 133:16;179:25 

3;115:2;244:14 186:2;224:18,19; 28:18;41:8;45:16; 93:2 stand-alone (1)

sold (6) 228:16,18;230:21; 47:17;60:16;62:2; spirit (1) 208:1 

101:24;142:4; 231:24;236:3 70:18;140:22;141:17; 71:1 standard (16)

 225:16,16;244:7,24 sort (16) 162:15;181:14; split (3) 36:25;52:19;61:5;

soldier (1) 37:13,14;63:2; 187:20;190:3;198:25; 111:14;112:3,12 133:6;149:10;181:17;

 76:2 65:20;66:12;84:25; 217:5;224:7;243:13 spoke (10) 184:6,11;188:3;

solely (2) 85:2;93:10;113:9,13, speaker (5) 17:10,20;44:21; 189:2;194:24;195:3,

 187:22;241:7 17;162:16;184:8,9; 5:1,9;12:2;152:15; 178:11;184:7;200:4; 17;207:10;222:6;

solicited (1) 193:10;208:12 179:18 232:1,3;236:15;240:8 238:16 

133:25 sorts (1) speakers (10) spoken (3) standardized (3)

solid (2) 150:12 4:8;5:24;11:3,7,10, 25:18;47:20;138:22 88:21;180:16;236:4 

62:22;242:25 SOS (3) 20;26:1,1;125:13; spokesperson (1) Standards (27)

soluble (1) 201:13;202:15,18 171:5 20:12 4:5;7:11;8:8;27:21;

 223:4 sought (1) speaker's (2) spooked (1) 43:12;82:15;117:14;

solution (7) 183:7 8:16;11:19 208:17 130:1;131:10;132:8;

 32:17;50:21;87:1; sound (5) speaking (10) spot (2) 162:17;171:22;172:6;

 123:5;125:16;154:21; 7:1;98:1;201:1,2; 37:12;45:7;83:24; 206:9;227:23 178:14;180:21;

 243:9 214:22 100:4,5;165:2;182:6; spotlight (1) 181:18;189:21;

solutions (4) sounds (6) 187:18;216:9;221:19 5:9 195:14;213:5;221:25;

 25:6;82:4;174:2; 36:4;63:21;129:12; spearheaded (1) spray (1) 222:9,9,24;223:9,13;

 231:13 140:11;231:18; 201:22 114:12 238:14;241:3 

solve (4) 232:13 special (1) sprayed (1) standpoint (5) 

Min-U-Script® Burke Court Reporting & Transcription (38) so-and-so - standpoint 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 2 

October 19, 2023 

58:11,16;79:4; steal (1) stories (2) struggles (2) 173:6 

135:22;152:23 46:5 25:7;39:14 28:7;147:8 suggest (6)

stands (1) stealing (1) storm (2) struggling (5) 13:9;14:4;132:11;

 203:18 245:2 22:6;23:22 54:17;74:6,10; 173:16;233:22;235:9 

star (5) steeped (1) storms (3) 96:25;123:5 suggesting (1)

 6:19;43:1;179:18, 100:2 38:9,16;39:7 study (2) 48:25 

19;180:7 step (11) story (6) 69:2;233:24 suggestion (2)

start (40) 14:2;26:16;34:15, 97:7;121:2;124:4; stuff (9) 92:5;173:10 

5:17,18;6:22;11:23; 16;35:2,12;36:11; 138:8;142:20;185:22 27:2;32:25;114:11; suggestions (7)

 22:23;38:2;46:6; 59:24;60:25;61:20; stout (1) 126:3;153:2,8,13,19; 13:8;43:11;97:21;

 50:22;51:3,14;60:10; 63:23 31:5 236:21 99:1;207:20;218:2;

 76:8,8;77:5;94:22; stepped (2) straight (3) subcommittee (5) 231:10 

97:25;98:11;103:12; 139:1;157:11 120:6;156:17,21 87:10;88:5;142:18; suggests (1)

 106:19,22;136:23,25; stepping (3) strategies (1) 196:6;204:8 103:12 

148:18,22;149:18; 66:20;152:23;157:7 115:16 subcommittees (2) suitable (1)

 163:22;171:21; steps (1) strategy (1) 234:12;242:7 170:5 

190:21;201:16,18; 61:12 178:7 subject (2) suite (1)

 205:8;206:20,25; sterile (1) strawberries (4) 142:17;234:8 94:8 

209:25;210:3;222:20; 13:14 83:3,9,12;187:16 subjectivity (1) sulfur (2)

 224:20;239:6;245:14; sterilized (1) strawberry (2) 74:9 81:5,6 

246:18 46:22 81:15,22 submit (1) sulfuric (1)

started (16) Steve (16) stream (1) 110:23 81:6 

39:25;46:3;50:25; 102:21;104:22,24; 161:7 submitted (2) sum (2)

 51:9;52:16,20,21; 105:4;108:1,4; street (4) 88:18;156:18 202:4,15 

140:21;141:18,19,19; 109:10;111:5;112:20; 88:24;89:5,9; submitting (1) summarize (3)

 174:17;187:12; 113:2;115:5,6,8; 236:10 110:17 4:9;13:8;243:1 

225:13;243:20;247:2 116:16;120:14; strengthen (1) subsequent (1) summary (2)

starting (5) 122:11 202:22 148:15 241:19;247:8 

16:10;38:19;80:14; stick (1) strengthening (8) subset (1) sunflower (1)

 81:24;170:14 121:3 63:3;117:25;177:1; 114:7 138:6 

starts (1) sticker (2) 201:12;216:8;217:2; subsidized (3) sunflowers (1)

 197:15 65:13;181:24 224:12;225:8 121:9,14;128:13 138:5 

Starving (1) sticking (1) stress (2) subsidizing (2) Sunset (3)

 120:23 247:21 98:10;232:23 116:7;128:12 217:6;218:1;241:4 

state (14) sticks (1) stricter (2) subsidy (1) Super (7)

 6:21;11:22;13:11, 155:13 61:20;65:9 126:23 20:6;23:21;54:2;

 13;60:11;81:4;88:3; still (24) strikes (1) subsoil (1) 55:6;56:1;160:6;

 96:1,7;158:11; 21:3;24:17;37:11; 59:12 223:2 194:3 

162:21;169:6;194:17; 39:3,3;49:10;52:25; string (1) substance (1) supplier (2)

 230:4 53:14;64:9;85:6;94:1; 158:20 189:5 156:12,17 

stated (1) 110:6;112:9;114:24; strokes (1) substances (9) supply (44)

 172:10 154:8;157:1;172:22; 27:23 51:5;188:11,14; 11:1;12:17;15:1,10;

statement (1) 183:19;185:16; strong (6) 189:6,9;193:12; 16:3;29:21,21;60:17;

 170:20 199:14;209:8;214:8; 12:12;212:3; 203:3,11;242:16 61:19;63:5,8,9,14,15;

States (14) 220:13;243:18 215:16;223:13; succeed (2) 64:1,10;65:6,18;

 29:15;34:16;68:2; stimulate (1) 224:10;227:25 165:16;198:7 67:19;98:17;111:10;

 131:9;136:1;149:5, 217:12 stronger (2) success (5) 117:23;118:1;131:7;

 19;153:12;162:22; stock (2) 60:17;121:4 47:7;82:6;130:20; 134:4,13;135:13;

 164:25;172:16;191:3; 78:7;162:3 strongly (8) 224:22;239:8 137:12;152:9,12;

 216:17;244:1 stocked (1) 123:3;183:19; successful (4) 155:3;163:12;168:7,

status (4) 245:7 184:4;187:23;202:19; 28:11;97:22;196:9; 12;185:12;201:11;

 12:18;86:21; stocks (1) 204:12;225:25; 246:25 209:10;210:4,8,22;

 161:11;239:19 78:14 234:17 successfully (2) 235:5;245:1,6,8 

statutory (2) stop (6) struck (2) 123:6;239:16 support (43)

 192:17;194:1 26:3;44:1;99:21; 58:14;97:11 succession (1) 8:23;13:7;14:1;

stay (8) 118:1;203:6;204:10 structural (1) 14:5 15:4;16:1;17:25;19:8;

 30:11;54:13; storage (2) 224:23 succinctly (1) 25:3;36:20;43:14,14;

 134:12;145:10; 231:1,1 structure (1) 11:17 44:6;50:7;59:15;

 148:12;187:2;200:20; store (4) 190:5 suddenly (4) 70:19;71:15;73:25;

 243:7 19:19;53:24;54:19; structured (1) 51:21;67:5;69:3,7 96:13;103:5;107:10,

staying (5) 245:7 66:11 sufficient (1) 11;117:2,16;150:10;

 27:1,2;199:15,25; stores (3) struggled (1) 93:19 161:17;166:5,12;

 232:15 19:23;213:6,10 115:21 sufficiently (1) 170:12;187:23,25; 

Min-U-Script® Burke Court Reporting & Transcription (39) stands - support 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 2 

October 19, 2023 

188:15,24;207:6;

 212:9;213:7;224:22;

 228:3;234:22;235:4,

 7,14,20;245:3 

supported (2)

 117:17;202:11 

supporter (1)

 191:20 

supporting (2)

 12:11;166:9 

supportive (1)

 64:11 

supports (8)

 81:5,10;188:4;

 202:19;222:25;225:9;

 241:9;242:13 

supportZoomUS (1)

 5:13 

suppose (2)

 66:17;148:25 

supposed (2)

 34:20;116:5 

Supreme (1)

 230:1 

sure (49)

 5:24;6:5;8:17;

 17:18;19:15;20:20,

 23;24:19;25:9;47:19;

 49:2;50:11;56:2;

 58:25;60:13;67:23;

 68:10;74:15;83:8,10;

 85:11;86:1;94:1;

 102:14,18;107:14;

 121:21;129:17;137:2;

 142:12;149:15;

 153:22;157:13,22,22;

 179:20;185:3,9;

 186:3;197:6;205:9;

 206:13,23;207:5;

 218:22;224:2;237:16;

 240:22;245:7 

surely (1)

 244:22 

surface (1)

 210:24 

surprised (1)

 58:17 

surprising (1)

 26:1 

sustainability (7)

 165:21;166:1;

 180:10;201:22;

 211:18;212:18;213:4 

sustainable (4)

 60:15;143:23;

 145:5;169:16 

swag (2)

 21:15,15 

sweat (1)

 227:2 

swine (7)

 222:4,8,12,19,19;

 223:23,24 

switch (1)

 34:18 

Sylivia (1)

 103:7 

Sylvia (4)

 187:7;191:12,14,16 

Syngenta (1)

 120:20 

synthetic (9)

 105:23;114:2;

 120:2,3,17;123:23,24;

 192:12,24 

synthetics (4)

 105:15,19;113:24;

 162:1 

system (20)

 13:1;14:11;37:3;

 40:2;54:21;64:22;

 118:15,17,18;153:4;

 169:13;170:6,25;

 183:8;190:4;195:9;

 211:8;230:16;236:24;

 243:25 

systems (15)

 13:23;30:24;49:15;

 100:20;124:19;

 170:10;201:12;210:9;

 216:9;217:2;223:6;

 234:1,5;243:21;

 245:22 

talk (42)

 14:19,24;19:16;

 22:3;25:5,22;28:2;

 32:14;33:16;41:7;

 52:11;55:16,17;62:3;

 66:1,4,6;74:20;92:7;

 98:20;99:1;102:8;

 103:8,9;106:7;111:3;

 119:16;125:12,15;

 129:1;135:21,23;

 136:19;144:9,18;

 148:13;149:1,10;

 153:7;154:20;158:16;

 216:15 

talked (14)

 20:5;30:20;37:14,

 17;66:5;88:21;

 100:15;104:5;125:13;

 127:16;129:4;138:1;

 141:12;158:16 

talking (26)

 13:21;15:9,11;

 25:24;28:24,25;36:2;

 65:3,7;78:23;83:5,24;

 99:4;100:17;104:17;

 108:15,16;113:3;

 120:1;136:23,25;

 156:9;181:7;197:18;

 229:13;230:3 

talks (1)

 122:21 

tamp (1)

 131:17 

tape (1)

 64:1 

target (4)

 19:21;45:21;

 109:15;205:14 

targeting (2)

 132:12;215:1 

task (7)

 4:11;6:16;64:15;

 165:20;197:5;217:14,

 24 

taskbar (1)

 4:18 

tax (3)

 89:4;116:7;233:21 

4:12,15;5:12;8:23;

 13:25;14:4,9 

technically (1)

 148:23 

techniques (2)

 49:14;108:14 

technological (2)

 188:1,11 

technologies (1)

 82:3 

technology (4)

 87:7;108:20;

 211:10;234:21 

teeth (1)

 48:13 

tele-Board (1)

 227:7 

tele-comments (1)

 221:10 

telling (2)

 54:16;124:4 

Telom (1)

 46:24 

temperature (1)

 241:15 

ten (5)

 50:18;121:24,25;

 183:17;206:18 

tend (2)

 135:2;240:16 

ten-fold (1)

 196:20 

tenor (1)

 119:3 

tens (1)

 143:24 

tent (4)

 121:4,9,15;178:8 

term (7)

 13:10;29:7,17;77:2;

 120:10;175:1;190:1 

termination (1)

 120:2 

terminology (1)

 153:4 

terms (12)

 31:22;82:25;88:23;

 124:18;132:12;136:6;

tested (15)

 117:17;128:1;

 135:25,25;143:16;

 149:14;154:11,15;

 155:15;181:4,5,6;

 183:11;185:3,14 

testing (53)

 29:14,16;34:16;

 43:20,22;87:20;

 111:10;117:17,21,24,

 25;131:6,25;132:5,9;

 149:13;153:19;

 155:16,20;157:17;

 162:25;170:12,13;

 181:3;182:8;183:12;

 185:8;189:2,9;

 202:19,22;203:5,8,10,

 14;204:6,20,24,25;

 205:1,2,9,21;206:7,

 20;207:1,7,10;215:5,

 6;235:5,6,8 

tests (6)

 132:21;133:7;

 154:15;155:20;163:3;

 215:7 

Texas (3)

 143:6;144:16;

 147:15 

thankful (1)

 133:13 

thanking (1)

 171:21 

Thanks (89)

 9:21;14:21;16:13,

 14,15;18:10,11;21:9,

 16;23:20;24:24;

 31:13;32:13;39:14;

 42:13;47:19;50:3;

 51:15;56:19,19;

 65:24;70:11;72:1;

 74:5,25;82:15;84:21;

 88:16;92:22;95:19,

 19;100:1;108:4;

 109:5,7,10;111:5,6;

 112:20;115:8;122:10;

 123:1;124:9;129:11;

 131:24;133:10,11;

 134:22,22;137:15;

T 

53:7 T- (1) taxes (1) 139:11;190:13;204:3, 144:15,15;147:25;

Surprisingly (1) 24:14 141:21 6;206:12;209:1 150:8;151:3;152:7;

 209:10 table (3) taxpayer (1) terrestrial (1) 157:23;159:7;160:14;

surrounded (1) 163:25;218:23; 116:13 223:1 162:12;164:10;

 183:15 221:2 TDLs (1) terrible (2) 166:17,18;167:20;

survey (4) tackle (2) 37:16 67:9,10 182:16;184:19;

 15:8;241:17,19; 28:10;168:20 teach (2) test (17) 198:10;205:24;206:2,

 242:19 tackling (2) 53:22;122:19 7:5;91:18;136:2; 3;209:2;213:15;

surveyed (1) 162:22;163:20 team (7) 143:13;153:21; 215:17;216:6;218:11,

 15:10 tad (2) 8:19,25;70:24; 154:13;155:21;156:3, 12;219:18,19;223:17;

surveys (1) 33:10;36:21 116:24;119:7;125:8; 18;163:2,5;185:12; 229:5,5;230:20;

 242:25 tagged (1) 231:17 188:22;189:4;197:19, 231:21;232:17;

suspect (1) 181:13 tears (1) 20;235:10 242:20;246:7,7;

 177:6 Tajikistan (1) 229:19 testament (1) 247:15,23 

suspected (1) 67:3 technical (7) 130:17 That'd (1) 

Min-U-Script® Burke Court Reporting & Transcription (40) supported - That'd 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 2 

October 19, 2023 

157:23 194:22;202:25; Today (99) tool (24) track (7)

that'll (1) 221:20;244:8 7:15,18;12:2,4,10; 19:25;36:1,5;39:8; 59:14;62:1,6;67:1;

 41:22 three-minute (1) 16:13;21:5;23:21; 81:11,19;82:12;98:2, 92:11;110:25;180:25 

theme (2) 234:9 25:6,22;27:24;28:2; 3;130:13;132:5; tracked (1)

 71:21;185:22 three-year (8) 30:18;35:10;36:15; 165:21;170:10;196:8; 91:17 

therefore (5) 46:7,18;188:10,12, 37:5,13;39:11,14; 201:25;202:22; tracking (4)

 59:9;91:17;141:10; 17,22;189:16;191:3 41:22,24;44:21; 203:14;204:4,5; 36:24;66:2;89:23;

 142:2;144:3 thrilled (1) 56:20;58:4;59:19; 207:5,5,7;209:14,20 156:23 

Thicke (8) 18:1 60:16;62:2,14;63:22; toolbox (2) tractors (1)

 164:17;169:4; thrive (1) 64:8,19;65:25;71:21; 43:10;170:11 42:11 

171:16;174:11,15,15; 169:15 76:13;78:5;79:3;81:3; tools (5) trade (18)

 176:17;178:10 throughout (5) 82:19;88:17;96:4,9; 35:10;126:8,20; 36:3,7;40:20;64:14;

thinking (13) 81:24;82:8;83:6; 116:25;124:9;129:11; 172:16,23 66:10;75:24;130:5,

 5:19;22:20;32:21; 100:8;244:1 133:11;134:25; top (8) 17,23;131:2;132:11,

 66:20;82:25,25; throw (2) 137:18;140:22; 4:4;97:25;136:19; 24;133:18;136:6,13;

 85:25;99:4,21;100:8; 102:10,15 141:22;144:11; 142:17;167:24; 164:25;173:1;201:23 

185:6;215:18;228:3 thumb (1) 147:12;150:9;158:4; 184:14;215:22;228:7 traders (1)

thinner (2) 155:13 159:8;160:14;161:1; topic (16) 130:14 

64:6,6 thumbs (1) 164:12;166:21; 20:17;83:1;96:5; trades (1)

third (5) 95:9 168:24;174:8,19; 102:5;105:11;107:4; 136:5 

23:9;133:7;181:15, Thus (2) 175:22;176:16; 156:2;163:23;216:21; Trade's (1)

 16;185:13 43:9;224:24 180:13;181:10; 218:3,19;220:6; 36:7 

thirdly (1) ticket (1) 182:15,16;184:17; 222:5;234:7,9;236:5 trading (3)

 155:9 65:13 185:21;187:9,18; topics (6) 129:23;133:20;

third-party (1) tied (2) 191:10,22;192:1; 148:2,13;165:1; 135:6 

202:6 214:1;237:12 193:5,9;194:6;197:7, 172:7;221:21;233:21 traditional (3)

thoroughness (1) ties (1) 24;198:21;201:19; topsoil (1) 75:24;108:13;

 238:5 153:9 206:3,8;213:25; 223:2 126:10 

though (12) tight (1) 216:9,16;217:5,12,16; total (3) trained (1)

 24:24;53:5;80:23; 110:1 218:12;221:7,19; 163:5;244:6;246:1 13:3 

85:16;110:16;113:13; tile (3) 224:8,11;228:25; totally (4) training (5)

 127:25;184:25; 5:10,25;7:3 233:14;236:1;243:14; 21:1;68:16;89:17; 14:8;74:22;169:14;

 208:15;214:7;236:18; tiles (1) 247:13 198:19 171:4;206:25 

244:23 120:7 today's (1) touch (10) trainings (2)

thought (10) till (17) 8:1 37:14,16;65:8;70:3; 172:22;232:10 

55:7;56:21;85:10; 119:23;120:13; toes (2) 148:6;156:17;181:2; trans (1)

 100:3;109:6;116:12; 123:2,8,18;124:11,11, 204:24;205:14 187:2;196:7;200:20 66:2 

123:14;195:18; 16,18,20,21,22,24; together (17) touched (1) transaction (1)

 201:16;218:15 168:10,11,15;176:7 43:17;63:14;64:15; 148:17 239:15 

thoughts (12) tillage (3) 71:23;84:16;111:1; tough (3) transactions (1)

 15:2;33:25;37:4; 49:14;124:12,23 118:3;121:3;126:12; 19:9;77:15;220:5 66:9 

109:13;113:19; timeline (1) 153:21;189:20; tougher (1) transcript (1)

 114:21;132:7,10; 135:17 205:15;210:15;214:1; 160:2 4:17 

142:16;173:11; timely (2) 232:6,14;238:12 touted (1) transcriptionist (1)

 201:17;220:3 30:1;202:21 toggle (2) 108:25 6:23 

thousands (3) timer (5) 5:1;6:19 towards (4) transcripts (3)

 44:15;117:18; 5:9;7:1,2,5;11:23 told (5) 25:6;81:16,18; 5:21,22;8:5 

217:12 times (13) 27:3;73:4,22; 227:20 transfer (3)

threat (3) 7:4;13:3,25;25:18; 156:20;245:11 town (2) 14:5;136:7,7 

118:20;171:3; 31:24;35:15;121:25; tomato (1) 93:16;209:21 transferred (1)

 198:24 126:5;193:9;204:10; 240:17 townhall (1) 136:13 

threatened (1) 208:7;226:20;239:2 tomatoes (4) 18:20 transforming (1)

 61:10 timing (4) 175:7;194:21; Township (3) 161:6 

three (36) 174:6;227:5; 199:3,7 89:6;94:5;180:23 transition (53)

 6:3,25;22:21;32:6; 233:16;246:5 tons (9) toxic (2) 12:11;13:8,12,18,

 40:7;46:10;47:7,21, tiny (1) 23:4;44:16;60:18, 53:12;169:25 21;14:6,22;15:4,5;

 21;51:19;72:15,17, 244:22 19,20,20;117:18; toxicity (1) 22:1;24:4,17;28:9;

 23;73:9,13;75:19,25; tip (1) 139:25;140:2 78:20 31:23;32:7;39:21;

 78:17;82:1;93:18; 5:2 Tony (6) trace (3) 45:4,6,10,12,13,23;

 103:7;117:1;119:1; tired (1) 116:20;119:10; 59:14;132:16,16 46:5,6,18;48:13;

 136:19;139:17;155:5, 163:5 125:2,7;128:8;141:12 traceability (4) 100:7,21,22,23;127:5;

 11;157:11;180:13; tireless (1) took (3) 53:14;63:5,15; 128:20;144:20;166:9;

 183:5,5;187:12; 171:9 48:8;72:19;95:22 237:12 167:25;168:8;176:25; 

Min-U-Script® Burke Court Reporting & Transcription (41) that'll - transition 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 2 

October 19, 2023 

177:10,11;188:5,9,10,

 12,16,18,19;189:15,

 20;191:3;197:19;

 224:2;235:14,15 

transitional (9)

 13:10;37:25;38:2,

 12,24;40:6,8;48:17;

 189:16 

transitioned (2)

 46:15;114:10 

transitioning (15)

 13:23;14:11;22:14,

 24;24:2;100:16,17,

 18;101:9;125:7;

 141:19;148:19;183:1,

 23;185:1 

translated (1)

 180:24 

transmitted (1)

 207:18 

transparency (13)

 41:18;53:14;

 110:21;118:11;135:1,

 4;136:15,16;178:7;

 193:2;195:25;207:20,

 22 

transparent (3)

 8:14;155:19;207:19 

traveled (1)

 58:12 

travels (1)

 117:23 

trays (1)

 103:18 

treat (3)

 80:15;116:2;233:19 

treated (4)

 99:21;117:19;

 134:3;196:3 

treating (1)

 98:11 

treatment (1)

 116:8 

treats (1)

 106:12 

tremendous (5)

 80:13;131:2;

 152:20;154:17;

 238:23 

126:8 

trilling (1)

 163:18 

trip (1)

 133:1 

tromping (1)

 21:2 

trouble (3)

 6:17;74:20;138:11 

trucks (1)

 20:3 

true (4)

 43:18;109:1;

 130:12;136:7 

truly (8)

 45:24;54:8;139:4;

 184:5,14;186:16,19;

 189:13 

trust (4)

 122:3;134:4;

 151:14;196:1 

trusting (1)

 135:13 

truth (4)

 53:20;54:3;184:4;

 186:24 

try (23)

 18:4;19:10,15;30:3;

 33:18;53:22;63:12;

 71:1;116:12;128:21;

 132:24;142:9;147:3;

 148:11;175:24;

 179:11;185:23;196:8;

 220:18;231:12;232:9,

 16;236:23 

trying (27)

 23:12;30:24;33:21;

 36:10;38:11;48:13;

 49:2;84:24;85:1,2;

 93:22;98:5;102:2;

 115:24;116:1,4;

 128:8;138:13;140:3;

 142:9,18;160:5;

 175:17;182:7;193:14;

 220:22;227:17 

Tuesday (13)

 7:8,16;10:20;11:2,

 14;44:21;56:24;

 80:16;166:21;202:5;

Turner (7)

 10:11,12;74:5,25;

 226:15,18;246:7 

turns (1)

 105:17 

TV (3)

 53:17,18;55:25 

Twice (1)

 48:11 

twist (1)

 178:9 

two (50)

 8:23;11:21;16:21;

 17:20;22:6,21;25:22,

 23;27:10;30:20;

 31:23;32:8;33:15;

 38:8,8,9;39:7;43:15;

 48:11;50:23;58:13;

 67:24;68:20;73:7,14;

 75:18;76:7,19;77:6;

 79:17;82:1;90:22;

 103:13,16;112:2,5;

 130:10;148:2,13;

 150:19;155:17;167:3;

 184:19;190:13;204:1,

 10;225:20;228:1;

 231:11;247:9 

two-and-a-half (1)

 22:6 

two-day (1)

 7:15 

T-yields (2)

 22:10;173:9 

type (6)

 59:14;123:10;

 131:2;133:2;136:5;

 186:9 

types (5)

 81:15;133:7;

 162:24;188:15;196:2 

typical (3)

 78:2;126:2;223:1 

typically (2)

 222:8;230:15 

Tyson (1)

 79:15 

unambiguous (1)

 238:17 

unannounced (11)

 99:13;117:20,25;

 204:18,19,21;205:8,

 10,19,21;214:15 

unbelievable (1)

 53:4 

unchecked (1)

 118:15 

uncomfortable (1)

 151:1 

uncover (1)

 63:13 

under (17)

 6:3;23:5;61:25;

 91:4;92:14;111:17,

 17;112:2;121:23;

 131:9;141:25;142:4;

 187:16;192:8,11,21;

 237:16 

undergo (1)

 188:9 

undergoing (1)

 13:12 

underlined (1)

 152:16 

under-shadow (1)

 182:2 

understands (1)

 189:11 

understatement (1)

 211:18 

understood (1)

 225:9 

underwriting (1)

 66:12 

undoubtedly (1)

 188:18 

unfair (1)

 61:11 

unfairly (1)

 225:21 

Unfortunate (2)

 39:14;185:11 

Unfortunately (10)

 19:25;53:17;

 104:16;130:16;

 186:22;200:7;221:7,

 131:9;149:5,19;

 153:12;164:24;

 172:16;216:17;244:1 

university (1)

 172:21 

unknown (1)

 180:3 

unless (5)

 4:15;84:16;117:4;

 124:22;127:14 

unlikely (1)

 61:6 

unmute (11)

 6:11,13,14,20;

 95:23;102:24;179:6,

 12,15;180:5,5 

unmuted (6)

 6:21;58:1;107:15;

 174:14;179:22;180:8 

unnecessarily (1)

 92:25 

unnecessary (1)

 214:24 

unpack (1)

 109:16 

unpackage (3)

 16:17;88:20;160:1 

unusual (1)

 196:16 

up (117)

 7:1;11:7;14:18;

 20:13;21:16,17;

 25:10,12;26:16;

 29:17;37:8;39:2;40:4,

 24;41:3;42:5,16,24;

 44:12,23;46:20;

 54:16,19;57:21,21;

 60:8;63:16;64:22;

 66:6;68:10;72:3;75:7;

 76:22;80:4;82:4;86:6;

 89:19;92:14;93:14;

 94:22;95:9;96:25;

 97:16;98:8;102:6,21;

 104:22;106:14;

 116:19;119:9;120:18;

 121:1;125:2;127:3;

 128:7,8;129:15,23;

 137:19;139:22;

 140:15;143:1;147:23;

U 

tremendously (2) 203:3;218:18;241:5 ubiquitous (1) 11;238:22;239:16 149:16;151:3;152:24;

 157:16;164:8 tunes (1) 170:25 unfunded (1) 156:25;157:7;160:19;

trend (1) 34:9 ugly (1) 234:18 164:14;167:12;

 111:15 Turkey (6) 217:21 unhealthy (1) 171:15;174:11;175:9;

trials (1) 33:16;60:19;65:1,1; Ukraine (8) 53:19 176:7,9,18;178:24;

 84:7 67:2,5 33:16;181:7,15,21, UNIDENTIFIED (1) 181:11;185:7;186:10;

trick (1) Turkish-origin (1) 22;182:3,6,7 179:18 187:6,12;191:12,23;

 82:24 134:2 ultimately (2) uninspected (1) 194:8;196:25;197:1,

tricky (2) turn (8) 61:23;137:10 45:25 6;200:18,24;202:9;

 85:8;208:15 4:19,23;6:1,14; umbrella (1) unique (3) 205:15;206:9,17;

tried (3) 7:10;47:9;202:18; 111:22 109:20;193:14; 207:23;208:5,5;

 115:16;220:15; 203:19 unable (4) 202:4 209:9;210:18;213:17;

 229:25 turned (2) 51:20;95:7;198:13; United (11) 215:25;219:19;221:5;

tries (1) 34:4;154:15 233:15 29:15;34:16;68:2; 224:4;227:24;229:17; 

Min-U-Script® Burke Court Reporting & Transcription (42) transitional - up 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 2 

October 19, 2023 

230:9;232:8;233:9;

 238:8;240:13,15;

 245:1;246:18,19;

 247:15 

update (3)

 161:22;163:24;

 202:19 

updated (5)

 43:21;161:21;

 165:23;177:5;182:9 

updates (2)

 160:19;203:12 

updating (2)

 203:1,2 

uphold (3)

 61:8;169:20;218:5 

upon (3)

 6:12;106:15;118:9 

upped (1)

 81:1 

upper (3)

 123:19;124:15;

 246:23 

upper-right (1)

 4:25 

upping (2)

 34:16,16 

upstream (1)

 163:16 

upwards (1)

 194:20 

urge (12)

 189:6;225:3 

use (74)

 4:21;7:1;13:1;

 29:13;31:3;38:3;40:3,

 18;44:15;45:23;46:2,

 24;51:11;67:25;68:1;

 69:9;81:13;84:25;

 87:8,20;94:9;96:16;

 98:14;103:14;104:7;

 105:19;106:19;107:3,

 7,10,11,20;108:13;

 109:3,19;121:4,12;

 124:2,3;125:20;

 126:8,9;139:10,14;

 141:8;148:19;153:4;

 157:16;162:20,23;

 163:16;170:10,17;

 172:14;182:7;183:15;

 196:6,9,9,13;203:15,

 15;207:7;214:2;

 217:10,23;234:3,20;

 235:7;241:10,18,21,

 25;242:13 

used (46)

 13:17;44:16;66:9;

 69:8;76:22;81:14,15;

 86:21;93:13;101:1;

 103:11,14;105:15,25;

 106:1,24;107:2,9,21;

 108:23;110:3,22,24;

 111:2;113:15,24;

 114:2,5;121:11;

Utica (1)

 37:18 

utmost (2)

 62:9,12 

verification (3)

 12:18;239:18;240:7 

verified (1)

 113:15 

verify (8)

 33:7;98:6,15;

 101:22;102:2;139:3,

 4;239:24 

verifying (1)

 214:19 

Vermont (8)

 95:24,25;96:2,6,21;

 99:6,10,17 

versus (9)

 40:8,15;97:24;

 100:17;173:6;179:20;

 194:1;208:1;246:11 

vet (1)

 134:13 

via (4)

 12:14,25,25;207:18 

viability (1)

 242:12 

viable (2)

 27:2;81:19 

VICE (10)

 9:9;54:15;90:17;

 92:1;115:8,11;

 116:15;122:10;

 199:12;200:17 

video (3)

 5:25;7:3;129:5 

voice (15)

 30:19;56:20;57:10,

 14;65:24;133:12;

 134:23;140:13;

 142:20;144:16;

 182:16;197:6;200:22;

 224:10;227:25 

Voices (3)

 166:6;200:13;

 219:12 

volatile (1)

 130:14 

volatility (1)

 137:9 

volume (6)

 10:2;36:7;62:1;

 64:25;181:12;182:9 

volumes (1)

 62:6 

voluntarily (1)

 216:18 

voluntary (1)

 81:8 

vote (1)

 149:12 

voted (1)

 44:8 

vulnerability (2)

 205:5;210:6 

V 

vaccine (3)

 86:16,17;87:1 

Vaccines (6)

 86:16,20,21,25;

 103:9;104:10 

valid (4)

 32:15;239:17,23;

 240:4 

validate (1)

 155:3 

Vallaeys (9)

 160:20,21;164:15,

 19,20;167:5,13;168:4,

 25 

value (6)

 43:18,18;59:6;

 128:2;161:8;165:7 

values (1)

 224:16 

vantage (1)

 131:13 

variety (7)

 78:16,22;87:7;

 107:22;125:9;233:25;

 241:11 

W 

82:14;104:9;117:8; 127:25;139:9;163:9, various (5) view (12) wait (1)

 149:12;169:23; 12;170:11;172:15; 87:6,8;93:13; 4:19,23,25;5:1,1, 67:15 

192:19;217:24;222:4; 173:17;183:16; 111:16;132:5 11;30:21,22;98:5; waiting (2)

 223:8,16;225:25; 188:14;189:3,25; varying (1) 101:25;130:4;196:8 104:24;189:1 

234:10 192:25;196:19,21; 196:2 viewers (1) waitlist (1)

urgent (2) 203:3;235:19;241:14 vast (5) 171:5 221:8 

32:15;170:22 useful (6) 15:10;33:4,5;96:21; Vilsack (2) walked (3)

urgently (1) 75:3;209:14,20; 124:22 49:11;178:11 20:4;61:15;62:21 

223:13 211:18;237:13,14 vastly (1) violation (1) wall (1)

urges (3) user (7) 177:11 44:9 246:18 

106:16,19;222:2 26:9;34:21;105:23; Vavercek (8) virtual (2) Walmart (1)

US-based (1) 114:5,8,18;137:11 21:17,21,23,24; 201:8;226:21 212:17 

33:7 users (3) 24:5,19;25:1,9 virtually (2) wants (1)

USCA (1) 28:25;130:22;133:3 veg (2) 7:20;239:18 68:12 

161:22 uses (3) 167:10;195:17 virtues (1) warehouse (3)

USDA (41) 103:17;113:14; vegetable (3) 118:8 112:3,6,14 

8:5;27:12;43:14; 120:2 45:8;119:13;230:12 virus (1) warehouses (2)

 44:14;49:3,8;53:11; using (21) vegetables (2) 114:6 175:11,18 

67:12;69:20;71:12; 5:11;22:10;23:2,11; 28:20;175:8 visibility (4) wash (1)

 76:15;87:18;90:22; 27:19;37:22;40:8; veggie (3) 209:23;210:12,16; 196:15 

91:2,4,15;153:21; 82:3;96:24;98:2; 16:18;17:6;26:21 211:2 washing (1)

 165:18;166:8;173:16; 111:11;117:3;123:12, veggies (1) visible (2) 54:6 

175:12,16;178:1; 24;153:18;172:23; 229:11 7:3;214:8 Washington (2)

 182:12;189:4,7; 198:7;211:7;228:23; vein (2) visit (3) 119:15,25 

200:9,12;212:22; 231:2,2 77:24;191:20 5:12;13:5;143:8 waste (1)

 213:1,3,8;233:24; usual (1) venture (1) visitors (1) 161:7 

234:4;235:17;238:20, 176:4 243:7 227:9 watch (4)

 22;239:3;244:21; usually (3) verb (2) visual (2) 23:10;45:22;

 245:15,23 5:1;136:5;198:22 161:5,5 201:24;211:19 122:20;176:5 

USDA's (5) usurp (2) verifiable (1) vitally (2) watched (1)

 170:15;188:3,4; 113:22;114:23 117:13 183:4;184:5 232:11 

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watching (2) 171:14,15;213:16; 110:19 without (20) 187:24;189:7,18,20,

 50:18;51:22 223:19;247:19 whipsaw (1) 13:24,25;19:8;37:2; 21;197:1;199:17;

water (20) weekend (1) 35:6 44:15;46:24;81:19; 202:20;203:22;

 23:7,10;81:13; 115:19 whole (20) 88:11;109:4;118:20; 210:17;211:4,4,12,13;

 106:5,6;116:2,2,8; weeks (3) 28:13;36:25;37:3; 124:21;128:2;135:2; 215:19,24;218:24;

 161:14;163:19; 5:22;22:6;68:20 49:16;57:16;60:19; 151:9;193:22;214:15, 220:14,20;221:21;

 181:24;185:2,3,3,5,8, Weimer (1) 68:19;70:24;77:4; 23;215:6,15;244:13 222:17;223:16;

 9,12,14;245:20 21:18 97:6;103:1;107:4; witness (1) 224:15,25;225:7;

waterways (1) weird (2) 137:12;139:2;141:18, 33:19 226:9,23,24;227:21;

 120:8 125:17;128:3 21;155:12,16;156:1; Wolf (14) 228:13;231:11,14;

waves (1) Welcome (13) 175:6 25:13;37:9;42:16, 232:5,16;235:3,19;

 29:9 4:3,4;7:16,17; wholeheartedly (1) 21,25,25,25;44:13; 247:15 

way (40) 10:10;37:11;42:14; 96:22 45:21;47:20,25;49:2; workable (1)

 26:9;34:14;35:13; 94:15;162:6;163:25; wholesale (1) 50:11;51:18 87:1 

41:12,12;58:10; 176:20;178:9;221:4 71:6 wonder (5) worked (8)

 61:22;63:17;66:10, welfare (1) Wholesalers (2) 14:18;162:14; 38:15;50:12;89:3;

 13;68:22;76:13; 222:12 12:8;17:14 177:3;199:23;245:23 104:8;139:13;152:10;

 91:18;93:3;94:7; well- (1) whomever (1) wondered (1) 216:18;218:20 

99:22;102:1;105:25; 71:8 67:18 124:13 workers (1)

 109:1;128:24;132:19; well-prepared (1) whoops (1) wonderful (4) 244:15 

141:15;142:10;144:4; 160:6 156:5 64:10;79:21;108:1, working (30)

 145:2;151:16;157:6; Welsh (5) who's (6) 4 17:23;18:6;20:14;

 160:7;162:21;163:6; 221:15;233:7; 47:18;48:16; wondering (12) 25:4;44:1;64:2;75:3;

 186:18;195:23; 238:8,11,11 107:15;134:13; 39:16;74:7;93:4; 79:17,18;81:16,18;

 199:25;209:16; weren't (3) 210:22,23 99:8;100:14,18; 82:5;83:21;90:9;

 215:18;220:14; 17:15;95:14;230:1 wide (4) 108:6;113:4,8; 96:10;131:13;132:1;

 229:24;230:1;246:17; West (3) 163:6;220:1; 122:15;133:17;231:6 150:11;153:21;

 247:10 59:5;143:6;246:23 233:25;241:11 wonk (1) 160:18;169:12;207:8;

ways (22) western (3) widely (3) 237:1 209:25;210:14;

 18:21;52:20;77:25; 58:8;105:6;125:8 63:18;81:14,23 Woo (1) 217:20,24;225:23;

 78:22;82:10;84:13; what's (32) widespread (3) 103:8 232:14,17,25 

87:7,12;106:18; 4:9;15:1;20:8;24:4; 82:7;209:16;223:11 Wood (4) workload (1)

 132:15;137:4;152:22, 26:3;31:2;45:25; Wiemer (9) 10:10,13;74:4; 106:10 

24;165:19,22;166:7; 52:15;54:20;62:4; 25:13;37:8,11; 226:17 works (6)

 189:14;193:20;211:8; 65:2;72:8;78:1;92:9; 39:22;40:17;41:20; Wood's (1) 70:24;149:19;

 214:24;224:15;232:9 97:14;109:20;121:11; 42:4,8,14 246:6 172:10;179:19,20;

wear (1) 127:12;134:8;137:25; willingness (1) Woody (1) 239:4 

114:11 139:3;145:11;147:20; 87:6 20:11 workshop (1)

web (1) 156:20;168:5;186:19, wind (6) word (4) 41:21 

168:2 20,20;193:4,13; 22:6;23:22;24:8; 168:21;185:24; world (11)

webinar (5) 231:4;240:8 153:9;156:5,9 220:25;239:2 58:12;103:21;

 5:17;8:1,11;164:3; wheat (11) window (1) words (4) 108:1;132:6;147:21;

 247:24 91:21;92:9,11,12; 5:4 115:24;121:4; 149:6;181:15,16;

webinars (5) 130:8;145:25,25; winds (1) 129:2;204:7 211:24;224:17;244:1 

4:5;7:16;8:20; 146:14;148:10; 22:7 work (98) worries (1)

 100:9;172:21 150:20,23 wing (1) 8:20;9:2;11:1; 240:16 

website (10) Wheaties (1) 175:14 17:13;21:9;26:19; worry (3)

 5:23;8:5;16:14; 176:2 winter (1) 27:24;32:14;36:8,10, 5:6;27:1;127:1 

21:8;44:3;56:3; wheel (7) 31:10 23;43:4,17;44:4; worrying (1)

 172:17,20,25;208:6 165:21;201:22,23; wise (2) 46:16;48:13,19; 138:22 

weed (4) 202:8;211:19;212:13, 64:3;135:17 51:23;61:8;63:8,14; worth (7)

 144:1;196:11; 13 wish (7) 64:21;66:13;70:24; 142:4;145:19;

 241:22;246:21 wheels (1) 11:17;17:9;19:5; 71:1;72:1,6;75:22; 146:6,8;150:21;

weed-control (1) 202:12 95:13;102:4;147:11; 76:8;78:12;84:10; 244:22;246:25 

47:10 whereabouts (1) 233:20 88:5;90:18;96:3,14; worthless (1)

weeds (4) 180:18 wishing (2) 97:24;100:23;103:2; 239:18 

49:13;81:12; whereas (2) 188:8,16 105:7,11;106:9,17,19, worthy (1)

 241:14;245:19 13:17;199:7 withdrawn (1) 25;113:5;119:7; 244:23 

week (19) Whereupon (1) 50:12 125:5;128:9;130:1; wound (1)

 5:21;8:2;19:16; 247:24 within (8) 140:11;142:11,19; 176:9 

30:8;44:8;48:3;51:20; wherever (2) 100:7;103:16; 151:15;159:5;166:6; wrap (1)

 77:9,14;78:24;100:9; 7:21;63:16 108:23;113:23,25; 170:14;171:22; 247:18 

113:4;161:25;162:7; whichever (1) 173:20;189:12;208:1 172:12;179:15,21,21; write (4) 

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37:20;106:14;

 111:7;128:22 

writing (1)

 73:24 

written (28)

 12:23;13:9;16:16,

 19;43:8;66:7;72:13,

 22;86:13;88:10,17;

 97:10,12;106:10;

 119:20;136:20;

 157:18;161:18;

 169:23;170:18;

 192:12;195:8;206:6;

 230:24;234:10;235:9;

 239:7;242:17 

wrong (4)

 74:19;110:10;

 115:9;233:9 

wrote (2)

 178:13;224:13 

Wu (6)

 178:15;181:8,10;

 183:5;194:17;200:3;

 208:8;217:3;220:5,

 13;231:11;244:5,8;

 245:6 

yellow (1)

 148:11 

Yepsen (6)

 160:20,24,25;

 162:18;164:10,13 

yesterday (4)

 7:8;20:5;50:4;

 159:5 

yield (20)

 22:17,19;24:15;

 37:23;38:3,21;39:1,

 23;40:3,5;67:25;68:2;

 141:2,2,3,8;148:19,

 22;173:3;241:15 

yields (17)

 22:4,15,23;23:1;

 153:25 141:20 

1975 (1)

 174:17 

1986 (1)

 243:20 

1988 (1)

 243:23 

19th (1)

 210:25 

2 

2 (3)

 4:4;5:24;43:4 

2,500 (1)

 148:9 

2:13 (1)

 94:19 

2:18 (1)

 95:5 

20 (8)

 211:1 

2025 (1)

 141:24 

20-ish (1) 

83:11 

21 (1)

 70:21 

223 (1)

 37:24 

23 (1)

 50:24 

24th (1)

 247:22 

25 (4)

 128:4;129:25;

 141:3;158:21 

293,000 (1)

 60:20 

1 

1 (1)

 69:21 

1,000-acre (1)

 89:10 

1,100 (1)

 233:12 

1,200 (1)

 175:15 

1,300 (1)

 238:13 

1,850 (1)

 213:24 

10 (4)

 49:7;69:18,21;

 135:15 

10,000 (1)

 129:7 

3 

187:7;191:12,15, 39:21;47:15;120:22; 100 (11) 38:20;49:9;65:5; 3 (2)

 16;193:16;194:7 126:3;140:24;141:1, 29:11;62:22;80:1; 69:19;70:16;125:10; 43:11;49:2 

Wyard (22) 6,9;142:3;173:7,11; 83:8;143:12,22; 152:9;173:10 3,000 (1)

 191:13;194:9; 242:12;245:12 149:14;155:23; 20,000 (1) 194:18 

200:24;201:1,4,6,8; yield's (1) 206:10;241:20;244:7 178:3 30 (5)

 203:25;204:6,17; 40:6 11 (1) 2000 (1) 65:5;128:4;145:19;

 205:24;206:12; York (4) 169:2 216:10 173:20;220:13 

207:15,22;208:2; 37:19,22;230:4,4 12 (6) 2000s (4) 30,000-foot (1)

 209:3,6,22;211:16,25; YouTube (2) 4:4;57:17;60:18,22; 48:11;153:24; 98:4 

213:14;217:1 55:11;129:5 138:5;239:17 175:4;216:17 30,000-level (1)

12,000 (1) 2002 (2) 101:25 

Y Z 219:3 48:12;217:9 30-something (1) 

12:00 (1) 2004 (1) 212:25 

y'all (3) Zach (8) 4:2 48:12 30-year (1) 

58:4;122:15;182:21 42:17,17;57:21,24, 12-month (1) 2005 (1) 216:22 

year (47) 25;59:21;129:16,16 240:5 216:11 338,000 (1)

 15:10;22:2,5,17,18; Zaffer (2) 12-state (1) 2008 (1) 60:20 

23:5,5,7,8,22;28:3; 122:19,20 233:13 177:11 35 (2)

 30:4,24;38:4,10,14, Zamora (1) 13.76 (1) 2010 (1) 244:5,8 

16,22;39:17;41:1; 10:13 38:22 218:19 350,000 (1)

 49:7;63:20;70:14,20; zero (6) 130,000 (1) 2011 (1) 178:3 

72:7,12,14,17;73:2; 17:10;32:14;69:19, 181:8 145:12 36 (2)

 89:19,20;90:23;

 138:12;139:11;

 140:10,24;141:4,24;

 150:22,22;174:9;

 22;137:4;244:6 

Zimmerman (9)

 140:17;143:2;

 147:23,25;149:25;

15 (3)

 27:14;135:15;

 141:19 

15,000 (1)

2013 (1)

 203:10 

2015 (2)

 140:21;217:13 

70:20;141:3 

4 

183:5;209:24;210:24; 150:16;151:11,20,23 169:18 2017 (2) 4 (2)

 215:11;239:23;240:4 zone (1) 151 (1) 141:9;162:19 43:17;106:3 

years (64) 116:5 44:3 2018 (2) 4,100 (1)

 13:22;22:14,15,15, Zoom (14) 155-year-old (1) 218:24;230:23 171:1 

21;23:13;31:23;32:5, 4:11,16,17,23;5:4, 164:23 2019 (3) 4:06 (1)

 6,8;38:8,9;39:7;40:7; 10,14;6:16;8:21; 156 (1) 104:10;136:21; 169:5 

43:5;44:6;46:10,10; 148:1;150:1;151:25; 37:25 216:22 4:11 (1)

 47:7,21,21;48:11; 158:8;227:13 156- (1) 2021 (2) 169:5 

49:9;50:19;67:9; 38:2 61:1;178:11 40 (7)

 70:15;72:12;73:7; 0 16 (1) 2022 (4) 15:11,11;65:5;

 82:2,8;90:22;115:21; 60:23 38:10;61:1;70:20; 145:20;175:2;178:6;

 119:3;125:10;127:18; 05 (1) 170,000 (1) 138:5 194:20 

128:4;129:7,23,25; 153:25 60:18 2023 (4) 43 (2)

 135:15,15,17;141:20, 06 (1) 18 (3) 38:10;141:22; 178:13,18 

23,23;143:7;152:9; 153:25 94:16;143:7;239:17 170:15;247:18 47 (1)

 158:21;167:16;175:2; 07 (1) 19 (1) 2024 (1) 38:21 

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750 (1)

5 96:1

5 (1) 8

 43:20 

5,000 (1) 80s (4)

 58:9 186:6;194:13;

50 (10)

 13:22;15:11;27:24;

 30:4;43:5;65:5;

 120:22;153:11,13;

 167:16 

500 (2)

 24:19,20 

50-bushel (2)

 141:4,15 

53 (1)

 239:2 

535 (1)

 169:16 

57,000 (1)

 60:19 

591 (1)

 38:4 

5A (1)

 89:19 

5A1 (1)

 89:20 

195:11;229:18 

9 

9 (1)

 178:5 

90 (4)

 156:2;169:17;

 183:18;187:15 

90s (2)

 159:10;175:3 

99 (1)

 245:15 

6 

6 (5)

 6:19;44:5;179:18,

 19;180:7 

6:01 (1)

 247:24 

60 (4)

 65:5;69:9;156:2;

 241:20 

601 (1)

 109:18 

605 (1)

 107:20 

65 (5)

 61:1;62:17;69:19,

 21;217:3 

67 (2)

 37:25;38:19 

67-bushel (1)

 38:21 

7 

7 (1)

 44:17 

70 (2)

 22:7;177:10 

70s (2)

 141:1;186:6 

71 (1)

 242:1 

75 (1)

 22:7 

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 UNITED STATES DEPARTMENT OF AGRICULTURE

 NATIONAL ORGANIC PROGRAM

 NATIONAL ORGANIC STANDARDS BOARD (NOSB)

 FALL 2023 MEETING

 Tuesday

 October 24, 2023, 10:01 a.m., EST

 Marriott Downtown Providence

 1 Orms Street

 Providence, Rhode Island 02904 
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2

 National Organic Standards Board (NOSB) Members

 Nate Powell-Palm, NOSB Chair

 Mindee Jeffery, NOSB Vice Chair (absent)

 Amy Bruch, NOSB Secretary

 Brian Caldwell

 Jerry D’Amore

 Carolyn Dimitri

 Kim Huseman

 Allison Johnson

 Kyla Smith

 Nate Lewis

 Dilip Nandwani

 Logan Petrey

 Franklin Quarcoo

 Wood Turner

 Javier Zamora (absent) 
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3

 USDA/National Organic Program Staff 

Dr. Jennifer Tucker, NOP Deputy Administrator

 Michelle Arsenault, Advisory Committee Specialist

 Jared Clark, National List Manager, Standards

 Andrea Holm, Agricultural Marketing Specialist, Standards 

Johanna Mirenda, Agricultural Marketing Specialist, 

Standards

 Heather Kumar, NOSB Technical Support Staff

 Esu Obu, NOSB Technical Support Staff 
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 CONTENTS

 Welcome, Call to Order, Agenda Overview, NOP

 Introductions ....................................... 5

 Transition to Organic Partnership Program (TOPP)

 Topics: 2025 Livestock Sunset Reviews:

 NOSB Introductions .................................. 9

 Secretary's Report .................................. 15

 NOSB Report ......................................... 16

 USDA/AMS/National Organic Program Updates ........... 24

 NOP-NOSB Q&A ........................................ 45

 Presentation ........................................ 73

 NOSB Q&A ............................................110

 Livestock Subcommittee (LS) .........................129

 Alcohols: Ethanol and Isopropanol...............130

 Aspirin ........................................135

 Biologics - Vaccines ...........................137

 Electrolytes ...................................146

 Glycerin(e) ....................................148

 Phosphoric acid ................................151

 Lime, hydrated .................................156

 Mineral oil ....................................158

 Adjourn .............................................168 
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 P R O C E E D I N G S 

(Time: 10:01 a.m.)

 DR. TUCKER: Good morning, everyone. I am Jennifer 

Tucker, Deputy Administrator of the National Organic Program. 

Welcome to all our Board members, and our audience in the room 

and online. It is my honor to officially open the Fall 2023 

National Organic Standards Board meeting.

 Let's start with some official business. This 

meeting, like other meetings of the National Organic Standards 

Board, is being run based on the Federal Advisory Committee Act 

and the Board's policy and procedures manual. I am your 

designated federal officer. Transcripts for all segments will 

be posted once completed.

 For a little housekeeping, we are in a new space 

together. And so the restrooms are out and to the left. There 

are also a number of emergency exits on both ends of this hall. 

On this end of the hall, it's a one story down on the stairs 

and then out. On this end, if you turn right, there's another 

set of stairs that go down and then outside.

 There will also be a photographer in the room. The 

Accredited Certifiers Association or ACA is celebrating its 

20th anniversary. Happy birthday, ACA, yay. And so a 

photographer is around to take some pictures to mark the event. 

This is a public meeting and so photography is allowed. 

 Next, we will take a look at the agenda. And I will 
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 introduce members of the National Organic Program team. I'll

 then turn the floor to Nate Powell-Palm, board chair, for Board

 introductions.

 So first the agenda. This morning will include

 introductions, some Board reports, and a program update with

 questions and answers with the Board. After lunch, we will

 hear from members of the Northeast Region of the Transition to

 Organic Partnership Program or TOPP. We will then start

 subcommittee work beginning with livestock. Tomorrow, we're

 going to hear from the Risk Management Agency as part of the

 CACS Committee's work. And then we'll continue subcommittee

 work through tomorrow. The work will continue into Thursday

 and then we will close with some Board business, including

 officer elections and a look ahead.

 I want to close our segment by thanking the National

 Organic Program team. First, let's thank Michelle Arsenault,

 our advisory board specialist, who always provides exceptional

 support to the program and the Board.

 (Applause.)

 DR. TUCKER: We also have a number of other team

 members from Standards and from the broader NOP team here both

 to support the meeting and to learn. So please stand and wave

 when I call your name. From the Standards team, we have

 returning staff members Jared Clark, our National List manager; 

 Andrea Holm, over there, there we go; and Joe Mirenda, where 
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 are you, Joe, right up front there, okay. And then we also --

 so these folks you have already met are absolutely vital in

 advancing our work in both practice and National List

 standards. 

We also have two new staff members in Standards,

 Heather Kumar and Esu Obu. Heather and Esu, do you want to

 stand up and just wave? Stand up, it's okay. Say hello. Yay.

 Okay. 

(Applause.) 

DR. TUCKER: So I wanted to introduce them, because

 Heather and Esu fill a vital new role with the program. This

 is a new role. They are scientific liaisons providing food

 technology expertise for the Board. They were hired as a

 direct outcome of this Board's recommendations related to human

 capital. We're really pleased to have them on board and in

 place for this meeting. 

Also in the room are Penny Zuck, Alexis McNerney

 (ph.), and Rebecca Claypool (ph.) on my staff. Go ahead and

 stand up, guys. Yay. So they have played a key role in

 getting ready for this meeting. But I also want to highlight

 that all three are playing a critical role in managing the

 Transition to Organic Partnership Program or TOPP. They are

 working directly with the regions and with our national level

 cooperating group, and doing a lot of work and hard 

 conversations behind the scenes. And that is vital work that 
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 successfully goes with setting up a $100 million program. They

 are also, just more personally, wonderful colleagues, who make

 every day a little easier and a lot more joyful. So I am very,

 very grateful to all three of them.

 I want to mention two people who are not here in the

 room. So Standards Director Erin Healy had to stay home to

 recover from a very unfortunate shoulder injury. But she is

 listening online. Erin, thank you for everything you do to

 keep the many, many plates in Standards spinning and for

 getting our new team members hired and onboard so quickly and

 so well. So I had been a little pessimistic about the ability

 to have new people on board by the time we had this meeting and

 here they are right in the front row. So Erin did a really

 beautiful job with that hiring project.

 I am also pleased to share that I have a new

 associate deputy administrator. As many of you know, the

 former associate, David Glasgow, got a terrific job back home

 in Tennessee and he left us this spring. Our new associate is

 Andrew Malone, who comes to us from the Department of the

 Treasury, where he served as the director of Alcohol Labeling

 and Formulation Division, in the Alcohol and Tobacco Tax and

 Trade Bureau. So that team reviews tens of thousands of labels

 for compliance each year, including those for organic alcohol,

 while also working through complex policy issues related to

 alcohol labeling. Andrew was previously with USDA over in 
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 APHIS, Animal Plant Health Inspection Service, doing a lot of

 rulemaking work. Andrew has been on board for a couple of

 weeks. We are thrilled to have him part of the NOP. 

Next, I turn the mike over to Nate Powell-Palm, our

 Board chair. Nate will be introducing Board members, all of

 whom devote hours and hours of volunteer time to serve the

 organic community. Let's give the full Board a big round of

 thanks and appreciation. 

(Applause.) 

DR. TUCKER: Nate, it is a true honor and privilege

 to sit beside you. So thank you for all your work in leading

 this Board and being such a strong community voice and member.

 So thank you. 

CHAIR POWELL-PALM: Thank you very much, Jenny. I

 wanted to get started off with thanking everybody in the room.

 What a great looking crowd. You look sharp, folks. And

 everyone on line. Thank you for joining us and being here

 today. I'm really looking forward to this meeting. 

Last night, I proposed at our admin meeting that we

 have a walk-on featuring music and really get it pumping in

 here. I was quickly shot down by everybody. So that will not

 be happening. But in its place, I hope we might be able to go

 around and just share who we are, how long we've been on the

 Board, and what we're looking forward to accomplishing in the 

next semester. Allison, would you kick us off, please? 
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BOARD MEMBER JOHNSON: I won't sing, I promise. Good

 morning, everyone. I'm Allison Johnson. I'm heading into my

 third year on the Board in the consumer public interest seat.

 I am a senior attorney with the Natural Resources Defense

 Council, as my other day job. And I'm really excited about all

 the work that's happening on transition to organic. So we have

 our part here to do with the CACS transition work item and I'm

 hoping that will help continue to feed the NOP's efforts to

 support transition. Really excited. 

CHAIR POWELL-PALM: Thank you. 

BOARD MEMBER CALDWELL: Brian Caldwell. This is my

 third year in the consumer and public interest chair. What I'm

 looking forward to mostly is just working with this incredible

 group of people. I have just been so pleased at the

 capabilities and the collegiality of this group. So that's --

 I think that's -- was I supposed to talk about something else? 

CHAIR POWELL-PALM: No, that's great. 

BOARD MEMBER CALDWELL: That's good enough. Okay. 

CHAIR POWELL-PALM: That's great. 

BOARD MEMBER CALDWELL: That's it then. Thank you. 

BOARD MEMBER LEWIS: I'm Nate Lewis from Olympia,

 Washington. I work for the Washington Farmland Trust and I'm

 sitting the natural resource conservation seat. I think I'm

 most looking forward to working on the inerts issue and

 bringing that into the 21st century. 
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 BOARD MEMBER NANDWANI: Good morning, all. My name

 is Dilip Nandwani. I work for Tennessee State University,

 based in Nashville, Tennessee. I'm on scientist seat and I am

 into end of my second year on the Board. I am very excited to

 meeting all of you in person. In fact, I had a little meeting

 on TOPP yesterday and this morning. And good to be here.

 Thank you.

 BOARD MEMBER D'AMORE: Good morning, all. Gerry

 D'Amore from Monterey, California. I'm in the handler's seat.

 And I'm closing out my fourth year on the Board. I've -- this

 year I'm celebrating 50 years of being in the agricultural

 industry. The first 30 years were primarily as a

 producer/grower and in that capacity a good 20 years were

 owning, building, and operating a hydroponic farm in Virginia.

 And then the last 20 years I've migrated to post-harvest

 activity and go to market activity. I guess what I'd like to

 say is that it's just such a kick working with this Board. I

 think they are great. And for me I'm personally grateful that

 I've had an opportunity to close out my years with agriculture

 in this capacity. So thank you.

 CHAIR POWELL-PALM: Thank you.

 BOARD MEMBER SMITH: Hello? Does it work?

 CHAIR POWELL-PALM: No.

 BOARD MEMBER SMITH: You broke it. Okay? All right, 

 my name is Kyla Smith. I am in the certifier seat. I work for 
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 PCO. I'm their certification policy advisor. I am a little

 over halfway through my Board term. This is we're going into a

 year with no transition of Board members. And so we have --

 we'll see the same lovely faces all of next year. And I am

 excited that this group gets to -- we have some interesting

 agenda items with inerts and compost, and so I'm excited that,

 that we get to work on those together with like a solid Board

 who has gone through the onboarding and we don’t have to tackle

 that as well. We also have annotations as a standing work

 agenda item, so hopefully we'll get to do a little bit of

 National List clean-up as well. Thanks. 

SECRETARY BRUCH: Thank you. Oh, okay, that was good

 luck. Thank you, Kyla. All right. Good morning, everybody.

 Thank you so much for attending our meeting. I'm looking

 forward to this meeting to serve with my fellow Board members

 here. My name is Amy Bruch. I am a sixth generation farmer

 from Nebraska. I serve in the farmer's seat. I'm currently in

 my third year serving on the Board. And my background, I have

 40 percent of the experience Gerry has in Ag, so a couple of

 decades of experience. Half of that has been overseas working

 on projects. In Brazil, I lived there for six years. And I

 was in several countries, and Africa, as well, before returning

 home to my family farms. My dad unfortunately passed away too

 early in life, so I was able to carry on in his honor on my 

 family farms and convert those to organic. We have about 2,700 
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 acres of agleam Ag land in Nebraska that we farm organically,

 row crops, small greens, etc. And let's see. I'm excited I

 guess for a lot of things going into this upcoming season with

 the Board. My primary focus has been dedication to the

 oversight to deter fraud series. Just with the stakeholder

 feedback that I've received, that's a very important area of

 opportunity. So that's where I like to dedicate my work on the

 Board. Thank you.

 BOARD MEMBER HUSEMAN: You're going to go last, Nate?

 Okay. Good morning. Woke everybody up, I hope. I'm Kimberly

 Huseman. I sit in the handler's seat and I reside in Northern

 Colorado. I grew up production agriculture and in the organic

 space. I've been responsible for purchasing grains and oil

 seeds, and feed ingredients for livestock. I am so grateful

 for Heather and Esu to be joining our team this year to give

 the space and the time for this Board to be able to really hit

 some heavy topics. And I think this is a great season to be

 able to do that. I just want to shoutout to the two of you for

 being available for, for the Board.

 BOARD MEMBER QUARCOO: Good morning. My name is

 Franklin Quarcoo. I'm an entomologist by training. I am a

 faculty member at Tuskegee University. I am on the

 environmental protection and natural resources conservation

 seat. This is my first year. I'm particularly interested in 

the work on, just as Nate said, on inerts and then also the 
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 Transition to Organic Partnership Program this year. These are

 things that I am particularly interested in and happy about.

 Thank you. 

BOARD MEMBER TURNER: Hi. I'm Wood Turner and one of

 the research conservation seats as well. I think you can blame

 me for the no -- the absence of the walk-on song, so apologies

 for that. I am head of ESG for Agriculture Capital based on

 San Francisco. We're a grower, packer, shipper of organic

 blueberries. And I'm at the end of my fourth year. I'm

 trained as an environmental planner and designer. I also am

 really fortunate to be able to start transitioning my family's

 farm in North Carolina. I moved. I left there 30 years ago.

 But I've now gotten an opportunity to help oversee the

 transition of that farm, so I'm really excited about that and

 excited about the relevance to what we're doing here on this

 Board. Kim, you stole my, my suggestion. I was going to

 celebrate Heather and Esu, as well. I'll do it again. I'm

 glad you're here. Thanks. 

BOARD MEMBER PETREY: Good morning. I'm Logan

 Petrey. I work with Grimmway Farms, manage their southeast

 operation and organics there, mainly carrots, some veg, and

 some other crops. So I'm in the farmer's seat. I am on my

 third year. And I'm hoping by the end of my Board term, I'll

 be ready to serve the Board. 

CHAIR POWELL-PALM: We unfortunately have a few 
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 absences this meeting. Javier Zamora is absent. Mindee

 Jeffrey is here, but has come down sick. And so we're -- she's

 trying to figure out what the next step will be, if she's able

 to join us, but for now absent. And then Dr. Carolyn Dimitri

 is enroute. She had to teach a class last night, so she is

 hustling this way, but for now absent.

 So to close out introductions, I'm Nate Powell-Palm.

 I'm a first generation farmer from Montana. I usually say

 Bozeman, but really I'm from Belgrade, which is sort of the

 other side of the tracks from what you might have seen in

 Yellowstone. And I, I have been certified organic since 2008.

 This is my fourth year on the Board. I was so elated to hear

 from all of the farmers, more farmers than I think NOSB has

 ever heard from this past public comment section, just to hear

 what their concerns are, how we are serving them, and how we

 can serve them better. And so I hope over this next semester

 we keep that engagement up and build on what we heard, allowing

 us to hopefully through TOPP deliver better results for our

 community as we grow this industry.

 And with that, I'm going to hand it over to Madam

 Bruch, secretary of the NOSB.

 SECRETARY BRUCH: Thank you, Nate, appreciate that.

 Fellow board members, so happy again to be with you in person,

 in Providence, Rhode Island. Before we jump into the minutes,

 I wanted to bring to light the state motto of Rhode Island. 
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 Does anybody know? Oh, okay, in the back. Sorry, I can't do

 that. It's actually hope, which I thought was very fitting as

 we look and reflect on the organic program, where we've been,

 where we are, and where we're going. I just thought that that

 was really appropriate.

 So now onto the minutes. You have received the

 minutes from our April 2023 meeting in Atlanta, Georgia. Does

 anybody have any corrections or additions to these minutes?

 Okay, they are approved as written. Thank you, Michelle, I

 appreciate that. And I'm handing it back over to Nate.

 CHAIR POWELL-PALM: All right. And I have a few

 slides to share for my Chair's report. Testing -- no. All

 right, let's see. When I was 8 days old, a crop duster sprayed

 directly on my parents' rental house. What should have been

 scents of fresh cut hay or a newborn baby wafting through the

 window was replaced by a choking, sweet fume one hot day in

 July 1991. My mom had given birth to me in that home the week

 before, longing to raise children safely in the country. My

 dad, a 26-year old log home builder, whose only goal when

 starting a family was to provide and rent a home with a few

 acres from which he could run his business.

 After my second birthday, my mom awoke one night to a

 rasping sound and it was me gasping for air. After the crop

 dusting, I had developed a shortness of breath. But one of

 those July nights and my parents were breaking every speed 
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 limit to get to town some 20 miles away to get to a hospital.

 They rushed both to find relief for my contracted lungs, but

 also to understand why by simply living next to farmland they

 and the baby had been exposed to life-altering toxins.

 Days after the crop dusting, the farmer who owned the

 property stopped by and told my parents that there was nothing

 to worry about, what was sprayed was harmless. And he

 represented a world outlook for many at the time that was

 normal.

 After my second birthday, my asthma attacks became

 unrelenting. My mom's sole focus turned to finding a way to

 heal the damage that had been done. This dogged determination

 led to organic. She hunted for a sliver of a world free from

 pesticides and toxins, a refuge for her children, that would

 fight for and no matter what it took she would find it.

 Before AFA and the National Organic Program, this

 meant hours of research, constantly interviewing grocery store

 employees, asking do you know what's in this, do you know where

 it's from. Before the USDA organic seal, my mom was a consumer

 who had to navigate a world of competing claims with no voice

 of authority on what the truth was about food, as she sought to

 heal me.

 In Bozeman, before Bozeman was anything more than a

 cow town, we had a local employee-owned grocery store. Not a

 co-op or a natural food store, just a store where working 
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 people bought there groceries at an affordable price. My mom

 searched for solutions to my asthma and to protect my siblings

 with clean food. She walked into this grocery store and asked

 if they could buy some organic baby food. The food buyer she

 remembers as being super kind, but earnestly saying I don't

 think anybody is going to buy that, so no, maybe she should try

 the health food store in the next town over.

 My mom replied with me hanging on her hip, I need you

 to sell it to me. I shouldn't have to go to a health food

 store. I'm sure other moms in this town want it for their

 babies as well. And my mom knew that every mother will do what

 it takes to try to find food free from synthetic pesticides, if

 only given the chance.

 The food buyer held out until my mom proposed that if

 they couldn't sell all of the organic baby food, then she would

 be on the hook and have to come up with a payment plan to buy

 it, herself. The buyer ordered six cases of Earth First

 organic baby food, four bags of organic carrots, and four bags

 of organic apples. He sold out of everything the same day the

 produce arrived.

 Before the USDA seal, the sweet folks at the grocery

 store would roll their eyes every time they saw my mom and her

 gaggle of kids coming in, because they knew they would have to

 line up, and she would pluck everything off the shelf and ask

 where did this come from, what's in it, was it sprayed. She 
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 was so grateful for every single thing she could buy that was

 certified organic when that green and white seal hit the

 shelves. Apples, carrots, and baby food were real staples in

 our house, because you could get them organic in our town.

 When my parents purchased their 10 acres that I grow

 up on the rest of my childhood, they applied for organic

 certification. My mom and dad wanted to make a property as

 safe as possible for their kids. They looked to organic

 certification for clarity on what materials to use on their

 land, which to avoid, a roadmap for how to farm safely.

 A few years ago, I found her application to OCIA,

 where she had earnestly tried to fill out an OSP. Little did

 she know how much that would become a part of her everyday with

 me.

 Though my parents never received certification,

 because the most they ever grew was a large market garden, my

 mother's pleas were the pleas of every parent. We beg you,

 give us a path to protect our children. Organic gave them that

 path. And my mom looked to organic to heal my asthma. And it

 did.

 I heard again on Tuesday the commenter from Iowa say

 her kids were made sick by glyphosate in their water. But she

 was able to heal them with organic food. She asked us to help

 educate about the benefits of organic to everyone. The organic

 seal has done measurable good to help young bodies grow up in 
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 this country with fewer chemicals.

 I'm not sure exactly when it was that I decided I

 wanted to be a farmer, but it likely started when my mom

 brought home some bum lambs -- brought home some bum lambs and

 by age 4, raising those bum lambs, I was hooked. From bottle

 lambs, to 4-H steers, to getting a loan to buy my own cows, I

 wanted to be a farmer with every fiber of my being. But also

 from an early age, I knew that I was gay. And in my perceived

 world, those two attributes would, would absolutely be

 incompatible. You can't be a gay farmer.

 When I discovered certified organic for myself, I

 found a group of people who, for the past many decades had been

 building a world informed by the same truth as my mom. Each

 day they woke and went to their fields, turned to their

 kettles, or stocked their grocery shelves asking the question

 can you make a good living in agriculture while sparing the

 health of your family and the environment.

 This past week, we heard public comments from the

 most farmers ever in the history of the NOSB, from Montana to

 Nebraska, from Texas to Vermont. They called out and said

 organic is the truth, organic is the future, please help us

 spread the word. They offered no call for exclusion. They

 said we are on the same team fighting for a future our kids can

 be proud of, a future where choosing between feeding our

 bellies and feeding the soil is a false choice. We know we can 
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 do both and we do both without harming the environment.

 In my world, a world of sweeping prairies and clear

 streamed mountains, organic is a big tent, a tent where folks

 search for more people to invite in. When at the age of 16 I

 asked may I join you in being certified organic, they all

 called back get in here. When I said but I only have 12 cows

 may I join your marketing co-op, they called back get in here.

 When I said I don't own land and probably never will, they

 called back get in here. When I said I wanted to raise grain,

 but could only raise 100 bushels, they called back get in here.

 When I asked if I could apprentice to be an inspector with

 Margaret Spawls (ph.), she called back get in here. And when I

 said to the organic community in the summer I want to marry the

 love of my life, who happens to be a man, they all called back

 can we come.

 In the same way that organic is a refuge from

 environmental violence, freeing mothers to protect their

 children, organic has been a refuge from economic violence,

 freeing farmers to protect their community. And we must work

 to keep it so. When I grew up and before I discovered organic,

 I assumed that being a farmer was a labor of passion. You

 could only make a living, but not a good living. But after

 becoming an organic inspector in 2013, I began traveling the

 country.

 And during my undergrad summers, I would plant my 
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 crops, and walk on the plain, do inspections, come back, water

 my crops, and walk on the plain. And inspected farms from

 Oregon to North Carolina, from California to Minnesota. And

 what I saw was breathtaking. Organic was breathing new life

 into corners of the country written off as not being dairy land

 anymore, not being a place you grow vegetables for your

 community.

 Organic offered a relief from get big or get out.

 Organic offered a relief for farmers who wanted to, like my

 dad, work a job where he could stay close to his family, where

 days are punctuated by a daughter learning to halter-break a

 calf, or a baby taking their first steps in the milking parlor.

 I inspected a new school seeking certification in Detroit,

 where mothers were trying to assemble land from vacant lots to

 farm organically. And they asked do not their children deserve

 the same refuge from toxins as every one else.

 Traveling the country conducting over 3,000

 inspections, I heard one thing from all farmers, organic works.

 From my own family's experience and from the experience of

 thousands of consumers who drive and make the organic market

 possible every day, I heard organic works. And in October of

 2022, USDA said organic works, with the unprecedented and

 expertly executed rollout of the Transition to Organic

 Partnership Program or TOPP.

 When Under Secretary Jenny Lester Moffitt called me 
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 and asked if she could visit Montana and hear from our

 community, I said I'll have to check. When I called 60 of my

 farming colleagues to see if they could drive to Bozeman to

 speak with the under secretary, they said we'll be there. And

 when you invite 60 Montana farmers who are in the middle of

 harvest to a chance to build organic, make it bigger and make

 it better, they drop what they're doing and they drive, some

 over 8 hours for a chance to join this meeting.

 When the under secretary pulled up to our fields, a

 rain we had been longing for brushed our heads but for a

 minute. And I remembered the fields on which the under

 secretary stood now as certified organic and teaming with life

 were the same fields sprayed near the house I was born in 30

 years ago.

 In this time, the same time we all sit together

 striving for a better path forward in organic, I must also sit

 in awe of how far we have come. To have an organic farmer, one

 of our own, serve as under secretary, to have USDA listen do

 closely and support so effectively organizations who move the

 needle to help farmers, and to see with each field day

 mentorship and new market builds, my mom's struggle to realize

 a world safe for her children arrive.

 Now let us go forth to make this true for every

 mother, everyone, everywhere. Let us go forth to make organic

 the norm, not the exception. Welcome to Fall 2023 NOSB. 
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 Thank you.

 (Applause.)

 CHAIR POWELL-PALM: If everyone doesn't mind, let's

 take a little break, grab some coffee. Thank you.

 (Off the record from 10:34 a.m. to 10:46 a.m.)

 CHAIR POWELL-PALM: All right. We're going to jump

 next and I'm going to hand the mike over to Deputy

 Administrator Jenny Tucker.

 DR. TUCKER: All right. Good morning, welcome back.

 All right, we are moving into the National Organic Program

 update, and questions and answers with the Board. So there

 should be some slides in there. Oh, I do that. There were

 are. So this is part 2 of our update. I do want to highlight

 that part 1 of our update is in the Organic Integrity Learning

 Center, that is a free learning resource where you can go and

 watch a presentation that is crowd sources from across NOP

 staff. It covers our TOPP update, updates through each of our

 different groups, provides kind of a real-time look. So if you

 log into the learning center, you can get to it under a course

 called NOP presentations. We also sent an Insider, Organic

 Insider last week that had a direct link to the presentation

 for anyone who wants to catch up on all of our happenings.

 I'm going to give an overview of some key items here

 today before I open it up for questions. So this is a picture

 of the National Organic Program as it stands in June 2023. We 
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 brought everybody to Washington, D.C. for the first time

 post-pandemic. And it really is remarkable how much the team

 has grown. So we are right now at about 88 people. And so we

 had somebody new yesterday join, and so a sort of natural ebb

 and flow of personnel. But we're approximately 88 people. And

 those folks are distributed across five key groups.

 I was asked last night by some board members to give

 a little bit more detail on where do all these people work and

 what do they do. So I'm going to spend a little bit of time on

 that here.

 First, accreditation, and compliance, and enforcement

 have both literally doubled over the last four or five years.

 That's where we put a tremendous amount of resources that have

 come with our increased budget. So there are at any given

 time, there are about somewhere between 20 and 25 people in

 those two groups. And so accreditation is split between two

 groups of equal size of accreditation managers, who are the

 touchpoints with our certifiers, and an audit team that is

 literally on the road all the time. In fact, we've got a team

 over in India right now doing the second part of a month-long,

 month-long each, on the ground audits of our international

 certifier step.

 In compliance and enforcement, that group is also

 split into two groups. One group is, well, we call them the

 operations team and they are responsible for processing 
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 incoming complaints about, for example, farms that are selling

 as organic without certification. That still makes up more

 than half of the complaints coming into the program are

 uncertified operations selling as organic. So that team has

 gotten to the point where they can very quickly respond to find

 out, okay, are they certified maybe under a different name, or

 they're not certified, they need to get themselves certified or

 stop selling as organic.

 The other half of that team is split between a

 livestock and enforcement compliance team and import oversight

 team. We are all concerned about imports and import oversight,

 and we have a whole team. We have devoted a lot of resources

 to that team. Aligning with that team is also our trade

 activities group, which is really all about the international

 world in organic.

 And so half of the trade activities group, which is

 about 15 people now -- that group did not even exist 5 years

 ago, so they're around 15 people now. They include the folks

 who oversee our international trade arrangement, so equivalency

 recognition arrangements. And then the other half of them is

 responsible for all of the data work and systems work involved

 in import oversight and in maintaining the organic integrity

 database. I'll get more into what they've been doing recently

 in a couple of minutes here.

 So, again, that team didn't even exist about 5 years 
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 ago and it is now 15 people just to oversee sort of trade

 arrangements, and all the data and international oversight.

 They work very, very closely with the import oversight group

 within compliance and enforcement.

 And then we have the Office of the Deputy

 Administrator, so that's the staff that kind of reports

 directly up through me. They are running the TOPP program, so

 Transition to Organic Partnership Program, as well as doing

 things like the Organic Insider and making sure that we're

 spending money, so the budget office. And also we have a

 customer service team that took in -- we literally get multiple

 calls a day from farmers who want to get certified, who have

 questions, or want to sort of talk through challenges. So we

 have a full customer service team to take those calls.

 So it is a lovely group. About two-thirds of them

 actually are not in D.C. We have been able to recruit some

 real talent from the community based on our ability to hire

 remote staff. And so we now have folks literally across the

 country working for the National Organic Program.

 Our goal areas are to grow and develop the organic

 sector, to develop and implement organic standards, and then we

 have to goals related to organic integrity, because there are

 really two big pieces of this. One is developing a strong

 oversight system. So global organic control systems have lots

 of different elements. And so one of our goals is to continue 
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 to build those systems. And then our accompanying goal relates

 to protecting integrity through robust enforcement. And so we

 actively do strategic planning in the program. Everyone's

 performance plan in the program is linked up to these four goal

 areas.

 So Transition to Organic Partnership Program, there

 was a lot of work and discussion on that, yesterday. But for

 folks who might be new to this realm here, this is a

 $100 million initiative that has four key workstreams, being

 administered by regions across the United States. So we have

 farmer to farmer mentoring, technical assistance, community

 development, workforce development, and data and reporting.

 And I want to give just kind of a sneak peak as to some of the

 successes there.

 In one year, so one year ago it was actually at this

 meeting where we really launched the very first iteration of

 the TOPP map that showed all the partners that were

 preliminarily being engaged in the program. There are now more

 than 180 partners across the country engaged at different

 levels. We have regional leads, six regional leads. We have

 core partners in each region who might own a full workstream or

 are responsible for a complete state.

 And then we have project-based partners, folks who

 are organizing groups with meetings, or farm tours, or other

 group events that bring together folks from audiences that we 
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 previously haven't talked to before, farmers that might be

 considering the organic option but never really had someone to

 talk to about it, to learn more about, okay, how do I find

 seeds, how do I approach this market, how do I -- how do I

 engage in this process, what can I grow with what under

 organic. These are real-life stories.

 There have been more than 165 events in just 1 year.

 Again, we just launched this program a year ago. There have

 already been 165 events. And in our online application system,

 we've already gotten 80 formal applications to be mentors from

 the organic community, and more than 80 applications from

 transitional farmers with some real detail about what they need

 and what they are experiencing, what they want to grow, what

 their process of transition is right now.

 And so all of this has been stood up by a network of

 partners in a very, very short time. Yesterday, I reported

 that we had through all of these events touched 1,100 people.

 I was gently reminded by my staff that I missed a one, it's

 actually 11,000. So that's over 1,000 people per month that

 have been touched through, through TOPP. So thank you. That

 extra one is important.

 I wanted to highlight some other points that USDA is

 doing to support transition. First, another program under the

 organic transition initiative is the organic market development

 grants. There were a number of very strong proposals for that. 
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 Those proposals are now being evaluated by those teams with

 awards coming.

 The organic integrity database, this part of our kind

 of longer term infrastructure around transitional operations.

 You know transitional continues to be somewhat of -- we call it

 an extra regulatory sort of part of the program, because the

 regs actually don't say a whole lot about transition. They

 talk about prohibited substances. So we have issued a memo

 that talks about criteria that certifiers can use to report

 transition operations to the organic integrity database.

 That is not publicly -- those are not publicly posted

 -- I don't think I did that. They are not publicly posted

 data, but they are a way for us to communicate with RMA, the

 risk management agency, about who is qualified. We have heard

 that is an issue, that transitional crop insurance have a bit

 of a problem with people being in that pre-regulatory phase

 where they have to demonstrate certain activities to RMA, but

 they are not actually under the certification banner. So this

 was a collaborative effort with RMA to find a solution to that.

 Can we get the slides back up? Thank you. I

 appreciate that. And so that leads into the next bullet,

 coordinating with RMA on transitioning farmer insurance. That

 was raised to us as a real challenge. And so I think we are

 making progress on that. The transitional operation reporting

 was part of that equation that we can control. 
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 We have also done live training for USDA teams on

 climate smart ag and transitional farmer training. So more

 than 120 folks have been part of those live training sessions.

 The Board had given very useful recommendations related to

 climate smart ag. We have translated that into a micro

 learning for the learning center that will be publicly

 available I think in the next couple of, of weeks. We also in

 the learning center have a micro learning on transitional, so

 tips for farmers. So this screenshot is from that, practices

 at a glance, to get people started. So that interactive

 module, the climate smart crops stuff will come out soon.

 We also will be publishing I'm really hoping in the

 next month or so what we're calling a transitional --

 transitioning producer plan template. I'm calling it a

 pre-OSP. It's not quite an OSP, because people aren't

 certified yet. But it is a glimpse at what the practices are

 and what transitional farmers need to be thinking about when

 transitioning into organic.

 So that has been a nice partnership with Accredit

 Certifiers Association, ACA. Again, happy birthday ACA. They

 have brought together a group. And that's been hard and I

 admire the work they've done on that, because it really goes --

 in any sort of policy area, it always comes down to an

 artifact. What's the thing that all of the values and

 different beliefs and different perspectives are focused on? 
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 And in this case, naturally it is the OPS. So how do you view

 the OSP depends largely on how you view organic and the meaning

 that it brings to you and your own story that you're bringing

 to that interaction with what is ultimately a regulatory

 document. And it's amazing the meaning that gets embedded in

 these objects and artifacts. And so I genuinely appreciate

 everybody who has been part of that effort within, within ACA.

 We have been spending a lot of time and focus in

 implementing the strengthening organic enforcement final rule.

 So for folks again who might be new to the conversation, people

 say, oh, everyone knows about that. But there are people who

 don't know about that and so we are talking about it at every

 opportunity. Strengthening organic enforcement is a final rule

 that was published in January 2023. It is a fundamental update

 of the organic regulations that is designed to reduce the

 number of uncertified entity, so increase the number of

 certified operations across the supply chain. Requires the use

 of electronic import certificates, strengthens recordkeeping,

 supply chain choice ability, and strengthens our oversight of

 accredited certifiers.

 And so this rule came out of a lot of Board

 recommendations. It came from our observations and working in

 the -- in the program. And a lot of enforcement work over

 several years. It is also driven by provisions in the 2018

 Farm Bill. So when folks talk about the Farm Bill, it's 
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 important. It's important. We're in Farm Bill season now.

 And so when you get sort of requests from the group that you're

 associated with for input to the Farm Bill, it matters. It

 counts. So the goal of the rule is to protect organic

 integrity and bolster consumer confidence in the USDA organic

 seal.

 Here is a look at some of our implementation

 activity. We have been doing outreach to the regulated

 community, including part of the community that doesn't know it

 needs to be regulated yet. And so the good news is we're

 talking to people we've never talked to before. So we're

 getting calls from associations that we've never actually been

 contacted before saying can you come and give a webinar. We

 give a webinar and about two months later they call. We've got

 a lot of questions. Can you come back for another webinar?

 And we're doing that. And so it has been a phased

 rollout here where our first focus was getting the word out

 about this rule, focusing on the need for certification and

 import certificates, just to get people's attention. We have

 done scores of webinars and meetings with different

 associations, different groups to tell them about the rule.

 And now we're doing follow-up now that they've actually really

 read the rule and have a lot of questions about how they

 approach it.

 I was with an association just this past week where 
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 we really talked about with members of the import community how

 do you talk to your certifiers about this, how do you talk to

 your exporters outside the United States. If you're bringing

 in importers, what can you do to protect the market. You

 choose who you buy from and how are -- what are you doing to

 protect the market, what are your obligations under SOE, and

 how are you going to approach that. And very thoughtful

 conversations that show that people are paying attention to

 this and that they are really working through what they need to

 think about with their supply chains to enhance those

 protections.

 We've been doing outreach to certifiers through the

 Accredit Certifiers Association. They've had a number of lunch

 and learns that I think have been valuable for people having

 conversations about what this means and how to implement it,

 where can we find alignment and consistency across certifiers.

 We have online resources in the form of what we call

 SOE primers, a good New England term there, primer. And we

 recently launched a, a learning center course on SOE. It was

 interesting. We did a series of internal brown-bags where we

 ran through the rule with our own staff. The learning center

 team was able to take some snippets of me talking to the staff,

 Sasha Strohm on our team, talking to staff about different

 parts of the rule.

 And she's excerpted those in fairly digestible chunks 
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 that sort of talk about not only what does the rule say, but

 why does it matter. Because why it matters, the why behind the

 rule helps point to how. And so we strongly encourage to

 listen to that because it gives the what we're really trying to

 do here is. And I think certifiers have reported that's

 helpful in understanding therefore what, what do I actually do

 or how do I implement that.

 Rules are designed to tell you the why and the what.

 It is then up to the regulated community to figure out the how

 based on, you know, we affectionally refer to site-specific

 conditions. And that also means unique supply chains. And so

 the entire supply chain needs to figure out how does this rule

 apply to them. We explain in training in the rule, itself, why

 this matters and what we're trying to achieve.

 So we've also been launching technology modules. Our

 first step was to launch what we call a trade partner module.

 This is a way to get our trade partners, so we're talking about

 folks who hold equivalency and recognition arrangements with

 us, examples are Canada, the EU, Japan, Korea, as examples, New

 Zealand, getting them set up in the organic integrity database.

 They have their own section now of the organic

 integrity database. We're now referring to that broader module

 as global, that's the global integrity database. And it is

 through those modules that those government certifiers will

 report certified operations that are exporting to the United 
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 States. A whole new level of visibility and to lists of

 certified operations in other government schemes that we've

 never had before.

 That module is also the foundation that side by side

 with USDA certifiers will be issuing the import certificate.

 So the import certificate module within the organic integrity

 database that fulfills strengthening organic enforcement

 requirement is now live. Certifiers can go in and start

 generating certificates and, in fact, already are. So we gave

 certifiers a head-start on that so they could get in and play.

 They have already generated scores of certificates to sort of

 start practicing. They have been approached by members of

 trade saying we want to be early adopters of this.

 And we're learning all sorts of things. Well, what

 do you mean by this rule. What do you mean by that field. And

 so if you are kind of wondering what certifiers are doing to

 get ready for this, ask them have they gone into the import

 certificate module. Have they tried to generate a certificate.

 This is particularly important if we have folks representing

 the export community in other countries. Ask how is your

 certifier getting ready for SOE. And if they haven't heard of

 it, I would like to know about that, okay?

 So getting everybody on board now is the best

 onboarding for the rule when it becomes effective. The team

 got this module launched about six months before the rule is to 
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 be implemented. So everybody has time to get in there, learn

 how to use the system, learn how to issue import certificates.

 We did that on purpose, because that March date next spring is

 a very, very important date.

 We'll be issuing publicly an Organic Insider on the

 NOP import certificate module we're guessing in about a week or

 two. Again, we wanted to give certifiers a bit of a chance to

 kind of take a deep breath, this is real, I've got to go learn

 how to use this, they weren't kidding around with this. And

 for everyone listening, we're not kidding around with this,

 okay. So, please, when you see that Organic Insider, please,

 please take it seriously.

 Just want to give a reminder of when I'm talking

 about global organic control systems what we're actually

 talking about there. We are talking about the standards, the

 rules, policy, this advisory board's input, community input,

 the accreditation oversight of third-party organic certifiers,

 the certifies who oversee organic farms and businesses, who do

 unannounced inspections, who collect samples for testing.

 One important part, for example, of strengthening

 organic enforcement are provisions that give certifiers

 actually the ability to more easily exit a market. So if they

 do not have what we call administrative capacity, if they can't

 get into a country, for example, to do an unannounced

 inspection, they shouldn't be working there. And the rule 
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 directs them to not work in places they can't do unannounced

 inspections. That's just an example of the types of things

 that SOE puts in place to tighten up these controls around the

 world.

 Enforcement is an important part of the reflecting

 the actions that we're taking to protect compliant businesses.

 Trade systems, again a new group for us, uses data. It's

 amazing what we have been able to get access to in Customs and

 Border Protection systems. Some of the very dry bureaucratic

 work has been updating memorandum of understanding related to

 data sharing across federal agencies. And that has opened up a

 world of data that we did not have available even three or four

 years ago. It's really remarkable the collaboration with

 Customs and Border Protection, which was formalized in the 2018

 Farm Bill as vital to protecting imports. And they have just

 been a tremendous partner for us.

 Our international trade arrangements facilitate

 global growth. But they are also intended to help protect the

 market, in order to maintain equivalency. It's not just about

 the standards. They don't have to be identical. They need to

 be equivalent. But it's not just about the standards. It's

 about the systems that we use respectively in our government to

 oversee the markets that, that we control. So very, very

 important, especially with the implementation of SOE.

 I want to share some of the activities that are 
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 ongoing in compliance and enforcement. Part of compliance is

 training, training and outreach to build capabilities. The

 team has put a number of courses in the organic integrity

 learning center that helps share information that community

 needs both certifiers and operations based on some of the

 challenges we've seen in the space. And so for example, our

 livestock team regularly posts a new course in advanced

 livestock oversight and it's based on some of the cases that we

 are seeing. And so that helps give certifiers kind of a leg up

 on how to implement the standards.

 We have also done a number of those courses related

 to import oversight, supply chain traceability, quantitative

 methods. I don’t think many inspectors getting into organic

 realized there was going to be quite so much math. And

 strengthening organic enforcement calls for a lot of math. It

 does also call for inspectors and certifiers to have the

 requisite training, experience, and expertise to be able to do

 some of those math problems. Very important in preventing

 fraud.

 Surveillance. This has been a big focus for us as

 we've grown the team. A lot of our work now is on complex

 supply chain surveillance. So if we have credible concerns

 about a region, all of a sudden there has been a tremendous

 amount of growth in an area, let's say a certifier all of a

 sudden is doubling the number of certified operations in a 
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 certain place, those are all indicators to us that, that we

 need to be getting ahead of the curve.

 And we now have a team that is able to fairly quickly

 initiate supply chain surveillance. Their work will be much

 easier through SOE. So one of our key points with

 strengthening organic enforcement is the need for certification

 across the supply chain. So while I'm getting a lot of

 questions about exemptions of, well, I'm only doing this, do I

 really need to be certified, our primary answer is it benefits

 everyone, for everyone in the supply chain to get certified.

 It protects all of us. It protects all of us for the public

 and greater good, for everyone in every supply chain to get

 certified, whether you're required to or not.

 So buyers, if you're out there listening, you can

 help us. You can help us by requiring that -- by getting

 certified, yourself, and requiring everybody in your supply

 chain to get certified. This will only work if we are all

 engaged in the process.

 We have issued a number of certifier directives in

 markets that have been particularly risky. So those have

 called for advanced testing, advanced mass balance and

 traceability exercises. A recent one was on livestock

 compliance domestically, but we've also done overseas

 directives as well.

 Operations and certifiers in fact can lose 
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 certification or accreditation under the National Organic

 Program. There are also now new legal penalties covered by

 trademark protection. So this is an area where we've made

 significant progress with Customs and Border Protection. We

 have activated the USDA organic seal in Customs and Border

 Protection trademark systems. And they are actively holding

 product at the border that use -- to products that use the seal

 that don’t have evidence of certification. And many of those

 shipments have been turned away. So many of those shipments

 have been turned away.

 Customs and Border Protection have some special

 authorities with trademark and we are regularly getting calls,

 hey, got this box, got the seal, no evidence of certification,

 what do you want us to do. And often they hold those at the

 border, which actually costs money. So we have civil penalties

 from the program. But Customs and Border Protection also

 charges to hold product at the border while it is under

 investigation. And so there is a business cost of that. Our

 goal is to take the profit out of fraud, to make fraud really,

 really expensive. And some of the work that we're doing with

 Customs and Border Protection is doing just that.

 And then finally we have seen cases where people are

 sentenced to prison time based on fraud. We work with a lot of

 agencies and having 88 people allows us to work more closely

 with representatives, for example, at the Office of Inspector 
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 General, Customs and Border Protection. We had a staff member

 up at the Port of Baltimore last week multiple days taking

 samples as they are coming into, into port. That is extending

 to other ports as well. We have signed arrangements with other

 AMS programs to do sampling for us at ports they are already at

 for oversight. And then we do through our Office of Inspector

 General work with the Department of Justice in cases of

 criminal, criminal cases.

 This is just a quick look at our complaints over the

 past year. Last year, fiscal year, the team closed almost 500

 cases. About a third of those cases were actually voluntary

 compliance. So for example the farms or businesses that are

 advertising as organic without certification, when they stop

 doing that and pay a civil penalty, that's considered voluntary

 compliance. So they've stopped, they are no longer marketing,

 and often will pay a civil penalty for having, having done so.

 On the right, you see a look at the distribution

 between cases. So that's almost 500 complaints. But we also

 have more than last year 200 just inquiries. And I gave this

 example in the past, at past NOSB meetings that you can hear

 things differently depending on whether you read a question of

 is Farmer Bob certified versus is Farmer Bob certified. That

 one sounds like it's a complaint, one is simply a question, is

 Farmer Bob certified? And we have really, really worked with

 the team to triage in a way that we say handles easy things 
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 fast. Easy thing should be easy. Whereas before we had our

 tiering system, it could take several weeks for us to actually

 look to see whether Farmer Bob was certified. I think that is

 one of the best improvements in that team over the past

 several, several years.

 In FY 2023, we resolved more complaints than, than

 received. We are currently hovering at about 350 open cases,

 but more than 75 percent of our cases are now closed in 180

 days or less. And many of them are much, much faster than

 that. But when cases involve OIG, they can be open for months

 or even unfortunately a couple of years.

 I want to remind the community how you can track

 progress on NOSB recommendations. Keep in mind that a lot of

 the things that I've just talked about today were borne from

 this group, the National Organic Standards Board. And so

 following along with where we are with their recommendations,

 we have institutionalized our communication on NOSB

 recommendations in a way we had not done before. And so we now

 do regular NOP updates for NOSB in the learning center. We've

 done that since spring 2020.

 NOSB recommendation indices, this has been a tool

 online for a long, long time, but it seemed to have been a bit

 of a hidden -- a hidden gem. So we're trying to do a better

 job of getting the word out. We're also trying to do a better

 job of explaining in the indices when we close something, a 
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 brief explanation of why. There are a number of times that are

 still open. But overall we have addressed over 90 percent of

 NOSB recommendations since the Board started its work. The

 number is about 85 percent for practice standards. It's higher

 for National List standards.

 We also regularly report to the NOSB through member

 -- through memos. These are publicly posted, so they are memos

 from the deputy administrator to the Board. But they are

 available online. We expanded those memos. There used to just

 be a report out from the meeting. We have now added a separate

 section to that memo that talks about what our regulatory

 priorities are for the upcoming semester. So the Board has a

 work agenda. But this meeting -- this memo is also our way of

 communicating what our priorities are at the program level so

 people can keep a log, track log.

 OMB regulatory agenda published every spring and fall

 is the definitive place where you go and learn about what the

 agency, and department, and government's regulatory priorities

 are. So those are the four tools that we have

 institutionalized for the last several years to continue to

 report on regulatory status and priorities for the upcoming

 semester.

 I want to thank you all for being here. I want to

 thank the Board. I want to thank the NOP team. You guys are

 an amazing group. The work that we reported on today really 
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 does take a group of very, very talented people that I feel

 very, very privileged to work with every day. So organic

 integrity from farm to table, consumers trust the organic

 label, that is our vision for the organization. With the

 challenges we have, it is a vision that we continue to work for

 and towards every day with the help of all of you in the room

 and listening. So thank you for being here. And I think we'll

 open up questions to the Board.

 CHAIR POWELL-PALM: Thank you, Jenny. Thank you for

 that update. Questions from the Board for Jenny. This is my

 favorite part of the meeting. So Nate Lewis, kick us off.

 Thank you.

 BOARD MEMBER LEWIS: Jenny, can you elaborate a

 little bit on how you anticipate SOE and its implementation

 will affect our equivalency arrangements with trading partners?

 DR. TUCKER: Yeah, this is really, really important.

 So I think I mentioned briefly during the presentation, but

 just a good reminder of how this works. We have trade

 arrangements with other governments like Canada, like the EU,

 where we have agreed that our standards are not necessarily

 identical, but they are equivalent, that they achieve the same

 goal and have approximately the same kind of regulatory burden

 for fair and -- fair trading. And more importantly in my mind

 or just as importantly is the system, itself. And so how

 governments are overseeing, how they are doing all the work 
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 we've talked about here and those control system points, how

 those governments are doing those.

 With the publication of strengthening organic

 enforcement, we have started the conversation with other

 governments on how are we going to update our equivalency

 arrangements. And that may mean that those governments need to

 make some changes in order to remain equivalent with us. And

 so other governments tend to update their regulations, too.

 So, for example, many know that the EU, European Union,

 recently updated its regulations. And so we've already started

 that technical dialogue.

 The dialogue with Canada has started through a series

 of supply chain traceability audits where we identify what some

 of the challenges are. The Canada arrangement was put in place

 in 2009. It's what's called kind of a global, a global

 arrangement, but it was before a lot of the challenges have

 emerged that we all are experiencing today, and so having

 honest conversations with the government there through the

 supply chain audits of where are we seeing collective risks,

 where are we seeing collective gaps.

 Canada was an early adopter of the trade partner

 module. And so they were one of the first ones to get in there

 and put their certifiers within the system. And so I think

 they have shown enthusiasm for that process and for getting

 their folks on board. 
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 We're having that conversation with every single 

 trade, trade partner at this time. But I think there are going

 to be some difficult conversations ahead about we have been

 able to here in the United States put some real investments

 into organic protection and that, it kind of raises the bar on

 harmonized systems around the world.

 CHAIR POWELL-PALM: Allison and then Brian.

 BOARD MEMBER JOHNSON: Thank you, Jenny. I have a

 comment and a question for you. First, I just really wanted to

 show appreciation to you and your team for all the work you've

 done to bring TOPP to life and to coordinate with other arms of

 USDA to support organic and transitioning producers. You

 mentioned that its Farm Bill season. And I and many others in

 this room are spending a lot of our time trying to convince

 Congress to continue this support and to, to make sure that

 there is a future for what you've begun to build through the

 organic transition initiative.

 So I'm really grateful for the statistics that you

 shared today and really encourage you to continue to bring that

 information forward to us so that we can use it in advocacy and

 show that there is a strong demand for the program, and that

 this is a way to build support, a path to organic core

 producers, and make organic food accessible to consumers across

 the country. So thank you for that.

 The question, we received several comments 
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 encouraging us to look to the USDA Equity Commission as a

 source of guidance on how we can build a more diverse and

 equitable and inclusive organic sector. So I wanted to get

 your perspective on how we as the Board can engage the Equity

 Commission and see if you think it might be possible to invite

 a commissioner to speak with us sometime in the future.

 DR. TUCKER: Thank you. And thank you for the

 question. The TOPP program is just incredibly exciting. And

 we're going to be hearing from the northeast groups right after

 lunch. So make sure you're back from lunch in time, because

 they've got some pretty incredible stories to tell.

 Let's talk about USDA Equity Commission. For folks

 who are not around this every day, I'm going to give a little

 bit of background here. It was put in place a couple of years

 ago. And it is -- its purpose is to make recommendations for

 enduring changes to USDA programs and policy that eliminate or

 mitigate barriers to inclusion or access, eliminate systemic

 discrimination, advance equity and justice, and provide

 meaningful processes for continuing oversight of civil rights

 issues. So that is what the group has been charged with.

 This is a secretary level commission. They meet up

 to four times each year. And, in fact, they are meeting right

 now as we speak. So they are having a meeting concurrently

 with us. They gave its first report earlier this year, so

 February of 2023. It had 32 recommendations that related to 
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 how programs and policies might be modified to reduce

 disparities and advance racial justice. And so lots of

 insights from that group that are already being carried through

 at the agency work.

 So what happens is agencies across USDA, and there

 are a lot of us, gets a copy of those recommendations. And

 then we look at our programs and our services to determine what

 can we do both now and in the future. And so there have

 already been changes within AMS, so that's the broader

 Agricultural Marketing Service within which the National

 Organic Program is housed.

 The regional food business centers program, so that

 was a program that was announced in May 2023. And so a large

 part of that program is designed to assist small and mid-sized

 producers in overcoming barriers, including communities that

 have not traditionally been part of USDA programs. There's

 also been a number of processing capacity grants, a number of

 other cooperative agreements and grants run out of our sister

 program, the transportation and marketing programs, that are

 bringing people to the -- to the party, to the table who have

 not been part of it before.

 Those are real changes in a relatively short time of

 hearing from people who have not been part of the conversation

 before. TOPP is also a reflection of that -- of that work.

 Now the work on TOPP was starting kind of concurrently while 
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 the Equity Commission was being developed. And I think we

 can't underestimate kind of the ripple effects up and down and

 all around of, of the work. And so I don't think this

 community is kind of sitting here waiting for, oh, wait, we've

 got to wait for the Equity Commission to tell us what to do.

 That is not how organic works.

 Organic has been very, very proactive in engaging the

 tough conversations and taking actions related to DEIA. One of

 the national partners under TOPP, it's led by the Organic

 Farmers Association, is specifically charged with bringing

 together affinity groups and bringing folks to the TOPP

 conversation that perhaps have not been part of the

 conversation before.

 So I think, though, the good work will continue into

 the long-term. I do want to kind of close that discussion by

 just reminding us all kind of what one thing I said during the

 spring meeting, this really does start with each of us, one

 conversation at a time, of reaching out to somebody we've not

 had a conversation with before, asking them about their

 experience. We heard Nate's really, really powerful story.

 And there were a lot of tears out in the hallway after Nate's

 story. Everyone has a story that they bring to this community.

 And there are lots of stories from people who are not

 part of our community that we deserve to hear and want to hear,

 that we want those stories to be part of our collective story. 
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 And that starts by asking somebody what their story is. And so

 that's a very personal step that can take real courage in

 picking up a phone or approaching somebody in the hall that

 you've never talked to before. And I encourage every single

 one of us to do that.

 CHAIR POWELL-PALM: Brian, please go ahead.

 BOARD MEMBER CALDWELL: Thanks, Jenny. And thanks

 very much for that last -- those last few words. I want to add

 my, my appreciation for the, the really good progress that you

 and your team are making on organic integrity. It's wonderful

 to hear.

 I sit in the consumer and public interest chair. And

 every year for these meetings, twice a year for these meetings

 we get many hundreds of, of consumer -- written and oral

 comments from consumers. And this time we, we really got a lot

 about concern about toxics in plastics and hydroponics. And so

 I want to put this, this question to both you and also to our

 stakeholders. That is how can we move forward and respond

 positively and productively to these concerns about hydroponics

 and toxics in plastics?

 DR. TUCKER: Okay. Thank you for the questions. And

 there are kind of multiple questions within that question. So

 let's start with -- let's start with plastics, because I know

 that has been a topic of significant public comment. It's been

 a topic that this Board has, has talked about. 
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 I think zooming out just a bit, I think one of the

 benefits of the current food system transformation effort is it

 really is helping, I think, communities and consumers

 understand a little bit more about where their food comes from

 and how it is produced. And I think there is no denying

 there's a lot of plastic in agriculture. Right? And that's

 not just organic. That's all of agriculture.

 And so I think organic is often -- I've sort of

 talked to, to new folks. Organization is often a very focal

 point because of its openness and transparency for a lot of

 these concerns to bubble up. So sometimes that can make it

 sound like it's an organic problem, when actually I want to

 just frame that this is a broader experience in agriculture,

 that there is a lot of plastic in agriculture and food, food

 production in general.

 And so this group has taken on some of that, that

 work and that inquiry through your discussion on materials, but

 then also just in general in your conversations. So I think

 those are important conversations to have. We do have your

 National List of deliberation process. We have a number of

 existing constructs and policy steps within this body's work.

 And I think you guys have used, used those well.

 On the topic of hydroponics, which is I tend to look

 at everything as kind of overlapping than Venn diagrams. So on

 the topic of hydroponics, which another area like a lot of -- a 
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 lot of ag, there is a lot of plastic in that, that part of the

 sector. And then to broaden that out to containers more

 broadly and lots of questions about soil-base versus soilless

 production.

 I do want to emphasize that that is a topic,

 containers, that we are very cognizant that that had a high

 place in the regulatory priorities conversation in 2022. So

 when we did our listening session in 2022, containers ranked

 right up there as a high priority, pretty close after the three

 big rules we call the triple crown, origin of livestock,

 strengthening organic enforcement, and organic livestock and

 poultry practice -- standards, sorry. Some of the acronyms are

 a lot even for me, right?

 So we had origin of livestock, OOL; strengthening

 organic enforcement, SOE; and organic livestock and poultry

 standards, OLPS. Those rules, as well as advance rule writing

 related to the nitrogen recommendation that was made in a

 previous meeting, as well as National List work, those have

 been a real focal point for us.

 We hear the community that containers remains a

 priority. We are talking with the administration about the

 best way to proceed with that conversation. We need to finish

 some of these rules. And we also need to make sure we get

 these rules effectively implemented. You know I spent some

 time on SOE and how to implement that. I also want to 
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 emphasize implementation of origin of livestock. We've already

 done a comprehensive review across certifiers for their

 compliance and then by extension their operations compliance.

 That's part of our surveillance work this fall as part of the

 livestock program. And so each of these rules also needs

 implementation.

 So we want to make sure that we're not just putting

 rules out in the world and saying good luck with that. We're

 putting out rules in the world and following through on

 implementation and compliance and enforcement. And so we would

 -- we would take the same very deliberative approach with

 containers in terms of if rulemaking were to proceed, we need

 to think about how best to move forward with that.

 So is that the Board working on it again? A lot of

 work has already been done. Some have suggested that this

 advanced notice of proposed rulemaking that we've done with

 something like inerts has worked well in terms of gathering

 some feedback, which then may lead to Board work. So I think

 there are some questions in terms of what the policy process

 should be related to containers, but it is certainly still on

 our minds as an important priority for the community.

 BOARD MEMBER CALDWELL: Great. Just to follow-up on

 the -- on the plastics, I wonder if, if we can target the, the

 known toxics in plastics perhaps with annotations, just off the

 top of my head disallowing the use of PFAS, or bisphenols, or 
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 phthalates in the production of, of organically approved

 plastics, is that an avenue that we, we could take to -- it's a

 huge problem. Just plastic waste is a huge problem. But I'm,

 I'm wondering if we can just attack it on or try to get a

 toehold via method like that.

 DR. TUCKER: Annotations are a really valuable tool.

 The National List, it is a living list. I think annotations

 can be a really valuable tool and that's part of your kind of

 established processes of the Board. My only kind of comment

 would be as you're working on annotations, do always have in

 the back of your mind what a certifier is going to have to do.

 And so annotations, it is another thing that certifiers have to

 check, so please just have their voices in your head when

 you're working on that so they can take annotations and

 effectively both implement and enforce them with, with

 operations. But annotations certainly are a tool in the

 organic toolbox for starting to address a very complex problem.

 BOARD MEMBER CALDWELL: Thank you so much, Jen.

 CHAIR POWELL-PALM: Amy, please go ahead.

 SECRETARY BRUCH: Sure. Thanks, Nate. Thanks,

 Jenny, for your time. Really appreciate you and the tremendous

 efforts that are undergoing with TOPP and SOE implementation.

 They are very important to the future of organics. I just

 wanted to mention a message from the Heartland. Times are

 extremely tough in our area. Corn and soybean producers are 
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 faced with severe price compression, and limited market options

 for their main crops and also their rotational crops.

 We all -- we heard from a few public commenters, but

 I hear this often from fellow farmers and friends that many

 producers in corn and soy, organic corn and soy are actually

 taking acres out of production just due to these challenging

 times, or contemplating doing so. In general, I believe it's

 easier to retain organic producers, because they know what

 they're getting into, and expand on their operations than

 transition new growers, even though we do need new growers in

 our -- in our operations as well or in our country as well.

 Can you talk more about the concerns about bringing new organic

 famers into our challenging grain world while we're facing

 these, these challenging times right now?

 DR. TUCKER: Thank you for the question. And I -- it

 really reflects that everything we've talked about this

 morning, it's all connected. Right? We are not going to --

for, for TOPP to be successful, we also have to do all the

 enforcement activities and oversight activities we're talking

 about. It has to be a fair market for everyone to be able to

 compete successfully.

 So lots of different elements of that. The import

 oversight program I think is making a difference. That we have

 seen very large shipments where buyers in the United States

 refuse them because we had done testing and they had done 
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 testing, and it revealed the presence of substances that said

 that this is not organic. And they've turned that away. We

 hear from more and more buyers in the U.S. of livestock feed in

 particular. They really would like to buy this at home.

 We are in a -- we are in a very difficult transition

 period where we're working to put even more practices in place

 to protect the market, to protect the integrity of the market,

 while also trying to attract new folks to the market. One of

 the national agreements that we have under TOPP is -- I

 mentioned the one with OFA, Organization Farmers Association.

 Another one is with the Organic Trade Association, partnering

 with Rodale on the demand side, on the buyer side, where they

 are hosting events that can help buyers in the U.S. explain

 buying to transitioning farmers and explain kind of what, what

 those contracts might look like, talk about market development,

 talk about how to approach market development. Those are also

 resources that will be available for existing farmers that we

 don't want to lose.

 It is we need to work on all -- on all fronts in

 order to have people in the United States feel safe enough to

 take that -- to take that jump. And this is why our team

 buildup has primarily been in the accreditation, and

 compliance, and enforcement group. This is why SOE is so

 important. Because if there are certifiers that are overseeing

 exporters to the United States that are not doing their jobs, 
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 we need -- we need SOE as a tool to hold them accountable.

 So if, if NOP is, well, yeah, I do that in addition

 to doing all these other things and they aren't approaching it

 with the same -- the same rigor, they need to either change

 their degree of rigor or they need to exit the market. And it

 is only through that oversight and that protection that it will

 -- folks will feel truly safe to stay in the market here and,

 and join it. But all of these levers work together. It's all

 connected.

 And for oversight, SOE, TOPP, strong clear standards,

 it is all part of an economic and sociological system that we

 have all chosen to be part of for very personal reasons. We

 are part of the system collectively that can make it better.

 CHAIR POWELL-PALM: Kyla, please go ahead.

 BOARD MEMBER SMITH: Hi, Jenny. So we heard several

 comments during the comment webinar really to imports and the

 challenges that the industry is still experiencing. And you

 shared a lot of great information today during your update, as

 well as the update that's in the learning center. So thank you

 so much for that, related to the testing that NOP is

 conducting. And you know as certifiers, we're required to

 disclose the results of the residue test that we take, if they

 are requested. Is there a similar mechanism or another way for

 the program to continue to be transparent on the testing and

 the results that is happening since imports continues to be 
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 such a concern for stakeholders?

 DR. TUCKER: Yeah, great question. We -- so sampling

 and testing is an important part of the program's oversight.

 And as a tool, actually, we're able to do a lot. We could

 always do sampling and testing. Now that we have Customs and

 Border Protection data, we have a sense of where to go to

 actually do the sampling and testing. So that is helping us in

 doing more, more targeted surveillance and, therefore, sampling

 and testing, because we actually know when these ships are

 going to arrive and what's on them, and we have the connections

 with CBP to do them.

 Our annual enforcement report to Congress, I think,

 is a vehicle through which we can do more of this reporting.

 The Farm Bill had some very specific requirements for

 reporting, which helps to drive SOE, but also improve organic

 integrity database. I think along with that in our report, we

 do report the activities that we're doing.

 There's always a little bit of a fine line between

 being open and transparent about what we're doing, because when

 you're open and transparent about what you're doing we let all

 of you know what we're doing, but we also let all the bad guys

 know what we are doing. And so there is a significant concern

 about what we call sources and methods where we don't

 necessarily want everybody to know who, you know, what we're

 doing or where we are. 
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 I can tell you that when we went to India in the

 spring, we did a pretty broad testing program of that. And it

 led directly to non-compliances for certifiers on the ground.

 We have a team over there right now that's following up how did

 you implement those. And if these are open, non-compliances

 that have not been resolved, then our next step under the

 regulations is to move to a proposed suspension.

 And so we -- I think the enforcement report is a good

 vehicle for us to talk more about what we're doing. We're also

 very, very sensitive about showing our hand too much.

 BOARD MEMBER D'AMORE: I, too, would like to lend my

 voice to the -- to the praise of SOE and that's where I'd like

 to stay now for a second. During our public comment sessions

 last week, there must have been three dozen times where I sat

 back in my chair and said, boy, thank god we've got SOE. Can

 you imagine addressing this crowd if we didn't have SOE?

 And so I think the comment that I would like to make

 to, to much of what was said and maybe almost redundant to some

 of what two of you have said is we're at a point in time and

 that point in time is, is -- we're in a lag time, I would call

 it. This is in motion. But for it to hit the ground and be

 meaningful to some of the questions that we're asking won't

 happen the second there was an SOE. It's going to happen in

 six months, better in a year, better in a year and a half.

 So I, you know, that's just a comment. It's not a 
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 judgment at all. But I tell you what, if we didn't have SOE as

 a talking point in the last, last week with those oral

 comments, I just don't know what we would have done. So thank

 you and, and I firmly believe that these concerns will, will

 diminish rapidly with time. And just hang onto your saddle

 right now. So thanks.

 DR. TUCKER: I appreciate that. I'm going to do a

 quick follow-up comment. This is -- one of the things that

 would be -- we're really sensitive about exemptions, because we

 are getting a lot. I get -- because my name is on the rule,

 for more information contact. And it's unbelievable the number

 of emails that I get on this. And unfortunately a lot of those

 emailers said, well, I'm only doing this, that, and the other

 thing, so I don't really need to be certified, do I? And I

 find that alarming.

 So I do want to -- because if we get to next sort of

 spring and summer, and, oh, well, I got myself exempt, then we

 didn't -- then all of this effort didn't have the impact that

 it could have. And so, again, I want to say to folks out in

 the community who are listening, this only works if we're all,

 all in. And so I know that there are going to be lots of folks

 looking for the loopholes. But this industry is worth

 protecting. And it only works if we're all, all in.

 And so it will take time. And we've already had a

 lot of time for folks to learn about this rule and to start --
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 to start to get certified. So I, I do want to emphasize the

 importance of this. Take it seriously. I'm also getting the,

 well, this part of the rule is really hard. And did you really

 mean this?

 The rule is hard where the risk is high. And if you

 read the rule carefully, the rule is hard where the risk is

 high, which means it's not supposed to be hard where the risk

 is low. And we want to read the rule in that -- in that

 context, which means small farmers out there should not

 actually be overly burdened by this rule. It is the middle of

 the supply chain. It's where those hand-offs are where it

 would be really easy for somebody to combine a non-organic load

 with an organic load.

 And we're asking for physical signage to mark it to

 decrease that risk because you know what, that's a high risk

 point in the supply chain. It's going to take all of us

 looking at how to do this and not trying to find the easiest

 way out, but really protecting it for this to work into the

 long term.

 BOARD MEMBER D'AMORE: Hi, Gerry, again. I'm sort of

 -- I just got an email, a text saying identify yourself,

 please. So anyway, that's why -- that's why Gerry again. I'm

 sort of laughing as you're talking on this last point. You're

 dealing with the segment of the supply chain that's not really

 used to having people tell them what to do. That's part of the 
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 problem, if I may be so bold. 

 So there's one segment, though, Jenny, that I am

 still concerned about. It was the rash of phone calls two

 months ago from major retailers and then an even greater amount

 of phone calls from the, the growing portion of our business

 that was wondering will the supply chains be open and fluid

 during the harvest after the 9th -- after 20 -- after the end

 of March.

 There is another group, though, and there's a lot of

 them that just don't know what they don't know. So what you've

 talked about are people that they do know and they're figuring

 out, yeah, they've got to comply. But I'm worried about the

 segment that is not the largest of the group, but maybe the

 most voluminous towards the end of that supply chain handling

 that is really clueless. That's the only -- that's my comment.

 Thank you.

 DR. TUCKER: Appreciate that. I'm really hoping that

 the level of clueness -- cluelessness continues to drop every

 day. And I do know there are a number of folks out in the

 audience and I, I can see you out there, who are doing a lot of

 work and educating. So it starts, it might start with the

 people in this room. But the people in this room are often

 involved in longer supply chains. And there are people online

 listening to us. There will be a transcript here. People will

 post things on Linked In and such like that. 
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64

 I think continuing in every single way possible to

 continue to push the word out, all of us need to be thinking

 throughout the supply chain of how do I -- how do I help the --

 I often talk to my team about you throw a stone in the -- in

 the lake, you never actually know where all those ripples are

 going to go. But be thoughtful in which stones you throw,

 where you throw them, and you'd be shocked what can happen.

 And I do believe this is an example. There might be

 a lot of stones in this room that can actually have ripple

 effects way beyond what we all realize.

 CHAIR POWELL-PALM: Other questions from the Board?

 Welcome, Carolyn. I'd like to mark Carolyn as present. Amy,

 please go ahead.

 SECRETARY BRUCH: Thanks, Nate. Jenny, I appreciate

 learning about the on the ground testing you guys are doing at

 point of departure. I was wondering now it's even more

 difficult. We have a lot of geo-political challenges. There

 is wars breaking out. Some of the impacted countries are where

 we're receiving imports. And some of them are still countries

 of high risk that are faced with these geo-political

 challenges. Can you speak to the work that's being done to

 ensure integrity of imports through these additional challenges

 abroad?

 DR. TUCKER: Yeah, it is scary times out there. We

 have already seen a number of certifiers working overseas exit, 
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 some countries, where they no longer have the administrative

 capacity. I mentioned that as part of SOE. But it's already

 happening where certifiers have dropped out of particular

 countries. We do keep an eye on the number of certified

 operations in certain countries. There is also -- so under

 SOE, certifiers can only go places they can do unannounced

 inspections. So that's, that's important. And I think some of

 that is already happening now.

 I think it's also kind of a fair question of what

 about NOP's oversight of the certifiers, right? So if you have

 certifiers that are working in countries that the State

 Department has said we can't travel to, what does that -- what

 does that mean in terms of our oversight of certifiers. And

 that is an active conversation that the team is kind of

 evaluating in terms of what is, you know, what are the

 regulatory constructs around limiting our administrative

 capacity to oversee certifiers operating in some of these

 places.

 And what does that mean? So if you -- because this

 gets complicated really quickly and it's aptly vital to figure

 out. So we suspend a certifier because we can't oversee that

 certifier's work in Country X. Okay. Well, now the war ends

 and we can go back. What happens to all of those operations

 that were suspended because the certifier could no longer do

 business and no certifiers could do business. And now you've 
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 got a lot of farmers who may have been perfectly playing by the

 rules and doing the best they could to contribute to this -- to

 this kind of global community, what do they do. Can they get

 reinstated and what does that -- and you have to reinstate the

 certifier.

 So this gets really messy really quickly. And it's

 something that is actively on our kind of internal work agenda,

 questions we're trying to work our way through.

 CHAIR POWELL-PALM: Did you have any questions,

 Carolyn?

 BOARD MEMBER DIMITRI: I don't have any questions.

 But I, I do have a comment. This is the end of my third year

 on the Board and I always thought of myself as an extremely

 informed organic person in terms of consuming and researching,

 having spent a lot of years writing papers. And it's just I

 guess being on this Board and having these interactions with

 the program. Of course, Jenny and Michelle are like our

 primary voices. I realize it's so much more complicated than I

 ever anticipated. And it -- I just find that surprising. And

 so I guess I thank like my Board colleagues and the National

 Organic Program. It's like not perfect by any stretch of the

 imagination, but it's a thing.

 DR. TUCKER: Carolyn, we're really, really happy that

 you are here and a part of that complex conversation.

 CHAIR POWELL-PALM: Other questions from the Board? 
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 I have a question for you, Jenny, that we did not actually talk

 about. But I was wondering if you might go back a few slides

 where we could talk about the crosswalk for Climate Smart. It

 was two or three back.

 So could you tell us a little bit about what the

 Climate Smart crosswalk is? And I think it's one of the most

 exciting things to come out of our Board, when we had such a

 short period of time to make it known that organic should be

 considered Climate Smart we were able to get it done. And I

 would love to hear from you sort of how you've taken that

 proposal and been able to build something off it.

 DR. TUCKER: This is an exciting project. And I, I

 think it really has shown sort of a lot of how this process

 works, when it works really, really well. So the Board had

 started with -- I think it's a letter, letter to the Secretary

 sort of outlining sort of observations of the Administration's

 engagement with, with climate change and sort of proposing a

 role for organic, and talking about the role of organic as part

 of that conversation.

 That letter got circulated throughout USDA and

 ultimately turned into a work agenda for the Board to continue

 the dialogue on that. And there was a lot of great feedback

 that came from the community and public comments so that it did

 end up being a recommendation.

 Our team, in listening at NOP and listening to all of 
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 those conversations, and reviewing the Board's recommendations,

 proposals, and that letter, and all the public comments

 associated with that, they were able to develop a very nice

 piece that takes the different parts of the organic regulations

 and talks about what the possible offerings through, for

 example, NRCS, Natural Resources Conservation Service. So what

 are the different offerings that, that NRCS provides, for

 example, the EQIP program and things like that. So how it

 cross -- how the regulations support Climate Smart agriculture

 in a very real annotated way.

 And so that ended up being a pdf document that has

 been shared with others in USDA and has been well received.

 We're translating that into an interactive module for the

 Organic Integrity Learning Center. You'll be able to go in

 there and kind of click on sort of different practices,

 different regulations to find out resources, for example, that

 NRCS may have to help you do this.

 And part of the goal here was if you're an organic

 farmer that also wants to get other types of credits, for

 example, through a state program or wants to qualify for

 certain conservation benefits, for example. They can more

 easily see what parts of the organic system plan that cover

 these regulations might actually, here's the language you can

 take and use for, for example, applying for some type of

 program. 
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 There's so much talk now also about regenerative.

 And I think this really helps kind of make the point that

 organic farmers are already, it's baked into the, the

 regulations. And so I think the crosswalk tries to make that

 more, more explicit. So coming soon to a learning center, free

 resource, sign up now, online, 24/7. We'll send out an Organic

 Insider.

 CHAIR POWELL-PALM: Thank you for that. And I just

 want to say thank you for the quick work giving us that work

 agenda item and making that so timely. And I also wanted to

 say, thank Amy, the chair of CACS for doggedly spending many

 nights on the phone with me as I tried to pound it out and

 write it, and gave great inside and feedback. So thank you for

 your work on that as well. It's great to see this come to

 fruition.

 Other questions from the Board? Well, folks we are

 just slaying it on the timing. I mean we're doing really well.

 So I would ask if it's all right with the team that we break

 for lunch now, still take the 1 1/2 hours, and I think our top

 presenters have been -- have given us the go ahead that they're

 all right to move the agenda up and we might be able to just

 finish the day early.

 And so that would be coming back at about 1:30

 Eastern Time. Is that right, Michelle? Anything to add to

 that schedule-wise? All right. With that, let's adjourn for 
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 lunch and we'll see you all back here in an hour and a half.

 Thank you.

 (Whereupon, at 12:01 p.m., a lunch recess was taken.) 
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71

 A F T E R N O O N S E S S I O N

 (1:44 p.m.)

 CHAIR POWELL-PALM: All right, welcome back again.

 I'm going to hand it over to Deputy Administrator Jenny Tucker.

 DR. TUCKER: Welcome back, everybody. I hope you had

 a good lunch. We are now moving to the next part of our

 program, which is an update and presentation from the

 Transition to Organic Partnership Program, specifically the

 Northeast TOPP region. And so I'm going to introduce the first

 speaker here, Diana Kobus. And she'll introduce the rest of

 her team.

 Before I turn it over, though, I wanted to just

 compliment this region. The New England Region, the Northeast

 Region has a whole lot of states in it and, in fact, includes

 all of New England, where we're all sitting right now, but then

 it also extends down to some states that don't see very much or

 haven't seen in the past very much organic. And that includes

 West Virginia and Virginia, and so it also -- it covers really

 the whole Chesapeake Bay area and all the way up to Maine.

 That's a pretty high lift.

 There are lots of states in that region, a lot of

 diversity in farming practices, and demographics, and

 socioeconomics, and everything else. And so I was really,

 really privileged to join a very early bringing together of

 partners. It was snowing, as I recall, in New York. And I 
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72

 think Diana set a real early tone of collaboration in that

 region. So, Diana, grateful to you and all the work in that

 --- in that region.

 Let me tell you a little bit about Diana. She is the

 executive director of Pennsylvania Certified Organic, or PCO.

 PCO is the northeast regional lead for, for TOPP. And so Diana

 joined the PCO team as its executive director in the middle of

 2020. She has over a decade of nonprofit leadership

 experience, with a particular focus in the certification of

 people in environmental and public health professions. People

 have such interesting backgrounds in organic.

 So Diana has a masters in environment science and

 management, with a study focus in organic from Duquesne

 University, Center for Environmental Research and Education.

 And she holds an undergraduate degree in English and

 communication studies from Carlow University. Before coming to

 PCO, she was the executive director of the Institute of

 Professional Environmental Practice. She did that for 12

 years, successfully facilitating a merger with another organic

 serving public health professions.

 She also worked at Whole Foods Market in the early

 2000s, different locations around the country, which really

 moved her to find ways to educate the public about the

 standards and food labeling after interacting with a lot of

 curious customers. So again those really personal stories 
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 about what brings us to organic.

 She brings a strong passion for organic production

 and the critical impacts it has on human health and the

 environment. She was born and raised in Pittsburgh. And, in

 fact, our last in-person meeting before we all went online for

 the pandemic was in Pittsburgh. It was a delightful meeting.

 She is there helping to help farmers directly in her work at

 PCO. She finds great joy in collaborating with stakeholders to

 find innovative and generative new pathways towards a health

 future for all.

 And so, Diana, thank you for being here, for all your

 work in the northeast.

 (Applause.)

 MS. KOBUS: Thank you, Dr. Tucker and the NOSB for

 the opportunity to share some of our accomplishments today.

 It's been a great honor for PCO to lead the Northeast

 Mid-Atlantic Region in the Transition to Organic Partnership

 Program, or TOPP as we all call it. I'm very happy to say it

 has been a pleasure to get to know this group of already strong

 leaders and the impactful work of their organizations in the

 northeast as we've taken up this work together in the region.

 I worked in this sector for only a little over two

 years before we became involved in this project. And as I have

 said to many of you, I cannot fathom any segment of industry

 that could have pulled together and coordinated an effort of 
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 this magnitude other than the organic community. The history

 of cooperation and interdependence shows through in every

 meeting, every interaction we have with each other. The spirit

 of teamwork in this group is truly an incredible thing. And I

 want to thank the other partners, the leads, and the NOP staff

 for their continuing support.

 The Northeast Mid-Atlantic Region is home to many

 prominent leaders and influential founders in the organic

 sector, as well as areas where organic markets have yet to be

 developed. PCO's approach to this region's TOPP work has been

 very intentional and that we aim to leverage this network of

 leaders in partnership, rather than attempt to lead alone.

 In addition to PCO's regional lead, we have nine core

 partners in this region, that includes 13 states and the

 District of Colombia, the highest number of states of any TOPP

 region. The northeast TOPP region is also home to a large

 number of founding and successful USDA certification agencies,

 which is why we have termed our region a partnership for

 organic transition, not a center, to reflect the ethos of our

 work, guiding the region together in this five-year program.

 Meeting online every other week for the last 10

 months and only meeting once in person to kick off during a

 snowstorm in March, our goal as core partners has been to

 create a strong network of networks led regionally by PCO, but

 with a central contact in each state, utilizing each of our 
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 local sets of relationships and partnerships to create

 connections that will last well into the future of growing the

 transition to organic agriculture.

 In addition to our lead and nine core partners, the

 region has added 36 project partners for a total of 45

 organizations collaborating in this work, just so far. We also

 have 95 mentees and 79 mentors, have reached over 2,000 farmers

 directly at events, and provided one-on-one technical

 assistance to 15 farmers.

 Our region has either hosted or have staff attending

 85 events so far this year, and all of that work was done with

 just the core partners and 7 partners as we continue to build

 the program and recruit the additional partners for Quarter 3

 with our total number now standing at 45. Consistent feedback

 from these events has been that if we want more farmers to

 transition, we need to do a better job at making the business

 case for transition.

 While we know the market development grants will help

 with that obstacle when they are announced, as we begin Year 2

 of this work in our region we will also be creating more

 regionwide programming to address that feedback, including

 coordinated marketing materials and outreach to farmers, making

 the business case for transition to certified organic.

 Mentorship. The northeast mentorship program, as

 many across the country, will be launching in November. And we 
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 wanted to feature a mentorship for you that can serve as an

 example to other farmers thinking about transition, a

 transition from dairy to tree fruit.

 Russell Wallack was one of the first to sign up as a

 mentee in a mentorship program. And his operation, Breadtree

 Farms, is located in the northern Hudson Valley on about 600

 acres in the hill country, northeast of New York's capital,

 between freshwater Hudson River and Vermont's high tectonic

 mountains. At breadtreefarms.com you'll find lots of

 educational information, including Russell's own words.

 He says much of the land here is actively farmed by

 family dairies. There are no interstate highways in Washington

 County and barely one DMV. We believe this place has the

 potential to become the breadbasket of the northeast. The

 first focus of our work is restoring landscapes by planting

 thousands of fruit trees. And we currently steward

 approximately 600 acres in the upper Hudson Valley without

 toxic chemicals, using strategies designed to build soil, clean

 water, and increase biodiversity. Breadtree is growing the

 regenerative chestnut industry in the northeastern United

 States. We farm to restore land to support a healthy climate

 and to build food security for future generations.

 On the mentor side of that equation, we have Brian

 Caldwell, who runs a certified organic orchard and lot grow

 farm in West Danby, New York. Brian is also a founding member 
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 of NOFA/New York and currently serves on NOSB in the public and

 consumer advocate role. On his profile, he says we believe

 that certified organic production is the most powerful, mutual

 approach to good farm stewardship at this time.

 So Russell and Brian, we look forward to following

 this transition. And this is just one example of the type of

 farmer-to-farmer relationships that TOPP will build by the

 hundreds across the country.

 CHAIR POWELL-PALM: Can we give a shoutout to Brian?

 MS. KOBUS: Yes.

 (Applause.)

 MS. KOBUS: All right. I want to give a shoutout to

 the -- to the website committee here, too. So this next slide

 shows us the TOPP website. PCO led the committee of extremely

 talented staff from all six regions in developing and launching

 the TOPP website, including a national landing page and

 regional subpages.

 All of the events for TOPP related work in the

 country can be found here. And they can be searched by state

 or region. We are already launching -- working on the launch

 of Version 2, incorporating suggested changes, more resources

 and mentorship participation, and training materials. So thank

 you to those committee members for your work to produce this

 resource in very short order. And our group will now pivot

 from website committee to marketing committee moving forward. 
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 To grow equity and accessibility in the region, we

 are also working with Black Farmers Index across multiple

 states to bring resources to growing underserved communities of

 farmers with many of the nations urban population centers

 located in our region. That includes D.C., Baltimore, New

 York, Newark, and Philadelphia and Boston. We are eager to

 further connect the work of the local organizations that are

 serving their communities by redeveloping their neighborhoods,

 bringing fresh food to food deserts, and in many cases feeding

 the hungry materially and in spirit. Foundational community

 building on this level is work that provides lessons for all of

 us.

 In addition, we are partnering with Grow Pittsburgh

 on a project that will create a template for helping urban

 farms transition to certified organic. NOFA/Mass, one of our

 core partners, also has a robust food access program and has

 developed a DEI program that provides the opportunity for

 communities of color to have sovereignty over and make useful

 connections around their relationships with the organic

 movement. They consider the foundational needs of these

 communities of farmers first, addressing systemic inequities in

 the process, and their team will bring educational programming

 and resources to our region.

 Kaia Shivers here with me is president of the Black

 Farmer Index and is here to share about their work and the work 
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 we have planned together with TOPP. Please welcome Kyla

 everyone -- Kaia.

 DR. SHIVERS: Thank you. Thank you so much for

 giving me this platform and to give everybody a platform. My

 name is Dr. Kaia Shivers, but everybody calls me Kaia. That's

 my nickname. Started Black Farmer Index April 2020 as an

 answer to the growing food insecurity during the global

 pandemic. I started with two questions, who will be affected

 first when there is a food shortage and, secondly, how can I be

 a part of the solution.

 Because so many black people live in food deserts and

 food swamps as a result of being forced out of the agrarian

 lifestyle, the answer was sobering. The remedy was to ask

 those in our communities who are closest to the food, black

 farmers. Thus began a commitment to bring as much business to

 black growers with a simple motto, direct consumers straight to

 farmers, all the while asking them how they survived

 generations of inequities in agriculture, to cull answers and

 an equitable agenda so we can all thrive.

 We started with 150 farmers on our index. Today, we

 have over 1,200 growers listed in most of the united -- in most

 of the states in the U.S. And also we have a few farmers in

 USVI and Puerto Rico since we've expanded in our work to ensure

 that black farmers receive as much support, resources, and

 exposure to be fully and wholly included as businesses in 
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 agriculture. During our journey, we were imbued with

 generations of agricultural stories that were rich in lessons

 and practices. Sadly, many are left out of the annuls of

 America's narratives.

 One piece of regularly shared information was that

 many of the growers used no chemicals, no pesticides, no

 invasive equipment, no till and other methods that will be

 called organic and climate friendly in agri business. However,

 these growers rarely if at all use the term organic. They

 describe their harvest and husbandry as tradition, the old way,

 or heritage, or heirlooms, what their parents, and

 grandparents, and ancestors spanning back before the Civil War

 taught them.

 So committed to the land were black agrarian

 societies to the environment that farmers in North Carolina

 protested against toxic soil being dumped in their communities

 in 1982, which sparked what we call now the environmental

 justice movement. However, they are sadly invisible when it

 comes to environment justice talks. However, though, we

 discovered that they were largely absent all of these farmers

 who talked about organic farming from the organic industry and

 have yet to reap the rewards of their sacrifices.

 We found out that these references to ecologically

 smart farming have been hijacked and often remixed.

 Unfortunately, the average black grower already has a fraught, 
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 unstable relationship with USDA and local offices. But we know

 that if we can -- if we cannot truly equalize agriculture right

 now, the whole industry will be gravely impacted. As a result,

 a major part of our commitment is to ensure that black farmers

 have more representation as certified organic farmers.

 Thankfully, several people saw our work as important in this

 initiative to transition as many growers into the certified

 organic space.

 Working with northeast TOPP, we plan to use our on

 the ground engagement practices and rich relationships we've

 been cultivating with agriculturalists to build a community of

 growers who are certified and in a position to pass on that

 rich cultural knowledge of growing, all the while feeding folk.

 We are working in Virginia, Maryland, West Virginia,

 Washington, D.C., Delaware, New Jersey, and Pennsylvania. We

 will be very busy, yes.

 We will do so by meeting the farmers where they are

 literally on the farms with intimate visits, where we have

 honest conversations about their needs, their interests, and

 questions about transitioning to organic. Also, we have

 planned an array of online and offline communications to

 consider farmers who are social -- who are media savvy in

 social media, and to even those who do not own a computer,

 which is a fact we come across more times than we want to admit

 in the field. 
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 As well, we will be conducting townhalls and 

 listening sessions that serve as a way to enhance the community

 of farmers, and provide a customized and culturally competent

 experience that explains the benefits of certification, and

 encourages them to join in a central part of agriculture that

 they've already been a part of for decades. Let me emphasize

 that farmers do not want handouts. Farmers do not want

 handouts. Farmers do not want handouts. They want their space

 in the market, and the resources and support that is owed to

 them, like the photo of the first slide, Purple Mountain

 Organics, founded by Dr. Amen and his family in Upper Marlboro,

 Maryland. Dr. Amen traveled and studies in Japan to learn how

 to harvest -- to learn better rice harvesting practices, to

 reduce the methane that comes from rice production.

 So we went to the farm and helped him plant Japanese

 brown rice by hand in May. Dr. Amen is certified and has

 become a go-to in the black farming community in better rice

 planting methods, but is highly undervalued in the larger

 organic space.

 The second slide we lovingly call Donna Deer (ph.)

 and Paulette Green (ph.), we call them the untees (ph.). They

 are transitioning to organic on land that Harriet Tubman's

 family once worked. And as a matter of fact, Paula Green --

 Paulette Green, who is in the yellow, this is the land that her

 family works, too, as well. So, okay, they are transitioning 
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 to organic on the land and Harriet Tubman's family once worked,

 and is now an heirloom of Ms. Green. So we want to help them

 plant more of their agroforest and seasonal vegetables.

 In closing, this type of work that we do, we know

 that farmers are committed to organic, but have been left out

 of the industry that has developed so many blind spots that

 must be corrected, so that real representation is achieved.

 And we are here to ensure that. Thank you for your time.

 (Applause.)

 DR. SHIVERS: Thank you.

 MS. KOBUS: Thank you so much, Kaia. And thank you

 for the spirit that you bring to our work together. It's very

 meaningful for me. And I've got to shoutout to Stephanie

 Jerger from OTA for connecting us.

 DR. SHIVERS: Yes.

 MS. KOBUS: Yeah, Stephanie.

 (Applause.)

 MS. KOBUS: All right. So I'm going to kick of a

 series of updates now from each core partner. And because so

 much of this work is specific to place, each of us have about

 two to three minutes to present the view of TOPP's work from

 the perspectives of our own metaphysical -- metaphorical

 backyards. I guess metaphysical, if you're into it.

 So mine is Pennsylvania. There we go. And those PCO

 is sharing responsibility also for Maryland and Delaware right 
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 now, as you'll see on the maps. Thank you, Katie, for the

 wonderful maps with stars with each region and where they are

 having impact.

 So in addition to PCO taking on the regional lead

 role in support of TOPP, Pennsylvania is home to organizations

 that are both at the foundation of the organic movement and the

 future, some familiar to you and some that may be new to you.

 The challenge to engage farmers into the process of transition

 is substantial. But by working with some of the best partner

 organizations on the planet to help, we are up for that

 challenge.

 The only state with its own Farm Bill, we are also

 home to more farmers under the age of 35 than any other state

 in the country. And we have both the opportunity and the will

 to be our nation's leader in the transition to organic from the

 highest levels.

 One event we really felt showcased the commitment of

 our Pennsylvania community to organic was Rodale Institute's

 annual field day, where farmers, students, and supporters of

 organic come to learn from the pioneers in organic research.

 Our staff tabled for TOPP and talked with farmers interested in

 transition, which is exciting in its own way. But more

 exciting was that Pennsylvania's Secretary of Agriculture,

 Russell Redding and our governor, Josh Shapiro, both made a

 point to come and support this work with our governor saying I 
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 believe very simply if we want to grow our economy here in the

 Commonwealth of Pennsylvania, we must invest in farms, we must

 invest in ag, and I believe organic farming is key to that

 growth. We at PCO agree. And we continue to build our

 networks and programming in the state in support of TOPP.

 So we're going to go down the line here and be a

 little patient with us. We're going to switch out kind of two

 at a time, when Devin is finished. But it's my pleasure to

 introduce to you Devin Cornia, NOFA/New Jersey's executive

 director, to talk to you about TOPP and his work in New Jersey.

 MR. CORNIA: Good afternoon, you all. Thank you,

 Diana. Thank you for not making me follow Kaia. That's

 awesome. For those of you who aren't lucky enough to know New

 Jersey intimately, we're a very diverse state. Can you show us

 the map, please?

 Organic farming in New Jersey has historically been

 clustered to the most wealthy areas in the state, which is

 really tough. As a really small organization with a small

 staff, we haven't been able to branch out and adequately reach

 our entire community. I've got farmers way down in South

 Jersey it takes 2 1/2 hours to get to. We don't have the

 staff, the resources, the time to support them. But now

 through TOPP we do. We're able to reach them. We're able to

 hire on additional staff, more resources, get the adequate

 resources to the folks that want to go organic but haven't been 
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 there before. So that's huge right off the bat. We're

 reaching more farmers as a whole, relationships with the

 foundation for all the work that we do.

 And again, if you're unfamiliar with New Jersey, we

 don't have great relationships in our industry. They've been

 siloed. Conventional farmers don't understand organic farmers.

 Organic farmers don't understand conventional or chemical-based

 farmers. And the resources and entities that support all of

 them don't always get along, don't integrate well. It's not a

 deliverable.

 But for this TOPP program prompting us to get a fix

 on those relationships, bring us all together, understand that

 we're not that different is huge. And it's not a one, a two, a

 three-year deliverable. This is a 10-year deliverable that

 TOPP is going to have an impact on, which I'm really excited

 about.

 So what are we doing in New Jersey to repair these

 damaged relationships? We're having events -- you can click

 the next slide. We're having events that draw both

 conventional producers in, as well as established organic

 producers who want to sharpen and hone their edge. We're

 having conservation webinars, soil health management, nutrient

 management webinars that speak the language to farmers that

 aren't currently engaged in the organic, shall I say more

 crunchy side of things. Being able to speak to both audiences 
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 I think will really help heal. And TOPP is allowing that to

 happen.

 To date, we have had events. Like I mentioned, the

 webinars. We've had a field walk on Closter Farm, highlighting

 one unique operation that is the only certified organic

 livestock and crops farm in New Jersey. There is only one.

 That's pretty wild. We're also supporting underserved

 producers with a partner, Food Shed Alliance, on one of their

 incubator sites. Now into 2024, we're really ramping up with

 community events and outreach. So we're going to be pounding

 the pavement. We're going to be in New Jersey, Eastern

 Pennsylvania, Delaware, attending farmers' markets, hosting

 field tours, community events, supporting the mentorship

 program, and just building those bridges back up that haven't

 existed yet for lack of resources.

 So I want to give a shoutout to our partners.

 Because I think the biggest thing TOPP has afforded is the

 ability to work with these amazing people every other week,

 keeping us going, keeping us inflated instead of deflated. So

 thank you to PCO for being awesome regional leads. Thank you

 for the NOP and the NOSB, and everyone who made this happen.

 Back to you, Diana.

 MS. KOBUS: Thank you, Devin.

 (Applause.)

 MS. KOBUS: So let's see, next we're going to bring 
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 up Teresa Downey from NOFA/New Hampshire and Laura Davison.

 We're just going to kind of let everyone introduce themselves

 as they come up here.

 MS. DOWNEY: Thank you. There we go, hello. I'm

 from NOFA/New Hampshire. I am the TOPP coordinator. I'm

 Teresa Downey. So NOFA/New Hampshire has developed a diverse

 network of 13 TOPP cohort partners to help build community,

 create programming, and increase outreach to farmers throughout

 the state. We are working with each cohort partner to develop

 events showcasing our specific areas of expertise, to assist

 transitioning farmers within their networks. Organizational

 partners are encouraged to cohost New Hampshire TOPP cohort

 events, providing increased networking opportunities for

 farmers across production practices and scopes.

 Several on-farm New Hampshire taught cohort programs

 have taken place to date. These events provided community

 building and technical assistance opportunities for farmers and

 producers who may wish to transition to organic. At an

 intensive rotational grazing and grassland management workshop

 with NOFA/New Hampshire TOPP cohort partner Granite State

 Graziers and the Northeast Organic Dairy Producers Alliance,

 farmers walked the host farm's fields to see how their fencing

 system allowed dairy animals free access to organic pasture and

 the barn, while maintaining intensive grazing, as well as

 organic hay production. 
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 On another on-farm workshop cohosted by our cohort

 partner Chesire County Conservation District, shared

 information on manure management with bedded packs. From

 structures and materials best suited for cows on dairy farms,

 to producing manure that can be spread on farms to improve soil

 for grassland management or sold as a value-added product, all

 aspects of manure management were shown and discussed.

 At the strategies for growing potatoes, cohosted with

 our cohort partner Vital Communities, farmers were shown

 methods that can be used by small and medium sized farms to

 utilize field rotation, trap crops, trial pest management

 techniques, and restore equipment to make organic potatoes a

 staple crop of their yearly production.

 We are looking forward to continuing to work with

 farmers and cohort partners in the coming months and year to

 expand TOPP resources across New Hampshire.

 MS. DAVIS: Thank you, Teresa. I'm Laura Davis. Do

 you want to advance the slides? I'm with NOFA/Mass. And my

 job at NOFA/Mass, I'm also -- I'm a board member, as well as an

 organic certification assistance coordinator. I do some soil

 test analysis as well. What's cool about my job is that it was

 formed sort of from the sound and sensible program that USDA

 had back a while ago. And since then I've been working to help

 farmers and food processors navigate the organic certification

 process. 
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 My other hats are I'm an organic vegetable farmer, as

 well as I co-chair the Interstate Council in seven NOFA

 chapters. So it's great to work with all of these groups,

 today. You can go back one, Diana. Thank you.

 So really exciting to me is our partnership with

 UMass extension in Amherst, which is their flagship

 agricultural school. Since I've been involved at NOFA for the

 last 20 -- or 12 years, they had always told us that they teach

 people how to farm and it's up to the farmer whether they are

 going to choose conventional or organic production. And we

 finally over the years have made progress in that relationship

 and especially as TOPP came about to sign them up to deliver --

 develop and deliver a series of seven workshops for organic

 growing. So we're really excited about that, because this is

 the first time that they have done anything like that.

 This is actually a picture of me and Congressman

 McGovern. He brought a cohort of about 30 people to my farm in

 August. And it included many from NRCS, FSA, World

 Development, and so forth. I was really surprised that no one

 had heard of TOPP yet. And the congressman says, no, we've got

 to get the word out about this, this is a great project. And

 he was -- he's always been a big supporter of agriculture in

 Massachusetts, as well as his whole district and in Washington,

 D.C., so we thank him for that.

 Diana already talked a little bit about the NOFA/Mass 
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 equity project. NOFA/Mass has been working internally on

 equity probably for about six or seven years, and they still

 hold dismantling racism training every two weeks for staff and

 board. And we're happy to report that that has made a world of

 difference within not only our board, but our staff, and the

 complexion of the people that come to our conferences. So

 we're really excited as we rollout TOPP to have this project

 involved with helping us to reach farmers of color.

 And just looking ahead at this next project, we're

 looking forward to continuing our outreach to bring in farmer

 mentees and mentors. Of critical importance, I think, is

 figuring out a way to crack the nut of getting in front of

 conventional farmers. In Massachusetts, we right now have 10

 farmers that are signed up for TOPP to transition. They are

 all growing organically now, so they are not converting from

 conventional chemical practices to organic. So how do we --

how do we get all of those farm bureau people to sign up,

 that's really the challenge is to get in front of those folks.

 So I will be looking forward to doing that. But we've got

 these 10 ready to go. And they are all eligible for

 certification in 2024, so that will be 90 acres next year for

 Massachusetts.

 All of our mentees and mentors will, will be able to

 take advantage of our soil health services that we offer, which

 is showing them their microbes under microscopes, actually 
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 doing soil test report analysis and amendment recommendations,

 as well as field soil health assessments. So we are pulling in

 those soil services for our, our mentees and our mentors as we

 work through TOPP. And we really do appreciate the

 opportunity.

 MS. KOBUS: Thank you, Teresa and Laura.

 (Applause.)

 MS. KOBUS: All right. We're going to welcome Chris

 Grigsby from MOFGA and Ted Tomao from NOFA/New York.

 MR. GRIGSBY: All right. Hello all, good afternoon.

 My name is Chris Grigsby. I'm the certification director at

 MOFGA, Maine Organic Farmers and Gardeners Association, MOFGA.

 We talked earlier about less acronyms, say it all out, so there

 we go.

 We're proud to be a regional partner with NOFA/Maine

 within the Northeast Mid-Atlantic TOPP region. We really

 appreciate USDA's unprecedented support and funding for

 transition to organic programming. A lot of us have been doing

 this for a really long time. And to have the support of USDA

 is very meaningful.

 Excuse me, I'm getting over a cold, so I apologize

 for the froggy throat. We're excited to be working with

 project partners, University of Maine Cooperative Extension and

 Maine Grain Alliance, who both submitted proposals through TOPP

 and received funding all the way through the finishing of the 
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 project in 2027. These robust proposals will support their

 outreach and education of grain and wild blueberry producers,

 and transition to organic opportunities in Maine and the

 region.

 In addition to wild blueberries, UMaine Extension is

 also focusing transition to organic outreach and training on

 dairy and livestock, mixed vegetables, and grain. There are

 roughly 430 wild blueberry land owners and 38,000 acres in

 Maine that are either conventionally managed or not certified

 organic. And due to current market opportunities, there is

 hope that through this programming and support, much of this

 land can be transitioned to organic, certified organic

 production.

 Maine Grain Alliance plans to build on their, their

 efforts to train, support, and create market opportunities for

 grain producers in Maine and New England, including their

 unique efforts to host organic, heritage, and land raised grain

 educational workshops as part of their Heritage Seed Center at

 the Kennebec Valley Community College. KVCC has a five-acre

 educational farm currently certified organic by MOFGA and there

 will be additional acres added at the college through his

 partnership. Both partners will be hiring staff to directly

 support TOPP efforts and project deliverables.

 So for 2024, looking ahead, MOFGA will be supporting

 these efforts through attendance at 18 partner events 
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 throughout 2024, technical assistance and training,

 demystifying organic certification, and creating relationships

 with conventional farmers and educating them about

 opportunities within USDA's larger organic transition

 initiative. We plan to add staffing capacity for direct

 outreach and recruitment of transitioning producer mentees to

 create a robust, statewide mentorship program.

 We will be building relationships and outreach in

 Aroostook County down east, in Western Maine, throughout six --

 through six of our own TOPP focused events. We also have as

 2024 goal of developing scope-specific training vides, which

 will be available for technical service providers, mentees,

 mentors, and conventional farmers, to provide NOP compliant

 guidance and details, as well as again demystifying the organic

 certification process. Thank you.

 (Applause)

 MR. TOMAO: Hello, everyone. I'm Teddy. I'm from

 Northeast Organic Farming Association of New York. I always

 just say NOFA, so I really have to think about it. I'm the

 Long Island transitions coordinator. I've been there for about

 a year and a half. I am also a new farmer on Long Island. So

 if we want to jump, it's okay, just jump to the next one, yeah.

 So if you can see on the map here, this is a map of

 all they New York State certified farms. We are second in the

 nation for number of certified farms. And we have plenty of 
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 area that can still be improved up there. We typically are

 growing for markets, such as locally produced organic in large

 cities, as well as throughout the state, and markets for

 regionally produced grains and pulse crops.

 New York is among the top four states in percentage

 of farmland that is organic, with 4 percent of our land

 organic. And we are about the same as California and Maine,

 and just behind Vermont. New York has a vibrant agricultural

 infrastructure. We have very diverse production of crops, so

 there's great opportunity to transition more ag acres into

 organic. There is a big demand for regionally produced grain

 such as wheat, rye, and pulse crops. We also have improving

 demand on locally produced organic in cities such as the New

 York metro area, which is one of the largest markets in the

 U.S., and throughout the state. And we have a continued

 regional demand that is growing for local and regional organic

 dairy.

 Up to the next one. So this is one of our events.

 So for the last year and half, I've been the Long Island

 educator. And when I started, we had different educators kind

 of throughout the state, but we didn't have a specific

 direction. So I was under a private grant that was working on

 a mentorship program, putting on events, and trying to help

 transition farms towards organic. And then a year later we

 hear about the TOPP grant, and it's the exact model that we 
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 kind of wanted to start pushing out throughout our entire

 state.

 So with TOPP, we're able to expand our reach with

 adding -- so right now we have two educators. We'll be able to

 add three more educators to cover five regions throughout New

 York State. And with this expanded, we'll be able to reach the

 sections of New York that we haven't been able to reach with

 just two, two educators.

 We have events throughout all region of the State,

 such as technical assistance and community building. We have

 our winter conference, which is in January, where we'll have

 four TOPP tracks. And then we're planning regional events

 throughout each different areas so that people that can't make

 it to Syracuse still have access to their local communities and

 farming community to learn about organic.

 We have also partnered with two different partners.

 We're with Glenwood (ph.), which have added TOPP to all of

 their craft events and have organic as a topic at all these

 farmer events, and on Long Island we partnered with East End

 Food Institute. Over the past year, East End Food Institute,

 NOFA/New York, and some other organizations were constantly

 putting on events, but not really collaboration all this much

 -- all that much. So TOPP gives us an opportunity to

 collaborate with our craft events. They put on 12. This year,

 six of them are going to be organic. And there will be TOPP 
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 information at every one, so it expands our reach quite well. 

 We have also done a bit of TA and workshop

 improvement. We have better organic dairy practices from

 calculating DMI, compliance with regulations, to pasture

 improvement. For vegetable growers, we have more information

 on IPM and tree nuts. We have improved our information on how

 to certify through recordkeeping and farm economics. And then

 we have added information about grains and beans as a

 standalone, and a means of diversification for existing dairy

 production.

 And the last thing that TOPP has really helped with

 New York is our mentorship program. We currently have 40 or 20

 mentees and 20 mentors signed up. Over the last three weeks,

 we have interviewed 30 of these 40, and we're really excited to

 get people matched up, talking to individual farmers about

 these opportunities. Really revitalized us. It's exciting to

 see where it can go. Thank you.

 (Applause.)

 MS. KOBUS: Thank you, Chris and Teddy. All right,

 we're going to welcome up Jeremy Pelletier from

 NOFA/Connecticut and Brent Wills from Virginia. Switch out

 those nametags.

 MR. PELLETIER: Thank you for having us here, today.

 Thank you -- I want to reiterate thank you to PCO for getting

 us all together and corralling all these different groups in 
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 the northeast to really come up with something exciting over

 the next few years. I would be remiss to not mention my

 colleague, who is there, Sherlene Rodriguez, who is actually

 running the TOPP program. But I'm lucky enough to come up here

 and speak to you all.

 So we're -- my name is Jeremy Pelletier. I'm the

 executive director of the Northeast Organic Farming

 Association, the Connecticut Chapter. And we're excited to be

 here in the northeast region under the leadership of PCO. In

 Connecticut, we have a fairly unique situation, although

 probably not that unique with some of the smaller states, in

 that we have a very tight-knit agricultural community. We work

 well with the Department of Agriculture. We work well with the

 extension office. And we work well with the Farm Bureau,

 because we don't have a ton of organic farms. I think 66 or

 67. And so it's critical that we work with all these

 organizations in our state to provide the correct amount of

 resources that are needed.

 So being a small state and a really tight-knit

 community, we're able to reach out to many organic farmers,

 transitioning farmers and farmers who have shown interest in

 becoming certified, many of whom we know on a first-name basis.

 So we are able to learn specific barriers to entry in becoming

 certified, what supports are needed in our state, and how the

 supports would work best with participating farms. 
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 Partnering with UConn Extension and the new 

 Connecticut Farmers Alliance, we seek to provide technical

 assistance, and a one-on-one consulting for both beginning and

 experienced farmers from, from plan to certification, for

 example, our getting started on organic farming conference in

 March, this March. We'll detail everything from land

 acquisition to organic application.

 So, yeah, our strength in Connecticut is with our

 partnerships this year and our ability to provide technical

 assistance. We'll be rolling out several different projects

 over the next year, not including our mentorship program.

 Currently, we have 10 mentors and 10 -- 9 mentees, so not bad

 for a really small state.

 UConn, for example, something I'm really excited

 about, will for the first time ever have an in-house organic

 farming specialist that will be available to all mentees and

 will extend their services to all farms looking to certify.

 This is something that they've shown interest to continue to

 fund, even after TOPP money runs out. So we're very excited

 about that. So this will include one-on-one technical

 assistance, farm visits, consulting, and general support to the

 farmers certifying.

 The New Connecticut Farmers Alliance will be hosting

 a farmer-to-farmer conference, in addition, that'll be in

 January, to build community among transitioning farmers, and 
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 build cohorts with some of these farmers who want to transition

 and work with each other in doing so. As I mentioned earlier,

 CT/NOFA will host the getting started in organic farming

 conference. And lastly, we have an organic certification

 expert on staff to walk farmers through the certification

 process once they've -- once they're ready to submit their

 paperwork.

 So our goal with this project and these projects is

 to provide support at all points during organic certification

 so that we can, one, ensure successful transition and, two,

 demystify the certification process, so that even more farms in

 Connecticut can confidently make the decision to transition.

 Thank you.

 (Applause.)

 MR. WILLS: Thanks, Jeremy. Thank you all for having

 us here. My name is Brent Wills. I'm from the Blue Ridge

 Mountains in Virginia. I really appreciate the opportunity to

 come up here. I don't know who ended up drawing the lines for

 the regions on these things, but I just -- I want to speak for

 my West Virginia counterpart, Spencer, and myself to say we're

 really glad that we got lumped in with the northeast. Nothing

 wrong with the southeast, but typically we work with a lot of

 southeast, so we're really excited to, to work with a lot of

 the institutional knowledge and experience in organic

 production in the northeast. So it's a little overwhelming and 
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 mind-blowing, to be honest with you, but we really appreciate

 the opportunity.

 I've been farming for about 20 years with my wife in

 the Blue Ridge Mountains of Virginia. We raise pasture,

 poultry, and pork. And did beef for a while, and now we work

 on poultry breeding. And I've been trying to network a lot

 more in my role as program director with the Virginia

 Association for Biological Farming. So not only do I get to

 keep my head down on my own farm, but I get to work with a lot

 of other farmers who are learning and interested in, in

 transitioning in regenerative and biological organic methods.

 So it's really kind of a cool thing to be able to do, touch on

 all those sides.

 As was mentioned earlier, I don't know if you know

 the numbers in Virginia, but we've got relatively few organic

 farms and processing operations in Virginia. So given that,

 there have always been gaps in the educational and outreach

 programs that support those farmers that are interested in

 transitioning to organic. And being able to partner with, with

 PCO and all these other wonderful organizations in the

 northeast is really going to allow us to provide that much

 needed technical assistance that's been missing for a long time

 in Virginia.

 We're also partnering with organizations such as the

 American Farmland Trust, Virginia State University, which I'll 
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 talk about in a few minutes, and the Virginia Soil Health

 Coalition. And we're able to extend our existing outreach and

 network potential beyond just the biological grower that we

 typically are familiar with, to increase the awareness of and

 adoption of certified organic in the Commonwealth of Virginia.

 As Devin mentioned earlier and kind of coupled with what Laura

 said, we have a lot of gaps. And we also have a pretty wide

 geographic and demographic changes across Virginia.

 So what we decided to do early on and this, this

 photograph here is one of the workshops that we did this year,

 we decided to focus on specifically what we call a train the

 trainer aspect of the program, where we try to corral NRCS soil

 and water conservation and extension folks who are a little bit

 interested in organic and understanding what the TOPP project

 is all about, we focus on them.

 And we get them on the farm and we talk about what

 those practices are, so that then they can go back and instead

 of when they get that call from the farmer that says I want to

 grow organic blueberries, instead of saying, yeah, sorry,

 you're on your own, there is a -- they can now say, hey,

 there's an organization that's doing some of this work, why

 don't you contact this guy. And so that's really been a

 helpful thing. Even just in the first six months of the

 project, I've seen a real difference in that. So it's really

 helping us get the word out more so than we've ever been able 
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 to do before.

 One of the most exciting things that we're really

 looking forward to now and I just saw the email come through

 this morning, we're having our 2024 winter conference in

 Roanoke, Virginia. We typically have a really cool winter

 conference, like a lot of organizations do. But this year we

 decided to have a focus on the TOPP project and we're able to

 provide a full day of pre-conference workshops specific to

 organic transition and learning more about organic production

 that will be free to all attendees. And that will really kick

 of our TOPP program for 2024.

 We're going to expand that by providing additional

 workshops regionally across the state. And really looking at

 the diversity across Virginia. If you look at Virginia, it's a

 really wide state and agriculture is very different in the west

 than it is to the east. So we really have to focus on those

 different demographics and, and farming practices.

 And as a part of the summit that we're doing this,

 this winter, we're partnering with Virginia State University

 and their small farm outreach program. One of the main reasons

 that we want to do that is because Virginia State University

 has a history as an HBCU. They're a solid partner in the

 effort to focus on equity and accessibility in organic

 production. So we're going to bring them in, because they help

 -- their small farm outreach program works with small, limited 
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 resource farmers of color. And that's really going to allow us

 to expand the diversity that we have and that we can reach in

 Virginia.

 So we really look forward to being a partner and a

 driver in this transition to certified organic in Virginia.

 And thank you for having us.

 (Applause)

 MS. KOBUS: Thank you, Jeremy and Brent. All right.

 Our next dazzling duo and last dazzling due, we have Spender

 Moss from West Virginia and Nicole Dehne from Vermont.

 MS. MOSS: Well, good afternoon. My name is Spencer

 Moss. I'm the executive director of the West Virginia Food and

 Farm Coalition, one of those states as Jenny pointed out that

 has had a little less organic action over the years. I think

 we -- I discovered during our first TOPP gathering, actually,

 in the Poconos, I think we have about 20 or 21 certified

 organic farms, which blew my mind. I really did not expect to

 even have that.

 So at the Food and Farm Coalition, we're a statewide

 organization. We're based in Charleston. And we work at the

 intersection of food -- or farm viability and food access. So

 what this work looks like for us is creating projects and

 programs for farmers and food entrepreneurs. We offer

 technical assistance. We do policy advocacy work. We

 coordinate programs and projects. We offer help even getting 
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 farmers to work together collectively, which is a huge feat for

 central Appalachian farmers. Where is -- where is my -- Brent,

 you know how hard it is to get farmers to work together

 sometimes.

 But I feel that to say we just actually filed the

 paperwork after working with this group of farmers for two

 years for the Mountain State Co-Hops Co-Op, and they'll come

 back up here again in a sec. So we do a lot of work across the

 state. And what we already knew about our farmers is that they

 already utilize organic practices and, and while they could not

 articulate this, they actually very much so believed in the

 tenets of organic and they very much believe in soil health.

 What we have -- what we have learned is that, you

 know, the feedback that we've received from our farmers is that

 they are not necessarily interested right now in certifying,

 even though they believe in organic, because of, of the

 expense, more importantly the paperwork, and having, having

 somebody on their farm that they don't necessarily want there.

 Again, this is Appalachian culture that we're contending with,

 especially when we don't have market prices or market for

 organics. So they are not getting a price point back that

 warrants the additional work on their part. So we are working

 to change that. Like Diana mentioned, those organic market

 grants are out, so I have my fingers crossed for some action

 there. 
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 With all of that said, we are using the TOPP program

 to really conduct outreach and education about the benefits of

 organic practices, ultimately utilizing those relationships to

 lead towards certification. Currently, we have three very

 enthusiastic mentees for -- in the State of West Virginia for

 the TOPP program. They are all part of that Mountain State

 Co-Hops Co-Op group that I previously mentioned.

 We are working with a community-based farm, New Roots

 Community Farm in Fayette County, West Virginia. They're going

 to work on transitioning to organic here shortly, as well. And

 lastly we're working with the West Virginia Maple Producers

 Association, because some of those folks are very much so

 interested in certifying, as well. So that's exciting.

 Looking forward in 2024 -- you can advance to our

 last slide there. No, no, no. We are excited to do more

 events, more outreach, grow our relationships, use our

 statewide staff to do this. Our biggest thing that we're going

 to introduce this year is a virtual coffee hour. So once a

 month we're going to have folks join us online. We're going to

 do a couple of minute update about what's going on with TOPP.

 We're going to do an education piece about some organic

 aspects, again utilizing that -- this opportunity for education

 to kind of reel people in. And then we'll have a 30-minute ask

 the -- ask the expert time in that coffee hour, again an

 opportunity to really grow relationships and sort of make all 
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 of this work a little less scary.

 So with that, I'll turn it over to Nicole.

 (Applause.)

 MS. DEHNE: Thanks, Spencer. My name is Nicole

 Dehne. I'm the certification director for Vermont Organic

 Farmers. And we are also, like my colleagues, excited about

 this funding and this opportunity. So, Diana, if you can

 advance to the next slide?

 I wanted to talk specifically about why TOPP is

 important in Vermont and why the timing is important right now.

 Unfortunately, what we're starting to see is a decline in the

 number of certified operations that we certify in the state.

 So in 2022, we saw a 2 percent drop in the total number of

 producers and we're expecting to see a similar decline this --

 by the end of this year.

 Part of the reason for this decline cause, some of it

 is the organic dairy crisis, some of it is just a number of our

 farms are retiring and they don't have any succession

 opportunities. So it does feel like there is an opportunity

 right now that TOPP might be able to address.

 We're also seeing the complexity of organic

 certification and recordkeeping requirements increase. And

 because of that, producers really need more support in

 navigating the certification process. And then in general we

 always find that producers need support in implementing organic 
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 practices. So that could look like improving pasture

 management or addressing biodiversity practices in sugarbushes,

 for example. So, again, just the opportunity right now for

 TOPP is important in Vermont.

 Thank you, not quite done. So I want to talk a

 little bit about how we're implementing TOPP in Vermont. So we

 are also -- the model of partnership, we're also sort of using

 in our state, like the rest of our colleagues, but we're

 partnering with the following organizations.

 So the Vermont Maple Sugar Makers Association, where

 it feels like an appropriate moment to say that we have close

 to 250 certified organic maple operations in Vermont. So it's

 definitely a growing sector and one that's becoming really

 important. We have more organic maple producers than any other

 type of farm in Vermont.

 We're also partnering with the Northern Grain Growers

 Cooperative. And Vermont Way Foods, which is a collaborative

 food hub project. So they are aggregating product in Vermont

 and then trying to open up markets in Boston and New York.

 And then we're also partnering with NOFA/Vermont's

 farmer services business planning team that does business

 planning work with different farmers.

 So with assistance from our partners, we're

 implementing a farmer-to-farmer mentorship program. And like

 our other partners, it's going to connect beginning farmers to 
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 our experienced, certified growers in the state. But we're

 also really excited about offering one-on-one technical

 assistance to these growers, hosting workshops and developing

 resources, all with this goal of making certification more

 accessible and understandable. Yes, now you may, thank you.

 (Applause.)

 MS. KOBUS: All right. Well, as we watch the fall

 season take hold here and the leaves change in the northeast,

 I'm so, so proud of what we've accomplished together in an

 astonishingly short period of time. I'm very grateful for the

 level of respect, contribution, and collaboration that this

 group brings. The organic farming and trade communities have

 created an entire industry through not always agreeing 100

 percent, but finding ways of working together for the good of

 all of us.

 We have watched this process through TOPP up close,

 not only in the region, but across the entire country. And I

 would also like to recognize our five other regionaliates (ph.)

 for their comradery, their spirit of collaboration, and

 demonstrated care for the people doing this work together.

 Oregon Till, CCOS, OCIA, AMOSA, and FARV, and Yosef, thank you

 so much.

 Our teams have collaborated on every set of guidance

 and tools that are governing this program to bring uniformity

 where appropriate nationwide. I'd also like to recognize 
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 Leilani and Katie, and our team at PCO for your support and

 standing up this program. It has been an absolutely team

 effort at PCO.

 So all of the successes that you heard today are

 barely after one year of getting the initial inquiries about

 TOPP. We all look forward to the evolution of this work we are

 doing together to better support all of our farmers and farming

 communities all over the nation. Of course, we have the

 stellar example of Dr. Jennifer Tucker and the team at NOP, who

 lead by example. They have been true partners in these

 cooperative agreements. And cooperative agreements, that means

 we celebrate our wins. We give and receive constructive

 feedback regularly. And we align all of our work on a massive

 scale. So we are -- we are all so grateful for USDA's

 investment in organic and indeed we are working to prove that

 organic is sustainable, it is regenerative, and it is climate

 smart, and the future of agriculture in the U.S. and around the

 world. So thank you so much.

 (Applause)

 MS. KOBUS: I think we have a mike floating around,

 if you have questions for the individuals.

 CHAIR POWELL-PALM: I'm going to briefly hand it back

 to Dr. Tucker. And then we'll have some questions for you.

 Questions from the Board actually before Dr. Tucker? Allison,

 please go ahead. 
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 BOARD MEMBER JOHNSON: Thank you so much to all of

 you. This is so inspiring and heartwarming. I'm just so

 impressed at how much has been done in a year and the

 trajectory that it puts this program on. I wanted to ask you

 about two things that are sort of peripheral to TOPP and I

 think really important to its success in the grand scheme. The

 first is in the organic transition initiative, we have three

 pillars, right? We have TOPP, we have the organic market

 grants, and then we have direct farmer assistance through NRCS.

 And I think one of the things that will be really

 important, especially in regions where we have fewer organic

 producers already, is providing financial assistance to help

 them especially through the bumpy transition time and building

 toward hopefully a place where they are really paid in the

 marketplace and recognized for the benefits they provide.

 Are you getting the support that you need to help

 producers connect with conservation programs and other funding

 sources that can pay them for the public benefits that they

 provide?

 MS. KOBUS: I will say we've been talking a lot the

 last couple of days here about wanting more involvement from

 NRCS, because that particular pillar of the three is one that

 could be deployed a lot more easily and in a lot more areas.

 So that's an active discussion and definitely something where

 we could use some more support. 
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 CHAIR POWELL-PALM: Dilip -- oh, sorry.

 BOARD MEMBER JOHNSON: Okay, thank you. Oh, can I

 ask a second?

 CHAIR POWELL-PALM: Of course. Go ahead.

 BOARD MEMBER JOHNSON: Farm Bureau came up a couple

 of times. And I'm wondering one -- oh, gosh, I'm losing track

 of everyone already. But there was one positive existing

 relationship and then areas where maybe it still could be

 built. And I'm wondering what opportunities you see to

 leverage the relationships that are being built through TOPP to

 help those organic producers who already participate in like

 nonorganic organizations or build momentum and support within

 those other organizations to reinforce the work that's being

 done through TOPP.

 MS. KOBUS: I hope this directly answers your

 question. I think that community building is, is a deliverable

 of ours. And we all in our different ways are working on that

 issue. Transition means we have to step into spaces where we

 aren't necessarily comfortable or traditionally comfortable or

 welcome. And so I think we're all working really hard to

 recognize the challenge, and give some grace and patience, and

 do that anyway, step into that space anyway. So definitely

 any, any Farm Bureaus, state level or local level, we would all

 love to be working with you. That's the conversation that,

 that we're all really eager to get moving and deepen those 
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 relationships.

 CHAIR POWELL-PALM: Dilip. And then Franklin.

 BOARD MEMBER NANDWANI: Thank you for your

 presentations. You all have wonderful speakers. I have two

 questions for Dr. Shivers and one for Laura Davis. I'd like to

 first, again, applaud Dr. Shivers' efforts that she is working

 for a black farmer. And we heard yesterday that 99 percent of

 the white farmers in the U.S. and 1 percent -- sorry, 98

 percent white and 1 percent are the black farmers here in the

 U.S. So it's definitely her efforts are applaud, you know.

 So the question is you mentioned that you are

 reaching out to U.S. Virgin Islands. And these islands are

 very unique. St. Croix, St. Thomas, St. John, on over. And I

 work with those organic farmers in those islands and I know how

 the challenges they are facing. So the question is that how

 you are reaching out to these farmers, and supporting, and

 working with them in those unique, you know, the islands, which

 are really need a lot of help and support especially in organic

 production.

 When I was there like 10 years ago and I know that I

 don't want to go into the detail because of the time, but they

 really are going through a lot of these challenges, so the one

 question.

 The second is about are you working with 1890 

 institutions or how do you see the role of 1890 institutions in 
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 your efforts, because 1890 institutions are -- they have kind

 of mandate to work and help African American committees.

 The question for Laura Davis I have, like you

 mentioned that you teach all farmers conventional and no matter

 what. So the question is that how you motivate among that

 farmer group that you go for organic? By telling them the

 benefits or how do you encourage them that the organic has some

 benefits in this one. Thank you.

 MS. KOBUS: It looks like Dr. Shivers may have

 stepped out for a moment, but we'll let Laura go, yeah.

 MS. DAVIS: I'll be happy to answer the question

 about how do we motivate conventional farmers. That's

 definitely a huge challenge for us. But one of the things that

 we've done is try to educate them on the little farmers

 underneath the soil that are being killed by chemicals. So we

 have active microscopes at our conferences where they can bring

 a soil sample to see what is alive in their soil, bacteria,

 fungi, nematodes. And they get really excited if it's moving

 and alive on the big screen TV.

 And so we start where they can really appreciate

 that. And we've had a couple of horticultural growers who have

 since reduced their reliance on chemicals and increased their

 biology. That's really what we're focusing on in our soil

 health group.

 So we're hoping that by looking at it that way and 
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 not sort of attacking them on their chemical use that they can

 learn and evolve. But it is definitely a challenge. But now

 that we're really excited about the UMass involvement, because

 the conventional farmers tend to really look to UMass Extension

 for a lot of -- well, we have a weekly newsletter they send out

 about what's going on in the field. So a lot of conventional

 readers appreciate that.

 BOARD MEMBER NANDWANI: Thank you. Very well said,

 Laura. Because life below ground is equally important. And

 there is more like the billions of bacteria and other micro

 organisms, they play a very vital role in organic farming, as

 we know. Thank you.

 CHAIR POWELL-PALM: Franklin, please go ahead.

 BOARD MEMBER QUARCOO: Yes. My question is related

 to tracking. I'm interested did you encounter any hurdles to

 transition that surprised you or were all the hurdles things

 you knew going in, especially different demographic groups,

 they may come up with something that wasn't something that was

 on your radar. Did you -- did you encounter any of this?

 MS. KOBUS: So one of the benefits and joys of

 working with a team of really strong leaders is that anything

 like that that comes up, I think we've -- we have tackled

 together or worked on a solution. I can't think of any, any

 particular challenges. Jenny mentioned that our region is very

 challenging sort of socially, right? 
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 I mean there are really big populations centers.

 There are huge rural tracks and demographically. So there's

 definitely been some candid and honest discussion about

 demographics and how we approach each other. How we talk about

 DEIJ work in Massachusetts needs to be different than the way

 we talk about it in, in sort of the southern tier of our

 region. So that's not to say one is better or worse, it's just

 different.

 And so, yeah, I think being -- staying curious,

 staying open -- thank you, Jesse Beckett-Parr (ph.), wherever

 you are -- and just being honest with each other. And this

 group in the northeast in particular, I have to say, has just

 been a joy to be a part of. They're -- they've just been

 wonderful support.

 BOARD MEMBER QUARCOO: Thank you.

 CHAIR POWELL-PALM: We're going to go Kim and then

 Amy.

 BOARD MEMBER HUSEMAN: Thank you. And thank you so

 much for the presentation today. This has been very

 delightful. My question might be somewhat similar to

 Allison's, to this last set of slides. We're talking about

 partnerships with current entities that can be focused in the

 conventional space. Can you expand a little bit on the

 Northeast Grain Growers Co-Op and the partnership, maybe some

 successes or, or some roadblocks there? I believe that was 
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 Vermont.

 MS. DEHNE: Yes, so we're partnered with the

 Northeast Grain Organic Growers Co-Operative -- not organic,

 Grain Growers Co-Operative. And the biggest hurdle that we're

 seeing there is market. So there is interest in growing grain,

 but there isn't the market. And some of that is being

 addressed by the other arm of, you know, those folks have also

 applied to funding from the other arm of market development

 funding. But that is a big hurdle. And we're not seeing as

 many mentees in that area, as we had hoped because of that,

 because of that roadblock.

 BOARD MEMBER HUSEMAN: Thank you.

 CHAIR POWELL-PALM: Amy, please go ahead.

 SECRETARY BRUCH: Okay, thank you. Wow, this was

 just very inspiring. It's lovely to hear how TOPP is being

 executed in the northeast and to hear all these stories is just

 powerful. I had a question for Dr. Kaia. I just saw you walk

 in. I love, love, love how you said farmers do not want direct

 payments. They don't want handouts. And you mentioned markets

 and the importance of developing competitive markets. Could

 you give me maybe kind of the top three areas that we could

 look at working on in the northeast? I know you crops are

 diverse. Your area is diverse. But what would be three big

 wins in market development in your region?

 DR. SHIVERS: So a lot of these farmers -- excuse me. 
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 A lot of these farmers farm, but they actually farm in food

 deserts. So they don’t even have a market locally. So they

 expressed -- a lot of them think in terms of what they do in a

 communal sense. They would like to have more markets locally

 in where they live. That's one of the things they expressed.

 They also need support in navigating the terms of

 getting it to market, the processing facilities. There is

 still a lot of racism in the processing facilities where either

 their food is getting destroyed or their food is getting

 stolen, whatever they take to the markets. So whatever type of

 management or protection, or even creating a processing

 facility where they feel safe, where they can get their food

 processed.

 A third thing that they need as well is in markets,

 is marketing. So some type of support so that people know that

 they are actually growers. We also get when I travel, they're

 like, oh, my gosh, I didn't even know that there were black

 farmers. Because a lot of the narrative is, is that black

 farmers have had such a hard time, people think that they don't

 exist. So they need marketing support for their food.

 And a fourth, I just -- I know you said three. I'm

 just going to add one more, is that okay?

 SECRETARY BRUCH: Perfect.

 DR. SHIVERS: We can go all day, every day talking

 about the market support. Black farmers need support in 
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 getting into local markets, like farmers markets, too. So a

 lot of the farmers markets that are probably the most popular

 or the most well-developed have a great system in place. But

 the system does not take into consideration farmers who have

 been so maligned that they don't have Venmo, and PayPal, and

 CashApp, and this and that.

 So also this push or drive to maybe provide some

 technical assistance or whatever is needed for them to be

 competitive at just farmers markets. So those are the four

 areas I would say that are most -- oh, a fifth, okay? And

 that's it, I promise you.

 SECRETARY BRUCH: No, I love it. Thank you.

 DR. SHIVERS: So there are row crop farmers, right?

 The average black farmer, we're talking about 10 acres, 15, 20

 acres. But there are row crop farmers. So in the commercial

 space, I always -- I challenge those big companies that are

 looking for bigger produce, I challenge them to kind of maybe

 reverse how they consider those who grow.

 And what I mean by that is, is that they have

 contracts built out for farms or collective farmers for like

 years at a time. These collectives are not opening up to black

 farmers. They say we already have our contract. We're not

 moving somebody out to bring somebody in or lessening whatever

 it is that this profits.

 So what else is needed is these conversations with 
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 these bigger companies that need tons of food, how are they

 creating something to allow these black farmers to compete and

 get into either the grower collectives or create a specific

 BIPOC grower collective, so they could put their grains, and so

 on and so forth in. And that's it, I promise you.

 SECRETARY BRUCH: Thank you kindly, Dr. Kaia.

 CHAIR POWELL-PALM: Dilip, did you have a question

 for Dr. Kaia as well?

 BOARD MEMBER NANDWANI: Yes. I think she's back now.

 Well, I was asking -- first, again, thank you for your

 presentation and reaching out to black farmer community. But

 two questions partly you answered to Amy's question. You

 mentioned about U.S. Virgin Islands and I was saying that these

 islands are very, you know, some are remote and uniquely

 located, St. Croix, and St. Thomas, and St. John. And I lived

 in those islands and worked with the organic community.

 Those farmers, they really need a lot of support and

 they are going through some challenges, I learned. And so my

 question was that how you are reaching out then to supporting

 them and whether it is affecting assistance or any of that

 form.

 The second question, I was asking about 1890

 institutions that they work -- they work for African American

 communities. How are you like working or collaborating with

 them, reaching out so that they can be very helpful in your 
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 goals to achieve. Thank you.

 DR. SHIVERS: Thank you so much for these questions.

 I'll start with -- I'll start with the first one and then I'll

 move on. So we also work with the southeast region, with

 Florida Organic Growers. That's where you have most of the

 HBCUs representation. So Florida Organic Growers has a growing

 relationship with HBCUs to bring them into the fold. We've

 reached out to HBCUs initially when we -- when I started the

 index.

 What happened, I started the index in the pandemic

 and so communication was, was far and few between. So what we

 did is we just started hitting the ground and just going

 straight to farmers. What we realized, a lot of the farmers

 that are the strongest or ones with the most ability have great

 relationships with the extension programs at HBCUs, right? So

 we admittedly are just developing our relationships with HBCUs,

 let me say that.

 And there is a -- HBCUs have, one of their major

 issues with agriculture, they are severely underfunded. And as

 well, from what we also understand, there is a lot of legal

 quagmire that exists in terms of how do we get the funding in

 order to go directly to the farmers to develop the programs

 with the farmers. So this is what, what we're hearing. So I

 wanted to, to say that. But there needs to be a lot more

 support at HBCUs in general, in the agricultural field. 
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 USVI and Puerto Rico, so we, we reached out -- a lot

 of our work is done digitally still with a hope to do a

 follow-up. USVI has been more represented -- more represented

 on the index because English, and we are mostly an

 English-based organization, even though we've actually brought

 in two interpreters who speak Spanish, one interpreter speaks

 French and also Creole, which we have had to incorporate

 because are working in Louisiana.

 So right now the, the communication is digitally.

 But what I can tell you about USVI and also meeting, there is

 one organic grower on USVI. But just like I said, a lot of

 these growers are practicing organic. There just needs to be

 more support on the infrastructure, especially in places that

 are remote or not in the mainland, because everything costs

 more. So you have more for compost, fertilizer, so on and so

 forth.

 And so that's the same thing Puerto Rico. As I

 talked to quite a few people representing Puerto Rico about

 maybe a month or two ago is, is that the process is so

 expensive in regards to what the farmers make and the cost of

 living on the islands. I hope that gives you some insight.

 BOARD MEMBER NANDWANI: Sure. Thank you.

 DR. SHIVERS: Thank you.

 CHAIR POWELL-PALM: Other questions from the Board?

 Gerry, please go ahead. 
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 BOARD MEMBER D'AMORE: I needed to get on just to

 tell you that your enthusiasm is infectious -- it's on. Oh,

 just not close enough? My mouth needs to be close to it? Come

 on, guys. The enthusiasm has been really infectious. I'd like

 to just note that yesterday, NOC had a grower panel, mostly

 local, and on that grower panel there was a Native American

 named Mr. Speer (ph.) that fielded pretty much the same

 question of what do you need. And the answer also wasn't money

 or a handout. And it was powerfully said. I can't contribute

 more exactly. What he said was we need a seat at the table.

 And if you can reach out to him somehow, perhaps that could be

 -- please, go ahead.

 DR. SHIVERS: One of the Black Farmers Index members

 is going to visit his farm tomorrow.

 BOARD MEMBER D'AMORE: Super.

 DR. SHIVERS: So we've already (inaudible/off

 microphone) six months ago in D.C., he had like a big cowboy

 hat on. I'm sorry, you all (inaudible/off microphone) are you

 a black farmer? He said, no, I'm a (inaudible/off microphone)

 So when I saw him yesterday, I said, look, one time was a

 coincidence, second time is divine. So we're overlapping

 there.

 CHAIR POWELL-PALM: Dr. Kaia, I have a question for

 you. You were mentioning that -- and I'm sorry, I won't make

 you yell again. 
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 DR. TUCKER: Yeah, can we get her a mike so the

 transcript will pick it up? Okay. Thank you.

 CHAIR POWELL-PALM: You were describing several of

 your, your colleagues who are pioneering black farmers. How do

 we get them in this room? How do we get them to Milwaukee?

 How do we get them on public comments? How do we get them

 elevating their voices?

 DR. SHIVERS: First, pay them. I, so, you know,

 self-admittance, I'm not a farmer. I jokingly say this, but

 it's true. I've killed aloe vera plants and cacti, right? But

 what I do recognize is that farmers are a business. So when

 you want them to come, you've got to pay them for their time.

 Because as we all know, all the farmers in the room, one of the

 members of Black Farmers Index is a farmer, they're always

 farming, or they're thinking about farming, or they're saving

 seeds, or they're doing that. So you must respect and pay them

 for their time.

 You would never as Elon Musk to come somewhere for --

 well, I mean now he's a billionaire, he can come for free. But

 do you understand the concept? So, one, you have to -- you

 have to pay them. Two, you have to totally give them a

 platform to, to express and speak how they see things without

 correcting them, right? And then there are cultural things

 that I think as well that you will learn along the way, the dos

 and the don'ts of what things. 
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 A lot of people tend to look at black farmers and

 farmers of color, native farmers, Latino farmers, Asian farmers

 as being in a deficit. They don't want to be looked at as

 being in a deficit. They want to be looked at as farmers, as

 thriving. So that's another thing. You don't come at them as

 you poor littler farmer, blah, blah, blah, whatever, okay.

 And then -- and let me tell you this, farmers from my

 experience operate very I would say through ancestor and

 lineage. Before I even got enrolled, I had to actually give my

 whole family tree and let them know that my family is from

 farming communities in the south, this and this and that, or

 they will not pick up the phone at all.

 So one of the things is that you could call Black

 Farmers Index. And if you need somebody, representation, we'll

 locate farmers who we think are appropriate and are not over

 used. So another thing is, is that you'll tend to see the same

 farmers at every single function and they don't represent the

 like expansive farming community that's all over the country.

 So you want to be able to diversify what that looks like so you

 can gauge how farmers are actually farming and what they call

 farming.

 Because when you're talking about 600, 700, 800

 acres, oh, my goodness. There is only on record two farms that

 are black-owned solely that own 1,000 acres or more. Two that

 are documented. One that is documented currently is fighting 
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 for their land in Colorado, if you heard about the Colorado

 ranchers that are facing a lot of vitriol from the local rural

 community.

 So I would say -- I would say that. But also and

 lastly, and in closing, in terms of how do you get farmers,

 plan events around growing seasons. If you're in the middle of

 a growing season, usually they are not going to come because

 they are planting or they are growing. So that means in the

 winter or low months. What we have learned for the index is,

 is that Louisiana specifically is to meet farmers at festivals.

 We didn't know that they grow around the sugarcane festival.

 They grow around the -- what the Latino community calls the Day

 of the Dead. It's actually called La Toussaint in Louisiana.

 And Mardi Gras. Right? So if you can meet them somewhere on

 Bourbon Street or whatever it is, they'll talk to you. But in

 between that, they are growing.

 CHAIR POWELL-PALM: Thank you so much for that. I

 had a question for Spencer. That was and sorry if I missed it,

 what is the Co-Hops Co-Ops? What do they grow?

 MS. MOSS: So that co-op was first created around

 growing hops. We actually got a research grant that we

 parlayed into helping eight farmers now get quarter-acre hops

 yards up and running on their property, which are really

 expensive to get going. And so initially around that. And

 then they've already -- we've just filed the paperwork and they 
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 have already expanded to allow value-added producers into their

 co-op.

 CHAIR POWELL-PALM: Thank you. I think I've got like

 11 more questions, so I'm going to spare you all and I'll find

 you directly. Yeah. But thank you so much again. With that,

 I'm going to hand it back to Dr. Tucker.

 DR. TUCKER: Let's all give a huge round of applause

 for all of the speakers.

 (Applause.)

 DR. TUCKER: Inspiring is the word I would have used,

 too. So somebody used that word and that was fabulous. And

 this is one of six regions and they are all doing this kind of

 work, touching people on the ground across the country. So

 what phenomenal stories, what phenomenal people. And thank you

 so much. Diana, very nice job. You did a beautiful job. I

 know a lot of folks said after the last meeting, well,

 southeast region did really well, it's going to be hard to top

 that. And it really does, every single region when you start

 talking about your work, it is just incredibly powerful. And

 watching the comradery really grow across that group has been

 really inspiring. So thank you. One last round of applause. 

 CHAIR POWELL-PALM: Bravo.

 (Applause.)

 CHAIR POWELL-PALM: All right. So checking in on our

 agenda. We are going to be moving into livestock, chaired by 
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 Kim Huseman. Do we want to take a break? Yeah, go ahead. Did

 you have something else, Nate? Sure, go ahead and then we'll

 take a break.

 BOARD MEMBER LEWIS: Just as we head into Board

 business, I wanted to acknowledge a former colleague and dear

 friend, Stephanie Jerger's public comment. She leads the

 justice, equity, diversity, and inclusion work at the Organic

 Trade Association, and reminded us that the language we use,

 the words we use can be a barrier to access of the work that we

 do. So she pointed out two words specifically, regulatory and

 compliance.

 And so I brought a bag of Halloween candy. So any

 time a board member says regulatory or compliance, they’ll get

 one. And at the end of the meeting, we'll count it up and see

 who wins.

 BOARD MEMBER HUSEMAN: We're not counting candy

 that's been eaten, though. Right?

 BOARD MEMBER LEWIS: You can -- you can have

 different strategies, that's fine, Kim.

 BOARD MEMBER HUSEMAN: It feels like the goal is not

 to say that. And so I feel like this is like the opposite.

 BOARD MEMBER LEWIS: Well, I think it's mostly just

 to hold ourselves accountable, and sort of realize and

 acknowledge how much we use these types of words. Oh, this is

 organic Halloween candy, actually. And you don't have to eat 
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 it. You can do whatever you want with it.

 CHAIR POWELL-PALM: All right. Let's plan to break

 for 15 minutes, yeah. So we'll come back at half-past.

 (Off the record from 3:16 p.m. to 3:31 p.m.)

 CHAIR POWELL-PALM: All right, we are just coming up.

 I think we're a little past time, so I'm going to convince Amy

 Bruch to retake her chair. And so our first subcommittee that

 we're going to be reviewing today or for this week is

 livestock, chaired by Kim Huseman. And I'm going to hand it

 over to Kim.

 BOARD MEMBER HUSEMAN: Thank you, Nate. Well,

 livestock, I think this is the first time since I've been on

 the Board especially as the chair that we've gone first as a

 subcommittee. So thank you all for staying this time for

 livestock. Livestock this season has been very specifically

 centered around the sunsets. But we do hear the community.

 There are -- there are some topics that are very pressing in

 the livestock industry and, and feel that those are at a point

 where we'll, we'll start to and continue to evolve, and add

 more to the livestock subset. But that being said, we're

 hitting it really hard in a lot of subcommittees right now. So

 for this particular fall session, livestock is, is relatively

 light.

 So of the, the nine sunsets that we have to review

 this afternoon, we will go ahead and get started. The first 
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 one that is set for review, okay, so the first -- the first

 sunset for review today -- do you want me to read them both in

 at the same time?

 CHAIR POWELL-PALM: Sure, that would be good. Thank

 you.

 BOARD MEMBER HUSEMAN: Okay. Will be the alcohols.

 And we have both ethanol and isopropanol listed at 205.603(a).

 Ethanol as a disinfectant and sanitizer only, prohibited as a

 feed additive. And isopropanol listed at 205.603(a) as a

 disinfectant only. Ethanol was voted out of subcommittee,

 motion to remove the alcohols from the National List was made

 by Nate Powell-Palm and seconded by Brian Caldwell.

 Isopropanol was motioned by Nate Powell-Palm and seconded by

 Kim Huseman. And both of these belong to Nate Powell-Palm.

 CHAIR POWELL-PALM: All right, thank you, Kim. And I

 just want to correct a little bit that I think Kim is

 underselling how great a subcommittee livestock is and how well

 she runs it. And so our agenda is light and our work is

 effective because of her leadership. So thank you, Kim.

 Ethanol and isopropanol, I reference back to the last

 panel we had which was I think November of 2020, where we

 talked about sanitizers. And I'm really excited to restart the

 panels. But I think back to that panel often where several of

 the experts talked about how to have a really effective

 sanitizer, sanitation regime you need lots of options. You 
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 need a lot of effective options that you can rotate through so

 that you don't become too reliant on any one.

 And I think we heard from the community that

 isopropanol and ethanol are two very important disinfectants,

 good sanitizer options to keep in the barn, in production, as

 we look to giving livestock producers all the tools that we can

 to make sure that they maintain a healthy and hygienic

 operation. Any questions from the Board on isopropanol or

 ethanol? Amy.

 SECRETARY BRUCH: Not a question, but just a comment

 representing some of the farmer stakeholders' views on these

 substances, both in livestock and also in crops. Just the

 accessibility to get access to ethanol and isopropanol is

 really important when you need to disinfect an area. These are

 locally available, so ready to be used.

 CHAIR POWELL-PALM: Amen, thank you. Nate?

 BOARD MEMBER LEWIS: Just in the spirit of commercial

 availability and organic options, do you have any information

 around availability of organic, certified organic ethanol as a

 -- was that part of the discussion?

 CHAIR POWELL-PALM: That was not part of the

 discussion, but I appreciate the question. Any other

 questions? All right. I'll send it back to you, Kim.

 Actually, never mind, I'm keeping this one. So moving from me

 as a committee member to me as Chair. So we're going to start 
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 with the vote. We have a motion to delist ethanol and

 isopropanol. So vote -- a reminder that because of several

 absences, we have 13 board members voting this round, so 9 is

 going to be the super majority.

 A no vote is going to be to keep it on the list. And

 a yes vote is to kick it off the list. So if we could start

 with Allison and we'll go around. I'll call your name. Please

 say your vote into the mike. Gerry, are you with me?

 BOARD MEMBER HUSEMAN: No, that was me. There is no

 -- the motion was made in subcommittee. So we're just -- we

 discussed and then now we're at the voting. The motion was

 already made.

 CHAIR POWELL-PALM: Brian?

 BOARD MEMBER CALDWELL: Just wondering if we are

 voting both of these at the same time.

 CHAIR POWELL-PALM: Thank you for that clarification.

 BOARD MEMBER CALDWELL: Or whether they need to be

 separated. We're going to start with ethanol and then we're

 going to go isopropanol. All right, ready for the vote.

 Please go ahead. Allison, on ethanol.

 BOARD MEMBER JOHNSON: No.

 CHAIR POWELL-PALM: Brian?

 BOARD MEMBER CALDWELL: No.

 CHAIR POWELL-PALM: Nate?

 BOARD MEMBER LEWIS: No. 
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 CHAIR POWELL-PALM: Dilip?

 BOARD MEMBER NANDWANI: No.

 BOARD MEMBER D'AMORE: No.

 CHAIR POWELL-PALM: Wait for me to call you first,

 please. Kyla?

 BOARD MEMBER SMITH: No.

 CHAIR POWELL-PALM: Amy?

 SECRETARY BRUCH: No.

 CHAIR POWELL-PALM: Kim?

 BOARD MEMBER HUSEMAN: No.

 CHAIR POWELL-PALM: Franklin?

 BOARD MEMBER QUARCOO: No.

 CHAIR POWELL-PALM: Wood?

 BOARD MEMBER TURNER: No.

 CHAIR POWELL-PALM: Logan?

 BOARD MEMBER PETREY: No.

 CHAIR POWELL-PALM: Carolyn?

 BOARD MEMBER DIMITRI: No.

 CHAIR POWELL-PALM: And the Chair votes no.

 BOARD MEMBER HUSEMAN: Okay. We have zero yes, 13

 no, zero abstention, zero recusals, 2 absences, so the motion

 fails.

 CHAIR POWELL-PALM: All right. We'll move to the

 vote on isopropanol. Starting with Brian this time.

 BOARD MEMBER CALDWELL: No. 
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 CHAIR POWELL-PALM: Nate?

 BOARD MEMBER LEWIS: No.

 CHAIR POWELL-PALM: Dilip?

 BOARD MEMBER NANDWANI: No.

 CHAIR POWELL-PALM: Gerry?

 BOARD MEMBER D'AMORE: No.

 CHAIR POWELL-PALM: Kyla?

 BOARD MEMBER SMITH: No.

 CHAIR POWELL-PALM: Amy?

 SECRETARY BRUCH: No.

 CHAIR POWELL-PALM: Kim?

 BOARD MEMBER HUSEMAN: No.

 CHAIR POWELL-PALM: Franklin?

 BOARD MEMBER QUARCOO: No.

 CHAIR POWELL-PALM: Wood?

 BOARD MEMBER TURNER: No.

 CHAIR POWELL-PALM: Logan?

 BOARD MEMBER PETREY: No.

 CHAIR POWELL-PALM: Carolyn?

 BOARD MEMBER DIMITRI: No.

 CHAIR POWELL-PALM: And the Chair votes no.

 BOARD MEMBER HUSEMAN: Also Allison.

 CHAIR POWELL-PALM: Oh, sorry, sorry. Thank you.

 Got me.

 BOARD MEMBER JOHNSON: No. 
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 CHAIR POWELL-PALM: Thank you. And the Chair

 votes no.

 BOARD MEMBER HUSEMAN: Okay. We have zero yes, 13

 no, zero abstentions, recusals zero, 2 absences. So the motion

 fails.

 CHAIR POWELL-PALM: All right, back to you, Kim.

 BOARD MEMBER HUSEMAN: Thank you, Nate. We'll have

 this process down before we start CACS in the morning.

 SECRETARY BRUCH: Thank you.

 BOARD MEMBER HUSEMAN: Thank you. I've learned the

 back button, there we go, all right. Next is aspirin listed at

 205.603(a), aspiring approved for health care use to reduce

 inflammation. I think we'll hear a lot this afternoon about

 the tools in the toolbox for proper livestock production and

 management. And when I reviewed the limited comments from this

 fall, they echoed the sentiment from the spring that aspirin is

 a relatively straightforward way to provide pain relief to

 animals. That it is easily accessible. It's available and

 it's well understood.

 There was -- there was not a dissent or a negative

 approach to keeping aspirin on the National List. And I will

 go ahead and turn it back over to you, Nate, for questions.

 CHAIR POWELL-PALM: Okay, yes. Any questions on

 aspirin from the Board? Hearing none, we'll go to a vote. So

 again a motion -- or, rather, a delisting is going to be a 
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 no -- or a yes vote. Keeping it on is going to be a no vote.

 And we're going to start with Nate.

 BOARD MEMBER LEWIS: No.

 CHAIR POWELL-PALM: Dilip?

 BOARD MEMBER NANDWANI: No.

 BOARD MEMBER D'AMORE: No.

 CHAIR POWELL-PALM: Gerry is a no. Kyla?

 BOARD MEMBER SMITH: No.

 CHAIR POWELL-PALM: Amy?

 SECRETARY BRUCH: No.

 CHAIR POWELL-PALM: Kim?

 BOARD MEMBER HUSEMAN: No.

 CHAIR POWELL-PALM: Franklin?

 BOARD MEMBER QUARCOO: No.

 CHAIR POWELL-PALM: Wood?

 BOARD MEMBER TURNER: No.

 CHAIR POWELL-PALM: Logan?

 BOARD MEMBER PETREY: No.

 CHAIR POWELL-PALM: Carolyn?

 BOARD MEMBER DIMITRI: No.

 CHAIR POWELL-PALM: Allison?

 BOARD MEMBER JOHNSON: No.

 CHAIR POWELL-PALM: Brian?

 BOARD MEMBER CALDWELL: No.

 CHAIR POWELL-PALM: And the Chair votes no. 
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 SECRETARY BRUCH: Okay. We have zero yes, 13 no,

 zero abstentions, zero recusals, and 2 absences. The motion

 fails.

 CHAIR POWELL-PALM: All right, back to you, Kim.

 BOARD MEMBER HUSEMAN: Thank you, Nate. Next we have

 biologics-vaccines, listed at 205.603(a), vaccines. The motion

 was made in subcommittee by Brian Caldwell and seconded by Amy

 Bruch. And this material belongs to Brian.

 BOARD MEMBER CALDWELL: Well, we love these slam dunk

 kinds of sunset reviews, but biologics-vaccines is not one of

 them. So I'm going to read a bunch of stuff that's going to

 hopefully surround this issue and try to -- try to bring up the

 important points.

 So vaccines are critical for livestock health and for

 the success of livestock farms. In general, they are quite

 effective. The issue is complicated by the presence of GMO

 vaccines or excluded method, vaccines made with excluded

 methods. They are listed at two places in OFPA. The first is

 at 205.603(a)(4) and that is -- that allows for unqualified use

 of vaccines. The second is at 205.105(e) and that says that

 vaccines produced with otherwise excluded methods, that would

 be GMOs, are allowed if they are approved according to the

 criteria for the inclusion of synthetic substances on the

 National List.

 Okay. And there was -- there has been over the years 
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 differing interpretations of these two listings. In 2019, the

 NOSB made a formal recommendation that the wording at

 205.105(e) be changed to allow GMO vaccines only when an

 equivalent non-GMO vaccine is not commercially available. This

 recommendation has not been adopted yet. And that being the

 case, it was really difficult to, to sort through all this.

 But the livestock subcommittee approved the following

 for this review. And that is and it's written in the -- in the

 sunset review at the end. It says in spite of important

 concerns over nonactive ingredients and a GMO status of many

 livestock vaccines, the livestock subcommittee feels that the

 need for effective vaccines is critical for livestock

 production. Since the 2019s have not been implemented at this

 time, the livestock subcommittee has adopted the following

 interpretation.

 And that is that this sunset review encompasses the

 entire class of synthetic livestock vaccines including those

 made with excluded methods. The livestock subcommittee

 encourages NOP to adopt the 2019 NOSB recommendation. In the

 meantime, our interpretation is that listing fulfills the

 requirement at 206.105(e) for all livestock vaccines. And with

 that, the livestock subcommittee finds biological --

 biologics-vaccines compliant with the Organic Foods Production

 Act and is not proposing removal.

 So having gone through that, I'd be glad to try to 
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 answer any questions.

 CHAIR POWELL-PALM: Please go ahead, Wood.

 BOARD MEMBER TURNER: Thanks, Brian. That's helpful.

 Can you just practically outline what that -- what that last

 statement from the committee means? Like could you put it into

 technical terms.

 BOARD MEMBER CALDWELL: Yeah. So there are two

 listings for, for vaccines and one of them is, is a blanket

 approval in OFPA. And the second one says, well, GMO vaccines

 can be used, but they have to go through the, the sunset review

 criteria. And basically what, what this decision says is that

 since that 2019 recommendation has not been implemented, that

 this review will cover all, all vaccines, all synthetic

 vaccines, GMO or not, and say that they can be used. And it's

 just -- it's really a matter of, of practicality and, and the

 importance of vaccines to livestock producers.

 BOARD MEMBER TURNER: In other words, when there is

 no -- when there is not an alternative?

 BOARD MEMBER CALDWELL: No. This approval is, is

 blanket approval for all vaccines. There is no requirement --

what we're doing here for commercial availability, that's not

 in there, because that, that part which is in the 2019

 recommendation has not been adopted yet. So rather than the --

the alternatives basically include having to review every,

 every GMO, every synthetic vaccine basically, GMO or no, or 
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 having to just review every GMO vaccine, or basically saying

 that, yes, they are all, you know, blanket approval, sort of

 what we do with electrolytes and a bunch of the other materials

 that we -- that we approve as a group. And this is just

 putting all synthetic vaccines, GMO and non-GMO in that -- in a

 group and then approving them. So in a lot of ways, not, not

 a great solution, but it's really kind of the only thing that

 we could see going forward.

 CHAIR POWELL-PALM: Allison?

 BOARD MEMBER JOHNSON: Thank you for the explanation

 and all your work on this. This is a messy one, particularly

 when we have an outstanding recommendation. My livestock

 knowledge is like this big compared to many of you, so I'm

 going to see if my perception is correct. Brian, you or anyone

 else please weigh in.

 My understanding is if we were to limit the use of

 vaccines, that increases the likelihood of the need to treat

 with antibiotics and pull an animal out of organic production.

 Is that accurate that vaccines are one of our fundamental tools

 for ensuring that we don't need antibiotics in organic?

 BOARD MEMBER CALDWELL: I think that some diseases

 that vaccines treat for can be -- can be treated with

 antibiotics. But in a lot of cases, it would just be loss of

 the animals or severe disease.

 CHAIR POWELL-PALM: Nate? 
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 BOARD MEMBER LEWIS: And simply ability to 

 participate in a commercial livestock market. Many states have

 vaccine requirements to ship animals.

 CHAIR POWELL-PALM: Other questions for Brian before

 I get started?

 BOARD MEMBER D'AMORE: Yes, please. A quick question

 is if we find -- does this conform to everything else we do and

 the next time we could really challenge this decision amongst

 ourselves is in five years?

 CHAIR POWELL-PALM: Yes.

 BOARD MEMBER D'AMORE: Okay. Thank you very much.

 Sorry?

 CHAIR POWELL-PALM: Go ahead, Wood.

 BOARD MEMBER TURNER: Sorry. I have so many

 questions about this, because I'm not as close to this

 committee. So why is it on hold?

 BOARD MEMBER CALDWELL: Oh, you mean why has the 2019

 recommendation not been adopted?

 BOARD MEMBER TURNER: I'm curious, if you know, yeah.

 BOARD MEMBER CALDWELL: That is a question for Jenny.

 But it's -- anyway, that's as much as I know, I guess on that.

 CHAIR POWELL-PALM: Do you want to take that, Jenny?

 DR. TUCKER: So this one is -- it is on the list. We

 do have it marked on the indices on hold. But it's not closed.

 It's on hold because there were a number of priorities that we 
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 needed to move/add with. Again, a lot of our regulatory

 priorities have been guided by the listening session we had in

 2022. This was not actually rated all that horribly high on

 that -- in that regulatory priorities exercise. We really

 needed to get the trifecta, the triple crown done.

 And so I think as we're moving ahead, we're going to

 continually re-evaluate regulatory priorities. This is one I

 get questions about a fair amount, so it is by no means it has

 not been closed. It's not off the table. It's just we have to

 work our way through the priorities.

 CHAIR POWELL-PALM: Dilip?

 BOARD MEMBER NANDWANI: So, Brian, thank you. Just

 to follow-up with what Wood said and I want to 100 percent

 understand that what we are voting today, these vaccines does

 include excluded methods and without excluded methods, so GE.

 Is that right?

 BOARD MEMBER CALDWELL: Yeah, yeah. And maybe it

 would help if, if I explain that, that the second listing on --

 in OFPA specifically says that, that under excluded methods,

 that they cannot be used in organic production except for

 vaccines that again go through the sunset process. So that is

 an explicit exception with OFPA for vaccines. And I think it's

 because the, the writers realized that this was such a thorny

 issue. And for some diseases, non-GMO vaccines are not

 available. And so it's kind of like we're between a rock and a 
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 hard place.

 BOARD MEMBER NANDWANI: Yeah, that helps. Thanks,

 Brian.

 CHAIR POWELL-PALM: Other questions for Brian? Wood?

 BOARD MEMBER TURNER: I just want to say, Nate, you

 owe Jenny a candy.

 BOARD MEMBER LEWIS: Thanks, Wood, for keeping us all

 accountable.

 CHAIR POWELL-PALM: I really appreciate your work on

 this, Brian. This has been a thorny one. And it's a very

 interesting place we find ourselves, because the power of these

 tools is so significant for keeping us going as a commercial

 livestock concern. And I think that the folks we've heard from

 who are representing the, the most, you know, the most

 producers, the most voices, and have the biggest stake both

 commercially, but as representatives of those farmers, I would

 call out crop cooperative, as being very clear that this is a

 fabulous bright spot in organics that we said all vaccines.

 And all vaccines are allowed. And we know that there is not

 probably ever going to be a vaccine developed specifically for

 organic production, just because we're too small. And the

 investment, the public and private dollars it would take to

 create vaccines are so significant that they are going to be

 marketing it to everybody.

 And so when we think about how do we both make sure 
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 that we never put our livestock producers in a position where

 they are hesitating to use best preventative practices possible

 and never putting certifiers in a position where they're really

 outside their competency, quite frankly, that most certifiers

 are not going to have veterinarians on staff. They are not

 going to be able to truly engage, even if it was possible to

 find non-GMO alternatives of these vaccines. It's we have a

 lot of things we're asking certifiers to do, so it seems really

 reasonable to not have this be one of them.

 Understanding the concerns in the community, as I

 think you have done so brilliantly, Brian, and making sure that

 we keep those concerns at the forefront, this seems like a

 really -- a fine compromise to acknowledge the 2019

 recommendation, but also a really great win for the livestock

 sector and our ability to make sure that we don't become sort

 of a disease Mary, as it were. That we don't become the, the

 outbreak that defines organic.

 And so as we go forward with this vote, I again want

 to thank Brian for all the work you put into this. And ask if

 there's any other questions about biologics/vaccines? All

 right. So again a no vote will keep all vaccines on the list.

 And we're going to start with Dilip.

 BOARD MEMBER NANDWANI: No.

 CHAIR POWELL-PALM: Gerry?

 BOARD MEMBER D'AMORE: No. 
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 CHAIR POWELL-PALM: Kyla?

 BOARD MEMBER SMITH: No.

 CHAIR POWELL-PALM: Amy?

 SECRETARY BRUCH: No.

 CHAIR POWELL-PALM: Kim?

 BOARD MEMBER HUSEMAN: No.

 CHAIR POWELL-PALM: Franklin?

 BOARD MEMBER QUARCOO: No.

 CHAIR POWELL-PALM: Wood?

 BOARD MEMBER TURNER: No.

 CHAIR POWELL-PALM: Logan?

 BOARD MEMBER PETREY: No.

 CHAIR POWELL-PALM: Carolyn?

 BOARD MEMBER DIMITRI: No.

 CHAIR POWELL-PALM: Allison?

 BOARD MEMBER JOHNSON: No.

 CHAIR POWELL-PALM: Brian?

 BOARD MEMBER CALDWELL: No.

 CHAIR POWELL-PALM: Nate?

 BOARD MEMBER LEWIS: No.

 CHAIR POWELL-PALM: And the Chair votes no. I would

 say that deserves a round of applause.

 (Applause.)

 CHAIR POWELL-PALM: I think that is a lift that Brian

 gave so much to and I am so grateful for the time. So thank you 
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 again, Brian.

 SECRETARY BRUCH: Okay. The motion fails. We had

 zero yes, 13 no, zero abstentions, zero recusals, and 2

 absents.

 CHAIR POWELL-PALM: And with that, back to you, Kim.

 BOARD MEMBER HUSEMAN: Next on the list for livestock

 is electrolytes, listed at 205.603(a), electrolytes without

 antibiotics. The motion to remove electrolytes was made by

 Brian Caldwell, seconded by Kim Huseman. And this material --

 Brian, you got the hard hitters. I really appreciate your work

 on the livestock subcommittee. So I'll let you take it away

 with electrolytes.

 BOARD MEMBER CALDWELL: Great. Yeah, thanks, Kim.

 This one should be a lot easier, I believe. Electrolytes are a

 class of relative simple and benign substances that are used to

 treat electrolytes imbalances in livestock that can result in

 severe pain and death to the animals. They are considered

 essential by just I think all the commenters that mentioned

 them in the -- in the written comments. The four that

 specifically noted were all in favor of relisting. And I think

 that's, that's it. I'm ready for questions.

 CHAIR POWELL-PALM: Questions for Brian? You've done

 too good a job. Nothing. All right, with that we're going to

 go to the vote. Thank you again, Brian. And we're going to

 start with Gerry. 
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 BOARD MEMBER D'AMORE: No.

 CHAIR POWELL-PALM: Kyla?

 BOARD MEMBER SMITH: No.

 CHAIR POWELL-PALM: Amy?

 SECRETARY BRUCH: No.

 CHAIR POWELL-PALM: Kim?

 BOARD MEMBER HUSEMAN: No.

 CHAIR POWELL-PALM: Franklin?

 BOARD MEMBER QUARCOO: No.

 CHAIR POWELL-PALM: Wood?

 BOARD MEMBER TURNER: No.

 CHAIR POWELL-PALM: Logan?

 BOARD MEMBER PETREY: No.

 CHAIR POWELL-PALM: Carolyn?

 BOARD MEMBER DIMITRI: No.

 CHAIR POWELL-PALM: Allison?

 BOARD MEMBER JOHNSON: No.

 CHAIR POWELL-PALM: Brian?

 BOARD MEMBER CALDWELL: No.

 CHAIR POWELL-PALM: Nate?

 BOARD MEMBER LEWIS: No.

 CHAIR POWELL-PALM: Dilip?

 BOARD MEMBER NANDWANI: No.

 CHAIR POWELL-PALM: And the Chair votes no.

 SECRETARY BRUCH: Zero yes, 13 no, zero abstentions, 
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 zero recusals, 2 absent. Motion fails.

 CHAIR POWELL-PALM: Thank you. Back to you, Kim.

 BOARD MEMBER HUSEMAN: Okay. Next is glycerin listed

 at 205.603(a), allowed as a livestock teat dip, must be

 produced through the hydrolysis of fats or oils. The motion to

 remove glycerin from the National List was made by Kim Huseman

 and was seconded by Amy Bruch.

 And that material belongs to me. I think it's

 already -- Nate, you should have said tools in the toolbox, not

 regulatory or compliance. You probably would have handed out

 more candy in the livestock subcommittee. That being said,

 having glycerin as an alternative and as a teat dip has been

 spoken through the farmer voice of necessity, and a nod to the

 acceptance of having multiple options.

 Through the spring comments, most were very

 supportive of ensuring that glycerin remains on the National

 List. There was a nod or a request to validate the methodology

 in which the glycerin was being produced or manufactured as

 very specific that it is not in a synthetic manner. We did ask

 the question and we did receive feedback from certifying bodies

 of, of, you know, their way of being able to validate that the

 manufacturing process was by hydrolysis. So we did get that

 feedback.

 I wouldn't say that there was much difference in the

 fall comments, not a significant amount of comments, but just 
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 that reiteration of validation of the manufacturer process

 because of the -- because of the use of production through

 hydrolysis of fats and oils.

 CHAIR POWELL-PALM: Questions for Kim? I don't have

 a question for you, Kim. But I do have a question for you,

 Nate Lewis. Instead of regulatory and compliance, what words

 should we use to make the language more accessible?

 DR. TUCKER: Otherwise, Jenny is going to be on this

 massive sugar rush for the rest of the afternoon.

 BOARD MEMBER LEWIS: I don't think we need to change

 our words.

 DR. TUCKER: Give me a lifeline.

 BOARD MEMBER LEWIS: I don't think they are bad words

 necessarily. I think it's mostly just to illustrate how we

 talk.

 DR. TUCKER: I try really hard with the acronyms.

 But regulatory and compliance? I'm actually I'm dead serious

 on that. When people kind of -- when we hear, oh, some words

 are hard or they're hard to hear, anytime somebody can say try

 this instead it would really, really help. So do we have some?

 CHAIR POWELL-PALM: So as a callout to the crowd,

 catch us at next break with recommendation for what we should

 be replacing those with.

 DR. TUCKER: These are really good but --

 UNIDENTIFIED SPEAKER: Rules and following the rules. 
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 DR. TUCKER: Rules and following the rules. Oh, I

 can do that.

 CHAIR POWELL-PALM: All right, game on. We're going

 to go to the vote, if we have no questions or comments for Kim.

 And we're going to start with Amy.

 SECRETARY BRUCH: No.

 CHAIR POWELL-PALM: Kim?

 BOARD MEMBER HUSEMAN: No.

 CHAIR POWELL-PALM: Franklin?

 BOARD MEMBER QUARCOO: No.

 CHAIR POWELL-PALM: Wood?

 BOARD MEMBER TURNER: No.

 CHAIR POWELL-PALM: Logan?

 BOARD MEMBER PETREY: No.

 CHAIR POWELL-PALM: Carolyn?

 BOARD MEMBER DIMITRI: No.

 CHAIR POWELL-PALM: Allison?

 BOARD MEMBER JOHNSON: No.

 CHAIR POWELL-PALM: Brian?

 BOARD MEMBER CALDWELL: No.

 CHAIR POWELL-PALM: Nate?

 BOARD MEMBER LEWIS: No.

 CHAIR POWELL-PALM: Dilip?

 BOARD MEMBER NANDWANI: No.

 CHAIR POWELL-PALM: Gerry? 
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 BOARD MEMBER CALDWELL: No.

 CHAIR POWELL-PALM: Kyla?

 BOARD MEMBER SMITH: No.

 CHAIR POWELL-PALM: And the Chair votes no.

 SECRETARY BRUCH: Zero yes, 13 no, zero abstentions,

 zero recusals, 2 absent. Motion fails.

 CHAIR POWELL-PALM: Thank you. Back to Kim.

 BOARD MEMBER HUSEMAN: All right. Next on sunset

 review for livestock is phosphoric acid, listed at 205.603(a),

 phosphoric acid allowed as an equipment cleaner provided that

 no direct contact with organically-managed livestock or land

 occurs. The motion to remove phosphoric acid from the National

 List was made by Amy Bruch and was seconded by Nate Lewis. And

 this material belongs to Amy.

 SECRETARY BRUCH: Thank you, Kim. Okay. Just to

 recap. After the spring meeting, the Board reviewed concerns

 from stakeholders regarding the need for clarity on several

 fronts. One was rinse or no rinse. Another one was what do we

 do with the downstream equipment. There was clarity needed

 surrounding the bulk tank that was downstream in the milking

 system equipment. Also, the third, third point for

 clarification and this is a little bit out of our jurisdiction,

 it's actual material review just to determine -- it's a

 function of inerts and if there are multiple products within

 the phosphoric sanitizer that includes inerts, should you have 
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 a rinse or should you just proceed with no rinse after those

 products are being used.

 So those three fronts demanded clarity from our

 stakeholders. We did catch word in the spring that there was

 an active ACA working group looking at these to try to provide

 clarity for the community. And I'm actually going to turn it

 over to my tablemate who sits in the certifier seat for just a

 brief update on ACA working group.

 BOARD MEMBER SMITH: Okay. So there is a standing

 materials working group within the ACA. And so this is where

 that topic was discussed. So I checked in with that group and

 just asked about certifier consistency of interpretation and

 implementation of the annotation specifically. And the

 response that I got back, and I'll probably repeat this again

 in the handling subcommittee, because this is double listed. I

 will focus on the 603 listing here.

 But, anyway, what I had received back was that the

 inconsistency with how certifiers would review is a little bit

 more broad and applies to all sanitizers. And there's

 different approaches that certifiers take to reviewing

 sanitizers. This is actually described in the ACA best

 practice document that is available on the ACA's website. And

 it talks -- it outlines different approaches for how certifiers

 review sanitizers broadly.

 For the 603 listing, specifically it was noted that 
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 there appears to be consensus that phosphoric acid annotation

 is managed and verified just like any milkhouse sanitizer,

 cleaner, or effluent. And it was just noted that there was

 discussion ongoing around the two listings and whether or not

 it's appropriate to align those listings, and again just more

 broadly the work that the Board could do with sanitizers, and

 again perhaps to fix the annotation.

 SECRETARY BRUCH: Thanks, Kyla, for the update and

 collaborating with me on the sunset. All right. So just

 looking at it from our written comments from our stakeholders,

 despite clarity needing to be achieved, we still had seven

 written comments from certifiers, farmer groups, advocacy

 groups indicating consensus for support for relisting. And

 some of the comments in favor of relisting, one from a farmer

 group stated phosphoric acid is an essential material. It is

 used to remove deposits on equipment, such as milk lines and

 bulk tanks that cannot be removed with other sanitizers,

 detergents, or acids.

 Advocacy groups mentioned environmental and health

 concerns. They mentioned also that phosphate is being mined

 and processed. The contact of phosphoric acid with skin and

 eyes should be avoided because of the corrosiveness. And

 phosphate pollution can contribute to nitrification of water

 bodies receiving treated wastewater.

 There were a couple of comments for additional 
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 improvement with the listing or just to help. And Kyla

 mentioned the one with the sanitizer panel or, sorry, sanitizer

 just working group, working an item. That's something we've

 heard that the Board should put on their work agenda. And then

 also this is for handling, but there is a little bit of

 difference in how the two listings, one under livestock and one

 under handling, are annotated. Stakeholders appreciated the

 defined or the more defined listing in livestock and hopes that

 that would carry over to handling.

 So with that, I will open it up to any questions or

 discussion.

 CHAIR POWELL-PALM: Questions for Amy? We lost the

 slides. Wood, please go ahead.

 BOARD MEMBER TURNER: I just wanted to acknowledge

 this is a thread that we've had on several meetings now just

 related to sanitizers. And this is obviously something as we

 continue on we still don't have a process, right, how to do

 this exactly right. But I just want to acknowledge the

 committee's job, work, and sort of essentially trying to --

 trying to road test something like that. It's not exactly the

 process, but this is -- this is a lot better review I think

 than some of the past sanitizer sunset reviews.

 CHAIR POWELL-PALM: Agreed. Other questions for Amy?

 Comments, questions? All right, with that we'll go to the

 vote. We're going to start this vote with Kim. 
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 BOARD MEMBER HUSEMAN: No.

 CHAIR POWELL-PALM: Franklin?

 BOARD MEMBER QUARCOO: No.

 CHAIR POWELL-PALM: Wood?

 BOARD MEMBER TURNER: No.

 CHAIR POWELL-PALM: Logan?

 BOARD MEMBER PETREY: No.

 CHAIR POWELL-PALM: Carolyn?

 BOARD MEMBER DIMITRI: No.

 CHAIR POWELL-PALM: Allison?

 BOARD MEMBER JOHNSON: No.

 CHAIR POWELL-PALM: Brian?

 BOARD MEMBER CALDWELL: No.

 CHAIR POWELL-PALM: Nate?

 BOARD MEMBER LEWIS: No.

 CHAIR POWELL-PALM: Dilip?

 BOARD MEMBER NANDWANI: No.

 CHAIR POWELL-PALM: Gerry?

 BOARD MEMBER D'AMORE: No.

 CHAIR POWELL-PALM: Kyla?

 BOARD MEMBER SMITH: No.

 CHAIR POWELL-PALM: Amy?

 SECRETARY BRUCH: No.

 CHAIR POWELL-PALM: And the Chair votes no.

 SECRETARY BRUCH: Zero yes, 13 no, zero abstentions, 
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 zero recusals, 2 absent. The motion fails. And I want to say

 thank you, I didn't say thank you.

 CHAIR POWELL-PALM: And back to you, Kim.

 BOARD MEMBER HUSEMAN: Okay, thank you, Nate. Next

 we will be doing the sunset review for hydrated lime, listed at

 205.603(b), as an external pest control not permitted to

 cauterize physical alterations or deodorize animal waste. The

 motion to remove lime from the National List was made by Kim

 Huseman and was seconded by Brian Caldwell. This material

 belongs to me for review.

 And I'll start by saying you'll see a pattern here.

 We had phosphoric acid. We have hydrated lime. There's quite

 a few different materials that we'll see, alcohols is another

 one, across the different subcommittees. You will hear about

 hydrated lime again from Franklin, when crops gives their,

 their review.

 In the case of livestock, hydrated lime, through the

 spring comments again were mostly in support as it is a

 necessity for good management practices for, for livestock. It

 is really another one of those tools in that toolbox. One

 commenter did bring up again that there could be some uses that

 are not intended for hydrated lime within the, the livestock

 aspect as far as using it as a -- as a deodorizer. But that's

 there for, for other uses and something to keep on the radar.

 But in the reviewing for the fall past that, all other comments 
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 were directed towards crops. That's the analyst part of that. 

 CHAIR POWELL-PALM: All right. Questions,

 discussion, comments for Kim? Hearing none, we'll go to the

 vote. We're going to start with Franklin this time.

 BOARD MEMBER QUARCOO: No.

 CHAIR POWELL-PALM: Wood?

 BOARD MEMBER TURNER: No.

 CHAIR POWELL-PALM: Logan?

 BOARD MEMBER PETREY: No.

 CHAIR POWELL-PALM: Carolyn?

 BOARD MEMBER DIMITRI: No.

 CHAIR POWELL-PALM: Allison?

 BOARD MEMBER JOHNSON: No.

 CHAIR POWELL-PALM: Brian?

 BOARD MEMBER CALDWELL: No.

 CHAIR POWELL-PALM: Nate?

 BOARD MEMBER LEWIS: No.

 CHAIR POWELL-PALM: Dilip?

 BOARD MEMBER NANDWANI: No.

 CHAIR POWELL-PALM: Gerry?

 BOARD MEMBER D'AMORE: No.

 CHAIR POWELL-PALM: Kyla?

 BOARD MEMBER SMITH: No.

 CHAIR POWELL-PALM: Amy?

 SECRETARY BRUCH: No. 
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 CHAIR POWELL-PALM: Kim?

 BOARD MEMBER HUSEMAN: No.

 CHAIR POWELL-PALM: And the Chair votes no.

 SECRETARY BRUCH: Zero yes, 13 no, zero abstentions,

 zero recusals, 2 absent. The motion fails.

 CHAIR POWELL-PALM: All right. One more, Kim.

 BOARD MEMBER HUSEMAN: Can you please forward the

 slide for me? We've got 45 minutes, you all, so we might as

 well just hang out.

 CHAIR POWELL-PALM: Just enjoy it. Having a good

 time.

 BOARD MEMBER HUSEMAN: There we go. Thank you, tech

 support. And let's go ahead and give a round of applause for

 tech support.

 (Applause.)

 BOARD MEMBER HUSEMAN: There's so much that is going

 on. And those puppeteering behind the background is so

 welcome, so thank you. I'm going to use all 45 minutes, Nate.

 The last livestock subcommittee material review is

 mineral oil, listed at 205.603(b), for topical use and as a

 lubricant. The motion to remove mineral oil from the National

 List was made by Brian Caldwell and seconded by Kim Huseman.

 And Brian, this is your material. You have the floor.

 BOARD MEMBER CALDWELL: All right, thanks, Kim. So

 the mineral oil for this purpose is a highly refined petroleum 
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159

 oil, sometimes called white mineral oil. It has very low

 toxicity. It is an effective product and stable on the shelf,

 which is a valuable attribute, against external parasites which

 can cause serious, again, animal health issues.

 This is -- this review, this listing is for external

 use only. There is a second listing that we -- that we

 reviewed a couple of years ago for internal uses. So again

 this is just for external uses. And it also includes

 lubrication, which as far as we can tell, as far as I could

 tell from looking at the literature and talking with folks is

 basically as a lubricant in terms of artificial insemination.

 So it's basically just used on the outside of the animal.

 The written comments were three in favor of

 relisting. Several of the certifiers listed a lot of use by

 farmers. And in general it was not controversial amongst our

 commenters. So any questions?

 CHAIR POWELL-PALM: Any questions for Brian?

 BOARD MEMBER HUSEMAN: I have a question.

 CHAIR POWELL-PALM: Go ahead, Kim.

 BOARD MEMBER HUSEMAN: Is there benefit to coupling

 the two mineral oil listings and putting them maybe at the same

 time for review in sunset, just for ease of process?

 CHAIR POWELL-PALM: I'd be a fan.

 BOARD MEMBER CALDWELL: Yeah, I think -- I think it

 would be great. And that would probably mean that, that this 
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160

 material, this listing would be reviewed like in three years

 instead of five, just to kind of have them both come up at the

 same time.

 BOARD MEMBER HUSEMAN: We have another example of

 that that Amy is working on with xylazine and tolazoline that I

 think would be a good way to -- or at least precedent that we

 work that turn then.

 SECRETARY BRUCH: And I think that might take away

 some of the confusion, too.

 BOARD MEMBER HUSEMAN: By having those with alcohols

 listed.

 CHAIR POWELL-PALM: Amy?

 SECRETARY BRUCH: Brian, thanks for your review. I

 just had a question on alternatives. Are there any natural

 alternatives that are out there or effective?

 BOARD MEMBER CALDWELL: Well, let me look at the --

I'd have to look into the TR for that. I mean lime sulfur was

 just reviewed and that's used for some of the same, same

 purposes. Again, it's good to have a variety of, of tools for

 the toolbox. And it's highly effective. So there may be --

 there may be some, some natural products that would -- could

 also be used for this. But this is what's in standard usage.

 And if there are some natural products, I think we need more

 research on it to demonstrate them and bring them out, and then

 we can use them. 
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161

 SECRETARY BRUCH: Sounds good. I didn't know if

 there was market opportunity, market expansion opportunity for

 any, any crops. So I just was curious. Thank you.

 CHAIR POWELL-PALM: I don’t want to be the one whose

 mind is just always in the gutter. But I think that there was

 just the most beautiful conversations about this material.

 We're all so trying to be extra polite about how we describe

 what we're talking about with artificial insemination. And I

 like your entrepreneur's opinion. I think there is always a

 chance for another crop out there.

 I would say as a cattle producer who uses this

 material and artificially inseminates my own cows that I've not

 come across an effective analog that we would be able to use.

 But I think this has been, I think to Kim's point, something

 that we have spent a lot of time. Brian has done an excellent

 job researching. And could probably reasonably be combined

 back with, with the other listing for mineral oil.

 Other questions or comments? All right, with that

 we'll go to the vote. We're going to get it kicked off with

 Wood.

 BOARD MEMBER TURNER: No.

 CHAIR POWELL-PALM: Logan?

 BOARD MEMBER PETREY: No.

 CHAIR POWELL-PALM: Carolyn?

 BOARD MEMBER DIMITRI: No. 
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 CHAIR POWELL-PALM: Allison?

 BOARD MEMBER JOHNSON: No.

 CHAIR POWELL-PALM: Brian?

 BOARD MEMBER CALDWELL: No.

 CHAIR POWELL-PALM: Nate?

 BOARD MEMBER LEWIS: No.

 CHAIR POWELL-PALM: Dilip?

 BOARD MEMBER NANDWANI: No.

 CHAIR POWELL-PALM: Gerry?

 BOARD MEMBER D'AMORE: No.

 CHAIR POWELL-PALM: Kyla?

 BOARD MEMBER SMITH: No.

 CHAIR POWELL-PALM: Amy?

 SECRETARY BRUCH: No.

 CHAIR POWELL-PALM: Kim?

 BOARD MEMBER HUSEMAN: No.

 CHAIR POWELL-PALM: Franklin?

 BOARD MEMBER QUARCOO: No.

 CHAIR POWELL-PALM: And the Chair votes no.

 SECRETARY BRUCH: Zero yes, 13 no, zero abstentions,

 zero recusals, 2 absent. The motion fails.

 CHAIR POWELL-PALM: Back to you, Kim.

 BOARD MEMBER HUSEMAN: Thank you, Nate. I just want

 to take just a brief moment to say how excited I am to be able

 to serve as the chairman of the livestock subcommittee for the 
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163

 past two years. I have a true passion for the livestock

 industry. Livestock and feed ingredients go hand in hand. So

 the more animals that we can introduce into the market space,

 the more farmers we can get to continue to grow grain, too.

 So I really appreciate the support of the Board and

 of the community. And I will not be running for chair of the

 livestock committee next year, just --

 CHAIR POWELL-PALM: I'm interested in how you think

 this works. There's no running for chair.

 BOARD MEMBER HUSEMAN: It's on the record.

 CHAIR POWELL-PALM: We're running a little bit ahead

 of time, which is great. And I -- so if it's all right, Kim, I

 would like to just sort of acknowledge an interesting comment

 that was made a few times in public comments, and that was

 asking about swine production. And I think as we get through

 very successfully, so thank you, Kim, the materials, we have a

 chance to think a little bit bigger about other aspects of the

 livestock sector that possibly we could be helping bring to

 light or at least explore with the community.

 And so one, one thing I would put out to the

 community in general is just that I don't see where the market

 is, yet. It seems like when as ask to chicken and egg, do we

 have a strong market that is calling for this organic pork, or

 do we have a lot of farmers who want to grow it and, therefore,

 we need to find a market or build a market. I think it would 
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164

 be wonderful if we were able to start hearing who are those

 organic pork buyers or brands, or who could we be reasonably

 pushing as a community to become an organic pork brand or

 buyer.

 I think it's very easy to round up some organic pork

 farmer and have them tell us their best strategies. But I

 hesitate to, to put too many eggs in that basket before we know

 that there is a market, because we've been talking about for

 several days now how can we make sure there is a market when we

 get folks to transition.

 BOARD MEMBER HUSEMAN: Can I add to that?

 CHAIR POWELL-PALM: Please.

 BOARD MEMBER HUSEMAN: And we're talking pork, not

 chicken. So we're talking bacon and --

 CHAIR POWELL-PALM: Well, to be clear, no chicken is

 involved in this conversation.

 BOARD MEMBER HUSEMAN: We'll talk about bacon in the

 pan, don't fry it all at once. We really did have some great

 robust conversation in the subcommittee regarding swine. In

 fact, not common practice, but we actually as a livestock

 subcommittee altered our research priorities for this fall that

 will be talking about voting on later on this week. And, and

 it does include now swine production very explicitly, that did

 not have that language before.

 So I'd like to encourage from an institutional aspect 
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165

 to list a university, other land grant universities, but may

 want to look at ways that we could put some dollars into

 research from an organic pork production standpoint. And not

 only from a buyer aspect, but just the challenges of swine

 production in an organic format. It is much different than

 raising cattle. And we start talked about vaccines and we

 start talking about other practices, and the barriers in that

 aspect as well. But it's a holistic process.

 And I'll use the chicken and the egg philosophy in

 our conversation as, yes, you have to have buyers, but which

 comes -- which comes first. But there's so many different

 segments that I think are, are challenged in this space. So

 kudos to the community for continuing to, to raise this. And I

 look forward to see where this -- where this goes. And just

 wanted to again just reiterate and acknowledge the research

 aspect to it.

 CHAIR POWELL-PALM: Thank you for that. Carolyn,

 please, go ahead.

 BOARD MEMBER DIMITRI: I mean as part of the swine,

 organic swine conversation, though, I think we have to look at

 processing facilities. And I think that for most meat

 products, like the lack of organic processing capacity has

 really been a barrier to market development. So maybe the

 whole entire food system, rather than just looking at the two

 ends. 
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166

 CHAIR POWELL-PALM: Thank you. Yes. Brian?

 BOARD MEMBER CALDWELL: Just an anecdotal comment.

 Our local supermarket that we go to always has organic bacon

 available. And for many years, they had organic sliced ham for

 cold cuts. And then it disappeared for about two years, but

 now it's back. And we bought it every week. And I don't see

 why there wouldn't be an organic market for, for hams, and

 bacon, and sausage, just as there is for conventional. It

 seems totally reasonable to me. And I've -- the quality that

 we can get when it's available is very high.

 BOARD MEMBER HUSEMAN: Also, this is another animal

 that eats organic corn, organic soybean meal, organic oils.

 I'm just putting that out there also from a shareholder --

 CHAIR POWELL-PALM: And a lot of byproducts, right?

 I mean you -- let's go Wood and then Carolyn.

 BOARD MEMBER TURNER: Nate, I just want to put you on

 the spot, because you talk a lot about market industries. Why,

 to Brian's point, why would there not be a market for, for this

 product? There's a market for chicken. There's a market for

 eggs. There's a market for beef. I don't understand this

 particular -- I just haven't -- I was really kind of amazed by

 the comments on this. And I'm sort of just excited to

 understand that better.

 CHAIR POWELL-PALM: I think that question is one that

 I proposed back to the community, trying to figure out how we 
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167

 can crowd source this information as best we can. There's a

 large brand, I'd call it an in crop cooperative, working on a

 pig rule, and asking them to bring that forth for what are the

 challenges accessing those markets, because there are certainly

 folks trying.

 I don’t really know. As an inspector, I've done a

 little over 3,000 inspections. I've inspected maybe one

 organic pig, maybe two operations. And, yeah, so I wish I had

 better, better insight on why. But I think back to Carolyn's

 point, if we look holistically at the supply chain for how does

 an organic hog grower access that slaughter infrastructure and

 then get to the market, usually that middle production point is

 kind of a bottleneck. Carolyn, please, go ahead.

 BOARD MEMBER DIMITRI: This is my, my humor in

 action. I'm letting you know I think it's a joke before I say

 it. Brian, I wonder what happens to the rest of the pig. If

 you end up with bacon in the store, like where did the rest of

 the animal go?

 BOARD MEMBER HUSEMAN: Organic casings.

 BOARD MEMBER DIMITRI: Yeah.

 CHAIR POWELL-PALM: Yeah, yeah.

 BOARD MEMBER DIMITRI: But that's just typical.

 BOARD MEMBER LEWIS: In our family, we said if pigs

 could fly, I'm sure their wings would be delicious. So just in

 the vein of kind of spit-balling a little bit about future work 
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168

 for the livestock subcommittee, I do want to just put on the

 table and get into the record the agriculture standards which

 are languishing at the department, and the obligation for us to

 develop wild caught seafood standards. That's an important

 concern for the folks and stakeholders I work with in

 Washington, in the Pacific Northwest. And look forward to

 seeing if there is an opportunity to engage on that. And our

 farm, our family farm is on Puget Sound, so I'm a hobby

 shellfish grower, myself, so sort of close to the -- to the

 industry.

 CHAIR POWELL-PALM: Any other thoughts? Any other

 aspirations for livestock subcommittee? All right. Well,

 again, thank you very much, Kim. Appreciate your leadership on

 this. And that's a wrap for day one, folks. So thank you so

 much. What a fantastic day. Really glad to see you all. And

 we'll do it again tomorrow starting with CACS.

 (Whereupon, at 4:29 p.m., the meeting was adjourned.) 
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 at the heari

169

 CERTIFICATION

 This is to certify that the attached proceeding

 before the:

 NATIONAL ORGANIC STANDARDS BOARD

 IN THE MATTER OF: FALL 2023 MEETING

 PLACE: Providence, Rhode Island

 DATE: October 24, 2023

 was held according to the record, and that this is the

 original, complete, true and accurate 

ng.

transcript which has been

 compared to the recording accomplished 

 __________________________

 Elaine M. LaRosee,

 Official Reporter 
 NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 3 

November 24, 2023 

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 96:3,4,6,7;98:20,23; accurate (1) 68:23;90:16;91:25; adopted (4) 94:14;105:8,19;

 101:12,19;102:2,25; 140:19 98:3;104:15;105:5, 138:5,14;139:23; 106:22,24;108:3;

 103:7;107:20;125:19; achieve (3) 11;110:24;118:1,16; 141:18 113:6;120:10;123:25;

 144:6;148:21;161:13; 35:14;45:21;121:1 122:5;125:9,20; adopter (1) 127:5;135:25;142:1,

 162:24;164:1 achieved (2) 126:13,21;128:25; 46:21 21;144:18,21;146:1,

abroad (1) 83:7;153:11 131:24;142:3;149:17; adopters (1) 24;152:14;153:5,7;

 64:23 acid (7) 152:6,21;164:20 36:13 156:15,18,21;159:4,7;

absence (1) 151:9,10,12;153:1, add (7) adoption (1) 160:19;165:15;

 14:6 15,21;156:12 51:8;69:24;94:5; 102:5 168:13,16 

absences (5) acids (1) 96:5;118:22;129:19; advance (6) against (2)

 15:1;132:3;133:21; 153:18 164:11 48:18;49:2;53:16; 80:16;159:3 

135:4;137:2 acknowledge (7) added (5) 89:18;106:14;107:8 age (4)

absent (9) 128:5,24;144:13; 44:10;75:5;93:21; advanced (4) 20:5,8;21:4;84:13 

15:1,4,6;80:20; 154:14,18;163:13; 96:17;97:8 39:7;40:21,21; agencies (4)

 148:1;151:6;156:1; 165:15 adding (1) 54:16 38:11;41:24;49:5;

 158:5;162:21 acquisition (1) 96:4 advancing (1) 74:17 

absents (1) 99:7 addition (7) 7:3 Agency (4)

 146:4 acres (14) 58:2;74:13;75:4; advantage (1) 6:10;30:14;44:18;

absolutely (3) 13:1;16:21;19:5; 78:13;84:4;93:5; 91:24 49:4 

7:2;20:9;110:2 56:6;76:7,17;91:21; 99:24 advertising (1) agenda (14)

abstention (1) 93:8,21;95:10; additional (7) 42:13 0:25;6:4;12:6,10;

 133:21 119:14,15;125:23,24 64:22;75:13;85:24; advisor (1) 44:13,16;66:7;67:21;

abstentions (8) acronyms (3) 93:21;103:12;105:22; 12:1 69:10,21;79:19;

 135:4;137:2;146:3; 53:12;92:13;149:16 153:25 Advisory (3) 127:25;130:18;154:4 

147:25;151:5;155:25; across (27) additions (1) 0:10;6:17;37:16 aggregating (1)

 158:4;162:20 24:16;25:6;27:18; 16:8 advocacy (4) 108:18 

ACA (9) 28:10,19;32:17; additive (1) 47:20;104:24; agleam (1)

 0:21,22;31:20,20; 34:16;38:11;40:7; 130:9 153:12,19 13:1 

32:7;152:5,8,10,21 47:23;49:5;54:2; address (3) advocate (1) ago (15)

ACA's (1) 75:25;77:8;78:2; 55:17;75:21;107:20 77:2 14:12;19:11;23:14;

 152:22 81:24;88:14;89:16; addressed (2) AFA (1) 26:18;27:1;28:15;

acceptance (1) 102:8;103:13,14; 44:2;117:7 17:16 29:8;38:13;48:15;

 148:14 105:8;109:17;127:13, addressing (3) affect (1) 63:4;89:23;113:20;

access (9) 20;156:14;161:13 60:16;78:21;108:2 45:15 122:19;123:17;159:7 

38:8;48:17;78:16; Act (2) adequate (1) affected (1) agrarian (2)

 88:23;96:14;104:21; 0:10;138:24 85:24 79:8 79:12;80:14 

128:9;131:13;167:11 action (3) adequately (1) affecting (1) agree (1)

accessibility (3) 104:14;105:24; 85:19 120:20 85:4 

78:1;103:23;131:13 167:15 adjourn (1) affectionally (1) agreed (2)

accessible (4) actions (2) 69:25 35:10 45:20;154:23 

47:23;109:5; 38:6;50:8 adjourned (1) affinity (1) agreeing (1)

 135:18;149:7 activated (1) 168:17 50:11 109:13 

accessing (1) 41:5 admin (1) affordable (1) agreements (4) 

Min-U-Script® Burke Court Reporting & Transcription (1) $100 - agreements 

(973) 692-0660 
 NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 3 

November 24, 2023 

49:18;57:9;110:11, 116:21 AMS (2) APHIS (1) 140:4 

11 allow (5) 42:5;49:9 9:1 approved (5)

agri (1) 101:21;104:1; Amy (25) apologies (1) 16:9;55:1;135:12;

 80:8 120:2;127:1;138:3 12:16;55:19;64:12; 14:6 137:22;138:7 

agricultural (7) allowed (6) 69:11;116:17;117:13; apologize (1) approving (1)

 11:11;49:10;80:2; 0:24;88:23;137:22; 129:6;131:9;133:7; 92:21 140:6 

90:7;95:8;98:12; 143:19;148:4;151:10 134:9;136:9;137:7; Appalachian (2) approximately (3)

 121:25 allowing (2) 145:3;147:4;148:7; 105:2,19 25:5;45:22;76:17 

agriculturalists (1) 15:17;87:1 150:5;151:13,14; appears (1) April (2)

 81:11 allows (2) 154:12,23;155:22; 153:1 16:7;79:6 

agriculture (21) 41:24;137:19 157:24;160:5,12; applaud (2) aptly (1)

 11:19;13:12;14:7; almost (3) 162:13 113:6,10 65:20 

20:16;52:6,7,13,14; 42:10,18;60:18 Amy's (1) Applause (25) area (12)

 68:9;75:3;79:18;80:1; aloe (1) 120:12 6:19;7:9;9:9;24:2; 13:6;31:23;39:24;

 81:2;82:5;84:23; 124:10 analog (1) 73:13;77:11;83:9,17; 41:3;52:25;55:25;

 90:22;98:13;103:15; alone (1) 161:13 87:24;92:7;94:16; 71:19;95:1,14;

 110:17;121:19;168:2 74:12 analysis (2) 97:18;100:14;104:7; 117:10,23;131:14 

agroforest (1) along (4) 89:21;92:1 107:3;109:6;110:19; areas (10)

 83:3 43:16;59:16;86:9; analyst (1) 127:7,9,21,23;145:22, 27:20;28:5;74:9;

ahead (31) 124:24 157:1 23;158:13,15 85:17;88:10;96:13;

 6:14;7:18;40:2; alterations (1) ancestor (1) apples (2) 111:23;112:8;117:21;

 47:3;51:6;55:19; 156:7 125:8 18:19;19:3 119:10 

58:14;64:13;69:20; altered (1) ancestors (1) application (3) arm (2)

 91:9;93:24;110:25; 164:21 80:12 19:11;29:9;99:7 117:7,8 

112:4;115:13;117:13; alternative (2) Andrea (1) applications (2) arms (1)

 122:25;123:12;128:1, 139:18;148:12 6:25 29:10,11 47:11 

2;129:25;132:20; alternatives (4) Andrew (3) applied (2) Aroostook (1)

 135:22;139:2;141:13; 139:24;144:7; 8:19,25;9:2 19:6;117:8 94:9 

142:6;154:13;158:13; 160:14,15 anecdotal (1) applies (1) around (24)

 159:19;163:11; although (1) 166:2 152:19 0:23;9:23;26:18;

 165:18;167:13 98:10 Animal (7) apply (1) 30:4;37:9,10;38:3;

aim (1) always (18) 9:1;140:18;156:7; 35:13 47:6;48:13;50:3;

 74:11 6:17;31:23;55:10; 159:4,12;166:11; applying (1) 65:16;72:22;78:19;

air (1) 59:5,18;66:13;86:9; 167:18 68:24 110:17,20;126:6,11,

 16:23 90:8,22;94:18; animals (6) appreciate (19) 12,20,24;129:16;

alarming (1) 101:17;107:25; 88:23;135:18; 15:22;16:10;30:21; 131:19;132:7;153:4 

61:15 109:13;119:16; 140:24;141:3;146:17; 32:6;55:21;61:7; arrangement (3)

Alcohol (4) 124:14;161:5,9;166:3 163:3 63:17;64:14;92:4,17; 26:19;46:14,16 

8:20,21,23,25 amazed (1) anniversary (1) 100:17;101:1;114:20; arrangements (8)

alcohols (4) 166:21 0:22 115:7;131:22;143:9; 26:20;27:2;35:18;

 130:6,11;156:13; amazing (4) annotated (2) 146:10;163:5;168:13 38:17;42:4;45:15,19;

 160:10 32:5;38:8;44:25; 68:10;154:7 appreciated (1) 46:6 

Alexis (1) 87:18 annotation (3) 154:7 array (1)

 7:17 Amen (4) 152:13;153:1,7 appreciation (3) 81:21 

align (2) 82:11,12,16;131:16 annotations (8) 9:8;47:10;51:9 arrive (2)

 110:13;153:5 amendment (1) 12:9;54:24;55:6,7, apprentice (1) 23:22;59:10 

Aligning (1) 92:1 10,12,14,16 21:11 arrived (1)

 26:13 American (4) announced (2) approach (9) 18:20 

alignment (1) 101:25;114:2; 49:13;75:19 29:4;33:24;34:7; Arsenault (1)

 34:16 120:23;123:6 annual (2) 54:11;57:16;74:10; 6:16 

alive (2) America's (1) 59:12;84:19 77:4;116:4;135:21 articulate (1)

 114:17,19 80:4 annuls (1) approached (1) 105:11 

Alliance (6) Amherst (1) 80:3 36:12 artifact (1)

 87:8;88:21;92:24; 90:6 answered (1) approaches (2) 31:24 

93:14;99:2,23 among (3) 120:12 152:20,23 artifacts (1)

Allison (15) 95:5;99:25;114:5 antibiotics (4) approaching (2) 32:6 

9:25;10:2;47:7; amongst (2) 140:18,20,23;146:8 51:3;58:3 artificial (2)

 110:24;132:7,20; 141:8;159:15 anticipate (1) appropriate (5) 159:11;161:8 

134:22;136:21;140:9; AMOSA (1) 45:14 16:5;108:11; artificially (1)

 145:15;147:16; 109:21 anticipated (1) 109:25;125:15;153:5 161:12 

150:17;155:10; amount (6) 66:19 approval (4) Asian (1)

 157:12;162:1 25:13;39:24;63:4; anymore (1) 139:9,19,20;140:2 125:2 

Allison's (1) 98:17;142:8;148:25 22:6 approve (1) aspect (6) 

Min-U-Script® Burke Court Reporting & Transcription (2) agri - aspect 

(973) 692-0660 
 NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 3 

November 24, 2023 

102:12;156:23;

 164:25;165:4,8,16 

aspects (3)

 89:7;106:22;163:17 

aspirations (1)

 168:12 

aspirin (4)

 135:11,16,21,24 

aspiring (1)

 135:12 

assemble (1)

 22:14 

assessments (1)

 92:2 

assist (2)

 49:14;88:10 

assistance (17)

 28:11;75:9;88:17;

 89:20;94:1;96:10;

 99:3,10,21;101:22;

 104:24;108:23;109:3;

 111:9,12;119:8;

 120:20 

associate (3)

 8:16,17,18 

associated (2)

 33:3;68:3 

Association (14)

 0:21;31:20;33:25;

 34:13;50:10;57:10,

 11;92:12;94:18;98:8;

 101:8;106:12;108:10;

 128:8 

associations (2)

 33:12,21 

assumed (1)

 21:21 

asthma (3)

 17:10;18:2;19:19 

astonishingly (1)

 109:10 

Atlanta (1)

 16:7 

attack (1)

 55:4 

attacking (1)

 115:1 

attacks (1)

 17:10 

attempt (1)

attribute (1)

 159:3 

attributes (1)

 20:9 

audience (2)

 0:5;63:20 

audiences (2)

 28:25;86:25 

audit (1)

 25:18 

audits (3)

 25:21;46:13,19 

August (1)

 90:18 

authorities (1)

 41:12 

authority (1)

 17:21 

availability (3)

 131:18,19;139:21 

available (14)

 13:19;31:7;38:12;

 44:9;57:17;94:12;

 99:16;131:15;135:18;

 138:4;142:25;152:22;

 166:4,10 

avenue (1)

 55:2 

average (2)

 80:25;119:14 

avoid (1)

 19:10 

avoided (1)

 153:22 

awards (1)

 30:2 

awareness (1)

 102:4 

away (7)

 12:23;17:1;41:9,10;

 57:2;146:11;160:8 

awe (1)

 23:17 

awesome (2)

 85:13;87:20 

awoke (1)

 16:22 

102:17;105:8,21;

 110:22;120:9;127:6;

 129:3;130:20,23;

 131:23;135:6,11,22;

 137:4;146:5;148:2;

 151:7;152:14,17;

 156:3;161:17;162:22;

 166:6,25;167:9 

background (3)

 12:18;48:14;158:17 

backgrounds (1)

 72:11 

backyards (1)

 83:23 

bacon (5)

 164:14,17;166:3,8;

 167:17 

bacteria (2)

 114:17;115:10 

bad (3)

 59:21;99:12;149:13 

bag (1)

 128:12 

bags (2)

 18:18,18 

baked (1)

 69:3 

balance (1)

 40:21 

Baltimore (2)

 42:2;78:5 

banner (1)

 30:18 

bar (1)

 47:5 

barely (2)

 76:13;110:5 

barn (2)

 88:24;131:5 

barrier (2)

 128:9;165:23 

barriers (4)

 48:17;49:15;98:23;

 165:7 

based (9)

 0:10;11:3;14:7;

 27:17;35:10;39:5,8;

 41:23;104:20 

basically (6)

 139:11,24,25;

became (2)

 17:10;73:23 

Beckett-Parr (1)

 116:10 

become (7)

 19:13;76:14;82:17;

 131:2;144:15,16;

 164:3 

becomes (1)

 36:24 

becoming (4)

 21:23;98:22,23;

 108:13 

bedded (1)

 89:3 

beef (2)

 101:5;166:20 

beg (1)

 19:17 

began (2)

 21:23;79:15 

begin (1)

 75:19 

beginning (3)

 6:9;99:3;108:25 

begun (1)

 47:16 

behind (4)

 7:25;35:2;95:8;

 158:17 

Belgrade (1)

 15:9 

beliefs (1)

 31:25 

bellies (1)

 20:25 

belong (1)

 130:14 

belongs (4)

 137:8;148:8;

 151:14;156:10 

below (1)

 115:9 

benefit (1)

 159:20 

benefits (11)

 19:24;40:9;52:2;

 68:21;82:4;106:2;

 111:15,18;114:7,8;

 115:20 

82:13,17;97:3;110:7;

 116:7;154:21;166:23;

 167:9,9 

beyond (2)

 64:10;102:3 

big (15)

 9:7;21:3;22:8;

 27:23;39:20;53:10;

 90:22;95:11;114:19;

 116:1;117:9,23;

 119:16;123:17;

 140:13 

bigger (4)

 23:6;119:17;120:1;

 163:17 

biggest (4)

 87:17;106:17;

 117:4;143:15 

Bill (8)

 32:25,25;33:1,3;

 38:15;47:13;59:14;

 84:12 

billionaire (1)

 124:19 

billions (1)

 115:10 

biodiversity (2)

 76:19;108:2 

Biological (4)

 101:8,11;102:3;

 138:22 

biologics/vaccines (1)

 144:20 

biologics-vaccines (3)

 137:6,10;138:23 

biology (1)

 114:23 

BIPOC (1)

 120:4 

birth (1)

 16:17 

birthday (4)

 0:22;16:22;17:10;

 31:20 

bisphenols (1)

 54:25 

bit (25)

 12:10;25:8,9;30:15;

 37:7;43:22;45:14;

 48:14;52:1,4;59:18;

B 

74:12 babies (1) 140:1;159:11,12 benign (1) 67:5;72:4;90:25;97:2;

attendance (1) 18:11 basis (1) 146:15 102:13;108:6;116:23;

 93:25 baby (7) 98:22 beside (1) 130:16;151:22;

attendees (1) 16:15;17:4;18:4,15, basket (1) 9:11 152:18;154:5;163:11,

 103:10 18;19:3;22:12 164:7 best (12) 17;167:25 

attending (3) back (53) bat (1) 36:23;43:4;53:22; Black (26)

 12:14;75:10;87:12 8:17;16:1,10;21:6, 86:1 54:13;66:2;84:9;89:4; 78:2,24;79:6,11,14,

attention (2) 7,9,10,12,14;22:1; Bay (1) 98:25;144:2;152:21; 16,24;80:14,25;81:4;

 33:19;34:8 24:9;30:20;33:15; 71:19 164:6;167:1 82:17;113:7,9;

attorney (1) 48:10;55:11;60:15; beans (1) better (19) 118:17,18,25;119:14,

 10:4 65:23;67:2,4;69:23; 97:8 15:16,18;23:7,16; 21;120:2,11;123:13,

attract (1) 70:1;71:3,5;80:12; beautiful (3) 43:23,24;58:13; 19;124:4,14;125:1,13 

57:8 87:14,22;89:23;90:4; 8:14;127:15;161:6 60:24,24;75:16; black-owned (1) 

Min-U-Script® Burke Court Reporting & Transcription (3) aspects - black-owned 

(973) 692-0660 
 NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 3 

November 24, 2023 

125:24 

blah (3)

 125:6,6,6 

blame (1)

 14:5 

blanket (3)

 139:8,20;140:2 

blew (1)

 104:17 

blind (1)

 83:6 

Blue (2)

 100:16;101:4 

blueberries (3)

 14:9;93:5;102:19 

blueberry (2)

 93:2,8 

Board (282)

 0:5,7,10;6:2,2,5,6,

 13,17,18;7:13,15;

 8:12;9:2,5,5,7,12,24;

 10:1,3,11,18,20,21;

 11:1,4,8,10,17,22,24;

 12:2,3,7,15,18;13:4,8,

 9,16,19,20;14:4,16,

 19,23,24;15:12,23;

 24:11;25:7;31:4;

 32:21;36:23;43:15;

 44:3,8,12,24;45:8,10,

 13;46:25;47:8;48:4;

 51:7,25;54:14,18,22;

 55:9,18;58:15;60:11;

 62:20;64:11;66:11,

 13,16,20,25;67:7,14,

 21;69:16;89:19;91:4,

 5;110:24;111:1;

 112:2,5;113:3;115:8,

 14;116:15,18;117:12;

 120:9;122:22,24;

 123:1,15;128:4,4,13,

 16,18,20,22;129:11,

 13;130:6;131:8,17;

 132:3,9,14,17,21,23,

 25;133:2,3,6,10,12,

 14,16,18,20,25;134:2,

 4,6,8,12,14,16,18,20,

 13,15,17,19,21,23;

 158:2,7,12,16,24;

 159:18,20,24;160:4,

 10,16;161:21,23,25;

 162:2,4,6,8,10,12,16,

 18,23;163:5,10;

 164:11,13,17;165:19;

 166:2,11,16;167:14,

 19,20,22,23 

Board's (4)

 0:11;7:14;37:16;

 68:1 

Bob (4)

 42:22,22,24;43:3 

bodies (3)

 19:25;148:20;

 153:24 

body's (1)

 52:21 

bold (1)

 63:1 

bolster (1)

 33:5 

Border (12)

 38:9,14;41:4,5,7,11,

 15,16,17,21;42:1;59:6 

born (2)

 23:13;73:4 

borne (1)

 43:14 

Boston (2)

 78:6;108:19 

both (27)

 0:16;6:21;7:3;17:2;

 21:1,1;25:12;39:5;

 49:8;51:17;55:15;

 84:6,14,24;86:19,25;

 92:24;93:22;99:3;

 130:2,7,14;131:12;

 132:15;143:15,25;

 160:2 

bottle (1)

 20:5 

bottleneck (1)

 167:13 

bought (2)

Brazil (1)

 12:21 

breadbasket (1)

 76:14 

Breadtree (2)

 76:5,19 

breadtreefarmscom (1)

 76:9 

break (6)

 24:4;69:18;128:1,3;

 129:2;149:22 

breaking (2)

 16:25;64:18 

breath (2)

 16:24;37:8 

breathing (1)

 22:4 

breathtaking (1)

 22:4 

breeding (1)

 101:6 

Brent (4)

 97:21;100:16;

 104:8;105:2 

Brian (43)

 10:11;47:7;51:6;

 76:23,25;77:5,9;

 130:12;132:13,22;

 133:24;136:23;137:7,

 8;139:3;140:14;

 141:4;142:12;143:3,

 4,10;144:11,19;

 145:17,24;146:1,9,10,

 22,24;147:18;150:19;

 155:12;156:9;157:14;

 158:22,23;159:17;

 160:13;161:15;162:3;

 166:1;167:16 

Brian's (1)

 166:18 

bridges (1)

 87:14 

brief (3)

 44:1;152:8;162:24 

briefly (2)

 45:17;110:22 

brings (4)

 32:3;73:1,2;109:12 

broad (2)

 60:2;152:19 

broaden (1)

 53:2 

broader (4)

 6:21;35:22;49:9;

 52:13 

broadly (3)

 53:3;152:24;153:6 

broke (1)

 11:24 

brought (7)

 20:4,4;25:1;31:21;

 90:17;122:5;128:12 

brown (1)

 82:16 

brown-bags (1)

 34:20 

BRUCH (37)

 12:12,16;15:21,22;

 55:20;64:14;117:14;

 118:23;119:12;120:6;

 129:7;131:10;133:8;

 134:10;135:9;136:10;

 137:1,8;145:4;146:2;

 147:5,25;148:7;

 150:6;151:5,13,15;

 153:8;155:23,25;

 157:25;158:4;160:8,

 13;161:1;162:14,20 

brushed (1)

 23:10 

bubble (1)

 52:11 

budget (2)

 25:14;27:10 

build (20)

 15:17;23:6;28:1;

 39:2;47:16,22;48:2;

 67:11;75:12;76:18,

 22;77:7;81:11;85:4;

 88:7;93:14;99:25;

 100:1;112:12;163:25 

builder (1)

bumpy (1)

 111:13 

bunch (2)

 137:11;140:3 

burden (1)

 45:22 

burdened (1)

 62:10 

Bureau (4)

 8:22;91:17;98:14;

 112:5 

bureaucratic (1)

 38:9 

Bureaus (1)

 112:23 

bushels (1)

 21:10 

business (16)

 0:8;6:13;16:21;

 41:18;49:12;63:5;

 65:25,25;75:16,23;

 79:15;80:8;108:21,

 21;124:11;128:5 

businesses (4)

 37:18;38:6;42:12;

 79:25 

busy (1)

 81:16 

button (1)

 135:11 

buy (7)

 18:4,6,16;19:1;

 20:6;34:5;57:4 

buyer (6)

 18:4,14,17;57:12;

 164:4;165:4 

buyers (6)

 40:14;56:24;57:3,

 13;164:2;165:10 

buying (1)

 57:14 

byproducts (1)

 166:14 

C 

22,25;135:3,7,10,24; 18:1;166:6 bright (1) 16:19 CACS (5)

 136:3,5,6,8,12,14,16, Bourbon (1) 143:18 building (9) 6:11;10:7;69:11;

 18,20,22,24;137:5,9; 126:15 brilliantly (1) 11:14;20:13;78:11; 135:8;168:16 

139:3,7,17,19;140:10, box (1) 144:11 87:14;88:17;94:8; cacti (1)

 21;141:1,6,11,14,17, 41:13 bring (22) 96:10;111:13;112:16 124:10 

19,20;142:12,17; boy (1) 15:25;28:25;47:11, builds (1) calculating (1)

 143:2,5,7;144:23,25; 60:15 19;50:22;78:3,22; 23:21 97:4 

145:2,6,8,10,12,14,16, Bozeman (4) 79:15;83:12;86:12; buildup (1) CALDWELL (37)

 18,20;146:6,13;147:1, 15:9;17:23,23;23:3 87:25;91:10;103:24; 57:22 10:11,11,18,20;

 3,7,9,11,13,15,17,19, branch (1) 109:24;114:16; built (3) 51:7;54:22;55:18;

 21,23;148:3;149:10, 85:19 119:23;121:7;137:12; 112:9,10;119:20 76:24;130:12;132:14,

 13;150:8,10,12,14,16, brand (2) 156:21;160:24; bulk (2) 17,23;133:25;136:24;

 18,20,22,24;151:1,3, 164:3;167:2 163:18;167:3 151:20;153:17 137:7,9;139:7,19;

 8,16;152:9;153:6; brands (1) bringing (9) bullet (1) 140:21;141:17,20;

 154:4,14;155:1,3,5,7, 164:2 10:25;32:3;34:3; 30:21 142:17;145:18;146:9,

 9,11,13,15,17,19,21; Bravo (1) 49:20;50:10,11; bum (3) 13;147:19;150:20;

 156:4;157:5,7,9,11, 127:22 56:12;71:24;78:9 20:4,4,5 151:1;155:13;156:9; 

Min-U-Script® Burke Court Reporting & Transcription (4) blah - CALDWELL 

(973) 692-0660 
 NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 3 

November 24, 2023 

157:15;158:22,24; 164:9,11;166:10; CBP (1) 13,16;35:5,24;36:5,8, 158:1,3,3,6,10;

 159:24;160:16;162:4; 167:1,1 59:11 10,16;37:7,17,21; 159:17,19,23;160:12;

 166:2 Canada (5) CCOS (1) 39:5,9,16;40:25; 161:4,22,24;162:1,3,

calf (1) 35:19;45:19;46:12, 109:21 46:23;54:2;55:12; 5,7,9,11,13,15,17,19,

 22:12 14,21 celebrate (2) 57:24;58:21;60:3; 19,22;163:6,8,9,11;

California (3) candid (1) 14:17;110:12 64:25;65:3,6,10,11, 164:12,15;165:17;

 11:9;22:3;95:7 116:3 celebrating (2) 13,17,25;144:3,4,8; 166:1,14,24;167:21;

call (24) candy (5) 0:21;11:11 152:18,20,23;153:12; 168:11 

6:23;20:22;25:24; 128:12,16,25; Center (14) 159:14 chaired (2)

 30:5;33:14;34:17; 143:6;148:11 24:15,19;31:6,8; certifier's (1) 127:25;129:9 

35:16;37:23;39:16; capabilities (2) 34:19,21;39:4;43:19; 65:22 chairman (1)

 53:10;59:23;60:20; 10:15;39:2 58:19;68:14;69:5; certifies (1) 162:25 

73:18;80:17;82:20, capacity (8) 72:14;74:19;93:18 37:18 Chair's (1)

 21;102:11,18;125:13, 11:13,20;37:23; centered (1) certify (3) 16:12 

20;132:7;133:4; 49:17;65:2,17;94:5; 129:16 97:7;99:17;107:12 challenge (10)

 143:17;167:2 165:22 centers (3) certifying (4) 30:23;84:8,11;

called (15) capital (3) 49:12;78:4;116:1 99:22;105:15; 91:18;112:21;114:13;

 20:20;21:6,7,9,10, 7:15;14:7;76:7 central (3) 106:13;148:20 115:2;119:16,17;

 12,14;22:25;23:2; care (2) 74:25;82:5;105:2 chain (18) 141:8 

24:20;40:21;46:15; 109:20;135:12 century (1) 32:17,19;35:12; challenged (1)

 80:8;126:13;159:1 carefully (1) 10:25 39:12,22;40:4,7,10, 165:12 

calling (3) 62:6 certain (4) 12,17;46:13,19;62:11, challenges (15)

 31:13,14;163:23 Carlow (1) 30:17;40:1;65:5; 16,24;63:14;64:3; 27:13;39:6;45:5;

callout (1) 72:16 68:21 167:10 46:14,16;58:17;

 149:21 Carolina (3) certainly (3) chains (4) 64:17,21,22;113:15,

calls (9) 14:12;22:3;80:15 54:20;55:16;167:4 34:10;35:11;63:6, 22;115:24;120:18;

 27:12,14;33:12; Carolyn (17) certificate (5) 23 165:4;167:4 

39:15;41:12;63:3,5; 15:4;64:12,12; 36:5,6,18,18;37:6 chair (216) challenging (4)

 79:5;126:12 66:10,23;133:17; certificates (5) 6:2;9:5,14;10:10, 56:6,13,14;115:25 

came (5) 134:19;136:19; 32:18;33:19;36:9, 12,17,19;11:21,23; chance (6)

 32:21,22;67:23; 145:13;147:14; 11;37:2 14:25;16:11;24:3,6; 18:13;23:6,8;37:7;

 90:12;112:5 150:15;155:8;157:10; certification (32) 45:9;47:7;51:6,12; 161:10;163:17 

can (118) 161:24;165:17; 12:1;19:7,9,15; 55:19;58:14;60:15; change (5)

 14:5;15:16;20:16, 166:15;167:13 22:13;26:2;30:18; 64:11;66:9,25;69:8, 58:4;67:17;105:23;

 23,25;21:15;24:15, Carolyn's (1) 33:18;40:6;41:1,8,13; 11;71:3;77:9;110:22; 109:8;149:10 

19;26:5;29:5;30:9,20, 167:9 42:13;72:9;74:17; 112:1,4;113:2; changed (1)

 25;33:13,15;34:4,16; carried (1) 82:4;89:20,24;91:21; 115:13;116:16; 138:3 

36:8;40:14,15,25; 49:3 92:11;94:2,15;99:4; 117:13;120:7;122:24; changes (6)

 42:20;43:10,12; carrots (3) 100:4,5,9,11;106:4; 123:23;124:3;126:17; 46:7;48:16;49:9,22;

 44:15;45:13;47:20; 14:21;18:18;19:3 107:5,22,24;109:4 127:3,22,24;129:2,5, 77:21;102:8 

48:2,4;49:8;51:2,18; carry (2) certified (50) 7,13;130:4,15;131:16, Chapter (1)

 52:11;54:23;55:4,8, 12:24;154:9 15:11;19:2;20:11; 21,25;132:13,16,22, 98:8 

14;56:12;57:13; case (5) 21:5;23:12;26:6,7,7; 24;133:1,4,7,9,11,13, chapters (1)

 58:13;59:13;60:1,15; 32:1;75:17,23; 27:12;31:16;32:17; 15,17,19,19,23;134:1, 90:3 

63:20;64:7,9,21;65:6, 138:6;156:17 35:25;36:2;39:25; 3,5,7,9,11,13,15,17, charged (2)

 6,23;66:3;68:21,23; cases (13) 40:9,10,13,16,17; 19,21,21,23;135:1,1, 48:20;50:10 

76:1;77:9,19,19;79:9, 18:17;39:8;41:22; 42:22,22,24;43:3; 6,23;136:4,7,9,11,13, charges (1)

 19;81:2;85:14;86:18; 42:7,8,11,11,18;43:7, 61:14;62:1;65:4;72:5; 15,17,19,21,23,25,25; 41:17 

89:5,10;90:4;93:12; 8,10;78:9;140:23 75:23;76:24;77:3; 137:4;139:2;140:9, Charleston (1)

 94:23;95:1;97:17; CashApp (1) 78:15;81:5,7,12; 25;141:4,10,13,22; 104:20 

100:10,12;102:17,20; 119:6 82:16;87:5;93:9,12, 142:11;143:4,9; check (2)

 104:2;106:14;107:7; casings (1) 20;94:24,25;98:22, 144:24;145:1,3,5,7,9, 23:2;55:13 

111:18;112:2;114:16, 167:19 24;102:5;104:5,16; 11,13,15,17,19,21,21, checked (1)

 20;115:1;116:22,23; catch (3) 107:12;108:12;109:1; 24;146:5,22;147:2,4, 152:11 

118:12,24;120:25; 24:22;149:22;152:4 131:19 6,8,10,12,14,16,18,20, checking (1)

 122:10;123:11;124:1, cattle (2) certifier (11) 22,24,24;148:2;149:4, 127:24 

19;125:20;126:14; 161:11;165:6 11:25;25:22;36:21; 21;150:3,7,9,11,13, chemical (2)

 128:9,18,18;129:1; caught (1) 39:24;40:19;55:11; 15,17,19,21,23,25; 91:16;115:1 

131:1,6;139:4,10,14; 168:4 65:21,24;66:5;152:7, 151:2,4,4,7;154:12, chemical-based (1)

 140:22,22;146:16; cause (2) 12 23;155:2,4,6,8,10,12, 86:7 

149:19;150:2;153:23; 107:16;159:4 Certifiers (44) 14,16,18,20,22,24,24; chemicals (5)

 158:7;159:4,9; cauterize (1) 0:21;25:18;30:9; 156:3;157:2,6,8,10, 20:1;76:18;80:6;

 160:25;163:3,4; 156:7 31:20;32:20;34:2,12, 12,14,16,18,20,22,24; 114:15,22 

Min-U-Script® Burke Court Reporting & Transcription (5) calf - chemicals 

(973) 692-0660 
 NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 3 

November 24, 2023 

Chesapeake (1) close (14) 107:6;108:8;124:4 Committee (10) 42:23 

71:19 6:13,15;11:19;15:7; collect (1) 0:10;77:13,14,23, complaints (5)

Chesire (1) 22:10;43:25;50:15; 37:19 25,25;131:25;139:5; 26:1,3;42:9,18;43:6 

89:2 53:9;108:11;109:16; collective (5) 141:16;163:7 complete (1)

chestnut (1) 123:3,3;141:15;168:9 46:19,20;50:25; committees (1) 28:22 

76:20 closed (4) 119:20;120:4 114:2 completed (1)

chicken (5) 42:10;43:8;141:24; collectively (2) Committee's (2) 0:13 

163:22;164:14,15; 142:9 58:13;105:1 6:11;154:19 complex (4)

 165:9;166:19 closely (3) collectives (2) common (1) 8:24;39:21;55:17;

childhood (1) 23:19;27:3;41:24 119:21;120:3 164:20 66:24 

19:6 closest (1) College (2) Commonwealth (2) complexion (1)

children (6) 79:14 93:19,21 85:2;102:5 91:6 

16:18;17:14;19:18; closing (3) collegiality (1) communal (1) complexity (1)

 21:18;22:15;23:22 11:10;83:4;126:5 10:15 118:4 107:21 

choice (2) Closter (1) Colombia (1) communicate (1) compliance (20)

 20:25;32:19 87:4 74:15 30:13 8:23;25:11,23;

choking (1) clueless (1) color (4) communicating (1) 26:10;27:4;39:1,1;

 16:16 63:15 78:18;91:8;104:1; 44:14 40:23;42:12,15;54:3,

choose (2) cluelessness (1) 125:2 communication (4) 3,10;57:23;97:4;

 34:5;90:10 63:18 Colorado (3) 43:17;72:16; 128:11,13;148:10;

choosing (1) clueness (1) 13:12;126:1,1 121:11;122:9 149:6,17 

20:24 63:18 combine (1) communications (1) compliant (3)

chosen (1) clustered (1) 62:12 81:21 38:6;94:13;138:23 

58:12 85:17 combined (1) communities (14) complicated (3)

Chris (3) Coalition (3) 161:16 49:15;52:3;78:3,8, 65:20;66:18;137:16 

92:8,11;97:19 102:2;104:13,19 comfortable (2) 18,21;79:14;80:16; compliment (1)

chunks (1) co-chair (1) 112:19,19 89:9;96:14;109:12; 71:13 

34:25 90:2 coming (9) 110:8;120:24;125:11 comply (1)

circulated (1) coffee (3) 18:23;26:3;30:2; community (60) 63:12 

67:20 24:4;106:18,24 42:3;69:5,23;72:16; 9:7,12;15:19;21:13, compost (2)

cities (2) cognizant (1) 89:15;129:5 19;22:7;23:2;27:17; 12:6;122:15 

95:3,13 53:6 comment (15) 28:11;29:11;33:9,9; comprehensive (1)

civil (5) Co-Hops (3) 15:14;47:9;51:24; 34:1;35:9;36:20; 54:2 

41:15;42:14,16; 105:7;106:7;126:19 55:9;58:16;60:13,17, 37:16;39:4;43:12; compression (1)

 48:19;80:12 cohort (9) 25;61:8;63:15;66:12; 50:4,22,24;53:20; 56:1 

claims (1) 88:7,9,12,15,20; 128:6;131:10;163:13; 54:21;61:20;66:3; compromise (1)

 17:20 89:1,9,15;90:17 166:2 67:23;74:1;78:10; 144:13 

clarification (2) cohorts (1) commenter (2) 81:11;82:2,17;84:18; computer (1)

 132:16;151:22 100:1 19:21;156:21 85:20;87:10,13;88:7, 81:23 

clarity (6) cohost (1) commenters (3) 16;93:19;96:10,15; comradery (2)

 19:9;151:17,19; 88:12 56:3;146:18;159:16 98:12,20;99:25; 109:19;127:20 

152:3,6;153:11 cohosted (2) comments (26) 106:9;112:16;120:11, concept (1)

Clark (1) 89:1,8 20:18;47:25;51:15; 16;125:18;126:3,12; 124:20 

6:24 coincidence (1) 58:16;61:3;67:23; 129:16;131:3;144:10; concern (5)

class (3) 123:21 68:2;124:6;135:15; 152:6;163:6,19,21; 51:16;59:1,22;

 15:5;138:17;146:15 cold (2) 146:19;148:15,25,25; 164:3;165:13;166:25 143:13;168:5 

Claypool (1) 92:21;166:5 150:4;153:10,12,14, community-based (1) concerned (2)

 7:18 collaborate (1) 25;154:24;156:18,25; 106:8 26:11;63:3 

clean (2) 96:24 157:3;159:13;161:18; companies (2) concerns (11)

 18:3;76:18 collaborated (1) 163:14;166:22 119:16;120:1 15:15;39:22;51:19;

cleaner (2) 109:23 commercial (5) compared (1) 52:11;56:12;61:4;

 151:10;153:3 collaborating (4) 119:15;131:17; 140:13 138:10;144:10,12;

clean-up (1) 73:8;75:6;120:24; 139:21;141:2;143:12 compete (2) 151:16;153:20 

12:11 153:9 commercially (2) 56:21;120:2 concurrently (2)

clear (4) collaboration (5) 138:4;143:16 competency (1) 48:23;49:25 

21:2;58:10;143:17; 38:13;72:1;96:22; Commission (6) 144:4 conditions (1)

 164:15 109:11,19 48:1,5,12,21;50:1,5 competent (1) 35:11 

click (2) collaborative (2) commissioner (1) 82:3 conduct (1)

 68:15;86:18 30:19;108:17 48:6 competing (1) 106:2 

climate (11) colleague (2) commitment (3) 17:20 conducting (3)

 31:2,5,11;67:3,6,9, 98:3;128:5 79:15;81:4;84:17 competitive (2) 22:17;58:21;82:1 

17;68:9;76:21;80:8; colleagues (6) committed (2) 117:20;119:9 conference (6)

 110:16 8:2;23:3;66:20; 80:14;83:5 complaint (1) 96:11;99:5,24; 

Min-U-Script® Burke Court Reporting & Transcription (6) Chesapeake - conference 

(973) 692-0660 
 NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 3 

November 24, 2023 

100:4;103:4,6 153:21 convert (1) count (1) 118:11;120:2 

conferences (2) contacted (1) 12:25 128:14 credible (1)

 91:6;114:16 33:13 converting (1) counterpart (1) 39:22 

confidence (1) containers (6) 91:15 100:20 credits (1)

 33:5 53:2,6,8,20;54:12, convince (2) counting (1) 68:19 

confidently (1) 20 47:14;129:6 128:16 Creole (1)

 100:12 contemplating (1) cool (3) countries (8) 122:7 

conform (1) 56:7 89:21;101:12;103:5 12:22;36:20;64:18, criminal (2)

 141:7 contending (1) co-op (7) 19;65:1,4,5,11 42:8,8 

confusion (1) 105:19 17:25;21:7;105:7; country (20) crisis (1)

 160:9 context (1) 106:7;116:24;126:20; 16:18;20:1;21:24; 107:17 

Congress (2) 62:9 127:2 22:5,17;27:19;28:19; criteria (3)

 47:15;59:12 continually (1) cooperating (1) 37:24;47:24;56:11; 30:9;137:23;139:11 

Congressman (2) 142:7 7:24 65:22;72:22;75:25; critical (6)

 90:16,20 continue (18) cooperation (1) 76:7;77:8,19;84:14; 7:21;73:3;91:11;

connect (3) 6:11,12;10:8;27:25; 74:2 109:17;125:18; 98:16;137:14;138:12 

78:7;108:25;111:17 44:20;45:5;47:15,19; cooperative (7) 127:13 Croix (2)

connected (2) 50:14;58:24;64:2; 49:18;92:23; counts (1) 113:13;120:15 

56:17;58:9 67:21;75:12;85:4; 108:17;110:11,11; 33:4 crop (10)

Connecticut (6) 99:18;129:19;154:17; 143:17;167:2 County (4) 16:13,23;17:5;

 98:8,10;99:2,8,23; 163:4 Co-Operative (2) 76:13;89:2;94:9; 30:15;89:13;119:13,

 100:12 continued (1) 117:3,4 106:9 15;143:17;161:10;

connecting (1) 95:15 Co-Ops (1) couple (12) 167:2 

83:14 continues (3) 126:19 9:2;12:19;26:24; crops (17)

connections (3) 30:5;58:25;63:18 coordinate (2) 31:7;43:11;48:14; 13:2;14:22;22:1,2;

 59:10;75:2;78:19 continuing (6) 47:11;104:25 106:20;111:21;112:5; 31:11;56:2,2;87:6;

consensus (2) 48:19;64:1;74:6; coordinated (2) 114:21;153:25;159:7 89:11;95:4,9,12;

 153:1,13 89:14;91:10;165:13 73:25;75:22 coupled (1) 117:22;131:12;

conservation (9) contract (1) coordinating (1) 102:6 156:15;157:1;161:3 

10:23;13:23;14:5; 119:22 30:22 coupling (1) cross (1)

 68:6,21;86:22;89:2; contracted (1) coordinator (3) 159:20 68:9 

102:13;111:17 17:2 88:5;89:20;94:20 courage (1) crossed (1)

consider (3) contracts (2) copy (1) 51:2 105:24 

78:20;81:22;119:18 57:15;119:20 49:6 course (6) crosswalk (3)

consideration (1) contribute (3) core (8) 24:19;34:19;39:7; 67:3,6;69:4 

119:4 66:2;123:9;153:23 28:21;47:22;74:13, 66:17;110:8;112:4 crowd (5)

considered (3) contribution (1) 23;75:4,12;78:16; courses (2) 9:16;24:16;60:16;

 42:14;67:9;146:17 109:11 83:19 39:3,11 149:21;167:1 

considering (1) control (6) Corn (4) cover (3) crown (2)

 29:2 27:24;30:25;37:14; 55:25;56:5,5; 68:22;96:5;139:13 53:10;142:5 

consistency (2) 38:23;46:1;156:6 166:12 covered (1) crunchy (1)

 34:16;152:12 controls (1) corners (1) 41:2 86:25 

Consistent (1) 38:3 22:5 covers (2) CT/NOFA (1)

 75:14 controversial (1) Cornia (2) 24:17;71:18 100:3 

constantly (2) 159:15 85:9,11 cow (1) cull (1)

 17:17;96:21 Conventional (14) corral (1) 17:24 79:18 

constructive (1) 86:6,7,20;90:10; 102:12 cowboy (1) cultivating (1)

 110:12 91:13,16;94:3,13; corralling (1) 123:17 81:11 

constructs (2) 114:4,12;115:4,6; 97:25 cows (4) cultural (2)

 52:21;65:16 116:23;166:8 corrected (1) 20:6;21:6;89:4; 81:13;124:23 

consulting (2) conventionally (1) 83:7 161:12 culturally (1)

 99:3,21 93:9 correcting (1) crack (1) 82:3 

consumer (7) conversation (18) 124:23 91:12 culture (1)

 10:3,12;17:19;33:5; 32:10;46:4;47:1; corrections (1) craft (2) 105:19 

51:12,14;77:2 49:23;50:12,13,18,19; 16:8 96:18,24 curious (4)

consumers (6) 53:7,22;65:14;66:24; corrosiveness (1) create (8) 72:25;116:9;

 22:20;45:3;47:23; 67:19;112:24;164:16, 153:22 74:24;75:1;78:14; 141:19;161:3 

51:15;52:3;79:16 19;165:10,20 cost (2) 88:8;93:15;94:7; current (3)

consuming (1) conversations (12) 41:18;122:20 120:3;143:23 52:2;93:10;116:22 

66:14 7:25;34:8,15;46:18; costs (2) created (2) currently (10)

contact (5) 47:3;50:8;52:18,19; 41:15;122:14 109:13;126:20 12:17;43:7;76:16;

 61:11;74:25; 68:1;81:19;119:25; Council (2) creating (5) 77:1;86:24;93:20;

 102:22;151:11; 161:6 10:5;90:2 75:20;94:2;104:22; 97:12;99:12;106:4; 

Min-U-Script® Burke Court Reporting & Transcription (7) conferences - currently 

(973) 692-0660 
 NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 3 

November 24, 2023 

125:25 

curve (1)

 40:2 

customer (2)

 27:11,14 

customers (1)

 72:25 

customized (1)

 82:3 

Customs (9)

 38:8,14;41:4,5,11,

 16,21;42:1;59:5 

cut (1)

 16:15 

cuts (1)

 166:5 

23:20;27:12;45:2,6;

 48:13;63:19;69:22;

 84:19;103:8;118:24,

 24;126:12;168:14,15 

days (7)

 16:13;17:5;22:11;

 42:2;43:9;111:21;

 164:9 

dazzling (2)

 104:9,9 

DC (6)

 25:1;27:16;78:5;

 81:15;90:24;123:17 

Dead (2)

 126:13;149:17 

dealing (1)

 62:24 

dear (1)

 128:5 

Dehne (4)

 104:10;107:4,5;

 117:2 

DEI (1)

 78:17 

DEIA (1)

 50:8 

DEIJ (1)

 116:5 

Delaware (3)

 81:15;83:25;87:12 

deliberation (1)

 52:20 

deliberative (1)

 54:11 

delicious (1)

 167:24 

delightful (2)

 73:6;116:20 

deployed (1)

 111:23 

deposits (1)

 153:16 

Deputy (6)

 0:4;8:16;24:7;27:5;

 44:8;71:4 

describe (2)

 80:10;161:7 

described (1)

 152:21 

describing (1)

 124:3 

deserts (3)

 78:9;79:11;118:2 

deserve (2)

 22:15;50:24 

deserves (1)

 145:22 

9:6 

devoted (1)

 26:12 

diagrams (1)

 52:24 

dialogue (3)

 46:11,12;67:22 

Diana (14)

 71:10;72:1,2,4,6,

 12;73:11;85:12;

 87:22;90:4,25;

 105:23;107:7;127:15 

difference (5)

 56:23;91:5;102:24;

 148:24;154:6 

different (35)

 24:18;26:6;27:25;

 28:19;31:25,25;

 33:20,21;34:23;

D 

dad (4) death (1) delist (1) designated (1) 56:22;68:4,7,15,16;

 12:23;16:19;19:7; 146:17 132:1 0:12 72:22;86:13;95:20;

 22:10 decade (1) delisting (1) designed (4) 96:13,16;97:25;

dairies (1) 72:8 135:25 32:15;35:8;49:14; 99:10;103:15,17;

 76:12 decades (3) deliver (3) 76:18 108:22;112:17;

dairy (10) 12:20;20:12;82:6 15:18;90:12,13 designer (1) 115:17;116:5,8;

 22:5;76:3;88:21,23; decided (4) deliverable (4) 14:10 128:19;152:20,23;

 89:4;93:7;95:17;97:3, 20:2;102:9,11; 86:10,14,14;112:16 despite (1) 156:13,14;165:5,11 

9;107:17 103:7 deliverables (1) 153:11 differently (1)

damage (1) decision (3) 93:23 destroyed (1) 42:21 

17:12 100:12;139:11; demand (5) 118:9 differing (1)

damaged (1) 141:8 47:21;57:12;95:11, detail (4) 138:1 

86:18 decline (3) 13,16 25:8;29:12;99:6; difficult (4)

D'AMORE (16) 107:11,14,16 demanded (1) 113:21 47:3;57:5;64:17;

 11:8,9;60:11;62:20; decrease (1) 152:3 details (1) 138:6 

123:1,15;133:3; 62:15 demographic (2) 94:14 digestible (1)

 134:6;136:6;141:6, dedicate (1) 102:8;115:17 deter (1) 34:25 

11;144:25;147:1; 13:7 demographically (1) 13:5 digitally (2)

 155:19;157:21; dedication (1) 116:2 detergents (1) 122:2,9 

162:10 13:4 demographics (3) 153:18 Dilip (14)

Danby (1) deep (1) 71:22;103:17;116:4 determination (1) 11:2;112:1;113:2;

 76:25 37:8 demonstrate (2) 17:12 120:7;133:1;134:3;

data (8) deepen (1) 30:17;160:24 determine (2) 136:4;142:11;144:22;

 26:21;27:2;28:12; 112:25 demonstrated (1) 49:7;151:23 147:22;150:23;

 30:13;38:7,11,12; Deer (1) 109:20 Detroit (1) 155:16;157:18;162:7 

59:6 82:20 demystify (1) 22:13 diminish (1)

database (8) Defense (1) 100:11 develop (7) 61:5 

26:23;30:3,10; 10:4 demystifying (2) 27:20,21;68:3;88:9; Dimitri (15)

 35:20,22,23;36:7; deficit (2) 94:2,14 90:13;121:22;168:4 15:4;66:11;133:18;

 59:16 125:3,4 denying (1) developed (7) 134:20;136:20;

date (4) defined (2) 52:5 16:24;50:1;74:10; 145:14;147:15;

 37:3,4;87:3;88:16 154:8,8 deodorize (1) 78:17;83:6;88:6; 150:16;155:9;157:11;

daughter (1) defines (1) 156:7 143:20 161:25;165:19;

 22:11 144:17 deodorizer (1) developing (6) 167:14,20,22 

David (1) definitely (7) 156:23 27:23;77:15;94:11; dip (2)

 8:17 108:13;111:24; Department (6) 109:3;117:20;121:16 148:4,12 

DAVIS (5) 112:22;113:10; 8:19;42:7;44:18; development (10) direct (7)

 89:17,17;113:5; 114:13;115:2;116:3 65:12;98:13;168:3 28:12,12;29:24; 7:14;24:21;79:16;

 114:3,11 definitive (1) departure (1) 57:15,16;75:18; 94:5;111:9;117:18;

Davison (1) 44:17 64:16 90:19;117:8,24; 151:11 

88:1 deflated (1) depending (1) 165:23 directed (1)

day (20) 87:19 42:21 Devin (4) 157:1 

8:3;10:5;16:16; degree (2) depends (1) 85:8,9;87:23;102:6 direction (1)

 18:19;20:14;22:21; 58:5;72:15 32:2 devote (1) 95:22 

Min-U-Script® Burke Court Reporting & Transcription (8) curve - direction 

(973) 692-0660 
 NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 3 

November 24, 2023 

directives (2)

 40:19,24 

directly (10)

 7:23;16:14;27:7;

 60:3;73:7;75:8;93:22;

 112:15;121:22;127:5 

Director (11)

 8:6,20;72:5,7,17;

 85:10;92:11;98:7;

 101:7;104:12;107:5 

directs (1)

 38:1 

disallowing (1)

 54:25 

disappeared (1)

 166:5 

disclose (1)

 58:22 

discovered (4)

 20:11;21:20;80:20;

 104:15 

discrimination (1)

 48:18 

discussed (3)

 89:7;132:11;152:11 

discussion (10)

 28:7;50:15;52:17;

 111:24;116:3;131:20,

 22;153:4;154:11;

 157:3 

disease (2)

 140:24;144:16 

diseases (2)

 140:21;142:24 

disinfect (1)

 131:14 

disinfectant (2)

 130:8,10 

disinfectants (1)

 131:4 

dismantling (1)

 91:3 

disparities (1)

 49:2 

dissent (1)

 135:20 

distributed (1)

 123:21 

Division (1)

 8:21 

DMI (1)

 97:4 

DMV (1)

 76:13 

document (3)

 32:5;68:11;152:22 

documented (2)

 125:25,25 

dogged (1)

 17:12 

doggedly (1)

 69:11 

dollars (2)

 143:22;165:2 

domestically (1)

 40:23 

don’t (6)

 12:8;39:13;41:8;

 118:2;161:4;167:6 

done (32)

 17:12;19:25;31:1,

 22;33:20;39:11;

 40:23;42:16;43:18,

 20;47:11;54:2,15,16;

 56:25,25;61:3;64:21;

 67:9;75:11;90:15;

 97:2;108:5;111:3;

 112:14;114:14;122:2;

 142:5;144:11;146:22;

 161:15;167:6 

Donna (1)

 82:20 

don'ts (1)

 124:25 

dos (1)

 124:24 

double (1)

 152:15 

doubled (1)

 25:12 

doubling (1)

 39:25 

down (12)

 0:17,19;9:21;15:2;

 82:11,12,16;83:10,15;

 110:9,23,24;113:5,6;

 114:9;117:17,25;

 118:24;119:13;120:6,

 8;121:2;122:23;

 123:13,16,23;124:1,8;

 127:6,7,10;141:23;

 149:8,12,16,24;150:1 

draw (1)

 86:19 

drawing (1)

 100:18 

drive (5)

 22:20;23:3,7;59:15;

 119:7 

driven (1)

 32:24 

driver (1)

 104:5 

drop (3)

 23:7;63:18;107:13 

dropped (1)

 65:3 

dry (1)

 38:9 

due (3)

 56:6;93:10;104:9 

dumped (1)

 80:16 

dunk (1)

 137:9 

duo (1)

 104:9 

Duquesne (1)

 72:13 

during (12)

 21:25;45:17;50:16;

 58:16,18;60:13;63:7;

 74:22;79:7;80:1;

 100:9;104:15 

duster (1)

 16:13 

dusting (2)

 16:24;17:5 

8:3;40:5;56:8;

 146:14 

easiest (1)

 62:17 

easily (4)

 37:22;68:22;

 111:23;135:18 

east (4)

 94:9;96:19,20;

 103:16 

Eastern (2)

 69:24;87:11 

easy (5)

 42:25;43:1,1;62:12;

 164:5 

eat (1)

 128:25 

eaten (1)

 128:17 

eats (1)

 166:12 

ebb (1)

 25:4 

echoed (1)

 135:16 

ecologically (1)

 80:23 

economic (2)

 21:18;58:11 

economics (1)

 97:7 

economy (1)

 85:1 

edge (1)

 86:21 

educate (3)

 19:24;72:23;114:14 

educating (2)

 63:21;94:3 

Education (5)

 72:14;93:2;106:2,

 21,22 

educational (5)

 76:10;78:22;93:18,

 20;101:17 

educator (1)

 95:20 

110:3 

efforts (9)

 10:8;55:22;93:15,

 17,23,25;113:6,10;

 114:1 

egg (2)

 163:22;165:9 

eggs (2)

 164:7;166:20 

eight (1)

 126:22 

either (5)

 58:4;75:10;93:9;

 118:8;120:3 

elaborate (1)

 45:13 

elated (1)

 15:12 

elections (1)

 6:14 

electrolytes (7)

 140:3;146:7,7,8,12,

 14,16 

electronic (1)

 32:18 

elements (2)

 27:25;56:22 

elevating (1)

 124:7 

eligible (1)

 91:20 

eliminate (2)

 48:16,17 

Elon (1)

 124:18 

else (7)

 10:16;22:16;71:23;

 119:25;128:2;140:15;

 141:7 

email (2)

 62:21;103:3 

emailers (1)

 61:13 

emails (1)

 61:12 

embedded (1)

 32:5 

E 

25:6 31:23;50:2;71:16; eager (2) educators (4) emerged (1)

distribution (1) 85:6,20;94:9;101:9; 78:6;112:25 95:20;96:4,5,8 46:17 

42:17 135:8 earlier (5) effective (10) emergency (1)

District (3) Downey (3) 48:24;92:13;100:2; 36:24;130:19,24; 0:16 

74:15;89:2;90:23 88:1,4,6 101:14;102:6 131:1;137:16;138:12; emphasize (4)

diverse (6) downstream (2) early (9) 159:2;160:15,20; 53:5;54:1;62:1;

 48:2;85:14;88:6; 151:19,20 12:24;20:8;36:13; 161:13 82:6 

95:9;117:23,23 dozen (1) 46:21;69:22;71:24; effectively (3) employee-owned (1)

diversification (1) 60:14 72:1,21;102:9 23:19;53:24;55:15 17:24 

97:9 DR (54) earnestly (2) effects (2) employees (1)

diversify (1) 0:3;6:20;7:10;9:10; 18:5;19:12 50:2;64:10 17:18 

125:19 15:4;24:9;45:16;48:7; Earth (1) effluent (1) encompasses (1)

diversity (4) 51:21;55:6;56:15; 18:17 153:3 138:16 

71:22;103:14; 59:2;61:7;63:17; ease (1) effort (7) encounter (2)

 104:2;128:7 64:24;66:23;67:12; 159:22 30:19;32:7;52:2; 115:15,19 

divine (1) 71:5;73:14;79:3,5; easier (4) 61:18;73:25;103:23; encourage (5) 

Min-U-Script® Burke Court Reporting & Transcription (9) directives - encourage 

(973) 692-0660 
 NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 3 

November 24, 2023 

35:3;47:19;51:4; 46:24;123:2,4 154:19 evolve (2) existing (5)

 114:7;164:25 enthusiastic (1) established (2) 115:2;129:19 52:21;57:17;97:9;

encouraged (1) 106:5 55:9;86:20 exact (1) 102:2;112:7 

88:12 entire (7) Esu (5) 95:25 exists (1)

encourages (2) 35:12;85:20;96:1; 7:6,6,11;13:15; exactly (4) 121:21 

82:5;138:19 109:13,17;138:17; 14:17 20:2;123:10; exit (3)

encouraging (1) 165:24 etc (1) 154:18,20 37:22;58:5;64:25 

48:1 entities (2) 13:2 example (24) exits (1)

end (15) 86:8;116:22 ethanol (11) 26:1;37:20,24;38:2; 0:16 

0:17,18;11:4;14:9, entity (1) 130:7,8,10,20; 39:6;41:25;42:12,20; expand (6)

 23;63:7,14;66:12; 32:16 131:4,9,13,19;132:1, 46:9;64:8;68:6,8,16, 56:9;89:16;96:3;

 67:24;96:19,20; entomologist (1) 18,20 20,21,24;76:2;77:6; 103:12;104:2;116:23 

107:15;128:14;138:9; 13:21 ethos (1) 99:5,14;108:3;110:9, expanded (4)

 167:17 entrepreneurs (1) 74:19 10;160:4 44:9;79:23;96:6;

ended (2) 104:23 EU (3) examples (2) 127:1 

68:11;100:18 entrepreneur's (1) 35:19;45:19;46:9 35:19,19 expands (1)

ends (3) 161:9 European (1) excellent (1) 97:1 

0:16;65:22;165:25 entry (1) 46:9 161:15 expansion (1)

enduring (1) 98:23 evaluated (1) except (1) 161:2 

48:16 environment (6) 30:1 142:20 expansive (1)

enforce (1) 20:17;21:1;72:12; evaluating (1) exception (2) 125:18 

55:15 73:4;80:15,19 65:15 23:25;142:22 expect (1)

enforcement (22) environmental (8) even (22) exceptional (1) 104:17 

25:11,23;26:10; 13:23;14:10;21:17; 26:17,25;38:12; 6:17 expecting (1)

 27:4;28:2;32:9,13,23; 72:10,14,18;80:17; 43:11;53:13;56:10; excerpted (1) 107:14 

36:7;37:21;38:5;39:1, 153:19 57:6;63:4;64:16; 34:25 expense (1)

 15;40:6;46:4;53:11, EQIP (1) 81:23;99:19;100:11; excited (25) 105:17 

15;54:10;56:19; 68:8 102:23;104:18,25; 10:5,9;11:4;12:5,6; expensive (3)

 57:23;59:12;60:8 equal (1) 105:16;118:2,11,17; 13:2;14:14,15;86:15; 41:20;122:20;

engage (5) 25:17 122:5;125:9;144:6 90:14;91:7;92:22; 126:24 

29:5;48:4;84:8; equalize (1) event (2) 97:14;98:8;99:14,19; experience (11)

 144:6;168:7 81:2 0:23;84:17 100:23;106:15;107:6; 12:19,20;22:19,19;

engaged (4) equally (1) events (29) 109:2;114:18;115:3; 39:17;50:20;52:13;

 28:18,19;40:18; 115:9 28:25;29:7,9,17; 130:22;162:24; 72:9;82:4;100:24;

 86:24 equation (2) 57:13;75:8,11,15; 166:22 125:8 

engagement (3) 30:25;76:23 77:18;86:18,19;87:3, exciting (10) experienced (2)

 15:17;67:17;81:10 equipment (6) 10,13;88:10,13,16; 48:8;67:7,12;84:22, 99:4;109:1 

engaging (1) 80:7;89:12;151:10, 93:25;94:10;95:18, 23;90:5;97:16;98:1; experiencing (3)

 50:7 19,21;153:16 23;96:9,12,18,19,22, 103:2;106:13 29:13;46:17;58:17 

England (4) equitable (2) 24;106:16;126:6 excluded (7) expert (2)

 34:18;71:13,15; 48:3;79:19 everybody (14) 137:17,17,21; 100:5;106:24 

93:16 Equity (11) 9:15,21;12:13; 138:18;142:15,15,19 expertise (3)

English (2) 48:1,4,12,18;50:1, 13:10;25:1;32:7; exclusion (1) 7:13;39:17;88:10 

72:15;122:4 5;78:1;91:1,2;103:23; 36:23;37:1;40:16; 20:22 expertly (1)

English-based (1) 128:7 59:24;71:5;79:4,5; Excuse (2) 22:23 

122:5 equivalency (5) 143:24 92:21;117:25 experts (1)

enhance (2) 26:19;35:18;38:19; everyday (1) executed (2) 130:24 

34:10;82:2 45:15;46:5 19:13 22:23;117:16 explain (4)

enjoy (1) equivalent (4) everyone (18) executive (6) 35:13;57:13,14;

 158:10 38:21;45:21;46:7; 0:3;9:17;10:2; 72:5,7,17;85:9; 142:18 

enough (5) 138:4 19:24;23:24;24:3; 98:7;104:12 explaining (1)

 10:18;57:20;85:13; Erin (3) 32:11;37:10;40:10, exempt (1) 43:25 

98:4;123:3 8:6,8,13 10,12;50:22;56:20; 61:17 explains (1)

enrolled (1) ESG (1) 79:2;87:21;88:2; exemptions (2) 82:4 

125:9 14:7 94:17;112:7 40:8;61:9 explanation (2)

enroute (1) especially (9) Everyone's (1) exercise (1) 44:1;140:10 

15:5 38:24;90:12; 28:3 142:4 explicit (2)

ensure (5) 105:20;111:11,13; everywhere (1) exercises (1) 69:5;142:22 

64:22;79:23;81:4; 113:18;115:17; 23:24 40:22 explicitly (1)

 83:8;100:10 122:13;129:13 evidence (2) exist (3) 164:23 

ensuring (2) essential (2) 41:8,13 26:17,25;118:20 explore (1)

 140:20;148:16 146:18;153:15 evolution (1) existed (1) 163:19 

enthusiasm (3) essentially (1) 110:6 87:15 export (1) 

Min-U-Script® Burke Court Reporting & Transcription (10) encouraged - export 

(973) 692-0660 
 NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 3 

November 24, 2023 

36:20 

exporters (2)

 34:3;57:25 

exporting (1)

 35:25 

exposed (1)

 17:4 

exposure (1)

 79:25 

express (1)

 124:22 

expressed (2)

 118:3,5 

extend (2)

 99:17;102:2 

extending (1)

 42:3 

extends (1)

 71:16 

extension (9)

 54:3;90:6;92:23;

 93:5;98:14;99:1;

 102:13;115:4;121:15 

external (4)

 156:6;159:3,5,8 

extra (3)

 29:21;30:6;161:7 

extremely (3)

 55:25;66:13;77:14 

eye (1)

 65:4 

eyes (2)

 18:22;153:22 

162:21 

fair (5)

 45:23,23;56:20;

 65:9;142:8 

fairly (3)

 34:25;40:3;98:10 

Fall (10)

 0:6;23:25;44:16;

 54:4;109:7;129:22;

 135:16;148:25;

 156:25;164:21 

false (1)

 20:25 

famers (1)

 56:13 

familiar (2)

 84:7;102:4 

family (14)

 12:23,25;16:20;

 20:17;22:10;76:12;

 82:11,23,25;83:1;

 125:10,10;167:23;

 168:8 

family's (2)

 14:11;22:19 

fan (1)

 159:23 

fantastic (1)

 168:15 

far (7)

 23:17;75:6,11;

 121:11;156:23;159:9,

 9 

farm (47)

 11:14;13:1;14:12,

 14;19:10;22:15;

farmers (148)

 15:13,13;20:19;

 21:19;22:9,18;23:5,

 20;27:12;29:1,12;

 31:9,17;50:10;56:4;

 57:10,14,17;62:9;

 66:1;69:3;73:7;75:7,

 9,15,22;76:2;78:2,4,

 21;79:15,17,20,22,24;

 80:15,20;81:4,5,17,

 22;82:3,7,7,8;83:5;

 84:8,13,19,21;85:20;

 86:2,6,6,7,8,23;88:8,

 11,14,17,22;89:9,15,

 24;91:8,13,14;92:12;

 94:3,13;97:15;98:20,

 21,21;99:2,4,22,23,

 25;100:1,5;101:10,

 18;104:1,23;105:1,2,

 3,6,9,14;107:6;

 108:22,25;110:7;

 113:8,9,14,16;114:4,

 12,14;115:4;117:18,

 25;118:1,18,19,25;

 119:1,2,4,9,13,15,20,

 22;120:2,17;121:13,

 13,22,23;122:20;

 123:13;124:4,11,13,

 14;125:1,2,2,2,2,4,7,

 14,15,17,20;126:5,10,

 22;143:16;159:15;

 163:4,24 

farmers' (1)

 87:12 

farmer's (2)

 12:17;14:22 

109:21 

fast (1)

 43:1 

faster (1)

 43:9 

fathom (1)

 73:24 

fats (2)

 148:5;149:3 

favor (3)

 146:20;153:14;

 159:13 

favorite (1)

 45:11 

Fayette (1)

 106:9 

feat (1)

 105:1 

feature (1)

 76:1 

featuring (1)

 9:20 

February (1)

 48:25 

Federal (3)

 0:10,12;38:11 

feed (5)

 10:8;13:14;57:3;

 130:9;163:2 

feedback (10)

 13:6;54:18;67:22;

 69:13;75:14,21;

 105:14;110:13;

 148:20,23 

feeding (4)

 20:24,25;78:9;

 20:1;111:11 

fiber (1)

 20:7 

field (10)

 23:20;36:15;81:25;

 84:19;87:4,13;89:11;

 92:2;115:6;121:25 

fielded (1)

 123:7 

fields (5)

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

 88:22 

fifth (1)

 119:10 

fight (1)

 17:15 

fighting (2)

 20:23;125:25 

figure (5)

 15:3;35:9,12;65:20;

 166:25 

figuring (2)

 63:11;91:12 

filed (2)

 105:5;126:25 

fill (2)

 7:11;19:12 

final (2)

 32:9,13 

finally (2)

 41:22;90:11 

financial (1)

 111:12 

find (20)

 17:2,15;18:12;26:5;

 29:3;30:19;34:16;

F 

fabulous (2) 28:24;32:25,25;33:1, farmer-to-farmer (3) 81:13 61:15;62:17;66:19;

 127:11;143:18 3;38:15;45:3;47:13; 77:7;99:24;108:24 feel (8) 68:16;72:23;73:9;

faced (2) 59:14;76:21,25;77:4; farming (25) 45:1;57:20;58:7; 76:9;107:25;127:4;

 56:1;64:20 82:15;84:12;87:4,6; 23:3;71:22;80:21, 105:5;107:19;118:12; 141:7;143:11;144:7;

faces (1) 90:9,17;91:17;93:20; 24;82:17;85:3,16; 128:21;129:18 163:25 

12:4 97:7;98:14;99:21; 94:18;96:15;98:7; feels (3) finding (2)

facilitate (1) 101:9;102:16;103:20, 99:5,16;100:3;101:3, 108:11;128:20; 17:11;109:14 

38:17 25;104:13,19,21; 8;103:17;109:12; 138:11 finds (2)

facilitating (1) 105:18;106:8,9; 110:7;115:11;124:15, fellow (3) 73:8;138:22 

72:19 108:15;112:5,23; 15;125:11,18,20,21 12:15;15:23;56:4 fine (3)

facilities (3) 118:1,1;123:14; Farmland (4) felt (1) 59:18;128:19;

 118:7,8;165:21 168:8,8 10:22;17:3;95:6; 84:17 144:13 

facility (1) farmed (1) 101:25 fencing (1) fingers (1)

 118:12 76:11 farms (27) 88:22 105:24 

facing (3) farmer (40) 12:23,25;14:20; fertilizer (1) finish (2)

 56:13;113:15;126:2 12:16;15:8;17:5; 22:2;26:1;37:18; 122:15 53:22;69:22 

fact (10) 20:3,7,10;21:21; 42:12;76:6;78:15; festival (1) finished (1)

 11:5;25:19;36:9; 23:17;28:11,11; 81:18;85:2;89:4,5,10; 126:11 85:8 

40:25;48:22;71:14; 30:22;31:2;42:22,22, 94:24,25;95:24; festivals (1) finishing (1)

 73:5;81:24;82:23; 24;43:3;68:19;78:25; 98:15,25;99:17; 126:10 92:25 

164:20 79:6;90:1,9;91:10; 100:11;101:16; few (15) firmly (1)

faculty (1) 94:21;96:19;102:18; 104:17;107:18; 14:25;16:11,20; 61:4 

13:22 108:21;111:9;113:7; 119:20;125:23; 19:11;51:8;56:3;67:2; first (41)

fails (9) 114:6;119:14;120:11; 137:15 79:22;98:2;101:15; 6:4,16;11:12;13:24;

 133:22;135:5; 123:19;124:9,14; farm's (1) 102:1;121:11;122:18; 15:8;18:17;22:12;

 137:3;146:2;148:1; 125:6;131:11;148:13; 88:22 156:13;163:14 25:1,11;28:16;29:23;

 151:6;156:1;158:5; 153:12,14;164:6 FARV (1) fewer (2) 33:17;35:16;46:22; 

Min-U-Script® Burke Court Reporting & Transcription (11) exporters - first 

(973) 692-0660 
 NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 3 

November 24, 2023 

47:9;48:24;71:9;76:4,

 15;78:21;79:9;82:10;

 90:15;99:15;102:23;

 104:15;111:7;113:6;

 120:10;121:3;124:8;

 126:20;129:7,12,13,

 25;130:1,1;133:4;

 137:18;165:11 

first-name (1)

 98:22 

fiscal (1)

 42:10 

fitting (1)

 16:2 

five (6)

 25:6,12;96:5;

 109:18;141:9;160:2 

five-acre (1)

 93:19 

five-year (1)

 74:20 

fix (2)

 86:11;153:7 

flagship (1)

 90:6 

floating (1)

 110:20 

floor (2)

 6:2;158:23 

Florida (2)

 121:5,6 

flow (1)

 25:5 

159:10;164:10;167:5;

 168:5,14 

follow (1)

 85:12 

following (9)

 43:16;54:9;60:4;

 77:5;108:9;138:7,14;

 149:25;150:1 

follow-up (5)

 33:22;54:22;61:8;

 122:3;142:13 

food (47)

 7:12;17:21,25;18:3,

 4,4,7,9,12,14,15,18;

 19:3,23;47:23;49:12;

 52:2,4,14,14;72:24;

 76:22;78:9,9,16;79:7,

 9,11,12,14;87:8;

 89:24;96:20,20;

 104:12,19,21,21,23;

 108:18;118:1,9,9,12,

 20;120:1;165:24 

Foods (3)

 72:21;108:17;

 138:23 

forced (1)

 79:12 

forefront (1)

 144:12 

form (2)

 34:17;120:21 

formal (2)

 29:10;138:2 

founded (1)

 82:11 

founders (1)

 74:8 

founding (2)

 74:17;76:25 

four (12)

 18:18,18;25:12;

 28:4,9;38:12;44:19;

 48:22;95:5;96:12;

 119:9;146:19 

fourth (4)

 11:10;14:9;15:12;

 118:21 

frame (1)

 52:13 

Francisco (1)

 14:8 

Franklin (13)

 13:21;113:2;

 115:13;133:11;

 134:13;136:13;145:7;

 147:8;150:9;155:2;

 156:15;157:4;162:17 

frankly (1)

 144:4 

fraud (5)

 13:5;39:19;41:19,

 19,23 

fraught (1)

 80:25 

free (7)

 17:13;18:12;24:15;

fulfills (2)

 36:7;138:20 

full (4)

 9:7;27:14;28:21;

 103:8 

fully (1)

 79:25 

fume (1)

 16:16 

function (2)

 125:17;151:24 

fund (1)

 99:19 

fundamental (2)

 32:14;140:19 

funding (7)

 92:17,25;107:7;

 111:17;117:8,9;

 121:21 

fungi (1)

 114:18 

further (1)

 78:7 

future (13)

 20:21,23,24;47:16;

 48:6;49:8;55:23;

 73:10;75:2;76:22;

 84:7;110:17;167:25 

FY (1)

 43:6 

generate (1)

 36:18 

generated (1)

 36:11 

generating (1)

 36:9 

generation (2)

 12:16;15:8 

generations (3)

 76:22;79:18;80:2 

generative (1)

 73:9 

gently (1)

 29:18 

genuinely (1)

 32:6 

geographic (1)

 102:8 

geo-political (2)

 64:17,20 

Georgia (1)

 16:7 

Gerry (14)

 11:8;12:19;62:20,

 22;122:25;132:8;

 134:5;136:7;144:24;

 146:25;150:25;

 155:18;157:20;162:9 

gets (5)

 12:5;32:5;49:6;

 65:20;66:6 

given (6)

 16:17;18:13;25:14;

G 

fluid (1) formalized (1) 69:5;88:23;103:10; gaggle (1) 31:4;69:20;101:16 

63:6 38:14 124:19 18:23 gives (4)

fly (1) format (1) freeing (2) game (1) 35:4;96:23;122:21;

 167:24 165:5 21:17,19 150:3 156:15 

focal (2) formed (1) French (1) gaps (3) giving (3)

 52:9;53:19 89:22 122:7 46:20;101:17;102:7 69:9;79:4;131:6 

focus (14) former (2) fresh (2) garden (1) glad (4)

 13:4;17:11;32:8; 8:17;128:5 16:15;78:9 19:16 14:18;100:21;

 33:17;39:20;72:9,13; Formulation (1) freshwater (1) Gardeners (1) 138:25;168:15 

76:15;102:11,15; 8:21 76:8 92:12 glance (1)

 103:7,16,23;152:16 forth (6) friend (1) gasping (1) 31:10 

focused (3) 23:23,24;90:19; 128:6 16:23 Glasgow (1)

 31:25;94:10;116:22 120:5;122:16;167:3 friendly (1) gathering (2) 8:17 

focusing (3) fortunate (1) 80:8 54:17;104:15 Glenwood (1)

 33:18;93:6;114:23 14:11 friends (1) gauge (1) 96:17 

fold (1) forward (23) 56:4 125:20 glimpse (1)

 121:7 9:18,24;10:13,24; froggy (1) gave (6) 31:16 

folk (1) 12:15;23:16;47:20; 92:22 19:18;36:9;42:19; global (9)

 81:13 51:18;54:13;77:5,25; front (4) 48:24;69:13;145:25 27:24;35:23,23;

folks (39) 89:14;91:10,19; 7:1;8:13;91:12,18 gay (2) 37:14;38:18;46:15,

 7:2;9:16;18:21; 103:3;104:4;106:14; fronts (3) 20:8,10 15;66:3;79:7 

21:3;25:6;26:18; 110:6;140:8;144:18; 57:19;151:18;152:3 GE (1) glycerin (5)

 27:18;28:8,23,25; 158:7;165:14;168:6 fruit (2) 142:15 148:3,6,12,16,18 

31:3;32:10,25;35:18; found (4) 76:3,16 gem (1) glyphosate (1)

 36:19;46:25;48:12; 19:11;20:12;77:19; fruition (1) 43:23 19:22 

50:11;52:9;57:8;58:7; 80:23 69:15 General (11) GMO (9)

 61:19,21,25;63:19; foundation (3) fry (1) 42:1,7;52:15,18; 137:16;138:3,10;

 69:16;85:25;91:18; 36:4;84:6;86:3 164:18 56:7;99:21;107:24; 139:9,14,25,25;140:1,

 102:13;106:12,19; Foundational (2) FSA (1) 121:25;137:15; 5 

117:7;127:16;143:13; 78:10,20 90:18 159:15;163:21 GMOs (1) 

Min-U-Script® Burke Court Reporting & Transcription (12) first-name - GMOs 

(973) 692-0660 
 NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 3 

November 24, 2023 

137:22 

goal (13)

 16:19;27:20;28:1,4;

 33:4;41:19;45:22;

 68:18;74:23;94:11;

 100:8;109:4;128:20 

goals (3)

 27:22,25;121:1 

god (1)

 60:15 

goes (3)

 8:1;31:22;165:14 

Good (39)

 0:3;10:1,18;11:1,6,

 8,13;12:12,13;13:10,

 20;14:19;19:25;

 20:16;21:22;24:9;

 33:10;34:18;40:12;

 45:18;50:14;51:9;

 54:8;60:8;71:6;77:4;

 85:11;92:10;104:11;

 109:14;130:4;131:5;

 146:23;149:24;

 156:19;158:10;160:6,

 19;161:1 

goodness (1)

 125:23 

gosh (2)

 112:6;118:17 

go-to (1)

 82:17 

governing (1)

 109:24 

government (4)

 35:24;36:2;38:22;

 46:18 

governments (6)

 45:19,25;46:2,5,6,8 

government's (1)

 44:18 

governor (2)

 84:24,25 

grab (1)

 24:4 

grace (1)

 112:21 

grain (15)

 21:9;56:13;92:24;

 93:2,7,14,16,17;

 95:11;108:16;116:24;

 117:3,4,5;163:4 

grains (4)

 13:13;95:4;97:8;

 120:4 

grand (1)

grants (6)

 29:25;49:17,18;

 75:18;105:24;111:9 

Gras (1)

 126:14 

grassland (2)

 88:19;89:6 

grateful (9)

 8:4;11:18;13:14;

 19:1;47:18;72:2;

 109:10;110:14;

 145:25 

gravely (1)

 81:3 

Graziers (1)

 88:21 

grazing (2)

 88:19,24 

great (26)

 9:16;10:17,19;

 11:18;13:17;54:22;

 58:18;59:2;67:22;

 69:13,14;73:8,16;

 86:5;90:3,21;95:10;

 119:3;121:14;130:17;

 140:7;144:14;146:13;

 159:25;163:12;

 164:18 

greater (2)

 40:12;63:4 

green (5)

 19:2;82:21,23,24;

 83:2 

greens (1)

 13:2 

grew (3)

 13:12;19:16;21:20 

Grigsby (3)

 92:9,10,11 

Grimmway (1)

 14:20 

groceries (1)

 18:1 

grocery (5)

 17:17,24;18:3,21;

 20:15 

ground (8)

 25:21;60:3,21;

 64:15;81:10;115:9;

 121:12;127:13 

group (43)

 7:24;10:14,15;12:5;

 20:12;25:23,24;

 26:14,16,17;27:3,15;

 28:25;31:21;33:2;

 154:3 

groups (15)

 24:18;25:6,16,17,

 24;28:24;33:21;48:9;

 50:11;90:3;97:25;

 115:17;153:12,13,19 

grow (21)

 15:19;19:5,25;22:6;

 27:20;29:5,13;76:24;

 78:1,13;85:1;102:19;

 106:16,25;119:18;

 126:11,12,19;127:20;

 163:4,24 

grower (10)

 14:8;80:25;102:3;

 120:3,4;122:11;

 123:5,6;167:11;168:9 

growers (20)

 56:10,10;79:16,21;

 80:6,9;81:7,12;97:5;

 108:16;109:1,3;

 114:21;116:24;117:3,

 4;118:16;121:5,6;

 122:12 

growing (19)

 63:5;75:2;76:19;

 78:3;79:7;81:13;89:8;

 90:14;91:15;95:2,16;

 108:13;117:5;121:6;

 126:6,7,8,16,21 

grown (2)

 25:3;39:21 

growth (3)

 38:18;39:24;85:4 

guess (6)

 11:16;13:3;66:16,

 20;83:23;141:21 

guessing (1)

 37:6 

guidance (3)

 48:2;94:14;109:23 

guided (1)

 142:2 

guiding (1)

 74:20 

gutter (1)

 161:5 

guy (1)

 102:22 

guys (6)

 7:19;44:24;52:22;

 59:21;64:15;123:4 

hall (3)

 0:16,17;51:3 

Halloween (2)

 128:12,25 

hallway (1)

 50:21 

halter-break (1)

 22:11 

ham (1)

 166:4 

Hampshire (7)

 88:1,5,6,12,15,20;

 89:16 

hams (1)

 166:7 

hand (10)

 15:20;24:7;60:10;

 71:4;82:16;110:22;

 127:6;129:9;163:2,2 

handed (1)

 148:10 

handing (1)

 16:10 

handler's (2)

 11:9;13:11 

handles (1)

 42:25 

handling (5)

 63:14;152:15;

 154:5,7,9 

hand-offs (1)

 62:11 

handout (1)

 123:9 

handouts (4)

 82:7,8,8;117:19 

hang (2)

 61:5;158:9 

hanging (1)

 18:8 

happen (5)

 60:23,23;64:7;87:2,

 21 

happened (1)

 121:10 

happening (5)

 9:22;10:6;58:25;

 65:3,8 

happenings (1)

 24:22 

happens (4)

 21:14;49:5;65:23;

 167:16 

Happy (8)

 0:22;14:2;15:23;

harming (1)

 21:1 

harmless (1)

 17:7 

harmonized (1)

 47:6 

Harriet (2)

 82:22;83:1 

harvest (4)

 23:6;63:7;80:10;

 82:13 

harvesting (1)

 82:13 

hat (1)

 123:18 

hats (1)

 90:1 

hay (2)

 16:15;88:25 

HBCU (1)

 103:22 

HBCUs (7)

 121:6,7,8,15,16,18,

 25 

head (5)

 14:7;54:25;55:13;

 101:9;128:4 

heading (1)

 10:2 

heads (1)

 23:10 

head-start (1)

 36:10 

heal (5)

 17:12,22;19:19,23;

 87:1 

Health (18)

 9:1;18:7,9;20:17;

 72:10,20;73:3,9;

 86:22;91:24;92:2;

 102:1;105:12;114:24;

 135:12;137:14;

 153:19;159:4 

healthy (2)

 76:21;131:7 

Healy (1)

 8:6 

hear (21)

 6:7,10;15:12,14;

 23:1;42:20;50:24,24;

 51:11;53:20;56:4;

 57:3;67:10;95:25;

 117:15,16;129:16;

 135:13;149:18,19;

 156:14 

H 

111:6 38:7;43:15;44:25; Half (9) 31:20;66:23;73:18; heard (18)

grandparents (1) 45:1;48:20;49:3; 12:20;26:3,9,16,20; 91:4;114:11 15:14,17;19:21;

 80:12 52:16;57:23;63:9,13; 60:24;70:1;94:21; hard (16) 20:18;22:18,21;

Granite (1) 73:19;74:4;77:24; 95:19 7:24;31:21;62:3,5, 30:14;36:21;50:20;

 88:20 105:6;106:7;109:12; half-past (1) 6,7;105:3;112:20; 56:3;58:15;90:20;

grant (4) 114:6,24;116:12; 129:3 118:19;127:17; 110:4;113:7;126:1;

 95:22,25;126:21; 127:20;140:4,6; halfway (1) 129:21;143:1;146:10; 131:3;143:13;154:4 

165:1 152:5,8,10,11;153:15; 12:2 149:16,19,19 hearing (6) 

Min-U-Script® Burke Court Reporting & Transcription (13) goal - hearing 

(973) 692-0660 
 NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 3 

November 24, 2023 

48:9;49:23;121:23;

 135:24;157:3;164:1 

Heartland (1)

 55:24 

heartwarming (1)

 111:2 

Heather (5)

 7:6,6,11;13:15;

 14:17 

heavy (1)

 13:17 

heirloom (1)

 83:2 

heirlooms (1)

 80:11 

held (1)

 18:14 

hello (5)

 7:7;11:22;88:4;

 92:10;94:17 

help (31)

 10:8;14:13;19:23,

 25;20:21;23:20;

 38:18;40:15,15;45:6;

 57:13;64:3;68:17;

 73:7;75:18;83:2;

 84:10;87:1;88:7;

 89:23;95:23;103:24;

 104:25;111:12,16;

 112:11;113:18;114:2;

 142:18;149:20;154:1 

helped (2)

 82:15;97:11 

helpful (4)

 35:6;102:23;

 120:25;139:3 

helping (8)

 52:3;59:7;73:7;

 78:14;91:8;102:25;

 126:22;163:18 

higher (1)

 44:4 

highest (2)

 74:15;84:16 

highlight (3)

 7:20;24:13;29:22 

highlighting (1)

 87:4 

highly (3)

 82:18;158:25;

 160:20 

highways (1)

 76:12 

hijacked (1)

 80:24 

hill (1)

 76:7 

hip (1)

 18:8 

hire (2)

 27:17;85:24 

hired (2)

 7:13;8:10 

hiring (2)

 8:14;93:22 

historically (1)

 85:16 

history (3)

 20:19;74:1;103:22 

hit (3)

 13:16;19:2;60:21 

hitters (1)

 146:10 

hitting (2)

 121:12;129:21 

hobby (1)

 168:8 

hog (1)

 167:11 

hold (10)

 0:6;9:10;12:24;

 73:16 

hook (1)

 18:16 

hooked (1)

 20:5 

hope (9)

 9:22;13:10;15:16;

 16:2;71:5;93:11;

 112:15;122:2,21 

hoped (1)

 117:10 

hopefully (4)

 12:10;15:18;

 111:14;137:12 

hopes (1)

 154:8 

hoping (5)

 10:8;14:23;31:12;

 63:17;114:25 

hops (2)

 126:21,22 

horribly (1)

 142:3 

horticultural (1)

 114:21 

hospital (1)

 17:1 

host (3)

 88:22;93:17;100:3 

hosted (1)

 75:10 

hosting (4)

 57:13;87:12;99:23;

 109:3 

hot (1)

 16:16 

hour (3)

 70:1;106:18,24 

hours (6)

 51:14;77:8 

hungry (1)

 78:10 

hunted (1)

 17:13 

hurdle (2)

 117:4,9 

hurdles (2)

 115:15,16 

husbandry (1)

 80:10 

HUSEMAN (49)

 13:9,11;116:18;

 117:12;128:1,16,20;

 129:9,11;130:6,14;

 132:9;133:10,20;

 134:12,22;135:3,7,10;

 136:12;137:5;145:6;

 146:6,9;147:7;148:3,

 6;150:8;151:8;155:1;

 156:4,9;158:2,7,12,

 16,22;159:18,20;

 160:4,10;162:16,23;

 163:10;164:11,13,17;

 166:11;167:19 

hustling (1)

 15:6 

hydrated (5)

 156:5,12,15,17,22 

hydrolysis (3)

 148:5,22;149:3 

hydroponic (1)

 11:14 

hydroponics (4)

 51:16,19;52:23,25 

hygienic (1)

 131:7 

27:21;34:15;35:7;

 39:10;53:25;55:15;

 60:5 

implementation (8)

 33:7;38:24;45:14;

 54:1,6,10;55:22;

 152:13 

implemented (4)

 37:1;53:24;138:13;

 139:12 

implementing (4)

 32:9;107:25;108:6,

 24 

import (14)

 26:10,11,22;27:3;

 32:18;33:19;34:1;

 36:5,6,17;37:2,6;

 39:12;56:22 

importance (4)

 62:2;91:11;117:20;

 139:16 

important (30)

 13:6;29:21;33:1,1;

 36:19;37:4,20;38:5,

 24;39:18;45:16;

 52:19;54:21;55:23;

 57:24;59:3;65:7;81:6;

 107:10,10;108:4,14;

 111:6,11;115:9;

 131:4,14;137:13;

 138:9;168:4 

importantly (3)

 45:23,24;105:17 

importers (1)

 34:4 

imports (6)

 26:11;38:15;58:16,

 25;64:19,22 

impressed (1)

 111:3 

I 

helps (6) 35:18;41:14,17; 9:6,6;17:17;23:8; identical (2) improve (2)

 35:3;39:4,9;59:15; 58:1;91:3;109:8; 69:19;85:21 38:20;45:21 59:15;89:5 

69:2;143:2 128:23;141:16,24,25 house (3) identify (2) improved (2)

here's (1) holding (1) 16:14;19:4;23:13 46:13;62:21 95:1;97:6 

68:23 41:6 housed (1) illustrate (1) improvement (3)

heritage (3) holds (1) 49:11 149:14 97:3,5;154:1 

80:11;93:17,18 72:15 housekeeping (1) imagination (1) improvements (1)

herself (1) holistic (1) 0:14 66:22 43:4 

18:17 165:8 hovering (1) imagine (1) improving (2)

hesitate (1) holistically (1) 43:7 60:16 95:12;108:1 

164:7 167:10 hub (1) imbalances (1) inaudible/off (3)

hesitating (1) Holm (1) 108:18 146:16 123:16,18,19 

144:2 6:25 Hudson (3) imbued (1) include (6)

hey (2) home (13) 76:6,8,17 80:1 6:4;26:18;99:20;

 41:13;102:20 8:6,17;12:23;16:17, huge (8) impact (3) 139:24;142:15;

Hi (3) 19,20;20:4,4;57:4; 55:3,3;86:1,13; 61:18;84:3;86:15 164:23 

14:4;58:15;62:20 74:7,16;84:5,13 105:1;114:13;116:2; impacted (2) included (2)

hidden (2) hone (1) 127:7 64:18;81:3 79:25;90:18 

43:23,23 86:21 human (2) impactful (1) includes (6)

high (10) honest (5) 7:14;73:3 73:20 71:14,17;74:14;

 53:6,9;62:5,7,15; 46:18;81:19;101:1; humor (1) impacts (1) 78:5;151:25;159:8 

64:20;71:20;76:8; 116:3,11 167:14 73:3 including (10)

 142:3;166:10 honor (4) hundreds (2) implement (7) 6:13;8:23;33:9; 

Min-U-Script® Burke Court Reporting & Transcription (14) Heartland - including 

(973) 692-0660 
 NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 3 

November 24, 2023 

49:15;75:21;76:10;

 77:16;93:16;99:11;

 138:17 

inclusion (3)

 48:17;128:7;137:23 

inclusive (1)

 48:3 

incoming (1)

 26:1 

incompatible (1)

 20:10 

inconsistency (1)

 152:18 

incorporate (1)

 122:7 

incorporating (1)

 77:21 

increase (5)

 32:16;76:19;88:8;

 102:4;107:22 

increased (3)

 25:14;88:13;114:22 

increases (1)

 140:17 

incredible (3)

 10:13;48:11;74:4 

incredibly (2)

 48:8;127:19 

incubator (1)

 87:9 

indeed (1)

 110:15 

Index (11)

 78:2,25;79:6,20;

 121:9,10;122:4;

 123:13;124:14;

 125:14;126:9 

India (2)

 25:20;60:1 

indicating (1)

 153:13 

indicators (1)

 40:1 

indices (3)

 123:2,4 

inflammation (1)

 135:13 

inflated (1)

 87:19 

influential (1)

 74:8 

information (13)

 39:4;47:20;58:18;

 61:11;76:10;80:5;

 89:3;97:1,5,6,8;

 131:18;167:1 

informed (2)

 20:13;66:14 

infrastructure (4)

 30:4;95:9;122:13;

 167:11 

ingredients (3)

 13:14;138:10;163:2 

in-house (1)

 99:15 

initial (1)

 110:5 

initially (2)

 121:8;126:24 

initiate (1)

 40:4 

initiative (6)

 28:9;29:24;47:17;

 81:7;94:5;111:7 

injury (1)

 8:7 

innovative (1)

 73:9 

in-person (1)

 73:5 

input (3)

 33:3;37:16,16 

inquiries (2)

 42:19;110:5 

inquiry (1)

 52:17 

insecurity (1)

 79:7 

65:7;167:7 

inspector (5)

 21:11,23;41:25;

 42:6;167:6 

inspectors (2)

 39:13,16 

inspiring (4)

 111:2;117:15;

 127:10,21 

instead (6)

 87:19;102:17,19;

 149:6,20;160:2 

Institute (3)

 72:17;96:20,20 

Institute's (1)

 84:18 

institutional (2)

 100:24;164:25 

institutionalized (2)

 43:17;44:20 

institutions (4)

 113:25,25;114:1;

 120:23 

insurance (2)

 30:15,22 

integrate (1)

 86:9 

Integrity (18)

 24:14;26:22;27:22;

 28:2;30:3,10;33:5;

 35:20,22,23;36:6;

 39:3;45:3;51:10;57:7;

 59:16;64:22;68:14 

intended (2)

 38:18;156:22 

intensive (2)

 88:19,24 

intentional (1)

 74:11 

interacting (1)

 72:24 

interaction (2)

 32:4;74:3 

interactions (1)

 34:20;66:7;159:7 

internally (1)

 91:1 

international (5)

 25:21;26:14,19;

 27:2;38:17 

interpretation (3)

 138:15,20;152:12 

interpretations (1)

 138:1 

interpreter (1)

 122:6 

interpreters (1)

 122:6 

intersection (1)

 104:21 

interstate (2)

 76:12;90:2 

interviewed (1)

 97:14 

interviewing (1)

 17:17 

intimate (1)

 81:18 

intimately (1)

 85:14 

into (54)

 6:12;10:2,25;11:4;

 12:2;13:3;15:24;18:3;

 22:5;24:10,19;25:24;

 26:3,23;30:21;31:5,

 18;36:17;37:24;

 39:13;42:3,3;47:5;

 50:14;56:9,13;62:18;

 67:21;68:13;69:3;

 75:2;81:7;83:23;84:8;

 87:9;95:10;112:18,

 22;113:21;119:1,4;

 120:3;121:7;126:22;

 127:1,25;128:4;

 132:8;139:5;144:19;

 160:17;163:3;165:2;

 168:2 

introduce (8)

invite (3)

 21:4;23:5;48:5 

involve (1)

 43:10 

involved (6)

 26:21;63:23;73:23;

 90:7;91:8;164:16 

involvement (2)

 111:21;115:3 

Iowa (1)

 19:21 

IPM (1)

 97:6 

Island (6)

 15:24,25;94:20,21;

 95:19;96:19 

islands (8)

 113:12,12,14,17;

 120:13,14,16;122:21 

isopropanol (10)

 130:7,9,13,20;

 131:4,8,13;132:2,19;

 133:24 

issue (7)

 10:24;30:15;37:2;

 112:18;137:12,16;

 142:24 

issued (2)

 30:8;40:19 

issues (4)

 8:24;48:20;121:19;

 159:4 

issuing (2)

 36:5;37:5 

item (4)

 10:7;12:10;69:10;

 154:3 

items (2)

 12:6;24:23 

iteration (1)

 28:16 

J 

43:21,25;141:24 inseminates (1) 66:16 6:1;7:10;71:9,10; January (3)

individual (1) 161:12 interactive (2) 85:9;88:2;106:18; 32:14;96:11;99:25 

97:15 insemination (2) 31:10;68:13 163:3 Japan (2)

individuals (1) 159:11;161:8 interdependence (1) introducing (1) 35:19;82:12 

110:21 inside (1) 74:2 9:5 Japanese (1)

industries (1) 69:13 interest (6) introductions (3) 82:15 

166:17 Insider (6) 10:3,12;51:12; 6:3,5;15:7 Jared (1)

industry (14) 24:20,21;27:9;37:5, 98:21;99:18;117:5 invasive (1) 6:24 

11:12;15:19;58:17; 11;69:7 interested (10) 80:7 Javier (1)

 61:22;73:24;76:20; insight (2) 13:24;14:2;84:21; invest (2) 15:1 

80:21;81:3;83:6;86:5; 122:21;167:9 101:10,18;102:14; 85:2,3 Jeffrey (1)

 109:13;129:18;163:2; insights (1) 105:15;106:13; investigation (1) 15:2 

168:10 49:3 115:15;163:8 41:18 Jen (1)

inequities (2) inspected (3) interesting (5) investment (2) 55:18 

78:21;79:18 22:2,13;167:7 12:5;34:20;72:11; 110:15;143:22 Jennifer (2)

inerts (6) Inspection (2) 143:11;163:13 investments (1) 0:3;110:9 

10:24;12:6;13:25; 9:1;37:25 interests (1) 47:4 Jenny (21)

 54:17;151:24,25 inspections (6) 81:19 invisible (1) 9:14;22:25;24:8;

infectious (2) 22:1,18;37:19;38:2; internal (3) 80:18 45:9,10,13;47:8;51:7; 

Min-U-Script® Burke Court Reporting & Transcription (15) inclusion - Jenny 

(973) 692-0660 
 NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 3 

November 24, 2023 

55:21;58:15;63:2;

 64:14;66:17;67:1;

 71:4;104:13;115:24;

 141:20,22;143:6;

 149:8 

Jeremy (4)

 97:20;98:6;100:15;

 104:8 

Jerger (1)

 83:14 

Jerger's (1)

 128:6 

Jersey (9)

 81:15;85:10,14,16,

 21;86:4,17;87:6,11 

Jersey's (1)

 85:9 

Jesse (1)

 116:10 

job (14)

 8:14,17;10:5;22:10;

 43:24,25;75:16;

 89:19,21;127:15,15;

 146:23;154:19;

 161:16 

jobs (1)

 57:25 

Joe (2)

 6:25;7:1 

John (2)

 113:13;120:15 

JOHNSON (16)

 10:1,2;47:8;111:1;

 112:2,5;132:21;

 134:25;136:22;

 140:10;145:16;

 147:17;150:18;

 155:11;157:13;162:2 

join (9)

 15:4;21:5,7;23:8;

 25:4;58:8;71:24;82:5;

 106:19 

joined (1)

 72:7 

joining (2)

 9:17;13:15 

joke (1)

 167:15 

jokingly (1)

 124:9 

Josh (1)

 84:24 

journey (1)

 80:1 

joy (2)

 73:8;116:13 

16:17,25 

jump (5)

 15:24;24:6;57:21;

 94:22,22 

June (1)

 24:25 

jurisdiction (1)

 151:22 

Justice (6)

 42:7;48:18;49:2;

 80:18,19;128:7 

K 

Kaia (10)

 78:24;79:2,5,5;

 83:11;85:12;117:17;

 120:6,8;123:23 

Katie (2)

 84:1;110:1 

keep (12)

 8:9;15:17;21:20;

 43:13;44:15;65:4;

 101:9;131:5;132:5;

 144:12,21;156:24 

keeping (7)

 87:19,19;131:24;

 135:21;136:1;143:7,

 12 

Kennebec (1)

 93:19 

kettles (1)

 20:15 

key (6)

 7:19;24:23;25:6;

 28:9;40:5;85:3 

kick (7)

 9:25;11:17;45:11;

 74:22;83:18;103:10;

 132:6 

kicked (1)

 161:19 

kidding (2)

 37:9,10 

kids (4)

 18:23;19:8,22;

 20:23 

killed (2)

 114:15;124:10 

Kim (43)

 14:16;116:16;

 128:1,19;129:9,10;

 130:14,15,16,19;

 131:23;133:9;134:11;

 135:6;136:11;137:4;

 145:5;146:5,9,13;

 13:10 

Kim's (1)

 161:14 

kind (45)

 18:5;24:18;27:6;

 28:13;30:3;36:16;

 37:8;39:9;45:22;

 46:15;47:5;49:25;

 50:2,4,15,16;51:22;

 52:24;55:8,9;57:14;

 65:9,14;66:3,7;68:15;

 69:2;85:7;88:2;95:20;

 96:1;101:12;102:6;

 106:23;114:1;117:21;

 119:17;127:12;140:7;

 142:25;149:18;160:2;

 166:21;167:13,25 

kindly (1)

 120:6 

kinds (1)

 137:10 

knew (5)

 18:11,23;20:8;

 105:9;115:17 

knowledge (3)

 81:13;100:24;

 140:13 

known (2)

 54:24;67:8 

knows (1)

 32:11 

Kobus (19)

 71:10;73:14;77:10,

 12;83:11,16,18;87:23,

 25;92:6,8;97:19;

 104:8;109:7;110:20;

 111:20;112:15;114:9;

 115:20 

Korea (1)

 35:19 

kudos (1)

 165:13 

Kumar (1)

 7:6 

KVCC (1)

 93:19 

Kyla (15)

 11:25;12:13;58:14;

 79:1;133:5;134:7;

 136:7;145:1;147:2;

 151:2;153:8;154:1;

 155:20;157:22;

 162:11 

8:22 

labor (1)

 21:21 

lack (2)

 87:15;165:22 

lag (1)

 60:20 

lake (1)

 64:5 

lambs (4)

 20:4,4,5,6 

land (19)

 13:1;19:10;21:8;

 22:5,14;76:11,21;

 80:14;82:22,24;83:1;

 93:8,12,17;95:6;99:6;

 126:1;151:11;165:1 

landing (1)

 77:16 

landscapes (1)

 76:15 

language (5)

 68:23;86:23;128:8;

 149:7;164:24 

languishing (1)

 168:3 

large (6)

 19:16;49:13;56:24;

 74:16;95:2;167:2 

largely (2)

 32:2;80:20 

larger (2)

 82:18;94:4 

largest (2)

 63:13;95:14 

Last (33)

 9:19;11:15;13:9;

 15:5;24:21;25:7,12;

 42:2,10,19;44:20;

 51:8,8;60:14;61:2,2;

 62:23;73:5;74:21;

 75:2;90:8;95:19;

 97:11,13;104:9;

 106:15;111:21;

 116:21;127:16,21;

 130:20;139:4;158:19 

lastly (3)

 100:4;106:11;126:5 

later (3)

 33:14;95:24;164:22 

Latino (2)

 125:2;126:12 

laughing (1)

 62:23 

launch (2)

 35:16;77:20 

88:1;89:17;92:6;

 102:6;113:5;114:3,

 10;115:9 

lead (9)

 54:18;72:6;73:16;

 74:12,13;75:4;84:4;

 106:4;110:10 

leader (1)

 84:15 

leaders (4)

 73:20;74:8,12;

 115:21 

leadership (4)

 72:8;98:9;130:19;

 168:13 

leading (1)

 9:11 

leads (6)

 28:20,20;30:21;

 74:5;87:20;128:6 

learn (14)

 6:22;29:3;37:1,2,8;

 44:17;61:25;82:12,

 13;84:20;96:15;

 98:23;115:2;124:24 

learned (4)

 105:13;120:18;

 126:9;135:10 

learning (19)

 22:11;24:14,15,19;

 31:6,6,8,8;34:19,21;

 36:14;39:4;43:19;

 58:19;64:15;68:14;

 69:5;101:10;103:9 

learns (1)

 34:14 

least (2)

 160:6;163:19 

leaves (1)

 109:8 

led (5)

 17:13;50:9;60:3;

 74:24;77:14 

left (5)

 0:15;8:18;14:12;

 80:3;83:5 

leg (1)

 39:9 

legal (2)

 41:2;121:20 

Leilani (1)

 110:1 

lend (1)

 60:11 

less (4)

 43:9;92:13;104:14;

L 

joyful (1) 147:6;148:2,6;149:4, La (1) launched (4) 107:1 

8:3 5;150:4,7;151:7,15; 126:13 28:16;29:8;34:19; lessening (1)

joys (1) 154:25;156:3,8; label (1) 36:25 119:23 

115:20 157:3;158:1,6,22,24; 45:4 launching (4) lessons (2)

judgment (1) 159:19;162:15,22; Labeling (3) 35:15;75:25;77:15, 78:11;80:2 

61:1 163:12,16;168:13 8:20,25;72:24 20 Lester (1)

July (2) Kimberly (1) labels (1) Laura (8) 22:25 

Min-U-Script® Burke Court Reporting & Transcription (16) Jeremy - Lester 

(973) 692-0660 
 NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 3 

November 24, 2023 

letter (4)

 67:15,15,20;68:2 

letting (1)

 167:15 

level (9)

 7:23;36:1;44:14;

 48:21;63:18;78:11;

 109:11;112:23,23 

levels (2)

 28:20;84:16 

leverage (2)

 74:11;112:10 

levers (1)

 58:8 

LEWIS (24)

 10:21,21;45:11,13;

 128:4,18,22;131:17;

 132:25;134:2;136:3;

 141:1;143:7;145:20;

List (22)

 6:24;7:3;12:11;

 44:5;52:20;53:18;

 55:7,7;130:11;132:5,

 6;135:21;137:24;

 141:23;144:21;146:6;

 148:6,17;151:13;

 156:8;158:22;165:1 

listed (14)

 79:21;130:7,9;

 135:11;137:6,18;

 146:7;148:3;151:9;

 152:15;156:5;158:20;

 159:14;160:11 

listen (2)

 23:18;35:4 

listening (11)

 8:8;37:10;40:14;

 45:7;53:8;61:20;

 18,21,22;139:16;

 140:12;141:2;143:13;

 144:1,14;146:6,11,16;

 148:4,11;151:9,11;

 154:6,8;156:17,19,22;

 158:19;162:25;163:1,

 2,7,18;164:20;168:1,

 12 

living (6)

 17:3;20:16;21:22,

 22;55:7;122:21 

load (2)

 62:12,13 

loan (1)

 20:6 

local (11)

 17:24;75:1;78:7;

 81:1;95:16;96:14;

 112:23;119:1;123:6;

 9:16,18,24;10:13,

 24;12:14;61:22;

 62:17;89:14;91:9,10,

 19;93:24;99:17;

 103:3,13;106:14;

 114:25;119:17;152:5;

 153:10;159:10;

 165:24 

looks (3)

 104:22;114:9;

 125:19 

loopholes (1)

 61:22 

lose (2)

 40:25;57:18 

losing (1)

 112:6 

loss (1)

 140:23 

62:8;126:9;159:1 

lubricant (2)

 158:21;159:11 

lubrication (1)

 159:9 

luck (2)

 12:13;54:8 

lucky (2)

 85:13;98:4 

lumped (1)

 100:21 

lunch (8)

 6:6;34:13;48:10,10;

 69:19;70:1,3;71:6 

lungs (1)

 17:2 

M 

147:21;149:6,10,13; 63:24;67:25,25;82:2; 126:2;166:3 lost (1) Madam (1)

 150:22;151:13; 142:2 locally (5) 154:12 15:20 

155:15;157:17;162:6; listing (10) 95:2,13;118:2,4; lot (91) magnitude (1)

 167:23 138:20;142:18; 131:15 7:24;8:3;9:1;13:3; 74:1 

liaisons (1) 152:16,25;154:1,8; locate (1) 26:12;28:7;30:7;32:8, main (2)

 7:12 159:5,6;160:1;161:17 125:15 21,23;33:15,23;39:15, 56:2;103:20 

life (6) listings (6) located (3) 21;40:7;41:23;43:13; Maine (10)

 12:24;21:14;22:4; 138:1;139:8;153:4, 76:6;78:5;120:15 46:16;47:14;49:6; 71:19;92:12,23,24;

 23:12;47:11;115:9 5;154:6;159:21 locations (1) 50:21;51:15;52:6,10, 93:3,9,14,16;94:9;

life-altering (1) lists (1) 72:22 14,25;53:1,1,13; 95:7 

17:4 36:1 log (4) 54:14;58:18;59:4; mainland (1)

lifeline (1) literally (5) 16:19;24:19;44:15, 61:10,12,25;63:9,20; 122:14 

149:12 25:12,19;27:11,18; 15 64:9,17;66:1,15; mainly (1)

lifestyle (1) 81:18 Logan (10) 67:13,22;71:14,21; 14:21 

79:13 literature (1) 14:19;133:15; 72:24;76:24;92:18; maintain (2)

lift (2) 159:10 134:17;136:17; 100:22,23;101:6,9; 38:19;131:7 

71:20;145:24 little (35) 145:11;147:12; 102:7;103:6;105:8; maintaining (2)

light (4) 0:14;8:3,11;11:5; 150:13;155:6;157:8; 111:20,23,23;113:18, 26:22;88:24 

15:25;129:23; 12:1,10;19:12;24:4; 161:22 22;115:5,6;117:25; major (3)

 130:18;163:19 25:8,9;45:14;48:13; long (10) 118:1,3,8,18;119:2; 63:4;81:4;121:18 

likelihood (1) 52:4;59:18;67:5;72:4; 9:23;43:22,22; 120:17;121:13,20,24; majority (1)

 140:17 73:22;85:7;90:25; 62:19;92:19;94:20, 122:1,11;125:1; 132:4 

likely (1) 100:25;102:13; 21;95:19;96:19; 126:2;127:16;129:21; Makers (1)

 20:3 104:14;107:1;108:6; 101:22 131:1;135:13;140:6, 108:10 

lime (7) 114:14;116:23;129:6; longer (5) 23;142:1;144:8; makes (1)

 156:5,8,12,15,17, 130:16;151:22; 30:4;42:15;63:23; 146:14;154:21; 26:2 

22;160:17 152:18;154:5;163:11, 65:1,24 159:14;161:15; making (10)

limit (2) 17;167:7,25 longing (2) 163:24;166:14,17 27:9;30:24;51:10;

 17:1;140:16 littler (1) 16:18;23:10 lots (10) 56:23;69:10;75:16,

limited (3) 125:6 long-term (1) 22:14;27:24;49:2; 22;85:12;109:4;

 56:1;103:25;135:15 live (5) 50:15 50:23;53:3;56:22; 144:11 

limiting (1) 31:1,3;36:8;79:11; look (30) 61:21;71:21;76:9; maligned (1)

 65:16 118:5 0:25;6:14;9:16; 130:25 119:5 

line (4) lived (2) 16:3;24:18;33:7;42:9, Louisiana (3) Malone (1)

 9:17;18:24;59:18; 12:21;120:15 17;43:3;48:1;49:7; 122:8;126:10,13 8:19 

85:6 livestock (65) 52:23;57:15;77:5; love (8) man (1)

lineage (1) 6:9;13:14;26:10; 103:14;104:4;108:1; 21:14;67:10; 21:14 

125:9 39:7,8;40:22;53:10, 110:6;115:4;117:22; 112:24;117:18,18,18; manage (1)

lines (2) 11,14,15;54:1,5;57:3; 123:20;125:1;131:6; 119:12;137:9 14:20 

100:18;153:16 87:6;93:7;127:25; 160:16,17;165:2,14, lovely (3) managed (2)

link (1) 129:9,12,15,15,18,20, 20;167:10;168:6 12:4;27:15;117:15 93:9;153:2 

24:21 22;130:17;131:6,12; looked (4) lovingly (1) Management (14)

linked (2) 135:14;137:14,15; 19:8,19;125:3,4 82:20 6:10;30:14;72:13;

 28:4;63:25 138:7,11,11,12,14,17, looking (23) low (3) 86:22,23;88:19;89:3, 

Min-U-Script® Burke Court Reporting & Transcription (17) letter - Management 

(973) 692-0660 
 NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 3 

November 24, 2023 

6,7,11;108:2;118:11; 25,25;164:8,9; 117:21;119:7,17; 60:11;62:20;66:11; 120:13;146:18;

 135:15;156:19 165:23;166:7,17,18, 122:19;142:17; 76:25;89:19;111:1; 153:19,20;154:2 

manager (1) 19,19,20;167:12 159:21;165:23;167:7, 112:2,5;113:3;115:8, mentioning (1)

 6:24 marketing (9) 8 14;116:15,18;117:12; 123:24 

managers (1) 21:7;42:15;49:10, McGovern (1) 120:9;122:22;123:1, mentor (1)

 25:17 19;75:22;77:25; 90:17 15;128:4,13,16,18,20, 76:23 

managing (1) 118:15,20;143:24 McNerney (1) 22;129:11;130:6; mentoring (1)

 7:21 marketplace (1) 7:17 131:17,25;132:9,14, 28:11 

mandate (1) 111:15 meal (1) 17,21,23,25;133:2,3, mentors (8)

 114:2 markets (18) 166:12 6,10,12,14,16,18,20, 29:10;75:7;91:11,

manner (1) 38:23;40:20;74:9; mean (15) 25;134:2,4,6,8,12,14, 23;92:3;94:13;97:13;

 148:19 87:12;95:2,3,14; 36:15,15;46:6;62:4; 16,18,20,22,25;135:3, 99:12 

manual (1) 108:19;117:19,20; 65:13,19;69:17; 7,10;136:3,5,6,8,12, mentorship (12)

 0:11 118:4,10,14;119:1,1, 116:1;119:19;124:19; 14,16,18,20,22,24; 23:21;75:24,24;

manufactured (1) 2,9;167:4 141:17;159:25; 137:5,9;139:3,7,17, 76:1,5;77:22;87:13;

 148:18 Marlboro (1) 160:17;165:19; 19;140:10,21;141:1,6, 94:7;95:23;97:12;

manufacturer (1) 82:11 166:15 11,14,17,19,20; 99:11;108:24 

149:1 marry (1) meaning (2) 142:12,17;143:2,5,7; merger (1)

manufacturing (1) 21:13 32:2,5 144:23,25;145:2,6,8, 72:19 

148:22 Mary (1) meaningful (4) 10,12,14,16,18,20; message (1)

manure (3) 144:16 48:19;60:22;83:13; 146:6,13;147:1,3,7,9, 55:24 

89:3,5,7 Maryland (3) 92:20 11,13,15,17,19,21,23; messy (2)

many (35) 81:14;82:12;83:25 means (10) 148:3;149:10,13; 66:6;140:11 

8:9,9,16;17:8; mass (1) 34:15;35:11;62:7,9; 150:8,10,12,14,16,18, met (1)

 20:12;39:13;41:8,9; 40:21 97:9;110:11;112:18; 20,22,24;151:1,3,8; 7:2 

43:9;46:9;47:13; Massachusetts (4) 126:8;139:5;142:8 152:9;154:14;155:1, metaphorical (1)

 51:14;56:4;69:11; 90:23;91:13,22; meant (1) 3,5,7,9,11,13,15,17, 83:22 

73:24;74:7;75:25; 116:5 17:17 19,21;156:4;157:5,7, metaphysical (2)

 78:4,9;79:11;80:3,6; massive (2) meantime (1) 9,11,13,15,17,19,21, 83:22,23 

81:7;83:6;90:18; 110:13;149:9 138:20 23;158:2,7,12,16,24; methane (1)

 98:20,22;117:10; masters (1) measurable (1) 159:18,20,24;160:4, 82:14 

138:10;140:13;141:2, 72:12 19:25 10,16;161:21,23,25; method (2)

 14;164:7;165:11; matched (1) meat (1) 162:2,4,6,8,10,12,16, 55:5;137:17 

166:4 97:15 165:21 18,23;163:10;164:11, methodology (1)

map (4) material (12) mechanism (1) 13,17;165:19;166:2, 148:17 

28:17;85:15;94:23, 137:8;146:9;148:8; 58:23 11,16;167:14,19,20, methods (12)

 23 151:14,23;153:15; media (2) 22,23 39:13;59:23;80:7;

Maple (4) 156:9;158:19,23; 81:22,23 members (18) 82:18;89:10;101:11;

 106:11;108:10,12, 160:1;161:6,12 medium (1) 0:5;6:1,7,21,24;7:5; 137:18,21;138:18;

 14 materially (1) 89:10 8:10;9:5;12:3,15; 142:15,15,19 

maps (2) 78:10 meet (3) 15:23;25:7;34:1; metro (1)

 84:1,2 materials (9) 48:21;126:10,14 36:12;77:23;123:13; 95:14 

March (5) 19:9;52:17;75:22; meeting (35) 124:14;132:3 Michelle (4)

 37:3;63:8;74:23; 77:22;89:4;140:3; 0:7,9,24;6:22;7:16, memo (3) 6:16;16:9;66:17;

 99:6,6 152:10;156:13; 20;8:12;9:18,19;11:5, 30:8;44:11,13 69:24 

Mardi (1) 163:16 5;12:14,15;15:1;16:7; memorandum (1) micro (3)

 126:14 math (3) 23:8;28:16;44:10,13; 38:10 31:5,8;115:10 

Margaret (1) 39:14,15,18 45:11;48:22,23; memos (3) microbes (1)

 21:12 matter (5) 50:17;53:18;73:5,6; 44:7,7,9 91:25 

mark (3) 17:15;35:2;82:23; 74:3,21,22;81:17; mentee (1) microphone (3)

 0:23;62:14;64:12 114:4;139:15 122:10;127:16; 76:5 123:17,18,19 

marked (1) matters (3) 128:14;151:16; mentees (11) microscopes (2)

 141:24 33:3;35:2,14 168:17 75:7;91:11,23;92:3; 91:25;114:16 

market (53) may (17) meetings (7) 94:6,12;97:13;99:12, Mid-Atlantic (3)

 11:16;19:16;22:20; 21:5,7;46:6;49:13; 0:9;28:24;33:20; 16;106:5;117:10 73:17;74:7;92:16 

23:21;29:4,24;34:4,6; 54:18;63:1;66:1; 42:20;51:13,13; mention (3) middle (5)

 37:22;38:19;56:1,20; 68:17;82:16;84:7; 154:15 8:5;55:24;98:2 23:5;62:10;72:7;

 57:7,7,8,15,16;58:5,7; 88:18;109:5;114:9; member (211) mentioned (19) 126:6;167:12 

72:21;75:18;82:9; 115:18;160:20,21; 9:12;10:1,11,18,20, 45:17;47:13;57:10; mid-sized (1)

 93:10,15;105:20,20, 165:1 21;11:1,8,22,24;13:9, 65:2;87:3;100:2; 49:14 

23;111:8;117:5,6,8, maybe (15) 20,22;14:4,19;42:1; 101:14;102:6;105:23; might (18)

 24;118:2,7,25;141:2; 18:6;26:6;60:18; 44:6;45:13;47:8;51:7; 106:7;113:11;114:4; 9:22;15:10;28:8,21;

 161:2,2;163:3,21,23, 63:13;112:8;116:24; 54:22;55:18;58:15; 115:24;117:19; 29:1;32:10;48:5;49:1; 

Min-U-Script® Burke Court Reporting & Transcription (18) manager - might 

(973) 692-0660 
 NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 3 

November 24, 2023 

57:15;63:21;64:8;

 67:2;68:23;69:21;

 107:20;116:20;158:8;

 160:8 

migrated (1)

 11:15 

mike (5)

 9:4;24:7;110:20;

 124:1;132:8 

miles (1)

 17:1 

milk (1)

 153:16 

milkhouse (1)

 153:2 

milking (2)

 22:12;151:20 

million (2)

 8:1;28:9 

Milwaukee (1)

 124:5 

mind (7)

 24:3;43:13;45:23;

 55:11;104:17;131:24;

 161:5 

mind-blowing (1)

 101:1 

Mindee (1)

 15:1 

minds (1)

 54:21 

mine (1)

 83:24 

46:22;68:13 

modules (2)

 35:15,24 

Moffitt (1)

 22:25 

MOFGA (5)

 92:9,12,12;93:20,

 24 

mom (12)

 16:17,22;17:19;

 18:1,8,11,14,22;19:7,

 19;20:3,13 

moment (3)

 108:11;114:10;

 162:24 

momentum (1)

 112:12 

moms (1)

 18:10 

mom's (2)

 17:11;23:21 

money (4)

 27:10;41:15;99:19;

 123:8 

Montana (4)

 15:8;20:19;23:1,5 

Monterey (1)

 11:9 

month (4)

 29:19;31:13;

 106:19;122:19 

month-long (2)

 25:20,21 

0:3;6:4;10:2;11:1,6,

 8;12:13;13:10,20;

 14:19;24:9;56:17;

 103:4;135:8 

Moss (4)

 104:10,11,12;

 126:20 

most (22)

 10:24;19:16;20:19;

 63:14;67:6;77:3;

 79:21,21;85:17;

 103:2;119:2,3,10;

 121:5,14;143:14,14,

 15;144:4;148:15;

 161:6;165:21 

mostly (6)

 10:13;122:4;123:5;

 128:22;149:14;

 156:18 

mother (2)

 18:11;23:24 

mothers (2)

 21:17;22:14 

mother's (1)

 19:17 

motion (21)

 60:21;130:11;

 132:1,10,11;133:21;

 135:4,25;137:2,6;

 146:2,8;148:1,5;

 151:6,12;156:1,8;

 158:5,21;162:21 

motioned (1)

 9;51:8;55:18;58:20;

 60:10,18;66:18;69:1;

 71:16,17;76:11;79:3,

 15,24;83:11,20;

 93:11;96:22,23;

 101:21;105:11,12;

 106:12;109:22;

 110:18;111:1,3;

 116:19;121:2;123:7;

 126:17;127:5,15;

 128:24;141:11,21;

 145:25;148:24;

 158:16;165:5;168:13,

 15 

multiple (6)

 27:11;42:2;51:22;

 78:2;148:14;151:24 

music (1)

 9:20 

Musk (1)

 124:18 

must (8)

 21:19;23:16;60:14;

 83:7;85:2,2;124:16;

 148:4 

mutual (1)

 77:3 

myself (5)

 20:11;61:17;66:13;

 100:20;168:9 

22;136:2;137:5;

 140:25;143:5;145:19;

 147:20;148:9;149:6;

 150:21;151:13;

 155:14;156:4;157:16;

 158:18;162:5,23;

 166:16 

Nate's (2)

 50:20,21 

nation (2)

 94:25;110:8 

National (32)

 0:4,7,9;6:1,15,24;

 7:3,23;12:11;17:16;

 24:10,25;27:19;41:1;

 43:15;44:5;49:10;

 50:9;52:20;53:18;

 55:7;57:9;66:20;

 77:16;130:11;135:21;

 137:24;148:6,16;

 151:12;156:8;158:21 

nations (1)

 78:4 

nation's (1)

 84:15 

nationwide (1)

 109:25 

Native (2)

 123:6;125:2 

Natural (9)

 10:4,23;13:23;

 17:25;25:4;68:6;

 160:14,21,23 

N 

mined (1) months (10) 130:13 name (14) naturally (1)

 153:20 33:14;36:25;43:10; motivate (2) 6:23;11:1,25;12:16; 32:1 

mineral (6) 60:24;63:4;74:22; 114:5,12 13:20;26:6;61:10; navigate (2)

 158:20,21,25; 89:15;102:23;123:17; motto (2) 79:5;92:11;98:6; 17:20;89:24 

159:1,21;161:17 126:9 15:25;79:16 100:16;104:11;107:4; navigating (2)

Minnesota (1) more (86) Mountain (3) 132:7 107:24;118:6 

22:3 8:2,3;15:13;17:23; 82:10;105:7;106:6 named (1) near (1)

minute (2) 21:4;25:8;26:2,23; mountains (4) 123:7 23:13 

23:11;106:20 28:18;29:3,7,11;31:2; 21:3;76:9;100:17; nametags (1) Nebraska (3)

minutes (10) 37:22;41:24;42:19; 101:4 97:22 12:17;13:1;20:20 

15:24;16:6,7,8; 43:6,8;45:23;48:2; mouth (1) NANDWANI (17) necessarily (6)

 26:24;83:21;102:1; 52:4;53:2;56:12;57:3, 123:3 11:1,2;113:3;115:8; 45:20;59:24;

 129:3;158:8,18 3,6;59:8,8,13;60:9; move (7) 120:9;122:22;133:2; 105:15,18;112:19;

Mirenda (1) 61:11;64:16;66:18; 23:19;51:18;54:13; 134:4;136:5;142:12; 149:14 

6:25 68:21;69:5,5;75:15, 60:7;69:21;121:4; 143:2;144:23;147:23; necessity (2)

missed (2) 20;77:21;81:5,24; 133:23 150:24;155:17; 148:13;156:19 

29:18;126:18 83:3;84:13,22;85:24; move/add (1) 157:19;162:8 need (47)

missing (1) 86:2,24;95:10;96:5; 142:1 narrative (1) 18:8;26:7;29:12;

 101:22 97:5;100:11;101:7; moved (2) 118:18 31:17;33:18;34:9;

mitigate (1) 102:25;103:9;105:17; 14:12;72:23 narratives (1) 38:20;40:2,6,9;46:6;

 48:17 106:15,16;107:23; movement (3) 80:4 53:22,23;54:12;

mixed (1) 108:14;109:4;111:21, 78:20;80:18;84:6 Nashville (1) 56:10;57:19;58:1,1,4,

 93:7 23,23,25;115:10; moving (9) 11:3 5;61:14;64:2;75:16;

model (2) 118:4,22;121:24; 24:10;71:6;77:25; Nate (40) 107:23,25;111:16;

 95:25;108:7 122:3,3,13,15,15; 112:25;114:18; 6:2;9:4,5,10;10:21; 113:18;118:6,14,20,

modified (1) 123:10;125:24;127:4; 119:23;127:25; 13:9,25;15:7,22; 25;120:1,17;123:8,

 49:1 129:20;148:11;149:7; 131:24;142:6 16:10;45:11;55:20; 10;125:14;130:25;

module (10) 152:19;153:5;154:8; much (49) 64:14;128:2;129:11; 131:1,14;132:17;

 31:11;35:16,22; 158:6;160:23;163:3,4 9:14;12:14;19:13; 130:12,13,14;131:16; 138:12;140:17,20;

 36:4,6,18,25;37:6; morning (14) 25:2;39:14;40:4;43:9, 132:24;134:1;135:7, 149:10;151:17; 

Min-U-Script® Burke Court Reporting & Transcription (19) migrated - need 

(973) 692-0660 
 NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 3 

November 24, 2023 

160:23;163:25 

needed (9)

 98:18,24;101:22;

 119:8,25;123:1;

 142:1,5;151:19 

needing (1)

 153:11 

needle (1)

 23:20 

needs (10)

 33:10;35:12;39:5;

 54:5;78:20;81:19;

 116:5;121:24;122:12;

 123:3 

negative (1)

 135:20 

neighborhoods (1)

 78:8 

nematodes (1)

 114:18 

network (6)

 29:15;74:11,24;

 88:7;101:6;102:3 

networking (1)

 88:13 

networks (3)

 74:24;85:5;88:11 

new (58)

 0:14;7:5,11,12;

 8:10,12,15,18;22:4,

 13;23:21;25:4;28:8;

 32:10;34:18;35:19;

 36:1;38:7;39:7;41:2;

 52:9;56:10,10,12;

 57:8;71:13,15,25;

 73:9;76:7,25;78:5;

 81:15;84:7;85:10,13,

 16;86:4,17;87:6,11;

 88:12,15;89:16;

 93:16;94:18,21,24;

 95:5,8,13;96:5,7;

 97:12;99:1,23;106:8;

 108:19 

Newark (1)

 78:6 

newborn (1)

 16:15 

news (1)

 33:10 

newsletter (1)

 115:5 

Next (36)

 0:25;9:4,25;12:4;

 15:3,16;17:3;18:7;

nice (3)

 31:19;68:3;127:15 

nickname (1)

 79:6 

Nicole (3)

 104:10;107:2,4 

night (4)

 9:19;15:5;16:22;

 25:7 

nights (2)

 16:25;69:12 

nine (3)

 74:13;75:4;129:24 

nitrification (1)

 153:23 

nitrogen (1)

 53:17 

NOC (1)

 123:5 

nod (2)

 148:13,17 

NOFA (3)

 90:2,7;94:19 

NOFA/Connecticut (1)

 97:21 

NOFA/Maine (1)

 92:15 

NOFA/Mass (5)

 78:15;89:18,19;

 90:25;91:1 

NOFA/New (8)

 77:1;85:9;88:1,5,6,

 20;92:9;96:21 

NOFA/Vermont's (1)

 108:20 

nonactive (1)

 138:10 

non-compliances (2)

 60:3,5 

none (2)

 135:24;157:3 

non-GMO (4)

 138:4;140:5;

 142:24;144:7 

nonorganic (1)

 112:12 

non-organic (1)

 62:12 

nonprofit (1)

 72:8 

NOP (15)

 6:21;9:3;24:16,20;

 37:6;43:19;44:24;

 58:2,20;67:25;74:5;

 14:12;22:3;80:15 

Northeast (29)

 6:7;48:9;71:9,13;

 72:6;73:12,16,21;

 74:7,16;75:24;76:7,

 14;81:9;88:21;92:16;

 94:18;98:1,7,9;

 100:21,25;101:21;

 109:8;116:12,24;

 117:3,16,22 

northeastern (1)

 76:20 

Northern (3)

 13:11;76:6;108:16 

Northwest (1)

 168:6 

NOSB (16)

 15:13,21;20:19;

 23:25;42:20;43:13,

 17,19,21;44:3,6;

 73:14;77:1;87:21;

 138:2,19 

note (1)

 123:5 

noted (3)

 146:20;152:25;

 153:3 

notice (1)

 54:16 

November (2)

 75:25;130:21 

NRCS (7)

 68:6,7,17;90:18;

 102:12;111:9,22 

number (27)

 0:16;6:20;29:25;

 32:16,16;34:13;39:3,

 11,25;40:19;44:1,4;

 49:17,17;52:20;

 61:11;63:19;64:25;

 65:4;74:15,17;75:14;

 94:25;107:12,13,17;

 141:25 

numbers (1)

 101:15 

nut (1)

 91:12 

nutrient (1)

 86:22 

nuts (1)

 97:6 

75:19 

Obu (1)

 7:6 

obviously (1)

 154:16 

occurs (1)

 151:12 

OCIA (2)

 19:11;109:21 

October (1)

 22:21 

OFA (1)

 57:10 

off (14)

 9:15,25;18:24;22:5;

 24:5;45:11;54:24;

 67:11;74:22;86:1;

 129:4;132:6;142:9;

 161:19 

offer (3)

 91:24;104:23,25 

offered (3)

 20:22;22:8,9 

offering (1)

 109:2 

offerings (2)

 68:5,7 

Office (5)

 27:5,10;41:25;42:6;

 98:14 

officer (2)

 0:12;6:14 

offices (1)

 81:1 

official (1)

 0:8 

officially (1)

 0:6 

offline (1)

 81:21 

OFPA (4)

 137:18;139:9;

 142:19,22 

often (9)

 41:14;42:16;52:8,9;

 56:4;63:22;64:4;

 80:24;130:23 

OIG (1)

 43:10 

oil (8)

 13:13;158:20,21,

 25;159:1,1,21;161:17 

oils (3)

 148:5;149:3;166:12 

8:10 

onboarding (2)

 12:8;36:24 

once (8)

 0:13;74:22;82:23;

 83:1;100:6,6;106:18;

 164:18 

one (111)

 0:17;14:4;16:16,22,

 24;22:16,18;23:17;

 25:24;27:23,25;

 28:15,15;29:18,21;

 37:20;40:5,22;42:23,

 23;43:4;46:22;50:8,

 16,17;51:5;52:1;57:8,

 10,11;61:8;63:2;67:6;

 76:4,13;77:6;78:15;

 80:5;84:17;86:13;

 87:5,6,8;90:4,19;

 94:22;95:14,18,18;

 97:1;100:10;102:10;

 103:2,20;104:13;

 108:13;110:5;111:10,

 22;112:6,7;113:5,22;

 114:8,13;115:20;

 116:7;118:5,22;

 121:3,18;122:6,11;

 123:13,20;124:13,20;

 125:13,25;127:12,21;

 128:14;130:1;131:2,

 24;137:10;139:8,9;

 140:11,19;141:23;

 142:7;143:10;144:9;

 146:14;151:18,18;

 153:14;154:2,6,6;

 156:14,20,20;158:6;

 161:4;163:20,20;

 166:24;167:7;168:14 

one-on-one (4)

 75:8;99:3,20;109:2 

ones (2)

 46:22;121:14 

on-farm (2)

 88:15;89:1 

ongoing (2)

 39:1;153:4 

online (12)

 0:6;8:8;29:9;34:17;

 43:22;44:9;63:23;

 69:6;73:5;74:21;

 81:21;106:19 

only (30)

 16:19;18:13;21:6,

 10,22;35:1;40:8,17;

O 

24:7;30:21;31:7,13; 87:21;94:13;110:9; objects (1) old (3) 55:9;58:6;61:13,20,

 37:3;60:6;61:16;71:6; 138:19 32:6 16:13,19;80:10 23;63:15;65:6;73:22;

 77:13;86:19;87:25; NOP's (2) obligation (1) OLPS (1) 74:22;84:12;87:5,6;

 91:9,21;94:22;95:18; 10:8;65:10 168:3 53:16 91:5;101:8;109:17;

 98:2;99:11;104:9; norm (1) obligations (1) Olympia (1) 125:23;130:8,10;

 107:8;135:11;137:5; 23:25 34:6 10:21 138:3;140:7;159:6;

 141:8;146:6;148:3; normal (1) observations (2) OMB (1) 165:4 

149:22;151:8;156:4; 17:9 32:22;67:16 44:16 onto (2)

 163:7 North (3) obstacle (1) onboard (1) 16:6;61:5 

Min-U-Script® Burke Court Reporting & Transcription (20) needed - onto 

(973) 692-0660 
 NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 3 

November 24, 2023 

OOL (1)

 53:14 

open (13)

 0:6;24:24;43:7,10;

 44:2;45:8;59:19,20;

 60:5;63:6;108:19;

 116:10;154:10 

opened (1)

 38:11 

opening (1)

 119:21 

openness (1)

 52:10 

operate (1)

 125:8 

operating (2)

 11:14;65:17 

operation (5)

 14:21;30:24;76:5;

 87:5;131:8 

operations (20)

 25:25;26:4;30:4,10;

 12:25;13:12;14:1,8;

 15:11;16:3;17:13,16,

 19;18:4,15,18,18,19;

 19:2,4,6,8,18,19,23,

 24,24;20:11,21,21;

 21:3,5,13,16,18,20,

 23;22:4,8,9,18,20,21,

 22,23;23:6,12,16,17,

 24;24:10,14,20,25;

 26:2,4,8,15,22;27:8,9,

 19,20,21,22,24;28:6;

 29:2,6,11,24,24;30:3,

 10;31:18;32:2,9,13,

 15;33:4,5;35:20,21;

 36:6,7;37:5,11,14,17,

 18,21;39:3,13,15;

 40:6;41:1,5;42:13;

 43:15;45:2,3;46:3;

 47:5,12,17,22,23;

 48:3;49:11;50:6,7,9;

 51:10;52:7,8,12;

 53:11,11,15,15;55:17;

 91:15 

organically-managed (1)

 151:11 

organics (5)

 14:21;55:23;82:11;

 105:21;143:18 

organisms (1)

 115:11 

organization (7)

 45:4;52:9;57:10;

 85:18;102:21;104:20;

 122:5 

Organizational (1)

 88:11 

organizations (14)

 23:19;73:20;75:6;

 78:7;84:5,10;96:21;

 98:17;101:20,24;

 103:6;108:9;112:12,

 13 

organizing (1)

 28:24 

166:13,25 

outbreak (1)

 144:17 

outcome (1)

 7:14 

outline (1)

 139:4 

outlines (1)

 152:23 

outlining (1)

 67:16 

outlook (1)

 17:8 

outreach (17)

 33:8;34:12;39:2;

 75:22;87:10;88:8;

 91:10;93:2,6;94:6,8;

 101:17;102:2;103:20,

 25;106:2,16 

outside (4)

 0:19;34:3;144:4;

 159:12 

100:25 

owe (1)

 143:6 

owed (1)

 82:9 

own (18)

 20:6;21:8;22:19;

 23:18;28:21;32:3;

 34:21;35:21;76:10;

 81:23;83:22;84:12,

 22;94:10;101:9;

 102:20;125:24;

 161:12 

owned (1)

 17:5 

owners (1)

 93:8 

owning (1)

 11:14 

P 

32:17;35:25;36:2; 56:5,8,12;57:2,11; origin (3) outstanding (1) Pacific (1)

 39:5,25;40:25;54:3; 59:15;62:13;66:14, 53:10,14;54:1 140:12 168:6 

55:16;56:9,11;65:5, 21;67:8,18,18;68:4, OSP (3) over (45) packer (1)

 23;101:16;107:12; 14,18,22;69:3,6;71:8, 19:12;31:15;32:2 6:25;8:25;9:4;12:2; 14:8 

108:12;167:8 17;72:5,11,13,19; OTA (1) 15:16,20;16:10;18:7; packs (1)

opinion (1) 73:1,2,17;74:1,8,9,19; 83:14 22:17;23:8;24:7; 89:3 

161:9 75:3,23;76:24;77:3; others (2) 25:12,20;29:19; page (1)

opportunities (9) 78:15,19;80:8,9,21, 47:13;68:12 32:23;42:9;43:4;44:2; 77:16 

88:13,17;93:3,10, 21;81:5,8,20;82:19, otherwise (2) 60:4;71:4,12;72:8; paid (1)

 15;94:4;97:16; 22;83:1,5;84:6,15,18, 137:21;149:8 73:22;75:7;78:18; 111:14 

107:19;112:9 20,20;85:3,16,25; ours (1) 79:21;90:11;92:21; pain (2)

opportunity (20) 86:6,7,20,24;87:5; 112:17 96:20;97:13;98:1; 135:17;146:17 

11:19;13:7;14:13; 88:18,21,23,25;89:12, ourselves (3) 99:11;104:14;107:2; pan (1)

 32:13;73:15;78:17; 20,24;90:1,10,13; 128:23;141:9; 110:8;113:13;125:15, 164:18 

84:14;92:5;95:10; 91:16;92:12,18;93:3, 143:11 18;129:10;135:22; pandemic (3)

 96:23;100:17;101:2; 6,10,12,12,17,20; out (86) 137:25;138:10;152:7; 73:6;79:8;121:10 

106:22,25;107:7,19; 94:2,4,14,18;95:2,6,7, 0:15,18;11:10,19; 154:9;167:7 panel (5)

 108:3;161:2,2;168:7 11,13,16,24;96:15,18, 15:3,7;18:14,19; overall (1) 123:5,6;130:21,23;

opposite (1) 25;97:3;98:7,15,20; 19:12;20:20;22:8; 44:2 154:2 

128:21 99:5,7,15;100:3,4,9, 26:6;31:11;32:21; overcoming (1) panels (1)

OPS (1) 24;101:11,15,19; 33:17;35:9,12;40:14; 49:15 130:23 

32:1 102:5,14,19;103:9,9, 41:19;43:24;44:10; overlapping (2) papers (1)

option (1) 23;104:5,14,17; 49:18;50:18,21;52:1; 52:24;123:21 66:15 

29:2 105:10,12,16,23; 53:2;54:8,9;56:6; overly (1) paperwork (4)

options (6) 106:3,10,21;107:5,17, 61:19;62:9,18;63:12, 62:10 100:7;105:6,17;

 56:1;130:25;131:1, 21,25;108:12,14; 19,20;64:2,18,24; overseas (3) 126:25 

5,18;148:14 109:12;110:15,16; 65:3,21;67:7;68:16; 12:20;40:23;64:25 parasites (1)

oral (2) 111:7,8,11;112:11; 69:6,12;79:12;80:3, oversee (7) 159:3 

51:14;61:2 113:14,18;114:6,7; 23;83:5;85:7,19; 14:13;26:19;27:1; parent (1)

orchard (1) 115:11;117:3,3; 90:21;91:12;92:13; 37:18;38:23;65:17,21 19:17 

76:24 120:16;121:5,6; 96:1;97:21;98:20; overseeing (2) parents (5)

order (5) 122:11,12;128:7,25; 99:10,19;102:25; 45:25;57:24 16:25;17:6;19:5,15;

 38:19;46:7;57:20; 131:18,19,19;138:23; 104:13;105:24; oversight (20) 80:11 

77:24;121:22 140:18,20;142:20; 113:12,16;114:10; 13:5;26:10,11,22; parents' (1)

ordered (1) 143:21;144:17; 115:5;119:20,23; 27:2,3,24;32:19; 16:14 

18:17 163:23;164:2,3,5; 120:11,19,25;121:8; 37:17;39:8,12;42:6; parlayed (1)

Oregon (2) 165:3,5,20,22;166:3, 122:1;123:11;128:10; 48:19;56:19,23;58:6, 126:22 

22:3;109:21 4,7,12,12,12;167:8, 130:10;140:18; 10;59:3;65:10,13 parlor (1)

Organic (305) 11,19 143:17;148:10; overview (1) 22:12 

0:4,7,9;6:1,8,16; organically (4) 151:22;158:9;160:15, 24:23 part (54)

 7:22;8:23;9:7;10:6; 13:1;22:15;55:1; 24;161:10;163:20; overwhelming (1) 6:10;9:3;10:7; 

Min-U-Script® Burke Court Reporting & Transcription (21) OOL - part 

(973) 692-0660 
 NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 3 

November 24, 2023 

19:13;24:13,14; pass (1) 84:5,18;85:2;87:12 31:25;83:22 pig (3)

 25:20;30:3,6,25;31:3; 81:12 Pennsylvania's (1) pessimistic (1) 167:3,8,16 

32:7;33:9;37:20;38:5; passed (1) 84:23 8:11 pigs (1)

 39:1;45:11;49:14,16, 12:23 Penny (1) pest (2) 167:23 

21,23;50:12,24,25; passion (3) 7:17 89:11;156:6 pillar (1)

 53:1;54:4,4;55:8; 21:21;73:2;163:1 people (57) pesticides (3) 111:22 

58:11,12,13;59:3; past (14) 8:5,12;10:14;18:1; 17:14;18:12;80:6 pillars (1)

 62:3,25;65:2;66:24; 15:14;20:12,18; 20:12;21:4;25:3,5,8, PETREY (11) 111:8 

67:18;68:18;71:6; 33:25;42:10,20,20; 15;26:17,18;27:1; 14:19,20;133:16; pioneering (1)

 79:10;81:4;82:5,6; 43:4;71:17;96:20; 29:17,19;30:16; 134:18;136:18; 124:4 

93:18;103:18;105:22; 129:6;154:22;156:25; 31:10,15;32:10,11; 145:12;147:13; pioneers (1)

 106:6;107:16;116:13; 163:1 33:11;34:8,14;41:22, 150:14;155:7;157:9; 84:20 

131:20,21;139:22; pasture (4) 24;44:15;45:1;49:20, 161:23 Pittsburgh (3)

 157:1;165:19 88:23;97:4;101:4; 23;50:23;57:20; petroleum (1) 73:4,6;78:13 

participate (2) 108:1 62:25;63:11,22,22,23, 158:25 pivot (1)

 112:11;141:2 path (4) 24;72:10,10;79:11; PFAS (1) 77:24 

participating (1) 19:18,19;23:16; 81:6;87:18;90:9,17; 54:25 place (17)

 98:25 47:22 91:6,17;96:13;97:15; ph (10) 7:16;9:22;22:6;

participation (1) pathways (1) 106:23;109:20; 7:18,18;21:12; 38:3;40:1;44:17;

 77:22 73:9 118:15,19;122:18; 82:20,21,21;96:17; 46:14;48:14;53:7;

particular (8) patience (1) 125:1;127:13,14; 109:18;116:10;123:7 57:6;76:13;83:20;

 57:4;65:3;72:9; 112:21 149:18 phase (1) 88:16;111:14;119:3;

 111:22;115:24; patient (1) people's (1) 30:16 143:1,11 

116:12;129:22; 85:7 33:19 phased (1) places (5)

 166:21 pattern (1) per (1) 33:16 38:1;65:6,18;

particularly (5) 156:11 29:19 phenomenal (2) 122:13;137:18 

13:24;14:2;36:19; Paula (1) perceived (1) 127:14,14 plain (2)

 40:20;140:11 82:23 20:8 Philadelphia (1) 22:1,2 

partly (1) Paulette (2) percent (12) 78:6 plan (9)

 120:12 82:21,24 12:19;43:8;44:2,4; philosophy (1) 18:16;28:4;31:14;

partner (16) pavement (1) 95:6;107:13;109:14; 165:9 68:22;81:9;94:5;99:4;

 35:16;38:16;46:21; 87:11 113:7,8,9,9;142:13 phone (5) 126:6;129:2 

47:2;83:19;84:9;87:8; pay (7) percentage (1) 51:3;63:3,5;69:12; planet (1)

 88:9,20;89:2,9;92:15; 42:14,16;111:18; 95:5 125:12 84:10 

93:25;101:19;103:22; 124:8,12,16,21 perception (1) phosphate (2) planned (2)

 104:4 paying (1) 140:14 153:20,23 79:1;81:21 

partnered (3) 34:8 perfect (2) phosphoric (8) planner (1)

 96:16,19;117:2 payment (1) 66:21;118:23 151:9,10,12,25; 14:10 

partnering (8) 18:16 perfectly (1) 153:1,15,21;156:12 planning (4)

 57:11;78:13;99:1; payments (1) 66:1 photo (1) 28:3;96:12;108:21,

 101:24;103:19;108:9, 117:19 performance (1) 82:10 22 

16,20 PayPal (1) 28:4 photograph (1) plans (1)

partners (28) 119:5 perhaps (4) 102:10 93:14 

28:17,19,21,23; PCO (18) 50:12;54:24; photographer (2) Plant (4)

 29:16;35:17;45:15; 12:1;72:5,6,7,17; 123:11;153:7 0:20,23 9:1;21:25;82:15;

 50:9;71:25;74:5,14, 73:8,16;74:24;77:14; period (3) photography (1) 83:3 

23;75:4,5,12,12,13; 83:24;84:4;85:4; 57:6;67:8;109:10 0:24 planting (3)

 78:16;87:16;88:7,12; 87:20;97:24;98:9; peripheral (1) phthalates (1) 76:15;82:18;126:8 

89:15;92:23;93:22; 101:20;110:1,3 111:5 55:1 plants (1)

 96:16;108:23,25; PCO's (2) permitted (1) physical (2) 124:10 

110:10 74:10,13 156:6 62:14;156:7 plastic (4)

Partnership (15) pdf (1) person (4) pick (2) 52:6,14;53:1;55:3 

6:8;7:22;14:1; 68:11 11:5;15:23;66:14; 124:2;125:12 plastics (6)

 22:24;27:8;28:6; peak (1) 74:22 picking (1) 51:16,20,23;54:23,

 31:19;71:8;73:17; 28:13 personal (3) 51:3 24;55:2 

74:12,18;90:5;93:22; Pelletier (3) 51:2;58:12;72:25 picture (2) plates (1)

 108:7;116:24 97:20,23;98:6 personally (2) 24:24;90:16 8:9 

partnerships (3) penalties (2) 8:2;11:18 pictures (1) platform (3)

 75:1;99:9;116:22 41:2,15 personnel (1) 0:23 79:4,4;124:22 

parts (3) penalty (2) 25:5 piece (3) play (2)

 34:24;68:4,22 42:14,16 perspective (1) 68:4;80:5;106:21 36:10;115:11 

party (1) Pennsylvania (7) 48:4 pieces (1) played (1)

 49:20 72:5;81:15;83:24; perspectives (2) 27:23 7:19 

Min-U-Script® Burke Court Reporting & Transcription (22) participate - played 

(973) 692-0660 
 NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 3 

November 24, 2023 

playing (2) 42:2,3 10,12,14,16,18,20,22, president (1) 11;107:24;109:16;

 7:21;66:1 portion (1) 24;148:2;149:4,21; 78:24 122:19;135:8;142:21;

pleas (2) 63:5 150:3,7,9,11,13,15,17, pressing (1) 148:22;149:1;154:17,

 19:17,17 ports (2) 19,21,23,25;151:2,4, 129:17 21;159:22;165:8 

please (30) 42:4,5 7;154:12,23;155:2,4, pretty (7) processed (2)

 6:22;9:25;20:21; position (3) 6,8,10,12,14,16,18,20, 48:11;53:9;60:2; 118:13;153:21 

37:11,11,12;51:6; 81:12;144:1,3 22,24;156:3;157:2,6, 71:20;87:7;102:7; processes (2)

 55:13,19;58:14; positive (1) 8,10,12,14,16,18,20, 123:7 48:19;55:9 

62:22;64:13;79:1; 112:7 22,24;158:1,3,6,10; preventative (1) processing (8)

 85:15;110:25;115:13; positively (1) 159:17,19,23;160:12; 144:2 25:25;49:17;

 117:13;122:25; 51:19 161:4,22,24;162:1,3, preventing (1) 101:16;118:7,8,11;

 123:12;132:7,20; possible (7) 5,7,9,11,13,15,17,19, 39:18 165:21,22 

133:5;139:2;140:15; 19:8;22:21;48:5; 22;163:8,11;164:12, previous (1) processors (1)

 141:6;154:13;158:7; 64:1;68:5;144:2,6 15;165:17;166:1,14, 53:18 89:24 

164:12;165:18; possibly (1) 24;167:21;168:11 previously (3) produce (3)

 167:13 163:18 power (1) 8:25;29:1;106:7 18:20;77:23;119:17 

pleased (3) post (1) 143:11 price (3) produced (8)

 7:15;8:15;10:14 63:25 powerful (4) 18:1;56:1;105:21 52:5;95:2,4,11,13;

pleasure (2) posted (4) 50:20;77:3;117:17; prices (1) 137:21;148:5,18 

73:19;85:8 0:13;30:11,12;44:7 127:19 105:20 producer (3)

plenty (1) post-harvest (1) powerfully (1) primarily (2) 31:14;94:6;161:11 

94:25 11:15 123:9 11:12;57:22 producer/grower (1)

pluck (1) post-pandemic (1) practicality (1) primary (3) 11:13 

18:24 25:2 139:15 13:4;40:9;66:18 producers (26)

pm (5) posts (1) practically (1) primer (1) 47:12,23;49:15;

 70:3;71:2;129:4,4; 39:7 139:4 34:18 55:25;56:5,8;86:20,

 168:17 potatoes (2) practice (6) primers (1) 21;87:8;88:18,21;

Poconos (1) 89:8,12 7:3;44:4;53:12; 34:18 93:2,16;106:11;

 104:16 potential (2) 72:18;152:22;164:20 priorities (11) 107:14,23,25;108:14;

point (19) 76:14;102:3 practices (20) 44:12,14,18,21; 111:12,17;112:11;

 26:5;35:3;52:10; poultry (4) 31:9,16;57:6;68:15; 53:7;141:25;142:2,4, 127:1;131:6;139:16;

 53:19;60:19,20;61:2; 53:12,15;101:5,6 71:22;80:3;81:10; 7,10;164:21 143:15;144:1 

62:16,23;64:16;69:2; pound (1) 82:13;88:14;91:16; priority (3) producing (1)

 84:25;105:21;129:18; 69:12 97:3;102:17;103:17; 53:9,21;54:21 89:5 

151:21;161:14; pounding (1) 105:10;106:3;108:1, prison (1) product (6)

 166:18;167:10,12 87:10 2;144:2;156:19;165:7 41:23 41:7,17;89:6;

pointed (2) Powell-Palm (201) practicing (2) private (2) 108:18;159:2;166:19 

104:13;128:10 6:2;9:4,14;10:10, 36:12;122:12 95:22;143:22 production (32)

points (5) 17,19;11:21,23; prairies (1) privilege (1) 13:12;52:15;53:4;

 29:22;40:5;46:1; 14:25;15:7;16:11; 21:2 9:10 55:1;56:6;73:2;77:3;

 100:9;137:13 24:3,6;45:9;47:7; praise (1) privileged (2) 82:14;88:14,25;

policies (1) 51:6;55:19;58:14; 60:12 45:2;71:24 89:13;90:10;93:13;

 49:1 64:11;66:9,25;69:8; precedent (1) proactive (1) 95:9;97:10;100:25;

policy (9) 71:3;77:9;110:22; 160:6 50:7 103:9,24;113:19;

 0:11;8:24;12:1; 112:1,4;113:2; pre-conference (1) probably (9) 131:5;135:14;138:13,

 31:23;37:16;48:16; 115:13;116:16; 103:8 21:8;91:2;98:11; 23;140:18;142:20;

 52:21;54:19;104:24 117:13;120:7;122:24; preliminarily (1) 119:2;143:20;148:10; 143:21;149:2;163:15;

polite (1) 123:23;124:3;126:17; 28:18 152:14;159:25; 164:23;165:3,5;

 161:7 127:3,22,24;129:2,5; pre-OSP (1) 161:16 167:12 

pollution (1) 130:4,12,13,14,15; 31:15 problem (6) productively (1)

 153:23 131:16,21;132:13,16, pre-regulatory (1) 30:16;52:12;55:3,3, 51:19 

poor (1) 22,24;133:1,4,7,9,11, 30:16 17;63:1 products (6)

 125:6 13,15,17,19,23;134:1, presence (2) problems (1) 41:7;151:24;152:2;

popular (1) 3,5,7,9,11,13,15,17, 57:1;137:16 39:18 160:21,23;165:22 

119:2 19,21,23;135:1,6,23; present (2) procedures (1) Professional (1)

population (1) 136:4,7,9,11,13,15,17, 64:12;83:21 0:11 72:18 

78:4 19,21,23,25;137:4; presentation (6) proceed (3) professions (2)

populations (1) 139:2;140:9,25; 24:16,21;45:17; 53:22;54:12;152:1 72:10,20 

116:1 141:4,10,13,22; 71:7;116:19;120:11 process (24) profile (1)

pork (7) 142:11;143:4,9; presentations (2) 29:5,14;40:18; 77:2 

101:5;163:23; 144:24;145:1,3,5,7,9, 24:20;113:4 46:24;52:20;54:19; profit (1)

 164:2,3,5,13;165:3 11,13,15,17,19,21,24; presenters (1) 67:13;78:22;84:8; 41:19 

Port (2) 146:5,22;147:2,4,6,8, 69:20 89:25;94:15;100:6, profits (1) 

Min-U-Script® Burke Court Reporting & Transcription (23) playing - profits 

(973) 692-0660 
 NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 3 

November 24, 2023 

119:24 

Program (74)

 0:4;6:1,5,8,16,18;

 7:11,22;8:1;14:1;

 16:3;17:16;22:24;

 24:10,25;26:3;27:7,8,

 19;28:3,4,6,18;29:8,

 23;30:6;32:23;41:2,

 16;44:14;47:21;48:8;

 49:11,12,13,14,19;

 54:5;56:23;58:24;

 60:2;66:17,21;68:8,

 20,25;71:7,8;73:18;

 74:20;75:13,24;76:5;

 78:16,17;86:11;

 87:14;89:22;94:7;

 95:23;97:12;98:4;

 99:11;101:7;102:12;

 103:11,20,25;106:1,6;

 108:24;109:24;110:2;

 111:4 

programming (6)

 75:21;78:22;85:5;

 88:8;92:18;93:11 

programs (13)

 42:5;48:16;49:1,7,

 16,19;88:15;101:18;

 104:23,25;111:17;

 121:15,22 

program's (1)

 59:3 

progress (5)

 30:24;41:4;43:13;

 51:9;90:11 

prohibited (2)

 30:8;130:8 

project (17)

 8:14;67:12;73:23;

 75:5;78:14;90:21;

 91:1,7,9;92:23;93:1,

 23;100:8;102:14,24;

 103:7;108:18 

project-based (1)

 28:23 

projects (5)

 12:21;99:10;100:8;

 104:22,25 

9:19;18:14;54:16;

 60:7;166:25 

proposing (2)

 67:17;138:24 

protect (11)

 18:2;19:18;21:17,

 19;33:4;34:4,6;38:6,

 18;57:7,7 

protecting (4)

 28:2;38:15;61:23;

 62:18 

protection (14)

 13:23;38:9,14;41:3,

 4,6,11,16,21;42:1;

 47:5;58:6;59:6;

 118:11 

protections (1)

 34:11 

protects (2)

 40:11,11 

protested (1)

 80:16 

proud (3)

 20:24;92:15;109:9 

prove (1)

 110:15 

provide (15)

 16:20;48:18;82:3;

 94:13;98:17;99:2,9;

 100:9;101:21;103:8;

 111:15,19;119:7;

 135:17;152:5 

provided (3)

 75:8;88:16;151:10 

Providence (1)

 15:24 

providers (1)

 94:12 

provides (5)

 6:17;24:18;68:7;

 78:11,17 

providing (4)

 7:12;88:13;103:12;

 111:12 

provisions (2)

 32:24;37:21 

public (21)

 79:23;122:1,17,18 

Puget (1)

 168:8 

pull (1)

 140:18 

pulled (2)

 23:9;73:25 

pulling (1)

 92:2 

pulse (2)

 95:4,12 

pumping (1)

 9:20 

punctuated (1)

 22:11 

puppeteering (1)

 158:17 

purchased (1)

 19:5 

purchasing (1)

 13:13 

Purple (1)

 82:10 

purpose (3)

 37:3;48:15;158:25 

purposes (1)

 160:19 

push (2)

 64:2;119:7 

pushing (2)

 96:1;164:3 

put (19)

 25:13;39:3;46:14,

 23;47:4;48:14;51:17;

 57:6;96:24;120:4;

 139:5;144:1,19;

 154:4;163:20;164:7;

 165:2;166:16;168:1 

puts (2)

 38:3;111:4 

putting (8)

 54:7,9;95:23;96:22;

 140:5;144:3;159:21;

 166:13 

Quarter (1)

 75:13 

quarter-acre (1)

 126:22 

quick (4)

 42:9;61:8;69:9;

 141:6 

quickly (6)

 8:10;9:21;26:5;

 40:3;65:20;66:6 

quite (8)

 31:15;39:14;97:1;

 108:5;122:18;137:15;

 144:4;156:12 

R 

racial (1)

 49:2 

racism (2)

 91:3;118:8 

radar (2)

 115:19;156:24 

rain (1)

 23:10 

raise (5)

 16:18;21:9,10;

 101:4;165:13 

raised (3)

 30:23;73:4;93:17 

raises (1)

 47:5 

raising (2)

 20:5;165:6 

ramping (1)

 87:9 

ran (1)

 34:21 

ranchers (1)

 126:2 

ranked (1)

 53:8 

rapidly (1)

 61:5 

rarely (1)

 80:9 

rash (1)

 16;120:11,19,25 

read (6)

 33:23;42:21;62:6,8;

 130:2;137:11 

readers (1)

 115:7 

ready (9)

 7:20;14:24;36:17,

 21;91:20;100:6;

 131:15;132:19;

 146:21 

real (13)

 19:3;27:17;29:12;

 30:23;37:8;47:4;

 49:22;51:2;53:19;

 68:10;72:1;83:7;

 102:24 

realize (4)

 23:21;64:10;66:18;

 128:23 

realized (3)

 39:14;121:13;

 142:23 

real-life (1)

 29:6 

really (162)

 7:15;8:13;9:18,20;

 10:5,9;13:16;14:11,

 14;15:9;16:5;25:2;

 26:14;27:23;28:16;

 29:2;31:12,22;33:22;

 34:1,9;35:4;38:13;

 40:9;41:19,20;42:24,

 24;44:25;45:16,16;

 47:9,18,19;50:17,20,

 20;51:9,15;52:3;55:6,

 8,21;56:16;57:4;

 58:16;61:9,14;62:3,3,

 12,18,24;63:15,17;

 65:20;66:6,6,23,23;

 67:13,14,14;69:2,17;

 71:18,23,24;72:22,25;

 84:17;85:18,18;

 86:15;87:1,9;90:5,14,

 19;91:7,18;92:4,16,

 19;94:19;96:22;

 97:11,14,16;98:1,19;

Q 

prominent (1) 0:24;10:3,12;15:14; quagmire (1) 63:3 99:13,14;100:17,21,

 74:8 20:18;40:11;51:12, 121:21 rasping (1) 23;101:1,12,21;

promise (3) 24;56:3;60:13;67:23; qualified (1) 16:23 102:22,24;103:2,5,10,

 10:1;119:11;120:5 68:2;72:10,20,23; 30:14 rated (1) 13,15,16;104:1,4,17;

prompting (1) 77:1;111:18;124:6; qualify (1) 142:3 106:2,25;107:23;

 86:11 128:6;143:22;163:14 68:20 rather (4) 108:13;109:2;111:6,

proper (1) publication (1) quality (1) 74:12;135:25; 10,14;112:20,25;

 135:14 46:3 166:9 139:23;165:24 113:18,22;114:18,20,

property (3) publicly (6) quantitative (1) reach (10) 23;115:3,4,21;116:1;

 17:6;19:7;126:23 30:11,11,12;31:6; 39:12 85:19,23;91:8;96:3, 120:17;123:4;126:23;

proposal (1) 37:5;44:7 QUARCOO (13) 6,7;97:1;98:20;104:2; 127:17,18,20,21;

 67:11 published (2) 13:20,21;115:14; 123:11 129:21;130:22,24;

proposals (5) 32:14;44:16 116:15;133:12; reached (3) 131:14;138:6;139:15;

 29:25;30:1;68:2; publishing (1) 134:14;136:14;145:8; 75:7;121:8;122:1 140:7;141:8;142:4;

 92:24;93:1 31:12 147:9;150:10;155:3; reaching (7) 143:9;144:3,8,13,14;

proposed (5) Puerto (4) 157:5;162:18 50:18;86:2;113:12, 146:10;149:16,20,20, 

Min-U-Script® Burke Court Reporting & Transcription (24) Program - really 

(973) 692-0660 
 NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 3 

November 24, 2023 

24;156:20;163:5; 27:16;75:13 115:24;116:7;117:24; 94:2,8;106:3,16,25; 16:16 

164:18;165:23; recruitment (1) 121:4;127:17,18 112:10;113:1;121:15, replacing (1)

 166:21;167:6;168:15 94:6 regional (12) 16 149:23 

realm (1) recusals (9) 28:20,20;49:12; relative (1) replied (1)

 28:8 133:21;135:4; 72:6;74:13;77:17; 146:15 18:8 

real-time (1) 137:2;146:3;148:1; 84:4;87:20;92:15; relatively (4) report (13)

 24:18 151:6;156:1;158:5; 95:16,16;96:12 49:22;101:15; 16:12;30:9;35:25;

reap (1) 162:21 regionaliates (1) 129:22;135:17 44:6,10,21;48:24;

 80:22 Redding (1) 109:18 relevance (1) 59:12,16,17;60:8;

reason (1) 84:24 regionally (4) 14:15 91:4;92:1 

107:16 redeveloping (1) 74:24;95:4,11; reliance (1) reported (3)

reasonable (2) 78:8 103:13 114:22 29:16;35:5;44:25 

144:9;166:9 reduce (4) regions (7) reliant (1) reporting (4)

reasonably (2) 32:15;49:1;82:14; 7:23;28:10;77:15; 131:2 28:12;30:24;59:13,

 161:16;164:2 135:12 96:5;100:19;111:11; relief (4) 15 

reasons (2) reduced (1) 127:12 17:2;22:8,9;135:17 reports (2)

 58:12;103:20 114:22 region's (1) relisting (4) 6:5;27:6 

Rebecca (1) redundant (1) 74:10 146:20;153:13,14; represent (1)

 7:18 60:18 regionwide (1) 159:14 125:17 

recall (1) reel (1) 75:21 remain (1) representation (4)

 71:25 106:23 regs (1) 46:7 81:5;83:7;121:6;

recap (1) re-evaluate (1) 30:7 remains (2) 125:14 

151:16 142:7 regular (1) 53:20;148:16 representatives (2)

receive (3) refer (1) 43:19 remarkable (2) 41:25;143:16 

79:24;110:12; 35:10 regularly (5) 25:2;38:13 represented (3)

 148:20 reference (1) 39:7;41:12;44:6; remedy (1) 17:8;122:3,3 

received (9) 130:20 80:5;110:13 79:13 representing (4)

 13:6;16:6;19:15; references (1) regulated (3) remembered (1) 36:19;122:18;

 43:7;47:25;68:12; 80:23 33:8,10;35:9 23:11 131:11;143:14 

92:25;105:14;152:17 referring (1) regulations (10) remembers (1) request (1)

receiving (2) 35:22 32:15;46:8,10;60:7; 18:5 148:17 

64:19;153:24 refined (1) 68:4,9,16,23;69:4; remind (1) requested (1)

recent (1) 158:25 97:4 43:12 58:23 

40:22 reflect (2) regulatory (17) reminded (2) requests (1)

recently (3) 16:3;74:19 30:6;32:4;44:11,16, 29:18;128:8 33:2 

26:23;34:19;46:10 reflecting (1) 18,21;45:22;53:7; reminder (3) required (2)

recess (1) 38:5 65:16;128:10,13; 37:13;45:18;132:2 40:13;58:21 

70:3 reflection (1) 142:1,4,7;148:10; reminding (1) requirement (3)

recognition (2) 49:24 149:6,17 50:16 36:8;138:21;139:20 

26:20;35:18 reflects (1) reinforce (1) remiss (1) requirements (3)

recognize (4) 56:16 112:13 98:2 59:14;107:22;141:3 

109:18,25;112:21; refuge (4) reinstate (1) remixed (1) Requires (1)

 124:11 17:14;21:16,18; 66:4 80:24 32:17 

recognized (1) 22:16 reinstated (1) remote (3) requiring (2)

 111:15 refuse (1) 66:4 27:18;120:14; 40:15,16 

recommendation (12) 56:25 reiterate (2) 122:14 requisite (1)

 43:21;53:17;67:24; regarding (2) 97:24;165:15 removal (1) 39:17 

138:2,5,19;139:12,23; 151:17;164:19 reiteration (1) 138:24 research (9)

 140:12;141:18; regards (1) 149:1 remove (7) 14:5;17:17;72:14;

 144:14;149:22 122:20 related (14) 130:11;146:8; 84:20;126:21;160:24;

recommendations (12) regenerative (4) 7:14;8:24;27:22; 148:6;151:12;153:16; 164:21;165:3,15 

7:14;31:4;32:22; 69:1;76:20;101:11; 31:4;38:10;39:11; 156:8;158:21 researching (2)

 43:13,16,18;44:3; 110:16 48:25;50:8;53:17; removed (1) 66:14;161:16 

48:15,25;49:6;68:1; regime (1) 54:20;58:20;77:18; 153:17 reside (1)

 92:1 130:25 115:14;154:16 rent (1) 13:11 

record (5) Region (37) relates (1) 16:20 residue (1)

 24:5;125:23;129:4; 6:7;28:21;39:23; 28:1 rental (1) 58:22 

163:10;168:2 71:9,13,13,14,21; relationship (4) 16:14 resolved (2)

recordkeeping (3) 72:2,3;73:17,21;74:7, 81:1;90:11;112:8; repair (1) 43:6;60:6 

32:18;97:7;107:22 14,16,16,18,20;75:5, 121:7 86:17 resource (5)

recover (1) 10,20;77:20;78:1,5, relationships (17) repeat (1) 10:23;24:15;69:6;

 8:7 23;84:2;92:16;93:4; 75:1;77:7;78:19; 152:14 77:24;104:1 

recruit (2) 96:9;98:9;109:17; 81:10;86:2,5,12,18; replaced (1) Resources (21) 

Min-U-Script® Burke Court Reporting & Transcription (25) realm - Resources 

(973) 692-0660 
 NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 3 

November 24, 2023 

10:4;13:23;25:13;

 26:12;34:17;57:17;

 68:6,16;77:21;78:3,

 23;79:24;82:9;85:22,

 24,25;86:8;87:15;

 89:16;98:18;109:4 

respect (2)

 109:11;124:16 

respectively (1)

 38:22 

respond (2)

 26:5;51:18 

response (1)

 152:14 

responsibility (1)

 83:25 

responsible (4)

 13:13;25:25;26:21;

 28:22 

rest (6)

revitalized (1)

 97:16 

rewards (1)

 80:22 

Rhode (2)

 15:24,25 

rice (4)

 82:13,14,16,17 

rich (3)

 80:2;81:10,13 

Rico (4)

 79:23;122:1,17,18 

Ridge (2)

 100:16;101:4 

right (82)

 0:18;7:1;8:13;

 11:24;12:13;16:11,

 13;24:6,9,10;25:3,20;

 29:14;42:17;48:9,22;

 52:6;53:9,13;56:14,

 117:11 

roadblocks (1)

 116:25 

roadmap (1)

 19:10 

Roanoke (1)

 103:5 

robust (5)

 28:2;78:16;93:1;

 94:7;164:19 

rock (1)

 142:25 

Rodale (2)

 57:12;84:18 

Rodriguez (1)

 98:3 

role (11)

 7:11,12,19,21;

 67:18,18;77:2;84:5;

 101:7;113:25;115:11 

running (6)

 27:7;98:4;126:23;

 163:6,9,11 

runs (3)

 76:24;99:19;130:18 

rural (2)

 116:2;126:2 

rush (1)

 149:9 

rushed (1)

 17:2 

Russell (3)

 76:4;77:5;84:24 

Russell's (1)

 76:10 

rye (1)

 95:12 

124:15 

savvy (1)

 81:22 

saw (7)

 18:22;22:4;81:6;

 103:3;107:13;117:17;

 123:20 

saying (10)

 18:5;33:13;36:13;

 54:8;62:21;84:25;

 102:19;120:13;140:1;

 156:11 

scale (1)

 110:14 

scary (2)

 64:24;107:1 

scenes (1)

 7:25 

scents (1)

 16:15 

S 

19:6;71:10;108:8; 17;60:4;61:6;65:10; roll (1) sacrifices (1) schedule-wise (1)

 149:9;167:16,17 69:18,21,24,25;71:3, 18:22 80:22 69:25 

restart (1) 15;77:12;81:2;83:18, rolling (1) saddle (1) scheme (1)

 130:22 25;86:1;91:13;92:8, 99:10 61:5 111:6 

restore (2) 10;96:4;97:19;104:8; rollout (3) Sadly (2) schemes (1)

 76:21;89:12 105:15;107:10,20; 22:23;33:17;91:7 80:3,18 36:2 

restoring (1) 108:3;109:7;111:8; room (12) safe (5) school (2)

 76:15 115:25;119:13; 0:5,20;7:17;8:6; 19:8;23:22;57:20; 22:13;90:7 

restrooms (1) 121:15;122:9;124:10, 9:15;45:6;47:14; 58:7;118:12 science (1)

 0:15 23;126:14;127:24; 63:22,22;64:9;124:5, safely (2) 72:12 

result (3) 128:17;129:2,5,21; 13 16:18;19:10 scientific (1)

 79:12;81:3;146:16 130:15;131:23; Roots (1) same (23) 7:12 

results (3) 132:19;133:23;135:6, 106:8 12:4;18:19;20:13, scientist (1)

 15:18;58:22,25 11;137:4;142:16; rotate (1) 23;21:16;22:16; 11:3 

retailers (1) 144:21;146:23;150:3; 131:1 23:13,15;45:21,22; scopes (1)

 63:4 151:8;153:9;154:17, rotation (1) 54:11;58:4,4;95:7; 88:14 

retain (1) 18,24;157:2;158:6, 89:11 122:17;123:7;125:16; scope-specific (1)

 56:8 24;161:18;163:12; rotational (2) 130:3;132:15;159:21; 94:11 

retake (1) 166:14;168:12 56:2;88:19 160:3,18,18 scores (2)

 129:7 rights (1) roughly (1) sample (1) 33:20;36:11 

retiring (1) 48:19 93:8 114:17 screen (1)

 107:18 rigor (2) round (7) samples (2) 114:19 

returning (2) 58:4,5 9:7;127:7,21;132:3; 37:19;42:3 screenshot (1)

 6:24;12:22 rinse (4) 145:22;158:13;164:5 sampling (5) 31:9 

revealed (1) 151:18,18;152:1,1 row (4) 42:5;59:2,5,7,8 seafood (1)

 57:1 ripple (2) 8:13;13:2;119:13, San (1) 168:4 

reverse (1) 50:2;64:9 15 14:8 seal (8)

 119:18 ripples (1) rule (27) sanitation (1) 17:19;18:21;19:2,

review (23) 64:5 32:9,13,21;33:4,18, 130:25 25;33:6;41:5,7,13 

54:2;129:24;130:1, Risk (8) 21,23;34:21,24;35:1, sanitizer (8) search (1)

 2;138:8,9,16;139:10, 6:10;30:14;62:5,6, 3,12,13;36:15,24,25; 130:8,25;131:5; 21:4 

13,24;140:1;151:9, 7,15,15;64:20 37:25;53:16;61:10, 151:25;153:2;154:2, searched (2)

 23;152:18,24;154:21; risks (1) 25;62:3,5,6,6,8,10; 2,22 18:2;77:19 

156:5,10,16;158:19; 46:19 167:3 sanitizers (7) season (7)

 159:5,22;160:13 risky (1) rulemaking (3) 130:22;152:19,21, 13:3,17;33:1;47:13;

reviewed (5) 40:20 9:2;54:12,16 24;153:6,17;154:16 109:8;126:7;129:15 

135:15;151:16; River (1) Rules (14) Sasha (1) seasonal (1)

 159:7;160:1,18 76:8 35:8;37:16;53:10, 34:23 83:3 

reviewing (4) RMA (4) 16,23,24;54:5,8,9; sat (1) seasons (1)

 68:1;129:8;152:20; 30:13,17,19,22 66:2;149:25,25; 60:14 126:6 

156:25 road (2) 150:1,1 sausage (1) seat (11)

reviews (3) 25:19;154:20 run (3) 166:8 10:3,23;11:3,9,25;

 8:22;137:10;154:22 roadblock (1) 0:10;16:21;49:18 saving (1) 12:17;13:11,24; 

Min-U-Script® Burke Court Reporting & Transcription (26) respect - seat 

(973) 692-0660 
 NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 3 

November 24, 2023 

14:22;123:10;152:7 124:9 seven (4) 77:24;109:10 64:1;125:17;127:18 

seats (1) sell (2) 90:2,13;91:2; shortage (1) sister (1)

 14:5 18:9,15 153:11 79:9 49:18 

sec (1) selling (3) several (18) shortly (1) sit (5)

 105:8 26:1,4,8 12:22;32:24;43:2,5, 106:10 9:11;13:11;23:15,

second (16) semester (4) 5;44:20;47:25;58:15; shortness (1) 16;51:12 

11:4;16:22;17:10; 9:25;15:16;44:12, 81:6;88:15;99:10; 16:24 sites (1)

 25:20;60:13,23; 22 124:3;130:23;132:2; shot (1) 87:9 

82:20;94:24;112:3; send (3) 151:17;154:15; 9:21 site-specific (1)

 113:24;120:22; 69:6;115:5;131:23 159:14;164:9 shoulder (1) 35:10 

123:21;137:20;139:9; senior (1) severe (3) 8:7 sits (1)

 142:18;159:6 10:4 56:1;140:24;146:17 shoutout (5) 152:7 

seconded (8) sense (2) severely (1) 13:18;77:9,12; sitting (3)

 130:12,13;137:7; 59:6;118:4 121:19 83:13;87:16 10:23;50:4;71:15 

146:9;148:7;151:13; sensible (1) shall (1) show (4) situation (1)

 156:9;158:22 89:22 86:24 34:8;47:10,21; 98:10 

secondly (1) sensitive (2) Shapiro (1) 85:14 six (13)

 79:9 60:10;61:9 84:24 showcased (1) 12:21;18:17;28:20;

SECRETARY (40) sent (1) share (7) 84:17 36:25;60:24;77:15;

 12:12;15:21,22; 24:20 8:15;9:23;16:12; showcasing (1) 91:2;94:9,10;96:25;

 22:25;23:4,9,12,18; sentenced (1) 38:25;39:4;73:15; 88:10 102:23;123:17;

 48:21;55:20;64:14; 41:23 78:25 showed (1) 127:12 

67:15;84:23;117:14; sentiment (1) shared (5) 28:17 sixth (1)

 118:23;119:12;120:6; 135:16 47:19;58:18;68:12; showing (2) 12:16 

131:10;133:8;134:10; separate (1) 80:5;89:2 60:10;91:25 size (1)

 135:9;136:10;137:1; 44:10 shareholder (1) shown (6) 25:17 

145:4;146:2;147:5, separated (1) 166:13 46:24;67:13;89:7,9; sized (1)

 25;150:6;151:5,15; 132:18 sharing (2) 98:21;99:18 89:10 

153:8;155:23,25; series (5) 38:11;83:25 shows (2) skin (1)

 157:25;158:4;160:8, 13:5;34:20;46:12; sharp (1) 74:2;77:14 153:21 

13;161:1;162:14,20 83:19;90:13 9:16 siblings (1) slam (1)

section (3) serious (2) sharpen (1) 18:2 137:9 

15:14;35:21;44:11 149:17;159:4 86:21 sick (2) slaughter (1)

sections (1) seriously (2) Shed (1) 15:2;19:22 167:11 

96:7 37:12;62:2 87:8 side (7) slaying (1)

sector (8) serve (9) shelf (2) 15:10;36:4,4;57:12, 69:17 

27:21;48:3;53:2; 9:6;12:15,17;14:24; 18:24;159:2 12;76:23;86:25 sliced (1)

 73:22;74:9;108:13; 15:16;23:18;76:1; shellfish (1) sides (1) 166:4 

144:15;163:18 82:2;162:25 168:9 101:13 slide (7)

security (1) served (1) shelves (2) sign (4) 77:13;82:10,20;

 76:22 8:20 19:3;20:15 69:6;76:4;90:12; 86:19;106:15;107:8;

Seed (1) serves (1) Sherlene (1) 91:17 158:8 

93:18 77:1 98:3 signage (1) slides (7)

seeds (3) Service (6) ship (1) 62:14 16:12;24:12;30:20;

 13:14;29:4;124:16 9:1;27:11,14;49:10; 141:3 signed (3) 67:2;89:18;116:21;

seeing (7) 68:6;94:12 shipments (3) 42:4;91:14;97:13 154:13 

39:9;46:19,20; services (5) 41:9,9;56:24 significant (6) sliver (1)

 107:21;117:5,9;168:7 49:7;91:24;92:3; shipper (1) 41:4;51:24;59:22; 17:13 

seek (1) 99:17;108:21 14:8 143:12,23;148:25 small (12)

 99:2 serving (4) ships (1) siloed (1) 13:2;49:14;62:9;

seeking (1) 12:18;15:15;72:20; 59:9 86:6 85:18,18;89:10;

 22:13 78:8 Shivers (15) similar (3) 98:19;99:13;103:20,

seemed (1) session (3) 78:24;79:3,5;83:10, 58:23;107:14; 25,25;143:21 

43:22 53:8;129:22;142:2 15;113:5;114:9; 116:20 smaller (1)

seems (4) sessions (3) 117:25;118:24; simple (2) 98:11 

144:8,12;163:22; 31:3;60:13;82:2 119:13;121:2;122:23; 79:16;146:15 smart (9)

 166:9 set (6) 123:13,16;124:8 simply (4) 31:2,5,11;67:3,6,9;

segment (5) 0:19;35:20;72:1; Shivers' (1) 17:3;42:23;85:1; 68:9;80:24;110:17 

6:15;62:24;63:2,13; 109:23;116:21;130:1 113:6 141:1 SMITH (14)

 73:24 sets (1) shocked (1) sing (1) 11:22,24,25;58:15;

segments (2) 75:1 64:7 10:1 133:6;134:8;136:8;

 0:12;165:12 setting (1) short (5) single (6) 145:2;147:3;151:3;

self-admittance (1) 8:1 29:16;49:22;67:8; 19:1;47:1;51:4; 152:9;155:21;157:23; 

Min-U-Script® Burke Court Reporting & Transcription (27) seats - SMITH 

(973) 692-0660 
 NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 3 

November 24, 2023 

162:12 52:11;105:4;159:1 spare (1) spots (1) stars (1)

sneak (1) somewhat (2) 127:4 83:6 84:2 

28:13 30:5;116:20 sparing (1) sprayed (4) start (31)

snippets (1) somewhere (3) 20:16 16:13;17:7;18:25; 0:8;6:8;14:11;36:8,

 34:22 25:15;124:18; sparked (1) 23:13 12;50:17;51:23,23;

snowing (1) 126:14 80:17 spread (2) 61:25;62:1;63:21;

 71:25 song (1) Spawls (1) 20:22;89:5 96:1;114:20;121:3,3;

snowstorm (1) 14:6 21:12 spring (12) 127:18;129:19;

 74:23 soon (2) speak (10) 8:18;37:3;43:20; 131:25;132:6,18;

sobering (1) 31:11;69:5 23:4;48:6,23;64:21; 44:16;50:17;60:2; 135:8;136:2;144:22;

 79:13 Sorry (13) 86:23,25;98:5; 61:17;135:16;148:15; 146:25;150:5;154:25;

social (2) 16:1;53:12;102:19; 100:19;122:6;124:22 151:16;152:4;156:18 156:11;157:4;164:1;

 81:22,23 112:1;113:8;123:18, speaker (2) St (6) 165:6,7 

socially (1) 24;126:18;134:23,23; 71:10;149:25 113:13,13,13; started (19)

 115:25 141:12,14;154:2 speakers (2) 120:15,15,15 9:15;20:3;31:10;

societies (1) sort (34) 113:4;127:8 stable (1) 44:3;46:4,10,12;

 80:15 15:9;25:4;27:1,13; speaks (1) 159:2 67:15;79:6,8,20;

socioeconomics (1) 30:6;31:23;33:2;35:1; 122:6 staff (24) 95:20;99:5;100:3;

 71:23 36:11;52:8;61:16; special (1) 6:24;7:5,18;24:17; 121:8,10,12;129:25;

sociological (1) 62:20,23;67:10,13,16, 41:11 27:6,18;29:18;34:21, 141:5 

58:11 16,17;68:15;89:22; specialist (2) 22,23;42:1;74:5; starting (6)

SOE (22) 106:25;108:7;111:5; 6:17;99:16 75:10;77:15;84:21; 16:20;49:25;55:17;

 34:6,18,19;36:21; 115:1,25;116:6; specific (8) 85:19,22,24;91:3,5; 107:11;133:24;

 38:3,24;40:5;45:14; 128:23;138:6;140:2; 59:14;83:20;88:10; 93:22;100:5;106:17; 168:16 

53:15,25;55:22; 144:15;154:19; 95:21;98:23;103:8; 144:5 starts (2)

 57:23;58:1,10;59:15; 163:13;166:22;168:9 120:3;148:19 staffing (1) 51:1;63:21 

60:12,15,16,23;61:1; sorts (1) specifically (12) 94:5 State (38)

 65:2,6 36:14 50:10;71:8;102:11; stairs (2) 11:2;15:25;28:22;

soil (17) sought (1) 107:9;126:10;128:10; 0:17,19 65:11;68:20;74:25;

 20:25;76:18;80:16; 17:21 129:15;142:19; stake (1) 77:19;84:12,13;85:5,

 86:22;89:5,20;91:24; sound (4) 143:20;146:20; 143:15 14,17;88:9,20;94:24;

 92:1,2,3;102:1,12; 16:23;52:12;89:22; 152:13,25 stakeholder (1) 95:3,15,21;96:2,6,9;

 105:12;114:15,17,17, 168:8 speed (1) 13:5 98:17,19,24;99:13;

 23 sounds (2) 16:25 stakeholders (8) 101:25;103:13,15,19,

soil-base (1) 42:23;161:1 Speer (1) 51:18;59:1;73:8; 21;105:7,9;106:5,6;

 53:3 source (2) 123:7 151:17;152:4;153:10; 107:12;108:8;109:1;

soilless (1) 48:2;167:1 Spencer (4) 154:7;168:5 112:23 

53:3 sources (3) 100:20;104:11; stakeholders' (1) stated (1)

sold (2) 24:16;59:23;111:18 107:4;126:18 131:11 153:15 

18:19;89:6 South (2) spend (1) stand (4) statement (1)

sole (1) 85:20;125:11 25:9 6:22;7:7,7,19 139:5 

17:11 southeast (5) Spender (1) standalone (1) States (19)

solely (1) 14:20;100:22,23; 104:9 97:9 28:10;34:3;36:1;

 125:24 121:4;127:17 spending (4) standard (1) 47:4;56:24;57:20,25;

solid (2) southern (1) 27:10;32:8;47:14; 160:22 71:14,16,21;74:14,15;

 12:7;103:22 116:6 69:11 Standards (23) 76:21;78:3;79:22;

solution (4) sovereignty (1) spent (3) 0:7,9;6:21,23;7:4,5; 95:5;98:11;104:13;

 30:19;79:10; 78:18 53:24;66:15;161:15 8:6,9;27:21;37:15; 141:2 

115:23;140:7 soy (2) spinning (1) 38:20,21;39:10; statewide (3)

solutions (1) 56:5,5 8:9 43:15;44:4,5;45:20; 94:7;104:19;106:17 

18:2 soybean (2) spirit (5) 53:12,16;58:10; statistics (1)

somebody (11) 55:25;166:12 74:3;78:10;83:12; 72:24;168:2,4 47:18 

25:4;50:18;51:1,3; space (12) 109:19;131:17 standing (4) status (2)

 62:12;105:18;119:23, 0:14;13:13,16;39:6; spit-balling (1) 12:9;75:14;110:2; 44:21;138:10 

23;125:14;127:11; 81:8;82:8,19;112:22; 167:25 152:9 stay (4)

 149:19 116:23;119:16;163:3; spite (1) standpoint (1) 8:6;22:10;58:7;

somehow (1) 165:12 138:9 165:3 60:13 

123:11 spaces (1) split (3) stands (1) staying (3)

someone (1) 112:18 25:16,24;26:9 24:25 116:9,10;129:14 

29:2 Spanish (1) spoken (1) staple (1) steers (1)

sometime (1) 122:6 148:13 89:13 20:6 

48:6 spanning (1) spot (2) staples (1) stellar (1)

sometimes (3) 80:12 143:18;166:17 19:3 110:9 

Min-U-Script® Burke Court Reporting & Transcription (28) sneak - stellar 

(973) 692-0660 
 NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 3 

November 24, 2023 

step (7)

 15:3;25:22;35:16;

 51:2;60:6;112:18,22 

53:11,14 

strengthens (2)

 32:18,19 

sudden (2)

 39:23,25 

Sugar (2)

 148:16 

supports (2)

 98:24,25 

T 

Stephanie (3) stretch (1) 108:10;149:9 supposed (2) TA (1) 83:13,16;128:6 66:21 sugarbushes (1) 10:16;62:7 97:2 

stepped (1) striving (1) 108:2 sure (17) table (5) 114:10 23:16 sugarcane (1) 18:10;20:2;27:9; 45:3;49:20;123:10; steps (2) Strohm (1) 126:11 47:15;48:10;53:23; 142:9;168:2 22:12;52:21 34:23 suggested (2) 54:7;55:20;122:22; tabled (1) steward (1) strong (10) 54:15;77:21 128:2;130:4;131:7; 84:21 

76:16 9:12;27:23;29:25; suggestion (1) 143:25;144:11,15; tablemate (1) stewardship (1) 47:21;58:10;73:2,19; 14:16 164:9;167:24 152:7 

77:4 74:24;115:21;163:23 suited (1) surprised (2) tackle (1) still (15) strongest (1) 89:4 90:19;115:16 12:8 

26:2;44:2;54:20; 121:14 sulfur (1) surprising (1) tackled (1) 58:17;63:3;64:19; strongly (1) 160:17 66:19 115:22 

69:19;91:2;95:1; 35:3 summer (2) surround (1) talent (1) 96:14;112:8;118:8; structures (1) 21:13;61:17 137:12 27:17 

122:2;153:11;154:17 89:4 summers (1) surrounding (1) talented (2) stocked (1) struggle (1) 21:25 151:20 45:1;77:15 20:15 23:21 summit (1) Surveillance (5) talk (28) stole (1) students (1) 103:18 39:20,22;40:4;54:4; 10:16;27:13;29:3; 14:16 84:19 sunset (11) 59:8 30:8;32:25;34:2,2; stolen (1) studies (2) 130:2;137:10; survived (1) 35:1;48:12;56:12; 118:10 72:16;82:12 138:9,16;139:10; 79:17 57:15,16;60:9;64:4; stone (1) study (1) 142:21;151:8;153:9; suspend (1) 67:1,3;69:1;85:10; 64:4 72:13 154:22;156:5;159:22 65:21 102:1,16;107:9; stones (2) stuff (2) sunsets (2) suspended (1) 108:5;116:4,6; 64:6,9 31:11;137:11 129:16,24 65:24 126:15;149:15; stood (2) subcommittee (22) super (3) suspension (1) 164:17;166:17 23:12;29:15 6:9,11;129:7,14; 18:5;123:15;132:4 60:7 talked (18) stop (2) 130:10,17;132:10; supermarket (1) sustainable (1) 29:1;33:11;34:1; 26:8;42:13 137:7;138:7,11,14,18, 166:3 110:16 43:14;46:1;51:4,25; stopped (2) 22;146:11;148:11; supply (22) swamps (1) 52:9;56:16;63:11; 17:6;42:15 152:15;158:19; 32:17,19;34:10; 79:12 80:21;84:21;90:25; store (9) 162:25;164:19,21; 35:11,12;39:12,22; sweeping (1) 92:13;122:18;130:22, 17:17,24,25,25; 168:1,12 40:4,7,10,12,16; 21:2 24;165:6 18:3,7,10,22;167:17 subcommittees (2) 46:13,19;62:11,16,24; sweet (2) talking (27) stories (8) 129:21;156:14 63:6,14,23;64:3; 16:16;18:21 32:12;33:11;34:22, 29:6;48:11;50:23, submit (1) 167:10 swine (6) 23;35:17;37:13,15, 25;72:25;80:2; 100:6 support (49) 163:15;164:19,23; 15;53:21;56:19;61:2; 117:16;127:14 submitted (1) 6:18,22;10:9;23:19; 165:4,19,20 62:23;67:18;97:15; story (7) 92:24 29:23;47:12,15,22; switch (2) 111:20;116:21; 0:17;32:3;50:20,22, subpages (1) 68:9;74:6;76:21; 85:7;97:21 118:24;119:14; 22,25;51:1 77:17 79:24;82:9;84:5,25; synthetic (7) 125:22;127:19; straight (2) subset (1) 85:5,22;86:8;92:17, 18:12;137:23; 159:10;161:8;164:8, 79:16;121:13 129:20 19;93:1,11,15,23; 138:17;139:13,25; 13,14,22;165:7 straightforward (1) substances (5) 99:21;100:9;101:18; 140:5;148:19 talks (5) 135:17 30:8;57:1;131:12; 107:23,25;110:1,7; Syracuse (1) 30:9;44:11;68:5; strategic (1) 137:23;146:15 111:16,25;112:12; 96:14 80:19;152:23 28:3 substantial (1) 113:18;116:14;118:6, system (16) tank (1) strategies (4) 84:9 15,20,25,25;120:17; 27:24;29:9;37:2; 151:20 

76:18;89:8;128:19; success (2) 121:25;122:13; 43:2;45:24;46:1,23; tanks (1) 164:6 111:6;137:15 153:13;156:18; 52:2;58:11,13;68:22; 153:17 

streamed (1) successes (3) 158:13,14;163:5 88:23;119:3,4; target (1) 21:3 28:14;110:4;116:25 supporter (1) 151:21;165:24 54:23 

Street (1) successful (3) 90:22 systemic (2) targeted (1) 126:15 56:18;74:17;100:10 supporters (1) 48:17;78:21 59:8 

strength (1) successfully (4) 84:19 systems (9) taught (2) 99:8 8:1;56:21;72:19; supporting (5) 26:21;27:24;28:1; 80:13;88:15 strengthening (9) 163:16 87:7,13;93:24; 37:14;38:7,9,22;41:6; Tax (1) 32:9,13;36:7;37:20; succession (1) 113:16;120:19 47:6 8:21 

39:15;40:6;46:3; 107:18 supportive (1) teach (3) 

Min-U-Script® Burke Court Reporting & Transcription (29) step - teach 

(973) 692-0660 
 NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 3 

November 24, 2023 

15:5;90:8;114:4 74:18 7:21;8:4;38:12; 109:9,14,20;110:7; total (3)

team (50) terms (12) 53:9;60:14;67:4; 115:23 75:5,14;107:13 

6:1,16,20,21,23; 54:12,17,19;65:13, 83:21;96:5;97:13; tolazoline (1) totally (2)

 8:10,22;13:15;20:23; 15;66:14;118:3,6; 106:4;111:7,22; 160:5 124:21;166:9 

25:2,18,19,25;26:4,9, 121:21;126:5;139:6; 117:21,23;118:21; told (2) touch (1)

 10,11,12,13,13,25; 159:11 152:3;159:13;160:1 17:6;90:8 101:12 

27:11,14;34:22,23; terrific (1) three-year (1) Tomao (2) touched (2)

 36:24;39:3,7,21;40:3; 8:17 86:14 92:9;94:17 29:17,20 

42:10,25;43:4;44:24; test (4) thrilled (1) Tomorrow (4) touching (1)

 47:10;51:10;57:21; 58:22;89:21;92:1; 9:3 6:9,12;123:14; 127:13 

60:4;64:4;65:14; 154:20 thrive (1) 168:16 touchpoints (1)

 67:25;69:18;71:11; Testing (13) 79:19 ton (1) 25:18 

72:7;78:22;108:21; 16:12;37:19;40:21; thriving (1) 98:15 tough (3)

 110:1,2,9;115:21 56:25;57:1;58:20,24; 125:5 tone (1) 50:8;55:25;85:18 

teaming (1) 59:3,5,7,9;60:2;64:15 throat (1) 72:1 tours (2)

 23:12 Texas (1) 92:22 tons (1) 28:24;87:13 

teams (3) 20:20 throughout (12) 120:1 Toussaint (1)

 30:1;31:1;109:23 Thankfully (1) 64:3;67:20;88:8; took (2) 126:13 

teamwork (1) 81:6 94:1,9;95:3,15,21; 17:15;27:11 toward (1)

 74:4 thanking (2) 96:1,5,9,13 tool (6) 111:14 

tears (1) 6:15;9:15 throw (3) 43:21;55:6,8,16; towards (6)

 50:21 thanks (18) 64:4,6,7 58:1;59:4 45:6;63:14;73:9;

teat (2) 9:8;12:11;14:18; Thursday (1) toolbox (5) 95:24;106:4;157:1 

148:4,12 51:7,7;55:20,20;61:6; 6:12 55:17;135:14; town (5)

tech (2) 64:14;100:15;107:4; Thus (1) 148:9;156:20;160:20 17:1,24;18:7,10;

 158:12,14 139:3;143:2,7; 79:15 tools (9) 19:4 

technical (15) 146:13;153:8;158:24; tier (1) 44:19;109:24; townhalls (1)

 28:11;46:11;75:8; 160:13 116:6 131:6;135:14;140:19; 82:1 

88:17;94:1,12;96:10; that'll (1) tiering (1) 143:12;148:9;156:20; toxic (2)

 99:2,9,20;101:22; 99:24 43:2 160:19 76:18;80:16 

104:24;109:2;119:8; therefore (3) tighten (1) top (5) toxicity (1)

 139:6 35:6;59:8;163:24 38:3 54:25;69:19;95:5; 159:2 

techniques (1) they’ll (1) tight-knit (2) 117:21;127:17 toxics (3)

 89:12 128:13 98:12,19 topic (7) 51:16,20;54:24 

technology (2) thinking (4) till (2) 51:24,25;52:23,25; toxins (3)

 7:13;35:15 31:17;64:2;76:2; 80:7;109:21 53:5;96:18;152:11 17:4,14;22:16 

tectonic (1) 124:15 timely (1) topical (1) TR (1)

 76:8 third (9) 69:10 158:20 160:17 

Ted (1) 10:3,12;12:18; times (10) topics (2) traceability (3)

 92:9 14:23;42:11;66:12; 44:1;48:22;55:24; 13:17;129:17 39:12;40:22;46:13 

Teddy (2) 118:14;151:21,21 56:7,14;60:14;64:24; TOPP (81) track (3)

 94:17;97:19 third-party (1) 81:24;112:6;163:14 6:8;7:22;11:6; 43:12;44:15;112:6 

telling (1) 37:17 timing (2) 15:18;22:24;24:17; tracking (1)

 114:6 Thomas (2) 69:17;107:10 27:7;28:17;29:20; 115:15 

template (2) 113:13;120:15 tips (1) 47:11;48:8;49:24,25; tracks (3)

 31:14;78:14 thorny (2) 31:9 50:9,11;55:22;56:18; 15:10;96:12;116:2 

tend (5) 142:23;143:10 Tobacco (1) 57:9;58:10;71:9;72:6; Trade (17)

 46:8;52:23;115:4; Though (11) 8:21 73:18;74:10,15,16; 8:22;26:13,16,19;

 125:1,16 19:15;50:14;56:10; today (16) 77:7,14,16,18;79:1; 27:1;35:16,17;36:13;

tenets (1) 63:2,9;71:12;80:19; 9:18;24:24;43:14; 81:9;84:5,21;85:5,10, 38:7,17;45:18;46:21;

 105:12 105:16;122:5;128:17; 44:25;46:17;47:19; 23;86:11,15;87:1,17; 47:2,2;57:11;109:12;

Tennessee (3) 165:20 58:18;73:15;79:20; 88:5,7,12,20;89:16; 128:8 

8:18;11:2,3 thought (3) 90:4;97:23;110:4; 90:12,20;91:7,14; trademark (3)

tens (1) 16:2,4;66:13 116:19;129:8;130:2; 92:4,16,24;93:23; 41:3,6,12 

8:22 thoughtful (2) 142:14 94:10;95:25;96:3,12, trading (2)

tent (2) 34:7;64:6 toehold (1) 17,23,25;97:11;98:4; 45:15,23 

21:3,3 thoughts (1) 55:5 99:19;102:14;103:7, tradition (1)

Teresa (4) 168:11 together (22) 11;104:15;106:1,6, 80:10 

88:1,6;89:17;92:6 thousands (3) 0:15;12:7;23:15; 20;107:9,20;108:4,6; traditionally (2)

term (6) 8:22;22:20;76:16 28:25;31:21;50:11; 109:16;110:6;111:5, 49:16;112:19 

12:2;14:23;30:4; thread (1) 58:8;71:24;73:21,25; 8;112:10,14;117:15 train (2)

 34:18;62:19;80:9 154:15 74:20;79:1;83:12; TOPP's (1) 93:15;102:11 

termed (1) three (18) 86:12;97:25;105:1,3; 83:21 trained (1) 

Min-U-Script® Burke Court Reporting & Transcription (30) team - trained 

(973) 692-0660 
 NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 3 

November 24, 2023 

14:10 

trainer (1)

 102:12 

training (13)

 13:21;31:1,2,3;

 35:13;39:2,2,17;

 77:22;91:3;93:6;94:1,

 11 

trajectory (1)

 111:4 

transcript (2)

 63:24;124:2 

Transcripts (1)

 0:12 

transformation (1)

 52:2 

Transition (52)

 6:7;7:22;10:6,7,9;

 12:3;14:1,14;22:23;

 27:8;28:6;29:14,23,

 24;30:7,10;47:17;

 56:10;57:5;71:8;

 73:17;74:19;75:3,16,

 17,23;76:2,3;77:6;

 78:15;81:7;84:8,15,

 22;88:18;91:14;

 92:18;93:3,6;94:4;

 95:10,24;100:1,10,12;

 103:9;104:5;111:7,

 13;112:18;115:16;

 164:10 

transitional (9)

 29:12;30:4,5,15,24;

 31:2,8,13,17 

transitioned (1)

 93:12 

transitioning (16)

 14:11;30:22;31:14,

 18;47:12;57:14;

 81:20;82:22,25;

 88:11;94:6;98:21;

 99:25;101:11,19;

 106:10 

transitions (1)

 94:20 

translated (1)

 31:5 

Treasury (1)

 8:20 

treat (3)

 140:17,22;146:16 

treated (2)

 140:22;153:24 

tree (3)

 76:3;97:6;125:10 

trees (1)

 76:16 

tremendous (4)

 25:13;38:16;39:23;

 55:21 

triage (1)

 42:25 

trial (1)

 89:11 

tried (3)

 19:12;36:18;69:12 

tries (1)

 69:4 

trifecta (1)

 142:5 

triple (2)

 53:10;142:5 

true (5)

 9:10;23:23;110:10;

 124:10;163:1 

truly (4)

 58:7;74:4;81:2;

 144:6 

Trust (3)

 10:22;45:3;101:25 

truth (3)

 17:21;20:13,21 

try (11)

 18:6,12;55:4;

 102:12;114:14;

 137:12,12;138:25;

 149:16,19;152:5 

trying (18)

 15:3;22:14;35:4,14;

 43:23,24;47:14;57:8;

 62:17;66:8;95:23;

 101:6;108:19;154:19,

 20;161:7;166:25;

 167:5 

107:2;135:22;152:6;

 160:7 

turned (6)

 17:11;20:14;41:9,

 10;57:2;67:21 

TURNER (18)

 14:4,4;133:14;

 134:16;136:16;139:3,

 17;141:14,19;143:5;

 145:10;147:11;

 150:12;154:14;155:5;

 157:7;161:21;166:16 

Tuskegee (1)

 13:22 

TV (1)

 114:19 

twice (1)

 51:13 

two (45)

 7:5;8:5;13:18;20:9;

 25:16,16,24;27:23;

 33:14;37:7;60:19;

 63:3;67:4;73:22;79:8;

 83:21;85:7;86:13;

 91:3;96:4,8,8,16;

 100:10;105:6;111:5;

 113:4;120:12;122:6,

 19;124:21;125:23,24;

 128:10;131:4;137:18;

 138:1;139:7;153:4;

 154:6;159:21;163:1;

 165:24;166:5;167:8 

two-thirds (1)

 27:15 

type (6)

 68:24;77:6;83:4;

 108:15;118:10,15 

types (3)

 38:2;68:19;128:24 

typical (1)

 167:22 

typically (4)

 95:1;100:22;102:4;

 103:5 

24:19;26:6;29:5,23;

 30:18;34:6;41:1,17;

 50:9;57:9;60:6;65:5;

 84:13;91:25;95:22;

 98:9;142:19;154:6,7 

underestimate (1)

 50:2 

underfunded (1)

 121:19 

undergoing (1)

 55:22 

undergrad (1)

 21:25 

undergraduate (1)

 72:15 

underneath (1)

 114:15 

underselling (1)

 130:17 

underserved (2)

 78:3;87:7 

understandable (1)

 109:5 

understood (1)

 135:19 

undervalued (1)

 82:18 

unfamiliar (1)

 86:4 

unfortunate (1)

 8:7 

unfortunately (6)

 12:23;14:25;43:11;

 61:12;80:25;107:11 

UNIDENTIFIED (1)

 149:25 

uniformity (1)

 109:24 

Union (1)

 46:9 

unique (7)

 35:11;87:5;93:17;

 98:10,11;113:13,17 

uniquely (1)

 120:14 

United (9)

 28:10;34:3;35:25;

untees (1)

 82:21 

up (78)

 7:1,7,7,19;8:1;

 13:10,12;15:17;

 18:16,24;19:6,25;

 21:20;23:9;24:22,24;

 26:2;27:7;28:4;29:15;

 30:20;35:9,20;38:3,

 11;39:9;42:2;45:8;

 48:21;50:2;51:3;

 52:11;53:9;60:4;

 67:24;68:11;69:6,21;

 71:19;73:21;76:4;

 84:10;87:9,14;88:1,3;

 90:9,12;91:14,17;

 95:1,18;97:13,15,20;

 98:1,4;100:18,18;

 105:8;108:19;109:16;

 110:2;112:5;115:18,

 22;119:21;124:2;

 125:12;126:23;

 128:14;129:5;137:12;

 154:10;156:21;160:2;

 164:5;167:17 

upcoming (3)

 13:3;44:12,21 

update (15)

 6:5;24:11,13,14,17;

 32:14;45:10;46:5,8;

 58:18,19;71:7;

 106:20;152:8;153:8 

updated (1)

 46:10 

updates (3)

 24:17;43:19;83:19 

updating (1)

 38:10 

upper (2)

 76:17;82:11 

urban (2)

 78:4,14 

usage (1)

 160:22 

USDA (22)

 8:25;17:19;18:21;

 22:22;23:18;29:22;

U 

translating (1) Tubman's (2) UConn (2) 47:4;56:24;57:20,25; 31:1;33:5;36:5;41:5;

 68:13 82:22;83:1 99:1,14 76:20;79:21 47:12;48:1,12,16;

transparency (1) TUCKER (34) ultimately (3) universities (1) 49:5,16;67:20;68:12;

 52:10 0:3,4;6:20;7:10; 32:4;67:21;106:3 165:1 74:17;81:1;89:22;

transparent (3) 9:10;24:8,9;45:16; UMaine (1) University (9) 92:19 

58:24;59:19,20 48:7;51:21;55:6; 93:5 11:2;13:22;72:14, USDA's (3)

transportation (1) 56:15;59:2;61:7; UMass (3) 16;92:23;101:25; 92:17;94:4;110:14 

49:19 63:17;64:24;66:23; 90:6;115:3,4 103:19,21;165:1 use (32)

trap (1) 67:12;71:4,5;73:14; unannounced (4) unprecedented (2) 19:9;30:9;32:17;

 89:11 110:9,23,24;124:1; 37:19,24;38:1;65:6 22:22;92:17 37:2,9;38:22;41:7,7;

travel (2) 127:6,7,10;141:23; unbelievable (1) unqualified (1) 47:20;54:25;68:24;

 65:12;118:16 149:8,12,16,24;150:1 61:11 137:19 80:9;81:9;106:16;

traveled (1) Tuesday (1) uncertified (2) unrelenting (1) 111:25;115:1;128:8,

 82:12 19:21 26:4;32:16 17:11 9,24;135:12;137:19;

traveling (2) turn (8) Under (24) unstable (1) 140:16;144:2;149:2,

 21:23;22:17 0:18;6:2;9:4;71:12; 22:25;23:4,9,11,18; 81:1 7;158:18,20;159:6, 

Min-U-Script® Burke Court Reporting & Transcription (31) trainer - use 

(973) 692-0660 
 NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 3 

November 24, 2023 

14;160:25;161:13;

 165:9 

used (19)

 44:9;52:22,22;

 62:25;80:6;89:10;

 125:16;127:10,11;

 131:15;139:10,14;

 142:20;146:15;152:2;

 153:16;159:12;

 160:18,22 

useful (2)

 31:4;78:18 

uses (6)

 38:7;156:21,24;

 159:7,8;161:11 

using (4)

 76:18;106:1;108:7;

 156:23 

usually (3)

 15:8;126:7;167:12 

USVI (5)

 79:23;122:1,3,10,

 11 

utilize (2)

 89:11;105:10 

utilizing (3)

 74:25;106:3,22 

vehicle (2)

 59:13;60:9 

vein (1)

 167:25 

Venmo (1)

 119:5 

Venn (1)

 52:24 

vera (1)

 124:10 

verified (1)

 153:2 

Vermont (13)

 20:20;95:8;104:10;

 107:5,10;108:4,6,10,

 12,15,17,18;117:1 

Vermont's (1)

 76:8 

Version (1)

 77:21 

versus (2)

 42:22;53:3 

veterinarians (1)

 144:5 

via (1)

 55:5 

viability (1)

 104:21 

vibrant (1)

 95:8 

vides (1)

voice (4)

 9:12;17:20;60:12;

 148:13 

voices (4)

 55:13;66:18;124:7;

 143:15 

voluminous (1)

 63:14 

voluntary (2)

 42:11,14 

volunteer (1)

 9:6 

vote (18)

 132:1,2,5,6,8,19;

 133:24;135:24;136:1,

 1;144:18,21;146:24;

 150:4;154:25,25;

 157:4;161:19 

voted (1)

 130:10 

votes (10)

 133:19;134:21;

 135:2;136:25;145:21;

 147:24;151:4;155:24;

 158:3;162:19 

voting (5)

 132:3,11,15;

 142:14;164:22 

24:16;109:7 

watched (1)

 109:16 

watching (1)

 127:20 

water (5)

 19:22;22:1;76:19;

 102:13;153:23 

wave (2)

 6:22;7:7 

way (31)

 15:6;17:11;21:16;

 30:13;35:17;42:25;

 43:18;44:13;47:22;

 53:22;58:23;62:18;

 64:1,10;66:8;68:10;

 71:19;80:10;82:2;

 84:22;85:20;91:12;

 92:25;108:17;114:25;

 116:5;124:24;135:17;

 142:10;148:21;160:6 

ways (5)

 72:23;109:14;

 112:17;140:6;165:2 

wealthy (1)

 85:17 

webinar (4)

 33:13,14,15;58:16 

webinars (4)

 33:20;86:22,23;

 87:4 

17:18;18:25;31:24;

 46:15;59:10;89:21;

 106:20;115:6;160:22 

wheat (1)

 95:12 

Whereas (1)

 43:1 

Whereupon (2)

 70:3;168:17 

wherever (1)

 116:10 

white (4)

 19:2;113:8,9;159:1 

whole (11)

 26:12;30:7;36:1;

 71:14,19;72:21;81:3;

 86:2;90:23;125:10;

 165:24 

wholly (1)

 79:25 

whose (2)

 16:19;161:4 

wide (2)

 102:7;103:15 

wife (1)

 101:3 

wild (5)

 87:7;93:2,5,8;168:4 

Wills (3)

 97:21;100:15,16 

win (1)

V 

W 

vacant (1)

 22:14 94:11 wafting (1) website (5) 144:14 

vaccine (5) view (3) 16:15 77:13,14,16,25; window (1)

 138:4;139:25; 32:1,2;83:21 wait (3) 152:22 16:16 

140:1;141:3;143:20 views (1) 50:4,5;133:4 week (13) wings (1)

vaccines (31) 131:11 waiting (1) 16:17;20:18;24:21; 167:24 

137:6,14,17,17,20, violence (2) 50:4 33:25;37:6;42:2; wins (3)

 21;138:3,11,12,17,21; 21:17,18 walk (5) 60:14;61:2;74:21; 110:12;117:24;

 139:8,9,13,14,16,20; Virgin (2) 22:1,2;87:4;100:5; 87:18;129:8;164:22; 128:15 

140:5,17,19,22; 113:12;120:13 117:17 166:6 winter (5)

 142:14,21,22,24; Virginia (29) walked (2) weekly (1) 96:11;103:4,5,19;

 143:18,19,23;144:7, 11:14;71:18,18; 18:3;88:22 115:5 126:9 

21;165:6 81:14,14;97:21; walk-on (2) weeks (5) wish (2)

validate (2) 100:17,20;101:4,7,15, 9:20;14:6 9:3;31:7;43:2;91:3; 88:18;167:8 

148:17,21 16,23,25;102:1,5,8; Wallack (1) 97:13 within (17)

validation (1) 103:5,14,14,19,21; 76:4 weigh (1) 27:4;32:7,7;36:6;

 149:1 104:3,5,10,12;106:5, wants (3) 140:15 46:23;49:9,10;51:22;

Valley (3) 9,11 24:22;68:19,20 Welcome (11) 52:21;88:11;91:5;

 76:6,17;93:19 virtual (1) war (2) 0:5;23:25;24:9; 92:16;94:4;112:12;

valuable (4) 106:18 65:22;80:12 64:12;71:3,5;79:1; 151:24;152:10;

 34:14;55:6,8;159:3 visibility (1) warrants (1) 92:8;97:20;112:20; 156:22 

value-added (2) 36:1 105:22 158:18 without (7)

 89:6;127:1 vision (2) wars (1) well-developed (1) 21:1;26:2;42:13;

values (1) 45:4,5 64:18 119:3 76:17;124:22;142:15;

 31:24 visit (2) Washington (7) weren't (1) 146:7 

variety (1) 23:1;123:14 10:22,22;25:1; 37:9 Woke (2)

 160:19 visits (2) 76:12;81:15;90:23; West (10) 13:10;20:14 

veg (1) 81:18;99:21 168:6 71:18;76:25;81:14; wonder (2)

 14:21 vital (7) waste (2) 100:20;103:15; 54:23;167:16 

vegetable (2) 7:2,11,25;38:15; 55:3;156:7 104:10,12;106:5,9,11 wonderful (7)

 90:1;97:5 65:20;89:9;115:11 wastewater (1) Western (1) 8:2;51:10;84:2;

vegetables (3) vitriol (1) 153:24 94:9 101:20;113:4;116:14;

 22:6;83:3;93:7 126:2 watch (2) what's (9) 164:1 

Min-U-Script® Burke Court Reporting & Transcription (32) used - wonderful 

(973) 692-0660 
 NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 3 

November 24, 2023 

wondering (8)

 36:16;55:4;63:6;

 64:16;67:2;112:6,9;

 132:14 

Wood (17)

 14:4;133:13;

 134:15;136:15;139:2;

 141:13;142:13;143:4,

 7;145:9;147:10;

 150:11;154:13;155:4;

 157:6;161:20;166:15 

word (9)

 20:22;33:17;43:24;

 64:2;90:21;102:25;

 127:10,11;152:4 

wording (1)

 138:2 

words (10)

 51:8;76:10;128:9,

 10,24;139:17;149:6,

 11,13,18 

work (146)

 6:9,11,12,12;7:3,24,

 25;9:2,11;10:6,7,22;

 11:2,22,25;12:7,9;

 13:7,25;14:20;21:19;

 22:10;25:8;26:21,21;

 27:3;28:7;31:22;

 32:23;38:1,10;39:21;

 40:4,17;41:20,23,24;

 42:7;44:3,13,25;45:2,

 5,25;47:10;49:4,24,

 25;50:3,14;52:17,21;

 53:18;54:4,15,18;

 57:19;58:8;62:18;

 63:21;64:21;65:22;

 66:7,8;67:21;69:9,9,

 14;72:2;73:7,12,20,

 21;74:10,20;75:6,11,

 20;76:15;77:18,23;

 78:7,11,25,25;79:23;

 81:6;83:4,12,20,21;

 84:25;85:10;86:3;

 87:18;89:14;90:3;

 92:4;98:12,13,14,16,

 25;100:2,22,23;101:5,

 9;102:21;104:20,22,

 24;105:1,3,8,22;

 106:10;107:1;108:22;

 109:20;110:6,13;

 112:13;113:14;114:2;

 116:5;120:23,23;

 121:4;122:2;127:13,

 19;128:7,9;130:18;

 140:11;142:10;143:9;

 144:19;146:10;153:6;

 154:4,19;160:7;

 167:25;168:5 

worked (8)

 42:24;54:17;72:21;

 73:22;82:23;83:1;

 115:23;120:16 

workforce (1)

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working (50)

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works (12)

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workshop (3)

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workshops (6)

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workstream (1)

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workstreams (1)

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world (18)

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worried (1)

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worry (1)

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worse (1)

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worth (1)

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Wow (1)

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wrap (1)

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write (1)

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writers (1)

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writing (2)

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written (8)

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wrong (1)

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Zamora (1)

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Zealand (1)

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zero (27)

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zooming (1)

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Zuck (1)

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1 (5)

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1,000 (2)

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1,100 (1)

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1,200 (1)

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1/2 (2)

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1:30 (1)

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1:44 (1)

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10 (8)

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10:01 (1)

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10:34 (1)

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10:46 (1)

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100 (3)

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10-year (1)

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11 (1)

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11,000 (1)

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12 (4)

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12:01 (1)

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120 (1)

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13 (12)

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15 (6)

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150 (1)

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16 (1)

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165 (2)

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18 (1)

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180 (2)

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1890 (4)

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1982 (1)

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1991 (1)

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xylazine (1)

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Y 

yards (1)

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yay (3)

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year (48)

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yearly (1)

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years (37)

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yell (1)

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yellow (1)

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Yellowstone (1)

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yesterday (7)

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York (15)

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York's (1)

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Yosef (1)

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young (1)

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2,700 (1)

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20 (11)

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200 (1)

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2000s (1)

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2008 (1)

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2009 (1)

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2013 (1)

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2018 (2)

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2019 (6)

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2019s (1)

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2020 (4)

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2022 (5)

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November 24, 2023 

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2024 (8)

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2027 (1)

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205.105e (2)

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205.603a (7)

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205.603a4 (1)

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205.603b (2)

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206.105e (1)

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20th (1)

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21 (1)

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21st (1)

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24/7 (1)

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25 (1)

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250 (1)

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26-year (1)

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4 (2)

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4:29 (1)

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40 (3)

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430 (1)

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45 (4)

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4-H (1)

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5 

5 (2)

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50 (1)

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500 (2)

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60 (2)

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600 (3)

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603 (2)

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66 (1)

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67 (1)

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9 (2)

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90 (2)

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95 (1)

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98 (1)

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99 (1)

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9th (1)

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3 

3 (1)

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22:17;167:7 700 (1) 3:16 (1) 125:22 

129:4 75 (1) 3:31 (1) 43:8 

129:4 79 (1) 30 (5) 75:7 

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30-minute (1)

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(973) 692-0660 
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 UNITED STATES DEPARTMENT OF AGRICULTURE

 NATIONAL ORGANIC PROGRAM

 NATIONAL ORGANIC STANDARDS BOARD (NOSB)

 FALL 2023 MEETING

 Wednesday,

 October 25, 2023, 10:11 a.m., EST

 Marriott Downtown Providence

 1 Orms Street

 Providence, Rhode Island 02904 
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 National Organic Standards Board (NOSB) Members

 Nate Powell-Palm, NOSB Chair

 Mindee Jeffery, NOSB Vice Chair (absent)

 Amy Bruch, NOSB Secretary

 Brian Caldwell

 Jerry D'Amore

 Carolyn Dimitri

 Kim Huseman

 Allison Johnson

 Kyla Smith

 Nate Lewis

 Dilip Nandwani

 Logan Petrey

 Franklin Quarcoo

 Wood Turner

 Javier Zamora (absent) 
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3

 USDA/National Organic Program Staff 

Dr. Jennifer Tucker, NOP Deputy Administrator

Michelle Arsenault, Advisory Committee Specialist

Jared Clark, National List Manager, Standards

 Andrea Holm, Agricultural Marketing Specialist, Standards 

Johanna Mirenda, Agricultural Marketing Specialist, 

Standards

 Heather Kumar, NOSB Technical Support Staff

 Esu Obu, NOSB Technical Support Staff 
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 CONTENTS

 USDA Risk Management Agency

 Francie Tolley, Director Product Administration &

 Standards Division................................ 7

 Compliance, Accreditation & Certification Subcommittee

 Topics:

 Proposal: Oversight improvements to deter fraud:

 Consistent Location Identification.............. 99

 Discussion Document: Enforcement: Residue Testing

 for a Global Supply Chain....................... 86

 Discussion Document: Organic and Climate-Smart

 Agriculture: Climate Induced Farming Risk and

 Crop Insurance.................................. 63

 Discussion Document: Opportunities in Organic:

 Improving Support for Organic................... 69

 Policy Development Subcommittee

 Topics:

 Verbal Update: PPM Updates........................ 125

 Crops Subcommittee

 Topics:

 Proposal: Potassium sorbate - petitioned.......... 129

 2025 Crops Sunset Reviews: 

Alcohols: Ethanol............................ 139 

Alcohols: Isopropanol

Newspaper or other recycled paper, without

........................ 139 

Sodium carbonate peroxyhydrate............... 143 

 glossy or colored inks..................... 147 

Plastic mulch and covers..................... 155 

Aqueous potassium silicate .................. Error!

 Bookmark not defined. 

Elemental Sulfur............................. 192 

Lime Sulfur.................................. 201 

Hydrated lime................................ 207 

Liquid fish products......................... 210 

Sulfurous acid............................... 220 

Ethylene gas................................. 223 

Microcrystalline cheese wax.................. 229 

Potassium chloride........................... 232

 Adjourn ............................................... 236 
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 P R O C E E D I N G S 

(Time: 10:11 a.m.)

 CHAIR POWELL-PALM: Good morning, Board Members. Hope 

everyone had a good night. Excited for today. Really excited 

to hear from our guests today, so with that I'm going to hand 

it over to Jenny Tucker to kick things.

 DR. TUCKER: All righty, good morning everybody. 

Welcome back for Day 2. Thank you for being here.

 I am pleased to introduce Francie Tolle. This is 

actually the first day Francie and I've ever met in person, and 

yet we've worked together for like three years, so, woo, you're 

a live person. And so, Francie is here to talk about -- about 

crop insurance, but I want to give some background and 

personally thank her for being here.

 Francie Tolle currently serves as the USDA Risk 

Management Agency Director of Product Administration and 

Standards Division, so her division covers national policy, 

underwriting, and loss adjustment, as well as the -- the 

specialty crop coordinator and new product development. She 

joined RMA in August of 2015 as the regional office director in 

Oklahoma City, covering Oklahoma, Texas, and New Mexico.

 Previous to being at RMA, she served as the Oklahoma 

Farm Service Agency State Director. Her career also includes 

serving as the policy analyst for American Ranchers -- Farmers 

and Ranchers, Oklahoma Farmers Union working on federal farm 
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 policy, agriculture liaison to Congressman Brad Carson, and

 executive director of the Oklahoma Wheat Growers Association. 

Wow, you've been around. Yeah. 

So, Francie served as the Oklahoma Farm Bureau Young

 Farmer Rancher State Committee chairman, has served on many

 agricultural advisory boards, was named as 2012 Oklahoma

 Agricultural Woman of the Year, and was featured as a

 significant woman in agriculture by the Oklahoma Department of

 Ag in 2017. She's a native of Oklahoma. She grew up on a farm

 and ranch. She and her husband continue to farm and have two

 sons. They are now raising their fourth generation on a farm. 

MS. TOLLE: Seventh. 

DR. TUCKER: Seventh generation on a farm, sorry. 

And so, Francies been a great partner with us, that

 there are a lot of different offices across USDA, and they have

 been so good about really listening to what the challenges are.

 We collaborated on how do we, sort of, get transitioning

 farmers under our kind of our framework by having them listed

 in the Organic Integrity Database to provide an onramp for

 transitioning farmers who have done an organic system plan or a

 precursor for an organic system plan to be in the system and

 acknowledged by RMA. And these things are always harder than

 they sound on the surface, and Frankies really worked to get to

 yes on -- on a lot of things with us. And I've been very, very 

 grateful for that. 
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 And so, I'm going to turn the floor over to her. 

 Frankie, thank you for being here.

 MS. TOLLE: Good morning.

 DR. TUCKER: Youve got to push the button.

 MS. TOLLE: All right. Can -- is it -- can everybody

 hear me okay?

 Thanks, Jenny. I really didn't know she was going to

 read the whole thing. My mom would have really liked to have

 heard that. But you did a great job.

 MS. TOLLE: I -- have been on a farm all of my life.

 Have two boys; one is farming full-time, and I have a

 grandchild, but the -- the other one has pursued a music career

 in Nashville, and is singing and songwriting, so I raised two

 gamblers, completely. So, anyway, it's -- it's a great life

 but it's not always so easy.

 I'm going to hit the -- just some high-level areas of

 crop insurance, and then also the report that came out that --

that has been put together that you guys are going to discuss,

 I want to really applaud you for that, because one of the

 biggest challenges we have in crop insurance is we hear it

 doesn't work but we don't hear the specific of why it doesn't

 work, and we really need that in order to help. And I think

 you -- you would find in RMA right now that there is a big

 desire to bring everybody into the crop insurance program. 

 We really need to have organic producers and 
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 transitional, specialty crops, everybody in the crop insurance

 program; there's no reason we should not because if you're

 farming it's -- it's incredibly capital-intensive and crop

 insurance just is a way that you can help sleep at night. You

 can, as well, you can go to the bank and get a loan. I know

 when my son started to farm he said. I think I'm going to buy

 60 percent crop insurance. And I said, really? Did you talk to

 the banker about that? He goes, no. And I said, maybe you

 ought to go do that. He came home and said, I think I'm going

 by 75 percent. I bet you are because what did he say your

 operating line was going to be? I bet it was going to

 correspond to whatever your crop insurance was going to be.

 It's important for everyone. 

So, trying to work through this with you guys is

 incredibly important to us and so, I'll hit some high points,

 talk a little bit about what's in the report. We're not going

 to get through all this today, so I hope that this is just the

 first conversation that we have. 

Just to start with, I want to give you an idea of

 what the federal crop insurance delivery system looks like. We

 are -- we work very differently than a lot of other agencies,

 like Farm Service Agency or NRCS. We are small. Weve got

 about 390 employees, but our delivery system is very large. We

 go through -- our delivery system goes through what we call

 approved insurance providers, AIPs. Theres -- there were 13 of 
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 those in 2023, and from there those crop insurance companies

 have agents they contract with, there's over 12,500 across the

 nation, with over 5,000 adjusters, and those insurance

 companies work directly through the insurance policy, which is

 a contract with the producer. So, we have the largest safety

 net in farm programs, but we are the smallest agency. It's

 delivered through the private industry.

 When we look at what we're going to implement, we --

 we have several different ways we come up with programs. One

 is legislation. We also have authority to develop programs.

 Our crop insurance policies that have been out for quite some

 time that are not pilots are codified, so they are in

 regulation. So, when we do a regulation, it's not like some --

some agencies do regulations that are more restrictive.

 Generally, when we do a regulation it's because a producer

 group has come to us and says, hey, we'd like to change this

 policy. That goes through regulation.

 So, another thing I would just mention is that crop

 insurance is the same price for a producer wherever you go.

 And I've heard even in -- in my area, maybe even at the dinner

 table -- it's surprising what I hear at my own dinner table --

you know, this crop insurance or that crop insurance agent gave

 me a better deal. No, they didn't; crop insurance is the same

 for that producer regardless of where they go. What's

 different is the crop insurance agent may be offering you 
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 different options on your crop insurance policy, different

 coverage levels because it's -- you can really tailor crop

 insurance to be different things for different people. So,

 what the crop insurance companies and the agents are competing

 on is service. How well can they service the producer?

 We do have several different types of policy --

 individual crop policies. For 2023 we had 84 distinct organic

 price selections. Weve got a couple more coming in 2024. Weve

 got 18 crops that don't have a -- an organic price selection

 right now because of those three reasons I've listed: no

 know -- no known organic production in the insured areas;

 there's limited production in data; or pricing suggests the

 organic crops do not receive a premium over conventional

 products.

 That No. 2 is our biggest issue, and that's mentioned

 throughout the report, is where do we get our data? How do we

 get data? We get it several different ways.

 People bring it to us. The NAP Program was

 mentioned, and if you're familiar with the Farm Service Agency

 NAP Program, that's another place that producers can get

 coverage up to 65 percent. NAP's not required to be

 actuarially sound. So, the premiums that producers pay is just

 a flat rate; it's 5-1/4 percent of the liability. So,

 producers that are going and purchasing NAP at FSA, while we

 may not be able to insure it and be actuarially sound, if it's 
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 being insured at NAP -- or at FSA through NAP, we can go get

 data there. So, if producers are doing that, that's one way.

 Like I mentioned, sometimes we get data from producer

 groups, and I think there's a question about how much data do

 we need? Theres not really a set amount but what we do need is

 multiple years of data that spans more than one producer for

 sure, maybe a county, there's not a set amount of producers,

 but the more producers you can get in an area and get

 production data over several years the more helpful it is.

 Another thing that we've been able to do in some

 cases is to look at a proxy crop. So, if there's a crop that

 is similar, that yields similarly to whatever crop were trying

 to ensure, sometimes well -- we will use that data.

 In the report, too, there was one producer that

 mentioned small grains are not insurable in their area. Small

 grains should be insurable pretty much everywhere, but if it's

 not, we certainly would like to know where. And so, when

 comments are made like that, we really want to look and see

 where is this happening? And is there a way to expand?

 Written agreements were mentioned in the report that's a way to

 get crop insurance when it's not offered in the county; that

 is -- it involves more paperwork, and I can see why someone

 wouldn't want to do it. But I can tell you that is how we

 expand, so when regional offices get a written agreement

 request, and they do that, they know that there's interest, 
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 they know what the production is in that county, and they can

 expand more easily.

 The contract price addendum, I think most of you that

 are familiar with crop insurance are aware of that. That came

 into being in 2014. I'm not going to spend a lot of time on

 that, but that was brought about to get to a price that is more

 comparable to what the value of the crop is for organic.

 Generally, most crops have a maximum value of two times the

 conventional price or 1-1/2 times the announced premium organic

 price selection. I just put a simple example with corn because

 it's -- it's very easy when -- up right there. You can see

 conventional price is 5.91, organic price was 11.10, and the

 maximum contract price factor for corns 1.5, so the maximum

 contract price is 16.65. And I put a link to the fact sheet

 there if you want more information. This presentation you can

 give to whoever you want, so you can follow back up and -- and

 take a look. I put some links and different information

 throughout.

 There are several kinds of plans that are available.

 Most popular are yield and revenue protection. Just like it

 sounds, you're insuring the yield or the revenue, which is

 yield times price and you're insuring a percent. Generally,

 it's 50 to 85 percent coverage level. That means, for example,

 if a farmer is -- got 70 percent coverage level, there's a 30

 percent deductible, so there's that 30 percent that they're 
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 going to have to cover themselves.

 There are various endorsements and supplemental

 policies out there that producers can have that help fill that

 deductible, and generally those are area type plans; they're

 not specific to the producer, so they're generally based on the

 county. A few of them that I've listed. They are: STAX --

 excuse me -- STAX, which is cotton related; Supplemental

 Coverage Option; Enhanced Coverage Option; and then the

 Hurricane Index Protection plan, which we added tropical storm

 to this year. That helps give the producer an opportunity to

 get up to a higher coverage level, generally 90 to 95 percent,

 with the -- with the exception of SCO, that's 86 percent.

 So, what does that look like for organic and

 transitional? Just to give you the ideas of the acres that

 participate in these kinds of supplemental policies, ECO has

 grown quite a bit, 38,000 to 112,000. HIP-WI, which is the

 hurricane, 29 to 36 thousand. SCO, 96,000 to 147,000 acres.

 And then STAX, 19,000 to 45,00. So, those are just ways a

 producer can get to higher coverage levels. It -- it is

 expensive in many areas, depending on the risk. I live in

 Oklahoma, I farm in Oklahoma, it's expensive. So, it really

 depends where you are.

 We also have Area and Rainfall Index Programs, like

 the Pasture Rangeland Forge Program that was mentioned in the

 report. That coverage is -- covers perennial crops 70 to 90 
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 percent. We did add the organic -- excuse me -- the organic

 and transitional practice to that last year, so those producers

 that had that policy could take advantage of the Transitional

 Organic Grower Assistance Program, which provided additional

 premium. I'm going to get into that later.

 Also, area plans, again, if you instead of wanting to

 have an individual crop policy, you can look at a -- a county

 wide policy, which sometimes is less expensive, but with that

 because it's a county policy, it doesn't exactly follow what

 happened on your farm. You may have a loss, county did well,

 so you -- the -- it's not going to trigger an indemnity. So,

 again just lots of different options for coverage out there.

 The big one that is talked about a lot within

 specialty crops and organic is Whole Farm Revenue and Micro

 Farm, and it was mentioned a lot in the -- in the report.

 Whole Farm Revenue was first offered in 2015, and Micro Farm in

 2022. Both of these policies cover all crops under one

 insurance policy. So, if there's a crop that is not -- unable

 to be insured individually, this is one way to get coverage for

 it. I'm not going to go through how Whole Farm and Micro Farm

 work. I certainly will later. I'm going to be around all day,

 too, if anybody's got more questions even after this.

 But what I do want to point out is, we made a number

 of new provisions this year for 2024, and most all of those

 came from -- we did a Whole Farm Roadshow where we went all 
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 over the country talking to producers and agents, and tried to

 incorporate as much feedback as we could, and so those are

 where the -- the new things came from.

 One, just extended sales close date -- close date --

 closing date for Micro Farm. That was one that agents were

 like, you know, I've got March 15th as a sales closing date,

 I've got all these other policies, I don't really have time to

 go out and get small producers insured, and if I had a little

 more time to talk to them it would help, so we extended the

 sales closing date by 30 days.

 In the report there was a -- a producer that

 mentioned that they didn't know if a Whole Farm was subsidized,

 and it is. And we made some changes to that just this year.

 So, previously if you only had one crop that you were covered

 with Whole Farm -- that you had with your Whole Farm policy, so

 let's just say you had a sweet corn, that's the only crop you

 have. Period. You were not eligible for 80 to 85 percent

 coverage; now you are.

 We also increased the subsidy level. So, you can see

 at the bottom there, that the subsidy level between 50 and 70

 percent is 80 percent, so the government is subsidizing 80

 percent of the premium. At 75 percent, 80 percent, 85, it goes

 down some. If you've got two or more commodities, the subsidy

 is a little bit higher. So, that's there just for your

 reference on subsidy. 
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 Generally, for the Crop Insurance Program, subsidy

 across the Board -- and I'm talking about forever -- for

 everything -- is 62 percent.

 A few notes on Whole Farm. One of the notes from the

 report talked about that expanding -- it's really difficult for

 expanding farmers, because it goes back to the T-yield, and

 that's -- that's probably just a misunderstanding. There are

 expansion provisions in both Whole Farm, as well as Micro Farm,

 and those expansion limits are based on their own -- your own

 production and your -- your own pricing. So, I just put that

 in there for -- for reference.

 There was also a reference in decreasing

 participation in Whole Farm Revenue, and Whole Farm Revenue

 does not mean necessarily specialty or organic crops. As a

 matter of fact, we have a lot of row crops -- conventional row

 crop growers that use Whole Farm. And in the last couple of

 years, when prices were so high, they dropped out of the Whole

 Farm Revenue Program.

 For organic specifically, if you look at the number

 of Whole Farm Revenue policies that identified a commodity in

 the farm plan as organic, there were seven in 2015, and in --

and there were 274 in 2023, so that part is growing. It's not

 growing as much, and I hope we can make more changes to whole

 Farm that make it more appealing.

 Also, one of the -- the comments was looking for 
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 better ways to include beginning farmers and ranchers. One

 hundred percent agree, and that's one of our priorities this

 year. The issue with Whole Farm and Micro Farm is, if you

 don't have history you can't be insured because that's what

 it's based on. So, what do you do with the beginning farmer

 that doesn't have any history? What do we -- what do we insure

 them for? We have a few ideas hopefully we can work through

 that before the next crop year and come up with something.

 Also, the reduction in paperwork. We've continually

 tried to do that. We can still do better I'm sure. Year

 before last, we removed expense reporting, which was a big part

 of Whole Farm Revenue.

 We also have a new program out called Production and

 Revenue History. PRH is designed for specialty and organic

 crops as an individual crop policy, but the producer is using

 their own price and yield history. It was initially offered

 for strawberries in 2021, first in Florida, then in California.

 And we've had several agents requesting it be extended to other

 crops, and so we're looking at other crops.

 You know, this is a new pilot. What's most helpful

 for us is to get feedback, specifically of how crop policies

 work or don't work. So, if you are involved in a policy, if

 you can give us examples of what -- what really worked or what

 didn't work, it's helpful.

 Program growth and performance. This just shows that 
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 the last 10 years, from 2013 to 2023, the number of policies

 have grown. I'm not going to read those numbers off to you;

 clearly, there's been a significant amount of growth.

 The one thing that was talked about throughout the

 report is loss ratios, and loss ratios are not good. When

 we -- when you look at loss ratios, you at least, for every

 dollar being paid out, you want a dollar coming back, so it

 really shouldn't be any higher than "one" when you're looking

 at being actually sound. The entire program, as mentioned in

 the report, is not only are we looking at a loss ratio of one,

 we are required by law to have a reasonable reserve, so the

 entire crop insurance program loss ratio is at about .88,

 generally.

 So, this is a struggle for us. And as in the report,

 a lot of producers talk about T-yields being too low. But,

 unfortunately, when we look at this, they're too high. I put a

 link in there to an organic report that's on our website. If

 you want to go more to specifics in different states, different

 crops, and look at what the loss ratios are to see what they

 are more specifically, you can do that, but this is something

 that -- that we do struggle with because we -- we want to give

 producers as much opportunity as we can, we don't have a lot of

 data, clearly we don't have it refined as much as we need to

 have it refined, and so it's -- it's just going to struggle.

 This is a map of the organic insurance policies that 
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 we had in 2022, as well as the Top 10 insured organic

 commodities by liability. You can see they're kind of grouped

 there; the darker the color, the more policies there are. You

 know, my thought on that is, anytime you have a producer doing

 something that is working, other producers start looking at it

 and say hey I think I might want to try to do that, and they go

 ask questions. and so, you know, I think the more successful

 organic farms we have, the more people will start to look at it

 and -- and try to get involved.

 Some changes in initiatives. One thing that was

 mentioned in the report are -- were deadlines and timing. One

 thing that we did change a couple of years ago is we revised

 when a producer must provide a written certificate -- written

 certification. We used to require that at Acreage Reporting

 Date. Not everybody has that at Acreage Reporting Date, so now

 we require that you just show us in writing that you have

 requested that. You do have to have it at loss time, because

 that's what we will look at when there is a claim filed.

 Some other notes from the report I just want to

 mention. Difficulty obtaining crop insurance with cover crops.

 I would -- I'd really like to hear more specifically on that.

 In 2020, we made some changes to cover crops and there's three

 different ways termination can happen with cover crops now. one

 is the zonal guidelines that were there previously. The second

 way is if there is published materials, let's say a university 
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 or -- or ag experts have published material for the area,

 saying this is a way that cover crops can be terminated; that's

 one way. Or the third way is that you have an ag expert that

 says this is a good way to terminate cover crops. That can be

 brought to your agent, to your AIP, and they can take a look

 and say, yeah we agree, and it can be insured. So, there's

 three different ways. I don't know if that has helped things,

 if people realize that yet or not, but I would like some

 feedback on it. That third way of getting an ag expert to

 provide written documentation on a new way for termination,

 I've had people ask question -- ask how that works but I've

 never seen anybody actually do it, so maybe somebody will do it

 in the future but I'm not aware of anyone that has yet.

 Also, there was a comment, RMA would like

 additional -- or there was a comment, and we would like

 additional information on deadlines that they come -- that come

 before a producer has time to analyze numbers from the previous

 year. Not sure what that was referring to but would be

 interested in looking at that.

 There was a comment, premiums are due in August.

 Join the club; nobody likes that. Thats legislation, so we

 can't do anything about that one.

 Planting dates. This one we've had a lot of

 conversations with organic groups wanting to plant later, and

 it's something we want to look more at. This is something that 
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 the regional offices look at, and what we -- what RMA is

 looking at in the regional offices is they're taking the data

 that they have and they're looking at plant dates, and then

 they're looking at indemnities. And so, what we need to see is

 people are planting later and yields are going up; not people

 are planting later, and yields are going down. So, that's

 really -- it's been difficult to work through because we'd like

 to allow planting dates later. We have a couple of ideas on it

 that we haven't worked completely through, but I'm hopeful we

 might -- might have something we can do on that in the next

 year or so.

 Also, we worked with AMS. Jenny has been my best

 friend. Really appreciate her helping us with things that we

 don't understand.

 And I need to just wrap it up here, and we will come

 back to this and start with other efforts. Kind of want to

 tell you about what we've done and give you -- talk to you

 about some opportunities that might be there. So, for sake of

 time and some important announcements, I will just pass it off

 to whoever is --

 DR. TUCKER: Okay, we're going to just stand by for a

 minute here. We're expecting a guest in. Let's give Francie a

 big round of applause. That was great.

 (Applause.)

 DR. TUCKER: And we're waiting. And we're waiting. 
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 Let's go ahead, and I think for right now, clear the slides.

 We're going to want to project in the room the Zoom thing if

 you're able to switch over.

 We could all stand up and breathe. In the meantime,

 I'm going to tell you that we will be posting the RMA slides --

 don't go far folks, stay in the room. We will be posting the

 RMA slides on the website with everything else. It is always

 good to stretch, though.

 (Pause.)

 DR. TUCKER: So, Francie you got a good joke?

 (Laughter.)

 CHAIR POWELL-PALM: Kim, you got a good dad joke for

 us?

 DR. TUCKER: We didn't want to start the Q&A with

 Francie and then introduce -- take a break just because that's

 a lot of switching.

 (Pause.)

 DR. TUCKER: Okay, find your seats again.

 Francie, thank you again. Lots of moving parts

 today.

 MS. TOLLE: They probably needed a break from me

 anyway.

 (Pause.)

 DR. TUCKER: Okay, couple of Zoom challenges on that

 end? 
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 MS. ARSENAULT: Right.

 DR. TUCKER: She's having a couple of -- of Zoom

 challenges, so it's not us.

 MS. ARSENAULT: Yeah, just stand by.

 (Pause.)

 DR. TUCKER: Okay, apparently they can hear her.

 Okay, so apparently folks can hear her online but not see her.

 Oh, there we go. Yay.

 Good morning.

 UNDERSEC MOFFITT: (No audible response.)

 DR. TUCKER: Okay, we can't hear you in the room,

 hold on.

 So, this is, for those who don't know, Under

 Secretary Jenny Lester Moffett, Marketing Regulatory Programs

 Under Secretary, and it is a pleasure to have you on.

 UNDERSEC MOFFITT: Yeah, thank -- thank you, Dr.

 Tucker.

 DR. TUCKER: Yay. We can hear you now.

 UNDERSEC MOFFITT: Okay, great. Well, it is a

 pleasure to be here. I'm glad you're all able to hear, and --

and I'm sorry that I'm not able to join you at the NOSB meeting

 in Providence this time. It was such a pleasure last year for

 the fall meeting to be able to join NOSB at the meeting in

 Sacramento. I know there was -- I really appreciated the

 questions, the answer -- the engagement, the just really 
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 genuine interest, and the work that we're doing at USDA from

 the National Organic Standards Board, so sorry again that I'm

 not able to be there in person.

 But I wanted to join you virtually, and swoop in in

 the middle of your NOSB meeting, to -- to share some really

 exciting news. Today, just in a little bit, we're going to

 release and announce -- the Secretary Vilsack is going to be

 announcing that we are -- we are moving forward, and we are

 rolling out the Final Rule for the Organic Livestock and

 Poultry Standards, or OLPS as we call it. This is a really,

 really exciting occasion. Something that I want to do first

 off, commend NOSB. This has been a long time coming, certainly

 through NOSB. And then through the National Organic Program

 staff in making this happen. So, I want to thank the -- both

 NOSB, the leadership of NOSB over the -- the years, if not more

 than a decade, and -- and the works, but also the National

 Organic Program staff. This is an exciting time that we are

 issuing this Final Rule for OLPS.

 I think many of you in the room knows what this

 means. This means that we are -- we are continuing as -- as

 NOSB and -- and all of our organic stakeholders know organic

 is -- is continually improving. That is what NOSB is about.

 That is what rulemaking is about. That is what the -- the

 original tenet of OFA is about; is yes, we have organic

 standards, and yes, we know that organic is -- is constantly 
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 changing, improving, and I think OLPS and the Final Rule today

 is just another example of that.

 Of course, earlier this year we also issued the Final

 Rule for strengthening organic enforcement. So, these rules

 are really an important part of continuous improvement, which

 is again a core tenet of organic production.

 So, as you know, these rules are going to establish

 clear, strong, and consistent standards for organic livestock

 production handling. It's going to level the playing field so

 that there is consistent rules that organic livestock farmers,

 ranchers, and businesses are -- are following when they're

 producing organic livestock and poultry products. It supports

 animal welfare through greater outdoor access and more

 consistent standard for living conditions for healthcare, for

 transport and slaughter of livestock and poultry. It does many

 different things, and of course as I talked about, more

 consistent standards for outdoor space, more consistent

 standards for indoor and outdoor living, more consistent

 standard for poultry stocking densities, preventative

 healthcare practices, physical alteration and euthanasia,

 transport handling and slaughtering.

 Consistency is key. This is about leveling the

 playing field. This is of course something that we've been

 talking about, and we've been working on across the department,

 making sure that all producers are operating in a fair and 
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 competitive -- in a market that is -- is really about

 bolstering the bottom line for producers and making sure that

 there's a fair competitive market. And also, that consumer

 confidence has continued trust that when -- when they buy

 something with that green USDA organic seal it means exactly

 what they think they're buying. And so that I think is a

 really important piece of consumer confidence and trust in the

 organic seal.

 So, one big part, and I know this was discussed a lot

 and so I just want to -- to raise it as far as the

 implementation timeline for OLPS, there are many different

 pieces of it but at most is a five-year implementation timeline

 for the furthest out parts of implementation for OLPS, and I

 think that's really key. I know we heard a lot from public

 comment; we had over 40,000 comments. We really strongly

 encourage comments. We've received really robust comments and

 I want I think the industry, want to thank everyone who was --

who is part in -- in helping to provide feedback as we develop

 these rules, both the Draft Rule last year and then as we got

 into the Final Rule, that makes a world of difference in -- in

 making sure that we're -- we're hearing from everyone and were

 hearing about the pros and cons of different decisions as the -

- as the rule is being made.

 So that, I think, is all I have to share. The

 Secretary, as I mentioned, was going to hop on a press call at 
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 11:00 today, so just in a few moments and -- and share this

 with -- with the media. I want to thank Chair Powell-Palm

 who's also going to join on that press call, so thank you

 for -- for agreeing to participate. This is an exciting day

 for us. This is an exciting day for the organic industry.

 This is an exciting day for NOSB, as we continue to work on

 implementing the important conversations, the important

 direction, the important guidance that we receive from NOSB

 through the rule making process, at the National Organic

 Program, this is again, as I said, this is about leveling the

 playing field. This is about continuous improvement in the

 organic -- in organic production systems, making sure that we

 have, and we maintain rigorous and -- and a strong organic seal

 that all consumers should feel proud and confident to -- to

 look for in the grocery aisle. So, I want to thank you all for

 your engagement and we're really excited about this

 announcement today.

 I'll pass it back to you, either Dr. Tucker or --

 yeah.

 DR. TUCKER: So, lots of --

 (Applause.)

 UNDERSEC MOFFITT: And big round of applause to you.

 This is -- this has this has really been a long time coming,

 and -- and it -- and we appreciate your patience.

 DR. TUCKER: So, lots of applause in the room here. 
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 I'm not sure whether you could hear us or not.

 UNDERSEC MOFFITT: Thank you.

 DR. TUCKER: But lots of -- and I can see the

 applause coming up on Zoom, so very well received here in the

 room. Thank you so much for -- for joining us at the meeting

 today.

 So, in terms of what we're doing here at the meeting,

 Nate and I are going to be stepping out for that -- for that

 press call, so we will be turning the meeting over into the

 capable hands of Amy. And NOP team is in the room, as well.

 And I think you're going to pick up with Q&A with Francie.

 Thank you, Francie, again for being here.

 And so have a good Q&A session and we look forward to

 seeing you on the flip side.

 Thanks again, Under Secretary, for being here.

 UNDERSEC MOFFITT: Thank you.

 SECRETARY BRUCH: All right, just an incredible day

 all around. That's a great, wonderful announcement that we

 just heard. And we're going to just continue this segment on

 crop insurance and then we might take just a short break

 because I know everybody is excited to interact with their

 communities, as well, on this news that were having, so we're

 just going to keep momentum a little bit longer on crop

 insurance, see if Francie has anything to finalize with her

 presentation, which was wonderful. It was just so powerful to 
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 hear all of the improvements and changes and just kind of the

 nimbleness of the program that our feedback is really well

 received, but we'll have you, if you have anything to finish up

 on, and then we'll open it up to any questions.

 MS. TOLLE: All right. You guys were probably ready

 for a -- for a break from me, anyway.

 So, I'll pick back up where I was with other efforts

 talking about our work with -- with AMS and -- and Jenny on

 NOP's Integrity Database certificate and utilizing that as a

 way for acceptable organic and transitional records.

 Transitional has been a challenge for us in what we

 can have from a grower that's in transition to show they are

 actually in transition. So, we're -- this is not perfect, but

 it's one way we have identified that we can identify

 transitional growers.

 One of the challenges is -- is, you know, I like to

 think that everybody that participates in the crop insurance

 program or farmers or whatever are completely honest, but we

 don't always see that in any, you know, in any industry, but

 that includes agriculture, and so what we don't want to happen

 is a producer that is out there, maybe during times when input

 costs are so high as they have been, saying, yeah I didn't

 apply this fertilizer or this chemical or this pesticide

 because I'm transitioning, and get a crop insurance indemnity,

 because the last thing we need is for more indemnities to go 
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 out the door and those loss ratios -- loss ratios to go up and

 the program become more expensive for everyone. So, thoughts

 from you guys to really talk about this issue, we would

 appreciate any feedback on that.

 Some other efforts, we have funded four of the last

 seven organic surveys with NAS. NAS, of course, just like any

 other agency has faced cuts and so forth, so we have provided

 $6 million for them to complete the various surveys. Data,

 again, I can't stress enough, that's one of the biggest issues

 that we've got, so any ideas that you have on -- for us to get

 more data, we are certainly open to.

 We do have an outreach and education program we call

 the Risk Management Education Partnerships. We just announced

 just not long ago, six and a half million dollars that we're

 providing to partners across the nation. That was for this

 last year. But I just pulled up a few -- those that identified

 that they were going to work specifically for -- with organic

 producers. So, in the last two years: in '22 and '23, the Iowa

 Organic Association; in '22 and '23 The Gleaning Network of

 Texas; '23, Center of Rural Affairs; '23, Napa Valley Grape

 Growers; and in 2022 the Organic Trade Association. And I put

 a link there to the RME Program. I would really encourage any

 organizations that are out there that can help us reach organic

 producers to look at this program and become a partner.

 The "NO's" from the report, other than producers not 
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 wanting or needing crop insurance, the reason for not having

 crop insurance is they're unfamiliar with it. You guys that

 know the producers and are talking to the producers are going

 to get to them far better than we are. So, just think about

 this; I wish I lived next to Amy, I might become an organic

 grower because she could probably teach me how to do a lot but,

 it's --it's the people that know what's going on that -- that

 help us move the needle on most everything.

 The Transitional and Organic Grower Assistance

 Program, that's something that we had for 2023. That was onetime pandemic funding that we used to support organic and

 transitional growers. That what we did was offer additional

 premium assistance. And for transition -- crops in transition,

 we offered an additional 10 percent premium subsidy, so if that

 crop or your coverage was subsidized by 70 percent, it was now

 subsidized by 80 percent.

 For organic grain and feed crops, we added $5 per

 acre premium assistance. And then for -- on top of that, if

 you had Whole Farm, in addition to any individual policies,

 there was a 10 percent subsidy increase, as well.

 This is preliminary, but what we've seen so far there

 were about 4900 produce -- producers that participated, with

 9,200 policies, so some producers obviously have more than one

 policy. For transitional organic, there was an additional

 subsidy paid out of 571,000, and for certified organic there 
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 was over 8.4 million paid out to organic grain and feed crops.

 So, just some things that we have that we're working

 on that we've heard requests for. One is allowing more

 enterprise units for specialty and perennial crops. Enterprise

 units is just a way of ensuring where you're pulling all your

 farms together, and because of the diversification in

 geography, there's a bigger discount. There's a premium

 discount for enterprise units, so it makes crop insurance more

 affordable. Anytime we expand the opportunity for enterprise

 units to specialty crops or perennial crops, that also means it

 goes into organic and transitional crops, as well. We're also

 looking at allowing enterprise units for organic farming

 practices, which is a request that we received. Also, looking

 at offering more optional units; another way to allow producers

 to tailor crop insurance more to however their -- their farming

 operation is set up and what their risk management situation

 is.

 Also, one of the requests we got from an organic

 group was they'd like to see some guidelines out there that

 really outline how -- how crop insurance works for organic and

 traditional farmers, but all -- and what the requirements are,

 but also something agents would have. So, we're working on

 those guidelines now, and we're going to be asking for feedback

 on this, so I don't know if maybe I can share those with Jenny,

 and she can pass those on for you guys to take a look. We're 
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 looking at incorporating that so AIPs and agents will have that

 to share.

 Also, the Good Farming Practices Handbook, making it

 clear that NRCS Conservation Practice standards are considered

 a good farming practice. And let me explain the good farming

 practice, how that works for crop insurance. When we say,

 "good farming practice," what that means in the crop insurance

 world is, let's say you're a producer and you have a claim, and

 the loss adjuster comes out and says, you know, I don't think

 you followed good farming practices and we're not going to pay

 the indemnity. The producer has the right to appeal, and he

 goes to the regional office, and say [sic], I did follow a good

 farming practice and here's what I did. And so, they provide

 whatever information they have that they followed. If it's,

 you know, a certain practice for conventional, it might be, did

 they put enough fertilizer on, whatever it is; they provide why

 they did what they did. The AIP will say, well, this is why we

 think that they didn't follow good farming practices. And so,

 the -- the regional office will look at both and say, yes we --

 we think that the farmer did what he was supposed to do

 according to good farming practices and ag what experts would

 say, or they will go with the AIP, and then there's appeal

 process. That's the good farming practice process that a

 producer would work through. So, when we say good farming

 practices, it's just not a simple thing. It's a -- it's a 
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 process.

 One of the notes in the report was that there's

 discrepancies between NRCS and RMA on what is recognized as a

 good farming practice. We -- if you've got specifics that

 would really be helpful for us. So, if there's practices out

 there that -- that there's been someone that's gone through the

 good farming process -- good farming practice process that did

 not go well, we'd really like to hear about that. Especially,

 if it's an NRCS practice.

 And with that, I'm finally wrapping up. There's a

 lot of information on our website, RMA Local. If you have not

 got to know your regional office, I would highly suggest you

 do. They're a good resource for lots of things and talk about

 T-yields. Planting dates, in particular, go through regional

 office. And then there's a -- a lot of tools on our website.

 And I'm -- I'll be here all day, whatever time we

 have now, later if you want to catch me. We also have a -- a

 whole team of organic SMEs, it's not just me; we have a good

 team of people that spend a lot of time trying to figure out

 what our next steps are on organics. So, appreciate the time

 and look forward to the conversation.

 (Applause.)

 SECRETARY BRUCH: Thank you, Francie.

 And this -- this is such a relevant topic to our

 community. We received a lot of comments from our 
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 stakeholders, particularly farmers. Thanks for being a farmer

 yourself and understanding our challenges. I think that's the

 first step for continuous improvement. And also, if you want

 to transition your farms, I'm sure I could help, or there's

 several people that wouldn't mind talking to you.

 So, with that, I'd like to open it up to some

 questions from our board. Dilip, go ahead.

 BD. MEM. NANDWANI: First, like to thank you for your

 excellent presentation. A lot of good information. And wanted

 to say that I do work with the local or regional office RMA in

 Tennessee.

 MS. TOLLE: Wonderful.

 BD. MEM. NANDWANI: They have been very helpful. And

 with other agencies. I have a question, a clarification, and a

 comment.

 So first, the question, you showed a U.S. map,

 country map where we have these green dots, crop insurance, and

 we notice that some states and some regions they have more and

 some they don't. What could be the possible region [sic] you

 think that they are lacking and what can be done? That's one

 question.

 Can I ask -- say the comment also?

 MS. TOLLE: Sure.

 BD. MEM. NANDWANI: The clarification, or the second

 is, you also mentioned in vertically integrated entities on the 
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 new -- on micro farm, so can you tell us a little bit about --

 I was talking to Nate while we were waiting for, you know,

 Under Secretary Moffitt to talk to us, and here a little bit

 mention about this, so. So, vertically integrated entity, is

 it about vertical farming? Or is it about soilless farming?

 Or what? Can you tell us a little bit more? Yeah.

 MS. TOLLE: Let me do this one, and then I'll go back

 to that slide.

 And you're asking about vertical integrated entities

 that can be insured in micro farm; is that the question --

 BD. MEM. NANDWANI: Yes.

 MS. TOLLE: -- now? Okay. All right. First

 question on this, you know, I can give you my best guess, but

 it's a guess. So, what this map shows is where we have organic

 insurance crop insurance policies, so the darker the green the

 more insurance policies we have in that particular area. So,

 when you're looking at -- at that darkest green, we have over

 50 policies.

 There's probably a lot of reasons, but to me as a

 farmer, if I've got somebody around me doing something that's

 successful, and -- and literally, me living next to Amy would

 be the best example, she's successful and I would be saying,

 Amy, what are you doing? And she'd help share that

 information, and then I'd have to talk my husband into it.

 But -- and so then once you get people talking about it, and 
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 doing it, and doing it right -- and that's a key, too; doing it

 in a way that's -- is successful for the producer, as well as

 your organic community and representing you well, that that

 helps spread.

 Crop insurance agents, where there are none, I'm just

 going to take my example. I live in north central Oklahoma.

 There's nothing around me. What -- if I went in to talk to my

 crop insurance agent, they would have to go research for me

 what to do. And so, I want to be able to provide you guys with

 enough information to go ask. So, if I were transitioning, or

 I were organic, I would take to my agent and say, this is what

 I'm looking for and, you know, this is what I want to insure.

 These are the things I've read I need; I need your help. And

 most will try to help you. There might be a few out there, but

 it's an educational process for those agents that don't. We've

 really tried to step up the training to the AIPs, as well as to

 the agents, to say this is how it works, this is what you need

 to be doing. The guidelines that I talked about that were

 going to put in one of our handbooks, it will be provided to

 that agent, as well as the producers, is another way of us

 trying to make it clear this is what you need to be doing, this

 is what you need to be looking at. So, I think there's a

 responsibility on all levels for people that are doing it, for

 us as an agency, to be getting as much information out there.

 So, I don't know if that exactly answers your 
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 question. It's kind of my speculation on all of it.

 BD. MEM. NANDWANI: No, you did very well.

 I wanted to very quickly add that there -- there are

 two cover crop council if you are aware of that? Southern

 Cover Crop Council and Northeast Cover Crop Council. And you

 were asking about some more data in your, I think, last slide,

 how you can obtain more data, so I would probably add that;

 that these two councils, they could be a great tool or resource

 to collaborate with them. And I'm part of the -- on their

 board, also. Probably I will mention to them to work on and,

 of course, email.

 In Tennessee, also when I go back to do something

 about these crop insurance, to collect more data, but SEC and

 MESCC, they are available, and we can convey them to work on

 these -- collect some, you know, help on this more data.

 MS. TOLLE: Okay.

 BD. MEM. NANDWANI: But thank you again for your

 excellent presentation. I don't know if you want to say

 anything on vertically.

 MS. TOLLE: Let me back up to your other question

 on -- I think you were asking about -- allow vertical

 integrated entities.

 BD. MEM. NANDWANI: Right.

 MS. TOLLE: So, micro farm, previous to this year, we

 did not allow vertically integrated entities for the primary 
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 reason we're insuring small farms up to 350,000, 400,000 if

 they're carryover insured. What we didn't want to see happen

 was very large entities start breaking up into different

 entities so they could apply for micro farm. But we decided

 there was enough of a request for those legitimate people that

 are vertically integrated, throughout the process we're just

 going to do it, and so we just did it. It was -- it was a big

 request that we got, and so we'll monitor it, but just another

 thing that we put out there for this year.

 BD. MEM. NANDWANI: Thank you very much. Thanks

 again.

 SECRETARY BRUCH: Okay, Dilip. Allison, go ahead.

 BD. MEM. JOHNSON: Thank you, Francie. This is very

 interesting, and I'll have to admit, over my head in a lot of

 spaces, so I may have some questions that ask you to reiterate

 points that you already made.

 This question, I -- I think you already partly

 answered, but I've heard that in Texas it's hard to find or

 maybe impossible to find Whole Farm policies. So, for a

 producer in a location where there's no one offering the type

 of policy that they need, what should they do?

 MS. TOLLE: So, No. 1, they should be offering it.

 There are agents that are more familiar with it than other

 agents are, for sure. So, if you can't -- we don't have a

 resource that says, okay, this agent provides Whole Farm, this 
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 one doesn't. They -- like I said, they all should be, but if

 somebody is really -- just can't find someone, contact the

 regional office and we'll see if we can help.

 BD. MEM. JOHNSON: Great. Thank you.

 MS. TOLLE: Or e-mail me. You guys are going to all -

- don't e-mail me everything, but if you have a question, you

 do have my email.

 BD. MEM. JOHNSON: Okay, thank you. And you had a

 few slides that had acreage, some that had policies, and I

 think the TOGA slide had, actually, number of operations

 participating, and I'm wondering if you can speak to operations

 participation in Whole Farm? Are we seeing increases in

 acreage for organic and in numbers of operations that are

 accessing crop insurance policies? Or do you have a sense of

 how that breaks down?

 MS. TOLLE: So, Whole Farm is just one way that

 someone can insure their operation, and it's not for everyone.

 Is this the one you were talking about, maybe?

 BD. MEM. JOHNSON: Yeah. This one, and then

 comparing later to TOGA --

 MS. TOLLE: To TOGA.

 BD. MEM. JOHNSON: -- where you did have number of

 operations in addition to policies.

 MS. TOLLE: Okay. All right. So, the program has

 grown quite a bit. What's not separated out here to your 
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 specific question is how many of these policies are Whole Farm

 versus individual type policies, and I think that's maybe what

 you were trying to get to?

 BD. MEM. JOHNSON: More how -- can we assume that

 number of policies is equivalent to number of operations? And

 are you seeing more operations overall take advantage of crop

 insurance opportunities as that acreage is growing? Or is it

 maybe that a similar number of farms are participating but they

 have more acreage?

 MS. TOLLE: Um-hum. So, for example, on the TOGA

 slide, and we can go back to it here in a little bit, there was

 something like 4,000 producers and 9,000 policies. So, if I'm

 growing corn, Wheatley, and sweet corn -- well, sweet corn

 might fall under corn. If I was growing two or three different

 crops, I'll have two or three different policies. Amy probably

 has more than one policy, I'm assuming. So, one producer might

 equal two or three policies, so when you're looking at this and

 it says we've got certified organic 10,000 policies, that could

 be 3,000 producers. I don't know for sure. Could be 4,000.

 But it's not going to be 10,000. I promise you.

 So, does that help? Did I get to what you were

 asking?

 BD. MEM. JOHNSON: Yeah. And there was a slide a few

 before this that showed the growth in acreage that was pretty

 significant, that just had acreage, and I wonder --
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 MS. TOLLE: Okay. So --

 BD. MEM. JOHNSON: -- if you have -- down there?

 MS. TOLLE: Um-hum, for that one -- this one? Okay,

 so these are supplemental policies, that when I talked about

 producers have a choice of getting an individual crop policy,

 so I'm going to buy specifically for my corn -- and I know I

 keep using that, this as the simplest one -- I've got a

 insurance policy specifically for corn. I've also -- what

 everybody likes to talk about is Whole Farm, and that's great

 for really diversified, if there's not an individual -- but

 there's a lot of people buying individual policies, and when

 you buy an individual policy ,like I said, you're deductible --

you might buy 70 percent coverage, which means 30 percent of

 the value of the crop if you have a loss you're covering

 yourself. And so, these supplemental policies, which are

 generally area based, you have an opportunity to purchase as a

 producer to help fill that gap up to 0 or 95 percent. So,

 these would be on individual crop policies. They're not on

 Whole Farm; this would just be, say, on that corn policy. So,

 Enhanced Coverage Option would go up to 90 or 95 percent;

 Hurricane Insurance goes up to 90 percent; Supplemental

 Coverage Option up to 86 percent; STAX up to 90 percent. This

 shows the number of acres that are transitional or organic that

 are covered by these various policies, specifically for organic

 or transitional. So, Enhanced Coverage Option goes up to 90, 
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 95 percent; that one has really taken off for a lot of

 transitional organic. I have not analyzed this before I say

 what I'm going to say; if I were guessing, it's going to be in

 the Midwest in the ice states and on grain crops is where I'm

 going to guess that's going on.

 BD. MEM. JOHNSON: But do you have a -- a breakdown

 of how these acres map to number of operations?

 MS. TOLLE: Not right off.

 BD. MEM. JOHNSON: Okay.

 MS. TOLLE: I mean, that's something we could

 probably look at, but I don't right off. I just wanted to kind

 of show there -- when we have policies for conventional crops,

 most of those are also available for transitional organic, so

 we've got other things, too. Quality Loss Option, those are --

not going to go in that, gets way in the weeds -- those are

 available for transitional and organic farmers. So, I don't

 have that right off if.

 If -- if there's really a need for data, and I think

 maybe there might -- there might be some more observations on

 or wanting to look at specific data, we can -- we can pull that

 for you.

 SECRETARY BRUCH: Thanks, Allison.

 Yeah, go ahead, Logan.

 BD. MEM. PETREY: Yeah. Hey, thank -- thank you.

 All right, question; why is the loss ratio greater in 
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 organic than in transitional?

 MS. TOLLE: There's more losses. I mean, it's --

 there's --

 BD. MEM. PETREY: I mean, that's -- I didn't know if

 it was the premium you were paying was less, and so the --

 like, for -- because if I was an organic grower, I would say my

 losses are probably higher in transitional than they are in

 organic. we've seen losses -- yield losses less in

 transitional than we have in organic because it does take time

 to really --

 MS. TOLLE: Sure.

 BD. MEM. PETREY: -- get that system to be organic to

 where it is benefiting. And so, I saw the -- the loss was --

was higher, and -- or higher in organic than in transitional, I

 didn't know if that was because of the premium that you're

 paying for that is less, so therefore, it is less on the

 government, but it's probably higher, maybe its higher on the

 grower? I don't --

 MS. TOLLE: So, I think to answer that question,

 you'd have to look more specifically at the crops and the

 locations.

 BD. MEM. PETREY: Um-hum.

 MS. TOLLE: You know, I don't know right off if

 they're grown in the same place? Is it the same weather

 events? Is it more transitional versus organic in certain 
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 areas, and so indemnities are, you know, based on weather

 events? What happened with that weather event? Where?

 BD. MEM. PETREY: Um-hum.

 MS. TOLLE: So, I think you'd have to do a deeper

 dive into the numbers and the crops to see exactly why that is.

 You know, like I said, this is the most challenging

 for us because we hear T-yields are too low. This tells us --

 BD. MEM. PETREY: Right.

 MS. TOLLE: -- the opposite of that.

 BD. MEM. PETREY: Right.

 MS. TOLLE: But we just don't want to rip the carpet

 out from everybody.

 BD. MEM. PETREY: Sure.

 MS. TOLLE: We're trying to figure out what's going

 on.

 BD. MEM. PETREY: Especially with the transitioning

 happening.

 MS. TOLLE: Yes. It's happening.

 BD. MEM. PETREY: Another follow-up question with

 transitional. So, when do you have to identify that is

 transitional? Just stating on when you made a comment that

 knowing in -- in hard times, maybe they didn't put an input and

 they're saying, well, I'm in transition now. So, are -- is

 that when that you're able to say that that it's covered, and

 it's put under this transitional loss ratio? 
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 MS. TOLLE: So --

 BD. MEM. PETREY: Or does it have to be --

 MS. TOLLE: -- by Acreage Reporting date, you have to

 show us that you have -- that you have talked to a certifier,

 and that you --

 BD. MEM. PETREY: Okay.

 MS. TOLLE: -- are in -- in the process of doing

 that.

 When you have a claim, you're going to have to

 provide something from -- and the -- the Integrity Database is

 a place we're hoping we can work with transitional growers,

 specifically, because they don't have an organic systems plan,

 what do they have? And that's what I'm kind of hoping you guys

 can help us with --

 BD. MEM. PETREY: Sure.

 MS. TOLLE: -- what else can we get from them to show

 they're doing that?

 BD. MEM. PETREY: Right. And -- and things like that

 would be, you know, what seed are you planting? Because

 there -- there's, you know, there's quite limitations on that.

 It can't just be an application, not made at the very end, to

 consider a transitional.

 MS. TOLLE: Correct.

 BD. MEM. PETREY: So, okay, great. Thank you.

 SECRETARY BRUCH: Thanks, Logan. 
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 Go ahead, Carolyn.

 MS. DIMITRI: Great. Thank you so much for this

 great, great conversation, Francie. I have two questions.

 The first one is about the new guidance that you are

 developing for crop insurance agents and AIP. I don't -- the

 AIP people. How will you measure the efficacy of those? Like

 will you -- like how do you know they're going to work? Are

 you going to follow up with them? Will you give the agents a

 test to see their organic knowledge? I mean it's great to have

 it, but how do you know that it will be used, and it will be

 helpful?

 MS. TOLLE: So, once we put something in procedure

 it's part of compliance reviews, so we'll be asking them. Can

 some slip through? I mean, anything can slip through anywhere,

 but it will be to their advantage because what's the

 disadvantage of not giving it to the -- the producer?

 We have requirements, not just on these guidelines,

 but different, all types of things that the producer is

 supposed to be provided information. You know, is everything

 perfect? No. But without it, we don't have anything.

 MS. DIMITRI: I don't understand what a compliance

 review is, sorry.

 MS. TOLLE: So, there's -- there's two different

 things when I talk about compliance.

 Number one, RMA has a complete division that is 
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 compliance, so AIPs are pulled for various compliance reviews

 every single year. So, when they go out and look at the

 process from the AIP to the agent to the producer, what

 happened in certain situations, they're reporting back findings

 to the AIP, as well as to RMA, and we will expect them to make

 changes based on anything that was not done according to

 procedure or policy. So, it's a -- it's a complete division

 and RMA is -- just to give you a little bit of idea what our

 agency is -- compliance is about a third of the agency, of the

 490 employees that I talked about, there's about a third of

 them are compliance.

 Third of them are regional offices, and regional

 offices are looking at and talking to people about how things

 are working right now. What's working? What's not working?

 Product management, where I am, is the other third, and we're

 developing or modifying policies. So, product management is

 looking at the future, how are we going to change things?

 Regional offices are looking at what's going on right now, what

 are these T-yields doing? What's plant dates looking like?

 Compliance, hopefully you don't talk to compliance. They're

 going to make sure everything is done correctly.

 MS. DIMITRI: But at the very minimum, you would

 expect to see more organic crop insurance policies? So, I

 mean, like will you look at that data in that particular way?

 Like I don't know how you measure success. 
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 MS. TOLLE: I don't know that that's going to be a

 way to measure success, because that's going to be given to the

 people that --that come in, are looking for organic insurance.

 I -- I guess if you were asking me what's a better

 measurement, it would be to look at our RME partners and the

 money that we're putting out there with different partnerships

 to see if our -- our message is getting out? Is it -- are

 people actually coming in and requesting crop insurance? Is

 the survey in the study, is that moving that needle at all?

 Are people more aware of it? Because one of the biggest things

 that I saw in there was producers aren't familiar with it; how

 do we get them familiar with it? And so those RME

 partnerships, of course, that way. Regional offices that are

 out there talking to different producer groups. But I'm open

 to ideas on what's a better way, but it -- honestly, the

 guidelines are not going to be a good measurement.

 MS. DIMITRI: Okay. Great. Thank you.

 MS. TOLLE: That was a long answer --

 MS. DIMITRI: No --

 MS. TOLLE: -- to the guidelines are not a good

 measurement.

 MS. DIMITRI: No, I mean, it's helpful to know

 because you put something out with an intention, and then like

 how do you know that it is achieving the goal? Because you're

 not doing it just for fun. 
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 MS. TOLLE: No. The intention of the guidelines is

 to make sure everybody fully understands what the requirements

 are to be transitional and organic, and there's not confusion

 out there about that.

 MS. DIMITRI: Great. Thank you.

 Now, I have like a more big picture question. I

 mean, just thinking about climate events are increasing in

 number, like how is your agency positioned to weather that --

 MS. TOLLE: Excuse the very funny joke again.

 MS. DIMITRI: -- going ahead? I mean, I think like

 these problems will become more severe for organic farmers

 and -- and conventional farmers, and I just wonder, do you just

 keep on going and you just take every year as it comes? Or do

 you have this long-range planning?

 MS. TOLLE: I mean, there's different things that

 we -- different practices that we look at, different crops

 that -- are -- are there crops that don't require as much water

 in certain areas, that do we have enough data to provide our

 crop insurance program so that people that can't or don't want

 to use as much water can have an insured crop? Different

 practices that help get into rotation, double cropping for

 example, is that practice available so people can rotate?

 So those are kind of things we look at. We are still

 heavily dependent on data, so it's challenging in some regard.

 We had the Pandemic Cover Crop Program that encourages the use 
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 of cover crops; that was funding for only two years. I know

 there's interest in Congress to do that program again through

 legislation, and -- and maybe they will. That's a way for us

 to collect data to see if different practices are being -- are

 helpful regarding loss ratios, because we don't -- we don't

 have enough information right now.

 So, there's a lot of little pieces going on, but

 not -- there's no snow -- silver bullet, for sure.

 MS. DIMITRI: Okay. Thank you. That is interesting,

 because it's like how do you reduce the variation in production

 through these other practices so you can actually encourage

 that by the way you write policies. Thank you so much.

 SECRETARY BRUCH: Thanks, Carolyn.

 Kim, go ahead.

 BD. MEM. HUSEMAN: Thank you.

 And thank you, Francie, for all of this information.

 My question, you touched on that when you were responding back

 to Logan, I believe, but I know you talked about the Organic

 Integrity Database, but can you also expand just on the RMA and

 the NOP collaboration and that partnership a little bit more?

 MS. TOLLE: So, I guess the best way to explain our

 relationship is just keeping an open dialogue on what each one

 of us are doing.

 Jenny, obviously, has a connection with you guys that

 I don't have. I would not be sitting here if it weren't for 
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 Jenny, probably. So, when we have an issue or we have an

 organic group that comes to talk to us and says we have a

 problem with, transitional was a great example; how can we work

 together to bridge that gap? So, just -- I guess the best way

 to describe it is just keeping in continual contact with each

 other and talking about the issues that are raised. Jenny may

 hear something here that she'll come to us and say, hey, I

 heard whatever; can you help me explain what's going on? Or is

 it a problem? Can we work on it together? So, that

 relationship is very important.

 BD. MEM. HUSEMAN: Thank you. And another follow-up

 to that, maybe a little bit more granular; can you go back to

 the slide that that showed the price levels for corn, I think

 is an example here.

 MS. TOLLE: Yeah.

 BD. MEM. HUSEMAN: And just, you know, as we talk

 about transition being an implementation, is there any thoughts

 around adding in a price factor for transition prices versus

 conventional and organic?

 MS. TOLLE: No. But if you have suggestions or

 thoughts on that, we would be willing to listen.

 BD. MEM. HUSEMAN: All right, thank you.

 MS. TOLLE: Let me -- let me let me ask one more

 question on that. So, what would -- do you have a vision for

 maybe what that would look like or? 
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 BD. MEM. HUSEMAN: No. I -- I don't at the moment.

 I just -- it stemmed based -- I just think that that is another

 gap, as producers have explained, and when we talk about some

 of these pricing models that that's -- I don't today.

 MS. TOLLE: Okay.

 BD. MEM. HUSEMAN: But I -- I think it's just worth

 noting and gives us something more to -- to work on, too, and

 to bring back more information.

 SECRETARY BRUCH: And one thing I do know about

 transition, transition producers can use the contract price

 addendum. So, conventional producers can't use that feature,

 but if you have a contract that's above the RMA price, as a

 transition producer, you can show that and get that stepped-up

 price. So, there's a -- a nice intermediate solution right

 now.

 BD. MEM. HUSEMAN: Okay.

 SECRETARY BRUCH: Okay, we'll go to Nate, Jerry,

 Kyla, then me, and then we'll wrap it up. This has been

 extensive, thank you.

 BD. MEM. LEWIS: One of the issues that organic

 producers struggle with, and it kind of varies from state to

 state, is losses due to pesticide drift, and oftentimes that

 sort of misapplications and they may be out of luck with RMA

 because that's not a weather-related event. But we're also

 seeing increases in trace amounts of pesticides just in the 
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 rainwater and contaminating crops and loss of organic premiums

 due to that through export markets.

 Do you see any sort of avenue through the Quality

 Loss Program? Or some other avenue where we could maybe bridge

 some of those gaps in coverage due to, you know, a loss of

 quality, which results in a loss of organic premium?

 MS. TOLLE: Not at the moment. That is one of the

 hardest things to deal with. And when you talk about -- you're

 talking about pesticide, but just drift in general for

 agriculture across the Board, is one of the most difficult

 things we deal with because, you know, even conventional

 farmers are asking us the exact same question. I've had the

 same issue on my farm.

 BD. MEM. LEWIS: Um-hum.

 MS. TOLLE: Somebody sprays dicamba and -- list. Big

 problem. My beans are dead. You guys are losing your

 certification. The problem is that, you know, it's -- it

 starts man made, and how do I know that Francie didn't spray

 because Nate thought he was going to have some sort of loss and

 he needs, you know -- you're welcome, you get an indemnity.

 You know, most people don't think like that. Most people don't

 do that. But compliance, we find that some people do.

 So, how do we deal with that? You brought something

 interesting, quality. So, when -- with what you just said, is

 it -- are -- are you losing certification or are you losing 
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 quality?

 BD. MEM. LEWIS: Both scenarios occur. And -- and

 depending on what state you're in -- you know, I -- I come from

 Washington State, and we've got robust laws around applicators

 insurance, so if someone misapplies you can usually get a

 indemnity from a --from a, you know, the company's insurance

 provider for loss of that year's crop or up to three years

 losses if you lose certification. But not all states are like

 Washington with -- with something like that. And so, sort of

 thinking about it, I think both scenarios occur, and it -- it

 sort of happens all -- you know, it -- it depends on the

 specific situation. Is it flame retardant from fighting a

 wildfire? That's been an issue in Washington and other states.

 Is it glyphosate in rainwater? Which I know is, in the

 Northern Great Plains, is a major issue for trying to get your

 specialty crop -- specialty grain crops to Europe, those types

 of markets.

 So, it's kind of all across the Board, but I'm just

 trying to explore ways that we can create a national approach

 to it, as opposed to leaving it state-by-state because it's --

 that's not working right now, and kind of a national way to

 address it would be great. And insurance coverage seems to be

 the logical tool, but I also acknowledge what -- the issues you

 bring up around fraud, and -- and the challenges that are --

that are posed there. 
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 So, it sounds like it probably is an act of Congress

 sort of issue at this point to give you all some more leeway in

 creating programs for that?

 MS. TOLLE: Um-hum.

 BD. MEM. LEWIS: But I'm curious what your reaction

 is to that?

 MS. TOLLE: It's a problem. It's a difficult problem

 to solve, and it's something that we've got in a lot of areas

 with a lot of different types of producers, so I appreciate any

 thoughts you can come up with. A national approach would be

 interesting.

 I mean, I'm sitting here thinking, okay, my Oklahoma

 laws are a little bit different than what you just stated, and

 I live right on the Kansas border, and I know those are

 different as well. It's a difficult problem. And I hate to

 say, let's keep thinking about that, but we really need some

 help thinking about that because it's difficult.

 BD. MEM. LEWIS: Fair enough. I appreciate the

 openness to --to the conversation.

 SECRETARY BRUCH: Thanks, Nate.

 Go ahead, Jerry.

 BD. MEM. D'AMORE: I, too, thank you and I, too, will

 plead a little bit of ignorance about the whole broad topic of

 insurance.

 I beg your pardon? 
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 BD. MEM. JOHNSON: Me, too.

 BD. MEM. D'AMORE: Okay. I'm intrigued by the slide

 that has the continental United States shown, if I could see

 that for a second?

 And while you're looking for it, I'm intrigued

 because it's -- it's way too geographically specific not to be

 giving you more information than I think you're getting. So,

 as I look at it, I see perhaps eight geographic clusters, and

 those geographic clusters indicate to me perhaps crop types.

 And so, then the question I have for you is, are there crop

 types that find this program more beneficial to them than

 others?

 MS. TOLLE: That's a good question. And, too, when I

 was looking at this just for this presentation, I pulled the

 NAS data to see where the crops were, regardless of if they're

 insured, and they follow this as well. So, it would be

 interesting maybe in research to overlay those and -- and start

 drawing some conclusions that way, as well.

 I will tell you that conventional farmers, crop

 farmers that go into transitional organic, are the first ones

 to get crop insurance because they're most familiar with it.

 So, when you get into the specialty crops, that's where it

 takes a lot more outreach because they're not familiar with

 crop insurance at all.

 Does that help? 
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 BD. MEM. D'AMORE: It helps a lot. And, you know,

 specialty crops are my wheelhouse, so that's -- yes. Thank you

 very much.

 MS. TOLLE: Okay.

 SECRETARY BRUCH: Go ahead, Kyla.

 MS. SMITH: I just wanted to make a comment, in

 that -- regarding the -- what Logan was asking about, and how

 to verify a producer's tradition -- or transitional claim. And

 so, Jenny, in her presentation yesterday, I believe, had

 mentioned that -- some work that the Accredited Certifiers

 Association did to create a transitional like pre-OSP, if you

 will.

 MS. TOLLE: Yeah.

 MS. SMITH: And so that tool, along with -- there was

 a memo that was sent out to certifiers to utilize the Integrity

 Database, so those tool -- two things together I -- I believe

 should hopefully address the concerns that you were raising

 here about how to actually verify those producers.

 MS. TOLLE: Well, I'm glad to hear you say that,

 because we hope so, too. But I'm also aware that nothing's

 perfect. But we worked with jenny a lot, and that -- the memo

 and everything you just talked about was several months' worth

 of work to try to get to that point, and I hope it does help.

 But also realize there's probably a little more work to do, but

 if you've got feedback regarding that, I sure would like to 
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 hear it.

 MS. SMITH: Great. Thanks.

 SECRETARY BRUCH: Thanks, Kyla.

 Okay, I have one last question, and then we'll wrap

 this session up. Thank you so much for entertaining all our

 questions. Mine is on quality, and I'll try to keep it not

 down into the weeds, because I can get there pretty fast.

 But I do think -- I love that we're considering

 organic by practice for the -- or enterprise units versus

 operational so folks aren't aggregating mixed production

 operations. I think that will be a big win for organic

 producers.

 But one next, I think, stone to kind of look at would

 be the quality issue. We kind of talked corn in some of the

 examples. Right now, there are standards for loss adjusting in

 quality, but it doesn't necessarily kick into Grade 4 or 5

 which, is all looking at feed-grade type conventional

 counterparts. So, I think, you know, a lot of our -- why we

 get contracts is because we deliver a Grade 1 or a Grade 2 type

 quality, so I think if there could be an additional factor with

 the contract price addendum to include a quality metric, as

 well, so that -- so it matches our contract essentially, I

 think would be super helpful. Because otherwise, we could get

 in a situation, and I have several times with blue corn, where

 I don't have a feed-grade outlet for blue corn, so if I don't 
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 hit my contract spec of Grade 1 due to a hailstorm, I'm still

 going to be above the Grade 4, so I don't get any quality

 compensation either on my crop insurance.

 So, there's kind of this purgatory zone, I guess,

 between Grade 4 is where the level starts kicking in for

 quality. So, sorry, more of --

 MS. TOLLE: Yeah.

 SECRETARY BRUCH: -- a comment or a -- an additional

 point --

 MS. TOLLE: No, you're right.

 SECRETARY BRUCH: -- but I -- but I think it -- it

 could also impact conventional producers, and I've talked to

 the corn -- Corn Board about this, about trying to rally in a

 broader type of audience because I know there's conventional

 producers that are also growing food-grade type corn, and they

 would be in a situation that's very similar, where there's just

 a -- a little bit of a purgatory zone between the quality kick-

 in standard.

 MS. TOLLE: So, specifically for food quality or

 organics, I think what we -- what we'd be looking for is what

 are those quality levels that we could set in the policy?

 For example, for conventional -- most -- most

 commodities, just let me generally say have discount factors,

 and producers don't agree with those, and we have a contracted

 study right now to look at that. That factor is a national 
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 factor, and really it should be more probably regional, and so

 the contract that we're looking at is how far can we bring it

 down to the local level? Because everybody knows when there's

 a weather event, then warehouses or delivery points start

 making different -- they don't want the -- yeah, the quality

 changes, and so it doesn't fit our national quality.

 And, you know, a long time ago, we had whatever the

 producer got for quality, you know, if it was below, that's

 what we would pay quality on. Well, then we had elevators

 start listing at insurance price and a non-insurance price;

 that doesn't work so well, either, and so there's a big balance

 between where do we get the quality standards? And so, we are

 looking at that -- that contract for our national quality

 factors now. But you're bringing in a whole other area, which

 we do need to look at. I don't know where we get those quality

 factors.

 And if anybody here can help with that, that would be

 great, because that's a big issue. And it's not the same for

 everyone, like you just mentioned. So, if you've got ideas,

 we're willing to listen.

 SECRETARY BRUCH: Well, thank you for your extended

 time during this session, and just your willingness to -- to be

 flexible and work with us.

 I think next steps from our Subcommittee working on

 crop insurance is trying to find solutions or ideas that could 
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 be wins for farmers, but also wins for Risk Management Agency,

 so it's mutually beneficial, I guess, in the long run. But I

 really appreciate your outlook, and philosophy, and time, and

 we'll continue the discussions then. Thank you.

 (Applause.)

 SECRETARY BRUCH: Okay, why don't we take a quick 15-

 minute break, and then we're going to dive into our CACS

 agenda. We have four topics to discuss when we come back from

 the break. Thank you.

 (Whereupon, a brief recess was taken.)

 CHAIR POWELL-PALM: All right, folks, my fellow

 NOSB'ers, please take your seats. We're going to get going

 again. We're still going to break for lunch at 12:45, but

 we're going in a -- in the best way -- we're never running

 behind on this board, we're exactly where we should be, but

 were going to have to make up some time, so were going to try

 to be brief in our comments.

 I'm sorry, Francie, for having missed the Q&A because

 it sounds great. Thank you again for being here. Really

 appreciate this. It's huge for our communities. We'll hear

 from you.

 I'm going to hand it over to Carolyn to kick off the

 Discussion Document: Oversight Improvements to Deter Fraud --

oh, I apologize, Discussion Document: Organic and Climate-Smart

 Agriculture: Climate Induced Farming Risk and Crop Insurance. 
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 Floor is yours.

 MS. DIMITRI: Okay, great. I want to tell everyone

 I'm brain dead. I feel full of crop insurance information, and

 I think that we covered a lot of the information already in

 the -- Francie's talk and then the Q&A, so I'm going to be

 super brief here.

 And I guess maybe what I would like to just jump into

 and hopefully people are okay, with this is maybe to talk about

 the next steps for this document, and where we want to go from

 here.

 I think we've heard RMA had -- is making some

 changes. RMA identified -- Francie identified a couple of

 places where she wanted more information. I made a note of two

 of them, and most of them have to do with specific evidence to

 back up some of our general statements about discrepancies. I

 can't find them here in my notes, but I'm sure -- I'm sure I

 have them and I will listen to the transcript.

 So, I -- Amy, are you okay with turning this over to

 a what -- where do we go from here with this document?

 SECRETARY BRUCH: Yeah, absolutely.

 MS. DIMITRI: Okay. So everyone, where do you think

 we should go from here with this document?

 CHAIR POWELL-PALM: Questions for Carolyn?

 MS. DIMITRI: I have my -- I -- I'm just curious what

 people --what people think are some good next steps? 
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 UNIDENTIFIED SPEAKER: (Indiscernible).

 MS. DIMITRI: Yeah. Well, why answer a question if

 someone else can do it for you?

 CHAIR POWELL-PALM: Allison, please go ahead.

 BD. MEM. JOHNSON: If it was law school, you would

 have just cold-called on me so, I appreciate this venue.

 MS. TOLLE: That's right.

 MEM. JOHNSON: I heard a few areas that Francie named

 that RMA is really wrestling with where there are opportunities

 to serve organic producers more effectively, and to me that's a

 good place to focus our attention.

 One area that stood out is how to demonstrate that a

 producer is in transition in a way that provides some assurance

 against fraud, but also isn't cumbersome for transitioning

 producers or beyond the requirements under OFA. So, it sounds

 like some sort of interaction with the certifier is what RMA is

 looking for now. There may also be transitioning producers who

 haven't yet started that relationship but may be participating

 in the TOPP program in some capacity. Or Logan mentioned

 buying organic compliant seed. Things like that might be other

 factors that we could look to, so starting to gather up some of

 those options and -- and present suggestions to the RMA I think

 is one place to focus.

 Another, oh, was I appreciated Francie's openness to

 feedback, and I was sort of thinking through on the break how 
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 can we make that really accessible to producers, helping them

 with what's there, so suggesting that there be some sort of, I

 don't know, clearing house or one point of contact where

 producers who are encountering specific challenges, say with

 NRCS and RMA requirements coming into conflict or not having

 access to the crop insurance options that they need, if there

 is one place for them to go, that might be a -- a

 simplification or a -- a streamlining way where we can start to

 address some of the challenges that are coming up. So, those

 are the first things that came to mind for me.

 MS. DIMITRI: Great. Thank you.

 CHAIR POWELL-PALM: Nate.

 BD. MEM. LEWIS: Oh, I can imagine that crop

 insurance will continue to have challenges for producers.

 We're not going to sort of clear it all up with this one

 document, so perhaps laying some -- some foundations for future

 boards to replicate this effort and continue the conversation

 with RMA. I think we function as a good clearinghouse for both

 hearing from RMA about areas you're interested in addressing,

 and also from producers and sort of synthesizing that

 conversation. So, if we can set up future boards for success

 in this conversation, that would be really helpful.

 DIMITRI: Great. Thank you.

 SECRETARY BRUCH: Yeah, I think it was awesome and

 wonderful to hear on some of the improvements that are up and 
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 coming, such as organic by practice, looking at enterprise

 units versus operational. We've heard a lot of feedback from

 our producers through written comments, oral comments on that

 particular issue, which is really just invigorating to know

 that, you know, we can find solutions to some of these

 challenges.

 So, on the short list -- the short, aggregated list

 that we have heard from producers and articulated in the

 document, I'd like to see if we could advance some of those

 items a little bit further, stress test them to -- to push the

 community for some solutions that could advance even more of

 the challenges to a solution-oriented outcome.

 So, that's -- and I think we labeled maybe five or

 six of them, so maybe we can pick a couple of them and at least

 make some progress on those. That would be amazing.

 MS. DIMITRI: Great. Excellent.

 CHAIR POWELL-PALM: I apologize for having missed the

 conversation, but I think that something that still sits top of

 mind for me, is how we can be more organized in getting data

 sets to RMA and having producers start growing crops now that

 they might want to ensure in the future and figuring out how to

 do that in a more organized way. So, as a question to the

 community, figuring out if there's any existing infrastructure

 to try to leverage it. Land grant institutions, growing crops,

 figuring out how we sign producers up to grow crops, so that 
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 that data set can start being established sooner, rather than

 later.

 MS. DIMITRI: Is it -- can I ask a follow-up question

 about that to Francie?

 CHAIR POWELL-PALM: Sure.

 MS. DIMITRI: Do you mind another question?

 Like, I guess one question I have for you, is like

 what kind of data? Like do you need to have federally

 collected data? Or like what kind of data would be

 statistically representative enough for your purposes?

 MS. TOLLE: So, if it was university data, and there

 were producers signed up, as you mentioned, and like I said the

 more the producers the better but, you know, if you had 10 to

 15 producers growing across several counties, or at least a

 couple of counties and multiple years, three, six is better,

 that type of data. And again, too, you know, even with that if

 you identify proxy crops, as I mentioned, we try to work with

 those as well to bring in additional data that's going to be

 similar.

 So, there's not a hard and fast rule to what that

 data looks like, but it doesn't need to be federal; it's the

 university types' information. Just well documented,

 producers' own production. You know, if -- if let's say you

 have a delivery point that's bringing in a certain crop and

 that delivery point can reach out to all those producers and 
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 ask -- and get their actual production and their acres, that's

 great.

 MS. DIMITRI: Oh, cool. Great. Thank you.

 CHAIR POWELL-PALM: That's a fantastic idea. I

 didn't know that was really -- yeah. I hadn't thought about

 the logistics of enrolling buyers to say who are you buying

 from? Let's get them -- get their data. That's awesome.

 Thank you.

 Other questions for Carolyn? Or ideas?

 (No response.)

 CHAIR POWELL-PALM: All right, well, I think we have

 some marching orders. Thank you, Carolyn, for the work on

 this.

 MS. DIMITRI: Of course. Thank you, everyone, for

 all your contributions.

 CHAIR POWELL-PALM: I hand it back to Amy Bruch,

 Chair of CACS.

 SECRETARY BRUCH: All right, thank you, I. Good to

 have you back.

 I, we're going to turn to you next. You've worked on

 some important -- or you worked on another important topic

 about transition, and I'd love for you to walk us through the

 discussion document. Thank you.

 BD. MEM. JOHNSON: Yeah, thank you. Given where we

 are on time, I had jotted down a bunch of notes summarizing 
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 public comments that will make it kind of long, or we could go

 straight into kind of everyone talking about what jumped out to

 you in -- in comments, and in the discussion.

 Do you want to go there and then I can kind of fill

 in gaps at the end if there's anything that we haven't touched

 on?

 CHAIR POWELL-PALM: I think that's a great idea.

 SECRETARY BRUCH: Yeah, that --

 BD. MEM. JOHNSON: Okay.

 SECRETARY BRUCH: That sounds good.

 BD. MEM. JOHNSON: Okay, well, well thanks for making

 this part of our -- our work agenda. This is a discussion

 document called "Improving Support for Organic Transition."

 And to me, organic transition means bringing more land under

 organic management, which has significant benefits for human

 and environmental health, as well as economic opportunities

 attached to it. And I really appreciate the attention that

 organic transition, and the Transition to Organic Partnership

 Program network has received throughout this meeting. It's

 really exciting to see so much already in motion, and how much

 we've been able to build quickly on the years of groundwork

 that had already been laid.

 So, the discussion document outlines the growth and

 attention to organic transition that we've seen in recent

 years, including USDA's unprecedented $300 million investment 
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 in the Organic Transition Initiative. I think everyone's

 familiar with this at this point, but I'll just reiterate; that

 initiative has three pillars.

 The first is funding to build a transition support

 network with organic certifiers in the lead. So, that's the

 TOPP Program that we've been hearing about this week.

 There's direct funding for farmers via an organic

 practice standard for conservation programs, and the crop

 insurance discount that we heard about this morning.

 And then there are market development grants that are

 really aimed at rounding out the supply chain, and building

 markets in specific areas that have a lot of potential for

 growth.

 So, the discussion document also notes that despite

 significant growth in organic, the sector is still relatively

 small, and that's in part due to barriers to transition. And

 it also names the heightened challenges that producers of color

 may face in participating in the organic sector.

 So, we as the NOSB, have a really unique ability to

 gather feedback from the community, from the organic sector,

 from the public, and distill that feedback to USDA to continue

 to improve upon what's already in motion through the Organic

 Transition Initiative, and look at what might else -- what else

 might be added, and what might come next in the future.

 So, we asked our community to answer kind of five 
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 categories of questions related to organic transition. We

 looked for specific feedback on the Organic Transition

 Initiative; specific feedback on the transition process and

 work -- what works well, what has been tried; the relationship

 between inputs and organic transition; strategies for long-term

 retention of organic producers; and how we can expand

 diversity, equity, and inclusion in organic.

 We've received a really impressive group of

 thoughtful public comments that ranged from high-level, big

 picture to really granular suggestions. I'm grateful to

 everyone in the room and online and who engaged in writing and

 through public comments to share your ideas. I was really

 impressed and honestly overwhelmed by the -- the quantity of

 feedback that we got. And the quality.

 So, I'll -- I'll name four categories that stood out

 to me, and I've jotted down some potential recommendations that

 we could make to USDA, but first, let's have a discussion and

 sort of get everyone's responses to the feedback that we got.

 So, the -- the high-level categories are: the role of

 consumer demand -- consumers demand and pricing; reducing the

 cost of certification; the role of relationships and trust --

I'm calling this "Money is time," and getting out of our

 existing circles, were sort of themes and -- and categories on

 the feedback that we received.

 So, with that, I'd love to hear what stood out to you 
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 all and what you think we might be able to recommend to USDA?

 CHAIR POWELL-PALM: Questions or comments for Allison

 on this document? Nate.

 BD. MEM. LEWIS: One of the areas that has come out

 to me was based on my participation in Organic Trade

 Association's "Ask Me Anything" series, was just around again

 back to language and what we use, but particularly when folks

 are asking questions of certifiers, there's a, I think, a

 reticence to share specific information due to the need to not

 assist producers in overcoming barriers to certification. And

 so, there may be --there may be a way to moderate that pendulum

 through some clarity around what does the program think is an

 accreditation violation in that regard and what is not. And so

 that certifiers, when -- I mean, the specific question was "How

 big does my buffer need to be?" and a certifier provided, you

 know -- I can understand why a vague answer that didn't help

 the producer figure out what they needed to do to get into

 organic. And so, if we could perhaps provide a recommendation

 around what we think the line is between an accreditation

 violation and technical assistance, which I also am trying to

 remove from my lexicon, that could be a very concrete way to

 get certifiers to develop that rapport with aspiring young

 farmers.

 CHAIR POWELL-PALM: Other ideas or questions? Amy,

 please. 
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 SECRETARY BRUCH: A couple -- thank you, Allison, for

 all your work. You really take this topic to heart, and it

 really shows. Appreciate your passion.

 I guess, a couple of things that really stood out to

 me was the commitment from the community. We heard from one

 organization that has a transition plan, they actually provide

 supplemental income in terms of price increase, price premium

 for transition producers. There isn't essentially an official

 transition market; there's some opportunities, they're hard to

 find but some companies are willing to invest in organic -- or

 in transition producers because ultimately, they want to work

 with them when they're organic. So, I think we need to build

 that pipeline.

 We're not instantly organic; it takes 36 months past

 the last restricted use pesticide. So, kind of coupling and

 walking with that producer the whole way is really important.

 And then retention is also something that we heard

 through public comments, and also just through stories the past

 few days, so looking at retention. Once we get these producers

 transitioned and officially organic, we need to solve some of

 the challenges that current organic producers are facing, also.

 And those are, again, with markets.

 And also, I just think looking at maintaining

 integrity and making sure we're upholding all of the rules.

 Thanks, Allison. 
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 CHAIR POWELL-PALM: I think echoing Nate Lewis's

 comment about how do we try to be more helpful; I see a world

 where organic inspectors cut their teeth with a few hundred,

 maybe a few thousand inspections, even, and then move over to

 being consultants and really just put their -- put their --

 rather, you know, hang their hat out there for saying I know

 exactly what it is that you need to be certified organic, let

 me do the work for you. And I think we need an army of those

 folks. I liken it to literacy campaigns in different countries

 where it's you find a 17-year-old who can read, and you show

 them a little bit how to teach reading, and then you send them

 out to spread literacy, and I think we could use a really

 similar strategy in organics, figuring out how do we get those

 who know what all of these technical terms mean, and -- and

 have made it their bread and butter, to go out and make it easy

 for farmers to farm and not worry about becoming regulatory

 experts, as well.

 Carolyn, please go ahead.

 MS. DIMITRI: Just to follow up on your comment,

 Nate. You triggered something in my mind that through my

 research I found that farmers that are in transition, the

 inspector is almost always the primary source of information,

 and they would never make that hurdle without having the

 inspector, which -- but based upon what you were saying, is it

 true that the inspector's not allowed to actually give 
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 technical assistance? I'm a little confused --

 CHAIR POWELL-PALM: Oh, sure. Great question.

 Thanks for that. So, the inspector's not allowed to help them

 overcome barriers to certification. If it's publicly available

 information, it's completely within bounds to provide that to

 them. But usually, it's a question of like how should I fill

 out this form, and that would be helping them overcome a

 barrier to certification, which the inspector can't do. So,

 being able to remove that division between what is technical

 assistance and what is consulting, which we take very seriously

 in organic inspecting, is get -- I would say the next step for

 how we get folks to be able to have no barriers in what they

 can help them with.

 Allison, and then Kyla.

 BD. MEM. JOHNSON: Yeah. I really appreciate that

 point, Carolyn and Nate and Nate.

 I'll unpack the "Money is time" category because I

 think it -- it touches on both of the things that you raised.

 I was reflecting on it on this yesterday as several

 of the TOPP partners mentioned that the TOPP funding has given

 them capacity to reach more of their state and spend more time

 with producers, and the -- one of the themes that came up in

 comments and throughout this rollout of TOPP, is that one-onone time or just time directly speaking with someone to walk

 them through the process makes a huge difference. 
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 We had one comment that someone who had gone through

 a training on certification was much more likely to succeed in

 their application for certification, be successful in entering

 the program. Just that one intervention made a huge

 difference. So, finding more ways to make people available to

 producers in different places, finding them where they are was

 one of the -- the comments that came up from the Black Farmers

 Index yesterday, is -- is a really accessible intervention

 and -- and literally just providing money to people to be able

 to do that in a lot of different venues could have a big

 impact.

 CHAIR POWELL-PALM: Wood. Just -- I'm sorry, hold on

 Wood. Kyla.

 MS. SMITH: You skipped me.

 Yeah, Allison, you made one of the points I was going

 to make, that was something that really stood out to me, was

 meeting folks where they are, and then using trusted agencies.

 And some certifiers do have like education and outreach arms,

 as a part of their organization, but several don't and we're

 busy doing the rule following verification, and -- and don't

 have the time and the resources to get out to meet producers

 where they are. So, I think that's a very huge component.

 The other thing that I have been thinking about,

 and -- is with the mentorship piece of -- that's going on with

 TOPP, is bringing in components not related necessarily to 
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 organic production practices, but just like business plans and

 things that -- record keeping, and just things that are not as

 fun but make producers successful.

 CHAIR POWELL-PALM: Wood, please go ahead.

 BD. MEM. TURNER: I was just thinking about the

 comment you made about consulting, and I was wondering, you

 know, there's some discussion about whether the barrier to

 certification, the cost of certification is a barrier, and

 I'm -- I worry about the -- the barrier that consulting costs

 could have, as well. And I'm -- I'm just thinking about it in

 the context of the comment you just made about mentorship, is

 also really interesting because I think that's -- that's --

that means -- that's important, but I also think the network

 effect of sort of building communities of organic growers.

 I mean, you know, your example in Montana is a great

 one. I mean, what's better than having people -- like having

 the -- the program help get groups of growers together to

 share -- to share ideas, and to share some of these issues, as

 opposed to sort of putting a burden to necessarily or expecting

 that someone's going to take on the mentoring role and -- and

 help someone shepherd through the process.

 So, it's interesting. I don't know if you have a

 thought on that, but --

 CHAIR POWELL-PALM: Oh, boy, do I. I don't know if

 you heard about this little program called Transition to 
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 Organic Partnerships [sic], but TOPP actually does exactly

 that; it goes and it pays farmers to be mentors for new

 farmers. And so, if you're an experienced organic farmer who

 is busy, but for, you know, signing up for 40 hours of

 question-asking by a mentee, they're going to provide a stipend

 to actually facilitate that relationship. And I think that's

 kind of the step forward I see. Best advice is farmer-to-

 farmer learning. I think that there's, you know, the -- the

 technical side of filling out an OSP; an inspector with very

 little farming experience, but who knows the rule, can

 definitely do that, but I imagine hearing from every single one

 of the NOFAs yesterday, if they had someone on their own staff,

 who is just your farmer hotline, how do I fill out my manure

 application record, that sort of thing I think is very, very

 much implementable without a ton of farming experience. But I

 think the -- the barrier to -- to the cost of it is very, very

 important.

 Franklin, then Kyla. Oh, sorry, yeah, Franklin.

 BD. MEM. QUARCOO: Okay, so normally when you go to

 somebody who you're talking to, to get into organic farming,

 you talk about the environment, you talk about human health.

 If they ask you what do the financials look like, how do you --

 what's the best method of answering that question? Giving some

 of the feedback, some farmers give about how much money are

 they making or not making in organic farming. So, how do you 
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 answer the question? You deal with the environment, it is good

 for our health, is good -- but at the end of the day they are

 in farming as a business, so how do you handle that question on

 the financials? I have a follow up comment, but this will be

 the first.

 CHAIR POWELL-PALM: I'll start that -- start off, and

 then I'll kick it over to you, Amy.

 I think that's been sort of -- when we had Under

 Secretary Lester Moffitt over at our farm a couple of weeks

 ago, and we were hearing from farmers, I was trying to capture

 what is that special sauce going on in Montana that makes it so

 we have such a growing, thriving organic community, and someone

 put out that we just don't hold our cards very close to our

 chest. That when someone asks what price are you getting for

 wheat, it's immediately on the table and who your buyer is, is

 immediately on the table. And that's been the -- what I think

 has catalyzed such growth in the industry. And partly that's,

 you know, a community that trusts each other, and that trust is

 put forth as -- as the sort of the most important part of -- of

 building out an organization.

 I would say though, too, smallholders, and folks who

 are going direct to consumers, really understanding how you can

 cooperate and how you don't have to see it as competition,

 either through formal cooperation -- cooperatives, but also

 through giving real numbers to trusted advisors, like land 
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 grant institutions, who are building out business models or

 profitability analyses. But I think bringing in as many of

 those, if there are commodity contracts, bringing in any of

 those real numbers and then the real cost of production is just

 essential to being able to set a farmer up for success without

 starry-eyed or underselling the numbers.

 Anything to add to that, Amy?

 SECRETARY BRUCH: No. I just reiterate the

 transparency. I think that was one thing that was really

 refreshing when I started transitioning into organic. I didn't

 know any organic producers in my area. I went to the OID

 because this was pre-TOPP, and fortunately I went to the OID.

 I could-called a farmer on that list, and we're friends to --

 to this day. He helped me out. He spent 30 minutes on the

 phone with me and helped me through things. But I think it's

 important to have that network, both formalized, informally as

 well, because there's so many entrepreneurial things that you

 face in organic production that you don't necessarily face in

 conventional production, because there's more checks and

 balances in place, so the transparency, like maintenance and

 with contracts and talking to folks, is really important

 because contract negotiation is something organic producers do

 more of than a conventional producer, because we do not have

 the CBOT, and things aren't as transparent, so we need to rely

 on each other to just kind of form a tighter network. 
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 CHAIR POWELL-PALM: Carolyn.

 MS. DIMITRI: I guess also the research shows that

 you need to make a -- a premium for your organic product if

 you're going to be more profitable as an organic producer, and

 I think this is where transparency becomes really important

 because if people are open about their prices, then you can't

 really pit farmer against farmer. But it also shows why

 regions, like the southeast of the U.S., it's really hard for a

 certified organic farmer to remain in business as a certified

 organic operation because there is no price premium. Speaking

 on average.

 CHAIR POWELL-PALM: Um-hum. Jerry, then Allison.

 BD. MEM. D'AMORE: Thanks. I'm glad you put me in

 right there because I'd like to get -- come right behind

 Carolyn with my one thought. I spent about six years of my

 life, from 2000 to 2006, trying to find an appropriate and

 profitable home between conventional and organic for that --

 thing we called transition back then, as well. And I -- I

 found zero path in six years where it would -- would -- that

 led to a -- any type of premium above conventional, which is,

 you know, I guess would be the measurement, it didn't occur.

 The -- at that point, the -- the consumer had enough already on

 their plate just to go back and forth between conventional

 and -- and organic, and I would have to -- I would have to

 believe that today there's even more visuals for -- for the 
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 consumer to consider, and I, for the life of me, I -- I don't

 know, short of a government subsidy, how that could be

 accomplished. Thank you.

 CHAIR POWELL-PALM: Allison.

 BD. MEM. JOHNSON: Thank you, Jerry. We need a

 government subsidy. This is going to be my point.

 CHAIR POWELL-PALM: Yes.

 BD. MEM. JOHNSON: The -- the point that -- I think

 it was Spencer in West Virginia made yesterday, about not

 having a consumer base nearby who can afford an organic premium

 is something that I think we have to examine really carefully

 because nobody should have to pay more than they can afford to

 have healthy, safe food in their communities. And so, we have

 to find a way to bridge that gap between ensuring that everyone

 in the supply chain is paid fairly, and that this food is

 affordable and accessible everywhere. So, thinking about

 costs, we already have the Organic Certification Cost Share

 Program, but the reimbursement levels haven't been updated in a

 decade and a half. It's not keeping up with costs.

 We did some analysis of the 2018 Farm Bill, and that

 was a $428 billion piece of legislation; 1/10 of 1 percent was

 dedicated to organic. So, it's not a matter of organic

 producers looking for a leg up, or some special treatment, we

 just need to get to even equitable treatment and ensure that we

 have mechanisms to pay producers for the public benefits that 
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 they're providing. So, I think we need to get creative in --

 in looking at things, in addition to market mechanisms, to get

 there.

 CHAIR POWELL-PALM: Franklin.

 BD. MEM. QUARCOO: This is just a comment. Another

 thing I've noticed is that a number of their seasoned extension

 agents whilst we wait for inspectors, then consultants to come

 into some of these areas, the people that their farmers are

 most comfortable with, who they meet with constantly at a

 county extension agent, and a number of the seasoned agents who

 were conventionally trained have never received any training in

 organic agriculture.

 When they get questions from farmers, some of them

 don't have the information because they've not been trained.

 So, there has to be some retraining of existing seasoned very

 good extension professionals, but who lack knowledge in organic

 agriculture, because the first discussions are going to happen

 between the farmers and those folks and if they say don't do

 it, then we don't get to -- because there's a high level of

 trust between the extension agents and from -- and if the

 extension agent doesn't know enough and is uncomfortable

 promoting that, and cannot answer some basic questions on that,

 that -- that becomes a problem.

 CHAIR POWELL-PALM: Completely agree. Yeah. I would

 say it's a dream of mine that one day every FSA agent and every 
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 county extension agent will have taken the IOIA basic course,

 and we can then have, as you said, those trusted advisers say

 with authority I know what organic is, and I know how I can be

 helpful. I think it would be just great, but on our To-Do

 List.

 Dilip.

 BD. MEM. NANDWANI: Very quick comment on what you

 just mentioned, and that's why again I reiterate, we have this

 TOPP Program, and that we have the technical assistance in a

 lot of our universities and educational institutes -- like you

 are also involved, I'm involved, and some other universities --

 where they provide training of trainers and they go to these

 counties and train extension agents, and they can train again

 to further their counties, and up including the farmers. Thank

 you.

 CHAIR POWELL-PALM: Love that idea.

 I think one bucket you had mentioned, Allison, is how

 do we meet folks where they're at? And I just wanted to give

 again a shout out to New Hampshire yesterday, who said they got

 Farm Bureau to show up and be one of their -- their partners,

 because I think that's sort of the inroads that we really have

 to be thinking about, is how do we get these trusted, very, you

 know, storied organizations that advocate on behalf of farmers

 to see organic as an asset and to be helpful towards it.

 So, I think the more Farm Bureau folks we can invite 
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 to these meetings, the more successful we're being.

 BD. MEM. JOHNSON: And picking up on one of the

 points that you made earlier, Nate, and adding to what you just

 said, paying mentors is really important, but also finding ways

 to pay mentees and pay people for their time to consider

 organic as an option. Stipends to attend trainings.

 Scholarships to come to our meetings here and meet all of us.

 It's a hard position to be in, especially for beginning

 farmers, for producers of color, for people who maybe don't see

 themselves in this community yet, and so making sure that

 they're compensated and have the opportunity to give it due

 consideration is one of the ways that we can start to invite

 people in.

 CHAIR POWELL-PALM: Franklin.

 BD. MEM. QUARCOO: Unless I'm mistaken, TOPP is

 giving a little bit of financial incentive to mentees, as well.

 Yes.

 CHAIR POWELL-PALM: Both mentors and mentees, um-hmm.

 All right, I hand it back to you, Allison.

 BD. MEM. JOHNSON: All right, this is really helpful.

 Thank you all. I will attempt to make some sort of sense of

 all of this great feedback, and the feedback that we got in

 public comments, and I hope we can come forward with a proposal

 that makes some recommendations to USDA on continuing to

 implement the Organic Transition Initiative, and what else we 
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 might want to see in the mix moving forward to continue to

 support transition. Thank you.

 CHAIR POWELL-PALM: All right, thank you.

 Madam Chair. 

 SECRETARY BRUCH: Okay, next -- thank you, Allison,

 for all your work on that. Really appreciate that.

 SECRETARY BRUCH: Next up, we're going to start

 document -- a discussion document on -- and it's in the

 "Oversight to Deter Fraud" series, "Residue Testing for a

 Global Supply Chain," and this was a collaborative effort

 between Nate Lewis, Nate Powell-Palm, Kim, and myself, and we

 have a PowerPoint that we'll show you. I'll begin that, and

 then I'll turn it over to Nate Lewis. And also, for both

 Oversight to Deter Fraud PowerPoints, please enjoy the pictures

 from our board; some of these are from our farms, so that will

 be in the background.

 CHAIR POWELL-PALM: Yeah, for the A/V team, is it

 possible to get the screen going, as well?

 SECRETARY BRUCH: We can do it this way. We can't

 see.

 CHAIR POWELL-PALM: It's okay. We'll just wait.

 We'll just wait a second, folks.

 (Pause.)

 SECRETARY BRUCH: Oh, thank you. Appreciate that.

 All right, residue testing background. We're -- the 
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 organic program, as we've heard, is no longer a niche. We're

 nearly a $70 billion business. We've grown considerably over

 the last couple of decades. The strengthening of organic

 enforcement rule, that's an implementation currently that we

 heard a lot about yesterday from Jenny, it's going to increase

 supply chain traceability, which is really, really important.

 It was brought to us by the 2018 Farm Bill. Oversight globally

 is also going to increase. And this requires operations

 importing products to ensure shipments have high integrity,

 meaning no prohibited substances, no ionization radiation. And

 that really brings us to potentially an encore, and that's what

 we're going to be talking about today; compliance certification

 via testing, and that's through residue testing.

 So, the idea with this discussion document is really

 to essentially build on top of supply chain supply -- supply

 chain traceability to have the verification step, as well. And

 verification really into our regulations. Compliance

 verification in our regulations. And it -- and it is an

 essential tool, and we have listed in several points of the

 regulations and our guidelines where this document -- where the

 origins of this document take place. And it's also

 complementary to the finalized organic periodic residue testing

 rule that occurred in 2013. That provided us with a minimum of

 5 percent of organic operations to be tested -- tested per

 year. 
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 And just a little bit more on the background and 

 jurisdiction of why this -- why are -- we were working on this,

 is EMS has legal responsibility to ensure NOP has adequate

 regulatory standards, enforcement guidelines, and residue

 testing procedures. And also, through OFA the NOSB has

 authority to work on residue testing.

 BD. MEM. LEWIS: So, the discussion document proposes

 a set of -- a framework and sort of via the -- via a set of

 questions on how to evaluate different -- different testing

 protocols for prohibited substances. They're focused on

 testing being a tool for verification that folks are following

 the rules, and so we want to make sure that the -- the message

 is loud and clear that we understand organic is a process-based

 standard, and that testing is not a substitute for following

 all the rules.

 We want to leverage federal oversight over prohibited

 substances when it's possible, so we currently reference EPA

 tolerances and FDA action levels for pesticides. We want to

 look at what other federal programs that are in charge of

 hazards and contaminants can be leveraged so that organic can

 remain a leader in products free of prohibited substances.

 We need to make sure any testing we propose is

 following what is in the regulations, which requires it to be a

 AOAC, I don't know that acronym, but it's a -- a accreditation

 for laboratories, so that we meet that that requirement in the 
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 current regulations. So, we want to make sure any tests that

 we bring forward are reliable, quantifiable, and widely

 accepted.

 And then we need to make sure that there's adequate

 guidance in terms of responding to positive results.

 A quick summary of the public comments. We heard

 loud and clear, as I mentioned, organic is process-based, not

 testing-based, and it is -- that testing is not a substitute

 for onsite compliance verification -- I'll give myself some

 candy -- contamination, mislabeling, and the 36-month land

 eligibility requirement are all parts of -- of that.

 We heard about the need to update the NOP handbook on

 expanding and increasing the utility of the prohibited

 substances list. I really like that idea. The next slide has

 some -- some thoughts around where we might push that out.

 And then expanding the response to positive results,

 particularly when there isn't an EPA tolerance or FDA action

 level for that substance or crop.

 And then some comments around revisiting the USDA

 organic regulations, so is there an opportunity in -- in

 providing some support to certifiers to share that -- the

 testing cost burden? How do we leverage the exclusion from

 organic markets reference to give certifiers more swift tools

 to respond to positive results?

 And then we heard about the need to figure out some 
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 way to compile test results so that we can anticipate where

 fraud is occurring, or where contamination concerns are

 greatest, as -- as opposed to react to them piecemeal or one by

 one.

 Okay, some next steps and some thoughts. Clarifying

 the testings -- clarifying testing's role in organic. I would

 love for the Board to consider a resolution at the spring,

 around just organic is process-based, testing is not a

 substitute for inspections and systems plans, but it is a tool,

 and so I'm sort of excited to see where that may -- may land.

 As I mentioned, there's -- we're seeing a need to

 propose updates to the NOP guidance on residue testing, so

 particularly around the list of prohibited substances and

 responding to positive results. And then consider proposing

 revisions to the organic regulations in the areas I've already

 mentioned.

 So, sort of a three-pronged approach: understanding

 that a resolution is something that we can do sort of one-off,

 and it's more of a statement to the community. Guidance, I'd

 be interested to hear from the program around how they look at

 the different burden they would incur in updating guidance

 versus regulation, so the guidance I imagine is a little bit of

 a lighter lift than a regulatory change, but just walking into

 this eyes wide open; that guidance is important, and maybe a

 lighter lift than the -- the regulation update, but we want to 
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 approach both of those topics.

 And I think -- is that all we have? The whole

 presentation's a problem? I know, the whole -- yeah. I mean,

 I'm going to -- yeah.

 SECRETARY BRUCH: Maybe you planned that.

 BD. MEM. LEWIS: So, I'll turn it back over to you,

 Amy.

 SECRETARY BRUCH: Yeah, thank you for finishing that

 up.

 All right, we want to just turn over to the committee

 and the full board for discussion, either with our public

 comments' summary, or maybe there's some additions you'd like

 to bring forth or any comments on our next steps. Go ahead,

 Dilip.

 BD. MEM. NANDWANI: It's not a question. AOAC, as a

 Nate Lewis asked, and I'm looking at here, just want to make

 sure I say it correct, started with Association of Official

 Agricultural Chemist, and later it was turned to Analytical

 Chemists --Association of Analytical Chemists later. Anyways.

 BD. MEM. LEWIS: Thank you.

 SECRETARY BRUCH: Perfect. Thank you.

 Kyla, go ahead.

 MS. SMITH: Super excited to get an update if we can

 make it happen on those documents that are in the program

 handbook. They are instruction to certifiers, which is 
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 different than guidance, in my understanding, and I think

 easier to update.

 BD. MEM. LEWIS: Duly noted.

 MS. SMITH: I could be wrong.

 SECRETARY BRUCH: Thanks, Kyla. That was --

 MS. SMITH: It's been known to happen.

 BD. MEM. JOHNSON: Well, that was going to be a

 question for Jenny in the next discussion. But so, the

 handbook is like best practices, but not formal guidance; is

 that --

 MS. SMITH: So, there is guidance that is more

 applicable to certified operations that are, you know, like

 best practices. If you follow the guidance, you will be

 complying with the regulations, right.

 BD. MEM. JOHNSON: But --

 MS. SMITH: There are other ways to comply with the

 regulations, and if you are doing something different than

 what's in the guidance, then certifiers might need to see a

 little bit more justification or things like that, right.

 Instruction is instruction to certifiers, and is

 expected to be followed, and again, if it's not being followed

 to a T, I think, you know, during accreditation audits, there's

 like an opportunity to like maybe show how you're doing it

 slightly differently, that it would still comply, but it is the

 expectation, and I know that PCO has gotten non-compliances for 
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 not following instruction to a T.

 CHAIR POWELL-PALM: Do we have a question --

 SECRETARY BRUCH: Go ahead, Nate.

 CHAIR POWELL-PALM: -- for jenny now that she's back?

 BD. MEM. LEWIS: Yeah.

 CHAIR POWELL-PALM: Right when she walks in the door,

 get her.

 BD. MEM. LEWIS: I -- I was going to -- I was going

 to post it, it will take me a little while to get it out, so

 you can --

 DR. TUCKER: If I could just get a minute to breathe?

 BD. MEM. LEWIS: Yeah, yeah.

 DR. TUCKER: That would be great.

 BD. MEM. LEWIS: My understanding is that guidance --

 to update guidance in the handbook, notice and comment has to

 occur in order to follow the Administrative Procedures Act.

 And the question is related to instruction to certifiers; does

 it fall -- does it have the same rules that guide -- that guide

 the updates to instruction documents?

 DR. TUCKER: Okay. Yes, is the bottom line. So, the

 handbook -- and this is as Office of Management and Budget,

 OMB, issues new guidance documents on how to do guidance

 documents. It does change how different agencies do things.

 And so, the handbook, you know, originally some of the

 documents in the handbook got posted without public comment, 
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 and then we started to do public comment on guidance, but not

 instructions. But a few years ago, it was right around the

 time we did the import oversight instruction, at that time the

 Council's office recommended that we could issue an interim

 instruction and hold people accountable for it, but we did need

 to open a -- a opportunity for public comment on it, so people

 can send feedback on it. So, guidance is a little bit

 different from instructions, but basically all of those --

 those -- anything we're going to enforce again, we need --

 against, we need to have an opportunity for the public to weigh

 in. For the regulated community to weigh in.

 Was that too bureaucratic?

 BD. MEM. LEWIS: That was clear to me, so.

 DR. TUCKER: Okay. And I didn't even use our magic

 words, so --

 BD. MEM. LEWIS: No, I know.

 DR. TUCKER: -- not bad, huh.

 BD. MEM. LEWIS: As a follow-up to that, is it a

 correct assumption that an update to the handbook is a smaller

 lift for the Standards Division than a rule change?

 DR. TUCKER: These days --

 BD. MEM. LEWIS: It depends?

 DR. TUCKER: -- it really depends. So, I think our -

- in general, right now guidance and rulemaking are about the

 same lift. So, the benefit of guidance is it provides -- it's 
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 longer, right, and so it provides more of the -- the thinking

 and the context, and so for super technical content, it is a

 good tool, but it's the same amount of work, ultimately, as

 rule making. Both just to internal clearance, but also with --

with OMB. Instructions are a little faster.

 I would say we're also going through the handbook

 right now because there are a lot of documents that need to

 either be archived, because they were completely replaced by

 strengthening organic enforcement where they need to be

 updated. Anything that needs to be substantively updated,

 meaning policy will change, even if it's gone through public

 comment before, would have to go through public comment again.

 So, we are being very strategic in what we do with a

 handbook. It will be an iterative process of updating the

 handbook based on what can be done quickly and what is going to

 take more time to get done.

 We also have an updated the handbook in a while, and

 so it could be that we get slightly different instructions on

 instructions, so -- because we haven't done one of these in a

 while, because we have been focused on rules, because we can

 actually really firmly enforce those.

 People are laughing; did I say something silly?

 BD. MEM. HUSEMAN: Instructions on instructions.

 DR. TUCKER: Oh, instructions in instructions.

 BD. MEM. HUSEMAN: We have an SOP on SOPs in my 
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 organization. We all laugh about it every time we see it.

 DR. TUCKER: There you go.

 CHAIR POWELL-PALM: Allison, please go ahead.

 BD. MEM. JOHNSON: Thank you. That was a really

 helpful clarification.

 I have two follow-up questions. This is getting

 wonkier and wonkier by the minute, so I apologize. So,

 effectively, the difference between guidance and a rule is that

 the rule would be binding, and the guidance is non-binding, but

 pretty much you have to do it anyways; is that accurate?

 DR. TUCKER: That's -- I think we -- we see guidance

 as enforceable. The guidance is enforceable because anything

 we put in the handbook, like guidance or instructions, always

 refers back to the regulation. So, when we issue a non -- can

 I say non-compliant? When we issue -- you broke the rule

 notice -- so, and I really do need some chocolate right now,

 I'm just saying.

 When we issue a notice to certifiers that they are

 not following the rules, we cite to the -- the 7 C.F.R. 205.

 The Rules. The regulation -- I am going to use -- we have

 regulation there, because it is a term of art in this very

 wonky conversation.

 Instructions do the same thing. Instructions do

 point back to the -- back to the -- the Code of Federal Reg --

 that's not any better. It does -- it does point back to the 
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 rule, and the -- and the Federal Register. And so that is

 actually

 what -- when we're taking an enforcement action, what we're

 enforcing against, is the rule itself, not the -- those other -

- those other documents. But having public commenting on those

 documents is important because then we can use, here's the

 cite -- the citation, and then here's what all these other

 documents say, that explain what we were thinking and why you

 do need to do it.

 BD. MEM. JOHNSON: So, then is -- do you have any

 tool to say this is a best practice, so it would be really good

 if you all did X, Y, Z, but where there's no risk that if you

 didn't do that you would be on the road to a non-compliance?

 DR. TUCKER: We're using the Learning Center more and more for

 that, and so we're very, very careful with Learning Center

 courses, that where it is a rule that you need to follow, we

 use words like "must" and "shall." If it is a best practice,

 we either, in the Learning Center say, here are some best

 practices, or you should do this, or it is strongly advised,

 though I don't like the passive voice. Occasionally, the

 passive voice can be kind of helpful. But we are very careful

 in the Learning Center, and there are a lot of courses in the

 Learning Center that refer to best practices, or this is what

 certifiers do successfully to implement these -- these rules

 and requirements. 
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98

 You really are just trying to get me to eat some more

 sugar, aren't you?

 CHAIR POWELL-PALM: Other questions for Jenny or any

 other thoughts or comments from the Board?

 (No response.)

 CHAIR POWELL-PALM: All right, back to you, Amy.

 SECRETARY BRUCH: All right, thanks, Nate. And

 thanks, Team, for working on this topic.

 I guess, let's see, do you want to proceed to the

 last item, Nate? Or we're close to --

 CHAIR POWELL-PALM: We are about four minutes from

 lunch, everybody, so let's just give ourselves those four

 minutes.

 SECRETARY BRUCH: Okay.

 CHAIR POWELL-PALM: We're going to come back in an

 hour and a half, and were going to finish up with -- so -- or

 2:00 p.m.; we're coming back at 2:00 p.m. No, sorry, one

 second. Let me do some math. How does everyone feel about an

 hour lunch?

 (Pause.)

 CHAIR POWELL-PALM: Okay, we'll keep this schedule as

 is. We're going to come back at 2:00, and we're going to pick

 up CACS; we have one more agenda item to cover on CACS. So,

 we'll see you all back here at 2:00. Thanks. 

(Whereupon, at 12:41 p.m., a luncheon recess was taken.) 
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 A F T E R N O O N S E S S I O N

 (Time Noted: 2:02 p.m.)

 CHAIR POWELL-PALM: In college, I wrote for a student

 newspaper, and I was never very good at the deadlines, so I'm

 always amazed at how fast the press makes good work. So, we

 have a political article about the release of OLPS, and I'm

 grateful that they quoted me as saying "This rule makes organic

 the gold standard for animal care. Everybody wants it.

 Organic farmers want it. Consumers want it. Organic

 certifiers want it. It provides excellent consistency."

 So, I think as we message about this continuous

 improvement, it's really exciting to, as we heard from

 consumers, get the word out about how organic is doing a bang-

 up job delivery. So, thanks everybody for all the work that's

 gone into the last 20 years to make this rule happen.

 (Applause.)

 CHAIR POWELL-PALM: Thank you. We're going to get --

keep going with CACS, which we need to rename unless we all

 want cavities, so -- but with that I'm going to hand it over to

 Madam Bruch.

 SECRETARY BRUCH: All right everybody, welcome back

 from lunch. We have one final topic to discuss in CACS, and

 that is a proposal, still in the "Oversight to Deter Fraud

 series," and this one is "Consistent Location Identification,"

 and Nate and I worked -- Nate Powell-Paul and I worked 
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 collaborative -- collaboratively on this document, and we have

 some slides for this, just to give a little background and

 examples.

 All right, currently the challenge is that location

 information is not consistently collected by certifiers. Some

 certifiers cannot show, in aggregate, where the fields they

 certify are located via an interactive mapping database.

 Solution: with zero impact to the farmer, certifiers would

 collect legal parcel ID or GPS codes.

 All right, the goals of this proposal is for

 consistency that all certifiers are deploying the same

 technique and enforcement, enable to do cross checks better

 amongst certifiers, facilitate effective unannounced

 inspections, and conduct aggregated analysis of high-risk

 regions or countries. Last season, last semester, we coined the

 phrase "Inspectors want to spend more time fighting the fraud

 than finding the farm."

 Okay. Sorry, before I passed to Nate, we did hear

 from the community about just some questions on how this could

 be deployed, so we put together an example to better articulate

 our vision with this.

 CHAIR POWELL-PALM: So, this is a little snapshot of

 an example that a certifier sent my way. When you go to see a

 field, say you're a certifier or a inspector, we have done such

 an incredible job making a big inclusive opportunity for folks 
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 to record and report their fields using very general and loose

 language, and so as you can see, Stacy's Field, or Man 1, or

 Leo's Field. When I asked this certifier how they would go

 about knowing where this field is, they said they would have to

 go and basically collate four different documents to try to put

 together the story of where they might be able to find this

 field.

 In most applications, inspectors are led around by

 the nose to each field. We would not be able to find them on

 our own. But, it's really important that farmers are still

 able to call the fields what they want so they can keep track

 of them. If I were to number all the fields on my farm, I

 probably wouldn't be able to remember which field is which, so

 usually I use the landowner's last name as the name of the

 field, but as you can see in this left column where we just

 have numbers, there's so -- it's -- it would be so easy to put

 a legal descriptor or a geocode in one of those columns just to

 marry up, so that we have a way to communicate between

 certifiers.

 In this example, the certifier we were talking to

 said that they received a question about a field from another

 certifier, and when they looked at it, they were trying to

 figure out how do I describe where this field is in this cross

 check? And you can't say "Tony's Field" or "Stacy's Field," it

 just doesn't work. So, we need to create a consistent way to 
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 describe fields, and we have a lot of options.

 This is purely rhetoric, but Brian, may I ask you a

 question?

 BRIAN CALDWELL: Sure.

 CHAIR POWELL-PALM: Do you pay property taxes?

 BRIAN CALDWELL: I do.

 CHAIR POWELL-PALM: Wood, in North Carolina at your

 family farm, do you pay property taxes?

 I've Googled -- and I'm surprised how many other

 people have apparently googled this -- "Are there any states

 without property taxes?" The answer is no.

 Nate.

 BD. MEM. LEWIS: There is a territory that does not

 pay property taxes, Puerto Rico.

 CHAIR POWELL-PALM: Okay, well that's helpful.

 In the greater United States, we all pay property

 taxes, and when we're thinking about, you know, the concern of

 how do we identify immutable information descriptors of fields,

 every field is going to have either a deed code, or its going

 to have a legal description. In the West, we have township

 section and range, and so this is not a big lift folks.

 Everyone who is in here is going to be able to describe their

 property in a way that corresponds with basically the

 authorities that manage that property right.

 This is a field map that you are likely to see in a 
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 certification file. So, we see that the name "Stacy" is tossed

 on there, we see that its 20 acres, and the directions to the

 field are on the bottom.

 Wood, would you mind reading that out to me?

 BD. MEM. TURNER: I believe "across from the barn."

 CHAIR POWELL-PALM: Barn.

 Allison, could you find this field?

 UNIDENTIFIED SPEAKER: (No audible response.)

 CHAIR POWELL-PALM: Only barn in the States.

 This is -- I again, I love how organics has made it

 so it's really easy for folks to meet us where we -- for us to

 meet them where they're at in certification. That when they

 describe their field, we've been really good at saying like,

 just give us a general description and we'll be able to keep

 going with it. We've kind of, in the spirit of continuous

 improvement, outgrown that system, that we need to start moving

 towards a place where we could say this field, township section

 and range, is recorded so that when somebody else has a

 question about this field, say a question about it being

 sprayed, or a question about who is also maybe certifying it,

 how can we go in and know with certainty what we're talking

 about. And then create a language between certifiers for how

 to describe these parcels.

 The big giveaway here is, in America, we're probably

 going to be okay. This is not a big lift. Where I'm very 
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 interested in finding out what happens is in the international

 space, and so when folks and international certifiers are told,

 you have to tell us exactly where every field for these

 millions of bushels that you're exporting of grain, will those

 fields suddenly disappear? And will we have a better idea

 about where these fields are, who is actually getting

 legitimately certified and not just certifying ghost fields,

 and how will that shake out?

 So, when we said geocodes, or any other legal land

 descriptors, it's making a big tent, where in the U.S. we're

 going to be able to know that by the -- mostly by the property

 tax codes, we're going to be -- have some immutable identifying

 information there, or in any application we could use a geocode

 because it applies to the entire globe.

 An example of this geocode, and this was always

 interesting for how much conversation this concept generated,

 is that the idea of where a field is, if you can get us to even

 just any point on a field if, you zoom out -- and this is a

 picture of one of Amy's fields -- we can get a good idea of the

 boundaries of the field. That you're able to see here that the

 four roads are going to be crossing. We have a path on that

 south side. The location is not -- you know, the location of

 the ping in the field is not that necessary -- like not that

 necessary, not that prescriptive ,but the idea was that this

 would be an easy solution for creating another reference point 
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 that, again, is going to be presented in such a way that we can

 reference back and back it up. Right now, we are sort of

 taking the word of any producer on an application as to what

 their field is, where it is, and how we find it.

 Anything to add to that, Amy?

 SECRETARY BRUCH: No, that's -- I guess -- yes,

 actually, one -- one thing. Sorry, I always have "one thing"

 to say. But we did listen to the community in the spring

 session. We were fortunately able to have two plains community

 folks join us during the public comment process, and we did ask

 them is parcel number -- so that's what you pay the property

 tax -- is that a common type, word, vocabulary, does that --

does that make sense? And that -- that was agreed upon, that

 that was more understandable than the term "field," so we did

 make modifications in our document to include parcel number.

 We did make modifications in our document to include other --

 other means of giving us GPS, and those are again the parcel

 number and address, not a mailing address that -- such as Route

 2, Box 176, which was my original address growing up, but a

 street address, because we did hear, I think from commoners in

 the Northeast, that -- that land is a little bit more

 developed, there's street addresses to a lot of the farms.

 Perfect. That's great. And legal address, like Nate

 mentioned, township, section, and range, that's really helpful

 also. All of those points will lead us to a GPS that then, you 
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 know, we did hear from certifiers that work for, I believe,

 WSDA, that said they take a point and then they make a KMZ

 file, which is actually a file that shows you the boundaries of

 each property. So again, I don't know if anybody uses

 QuickBooks for tax purposes, you enter -- once you enter in the

 data, you can generate reports really nicely. It is a little

 bit of a lift to enter in the data; however, when you can

 manage aggregate data it's really going to be important. And

 managing aggregated data for where these fields are, again, are

 going to help us understand mass balances from a regional

 standpoint. Like Nate mentioned, from an international

 standpoint, in doing these mass balances showing where highrisk areas are, et cetera.

 CHAIR POWELL-PALM: If I -- if I could just offer a

 little more specificity.

 SECRETARY BRUCH: Yeah.

 CHAIR POWELL-PALM: I think we heard from several

 commenters that they couldn't quite understand why -- how this

 would help with mass balance. So, just again as a little

 example, so if we're being able to record these fields and

 enter a crop along with them, so we record this field you see

 in front of you, and its corn this year, and certifiers are

 able to assign and marry up both that legal identity of the

 field, its acreage, as well as the crop in which its growing,

 they're able to understand how much of the -- is the capacity 
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 of their portfolio of clients. And they're able to understand,

 if I suddenly see receipts that far exceed what I would expect,

 I have a reference point to go back to and make a, you know,

 make a risk determination over what I'm seeing actually in the

 field over the course of the inspection season.

 Normally, that's doable by a lot of different

 certifiers. We have CCOF who said they can do it. Oregon

 Tilth. WSDA. Montana Department of Ag puts the legal

 description right on the certificate. So, this is not new to

 anybody, but it is inconsistent across the -- both across the

 United States, but really across the world, and I think that

 across the world part is most interesting for how we can

 possibly improve the system.

 SECRETARY BRUCH: Yeah, absolutely. And then when we

 look to benchmarking with other -- other countries and their

 systems, the Mexican organic system, which we learned last

 semester requires GPS coordinates for all the farms they

 certify to their standard. We heard from certifiers

 domestically. I believe it was OneCert, for all international

 farms they require GPS codes, so it -- it's something that's

 common language.

 Risk Management Agency, who we heard earlier today,

 they expect and -- and need for reconciliation purposes, actual

 field locations, so it's -- it's where the industry is

 morphing, and it is starting to be more common -- common type 
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 language. But we do recognize the diversity in our community

 and that's again why we point to several means of getting us to

 the end result.

 CHAIR POWELL-PALM: I would just add that in the --

 in the recommendation, we note that the goal here is for

 accredited certifiers to obtain consistent location

 information, with an example of geocodes being one. This is

 not prescriptive, we're just looking to, you know, get -- to

 try to get everybody pulling in the same direction to have a

 better idea as to where the fields are that produce all this

 grain, that in a way as we sort of look back is a source for so

 much consternation in -- in public comments over here. How do

 we make sure that the grain being produced, purchased, imported

 is legitimate? And this is one step. It's a very low hanging

 fruit, and -- and we see it as something that's going to be

 just the beginning of hopefully a bigger, more robust system

 that helps fight fraud.

 SECRETARY BRUCH: Yep. I like to call it "basic

 conditions." It's not the tool that's going to solve all the

 issues, but we need to get the foundation solidified,

 especially since our industry is growing like it's growing.

 CHAIR POWELL-PALM: Questions from the Board?

 Allison.

 BD. MEM. JOHNSON: Thank you for this presentation.

 It's really clear. This felt pretty straightforward in 
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 Subcommittee. We got a lot of comments, so I -- I want to walk

 through my understanding and make sure I understand what we're

 actually proposing here and what the impact is.

 So, Nate, what you just said, I think, is the key to

 some of the confusion; that the "(geocodes)" is meant to be an

 example, but not an exhaustive list of how you could get the

 location information?

 CHAIR POWELL-PALM: Correct.

 BD. MEM. JOHNSON: And that the list above, in the

 Proposal C, in the -- the feedback piece, is another -- or

 three other examples of how you could --

 CHAIR POWELL-PALM: Um-hum.

 BD. MEM. JOHNSON: Okay. So, I think we might need

 like a copy-editing fix here, an "e.g." or an "example" or

 something like that in that parenthetical, because I've, going

 back and rereading it several times, I thought it was saying

 location information, which is a geocode, and going on.

 CHAIR POWELL-PALM: Um-hum.

 BD. MEM. JOHNSON: So, if we can make that

 clarification, I hope that will address --

 CHAIR POWELL-PALM: Sure.

 BD. MEM. JOHNSON: -- some of the concerns.

 And then just pulling their -- our discussion from

 earlier about guidance, what we're proposing here is that the

 NOP provide guidance on this issue, which would have to go 
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 through public comments and be binding -- essentially binding,

 right?

 CHAIR POWELL-PALM: So, that was something that I was

 very interested in; who commented on this proposal? Because

 there is nowhere in OFA that this isn't -- that this is rule

 [sic], so it will go through the same process. And again, it's

 a conversation starter to get certifiers thinking about do we

 have any idea where the fields we are -- fields are that we

 certify? So, your example, yes, correct for the path forward,

 but it's also not something that -- it's going to be, you know,

 a condition of accreditation hopefully. Nothing that would

 lose a certifier accreditation.

 BD. MEM. JOHNSON: Maybe this is a question to Jenny

 or Jared then. What I took away from our conversation earlier

 is that by making it guidance it could actually put someone's

 accreditation at risk if they didn't do this.

 DR. TUCKER: It could. I -- I would want to -- I

 would want to also look at this recommendation through the

 light of the capabilities that are already in the Organic

 Integrity Database, because strengthening organic enforcement

 specifically calls on certifiers to submit information through

 the database. So, if that becomes a requirement of the

 database, then it's actually covered under the regs by -- by

 reference.

 So, I -- we would want to take a look at what is the 
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111

 most, both expedient and reasonable response to this type of

 recommendation. I'm waiting. I have a technical person in the

 chat and I'm really hoping that she'll send me an answer to a

 question I just sent her. So, I think we would have to look at

 it in terms of guidance and perhaps building on capabilities

 that -- that may, in fact, already exist. So, we'll have to

 take a look at that.

 CHAIR POWELL-PALM: Other questions? Kyla.

 MS. SMITH: Yeah. Good? Okay, sorry. Yes, I have

 had the opportunity to have lots of conversations on this topic

 and appreciate the presentation. And I do think that, you

 know, and we heard through public comment, that there are

 differences in the East and the West in how we talk about land.

 And so, I think that that's like coming through, and so I do

 think just a reminder on terms because even, Nate, when you

 were talking, you were saying "field," and I was like you mean

 "parcel"? And so, I just am like continuing to say that in

 my -- in my head.

 And you know, we -- we heard that, again, in the East

 that -- and you said this again in the presentation -- just

 that there is more often a address, physical address, street

 address that goes with land in the East, more so than in in the

 West, and so that seems like a viable option here.

 And just to be clear, too, that this was helpful for

 me because I'm not a farmer, and so I don't think about these 
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 distinctions with like parcels and fields as much, but a -- a

 parcel number, if that is what is being used, could be used for

 more than one field. So, on that chart with like Stacy and Leo

 and Bill 1, 2, 3 -- like Bill 1, 2, 3 like could all have the

 same number associated with them because it's the parcel number

 that includes those three fields. And so that was -- I think

 we often talk about like a unique identifier, right, and so the

 unique identifier is to the parcel, not necessarily to the

 field. And so, you're getting in the general location, like

 spitting distance of Bill 1, 2 and 3 by using that code. That

 was --

 CHAIR POWELL-PALM: Absolutely.

 MS. SMITH: -- was really helpful for me to like be

 talking about this in like real examples.

 CHAIR POWELL-PALM: Um-hum. The goal is to get us

 within earshot of where we're producing these products. There

 was a lot of concern over what if my fields change? What if

 the sizes change? The legal boundaries of the field does not

 change unless you're submitting a subdivision, and that's a

 much bigger process. And how often that occurs is going to be

 rare.

 But we have an update from Jenny, I think, on that

 earlier question.

 DR. TUCKER: Yeah. So, apparently in the Organic

 Integrity Database, we take addresses that are provided by 
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113

 certifiers, and then we use an external service to translate

 the -- them into geocodes, but right now we don't accept

 geocodes as part of the data submission template. So, this

 would likely, given that, could become -- we'd have to think

 about could we expose, for example, the results? If we're

 taking addresses and trans -- but that's just at the address

 not the field level, so that's really different. So, I -- I

 think the reality is on this one it would be a, both policy and

 technology solution. We'd have to deal with it on both fronts;

 it's not already built into the technology.

 So, I don't know if that just complicated it or not.

 We'd have to really -- we'd have to think about how to deal

 with that, both policy wise and technology wise. Bottom line.

 CHAIR POWELL-PALM: Carolyn.

 MS. DIMITRI: I guess, I find this whole conversation

 like simple, but also extremely confusing at the same time.

 So, I wonder, Nate, have you thought of like any

 unintended consequences that could happen based upon what

 you're proposing? Like unpleasant outcomes.

 CHAIR POWELL-PALM: I love that question. Of the

 3,000 inspections I've done in my career, probably about half

 have been on Amish farms, and so I really take to heart this

 question of will this affect any one group more than the --

more than others? And I feel very confident that the answer is

 no, because it's all on certifiers. 
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 When I look to certifiers who have already executed

 similar -- well, some groups, the certifiers, but when I look

 to certifiers who have already done this system, from WSDA,

 CCOF, Oregan Tilth as we had in our slide, the certifiers who

 represent more than half the certified operations, it's going

 well. That we know where those fields are. It's -- they're

 easily located. They're mappable.

 In eSearch, which is a technology -- a database that

 a lot of certifiers use, not everyone but a lot, they also have

 spots for all this information to already go and be entered for

 geocodes, latitude, longitude. And I think it's something that

 when we hear from inspectors who are out there doing the heavy

 lifting, trying to find fields, and fight fraud, that they also

 resoundingly said this would just be a big help. So, as we

 think about human capital, making the inspector's life easier,

 I think this is huge. It's going to be a zero burden on the

 farmer because it's all on the certifier.

 And with deep gratitude, I say thank you certifiers

 for always doing the heaviest lifting. I mean this is always

 an ask for more and more, and I am very grateful.

 MS. SMITH: I just was laughing to myself because

 of -- we're in the middle of that SOE --

 CHAIR POWELL-PALM: Yeah.

 MS. SMITH: -- we just had OLPS drop, and we're like

 oh, just go grab those geocodes, guys, that'd be great. 
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 BD. MEM. JOHNSON: Add to that, Nate. So --

 CHAIR POWELL-PALM: Please.

 BD. MEM. JOHNSON: -- I appreciate those thoughts.

 So, one scenario is you're using this information for

 a mass balance; something looks funny, and then what, an

 inspector goes out at -- like, so like I guess I see that's

 where a problem could come up. Like how would you solve that

 if using this information? Like, can you sort of walk through

 how this helps you solve a mass balance problem, one. And two,

 what happens if like, say, the things moved around on a farm --

on a particular farm and things are a little bit not exactly

 matching --

 CHAIR POWELL-PALM: Um-hum. Um-hum.

 BD. MEM. JOHNSON: -- that information? I guess

 that -- yeah.

 CHAIR POWELL-PALM: So, I -- correct me if I'm not

 understanding what you're saying, please. With the -- the

 location information, we're going back to a legal parcel, and

 so we have a way, either through your county cadastral, you're

 interactive mapping, through your, you know, your -- your state

 interactive mapping system; when a farmer says, this is where

 my farm is and this is how big it is, we can go check. If we

 need to. If someone says that it seems like they're producing

 a heck of a lot of wheat off that field, there's one way to go

 back and say, is that the -- what information they give us is 
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 accurate? We have folks that are -- may also do the same work

 every single season, so it's not -- we're not reinventing the

 wheel at all here.

 For the mass balance application, right now we do

 such -- such, sort of, focused and tiny mass balances, so if

 we're doing at the farm level, usually we're doing it on a

 single crop for the whole year. And so, we're saying, how much

 wheat did you produce this year? Then we're going to get a

 "bushels per acre" out of that. But that doesn't really expose

 any sort of systemic fraud, and so I see it as a certifier,

 being able to hear from someone, it seems like this county is

 producing a lot, you're the biggest certifier there, and

 there's not a way for them to go in now, on the whole, to -- to

 have some data to check that out.

 Dilip.

 BD. MEM. NANDWANI: Okay. To understand in simpler

 terms of what Carolyn, and I think Kyla just mentioned, what

 I'm getting is that -- or it's a question also -- for example,

 a farmer has 100 acres, or let's say 500, it's a big farmer,

 500 acres of land.

 CHAIR POWELL-PALM: Um-hum.

 BD. MEM. NANDWANI: And he or she is growing

 different crops, let's say in one corner of Plot A, which is

 next year because of crop rotation and, you know, the practices

 we do move 200 acres or 500 acres apart from East to West; is 
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 it going to be in the records like this is the GPS location,

 and then next year is going to change to this and that and all

 that? Or is just the one geocode we are discussing to have

 only for one land parcel? Thank you.

 CHAIR POWELL-PALM: And I would -- please correct me

 if I'm not understanding you right. But clarifying that, that

 500 acres could be a single land parcel. It could be four land

 parcels, say it's, you know, 100 acres that have been married

 together; we're really just looking -- and this is sort of how,

 again, low hanging fruit this is, we're just looking to get to

 that 500 acres.

 BD. MEM. NANDWANI: Okay.

 CHAIR POWELL-PALM: Internally, a lot of other OSP

 questions we would ask. We would look at the maps. We would

 dive in deeper. But right now, we don't really have a

 consistent way across certifiers to even find that 500 acres.

 BD. MEM. NANDWANI: Okay, thank you.

 CHAIR POWELL-PALM: Thank you for the question.

 Any other questions? Allison, please.

 BD. MEM. JOHNSON: This has been really helpful,

 thank you.

 I have three friendly amendments to the language to

 offer, if that is reasonable --

 CHAIR POWELL-PALM: We welcome them.

 BD. MEM. JOHNSON: -- protocol. 
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118

 Okay, so the first is to consider saying "NOP advise

 all accredited certifiers," instead of "provide guidance," so

 then NOP can kind of look at OFPA, look at the implications of

 different types of communication with certifiers, and choose

 the right tool, so that there aren't accreditation

 repercussions, but it's clear that this is the best practice.

 CHAIR POWELL-PALM: Um-hum.

 BD. MEM. JOHNSON: Second would be, further in that

 sentence it says, "To obtain," I'm wondering if we want to say,

 "to record" or "to document," because if I'm certification

 staff who haven't heard this discussion, I see "obtain," I ask

 for it.

 CHAIR POWELL-PALM: Um-hum.

 BD. MEM. JOHNSON: So, some sort of language to

 indicate that it's intended that the certifier does the work,

 not the producer.

 CHAIR POWELL-PALM: Love that.

 BD. MEM. JOHNSON: And then the last would be, in

 that parenthetical that says "(geocodes)," to make it a little

 bit longer and say, "e.g. geocodes, parcel numbers, street

 address legal address," so that if someone's just looking at

 this recommendation and not reading the discussion that's right

 above it, you still know that those are acceptable forms of

 location information.

 CHAIR POWELL-PALM: Now, I'm just --
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 SECRETARY BRUCH: Thanks.

 CHAIR POWELL-PALM: -- looking at --

 SECRETARY BRUCH: Our resident Legal Eagle. Thank

 you. No, that's -- that's helpful because I think there was

 additional need for clarity there.

 CHAIR POWELL-PALM: I'm looking for the

 parliamentarian to tell me --

 SECRETARY BRUCH: Hey, are these --

 CHAIR POWELL-PALM: -- if we have to go --

 SECRETARY BRUCH: -- substantive changes?

 CHAIR POWELL-PALM: Yeah, are these substantive

 changes? I defer to you, Allison; are these substantive

 changes?

 BD. MEM. JOHNSON: I think they're clarifying

 amendments.

 CHAIR POWELL-PALM: I agree. All right, so let's

 see. Okay, and we can have this -- a cover sheet, as well, but

 it would read, Allison, if I've got you right, "The CACS

 recommends that the NOP advise all accredited certifiers to

 record consistent location information, e.g. geocodes, parcel

 location -- or parcel location, legal parcel ID, that can lead

 to GPS coordinates of all applicants for certification and

 certified operations (parcels, production units, grower groups,

 handling locations, importers, brokers, et cetera). This will

 result in harmony -- harmonization of location data of all 
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 parcels, enabling certifiers to streamline crosschecks and

 share information internally between operator, certifier, and

 inspector."

 All right, any discussion? Any questions?

 BD. MEM. JOHNSON: Again, and I'm not a

 parliamentarian, so these are friendly amendments. Do the

 motioner and the seconder need to agree to the friendly

 amendments?

 CHAIR POWELL-PALM: Go ahead, Motioner.

 BD. MEM. JOHNSON: I need my Robert's Rules of Order

 book.

 CHAIR POWELL-PALM: I know.

 BD. MEM. JOHNSON: Joe gave me one after our first

 NOSB meeting together, by the way. Fun fact.

 CHAIR POWELL-PALM: To cover our bases, let's do

 that.

 SECRETARY BRUCH: Yeah. Yeah, that's fine. As

 motioner, I accept these amendments.

 CHAIR POWELL-PALM: And, as seconder, I accept these

 amendments.

 SECRETARY BRUCH: All right.

 CHAIR POWELL-PALM: With that, we'll go to the vote.

 I think we're going to start with Logan.

 Waiting for the secretary. Jerry.

 BD. MEM. D'AMORE: As you probably would do anyway, 
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 to let us know which way these votes -- are yes is a no and no

 is a yes on this one?

 CHAIR POWELL-PALM: Yes. For this one, it's going to

 be a yes is a yes. Thank goodness. No National List involved.

 We're just getting the voting sheet up here real

 quick.

 Logan, your vote please.

 BD. MEM. PETREY: Yes.

 CHAIR POWELL-PALM: Carolyn?

 MS. DIMITRI: Yes.

 CHAIR POWELL-PALM: Allison?

 BD. MEM. JOHNSON: Yes.

 CHAIR POWELL-PALM: Brian?

 BD. MEM. CALDWELL: Yes.

 CHAIR POWELL-PALM: Nate?

 BD. MEM. LEWIS: Yes.

 CHAIR POWELL-PALM: Dilip?

 BD. MEM. NANDWANI: Yes.

 CHAIR POWELL-PALM: Jerry?

 BD. MEM. D'AMORE: Yes.

 CHAIR POWELL-PALM: Kyla?

 MS. SMITH: Yes.

 CHAIR POWELL-PALM: Amy?

 SECRETARY BRUCH: Yes.

 CHAIR POWELL-PALM: Kim? 
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 BD. MEM. HUSEMAN: Yes.

 CHAIR POWELL-PALM: Franklin?

 BD. MEM. QUARCOO: Yes.

 CHAIR POWELL-PALM: Wood?

 BD. MEM. TURNER: Yes.

 CHAIR POWELL-PALM: And the Chair votes yes.

 SECRETARY BURCH: Okay, 13 yes, zero no, zero

 abstentions, zero recusals, 2 absent. The motion passes.

 CHAIR POWELL-PALM: Thank you, everybody. Hopefully,

 a first step towards a better system.

 SECRETARY BRUCH: Okay, that concludes the ACS.

 I didn't get to thank everybody on the front end, our

 Subcommittee and the full board, but I do want to thank you on

 the tail end. Really appreciate the work all the committee

 members put into this semester's work agenda. We -- I think we

 have our work cut out for us next semester with our work

 agenda, which we'll preview at the end of our board meeting.

 I also want to thank public commenters. It was

 extremely helpful to gain insight in our -- in our work agenda

 material with your comments and inputs so keep them coming as

 always but thank you so much.

 And then I think I have one last slide I wanted to

 proceed to, real quick. Okay, so today, it's a big day for the

 committees that I serve on, but it's also a big day for my son;

 he turns 2, so I just wanted to recognize him. And he loves 
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 farming already, and it's nothing that Mama taught him, it's

 just everything driven by him, but I think he'll be the future

 organic farmer in the -- to come, so thank you.

 CHAIR POWELL-PALM: Could we all sing Beckham a

 little happy birthday?

 SECRETARY BRUCH: Oh, if you do, I'm going to record

 it.

 CHAIR POWELL-PALM: I got you. I got you.

 SECRETARY BRUCH: Okay.

 (Chair sings Happy Birthday.)

 (Applause.)

 MS. DIMITRI: And Happy Birthing Day to Mama.

 CHAIR POWELL-PALM: To Amy.

 MS. DIMITRI: Big part of the process.

 SECRETARY BRUCH: Thank you. I've got to send that

 to all of you. Thank you so much. Really appreciate it, and

 I'll turn it back over to the Chair.

 CHAIR POWELL-PALM: Thank you. I just want to -- I

 think it's not lost on anyone that the CACS Subcommittee has

 really flourished under Amy's leadership, and we went from a

 single meeting a month to two meetings a month, and we have

 just been very busy, and so thank you for bringing the energy.

 And thank you for every year spending your baby's birthday with

 us. We really appreciate that sacrifice. It's not small, so

 thank you. 
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 (Applause.)

 SECRETARY BRUCH: Thank you.

 CHAIR POWELL-PALM: All right, and with that, I

 believe we're going to be jumping over to PDS, led by Allison.

 BD. MEM. JOHNSON: (No audible response.)

 CHAIR POWELL-PALM: Oh, say that again, Allison.

 BD. MEM. JOHNSON: (No audible response.)

 CHAIR POWELL-PALM: We just voted, didn't we?

 BD. MEM. JOHNSON: Did we just vote?

 CHAIR POWELL-PALM: Yeah. I hope so. All right,

 Allison, the floor is yours.

 BD. MEM. JOHNSON: Thank you.

 So, we are a small, but mighty, PDS committee and we

 don't have anything to discuss or vote on today. But we are

 working toward Policies and Procedures Manual proposal in the

 spring that Mindee and Nate Lewis will be leading, so we just

 wanted to preview the topics that we're hoping to address.

 We're going to take on setting board members up for

 success and some participation and communication expectations,

 making sure that we have clarity there. The meeting formats,

 you know, updates to reflect having gone through COVID times

 and -- and ways that we may be operating differently now, as

 well as just sort of expectations around when it may or may not

 be ok to miss meetings. We're going to try to include some

 specific areas where we can address diversity, equity, and 
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 inclusion as a board, and how we can integrate principles of

 DEI into our training and board participation. And then also

 be explicit about communication of non-unanimous proposals and

 decisions and how we can be really clear to our stakeholders.

 Separately from the PPM updates, we'll also be

 exploring how the Board can engage with the Equity Commission.

 We really appreciated the comments in that area, and our

 understanding is that there will need to be some formality

 around that because it is a Commission of the Secretary of

 Agriculture, so we'll be looking to the National Organic

 Program to help us navigate building that relationship.

 I think that's all from us for now.

 CHAIR POWELL-PALM: Slammin'. If I may give an idea

 that I think I've been stewing on for years, but it seems like

 we are having some fantastic discussions that are really

 outside the National List, and the work were doing the National

 List, and I would be so stoked if we might consider adding to

 the PPM that if a material is unanimous coming out of

 Subcommittee we added to a slate to vote on with the single

 vote. If there is dissent, then we vote on it individually,

 but just to speed this up so we can keep these great

 conversations expanding.

 Any thoughts from anyone else on that? Carolyn.

 BD. MEM. DIMITRI: I like that idea, Nate, because

 I'm all about efficiencies, but I think maybe in addition to 
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 unanimous, we'd also want to make sure there were no strong

 public --

 CHAIR POWELL-PALM: Sure.

 MS. DIMITRI: -- public comments in opposition of

 that particular material being relisted. Okay.

 CHAIR POWELL-PALM: Yeah, thank you. Wood?

 BD. MEM. TURNER: Very supportive and I like what

 Carolyn is suggesting. I -- I just think it to -- to free up

 some time during the meeting to have some of these -- some of

 these more, sort of, far reaching, you know, almost

 philosophical conver -- questions about sort of what -- what

 the future of organic is I think are really important, so I

 think that's a nice way to address that issue, too.

 CHAIR POWELL-PALM: I agree. Kim?

 BD. MEM. HUSEMAN: Yeah, on that -- that same token,

 I would suggest some type of language around being able to

 carve out at one person's request --

 CHAIR POWELL-PALM: Sure. Yeah.

 BD. MEM. HUSEMAN: -- if there were an item of -- outside of

 Subcommittee because we know what -- what the vote takes to get

 something to pass, right. That each of the Board members is

 given the opportunity to review that -- that consent agenda,

 and then it's one person's vote to be able to carve out a

 component, if needed.

 CHAIR POWELL-PALM: Um-hum. Totally agree. 
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 BD. MEM. HUSEMAN: So that --

 CHAIR POWELL-PALM: Yeah, just to get the

 conversation started. I think as Rick Greenwood reminded us

 every single meeting, this seems like a good idea, and I'd like

 to honor that and see if we can put that on PDs' plate to -- to

 go forward with.

 MS. DIMITRI: Well, that's something --

 SECRETARY BRUCH: Yeah, thank you. We're happy to

 try to tackle it.

 MS. DIMITRI: -- we'll have to talk about.

 yeah thank you were happy to try.

 CHAIR POWELL-PALM: All right, thank you, PDS.

 Appreciate it. And thank you for all the leadership on PDS.

 It's -- it's taken a lot. We have very interesting challenges

 over the last couple of years and we're hoping to address

 those.

 How we doing on a break, folks? Doing all right?

 Okay. We're going to move over to crops now, and with that

 I'll hand it back to Amy.

 SECRETARY BURCH: Okay, I will thank the Crops

 Committee on the front end. The Crops Subcommittee, really

 appreciate the service. We have, I feel like, breathed a lot

 of life into the materials review process this past year with

 the substances that we have. We've had a lot of extended

 conversations on these materials, so I'm looking forward to the 
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 discussion with those, with the full board.

 And I also again want to thank the community.

 Appreciate your comments and involvement in the process, as

 always. One thing that was a follow-up from our spring

 semester was our TR review process. As a Subcommittee, we have

 prioritized when we do receive TRs to try to get them reviewed

 as quickly as possible. We have an extended time frame in

 which it's acceptable for us to review them, but we have

 prioritized as a Subcommittee to try to get those reviewed

 quicker so they're available to stakeholders as soon as they

 can be. So that was a follow-up and good feedback from the

 community.

 So, without further ado, we have one proposal to

 start off with, and then we'll go to the National List items

 after that. That proposal is on potassium sorbate. It's got a

 few slides to walk through here, and then a couple comments.

 So, potassium sorbate, I have it abbreviated as "KS,"

 is petitioned to -- for two uses; it's synthetic and is

 petitioned to be used as an insecticide, and also petitioned to

 be used as disease control. And the main method of -- of

 effectiveness is contact. There is no residual with this --

with this product. This is just a list -- the summary list of

 KS.

 So, potassium sorbate's history. It is currently

 allowed on the National List, under the synthetic -- as a 
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 synthetic inert ingredient, so it is found in some of the

 products that are available for organic producers currently.

 And EPA has listed it as a -- on a list for a minimal risk

 inert ingredient. FDA has it listed as grass. And

 internationally, currently it's not accepted for this

 petitioned use. It's been previously petitioned three other

 times for different reasons.

 Environmental and health impact. So, this is similar

 data from the last time. If you guys remember right, potassium

 sorbate with our TR, it was a great TR but at the end of the

 day we learned that there's just not a lot of information in

 regards to this particular substance, this particular material

 in this regard, so our information with potassium sorbate

 really relates to its use as a food preservative. So, we

 requested information from the community over the last year,

 and also -- and actually, the Petitioner responded and provided

 us with some additional information, which we reviewed in

 Subcommittee.

 One thing that was notable that the Petitioner did

 mention, is that this product, because it's going to be applied

 through -- or via full year application, will have minimal soil

 interaction, was the comment because concerns environmentally

 stem from just inhibiting growth of soil micro --

 microorganisms, increase and pH, impacting bacterial

 communities. 
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 Also, there was some comments with just its sub

 products. So, potassium sorbate, when it breaks down, the

 degradation of the products is more hazardous than the product

 itself. So, sorbic acid, this is one thing to note, is

 reported to have synergistic effects with sodium nitrate and

 form direct acting mutagens.

 In summary, the -- the Subcommittee reviewed this and

 for various reasons listed below with our off-product criteria,

 this is where we netted out that potassium sorbate is not made

 from renewable resources, materials used to produce potassium

 sorbate are not recyclable, it doesn't complement the use of

 natural and biological controls. Many alternative substances

 do exist; I had a slide last time that showed, I think there

 was over nine different products out there that are already

 approved. They're approved as synthetic to be used. There's

 some biological controls that folks are using for insect

 control and disease control. There's also cultural practices

 and different -- different practices deployed on the farm to

 try to mitigate substances, so that one came through with just

 a lot of alternatives.

 The Petitioner did respond that the idea with

 potassium sorbate could be to reduce the dependency of

 substances, such as copper and sulfur, which is notable. The

 efficacy data that we did receive from the Petitioner did not

 show that they were testing the -- the strength of potassium 
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 sorbate versus copper or versus sulfur, but it was interesting

 to note that it could be used as a replacement. Just in

 general though, more research ultimately is needed.

 The Petitioner responded just because it's on -- it's

 been really reviewed regular -- regulatory many times through

 FDA and EPA that he doesn't really anticipate more information

 going into understanding its environment -- environmental or

 health impacts.

 So, when we look at public comments for this

 substance, let me just pull up my summary, we had seven written

 comments and two oral comments. So, two activist groups, one

 certifier, one advocacy group, and two grower groups said -- or

 sorry, two activist groups, one certifier, and one advocacy

 group said no for it -- for its use as an insecticide, and also

 a fungicide. Two grower groups during oral comments were asked

 and they were in support of it in the spring. Their response

 in the fall was they just -- they didn't have a push from

 farmers to actually want to have this product as an option, so

 they -- they just didn't necessarily support this anymore. Two

 grower groups said yes for the allowance for disease control,

 but not for use as an insecticide. And one grower group said

 yes to -- to its use in both fashions. So potentially where

 the grower groups were saying about yes to disease control is

 because it does -- the Petitioner said it does target powdery

 mildew, and we hear from growers that that is a substance 
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 that's really challenging. Even conventional farmers are

 challenged by powdery mildew, so this has a potential to help

 with that in -- in a variety of different crops. More than

 one. And as an insecticide, the groups that said yes to

 disease control but no to insecticide, they just didn't think

 that the mode of action was really that strong for its use as

 an insecticide.

 I'm just going to turn -- I know in Subcommittee

 Logan and Brian had some additional comments on the efficacy

 data. I don't know if you guys have anything you want to add

 to this before we open it up?

 BD. MEM. PETREY: Sure. Thank you, yes.

 So looking at, from the Petitioner, the -- the

 studies that were conducted, we did not see, like you

 mentioned, the sulfur or the copper to be compared with. We

 did see kaligreen, which is potassium bicarbonate, which is on

 the list. It did -- so it performed better than the potassium

 bicarbonate.

 And also, you know, kind of to go back to the

 application on the label of kaligreen, it actually says do not

 using chemigation water, so it is strictly a foliar application

 so were not getting that soil contact. That may, you know,

 inhibit growth of soil microbes. But the -- the data again, it

 was -- it was kind of hard to -- to justify or to say that it

 is better than our alternatives now that we do have, because 
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 only -- and it was using its oxidate, as well, which I'm -- I'm

 not a big oxidate user in season. Almost a sterilizer and --

and can kind of make things blow up, at least is what I've

 seen. And so also, you had to put almost as much acidifier in

 the tank mix with it as you did the product itself, and you saw

 it was almost like twice as good if you put a one-to-one ratio

 within an acidifier than it was if it was 1/2 ratio.

 So, I guess that's -- that's my comments on the data.

 SECRETARY BRUCH: Yeah, thank you, Logan. I

 appreciate that review.

 Brian, did you have anything to add before I open it

 up?

 BRIAN CALDWELL: No. I think that you two have done

 a great job of covering those things.

 SECRETARY BRUCH: Okay, thank you. I'll turn it back

 over to the Chair.

 CHAIR POWELL-PALM: All right, any other questions or

 comments for Amy?

 (No response.)

 CHAIR POWELL-PALM: Okay, with that, we'll go to the

 vote. And for this, it's a petition to add it to the National

 List, so a "No" will keep it off the list, a "Yes" --

 MS. SMITH: Yeah.

 CHAIR POWELL-PALM: Oh, thank you, sorry. Got to

 read in. Sure. Yeah. 
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 So, the first motion, to classify potassium sorbate

 as synthetic. The motion was made by Amy Bruch and seconded by

 Mindee Jeffrey. Out of Subcommittee, 7 yeses and 1 absent.

 So, first, we will vote to classify it as a board.

 And we're going to start with Caroline, so the motion to

 classify potassium sorbate as synthetic. 

 MS. DIMITRI: Yes.

 CHAIR POWELL-PALM: 

 BD. MEM. JOHNSON: 

 CHAIR POWELL-PALM: 

 BD. MEM. CALDWELL: 

 CHAIR POWELL-PALM: 

Allison? 

Yes. 

Brian? 

Yes. 

Nate? 

 BD. MEM. LEWIS: Yes. 

 CHAIR POWELL-PALM: 

 BD. MEM. NANDWANI: 

 CHAIR POWELL-PALM: 

 BD. MEM. D'AMORE: 

 CHAIR POWELL-PALM: 

 MS. SMITH: Yes.

 CHAIR POWELL-PALM: 

Dilip? 

Yes. 

Jerry? 

Yes. 

Kayla? 

Amy? 

 SECRETARY BRUCH: Yes.

 CHAIR POWELL-PALM: Kim?

 BD. MEM. HUSEMAN: Yes.

 CHAIR POWELL-PALM: Franklin?

 BD. MEM. QUARCOO: Yes. 
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 CHAIR POWELL-PALM: Wood?

 BD. MEM. TURNER: Yes.

 CHAIR POWELL-PALM: Logan?

 BD. MEM. PETREY: Yes.

 CHAIR POWELL-PALM: And the Chair votes yes.

 SECRETARY BRUCH: Okay, 13 yes, zero no, zero

 abstentions, zero recusals, 2 absent. The motion passes.

 CHAIR POWELL-PALM: All right, so we're now going to

 move to the motion to add potassium sorbate to the National

 List at 205.601(e), synthetic substances allowed to use in

 organic crop production as insecticides. Out of Subcommittee,

 the motion was made by Amy Bruch and seconded by Logan Petrey,

 and we're going to start with Allison, full circle now.

 BD. MEM. JOHNSON: No.

 CHAIR POWELL-PALM: Brian?

 BD. MEM. CALDWELL: No.

 CHAIR POWELL-PALM: Nate?

 BD. MEM. LEWIS: No.

 CHAIR POWELL-PALM: Dilip?

 BD. MEM. NANDWANI: No.

 CHAIR POWELL-PALM: Jerry?

 BD. MEM. D'AMORE: No.

 CHAIR POWELL-PALM: Kyla?

 MS. SMITH: No.

 CHAIR POWELL-PALM: Amy? 
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 SECRETARY BRUCH: No.

 CHAIR POWELL-PALM: Kim?

 BD. MEM. HUSEMAN: No.

 CHAIR POWELL-PALM: Franklin?

 BD. MEM. QUARCOO: No.

 CHAIR POWELL-PALM: Wood?

 BD. MEM. TURNER: No.

 CHAIR POWELL-PALM: Logan?

 BD. MEM. PETREY: No.

 CHAIR POWELL-PALM: Carolyn?

 MS. DIMITRI: No.

 CHAIR POWELL-PALM: And the Chair votes no.

 SECRETARY BRUCH: Okay, that's zero yes, 13 no, zero

 abstentions, zero recusals, and 2 absent. The motion fails.

 CHAIR POWELL-PALM: And I'll hand it back to you,

 Amy.

 SECRETARY BRUCH: We have to --

 CHAIR POWELL-PALM: Oh, we do. The last motion, I

 just can't get enough of this stuff, motion to add potassium

 sorbate to the National List, at 601(i), synthetic substances

 allowed for use in organic crop production as plant disease

 control. We're going to start with Brian for this vote.

 BD. MEM. CALDWELL: No.

 CHAIR POWELL-PALM: Nate?

 BD. MEM. LEWIS: No. 
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 CHAIR POWELL-PALM: Dilip?

 BD. MEM. NANDWANI: No.

 CHAIR POWELL-PALM: Jerry?

 BD. MEM. D'AMORE: No.

 CHAIR POWELL-PALM: Kyla?

 MS. SMITH: No.

 CHAIR POWELL-PALM: Amy?

 SECRETARY BRUCH: No.

 CHAIR POWELL-PALM: Kim?

 BD. MEM. HUSEMAN: No.

 CHAIR POWELL-PALM: Franklin?

 BD. MEM. QUARCOO: No.

 CHAIR POWELL-PALM: Wood?

 BD. MEM. TURNER: No.

 CHAIR POWELL-PALM: Logan?

 BD. MEM. PETREY: No.

 CHAIR POWELL-PALM: Carolyn?

 MS. DIMITRI: No.

 CHAIR POWELL-PALM: Allison?

 BD. MEM. JOHNSON: No.

 CHAIR POWELL-PALM: The Chair votes no.

 SECRETARY BRUCH: Zero yes, 13 no, zero abstention,

 zero recusals, 2 absent. The motion fails.

 CHAIR POWELL-PALM: I think now we can lay potassium

 sorbate to rest for the agenda. Back to you, Amy. 
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 SECRETARY BRUCH: Okay, thanks for your help, Nate.

 With that, and multitasking, I'm never good at that,

 anyway, we are going to kick things off with our Sunsets. I

 will advance the slide.

 So, first up we have our Alcohols, and if Logan's

 okay with this, we can review them -- I'm seeing a headshake --

 we'll review them in tandem, but I'll read them both in -- into

 the record.

 So, first one that we'll be loading on and

 discussing, along with isopropanol is ethanol, so that's

 205.601 [sic], and it's at (a)(1)(i), ethanol. Go ahead -- oh

 sorry, and then I'll read the next one real quick, and then

 we'll go to Logan. So, the next one is 205.601 [sic], and this

 is (a)(1)(ii), isopropanol. Go ahead, Logan.

 BD. MEM. PETREY: Okay, so both of these are

 sanitizers and disinfectants used for harvest equipment

 cleaning, equipment cleaning, irrigation system cleaning. It's

 widely accepted internationally as approved synthetic for its

 use. These materials are considered non-toxic and are

 biodegradable, and are not used in quantities that could cause

 smog or pollution. There's broad support in the written and

 oral -- or written comment, we didn't have any oral comments in

 both spring and fall, for its relisting, and the commenters say

 that these materials are efficacious, they're cost effective,

 and easy to get in rural areas. 
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139

 One of the quotes, just to -- just to back that or

 one of the comments was growers mentioned that they

 specifically value allowance of these because these materials

 are generally available in rural areas and can be obtained

 easily when needed without waiting for ordering and delivering.

 CHAIR POWELL-PALM: Questions or comments for Logan

 on this material?

 (No response.)

 CHAIR POWELL-PALM: All right, we'll go to the votes.

 SECRETARY BRUCH: Sorry. The motion is to remove

 isopropyl -- isopropanol -- oh, maybe we'll start with ethanol,

 sorry. The motion is to remove ethanol from the National List,

 and that was motioned by Logan and seconded by Brian Caldwell.

 And remember, this is a yes vote removes it from the National

 List, a no vote maintains it on the list.

 CHAIR POWELL-PALM: All right, I think we're starting

 with Nate this time.

 BD. MEM. LEWIS: No.

 CHAIR POWELL-PALM: Dilip?

 BD. MEM. NANDWANI: No.

 CHAIR POWELL-PALM: Jerry?

 BD. MEM. D'AMORE: No.

 CHAIR POWELL-PALM: Kyla?

 MS. SMITH: No.

 CHAIR POWELL-PALM: Amy? 
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140

 SECRETARY BRUCH: No.

 CHAIR POWELL-PALM: Kim?

 BD. MEM. HUSEMAN: No.

 CHAIR POWELL-PALM: Franklin?

 BD. MEM. QUARCOO: No.

 CHAIR POWELL-PALM: Wood?

 BD. MEM. TURNER: No.

 CHAIR POWELL-PALM: Logan?

 BD. MEM. PETREY: No.

 CHAIR POWELL-PALM: Carolyn?

 MS. DIMITRI: No.

 CHAIR POWELL-PALM: Allison?

 BD. MEM. JOHNSON: No.

 CHAIR POWELL-PALM: Brian?

 BD. MEM. CALDWELL: No.

 CHAIR POWELL-PALM: And the Chair votes no. I'm so

 excited for this slate that's coming. All right next one.

 SECRETARY BRUCH: Okay, so that was zero yes, 13 no,

 zero abstention, zero recusals, 2 absent. The motion fails.

 And we're going to be voting for isopropanol next.

 So, the motion is to remove isopropanol from the National List.

 Motion was made by Logan Petrey, seconded by Amy Bruch.

 CHAIR POWELL-PALM: We're going to start the voting

 with Dilip.

 BD. MEM. NANDWANI: No. 
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141

 CHAIR POWELL-PALM: Jerry?

 BD. MEM. D'AMORE: No.

 CHAIR POWELL-PALM: Kyla?

 MS. SMITH: No.

 CHAIR POWELL-PALM: Amy?

 SECRETARY BRUCH: No.

 CHAIR POWELL-PALM: Kim?

 BD. MEM. HUSEMAN: No.

 CHAIR POWELL-PALM: Franklin?

 BD. MEM. QUARCOO: No.

 CHAIR POWELL-PALM: Wood?

 BD. MEM. TURNER: No.

 CHAIR POWELL-PALM: Logan?

 BD. MEM. PETREY: No.

 CHAIR POWELL-PALM: Carolyn?

 MS. DIMITRI: No.

 CHAIR POWELL-PALM: Allison?

 BD. MEM. JOHNSON: No.

 CHAIR POWELL-PALM: Brian?

 BD. MEM. CALDWELL: No.

 CHAIR POWELL-PALM: Nate?

 BD. MEM. LEWIS: No.

 CHAIR POWELL-PALM: And the Chair votes no.

 SECRETARY BRUCH: Zero yes, 13 no, zero abstentions,

 zero recusals, 2 absent. The motion fails. 
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142

 CHAIR POWELL-PALM: On the agenda we have noted that

 Mindee behind sodium carbonate peroxyhydrate [sic], but

 Franklin is going to be presenting her Sunsets.

 BD. MEM. QUARCOO: Thanks.

 CHAIR POWELL-PALM: We'll have Amy read it in real

 quick, and then hand it over to you.

 BD. MEM. QUARCOO: Okay.

 SECRETARY BRUCH: So, we are at 205.601(a)(8) sodium

 carbonate peroxyhydrate. Federal law restricts the use of the

 substance in food crop production to approved food uses

 identified on the product label.

 Go ahead Franklin, and thank you.

 BD. MEM. QUARCOO: So, it is registered as an

 algicide, disinfectant, and sanitizer, and for irrigation

 system cleaning. Its uses to which it's approved are target

 pests, algae, moss, and slime molds.

 When it comes to international acceptance, in some

 places it is -- it -- the -- are listed but the product itself

 is not. In other places, it's not listed.

 And then when it comes to the environmental issue --

 issues, there are emissions into the environment that could

 happen during production, formulation, and a few other

 processes. It can have -- it is listed as inable to have

 negative impacts on fish, birds, and bees but a closer read on

 that, it depends upon when it's created; that timing is chosen 
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143

 correctly it -- it will not have those impact -- impacts. So,

 there are a few of those non-target organism issues concerning

 that.

 The Subcommittee discussed it and some of the

 breakdown products, water and oxygen, some -- some of the

 people who made comments said that some of the breakdown

 products, water and oxygen, are more favorable than the

 elemental copper that has -- is a copper sulfate, which it is

 supposed to replace. And it's also said to have fewer

 corrosion issues.

 And then when you look at public comments, a number

 of comments were for releasing it with a couple of notable

 details. Some people talked about the fact that it -- it was

 not being used; even though it was supposed to replace copper

 sulphate it was not being used like it should, like in the

 number of people using it. And they said it was way better.

 It had way better performance than cooper sulfate.

 Let's see, so the Subcommittee finds it's well -- at

 the Subcommittee level it was considered compliant with Organic

 Food Production Act, and we are here to see what the whole

 board thinks.

 CHAIR POWELL-PALM: All right, well thank you very

 much for taking this on, on short notice. Really appreciate as

 a first year taking one for the team, and helping us out with

 this one. We appreciate it. 
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 Questions for Franklin? Nate, please go ahead.

 BD. MEM. LEWIS: I think it's more for the -- the

 Subcomittee; was there discussion about the annotation? I just

 want to put in the record I don't like that annotation because

 I think it applies to every pesticide that is governed by

 FIFRA, so is there any discussion about why we have that in

 this one? And if not, I just want to make sure that my dislike

 of it is recorded.

 CHAIR POWELL-PALM: Noted.

 SECRETARY BRUCH: Thank you for that comment. I

 don't -- I am just recalling our Subcommittee discussion; I

 don't think we tackled the annotation, how broad it is, but I

 think it's good to put that on the record. Okay.

 CHAIR POWELL-PALM: All right, no comments or other

 questions, we'll go to the vote, and were going to start with

 Jerry. Oh, please read the motion, sorry.

 SECRETARY BRUCH: Okay, motion to remove sodium

 carbon --carbonate peroxyhydrate from the National List. The

 motion was made by Mindee Jeffrey and seconded by Brian

 Caldwell.

 CHAIR POWELL-PALM: Jerry, your vote please.

 BD. MEM. D'AMORE: No.

 CHAIR POWELL-PALM: Kyla?

 MS. SMITH: No.

 CHAIR POWELL-PALM: Amy? 
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145

 SECRETARY BRUCH: No.

 CHAIR POWELL-PALM: Kim?

 BD. MEM. HUSEMAN: No.

 CHAIR POWELL-PALM: Franklin?

 BD. MEM. QUARCOO: No.

 CHAIR POWELL-PALM: Wood?

 BD. MEM. TURNER: No.

 CHAIR POWELL-PALM: Logan?

 BD. MEM. PETREY: No.

 CHAIR POWELL-PALM: Carolyn?

 MS. DIMITRI: No.

 CHAIR POWELL-PALM: Allison?

 BD. MEM. JOHNSON: No.

 CHAIR POWELL-PALM: Brian?

 BD. MEM. CALDWELL: No.

 CHAIR POWELL-PALM: Nate?

 BD. MEM. LEWIS: No.

 CHAIR POWELL-PALM: And Dilip?

 BD. MEM. NANDWANI: No.

 CHAIR POWELL-PALM: And the Chair votes no.

 SECRETARY BRUCH: Okay, ok that's zero yes, 13 no,

 zero recusals, zero abstentions, and 2 absent. The motion

 fails.

 Okay, next on the list, we have two listings for Wood

 here, and they're in regards to newspaper, so we'll tackle the 
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146

 review of both of them and vote just sequentially on that. So,

 we're at 205.601, synthetic substances allowed for use in

 organic crop production, we're at (b)(2)(i), newspaper or other

 recycled paper without glossy or colored ink. And we're also

 at (b)(2)(i),which is newspaper or other recycled materials

 without glossy or colored ink.

 BD. MEM. LEWIS: And at (c); at 601(c), compost

 feedstocks. That's because you said the same thing.

 SECRETARY BRUCH: Yes.

 BD. MEM. LEWIS: Okay.

 SECRETARY BRUCH: Okay.

 CHAIR POWELL-PALM: Go ahead.

 BD. MEM. LEWIS: Sorry. Great. So, so thanks for

 reading those. We have well-known material, newspaper and --

and other recycled paper. I think the biggest issue with this

 material has been how to -- that -- that the listing is glossy

 or colored inks, very difficult to actually manage around

 those -- around those issues in -- in a number of different

 contexts.

 I mean, it's -- the materials being used, newspapers

 being used for weed suppression or as a weed barrier, for

 example, you know, the -- the newspaper is breaking down and --

and getting -- getting -- degrading into soil. Similarly, on

 the compost side of things, the use of this material as a -- as

 a compost feedstock, as we discussed in our spring meeting, is 
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 that given the fact that municipal compost is allowed within

 organic -- organic production and could include newspaper that

 may have some of these inks, it just -- it becomes a difficult

 issue to -- to fully -- to fully understand sort of how this

 gets managed. And I think some of the -- some of the -- the

 comments from the community I think were recognizing that the

 listing that just that just focuses on glossy or colored inks

 and doesn't -- doesn't focus on the materials that are in those

 glossy and colored inks. The things that you talked about,

 Brian, yesterday, the -- the materials that are commonly in

 plastics and other -- other petroleum-based products sort of

 raises some -- some issues.

 So, you know, we had a, I think, a healthy discussion

 about this in the spring. The feedback from the community is

 pretty clear and we've heard from grower groups, we've heard

 from consultants, we've heard from trade associations, we've

 heard from certifiers, we've heard from nonprofits and

 coalitions, in -- in general that retailers, in general that --

that there's either support for or no opposition to the

 relisting of the material.

 There were some -- a lot of healthy and careful reads

 of the prior TR on this from 2017, just to sort of elevate some

 of the issues that are focus -- that -- that are that are part

 of some of these -- these inks that are -- that are of so much

 concern. There has been a call for a limited scope 
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 supplemental TR to sort of go deeper into this perhaps in the

 future, but

 no -- no opposition to relisting the material. Again, I want

 to be clear, that there was -- there were some that supported

 continuing to relist it and some that just simply did not

 oppose the relisting. I just want to be clear about that

 language.

 There was general feedback from certifiers that

 members are using this -- using this material in their --

 listing this in their OSPs. We -- we had asked some questions

 about sort of thinking about potentially annotating this

 differently; there was not really any feedback around changing

 this annotation or updating the annotation today. A lot of --

 a lot of focus on supporting growers who are small scale or

 transitioning who have really relied on this material. So, I

 think that outlines most of the issues, unless there's any

 questions.

 CHAIR POWELL-PALM: Questions for Wood? Brian,

 please go ahead.

 BD. MEM. CALDWELL: Yeah, thanks Wood. And I think

 that -- that issues with -- with paper and -- and recycled

 paper and newspaper goes a little bit farther than just what's

 in the inks. And now, I believe there are actually sort of

 plasticized paper that that -- that I get in the mail and those

 kind of places, and I'm concerned about the -- the materials 
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 that can be in them. I think it's -- there's a little bit of a

 Pandora's Box and -- and back in the day when I think this

 was -- this was, you know, originally put on the list and --

and even before the -- the NOP existed, it was allowed in

 organic systems in the -- some of the state certification

 programs and it -- newspaper and recycled paper was a different

 thing back then, it's -- really has evolved over time.

 So, I think my feeling is on this that -- that I

 would like us to -- to -- to hold the possibility of -- of

 adding an annotation to this through our new process, which I'm

 looking forward to, and seeing if we could deal with -- with

 the, you know, the thiolates and the other things that might be

 in there and just what might be considered plasticized paper.

 So, I just -- I just wanted to kind of put that out there.

 Another question I have, which I -- I should know the

 answer to, and I don't, and does this include cardboard? Is

 that -- is that under this?

 BD. MEM. LEWIS: It does.

 BD. MEM. CALDWELL: Okay, great. So, yeah that's --

 that's it. Thanks.

 BD. MEM. LEWIS: Thanks for that. I appreciate that

 clarify --that -- that additional -- that additional point.

 And I would say that the fact that the compost is on our work

 agenda, as well, gives us a great opportunity to really address

 some of those issues, at least in that particular part of the -
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 - that particular listing, so. 

 CHAIR POWELL-PALM: Other questions or comments?

 (No response.)

 CHAIR POWELL-PALM: All right. The compost work

 agenda can't come soon enough it seems like.

 BD. MEM. LEWIS: It seems like it.

 CHAIR POWELL-PALM: A lot of questions. Amy, I'll

 hand it to you to read the motion.

 SECRETARY BRUCH: Yeah, no problem. And thanks,

 Wood, for correcting me. I noticed we don't have a slide for

 the next listing, so I'm going to read that out of the book to

 make sure that's in the record.

 BD. MEM. LEWIS: Oh, yeah.

 SECRETARY BRUCH: But, we do have this listing so

 we're going to be voting on 205.601(b)(2)(1) right now, the

 motion to remove newspaper or other recycled -- or other

 recycled paper without glossy or colored things from the

 National List. The motion was made by Wood Turner, seconded by

 Mindee Jeffrey.

 CHAIR POWELL-PALM: And we're going to start the vote

 with Kyla.

 MS. SMITH: No.

 CHAIR POWELL-PALM: Amy?

 SECRETARY BRUCH: No.

 CHAIR POWELL-PALM: Kim? 
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 BD. MEM. HUSEMAN: No.

 CHAIR POWELL-PALM: Franklin?

 BD. MEM. QUARCOO: No.

 CHAIR POWELL-PALM: Wood?

 BD. MEM. TURNER: No.

 CHAIR POWELL-PALM: Logan?

 BD. MEM. PETREY: No.

 CHAIR POWELL-PALM: Carolyn?

 MS. DIMITRI: No.

 CHAIR POWELL-PALM: Allison?

 BD. MEM. JOHNSON: No.

 CHAIR POWELL-PALM: Brian?

 BD. MEM. CALDWELL: No.

 CHAIR POWELL-PALM: Nate?

 BD. MEM. LEWIS: No.

 CHAIR POWELL-PALM: Dilip?

 BD. MEM. NANDWANI: No.

 CHAIR POWELL-PALM: Jerry?

 BD. MEM. D'AMORE: No.

 CHAIR POWELL-PALM: And Chair votes no.

 SECRETARY BRUCH: Okay, zero yes, 13 no, zero

 abstentions, zero recusals, 2 absent. The motion fails.

 Okay, we do have it, yeah. Okay. So, we're going to

 be voting on 205.601(c), and this is as compost feedstocks,

 newspaper or other recycled paper without glossy or colored 
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 inks. So, the motion to remove newspaper or other recycled

 materials without glossy or colored inks from the National

 List, motioned by Wood Turner, seconded by Jerry.

 CHAIR POWELL-PALM: And were going to start with you,

 Madam Secretary.

 SECRETARY BRUCH: No.

 CHAIR POWELL-PALM: Kim?

 BD. MEM. HUSEMAN: No.

 CHAIR POWELL-PALM: Franklin?

 BD. MEM. QUARCOO: No.

 CHAIR POWELL-PALM: Wood?

 BD. MEM. TURNER: No.

 CHAIR POWELL-PALM: Logan?

 BD. MEM. PETREY: No.

 CHAIR POWELL-PALM: Carolyn?

 MS. DIMITRI: No.

 CHAIR POWELL-PALM: Allison?

 BD. MEM. JOHNSON: No.

 CHAIR POWELL-PALM: Brian?

 BD. MEM. CALDWELL: I abstain on this one.

 CHAIR POWELL-PALM: Nate?

 BD. MEM. LEWIS: No.

 CHAIR POWELL-PALM: Dilip?

 BD. MEM. NANDWANI: No.

 CHAIR POWELL-PALM: Jerry? 
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 BD. MEM. D'AMORE: No.

 CHAIR POWELL-PALM: Kyla?

 MS. SMITH: No.

 CHAIR POWELL-PALM: And the Chair votes no.

 SECRETARY BRUCH: Okay, zero yes, 12 no, 1

 abstention, zero recusals, 2 absent. The motion fails.

 CHAIR POWELL-PALM: Okay.

 SECRETARY BRUCH: All right, Logan, we're up -- up to

 you next, so were looking at 205.601(b)(2)(ii) plastic mulch

 and covers, (petroleum-based other than polyvinyl

 chloride(PVC)).

 BD. MEM. PETREY: Okay, all right, this material is

 also listed in OFPA under 6508(c)(2), the crop management --

the prohibited -- prohibited crop production practices and

 materials under crop management, and it states that that

 plastic mulch is prohibited unless it is removed at the end of

 the growing season, and so therefore it is also found at

 205.206(c)(6) "Plastic or synthetic mulches: provided, that,

 they are removed from the end -- from the field at the end of

 the growing or harvest season."

 Plastic mulches. They, and covers, they have

 multiple functions. Examples: weed management, soil warming,

 insect management, disease management, slow moisture and

 nutrient retention, and frost protection. Crops predominantly

 grown in plastic culture are high-value vegetable and fruit 
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 crops. Some of these organic crops are almost exclusively

 grown on plastic beds, including tomatoes, peppers, cucurbits,

 egg plants, and strawberries.

 In public comments, many growers, certifiers, and

 other organic coalition groups started -- stated the current

 essentiality of this material, along with some with concern of

 the dependency of this material. One of the commenters from

 the fall written comments states, "We support the continued

 listing of plastic mulch and covers while we also appreciate

 the desire to move away from disposable plastic products in

 organic production."

 International acceptances. Canadian standards have

 similar annotations of removal and restriction of PVC. And the

 EU.

 There's two listings for the plastic mulches. You

 have one similar to our mulch, and is CSNEN13655. And then

 there has been a new one, I guess, since 2018, that actually

 does allow the biodegradable mulch films for use in organic and

 horticulture, but requirements for test methods. And so that's

 really on the biodegradable side, but I didn't want to add that

 in.

 So, environmental concerns for this product.

 Environmental concerns of this product includes soil and water

 contamination, and the limitations to recycling. Because the

 debris of plastic mulch and covers is very dirty at the end of 
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 the season most is not recycled.

 Also, we have heard from some commenters that there

 are not many recycling facilities that can handle this

 material, which also adds to the limitations. There's much

 concern of -- in the community of the breakdown of this

 material. Practically, plastic mulch in the soils and the

 water. One of the commenters stated, "In essence, this is a

 lose-lose situation, whereby the use of mulch increases plastic

 contamination in our environment, but the delisting of the

 material would be a serious consequence to many organic

 growers. For human health there is concern for PFOS and

 thiolates contamination on food grown on plastic mulch.

 In the written comments this fall, there was one

 comment duplicated more than 10 times, and another duplicated

 about 10 times; both comments opposed the relisting of plastic

 mulch, stating the need to remove microplastic contaminations

 from food. One of those comments did list -- did list five

 proposed implementations for the Board. One of them was to:

 place the entire class of PFOS chemicals on the Prohibited

 Substance List; to phased out fluorinated plastic containers

 and packaging; phase out all fossil fuel-based plastic

 containers and packaging; phase out all plastic mulch and traps

 for growing; compile and post in Federal Register a list of all

 inert ingredients used in organic and begin evaluating them.

 Also, in that comment listed a study of the PFOS 
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 chemicals found in organic kale. I did read the study. I did

 look at that. What I did notice is -- is the commenters were

 right; there is -- there was no -- there wasn't a significant

 difference between organic and conventional kale, but there was

 a significant difference between kale that was in packaging and

 loose leaf kale. And kale is not predominantly grown on

 plastic mulch, and so but there was no -- these -- these

 samples were pulled straight from the grocery store without

 knowing the grower practices, so we don't know whether they

 were grown in plastic mulch or not. This is strictly -- the

 only identifier I could find was the packaging material. So, I

 encourage people when conducting these straw studies to

 identify commonalities in their review of things, like plastic

 packaging.

 Alternatives. Based on this material, because it has

 many functions, it is likely that different alternatives would

 be needed for each function. For example, cultivation would

 not assist in soil warming or provide insect reflective

 barrier. More hand weeding would not increase water nutrient

 or soil retention. Biodegradable mulch is understood to

 achieve many of these functions, but the industry does not yet

 have a material that complies with the NOSB recommendations.

 A couple of commenters and stakeholders regarded

 alternatives, stating, "We support research in the most cost-

 effective labor methods of mulching that could be used in place 
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 of BBMF or of plastic mulch. Such research should consider

 separately weed suppression and soil warming for which

 alternatives may be different. Organic no-till and cover crop

 and intercropping practices are in the scope of research.

 Another commenter said, "We would like the industry

 to promote cultivation practices over plastic covers for weed

 management, but this is not a viable option for all operations.

 Also, plastic much or plastic covers used as mulch for heat

 loving plants do not have good alternative. We support more

 work being done to identify real alternatives to ensure that

 biodegradable product will not contribute to the contamination

 of soil and natural resources."

 Many of the crops I listed at the beginning have

 fruits that are subject to being easily bruised or scratched,

 that have vining growth habits that spread and prohibit mid to

 late season cultivation, or are trellis on structures that are

 too tall for equipment -- for cultivation equipment to enter

 the field.

 Other international standards have similar

 annotations to plastic mulch, or some do have the biodegradable

 mulch.

 These Crop Subcommittee -- the Crop Subcommittee was

 in alignment with many commenters and stakeholders. There's an

 understanding of the industry's dependence that is of

 frustration in the lack of progress made in the reducing 
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 dependency of this material. In general, the comments were

 those that were in support were growers and grower groups, zero

 percent were -- of consumers were in support, and then of the

 opposition zero percent of them were growers, and almost all

 were consumers or advocacy groups.

 And I'm ready for -- to discuss.

 CHAIR POWELL-PALM: Who the -- whose got a question

 for Logan? Let's start on this side, we'll work our way

 around. Brian, please go ahead.

 BD. MEM. CALDWELL: Logan, thanks so much for

 reviewing that. You did a great job and -- and I think you --

you summed up the issues really well. And I guess I just want

 to repeat what I said on the -- the newspaper one, that -- that

 I think I -- I think and hope we can use the -- the annotation

 process to -- to start a giant wheel slowly moving maybe

 towards dealing with this -- this big environmental problem

 that we're all realizing is -- is a big one. So, thanks.

 CHAIR POWELL-PALM: Let's go to Carolyn next.

 MS. DIMITRI: I mean, I want to first say I think

 it's kind of funny that Logan, when you summarized it, you said

 like the growers were supporting and the consumers were against

 it, but think of all the packaged plastic products consumers

 buy, and I find that to be like so contradictory. It's like I

 can buy the plastic, but the farmer can't use it on the farm.

 So, there's that one thought. 
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 And then the other one is, like I think that we 

 should also stop thinking about the ability to recycle plastic

 as a solution and a direction forward. And I -- I know it's

 discussed in here, so I just wanted to throw that out for the

 conversation. And thank you for taking on this complicated

 topic.

 BD. MEM. PETREY: And actually, I kind of skipped

 over one of the comments, and I was also going to say, based on

 the study referenced talking about the PFOS and the kale, I

 just encourage the consumers to not buy in plastic, you know,

 while that's still an option; buy the loose-leaf kale and --

and, you know, if that's your concern. So, I mean I -- I agree

 with you.

 CHAIR POWELL-PALM: We can go Wood and then Amy.

 BD. MEM. TURNER: I think it's hard to separate this

 whole discussion from the biodegradable -- biobased mulch issue

 that we've wrestled with, and I -- I just have come to the

 conclusion personally that -- that if we -- I'd rather see the

 problem. As I said before, I'd rather see the problem than

 hide the problem or biodegrade the problem and not know what

 the heck is going on, so I'd rather see the problem and have us

 all face it as a community.

 I hope that the abstentions from -- in the vote in

 Subcommittee sent the message to the community as a whole that

 this is a big issue. We all should be wrestling with this 
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 issue. I -- I think the comments -- the number of comments

 reflected that. So, anyway, that's my question -- that's my

 point.

 CHAIR POWELL-PALM: Kyla, then Jerry. Or sorry, Amy.

 I'm sorry, go ahead.

 SECRETARY BRUCH: That's okay.

 Logan, thanks for your work on this difficult subject

 matter. I like the question that was added this go around to

 learn about alternatives and hear from our community, and you

 did a good job summarizing those. I think it did push people

 to think of alternatives outside of biodegradable, biobased

 mulch. We heard, and I'd love to explore deeper, some of those

 challenges with the alternatives that are out there. You know,

 weeds in row I heard it was a big one. we can handle the weeds

 in the middle of the row; weeds in row are a problem. And

 universally, that's a challenge with anything you grow in a row

 in organic farming, whether you're a soybean farmer, whether

 you're a carrot farmer, et cetera.

 But I actually wanted to turn it back over to you,

 Logan, for a little more floor time because you do currently

 grow in a very challenging environment, in the south, and you

 grow crops, fruits -- or sorry, mostly veggies, and I don't

 believe that you use plastic on those --

 BD. MEM. PETREY: No.

 SECRETARY BRUCH: -- so, I'd --
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 BD. MEM. PETREY: No, we don't

 SECRETARY BRUCH: I'd love to hear you just briefly

 talk a little bit more on operations on your farm.

 BD. MEM. PETREY: Sure. Okay, so yeah, we have a

 variety of vegetables. We do have kale, for example, and so --

 so the ones that I listed that were predominantly grown on

 plastic mulch we actually do not grow. We do grow watermelons

 in some regions, and they are on plastic mulch, but the

 vegetables that we grow like kales, onions, carrots, I mean,

 you could not grow carrot and plastic mulch. And there are

 other, like the herbs, they're grown some on plastic mulch,

 but -- but not what I would say more necessary to be on mulch.

 We don't grow tomatoes, and we don't grow eggplants, we don't

 grow those types of things that are trellised, or that have,

 you know, like strawberries that have fruits that are

 sensitive. So, yes we do grow some of the crops that some

 people do grow on plastic. I think that possibly the growers

 grow them on plastic because it's part of their rotation, and

 that is their -- their growing standard, and so they do grow

 those things on plastic to -- to match it with the other things

 that really do need it.

 And then you're right, the in row weeds is a problem

 in every single crop. We grow corn, too, and so the way we --

 we do it in corn is we "throw dirt" is what we say, you know,

 on layby application -- or layby cultivation. We throw four, 
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 five, six inches of dirt, whatever we can at the base of the

 plant, so we're really burying those in row weeds at the -- at

 the last, you know, chance that we can get in. Soil -- corn is

 pretty resilient and can handle that. And so same with --

 maybe with like soybeans, we grow at Edamame, so kind of the

 same thing there.

 A lot of these veg crops can't handle -- they're --

 they're more sensitive, and so the -- there's a lot of root

 diseases. You know, there's Pythium, and there's Phytophthora,

 and then there's also you have Ralstonia, so there's a lot of

 things, soil-borne diseases that can be stimulated on those

 high value crops there. So, yes we grow some veg crops. We

 spend a -- quite a bit of money on hand-weeding. We also have

 the available labor because we, in the Southeast we have The

 H2-A program, and so we have -- we have available labor for 10

 months out of the year, and so we do have a significant amount.

 So, we have the labor for a hand-harvesting, and then they're

 also there to be able to weed when necessary. So, that's how

 we handle

 SECRETARY BRUCH: Yeah, thank you. I appreciate

 that. And I -- wanted to know, I didn't see too many

 commenters mention this, but there's a ton of innovation. We

 were doing the cultivation in the past; this year we were doing

 a tine weeder, so instead of throwing a lot of dirt, we were

 doing fractional -- fractional movement of dirt, but just right 
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 on top of the crop. There's propane flamers. There's lasers;

 we talked about that I think last time and they're pretty

 expensive right now, but they are actually getting deployed in

 organic commodity crops right now just to handle weeds because

 they're a challenge.

 Two things I thought were two solves. One, the

 strawberry growers mention about fungicide and that the

 plastic -- or sorry fungus, so the plastic prevents that

 strawberry touching the ground and -- and interchanging with

 the fungus. And then the other thing that's a challenge is

 probably the -- the irrigation systems in some --

 BD. MEM. PETREY: Oh, yeah.

 SECRETARY BRUCH: -- of these areas.

 In California where they're using just admitters and

 things like that, are hard to navigate with tillage so --

 BD. MEM. PETREY: That's right, cultivation for --

 yeah, that's --

 SECRETARY BRUCH: Yeah.

 BD. MEM. PETREY: -- I've wrapped one up before.

 Yeah, that's not fun.

 SECRETARY BRUCH: Yeah. So, I think there's some

 easy wins here with, you know, applying other techniques and

 then some challenges still --

 BD. MEM. PETREY: Yeah.

 SECRETARY BRUCH: -- to solve in these areas they're 
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 using plastic, so.

 BD. MEM. PETREY: Yeah, but the laser weeder is

 exciting. If it could definitely reduce costs of -- of that

 machine' it's about 1.5 million, so.

 SECRETARY BRUCH: Yeah.

 BD. MEM. PETREY: Yeah, it -- it's a lot, but it is

 exciting. Everything's expensive up front, so maybe that can

 move along.

 And propane, we do use propane burning. You wouldn't

 be able to use that in plastic molds.

 SECRETARY BRUCH: No.

 BD. MEM. PETREY: Wouldn't recommend that for

 plastic, but yeah, we use -- we strictly use that, you know,

 right before germination to make that sterile seed bed. So, it

 does have its, you know, its window. It is very early and it's

 not in any kind of, you know, in the season, but it can -- it

 can significant -- you know, significantly reduce weed control

 if people are wanting to move away from the plastic mulch, you

 know, implementing that part of --

 It's -- it's got to be a whole strategy. You know,

 the -- the plastic mulch is there the entire season, and so

 it's providing kind of a blanket weed control method, where if

 you're going to substitute it with other weed control methods,

 there's going to have to be a multiple step wise to do.

 SECRETARY BRUCH: Um-hum. Thank you. Appreciate it. 
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 CHAIR POWELL-PALM: Allison.

 BD. MEM. JOHNSON: Thank you, Logan. That it's

 really helpful to hear sort of in practice what this looks

 like.

 I'm sitting here wrestling with the -- kind of the

 true cost of food idea, and that as long as plastic mulch is

 available to someone, it's going to be really hard for someone

 else to decide to take the extra steps to build that whole

 integrated system that will get us away from the plastic mulch,

 eventually. So, I feel like we're coming up at a time where

 were going to have to rip off the band-aid and I hope our

 community is taking this discussion really seriously. I hear

 so much discomfort with how much plastic is in our food system,

 and a lot of interest in looking for solutions, and so I'm --

I'm feeling like it's time for this to at least move towards

 coming off the list so that we have a level playing field and a

 really strong incentive to all put our heads together and come

 up with a solution.

 BD. MEM. PETREY: Um-hum.

 CHAIR POWELL-PALM: I'm going to go to Kyla, and then

 I'm going to force Jerry to be on the spot for this discussion.

 MS. SMITH: Yes, thanks Logan for your work on this

 topic, and for everybody's comments.

 My concern a little bit about what Allison had

 brought up and Carolyn brought up, is that, you know, plastic 
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 mulch is the only place that we really see plastic on the

 National List, and there's plastic used all throughout the

 supply chain, right. And so, I -- I guess I'm just concerned

 that of the fairness of if we annotate then that all is falling

 only in one sort of sector of plastic usage. Like if we would

 annotate to like not -- to not have PFOS or whatever all the

 things, but that does not cover packaging, and drip tape, and

 bail wrap, and transplant containers, and all the other uses of

 plastic, and so it feels like we're -- or if we delist it, then

 again, we're delisting this one thing, but it's prevalent, and

 so I'm -- I don't -- I know that the community is wanting to

 see some solution here, and it's just going to be an

 interesting conversation. So, I don't know exactly how we

 tackle all that but it's -- there's this one listing and

 there's a lot of plastic that's not covered by this one

 listing.

 CHAIR POWELL-PALM: I wasn't kidding, Jerry.

 BD. MEM. D'AMORE: Are you reading my body language

 over here?

 CHAIR POWELL-PALM: Well, I think you have, I think,

 on the record stated several times that and -- and I -- and

 stop me if I'm interpreting --

 BD. MEM. D'AMORE: Do -- do me favor, add it when I

 don't do it, okay? Let me --

 CHAIR POWELL-PALM: Please go ahead. Thank you. 
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 BD. MEM. D'AMORE: Thank you.

 CHAIR POWELL-PALM: Yes.

 BD. MEM. D'AMORE: Thank you very much.

 First of all, Logan, I -- I admire the great work. I

 agree with all that you've said, which already says a little

 bit about what I'm going to say.

 Where I have my problem, and I thought between

 Allison and -- and Kyla that it would get said, you know,

 ripping the band-aid off and then how broad this problem is

 and -- and people looking to get something done, after

 agonizing over this for a full semester, matter of fact I've

 agonized over this as much as I have some of my own Sunsets, is

 we're not the people to do it. I'm sorry. we -- we, this

 organic world, is not the group that can do anything. We

 cannot move the needle. If we -- if we penalize our organic

 community by taking this away from them, I don't want to

 even -- even try to guess what the cost would be, but it's

 going to be somewhere between 300

 and -- and much more of a percent, but if we do that, we're

 going to -- and take it away from our growers, what we're going

 to have leftover is still 97 percent of all the plastic that

 goes everywhere because until we can move the conventional

 world, our three to 5 percent is meaningless. We will have no

 negotiation -- no -- no strength, no teeth vis-à-vis the

 manufacturer, no incentives. 
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 So, yeah, I -- I and -- and the devil on this one is

 everything you said about the good side of plastic is

 absolutely true. It's marvelous stuff. Thank you.

 CHAIR POWELL-PALM: Dilip, did you have -- do you

 want to go?

 BD. MEM. PETREY: May I answer that really quickly?

 CHAIR POWELL-PALM: Please. Absolutely.

 BD. MEM. PETREY: Just a little comment.

 CHAIR POWELL-PALM: Yes.

 BD. MEM. PETREY: Not only -- okay, so yes, you're

 right, it's going to be very significant to the organic

 growers. But, also to mention that other international farmers

 are using this, too, and I don't understand the equivalency

 and -- and how that would be recognized, but more than likely

 were going to disadvantage, you know, the -- the domestic

 growers and still receive product from European growers or

 Canadian growers or anything, you know, of, you know, Latin

 American growers that are grown on plastic with this product.

 BD. MEM. D'AMORE: Yeah.

 BD. MEM. PETREY: And we're going to consider it

 organic.

 BD. MEM. D'AMORE: Okay, permit me to follow up on

 that. I had the great opportunity or the luxury to visit and

 look at plastic mulches on farms in France, Italy, and Germany

 this summer and you're absolutely right, they -- they wrestle 
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 with it other ways. They -- they advocate completely

 differently than we do, which is you got to roll it up and take

 it away after each crop. they -- they use it to the second and

 third year, which of course is -- is a lot of work, too. So,

 but you're right, I -- I think the -- well, I'm -- the whole

 world is wrestling with this product that is both evil and --

and highly functional. Thank you.

 CHAIR POWELL-PALM: Go Dilip, and then Nate.

 BD. MEM. NANDWANI: Well, this is a comment only, not

 a question. Thanks, Logan, again. This is a very complex

 issue. one of the complex issue as a board we are, you know,

 struggling or juggling.

 I also understand we have come a long way, you know,

 from 2001 when we had these regulations that came in Federal

 Register and we had no -- not many crops organic seeds were

 available and now in 2023, 21 years, we have almost in most of

 the crops organic seeds. Likewise, we have lot of other

 innovations, so I believe until then we have 100 percent BBDM,

 biobased biodegradable mulches available, or we have any other

 solution. Until then, I -- I think we will be still, what you

 know Wood said, probably live with this one. We understand the

 issue of the farmers problem and environmental issues, but

 until then.

 Yeah, that's all I wanted to make, comment. Thank

 you, Nate. 
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 CHAIR POWELL-PALM: Thank you. Thank you very much.

 Nate, please go ahead. Okay, Kim, and then Franklin.

 BD. MEM. HUSEMAN: So, I've got two -- two things

 here. So, if I'm reading this correctly on the justification

 for the vote, removing plastic mulching covers from the

 National List, but also remove the prohibition of PVC-based

 mulch; is that --

 BD. MEM. PETREY: That's my understanding, yes,

 because not in the other -- wherever it's listed in the OFPA

 and then 205.206, the restriction for PVC is not there, so.

 BD. MEM. HUSEMAN: Okay. I think I saw that during

 Subcommittee there was four abstentions for this.

 BD. MEM. PETREY: You should have seen it before.

 BD. MEM. HUSEMAN: All right, so at the end of the

 day, let's all abstain so the --

 BD. MEM. PETREY: (Indiscernible) the Ying and the

 Yang. Let's just say that's not in that category --

 BD. MEM. HUSEMAN: So, Madam Secretary, if everyone

 were to abstain, what happens? I'm just curious.

 SECRETARY BRUCH: (No audible response.)

 BD. MEM. HUSEMAN: You know, does -- does that then

 reduce the two-thirds by the -- like the more people that

 abstain, that reduces the two-thirds clearance, right?

 SECRETARY BRUCH: Right. I mean, in general, an

 abstention is somewhat equivalent to an absence. 
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 BD. MEM. JOHNSON: Right.

 SECRETARY BRUCH: Um-hum.

 BD. MEM. HUSEMAN: Okay, so just pointing those two

 pieces out, I think we all struggle with this, there's the

 Ying, and the -- and the reduction aspect of it, so trying to

 find incentives. You know, this is where the community, you

 know, they're -- a plastic reduction pledge, I don't know

 similar to a carbon reduction pledge, right? Maybe they --

 there's a -- an offset, you know, in -- in some form that, you

 know, looking at the community make a, I don't know, something

 of that. But, you know, I think that's the challenge.

 The state of Colorado has removed plastic bags from

 grocery stores. It's the new version of a dime bag, but as of

 January, those are actually to be completely removed, and it's

 75 cents to buy a reusable bag in the state of Colorado. So,

 you should have seen me clean out my purse before I went to

 Whole Foods, just down the road here, and people thought that I

 looked weird because I'm shoving stuff in my purse as I leave

 because I mean it's just -- it's a -- it's a state of mind.

 So, I -- I think if we reiterate it's a state of mind "what can

 we do" I might have not dumped the clamshell of raspberries

 into my purse, but I did not, you know, use a plastic bag.

 So, I guess when I'm looking at that and thinking of

 offsets, I'm going to challenge our community. When we -- we

 aren't able to get there yet, what are our offsets and how do 
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 we start tracking those offsets?

 CHAIR POWELL-PALM: Franklin.

 BD. MEM. QUARCOO: I do agree that the use of

 plastics is very important. Farmers need it. It just is not

 consistent with our image as stewards of the environment and

 all of that. So, my question is, what can be done to

 incentivize those conducting research so we don't keep kicking

 the can down the road? Because it will always -- farmers will

 always need something that can help suppress weeds, you know,

 this will not change, and it's been on the table for a while.

 What can we do to incentivize research, so we don't keep

 following the same "okay, let's talk about it some other time."

 CHAIR POWELL-PALM: Logan, please go ahead.

 BD. MEM. PETREY: Yeah. I think -- I think that's

 going to --that would be an interesting -- because there is

 research going on with the biodegradable mulch that, you know,

 done in Washington State, so -- so that is going on. But if

 you're going to take it for like cold -- like substituting

 cultivation, it almost has to be a proposed research that

 includes all of the functions that plastic mulch does, and then

 you've got to implement this IPM that does all of those things;

 otherwise, the grower is going to say, okay, you gave me a weed

 control method, but you didn't give me, you know, insect

 reflective barrier treatment, or whatever, or soil retention.

 I mean there's -- there's just a lot of things, and I 
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 think it would have to be something that's kind of inclusive

 for -- for all of them, for the grower to -- to move towards

 incentivize. Because at the end of the day, the grower is

 still going to say, well, I'm getting -- still getting more of

 the plastic mulch.

 CHAIR POWELL-PALM: Do you have follow-up with that,

 Franklin?

 BD. MEM. QUARCOO: So, just the biobased, what --

 whatever percentage we get to, I'm not saying let's not use

 any, but -- but even if it's biobased, does it really work for

 the farmers? What percentage does it get to? There has to be

 a direction where we see that we are weening ourselves off this

 product.

 CHAIR POWELL-PALM: Um-hum.

 BD. MEM. QUARCOO: I'm just uncomfortable with

 saying, oh, it's a big problem, we need it, and we just keep

 going.

 BD. MEM. PETREY: You know, when we had Liz on here,

 she did mention that she would want to move to it, so there --

 there is a -- you know, the biodegradable mulch. If we can get

 to whatever that product is that, you know, the community

 agrees upon is safe, I think that there is definitely an

 incentive and growers want to go that route if we can ever find

 that material.

 CHAIR POWELL-PALM: I would just like to note here 
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 how important that small vegetable grower voice is on the

 Board, and not having the voice right now is really damaging,

 so just to make that noted for the record.

 I think it's Brian, and then Nate, and then Wood --

 or no, Brian, Jerry, then Wood; am I getting that right?

 Sorry, folks. And Jerry, what am I getting that right? Sorry

 folks, I started writing it down only after like everyone's

 hands started going up.

 BD. MEM. CALDWELL: Thanks. This is -- this is a

 great conversation. I just want to put out there that -- that

 personally, I -- I am definitely not in favor of -- of taking

 plastic mulch off the list at this point. But even though

 organic is a small percentage of all the plastic mulch that's

 used, as Jerry pointed out, I think we can lead the way here.

 I like what Kim said, there may be other kinds and -- and

 Franklin, other kinds of incentives and -- and pushes that

 will -- will, you know, make us go in the right direction.

 So, just wanted to second all those -- all that

 thinking and -- and anybody in the in our stakeholder

 community, we all need, you know, all the best thoughts on this

 one, because it's a big one.

 But my last -- my quick question, though, in addition

 to that is, where is it -- where is the requirement for

 removing the -- the mulch at the end of the growing season?

 I -- I missed that, Logan. 
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 BD. MEM. PETREY: That's okay. It's under 205.206,

 and under OFPA.

 SECRETARY BRUCH: Okay.

 CHAIR POWELL-PALM: It's in the pest control section.

 BD. MEM. CALDWELL: Oh, okay, great. Thank you.

 BD. MEM. PETREY: Um-hum.

 CHAIR POWELL-PALM: Nate, please go ahead.

 BD. MEM. LEWIS: Just some ideas for consideration.

 One would be to evaluate the potential for kind of a hierarchy

 approach to weed management, so that you can use plastic mulch

 when mechanical cultivation is not sufficient we use that

 oftentimes and the stepwise approach to pest management, where

 you have to prevent them and then you can use natural

 materials, then you can use synthetic materials, so building

 something like that into the weed management standard might be

 a place to make a -- a step forward.

 And then we see with the PVC restriction the

 invitation already allows for further restricting the types of

 materials, and so if we can get some additional information

 around PFOS or what, you know, whatever the -- the concern du

 jour is about the brief period it is in the soil and the

 potential for leaching, we could consider expanding that list

 of annotations.

 CHAIR POWELL-PALM: Jerry, please go ahead.

 BD. MEM. D'AMORE: Well, I can go home and have my 
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 wife tell me I'm a stubborn old man, but I want to -- I want to

 run this by the team one more time, and maybe I can make it --

cut it all short and say, I think we should go find the -- the

 EPA and tell them what needs to be done here. Because again,

 the -- the strength and the and the wherewithal to -- to move

 this needle is not going to come from 3 percent of the plastic

 on the ground. Thank you.

 CHAIR POWELL-PALM: Wood.

 BD. MEM. TURNER: I was just going to respond to

 Franklin's comment about what -- how do we incentivize this

 research priority?

 Well ,it is on the list. We could take everything

 else off the list and let it be the only one.

 CHAIR POWELL-PALM: Uh-huh.

 BD. MEM. LEWIS: I mean, it's -- it's that big of a

 deal.

 CHAIR POWELL-PALM: I don't hate that. Yeah.

 BD. MEM. LEWIS: It's that big of a deal. So, I mean

 again, I just want to make sure, back to your point, Kim,

 because I was an abstention in the Subcommittee, I hate this

 material. I -- I hate that it's I -- I hate and don't believe

 that there's no recycling potential for this material, I just

 simply refuse to believe that, but I -- I refuse to kill

 organic with this vote, so.

 AUDIENCE MEMBER: Well said. 
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 CHAIR POWELL-PALM: As it settles down, I have so

 many things to say that I'm going to try to be very brief.

 In -- in kind of triangulating between Kim's point about

 plastics more on the consumer side, I really want to elevate

 what Carolyn said, that -- and I -- and I don't mean to -- to

 take the farmer position too hard, because I think it's

 important that we give due consideration, but this feels like a

 really cheap shot. That there is so much plastic that we

 farmers are always easiest to blame, and because we have very

 little political power, it's going to be a lot harder to tell

 consumers, no, you don't get your bags. Have you seen like

 uproars over the plastic bags around the country? If you tell

 farmers, who are 2 percent of the population, and then we are 1

 percent of that 2 percent in organic, we will never be able to

 effectively fight back against this. And we're, also to

 Jerry's point, never going to really make a dent with it's this

 is a virtue signal if we were to delist this material.

 I realize and I so appreciate the passion that

 everyone's bringing to this. Plastics are a problem. I would

 elevate Mike Dill's swag game over plastic sucks, but sometimes

 it's necessary. And I think when we look to figuring out how

 do we take to a heart the value and the vision of TOPP, where

 we're trying to get producers to go organic, and if we say that

 you're going to have one very major hammer not in your toolbox

 if you go organic, or if you're currently organic that toolbox 
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 is going to get taken away, I think we are just aiming for the

 wrong target. And I realize that, again, it is such a problem,

 but I would challenge us to look to, and I love this event

 every year, look to Expo West and tell me about plastic, and

 tell me you're going to go to each of those very innovative CPG

 companies, who have plastic packaging and say no more. That's

 a much harder lift. Been telling us farmers that you're going

 to take away our tools. And I don't use plastic, so I speak

 proverbially and as the royal "we," but it is something that I

 think to challenge ourselves to think that if we're going to

 pick a fight, pick it with a big guy. Don't just go after the

 farmer.

 Any other thoughts? One question for you, Logan.

 BD. MEM. PETREY: You finished that really well, but

 go ahead.

 CHAIR POWELL-PALM: I think we hear a lot about

 needing to help medium and small sized farmers, and I -- I

 wanted to just elevate what you said a little bit with labor.

 But I don't know if it's business sensitive information, but

 could you give us a rough idea as to how many employees your

 operation employs?

 BD. MEM. PETREY: Sure. So, we usually work with a

 weeding group at least 30 people.

 CHAIR POWELL-PALM: Um-hum.

 BD. MEM. PETREY: And then sometimes we can use the 
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 entire crew, which can be upwards of 100.

 CHAIR POWELL-PALM: Um-hum.

 BD. MEM. PETREY: And you're looking at, depending on

 how good the cultural prices are and the weather has been, you

 know, good with the cultivation and whether it's been able to

 dry out, all of these things, the weed, seed bang, you can look

 to spend around $300 an acre to even, you know, $1500 an acre

 on that, and so it gets -- it gets quite costly for that.

 And also, to mention the small growers. During the

 presentation -- the presentations that we saw yesterday and all

 the PowerPoints of the growers that were up, I think I saw

 plastic mulch in every single one.

 CHAIR POWELL-PALM: Um-hum.

 BD. MEM. PETREY: And I wanted to point it out, but I

 didn't want to interrupt, either.

 CHAIR POWELL-PALM: I so appreciate that.

 BD. MEM. PETREY: I should just have a sign that said

 plastic mulch, you know, and that is just to show the

 importance because I know labor is an issue in these small --

 in smaller growers that can't have the contract labor sources.

 And -- and weeding is -- needs to be very -- done very timely

 or it can be the 1500 an acre or the $2,000 an acre. That's

 really how you can get it, is when you have available labor and

 the timing of it's correct.

 CHAIR POWELL-PALM: Thank you for that. 
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 The reason I wanted to elevate that is that we think

 to the resources of small farms, say the farms we saw yesterday

 in the TOPP presentations, they do not have 100 employees.

 They do not have 30 employees. They have one employee and it's

 usually the farmer themselves. And when we think about keeping

 those folks in business, I would really caution us to consider

 is this something -- are we -- is it -- are we having an effect

 or are we signaling? And if we are signaling, is the price

 worth putting those folks out of business?

 Franklin?

 BD. MEM. QUARCOO: I want to be very clear, so yes,

 small scale folks labor is a major issue, so I want to be on

 record as stating that I'm not thinking about let's take it

 away from them now. So, all the advantages of it, we are

 talking about the advantages we all know. So, I -- I'm not

 getting the impression that there's anybody here who doesn't

 see the advantages of plastic, it's just that we have to start

 thinking about what we want to do in the future. So, for now

 taking it away will be a major issue.

 CHAIR POWELL-PALM: Yes.

 BD. MEM. QUARCOO: But what we -- what can we do so

 that the process towards finding a solution, a type of plastic

 and no research is going on, what can we do to accelerate the

 process? If there is anything at all we can do I don't know,

 but what -- what can be done to accelerate the process? 
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181

 CHAIR POWELL-PALM: I think that's a fantastic 

 question. I look to recently we saw somewhere in the realm of,

 I think, 24 million in OREI grants distributed, and I think it

 would be very interesting to look at who is doing organic

 research, or who is interested in the organic space, and start

 to cultivate relationships with those folks. I would lean on

 Carolyn if she has any more ideas on this front. But looking

 at how we build those, get those folks in this room to hear

 these conversations and identify what it takes to make our

 concerns, our needs heard more directly by the folks actually

 doing the work. Because it seems like we put research

 priorities out all the time, and I'm always surprised about how

 few of our research priorities end up in proposals or funded

 proposals and -- and grant projects. So, I think -- I hear

 your -- your question. I think it's a I would love to see in

 Spring Milwaukee ideas for how we push researchers to help us

 out with this question.

 Amy, please go ahead.

 SECRETARY BRUCH: Yeah. And I think it's -- I think

 it's a full court premiums. I often struggle with that, too,

 Franklin. I -- I love solutions. I mean, challenges just make

 you think what -- what can we do to prevent this? I think and

 outreach to the private -- private sector is really important

 here. This impacts everybody. And as -- as Jerry mentioned,

 you know, it's not just our sector, it's all sectors. We -- I 
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 think plastic mulch, we see that, it's very visible but plastic

 and is -- is in a lot of forms. And I think Nate circulated a

 report that was done in Europe, and -- and actually bailing

 twine seemed to rate way higher than plastic mulch in terms of

 just the -- the prolific use of plastic and -- and that hits

 home pretty fast in a lot of other areas. So, this is an issue

 I think we need all hands on deck trying to solve it and not

 just the organic sector, either.

 CHAIR POWELL-PALM: In a positive light, I think we

 should have a contest for that CPG or that grocery store that

 is themselves able to eliminate plastic or celebrate the

 incremental march towards that elimination. Dilip?

 BD. MEM. NANDWANI: Very quickly at what you just

 mentioned. So, because one of the researcher for that OREI

 grant was from Tennessee, my colleague, and there are a couple

 of other researchers I worked with them. If there is any

 update or recent update, you know, needed in Milwaukee, I can

 look into it.

 CHAIR POWELL-PALM: Thank you. That would be

 wonderful to have them.

 BD. MEM. NANDWANI: And some other updates on this

 issue.

 CHAIR POWELL-PALM: Yes. And I don't want to for a

 second minimize that we are so grateful you are here and

 providing that scientist voice, so thank you. 
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 BD. MEM. NANDWANI: It's great to be here. Thank

 you.

 CHAIR POWELL-PALM: Carolyn, please go ahead.

 MS. DIMITRI: I mean, I guess I'm also thinking that

 if we could make -- if there could be, from a social

 perspective. like a bigger dent at reducing plastic at the

 consumer level, then maybe there wouldn't -- you wouldn't feel

 such a pressure to do it at the farm level, as well. It's sort

 of like use it where it has the most benefit.

 CHAIR POWELL-PALM: Completely agree.

 MS. DIMITRI: Yeah.

 CHAIR POWELL-PALM: Yes. Other comments? Questions?

 (No response.)

 CHAIR POWELL-PALM: I just want to take a moment to

 recognize Logan's work. we've done it -- I've heard a few of

 you give nod to it, but a round of applause for how hard this

 issue is.

 (Applause)

 CHAIR POWELL-PALM: And logan tirelessly asked the

 questions that I think is so representative of the needs of the

 community. Taking to heart the comments that we received that

 we really want to address this, but also making sure not to

 lose sight of those that this will affect most, so thank you

 for your work.

 I turn it back to you, Madam Chair. 
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184

 SECRETARY BRUCH: Okay, if there's no other 

 discussion or questions, we'll move to a vote. There was a

 motion in Subcommittee to remove plastic mulch and covers from

 the National List. Motion was by Logan, seconded by Mindee.

 CHAIR POWELL-PALM: I think we start with Kim this

 time.

 BD. MEM. HUSEMAN: No.

 CHAIR POWELL-PALM: Franklin?

 BD. MEM. QUARCOO: No.

 CHAIR POWELL-PALM: Wood?

 BD. MEM. TURNER: Ugh, no.

 CHAIR POWELL-PALM: Logan?

 BD. MEM. PETREY: No.

 CHAIR POWELL-PALM: Carolyn?

 MS. DIMITRI: We're such bad people. No.

 BD. MEM. JOHNSON: Yes.

 CHAIR POWELL-PALM: Sorry, that was Allison as a yes.

 Brian?

 BD. MEM. CALDWELL: No.

 CHAIR POWELL-PALM: Nate?

 BD. MEM. LEWIS: No.

 CHAIR POWELL-PALM: Dilip?

 BD. MEM. NANDWANI: No.

 CHAIR POWELL-PALM: Jerry?

 BD. MEM. D'AMORE: No. 
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 CHAIR POWELL-PALM: Kyla?

 BD. MEM. SMITH: No.

 CHAIR POWELL-PALM: Amy?

 SECRETARY BRUCH: No.

 BD. MEM. CALDWELL: And the Chair votes no.

 SECRETARY BRUCH: Okay, had 1 yes, 12 no, zero

 abstentions, zero recusals, 2 absent. The motion fails. And

 there was one "Ugh" I heard from Wood.

 CHAIR POWELL-PALM: All right. With that folks, I

 propose we take a break. Let's come back in 15 minutes.

 (Whereupon, a brief recess was taken.)

 CHAIR POWELL-PALM: Next up is going to be aqueous

 potassium silicate. And I'm going to go back to Madam Chair.

 SECRETARY BRUCH: All right, welcome back. We have

 two listings for aqueous potassium silicate. I'll read them

 both into the record and then turn it over to Brian to discuss

 them.

 So aqueous potassium silicate, 205.601(e)(2), as a --

 let's see, insecticide, and then 205.601(i), as plant disease

 control. Go ahead, Brian.

 BD. MEM. CALDWELL: Thanks, Amy. Okay. Aqueous

 potassium silicate is an effective fungicide and miticide

 insecticide used by hundreds of organic farmers. Silicates are

 common in nature in soils and in plants. According to the

 technical review, very low environmental impact, nontoxic to 
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186

 birds, fish, and honeybees. It's rated as generally regarded

 as safe for humans and exempt from a resident tolerance. So

 this stuff is a slam dunk, right?

 Well, in these reviews, we go a little deeper than,

 than the EPA in their analysis and the FDA. So there are

 concerns about, about aqueous potassium silicate and I want to

 go through them. In the past, people have raised concerns

 about negative effects on farm workers, produce quality, and

 whether it's -- whether they -- it's an essential tool for the

 organic tool chest.

 And we put -- we requested a new technical review

 last year, which I'm going to respond to those, those concerns

 now. Our new TR really allayed a lot of concerns, basically

 all the concerns that I could ferret out about the toxicity of

 this product, potassium silicate, to applicators. And the 2015

 technical review noted that there were no concerns for oral,

 inhalation, or dermal toxicity. Although, skin irritation

 could occur at higher than normal concentrations. And overall,

 the aggregate exposure risks were regarded as -- were rated as

 negligible.

 In terms of the produce quality concerns, I talked

 about this at our spring meeting in some length and it's in

 the -- it's in the write-up and the review. But, basically,

 those concerns were, were based on research that wasn't really

 done on this kind of a product in a -- in a use as a spray. 
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 They were done with, with nutrient solutions with very high

 silicate quantities, which then kind of deformed the plants,

 that sort of thing. It really wasn't appropriate. It wasn't,

 wasn't relevant to, to the kind of uses that we're talking

 about here. So in the -- so anyways in my mind that and the,

 the Crops Committee Subcommittee agreed with me that really

 answered a lot of those questions, which I'm really glad that

 we, we have those kinds of questions to -- that are brought up.

 For the written comments for this meeting, three were

 in favor of relisting for both uses. One was for disease

 listing only. And one opposed both. Over 23zero listings for

 farmers on their organic systems plans. One noted that its use

 can produce incidental nanoparticles. And again in response,

 it turns out these are incidental nanoparticles. Nanoparticles

 are, are pretty common in nature and they did not cause any

 concerns in health and environmental testing that was reported

 in the -- in the two TRs.

 So overall my sum-up and what the Crops Committee

 voted for was that aqueous potassium silicate presents an

 environmentally benign fungicide, insecticide, and miticide,

 which in addition can reduce some reliance on, on sulfur and

 copper, which is -- which is one of our goals. With that,

 questions?

 CHAIR POWELL-PALM: Logan, please go ahead.

 BD. MEM. PETREY: Maybe a question and comment. We 
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 do use like Sil-MATRIX, I guess is what this product is. And

 so looking at it, it says it makes it more difficult to chew

 and digest. And I'm assuming that's because it is actually a

 systemic product that actually goes into the silicate would be

 used for the cell structure to make it stronger. Is that the

 mode?

 BD. MEM. CALDWELL: So that was -- that's not on the,

 the Sil-MATRIX promotional material or anything, I assume. Or

 is it?

 BD. MEM. PETREY: No. No, it's not.

 BD. MEM. CALDWELL: No. It's --

 BD. MEM. PETREY: I'm sorry. I was looking in the

 Sunset Review saying, yeah, forages, it can make it more

 difficult to digest.

 BD. MEM. CALDWELL: Exactly.

 BD. MEM. PETREY: And more or less it just shows that

 it does work, I guess. And so or at least does get into the,

 the cell structure to make it harder. And the idea is for the

 fungi will not be able to infect the cell as, as well.

 BD. MEM. CALDWELL: The comment about sort of more

 difficult to digest and chew for forages, that was a study that

 was done with different levels of soil fertility. And, and

 basically lower yields in the lower fertility had higher levels

 of, of -- they were poor quality forage, higher levels of

 silicates. And that was correlated with, with poorer 
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 digestion, poorer, you know, more difficulty.

 Again, that study had nothing to do with, with the

 application of Sil-MATRIX or --

 BD. MEM. PETREY: Right.

 BD. MEM. CALDWELL: -- potassium silicate in a -- in

 a cropping system.

 BD. MEM. PETREY: Got you.

 BD. MEM. CALDWELL: So it was -- I think it was

 unfortunate that the TR kind of brought up some of those issues

 without really kind of looking more closely and is this really

 relevant to this -- to that review. But they did bring them

 up. And I went through and read the articles, and they were

 not really on target, in my opinion.

 BD. MEM. PETREY: Thank you.

 BD. MEM. CALDWELL: So, yeah. Now just to follow-up

 a little bit further on your question is that they -- the, the

 mode of action of, of potassium silicate does involve getting

 into the layer between the epidermis and the internal cells,

 and how -- and so creating some kind of a -- of a layer there.

 But it's really a tiny, tiny amount. It doesn't -- it's like,

 you know, I don't know what the number would be, but it would

 like a hundredth of a percent of the -- of the mass of the,

 like say the tomato plant or the tomato fruit, I mean.

 So, so that is what's happening. And it definitely

 makes a difference to fungi and pathogens. But it doesn't --
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 there's no effect on, on the fruit quality. So --

 BD. MEM. PETREY: Thank you.

 CHAIR POWELL-PALM: Other questions for Brian? All

 right, hearing none, we'll go Madam Chair to read in the

 motion.

 SECRETARY BRUCH: Okay. Thank you, Nate. Thank you,

 Brian, for that review. We're going to vote first on aqueous

 potassium silicate as an insecticide. So the motion is motion

 to remove aqueous potassium silicate and that's found at

 205.601(e)(2) from the National List. Motion by Brian,

 seconded by Wood.

 CHAIR POWELL-PALM: Is it Franklin? Okay, thank you.

 Franklin, your vote, please?

 BD. MEM. QUARCOO: No.

 CHAIR POWELL-PALM: Wood?

 BD. MEM. TURNER: No.

 CHAIR POWELL-PALM: Logan?

 BD. MEM. PETREY: No. 

 CHAIR POWELL-PALM: 

 BD. MEM. DIMITRI: 

 CHAIR POWELL-PALM: 

 BD. MEM. JOHNSON: 

 CHAIR POWELL-PALM: 

 BD. MEM. CALDWELL: 

 CHAIR POWELL-PALM: 

Carolyn? 

No. 

Allison? 

No. 

Brian? 

No. 

Nate? 
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 BD. MEM. LEWIS: No.

 CHAIR POWELL-PALM: Dilip?

 BD. MEM. NANDWANI: No.

 CHAIR POWELL-PALM: Jerry?

 BD. MEM. D'AMORE: No.

 CHAIR POWELL-PALM: Kyla?

 BD. MEM. SMITH: No.

 CHAIR POWELL-PALM: Amy?

 SECRETARY BRUCH: No.

 CHAIR POWELL-PALM: And Kim?

 BD. MEM. HUSEMAN: No.

 CHAIR POWELL-PALM: And the Chair votes no.

 SECRETARY BRUCH: Zero yes, 13 no, zero abstentions,

 zero recusals, 2 absences. The motion fails.

 Okay. Now we are going to be voting on the second

 listing and that's at 205.601(i)(1), motion to remove aqueous

 potassium silicate from the National List. It was motioned by

 Brian, seconded by Jerry.

 CHAIR POWELL-PALM: With this voting, we're going to

 start with Wood.

 BD. MEM. TURNER: No.

 CHAIR POWELL-PALM: Logan?

 BD. MEM. PETREY: No.

 CHAIR POWELL-PALM: Carolyn?

 BD. MEM. DIMITRI: No. 
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 CHAIR POWELL-PALM: Allison?

 BD. MEM. JOHNSON: No.

 CHAIR POWELL-PALM: Brian?

 BD. MEM. CALDWELL: No.

 CHAIR POWELL-PALM: Nate?

 BD. MEM. LEWIS: No.

 CHAIR POWELL-PALM: Dilip?

 BD. MEM. NANDWANI: No.

 CHAIR POWELL-PALM: Jerry?

 BD. MEM. D'AMORE: No.

 CHAIR POWELL-PALM: Kyla?

 BD. MEM. SMITH: No.

 CHAIR POWELL-PALM: Amy?

 SECRETARY BRUCH: No.

 CHAIR POWELL-PALM: Kim?

 BD. MEM. HUSEMAN: No.

 CHAIR POWELL-PALM: Franklin?

 BD. MEM. QUARCOO: No.

 CHAIR POWELL-PALM: And the Chair votes no.

 SECRETARY BRUCH: Zero yes, 13 no, zero abstentions,

 zero recusals, 2 absent. The motion fails.

 Okay. Next on the list is elemental sulfur. So this

 is three listings and I'm going to present the Sunset. It's at

 205.601(e), as an insecticide, including acaricides or mite

 control; elemental sulfur at 5(i), so that's as disease 
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 control; and elemental sulfur as plant or soil amendment.

 So, I'm going to start off just highlighting the

 environmental issues, get into our discussion, and then work

 through public comments here. So environmental issues in

 general, elemental sulfur is relatively benign in the

 environment when used according to product label. Although low

 in acute toxicity, it still has the potential for respiratory,

 ocular, or dermal impacts, irritants mainly. Farm exposure can

 be mitigated again if label recommendation, the proper PPEs are

 followed.

 The Board reviewed journal articles and a study found

 on the inner-webs that Oregon State University conducted about

 the effects on children's respiratory health. So that was

 something that the Subcommittee specifically reviewed.

 And then moving onto our discussion, historically

 there has been strong support for the continued listing of

 sulfur, particularly for the use against various bacterial and

 fungal diseases, insects, and as soil and plant -- and as plant

 and soil amendments. Elemental sulfur has been included on the

 original National List since 1995. And that alternatives are

 not as effective.

 This is something that we did discuss in Subcommittee

 this past season was this for a note for the inerts working

 group. So, in the listing at 205.601(e), the Board recommends

 consistency with definitions as an acaricide may not be an 
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 insecticide and an insecticide may not be an acaricide. So

 during the review -- and thank you, Franklin, you were the one

 that brought that up, appreciate that. I think you'll be

 working on that in the inerts review. So, during the review,

 the NOP suggested that this could be a technical correction as

 part of inserts rulemaking.

 So, we had nine commenters. They were all in

 support, but there were a few that had concerns. And we heard

 from a big cross-section of our stakeholders. For insects, a

 producer group stated that it's a backbone of many organic

 integrated pest management programs. So sulfur kills insects

 if they touch or eat the product.

 As a fungicide, a producer group stated sulfur is

 used to control a wide range of plant diseases, including

 powdery mildew. And basically, it's mode of action, it just

 kills fungus on contact there. The way sulfur works for

 disease control, and this was a comment, it's not completely

 understood. However, the main theory is that sulfur enters the

 fungi cells and affects cell respiration.

 As a soil amendment, commenters stated that soil may

 be deficient in sulfur for a number of reasons such as rain

 saturating the soil. Soils that contain lots of iron oxides

 and sandy soils both have tendencies towards sulfur

 deficiencies. And if we just think about it agronomically, we

 have nitrogen, that's movable; we have sulfur, that's movable; 
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 and boron, that's movable. So, in our soil test, we always

 have to really be cognizant of those nutrients that we make

 sure we look at deficiencies there. And this is one, one soil

 amendment that right now it is not annotated that soil samples

 need to be provided in order to justify the use here, compared

 to some of the other soil amendments that we reviewed last

 year.

 The concerns from our commenters really surrounded

 from just the way in which sulfur is derived. It can be

 derived through scrubbers, so derived from scrubbing, from the

 burning of fossil fuels. There is a concern about heavy metal

 contamination. Some groups called for increased worker

 protections due to respiratory concerns and contamination.

 There were other commenters that said those could be alleviated

 if stable recs and safety procedures were properly followed.

 And there was a comment and, and some consensus around the

 stakeholders that currently there's, there's little to no

 alternatives available really that are as effective as sulfur.

 We did ask previously, and I did see some comments

 about this, this most recent stakeholder comment session. But

 we asked the question last semester about dry versus wet

 application. And we really learned from the community that

 both forms are needed for various reasons. There is just

 different efficacies and different timings that make those more

 appropriate, especially in a berry growing environment. Others 
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 noted that, that were growing other crops that dry sulfur forms

 were, were superior.

 So, I will turn that over to the Board chair right

 now.

 CHAIR POWELL-PALM: All right. Questions for Amy?

 Allison, please go ahead.

 BD. MEM. JOHNSON: Just I guess a comment and a

 request. The worker issues that are raised here are really

 worth taking quite seriously. I mean it's easy to read dermal

 irritant and sort of like keep going. I had the opportunity to

 interview a former farm worker last year, who had encountered a

 number of health issues on the farm including having red

 inflamed hands and body indefinitely. And then after she had

 been off the farm for a year, these symptoms cleared. And she

 realized it was something she had been exposed to on the farm.

 And when she was there, she had asked what this powdery stuff

 she was touching was and they told her sulfur.

 So, this stuff is really impactful, and it's pretty

 well known that labels are not always followed. You can write

 down protocols. But when you're dealing with language barriers

 and potentially not providing workers with adequate protection,

 it's not enough. So the suggestion is to take up an annotation

 or, or some additional assurance to make sure that protections

 really are in place I think is worth some consideration by the

 committee. 
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 CHAIR POWELL-PALM: Other thoughts or questions?

 Brian, please go ahead.

 BD. MEM. CALDWELL: Just to address the issue that,

 that often comes up in terms of the effect of, of repeated

 applications of sulfur on soil, in, in my own orchard over 20

 years, I was heavily reliant on a -- on a sulfur fungicide

 program. And basically, dropped the pH of the soil down to a

 point where a calcium deficiency in the crop and, and a

 condition called bitter pit, and it just was kind of spiraling

 out of control.

 Now a lot of that was because I, I hadn't been

 testing my soil the way I should. But just shows that these

 sort of things can happen and that's, you know, pretty much

 everybody who uses it besides me should be fully aware that

 that issue is, is part of the whole package that you get with

 sulfur.

 SECRETARY BRUCH: Yeah, that's a good point. This

 isn't a substance that requires a soil test to use. However,

 it does impact soil over time, the pH, like you mentioned.

 BD. MEM. CALDWELL: Right. And that can be remedied

 also over time with, with lime, high calcium lime, gypsum,

 those kinds of things.

 CHAIR POWELL-PALM: Any other questions? Comments?

 All right, I just real quick want to acknowledge Amy having to

 be both secretary, chair, and the lead on this material. So 
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 thank you for the acrobatics. We do appreciate it.

 SECRETARY BRUCH: I'm trying. Thanks for bearing

 with me here. Okay. So just a reminder this is a three vote

 substance here. So, we'll take it one at a time. First one,

 motion to remove elemental sulfur from the National List at

 205.601(e), so this is as an insecticide. Motion by Amy,

 seconded by Mindee. Turn it over to you.

 CHAIR POWELL-PALM: All right. So, for the vote,

 we're going to start with Logan.

 BD. MEM. PETREY: No.

 CHAIR POWELL-PALM: Carolyn?

 BD. MEM. DIMITRI: No.

 CHAIR POWELL-PALM: Allison?

 BD. MEM. JOHNSON: No.

 CHAIR POWELL-PALM: Brian?

 BD. MEM. CALDWELL: No.

 CHAIR POWELL-PALM: Nate?

 BD. MEM. LEWIS: No.

 CHAIR POWELL-PALM: Dilip?

 BD. MEM. NANDWANI: No.

 CHAIR POWELL-PALM: Jerry?

 BD. MEM. D'AMORE: No.

 CHAIR POWELL-PALM: Kyla?

 BD. MEM. SMITH: No.

 CHAIR POWELL-PALM: Amy? 
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 SECRETARY BRUCH: No.

 CHAIR POWELL-PALM: Kim?

 BD. MEM. HUSEMAN: No.

 CHAIR POWELL-PALM: Franklin?

 BD. MEM. QUARCOO: No.

 CHAIR POWELL-PALM: Wood?

 BD. MEM. TURNER: No.

 CHAIR POWELL-PALM: And the Chair votes no.

 SECRETARY BRUCH: Okay. That's zero yes, 13 no, zero

 abstentions, zero recusals, 2 absent. The motion fails.

 Okay. Moving onto the next listing, this is motion

 to remove elemental sulfur from the National List at 205.601(i)

 as plant disease control.

 CHAIR POWELL-PALM: We'll start with Carolyn.

 BD. MEM. DIMITRI: No.

 CHAIR POWELL-PALM: Allison?

 BD. MEM. JOHNSON: No.

 CHAIR POWELL-PALM: Brian?

 BD. MEM. CALDWELL: No.

 CHAIR POWELL-PALM: Nate?

 BD. MEM. LEWIS: No.

 CHAIR POWELL-PALM: Dilip?

 BD. MEM. NANDWANI: No.

 CHAIR POWELL-PALM: Jerry?

 BD. MEM. D'AMORE: No. 
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 CHAIR POWELL-PALM: Kyla?

 BD. MEM. SMITH: No.

 CHAIR POWELL-PALM: Amy?

 SECRETARY BRUCH: No.

 CHAIR POWELL-PALM: Kim?

 BD. MEM. HUSEMAN: No.

 CHAIR POWELL-PALM: Franklin?

 BD. MEM. QUARCOO: No.

 CHAIR POWELL-PALM: Wood?

 BD. MEM. TURNER: No.

 CHAIR POWELL-PALM: Logan?

 BD. MEM. PETREY: No.

 CHAIR POWELL-PALM: And the Chair votes no.

 SECRETARY BRUCH: Zero yes, 13 no, zero abstentions,

 zero recusals, 2 absent. The motion fails.

 And the third listing, motion to remove elemental

 sulfur from the National List at 205.601(j) as plant or soil

 amendment.

 CHAIR POWELL-PALM: We're going to start with

 Allison.

 BD. MEM. JOHNSON: No.

 CHAIR POWELL-PALM: Brian?

 BD. MEM. CALDWELL: No.

 CHAIR POWELL-PALM: Nate?

 BD. MEM. LEWIS: No. 
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 CHAIR POWELL-PALM: Dilip?

 BD. MEM. NANDWANI: No.

 CHAIR POWELL-PALM: Jerry?

 BD. MEM. D'AMORE: No.

 CHAIR POWELL-PALM: Kyla?

 BD. MEM. SMITH: No.

 CHAIR POWELL-PALM: Amy?

 SECRETARY BRUCH: No.

 CHAIR POWELL-PALM: Kim?

 BD. MEM. HUSEMAN: No.

 CHAIR POWELL-PALM: Franklin?

 BD. MEM. QUARCOO: No.

 CHAIR POWELL-PALM: Wood?

 BD. MEM. TURNER: No.

 CHAIR POWELL-PALM: Logan?

 BD. MEM. PETREY: No.

 CHAIR POWELL-PALM: Carolyn?

 BD. MEM. DIMITRI: No.

 CHAIR POWELL-PALM: The Chair votes no.

 SECRETARY BRUCH: Zero yes, 13 no, zero abstentions,

 zero recusals, 2 absent. The motion fails.

 Okay. That brings us to lime sulfur. And this also

 is listed twice that we'll be voting on. This one is going

 back to Brian. So, I'll read this into the record,

 205.601(e)(6) lime sulfur including calcium polysulfide, and 
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202

 205.601(i)(4), hydrated lime.

 BD. MEM. CALDWELL: Actually, I think that one, there

 should be two listings for lime sulfur, yeah, one for disease

 and one --

 SECRETARY BRUCH: Thank you, sorry. 205.601(i)(6),

 lime sulfur.

 BD. MEM. CALDWELL: All right. Thank you, Amy. Lime

 sulfur, also known as calcium polysulfide, people often think

 of it as, as sort of similar to sulfur and the name sounds like

 it, but it's really its activity is really quite different.

 And sulfur, as I mentioned previously, is a pretty strong

 acidifier in the soil. Lime sulfur is a more -- much more

 basic material, much more alkaline material, and but used for

 some of the same purposes.

 It is widely used and a very effective tool for

 organic farmers. It's very caustic in its concentrated form.

 And so applicators and mixers have to be really careful,

 basically just when they're -- when they're using the original

 concentrate before it gets diluted in the spray mix. It's

 pretty -- you don't want to like touch your eyes or something

 like that.

 Lime sulfur can be hard on beneficials, and that's --

this is one of the, the main concerns with it. But that, that

 issue has been well known for probably 50, 60 years at least.

 And the timing regimes for using lime sulfur are really well-
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 defined for -- certainly for fruit growers. I'm not as clear

 on how it may be used in vegetables. But, but it's very easy

 to time it so that you do not crash your beneficial

 populations. So that, that's pretty easily to deal with.

 And one thing that's, that's remarkable about lime

 sulfur that, that really is different than sulfur is it has

 what, what growers call a kickback effect, meaning that, that

 an infection, a fungal infection can actually be underway for

 maybe up to two or three days. And so, it's the infection has

 already penetrated into the plant leaves, but lime sulfur will,

 will have a curative effect on that and kill that, that early

 infection, whereas most -- sulfur and most, almost all other

 organic fungicides have to be in place before the infection

 event occurs. And so, it can be a really important tool when

 for weather reasons or whatever, the farmer hasn't gotten out

 there to put the protective layer on, they can come in with

 lime sulfur and still control fungal diseases.

 It's, it's relatively nonpersistent on the -- on the

 plants. We consider that we get five days of protection from a

 spray. It washes off quickly. And in terms of the, the

 comments that we got for this round, there were nine in favor

 of relisting for both uses, one for insecticide only, and one

 wasn't really clear about whether it was in favor or not, but

 it specifically required annotation about timing for, for no

 impact on the beneficial population. And over 280 farms listed 
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 lime sulfur on their organic system plants. So, questions?

 CHAIR POWELL-PALM: Questions from the Board? Go

 ahead, Nate.

 BD. MEM. LEWIS: Just wanting to represent my

 stakeholders from Washington. It's an essential component of a

 fire blight control, a non-antibiotic fire blight control. It

 provides a thinning effect so that there's fewer infection

 sites when fire blight comes to a particular orchard. And just

 noting that it was cited by the Board in its decision not to

 renew antibiotics for tree fruit as an essential component to,

 to justifying that decision. So, I just wanted to provide a

 little context and acknowledge its importance in Washington

 State.

 CHAIR POWELL-PALM: Thank you for that, yes. Other

 questions for Brian or comments? All right.

 BD. MEM. CALDWELL: Yeah, just to follow-up on Nate.

 Lime sulfur has that effect. Sulfur does not. So that's

 really an important tool.

 CHAIR POWELL-PALM: We're ready for the motion.

 SECRETARY BRUCH: Okay. Motion to remove lime sulfur

 from the National List. And we are voting first for 205.601(e)

 as an insecticide. The motion was by Brian and seconded by

 Jerry.

 CHAIR POWELL-PALM: I think Brian is going to be the

 first vote. 
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205

 BD. MEM. CALDWELL: No.

 CHAIR POWELL-PALM: Nate?

 BD. MEM. LEWIS: No.

 CHAIR POWELL-PALM: Dilip?

 BD. MEM. NANDWANI: No.

 CHAIR POWELL-PALM: Jerry?

 BD. MEM. D'AMORE: No.

 CHAIR POWELL-PALM: Kyla?

 BD. MEM. SMITH: No.

 CHAIR POWELL-PALM: Amy?

 SECRETARY BRUCH: No.

 CHAIR POWELL-PALM: Kim?

 BD. MEM. HUSEMAN: No.

 CHAIR POWELL-PALM: Franklin?

 BD. MEM. QUARCOO: No.

 CHAIR POWELL-PALM: Wood?

 BD. MEM. TURNER: No.

 CHAIR POWELL-PALM: Logan?

 BD. MEM. PETREY: No.

 CHAIR POWELL-PALM: Carolyn?

 BD. MEM. DIMITRI: No.

 CHAIR POWELL-PALM: Allison?

 BD. MEM. JOHNSON: No.

 CHAIR POWELL-PALM: And the Chair votes no.

 SECRETARY BRUCH: Zero yes, 13 no, zero abstentions, 
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 zero recusals, 2 absent. The motion fails.

 Okay. We are moving onto hydrated lime.

 CHAIR POWELL-PALM: We have to do the second vote on

 lime sulfur, sorry.

 SECRETARY BRUCH: Sorry. Thank you, guys. I

 appreciate it. Okay. So, we're going to be voting on

 205.601(i) as plant disease control. So motion to remove lime

 sulfur from the National List, motion by Brian, seconded by

 Jerry.

 CHAIR POWELL-PALM: All right. We're going to start

 the vote with Nate.

 BD. MEM. LEWIS: No.

 CHAIR POWELL-PALM: Dilip?

 BD. MEM. NANDWANI: No.

 CHAIR POWELL-PALM: Jerry?

 BD. MEM. D'AMORE: No.

 CHAIR POWELL-PALM: Kyla?

 BD. MEM. SMITH: No.

 CHAIR POWELL-PALM: Amy?

 SECRETARY BRUCH: No.

 CHAIR POWELL-PALM: Kim?

 BD. MEM. HUSEMAN: No.

 CHAIR POWELL-PALM: Franklin?

 BD. MEM. QUARCOO: No.

 CHAIR POWELL-PALM: Wood? 
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 BD. MEM. TURNER: No.

 CHAIR POWELL-PALM: Logan?

 BD. MEM. PETREY: No.

 CHAIR POWELL-PALM: Carolyn?

 BD. MEM. DIMITRI: No.

 CHAIR POWELL-PALM: And it just builds the energy for

 a little bit of a slight, no from the chair.

 BD. MEM. JOHNSON: Wait, wait.

 CHAIR POWELL-PALM: Oh, I'm sorry. Ah, I got too

 excited. Allison?

 BD. MEM. JOHNSON: I know. No.

 CHAIR POWELL-PALM: And Brian?

 BD. MEM. CALDWELL: No.

 CHAIR POWELL-PALM: No from the Chair.

 SECRETARY BRUCH: Okay. Zero yes, 13 no, zero

 abstentions, zero recusals, 2 absent. The motion fails.

 Now moving onto hydrated lime. And that is again

 going to be reviewed by Franklin. So, we'll read that into the

 record, 205.601(i)(4), hydrated lime. One listing. Go ahead,

 Franklin.

 BD. MEM. QUARCOO: So hydrated lime is listed under

 205.601(i). It's a synthetic product for use in organic

 production for plant disease control. It is said that it may

 not be used to cauterize physical alterations, or deodorize

 animal waste that you cannot use for. And when it comes to the 
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 environmental concerns, well, it's said to be practically

 nontoxic to and slightly toxic to fresh water fish and

 invertebrates when added in quantities that do not raise the pH

 significantly and suddenly. Additionally, when large volumes

 are released and they significantly increase the pH, soft

 bodied organisms, like some worms, it affects them, but

 bacteria are able to adjust to a wide range of pH changes.

 Now when it comes to the public comments on this,

 there was a ranking endorsement of the product. For its use

 for disease control, I have one comment that said that it

 should be used specifically for disease control, not an -- it

 should be restricted to that and annotated with a specific use.

 So that's one of the comments on that.

 Generally, the committee discussed the potential for

 environmental issues, especially in regard to that. And after

 a TR and everything, the committee determined that this was a

 product that needed to be maintained on the -- on the list.

 And so that's what I have.

 CHAIR POWELL-PALM: Questions for Franklin? Kim.

 BD. MEM. HUSEMAN: Just, just more or less pointing

 out that hydrated lime is another one of those materials that

 we see across the spectrum of Subcommittees.

 CHAIR POWELL-PALM: Thank you for that, yes. All

 right, we go to the vote.

 SECRETARY BRUCH: Motion to remove hydrated lime from 
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 the National List, motion was by Mindee, seconded by Amy.

 CHAIR POWELL-PALM: And we're going to start voting

 with Dilip.

 BD. MEM. NANDWANI: No.

 CHAIR POWELL-PALM: Jerry?

 BD. MEM. D'AMORE: No.

 CHAIR POWELL-PALM: Kyla?

 BD. MEM. SMITH: No.

 CHAIR POWELL-PALM: Amy?

 SECRETARY BRUCH: No. 

 CHAIR POWELL-PALM: 

 BD. MEM. HUSEMAN: 

 CHAIR POWELL-PALM: 

 BD. MEM. QUARCOO: 

 CHAIR POWELL-PALM: 

Kim? 

No. 

Franklin? 

No. 

Wood? 

 BD. MEM. TURNER: No.

 CHAIR POWELL-PALM: Logan?

 BD. MEM. PETREY: No. 

 CHAIR POWELL-PALM: 

 BD. MEM. DIMITRI: 

 CHAIR POWELL-PALM: 

 BD. MEM. JOHNSON: 

 CHAIR POWELL-PALM: 

 BD. MEM. CALDWELL: 

 CHAIR POWELL-PALM: 

Carolyn? 

No. 

Allison? 

No. 

Brian? 

No. 

Nate? 
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 BD. MEM. LEWIS: No.

 CHAIR POWELL-PALM: And the Chair votes no.

 SECRETARY BRUCH: Zero yes, 13 no, zero abstentions,

 zero recusals, 2 absent. The motion fails.

 Okay. Next on the list is liquid fish products. And

 that's one of my Sunsets. We'll read it into the record,

 205.601(j)(8), 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.

 And we will kind of start discussing this Sunset

 where we left off again in the spring. So, the NOP stated at

 the 2023 meeting that the recommendation regarding the

 annotation was currently on hold. And I start there because we

 did get a lot of feedback from the community on, on the

 annotation portion of this, this material at the October 2020

 meeting. And then I'm just going to state what that annotation

 was, so we all remember that clearly when we're discussing this

 going forward.

 So, the October 2020 meeting, the Board proposed,

 approved, and recommended to the NOP to add an annotation to

 liquid fish products that, that would have limited liquid fish

 products to be made with fish sourced only from fish waste,

 bycatch, or invasive species. So, the Subcommittee did

 continue to discuss the importance of this annotation and

 reviewed the history of previous marine material boats, 
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 including the fish oil annotation from handling that was the

 fall of 2021, and also reviewed the 2016 NOSB recommendation to

 add squid byproducts to the National List.

 Since there seemed to be a precedence for the term

 byproduct similar to bycatch being accepted, the Subcommittee

 was hopeful that the liquid fish annotation from 2020 could

 eventually be completed. Recently, the NOSB recommendations

 library list saw -- noticed that the recommendation for wild

 native fish for liquid fish products as closed and the reason

 stated is technical complexity of marine environments makes

 rulemaking on these topics problematic. NOP does not currently

 plan to move forward on this item.

 And I'm glad Jenny returned. I thought we'll just

 turn it over to Jenny real quick to make any additional

 comments from that rulemaking statement.

 DR. TUCKER: Yeah, I touched on this a bit in the

 National Organic Coalition meeting earlier this week, but I

 want to come reshare that information here. We did -- so last

 we met, this was on hold. We have after every meeting, we go

 through the indices of recommendations and kind of do an

 update. That is part of our kind of institutionalized

 reporting now on kind of where we are. And it is important for

 us, I think, to, to really provide clarity even when folks

 don't like the answer. So, I could leave it open and, oh,

 yeah, maybe someday we'll work on it. But I think when it is 
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 unrealistic for us to work on something, I think we want to

 share that information.

 So, in this case we feel like this one, we have -- we

 have closed it. There were a few challenges here. Number one,

 marine environments are foundationally difficult for statutory

 reasons. We share jurisdiction -- well, anyone shares

 jurisdiction with NOAA, National Oceanic and Atmospheric

 Administration, NOAA, on anything related to, to those marine

 environments. So anytime we're dealing with another federal

 agency, that adds complexity. And so, we have chosen to engage

 in that complexity with groups like Customs and Border

 Protection with imports. But it also feeds into our decision

 to either prioritize or deprioritize things.

 The second was there was not really clear consensus

 on this. That the recommendation passed the Board, but the

 public comments on this were quite mixed. And so we do tend to

 move forward on rulemaking on areas where there is consensus,

 where the community has come together, industry sectors come

 together on a path forward. And it was clear from the public

 comments that was not, not the case.

 And then the third driver is we really all need to

 have in the back of our minds our certifiers, right? Our

 certifiers have a tremendously difficult job already. And some

 of the criteria that they would need to apply and evaluate, to

 evaluate these materials, we have a material specialist now on 
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 staff who has been actually doing material audits of our

 certifiers. And this is a challenge for some of our

 certifiers.

 So, while I, I warn you all to be thinking about them

 during annotations, this is another really good example where

 the burden on certifiers for this would have been pretty

 significant. So, between the statutory authority questions,

 burden on certifiers, the -- and just in general the workload,

 that we want to move ahead on things that have consensus.

 We've kind of completed the triple crown this morning of, of

 rulemaking and part of the reason we've been able to do that is

 we have focused more. We've said no to more things, which has

 allowed us to say yes to the really important things.

 This was not ranked all that highly in the 2022

 regulatory priorities listing. We did that listening session

 where we asked for a lot of feedback on what the highest

 priorities were. This didn't really make the high, high list.

 And so, for all of those reasons, we decided to provide clarity

 to the community and close the item.

 CHAIR POWELL-PALM: Allison?

 BD. MEM. JOHNSON: Can I ask a question about that?

 CHAIR POWELL-PALM: Sure.

 BD. MEM. JOHNSON: I've received the explanation.

 The piece about there not being consensus in the community

 gives me a lot of pause, because I don't understand what the 
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 Board's rule is then. You know we tackle a lot of hard issues.

 And so, I think of our role as looking at the divergent

 opinions out there and coming to the best consensus

 recommendation that we can as a Board. If we weren't able to

 reach consensus, that would be one thing. But so, I guess my

 question is what is your recommendation where there are

 divergent opinions in the community, how can we as a Board then

 move forward with recommendations that will be put into action

 by NOP?

 DR. TUCKER: Great question. And there's certainly

 times where we have moved forward with things that even though

 there wasn't -- we don't need complete agreement. But on this

 one there were, you know, significant concerns in, in the

 public comments. And some of the comments that I shared about

 our concerns on this, we actually shared during the process,

 right? So, this was known at the time by the Board that these

 were, were concerns.

 I think one of the things you've done really

 successfully is when you're getting feedback from the community

 that is kind of controversial or shows there isn't quite yet

 consensus, you have been sending it back to Subcommittee and

 working on it. That particular item I think had already gone

 back and had been worked on a number of times. And I think at

 that time the Board said, all right, we've worked on this

 enough. We're going to vote on it, see if it passes, and send 
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 it to NOP.

 So, I think each, each of those items needs to be

 taken case by case. We do not need complete consensus or

 complete agreement. In fact, there are very little that there

 is complete consensus or complete agreement on, right? But

 that was a case that combined with the other factors that I

 mentioned kind of weighed to closing this item. The statutory

 authority one is a big issue. We did not finish aquaculture.

 And so that I think is -- marine environments are very

 different. And it would open up a whole new world of

 regulatory questions -- oh, sorry.

 CHAIR POWELL-PALM: Of rules.

 DR. TUCKER: Open up a whole new area of

 rule-oriented questions. I did catch myself.

 BD. MEM. TURNER: Just to follow up on that last

 point, I totally understand that and at the same time I feel

 like even if the -- even if the result of, of the process would

 have led to say focusing specifically on invasives, let's say,

 I mean NIMS, U.S. Fish and Wildlife are all concerned about

 invasive species. So, to me it is an opportunity here for

 leadership from, from organic and an opportunity to create sort

 of a win-win with other agencies. And I just -- I totally

 appreciate the process. I'm not in -- I'm not in that process.

 But I just -- I do think when there's opportunities for us to

 build bridges to other -- to other agencies, other regulatory 
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 bodies, I'll take the candy, I think that's, that's exciting to

 me on some level. And I feel like that was -- that was the

 opportunity here and I hate to see it, I really hate to see it

 dismissed like that. But appreciate it.

 DR. TUCKER: I appreciate the comments. And

 actually, I fundamentally agree and there are only so many

 sources of excitement that we can deal with at the program at a

 given -- at a given time. So, I think we're certainly -- we

 remain aware of the importance that is held by many people on

 this. I think for right now, I think our closed determination

 is the right move. And there are times where things have been

 closed and then they become reopen again. And so I, I never --

 I want to provide clarity now, understanding that in the future

 maybe things open up again for different reasons, different

 criteria, different timing. The timing could get right.

 CHAIR POWELL-PALM: All right. I'm going to kick it

 back to Amy. Thank you very much, Jenny, for fielding that

 question.

 DR. TUCKER: Those are good comments and good

 observations, and I always appreciate the conversation.

 SECRETARY BRUCH: Yeah, that's important to have.

 And especially understand a little bit more behind the, the

 statement for sure. So, thank you for that. I'm just going to

 wrap things up with this Sunset Review and then we'll open it

 up to more discussion. But the comment summary, there were 10 
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 written comments that we received. Over half of them mentioned

 the necessity of the sanitations, so I wanted to spend more

 time on unpackaging that a little bit.

 There were two advocacy groups that said they would

 not support this product if the annotation was not approved.

 There's a lot of usage in the community with products that are

 formulated with liquid fish products. One certifier mentioned

 over 1,100 of their members list liquid fish products on their

 OSP. Comments in favor, strong comments by tree growers in the

 northwest. Fruit and veggie growers, growers in sandy

 conditions, growers in tropical areas that experience a lot of

 rain all expressing the importance of being able to deliver

 nitrogen to their crops in season to correct deficiencies.

 One farmer group mentioned when managing fertility

 programs, producers should emphasize soil building practices

 and use fish products to supplement overall fertility programs.

 There were additional concerns about this product, just that

 commenters expressed concerns that even if fish does not have a

 commercial value, it may have an ecological value so need to

 understand from a macro view what's happening in the

 environment.

 Commenters also noted that the use of discarded fish

 parts for fertilizer may remove food from the marine ecosystem

 and there is a potential for contamination with PFOS. Again,

 we've seen that with other products that we've discussed today. 
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 Let's see. There was one comment that even went further with

 the annotation necessity, just that we needed even more of a

 restricted annotation from what was originally recommended.

 And also last semester, last season at our meeting in

 Atlanta, we talked about supplementation a little bit as well.

 We had comments last, last semester on supplementation. I

 didn't see any this semester. But the Board or the

 Subcommittee did dive into that a little bit further with OMRI.

 So, one commenter noted last semester that there were concerns

 about the potential of fortification with phosphorous and that

 the crop Subcommittee reviewed the landscape of the products.

 And phosphorous is actually used from the products

 that are surveyed by OMRI 58 percent of the time of the 239

 products that are out there. So phosphoric acid is used as the

 stabler, versus citric acid or, or sulfuric, sulfuric acid.

 So, in the U.S., phosphoric acid is primarily used as the

 acidifier.

 So, with that information, I will turn it back over

 to Nate.

 CHAIR POWELL-PALM: All right. We're going to move

 to the vote, if there's no other questions or comments. Yep,

 seeing none, all right, read the motion.

 SECRETARY BRUCH: Okay. Motion to remove liquid fish

 products from the National List. Motion was by Amy Bruch,

 seconded by Mindee. 
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 CHAIR POWELL-PALM: And we're going to start the

 voting with Jerry.

 BD. MEM. D'AMORE: No.

 CHAIR POWELL-PALM: Kyla?

 BD. MEM. SMITH: No.

 CHAIR POWELL-PALM: Amy?

 SECRETARY BRUCH: No.

 CHAIR POWELL-PALM: Kim?

 BD. MEM. HUSEMAN: No.

 CHAIR POWELL-PALM: Franklin?

 BD. MEM. QUARCOO: No.

 CHAIR POWELL-PALM: Wood?

 BD. MEM. TURNER: Abstain.

 CHAIR POWELL-PALM: Logan?

 BD. MEM. PETREY: No.

 CHAIR POWELL-PALM: Carolyn?

 BD. MEM. DIMITRI: No.

 CHAIR POWELL-PALM: Allison?

 BD. MEM. JOHNSON: Yes.

 CHAIR POWELL-PALM: Brian?

 BD. MEM. CALDWELL: No.

 CHAIR POWELL-PALM: Nate?

 BD. MEM. LEWIS: No.

 CHAIR POWELL-PALM: Dilip?

 BD. MEM. NANDWANI: No. 
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 CHAIR POWELL-PALM: And the Chair votes no.

 SECRETARY BRUCH: One yes, 11 no, 1 abstention, zero

 recusals, 2 absent. The motion fails.

 Okay. Moving on down our Sunset Review list, we have

 Jerry up with sulfurous acid next. So sulfurous acid, it's at

 205.601(j)(11), for on-farm generation of substance utilizing

 99 percent purity elemental sulfur per paragraph (j)(2) of this

 section. Go ahead, Jerry.

 BD. MEM. D'AMORE: Amy, thank you. The primary use

 of sulfurous acid is to -- is as an acidifying agent to

 neutralize and reduce excessive alkalinity in soil and/or

 water. The substance was discussed in the 2023 spring meeting

 in Atlanta. It was presented to the Board with a unanimous

 crop Subcommittee vote to remain on the National List. This

 2003 [sic] Sunset is reviewed -- review is supported by a

 February 2023 inner-scope GR, which largely focused on

 essentiality. For this 2023 fall session, there were about 14

 total stakeholder comments with nearly all being written and

 with nearly all in favor or in support of continued use.

 The strongest comment against the continued use of

 sulfurous acid notes that its current and continued use could

 mask poor soil conditions and/or practices. I don't know if

 I'm supposed to read this or not, but I'll continue. The Crop

 Subcommittee finds sulfurous acid compliant with the Organic

 Food Production Act and is not proposing removal. 
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 CHAIR POWELL-PALM: Thank you. Any discussion or

 questions for Jerry? Nate, please go ahead.

 BD. MEM. LEWIS: Just want to also note for the

 Washington stakeholders I represent that this is a necessary

 material for the growth of soil-based blueberry production.

 And remember Washington is number one, I will point it out, so

 we are number one in blueberries and it's largely due to the

 ability to acidify irrigation water in the eastern part of the

 city.

 CHAIR POWELL-PALM: Thank you.

 BD. MEM. LEWIS: With this substance.

 BD. MEM. D'AMORE: Thank you for that.

 CHAIR POWELL-PALM: Amy?

 SECRETARY BRUCH: Yeah, just more of a comment. I, I

 was hoping that potentially there would be alternatives for

 this. But then learning through the comment process, it sounds

 like not only is it an acidifier, pH adjuster, it also removes

 some impurities so that -- or reduces the amount of

 alternatives that are available to do a similar function. So,

 thank you.

 CHAIR POWELL-PALM: All right. If no further

 discussion, we'll go to the motion.

 SECRETARY BRUCH: Okay. Motion to remove sulfurous

 acid from the National List. Motion by Jerry, seconded by

 Brian. 
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 CHAIR POWELL-PALM: And we're going to start with

 Kyla.

 BD. MEM. SMITH: No.

 CHAIR POWELL-PALM: Amy?

 SECRETARY BRUCH: No.

 CHAIR POWELL-PALM: Kim?

 BD. MEM. HUSEMAN: No.

 CHAIR POWELL-PALM: Franklin?

 BD. MEM. QUARCOO: No.

 CHAIR POWELL-PALM: Wood?

 BD. MEM. TURNER: No.

 CHAIR POWELL-PALM: Logan?

 BD. MEM. PETREY: No.

 CHAIR POWELL-PALM: Carolyn?

 BD. MEM. DIMITRI: No.

 CHAIR POWELL-PALM: Allison?

 BD. MEM. JOHNSON: No.

 CHAIR POWELL-PALM: Brian?

 BD. MEM. CALDWELL: No.

 CHAIR POWELL-PALM: Nate?

 BD. MEM. LEWIS: No.

 CHAIR POWELL-PALM: Dilip?

 BD. MEM. NANDWANI: No.

 CHAIR POWELL-PALM: Jerry?

 BD. MEM. D'AMORE: No. 
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 CHAIR POWELL-PALM: And the Chair votes no.

 SECRETARY BRUCH: Zero yes, 13 no, zero abstentions,

 zero recusals, 2 absent. The motion fails.

 Okay. Next on the list, we have ethylene gas with

 Logan. So, this is at 205.601(k)(1), ethylene gas for

 regulation of pineapple flowering. Go ahead, Logan.

 BD. MEM. PETREY: All right, thank you. Yes, so

 ethylene gas, it's primary use is for to induce flowering in

 pineapple. And also, so ethylene gas is on the National List

 for as a plant growth regulator for pineapple production. We

 didn't hear any oral comments on, on this from any pineapple

 producers, but we did have some written comments. We did have

 a comment from Dole that did state, said we do not utilize it

 as a ripening agent. We use it for to induce flowering. In

 the past, Dole has conducted research to try to find

 alternatives to ethylene as a flowering inductor, but we

 haven't found any that could be utilized in organic production.

 Basically, we depend entirely on ethylene for that purpose.

 Not as a ripening agent, because we harvest the fruit when it

 is ripened naturally, not with the agent for that matter.

 So, this product is applied -- this is a long crop,

 right? So not as long as a blueberry, but it, it can be

 applied between 7 and 15 months, and so pineapples do have very

 staggered flowering, which, which limits the, the ability to

 harvest efficiently, to harvest economically, to also apply 
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 some products that would be catered towards harvesting, whether

 it's a certain pest, like an insecticide or something that is

 catered towards more of a ripened fruit. And so when you have

 these plants that are very staggered, that makes that type of

 production very difficult.

 Looking back at the -- at the comments from 2015,

 when we did have pineapple growers that would show up, it was

 stated that the abandonment or the delisting of this material

 would make growers go to conventional. Also, it was noted in

 the comments that being able to have this product allows a lot

 of small growers in rural areas, and these farms in Costa Rica

 to be able to make -- to make a living.

 So as far as the environmental issues from the -- we

 did get a TR. And so from the TR, the toxic release inventory

 in 2021, the total release of ethylene as airborne emissions in

 the U.S. was 18 million pounds. Of that, 17.2 was emitted by

 chemical manufacturing industry and about 0.7 million pounds

 was from the petroleum industry. It's not known how much

 ethylene is released due to ripening, but it's got to be quite

 small from that whole total. And so there does not seem to be

 an issue with that. So, trying to affect the total emissions

 would completely -- to wipe out that pineapple production

 doesn't seem to make much sense.

 And then as far as for the human health, ethylene is

 highly flammable and explosive. Overexposure causes headaches, 
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 drowsiness, or muscular weaknesses. High concentrations of

 ethylene can cause dizziness or light-headedness. This is

 limited to the work area of ethylene production or its use.

 Environmental exposure from general public, that would be too

 low to cause adverse effects. And that is all from the TR.

 There were other -- let's see, a total of nine

 comments from the written comments. Eight were in support and

 one was in opposition. Another grower group did reply and said

 it reached out to pineapple growers through our supply chains

 and received numerous comments from growers in Central America.

 They are unanimous in stating that ethylene is necessary to the

 production of pineapples that they ship to the United States.

 This is the most important agricultural practice for organic

 pineapple farming. It is also accepted in other international

 standards.

 And that's it. Anybody have any questions?

 CHAIR POWELL-PALM: Questions for Logan? Jerry,

 please go ahead.

 BD. MEM. D'AMORE: No question. Everything you said,

 I am -- is extremely accurate. It fails to say the purpose,

 though. I mean it says what it does, but what it -- but the

 end result is it's a labor-saving initiative. Right? Is

 that --

 BD. MEM. PETREY: Yes. It's labor-saving, but it's

 and then also we could add, too, that I found in the comments 
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 that it actually reduces quality issues, because it's very hard

 to indicate whether a pineapple is close to maturity. And so,

 if you can narrow down that window, it does increase the, the

 quality of when it's harvested. So, it's much harder -- it's

 much easier to tell once it's been at the grocery store, for us

 to tell. But it is much harder in the -- in the field.

 BD. MEM. D'AMORE: Thank you.

 CHAIR POWELL-PALM: Allison, then Nate.

 BD. MEM. JOHNSON: Thank you. I see the Subcommittee

 vote was not unanimous. And I see one line that there was

 concern about using material to produce a crop during

 unfavorable conditions. Could you or anyone else speak to the,

 the non-unanimous --

 BD. MEM. PETREY: Yeah. No, I think Mindee

 definitely was, was somebody who was concerned, you know,

 because her, in her work, she had come across some poor-quality

 pineapples, and it seemed to be off-season. Because it did

 not -- stated that it was not used for maturity reasons, it was

 just to kind of -- it's not used, you know, once that you have

 a flowering, it's not used sequentially to mature the crop.

 It's just to try to time that. And so, I don't know how to

 state whether it is out of season or not. So, no, I did not --

 I was not able to find that in the comments.

 CHAIR POWELL-PALM: Nate?

 BD. MEM. LEWIS: Just to put a finer point on the 
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 labor-saving. It's a somewhat accurate characterization, but

 there is also a worker safety element. It's really dangerous

 and painful to harvest pineapples. And so, the fewer times you

 need to go through the field, the better it is for workers.

 And I recall the in-person testimony from 2015 and just how

 important that was stressed from folks in the field.

 And I also recognize the OPW's, the Organic Produce

 Wholesalers Coalition sort of took a picture of what the

 pineapple leaves look like. And you can sort of see why you'd

 want to minimize your exposure to that working environment.

 BD. MEM. PETREY: Very good point.

 CHAIR POWELL-PALM: Dilip?

 BD. MEM. NANDWANI: Very quick. Thanks, Logan. A

 kind of clarification. This is about inducing flowering in

 pineapple, not as a ripening agent. A lot of fruits in many

 places, especially tropical countries, they use it. So, the

 Subcommittee looked into this as a role as ripening?

 BD. MEM. PETREY: Sure. So that's actually in

 handling. And so you'll see that tomorrow. And so, yes, there

 is a lot more uses. No, there's a lot more uses for this

 product post-harvest that we'll get into. But as far as, as a

 crop input during the growing season, this is the only use.

 And we've actually looked out, you know, asked that in the

 spring, are there any other uses for this material. And

 everything that came up for it would have been a post-harvest 
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 deal. Even the preventing potatoes from sprouting would be a

 post-harvest issue. Anyway, thank you.

 BD. MEM. NANDWANI: Thank you.

 CHAIR POWELL-PALM: All right. With that we'll go to

 the motion, please.

 SECRETARY BRUCH: Thank you, Logan, for that review.

 Motion to remove ethylene gas from the National List, motioned

 by Logan, seconded by Jerry.

 CHAIR POWELL-PALM: And I think we're starting with

 Kim -- Amy, okay, go ahead.

 SECRETARY BRUCH: No.

 CHAIR POWELL-PALM: Kim?

 BD. MEM. HUSEMAN: No.

 CHAIR POWELL-PALM: Franklin?

 BD. MEM. QUARCOO: No.

 CHAIR POWELL-PALM: Wood?

 BD. MEM. TURNER: No.

 CHAIR POWELL-PALM: Logan?

 BD. MEM. PETREY: No.

 CHAIR POWELL-PALM: Carolyn?

 BD. MEM. DIMITRI: No.

 CHAIR POWELL-PALM: Allison?

 BD. MEM. JOHNSON: No.

 CHAIR POWELL-PALM: Brian?

 BD. MEM. CALDWELL: No. 
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 CHAIR POWELL-PALM: Nate?

 BD. MEM. LEWIS: No.

 CHAIR POWELL-PALM: Dilip?

 BD. MEM. NANDWANI: No.

 CHAIR POWELL-PALM: Jerry?

 BD. MEM. D'AMORE: No.

 CHAIR POWELL-PALM: Kyla?

 BD. MEM. SMITH: No.

 CHAIR POWELL-PALM: And the Chair votes no.

 SECRETARY BRUCH: Zero yes, 13 no, zero abstentions,

 zero recusals, 2 absent. The motion fails.

 Okay, Jerry, going back to you for microcrystalline

 cheese wax. It's at 205.601(o)(1) for use in log-grown

 mushroom production, must be made without either

 ethylene-propylene co-polymer or synthetic colors. Go ahead,

 Jerry. Thank you.

 BD. MEM. D'AMORE: Well, thank you. I happen to like

 this Sunset. It's first time I can talk about being a grower

 without using the H word. So, I had -- I did -- I grew this

 for about six years in, in Virginia, and am completely

 comfortable with what the -- what the Sunset Review here says.

 So, when this substance was discussed in Atlanta

 during the 2023 spring meeting, the bulk of the conversation

 centered around current need. And they referenced the concerns

 that the log method, which is what this is called, of shitake 
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 mushroom production was no longer practiced. It was noted,

 however, that this method of production was still widely used

 by small producers.

 During the spring 2023 session, there were about 10

 stakeholder comments, all of which were written. None of the

 comments were against the continued use of microcrystalline

 cheese wax. One commenter expressed support for the use until

 a non-petroleum base alternative becomes available. The fall

 stakeholder comments mirrored the spring comments almost

 exactly. Both sets of stakeholder comments gave support to the

 claim that microcrystalline cheese wax continues to be widely

 used by small shitake growers.

 The crop Subcommittee finds microcrystalline cheese

 wax compliant with OFPA, or the Organic Food Production Act,

 OFPA and/or 205.601(o) and is not proposing removal.

 CHAIR POWELL-PALM: Questions, comments for Jerry?

 All right, we'll go to the motion.

 SECRETARY BRUCH: Motion to remove microcrystalline

 cheese wax from the National List, motion by Jerry, seconded by

 Brian.

 CHAIR POWELL-PALM: All right, now we're going to

 start with Kim.

 BD. MEM. HUSEMAN: No.

 CHAIR POWELL-PALM: Franklin?

 BD. MEM. QUARCOO: No. 
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 CHAIR POWELL-PALM: Wood?

 BD. MEM. TURNER: No.

 CHAIR POWELL-PALM: Logan?

 BD. MEM. PETREY: No.

 CHAIR POWELL-PALM: Carolyn?

 BD. MEM. DIMITRI: No.

 CHAIR POWELL-PALM: Allison?

 BD. MEM. JOHNSON: No.

 CHAIR POWELL-PALM: Brian?

 BD. MEM. CALDWELL: No.

 CHAIR POWELL-PALM: Nate?

 BD. MEM. LEWIS: No.

 CHAIR POWELL-PALM: Dilip?

 BD. MEM. NANDWANI: No.

 CHAIR POWELL-PALM: Jerry?

 BD. MEM. D'AMORE: No.

 CHAIR POWELL-PALM: Kyla?

 BD. MEM. SMITH: No.

 CHAIR POWELL-PALM: Kim? I'm sorry. Allison? Okay,

 almost there folks. Amy?

 SECRETARY BRUCH: No.

 CHAIR POWELL-PALM: And the Chair votes no.

 SECRETARY BRUCH: But thank you for the compliment.

 Thank you for all those compliments.

 CHAIR POWELL-PALM: I haven't said regulatory or 
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 compliance enough, apparently.

 SECRETARY BRUCH: Okay.

 UNIDENTIFIED SPEAKER: I have chocolate here, anyway.

 CHAIR POWELL-PALM: Beautiful, beautiful shot.

 SECRETARY BRUCH: Zero yes, 13 no, zero abstentions,

 zero recusals, 2 absent. The motion fails. Thank you for your

 review, Jerry.

 Okay, Wood, you're going to bring us home. We're

 going to switch gears, though. We're going to go to the

 205.602 list. So, this is non-synthetic substances prohibited

 for use in organic crop production, (e) potassium chloride,

 unless derived from a mined source and applied in a manner that

 minimizes chloride accumulation in the soil. Okay, Wood?

 BD. MEM. TURNER: Yep, great. Yeah, so let's see.

 Potassium is an essential element for plants. Potassium

 chloride is a means of getting that potassium to plants, but it

 also can, can accumulate in the soil. And so that's, that's

 the point of this, where this is listed that if this is being

 used and is from a mined source, it has to be monitored

 appropriately to make sure that the soil -- doesn't affect soil

 salinity.

 And so that's the primary issue here. We had good

 discussions about this, had a TR on this. It's actually

 listed, has a listing in handling, a listing in prohibition in

 crops. We had a good discussion about the material. I think 
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 it's perceived, I think, to be a less expensive means of

 delivering potassium to plants, as there may be some other

 materials. Potassium sulfate is often mentioned, but also

 considered to be relatively cost-effective as well.

 I think -- I think we continue to see strong support

 from the community in terms of the way this is listed. And I

 would say across the Board we had 11, 11 comments, written

 comments unanimously in support of this continued restriction

 on the material. That said -- well, there's a couple of things

 that I thought were interesting. One is that it -- one group

 mentioned that it is on the EPA, that it is a material that's

 on EPA List 4, but also on the safer list.

 A couple of different certifiers mentioned that they

 have fairly significant use of this material with this

 restriction, you know, with the restriction in the OSP, so it

 is -- it is being used by some organic growers. One, one

 certifier actually indicated that it's actually growing in use

 by organic growers and so I thought that was -- that was

 interesting, even given the -- given the restriction.

 Oh, I just wanted to read one, one comment that to me

 I thought was kind of interesting just in terms of sort of the

 issues here and how we -- how we think about the challenges

 with monitoring chloride accumulation in the soil, in

 particular. One group said greater industry consistency is

 needed regarding how certifiers determine chloride is not 
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 accumulating in the soil over time. The certification

 currently accepts but does not require soil test to prove

 chloride accumulation is minimized. And they also accept OSPs

 that include very small amounts of potassium chloride in very

 infrequent applications as techniques that minimize soil

 accumulation.

 And this particular group was unsure if there were

 other certifiers were handling material restriction in the same

 way. So I just think that's an interesting -- it's an

 interesting dimension to kind of the challenges with managing

 this particular listing. But in general, unanimous support to

 maintain this listing as it is.

 CHAIR POWELL-PALM: Comments or questions for Wood?

 All right, last one.

 SECRETARY BRUCH: Okay. Motion to remove potassium

 chloride from the National List, motion by Wood, seconded by

 Mindee.

 CHAIR POWELL-PALM: We're going to start the voting

 with Franklin.

 BD. MEM. QUARCOO: No.

 CHAIR POWELL-PALM: Wood?

 BD. MEM. TURNER: No.

 CHAIR POWELL-PALM: Logan?

 BD. MEM. PETREY: No.

 CHAIR POWELL-PALM: Carolyn? 
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 BD. MEM. DIMITRI: No.

 CHAIR POWELL-PALM: Allison?

 BD. MEM. JOHNSON: No.

 CHAIR POWELL-PALM: Brian?

 BD. MEM. CALDWELL: No.

 CHAIR POWELL-PALM: Nate?

 BD. MEM. LEWIS: No.

 CHAIR POWELL-PALM: Dilip?

 BD. MEM. NANDWANI: No.

 CHAIR POWELL-PALM: Jerry?

 BD. MEM. D'AMORE: No.

 CHAIR POWELL-PALM: Kyla?

 BD. MEM. SMITH: No.

 CHAIR POWELL-PALM: Amy?

 SECRETARY BRUCH: No.

 CHAIR POWELL-PALM: Kim?

 BD. MEM. HUSEMAN: No.

 CHAIR POWELL-PALM: And the Chair votes no.

 SECRETARY BRUCH: Zero yes, 13 no, zero abstentions,

 zero recusals, 2 absent. The motion fails.

 Thanks for your review, Wood. And thank you,

 everybody. Thank you, thank you. That was a good thorough

 discussion of these materials in crops, and I really appreciate

 working with all of you.

 UNIDENTIFIED SPEAKER: Thank you, Amy, for a big day. 
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 You did good.

 CHAIR POWELL-PALM: Thank you, Amy.

 (Applause)

 CHAIR POWELL-PALM: Well, folks, that's a wrap.

 We're going to do this tomorrow. I'm excited to see you all

 again. And the happy hour is going to be at 7 o'clock at the

 Bayberry Beer Hall. Is that right, Abby? All right. So

 looking forward to see you all there. Have a good night.

 (Whereupon, at 5:26 p.m., the meeting was adjourned,

 to reconvene on Thursday, October 26, 2023.) 
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 at the heari

237

 CERTIFICATION

 This is to certify that the attached proceeding

 before the:

 NATIONAL ORGANIC STANDARDS BOARD

 IN THE MATTER OF: FALL 2023 MEETING

 PLACE: Providence, Rhode Island

 DATE: October 25, 2023

 was held according to the record, and that this is the

 original, complete, true and accurate 

ng.

transcript which has been

 compared to the recording accomplished 

 __________________________

 Elaine M. LaRosee,

 Official Reporter 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 4 

October 25, 2023 

191:14 

absent (23)

 122:8;134:3;135:7;

 94:5 

accreditation (8)

 72:13,19;88:24;

 122:11 

act (5)

 56:1;93:16;143:20;

Additionally (1)

 208:4 

additions (1) $ 

$1500 (1) 136:14;137:23; 92:22;110:11,12,16; 220:25;230:14 91:12 

179:7 140:19;141:25; 118:5 acting (1) address (22)

$2,000 (1) 145:22;151:22;153:6; Accredited (4) 130:6 55:22;58:17;65:9;

 179:22 185:7;192:21;199:10; 58:10;108:6;118:2; action (7) 105:18,18,19,20,23;

$300 (2) 200:15;201:21;206:1; 119:19 88:18;89:17;97:3; 109:20;111:21,21,22;

 69:25;179:7 207:16;210:4;220:3; accumulate (1) 132:6;189:17;194:15; 113:6;118:21,21;

$428 (1) 223:3;229:11;232:6; 232:17 214:8 124:17,25;126:13;

 82:21 235:20 accumulating (1) activist (2) 127:15;149:24;

$5 (1) absolutely (6) 234:1 131:11,13 183:22;197:3 

31:17 63:20;107:14; accumulation (4) activity (1) addresses (3)

$6 (1) 112:12;168:3,7,25 232:13;233:23; 202:10 105:22;112:25;

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abstention (6)

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achieve (1)

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actually (48)

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adds (2)

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adequate (3) [ 

[sic] (8) 220:2 achieving (1) 74:25;78:1,6;95:21; 88:3;89:4;196:21 

33:12;35:19;78:1; abstentions (21) 49:24 97:2;104:6;105:7; adjourned (1)

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142:2;220:15 136:14;141:24;

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110:15,23;129:16;

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adjust (1)

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adjusted (1)

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A 

A/V (1) 199:10;200:14; acidifier (5) 161:7;163:3;171:14; adjuster (2)

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a1i (1) 207:16;210:3;223:2; 218:17;221:17 4;202:2;203:8;213:1; adjusters (1)

 138:11 229:10;232:5;235:19 acidify (1) 214:15;216:6;218:12; 9:3 

a1ii (1) acaricide (2) 221:8 226:1;227:18,23; adjusting (1)

 138:14 193:25;194:1 acidifying (1) 232:23;233:17,17 59:15 

abandonment (1) acaricides (1) 220:10 actuarially (2) adjustment (1)

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abbreviated (1) accelerate (2) 55:23;197:24; acute (1) Administration (2)

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Abby (1) accept (4) acknowledged (1) add (17) Administrative (1)

 236:7 113:2;120:18,19; 6:22 14:1;38:3,7;80:7; 93:16 

ability (4) 234:3 acre (6) 105:5;108:4;115:1; admire (1)

 70:19;159:2;221:8; acceptable (3) 31:18;116:9;179:7, 132:10;133:11,21; 167:4 

223:24 29:10;118:23;128:8 7,22,22 135:9;136:19;154:20; admit (1)

able (45) acceptance (1) Acreage (10) 166:23;210:20;211:3; 39:14 

10:25;11:10;22:3; 142:17 19:14,15;40:9,13; 225:25 admitters (1)

 23:20,21,23;24:3; acceptances (1) 41:7,9,24,25;46:3; added (6) 163:14 

37:9;45:24;69:21; 154:12 106:24 13:9;31:17;70:24; ado (1)

 72:1;75:9,12;76:9; accepted (5) acres (14) 125:19;160:8;208:3 128:13 

80:5;101:6,9,11,13; 89:3;129:5;138:18; 13:14,17;42:23; addendum (3) advance (3)

 102:22;103:14; 211:5;225:14 43:7;68:1;103:2; 12:3;53:11;59:21 66:9,11;138:4 

104:11,20;105:9; accepts (1) 116:19,20,25,25; adding (4) advantage (3)

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116:11;126:16,23; access (2) acrobatics (1) 149:10 advantages (3)

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171:25;177:14;179:5; accessible (3) acronym (1) 31:19;40:23;83:2; adverse (1)

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213:11;214:4;217:12; accessing (1) across (17) 187:21 advice (1)

 224:10,12;226:23 40:14 6:15;9:2;16:2; additional (18) 78:7 

above (5) accomplished (1) 25:24;30:15;54:10; 14:4;20:15,16; advise (2)

 53:12;60:2;81:20; 82:3 55:18;67:14;103:5; 31:12,14,24;59:20; 118:1;119:19 

109:9;118:23 according (4) 107:10,10,11,12; 60:8;67:18;119:5; advised (1)

absence (1) 33:21;48:6;185:24; 117:16;208:22; 129:17;132:9;149:22, 97:19 

170:25 193:6 226:16;233:7 22;175:19;196:23; advisers (1)

absences (1) accountable (1) ACS (1) 211:14;217:17 84:2 

Min-U-Script® Burke Court Reporting & Transcription (1) $1500 - advisers 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 4 

October 25, 2023 

advisors (1) 220:10;223:14,19,20; 225:18;228:10; allows (2) 80:7;91:7;98:6;105:5;

 79:25 227:15 229:15 175:18;224:10 121:23;123:13;

advisory (1) agents (18) aimed (1) almost (12) 127:19;133:18;134:2,

 6:6 9:2;10:4;15:1,5; 70:11 74:22;126:10; 20;135:12,25;136:16;

advocacy (4) 17:18;32:22;33:1; aiming (1) 133:2,4,6;154:1; 137:7,25;139:25;

 131:12,13;158:5; 37:5,15,17;39:23,24; 178:1 158:4;169:16;172:19; 140:22;141:5;142:5;

 217:4 47:5,8;83:7,10,20; AIP (7) 203:12;230:9;231:20 144:25;150:7,23;

advocate (2) 84:13 20:5;33:17,22;47:5, along (5) 159:14;160:4;181:18;

 84:23;169:1 aggregate (3) 6;48:3,5 58:14;106:21; 185:3,21;191:8;

Affairs (1) 100:6;106:8;186:19 AIPs (4) 138:10;154:6;164:8 192:13;196:5;197:24;

 30:20 aggregated (3) 8:25;33:1;37:16; alteration (1) 198:6,25;200:3;

affect (4) 66:7;100:14;106:9 48:1 25:20 201:7;202:7;205:10;

 113:23;183:23; aggregating (1) airborne (1) alterations (1) 206:19;209:1,9;

 224:21;232:20 59:10 224:15 207:24 216:17;218:24;219:6;

affects (2) ago (5) aisle (1) alternative (3) 220:9;221:13;222:4;

 194:19;208:6 19:12;30:14;61:7; 27:15 130:12;157:9;230:8 228:10;231:20;

afford (2) 79:10;94:2 Alcohols (1) alternatives (15) 235:14,25;236:2 

82:10,12 agonized (1) 138:5 130:20;132:25; Amy's (2)

affordable (2) 167:12 algae (1) 156:15,16,24;157:3, 104:19;123:20 

32:9;82:16 agonizing (1) 142:16 10;160:9,11,13; analyses (1)

Ag (6) 167:11 algicide (1) 193:20;195:18; 80:2 

6:9;20:1,3,9;33:21; agree (13) 142:14 221:15,19;223:16 analysis (3)

 107:8 17:2;20:6;60:24; alignment (1) Although (2) 82:20;100:14;186:5 

again (55) 83:24;119:16;120:7; 157:23 186:17;193:6 analyst (1)

 14:6,12;22:18,19; 126:14,25;159:12; alkaline (1) always (20) 0:24 

24:2;25:6;27:10; 167:5;172:3;183:10; 202:13 6:22;7:15;22:7; Analytical (2)

 28:12,15;30:9;38:17; 216:6 alkalinity (1) 29:19;74:22;96:13; 91:18,19 

39:11;50:9;51:2; agreed (2) 220:11 99:5;104:15;105:7; analyze (1)

 62:13,19;67:16;72:6; 105:13;187:6 allayed (1) 114:19,19;122:21; 20:17 

73:22;84:8,13,19; agreeing (1) 186:13 128:4;172:8,9;177:9; analyzed (1)

 92:21;94:9;95:12; 27:4 alleviated (1) 181:12;195:1;196:19; 43:2 

103:10;105:1,17; agreement (4) 195:14 216:20 and/or (3)

 106:4,9,19;108:2; 11:24;214:12; Allison (52) amazed (1) 220:11,22;230:15 

110:6;111:19,20; 215:4,5 39:12;43:22;64:4; 99:5 animal (3)

 117:10;120:5;124:6; agreements (1) 72:2;73:1,25;75:14; amazing (1) 25:13;99:8;207:25 

128:2;132:23;148:3; 11:20 76:15;81:12;82:4; 66:15 annotate (2)

 166:10;169:10;176:4, agrees (1) 84:17;85:19;86:5; amendment (4) 166:4,6 

19;178:2;187:13; 173:22 96:3;103:7;108:23; 193:1;194:20; annotated (2)

 189:2;193:9;207:17; agricultural (4) 117:19;119:12,18; 195:4;200:18 195:4;208:12 

210:11;216:12,14; 6:6,7;91:18;225:13 121:11;124:4,6,11; amendments (8) annotating (1)

 217:24;236:6 agriculture (8) 134:8;135:13;137:19; 117:22;119:15; 148:11 

against (9) 6:1,8;29:20;54:10; 140:12;141:17; 120:6,8,18,20;193:19; annotation (19)

 64:14;81:7;94:10; 62:25;83:12,17; 145:12;151:10; 195:6 144:3,4,12;148:13,

 97:4;158:21;177:15; 125:10 152:17;165:1,24; America (2) 13;149:10;158:14;

 193:17;220:20;230:6 agronomically (1) 167:8;184:17;190:21; 103:24;225:10 196:22;203:24;

agencies (7) 194:24 192:1;196:6;198:13; American (2) 210:13,15,16,20,24;

 8:21;9:14;35:14; Ah (1) 199:16;200:20; 0:24;168:18 211:1,6;217:5;218:2,

 76:17;93:23;215:22, 207:9 205:22;207:10; Amish (1) 3 

25 ahead (46) 209:21;213:20; 113:22 annotations (4)

Agency (13) 22:1;35:7;39:12; 219:18;222:16;226:8; amongst (1) 154:13;157:20;

 0:16,23;8:22;9:6; 43:23;47:1;50:10; 228:22;231:7,19; 100:13 175:23;213:5 

10:19;30:7;37:24; 51:14;56:21;58:5; 235:2 amount (8) announce (1)

 48:9,9;50:8;62:1; 64:4;74:18;77:4; allow (5) 11:5,7;18:3;95:3; 24:7 

107:22;212:10 91:13,22;93:3;96:3; 21:8;32:14;38:21, 162:16;189:20;210:8; announced (2)

agenda (11) 120:9;138:11,14; 25;154:18 221:18 12:9;30:13 

62:8;69:12;98:23; 142:12;144:1;146:12; allowance (2) amounts (2) announcement (2)

 122:15,17,19;126:22; 148:19;158:9;160:5; 131:20;139:3 53:25;234:4 27:17;28:18 

137:25;142:1;149:24; 166:25;170:2;172:13; allowed (9) AMS (2) announcements (1)

 150:5 175:7,24;178:15; 74:25;75:3;128:25; 21:12;29:8 21:19 

agent (17) 181:18;183:3;185:20; 135:10;136:21;146:2; Amy (60) announcing (1)

 9:22,25;20:5;37:8, 187:24;196:6;197:2; 147:1;149:4;213:13 28:10;31:5;36:21, 24:8 

11,20;39:25;48:3; 204:3;207:19;213:9; allowing (2) 23;41:15;63:18; answered (2)

 83:10,21,25;84:1; 220:8;221:2;223:6; 32:3,12 68:16;72:24;79:7; 39:18;187:7 

Min-U-Script® Burke Court Reporting & Transcription (2) advisors - answered 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 4 

October 25, 2023 

antibiotics (1)

 204:10 

anticipate (2)

 90:1;131:6 

anymore (1)

 131:19 

Anyways (3)

 91:19;96:10;187:5 

AOAC (2)

 88:24;91:15 

apart (1)

 116:25 

apologize (3)

 62:24;66:17;96:7 

apparently (5)

 23:6,7;102:10;

 112:24;232:1 

appeal (2)

 33:11,22 

appealing (1)

 216:4,5,20;235:23 

appreciated (3)

 23:24;64:24;125:7 

approach (6)

 55:19;56:10;90:17;

 91:1;175:10,12 

appropriate (3)

 81:16;187:3;195:25 

appropriately (1)

 232:20 

approved (8)

 8:25;130:15,15;

 138:18;142:10,15;

 210:20;217:5 

aquaculture (1)

 215:8 

aqueous (9)

 185:12,15,18,21;

 186:6;187:19;190:7,

 9;191:16 

66:8 

aspect (1)

 171:5 

aspiring (1)

 72:22 

asset (1)

 84:24 

assign (1)

 106:23 

assist (2)

 72:10;156:18 

Assistance (8)

 14:4;31:9,13,18;

 72:20;75:1,10;84:9 

associated (1)

 112:5 

Association (6)

 6:2;30:19,21;58:11;

 91:17,19 

associations (1)

 169:16,19;179:23;

 195:18;221:19;230:8 

avenue (2)

 54:3,4 

average (1)

 81:11 

aware (7)

 12:4;20:13;38:4;

 49:10;58:20;197:14;

 216:9 

away (11)

 110:14;154:10;

 164:18;165:9;167:16,

 20;169:3;178:1,8;

 180:14,19 

awesome (2)

 65:24;68:7 

bail (1)

 166:8 

bailing (1)

 182:3 

balance (5)

 61:11;106:19;

 115:5,9;116:4 

balances (4)

 80:20;106:10,12;

 116:5 

band-aid (2)

 165:11;167:9 

bang (1)

 179:6 

bang- (1)

 99:13 

bank (1)

 8:5 

banker (1)

 8:8 

B 

16:24 archived (1) 147:16 b2i (1) barn (3)

applaud (1) 95:8 Association's (1) 146:3 103:5,6,9 

7:19 area (15) 72:6 b2iwhich (1) barrier (8)

applause (14) 9:20;11:8,15;13:4, assume (2) 146:5 75:8;77:7,8,9;

 21:23,24;27:21,22, 23;14:6;20:1;36:16; 41:4;188:8 baby's (1) 78:16;146:21;156:19;

 25;28:4;34:22;62:5; 42:16;61:14;64:12; assuming (2) 123:23 172:24 

99:16;123:11;124:1; 80:11;125:7;215:13; 41:16;188:3 back (66) barriers (5)

 183:16,18;236:3 225:3 assumption (1) 0:8;12:16;16:6; 70:16;72:10;75:4,

applicable (1) areas (22) 94:19 18:7;21:16;27:18; 12;196:20 

92:12 7:16;10:11;13:20; assurance (2) 29:7;36:7;38:12,20; base (3)

applicants (1) 45:1;50:18;56:8;64:8; 64:13;196:23 41:11;48:4;51:17; 82:10;162:1;230:8 

119:22 65:19;70:12;72:4; Atlanta (3) 52:12;53:8;62:8; based (14)

application (12) 83:8;90:15;106:13; 218:5;220:13; 63:15;68:16,19;72:7; 13:5;16:9;17:5;

 46:21;76:3;78:14; 124:25;138:25;139:4; 229:22 81:18,23;85:19;91:6; 42:16;45:1;48:6;53:2;

 104:13;105:3;116:4; 163:13,25;182:6; Atmospheric (1) 93:4;96:14,24,24,25; 72:5;74:24;95:15;

 129:21;132:20,21; 212:17;217:11; 212:7 98:6,15,17,22,24; 113:18;156:15;159:8;

 161:25;189:3;195:22 224:11 attached (1) 99:21;105:2,2;107:3; 186:24 

applications (3) arms (1) 69:17 108:11;109:16; bases (1)

 101:8;197:5;234:5 76:18 attempt (1) 115:18,25;123:17; 120:15 

applicators (3) army (1) 85:21 127:19;132:19; basic (4)

 55:4;186:15;202:17 74:8 attend (1) 133:15;136:15; 83:22;84:1;108:18;

applied (4) around (32) 85:6 137:25;139:1;149:2, 202:13 

129:20;223:21,23; 6:3;14:21;28:18; attention (3) 7;160:19;176:19; basically (10)

 232:12 36:20;37:7;52:18; 64:11;69:17,24 177:15;183:25; 94:8;101:5;102:23;

applies (2) 55:4,24;72:6,12,19; audible (5) 185:10,13,14;201:24; 186:13,23;188:23;

 104:14;144:5 89:15,19;90:8,13,20; 23:10;103:8;124:5, 212:22;214:21,23; 194:15;197:7;202:18;

apply (4) 94:2;101:8;115:10; 7;170:20 216:17;218:18;224:6; 223:18 

29:23;39:4;212:24; 124:23;125:9;126:16; audience (2) 229:12 Bayberry (1)

 223:25 146:17,18;148:12; 60:14;176:25 backbone (1) 236:7 

applying (1) 158:9;160:8;175:20; audits (2) 194:10 BBDM (1)

 163:22 177:12;179:7;195:16; 92:22;213:1 background (5) 169:18 

appreciate (39) 229:24 August (2) 0:13;86:16,25;88:1; BBMF (1)

 21:13;27:24;30:4; ARSENAULT (2) 0:20;20:20 100:2 157:1 

34:20;56:9,18;62:3, 23:1,4 authorities (1) bacteria (1) BD (477)

 20;64:6;69:17;73:3; art (1) 102:24 208:7 35:8,13,24;36:11;

 75:15;86:6,24; 96:21 authority (5) bacterial (2) 38:2,17,23;39:10,13;

 111:11;115:3;122:14; article (1) 9:10;84:3;88:6; 129:24;193:17 40:4,8,19,22;41:4,23;

 123:16,24;127:13,22; 99:6 213:7;215:8 bad (2) 42:2;43:6,9,24;44:4,

 128:3;133:10;143:23, articles (2) available (19) 94:17;184:15 12,22;45:3,8,10,13,

 25;149:21;154:9; 189:12;193:11 12:19;38:14;43:13, bag (3) 16,19;46:2,6,15,18,

 162:20;164:25; articulate (1) 16;50:22;75:4;76:5; 171:13,15,22 24;51:15;52:11,16,

 177:18;179:16;194:3; 100:20 128:10;129:2;139:4; bags (3) 22;53:1,6,16,20;

 198:1;206:6;215:23; articulated (1) 162:14,15;165:7; 171:12;177:11,12 54:14;55:2;56:5,18, 

Min-U-Script® Burke Court Reporting & Transcription (3) antibiotics - BD 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 4 

October 25, 2023 

22;57:1,2;58:1;64:5; 9,13,15,17,19,21,23; 202:22 biodegradable (11) 6:6;65:17,21 

65:13;68:24;69:9,11; 206:12,14,16,18,22, benefit (2) 138:20;154:18,20; Board's (1)

 72:4;75:15;77:5; 24;207:1,3,5,8,11,13, 94:25;183:9 156:20;157:11,20; 214:1 

78:19;81:13;82:5,8; 21;208:20;209:4,6,8, benefiting (1) 159:16;160:11; boats (1)

 83:5;84:7;85:2,15,20; 12,14,16,18,20,22,24; 44:13 169:19;172:16; 210:25 

88:7;91:6,15,20;92:3, 210:1;213:21,23; benefits (2) 173:20 bodied (1)

 7,15;93:5,8,12,14; 215:15;219:3,5,9,11, 69:15;82:25 biodegrade (1) 208:6 

94:13,16,18,22;95:23, 13,15,17,19,21,23,25; benign (2) 159:20 bodies (1)

 25;96:4;97:10; 220:9;221:3,11,12; 187:20;193:5 biological (2) 216:1 

102:13;103:5;108:24; 222:3,7,9,11,13,15,17, berry (1) 130:12,16 body (2)

 109:9,13,19,22; 19,21,23,25;223:7; 195:25 birds (2) 166:18;196:13 

110:13;115:1,3,14; 225:19,24;226:7,9,14, besides (1) 142:24;186:1 bolstering (1)

 116:16,22;117:12,17, 25;227:11,13,18; 197:14 birthday (3) 26:2 

20,25;118:8,14,18; 228:3,13,15,17,19,21, best (17) 123:5,10,23 book (2)

 119:14;120:5,10,13, 23,25;229:2,4,6,8,17; 21:12;36:13,22; Birthing (1) 120:11;150:11 

25;121:8,12,14,16,18, 230:23,25;231:2,4,6, 51:21;52:4;62:14; 123:12 border (2)

 20;122:1,3,5;124:5,7, 8,10,12,14,16,18; 78:7,23;92:9,13; bit (41) 56:14;212:11 

9,12;125:24;126:7,15, 232:14;234:20,22,24; 97:11,17,18,23;118:6; 8:16;13:16;15:24; boron (1)

 19;127:1;132:12; 235:1,3,5,7,9,11,13,17 174:20;214:3 24:6;28:23;36:1,3,6; 195:1 

134:9,11,13,15,17,23, beans (1) bet (2) 40:25;41:11;48:8; Both (35)

 25;135:2,4,14,16,18, 54:16 8:10,11 51:20;52:12;56:13, 14:17;16:8;24:14;

 20,22;136:3,5,7,9,23, bearing (1) better (20) 23;60:17;66:10; 26:19;33:19;55:2,10;

 25;137:2,4,10,12,14, 198:2 9:23;17:1,10;31:4; 74:11;85:16;88:1; 65:18;75:18;80:16;

 16,20;138:15;139:18, Beautiful (2) 49:4,15;67:13,15; 90:22;92:19;94:7; 85:18;86:13;91:1;

 20,22;140:3,5,7,9,13, 232:4,4 77:16;96:25;100:12, 105:21;106:7;115:11; 95:4;106:23;107:10;

 15,25;141:2,8,10,12, Beckham (1) 20;104:5;108:10; 118:20;148:22;149:1; 111:1;113:8,9,13;

 14,18,20,22;142:4,7, 123:4 122:10;132:17,25; 161:3;162:13;165:24; 131:22;138:7,15,23;

 13;144:2,22;145:3,5, become (6) 143:16,17;227:4 167:6;178:18;189:16; 146:1;155:15;169:6;

 7,9,13,15,17,19; 30:2,24;31:5;50:11; beyond (1) 207:7;211:16;216:22; 185:16;187:10,11;

 146:7,10,13;148:20; 113:4;216:12 64:15 217:3;218:5,8 194:23;195:23;

 149:18,19,21;150:6, becomes (5) bicarbonate (2) bitter (1) 197:25;203:22;

 13;151:1,3,5,7,11,13, 81:5;83:23;110:22; 132:16,18 197:9 230:10 

15,17,19;152:8,10,12, 147:3;230:8 big (39) Black (1) bottom (5)

 14,18,20,22,24;153:1, becoming (1) 7:23;14:13;17:11; 76:7 15:20;26:2;93:20;

 12;158:10;159:7,15; 74:16 21:23;26:9;27:22; blame (1) 103:3;113:13 

160:24;161:1,4; bed (1) 39:7;50:6;54:15; 177:9 boundaries (3)

 163:12,16,19,24; 164:14 59:11;61:11,18;71:9; blanket (1) 104:20;106:3;

 164:2,6,12;165:2,19; beds (1) 72:15;76:10;100:25; 164:22 112:18 

166:18,23;167:1,3; 154:2 102:21;103:24,25; blight (3) bounds (1)

 168:6,8,10,19,20,22; Beer (1) 104:10;114:14; 204:6,6,8 75:5 

169:9;170:3,8,11,13, 236:7 115:22;116:19; blow (1) Box (2)

 14,16,18,21;171:1,3; bees (1) 122:23,24;123:14; 133:3 105:19;149:2 

172:3,14;173:8,15,18; 142:24 133:2;158:16,17; blue (2) boy (1)

 174:9;175:1,5,6,8,25; beg (1) 159:25;160:14; 59:24,25 77:24 

176:9,15,18;178:14, 56:25 173:16;174:21; blueberries (1) boys (1)

 22,25;179:3,14,17; begin (2) 176:15,18;178:11; 221:7 7:11 

180:11,21;182:13,21; 86:12;155:24 194:9;215:8;235:25 blueberry (2) Brad (1)

 183:1;184:7,9,11,13, beginning (5) bigger (4) 221:5;223:22 6:1 

16,19,21,23,25;185:2, 17:1,5;85:8;108:16; 32:7;108:16; Board (41) brain (1)

 5,21;187:25;188:7,10, 157:13 112:20;183:6 0:3;16:2;24:2;35:7; 63:3 

11,12,15,16,20;189:4, behalf (1) biggest (6) 38:10;54:10;55:18; bread (1)

 5,7,8,14,15;190:2,14, 84:23 7:20;10:15;30:9; 60:13;62:15;86:15; 74:15 

16,18,20,22,24;191:1, behind (4) 49:10;116:12;146:15 90:7;91:11;98:4; break (10)

 3,5,7,11,21,23,25; 62:15;81:14;142:2; Bill (5) 108:22;122:13,17; 22:15,21;28:20;

 192:2,4,6,8,10,12,16, 216:22 82:20;87:7;112:4,4, 124:18;125:1,2,6; 29:6;62:7,9,13;64:25;

 18;196:7;197:3,20; below (2) 10 126:21;128:1;134:4; 127:17;185:10 

198:10,12,14,16,18, 61:8;130:8 billion (2) 143:21;155:18; breakdown (4)

 20,22,24;199:3,5,7, benchmarking (1) 82:21;87:2 169:11;174:2;193:11, 43:6;143:5,6;155:5 

15,17,19,21,23,25; 107:15 binding (3) 24;196:3;204:2,9; breaking (2)

 200:2,6,8,10,12,21,23, beneficial (4) 96:9;110:1,1 210:19;212:15;214:4, 39:3;146:22 

25;201:2,4,6,10,12, 57:11;62:2;203:3, biobased (5) 7,16,24;218:7; breaks (2)

 14,16,18;202:2,7; 25 159:16;160:11; 220:13;233:7 40:15;130:2 

204:4,16;205:1,3,5,7, beneficials (1) 169:19;173:8,10 boards (3) breathe (2) 

Min-U-Script® Burke Court Reporting & Transcription (4) beans - breathe 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 4 

October 25, 2023 

22:4;93:11 

breathed (1)

 127:22 

Brian (49)

 102:2,4,6;121:13;

 132:9;133:11,13;

 134:10;135:15;

 136:22;139:13;

 140:14;141:19;

 144:19;145:14;

 147:10;148:18;

 151:12;152:19;158:9;

 174:4,5;184:18;

 185:16,20;190:3,7,10,

 23;191:18;192:3;

 197:2;198:15;199:18;

 200:22;201:24;

 204:15,22,24;206:8;

 207:12;209:23;

 219:20;221:25;

 222:18;228:24;

 230:20;231:9;235:4 

bridge (3)

 52:4;54:4;82:14 

bridges (1)

 215:25 

brief (6)

 62:10,17;63:6;

 175:21;177:2;185:11 

briefly (1)

 161:2 

bring (10)

 7:24;10:18;53:8;

 55:24;61:2;67:18;

 89:2;91:13;189:11;

 232:8 

bringing (8)

 61:14;67:24;69:14;

 76:25;80:2,3;123:22;

 177:19 

brings (2)

 87:11;201:22 

broad (4)

 56:23;138:21;

 24;91:5,8,21;92:5;

 93:3;98:7,14;99:20,

 21;105:6;106:16;

 107:14;108:18;119:1,

 3,8,10;120:17,21;

 121:24;122:11;123:6,

 9,15;124:2;127:8;

 133:9,15;134:2,21;

 135:6,12;136:1,13,17;

 137:8,22;138:1;

 139:10;140:1,18,22;

 141:6,24;142:8;

 144:10,17;145:1,21;

 146:9,11;150:9,14,24;

 151:21;152:6;153:5,

 8;160:6,25;161:2;

 162:20;163:13,18,21,

 25;164:5,11,25;

 170:20,24;171:2;

 175:3;181:19;184:1;

 185:4,6,14;190:6;

 191:9,13;192:14,20;

 197:17;198:2;199:1,

 9;200:4,14;201:8,20;

 202:5;204:20;205:11,

 25;206:5,20;207:15;

 208:25;209:10;210:3;

 216:21;218:23,24;

 219:7;220:2;221:14,

 23;222:5;223:2;

 228:6,11;229:10;

 230:18;231:21,23;

 232:2,5;234:15;

 235:15,19 

bruised (1)

 157:14 

bucket (1)

 84:17 

Budget (1)

 93:21 

buffer (1)

 72:15 

build (7)

 69:21;70:4;73:12;

 77:19;89:22;90:21;

 114:16;213:6,8 

Bureau (3)

 6:4;84:20,25 

bureaucratic (1)

 94:12 

burning (2)

 164:9;195:11 

burying (1)

 162:2 

bushels (2)

 104:4;116:9 

business (8)

 77:1;79:3;80:1;

 81:9;87:2;178:19;

 180:6,9 

businesses (1)

 25:11 

busy (3)

 76:20;78:4;123:22 

butter (1)

 74:15 

button (1)

 7:4 

buy (10)

 8:6;26:4;42:6,12,

 13;158:23,24;159:10,

 11;171:15 

buyer (1)

 79:15 

buyers (1)

 68:6 

buying (4)

 26:6;42:11;64:20;

 68:6 

bycatch (2)

 210:23;211:5 

byproduct (1)

 211:5 

byproducts (1)

 211:3 

21;188:7,11,15,20;

 189:5,8,15;190:24;

 192:4;197:3,20;

 198:16;199:19;

 200:23;202:2,7;

 204:16;205:1;207:13;

 209:24;219:21;

 222:19;228:25;

 231:10;235:5 

California (2)

 17:17;163:14 

call (10)

 8:24;24:10;26:25;

 27:3;28:9;30:12;

 101:11;108:18;

 147:25;203:7 

called (7)

 17:13;69:13;77:25;

 81:18;195:12;197:9;

 229:25 

calling (1)

 71:22 

calls (1)

 110:21 

came (11)

 7:17;8:9;12:4;

 14:25;15:3;65:10;

 75:22;76:7;130:19;

 169:14;227:25 

campaigns (1)

 74:9 

can (210)

 7:5,5;8:4,5,5;10:2,

 5,20;11:1,8,22,23;

 12:1,11,15,16;13:3,

 19;14:7;15:19;16:23;

 17:7,10,23;18:20,22;

 19:2,23;20:2,4,5,6;

 21:10;23:6,7,18;28:3;

 29:12,14;30:23;

 32:24,25;35:20,22;

 36:1,6,10,13;38:7,14;

 40:3,11,17;41:4,11;

 43:20,20;46:11,14,16;

 127:5;128:11;133:3;

 137:24;138:6;139:4;

 142:23;149:1;155:3;

 158:14,24;159:14;

 160:14;162:1,3,4,11;

 164:7,16,17;167:14,

 22;171:20;172:6,8,9,

 11;173:20,23;174:14;

 175:10,13,14,19,25;

 176:2;178:25;179:1,

 6,22,23;180:21,23,24,

 25;181:22;182:17;

 187:13,21;188:13;

 193:8;195:9;196:19;

 197:13,20;202:22;

 203:8,14,16;210:7;

 213:21;214:4,7;

 216:7;223:22;225:2;

 226:3;227:9;229:18;

 232:17,17 

Canadian (2)

 154:12;168:17 

candy (2)

 89:10;216:1 

capabilities (2)

 110:19;111:5 

capable (1)

 28:10 

capacity (3)

 64:19;75:21;106:25 

capital (1)

 114:15 

capital-intensive (1)

 8:3 

capture (1)

 79:10 

carbon (2)

 144:18;171:8 

carbonate (3)

 142:2,9;144:18 

cardboard (1)

 149:16 

cards (1)

 79:13 

C 

144:12;167:9 87:15;165:8;181:8; CACS (8) 47:13,14;50:20,22; care (1)

broader (1) 215:25 62:7;68:17;98:23, 51:11,19;52:3,8,9,12; 99:8 

60:14 building (8) 23;99:18,22;119:18; 53:10,13;55:5,19; career (3)

broke (1) 70:11;77:14;79:20; 123:19 56:10;59:7;61:2,17; 0:23;7:12;113:21 

96:15 80:1;111:5;125:11; cadastral (1) 64:3;65:1,8,13,21; careful (4)

brokers (1) 175:14;217:15 115:19 66:5,14,19;67:1,3,25; 97:15,21;147:21;

 119:24 builds (1) calcium (4) 69:4;71:6;72:16; 202:17 

brought (9) 207:6 197:8,21;201:25; 74:10;75:13;78:10; carefully (1)

 12:6;20:5;54:23; built (1) 202:8 79:22;82:10,12;84:2, 82:11 

87:7;165:25,25; 113:10 CALDWELL (47) 3,13,25;85:12,23; Carolina (1)

 187:8;189:9;194:3 bulk (1) 102:4,6;121:14; 86:19;88:20,20;90:1, 102:7 

BRUCH (148) 229:23 133:13;134:11; 18;91:23;93:10;94:7; Caroline (1)

 28:17;34:23;39:12; bullet (1) 135:16;136:23; 95:15,20;96:14;97:6, 134:5 

43:22;46:25;51:13; 51:8 139:13;140:15; 21;101:2,11,15; Carolyn (41)

 53:9,17;56:20;58:5; bunch (1) 141:20;144:20; 103:21;104:17,19; 47:1;51:13;62:22;

 59:3;60:8,11;61:21; 68:25 145:15;148:20; 105:1;106:6,7;107:7, 63:23;68:9,12;74:18;

 62:6;63:20;65:24; BURCH (2) 149:19;151:13; 12;109:19;115:8,22; 75:16;81:1,15;

 68:16,18;69:8,10; 122:7;127:20 152:20;158:10;174:9; 118:3;119:17,21; 113:14;116:17;121:9;

 73:1;80:8;86:5,7,19, burden (6) 175:5;184:19;185:5, 124:25;125:1,4,6,21; 125:23;126:8;136:10; 

Min-U-Script® Burke Court Reporting & Transcription (5) breathed - Carolyn 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 4 

October 25, 2023 

137:17;140:10; 229:24 225:9 21,23,25;191:2,4,6,8, changes (12)

 141:15;145:10;151:8; central (2) CHAIR (529) 10,12,12,19,22,24; 15:13;16:23;19:10,

 152:15;158:18; 37:6;225:10 0:3;22:12;27:2; 192:1,3,5,7,9,11,13, 22;29:1;48:6;61:6;

 165:25;177:5;181:7; cents (1) 62:11;63:23;64:4; 15,17,19,19;196:3,5; 63:12;119:10,12,13;

 183:3;184:14;190:19; 171:15 65:12;66:17;67:5; 197:1,23,25;198:8,11, 208:7 

191:24;198:11; certain (6) 68:4,11,16,17;69:7; 13,15,17,19,21,23,25; changing (2)

 199:14;201:17; 33:15;44:25;48:4; 72:2,24;74:1;75:2; 199:2,4,6,8,8,14,16, 25:1;148:12 

205:20;207:4;209:19; 50:18;67:24;224:2 76:12;77:4,24;79:6; 18,20,22,24;200:1,3, characterization (1)

 219:16;222:14; certainly (7) 81:1,12;82:4,7;83:4, 5,7,9,11,13,13,19,22, 227:1 

228:20;231:5;234:25 11:17;14:21;24:12; 24;84:16;85:14,18; 24;201:1,3,5,7,9,11, charge (1)

carpet (1) 30:11;203:1;214:10; 86:3,4,17,21;93:2,4,6; 13,15,17,19,19;204:2, 88:19 

45:11 216:8 96:3;98:3,6,11,15,21; 14,19,24;205:2,4,6,8, chart (1)

carrot (2) certainty (1) 99:3,17;100:22; 10,12,14,16,18,20,22, 112:3 

160:18;161:10 103:21 102:5,7,15;103:6,9; 24,24;206:3,10,13,15, chat (1)

carrots (1) certificate (3) 106:14,17;108:4,22; 17,19,21,23,25;207:2, 111:3 

161:9 19:13;29:9;107:9 109:8,12,18,21;110:3; 4,6,7,9,12,14,14; cheap (1)

carryover (1) certification (20) 111:8;112:12,15; 208:19,23;209:2,5,7, 177:8 

39:2 19:14;54:17,25; 113:14,20;114:23; 9,11,13,15,17,19,21, check (3)

Carson (1) 55:8;71:21;72:10; 115:2,13,16;116:21; 23,25;210:2,2;213:20, 101:24;115:22;

 6:1 75:4,8;76:2,3;77:8,8; 117:5,13,18,24;118:7, 22;215:12;216:16; 116:14 

carve (2) 82:17;87:12;103:1, 13,17,25;119:2,6,9, 218:20;219:1,4,6,8, checks (2)

 126:17,23 12;118:10;119:22; 11,16;120:9,12,15,19, 10,12,14,16,18,20,22, 80:19;100:12 

case (5) 149:5;234:1 22;121:3,9,11,13,15, 24;220:1,1;221:1,10, cheese (5)

 212:3,20;215:3,3,6 certified (9) 17,19,21,23,25;122:2, 13,21;222:1,4,6,8,10, 229:13;230:7,11,

cases (1) 31:25;41:18;74:7; 4,6,6,9;123:4,8,10,13, 12,14,16,18,20,22,24; 13,19 

11:11 81:9,9;92:12;104:7; 17,18;124:3,6,8,10; 223:1,1;225:17; chemical (2)

catalyzed (1) 114:5;119:23 125:13;126:3,6,14,18, 226:8,24;227:12; 29:23;224:17 

79:17 certifier (18) 25;127:2,12;133:16, 228:4,9,12,14,16,18, chemicals (2)

catch (2) 46:4;64:16;72:15; 17,20,24;134:8,10,12, 20,22,24;229:1,3,5,7, 155:19;156:1 

34:17;215:14 100:23,24;101:3,20, 14,16,18,20,22,24; 9,9;230:16,21,24; chemigation (1)

categories (4) 22;110:12;114:17; 135:1,3,5,5,8,15,17, 231:1,3,5,7,9,11,13, 132:21 

71:1,15,19,23 116:10,12;118:15; 19,21,23,25;136:2,4, 15,17,19,22,22,25; Chemist (1)

category (2) 120:2;131:12,13; 6,8,10,12,12,15,18,24; 232:4;234:13,18,21, 91:18 

75:17;170:17 217:7;233:17 137:1,3,5,7,9,11,13, 23,25;235:2,4,6,8,10, Chemists (2)

catered (2) Certifiers (56) 15,17,19,21,21,24; 12,14,16,18,18;236:2, 91:19,19 

224:1,3 58:10,15;70:5;72:8, 139:6,9,16,19,21,23, 4 chest (2)

cause (4) 14,22;76:18;89:21, 25;140:2,4,6,8,10,12, chairman (1) 79:14;186:10 

138:20;187:15; 23;91:25;92:18,20; 14,16,16,23;141:1,3, 6:5 chew (2)

 225:2,5 93:17;96:18;97:24; 5,7,9,11,13,15,17,19, challenge (10) 188:2,21 

causes (1) 99:10;100:5,6,8,11, 21,23,23;142:1,5; 29:11;100:4; children's (1)

 224:25 13;101:19;103:22; 143:22;144:9,14,21, 160:16;163:5,10; 193:13 

caustic (1) 104:2;106:1,22; 23,25;145:2,4,6,8,10, 171:11,24;178:3,10; chloride (8)

 202:16 107:7,18;108:6; 12,14,16,18,20,20; 213:2 232:11,13,16;

cauterize (1) 110:7,21;113:1,25; 146:12;148:18;150:2, challenged (1) 233:23,25;234:3,4,16 

207:24 114:1,2,3,4,9,18; 4,7,20,23,25;151:2,4, 132:2 chloridePVC (1)

caution (1) 117:16;118:2,4; 6,8,10,12,14,16,18,20, challenges (21) 153:11 

180:6 119:19;120:1;147:17; 20;152:4,7,9,11,13, 6:16;7:20;22:24; chocolate (2)

cavities (1) 148:8;154:4;212:22, 15,17,19,21,23,25; 23:3;29:16;35:2; 96:16;232:3 

99:19 23;213:2,3,6,8; 153:2,4,4,7;158:7,18; 55:24;65:4,9,14;66:6, choice (1)

CBOT (1) 233:13,25;234:8 159:14;160:4;165:1, 12;70:17;73:21; 42:5 

80:24 certify (3) 20;166:17,20,25; 127:14;160:13; choose (1)

CCOF (2) 100:7;107:18;110:9 167:2;168:4,7,9; 163:23;181:21;212:4; 118:4 

107:7;114:4 certifying (2) 169:8;170:1;172:2, 233:22;234:10 chosen (2)

celebrate (1) 103:20;104:7 13;173:6,14,25;175:4, challenging (4) 142:25;212:10 

182:11 cetera (3) 7,24;176:8,14,17; 45:6;50:24;132:1; circle (1)

cell (4) 106:13;119:24; 177:1;178:16,24; 160:21 135:13 

188:5,18,19;194:19 160:18 179:2,13,16,25; chance (1) circles (1)

cells (2) CFR (1) 180:20;181:1;182:9, 162:3 71:23 

189:18;194:19 96:19 19,23;183:3,10,12,14, change (12) circulated (1)

Center (6) chain (7) 19,25;184:5,8,10,12, 9:16;19:12;48:17; 182:2 

30:20;97:14,15,18, 70:11;82:15;86:10; 14,17,20,22,24;185:1, 90:23;93:23;94:20; citation (1)

 22,23 87:6,15,16;166:3 3,5,9,12,13;187:24; 95:11;112:17,18,19; 97:7 

centered (1) chains (1) 190:3,4,12,15,17,19, 117:2;172:10 cite (2) 

Min-U-Script® Burke Court Reporting & Transcription (6) carpet - cite 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 4 

October 25, 2023 

96:19;97:7 closely (1) 101:17 214:14,14;216:5,19; compared (2)

cited (1) 189:10 combined (1) 217:1,9,9;218:6,21; 132:15;195:5 

204:9 closer (1) 215:6 220:18;223:11,12; comparing (1)

citric (2) 142:24 comfortable (2) 224:6,10;225:7,7,10, 40:20 

210:8;218:15 closing (4) 83:9;229:21 25;226:23;230:5,6,9, compensated (1)

City (2) 15:5,6,10;215:7 coming (17) 9,10,16;233:7,8; 85:11 

0:21;221:9 club (1) 10:8;18:7;24:12; 234:13 compensation (1)

claim (5) 20:21 27:23;28:4;49:8;65:5, comments' (1) 60:3 

19:18;33:8;46:9; clusters (2) 9;66:1;98:17;111:14; 91:12 competing (1)

 58:8;230:11 57:8,9 122:20;125:18; commercial (1) 10:4 

clamshell (1) coalition (3) 140:17;165:10,16; 217:19 competition (1)

 171:21 154:5;211:17;227:8 214:3 Commission (2) 79:23 

clarification (5) coalitions (1) commend (1) 125:6,9 competitive (2)

 35:14,24;96:5; 147:18 24:12 commitment (1) 26:1,3 

109:20;227:14 Code (3) comment (48) 73:5 compile (2)

clarify (1) 96:24;102:19; 20:14,15,20;26:15; Committee (10) 90:1;155:23 

149:22 112:10 35:15,22;45:21;58:6; 6:5;91:10;122:14; complement (1)

Clarifying (4) codes (3) 60:8;74:2,19;76:1; 124:13;127:21;187:6, 130:11 

90:5,6;117:6; 100:9;104:12; 77:6,11;79:4;83:5; 18;196:25;208:14,16 complementary (1)

 119:14 107:20 84:7;93:15,25;94:1,6; committees (1) 87:22 

clarity (6) codified (1) 95:12,12;105:10; 122:24 complete (8)

 72:12;119:5; 9:12 111:12;129:22; commodities (3) 30:8;47:25;48:7;

 124:20;211:23; cognizant (1) 138:22;144:10; 15:23;19:2;60:23 214:12;215:3,4,5,5 

213:18;216:13 195:2 155:14,25;168:8; commodity (3) completed (2)

class (1) coined (1) 169:9,24;176:10; 16:20;80:3;163:4 211:7;213:10 

155:19 100:15 187:25;188:20; common (6) completely (12)

classify (3) cold (1) 194:17;195:16,20; 105:12;107:21,25, 7:14;21:9;29:18;

 134:1,4,6 172:18 196:7;208:10;216:25; 25;185:24;187:15 75:5;83:24;95:8;

clean (1) cold-called (1) 218:1;220:20;221:14, commonalities (1) 169:1;171:14;183:10;

 171:16 64:6 16;223:13;233:20 156:13 194:17;224:22;

cleaning (4) collaborate (1) commented (1) commoners (1) 229:20 

138:17,17,17; 38:9 110:4 105:20 complex (2)

 142:15 collaborated (1) commenter (3) commonly (1) 169:10,11 

clear (20) 6:17 157:5;218:9;230:7 147:10 complexity (3)

 22:1;25:8;33:4; collaboration (1) commenters (16) communicate (1) 211:10;212:10,11 

37:21;65:15;88:13; 51:20 106:18;122:18; 101:18 compliance (14)

 89:7;94:13;108:25; collaborative (2) 138:23;154:7;155:2, communication (3) 47:13,21,24;48:1,1,

 111:24;118:6;125:4; 86:10;100:1 7;156:2,23;157:23; 118:4;124:19;125:3 9,11,20,20;54:22;

 147:15;148:4,6; collaboratively (1) 162:22;194:7,20; communities (5) 87:12,17;89:9;232:1 

180:11;203:1,23; 100:1 195:8,14;217:18,22 28:22;62:20;77:14; compliant (4)

 212:14,19 collate (1) commenting (1) 82:13;129:25 64:20;143:19;

clearance (2) 101:5 97:5 community (43) 220:24;230:14 

95:4;170:23 colleague (1) comments (98) 34:25;37:3;66:11, complicated (2)

cleared (1) 182:15 11:18;16:25;26:15, 23;70:20,25;73:5; 113:11;159:5 

196:14 collect (4) 16,16;34:25;62:17; 79:12,18;85:10; complies (1)

clearing (1) 38:13,15;51:4; 66:3,3;69:1,3;71:9, 90:19;94:11;100:19; 156:22 

65:3 100:9 12;72:2;73:18;75:23; 105:8,9;108:1;128:2, compliment (1)

clearinghouse (1) collected (2) 76:7;85:23;89:6,19; 12;129:15;147:6,14; 231:23 

65:18 67:9;100:5 91:13;98:4;108:12; 155:5;159:22,24; compliments (1)

clearly (3) college (1) 109:1;110:1;122:20; 160:9;165:12;166:11; 231:24 

18:3,23;210:17 99:3 125:7;126:4;128:3, 167:16;171:6,10,24; comply (2)

clients (1) color (3) 16;130:1;131:9,11,11, 173:21;174:20; 92:16,24 

107:1 19:3;70:17;85:9 15;132:9;133:8,18; 183:21;195:22; complying (1)

climate (2) Colorado (2) 138:22;139:2,6; 210:14;212:18; 92:14 

50:7;62:25 171:12,15 143:6,11,12;144:14; 213:19,24;214:7,19; component (4)

Climate-Smart (1) colored (8) 147:6;150:2;154:4,8; 217:6;233:6 76:22;126:24;

 62:24 146:4,6,17;147:7,9; 155:13,15,17;158:1; companies (5) 204:5,10 

close (6) 150:17;151:25;152:2 159:8;160:1,1; 9:1,4;10:4;73:10; components (1)

 15:4,4;79:13;98:10; colors (1) 165:23;183:12,21; 178:6 76:25 

213:19;226:2 229:15 187:9;193:4;195:19; company's (1) compost (7)

closed (4) column (1) 197:23;203:21; 55:6 146:7,24,25;147:1;

 211:9;212:4; 101:15 204:15;208:8,13; comparable (1) 149:23;150:4;151:24 

216:10,12 columns (1) 211:15;212:16,20; 12:7 concentrate (1) 

Min-U-Script® Burke Court Reporting & Transcription (7) cited - concentrate 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 4 

October 25, 2023 

202:19 6:1 194:22 172:23;175:4;185:20; 60:13,13,15;106:22;

concentrated (1) connection (1) containers (3) 192:25;193:1;194:14, 161:23,24;162:3 

202:16 51:24 155:20,22;166:8 17;197:10;199:13; corner (1)

concentrations (2) cons (1) contaminants (1) 203:17;204:6,6; 116:23 

186:18;225:1 26:22 88:20 206:7;207:23;208:10, corns (1)

concept (1) consensus (10) contaminating (1) 11 12:13 

104:16 195:16;212:14,17; 54:1 controls (2) correcting (1)

concern (11) 213:9,24;214:3,5,21; contamination (9) 130:12,16 150:10 

102:17;112:17; 215:3,5 89:10;90:2;154:24; controversial (1) correction (1)

 147:25;154:6;155:5, consent (1) 155:9,12;157:11; 214:20 194:5 

11;159:12;165:24; 126:22 195:12,13;217:24 conventional (24) correctly (3)

 175:20;195:11; consequence (1) contaminations (1) 10:13;12:9,12; 48:21;143:1;170:4 

226:11 155:10 155:16 16:15;33:15;43:12; correlated (1)

concerned (4) consequences (1) content (1) 50:12;52:19;53:11; 188:25 

148:25;166:3; 113:18 95:2 54:11;57:19;59:17; correspond (1)

 215:19;226:15 Conservation (2) contest (1) 60:12,14,22;80:19,23; 8:12 

concerning (1) 33:4;70:8 182:10 81:17,20,23;132:1; corresponds (1)

 143:2 consider (12) context (3) 156:4;167:22;224:9 102:23 

concerns (28) 46:22;82:1;85:5; 77:11;95:2;204:12 conventionally (1) corrosion (1)

 58:17;90:2;109:22; 90:7,14;118:1; contexts (1) 83:11 143:10 

129:22;154:22,23; 125:17;157:1;168:20; 146:19 conver (1) cost (9)

 181:10;186:6,7,12,13, 175:22;180:6;203:19 continental (1) 126:11 71:21;77:8;78:16;

 14,16,21,24;187:16; considerably (1) 57:3 conversation (19) 80:4;82:17;89:22;

 194:8;195:8,13; 87:2 continual (1) 8:18;34:21;47:3; 138:24;165:6;167:17 

202:23;208:1;214:13, consideration (4) 52:5 56:19;65:17,21,22; cost- (1)

 15,17;217:17,18; 85:12;175:8;177:7; continually (2) 66:18;96:22;104:16; 156:24 

218:9;229:24 196:24 17:9;24:22 110:7,14;113:15; Costa (1)

concludes (1) considered (5) continue (11) 127:3;159:5;166:13; 224:11 

122:11 33:4;138:19; 6:10;27:6;28:19; 174:10;216:20; cost-effective (1)

conclusion (1) 143:19;149:13;233:4 62:4;65:14,17;70:21; 229:23 233:4 

159:18 considering (1) 86:1;210:24;220:23; conversations (6) costly (1)

conclusions (1) 59:8 233:5 20:24;27:7;111:10; 179:8 

57:18 Consistency (5) continued (8) 125:22;127:25;181:9 costs (5)

concrete (1) 25:22;99:10; 26:4;154:8;193:16; convey (1) 29:22;77:9;82:17,

 72:21 100:11;193:25; 220:19,20,21;230:6; 38:14 19;164:3 

condition (2) 233:24 233:8 cool (1) cotton (1)

 110:11;197:9 consistent (12) continues (1) 68:3 13:7 

conditions (5) 25:8,10,14,17,17, 230:11 cooper (1) could-called (1)

 25:14;108:19; 18;99:24;101:25; continuing (4) 143:17 80:13 

217:11;220:22; 108:6;117:16;119:20; 24:20;85:24; cooperate (1) council (3)

 226:12 172:5 111:17;148:5 79:23 38:4,5,5 

conduct (1) consistently (1) continuous (5) cooperation (1) councils (1)

 100:14 100:5 25:5;27:11;35:3; 79:24 38:8 

conducted (3) constantly (2) 99:11;103:15 cooperatives (1) Council's (1)

 132:14;193:12; 24:25;83:9 contract (14) 79:24 94:4 

223:15 consternation (1) 9:2,5;12:3,13,14; coordinates (2) counterparts (1)

conducting (2) 108:12 53:10,12;59:21,22; 107:17;119:22 59:18 

156:12;172:7 consultants (3) 60:1;61:2,13;80:22; coordinator (1) counties (4)

confidence (2) 74:5;83:7;147:16 179:20 0:19 67:14,15;84:13,14 

26:4,7 consulting (3) contracted (1) co-polymer (1) countries (4)

confident (2) 75:10;77:6,9 60:24 229:15 74:9;100:15;

 27:14;113:24 consumer (8) contracts (3) copper (7) 107:15;227:16 

conflict (1) 26:3,7;71:20;81:22; 59:19;80:3,21 130:23;131:1; country (3)

 65:5 82:1,10;177:4;183:7 contradictory (1) 132:15;143:8,8,14; 15:1;35:17;177:12 

confused (1) consumers (11) 158:23 187:22 county (11)

 75:1 27:14;71:20;79:22; contribute (1) copy-editing (1) 11:7,21;12:1;13:6;

confusing (1) 99:9,13;158:3,5,21, 157:11 109:14 14:7,9,10;83:10;84:1;

 113:16 22;159:10;177:11 contributions (1) core (1) 115:19;116:11 

confusion (2) contact (6) 68:15 25:6 couple (20)

 50:3;109:5 40:2;52:5;65:3; control (26) corn (20) 10:8;16:16;19:12;

Congress (2) 128:21;132:22; 128:20;130:17,17; 12:10;15:16;41:13, 21:8;22:24;23:2;

 51:2;56:1 194:16 131:20,23;132:5; 13,13,14;42:6,8,19; 63:12;66:14;67:15;

Congressman (1) contain (1) 136:22;164:17,22,23; 52:13;59:14,24,25; 73:1,4;79:9;87:3; 

Min-U-Script® Burke Court Reporting & Transcription (8) concentrated - couple 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 4 

October 25, 2023 

127:15;128:16;

 143:12;156:23;

 182:15;233:9,13 

coupling (1)

 73:15 

course (10)

 25:3,16,23;30:6;

 38:11;49:13;68:14;

 84:1;107:5;169:4 

courses (2)

 97:16,22 

court (1)

 181:20 

cover (17)

 13:1;14:17;19:20,

 22,23;20:2,4;38:4,5,5;

 50:25;51:1;98:23;

 119:17;120:15;157:3;

 166:7 

coverage (19)

 10:2,21;12:23,24;

 13:8,8,11,19,25;

 14:12,19;15:18;

 31:15;42:13,20,22,25;

 54:5;55:22 

covered (6)

 28:20,23;29:17,24;

 31:1,2,15;32:8,15,20;

 33:6,7;35:17;36:15;

 37:5,8;38:4,5,5,13;

 40:14;41:6;42:5,14,

 18;47:5;48:23;49:8;

 50:19,20,25;55:7,16;

 57:9,10,19,21,24;

 60:3;61:25;62:25;

 63:3;65:6,13;67:24;

 70:8;89:18;106:21,

 24;116:7,24;135:11;

 136:21;142:10;146:3;

 153:13,14,15;157:3,

 22,22;161:23;163:1;

 169:3;197:8;218:11;

 220:14,23;223:21;

 226:11,20;227:22;

 230:13;232:11 

cropping (2)

 50:21;189:6 

crops (65)

 8:1;10:9,13;12:8;

 13:25;14:14,17;

 16:14,15;17:15,19,19;

 18:19;19:20,22,23;

culture (1)

 153:25 

cumbersome (1)

 64:14 

curative (1)

 203:11 

curious (3)

 56:5;63:24;170:19 

current (5)

 73:21;89:1;154:5;

 220:21;229:24 

currently (13)

 0:15;87:4;88:17;

 100:4;128:24;129:2,

 5;160:20;177:25;

 195:17;210:13;

 211:11;234:2 

Customs (1)

 212:11 

cut (3)

 74:3;122:16;176:3 

cuts (1)

 30:7 

51:19;58:16;100:7;

 110:20,22,23;112:25;

 114:8 

date (8)

 15:4,4,5,6,10;19:15,

 15;46:3 

dates (5)

 20:23;21:3,8;34:14;

 48:19 

Day (19)

 0:8,10;14:21;27:4,

 5,6;28:17;34:16;79:2;

 80:14;83:25;122:23,

 24;123:12;129:11;

 149:2;170:15;173:3;

 235:25 

days (5)

 15:10;73:19;94:21;

 203:9,19 

dead (2)

 54:16;63:3 

deadlines (3)

 19:11;20:16;99:4 

deal (13)

 9:23;54:8,11,23;

 79:1;113:9,12;

 194:24;195:3;

 217:13 

deficiency (1)

 197:8 

deficient (1)

 194:21 

defined (1)

 203:1 

definitely (6)

 78:11;164:3;

 173:22;174:11;

 189:24;226:15 

definitions (1)

 193:25 

deformed (1)

 187:2 

degradation (1)

 130:3 

degrading (1)

 146:23 

DEI (1)

 125:2 

delist (2)

 166:9;177:17 

delisting (3)

 155:9;166:10;224:8 

D 

15:14;42:24;45:24; 20:2,4;31:13,17;32:1, dad (1) 149:11;176:16,18; deliver (2)

 63:4;110:23;166:15 4,10,10,11;41:15; 22:12 203:4;216:7;228:1 59:19;217:12 

covering (3) 43:4,12;44:20;45:5; damaging (1) dealing (3) delivered (1)

 0:21;42:14;133:14 50:16,17;51:1;54:1; 174:2 158:16;196:20; 9:7 

covers (10) 55:16;57:15,22;58:2; D'AMORE (40) 212:9 delivering (2)

 0:17;13:25;153:10, 66:20,24,25;67:17; 56:22;57:2;58:1; debris (1) 139:5;233:2 

21;154:9,25;157:6,8; 116:23;127:18,20,21; 81:13;120:25;121:20; 154:25 delivery (7)

 170:5;184:3 132:3;153:24;154:1, 134:17;135:22;137:4; decade (2) 8:20,23,24;61:4;

COVID (1) 1;157:13;160:22; 139:22;141:2;144:22; 24:16;82:19 67:24,25;99:14 

124:21 161:16;162:7,12,12; 151:19;153:1;166:18, decades (1) demand (2)

CPG (2) 163:4;169:15,17; 23;167:1,3;168:19, 87:3 71:20,20 

178:5;182:10 187:6,18;196:1; 22;175:25;184:25; decide (1) demonstrate (1)

crash (1) 217:13;232:25; 191:5;192:10;198:22; 165:8 64:12 

203:3 235:23 199:25;201:4;205:7; decided (2) densities (1)

create (5) cross (2) 206:16;209:6;219:3; 39:4;213:18 25:19 

55:19;58:11; 100:12;101:23 220:9;221:12;222:25; decision (3) dent (2)

 101:25;103:22; crosschecks (1) 225:19;226:7;229:6, 204:9,11;212:12 177:16;183:6 

215:21 120:1 17;231:16;235:11 decisions (2) deodorize (1)

created (1) crossing (1) dangerous (1) 26:22;125:4 207:24 

142:25 104:21 227:2 deck (1) Department (3)

creating (3) cross-section (1) darker (2) 182:7 6:8;25:24;107:8 

56:3;104:25;189:19 194:9 19:3;36:15 decreasing (1) depend (1)

creative (1) crown (1) darkest (1) 16:12 223:18 

83:1 213:10 36:17 dedicated (1) dependence (1)

crew (1) CSNEN13655 (1) data (46) 82:22 157:24 

179:1 154:16 10:12,16,17;11:2,3, deductible (3) dependency (3)

criteria (3) cucurbits (1) 4,6,9,13;18:23;21:2; 12:25;13:4;42:12 130:22;154:7;158:1 

130:8;212:24; 154:2 30:8,11;38:6,7,13,15; deed (1) dependent (1)

 216:15 cultivate (1) 43:18,20;48:24; 102:19 50:24 

crop (112) 181:6 50:18,24;51:4;57:15; deep (1) depending (3)

 0:13,19;7:17,20,24; cultivation (10) 66:19;67:1,8,9,9,11, 114:18 13:20;55:3;179:3 

8:1,3,7,12,20;9:1,11, 156:17;157:6,16, 16,18,21;68:7;106:6, deeper (5) depends (5)

 18,22,22,23,25;10:1, 17;161:25;162:23; 7,8,9;113:3;116:14; 45:4;117:15;148:1; 13:22;55:11;94:22,

 2,4,7;11:11,11,12,21; 163:16;172:19; 119:25;129:9;130:24; 160:12;186:4 23;142:25 

12:4,7;14:7,18;15:14, 175:11;179:5 132:10,23;133:8 defer (1) deployed (3)

 16;16:1,16;17:8,15, cultural (2) Database (11) 119:12 100:20;130:18;

 21;18:12;19:20; 130:17;179:4 6:19;29:9;46:10; deficiencies (3) 163:3 

Min-U-Script® Burke Court Reporting & Transcription (9) coupling - deployed 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 4 

October 25, 2023 

deploying (1) 88:9,9;90:21;92:1,17; 228:21;231:6;235:1 207:23;208:10,11 dollars (1)

 100:11 93:23;94:8;95:18; dinner (2) diseases (5) 30:14 

deprioritize (1) 101:5;107:6;113:7; 9:20,21 162:9,11;193:18; domestic (1)

 212:13 116:23;118:4;129:7; direct (3) 194:14;203:17 168:15 

derived (4) 130:14,18,18;132:3; 70:7;79:22;130:6 disinfectant (1) domestically (1)

 195:9,10,10;232:12 146:18;149:6;156:16; direction (5) 142:14 107:19 

dermal (3) 157:3;188:22;195:24, 27:8;108:9;159:3; disinfectants (1) done (25)

 186:17;193:8;196:9 24;202:10;203:6; 173:12;174:17 138:16 6:20;21:17;35:20;

describe (6) 215:10;216:14,14,15; directions (1) dislike (1) 48:6,21;95:15,16,19;

 52:5;101:23;102:1, 233:13 103:2 144:7 100:24;113:21;114:3;

 22;103:13,23 differently (5) directly (3) dismissed (1) 133:13;157:10;

description (3) 8:21;92:24;124:22; 9:4;75:24;181:10 216:4 167:10;172:6,17;

 102:20;103:14; 148:12;169:2 Director (4) disposable (1) 176:4;179:21;180:25;

 107:9 difficult (15) 0:16,20,23;6:2 154:10 182:3;183:15;186:25;

descriptor (1) 16:5;21:7;54:10; dirt (4) dissent (1) 187:1;188:22;214:18 

101:17 56:7,15,17;146:17; 161:24;162:1,24,25 125:20 door (2)

descriptors (2) 147:3;160:7;188:2, dirty (1) distance (1) 30:1;93:6 

102:18;104:10 14,21;212:5,23;224:5 154:25 112:10 dots (1)

designed (1) Difficulty (2) disadvantage (2) distill (1) 35:17 

17:14 19:20;189:1 47:16;168:15 70:21 double (1)

desire (2) digest (3) disappear (1) distinct (1) 50:21 

7:24;154:10 188:3,14,21 104:5 10:7 down (18)

despite (1) digestion (1) discarded (1) distinctions (1) 15:23;21:6;40:15;

 70:14 189:1 217:22 112:1 42:2;59:7;61:3;68:25;

details (1) Dilip (32) discomfort (1) distributed (1) 71:16;130:2;146:22;

 143:13 35:7;39:12;84:6; 165:13 181:3 171:17;172:8;174:7;

Deter (4) 91:14;116:15;121:17; discount (4) dive (4) 177:1;196:20;197:7;

 62:23;86:9,14; 134:14;135:19;137:1; 32:7,8;60:23;70:9 45:5;62:7;117:15; 220:4;226:3 

99:23 139:19;140:24; discrepancies (2) 218:8 DR (36)

determination (2) 145:18;151:16; 34:3;63:15 divergent (2) 0:7;6:13;7:4;21:21,

 107:4;216:10 152:23;168:4;169:8; discuss (8) 214:2,7 25;22:10,14,18,24;

determine (1) 182:12;184:22;191:2; 7:18;62:8;99:22; diversification (1) 23:2,6,11,16,18;

 233:25 192:7;198:19;199:22; 124:14;158:6;185:16; 32:6 27:18,20,25;28:3;

determined (1) 201:1;205:4;206:13; 193:22;210:24 diversified (1) 93:11,13,20;94:14,17,

 208:16 209:3;219:24;222:22; discussed (8) 42:10 21,23;95:24;96:2,11;

develop (3) 227:12;229:3;231:13; 26:9;143:4;146:25; diversity (3) 97:14;110:17;112:24;

 9:10;26:18;72:22 235:8 159:4;208:14;217:25; 71:7;108:1;124:25 211:16;214:10;

developed (1) Dill's (1) 220:12;229:22 division (6) 215:13;216:5,19 

105:22 177:20 discussing (4) 0:17,17;47:25;48:7; Draft (1)

developing (2) diluted (1) 117:3;138:10; 75:9;94:20 26:19 

47:5;48:16 202:19 210:10,17 dizziness (1) drawing (1)

development (2) dime (1) Discussion (34) 225:2 57:18 

0:19;70:10 171:13 62:23,24;68:23; doable (1) dream (1)

devil (1) dimension (1) 69:3,12,23;70:14; 107:6 83:25 

168:1 234:10 71:17;77:7;86:8; Document (22) drift (2)

dialogue (1) DIMITRI (55) 87:14;88:7;91:11; 62:23,24;63:9,19, 53:22;54:9 

51:22 47:2,21;48:22; 92:8;109:23;118:11, 22;65:16;66:9;68:23; drip (1)

dicamba (1) 49:17,19,22;50:5,10; 22;120:4;128:1; 69:13,23;70:14;72:3; 166:7 

54:15 51:9;63:2,21,24;64:2; 144:3,6,11;147:13; 86:8,8;87:14,20,21; driven (1)

difference (7) 65:11,23;66:16;67:3, 159:16;165:12,21; 88:7;100:1;105:15, 123:2 

26:20;75:25;76:5; 6;68:3,14;74:19;81:2; 184:2;193:3,15; 16;118:10 driver (1)

 96:8;156:4,5;189:25 113:15;121:10; 216:25;221:1,22; documentation (1) 212:21 

differences (1) 123:12,14;125:24; 232:25;235:23 20:10 drop (1)

 111:13 126:4;127:7,10; discussions (4) documented (1) 114:24 

different (69) 134:7;136:11;137:18; 62:4;83:17;125:15; 67:22 dropped (2)

 6:15;9:9,25;10:1,1, 140:11;141:16; 232:23 documents (10) 16:17;197:7 

3,3,6,17;12:17;14:12; 145:11;151:9;152:16; disease (17) 91:24;93:19,22,23, drowsiness (1)

 18:18,18;19:23;20:7; 158:19;183:4,11; 128:20;130:17; 25;95:7;97:5,6,8; 225:1 

25:16;26:11,22;39:3; 184:15;190:20; 131:20,23;132:5; 101:5 dry (3)

 41:14,15;47:18,23; 191:25;198:12; 136:21;153:23; Dole (2) 179:6;195:21;196:1 

49:6,14;50:15,16,16, 199:15;201:18; 185:19;187:10; 223:13,15 du (1)

 20;51:4;56:9,13,15; 205:21;207:5;209:20; 192:25;194:17; dollar (2) 175:20 

61:5;74:9;76:6,10; 219:17;222:15; 199:13;202:3;206:7; 18:7,7 due (12) 

Min-U-Script® Burke Court Reporting & Transcription (10) deploying - due 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 4 

October 25, 2023 

20:20;53:22;54:2,5;

 60:1;70:16;72:9;

 85:11;177:7;195:13;

 221:7;224:19 

Duly (1)

 92:3 

dumped (1)

 171:21 

dunk (1)

 186:3 

duplicated (2)

 155:14,14 

during (17)

 29:21;61:22;92:22;

 105:10;126:9;131:15;

 142:22;170:11;179:9;

 194:2,4;213:5;

 214:15;226:11;

 227:22;229:23;230:4 

E 

Edamame (1)

 162:5 

education (3)

 30:12,13;76:18 

educational (2)

 37:15;84:10 

effect (8)

 77:14;180:7;190:1;

 197:4;203:7,11;

 204:7,17 

effective (7)

 100:13;138:24;

 156:25;185:22;

 193:21;195:18;

 202:15 

effectively (3)

 64:10;96:8;177:15 

effectiveness (1)

 128:21 

effects (4)

 130:5;186:8;

 193:13;225:5 

89:11 

eligible (1)

 15:17 

eliminate (1)

 182:11 

elimination (1)

 182:12 

else (11)

 22:7;46:16;64:3;

 70:23,23;85:25;

 103:18;125:23;165:8;

 176:13;226:12 

email (2)

 38:11;40:7 

e-mail (2)

 40:5,6 

emissions (3)

 142:21;224:15,21 

emitted (1)

 224:16 

emphasize (1)

 217:15 

enforcement (7)

 25:4;87:4;88:4;

 95:9;97:3;100:12;

 110:20 

enforcing (1)

 97:4 

engage (2)

 125:6;212:10 

engaged (1)

 71:11 

engagement (2)

 23:25;27:16 

Enhanced (3)

 13:8;42:20,25 

enjoy (1)

 86:14 

enough (15)

 30:9;33:16;37:10;

 39:5;50:18;51:6;

 56:18;67:10;81:22;

 83:21;136:19;150:5;

 196:22;214:25;232:1 

158:16;169:22;

 185:25;187:16;193:3,

 4;208:1,15;224:13;

 225:4 

environmentally (2)

 129:22;187:20 

environments (4)

 211:10;212:5,9;

 215:9 

EPA (8)

 88:17;89:17;129:3;

 131:6;176:4;186:5;

 233:11,12 

epidermis (1)

 189:18 

equal (1)

 41:17 

equipment (4)

 138:16,17;157:17,

 17 

equitable (1)

 82:24 

Eagle (1) efficacies (1) employee (1) enrolling (1) equity (3)

 119:3 195:24 180:4 68:6 71:7;124:25;125:6 

earlier (7) efficacious (1) employees (5) ensure (6) equivalency (1)

 25:3;85:3;107:22; 138:24 8:23;48:10;178:20; 11:13;66:21;82:24; 168:13 

109:24;110:14; efficacy (3) 180:3,4 87:9;88:3;157:10 equivalent (2)

 112:23;211:17 47:6;130:24;132:9 employs (1) ensuring (2) 41:5;170:25 

early (2) efficiencies (1) 178:21 32:5;82:14 eSearch (1)

 164:15;203:11 125:25 EMS (1) enter (5) 114:8 

earshot (1) efficiently (1) 88:3 106:5,5,7,21; Especially (8)

 112:16 223:25 enable (1) 157:17 34:8;45:16;85:8;

easier (3) effort (2) 100:12 entered (1) 108:21;195:25;

 92:2;114:15;226:5 65:17;86:10 enabling (1) 114:10 208:15;216:22;

easiest (1) efforts (3) 120:1 entering (1) 227:16 

177:9 21:16;29:7;30:5 encore (1) 76:3 essence (1)

easily (5) eg (3) 87:11 enterprise (7) 155:7 

12:2;114:7;139:5; 109:14;118:20; encountered (1) 32:4,4,8,9,12;59:9; essential (6)

 157:14;203:4 119:20 196:11 66:1 80:5;87:19;186:9;

East (4) egg (1) encountering (1) enters (1) 204:5,10;232:15 

111:13,19,22; 154:3 65:4 194:18 essentiality (2)

 116:25 eggplants (1) encourage (5) entertaining (1) 154:6;220:17 

eastern (1) 161:13 26:16;30:22;51:11; 59:5 essentially (4)

 221:8 eight (2) 156:12;159:10 entire (6) 59:22;73:8;87:15;

easy (10) 57:8;225:7 encourages (1) 18:9,12;104:14; 110:1 

7:15;12:11;74:15; either (14) 50:25 155:19;164:21;179:1 establish (1)

 101:16;103:11; 27:18;60:3;61:11; end (19) entirely (1) 25:7 

104:25;138:25; 79:24;91:11;95:8; 22:25;46:21;69:5; 223:18 established (1)

 163:22;196:9;203:2 97:18;102:19;115:19; 79:2;108:3;122:12, entities (6) 67:1 

eat (2) 147:19;179:15;182:8; 14,17;127:21;129:10; 35:25;36:9;38:22, et (3)

 98:1;194:12 212:13;229:14 153:16,19,19;154:25; 25;39:3,4 106:13;119:24;

echoing (1) element (2) 170:14;173:3;174:24; entity (1) 160:18 

74:1 227:2;232:15 181:13;225:22 36:4 ethanol (4)

ECO (1) elemental (10) endorsement (1) entrepreneurial (1) 138:10,11;139:11,

 13:15 143:8;192:22,25; 208:9 80:17 12 

ecological (1) 193:1,5,19;198:5; endorsements (1) environment (11) ethylene (13)

 217:19 199:12;200:16;220:7 13:2 78:21;79:1;131:7; 223:4,5,8,9,16,18;

economic (1) elevate (5) energy (2) 142:21;155:9;160:21; 224:15,19,24;225:2,3,

 69:16 147:22;177:4,20; 123:22;207:6 172:5;193:6;195:25; 11;228:7 

economically (1) 178:18;180:1 enforce (2) 217:21;227:10 ethylene-propylene (1)

 223:25 elevators (1) 94:9;95:21 environmental (16) 229:15 

ecosystem (1) 61:9 enforceable (2) 69:16;129:8;131:7; EU (1)

 217:23 eligibility (1) 96:12,12 142:20;154:22,23; 154:14 

Min-U-Script® Burke Court Reporting & Transcription (11) Duly - EU 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 4 

October 25, 2023 

Europe (2)

 55:16;182:3 

European (1)

 168:16 

euthanasia (1)

 25:20 

evaluate (4)

 88:9;175:9;212:24,

 25 

evaluating (1)

 155:24 

even (31)

 9:20,20;14:22;

 54:11;66:11;67:16;

 74:4;81:25;82:24;

 94:14;95:11;104:17;

 104:3;115:11;166:13;

 188:15;230:10 

examine (1)

 82:11 

example (26)

 12:10,23;25:2;

 36:22;37:6;41:10;

 50:22;52:3,14;60:22;

 77:15;100:20,23;

 101:20;104:15;

 106:20;108:7;109:6,

 14;110:9;113:5;

 116:18;146:22;

 156:17;161:5;213:5 

examples (6)

 17:23;59:15;100:3;

expansion (2)

 16:8,9 

expect (4)

 48:5,23;107:2,23 

expectation (1)

 92:25 

expectations (2)

 124:19,23 

expected (1)

 92:21 

expecting (2)

 21:22;77:19 

expedient (1)

 111:1 

expense (1)

 17:11 

83:6,10,16,20,21;

 84:1,13 

extensive (1)

 53:19 

external (1)

 113:1 

extra (1)

 165:8 

extremely (3)

 113:16;122:19;

 225:20 

eyes (2)

 90:24;202:20 

70:2 

family (1)

 102:8 

fantastic (3)

 68:4;125:15;181:1 

far (10)

 22:6;26:10;31:4,21;

 61:2;107:2;126:10;

 224:13,24;227:21 

Farm (74)

 0:23,25;6:4,9,10,11,

 13;7:10;8:6,22;9:6;

 10:19;13:21;14:10,

 14,15,16,16,20,20,25;

 15:5,12,15,15;16:4,8,

 8,13,13,16,18,20,21,

F 

111:15;117:16;132:1; 109:11;112:14; expensive (7) face (4) 24;17:3,3,12;31:19;

 143:14;149:4;167:17, 153:22 13:20,21;14:8;30:2; 70:18;80:18,18; 36:1,10;38:24;39:4,

 17;173:10;174:12; exceed (2) 163:3;164:7;233:1 159:22 19,25;40:12,16;41:1;

 179:7;211:23;214:11; 107:2;210:9 experience (3) faced (1) 42:9,19;54:13;74:16;

 215:17,17;217:18; excellent (4) 78:10,15;217:11 30:7 79:9;82:20;84:20,25;

 218:1,2;228:1;233:19 35:9;38:18;66:16; experienced (1) facilitate (2) 87:7;100:17;101:12;

event (5) 99:10 78:3 78:6;100:13 102:8;115:10,11,22;

 45:2;53:24;61:4; exception (1) expert (2) facilities (1) 116:6;130:18;158:24;

 178:3;203:14 13:12 20:3,9 155:3 161:3;183:8;186:8;

events (3) excessive (1) experts (3) facing (1) 193:8;196:11,12,14,

 44:25;45:2;50:7 220:11 20:1;33:21;74:17 73:21 15 

eventually (2) Excited (9) explain (4) fact (9) Farmer (29)

 165:10;211:7 0:4,4;27:16;28:21; 33:5;51:21;52:8; 12:14;16:15;111:6; 6:5;12:24;17:5;

everybody (21) 90:10;91:23;140:17; 97:8 120:14;143:13;147:1; 33:20;35:1;36:20;

 0:7;7:5,24;8:1; 207:10;236:5 explained (1) 149:23;167:11;215:4 78:3,8,13;80:5,13;

 19:15;28:21;29:17; excitement (1) 53:3 factor (5) 81:7,7,9;100:8;

 42:9;45:12;50:2;61:3; 216:7 explanation (1) 12:13;52:18;59:20; 111:25;114:17;

 98:12;99:8,14,21; exciting (11) 213:23 60:25;61:1 115:21;116:19,19;

 108:9;122:9,12; 24:6,11,17;27:4,5, explicit (1) factors (5) 123:3;158:24;160:17,

 181:24;197:14; 6;69:20;99:12;164:3, 125:3 60:23;61:14,16; 18;177:6;178:12;

 235:22 7;216:1 explore (2) 64:21;215:6 180:5;203:15;217:14 

everybody's (1) exclusion (1) 55:19;160:12 fails (22) Farmers (48)

 165:23 89:22 exploring (1) 136:14;137:23; 0:24,25;6:18,20;

everyone (17) exclusively (1) 125:6 140:19;141:25; 16:6;17:1;25:10;

 0:4;8:13;26:17,21; 154:1 explosive (1) 145:23;151:22;153:6; 29:18;32:21;35:1;

 30:2;40:17;61:19; excuse (3) 224:25 185:7;191:14;192:21; 43:16;50:11,12;

 63:2,21;68:14;69:2; 13:7;14:1;50:9 Expo (1) 199:10;200:15; 54:12;57:19,20;62:1;

 71:11;82:14;98:18; executed (1) 178:4 201:21;206:1;207:16; 70:7;72:23;74:16,21;

 102:22;114:9;170:18 114:1 export (1) 210:4;220:3;223:3; 76:7;78:2,3,24;79:10;

everyone's (4) executive (1) 54:2 225:20;229:11;232:6; 83:8,13,18;84:14,23;

 70:1;71:18;174:7; 6:2 exporting (1) 235:20 85:9;99:9;101:10;

 177:19 exempt (1) 104:4 fair (3) 131:18;132:1;168:12;

Everything's (1) 186:2 expose (2) 25:25;26:3;56:18 169:22;172:4,8;

 164:7 exhaustive (1) 113:5;116:9 fairly (2) 173:11;177:9,13;

everywhere (3) 109:6 exposed (1) 82:15;233:14 178:7,17;185:23;

 11:16;82:16;167:22 exist (2) 196:15 fairness (1) 187:12;202:16 

evidence (1) 111:6;130:13 exposure (4) 166:4 farmer-to- (1)

 63:14 existed (1) 186:19;193:8; fall (10) 78:7 

evil (1) 149:4 225:4;227:10 23:23;41:14;93:18; farming (28)

 169:6 existing (3) expressed (2) 131:17;138:23;154:8; 7:11;8:3;32:12,15;

evolved (1) 66:23;71:23;83:15 217:18;230:7 155:13;211:2;220:17; 33:3,5,5,7,10,13,18,

 149:7 expand (6) expressing (1) 230:8 21,23,24;34:4,7,7;

exact (1) 11:19,24;12:2;32:9; 217:12 falling (1) 36:5,5;62:25;78:10,

 54:12 51:19;71:6 extended (6) 166:4 15,20,25;79:3;123:1;

exactly (12) expanding (6) 15:4,9;17:18;61:21; familiar (8) 160:17;225:14 

14:9;26:5;37:25; 16:5,6;89:13,16; 127:24;128:7 10:19;12:4;39:23; farms (15)

 45:5;62:15;74:7;78:1; 125:22;175:22 extension (7) 49:11,12;57:21,23; 19:8;32:6;35:4; 

Min-U-Script® Burke Court Reporting & Transcription (12) Europe - farms 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 4 

October 25, 2023 

39:1;41:8;86:15; 166:9;177:7 78:9 215:19;217:7,8,16,18, 79:4;92:13;93:16;

 105:22;107:17,20; fellow (1) films (1) 22;218:23 97:16;168:22;215:15 

113:22;168:24;180:2, 62:11 154:18 fit (1) followed (7)

 2;203:25;224:11 felt (1) Final (6) 61:6 33:10,14;92:21,21;

farther (1) 108:25 24:9,18;25:1,3; five (5) 193:10;195:15;

 148:22 ferret (1) 26:20;99:22 66:13;70:25; 196:19 

fashions (1) 186:14 finalize (1) 155:17;162:1;203:19 following (8)

 131:22 fertility (4) 28:24 five-year (1) 25:11;76:20;88:11,

fast (4) 188:22,23;217:14, finalized (1) 26:12 14,23;93:1;96:19;

 59:7;67:20;99:5; 16 87:22 fix (1) 172:12 

182:6 fertilizer (3) finally (1) 109:14 follow-up (10)

faster (1) 29:23;33:16;217:23 34:10 flame (1) 45:19;52:11;67:3;

 95:5 few (20) financial (1) 55:12 94:18;96:6;128:4,11;

favor (7) 13:6;16:4;17:7; 85:16 flamers (1) 173:6;189:15;204:16 

166:23;174:11; 27:1;30:16;37:14; financials (2) 163:1 food (14)

 187:10;203:21,23; 40:9;41:23;64:8; 78:22;79:4 flammable (1) 60:19;82:13,15;

 217:9;220:19 73:19;74:3,4;94:2; find (28) 224:25 129:14;142:10,10;

favorable (1) 128:16;142:22;143:2; 7:23;22:18;39:18, flat (1) 143:20;155:12,17;

 143:7 181:13;183:15;194:8; 19;40:2;54:22;57:11; 10:23 165:6,13;217:23;

FDA (5) 212:4 61:25;63:16;66:5; flexible (1) 220:25;230:14 

88:18;89:17;129:4; fewer (3) 73:10;74:10;81:16; 61:23 food-grade (1)

 131:6;186:5 143:9;204:7;227:3 82:14;101:6,9;103:7; flip (1) 60:15 

feature (1) field (45) 105:4;113:15;114:13; 28:14 Foods (1)

 53:11 25:9,23;27:11; 117:16;156:11; floor (4) 171:17 

featured (1) 100:24;101:2,3,4,7,9, 158:23;171:6;173:23; 7:1;63:1;124:11; forage (1)

 6:7 13,15,21,23,24,24; 176:3;223:15;226:23 160:20 188:24 

February (1) 102:19,25;103:3,7,13, finding (6) Florida (1) forages (2)

 220:16 17,19;104:3,17,18,20, 76:5,6;85:4;100:17; 17:17 188:13,21 

federal (11) 23;105:4,14;106:21, 104:1;180:22 flourished (1) force (1)

 0:25;8:20;67:21; 24;107:5,24;111:16; findings (1) 123:20 165:21 

88:16,19;96:24;97:1; 112:3,9,18;113:7; 48:4 flowering (7) forever (1)

 142:9;155:23;169:14; 115:24;153:19; finds (3) 223:6,8,14,16,24; 16:2 

212:9 157:18;165:16;226:6; 143:18;220:24; 226:20;227:14 Forge (1)

federally (1) 227:4,6 230:13 fluorinated (1) 13:24 

67:8 fielding (1) fine (1) 155:20 form (5)

feed (2) 216:17 120:17 focus (5) 75:7;80:25;130:6;

 31:17;32:1 fields (20) finer (1) 64:11,23;147:8,23; 171:9;202:16 

feedback (29) 100:6;101:1,11,12; 226:25 148:14 formal (2)

 15:2;17:21;20:9; 102:1,18;104:5,6,7, finish (3) focused (5) 79:24;92:9 

26:18;29:2;30:4; 19;106:9,20;108:10; 29:3;98:16;215:8 88:10;95:20;116:5; formality (1)

 32:23;58:25;64:25; 110:8,8;112:1,6,17; finished (1) 213:12;220:16 125:8 

66:2;70:20,21;71:2,3, 114:6,13 178:14 focuses (1) formalized (1)

 14,18,24;78:24;85:22, FIFRA (1) finishing (1) 147:7 80:16 

22;94:7;109:10; 144:6 91:8 focusing (1) formats (1)

 128:11;147:14;148:8, fight (4) fire (3) 215:18 124:20 

12;210:14;213:16; 108:17;114:13; 204:6,6,8 foliar (1) former (1)

 214:19 177:15;178:11 firmly (1) 132:21 196:11 

feed-grade (2) fighting (2) 95:21 folks (36) forms (4)

 59:17,25 55:12;100:16 first (31) 22:6;23:7;59:10; 118:23;182:2;

feeds (1) figure (5) 0:10;8:18;14:16; 62:11;72:7;74:9; 195:23;196:1 

212:12 34:19;45:14;72:17; 17:17;24:11;35:3,8, 75:12;76:17;79:21; formulated (1)

feedstock (1) 89:25;101:23 16;36:12;47:4;57:20; 80:21;83:18;84:18, 217:7 

146:25 figuring (5) 65:10;70:4;71:17; 25;86:22;88:11; formulation (1)

feedstocks (2) 66:21,23,25;74:13; 79:5;83:17;118:1; 100:25;102:21; 142:22 

146:8;151:24 177:21 120:13;122:10;134:1, 103:11;104:2;105:10; forth (4)

feel (10) file (3) 4;138:5,9;143:24; 116:1;127:17;130:16; 30:7;79:19;81:23;

 27:14;63:3;98:18; 103:1;106:3,3 158:19;167:4;190:7; 174:6,7;180:6,9,12; 91:13 

113:24;127:22; filed (1) 198:4;204:21,25; 181:6,8,10;185:9; fortification (1)

 165:10;183:7;212:3; 19:18 229:18 211:23;227:6;231:20; 218:10 

215:16;216:2 fill (5) fish (20) 236:4 fortunately (2)

feeling (2) 13:3;42:17;69:4; 142:24;186:1; follow (13) 80:12;105:9 

149:8;165:15 75:6;78:13 208:2;210:5,7,21,21, 12:16;14:9;33:12, forward (20)

feels (2) filling (1) 22,22;211:1,6,9,9; 18;47:8;57:16;74:19; 24:8;28:13;34:21; 

Min-U-Script® Burke Court Reporting & Transcription (13) farther - forward 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 4 

October 25, 2023 

78:7;85:23;86:1;89:2;

 110:9;127:6,25;

 149:11;159:3;175:16;

 210:18;211:12;

 212:17,19;214:8,11;

 236:8 

fossil (2)

 155:21;195:11 

found (9)

 74:21;81:19;129:1;

 153:17;156:1;190:9;

 193:11;223:17;

 225:25 

foundation (1)

 108:20 

foundationally (1)

 212:5 

foundations (1)

 65:16 

four (10)

 30:5;62:8;71:15;

 98:11,12;101:5;

 104:21;117:7;161:25;

 170:12 

fourth (1)

 6:11 

fractional (2)

 162:25,25 

frame (1)

 128:7 

framework (2)

 6:18;88:8 

France (1)

 168:24 

Francie (21)

 0:9,10,12,15;6:4;

 228:14;230:24;

 234:19 

Franklin's (1)

 176:10 

fraud (11)

 55:24;62:23;64:14;

 86:9,14;90:2;99:23;

 100:16;108:17;

 114:13;116:10 

free (2)

 88:21;126:8 

fresh (1)

 208:2 

friend (1)

 21:13 

friendly (3)

 117:22;120:6,7 

friends (1)

 80:13 

front (5)

 106:22;122:12;

 127:21;164:7;181:7 

fronts (1)

 113:9 

frost (1)

 153:24 

fruit (10)

 108:15;117:10;

 153:25;189:23;190:1;

 203:1;204:10;217:10;

 223:19;224:3 

fruits (4)

 157:14;160:22;

 161:15;227:15 

frustration (1)

 157:25 

216:6 

funded (2)

 30:5;181:13 

funding (5)

 31:11;51:1;70:4,7;

 75:20 

fungal (3)

 193:18;203:8,17 

fungi (3)

 188:19;189:25;

 194:19 

fungicide (6)

 131:15;163:7;

 185:22;187:20;

 194:13;197:6 

fungicides (1)

 203:13 

fungus (3)

 163:8,10;194:16 

funny (3)

 50:9;115:5;158:20 

further (9)

 66:10;84:14;118:8;

 128:13;175:18;

 189:16;218:1,8;

 221:21 

furthest (1)

 26:13 

future (11)

 20:13;48:17;65:16,

 21;66:21;70:24;

 123:2;126:12;148:2;

 180:18;216:13 

Generally (13)

 9:15;12:8,22;13:4,

 5,11;16:1;18:13;

 42:16;60:23;139:4;

 186:1;208:14 

generate (1)

 106:6 

generated (1)

 104:16 

generation (3)

 6:11,13;220:6 

genuine (1)

 24:1 

geocode (5)

 101:17;104:13,15;

 109:17;117:3 

geocodes (10)

 104:9;108:7;109:5;

 113:2,3;114:11,25;

 118:19,20;119:20 

geographic (2)

 57:8,9 

geographically (1)

 57:6 

geography (1)

 32:7 

Germany (1)

 168:24 

germination (1)

 164:14 

gets (5)

 43:15;147:5;179:8,

 8;202:19 

ghost (1)

 104:7 

giant (1)

 55:14 

goal (3)

 49:24;108:5;112:15 

goals (2)

 100:10;187:22 

goes (15)

 8:8,24;9:17;15:22;

 16:6;32:11;33:12;

 42:21,25;78:2;

 111:22;115:6;148:22;

 167:22;188:4 

gold (1)

 99:8 

Good (66)

 0:3,4,7;6:16;7:3;

 18:5;20:4;22:8,10,12;

 23:9;28:13;33:3,5,5,7,

 10,12,18,21,23,24;

 34:4,7,7,13,18;35:9;

 49:16,20;57:13;

 63:25;64:11;65:18;

 68:18;69:10;79:1,2;

 83:16;95:3;97:11;

 99:4,5;103:13;

 104:19;111:9;127:4;

 128:11;133:6;138:2;

 144:13;157:9;160:10;

 168:2;179:4,5;

 197:17;213:5;216:19,

 19;227:11;232:22,25;

 235:22;236:1,8 

goodness (1)

 121:4 

Googled (2)

 102:9,10 

governed (1)

G 

21:22;22:10,15,19; FSA (3) gain (1) 158:15 144:5 

28:11,12,24;34:23; 10:24;11:1;83:25 122:19 giveaway (1) government (4)

 39:13;47:3;51:16; fuel-based (1) gamblers (1) 103:24 15:21;44:17;82:2,6 

54:18;62:18;63:12; 155:21 7:14 given (10) GPS (7)

 64:8;67:4 fuels (1) game (1) 49:2;68:24;75:20; 100:9;105:17,25;

Francies (1) 195:11 177:20 113:4;126:22;147:1; 107:17,20;117:1;

 6:14 full (8) gap (4) 216:8,8;233:19,19 119:22 

Francie's (2) 63:3;91:11;122:13; 42:17;52:4;53:3; gives (3) GR (1)

 63:5;64:24 128:1;129:21;135:13; 82:14 53:7;149:24;213:25 220:16 

Frankie (1) 167:11;181:20 gaps (2) giving (6) grab (1)

 7:2 full-time (1) 54:5;69:5 47:16;57:7;78:23; 114:25 

Frankies (1) 7:11 gas (5) 79:25;85:16;105:17 Grade (6)

 6:23 fully (4) 223:4,5,8,9;228:7 glad (5) 59:16,19,19;60:1,2,

Franklin (41) 50:2;147:4,4; gather (2) 23:20;58:19;81:13; 5 

78:18,18;83:4; 197:14 64:21;70:20 187:7;211:13 grain (7)

 85:14;122:2;134:24; fun (4) gave (4) Gleaning (1) 31:17;32:1;43:4;

 136:4;137:11;140:4; 49:25;77:3;120:14; 9:22;120:13; 30:19 55:16;104:4;108:11,

 141:9;142:3,12; 163:20 172:22;230:10 Global (1) 13 

144:1;145:4;151:2; function (3) gears (1) 86:10 grains (2)

 152:9;170:2;172:2; 65:18;156:17; 232:9 globally (1) 11:15,16 

173:7;174:16;180:10; 221:19 general (16) 87:7 grandchild (1)

 181:21;184:8;190:12, functional (1) 54:9;63:15;94:24; globe (1) 7:12 

13;192:17;194:2; 169:7 101:1;103:14;112:9; 104:14 grant (4)

 199:4;200:7;201:11; functions (4) 131:3;147:18,18; glossy (8) 66:24;80:1;181:14;

 205:14;206:23; 153:22;156:16,21; 148:8;158:1;170:24; 146:4,6,16;147:7,9; 182:15 

207:18,20;208:19; 172:20 193:5;213:8;225:4; 150:17;151:25;152:2 grants (2)

 209:13;219:10;222:8; fundamentally (1) 234:11 glyphosate (1) 70:10;181:3 

Min-U-Script® Burke Court Reporting & Transcription (14) fossil - grants 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 4 

October 25, 2023 

granular (2)

 52:12;71:10 

Grape (1)

 30:20 

grass (1)

 129:4 

grateful (5)

 6:25;71:10;99:7;

 114:20;182:24 

gratitude (1)

 114:18 

great (50)

 6:14;7:9,14;21:23;

 23:19;28:18;38:8;

 40:4;42:9;46:24;47:2,

 3,3,9;49:17;50:5;

 52:3;55:15,22;59:2;

 61:18;62:19;63:2;

 65:11,23;66:16;68:2,

 3;69:7;75:2;77:15;

 84:4;85:22;93:13;

 105:23;114:25;

 125:21;129:10;

grow (18)

 66:25;160:16,21,

 22;161:7,7,9,10,13,

 13,14,16,17,18,19,23;

 162:5,12 

Grower (21)

 14:4;29:12;31:6,9;

 44:6,18;119:23;

 131:12,15,20,21,23;

 147:15;156:9;158:2;

 172:22;173:2,3;

 174:1;225:8;229:18 

Growers (42)

 6:2;16:16;29:15;

 30:21;31:12;46:11;

 77:14,17;131:25;

 139:2;148:14;154:4;

 155:11;158:2,4,21;

 161:17;163:7;167:20;

 168:12,16,16,17,18;

 173:23;179:9,11,20;

 203:1,7;217:9,10,10,

 11;224:7,9,11;225:9,

 93:14,15,22,22;94:1,

 7,24,25;96:8,9,11,12,

 13;109:24,25;110:15;

 111:5;118:2 

guide (2)

 93:18,18 

guidelines (10)

 19:24;32:19,23;

 37:18;47:17;49:16,

 20;50:1;87:20;88:4 

guy (1)

 178:11 

guys (15)

 7:18;8:14;29:5;

 30:3;31:2;32:25;37:9;

 40:5;46:13;51:24;

 54:16;114:25;129:9;

 132:10;206:5 

gypsum (1)

 197:21 

162:13 

hang (1)

 74:6 

hanging (2)

 108:14;117:10 

happen (12)

 19:23;24:14;29:20;

 39:2;83:17;91:24;

 92:6;99:15;113:18;

 142:22;197:13;

 229:17 

happened (3)

 14:10;45:2;48:4 

happening (5)

 11:19;45:17,18;

 189:24;217:20 

happens (4)

 55:11;104:1;

 115:10;170:19 

happy (6)

 123:5,10,12;127:8,

 11;236:6 

hard (15)

 69:16;78:21;79:2;

 129:8;131:8;155:11;

 187:16;193:13;

 196:12;224:24 

healthcare (2)

 25:14,20 

healthy (3)

 82:13;147:13,21 

hear (36)

 0:5;7:6,20,21;9:21;

 19:21;23:6,7,11,18,

 20;28:1;29:1;34:8;

 45:7;52:7;58:19;59:1;

 62:20;65:25;71:25;

 90:20;100:18;105:20;

 106:1;114:12;116:11;

 131:25;160:9;161:2;

 165:3,12;178:16;

 181:8,14;223:11 

heard (39)

 7:9;9:20;26:14;

 28:19;32:3;39:18;

 52:8;63:11;64:8;66:2,

H 

133:14;146:13; 10;230:12;233:16,18 H2-A (1) 39:18;45:22;67:20; 8;70:9;73:5,17;77:25;

 149:19,24;158:11; growing (24) 162:15 73:9;81:8;85:8; 87:1,5;89:6,12,25;

 167:4;168:23;174:10; 16:22,23;41:7,13, habits (1) 132:24;159:15; 99:12;106:17;107:18,

 175:5;183:1;214:10; 14;60:15;66:20,24; 157:15 163:15;165:7;177:6; 22;111:12,19;118:11;

 232:14 67:14;79:12;105:19; hailstorm (1) 183:16;202:22;214:1; 147:15,15,16,17,17;

greater (4) 106:24;108:21,21; 60:1 226:1 155:2;160:12,14;

 25:13;43:25; 116:22;153:17,20; half (6) harder (6) 181:10;183:15;185:8;

 102:16;233:24 155:23;161:19; 30:14;82:19;98:16; 6:22;177:10;178:7; 194:8 

greatest (1) 174:24;195:25;196:1; 113:21;114:5;217:1 188:18;226:4,6 hearing (7)

 90:3 227:22;233:17 Hall (1) hardest (1) 26:21,22;65:19;

green (4) grown (13) 236:7 54:8 70:6;78:11;79:10;

 26:5;35:17;36:15, 13:16;18:2;40:25; hammer (1) harmonization (1) 190:4 

17 44:24;87:2;153:25; 177:24 119:25 heart (4)

Greenwood (1) 154:2;155:12;156:6, Hampshire (1) harmony (1) 73:2;113:22;

 127:3 10;161:6,11;168:18 84:19 119:25 177:22;183:21 

grew (2) growth (12) hand (10) harvest (6) heat (1)

 6:9;229:19 17:25;18:3;41:24; 0:5;62:22;68:16; 138:16;153:20; 157:8 

grocery (5) 69:23;70:13,15; 85:19;99:19;127:19; 223:19,25,25;227:3 heaviest (1)

 27:15;156:8; 79:17;129:23;132:23; 136:15;142:6;150:8; harvested (1) 114:19 

171:13;182:10;226:5 157:15;221:5;223:10 156:19 226:4 heavily (2)

ground (2) guess (29) Handbook (14) harvesting (1) 50:24;197:6 

163:9;176:7 36:13,14;43:5;49:4; 33:3;89:12;91:25; 224:1 heavy (2)

groundwork (1) 51:21;52:4;60:4;62:2; 92:9;93:15,21,24,25; hat (1) 114:12;195:11 

69:21 63:7;67:7;73:4;81:2, 94:19;95:6,14,15,17; 74:6 heck (2)

group (18) 21;98:9;105:6; 96:13 hate (7) 115:24;159:21 

9:16;32:19;52:2; 113:15;115:6,14; handbooks (1) 56:15;176:17,20, heightened (1)

 71:8;113:23;131:12, 133:8;154:17;158:12; 37:19 21,21;216:3,3 70:17 

14,21;167:14;178:23; 166:3;167:17;171:23; hand-harvesting (1) hazardous (1) held (1)

 193:24;194:10,13; 183:4;188:1,17; 162:17 130:3 216:9 

217:14;225:8;233:10, 196:7;214:5 handle (7) hazards (1) help (35)

 24;234:7 guessing (1) 79:3;155:3;160:14; 88:20 7:22;8:4;13:3;15:9;

grouped (1) 43:3 162:4,7,19;163:4 head (2) 30:23;31:8;35:4;

 19:2 guest (1) handling (7) 39:14;111:18 36:23;37:13,14;

groups (20) 21:22 25:9,21;119:24; headaches (1) 38:15;40:3;41:21;

 11:4;20:24;49:14; guests (1) 211:1;227:19;232:24; 224:25 42:17;46:14;50:21;

 77:17;114:2;119:23; 0:5 234:8 heads (1) 52:8;56:17;57:25;

 131:11,12,13,15,20, guidance (31) hands (4) 165:17 58:23;61:17;72:16;

 23;132:4;147:15; 27:8;47:4;89:5; 28:10;174:8;182:7; headshake (1) 75:3,13;77:17,21;

 154:5;158:2,5; 90:12,19,21,22,24; 196:13 138:6 106:10,19;114:14;

 195:12;212:11;217:4 92:1,9,11,13,18; hand-weeding (1) health (10) 125:11;132:2;138:1; 

Min-U-Script® Burke Court Reporting & Transcription (15) granular - help 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 4 

October 25, 2023 

172:9;178:17;181:16 

helped (3)

 20:7;80:14,15 

helpful (24)

 11:9;17:20,24;34:5;

 35:13;47:11;49:22;

 51:5;59:23;65:22;

 74:2;84:4,24;85:20;

 96:5;97:21;102:15;

 105:24;111:24;

 112:13;117:20;119:4;

 122:19;165:3 

helping (5)

 21:13;26:18;65:1;

 75:7;143:24 

helps (5)

 13:10;37:4;58:1;

 108:17;115:9 

herbs (1)

 161:11 

here's (3)

 33:13;97:6,7 

hey (5)

 9:16;19:6;43:24;

 52:7;119:8 

hide (1)

 159:20 

hits (1)

 182:5 

hold (7)

 23:12;76:12;79:13;

 94:5;149:9;210:13;

 211:19 

home (5)

 8:9;81:17;175:25;

 182:6;232:8 

honest (1)

 29:18 

honestly (2)

 49:15;71:13 

honeybees (1)

 186:1 

honor (1)

 127:5 

hop (1)

 26:25 

Hope (11)

 0:3;8:17;16:23;

 58:20,23;85:23;

 109:20;124:10;

 158:14;159:23;

 165:11 

hopeful (2)

 21:9;211:6 

74:23 

Hurricane (3)

 13:9,17;42:21 

husband (2)

 6:10;36:24 

HUSEMAN (42)

 51:15;52:11,16,22;

 53:1,6,16;95:23,25;

 122:1;126:15,19;

 127:1;134:23;136:3;

 137:10;140:3;141:8;

 145:3;151:1;152:8;

 170:3,11,14,18,21;

 171:3;184:7;191:11;

 192:16;199:3;200:6;

 201:10;205:13;

 206:22;208:20;

 209:12;219:9;222:7;

 228:13;230:23;

 235:17 

hydrated (7)

 202:1;206:2;

 207:17,19,21;208:21,

 25 

65:13;78:11;90:22 

immediately (2)

 79:15,16 

immutable (2)

 102:18;104:12 

impact (9)

 60:12;76:11;100:8;

 109:3;129:8;143:1;

 185:25;197:19;

 203:25 

impactful (1)

 196:18 

impacting (1)

 129:24 

impacts (5)

 131:8;142:24;

 143:1;181:24;193:8 

implement (4)

 9:8;85:25;97:24;

 172:21 

implementable (1)

 78:15 

implementation (5)

 26:11,12,13;52:17;

 87:4 

implementations (1)

 155:18 

impressive (1)

 71:8 

improve (2)

 70:22;107:13 

improvement (5)

 25:5;27:11;35:3;

 99:12;103:16 

improvements (3)

 29:1;62:23;65:25 

improving (3)

 24:22;25:1;69:13 

impurities (1)

 221:18 

inable (1)

 142:23 

incentive (3)

 85:16;165:17;

 173:23 

incentives (3)

 167:25;171:6;

 174:16 

incentivize (4)

 172:7,11;173:3;

 176:10 

inches (1)

 162:1 

incidental (2)

I 

hierarchy (1) hopefully (7) ice (1) implementing (2) 187:13,14 

175:9 17:7;48:20;58:17; 43:4 27:7;164:19 include (8)

high (12) 63:8;108:16;110:11; ID (2) implications (1) 17:1;59:21;105:15,

 8:15;16:17;18:16; 122:9 100:9;119:21 118:3 16;124:24;147:2;

 29:22;83:19;87:9; hoping (6) idea (20) import (1) 149:16;234:4 

162:12;187:1;197:21; 46:11,13;111:3; 8:19;48:8;68:4; 94:3 included (1)

 213:17,17;225:1 124:17;127:15; 69:7;84:16;87:14; importance (5) 193:19 

high- (1) 221:15 89:14;104:5,17,19,24; 179:19;204:12; includes (5)

 106:12 horticulture (1) 108:10;110:8;125:13, 210:24;216:9;217:12 0:23;29:20;112:6;

higher (13) 154:19 24;127:4;130:21; important (36) 154:23;172:20 

13:11,19;15:24; hotline (1) 165:6;178:20;188:18 8:13,15;21:19;25:5; including (8)

 18:8;44:7,14,14,17, 78:13 ideas (14) 26:7;27:7,7,8;52:10; 69:25;84:14;154:2;

 17;182:4;186:18; hour (3) 13:14;17:7;21:8; 68:21,21;73:16; 192:24;194:14;

 188:23,24 98:16,19;236:6 30:10;49:15;61:19, 77:13;78:17;79:19; 196:12;201:25;211:1 

highest (1) hours (1) 25;68:9;71:12;72:24; 80:16,21;81:5;85:4; inclusion (2)

 213:16 78:4 77:18;175:8;181:7,16 87:6;90:24;97:6; 71:7;125:1 

high-level (3) house (1) Identification (1) 101:10;106:8;126:12; inclusive (2)

 7:16;71:9,19 65:3 99:24 172:4;174:1;177:7; 100:25;173:1 

highlighting (1) huge (5) identified (6) 181:23;203:14; income (1)

 193:2 62:20;75:25;76:4, 16:20;29:14;30:16; 204:18;211:22; 73:7 

highly (4) 22;114:16 63:12,12;142:11 213:13;216:21; inconsistent (1)

 34:12;169:7; huh (1) identifier (3) 225:13;227:6 107:10 

213:14;224:25 94:17 112:7,8;156:11 imported (1) incorporate (1)

high-risk (1) human (5) identify (7) 108:13 15:2 

100:14 69:15;78:21; 29:14;45:20;67:17; importers (1) incorporating (1)

high-value (1) 114:15;155:11; 102:18;156:13; 119:24 33:1 

153:25 224:24 157:10;181:9 importing (1) increase (8)

HIP-WI (1) humans (1) identifying (1) 87:9 31:20;73:7;87:5,8;

 13:16 186:2 104:12 imports (1) 129:24;156:19;208:5;

historically (1) hundred (2) identity (1) 212:12 226:3 

193:15 17:2;74:3 106:23 impossible (1) increased (2)

history (6) hundreds (1) ignorance (1) 39:19 15:19;195:12 

17:4,6,14,16; 185:23 56:23 impressed (1) increases (3)

 128:24;210:25 hundredth (1) image (1) 71:13 40:12;53:25;155:8 

hit (3) 189:22 172:5 impression (1) increasing (2)

 7:16;8:15;60:1 hurdle (1) imagine (3) 180:16 50:7;89:13 

Min-U-Script® Burke Court Reporting & Transcription (16) helped - increasing 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 4 

October 25, 2023 

incredible (2) 12:15,17;20:16; 132:4,5,7;185:19,23; 10:25;17:6;37:12; 179:15 

28:17;100:25 33:14;34:11;35:9; 187:20;190:8;192:24; 40:17 intervention (2)

incredibly (2) 36:24;37:10,24; 194:1,1;198:6; insured (11) 76:4,8 

8:3,15 47:19;51:6,16;53:8; 203:22;204:22;224:2 10:11;11:1;14:19; interview (1)

incremental (1) 57:7;63:3,4,13;67:22; insecticides (1) 15:8;17:4;19:1;20:6; 196:11 

182:12 72:9;74:22;75:5; 135:11 36:10;39:2;50:20; into (52)

incur (1) 83:14;100:5;102:18; insects (3) 57:16 7:24;12:5;14:5;

 90:21 104:13;108:7;109:7, 193:18;194:9,11 insuring (3) 26:20;28:9;32:11;

indefinitely (1) 17;110:21;114:10; inserts (1) 12:21,22;39:1 36:24;39:3;45:5;

 196:13 115:4,8,14,18,25; 194:6 integrate (1) 50:21;57:20,22;59:7,

indemnities (3) 118:24;119:20;120:2; insight (1) 125:1 16;62:7;63:7;65:5;

 21:4;29:25;45:1 129:11,13,15,17; 122:19 integrated (8) 69:2;72:17;78:20;

indemnity (5) 131:6;175:19;178:19; inspecting (1) 35:25;36:4,9;38:22, 80:10;83:8;87:17;

 14:11;29:24;33:11; 211:18;212:2;218:18 75:11 25;39:6;165:9;194:11 90:23;99:15;113:2,

 54:20;55:6 infrastructure (1) inspection (1) Integrity (9) 10;122:15;125:2;

Index (3) 66:23 107:5 6:19;29:9;46:10; 127:23;131:7;138:7;

 13:9,23;76:8 infrequent (1) inspections (4) 51:19;58:15;73:24; 142:21;146:23;148:1;

indicate (3) 234:5 74:4;90:9;100:14; 87:9;110:20;112:25 171:22;175:15;

 57:9;118:15;226:2 ingredient (2) 113:21 intended (1) 182:18;185:16;188:4,

indicated (1) 129:1,4 inspector (7) 118:15 17;189:18;193:3;

 233:17 ingredients (1) 74:22,24;75:8;78:9; intention (2) 201:24;203:10;

indices (1) 155:24 100:24;115:6;120:3 49:23;50:1 207:18;210:6;212:12;

 211:20 inhalation (1) inspectors (5) interact (1) 214:8;218:8;227:17,

Indiscernible (2) 186:17 74:3;83:7;100:16; 28:21 21 

64:1;170:16 inhibit (1) 101:8;114:12 interaction (2) intrigued (2)

individual (10) 132:23 inspector's (3) 64:16;129:22 57:2,5 

10:7;14:7;17:15; inhibiting (1) 74:25;75:3;114:15 interactive (3) introduce (2)

 31:19;41:2;42:5,10, 129:23 instantly (1) 100:7;115:20,21 0:9;22:15 

11,12,18 initially (1) 73:14 interchanging (1) invasive (2)

individually (2) 17:16 instead (3) 163:9 210:23;215:20 

14:19;125:20 Initiative (6) 14:6;118:2;162:24 intercropping (1) invasives (1)

indoor (1) 70:1,3,23;71:3; institutes (1) 157:4 215:18 

25:18 85:25;225:22 84:10 interest (4) inventory (1)

induce (2) initiatives (1) institutionalized (1) 11:25;24:1;51:2; 224:14 

223:8,14 19:10 211:21 165:14 invertebrates (1)

Induced (1) ink (2) institutions (2) interested (6) 208:3 

62:25 146:4,6 66:24;80:1 20:19;65:19;90:20; invest (1)

inducing (1) inks (8) instruction (8) 104:1;110:4;181:5 73:10 

227:14 146:17;147:3,7,9, 91:25;92:20,20; interesting (19) investment (1)

inductor (1) 24;148:23;152:1,2 93:1,17,19;94:3,5 39:14;51:9;54:24; 69:25 

223:16 inner-scope (1) instructions (12) 56:11;57:17;77:12, invigorating (1)

industry (13) 220:16 94:2,8;95:5,18,19, 22;104:16;107:12; 66:4 

9:7;26:17;27:5; inner-webs (1) 23,23,24,24;96:13,23, 127:14;131:1;166:13; invitation (1)

 29:19;79:17;107:24; 193:12 23 172:15;181:4;233:10, 175:18 

108:21;156:21;157:5; innovation (1) insurable (2) 19,21;234:9,10 invite (2)

 212:18;224:17,18; 162:22 11:15,16 interim (1) 84:25;85:12 

233:24 innovations (1) insurance (70) 94:4 involve (1)

industry's (1) 169:18 0:13;7:17,20,24; intermediate (1) 189:17 

157:24 innovative (1) 8:1,4,7,12,20,25;9:1, 53:14 involved (5)

inert (3) 178:5 3,4,11,19,22,22,23,25; internal (2) 17:22;19:9;84:11,

 129:1,4;155:24 in-person (1) 10:1,3,4;11:21;12:4; 95:4;189:18 11;121:4 

inerts (2) 227:5 14:18;16:1;18:12,25; Internally (2) involvement (1)

 193:23;194:4 input (3) 19:20;28:20,24; 117:13;120:2 128:3 

infect (1) 29:21;45:22;227:22 29:17,24;31:1,2;32:8, international (9) involves (1)

 188:19 inputs (2) 15,20;33:6,7;35:17; 104:1,2;106:11; 11:22 

infection (6) 71:5;122:20 36:15,15,16;37:5,8; 107:19;142:17; IOIA (1)

 203:8,8,9,12,13; inroads (1) 38:13;40:14;41:7; 154:12;157:19; 84:1 

204:7 84:21 42:8,21;47:5;48:23; 168:12;225:14 ionization (1)

inflamed (1) insect (4) 49:3,8;50:19;55:5,6, internationally (2) 87:10 

196:13 130:16;153:23; 22;56:24;57:21,24; 129:5;138:18 Iowa (1)

informally (1) 156:18;172:23 60:3;61:10,25;62:25; interpreting (1) 30:18 

80:16 insecticide (17) 63:3;65:6,14;70:9 166:22 IPM (1)

information (48) 128:19;131:14,21; insure (4) interrupt (1) 172:21 

Min-U-Script® Burke Court Reporting & Transcription (17) incredible - IPM 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 4 

October 25, 2023 

iron (1)

 194:22 

irrigation (4)

 138:17;142:14;

 163:11;221:8 

irritant (1)

 196:10 

irritants (1)

 193:8 

irritation (1)

 186:17 

isopropanol (5)

 138:10,14;139:11;

 140:20,21 

isopropyl (1)

 139:11 

issue (39)

 10:15;17:3;30:3;

 52:1;54:13;55:13,15;

 56:2;59:14;61:18;

 66:4;94:4;96:14,15,

 18;109:25;126:13;

 142:20;146:15;147:4;

 159:16,25;160:1;

 169:11,11,22;179:19;

 180:12,19;182:6,22;

 183:17;197:3,15;

 202:24;215:8;224:21;

 228:2;232:22 

issued (1)

 25:3 

issues (28)

 30:9;52:6;53:20;

 55:23;77:18;93:22;

 108:20;142:21;143:2,

 10;146:18;147:12,23;

 148:16,21;149:25;

 158:12;169:22;189:9;

 193:3,4;196:8,12;

 208:15;214:1;224:13;

 226:1;233:22 

issuing (1)

 24:18 

Italy (1)

 168:24 

item (7)

 98:10,23;126:19;

 211:12;213:19;

 214:22;215:7 

items (3)

 66:10;128:14;215:2 

iterative (1)

 95:14 

134:3;144:19;

 150:19 

Jenny (20)

 0:6;7:7;21:12;

 23:14;29:8;32:24;

 51:24;52:1,6;58:9,21;

 87:5;92:8;93:4;98:3;

 110:13;112:22;

 211:13,14;216:17 

Jerry (52)

 53:17;56:21;81:12;

 82:5;120:24;121:19;

 134:16;135:21;137:3;

 139:21;141:1;144:16,

 21;151:18;152:3,25;

 160:4;165:21;166:17;

 174:5,6,14;175:24;

 181:24;184:24;191:4,

 18;192:9;198:21;

 199:24;201:3;204:23;

 205:6;206:9,15;

 209:5;219:2;220:5,8;

 221:2,24;222:24;

 225:17;228:8;229:5,

 12,16;230:16,19;

 231:15;232:7;235:10 

Jerry's (1)

 177:16 

job (7)

 7:9;99:14;100:25;

 133:14;158:11;

 160:10;212:23 

Joe (1)

 120:13 

JOHNSON (77)

 39:13;40:4,8,19,22;

 41:4,23;42:2;43:6,9;

 57:1;64:5,8;68:24;

 69:9,11;75:15;82:5,8;

 85:2,20;92:7,15;96:4;

 97:10;108:24;109:9,

 13,19,22;110:13;

 115:1,3,14;117:20,25;

 118:8,14,18;119:14;

 120:5,10,13;121:12;

 124:5,7,9,12;134:9;

 135:14;137:20;

 140:13;141:18;

 145:13;151:11;

 152:18;165:2;171:1;

 184:16;190:22;192:2;

 196:7;198:14;199:17;

 200:21;205:23;207:8,

 11;209:22;213:21,23;

 219:19;222:17;226:9;

 228:23;231:8;235:3 

joke (3)

 22:10,12;50:9 

jotted (2)

 68:25;71:16 

jour (1)

 175:21 

journal (1)

 193:11 

juggling (1)

 169:12 

jump (1)

 63:7 

jumped (1)

 69:2 

jumping (1)

 124:4 

jurisdiction (3)

 88:2;212:6,7 

justification (2)

 92:19;170:4 

justify (2)

 132:24;195:5 

justifying (1)

 204:11 

176:23;203:11 

kills (2)

 194:11,16 

Kim (33)

 22:12;51:14;86:11;

 121:25;126:14;

 134:22;136:2;137:9;

 140:2;141:7;145:2;

 150:25;152:7;170:2;

 174:15;176:19;184:5;

 191:10;192:15;199:2;

 200:5;201:9;205:12;

 206:21;208:19;

 209:11;219:8;222:6;

 228:10,12;230:22;

 231:19;235:16 

Kim's (1)

 177:3 

kind (58)

 6:18;19:2;21:16;

 29:1;38:1;43:11;

 46:13;50:23;53:21;

 55:18,21;59:13,14;

 60:4;67:8,9;69:1,2,4;

 70:25;73:15;78:7;

 80:25;97:21;103:15;

 118:3;132:19,24;

 133:3;148:25;149:14;

 158:20;159:7;162:5;

 164:16,22;165:5;

 173:1;175:9;177:3;

 186:25;187:2,4;

 189:9,10,19;197:9;

 210:10;211:20,21,22;

 213:10;214:20;215:7;

 226:19;227:14;

 233:21;234:10 

kinds (6)

 12:19;13:15;

 174:15,16;187:8;

 197:22 

KMZ (1)

 106:2 

knowing (3)

 45:22;101:4;156:9 

knowledge (2)

 47:9;83:16 

known (7)

 10:11;92:6;196:19;

 202:8,24;214:16;

 224:18 

knows (3)

 24:19;61:3;78:10 

KS (2)

 128:17,23 

Kyla (35)

 167:8;185:1;191:6;

 192:11;198:23;200:1;

 201:5;205:8;206:17;

 209:7;219:4;222:2;

 229:7;231:17;235:12 

L 

label (4)

 132:20;142:11;

 193:6,9 

labeled (1)

 66:13 

labels (1)

 196:19 

labor (9)

 156:25;162:14,15,

 17;178:18;179:19,20,

 23;180:12 

laboratories (1)

 88:25 

labor-saving (3)

 225:22,24;227:1 

lack (2)

 83:16;157:25 

lacking (1)

 35:20 

laid (1)

 69:22 

Land (13)

 66:24;69:14;79:25;

 89:10;90:10;104:9;

 105:21;111:13,22;

 116:20;117:4,7,7 

landowner's (1)

 101:14 

landscape (1)

 218:11 

language (11)

 72:7;101:2;103:22;

 107:21;108:1;117:22;

 118:14;126:16;148:7;

 166:18;196:20 

large (3)

 8:23;39:3;208:4 

largely (2)

 220:16;221:7 

largest (1)

 9:5 

laser (1)

 164:2 

lasers (1)

 163:1 

last (42)

 14:2;16:16;17:11;

 18:1;23:22;26:19;

K 

kale (8)

 156:1,4,5,6,6;159:9,

 11;161:5 

kales (1)

 161:9 

kaligreen (2)

 132:16,20 

Kansas (1)

 56:14 

Kayla (1)

 134:18 

keep (16)

 28:23;42:7;50:13;

 56:16;59:6;98:21;

 99:18;101:11;103:14;

 122:20;125:21;

 133:22;172:7,11;

 173:16;196:10 

keeping (5)

 51:22;52:5;77:2;

 82:19;180:5 

key (4)

 25:22;26:14;37:1;

 109:4 

kick (6)

 0:6;59:16;62:22;

 79:7;138:3;216:16 

kick- (1)

 60:17 

J 

j2 (1) Join (6) kickback (1) 53:18;58:5;59:3; 29:25;30:5,16,18;

 220:7 20:21;23:21,23; 203:7 75:14;76:13;78:18; 38:6;59:4;73:15;87:3;

January (1) 24:4;27:3;105:10 kicking (2) 91:22;92:5;111:8; 98:10;99:15;100:15,

 171:14 joined (1) 60:5;172:7 116:17;121:21; 15;101:14;107:16;

Jared (1) 0:20 kidding (1) 135:23;137:5;139:23; 118:18;122:22;

 110:14 joining (1) 166:17 141:3;144:23;150:21; 127:15;129:9,15;

Jeffrey (3) 28:5 kill (2) 153:2;160:4;165:20; 130:13;136:18;162:3; 

Min-U-Script® Burke Court Reporting & Transcription (18) iron - last 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 4 

October 25, 2023 

163:2;174:22;186:12; 171:18;211:24 124:16;134:13; line (6) literally (2)

 195:6,21;196:11; leaves (2) 135:18;136:25; 8:11;26:2;72:19; 36:21;76:9 

211:18;215:15;218:4, 203:10;227:9 139:18;141:22;144:2; 93:20;113:13;226:10 little (57)

 4,6,6,9;234:14 leaving (1) 145:17;146:7,10,13; link (3) 8:16;15:8,24;24:6;

late (1) 55:20 149:18,21;150:6,13; 12:14;18:17;30:22 28:23;36:1,3,6;41:11;

 157:16 led (4) 151:15;152:22;175:8; links (1) 48:8;51:7,20;52:12;

later (11) 81:20;101:8;124:4; 176:15,18;184:21; 12:17 56:13,23;58:24;

 14:5,21;20:24;21:5, 215:18 191:1;192:6;198:18; liquid (9) 60:17;66:10;74:11;

 6,8;34:17;40:20;67:2; leeway (1) 199:21;200:25;204:4; 210:5,7,21,21; 75:1;77:25;78:10;

 91:18,19 56:2 205:3;206:12;210:1; 211:6,9;217:7,8; 85:16;88:1;90:22;

Latin (1) left (2) 219:23;221:3,11; 218:23 92:19;93:9;94:7;95:5;

 168:17 101:15;210:11 222:21;226:25;229:2; list (71) 100:2,22;105:21;

latitude (1) leftover (1) 231:12;235:7 54:15;66:7,7;80:13; 106:6,15,19;115:11;

 114:11 167:21 Lewis's (1) 84:5;89:14;90:13; 118:19;123:5;148:22;

laugh (1) leg (1) 74:1 109:6,9;121:4; 149:1;160:20;161:3;

 96:1 82:23 lexicon (1) 125:16,17;128:14,22, 165:24;167:5;168:8;

laughing (2) legal (13) 72:21 22,25;129:3;132:17; 177:10;178:18;186:4;

 95:22;114:21 88:3;100:9;101:17; liability (2) 133:22,22;135:10; 189:16;195:17;

Laughter (1) 102:20;104:9;105:23; 10:23;19:2 136:20;139:12,15,15; 204:12;207:7;215:4;

 22:11 106:23;107:8;112:18; liaison (1) 140:21;144:18; 216:22;217:3;218:5,8 

law (3) 115:18;118:21;119:3, 6:1 145:24;149:3;150:18; live (5)

 18:11;64:5;142:9 21 library (1) 152:3;155:17,17,20, 0:12;13:20;37:6;

laws (2) legislation (4) 211:8 23;165:16;166:2; 56:14;169:21 

55:4;56:13 9:10;20:21;51:3; life (6) 170:6;174:12;175:22; lived (1)

lay (1) 82:21 7:10,14;81:16;82:1; 176:12,13;184:4; 31:5 

137:24 legitimate (2) 114:15;127:23 190:10;191:17; Livestock (5)

layby (2) 39:5;108:14 lift (8) 192:22;193:20;198:5; 24:9;25:8,10,12,15 

161:25,25 legitimately (1) 90:23,25;94:20,25; 199:12;200:17; living (4)

layer (3) 104:7 102:21;103:25;106:7; 204:21;206:8;208:17; 25:14,18;36:21;

 189:18,19;203:16 length (1) 178:7 209:1;210:5;211:3,8; 224:12 

laying (1) 186:22 lifting (2) 213:17;217:8;218:24; Liz (1)

 65:16 Leo (1) 114:13,19 220:4,14;221:24; 173:18 

leaching (1) 112:3 light (2) 223:4,9;228:7; loading (1)

 175:22 Leo's (1) 110:19;182:9 230:19;232:10; 138:9 

lead (5) 101:3 lighter (2) 233:12,12;234:16 loan (1)

 70:5;105:25; less (8) 90:23,25 listed (21) 8:5 

119:21;174:14; 14:8;44:5,8,16,16; light-headedness (1) 6:18;10:10;13:6; Local (3)

 197:25 188:16;208:20;233:1 225:2 87:19;129:3,4;130:8; 34:11;35:10;61:3 

leader (1) Lester (2) liked (1) 142:18,19,23;153:13; located (2)

 88:21 23:14;79:9 7:8 155:25;157:13;161:6; 100:7;114:7 

leadership (4) level (17) likely (5) 170:9;201:23;203:25; location (16)

 24:15;123:20; 12:23,24;13:11; 76:2;102:25;113:4; 207:21;232:18,24; 39:20;99:24;100:4;

 127:13;215:21 15:19,20;25:9;60:5; 156:16;168:14 233:6 104:22,22;108:6;

leading (1) 61:3;83:19;89:18; liken (1) listen (4) 109:7,17;112:9;

 124:16 113:7;116:6;143:19; 74:9 52:21;61:20;63:17; 115:18;117:1;118:24;

leaf (1) 165:16;183:7,8;216:2 likes (2) 105:8 119:20,21,21,25 

156:6 leveling (2) 20:21;42:9 listening (2) locations (3)

lean (1) 25:22;27:10 Likewise (1) 6:16;213:15 44:21;107:24;

 181:6 levels (10) 169:17 listing (22) 119:24 

learn (1) 10:2;13:19;37:23; lime (25) 61:10;146:16; log (1)

 160:9 52:13;60:21;82:18; 197:21,21;201:22, 147:7;148:10;150:1, 229:25 

learned (3) 88:18;188:22,23,24 25;202:1,3,6,7,12,22, 11,14;154:9;166:14, Logan (59)

 107:16;129:11; leverage (3) 25;203:5,10,17;204:1, 16;187:11;191:16; 43:23;46:25;51:18;

 195:22 66:24;88:16;89:22 17,20;206:2,4,7; 193:16,24;199:11; 58:7;64:19;120:23;

learning (7) leveraged (1) 207:17,19,21;208:21, 200:16;207:19; 121:7;132:9;133:9;

 78:8;97:14,15,18, 88:20 25 213:15;232:24,24; 135:3,12;136:8;

 22,23;221:16 LEWIS (62) limitations (3) 234:11,12 137:15;138:13,14;

least (9) 53:20;54:14;55:2; 46:20;154:24;155:4 listings (6) 139:6,13;140:8,22;

 18:6;66:14;67:14; 56:5,18;65:13;72:4; limited (4) 145:24;154:15; 141:13;145:8;151:6;

 133:3;149:25;165:15; 86:11,13;88:7;91:6, 10:12;147:25; 185:15;187:11; 152:13;153:8;158:8,

 178:23;188:17; 16,20;92:3;93:5,8,12, 210:21;225:3 192:23;202:3 10,20;160:7,20;165:2,

 202:24 14;94:13,16,18,22; limits (2) literacy (2) 22;167:4;169:10;

leave (2) 102:13;121:16; 16:9;223:24 74:9,12 172:13;174:25; 

Min-U-Script® Burke Court Reporting & Transcription (19) late - Logan 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 4 

October 25, 2023 

178:13;183:19;184:4,

 12;187:24;190:17;

 191:22;198:9;200:11;

 201:15;205:18;207:2;

 209:17;219:14;

 222:12;223:5,6;

 225:17;227:13;228:6,

 8,18;231:3;234:23 

Logan's (2)

 138:5;183:15 

log-grown (1)

 229:13 

logical (1)

 55:23 

logistics (1)

 68:6 

long (11)

 24:12;27:23;30:14;

 49:18;61:7;62:2;69:1;

 165:6;169:13;223:21,

 22 

longer (5)

 28:23;87:1;95:1;

 118:20;230:1 

longitude (1)

 114:11 

long-range (1)

 50:14 

long-term (1)

 71:5 

look (63)

 117:9,10;118:21;

 119:2,6;125:10;

 127:25;132:13;

 149:11;153:9;165:14;

 167:10;171:10,23;

 179:3;181:7;188:2,

 12;189:10;214:2;

 224:6;236:8 

looks (4)

 8:20;67:21;115:5;

 165:3 

loose (2)

 101:1;156:6 

loose-leaf (1)

 159:11 

lose (3)

 55:8;110:12;183:23 

lose-lose (1)

 155:8 

losing (3)

 54:16,25,25 

loss (25)

 0:18;14:10;18:5,5,

 6,10,12,19;19:17;

 30:1,1;33:9;42:14;

 43:14,25;44:13;

 45:25;51:5;54:1,4,5,6,

 19;55:7;59:15 

losses (6)

 44:2,7,8,8;53:22;

 55:8 

111:10;194:22 

loud (2)

 88:13;89:7 

love (13)

 59:8;68:22;71:25;

 84:16;90:7;103:10;

 113:20;118:17;

 160:12;161:2;178:3;

 181:15,21 

loves (1)

 122:25 

loving (1)

 157:9 

low (7)

 18:15;45:7;108:14;

 117:10;185:25;193:6;

 225:5 

lower (3)

 188:23,23;210:9 

luck (1)

 53:23 

lunch (4)

 62:13;98:12,19;

 99:22 

luncheon (1)

 98:25 

luxury (1)

 168:23 

makes (11)

 26:20;32:8;75:25;

 79:11;85:24;99:5,7;

 188:2;189:25;211:10;

 224:4 

making (21)

 24:14;25:25;26:2,

 21;27:9,12;33:3;61:5;

 63:11;69:11;73:24;

 78:25,25;85:10;95:4;

 100:25;104:10;

 110:15;114:15;

 124:20;183:22 

Mama (2)

 123:1,12 

man (3)

 54:18;101:2;176:1 

manage (3)

 102:24;106:8;

 146:17 

managed (1)

 147:5 

Management (19)

 0:16;30:13;32:16;

 48:15,16;62:1;69:15;

 93:21;107:22;153:13,

 15,22,23,23;157:7;

 175:10,12,15;194:11 

managing (3)

 106:9;217:14;

 234:10 

68:12 

marine (6)

 210:25;211:10;

 212:5,8;215:9;217:23 

market (5)

 26:1,3;70:10;73:9;

 83:2 

Marketing (1)

 23:14 

markets (5)

 54:2;55:17;70:12;

 73:22;89:23 

married (1)

 117:8 

marry (2)

 101:18;106:23 

marvelous (1)

 168:3 

mask (1)

 220:22 

mass (8)

 106:10,12,19;

 115:5,9;116:4,5;

 189:22 

match (1)

 161:20 

matches (1)

 59:22 

matching (1)

 115:12 

material (44)

M 

9:8;11:11,18;12:17; lost (1) machine' (1) manner (1) 20:1;122:20;

 13:13;14:7;16:19; 123:19 164:4 232:12 125:18;126:5;129:12;

 18:6,16,19;19:8,18; lot (84) macro (1) Manual (1) 139:7;146:14,16,24;

 20:5,25;21:1;27:15; 6:15,24;8:21;12:5; 217:20 124:15 147:20;148:3,9,15;

 28:13;30:24;32:25; 14:13,15;16:15; Madam (7) manufacturer (1) 153:12;154:6,7;

 33:19;34:21;43:11, 18:15,22;20:23; 86:4;99:20;152:5; 167:25 155:4,6,10;156:11,15,

 20;44:20;48:2,24; 22:16;26:9,14;31:6; 170:18;183:25; manufacturing (1) 22;158:1;173:24;

 49:5;50:16,23;52:25; 34:11,15,19,25;35:9; 185:13;190:4 224:17 176:21,22;177:17;

 57:8;59:13;60:25; 36:19;39:14;42:11; magic (1) manure (1) 188:8;197:25;202:13,

 61:15;64:21;70:23; 43:1;51:7;56:8,9; 94:14 78:13 13;210:15,25;212:25;

 78:22;88:19;90:20; 57:23;58:1,21;59:18; mail (1) many (26) 213:1;221:5;224:8;

 107:15;108:11; 63:4;66:2;70:12; 148:24 6:5;13:20;24:19; 226:11;227:24;

 110:18,25;111:4,7; 76:10;84:10;87:5; mailing (1) 25:15;26:11;41:1; 232:25;233:9,11,14;

 114:1,2;117:14; 95:7;97:22;102:1; 105:18 80:2,17;102:9; 234:8 

118:3,3;131:9; 105:22;107:6;109:1; main (3) 130:12;131:5;154:4; materials (21)

 143:11;156:2;168:24; 112:17;114:9,9; 128:20;194:18; 155:3,10;156:16,21; 19:25;127:23,25;

 177:21;178:3,4; 115:24;116:12; 202:23 157:13,23;162:21; 130:10;138:19,24;

 179:6;181:2,4; 117:13;127:14,22,24; mainly (1) 169:15;177:2;178:20; 139:3;146:5,20;

 182:18;195:3;227:9 129:11;130:20; 193:8 194:10;216:6,9; 147:8,10;148:25;

looked (5) 147:21;148:13,14; maintain (2) 227:15 152:2;153:15;175:14,

 71:2;101:22; 150:7;162:7,8,10,24; 27:13;234:12 map (6) 14,19;208:21;212:25;

 171:18;227:17,23 164:6;165:14;166:15; maintained (1) 18:25;35:16,17; 233:3;235:23 

looking (57) 169:4,17;172:25; 208:17 36:14;43:7;102:25 math (1)

 16:25;17:19;18:8, 177:10;178:16;182:2, maintaining (1) mappable (1) 98:18 

10;19:5;20:19;21:2,3, 6;186:13;187:7; 73:23 114:7 matter (5)

 4;32:12,13;33:1; 197:11;210:14; maintains (1) mapping (3) 16:15;82:22;160:8;

 36:17;37:12,22; 213:16,25;214:1; 139:15 100:7;115:20,21 167:11;223:20 

41:17;48:13,17,18,19; 217:6,11;224:10; maintenance (1) maps (1) mature (1)

 49:3;57:5,14;59:17; 227:15,20,20 80:20 117:14 226:20 

60:20;61:2,13;64:17; lots (8) major (4) March (2) maturity (2)

 66:1;73:19,23;82:23; 14:12;22:19;27:20, 55:15;177:24; 15:6;182:12 226:2,18 

83:2;91:16;108:8; 25;28:3;34:13; 180:12,19 marching (1) maximum (3) 

Min-U-Script® Burke Court Reporting & Transcription (20) Logan's - maximum 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 4 

October 25, 2023 

12:8,13,13 media (1) 12;158:10;159:7,15; 179:9 19:6;21:10,10,18;

may (33) 27:2 160:24;161:1,4; mentioned (39) 28:20;31:5;33:15;

 9:25;10:25;14:10; medium (1) 163:12,16,19,24; 10:15,19;11:3,15, 37:14;41:14,16;

 39:15;52:6;53:23; 178:17 164:2,6,12;165:2,19; 20;13:24;14:15; 42:13;43:19,19;

 64:17,18;70:18; meet (7) 166:18,23;167:1,3; 15:12;18:9;19:11; 64:20;65:7;66:21;

 72:11,11;90:10,10; 76:21;83:9;84:18; 168:6,8,10,19,20,22; 26:25;35:25;58:10; 70:23,24,24;72:1;

 102:2;111:6;116:1; 85:7;88:25;103:11,12 169:9;170:3,8,11,13, 61:19;64:19;67:12, 86:1;89:15;92:18;

 124:22,23,23;125:13; meeting (27) 14,16,18,21;171:1,3; 17;75:20;84:8,17; 101:6;109:13;125:17;

 132:22;147:3;157:3; 23:21,23,23;24:5; 172:3,14;173:8,15,18; 89:7;90:11,16; 149:12,13;171:21;

 168:6;174:15;193:25; 28:5,7,9;69:19;76:17; 174:9;175:1,5,6,8,25; 105:24;106:11; 175:15 

194:1,20;203:2; 120:14;122:17; 176:9,15,18;178:14, 116:17;132:15;139:2; mighty (1)

 207:23;217:19,23; 123:21;124:20;126:9; 22,25;179:3,14,17; 181:24;182:14; 124:13 

233:2 127:4;146:25;186:22; 180:11,21;182:13,21; 197:19;202:11;215:7; Mike (1)

maybe (42) 187:9;210:12,16,19; 183:1;184:7,9,11,13, 217:1,7,14;233:3,11, 177:20 

8:8;9:20;11:7; 211:17,19;218:4; 16,19,21,23,25;185:2, 13 mildew (3)

 20:12;29:21;32:24; 220:12;229:23;236:9 5,21;187:25;188:7,10, mentoring (1) 131:25;132:2;

 39:19;40:18;41:2,8; meetings (4) 11,12,15,16,20;189:4, 77:20 194:15 

43:19;44:17;45:22; 85:1,7;123:21; 5,7,8,14,15;190:2,14, mentors (3) million (8)

 51:3;52:12,25;54:4; 124:24 16,18,20,22,24;191:1, 78:2;85:4,18 30:8,14;32:1;69:25;

 57:17;63:7,8;66:13, MEM (478) 3,5,7,11,21,23,25; mentorship (2) 164:4;181:3;224:16,

 14;74:4;85:9;90:24; 35:8,13,24;36:11; 192:2,4,6,8,10,12,16, 76:24;77:11 17 

91:5,12;92:23; 38:2,17,23;39:10,13; 18;196:7;197:3,20; MESCC (1) millions (1)

 103:20;110:13; 40:4,8,19,22;41:4,23; 198:10,12,14,16,18, 38:14 104:4 

125:25;139:11; 42:2;43:6,9,24;44:4, 20,22,24;199:3,5,7, message (4) Milwaukee (2)

 158:15;162:5;164:7; 12,22;45:3,8,10,13, 15,17,19,21,23,25; 49:7;88:12;99:11; 181:16;182:17 

171:8;176:2;183:7; 16,19;46:2,6,15,18, 200:2,6,8,10,12,21,23, 159:24 mind (9)

 187:25;203:9;211:25; 24;51:15;52:11,16, 25;201:2,4,6,10,12, met (2) 35:5;65:10;66:19;

 216:14 22;53:1,6,16,20; 14,16,18;202:2,7; 0:10;211:19 67:6;74:20;103:4;

mean (35) 54:14;55:2;56:5,18, 204:4,16;205:1,3,5,7, metal (1) 171:19,20;187:5 

16:14;43:10;44:2,4; 22;57:1,2;58:1;64:5, 9,13,15,17,19,21,23; 195:11 Mindee (11)

 47:9,14;48:24;49:22; 8;65:13;68:24;69:9, 206:12,14,16,18,22, method (6) 124:16;134:3;

 50:7,10,15;56:12; 11;72:4;75:15;77:5; 24;207:1,3,5,8,11,13, 78:23;128:20; 142:2;144:19;150:19;

 72:14;74:14;77:15, 78:19;81:13;82:5,8; 21;208:20;209:4,6,8, 164:22;172:23; 184:4;198:7;209:1;

 16;91:3;111:16; 83:5;84:7;85:2,15,20; 12,14,16,18,20,22,24; 229:25;230:2 218:25;226:14;

 114:19;146:20; 88:7;91:6,15,20;92:3, 210:1;213:21,23; methods (3) 234:17 

158:19;159:12;161:9; 7,15;93:5,8,12,14; 215:15;219:3,5,9,11, 154:19;156:25; minds (1)

 170:24;171:19; 94:13,16,18,22;95:23, 13,15,17,19,21,23,25; 164:23 212:22 

172:25;176:15,18; 25;96:4;97:10; 220:9;221:3,11,12; metric (1) Mine (2)

 177:5;181:21;183:4; 102:13;103:5;108:24; 222:3,7,9,11,13,15,17, 59:21 59:6;83:25 

189:23;196:9;215:19; 109:9,13,19,22; 19,21,23,25;223:7; Mexican (1) mined (2)

 225:21 110:13;115:1,3,14; 225:19,24;226:7,9,14, 107:16 232:12,19 

meaning (3) 116:16,22;117:12,17, 25;227:11,13,18; Mexico (1) minimal (2)

 87:10;95:11;203:7 20,25;118:8,14,18; 228:3,13,15,17,19,21, 0:21 129:3,21 

meaningless (1) 119:14;120:5,10,13, 23,25;229:2,4,6,8,17; Micro (11) minimize (3)

 167:23 25;121:8,12,14,16,18, 230:23,25;231:2,4,6, 14:14,16,20;15:5; 182:24;227:10;

means (13) 20;122:1,3,5;124:5,7, 8,10,12,14,16,18; 16:8;17:3;36:1,10; 234:5 

12:23;24:20,20; 9,12;125:24;126:7,15, 232:14;234:20,22,24; 38:24;39:4;129:23 minimized (1)

 26:5;32:10;33:7; 19;127:1;132:12; 235:1,3,5,7,9,11,13,17 microbes (1) 234:3 

42:13;69:14;77:13; 134:9,11,13,15,17,23, MEMBER (1) 132:23 minimizes (1)

 105:17;108:2;232:16; 25;135:2,4,14,16,18, 176:25 microcrystalline (5) 232:13 

233:1 20,22;136:3,5,7,9,23, Members (6) 229:12;230:6,11, minimum (3)

meant (1) 25;137:2,4,10,12,14, 0:3;122:15;124:18; 13,18 48:22;87:23;210:9 

109:5 16,20;138:15;139:18, 126:21;148:9;217:8 microorganisms (1) minute (4)

meantime (1) 20,22;140:3,5,7,9,13, memo (2) 129:24 21:22;62:7;93:11;

 22:4 15,25;141:2,8,10,12, 58:15,21 microplastic (1) 96:7 

measure (3) 14,18,20,22;142:4,7, mentee (1) 155:16 minutes (4)

 47:6;48:25;49:2 13;144:2,22;145:3,5, 78:5 mid (1) 80:14;98:11,13;

measurement (4) 7,9,13,15,17,19; mentees (3) 157:15 185:10 

49:5,16,21;81:21 146:7,10,13;148:20; 85:5,16,18 middle (3) mirrored (1)

mechanical (1) 149:18,19,21;150:6, mention (10) 24:5;114:22;160:15 230:9 

175:11 13;151:1,3,5,7,11,13, 9:18;19:20;36:4; Midwest (1) misapplications (1)

mechanisms (2) 15,17,19;152:8,10,12, 38:10;129:20;162:22; 43:4 53:23 

82:25;83:2 14,18,20,22,24;153:1, 163:7;168:12;173:19; might (30) misapplies (1) 

Min-U-Script® Burke Court Reporting & Transcription (21) may - misapplies 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 4 

October 25, 2023 

55:5 

mislabeling (1)

 89:10 

miss (1)

 124:24 

missed (3)

 62:18;66:17;174:25 

mistaken (1)

 85:15 

misunderstanding (1)

 16:7 

mite (1)

 192:24 

miticide (2)

 185:22;187:20 

mitigate (1)

 130:19 

mitigated (1)

 193:9 

mix (3)

 86:1;133:5;202:19 

mixed (2)

 59:10;212:16 

mixers (1)

 202:17 

mode (4)

 132:6;188:6;

 189:17;194:15 

models (2)

 53:4;80:1 

moderate (1)

 72:11 

modifications (2)

 105:15,16 

modifying (1)

 48:16 

Moffett (1)

 23:14 

MOFFITT (8)

 23:10,16,19;27:22;

 28:2,16;36:3;79:9 

moisture (1)

 153:23 

molds (2)

 142:16;164:10 

mom (1)

 77:15;79:11;107:8 

month (2)

 123:21,21 

months (3)

 73:14;162:16;

 223:23 

months' (1)

 58:22 

more (154)

 9:14;10:8;11:6,8,9,

 22;12:2,6,15;14:22;

 15:9,23;16:23,24;

 18:18,20;19:3,7,8,21;

 20:25;24:15;25:13,

 16,17,18;29:25;30:2,

 11;31:23;32:3,8,14,

 15;35:18;36:6,16;

 38:6,7,13,15;39:23;

 41:4,6,9,16;43:19;

 44:2,20,25;48:23;

 49:10;50:6,11;51:20;

 52:12,23;53:7,8;56:2;

 57:7,11,23;58:24;

 60:6;61:1;63:13;

 64:10;66:11,19,22;

 67:13;69:14;74:2;

 75:21,21;76:2,5;

 80:19,23;81:4,25;

 82:12;84:25;85:1;

 88:1;89:23;90:19;

 92:11,19;95:1,16;

 97:14,14;98:1,23;

 100:16;105:14,21;

 106:15;107:25;

 108:16;111:21,22;

 112:3;113:23,24;

 114:5,20,20;126:10;

 130:3;131:3,6;132:3;

 143:7;144:2;155:14;

 156:19;157:9;160:20;

 161:3,12;162:8;

 167:19;168:14;

 170:22;173:4;176:2;

 177:4;178:6;181:7,

 10;188:2,13,16,20;

 189:1,10;195:24;

 79:19;83:9;101:8;

 107:12;111:1;148:16;

 155:1;156:24;169:16;

 183:9,23;195:20;

 203:12,12;225:13 

mostly (2)

 104:11;160:22 

motion (74)

 69:20;70:22;122:8;

 134:1,2,5;135:7,9,12;

 136:14,18,19;137:23;

 139:10,12;140:19,21,

 22;141:25;144:16,17,

 19;145:22;150:8,16,

 18;151:22;152:1;

 153:6;184:3,4;185:7;

 190:5,8,8,10;191:14,

 16;192:21;198:5,6;

 199:10,11;200:15,16;

 201:21;204:19,20,22;

 206:1,7,8;207:16;

 208:25;209:1;210:4;

 218:22,23,24;220:3;

 221:22,23,24;223:3;

 228:5,7;229:11;

 230:17,18,19;232:6;

 234:15,16;235:20 

motioned (4)

 139:13;152:3;

 191:17;228:7 

motioner (3)

 120:7,9,18 

movable (3)

 194:25,25;195:1 

move (21)

 31:8;74:4;116:25;

 127:18;135:9;154:10;

 164:8,18;165:15;

 167:15,22;173:2,19;

 176:5;184:2;211:12;

 212:17;213:9;214:8;

 216:11;218:20 

moved (2)

 115:10;214:11 

movement (1)

 162:25 

167:3,12,19;170:1;

 177:8;178:7;197:13;

 202:12,13;216:17;

 224:18,23;226:4,5,6 

mulch (44)

 153:9,16;154:9,16,

 18,25;155:6,8,12,16,

 22;156:7,10,20;157:1,

 8,20,21;159:16;

 160:12;161:7,8,10,11,

 12;164:18,21;165:6,

 9;166:1;170:7;

 172:16,20;173:5,20;

 174:12,13,24;175:10;

 179:12,18;182:1,4;

 184:3 

mulches (5)

 153:18,21;154:15;

 168:24;169:19 

mulching (2)

 156:25;170:5 

multiple (4)

 11:6;67:15;153:22;

 164:24 

multitasking (1)

 138:2 

municipal (1)

 147:1 

muscular (1)

 225:1 

mushroom (2)

 229:14;230:1 

music (1)

 7:12 

must (3)

 19:13;97:17;229:14 

mutagens (1)

 130:6 

mutually (1)

 62:2 

myself (4)

 86:11;89:9;114:21;

 215:14 

191:3;192:8;198:20;

 199:23;201:2;205:5;

 206:14;209:4;219:25;

 222:23;227:13;228:3;

 229:4;231:14;235:9 

nanoparticles (3)

 187:13,14,14 

NAP (5)

 10:18,20,24;11:1,1 

Napa (1)

 30:20 

NAP's (1)

 10:21 

narrow (1)

 226:3 

NAS (3)

 30:6,6;57:15 

Nashville (1)

 7:13 

Nate (69)

 28:8;36:2;53:17;

 54:19;56:20;65:12;

 72:3;74:1,20;75:16,

 16;85:3;86:11,11,13;

 91:16;93:3;98:7,10;

 99:25,25;100:18;

 102:12;105:23;

 106:11;109:4;111:15;

 113:17;115:1;121:15;

 124:16;125:24;

 134:12;135:17;

 136:24;138:1;139:17;

 141:21;144:1;145:16;

 151:14;152:21;169:8,

 25;170:2;174:4;

 175:7;182:2;184:20;

 190:6,25;192:5;

 198:17;199:20;

 200:24;204:3,16;

 205:2;206:11;209:25;

 218:19;219:22;221:2;

 222:20;226:8,24;

 229:1;231:11;235:6 

nation (2)

 9:3;30:15 

national (48)

N 

7:8 202:12,12,13;208:20; moving (11) name (5) 0:17;24:2,13,16;

moment (3) 213:12,12;216:22,25; 22:19;24:8;49:9; 71:15;101:14,14; 27:9;55:19,21;56:10;

 53:1;54:7;183:14 217:2;218:2;221:14; 86:1;103:16;158:15; 103:1;202:9 60:25;61:6,13;121:4;

moments (1) 224:3;227:20,20 193:15;199:11;206:2; named (2) 125:10,16,16;128:14,

 27:1 morning (6) 207:17;220:4 6:6;64:8 25;133:21;135:9;

momentum (1) 0:3,7;7:3;23:9; much (52) names (1) 136:20;139:12,14;

 28:23 70:9;213:10 11:4,16;15:2;16:23; 70:17 140:21;144:18;

money (6) morphing (1) 18:22,23;28:5;37:24; NANDWANI (43) 150:18;152:2;166:2;

 49:6;71:22;75:17; 107:25 39:10;47:2;50:17,20; 35:8,13,24;36:11; 170:6;184:4;190:10;

 76:9;78:24;162:13 moss (1) 51:12;58:3;59:5; 38:2,17,23;39:10; 191:17;193:20;198:5;

monitor (1) 142:16 69:20,20;76:2;78:15, 84:7;91:15;116:16, 199:12;200:17;

 39:8 most (32) 24;96:10;104:16; 22;117:12,17;121:18; 204:21;206:8;209:1;

monitored (1) 12:3,8,20;14:24; 106:25;108:12;112:1, 134:15;135:20;137:2; 211:3,17;212:7;

 232:19 17:20;26:12;31:8; 20;116:7;122:21; 139:20;140:25; 218:24;220:14;

monitoring (1) 37:14;43:13;45:6; 123:16;133:4;143:23; 145:19;151:17; 221:24;223:9;228:7;

 233:23 54:10,21,21;57:21; 147:24;155:4;157:8; 152:24;169:9;182:13, 230:19;234:16 

Montana (3) 60:22,22;63:14; 158:10;165:13,13; 21;183:1;184:23; native (2) 

Min-U-Script® Burke Court Reporting & Transcription (22) mislabeling - native 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 4 

October 25, 2023 

6:9;211:9 

natural (3)

 130:12;157:12;

 175:13 

naturally (1)

 223:20 

nature (2)

 185:24;187:15 

navigate (2)

 125:11;163:15 

nearby (1)

 82:10 

nearly (3)

 87:2;220:18,19 

necessarily (7)

 16:14;59:16;76:25;

 77:19;80:18;112:8;

 131:19 

necessary (7)

 104:23,24;161:12;

 162:18;177:21;221:4;

 225:11 

necessity (2)

 217:2;218:2 

need (71)

 7:22,25;11:5,5;

 18:23;21:4,15;29:25;

 37:13,13,17,21,22;

 39:21;43:18;56:16;

 61:15;65:6;67:8,21;

 72:9,15;73:12,20;

 74:7,8;80:24;81:3;

 82:5,24;83:1;88:22;

 89:4,12,25;90:11;

 92:18;94:5,9,10;95:7,

 9;96:16;97:9,16;

 99:18;101:25;103:16;

 107:23;108:20;

 109:13;115:23;119:5;

 120:7,10;125:8;

 155:16;161:21;172:4,

 9;173:16;174:20;

 182:7;195:5;212:21,

 24;214:12;215:3;

 217:19;227:4;229:24 

needed (12)

 22:21;72:17;

 126:24;131:3;139:5;

 156:17;182:17;

 195:23;208:17;210:9;

 218:2;233:25 

needing (2)

 31:1;178:17 

needle (4)

 31:8;49:9;167:15;

 176:6 

needs (7)

 54:20;95:10;176:4;

 179:21;181:10;

 183:20;215:2 

negative (2)

 142:24;186:8 

negligible (1)

 186:20 

negotiation (2)

 80:22;167:24 

net (1)

 9:6 

netted (1)

 130:9 

Network (6)

 30:19;69:19;70:5;

 77:13;80:16,25 

neutralize (1)

 220:11 

new (20)

 0:19,21;14:24;15:3;

 17:13,20;20:10;36:1;

 47:4;78:2;84:19;

 93:22;107:9;149:10;

 154:17;171:13;

 186:11,13;215:10,13 

news (2)

 24:6;28:22 

newspaper (13)

 99:4;145:25;146:3,

 5,14,22;147:2;

 148:22;149:6;150:16;

 151:25;152:1;158:13 

newspapers (1)

 146:20 

next (35)

 17:8;21:10;31:5;

 34:20;36:21;59:13;

 61:24;63:9,25;68:20;

 70:24;75:11;86:5,7;

 89:14;90:5;91:13;

 92:8;116:24;117:2;

 122:16;138:12,13;

 140:17,20;145:24;

 150:11;153:9;158:18;

 185:12;192:22;

 199:11;210:5;220:5;

 223:4 

nice (2)

 53:14;126:13 

nicely (1)

 106:6 

niche (1)

 87:1 

night (3)

 0:4;8:4;236:8 

nimbleness (1)

 29:2 

NIMS (1)

 215:19 

nine (4)

 130:14;194:7;

 203:21;225:6 

nitrate (1)

 130:5 

nitrogen (2)

 194:25;217:13 

NOAA (2)

 212:7,8 

nobody (2)

 20:21;82:12 

nod (1)

 183:16 

NOFAs (1)

 78:12 

non (1)

 96:14 

non-antibiotic (1)

 204:6 

non-binding (1)

 96:9 

non-compliance (1)

 97:13 

non-compliances (1)

 92:25 

non-compliant (1)

 96:15 

none (4)

 37:5;190:4;218:22;

 230:5 

non-insurance (1)

 61:10 

nonpersistent (1)

 203:18 

non-petroleum (1)

 230:8 

nonprofits (1)

 147:17 

non-synthetic (1)

 232:10 

non-target (1)

 143:2 

nontoxic (2)

 185:25;208:2 

non-toxic (1)

 138:19 

non-unanimous (2)

 125:3;226:13 

NOP (16)

 28:10;51:20;88:3;

 89:12;90:12;109:25;

 118:1,3;119:19;

 149:4;194:5;210:11,

 20;211:11;214:9;

 215:1 

NOP's (1)

 29:9 

normal (1)

 186:18 

normally (2)

 78:19;107:6 

north (2)

 37:6;102:7 

Northeast (2)

 38:5;105:21 

Northern (1)

 55:15 

northwest (1)

 217:10 

NO's (1)

 30:25 

NOSB (17)

 23:21,23;24:5,12,

 13,15,15,21,22;27:6,

 8;70:19;88:5;120:14;

 156:22;211:2,7 

NOSB'ers (1)

 62:12 

nose (1)

 101:9 

notable (3)

 129:19;130:23;

 143:12 

note (7)

 63:13;108:5;130:4;

 131:2;173:25;193:23;

 221:3 

noted (12)

 92:3;99:2;142:1;

 144:9;174:3;186:16;

 187:12;196:1;217:22;

 218:9;224:9;230:1 

notes (8)

 16:4,4;19:19;34:2;

 63:16;68:25;70:14;

 220:21 

nothing's (1)

 58:20 

notice (6)

 35:18;93:15;96:16,

 18;143:23;156:2 

noticed (3)

 83:6;150:10;211:8 

no-till (1)

 157:3 

noting (2)

 53:7;204:9 

nowhere (1)

 110:5 

NRCS (5)

 8:22;33:4;34:3,9;

 65:5 

number (32)

 14:23;16:19;18:1;

 40:10,22;41:5,5,8;

 42:23;43:7;47:25;

 50:8;83:6,10;101:12;

 105:11,15,18;112:2,5,

 5;143:11,16;146:18;

 160:1;189:21;194:21;

 196:12;212:4;214:23;

 221:6,7 

numbers (9)

 18:2;20:17;40:13;

 45:5;79:25;80:4,6;

 101:16;118:20 

numerous (1)

 225:10 

nutrient (3)

 153:24;156:19;

 187:1 

nutrients (1)

 195:2 

observations (2)

 43:19;216:20 

obtain (4)

 38:7;108:6;118:9,

 11 

obtained (1)

 139:4 

obtaining (1)

 19:20 

obviously (2)

 31:23;51:24 

occasion (1)

 24:11 

Occasionally (1)

 97:20 

occur (5)

 55:2,10;81:21;

 93:16;186:18 

occurred (1)

 87:23 

occurring (1)

 90:2 

occurs (2)

 112:20;203:14 

Oceanic (1)

 212:7 

o'clock (1)

 236:6 

October (3)

 210:15,19;236:10 

ocular (1)

 193:8 

OFA (4)

 24:24;64:15;88:5;

 110:5 

off (24)

 18:2;21:19;24:12;

 43:1,8,11,17;44:23;

 62:22;79:6;115:24;

 128:14;133:22;138:3;

 165:11,16;167:9;

 173:12;174:12;

 176:13;193:2;196:14;

 203:20;210:11 

offer (3)

 31:12;106:14;

 117:23 

offered (4)

 11:21;14:16;17:16;

 31:14 

offering (4)

 9:25;32:14;39:20,

 22 

office (9)

 0:20;33:12,19;

 34:12,15;35:10;40:3;

 93:21;94:4 

offices (8)

 6:15;11:24;21:1,2;

 48:12,13,18;49:13 

official (2)

 73:8;91:17 

officially (1) 

O 

Min-U-Script® Burke Court Reporting & Transcription (23) natural - officially 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 4 

October 25, 2023 

73:20 104:19;105:7,7,7; 193:15;199:11; 223:11 187:12;194:10;

off-product (1) 108:7,14;112:3; 206:2;207:17 orchard (2) 202:16;203:13;204:1;

 130:8 113:8,23;115:4,9,24; open (15) 197:5;204:8 207:22;211:17;

off-season (1) 116:23;117:3,4; 29:4;30:11;35:6; order (4) 215:21;220:24;

 226:17 120:13;121:2,3; 49:14;51:22;81:6; 7:22;93:16;120:10; 223:17;225:13;227:7;

offset (1) 122:22;126:17,23; 90:24;94:6;132:11; 195:5 230:14;232:11;

 171:9 128:4,13;129:19; 133:11;211:24; ordering (1) 233:16,18 

offsets (3) 130:4,19;131:11,12, 215:10,13;216:14,24 139:5 organics (4)

 171:24,25;172:1 13,13,21;132:4;138:9, openness (2) orders (1) 34:20;60:20;74:13;

OFPA (6) 12,13;139:1,2; 56:19;64:24 68:12 103:10 

118:3;153:13; 140:17;143:24,25; operating (3) Oregan (1) organism (1)

 170:9;175:2;230:14, 144:7;152:20;154:7, 8:11;25:25;124:22 114:4 143:2 

15 16,17;155:7,13,17,18; operation (4) Oregon (2) organisms (1)

often (7) 158:13,17,25;159:1,8; 32:16;40:17;81:10; 107:7;193:12 208:6 

111:21;112:7,20; 160:14;163:6,19; 178:21 OREI (2) organization (4)

 181:20;197:4;202:8; 166:5,10,14,15;168:1; operational (2) 181:3;182:14 73:6;76:19;79:20;

 233:3 169:11,21;174:21,21; 59:10;66:2 Organic (230) 96:1 

oftentimes (2) 175:9;176:2,13; operations (15) 6:19,20,21;7:25; organizations (2)

 53:22;175:12 177:24;178:13; 40:10,11,13,23; 10:7,9,11,13;12:7,9, 30:23;84:23 

OID (2) 179:12;180:4;182:14; 41:5,6;43:7;59:11; 12;13:13;14:1,1,4,14; organized (2)

 80:11,12 185:8;187:10,11,12, 87:8,24;92:12;114:5; 16:14,19,21;17:14; 66:19,22 

oil (1) 22;194:2;195:3,3; 119:23;157:7;161:3 18:17,25;19:1,8; original (4)

 211:1 198:4,4;201:23; operator (1) 20:24;24:2,9,13,17, 24:24;105:19;

ok (2) 202:2,3,4,23;203:5, 120:2 21,21,24,25;25:4,6,8, 193:20;202:18 

124:24;145:21 22,22;207:19;208:10, opinion (1) 10,12;26:5,8;27:5,9, originally (3)

Oklahoma (13) 13,21;210:6;212:3,4; 189:13 12,12,13;29:10;30:6, 93:24;149:3;218:3 

0:21,21,22,25;6:2,4, 214:5,13,18;215:8; opinions (2) 17,19,21,23;31:5,9, origins (1)

 6,8,9;13:21,21;37:6; 217:7,14;218:1,9; 214:3,7 11,17,24,25;32:1,11, 87:21 

56:12 220:2;221:6,7;225:8; opportunities (6) 12,18,20;34:18; OSP (4)

old (1) 226:10;230:7;233:10, 21:18;41:7;64:9; 36:14;37:3,11;40:13; 78:9;117:13;217:9;

 176:1 10,16,16,20,20,24; 69:16;73:9;215:24 41:18;42:23,24;43:2, 233:15 

OLPS (7) 234:14 opportunity (18) 13,16;44:1,6,8,9,12, OSPs (2)

 24:10,18;25:1; one- (1) 13:10;18:22;32:9; 14,25;46:12;47:9; 148:10;234:3 

26:11,13;99:6;114:24 31:10 42:16;85:11;89:20; 48:23;49:3;50:3,11; others (3)

OMB (2) OneCert (1) 92:23;94:6,10; 51:18;52:2,19;53:20; 57:12;113:24;

 93:22;95:5 107:19 100:25;111:10; 54:1,6;57:20;59:9,11; 195:25 

OMRI (2) one-off (1) 126:22;149:24; 62:24;64:10,20;66:1; otherwise (2)

 218:8,13 90:18 168:23;196:10; 69:13,14,15,18,18,24; 59:23;172:22 

once (6) one-on- (1) 215:20,21;216:3 70:1,5,7,15,18,20,22; ought (1)

 36:25;47:12;73:19; 75:23 oppose (1) 71:1,2,5,6,7;72:5,18; 8:9 

106:5;226:5,19 ones (2) 148:6 73:10,12,14,20,21; ourselves (3)

one (211) 57:20;161:6 opposed (5) 74:3,7;75:11;77:1,14; 98:12;173:12;

 7:11,12,19;9:9; one-to-one (1) 55:20;77:19;90:3; 78:1,3,20,25;79:12; 178:10 

11:2,6,14;14:13,17, 133:6 155:15;187:11 80:10,11,18,22;81:3, out (114)

 19;15:4,5,14;16:4,25; on-farm (1) opposite (1) 4,9,10,17,24;82:10, 7:17;9:11;13:3;

 17:1,2;18:4,8,10; 220:6 45:9 17,22,22;83:12,16; 14:12,23;15:8;16:17;

 19:10,11,23;20:3,22, onions (1) opposition (5) 84:3,24;85:6,25;87:1, 17:13;18:7;24:9;

 23;26:9;29:14,16; 161:9 126:4;147:19; 3,22,24;88:13,20; 26:13;28:8;29:21;

 30:9;31:23;32:3,18; online (2) 148:3;158:4;225:8 89:7,20,23;90:6,8,15; 30:1,23;31:25;32:1,

 34:2;35:20;36:7; 23:7;71:11 Option (11) 95:9;99:7,9,9,13; 19;33:9;34:5,19;

 37:19;39:20;40:1,16, only (20) 13:8,8;42:20,22,25; 107:16;110:19,20; 37:14,24;39:9;40:25;

 18,19;41:16,16;42:3, 15:14,16;18:10; 43:14;85:6;111:23; 112:24;123:3;125:10; 45:12,14;48:2;49:6,7,

 3,7;43:1;47:4,25; 51:1;103:9;117:4; 131:18;157:7;159:11 126:12;129:2;135:11; 14,23;50:4;53:23;

 49:10;51:22;52:23; 133:1;156:11;166:1, optional (1) 136:21;143:19;146:3; 58:15;64:12;66:21,

 53:9,20;54:7,10;59:4, 5;168:10;169:9; 32:14 147:2,2;149:5;154:1, 23,25;67:25;69:2;

 13;64:12,23;65:3,7, 174:7;176:13;187:11; options (5) 5,11,18;155:10,24; 70:11;71:15,22,25;

 15;67:7;72:4;73:5; 203:22;210:22;216:6; 10:1;14:12;64:22; 156:1,4;157:3; 72:4,17;73:4;74:6,12,

 75:22,24;76:1,4,7,15; 221:17;227:22 65:6;102:1 160:17;163:4;167:14, 13,15;75:7;76:16,21;

 77:16;78:11;80:9; onramp (1) OPW's (1) 15;168:11,21;169:15, 78:9,13;79:13,20;

 81:15;83:25;84:17, 6:19 227:7 17;174:13;176:24; 80:1,14;84:19;89:15,

 20;85:2,12;90:3,4; onsite (1) oral (7) 177:14,23,25,25; 25;93:9;99:13;

 95:19;98:17,23; 89:9 66:3;131:11,15; 181:4,5;182:8; 101:23;103:4;104:1,

 99:22,24;101:17; onto (4) 138:22,22;186:16; 185:23;186:10; 8,18;114:12;115:6; 

Min-U-Script® Burke Court Reporting & Transcription (24) off-product - out 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 4 

October 25, 2023 

116:9,14;122:16;

 125:18;126:17,23;

 130:9,14;134:3;

 135:11;143:24;

 149:14;150:11;

 155:20,21,22;159:4;

 160:13;162:16;171:4,

 16;174:10,14;177:21;

 179:6,14;180:9;

 181:12,17;186:14;

 187:14;197:10;

 203:15;208:21;214:3;

 218:14;221:6;224:22;

 225:9;226:22;227:23 

outcome (1)

 66:12 

outcomes (1)

 113:19 

outdoor (3)

 25:13,17,18 

outgrown (1)

 224:25 

overlay (1)

 57:17 

Oversight (7)

 62:23;86:9,14;87:7;

 88:16;94:3;99:23 

overwhelmed (1)

 71:13 

own (10)

 9:21;16:9,9,10;

 17:16;67:23;78:12;

 101:10;167:12;197:5 

oxidate (2)

 133:1,2 

oxides (1)

 194:22 

oxygen (2)

 143:5,7 

79:19;107:12;113:3;

 123:14;147:23;

 149:25;161:18;

 164:19;194:6;197:15;

 211:21;213:11;221:8 

participate (2)

 13:15;27:4 

participated (1)

 31:22 

participates (1)

 29:17 

participating (4)

 40:11;41:8;64:18;

 70:18 

participation (5)

 16:13;40:12;72:5;

 124:19;125:2 

particular (15)

 34:14;36:16;48:24;

 66:4;115:11;126:5;

 129:12,12;149:25;

 27:24 

Pause (7)

 22:9,17,23;23:5;

 86:23;98:20;213:25 

pay (12)

 10:22;33:10;61:9;

 82:12,25;85:5,5;

 102:5,8,14,16;105:11 

paying (3)

 44:5,16;85:4 

pays (1)

 78:2 

PCO (1)

 92:25 

PDS (4)

 124:4,13;127:12,13 

PDs' (1)

 127:5 

penalize (1)

 167:15 

pendulum (1)

 13:25;32:4,10 

perfect (5)

 29:13;47:20;58:21;

 91:21;105:23 

performance (2)

 17:25;143:17 

performed (1)

 132:17 

perhaps (6)

 57:8,9;65:16;72:18;

 111:5;148:1 

Period (2)

 15:17;175:21 

periodic (1)

 87:22 

permit (1)

 168:22 

peroxyhydrate (3)

 142:2,9;144:18 

person (4)

 0:10,12;24:3;111:2 

P 

103:16 package (1) 150:1;204:8;214:22; 72:11 personally (3)

outlet (1) 197:15 233:24;234:7,11 penetrated (1) 0:14;159:18;174:11 

59:25 packaged (1) particularly (5) 203:10 person's (2)

outline (1) 158:22 35:1;72:7;89:17; people (55) 126:17,23 

32:20 packaging (7) 90:13;193:17 10:3,18;19:8;20:8, perspective (1)

outlines (2) 155:21,22;156:5, partly (2) 11;21:5,5;31:7;34:19; 183:6 

69:23;148:16 11,14;166:7;178:6 39:17;79:17 35:5;36:25;37:23; pest (4)

outlook (1) paid (4) partner (2) 39:5;42:11;47:6; 175:4,12;194:11;

 62:3 18:7;31:25;32:1; 6:14;30:24 48:13;49:3,8,10; 224:2 

outreach (4) 82:15 partners (4) 50:19,22;54:21,21,22; pesticide (5)

 30:12;57:23;76:18; painful (1) 30:15;49:5;75:20; 63:8,25,25;76:5,9; 29:23;53:22;54:9;

 181:23 227:3 84:20 77:16;81:6;83:8;85:5, 73:15;144:5 

outside (3) pandemic (2) partnership (2) 9,13;94:5,6;95:22; pesticides (2)

 125:16;126:19; 31:11;50:25 51:20;69:18 102:10;143:6,13,16; 53:25;88:18 

160:11 Pandora's (1) Partnerships (4) 156:12;160:10; pests (1)

over (59) 149:2 30:13;49:6,13;78:1 161:17;164:18; 142:16 

0:6;7:1;9:2,3; paper (9) parts (4) 167:10,13;170:22; petition (1)

 10:13;11:9;15:1;22:3; 146:4,15;148:21, 22:19;26:13;89:11; 171:17;178:23; 133:21 

24:15;26:15;28:9; 22,24;149:6,13; 217:23 184:15;186:7;202:8; petitioned (5)

 32:1;36:17;39:14; 150:17;151:25 pass (4) 216:9 128:18,19,19;

 62:22;63:18;74:4; paperwork (2) 21:19;27:18;32:25; peppers (1) 129:6,6 

79:7,9;86:13;87:2; 11:22;17:9 126:21 154:2 Petitioner (7)

 88:16;91:6,10;99:19; paragraph (1) passed (2) per (4) 129:16,19;130:21,

 107:4,5;108:12; 220:7 100:18;212:15 31:17;87:24;116:9; 24;131:4,24;132:13 

112:17;123:17;124:4; parcel (15) passes (3) 220:7 PETREY (85)

 127:15,18;129:15; 100:9;105:11,15, 122:8;135:7;214:25 perceived (1) 43:24;44:4,12,22;

 130:14;133:16;142:6; 17;111:17;112:2,5,8; passion (2) 233:1 45:3,8,10,13,16,19;

 149:7;157:6;159:8; 115:18;117:4,7; 73:3;177:18 percent (47) 46:2,6,15,18,24;

 160:19;166:19; 118:20;119:20,21,21 passive (2) 8:7,10;10:21,23; 121:8;132:12;135:4,

 167:11,12;177:12,20; parcels (5) 97:20,21 12:22,23,24,25,25; 12;136:9;137:16;

 185:16;187:11;196:3; 103:23;112:1; past (7) 13:11,12;14:1;15:17, 138:15;140:9,22;

 197:5,19,21;198:7; 117:8;119:23;120:1 73:14,18;127:23; 21,21,22,22,22;16:3; 141:14;145:9;151:7;

 203:25;211:14;217:1, pardon (1) 162:23;186:7;193:23; 17:2;31:14,15,16,20; 152:14;153:12;159:7;

 8;218:18;234:1 56:25 223:15 42:13,13,17,20,21,22, 160:24;161:1,4;

overall (4) parenthetical (2) Pasture (1) 22;43:1;82:21;87:24; 163:12,16,19,24;

 41:6;186:18; 109:15;118:19 13:24 158:3,4;167:19,21,23; 164:2,6,12;165:19;

 187:18;217:16 parliamentarian (2) path (4) 169:18;176:6;177:13, 168:6,8,10,20;170:8,

overcome (2) 119:7;120:6 81:19;104:21; 14,14;189:22;218:13; 13,16;172:14;173:18;

 75:4,7 part (23) 110:9;212:19 220:7 175:1,6;178:14,22,25;

overcoming (1) 16:22;17:11;25:5; pathogens (1) percentage (3) 179:3,14,17;184:13;

 72:10 26:9,18;38:9;47:13; 189:25 173:9,11;174:13 187:25;188:10,12,16;

Overexposure (1) 69:12;70:16;76:19; patience (1) perennial (3) 189:4,7,14;190:2,18; 

Min-U-Script® Burke Court Reporting & Transcription (25) outcome - PETREY 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 4 

October 25, 2023 

191:23;198:10; pineapple (11) 13;175:10;176:6; 31:19,23;36:15,16,18; 129:9,13;130:2,9,10,

 200:12;201:16; 223:6,9,10,11; 177:8,12,20;178:4,6, 39:19;40:9,14,23; 22,25;132:16,17;

 205:19;207:3;209:18; 224:7,22;225:9,14; 8;179:12,18;180:17, 41:1,2,5,12,15,17,18; 134:1,6;135:9;

 219:15;222:13;223:7; 226:2;227:9,15 22;182:1,1,4,5,11; 42:4,11,15,18,24; 136:19;137:24;

 225:24;226:14; pineapples (4) 183:6;184:3 43:12;48:16,23; 185:13,15,18,22;

 227:11,18;228:19; 223:23;225:12; plasticized (2) 51:12;124:15 186:6,15;187:19;

 231:4;234:24 226:17;227:3 148:24;149:13 policy (27) 189:5,17;190:8,9;

petroleum (1) ping (1) plastics (4) 0:17,24;6:1;9:4,17; 191:17;232:11,15,15,

 224:18 104:23 147:11;172:4; 10:1,6;14:3,7,8,9,18; 16;233:2,3;234:4,15 

petroleum-based (2) pipeline (1) 177:4,19 15:15;17:15,22; potatoes (1)

 147:11;153:10 73:13 plate (2) 31:24;39:21;41:16; 228:1 

PFOS (7) pit (2) 81:23;127:5 42:5,8,12,19;48:7; potential (10)

 155:11,19,25; 81:7;197:9 playing (4) 60:21;95:11;113:8,13 70:12;71:16;132:2;

 159:9;166:6;175:20; place (15) 25:9,23;27:11; political (2) 175:9,22;176:22;

 217:24 10:20;44:24;46:11; 165:16 99:6;177:10 193:7;208:14;217:24;

pH (9) 64:11,23;65:7;80:20; plead (1) pollution (1) 218:10 

129:24;197:7,19; 87:21;103:17;155:19; 56:23 138:21 potentially (5)

 208:3,5,7;210:7,9; 156:25;166:1;175:16; please (32) polysulfide (2) 87:11;131:22;

 221:17 196:24;203:13 62:12;64:4;72:25; 201:25;202:8 148:11;196:21;

phase (2) places (6) 74:18;77:4;86:14; polyvinyl (1) 221:15 

155:21,22 63:13;76:6;142:18, 96:3;115:2,17;117:5, 153:10 Poultry (4)

phased (1) 19;148:25;227:16 19;121:7;144:1,16, poor (2) 24:10;25:12,15,19 

155:20 Plains (2) 21;148:19;158:9; 188:24;220:22 pounds (2)

philosophical (1) 55:15;105:9 166:25;168:7;170:2; poorer (2) 224:16,17 

126:11 plan (7) 172:13;175:7,24; 188:25;189:1 powdery (4)

philosophy (1) 6:20,21;13:9;16:21; 181:18;183:3;187:24; poor-quality (1) 131:24;132:2;

 62:3 46:12;73:6;211:12 190:13;196:6;197:2; 226:16 194:15;196:16 

phone (1) planned (1) 221:2;225:18;228:5 popular (1) POWELL-PALM (496)

 80:15 91:5 pleased (1) 12:20 0:3;22:12;27:2;

phosphoric (3) planning (1) 0:9 population (2) 62:11;63:23;64:4;

 210:8;218:14,16 50:14 pleasure (3) 177:13;203:25 65:12;66:17;67:5;

phosphorous (2) plans (6) 23:15,20,22 populations (1) 68:4,11,16;69:7;72:2,

 218:10,12 12:19;13:4;14:6; pledge (2) 203:4 24;74:1;75:2;76:12;

phrase (1) 77:1;90:9;187:12 171:7,8 portfolio (1) 77:4,24;79:6;81:1,12;

 100:16 plant (17) Plot (1) 107:1 82:4,7;83:4,24;84:16;

physical (3) 20:24;21:3;48:19; 116:23 portion (1) 85:14,18;86:3,11,17,

 25:20;111:21; 136:21;162:2;185:19; pm (5) 210:15 21;93:2,4,6;96:3;

 207:24 189:23;193:1,18,18; 98:17,17,25;99:2; posed (1) 98:3,6,11,15,21;99:3,

Phytophthora (1) 194:14;199:13; 236:9 55:25 17;100:22;102:5,7,

 162:9 200:17;203:10;206:7; point (33) position (2) 15;103:6,9;106:14,

pick (6) 207:23;223:10 14:23;56:2;58:23; 85:8;177:6 17;108:4,22;109:8,12,

 28:11;29:7;66:14; Planting (6) 60:9;65:3;67:24,25; positioned (1) 18,21;110:3;111:8;

 98:22;178:11,11 20:23;21:5,6,8; 70:2;75:16;81:22; 50:8 112:12,15;113:14,20;

picking (1) 34:14;46:19 82:6,8;96:24,25; positive (5) 114:23;115:2,13,16;

 85:2 plants (10) 104:18,25;106:2; 89:5,16,24;90:14; 116:21;117:5,13,18,

picture (4) 154:3;157:9; 107:3;108:2;149:22; 182:9 24;118:7,13,17,25;

 50:6;71:10;104:19; 185:24;187:2;203:19; 160:3;174:12;176:19; possibility (1) 119:2,6,9,11,16;

 227:8 204:1;224:4;232:15, 177:3,16;179:14; 149:9 120:9,12,15,19,22;

pictures (1) 16;233:2 197:8,17;215:16; possible (4) 121:3,9,11,13,15,17,

 86:14 plastic (84) 221:6;226:25;227:11; 35:19;86:18;88:17; 19,21,23,25;122:2,4,

piece (5) 153:9,16,18,21,25; 232:18 128:7 6,9;123:4,8,13,18;

 26:7;76:24;82:21; 154:2,9,10,15,25; pointed (1) possibly (2) 124:3,6,8,10;125:13;

 109:10;213:24 155:6,8,12,15,20,21, 174:14 107:13;161:17 126:3,6,14,18,25;

piecemeal (1) 22;156:7,10,13;157:1, pointing (2) post (2) 127:2,12;133:17,20,

 90:3 6,8,8,20;158:22,24; 171:3;208:20 93:9;155:23 24;134:8,10,12,14,16,

pieces (3) 159:2,10;160:23; points (7) posted (1) 18,20,22,24;135:1,3,

 26:12;51:7;171:4 161:7,8,10,11,17,18, 8:15;39:16;61:4; 93:25 5,8,15,17,19,21,23,25;

pillars (1) 20;163:8,8;164:1,10, 76:15;85:3;87:19; post-harvest (3) 136:2,4,6,8,10,12,15,

 70:3 13,18,21;165:6,9,13, 105:25 227:21,25;228:2 18,24;137:1,3,5,7,9,

pilot (1) 25;166:1,2,5,9,15; policies (37) posting (2) 11,13,15,17,19,21,24;

 17:20 167:21;168:2,18,24; 9:11;10:7;13:3,15; 22:5,6 139:6,9,16,19,21,23,

pilots (1) 170:5;171:7,12,22; 14:17;15:7;16:20; potassium (37) 25;140:2,4,6,8,10,12,

 9:12 172:20;173:5;174:12, 17:21;18:1,25;19:3; 128:15,17,24; 14,16,23;141:1,3,5,7, 

Min-U-Script® Burke Court Reporting & Transcription (26) petroleum - POWELL-PALM 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 4 

October 25, 2023 

9,11,13,15,17,19,21, 28:25 presents (1) prioritize (1) 42:17;47:16,18;48:3;

 23;142:1,5;143:22; PowerPoint (1) 187:19 212:13 49:14;53:13;61:8;

 144:9,14,21,23,25; 86:12 preservative (1) prioritized (2) 64:13;72:17;73:16;

 145:2,4,6,8,10,12,14, PowerPoints (2) 129:14 128:6,9 80:23;81:4;105:3;

 16,18,20;146:12; 86:14;179:11 press (4) priority (1) 118:16;194:10,13 

148:18;150:2,4,7,20, PPEs (1) 26:25;27:3;28:9; 176:11 producers (75)

 23,25;151:2,4,6,8,10, 193:9 99:5 private (3) 7:25;10:20,22,24;

 12,14,16,18,20;152:4, PPM (2) pressure (1) 9:7;181:23,23 11:2,7,8;13:3;14:2;

 7,9,11,13,15,17,19,21, 125:5,18 183:8 probably (22) 15:1,8;18:15,22;19:5;

 23,25;153:2,4,7; Practically (2) pre-TOPP (1) 16:7;22:21;29:5; 25:25;26:2;30:18,24,

 158:7,18;159:14; 155:6;208:1 80:12 31:6;36:19;38:7,10; 25;31:3,3,22,23;

 160:4;165:1,20; practice (20) pretty (16) 41:15;43:11;44:7,17; 32:14;37:20;41:12,

 166:17,20,25;167:2; 14:2;33:4,5,6,7,13, 11:16;41:24;59:7; 52:1;56:1;58:24;61:1; 19;42:5;49:11;53:3,

 168:4,7,9;169:8; 15,23;34:4,7,9;50:22; 96:10;108:25;147:15; 101:13;103:24; 10,11,21;56:9;58:18;

 170:1;172:2,13; 59:9;66:1;70:8;97:11, 162:4;163:2;182:6; 113:21;120:25; 59:12;60:12,15,24;

 173:6,14,25;175:4,7, 17;118:6;165:3; 187:15;196:18; 163:11;169:21; 64:10,15,17;65:1,4,

 24;176:8,14,17; 225:13 197:13;202:11,20; 202:24 14,20;66:3,8,20,25;

 177:1;178:16,24; practiced (1) 203:4;213:6 problem (26) 67:12,13,14,25;70:17;

 179:2,13,16,25; 230:1 prevalent (1) 52:3,9;54:16,17; 71:6;72:10;73:8,11,

 180:20;181:1;182:9, practices (26) 166:10 56:7,7,15;83:23;91:3; 19,21;75:22;76:6,21;

 19,23;183:3,10,12,14, 25:20;32:13;33:3, prevent (2) 115:7,9;150:9; 77:3;80:11,22;82:23,

 19;184:5,8,10,12,14, 10,18,21,25;34:5; 175:13;181:22 158:16;159:19,19,20, 25;85:9;129:2;

 17,20,22,24;185:1,3, 50:16,21;51:4,11; preventative (1) 20,21;160:15;161:22; 177:23;217:15;

 9,12;187:24;190:3,12, 77:1;92:9,13;97:19, 25:19 167:7,9;169:22; 223:12;230:3 

15,17,19,21,23,25; 23;116:24;130:17,18; preventing (1) 173:16;177:19;178:2 producers' (1)

 191:2,4,6,8,10,12,19, 153:14;156:9;157:4, 228:1 problematic (1) 67:23 

22,24;192:1,3,5,7,9, 6;217:15;220:22 prevents (1) 211:11 producer's (1)

 11,13,15,17,19;196:5; precedence (1) 163:8 problems (1) 58:8 

197:1,23;198:8,11,13, 211:4 preview (2) 50:11 producing (4)

 15,17,19,21,23,25; precursor (1) 122:17;124:17 procedure (2) 25:12;112:16;

 199:2,4,6,8,14,16,18, 6:21 Previous (4) 47:12;48:7 115:23;116:12 

20,22,24;200:1,3,5,7, predominantly (3) 0:22;20:17;38:24; procedures (4) Product (34)

 9,11,13,19,22,24; 153:24;156:6;161:6 210:25 88:5;93:16;124:15; 0:16,19;48:15,16;

 201:1,3,5,7,9,11,13, preliminary (1) previously (5) 195:15 81:3;128:22;129:20;

 15,17,19;204:2,14,19, 31:21 15:14;19:24;129:6; proceed (2) 130:3;131:18;133:5;

 24;205:2,4,6,8,10,12, premium (16) 195:19;202:11 98:9;122:23 142:11,18;154:22,23;

 14,16,18,20,22,24; 10:13;12:9;14:5; PRH (1) process (31) 157:11;168:16,18;

 206:3,10,13,15,17,19, 15:22;31:13,14,18; 17:14 27:9;33:23,23;34:1, 169:6;173:13,21;

 21,23,25;207:2,4,6,9, 32:7;44:5,15;54:6; price (26) 7,7;37:15;39:6;46:7; 186:15,25;188:1,4;

 12,14;208:19,23; 73:7;81:3,10,20; 9:19;10:8,9;12:3,6, 48:3;71:3;75:25; 193:6;194:12;207:22;

 209:2,5,7,9,11,13,15, 82:10 9,10,12,12,13,14,22; 77:21;95:14;105:10; 208:9,17;217:5,17;

 17,19,21,23,25;210:2; premiums (4) 17:16;52:13,18; 110:6;112:20;123:14; 223:21;224:10;

 213:20,22;215:12; 10:22;20:20;54:1; 53:10,12,14;59:21; 127:23;128:3,5; 227:21 

216:16;218:20;219:1, 181:20 61:10,10;73:7,7; 149:10;158:15; production (41)

 4,6,8,10,12,14,16,18, pre-OSP (1) 79:14;81:10;180:8 180:22,24,25;214:15; 10:11,12;11:9;12:1;

 20,22,24;220:1;221:1, 58:11 prices (4) 215:17,23,23;221:16 16:10;17:13;25:6,9;

 10,13,21;222:1,4,6,8, prescriptive (2) 16:17;52:18;81:6; process-based (3) 27:12;51:10;59:10;

 10,12,14,16,18,20,22, 104:24;108:8 179:4 88:13;89:7;90:8 67:23;68:1;77:1;80:4,

 24;223:1;225:17; present (2) pricing (4) processes (1) 18,19;119:23;135:11;

 226:8,24;227:12; 64:22;192:23 10:12;16:10;53:4; 142:23 136:21;142:10,22;

 228:4,9,12,14,16,18, presentation (10) 71:20 produce (9) 143:20;146:3;147:2;

 20,22,24;229:1,3,5,7, 12:15;28:25;35:9; primarily (1) 31:22;108:10; 153:14;154:11;

 9;230:16,21,24;231:1, 38:18;57:14;58:9; 218:16 116:8;130:10;186:8, 207:23;220:25;221:5;

 3,5,7,9,11,13,15,17, 108:24;111:11,20; primary (5) 21;187:13;226:11; 223:10,17;224:5,22;

 19,22,25;232:4; 179:10 38:25;74:22;220:9; 227:7 225:3,12;229:14;

 234:13,18,21,23,25; presentations (2) 223:8;232:22 produced (1) 230:1,2,14;232:11 

235:2,4,6,8,10,12,14, 179:10;180:3 principles (1) 108:13 products (29)

 16,18;236:2,4 presentation's (1) 125:1 producer (39) 10:14;25:12;87:9;

Powell-Paul (1) 91:3 prior (1) 9:5,15,19,24;10:5; 88:21;112:16;129:2;

 99:25 presented (2) 147:22 11:3,6,14;13:5,10,19; 130:2,3,14;143:5,7;

power (1) 105:1;220:13 priorities (5) 15:11;17:15;19:4,13; 147:11;154:10;

 177:10 presenting (1) 17:2;181:12,13; 20:17;29:21;33:8,11, 158:22;210:5,7,21,22;

powerful (1) 142:3 213:15,17 24;37:2;39:20;41:16; 211:9;217:6,7,8,16, 

Min-U-Script® Burke Court Reporting & Transcription (27) Powell-Paul - products 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 4 

October 25, 2023 

25;218:11,12,14,24;

 224:1 

professionals (1)

 83:16 

profitability (1)

 80:2 

profitable (2)

 81:4,17 

program (44)

 7:24;8:2;10:18,20;

 13:24;14:4;16:1,18;

 17:13,25;18:9,12;

 24:13,17;27:10;29:2,

 18;30:2,12,22,24;

 31:10;40:24;50:19,

 25;51:2;54:4;57:11;

 64:19;69:19;70:6;

 72:12;76:4;77:17,25;

 124:15;128:13,15 

proposals (3)

 125:3;181:13,14 

propose (3)

 88:22;90:12;185:10 

proposed (3)

 155:18;172:19;

 210:19 

proposes (1)

 88:7 

proposing (6)

 90:14;109:3,24;

 113:19;220:25;

 230:15 

pros (1)

 26:22 

protection (6)

 12:20;13:9;153:24;

 11:11;67:17 

public (33)

 26:14;69:1;70:21;

 71:9,12;73:18;82:25;

 85:23;89:6;91:11;

 93:25;94:1,6,10;

 95:11,12;97:5;

 105:10;108:12;110:1;

 111:12;122:18;126:2,

 4;131:9;143:11;

 154:4;193:4;208:8;

 212:16,19;214:14;

 225:4 

publicly (1)

 75:4 

published (2)

 19:25;20:1 

Puerto (1)

 149:3,14;165:17;

 174:10;181:11;

 186:11;203:16;214:8;

 226:25 

puts (1)

 107:8 

putting (3)

 49:6;77:19;180:9 

PVC (3)

 154:13;170:10;

 175:17 

PVC-based (1)

 170:6 

Pythium (1)

 162:9 

9:11;13:16;40:25;

 46:20;106:18;162:13;

 179:8;196:9;202:10;

 212:16;214:20;

 224:19 

quoted (1)

 99:7 

quotes (1)

 139:1 

R 

radiation (1)

 87:10 

rain (2)

 194:21;217:12 

Rainfall (1)

 13:23 

Q 

82:18;84:9;87:1; 196:21;203:19; 102:14 Q&A (5) rainwater (2)

 90:20;91:24;125:11; 212:12 pull (2) 22:14;28:11,13; 54:1;55:14 

162:15;197:7;216:7 protections (2) 43:20;131:10 62:18;63:5 raise (2)

programs (12) 195:13;196:23 pulled (4) Quality (29) 26:10;208:3 

9:6,9,10;13:23; protective (1) 30:16;48:1;57:14; 43:14;54:3,6,24; raised (5)

 23:14;56:3;70:8; 203:16 156:8 55:1;59:6,14,16,20, 7:13;52:6;75:18;

 88:19;149:6;194:11; protocol (1) pulling (3) 21;60:2,6,17,19,21; 186:7;196:8 

217:15,16 117:25 32:5;108:9;109:23 61:5,6,8,9,12,13,15; raises (1)

progress (2) protocols (2) purchase (1) 71:14;186:8,21; 147:12 

66:15;157:25 88:10;196:20 42:16 188:24;190:1;226:1,4 raising (2)

prohibit (1) proud (1) purchased (1) quantifiable (1) 6:11;58:17 

157:15 27:14 108:13 89:2 rally (1)

prohibited (11) prove (1) purchasing (1) quantities (3) 60:13 

87:10;88:10,16,21; 234:2 10:24 138:20;187:2;208:3 Ralstonia (1)

 89:13;90:13;153:14, proverbially (1) purely (1) quantity (1) 162:10 

14,16;155:19;232:10 178:9 102:2 71:13 ranch (1)

prohibition (2) provide (21) purgatory (2) QUARCOO (35) 6:10 

170:6;232:24 6:19;19:13;20:10; 60:4,17 78:19;83:5;85:15; Rancher (1)

project (1) 26:18;33:13,16;37:9; purity (1) 122:3;134:25;136:5; 6:5 

22:2 46:10;50:18;72:18; 220:7 137:12;140:5;141:10; Ranchers (4)

projects (1) 73:6;75:5;78:5;84:12; purpose (2) 142:4,7,13;145:5; 0:24,25;17:1;25:11 

181:14 109:25;118:2;156:18; 223:18;225:20 151:3;152:10;172:3; range (5)

prolific (1) 204:11;211:23; purposes (4) 173:8,15;180:11,21; 102:21;103:18;

 182:5 213:18;216:13 67:10;106:5; 184:9;190:14;192:18; 105:24;194:14;208:7 

promise (1) provided (10) 107:23;202:14 199:5;200:8;201:12; ranged (1)

 41:20 14:4;30:7;37:19; purse (3) 205:15;206:24; 71:9 

promote (1) 47:19;72:15;87:23; 171:16,18,22 207:21;209:14; Rangeland (1)

 157:6 112:25;129:16; pursued (1) 219:11;222:9;228:15; 13:24 

promoting (1) 153:18;195:5 7:12 230:25;234:20 ranked (1)

 83:22 Providence (1) push (6) question-asking (1) 213:14 

promotional (1) 23:22 7:4;66:10;89:15; 78:5 ranking (1)

 188:8 provider (1) 131:17;160:10; quick (11) 208:9 

propane (3) 55:7 181:16 62:6;84:7;89:6; rapport (1)

 163:1;164:9,9 providers (1) pushes (1) 121:6;122:23;138:12; 72:22 

proper (1) 8:25 174:16 142:6;174:22;197:24; rare (1)

 193:9 provides (6) put (39) 211:14;227:13 112:21 

properly (1) 39:25;64:13;94:25; 7:18;12:10,14,17; QuickBooks (1) raspberries (1)

 195:15 95:1;99:10;204:7 16:10;18:16;30:21; 106:5 171:21 

property (10) providing (7) 33:16;37:19;39:9; quicker (1) rate (2)

 102:5,8,11,14,16, 30:15;76:9;83:1; 45:22,25;47:12; 128:10 10:23;182:4 

23,24;104:11;105:11; 89:21;164:22;182:25; 49:23;74:5,5;79:13, quickly (7) rated (2)

 106:4 196:21 19;81:13;96:13; 38:3;69:21;95:15; 186:1,19 

proposal (8) provisions (2) 100:20;101:5,16; 128:7;168:6;182:13; rather (5)

 85:23;99:23; 14:24;16:8 110:15;122:15;127:5; 203:20 67:1;74:6;159:18,

 100:10;109:10;110:4; proxy (2) 133:4,6;144:4,13; quite (12) 19,21 

Min-U-Script® Burke Court Reporting & Transcription (28) professionals - rather 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 4 

October 25, 2023 

ratio (6) 71:8,10,12;73:2,3,4, recently (2) 154:24;155:3; 18;49:13;61:1;106:10 

18:10,12;43:25; 16;74:5,12;75:15; 181:2;211:7 176:22 regions (4)

 45:25;133:6,7 76:8,16;77:12;79:22; recess (3) red (1) 35:18;81:8;100:15;

ratios (7) 80:9,21;81:5,7,8; 62:10;98:25;185:11 196:12 161:8 

18:5,5,6,19;30:1,1; 82:11;84:21;85:4,20; recognize (4) reduce (7) Register (3)

 51:5 86:6;87:6,6,11,14,17; 108:1;122:25; 51:10;130:22; 97:1;155:23;169:15 

reach (4) 89:14;94:23;95:21; 183:15;227:7 164:3,17;170:22; registered (1)

 30:23;67:25;75:21; 96:4,16;97:11;98:1; recognized (2) 187:21;220:11 142:13 

214:5 99:12;101:10;103:11, 34:3;168:14 reduces (3) regs (1)

reached (1) 13;105:24;106:6,8; recognizing (1) 170:23;221:18; 110:23 

225:9 107:11;108:25;111:3; 147:6 226:1 regular (1)

reaching (1) 112:13;113:7,12,22; recommend (2) reducing (3) 131:5 

126:10 116:9;117:9,15,20; 72:1;164:12 71:20;157:25;183:6 regulated (1)

react (1) 122:14;123:16,20,24; recommendation (12) reduction (4) 94:11 

90:3 125:4,7,15;126:12; 72:18;108:5; 17:9;171:5,7,8 regulation (10)

reaction (1) 127:21;129:14;131:5, 110:18;111:2;118:22; refer (1) 9:13,13,15,17;

 56:5 6;132:1,6;143:23; 193:9;210:12;211:2, 97:23 90:22,25;96:14,20,21;

read (24) 148:12,15;149:7,24; 8;212:15;214:4,6 reference (9) 223:6 

7:8;18:2;37:13; 154:20;158:12; recommendations (6) 15:25;16:11,12; regulations (11)

 74:10;119:18;133:25; 161:21;162:2;165:3, 71:16;85:24; 88:17;89:23;104:25; 9:14;87:17,18,20;

 138:7,12;142:5,24; 7,12,17;166:1;168:6; 156:22;211:7,20; 105:2;107:3;110:24 88:23;89:1,20;90:15;

 144:16;150:8,11; 173:10;174:2;177:4, 214:8 referenced (2) 92:14,17;169:14 

156:1;185:15;189:12; 8,16;178:14;179:23; recommended (3) 159:9;229:24 regulator (1)

 190:4;196:9;201:24; 180:6;181:23;183:22; 94:4;210:20;218:3 referring (1) 223:10 

207:18;210:6;218:22; 186:13,24;187:3,6,7; recommends (2) 20:18 Regulatory (9)

 220:23;233:20 189:10,10,13,20; 119:19;193:24 refers (1) 23:14;74:16;88:4;

reading (6) 195:2,8,18,22;196:8, reconciliation (1) 96:14 90:23;131:5;213:15;

 74:11;103:4; 18,24;202:10,10,17, 107:23 refined (2) 215:11,25;231:25 

118:22;146:14; 25;203:6,14,23; reconvene (1) 18:23,24 reimbursement (1)

 166:18;170:4 204:18;211:23; 236:10 reflect (1) 82:18 

reads (1) 212:14,21;213:5,13, record (19) 124:21 reinventing (1)

 147:21 17;214:18;216:3; 77:2;78:14;101:1; reflected (1) 116:2 

ready (3) 227:2;235:23 106:20,21;118:10; 160:2 reiterate (5)

 29:5;158:6;204:19 realm (1) 119:20;123:6;138:8; reflecting (1) 39:15;70:2;80:8;

real (11) 181:2 144:4,13;150:12; 75:19 84:8;171:20 

79:25;80:4,4; reason (6) 166:21;174:3;180:13; reflective (2) related (5)

 112:14;121:5;122:23; 8:2;31:1;39:1; 185:16;201:24; 156:18;172:24 13:7;71:1;76:25;

 138:12;142:5;157:10; 180:1;211:9;213:11 207:19;210:6 refreshing (1) 93:17;212:8 

197:24;211:14 reasonable (3) recorded (2) 80:10 relates (1)

reality (1) 18:11;111:1;117:23 103:18;144:8 refuse (2) 129:14 

113:8 reasons (11) records (2) 176:23,23 relationship (6)

realize (4) 10:10;36:19;129:7; 29:10;117:1 Reg (1) 51:22;52:10;64:18;

 20:8;58:24;177:18; 130:8;194:21;195:23; recs (1) 96:24 71:4;78:6;125:11 

178:2 203:15;212:6;213:18; 195:15 regard (4) relationships (2)

realized (1) 216:14;226:18 recusals (23) 50:24;72:13; 71:21;181:6 

196:15 recall (1) 122:8;135:7; 129:13;208:15 relatively (4)

realizing (1) 227:5 136:14;137:23; regarded (3) 70:15;193:5;

 158:17 recalling (1) 140:19;141:25; 156:23;186:1,19 203:18;233:4 

Really (185) 144:11 145:22;151:22;153:6; regarding (5) release (4)

 0:4;6:16,23;7:7,8, receipts (1) 185:7;191:14;192:21; 51:5;58:7,25; 24:7;99:6;224:14,

 19,22,25;8:7;10:2; 107:2 199:10;200:15; 210:12;233:25 15 

11:5,18;13:21;15:7; receive (5) 201:21;206:1;207:16; regardless (2) released (2)

 16:5;17:23;18:8; 10:13;27:8;128:6; 210:4;220:3;223:3; 9:24;57:15 208:5;224:19 

19:21;21:7,13;23:24, 130:24;168:16 229:11;232:6;235:20 regards (2) releasing (1)

 25;24:5,10,11;25:5; received (14) recyclable (1) 129:12;145:25 143:12 

26:1,7,14,15,16; 26:16;28:4;29:3; 130:11 regimes (1) relevant (3)

 27:16,23;29:2;30:3, 32:13;34:25;69:19; recycle (1) 202:25 34:24;187:4;189:11 

22;32:20;34:5,8; 71:8,24;83:11; 159:2 region (1) reliable (1)

 37:16;40:2;42:10; 101:21;183:21; recycled (10) 35:19 89:2 

43:1,18;44:10;56:16; 213:23;217:1;225:10 146:4,5,15;148:21; regional (16) reliance (1)

 61:1;62:3,19;64:9; recent (3) 149:6;150:16,17; 0:20;11:24;21:1,2; 187:21 

65:1,22;66:4;68:5; 69:24;182:17; 151:25;152:1;155:1 33:12,19;34:12,14; reliant (1)

 69:17,20;70:11,19; 195:20 recycling (3) 35:10;40:3;48:12,12, 197:6 

Min-U-Script® Burke Court Reporting & Transcription (29) ratio - reliant 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 4 

October 25, 2023 

relied (1) 95:8 researchers (2) results (7) 46:18;48:14,18;51:6;

 148:15 replacement (1) 181:16;182:16 54:6;89:5,16,24; 52:22;53:14;55:21;

relist (1) 131:2 reserve (1) 90:1,14;113:5 56:14;59:15;60:10,

 148:5 replicate (1) 18:11 retailers (1) 25;62:11;64:7;68:11,

relisted (1) 65:17 reshare (1) 147:18 18;81:14,14;85:19,

 126:5 reply (1) 211:18 retardant (1) 20;86:3,25;91:10;

relisting (7) 225:8 resident (2) 55:12 92:14,19;93:6;94:2,

 138:23;147:20; report (19) 119:3;186:2 retention (6) 24;95:1,7;96:16;98:6,

 148:3,6;155:15; 7:17;8:16;10:16; residual (1) 71:6;73:17,19; 7;99:21;100:4,10;

 187:10;203:22 11:14,20;13:25; 128:21 153:24;156:20; 102:24;105:2;107:9;

rely (1) 14:15;15:11;16:5; Residue (7) 172:24 110:2;112:7;113:2;

 80:24 18:5,10,14,17;19:11, 86:9,25;87:13,22; reticence (1) 116:4;117:6,15;

remain (4) 19;30:25;34:2;101:1; 88:4,6;90:12 72:9 118:5,22;119:16,18;

 81:9;88:21;216:9; 182:3 resilient (1) retraining (1) 120:4,21;124:3,10;

 220:14 reported (2) 162:4 83:15 126:21;127:12,17;

remarkable (1) 130:5;187:16 resolution (2) returned (1) 129:9;133:17;135:8;

 203:5 reporting (6) 90:7,18 211:13 139:9,16;140:17;

remedied (1) 17:11;19:14,15; resoundingly (1) reusable (1) 143:22;144:14;150:4,

 197:20 46:3;48:4;211:22 114:14 171:15 15;153:8,12;156:3;

remember (5) reports (1) resource (3) revenue (10) 161:22;162:25;163:3,

 101:13;129:9; 106:6 34:13;38:8;39:25 12:20,21;14:14,16; 4,16;164:14;166:3;

 139:14;210:17;221:6 represent (3) resources (4) 16:13,13,18,20;17:12, 168:11,25;169:5;

reminded (1) 114:5;204:4;221:4 76:21;130:10; 14 170:14,23,24;171:1,8;

 127:3 representative (2) 157:12;180:2 review (27) 174:2,5,6,17;185:9,

reminder (2) 67:10;183:20 respiration (1) 47:22;126:22; 14;186:3;189:4;

 111:15;198:3 representing (1) 194:19 127:23;128:5,8; 190:4;195:4;196:3,5;

removal (3) 37:3 respiratory (3) 133:10;138:6,7; 197:20,24;198:8;

 154:13;220:25; request (6) 193:7,13;195:13 146:1;156:13;185:25; 202:7;204:15;206:10;

 230:15 11:25;32:13;39:5,8; respond (4) 186:11,16,23;188:13; 208:24;212:22;

remove (25) 126:17;196:8 89:24;130:21; 189:11;190:7;194:2, 214:16,24;215:5;

 72:21;75:9;139:10, requested (3) 176:9;186:12 4,4;216:24;220:4,15; 216:10,11,15,16;

 12;140:21;144:17; 19:17;129:15; responded (2) 228:6;229:21;232:7; 218:20,22;221:21;

 150:16;152:1;155:16; 186:11 129:16;131:4 235:21 223:7,22;225:22;

 170:6;184:3;190:9; requesting (2) responding (3) reviewed (13) 228:4;230:17,21;

 191:16;198:5;199:12; 17:18;49:8 51:17;89:5;90:14 128:6,9;129:17; 234:14;236:7,7 

200:16;204:20;206:7; requests (2) response (15) 130:7;131:5;193:11, righty (1)

 208:25;217:23; 32:3,18 23:10;68:10;89:16; 14;195:6;207:18; 0:7 

218:23;221:23;228:7; require (5) 98:5;103:8;111:1; 210:25;211:2;218:11; rigorous (1)

 230:18;234:15 19:14,16;50:17; 124:5,7;131:16; 220:15 27:13 

removed (5) 107:20;234:2 133:19;139:8;150:3; reviewing (1) rip (2)

 17:11;153:16,19; required (3) 170:20;183:13; 158:11 45:11;165:11 

171:12,14 10:21;18:11;203:24 187:13 reviews (3) ripened (2)

removes (2) requirement (4) responses (1) 47:13;48:1;186:4 223:20;224:3 

139:14;221:17 88:25;89:11; 71:18 revised (1) ripening (5)

removing (2) 110:22;174:23 responsibility (2) 19:12 223:14,19;224:19;

 170:5;174:24 requirements (7) 37:23;88:3 revisions (1) 227:15,17 

rename (1) 32:21;47:17;50:2; rest (1) 90:15 ripping (1)

 99:18 64:15;65:5;97:25; 137:25 revisiting (1) 167:9 

renew (1) 154:19 restricted (3) 89:19 Risk (12)

 204:10 requires (4) 73:15;208:12;218:3 rhetoric (1) 0:15;13:20;30:13;

renewable (1) 87:8;88:23;107:17; restricting (1) 102:2 32:16;62:1,25;97:12;

 130:10 197:18 175:18 Rica (1) 106:13;107:4,22;

reopen (1) rereading (1) restriction (8) 224:11 110:16;129:3 

216:12 109:16 154:13;170:10; Rick (1) risks (1)

repeat (1) research (19) 175:17;233:8,15,15, 127:3 186:19 

158:13 37:8;57:17;74:21; 19;234:8 Rico (1) RMA (26)

repeated (1) 81:2;131:3;156:24; restrictive (1) 102:14 0:20,22;6:22;7:23;

 197:4 157:1,4;172:7,11,16, 9:14 right (142) 20:14;21:1;22:5,7;

repercussions (1) 19;176:11;180:23; restricts (1) 7:5,23;10:10;12:11; 34:3,11;35:10;47:25;

 118:6 181:5,11,13;186:24; 142:9 22:1;23:1;28:17;29:5; 48:5,8;51:19;53:12,

replace (2) 223:15 result (4) 33:11;36:12;37:1; 23;63:11,12;64:9,16,

 143:9,14 researcher (1) 108:3;119:25; 38:23;40:24;43:8,11, 22;65:5,18,19;66:20 

replaced (1) 182:14 215:17;225:22 17,25;44:23;45:8,10; RME (3) 

Min-U-Script® Burke Court Reporting & Transcription (30) relied - RME 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 4 

October 25, 2023 

30:22;49:5,12 

road (3)

 97:13;171:17;172:8 

roads (1)

 104:21 

Roadshow (1)

 14:25 

Robert's (1)

 120:10 

robust (3)

 26:16;55:4;108:16 

role (6)

 20;97:24;120:10;

 215:12 

run (2)

 62:2;176:2 

running (1)

 62:14 

Rural (4)

 30:20;138:25;

 139:4;224:11 

148:14;180:12 

scenario (1)

 115:4 

scenarios (2)

 55:2,10 

schedule (1)

 98:21 

Scholarships (1)

 85:7 

school (1)

 64:5 

scientist (1)

 68:18;69:8,10;73:1;

 79:9;80:8;86:5,7,19,

 24;91:5,8,21;92:5;

 93:3;98:7,14;99:21;

 105:6;106:16;107:14;

 108:18;119:1,3,8,10;

 120:17,21,24;121:24;

 122:7,11;123:6,9,15;

 124:2;125:9;127:8,

 20;133:9,15;134:21;

 135:6;136:1,13,17;

 137:8,22;138:1;

 28:19 

selection (2)

 10:9;12:10 

selections (1)

 10:8 

semester (10)

 100:15;107:17;

 122:16;128:5;167:11;

 195:21;218:4,6,7,9 

semester's (1)

 122:15 

send (5)

S 

71:19,21;77:20; Sacramento (1) 182:25 139:10;140:1,18; 74:11;94:7;111:3;

 90:6;214:2;227:17 23:24 SCO (2) 141:6,24;142:8; 123:15;214:25 

roll (1) sacrifice (1) 13:12,17 144:10,17;145:1,21; sending (1)

 169:2 123:24 scope (2) 146:9,11;150:9,14,24; 214:21 

rolling (1) safe (3) 147:25;157:4 151:21;152:5,6; sense (4)

 24:9 82:13;173:22;186:2 scratched (1) 153:5,8;160:6,25; 40:14;85:21;

rollout (1) safer (1) 157:14 161:2;162:20;163:13, 105:13;224:23 

75:23 233:12 screen (1) 18,21,25;164:5,11,25; sensitive (3)

room (9) safety (3) 86:18 170:18,20,24;171:2; 161:16;162:8;

 22:2,6;23:11;24:19; 9:5;195:15;227:2 scrubbers (1) 175:3;181:19;184:1; 178:19 

27:25;28:5,10;71:11; sake (1) 195:10 185:4,6,14;190:6; sent (4)

 181:8 21:18 scrubbing (1) 191:9,13;192:14,20; 58:15;100:23;

root (1) sales (3) 195:10 197:17,25;198:2; 111:4;159:24 

162:8 15:4,6,10 seal (3) 199:1,9;200:4,14; sentence (1)

rotate (1) salinity (1) 26:5,8;27:13 201:8,20;202:5; 118:9 

50:22 232:21 season (16) 204:20;205:11,25; separate (1)

rotation (3) same (25) 100:15;107:5; 206:5,20;207:15; 159:15 

50:21;116:24; 9:19,23;44:24,24; 116:2;133:2;153:17, 208:25;209:10;210:3; separated (1)

 161:18 54:12,13;61:18; 20;155:1;157:16; 216:21;218:23;219:7; 40:25 

rough (1) 93:18;94:25;95:3; 164:16,21;174:24; 220:2;221:14,23; Separately (2)

 178:20 96:23;100:11;108:9; 193:23;217:13;218:4; 222:5;223:2;228:6, 125:5;157:2 

round (4) 110:6;112:5;113:16; 226:22;227:22 11;229:10;230:18; sequentially (2)

 21:23;27:22; 116:1;126:15;146:8; seasoned (3) 231:21,23;232:2,5; 146:1;226:20 

183:16;203:21 162:4,6;172:12; 83:6,10,15 234:15;235:15,19 series (3)

rounding (1) 202:14;215:16;234:8 seats (2) section (5) 72:6;86:9;99:24 

70:11 samples (2) 22:18;62:12 102:21;103:17; serious (1)

Route (2) 156:8;195:4 SEC (1) 105:24;175:4;220:8 155:10 

105:18;173:23 sandy (2) 38:13 sector (7) seriously (3)

row (8) 194:23;217:10 second (12) 70:15,18,20;166:5; 75:10;165:12;196:9 

16:15,15;160:14, sanitations (1) 19:24;35:24;57:4; 181:23,25;182:8 serve (2)

 15,15,16;161:22; 217:2 86:22;98:18;118:8; sectors (2) 64:10;122:24 

162:2 sanitizer (1) 169:3;174:18;182:24; 181:25;212:18 served (3)

royal (1) 142:14 191:15;206:3;212:14 seed (4) 0:22;6:4,5 

178:9 sanitizers (1) seconded (19) 46:19;64:20; serves (1)

Rule (25) 138:16 134:2;135:12; 164:14;179:6 0:15 

24:9,18;25:1,4; saturating (1) 139:13;140:22; seeds (2) Service (7)

 26:19,20,23;27:9; 194:22 144:19;150:18;152:3; 169:15,17 0:23;8:22;10:5,5,

 67:20;76:20;78:10; sauce (1) 184:4;190:11;191:18; seeing (9) 19;113:1;127:22 

87:4,23;94:20;95:4; 79:11 198:7;204:22;206:8; 28:14;40:12;41:6; serving (1)

 96:8,9,15;97:1,4,16; saw (9) 209:1;218:25;221:24; 53:25;90:11;107:4; 0:24 

99:7,15;110:5;214:1 44:13;49:11;133:5; 228:8;230:19;234:16 138:6;149:11;218:22 session (8)

rulemaking (7) 170:11;179:10,11; seconder (2) seem (2) 28:13;59:5;61:22;

 24:23;94:24;194:6; 180:2;181:2;211:8 120:7,19 224:20,23 105:9;195:20;213:15;

 211:11,15;212:17; saying (18) Secretary (156) seemed (3) 220:17;230:4 

213:11 20:2;29:22;36:22; 23:14,15;24:7; 182:4;211:4;226:17 set (9)

rule-oriented (1) 45:23;74:6,24;96:17; 26:25;28:15,17; seems (9) 11:5,7;32:16;60:21;

 215:14 99:7;103:13;109:16; 34:23;36:3;39:12; 55:22;111:23; 65:21;67:1;80:5;88:8,

rules (14) 111:16;115:17;116:7; 43:22;46:25;51:13; 115:23;116:11; 8 

25:4,7,10;26:19; 118:1;131:23;173:9, 53:9,17;56:20;58:5; 125:14;127:4;150:5, sets (2)

 73:24;88:12,15; 16;188:13 59:3;60:8,11;61:21; 6;181:11 66:20;230:10 

93:18;95:20;96:19, scale (2) 62:6;63:20;65:24; segment (1) setting (1) 

Min-U-Script® Burke Court Reporting & Transcription (31) road - setting 

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NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 4 

October 25, 2023 

124:18 17:25;36:14;42:23; single (10) 39:1;70:16;123:24; solidified (1)

settles (1) 73:3;81:2,7;106:3; 48:2;78:11;116:2,7; 124:13;148:14;174:1, 108:20 

177:1 188:16;197:12; 117:7;123:21;125:19; 13;178:17;179:9,19; solution (9)

seven (3) 214:20 127:4;161:23;179:12 180:2,12;224:11,20; 53:14;100:8;

 16:21;30:6;131:10 side (8) sings (1) 230:3,12;234:4 104:25;113:9;159:3;

Seventh (2) 28:14;78:9;104:22; 123:10 smaller (2) 165:18;166:12;

 6:12,13 146:24;154:20;158:8; sites (1) 94:19;179:20 169:20;180:22 

several (17) 168:2;177:4 204:8 smallest (1) solution-oriented (1)

 9:9;10:6,17;11:9; sight (1) sits (1) 9:6 66:12 

12:19;17:18;35:5; 183:23 66:18 smallholders (1) solutions (6)

 58:22;59:24;67:14; sign (2) sitting (3) 79:21 61:25;66:5,11;

 75:19;76:19;87:19; 66:25;179:17 51:25;56:12;165:5 SMEs (1) 165:14;181:21;187:1 

106:17;108:2;109:16; signal (1) situation (5) 34:18 solve (7)

 166:21 177:17 32:16;55:12;59:24; SMITH (38) 56:8;73:20;108:19;

severe (1) signaling (2) 60:16;155:8 58:6,14;59:2;76:14; 115:7,9;163:25;182:7 

50:11 180:8,8 situations (1) 91:23;92:4,6,11,16; solves (1)

shake (1) signed (1) 48:4 111:9;112:13;114:21, 163:6 

104:8 67:12 six (7) 24;121:22;133:23; somebody (7)

shall (2) significant (13) 30:14;66:14;67:15; 134:19;135:24;137:6; 20:12;36:20;40:2;

 97:17;210:9 6:8;18:3;41:25; 81:15,19;162:1; 139:24;141:4;144:24; 54:15;78:20;103:18;

share (16) 69:15;70:15;156:3,5; 229:20 150:22;153:3;165:22; 226:15 

24:5;26:24;27:1; 162:16;164:17; sized (1) 185:2;191:7;192:12; someday (1)

 32:24;33:2;36:23; 168:11;213:7;214:13; 178:17 198:24;200:2;201:6; 211:25 

71:12;72:9;77:18,18, 233:14 sizes (1) 205:9;206:18;209:8; someone (16)

 18;82:17;89:21; significantly (3) 112:18 219:5;222:3;229:8; 11:22;34:6;40:2,17;

 120:2;212:2,6 164:17;208:4,5 skin (1) 231:18;235:13 55:5;64:3;75:24;76:1;

shared (2) signing (1) 186:17 smog (1) 77:21;78:12;79:12,

 214:14,15 78:4 skipped (2) 138:21 14;115:23;116:11;

shares (1) silicate (14) 76:14;159:7 snapshot (1) 165:7,7 

212:6 185:13,15,18,22; slam (1) 100:22 someone's (3)

sheet (3) 186:6,15;187:2,19; 186:3 snow (1) 77:20;110:15;

 12:14;119:17;121:5 188:4;189:5,17; Slammin' (1) 51:8 118:21 

shepherd (1) 190:8,9;191:17 125:13 social (1) sometimes (5)

 77:21 Silicates (2) slate (2) 183:5 11:3,13;14:8;

ship (1) 185:23;188:25 125:19;140:17 sodium (4) 177:20;178:25 

225:12 silly (1) slaughter (1) 130:5;142:2,8; somewhat (2)

shipments (1) 95:22 25:15 144:17 170:25;227:1 

87:9 Sil-MATRIX (3) slaughtering (1) SOE (1) somewhere (2)

shitake (2) 188:1,8;189:3 25:21 114:22 167:18;181:2 

229:25;230:12 silver (1) sleep (1) soft (1) son (2)

short (6) 51:8 8:4 208:5 8:6;122:24 

28:20;66:7,7;82:2; similar (14) slide (13) soil (43) songwriting (1)

 143:23;176:3 11:12;41:8;60:16; 36:8;38:6;40:10; 129:21,23;132:22, 7:13 

shot (2) 67:19;74:13;114:2; 41:11,23;52:13;57:2; 23;146:23;153:22; sons (1)

 177:8;232:4 129:8;154:13,16; 89:14;114:4;122:22; 154:23;156:18,20; 6:11 

shout (1) 157:19;171:8;202:9; 130:13;138:4;150:10 157:2,12;162:3; soon (2)

 84:19 211:5;221:19 slides (6) 172:24;175:21; 128:10;150:5 

shoving (1) similarly (2) 22:1,5,7;40:9; 188:22;193:1,18,19; sooner (1)

 171:18 11:12;146:23 100:2;128:16 194:20,20,22;195:1,3, 67:1 

show (14) simple (3) slight (1) 4,6;197:5,7,12,18,19; SOP (1)

 19:16;29:12;43:12; 12:10;33:25;113:16 207:7 200:17;202:12; 95:25 

46:4,16;53:13;74:10; simpler (1) slightly (3) 217:15;220:11,22; SOPs (1)

 84:20;86:12;92:23; 116:16 92:24;95:18;208:2 232:13,17,20,20; 95:25 

100:6;130:25;179:18; simplest (1) slime (1) 233:23;234:1,2,5 sorbate (14)

 224:7 42:7 142:16 soil-based (1) 128:15,17;129:10,

showed (4) simplification (1) slip (2) 221:5 13;130:2,9,11,22;

 35:16;41:24;52:13; 65:8 47:14,14 soil-borne (1) 131:1;134:1,6;135:9;

 130:13 simply (2) slow (1) 162:11 136:20;137:25 

showing (1) 148:5;176:23 153:23 soilless (1) sorbate's (1)

 106:12 sing (1) slowly (1) 36:5 128:24 

shown (1) 123:4 158:15 soils (4) sorbic (1)

 57:3 singing (1) small (21) 155:6;185:24; 130:4 

shows (10) 7:13 8:22;11:15,15;15:8; 194:22,23 sorry (34) 

Min-U-Script® Burke Court Reporting & Transcription (32) settles - sorry 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 4 

October 25, 2023 

6:13;23:21;24:2; 75:24;81:10 spread (3) 181:5;184:5;191:20; stepping (1)

 47:22;60:6;62:18; spec (1) 37:4;74:12;157:15 193:2;198:9;199:14; 28:8 

76:12;78:18;98:17; 60:1 spring (16) 200:19;206:10;209:2; steps (7)

 100:18;105:7;111:9; special (2) 90:7;105:8;124:16; 210:10,13;219:1; 34:20;61:24;63:9,

 131:13;133:24; 79:11;82:23 128:4;131:16;138:23; 222:1;230:22;234:18 25;90:5;91:13;165:8 

138:12;139:10,12; specialist (1) 146:25;147:14; started (9) stepwise (1)

 144:16;146:13;160:4, 212:25 181:16;186:22; 8:6;64:18;80:10; 175:12 

5,22;163:8;167:13; specialty (11) 210:11;220:12; 91:17;94:1;127:3; sterile (1)

 174:6,6;184:17; 0:19;8:1;14:14; 227:24;229:23;230:4, 154:5;174:7,8 164:14 

188:12;202:5;206:4, 16:14;17:14;32:4,10; 9 starter (1) sterilizer (1)

 5;207:9;215:11; 55:16,16;57:22;58:2 sprouting (1) 110:7 133:2 

231:19 species (2) 228:1 starting (4) stewards (1)

sort (53) 210:23;215:20 squid (1) 64:21;107:25; 172:5 

6:17;53:23;54:3,19; specific (15) 211:3 139:16;228:9 stewing (1)

 55:9,11;56:2;64:16, 7:21;13:5;41:1; stable (1) starts (2) 125:14 

25;65:2,15,20;71:18, 43:20;55:12;57:6; 195:15 54:18;60:5 still (20)

 23;77:14,19;78:14; 63:14;65:4;70:12; stabler (1) State (19) 17:10;50:23;60:1;

 79:8,19;84:21;85:21; 71:2,3;72:9,14; 218:15 0:23;6:5;53:21,22; 62:13;66:18;70:15;

 88:8;90:10,17,18; 124:25;208:12 Stacy (2) 55:3,4;75:21;115:20; 92:24;99:23;101:10;

 105:2;108:11;115:8; specifically (17) 103:1;112:3 149:5;171:12,15,19, 118:23;159:11;

 116:5,10;117:9; 16:19;17:21;18:20; Stacy's (2) 20;172:17;193:12; 163:23;167:21;

 118:14;124:23; 19:21;30:17;42:6,8, 101:2,24 204:13;210:16; 168:16;169:20;173:4,

 126:10,11;147:4,11, 24;44:20;46:12; staff (5) 223:13;226:22 4;193:7;203:17;230:2 

22;148:1,11,23; 60:19;110:21;139:3; 24:14,17;78:12; state-by-state (1) stimulated (1)

 165:3;166:5;183:8; 193:14;203:24; 118:11;213:1 55:20 162:11 

187:3;188:20;196:10; 208:11;215:18 staggered (2) stated (11) stipend (1)

 197:13;202:9;215:21; specificity (1) 223:24;224:4 56:13;154:5;155:7; 78:5 

227:8,9;233:21 106:15 stakeholder (6) 166:21;194:10,13,20; Stipends (1)

sound (4) specifics (2) 174:19;195:20; 210:11;211:10;224:8; 85:6 

6:23;10:22,25;18:9 18:18;34:4 220:18;230:5,9,10 226:18 stocking (1)

sounds (7) spectrum (1) stakeholders (10) statement (3) 25:19 

12:21;56:1;62:19; 208:22 24:21;35:1;125:4; 90:19;211:15; stoked (1)

 64:15;69:10;202:9; speculation (1) 128:10;156:23; 216:23 125:17 

221:16 38:1 157:23;194:9;195:17; statements (1) stone (1)

source (4) speed (1) 204:5;221:4 63:15 59:13 

74:22;108:11; 125:21 stand (3) states (13) stood (5)

 232:12,19 Spencer (1) 21:21;22:4;23:4 18:18;35:18;43:4; 64:12;71:15,25;

sourced (1) 82:9 standard (9) 55:8,13;57:3;102:10, 73:4;76:16 

210:22 spend (7) 25:14,19;60:18; 16;103:9;107:11; stop (2)

sources (2) 12:5;34:19;75:21; 70:8;88:14;99:8; 153:15;154:8;225:12 159:2;166:22 

179:20;216:7 100:16;162:13;179:7; 107:18;161:19; stating (5) store (3)

south (2) 217:2 175:15 45:21;155:16; 156:8;182:10;226:5 

104:22;160:21 spending (1) Standards (15) 156:24;180:13; stores (1)

southeast (2) 123:23 0:17;24:2,10,25; 225:11 171:13 

81:8;162:14 spent (2) 25:8,17,18;33:4; statistically (1) storied (1)

Southern (1) 80:14;81:15 59:15;61:12;88:4; 67:10 84:23 

38:4 spiraling (1) 94:20;154:12;157:19; statutory (3) stories (1)

soybean (1) 197:9 225:15 212:5;213:7;215:7 73:18 

160:17 spirit (1) standpoint (2) STAX (4) storm (1)

soybeans (1) 103:15 106:11,12 13:6,7,18;42:22 13:9 

162:5 spitting (1) starry-eyed (1) stay (1) story (1)

space (3) 112:10 80:6 22:6 101:6 

25:17;104:2;181:5 spot (1) start (46) stem (1) straight (2)

spaces (1) 165:21 8:19;19:5,8;21:16; 129:23 69:2;156:8 

39:15 spots (1) 22:14;39:3;57:17; stemmed (1) straightforward (1)

spans (1) 114:10 61:4,10;65:8;66:20; 53:2 108:25 

11:6 spray (4) 67:1;79:6,6;85:12; step (9) strategic (1)

speak (3) 54:18;186:25; 86:7;103:16;120:23; 35:3;37:16;75:11; 95:13 

40:11;178:8;226:12 202:19;203:20 128:14;134:5;135:13; 78:7;87:16;108:14; strategies (1)

SPEAKER (4) sprayed (1) 136:22;139:11; 122:10;164:24; 71:5 

64:1;103:8;232:3; 103:20 140:23;144:15; 175:16 strategy (2)

 235:25 sprays (1) 150:20;152:4;158:8, stepped-up (1) 74:13;164:20 

speaking (2) 54:15 15;172:1;180:17; 53:13 straw (1) 

Min-U-Script® Burke Court Reporting & Transcription (33) sort - straw 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 4 

October 25, 2023 

156:12 

strawberries (3)

 17:17;154:3;161:15 

strawberry (2)

 163:7,9 

streamline (1)

 120:1 

streamlining (1)

 65:8 

street (4)

 105:20,22;111:21;

 118:20 

strength (3)

 130:25;167:24;

 176:5 

strengthening (4)

 25:4;87:3;95:9;

 110:20 

stress (2)

 30:9;66:10 

stressed (1)

 227:6 

stretch (1)

 22:8 

strictly (3)

 132:21;156:10;

 164:13 

strong (9)

 25:8;27:13;126:1;

 132:6;165:17;193:16;

 202:11;217:9;233:5 

stronger (1)

 188:5 

strongest (1)

 220:20 

strongly (2)

 26:15;97:19 

structure (2)

 188:5,18 

structures (1)

 157:16 

struggle (6)

 18:14,21,24;53:21;

 171:4;181:20 

struggling (1)

 169:12 

stubborn (1)

 176:1 

student (1)

 99:3 

144:3 

Subcommittee (37)

 61:24;109:1;

 122:13;123:19;

 125:19;126:20;

 127:21;128:5,9;

 129:18;130:7;132:8;

 134:3;135:11;143:4,

 18,19;144:11;157:22,

 22;159:24;170:12;

 176:20;184:3;187:6;

 193:14,22;210:23;

 211:5;214:21;218:8,

 11;220:14,24;226:9;

 227:17;230:13 

Subcommittees (1)

 208:22 

subdivision (1)

 112:19 

subject (2)

 157:14;160:7 

submission (1)

 113:3 

submit (1)

 110:21 

submitting (1)

 112:19 

subsidized (3)

 15:12;31:15,16 

subsidizing (1)

 15:21 

subsidy (10)

 15:19,20,23,25;

 16:1;31:14,20,25;

 82:2,6 

substance (12)

 89:18;129:12;

 131:10,25;142:10;

 155:20;197:18;198:4;

 220:6,12;221:11;

 229:22 

substances (14)

 87:10;88:10,17,21;

 89:14;90:13;127:24;

 130:12,19,23;135:10;

 136:20;146:2;232:10 

substantive (3)

 119:10,11,12 

substantively (1)

 95:10 

successfully (2)

 97:24;214:19 

sucks (1)

 177:20 

suddenly (3)

 104:5;107:2;208:4 

sufficient (1)

 175:11 

sugar (1)

 98:2 

suggest (2)

 34:12;126:16 

suggested (1)

 194:5 

suggesting (2)

 65:2;126:8 

suggestion (1)

 196:22 

suggestions (3)

 52:20;64:22;71:10 

suggests (1)

 10:12 

sulfate (3)

 143:8,17;233:3 

sulfur (49)

 130:23;131:1;

 132:15;187:21;

 192:22,25;193:1,5,17,

 19;194:11,13,16,18,

 21,23,25;195:9,18;

 196:1,17;197:5,6,16;

 198:5;199:12;200:17;

 201:22,25;202:3,6,8,

 9,11,12,22,25;203:6,

 6,10,12,17;204:1,17,

 17,20;206:4,8;220:7 

sulfuric (3)

 210:8;218:15,15 

sulfurous (6)

 220:5,5,10,21,24;

 221:23 

sulphate (1)

 143:15 

summarized (1)

 158:20 

summarizing (2)

 68:25;160:10 

summary (6)

 89:6;91:12;128:22;

 130:7;131:10;216:25 

super (4)

 59:23;63:6;91:23;

 95:2 

superior (1)

 196:2 

supplement (1)

 217:16 

supplemental (8)

 13:2,7,15;42:4,15,

 21;73:7;148:1 

supplementation (2)

 218:5,6 

supply (9)

 70:11;82:15;86:10;

 87:6,15,15,15;166:3;

 225:9 

support (24)

 31:11;69:13;70:4;

 86:2;89:21;131:16,

 19;138:21;147:19;

 154:8;156:24;157:9;

 158:2,3;193:16;

 194:8;217:5;220:19;

 225:7;230:7,10;

 233:5,8;234:11 

supported (2)

 148:4;220:15 

supporting (2)

 148:14;158:21 

supportive (1)

 126:7 

supports (1)

 25:12 

supposed (5)

 33:20;47:19;143:9,

 14;220:23 

suppress (1)

 172:9 

suppression (2)

 146:21;157:2 

sure (52)

 11:7;17:10;20:18;

 25:25;26:2,21;27:12;

 28:1;35:4,23;39:24;

 41:19;44:11;45:13;

 46:15;48:21;50:2;

 51:8;58:25;63:16,16;

 67:5;73:24;75:2;

 85:10;88:12,22;89:1,

 4;91:17;102:4;

 9:21 

surrounded (1)

 195:8 

survey (1)

 49:9 

surveyed (1)

 218:13 

surveys (2)

 30:6,8 

swag (1)

 177:20 

sweet (3)

 15:16;41:13,13 

swift (1)

 89:23 

switch (2)

 22:3;232:9 

switching (1)

 22:16 

swoop (1)

 24:4 

symptoms (1)

 196:14 

synergistic (1)

 130:5 

synthesizing (1)

 65:20 

synthetic (14)

 128:18,25;129:1;

 130:15;134:2,6;

 135:10;136:20;

 138:18;146:2;153:18;

 175:14;207:22;

 229:15 

system (20)

 6:20,21,21;8:20,23,

 24;44:12;103:16;

 107:13,16;108:16;

 114:3;115:21;122:10;

 138:17;142:15;165:9,

 13;189:6;204:1 

systemic (2)

 116:10;188:4 

systems (7)

 27:12;46:12;90:9;

 107:16;149:5;163:11;

 187:12 

T 

studies (2) substitute (4) summed (1) 108:13;109:2,21; table (5)

 132:14;156:12 88:14;89:8;90:9; 158:12 124:20;126:1,3,18; 9:21,21;79:15,16;

study (8) 164:23 summer (1) 132:12;133:25;144:7; 172:10 

49:9;60:25;155:25; substituting (1) 168:25 150:12;161:4;176:19; tackle (4)

 156:1;159:9;188:21; 172:18 sum-up (1) 178:22;183:22;195:3; 127:9;145:25;

 189:2;193:11 succeed (1) 187:18 196:23;213:22; 166:14;214:1 

stuff (6) 76:2 Sunset (8) 216:23;227:18; tackled (1)

 136:19;168:3; success (5) 188:13;192:23; 232:20 144:12 

171:18;186:3;196:16, 48:25;49:2;65:21; 210:10;216:24;220:4, surface (1) tail (1)

 18 80:5;124:19 15;229:18,21 6:23 122:14 

sub (1) successful (7) Sunsets (4) surprised (2) tailor (2)

 130:1 19:7;36:21,22;37:2; 138:3;142:3; 102:9;181:12 10:2;32:15 

Subcomittee (1) 76:3;77:3;85:1 167:12;210:6 surprising (1) talk (28) 

Min-U-Script® Burke Court Reporting & Transcription (34) strawberries - talk 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 4 

October 25, 2023 

0:12;8:7,16;15:9; tells (1) 158:10,17;160:7; 90:17 tolerance (2)

 18:15;21:17;30:3; 45:7 165:22;169:10;174:9; thriving (1) 89:17;186:2 

34:13;36:3,24;37:7; template (1) 185:21;198:2;227:13; 79:12 tolerances (1)

 42:9;47:24;48:20; 113:3 235:21 throughout (7) 88:18 

52:2,16;53:3;54:8; tend (1) that'd (1) 10:16;12:18;18:4; Tolle (65)

 63:5,8;78:21,21; 212:16 114:25 39:6;69:19;75:23; 0:9,15;6:12;7:3,5,

 111:13;112:7;127:10; tendencies (1) Thats (1) 166:2 10;22:21;29:5;35:12,

 161:3;172:12;229:18 194:23 20:21 throw (3) 23;36:7,12;38:16,20,

talked (17) tenet (2) themes (2) 159:4;161:24,25 24;39:22;40:5,16,21,

 14:13;16:5;18:4; 24:24;25:6 71:23;75:22 throwing (1) 24;41:10;42:1,3;43:8,

 25:16;37:18;42:4; Tennessee (3) theory (1) 162:24 10;44:2,11,19,23;

 46:4;48:10;51:18; 35:11;38:12;182:15 194:18 Thursday (1) 45:4,9,11,14,18;46:1,

 58:22;59:14;60:12; tent (1) therefore (2) 236:10 3,7,16,23;47:12,23;

 143:13;147:9;163:2; 104:10 44:16;153:17 tighter (1) 49:1,18,20;50:1,9,15;

 186:21;218:5 term (3) Theres (2) 80:25 51:21;52:15,20,23;

talking (24) 96:21;105:14;211:4 8:25;11:5 tillage (1) 53:5;54:7,15;56:4,7;

 15:1;16:2;25:24; terminate (1) thinking (23) 163:15 57:13;58:4,13,19;

 29:8;31:3;35:5;36:2, 20:4 50:7;55:10;56:12, Tilth (2) 60:7,10,19;64:7;

 25;40:18;48:13; terminated (1) 16,17;64:25;76:23; 107:8;114:4 67:11 

49:14;52:6;54:9;69:2; 20:2 77:5,10;82:16;84:22; timeline (2) tomato (2)

 78:20;80:21;87:12; termination (2) 95:1;97:8;102:17; 26:11,12 189:23,23 

101:20;103:21; 19:23;20:10 110:7;148:11;159:2; timely (1) tomatoes (2)

 111:16;112:14;159:9; terms (13) 171:23;174:19; 179:21 154:2;161:13 

180:15;187:4 28:7;73:7;74:14; 180:13,18;183:4; times (17) tomorrow (2)

tall (1) 89:5;111:5,15; 213:4 12:8,9,22;29:21; 227:19;236:5 

157:17 116:17;182:4;186:21; thinning (1) 45:22;59:24;109:16; ton (2)

tandem (1) 197:4;203:20;233:6, 204:7 124:21;129:7;131:5; 78:15;162:22 

138:7 21 thiolates (2) 155:14,15;166:21; Tony's (1)

tank (1) territory (1) 149:12;155:12 214:11,23;216:11; 101:24 

133:5 102:13 third (9) 227:3 took (2)

tape (1) test (7) 20:3,9;48:9,10,12, timing (7) 110:14;227:8 

166:7 47:9;66:10;90:1; 15;169:4;200:16; 19:11;142:25; tool (16)

target (4) 154:19;195:1;197:18; 212:21 179:24;202:25; 38:8;55:23;58:14,

 131:24;142:15; 234:2 thorough (1) 203:24;216:15,15 16;87:19;88:11;90:9;

 178:2;189:13 tested (2) 235:22 timings (1) 95:3;97:11;108:19;

taught (1) 87:24,24 though (10) 195:24 118:5;186:9,10;

 123:1 testimony (1) 22:8;79:21;97:20; tine (1) 202:15;203:14;

tax (3) 227:5 131:3;143:14;174:12, 162:24 204:18 

104:12;105:12; Testing (18) 22;214:11;225:21; tiny (3) toolbox (2)

 106:5 86:9,25;87:13,13, 232:9 116:5;189:20,20 177:24,25 

taxes (5) 22;88:5,6,9,11,14,22; thought (15) tirelessly (1) tools (3)

 102:5,8,11,14,17 89:8,22;90:8,12; 19:4;54:19;68:5; 183:19 34:15;89:23;178:8 

teach (2) 130:25;187:16; 77:23;81:15;109:16; today (17) Top (5)

 31:6;74:11 197:12 113:17;158:25;163:6; 0:4,5;8:17;22:20; 19:1;31:18;66:18;

team (7) testing-based (1) 167:7;171:17;211:13; 24:6;25:1;27:1,17; 87:15;163:1 

28:10;34:18,19; 89:8 233:10,18,21 28:6;53:4;81:25; topic (9)

 86:17;98:8;143:24; testings (1) thoughtful (1) 87:12;107:22;122:23; 34:24;56:23;68:21;

 176:2 90:6 71:9 124:14;148:13; 73:2;98:8;99:22;

technical (13) testing's (1) thoughts (12) 217:25 111:10;159:6;165:23 

72:20;74:14;75:1,9; 90:6 30:2;52:17,21; To-Do (1) topics (4)

 78:9;84:9;95:2;111:2; tests (1) 56:10;89:15;90:5; 84:4 62:8;91:1;124:17;

 185:25;186:11,16; 89:1 98:4;115:3;125:23; TOGA (4) 211:11 

194:5;211:10 Texas (3) 174:20;178:13;197:1 40:10,20,21;41:10 TOPP (11)

technique (1) 0:21;30:20;39:18 thousand (2) together (14) 64:19;70:6;75:20,

 100:12 Thanks (37) 13:17;74:4 0:11;7:18;32:6; 20,23;76:25;78:1;

techniques (2) 7:7;28:15;35:1; three (19) 52:4,9;58:16;77:17; 84:9;85:15;177:22;

 163:22;234:5 39:10;43:22;46:25; 0:11;10:10;19:22; 100:20;101:6;117:9; 180:3 

technology (4) 51:13;56:20;59:2,3; 20:7;41:14,15,17; 120:14;165:17; tossed (1)

 113:9,10,13;114:8 69:11;73:25;75:3; 55:7;67:15;70:3; 212:18,19 103:1 

teeth (2) 81:13;92:5;98:7,8,24; 109:11;112:6;117:22; token (1) total (5)

 74:3;167:24 99:14;119:1;138:1; 129:6;167:23;187:9; 126:15 220:18;224:15,20,

telling (1) 142:4;146:13;148:20; 192:23;198:3;203:9 told (2) 21;225:6 

178:7 149:20,21;150:9; three-pronged (1) 104:2;196:17 Totally (3) 

Min-U-Script® Burke Court Reporting & Transcription (35) talked - Totally 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 4 

October 25, 2023 

126:25;215:16,22 

touch (2)

 194:12;202:20 

touched (3)

 51:17;69:5;211:16 

touches (1)

 75:18 

touching (2)

 163:9;196:17 

toward (1)

 124:15 

towards (11)

 84:24;103:17;

 122:10;158:16;

 165:15;173:2;180:22;

 182:12;194:23;224:1,

 3 

township (3)

 102:20;103:17;

 105:24 

toxic (2)

 208:2;224:14 

toxicity (3)

 186:14,17;193:7 

TR (12)

 128:5;129:10,10;

 147:22;148:1;186:13;

 189:9;208:16;224:14,

 14;225:5;232:23 

24;70:1,4,16,23;71:1,

 2,3,5;73:6,8,9,11;

 74:21;77:25;81:18;

 85:25;86:2 

transitional (31)

 8:1;13:14;14:2,3;

 29:10,11,15;31:9,12,

 24;32:11;42:23,25;

 43:2,13,16;44:1,7,9,

 14,25;45:20,21,25;

 46:11,22;50:3;52:3;

 57:20;58:8,11 

transitioned (1)

 73:20 

transitioning (9)

 6:17,20;29:24;

 37:10;45:16;64:14,

 17;80:10;148:15 

translate (1)

 113:1 

transparency (3)

 80:9,20;81:5 

transparent (1)

 80:24 

transplant (1)

 166:8 

transport (2)

 25:15,21 

traps (1)

trusts (1)

 79:18 

try (21)

 19:6,9;37:14;58:23;

 59:6;62:16;66:24;

 67:17;74:2;101:5;

 108:9;124:24;127:9,

 11;128:6,9;130:19;

 167:17;177:2;223:15;

 226:21 

trying (21)

 8:14;11:12;34:19;

 37:21;41:3;45:14;

 55:15,19;60:13;

 61:25;72:20;79:10;

 81:16;98:1;101:22;

 114:13;171:5;177:23;

 182:7;198:2;224:21 

Tucker (37)

 0:6,7;6:13;7:4;

 21:21,25;22:10,14,18,

 24;23:2,6,11,17,18;

 27:18,20,25;28:3;

 93:11,13,20;94:14,17,

 21,23;95:24;96:2,11;

 97:14;110:17;112:24;

 211:16;214:10;

 215:13;216:5,19 

turn (15)

 123:21;128:18;

 131:11,11,12,13,15,

 19;133:13;145:24;

 154:15;163:6,6;

 170:3,3;171:3;

 185:15;187:17;202:3;

 203:9;217:4 

two-thirds (2)

 170:22,23 

T-yield (1)

 16:6 

T-yields (4)

 18:15;34:14;45:7;

 48:19 

type (15)

 13:4;39:20;41:2;

 59:17,19;60:14,15;

 67:16;81:20;105:12;

 107:25;111:1;126:16;

 180:22;224:4 

types (9)

 10:6;47:18;55:16;

 56:9;57:9,11;118:4;

 161:14;175:18 

types' (1)

 67:22 

153:13,15;175:1,2;

 207:21 

UNDERSEC (6)

 23:10,16,19;27:22;

 28:2,16 

underselling (1)

 80:6 

understandable (1)

 105:14 

understands (1)

 50:2 

understood (2)

 156:20;194:18 

underway (1)

 203:8 

underwriting (1)

 0:18 

unfamiliar (1)

 31:2 

unfavorable (1)

 226:12 

unfortunate (1)

 189:9 

unfortunately (1)

 18:16 

UNIDENTIFIED (4)

 64:1;103:8;232:3;

 235:25 

unintended (1)

U 

trace (1) 155:22 7:1;68:20;86:13; Ugh (2) 113:18 

53:25 treatment (3) 91:6,10;123:17; 184:11;185:8 Union (1)

traceability (2) 82:23,24;172:24 132:8;133:15;160:19; ultimately (3) 0:25 

87:6,16 tree (2) 183:25;185:16;196:3; 73:11;95:3;131:3 unique (3)

track (1) 204:10;217:9 198:7;211:14;218:18 um-hmm (1) 70:19;112:7,8 

101:11 trellis (1) turned (1) 85:18 United (4)

tracking (1) 157:16 91:18 Um-hum (24) 57:3;102:16;

 172:1 trellised (1) TURNER (32) 41:10;42:3;44:22; 107:11;225:12 

Trade (3) 161:14 77:5;103:5;122:5; 45:3;54:14;56:4; units (9)

 30:21;72:5;147:16 tremendously (1) 126:7;135:2;136:7; 81:12;109:12,18; 32:4,5,8,10,12,14;

tradition (1) 212:23 137:14;140:7;141:12; 112:15;115:13,13; 59:9;66:2;119:23 

58:8 triangulating (1) 145:7;150:18;151:5; 116:21;118:7,13; universally (1)

traditional (1) 177:3 152:3,12;159:15; 126:25;164:25; 160:16 

32:21 tried (4) 176:9;184:11;190:16; 165:19;171:2;173:14; universities (2)

train (2) 15:1;17:10;37:16; 191:21;199:7;200:10; 175:6;178:24;179:2, 84:10,11 

84:13,13 71:4 201:14;205:17;207:1; 13 university (4)

trained (2) trigger (1) 209:16;215:15; unable (1) 19:25;67:11,22;

 83:11,14 14:11 219:13;222:11; 14:18 193:12 

trainers (1) triggered (1) 228:17;231:2;232:14; unanimous (6) Unless (6)

 84:12 74:20 234:22 125:18;126:1; 85:15;99:18;

training (5) triple (1) turning (2) 220:13;225:11; 112:19;148:16;

 37:16;76:2;83:11; 213:10 28:9;63:18 226:10;234:11 153:16;232:12 

84:12;125:2 tropical (3) turns (2) unanimously (1) unpack (1)

trainings (1) 13:9;217:11;227:16 122:25;187:14 233:8 75:17 

85:6 TRs (2) twice (2) unannounced (1) unpackaging (1)

trans (1) 128:6;187:17 133:6;201:23 100:13 217:3 

113:6 true (3) twine (1) uncomfortable (2) unpleasant (1)

transcript (1) 74:25;165:6;168:3 182:4 83:21;173:15 113:19 

63:17 trust (5) two (40) under (20) unprecedented (1)

transition (35) 26:4,7;71:21;79:18; 6:10;7:11,13;12:8; 6:18;14:17;23:13, 69:25 

29:12,13;31:13,13; 83:20 15:23;30:18;38:4,8; 15;28:15;36:3;41:14; unrealistic (1)

 35:4;45:23;52:17,18; trusted (4) 41:14,15,17;47:3,23; 45:25;64:15;69:14; 212:1 

53:10,10,13;64:13; 76:17;79:25;84:2, 51:1;58:16;63:13; 79:8;110:23;123:20; unsure (1)

 68:22;69:13,14,18,18, 22 96:6;105:9;115:9; 128:25;149:17; 234:7 

Min-U-Script® Burke Court Reporting & Transcription (36) touch - unsure 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 4 

October 25, 2023 

up (106)

 6:9;9:9;10:21;

 12:11,16;13:11;17:8;

 25;53:10,11;72:7;

 73:15;74:12;94:14;

 96:20;97:6,17;

violation (2)

 72:13,20 

Virginia (2)

 21:25,25;36:2;

 111:2;120:24;139:5 

walk (5)

V 

21:5,15;22:4;28:4,11; 101:14;104:13;113:1; vague (1) 82:9;229:20 68:22;75:24;109:1;

 29:3,4,7;30:1,16; 114:9;129:6,14; 72:16 virtually (1) 115:8;128:16 

32:16;34:10;35:6; 130:11;131:14,21,22; Valley (1) 24:4 walking (2)

 37:16;38:20;39:1,3; 132:6;135:10;136:21; 30:20 virtue (1) 73:16;90:23 

42:17,20,21,22,22,25; 138:19;142:9;146:2, value (8) 177:17 walks (1)

 47:8;53:18;55:7,24; 24;154:18;155:8; 12:7,8;42:14;139:3; vis-à-vis (1) 93:6 

56:10;59:5;62:16; 158:14,24;160:23; 162:12;177:22; 167:24 wants (1)

 63:15;64:21;65:9,15, 164:9,10,13,13;169:3; 217:19,19 visible (1) 99:8 

21,25;66:25;67:12; 171:22;172:3;173:9; variation (1) 182:1 warehouses (1)

 74:19;75:22;76:7; 175:10,11,13,14; 51:10 vision (3) 61:4 

78:4;79:4;80:5;82:19, 178:8,25;182:5; varies (1) 52:24;100:21; warming (3)

 23;84:14,20;85:2; 183:9;186:25;187:12; 53:21 177:22 153:22;156:18;

 86:7;91:9;98:16,23; 188:1;193:17;195:5; variety (2) visit (1) 157:2 

99:14;101:18;105:2, 197:18;207:22,25; 132:3;161:5 168:23 warn (1)

 19;106:23;115:7; 208:9,12;217:16,22; various (7) visuals (1) 213:4 

121:5;124:18;125:21; 220:9,19,20,21;223:8, 13:2;30:8;42:24; 81:25 washes (1)

 126:8;131:10;132:11; 14;225:3;227:16,22; 48:1;130:8;193:17; vocabulary (1) 203:20 

133:3,12;138:5; 229:13;230:6,7; 195:23 105:12 Washington (8)

 153:8,8;158:12; 232:11;233:14,17 veg (2) voice (5) 55:4,9,13;172:17;

 163:19;164:7;165:10, used (41) 162:7,12 97:20,21;174:1,2; 204:5,12;221:4,6 

18,25,25;168:22; 19:14;31:11;47:10; vegetable (2) 182:25 waste (2)

 169:2;174:8;179:11; 112:2,2;128:19,20; 153:25;174:1 volumes (1) 207:25;210:22 

181:13;185:12;187:8; 130:10,15;131:2; vegetables (3) 208:4 water (11)

 189:9,12;194:3; 138:16,20;143:14,15; 161:5,9;203:2 vote (34) 50:17,20;132:21;

 196:22;197:4;203:9; 146:20,21;155:24; veggie (1) 120:22;121:7; 143:5,7;154:23;

 215:10,13,15;216:14, 156:25;157:8;166:2; 217:10 124:9,14;125:19,20, 155:7;156:19;208:2;

 24,25;220:5;224:7; 174:14;185:23;188:5; veggies (1) 20;126:20,23;133:21; 220:12;221:8 

227:25 193:6;194:14;202:13, 160:22 134:4;136:22;139:14, watermelons (1)

update (10) 15;203:2;207:24; venue (1) 15;144:15,21;146:1; 161:7 

89:12;90:25;91:23; 208:11;210:8;218:12, 64:6 150:20;159:23;170:5; wax (5)

 92:2;93:15;94:19; 14,16;226:18,19,20; venues (1) 176:24;184:2;190:7, 229:13;230:7,11,

 112:22;182:17,17; 230:2,12;232:19; 76:10 13;198:3,8;204:25; 14,19 

211:21 233:16 verification (6) 206:3,11;208:24; way (66)

updated (4) user (1) 76:20;87:16,17,18; 214:25;218:21; 8:4;11:2,19,20;

 82:18;95:10,10,17 133:2 88:11;89:9 220:14;226:10 14:19;19:25;20:2,3,3,

updates (5) uses (12) verify (2) voted (2) 4,9,10;29:10,14;32:5,

 90:12;93:19; 106:4;128:18; 58:8,18 124:8;187:19 14;37:2,20;40:16;

 124:21;125:5;182:21 142:10,15;166:8; version (1) votes (24) 43:15;48:24;49:2,13,

updating (3) 187:4,10;197:14; 171:13 121:1;122:6;135:5; 15;51:3,12,21;52:4;

 90:21;95:14;148:13 203:22;227:20,20,24 versus (10) 136:12;137:21;139:9; 55:21;57:6,18;62:14;

upholding (1) using (21) 41:2;44:25;52:18; 140:16;141:23; 64:13;65:8;66:22;

 73:24 17:15;42:7;76:17; 59:9;66:2;90:22; 145:20;151:20;153:4; 72:11,21;73:16;

upon (6) 97:14;101:1;112:10; 131:1,1;195:21; 185:5;191:12;192:19; 82:14;86:19;90:1;

 70:22;74:24; 115:4,8;130:16; 218:15 199:8;200:13;201:19; 100:23;101:18,25;

 105:13;113:18; 132:21;133:1;143:16; vertical (3) 205:24;210:2;220:1; 102:23;105:1;108:11;

 142:25;173:22 148:9,9;163:14; 36:5,9;38:21 223:1;229:9;231:22; 115:19,24;116:13;

uproars (1) 164:1;168:13;202:18, vertically (5) 235:18 117:16;120:14;121:1;

 177:12 25;226:11;229:19 35:25;36:4;38:19, voting (13) 126:13;143:16,17;

upwards (1) usually (6) 25;39:6 121:5;140:20,23; 158:8;161:23;169:13;

 179:1 55:5;75:6;101:14; via (6) 150:15;151:24; 174:14;182:4;194:16;

usage (2) 116:6;178:22;180:5 70:7;87:13;88:8,8; 191:15,19;201:23; 195:9;197:12;233:6;

 166:5;217:6 utility (1) 100:7;129:21 204:21;206:6;209:2; 234:9 

USDA (9) 89:13 viable (2) 219:2;234:18 ways (13)

 0:15;6:15;24:1;

 26:5;70:21;71:17;

utilize (2)

 58:15;223:13 111:23;157:7 

view (1) W 

9:9;10:17;13:18;

 17:1;19:23;20:7;

 72:1;85:24;89:19 utilized (1) 217:20 55:19;76:5;85:4,12;

USDA's (1) 223:17 Vilsack (1) wait (5) 92:16;124:22;169:1 

69:25 utilizing (2) 24:7 83:7;86:21,22; weaknesses (1)

use (78) 29:9;220:6 vining (1) 207:8,8 225:1 

11:13;16:16;50:20, 157:15 waiting (6) weather (7) 

Min-U-Script® Burke Court Reporting & Transcription (37) up - weather 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 4 

October 25, 2023 

44:24;45:1,2;50:8;

 61:4;179:4;203:15 

weather-related (1)

 53:24 

website (4)

 18:17;22:7;34:11,

 15 

weed (13)

 146:21,21;153:22;

 157:2,6;162:18;

 164:17,22,23;172:22;

 175:10,15;179:6 

weeder (2)

 162:24;164:2 

weeding (3)

 156:19;178:23;

 179:21 

weeds (9)

 43:15;59:7;160:14,

 14,15;161:22;162:2;

 163:4;172:9 

Wheatley (1)

 41:13 

wheel (2)

 116:3;158:15 

wheelhouse (1)

 58:2 

whereas (1)

 203:12 

whereby (1)

 155:8 

Whereupon (4)

 62:10;98:25;

 185:11;236:9 

wherever (2)

 9:19;170:9 

wherewithal (1)

 176:5 

whilst (1)

 83:7 

whole (46)

 7:8;14:14,16,20,25;

 215:22 

wipe (1)

 224:22 

wise (3)

 113:13,13;164:24 

wish (1)

 31:5 

within (5)

 14:13;75:5;112:16;

 133:7;147:1 

without (17)

 47:20;74:23;78:15;

 80:5;93:25;102:11;

 128:13;139:5;146:4,

 6;150:17;151:25;

 152:2;156:8;189:10;

 229:14,19 

Woman (2)

 6:7,8 

wonder (3)

 41:25;50:12;113:17 

68:12;69:12;71:4;

 73:2,11;74:8;86:6;

 88:6;95:3;99:5,14;

 101:25;106:1;116:1;

 118:15;122:14,15,16,

 16,19;125:16;149:23;

 150:4;157:10;158:8;

 160:7;165:22;167:4;

 169:4;173:10;178:22;

 181:11;183:15,24;

 188:17;193:3;211:25;

 212:1;225:3;226:16 

worked (13)

 0:11;6:23;17:23;

 21:9,12;58:21;68:20,

 21;99:25,25;182:16;

 214:23,24 

worker (4)

 195:12;196:8,11;

 227:2 

workers (3)

 51:12;196:19 

write-up (1)

 186:23 

writing (3)

 19:16;71:11;174:7 

Written (18)

 11:20,24;19:13,13;

 20:10;66:3;131:10;

 138:21,22;154:8;

 155:13;187:9;217:1;

 220:18;223:12;225:7;

 230:5;233:7 

wrong (2)

 92:4;178:2 

wrote (1)

 99:3 

WSDA (3)

 106:2;107:8;114:3 

Y 

week (2) 15:12,15,15;16:4,8, wonderful (5) 186:8;196:21;227:4 Yang (1)

 70:6;211:17 13,13,16,17,20,23; 28:18,25;35:12; working (18) 170:17 

weeks (1) 17:3,12;31:19;34:18; 65:25;182:20 0:25;19:5;25:24; Yay (2)

 79:9 39:19,25;40:12,16; wondering (3) 32:2,22;48:14,14,14; 23:8,18 

weening (1) 41:1;42:9,19;56:23; 40:11;77:6;118:9 55:21;61:24;88:2; Year (37)

 173:12 61:14;73:16;91:2,3; wonkier (2) 98:8;124:15;193:23; 6:7;13:10;14:2,24;

weigh (2) 113:15;116:7,13; 96:7,7 194:4;214:22;227:10; 15:13;17:3,8,10;

 94:10,11 143:20;159:16,24; wonky (1) 235:24 20:18;21:11;23:22;

weighed (1) 164:20;165:8;169:5; 96:22 workload (1) 25:3;26:19;30:16;

 215:7 171:17;197:15; woo (1) 213:8 38:24;39:9;48:2;

weird (1) 215:10,13;224:20 0:11 works (7) 50:13;87:25;106:22;

 171:18 Wholesalers (1) Wood (47) 20:11;24:16;32:20; 116:7,8,24;117:2;

Welcome (5) 227:8 76:12,13;77:4; 33:6;37:17;71:4; 123:23;127:23;

 0:8;54:20;99:21; who's (1) 102:7;103:4;122:4; 194:16 129:15,21;143:24;

 117:24;185:14 27:3 126:6;135:1;136:6; world (9) 162:16,23;169:4;

welfare (1) whose (1) 137:13;140:6;141:11; 26:20;33:8;74:2; 178:4;186:12;195:7;

 25:13 158:7 145:6,24;148:18,20; 107:11,12;167:14,23; 196:11,14 

well- (1) wide (4) 150:10,18;151:4; 169:6;215:10 years (23)

 202:25 14:8;90:24;194:14; 152:3,11;159:14; worms (1) 0:11;11:6,9;16:17;

well-known (1) 208:7 169:21;174:4,5; 208:6 18:1;19:12;24:15;

 146:14 widely (5) 176:8;184:10;185:8; worry (2) 30:18;51:1;55:7;

weren't (2) 89:2;138:18; 190:11,15;191:20; 74:16;77:9 67:15;69:21,25;

 51:25;214:4 202:15;230:2,11 199:6;200:9;201:13; worth (5) 81:15,19;94:2;99:15;

West (6) wife (1) 205:16;206:25; 53:6;58:22;180:9; 125:14;127:15;

 82:9;102:20; 176:1 209:15;219:12; 196:9,24 169:16;197:6;202:24;

 111:13,23;116:25; wild (1) 222:10;228:16;231:1; Wow (1) 229:20 

178:4 211:8 232:8,13;234:13,16, 6:3 year's (1)

wet (1) wildfire (1) 21;235:21 wrap (6) 55:7 

195:21 55:13 word (4) 21:15;53:18;59:4; Yep (3)

Weve (3) Wildlife (1) 99:13;105:3,12; 166:8;216:24;236:4 108:18;218:21;

 8:22;10:8,8 215:19 229:19 wrapped (1) 232:14 

what's (22) willing (3) words (2) 163:19 yeses (1)

 8:16;9:24;17:20; 52:21;61:20;73:10 94:15;97:17 wrapping (1) 134:3 

31:7;40:25;45:14; willingness (1) work (70) 34:10 yesterday (10)

 47:15;48:14,14,18,19; 61:22 7:21,22;8:14,21; wrestle (1) 58:9;75:19;76:8;

 49:4,15;52:8;65:2; win (1) 9:4;14:21;17:7,22,22, 168:25 78:12;82:9;84:19;

 70:22;77:16;78:23; 59:11 24;21:7;24:1;27:6; wrestled (1) 87:5;147:10;179:10;

 92:18;148:22;189:24; window (2) 29:8;30:17;33:24; 159:17 180:2 

217:20 164:15;226:3 35:10;38:10,14; wrestling (4) yield (5)

Wheat (4) wins (3) 46:11;47:7;52:3,9; 64:9;159:25;165:5; 12:20,21,22;17:16;

 6:2;79:15;115:24; 62:1,1;163:22 53:7;58:10,23,24; 169:6 44:8 

116:8 win-win (1) 61:11,23;67:17; write (2) yields (4) 

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Ying (2)

 170:16;171:5 

Young (2)

 6:4;72:22 

Youve (1)

 7:4 

10,000 (2)

 41:18,20 

10:11 (1)

 0:2 

100 (5)

 116:19;117:8;

 169:18;179:1;180:3 

11 (3)

 220:2;233:7,7 

11.10 (1)

 12:12 

1-1/2 (1)

 12:9 

11:00 (1)

 27:1 

112,000 (1)

 13:16 

12 (2)

 153:5;185:6 

12,500 (1)

 9:2 

12:41 (1)

 98:25 

12:45 (1)

 62:13 

13 (21)

 8:25;122:7;135:6;

 136:13;137:22;

 140:18;141:24;

 145:21;151:21;

 191:13;192:20;199:9;

 200:14;201:20;

 205:25;207:15;210:3;

 223:2;229:10;232:5;

 235:19 

14 (1)

 220:17 

147,000 (1)

 13:17 

15 (3)

 67:14;185:10;

 223:23 

15- (1)

 62:6 

1500 (1)

 179:22 

15th (1)

 15:6 

16.65 (1)

 12:14 

17.2 (1)

 224:16 

176 (1)

 105:19 

17-year-old (1)

 74:10 

18 (2)

 10:9;224:16 

19,000 (1)

 13:18 

1995 (1)

 193:20 

96:19 

205.206 (2)

 170:10;175:1 

205.206c6 (1)

 153:18 

205.601 (3)

 138:11,13;146:2 

205.601a8 (1)

 142:8 

205.601b21 (1)

 150:15 

205.601b2ii (1)

 153:9 

205.601c (1)

 151:24 

205.601e (5)

 135:10;192:24;

 193:24;198:6;204:21 

205.601e2 (2)

 185:18;190:10 

205.601e6 (1)

 201:25 

205.601i (4)

 185:19;199:12;

 206:7;207:22 

205.601i1 (1)

 191:16 

205.601i4 (2)

 202:1;207:19 

205.601i6 (1)

 202:5 

205.601j (1)

 200:17 

205.601j11 (1)

 220:6 

205.601j8 (1)

 210:7 

205.601k1 (1)

 223:5 

205.601o (1)

 230:15 

205.601o1 (1)

 229:13 

205.602 (1)

 232:10 

21 (1)

 169:16 

22 (2)

 30:18,19 

23 (4)

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239 (1)

 218:13 

23zero (1)

 187:11 

24 (1)

 181:3 

26 (1)

 236:10 

274 (1)

 16:22 

280 (1)

 203:25 

29 (1)

 13:17 2 

2 (33) 3

 0:8;10:15;59:19;

 105:19;112:4,4,10;

 122:8,25;135:7;

 136:14;137:23;

 140:19;141:25;

 145:22;151:22;153:6;

 177:13,14;185:7;

 191:14;192:21;

 199:10;200:15;

 201:21;206:1;207:16;

 210:4;220:3;223:3;

 229:11;232:6;235:20 

2:00 (4)

 98:17,17,22,24 

2:02 (1)

 99:2 

20 (3)

 99:15;103:2;197:5 

200 (1)

 116:25 

2000 (1)

 81:16 

2001 (1)

 169:14 

2003 (1)

 220:15 

2006 (1)

 81:16 

2012 (1)

 6:6 

2013 (2)

 18:1;87:23 

2014 (1)

 12:5 

2015 (6)

 0:20;14:16;16:21;

 186:15;224:6;227:5 

2016 (1)

 211:2 

2017 (2)

 6:9;147:22 

2018 (3)

 82:20;87:7;154:17 

2020 (4)

 19:22;210:15,19;

 211:6 

2021 (3)

 17:17;211:2;224:15 

2022 (4)

 14:17;19:1;30:21;

 213:14 

2023 (13)

 9:1;10:7;16:22;

 18:1;31:10;169:16;

 210:12;220:12,16,17;

 229:23;230:4;236:10 

2024 (2)

 10:8;14:24 

205 (1)

3 (4)

 112:4,4,10;176:6 

3,000 (2)

 41:19;113:21 

3.5 (1)

 210:9 

30 (7)

 12:24,25;15:10;

 42:13;80:14;178:23;

 180:4 

300 (1)

 167:18 

350,000 (1)

 39:1 

36 (2)

 13:17;73:14 

36-month (1)

 89:10 

38,000 (1)

 13:16 

390 (1)

 8:23 

Z 

zero (70)

 81:19;100:8;

 114:16;122:7,7,8;

 135:6,6,7;136:13,13,

 14;137:22,22,23;

 140:18,19,19;141:24,

 24,25;145:21,22,22;

 151:21,21,22;153:5,6;

 158:2,4;185:6,7;

 191:13,13,14;192:20,

 20,21;199:9,9,10;

 200:14,14,15;201:20,

 20,21;205:25,25;

 206:1;207:15,15,16;

 210:3,3,4;220:2;

 223:2,2,3;229:10,10,

 11;232:5,5,6;235:19,

 19,20 

zonal (1)

 19:24 

zone (2)

 60:4,17 

Zoom (5)

 22:2,24;23:2;28:4;

 104:18 

4 

4 (4)

 59:16;60:2,5;

 233:12 

4,000 (2)

 41:12,19 

40 (1)

 78:4 

40,000 (1)

 26:15 

400,000 (1)

 39:1 

45,00 (1)

 13:18 

490 (1)

 48:10 

4900 (1)

 31:22 

0 

0 (1)

 42:17 

0.7 (1)

 224:17 

1 

1 (13)

 39:22;59:19;60:1;

 82:21;101:2;112:4,4,

 10;134:3;153:5;

 177:13;185:6;220:2 

1,100 (1)

 217:8 

1.5 (2)

 12:13;164:4 

1/10 (1)

 82:21 

1/2 (1)

 133:7 

10 (10)

 18:1;19:1;31:14,20;

 67:13;155:14,15;

 162:15;216:25;230:4 

5 

5 (3)

 59:16;87:24;167:23 

5,000 (1)

 9:3 

5.91 (1)

 12:12 

5:26 (1)

 236:9 

50 (4)

 12:23;15:20;36:18;

 202:24 

500 (6)

 116:19,20,25; 

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5-1/4 (1)

 10:23 

571,000 (1)

 31:25 

58 (1)

 218:13 

5i (1)

 192:25 

43:1 

96,000 (1)

 13:17 

97 (1)

 167:21 

99 (1)

 220:7 

6 

60 (2)

 8:7;202:24 

601c (1)

 146:7 

601i (1)

 136:20 

62 (1)

 16:3 

65 (1)

 10:21 

6508c2 (1)

 153:13 

7 

7 (4)

 96:19;134:3;

 223:23;236:6 

70 (5)

 12:24;13:25;15:20;

 31:15;42:13 

75 (3)

 8:10;15:22;171:15 

8 

8.4 (1)

 32:1 

80 (5)

 15:17,21,21,22;

 31:16 

84 (1)

 10:7 

85 (3)

 12:23;15:17,22 

86 (2)

 13:12;42:22 

88 (1)

 18:12 

9 

9,000 (1)

 41:12 

9,200 (1)

 31:23 

90 (6)

 13:11,25;42:20,21,

 22,25 

95 (4)

 13:11;42:17,20;

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 UNITED STATES DEPARTMENT OF AGRICULTURE

 NATIONAL ORGANIC PROGRAM

 NATIONAL ORGANIC STANDARDS BOARD (NOSB)

 FALL 2023 MEETING

 Thursday,

 October 26, 2023, 10:01 a.m., EST

 Marriott Downtown Providence

 1 Orms Street

 Providence, Rhode Island 02904 
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2

 National Organic Standards Board (NOSB) Members

 Nate Powell-Palm, NOSB Chair

 Mindee Jeffery, NOSB Vice Chair (absent)

 Amy Bruch, NOSB Secretary

 Brian Caldwell

 Jerry D’Amore

 Carolyn Dimitri

 Kim Huseman

 Allison Johnson

 Kyla Smith

 Nate Lewis

 Dilip Nandwani

 Logan Petrey

 Franklin Quarcoo

 Wood Turner

 Javier Zamora (absent) 
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3

 USDA/National Organic Program Staff 

Dr. Jennifer Tucker, NOP Deputy Administrator

 Michelle Arsenault, Advisory Committee Specialist

 Jared Clark, National List Manager, Standards

 Andrea Holm, Agricultural Marketing Specialist, Standards 

Johanna Mirenda, Agricultural Marketing Specialist, 

Standards

 Heather Kumar, NOSB Technical Support Staff

 Esu Obu, NOSB Technical Support Staff 
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4

 CONTENTS

 HANDLING SUBCOMMITTEE (HS):

 Discussion Document: Magnesium carbonate ................................. 6

 2025 Handling Sunset Reviews: 

 (Arabic; Guar; Locus bean; and Carob bean) 

 Discussion Document: Magnesium carbonate hydroxide...... 6

Calcium carbonate ....................................................................................... 9 

Flavors ..................................................................................................................... 11 

Gellan gum (high-acyl form only) .......................................... 17 

Xanthan gum ......................................................................................................... 23 

Gums - water extracted only ......................................................... 24

Tamarind seed gum ....................................................................................... 26 

Tragacanth gum ................................................................................................ 27 

Oxygen ........................................................................................................................ 28 

Potassium chloride .................................................................................... 30 

Alginates ............................................................................................................... 32 

Calcium hydroxide ....................................................................................... 40 

Ethylene .................................................................................................................. 43 

Glycerides ............................................................................................................ 47 

Magnesium stearate .................................................................................... 55 

Phosphoric acid ............................................................................................. 57 

Potassium carbonate ................................................................................. 61 

Sulfur dioxide ................................................................................................ 64 

Fructooligosaccharides (FOS) ...................................................... 71 

Lecithin - de-oiled ................................................................................. 76

 MATERIALS SUBCOMMITTEE (MS)

 Proposal: Research Priorities 2023 ................................................... 94

 NOSB Officer Elections ......................................................................................................131

 NOSB Work agendas and Materials Update ......................................................135

 Other Business ..............................................................................................................................141

 Closing Remarks ...........................................................................................................................160

 Adjourn ...................................................................................................................................................162 
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 P R O C E E D I N G S 

(Time: 10:01 a.m.)

 CHAIR POWELL-PALM: Good morning, everybody. We're 

going to be getting started here, very exciting day of handling 

materials to go through. So I'm glad the crowd is popping off 

still, lots of energy in the room. So I'm going to call my 

fellow board members to their seats. All right, and I'm going 

to hand it off right away to Kyla.

 BOARD MEMBER SMITH: Do I get the clicker?

 CHAIR POWELL-PALM: You get the clicker.

 BOARD MEMBER SMITH: Okay. Welcome back, everybody. 

We're going to move into Handling Subcommittee. Our crowd is 

dwindling. Thank you for all of the audience members who are 

sticking with us and all those that are still on, on Zoom. We 

had a great team on the Handling Subcommittee this past 

semester. Again, we were fortunate to add Nate Lewis to our, 

our crew, which really will help us as we move into next year, 

because our workload really spikes up there. So we had to make 

sure we had a really deep bench so that we can -- we get 

through all of our work.

 But let's not get ahead of ourselves. We have lots 

to talk about on our agenda today. So our work agenda this 

semester consisted of 19 sunsets and a few petitions. I am the 

lead on the two petition discussion documents that were in the 

packet, so let's jump right in. 
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 Magnesium carbonate and magnesium carbonate hydroxide

 were both petitioned. I'm just going to talk a little bit

 about the process before we talk about the materials,

 themselves. These were both included as discussion documents

 on the agenda before the Board today because we didn't receive

 the TR in time to do the full review and be included on the

 agenda. So for this meeting, we went with discussion documents

 until we got the TR.

 We, we could have waited, but we decided maybe we

 could try to get some information, gather some information

 based on questions that might better come from the community

 versus hearing out of the TR. That approach wasn't super

 effective, to be honest with you. But before I get into the

 public comment, let's talk about the materials, themselves.

 So magnesium carbonate and magnesium carbonate

 hydroxide were both petitioned as processing aids to the

 National List at 205.605. I'm going to talk about them

 collectively because they have the same use and are used in the

 same way. It's my understanding that these materials are used

 interchangeably, not together. But since they are distinct

 chemical compounds, they were petitioned separately. Both

 materials are used as drying agents or anti-caking agents. The

 petitioned use was focused specifically on organic chicory

 production, specifically organic instant chicory powder. The

 petitioner stated that during the final steps of the 
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 atomization and packing, that the instant chicory powder sticks

 to the walls of the installations and requires several stops

 for cleaning, which reduces the rate of production.

 Magnesium carbonate does have a bit of history with

 the National List. It was previously listed on the National

 List at 205.605(b) with the annotation for use only in

 agricultural products labeled made with organic specified

 ingredients or food groups and prohibited in agricultural

 products labeled as organic. During the sunset review process

 in 2015, the Board voted to remove magnesium carbonate from the

 National List stating that, quote, "the material does not

 appear to be essential to organic handling," end quote.

 Magnesium carbonate was removed from the National

 List effective August 7, 2017. The final rule stated, quote,

 "AMS received no public comments concerning the proposed

 removal of magnesium carbonate from the National List," end

 quote.

 Additionally, in 2005, magnesium carbonate was

 petitioned for inclusion on the National List as a filtering

 aid to 205.606. The petition was rejected by the NOP because

 the petition was incomplete and because this substance was

 ineligible to be added to 205.606 because it is not

 agricultural.

 As for public comments, we only received three. Most

 comments just stated that they needed to wait until the TR was 
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 complete and reviewable to be able to provide full comments.

 Two comments did state -- or two commenters did state that if

 the petition -- or what we should stick to the petitioned use

 basically and annotate as such to limit the use for -- only for

 use in organic chicory production. One commenter stated that

 they did do a preliminary review. And based on that, there was

 no hazards that were revealed. But, again, it was preliminary

 and that they wanted to wait to fully evaluate the material

 once the TR was made public.

 The Handling Subcommittee did receive the TR at the

 end of August and we deemed it sufficient, but I have not taken

 a deep dive into the TR yet so don't ask me too many hard

 questions. That's it.

 CHAIR POWELL-PALM: Questions? Discussion for Kyla?

 Franklin.

 BOARD MEMBER QUARCOO: Yes. There is a comment here

 or something within here about it appears silicon dioxide is

 currently used as an alternative. But then they -- either they

 use nanotechnology, which is not allowed. Do we have some kind

 of information on whether they use nanotechnology for the

 silicon dioxide?

 BOARD MEMBER SMITH: Nanotech is prohibited. So I

 think we'll get -- maybe hopefully we'll get some more

 information about that in the TR. That was made -- a comment

 made by the petitioner and I don't know whether or not there is 
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 merits to those claims. So hopefully we'll perhaps get some

 information from the TR, but nanotech is prohibited. There is

 a policy member in the program handbook that states as much.

 So --

 CHAIR POWELL-PALM: Any other questions, comments?

 All right.

 BOARD MEMBER SMITH: Okay. Moving onto sunsets, we

 are going to start off with calcium carbonate. Calcium

 carbonate is listed at 205.605(a)(6), non-synthetics allowed.

 And this is Kim.

 BOARD MEMBER HUSEMAN: Thank you, Kyla. Okay, sorry,

 I thought we had more discussion. I was not quite prepared.

 Okay, here we go. So good morning. Good morning everybody in

 the audience. I really appreciate everybody still being here.

 This one is going to be very riveting.

 So calcium carbonate. The spring comments, I'm going

 to refer back to the spring comments because that's where we

 saw the most amount of comments. But this had a very diverse

 background of commenters that really spoke to the vast uses for

 calcium carbonate in organic production, from juice production

 to sauces, dressings. Calcium carbonate has a wide variety of

 uses. One certifier mentioned that there's over 70

 applications for use of calcium carbonate. And overwhelmingly

 there was support for relisting.

 There was a comment made about listing all -- to 
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 annotate listing all of the uses eventuality. Sometimes, I

 think we can limit ourselves almost too much, especially with a

 product that can get widely used. But that being said, there

 seems to be a significant support for calcium carbonate to

 remain on the National List.

 Any questions?

 CHAIR POWELL-PALM: Questions for Kim? All right,

 we'll go to the motion.

 BOARD MEMBER SMITH: The motion to remove calcium

 carbonate from the National List was made by Kim and seconded

 by Wood.

 CHAIR POWELL-PALM: I am trying to remember where we

 ended yesterday.

 BOARD MEMBER QUARCOO: It was me.

 CHAIR POWELL-PALM: Was it you? Okay. So we're

 going to start the voting with Logan.

 BOARD MEMBER QUARCOO: No, with me.

 CHAIR POWELL-PALM: Oh, oh, it was Franklin was last,

 okay.

 BOARD MEMBER QUARCOO: Yeah, that's right.

 CHAIR POWELL-PALM: What did you vote, please?

 BOARD MEMBER QUARCOO: No.

 CHAIR POWELL-PALM: Logan?

 BOARD MEMBER PETREY: No.

 CHAIR POWELL-PALM: Carolyn? 
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 BOARD MEMBER DIMITRI: No.

 CHAIR POWELL-PALM: Allison?

 BOARD MEMBER JOHNSON: No.

 CHAIR POWELL-PALM: Brian?

 BOARD MEMBER CALDWELL: No.

 CHAIR POWELL-PALM: Nate?

 BOARD MEMBER LEWIS: No.

 CHAIR POWELL-PALM: Dilip?

 BOARD MEMBER NANDWANI: No.

 CHAIR POWELL-PALM: Gerry?

 BOARD MEMBER D'AMORE: No.

 CHAIR POWELL-PALM: Kyla?

 BOARD MEMBER SMITH: No.

 CHAIR POWELL-PALM: Amy?

 SECRETARY BRUCH: No.

 CHAIR POWELL-PALM: Kim?

 BOARD MEMBER HUSEMAN: No.

 CHAIR POWELL-PALM: Franklin?

 BOARD MEMBER QUARCOO: No.

 CHAIR POWELL-PALM: And the Chair votes no.

 SECRETARY BRUCH: Zero yes, 13 no, zero abstentions,

 zero recusals, 2 absent. The motion fails.

 BOARD MEMBER SMITH: Oops, wrong button. Okay.

 Moving onto flavors. So this is at 205.605(a)(12), flavors,

 non-synthetic flavors may be used when organic flavors are not 
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 commercially available. All flavors must be derived from

 organic or non-synthetic sources only and must be produced

 using synthetic solvents and carrier systems or any artificial

 preservative. And this material is Logan's.

 BOARD MEMBER PETREY: All right, let's spice it up a

 bit with flavors. All right, okay. So flavors are broadly

 distinguished between natural and artificial, which are defined

 by the FDA. And commoners were concerned that the FDA

 definition of natural flavor includes fermentation products.

 Since more fermentation processes are using excluded methods,

 this is another potential loophole for excluded methods to make

 their way into organic products. That was a comment listed I

 think twice in the written comments.

 But from the TR on that issue, a growing number of

 compounds previously derived from wild sources are being

 produced synthetically or through the fermentation of

 genetically modified organisms. The FDA has declined to

 address the identification and labeling of flavors obtained

 from genetically modified organisms. Most of the sources would

 be considered excluded from organic production and handling by

 the excluded method prohibition at 205.105(e).

 Non-synthetic, non-agricultural ingredients may also

 be derived from microbial fermentation, such as yeast

 flavoring. As discussed below, a growing number of

 fermentation flavor ingredients use production methods excluded 
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 from organic production and handling. Yeast and potentially

 other fermentation organisms can produce organically.

 The use of these -- this material and natural flavors

 are widely used in organic industry for things such as baked

 goods, dairy products, jams, snacks, and juices. The main

 function is to affect flavor, not nutrition.

 One of the commenters said that flavors added to

 finished organic products are generally mixtures of individual

 substances referred to flavor ingredients, whose primary

 purpose is to provide all or part of specific flavor effects to

 food products and to facilitate the function of the flavoring

 substances in the mixture. These flavor mixtures are also

 called compound flavors or flavor systems and are custom

 developed to provide a particular taste. So that means flavors

 can be quite complex, is what that is getting to.

 Manufacturing. Flavors can be derived via several

 different methods, like cold pressing, solvent extraction,

 distillation, fermentation, and from many sources like wild

 plants and animals, botanicals, herbs, algae, fungi. Multiple

 commenter state in written comments manufacturers should

 document in their organic handling plans, progress towards

 wholly organic natural flavors. And can you all hear me over

 that? I don't have a volume on this thing.

 Okay. Organic sources. We heard from one oral

 commenter stating that there has been progress in two organic 
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 flavors, the ethylene acetate and the benzaldehyde. I would

 like to read a lengthy comment from Flavor Extract

 Manufacturing Association describing obstacles around sourcing

 organic flavors.

 The quantity of available certified organic flavors

 is limited by the underdeveloped and unstable downstream raw

 material supply market. Until the market for organic raw

 material and flavor ingredients is more fully developed, flavor

 manufacturers will continue to struggle to obtain a consistent

 quantity of raw materials to produce organic certified flavors.

 An example that was given was the grapefruit

 industry. Because of the greening and because of natural

 disasters, the organic grapefruit industry, particularly in

 Florida, has crashed. And so getting those materials

 consistently has become a problem.

 Another comment was from a dairy products producer.

 That says we've been working diligently ever since annotation

 to pursue organic flavors whenever possible. Our processes

 include reaching out to flavor vendors, continuously screening

 new certified organic flavors for existing or new products, and

 we've been successful at converting about 40 percent of our

 flavors to organic so far. But the process is time consuming

 for our product research and development team. The main

 limitations to converting flavors are difficult to achieve the

 desired flavor profile and intensity, and the constraint of a 
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 low flashpoint in organic flavors does make the use in

 pasteurized fruit and preparation very challenging.

 And other comments or to summarize the comments,

 there were -- I don't think there were any opposing. There was

 one from a consumer that didn't make a very clear stance.

 However, all other comments were in support of relisting

 flavors and they were in support of the new annotation, and

 were advising the NOSB to continue the work in organic flavor

 sourcing.

 Are there any questions?

 CHAIR POWELL-PALM: Questions for Logan? Gerry?

 BOARD MEMBER D'AMORE: Not a question. If I remember

 at subcommittee, it had an issue that the colors had as well,

 and that is that sourcing a flavor from one spot, the same

 flavor from another spot, sometimes they didn't mix very well.

 So that was one of the limiting factors, how they do or do not

 bundle the other.

 BOARD MEMBER PETREY: Thank you.

 CHAIR POWELL-PALM: Any other questions for Logan?

 We'll go to the motion.

 BOARD MEMBER SMITH: The motion to remove flavors

 from the National List was made by Logan, seconded by Kyla

 Smith, myself. And --

 CHAIR POWELL-PALM: And Logan is going to be the

 first to vote. 
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 BOARD MEMBER PETREY: No.

 CHAIR POWELL-PALM: Carolyn?

 BOARD MEMBER DIMITRI: No.

 CHAIR POWELL-PALM: Allison?

 BOARD MEMBER JOHNSON: No.

 CHAIR POWELL-PALM: Brian?

 BOARD MEMBER CALDWELL: No.

 CHAIR POWELL-PALM: Nate?

 BOARD MEMBER LEWIS: No.

 CHAIR POWELL-PALM: Dilip?

 BOARD MEMBER NANDWANI: No.

 CHAIR POWELL-PALM: Gerry?

 BOARD MEMBER D'AMORE: No.

 CHAIR POWELL-PALM: Kyla?

 BOARD MEMBER SMITH: No.

 CHAIR POWELL-PALM: Amy?

 SECRETARY BRUCH: No.

 CHAIR POWELL-PALM: Kim?

 BOARD MEMBER HUSEMAN: No.

 CHAIR POWELL-PALM: Franklin?

 BOARD MEMBER QUARCOO: No.

 CHAIR POWELL-PALM: Wood?

 BOARD MEMBER TURNER: No.

 CHAIR POWELL-PALM: Logan -- oh, sorry. And the

 Chair votes no. 
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 BOARD MEMBER PETREY: I had pregnancy brain,

 yesterday. That is not --

 CHAIR POWELL-PALM: Just trying to spread it around.

 (Laughter.)

 BOARD MEMBER PETREY: It is contagious, I hear. My

 husband said.

 SECRETARY BRUCH: Zero yes, 13 no, zero abstentions,

 zero recusals, 2 absent. The motion fails.

 BOARD MEMBER SMITH: Okay. We are now going into the

 gums. So Carolyn, bless her, took on all the gums. And so I

 believe she's going to talk about them all together. I'm going

 to read them in and then pass, pass it to, to you, Carolyn. So

 we have at 205.605(a)(13), gellan gum, high-acyl form only. We

 have at 205.605(b)(37), xanthan gum. We have at 205.606 --

does that say J? I can't see -- (j), gums, water extracted

 only, arabic, guar, locus bean, and carob bean. And we have at

 205.606(r), tamarind seed gum. I think I got them all. Okay,

 back to -- oh, thank you. And 205.605(s), tragacanth gum.

 Okay. Now we go backwards. Go ahead, Carolyn. I'll

 get there.

 BOARD MEMBER DIMITRI: Okay, great. I feel like I

 really understand processed organic products now and I will

 never look at them the same. So we have seven gums in five

 different listings. And they basically serve a process of

 thickening and gelling or stabilizing, emulsifying, and a few 
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 others. And each gum has its own special quality, so you can't

 swap them out one for one.

 So, for example, gellan gum is used for thickening

 and gelling. Xanthan gum is an important part of gluten-free

 products. And guar gum is used in ice cream, yogurt, and other

 dairy products.

 So the public comments were basically organized

 around essentiality and organic availability. And the public

 comments also revealed that at least from what we've received

 that xanthan gum is the most commonly used of all these gums.

 One processor said that they replaced carrageenan with gellan

 gum. Another processor, a dairy processor uses organic guar

 gum. And another organic dairy processor was able to find

 organic carob bean gum, but they've had some supply issues.

 The few suggestions that we received were to break

 out the water extracted gums into three separate listings, to

 provide guidance on fermentation, from which other ingredients

 have reported the same guidance, and to disclose confidential

 business information. But overall there was support for

 relisting all of the gums.

 CHAIR POWELL-PALM: Questions? Comments? Amy?

 SECRETARY BRUCH: Carolyn, thank you for that nice

 review. The gellan gum in particular I thought was

 interesting. One stakeholder's comment that said when compared

 to carrageenan, gellan gum is preferred by customers. I know 
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 when we reviewed carrageenan the last time, we had quite a bit

 of discussion on that particular substance. Does it make sense

 since carrageenan looks like a very complimentary substance to

 the gums that we try to get review of carrageenan in a similar

 sequence to these gums? Are there other products similar to

 these gums outside of carrageenan in handling when you look at

 alternatives?

 BOARD MEMBER DIMITRI: I have a feeling that Kyla has

 a lot more knowledge on that topic than I have. I mean I guess

 carrageenan has its own set of issues, which we probably don't

 want to talk about since -- I don't know. What do you think,

 Kyla? I'm going to stop talking.

 BOARD MEMBER SMITH: I mean I do think it makes sense

 to put carrageenan on the same cycle. I'm -- without looking,

 I don't -- without looking at the list, nothing is coming like

 to the top of my head at this moment.

 SECRETARY BRUCH: Yeah, no problem. I just thought,

 I mean, we kind of step back and look at sunsets and a few

 other subcommittees. And sometimes, I don't know, when we're

 looking at alternatives and when we review these out of

 sequence, it's a little bit challenging that maybe we get a lot

 more aggregated comments that one is superior over the other

 and maybe we don't need all these options. I don't know. It

 would be interesting.

 BOARD MEMBER SMITH: Yes. I guess I don't know how 
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 we'd make that recommendation. But I'm sure it can be

 reorganized. I'm not sure it would change the outcome of

 people's stances, but it would be good to talk about them all

 at once.

 CHAIR POWELL-PALM: Nate?

 BOARD MEMBER LEWIS: I think for me on these

 substances it really comes down to sort of consumer preference.

 And from the reading I did, many of them are used to prevent

 chalky mouth feel in products. And that's something that

 consumers sometimes want to choose. But then when I look at

 the options that I have available to me, kind of both at my

 crunchy hippie store, food co-op, as well as the main grocery

 store, Safeway, there's a lot of options that advertise no guar

 gum, no carrageenan, no whatever. So those are all kind of

 adjacent to one another, so I feel like the necessity is there.

 The essentiality is there to prevent some of these features

 that folks are trying to avoid and that the alternatives

 without these products are also available in the marketplace.

 So I support relisting.

 CHAIR POWELL-PALM: Amy?

 SECRETARY BRUCH: Well, the only other comment that I

 -- that kind of struck me is when we look at commercial

 availability, when we're switching or trying to switch folks

 from synthetic to organic products when they are available,

 there was a comment made about how difficult small 
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 manufacturers have of sourcing some of these organics.

 Sometimes, there is a minimum run quantity. So, yeah, I mean

 when we look at flavors or gums, I just think we need to put

 that in the back of our head, too, on minimum run quantities

 for things.

 CHAIR POWELL-PALM: Franklin?

 BOARD MEMBER QUARCOO: I see a fermentation step for

 gums and my question is, is there a possibility of excluded

 methods being involved.

 BOARD MEMBER DIMITRI: I mean I think that's a

 concern that several commenters have raised. And I believe our

 initial solution to that is a modification to a document that

 Nate did. And maybe, Nate, you can fill us in with that

 information?

 BOARD MEMBER LEWIS: Sure, yeah. This is a

 collaborative effort with Mindy. And I would have deferred to

 her as the lead on that on the Material Subcommittee. But we

 are looking at updating the TR template to specifically ask

 questions related to the use of excluded methods in

 fermentation products. So the way that TRs are often used by

 the certifier community is they, when evaluating a particular

 ingredient for a particular product and its compliance with

 organic regulations -- I'm going to be eating a lot of candy

 today. They, they look to those TRs as a -- as a resource for

 determining whether or not a particular ingredient has been 
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 produced using excluded methods. And the TR doesn't explicitly

 ask when in the process those excluded methods may have been

 used. So that's what our -- we're trying to put a finer point

 on the questions the TRs are asking so that that resource is

 publicly available and certifiers can utilize it when

 evaluating specific ingredients for product composition

 approvals.

 BOARD MEMBER PETREY: Thank you.

 CHAIR POWELL-PALM: Other questions or comments? All

 right, let's go to the motion.

 BOARD MEMBER SMITH: Okay. So we will vote on these

 separately. So the motion to remove gellan gum from the

 National List was made by Carolyn and seconded by Nate Lewis.

 CHAIR POWELL-PALM: And we're going to start with

 Carolyn.

 BOARD MEMBER DIMITRI: No. I was trying to remember

 what the vote was.

 CHAIR POWELL-PALM: Allison?

 BOARD MEMBER JOHNSON: No.

 CHAIR POWELL-PALM: Brian?

 BOARD MEMBER CALDWELL: No.

 CHAIR POWELL-PALM: Nate?

 BOARD MEMBER LEWIS: No.

 CHAIR POWELL-PALM: Dilip?

 BOARD MEMBER NANDWANI: No. 
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 CHAIR POWELL-PALM: Gerry?

 BOARD MEMBER D'AMORE: No.

 CHAIR POWELL-PALM: Kyla?

 BOARD MEMBER SMITH: No.

 CHAIR POWELL-PALM: Amy?

 SECRETARY BRUCH: No.

 CHAIR POWELL-PALM: Kim?

 BOARD MEMBER HUSEMAN: No.

 CHAIR POWELL-PALM: Franklin?

 BOARD MEMBER QUARCOO: No.

 CHAIR POWELL-PALM: Wood?

 BOARD MEMBER TURNER: No.

 CHAIR POWELL-PALM: Logan?

 BOARD MEMBER PETREY: No.

 CHAIR POWELL-PALM: And the Chair votes no.

 SECRETARY BRUCH: Zero yes -- sorry. Zero yes, 13

 no, zero abstentions, zero recusals, 2 absent. The motion

 fails.

 BOARD MEMBER SMITH: Okay. Now we will vote on

 xanthan gum, the motion to remove xanthan gum from the National

 List was motion by Carolyn, seconded by Kim.

 CHAIR POWELL-PALM: We'll start with Allison.

 BOARD MEMBER JOHNSON: No.

 CHAIR POWELL-PALM: Brian?

 BOARD MEMBER CALDWELL: No. 
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 CHAIR POWELL-PALM: Nate?

 BOARD MEMBER LEWIS: No.

 CHAIR POWELL-PALM: Dilip?

 BOARD MEMBER NANDWANI: No.

 CHAIR POWELL-PALM: Gerry?

 BOARD MEMBER D'AMORE: No.

 CHAIR POWELL-PALM: Kyla?

 BOARD MEMBER SMITH: No.

 CHAIR POWELL-PALM: Amy?

 SECRETARY BRUCH: No.

 CHAIR POWELL-PALM: Kim?

 BOARD MEMBER HUSEMAN: No.

 CHAIR POWELL-PALM: Franklin?

 BOARD MEMBER QUARCOO: No.

 CHAIR POWELL-PALM: Wood?

 BOARD MEMBER TURNER: No.

 CHAIR POWELL-PALM: Logan?

 BOARD MEMBER PETREY: No.

 CHAIR POWELL-PALM: Carolyn?

 BOARD MEMBER DIMITRI: No.

 CHAIR POWELL-PALM: And the Chair votes no.

 SECRETARY BRUCH: Zero yes, 13 no, zero abstentions,

 zero recusals, 2 absent. The motion fails.

 BOARD MEMBER SMITH: Okay. The motion to remove

 gums, water extracted only, arabic, guar, locus bean, and carob 
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 bean, from the National List was made by Carolyn and seconded

 by Gerry.

 CHAIR POWELL-PALM: We'll start with Brian.

 BOARD MEMBER CALDWELL: No.

 CHAIR POWELL-PALM: Nate?

 BOARD MEMBER LEWIS: No.

 CHAIR POWELL-PALM: Dilip?

 BOARD MEMBER NANDWANI: No.

 CHAIR POWELL-PALM: Gerry?

 BOARD MEMBER D'AMORE: No.

 CHAIR POWELL-PALM: Kyla?

 BOARD MEMBER SMITH: No.

 CHAIR POWELL-PALM: Amy?

 SECRETARY BRUCH: No.

 CHAIR POWELL-PALM: Kim?

 BOARD MEMBER HUSEMAN: No.

 CHAIR POWELL-PALM: Franklin?

 BOARD MEMBER QUARCOO: No.

 CHAIR POWELL-PALM: Wood?

 BOARD MEMBER TURNER: No.

 CHAIR POWELL-PALM: Logan?

 BOARD MEMBER PETREY: No.

 CHAIR POWELL-PALM: Carolyn?

 BOARD MEMBER DIMITRI: No.

 CHAIR POWELL-PALM: Allison? 
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 BOARD MEMBER JOHNSON: No.

 CHAIR POWELL-PALM: And the Chair votes no.

 SECRETARY BRUCH: Zero yes, 13 no, zero abstentions,

 zero recusals, 2 absent. The motion fails.

 BOARD MEMBER SMITH: The motion to remove tamarind

 seed gum from the National List was made by Carolyn, seconded

 by Allison.

 CHAIR POWELL-PALM: Let's start with Nate.

 BOARD MEMBER LEWIS: No.

 CHAIR POWELL-PALM: Dilip?

 BOARD MEMBER NANDWANI: No.

 CHAIR POWELL-PALM: Gerry?

 BOARD MEMBER D'AMORE: No.

 CHAIR POWELL-PALM: Kyla?

 BOARD MEMBER SMITH: No.

 CHAIR POWELL-PALM: Amy?

 SECRETARY BRUCH: No.

 CHAIR POWELL-PALM: Kim?

 BOARD MEMBER HUSEMAN: No.

 CHAIR POWELL-PALM: Franklin?

 BOARD MEMBER QUARCOO: No.

 CHAIR POWELL-PALM: Wood?

 BOARD MEMBER TURNER: No.

 CHAIR POWELL-PALM: Logan?

 BOARD MEMBER PETREY: No. 
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 CHAIR POWELL-PALM: Carolyn?

 BOARD MEMBER DIMITRI: No.

 CHAIR POWELL-PALM: Allison?

 BOARD MEMBER JOHNSON: No.

 CHAIR POWELL-PALM: Brian?

 BOARD MEMBER CALDWELL: No.

 CHAIR POWELL-PALM: And the Chair votes no.

 SECRETARY BRUCH: Zero yes, 13 no, zero abstentions,

 zero recusals, 2 absent. The motion fails.

 BOARD MEMBER SMITH: The motion to remove tragacanth

 gum from the National List was made by Carolyn, seconded by

 Kyla, myself.

 CHAIR POWELL-PALM: Let's start the voting with

 Dilip.

 BOARD MEMBER NANDWANI: No.

 CHAIR POWELL-PALM: Gerry?

 BOARD MEMBER D'AMORE: No.

 CHAIR POWELL-PALM: Kyla?

 BOARD MEMBER SMITH: No.

 CHAIR POWELL-PALM: Amy?

 SECRETARY BRUCH: No.

 CHAIR POWELL-PALM: Kim?

 BOARD MEMBER HUSEMAN: No.

 CHAIR POWELL-PALM: Franklin?

 BOARD MEMBER QUARCOO: No. 
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 CHAIR POWELL-PALM: Wood?

 BOARD MEMBER TURNER: No.

 CHAIR POWELL-PALM: Logan?

 BOARD MEMBER PETREY: No.

 CHAIR POWELL-PALM: Carolyn?

 BOARD MEMBER DIMITRI: No.

 CHAIR POWELL-PALM: Allison?

 BOARD MEMBER JOHNSON: No.

 CHAIR POWELL-PALM: Brian?

 BOARD MEMBER CALDWELL: No.

 CHAIR POWELL-PALM: Nate?

 BOARD MEMBER LEWIS: No.

 CHAIR POWELL-PALM: And the Chair votes no.

 SECRETARY BRUCH: Zero yes, 13 no, zero abstentions,

 zero recusals, 2 absent. The motion fails. It's like speed

 voting.

 BOARD MEMBER SMITH: Okay. We will move onto oxygen.

 Oxygen is 205.605(a)(21), oxygen oil-free grades. And this is

 Wood.

 BOARD MEMBER TURNER: Shout out to oxygen. I hope

 everybody gets outside and enjoys a walk today. This is a

 substance that we all know and love. It's used in modified

 atmosphere packaging. It is odorless and tasteless -- what's

 wrong? You can't hear me? Okay, sorry. Thank you. It helps

 to prevent spoilage in products, has been unanimously relisted 
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 in the past. Discussion was very limited at the last meeting.

 We heard from five commenters. Everyone either supports it or

 has no concerns from their members. I think that's it.

 CHAIR POWELL-PALM: Questions for Wood on oxygen?

 Hearing none, let's please read the motion.

 BOARD MEMBER SMITH: The motion to remove oxygen from

 the National List was made by Wood, seconded by Kyla, myself.

 CHAIR POWELL-PALM: And we'll go to the votes

 starting with Gerry.

 BOARD MEMBER D'AMORE: No.

 CHAIR POWELL-PALM: Kyla?

 BOARD MEMBER SMITH: No.

 CHAIR POWELL-PALM: Amy?

 SECRETARY BRUCH: No.

 CHAIR POWELL-PALM: Kim?

 BOARD MEMBER HUSEMAN: No.

 CHAIR POWELL-PALM: Franklin?

 BOARD MEMBER QUARCOO: No.

 CHAIR POWELL-PALM: Wood?

 BOARD MEMBER TURNER: No.

 CHAIR POWELL-PALM: Logan?

 BOARD MEMBER PETREY: No.

 CHAIR POWELL-PALM: Carolyn?

 BOARD MEMBER DIMITRI: No.

 CHAIR POWELL-PALM: Allison? 
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 BOARD MEMBER JOHNSON: No.

 CHAIR POWELL-PALM: Brian?

 BOARD MEMBER CALDWELL: No.

 CHAIR POWELL-PALM: Nate?

 BOARD MEMBER LEWIS: No.

 CHAIR POWELL-PALM: Dilip?

 BOARD MEMBER NANDWANI: No.

 CHAIR POWELL-PALM: And the Chair votes no.

 SECRETARY BRUCH: Zero yes, 13 no, zero abstentions,

 zero recusals, 2 absent. The motion fails.

 BOARD MEMBER SMITH: The next material is potassium

 chloride. Potassium chloride is 205.605(a)(23), potassium

 chloride. This is also Wood.

 BOARD MEMBER TURNER: Reminder that potassium

 chloride was something we voted on yesterday, prohibited in

 crops. But listed -- allowed in handling and generally enjoys

 strong support from commenters. We had a group of seven

 commenters, all of whom supported continued listing or talked

 about the use of the material in OSPs. Some discussion we've

 had historically about use annotations potentially, but

 generally support.

 It's a substance that is a flavor enhancer, flavoring

 agent, helps provide a salty flavor in products. Supports

 taste, texture, and shelf-life in food products. Has been

 unanimously supported for relisting in the past. And 
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 discussion has been similar to that by this Board. Again,

 strong support from the community.

 CHAIR POWELL-PALM: Questions for Wood? All right,

 we'll go to the motion.

 BOARD MEMBER SMITH: The motion to remove potassium

 chloride from the National List was made by Wood and seconded

 by Nate Lewis.

 CHAIR POWELL-PALM: We'll start the vote with you,

 Kyla.

 BOARD MEMBER SMITH: No.

 CHAIR POWELL-PALM: Amy?

 SECRETARY BRUCH: No.

 CHAIR POWELL-PALM: Kim?

 BOARD MEMBER HUSEMAN: No.

 CHAIR POWELL-PALM: Franklin?

 BOARD MEMBER QUARCOO: No.

 CHAIR POWELL-PALM: Wood?

 BOARD MEMBER TURNER: No.

 CHAIR POWELL-PALM: Logan?

 BOARD MEMBER PETREY: No.

 CHAIR POWELL-PALM: Carolyn?

 BOARD MEMBER DIMITRI: No.

 CHAIR POWELL-PALM: Allison?

 BOARD MEMBER JOHNSON: No.

 CHAIR POWELL-PALM: Brian? 
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 BOARD MEMBER CALDWELL: No.

 CHAIR POWELL-PALM: Nate?

 BOARD MEMBER LEWIS: No.

 CHAIR POWELL-PALM: Dilip?

 BOARD MEMBER NANDWANI: No.

 CHAIR POWELL-PALM: And Gerry?

 BOARD MEMBER D'AMORE: No.

 CHAIR POWELL-PALM: And the Chair votes no.

 SECRETARY BRUCH: Zero yes, 13 no, zero abstentions,

 zero recusals, 2 absent. The motion fails.

 BOARD MEMBER SMITH: Now we will go to alginates.

 Alginates are listed at 205.605(b)(3), alginates. And this is

 Dilip's material.

 BOARD MEMBER NANDWANI: Thanks, Kyla. Good morning,

 again. Still pretty straight-forward. So alginates are used

 in food production and handling, and an emulsifier, or

 emulsifier salt, firming agent, flavor enhancer or flavor

 adjuvant, formulation aid, processing aid, stabilizer or

 thickener. The use of alginates is also known in industrial

 applications and the medical field.

 They are produced from algin and are usually

 extracted from the sand bars of brown algae. Commercial

 alginates are isolated mainly from the algin species, namely

 laminaria hyperborea, laminaria digitata, laminaria japonica,

 as for file and species, and there are a few other species. 
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 They are listed in the document.

 Seaweed cultivation is largely considered to be an

 environmentally friendly form of agriculture. And we are not

 aware of any evidence that the harvesting practices for brown

 seaweed are damaging to local ecosystems.

 Previous sunset review demonstrated a continued need

 for this material. And public comments from the spring 2023

 meeting support relisting of alginates at 205.605(b).

 From the comment docket, I'm going to read this one

 comment, quote, "Alginates are a versatile ingredient that

 provide unique stabilizing properties. In response to Handling

 Subcommittee questions, the International Food Additives

 Council, IFAC, expects that there will be increased organic

 community interest in sodium alginate in particular based on

 its use in meat alternative products," end quote.

 So the question we asked the stakeholders was what

 forms of alginate are currently being used in organic

 production. And we got public comments illustrating that given

 the growing interest in plant-based meat alternatives, sodium

 alginate would be of particular interest of relisting. The

 subcommittee discussion centered on the current forms of

 alginates that are being used in organic production. Thank

 you.

 CHAIR POWELL-PALM: Thank you. Questions for Dilip?

 Amy? 
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 SECRETARY BRUCH: Dilip, I just have a general 

 question. You mentioned the public comment. That was really

 interesting. Can you comment how bit the organic nonmeat space

 is, alternative meat products? I'm just not familiar with that

 being in Nebraska. Thank you.

 BOARD MEMBER NANDWANI: Kyla also maybe can add, but

 what my understanding is that I think there is a growing

 interest in plant-based meat alternatives. That's my

 understanding. And since I am this area, I have seen some

 products in the grocery stores, as well. This is just my

 personal observation.

 SECRETARY BRUCH: Yeah, I'm familiar the space is

 growing, but I didn't know an organic sector of that space, the

 processing and all the additives. I was just curious, because

 I saw on some other public comments they said, well, we don’t

 need this now, but we're going to be innovating in the future.

 So I was just trying to understand is that where the innovation

 is coming from, in the organic alternative meat space.

 BOARD MEMBER NANDWANI: That's my understanding is

 that, yes. That's a good question. Kyla, I think you want to

 add something?

 BOARD MEMBER SMITH: I think what you just said is

 accurate. Just, yes, I don't -- I don't think -- I don’t think

 PCO certified any like plant-based meat alternatives currently.

 And I do think that you're right that like some of the 
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 ingredients are not compatible with organic production. But

 that is an opportunity for development.

 BOARD MEMBER NANDWANI: Correct.

 SECRETARY BRUCH: Okay. That's how I kind of

 understood. If you give us this, maybe the production will

 come or something like that. Because it's not like there was

 more innovation. It didn't seem like there was anybody

 necessarily using this, at this time --

 BOARD MEMBER NANDWANI: Right. I think it's still in

 infancy.

 SECRETARY BRUCH: -- from the public comments that I

 read.

 BOARD MEMBER NANDWANI: Yeah.

 CHAIR POWELL-PALM: Allison?

 BOARD MEMBER JOHNSON: Yeah, thank you. I mean this

 is a pet project dream of mine, so organic comportation burger,

 one of these days.

 SECRETARY BRUCH: And I just wanted to draw attention

 to one of the comments that asked us to look at the alginates

 at a more granular level so we could look at production areas

 and the environmental impact. I don't think we can do that

 through the sunset process. But as we're continuing to keep a

 list of annotations, we may want to look at like tweaks that

 could be made to the list. This is one that we should

 consider. 
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 CHAIR POWELL-PALM: Gerry?

 BOARD MEMBER D'AMORE: I just want to make a comment,

 but I think we're all clear there is an aspirational piece of

 this, which we just discussed. But it is -- it is used in the

 handling sphere, emulsifier, firming agent, flavor enhancer,

 etc. Thank you.

 CHAIR POWELL-PALM: Franklin?

 BOARD MEMBER QUARCOO: Yes. This is a follow-up to a

 question I asked you in the spring about seaweed being used for

 bioremediation. And then being used for the extraction of

 alginates. And I see here that there is a statement to the

 effect that it was determined that there are likely -- the ones

 that I used for the alginate extraction are likely from

 different sources. Am I to understand that this seaweed is

 seaweed. Wherever you find it, if it does bioremediation

 that's what it does. It goes fully in the soil, also. In the

 water, it will take it up.

 So am I to understand that this particular seaweed

 that is being used for alginate is being grown somewhere where

 they can ensure that there is nothing in there? Because if the

 statement is that it goes through a purification process so we

 assure there is nothing in it, I understand. But if it's grown

 from a different source, pollution is all over the place. The

 world is an equal opportunity. We are polluting every place.

 It's not like some places are better than others. But I'm just 
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 -- I just want to be sure where this being grown that makes

 them free of some of the thing that bio-remediating plants take

 from the water.

 CHAIR POWELL-PALM: Gerry?

 BOARD MEMBER D'AMORE: I can't answer that question.

 But I can say that the algae, themselves, is a purifier. So

 it's job or part of it's job is to take impurities out of the

 water. So I think the question is a strong question.

 CHAIR POWELL-PALM: Nate?

 BOARD MEMBER LEWIS: To your question, Franklin, the

 TR does -- to quote from the TR, it says commercial

 manufacturing of alginate almost always involves a purification

 step wherein acid treatment precipitates the alginate as

 alginic acid. It also mentions regular use of an ion exchange

 column for purification. So whether or not that removes

 potential contaminants or not, I think we may be able to infer

 that. But your comment was taken to heart in my review of

 this. And those steps alleviated some of those concerns for

 me.

 BOARD MEMBER QUARCOO: Thank you.

 CHAIR POWELL-PALM: Other questions for Dilip?

 Kayla?

 BOARD MEMBER SMITH: First, just a clarification,

 because I just noticed this typo myself and then Carolyn also

 noticed it. There was a typo where it says the alginates were 
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 added to the National List in 2022. And that's not correct.

 CHAIR POWELL-PALM: Good catch.

 BOARD MEMBER SMITH: I think it should have been

 2002. I think it's been listed since the original Final Rule

 was published. My question though is, Dilip, you -- and I saw

 this in the comments, as well, and you specifically noted that

 comments were received particularly on sodium alginate as a

 form. I didn't see any comments on the additional forms. Did

 you see anything related to those? And so I guess I'm just

 like wondering if that is the only form, if it's worth an

 annotation or not I guess is where I was going.

 BOARD MEMBER NANDWANI: Sure. First, yeah, that's a

 good catch and I saw this morning it's 2022 and wanted to

 brought to your attention that that's a typo. Going back to

 your question on sodium alginates, there was one comment in the

 stakeholders. I think we received 12 comments from

 stakeholders. And they were in favor of relisting. But one of

 the comment mentioned about the sodium alginates. And I have

 additional information here. I can read it. I don't know if

 you can also read about this regarding your question that we

 discussed in the subcommittee also. And I think that links to

 Franklin that the seaweed used to produce alginates that used

 for bioremediation and the potential for having a contamination

 (ph.) determined that these are likely from different sources.

 Additional, though, FDA, Food and Drug Administration 
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 regulates having micro-testing of sodium alginates and,

 therefore, the subcommittee is not considering the continued

 listing of alginates. That's all I have. I hope I added some

 information, if not full.

 BOARD MEMBER SMITH: Yeah. Just I don't know that we

 got a lot of public comments on other sources, so it would be

 interesting to continue to keep that as part of the discussion.

 CHAIR POWELL-PALM: Any other discussion? Thank you,

 Dilip. We'll go to the motion.

 BOARD MEMBER SMITH: Motion to remove alginates from

 the National List was motioned by Dilip, seconded by myself,

 Kyla.

 CHAIR POWELL-PALM: All right. Let me think for a

 second. It's going to be Amy is our first vote.

 SECRETARY BRUCH: No.

 CHAIR POWELL-PALM: Kim?

 BOARD MEMBER HUSEMAN: No.

 CHAIR POWELL-PALM: Franklin?

 BOARD MEMBER QUARCOO: Abstain.

 CHAIR POWELL-PALM: Wood?

 BOARD MEMBER TURNER: Abstain.

 CHAIR POWELL-PALM: Logan?

 BOARD MEMBER PETREY: No.

 CHAIR POWELL-PALM: Carolyn?

 BOARD MEMBER DIMITRI: No. 
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 CHAIR POWELL-PALM: Allison?

 BOARD MEMBER JOHNSON: No.

 CHAIR POWELL-PALM: Brian?

 BOARD MEMBER CALDWELL: Abstain.

 CHAIR POWELL-PALM: Nate?

 BOARD MEMBER LEWIS: No.

 CHAIR POWELL-PALM: Dilip?

 BOARD MEMBER NANDWANI: No.

 CHAIR POWELL-PALM: Gerry?

 BOARD MEMBER D'AMORE: No.

 CHAIR POWELL-PALM: Kyla?

 BOARD MEMBER SMITH: No.

 CHAIR POWELL-PALM: And the Chair votes no.

 SECRETARY BRUCH: Zero yes, 10 no, 3 abstentions,

 zero recusals, 2 absent. The motion fails.

 BOARD MEMBER SMITH: Okay. 205.605(b)(8) is calcium

 hydroxide. And this is also Dilip's material.

 BOARD MEMBER NANDWANI: Okay. Thanks again. Calcium

 hydroxide is used in food processing as a buffer neutralizing

 agent and firming agent processing. It is also used in making

 calcium acid phosphate and in nutrient supplements. Calcium

 hydroxide is produced through four steps. I'm not going to go

 into those details, but the first is the mining of limestone

 and then preparation of the limestone for the furnaces. And

 then calcium mining the limestone and then hydrodate (ph.), 
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 which is mixing with the water to make the quick lime.

 The temperature for this fourth step, while gas line

 for exit temperatures achieved in the home kitchen, which the

 NOSB has previously considered decisive integrin substances

 synthetic. So we have the new TR on calcium hydroxide.

 According to that we don't see any new techniques for the

 manufacture of calcium hydroxide new to that lab.

 Public comments. During the previous sunset review

 submitted by organic manufacturers, trade associations,

 material suppliers, and certifiers, detail calcium hydroxide

 use a necessity in the processing. The majority of public

 comments supported relisting of calcium hydroxide. One

 commenter suggested that NOSB clarify which uses of calcium

 hydroxide are permitted, specifically if calcium hydroxide can

 be used as a firming agent. Additional commenters stated that

 they use calcium hydroxide in infant formula.

 NOSB received 11 public comments all in favor of

 relisting of calcium hydroxide. The NOSB did not receive much

 response to the questions it asked in the spring review. A

 couple of commenters said that they are not aware of any

 commercially available alternatives. That's all I have.

 CHAIR POWELL-PALM: Thank you. Any questions or

 comments for Dilip on calcium hydroxide? All right, we'll go

 to the motion.

 BOARD MEMBER SMITH: The motion to remove calcium 
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 hydroxide from the National List was motioned by Dilip and

 seconded by Gerry.

 CHAIR POWELL-PALM: And we'll start the voting

 with Kim.

 BOARD MEMBER HUSEMAN: No.

 CHAIR POWELL-PALM: Franklin?

 BOARD MEMBER QUARCOO: No.

 CHAIR POWELL-PALM: Wood?

 BOARD MEMBER TURNER: No.

 CHAIR POWELL-PALM: Logan?

 BOARD MEMBER PETREY: No.

 CHAIR POWELL-PALM: Carolyn?

 BOARD MEMBER DIMITRI: No.

 CHAIR POWELL-PALM: Allison?

 BOARD MEMBER JOHNSON: No.

 CHAIR POWELL-PALM: Brian?

 BOARD MEMBER CALDWELL: No.

 CHAIR POWELL-PALM: Nate?

 BOARD MEMBER LEWIS: No.

 CHAIR POWELL-PALM: Dilip?

 BOARD MEMBER NANDWANI: No.

 CHAIR POWELL-PALM: Gerry?

 BOARD MEMBER D'AMORE: No.

 CHAIR POWELL-PALM: Kyla?

 BOARD MEMBER SMITH: No. 
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 CHAIR POWELL-PALM: Amy?

 SECRETARY BRUCH: No.

 CHAIR POWELL-PALM: And the Chair votes no.

 SECRETARY BRUCH: Zero yes, 13 no, zero abstentions,

 zero recusals, 2 absent. The motion fails.

 BOARD MEMBER SMITH: Okay. Next is ethylene. It's

 listed at 205.605(b)(14), ethylene allowed for post-harvest

 ripening of tropical fruit and degrading of citrus. And this

 is also -- Logan had ethylene in crops and she also took it on

 in handling as well. Logan?

 BOARD MEMBER PETREY: All right, because it's easy to

 take on the same one. Thank you, Kyla. Yes, okay. So

 ethylene, it's uses are for post-harvest handling. And we see

 this in bananas. We see this in avocados, mangoes, citrus

 fruits. We went over the manufacturing, the human and

 environmental health concerns, yesterday. So for time's sake,

 we'll go on, unless you have questions that also share the same

 TR.

 Historically, there was also a petition for the use

 in pears and that did not pass. There is a statement that

 there are no alternatives existing. The question was asked

 what would the impact be if ethylene was no longer allowed. A

 commenter stated because the fruit reaches internal maturity

 for shipment prior to reaching full color and fresh -- for

 fresh shipments, without ethylene would lose 30 to 60 days or 
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 1/3rd of our shipping season. These economic losses would

 devastate our company.

 That is because a lot of these fruits cannot be

 produced domestically and so we are sourcing these fruits. And

 these fruits are a huge part of our industry, the tropical

 fruits. And they are part of our American diet. I think it's

 on record my child eats a lot of bananas.

 Many of these fruits are not produced domestically

 and -- sorry, removal of ethylene as post-harvest treatment

 would create a major disruption in the supply chain. One

 advocacy group did say and state that they opposed the

 relisting and said that this material was not necessary for its

 listing. There is also -- there was also interest in possibly

 expanding its use to -- for sprouting, as a sprouting inhibitor

 for storage potatoes. A petition would be needed for this

 listing. Canadian and EU standards do allow this material as a

 sprout inhibitor for potatoes.

 CHAIR POWELL-PALM: Questions for Logan? Gerry,

 please go ahead.

 BOARD MEMBER D'AMORE: Thank you. I agree with

 everything that was said, but I forgot that, that it's actually

 as you went through it I think it's understated. I think

 there's some things that we just flat wouldn't have at all,

 bananas being one of them. My 10 years with Chiquita and

 worldwide shipping of bananas, they are shipped green. And 
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 they're not -- they're not ripe. The ripening process doesn't

 start at all until they reach destination and then they are

 ripened in a -- in a ripening room. And I can flat say bananas

 as we know them on our shelf today would not exist without it.

 CHAIR POWELL-PALM: Nate?

 BOARD MEMBER LEWIS: I think this is an interesting

 annotation that's sort of illustrative of the challenges of

 annotations in that when you use words like tropical that are

 somewhat vague, it makes the certification process a little bit

 harder. So what about an avocado grown north of the 23 1/2

 parallel. Is that a tropical fruit or not? And I think

 certifiers, they have the competence to make those

 determinations.

 But I think when I read between the lines, this

 annotation is to prohibit its use as a tomato ripener, but I

 don't know if that's true or not. So I think it's just a

 lesson in if we want to annotate, let's be extremely clear

 about what it is we're doing so that we take the guesswork out

 of making sure people are following the rules.

 BOARD MEMBER PETREY: I'm glad you mentioned that,

 because we did ask that in the spring comments, what are

 tropical fruits. And we, we got a list of some things that we,

 we still don’t have that strong definition. So that is a great

 point. CHAIR POWELL-PALM: Gerry?

 BOARD MEMBER D'AMORE: It's been a while since I've 
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 dealt with tomatoes. But I would still venture to guess that

 over 50 percent of all tomatoes consumed by us have gone

 through an ethylene ripening process.

 CHAIR POWELL-PALM: Any other questions or comments?

 All right, thank you, Logan. We'll go to the motion.

 BOARD MEMBER SMITH: The motion to remove ethylene

 from the National List was made by Logan and seconded by Gerry.

 CHAIR POWELL-PALM: We're going to start with

 Franklin.

 BOARD MEMBER QUARCOO: No.

 CHAIR POWELL-PALM: Wood?

 BOARD MEMBER TURNER: No.

 CHAIR POWELL-PALM: Logan?

 BOARD MEMBER PETREY: No.

 CHAIR POWELL-PALM: Carolyn?

 BOARD MEMBER DIMITRI: No.

 CHAIR POWELL-PALM: Allison?

 BOARD MEMBER JOHNSON: No.

 CHAIR POWELL-PALM: Brian?

 BOARD MEMBER CALDWELL: No.

 CHAIR POWELL-PALM: Nate?

 BOARD MEMBER LEWIS: No.

 CHAIR POWELL-PALM: Dilip?

 BOARD MEMBER NANDWANI: No.

 CHAIR POWELL-PALM: And Gerry? 
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 BOARD MEMBER D'AMORE: No.

 CHAIR POWELL-PALM: Kyla?

 BOARD MEMBER SMITH: No.

 CHAIR POWELL-PALM: Amy?

 SECRETARY BRUCH: No.

 CHAIR POWELL-PALM: Kim?

 BOARD MEMBER HUSEMAN: No.

 CHAIR POWELL-PALM: And the Chair votes no.

 SECRETARY BRUCH: Zero yes, 13 no, zero abstentions,

 zero recusals, 2 absent. The motion fails.

 BOARD MEMBER SMITH: The next material is glycerides,

 mono and di, at 205.605(b)(16). Glycerides, mono and di, for

 use only in drum drying of food. And this material is Allison.

 BOARD MEMBER JOHNSON: Thank you. So glycerides are

 components of fats. They are used as an emulsifier and release

 agent in drum drying processes in organic, so creating flakes

 or powders. I think this product is basically still on the

 list so that organic potato flakes exist. Back in 1995, the

 NOSB had noted that the food industry is moving away from this

 material, but it was still really needed for potato flake

 products.

 There are some potential alternatives, but apparently

 none are quite equivalent. And we've asked now spring and fall

 what organic products glycerides are used in and whether there

 are any alternatives. And we still haven't heard from anyone 
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 who actually uses the material or is aware of a specific

 organic product that uses it.

 We did have one commenter who ran a search in USDA's

 food data central data of branded foods, which I don't know

 anything about but looks interesting. And I tried to replicate

 their search. You can actually pull this huge list of branded

 products and their ingredients. I don't know why this list

 exists or how we might use it, but it seems interesting. So

 I'd love if someone brings it forward in the future to have

 them provide a little bit more context.

 But as far as I could tell, the numbers that this

 commenter put together are not actually certified organic

 products. They are products where there is maybe an organic

 ingredient or two in glycerides, so it doesn't help us figure

 out if organic products need this ingredient. I did spend some

 time on Google, probably more than a reasonable amount of time

 on Google trying to find if a product exists and I found one.

 And that manufacturer's website says that glycerides are

 necessary for their process. So we haven't heard directly from

 that producer, but they are making that statement to the

 public. And so I think there is an argument for keeping it.

 We did have a couple of commenters suggest that there

 may be organic agricultural alternatives, so I hope we can kind

 of put a pin in that and hope that next time around maybe we

 ask for an updated TR that looks at the technology again and 
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 really push on that potential commercial availability option,

 because there are also products that don't have glycerides that

 are marketed as organic potato flakes. So it seems possible,

 but I don't know. We don't have enough information about

 individual manufacturers' processes. Any questions?

 CHAIR POWELL-PALM: Wood. Then Amy.

 BOARD MEMBER TURNER: Thanks, Allison. So the

 product you found was potato flakes?

 BOARD MEMBER JOHNSON: Yeah, one organic potato

 flakes product with potatoes and mono and diglycerides as the

 ingredients.

 CHAIR POWELL-PALM: Amy?

 SECRETARY BRUCH: Allison, hi. Just a quick

 question. Thanks for that review. You mentioned in 1995, when

 this product was added, that the -- that the thought was that

 industry was going to move away from this. What were they

 going to move to?

 BOARD MEMBER JOHNSON: That's a good question. It

 said they were trying to move away from glycerides. And I

 think there are like some of the examples that came up are rice

 brand extract, soy lecithin, gum arabic. So there may be other

 emulsifiers and release agents that could work. And then maybe

 alternative processes that could work or a sort of more

 advanced drum drying technology. But we -- the last TR was in

 2015 and it didn't indicate that there was no longer a need. 
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 SECRETARY BRUCH: Thank you.

 CHAIR POWELL-PALM: Nate?

 BOARD MEMBER LEWIS: These are -- this is a

 processing aid, right? So -- or is it an ingredient?

 BOARD MEMBER JOHNSON: I guess it's an ingredient.

 It shows up on the label.

 BOARD MEMBER LEWIS: It does.

 BOARD MEMBER JOHNSON: Yeah.

 BOARD MEMBER LEWIS: In all cases? Like if I were to

 make organic, you know, organic Pringles with dehydrated potato

 flakes, would it also list mono/diglycerides?

 BOARD MEMBER JOHNSON: It's a good -- I don't know if

 there are instances where it does not show up on the label, but

 there are instances where it does show up on the label.

 BOARD MEMBER LEWIS: Okay. All right. Well, suffice

 it -- anyway, thank you.

 CHAIR POWELL-PALM: Brian?

 BOARD MEMBER CALDWELL: So this -- thank you for all

 your diligent work, Allison. In my mind, this is -- this is a

 real question of whether the material is essential or not. It

 sounds to me like it's not. And I guess, Allison, I have a

 question. Are there any health downsides with, with these

 materials?

 BOARD MEMBER JOHNSON: I don't think so. There

 wasn't anything particularly concerning for the environment or 
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 health noted in the TR. They are components of that. So fatty

 acid has -- it's like an arm and -- or like a backbone and

 three arms, so these are the arms. We cut them off. That

 sounds kind of -- it's just a molecule. But they are products

 of conventional agriculture, so presumably produced with

 synthetic inputs. So to the extent that there is an opinion to

 move away from that and toward an organic alternative, or just

 eliminate them from the organic supply chain completely has the

 benefits of shifting toward organic. But nothing particular

 concerning about it that weigh heavily against continuing to

 allow it.

 BOARD MEMBER CALDWELL: Thank you very much.

 CHAIR POWELL-PALM: Kim?

 BOARD MEMBER HUSEMAN: Allison, great review. As we

 look to try to identify who, where this is being used, and

 looking at the international acceptance, did you happen to poke

 into maybe some of the Canadian products? It looks like Canada

 has a permitted product. No other international acceptances

 were listed.

 BOARD MEMBER JOHNSON: I didn't dig very deep. Yeah,

 it's not consistent against our trade partners whether it's

 allowed or not. Like we're looking at a pretty small subset,

 it seems like. So, yeah, I don't have more information to

 share, sorry.

 BOARD MEMBER HUSEMAN: It's okay. Thank you, 
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 Allison.

 CHAIR POWELL-PALM: Nate?

 BOARD MEMBER LEWIS: Sorry to keep pushing this. But

 I did find Shiloh Farms on the -- is that the one? And it is

 PCO certified, so, with list as mono-diglycerides as an

 ingredient in it. So I may have resolved my earlier question.

 CHAIR POWELL-PALM: Brian?

 BOARD MEMBER CALDWELL: So sort of just a kind of

 procedural question. But if, if this is delisted, can it be

 repetitioned to be added back onto the list?

 CHAIR POWELL-PALM: Mm-hmm.

 BOARD MEMBER CALDWELL: Okay.

 CHAIR POWELL-PALM: Any other questions or comments

 before we go to the vote? Allison?

 BOARD MEMBER JOHNSON: Just responding to Brian.

 CHAIR POWELL-PALM: Sure.

 BOARD MEMBER JOHNSON: Or, yeah, to Brian. This room

 is starting to turn into a blur.

 CHAIR POWELL-PALM: Finally, someone else besides me.

 (Laughter.)

 BOARD MEMBER JOHNSON: I was kind of wresting with

 like, well, okay, if we pull it off, they have probably about

 two years to change process or come up with an alternative

 before it was actually pulled off the list, so there would be

 time to accommodate or to petition back. But the website of 
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 the one that I found did say explicitly we really need this.

 So do we make that one producer change or do we say, okay, one

 is enough. It's a hard call.

 CHAIR POWELL-PALM: I don't find it to be a hard

 call, only because it's just -- I mean how cool is it that we

 have someone trying to make organic potato chips. And it's --

and it's going to be a small producer. And I think it's very

 interesting that they took the opportunity to put that

 explanation on the website. Sure does make it a lot easier for

 us to understand its utility. Brian?

 BOARD MEMBER CALDWELL: But potato chips are

 different than potato flakes.

 CHAIR POWELL-PALM: Potato flakes, yeah.

 BOARD MEMBER CALDWELL: And I think there's a lot of

 organic potato chips.

 CHAIR POWELL-PALM: Mm-hmm.

 BOARD MEMBER JOHNSON: Yeah. And from what I can

 tell, it's also different from dried mashed potatoes.

 CHAIR POWELL-PALM: Good distinction. Nate?

 BOARD MEMBER LEWIS: This will be my last. But come

 on, Brian, organic Pringles? I mean --

 CHAIR POWELL-PALM: Any other thoughts before we go

 to the vote? All right. Kyla, please.

 BOARD MEMBER SMITH: The motion to remove glycerides,

 mono and di, from the National List was motioned by Allison and 
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 seconded by Gerry.

 CHAIR POWELL-PALM: And we're going to start with

 Wood.

 BOARD MEMBER TURNER: Abstain.

 CHAIR POWELL-PALM: Logan?

 BOARD MEMBER PETREY: No.

 CHAIR POWELL-PALM: Carolyn?

 BOARD MEMBER DIMITRI: No.

 CHAIR POWELL-PALM: Allison?

 BOARD MEMBER JOHNSON: No.

 CHAIR POWELL-PALM: Brian?

 BOARD MEMBER CALDWELL: Yes.

 CHAIR POWELL-PALM: Nate?

 BOARD MEMBER LEWIS: No.

 CHAIR POWELL-PALM: Dilip?

 BOARD MEMBER NANDWANI: No.

 CHAIR POWELL-PALM: Gerry?

 BOARD MEMBER D'AMORE: No.

 CHAIR POWELL-PALM: Kyla?

 BOARD MEMBER SMITH: No.

 CHAIR POWELL-PALM: Amy?

 SECRETARY BRUCH: No.

 CHAIR POWELL-PALM: Kim?

 BOARD MEMBER HUSEMAN: Abstain.

 CHAIR POWELL-PALM: Franklin? 
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 BOARD MEMBER QUARCOO: No.

 CHAIR POWELL-PALM: And the Chair votes no.

 BOARD MEMBER DIMITRI: I have to say, Nate, you

 really got me with the small producer angle. Like I was

 wavering and then you said that. I thought, yeah.

 CHAIR POWELL-PALM: I would just call out again how I

 so appreciate these discussions. This, I mean, in another

 world this could turn gnarly. And thank you, Brian, for

 bringing such a fair contemplation to the discussion. So I

 appreciate that.

 SECRETARY BRUCH: One yes, 10 no, 2 abstentions, zero

 recusals, 2 absent. The motion fails.

 BOARD MEMBER SMITH: Okay. Next up is magnesium

 stearate. Magnesium stearate is listed at 205.605(b)(19).

 Magnesium stearate for use only in agricultural products

 labeled made with organic, parentheses, specified ingredients

 or food groups, end parentheses, prohibited in agricultural

 products labeled organic. And this material is also Allison.

 BOARD MEMBER JOHNSON: Thank you. This is another

 like quite narrow use item. It's most commonly used as a

 binding agent in supplements or an anti-caking agent in

 powdered products. It's made from hydrogenation of fatty acids

 from edible sources that go through several chemical reactions.

 And again we asked in the spring and again in the fall how this

 product is being used by organic processors and whether there 
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 are any alternatives.

 For this one, we had one commenter say that they have

 three members who use magnesium stearate in pharmaceutical and

 dietary products. We got a couple of support generally and a

 couple of not particularly opposed. We did get one commenter

 who said that they'd like to see more information on the need

 for it and also pointed out the office as the -- the National

 List substances need to be listed by specific use or

 application. I think that was a comment that came up

 repeatedly. So that's something that we could consider. But

 in use, no particular opposition to continued use.

 CHAIR POWELL-PALM: Questions for Allison on

 magnesium stearate? All right, go to the motion.

 BOARD MEMBER SMITH: The motion to remove magnesium

 stearate from the National List was motioned by Allison,

 seconded by myself, Kyla.

 CHAIR POWELL-PALM: And we're going to start with

 Logan.

 BOARD MEMBER PETREY: No.

 CHAIR POWELL-PALM: Carolyn?

 BOARD MEMBER DIMITRI: No.

 CHAIR POWELL-PALM: Allison?

 BOARD MEMBER JOHNSON: No.

 CHAIR POWELL-PALM: Brian?

 BOARD MEMBER CALDWELL: No. 
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 CHAIR POWELL-PALM: Nate?

 BOARD MEMBER LEWIS: No.

 CHAIR POWELL-PALM: Dilip?

 BOARD MEMBER NANDWANI: No.

 CHAIR POWELL-PALM: Gerry?

 BOARD MEMBER D'AMORE: No.

 CHAIR POWELL-PALM: Kyla?

 BOARD MEMBER SMITH: No.

 CHAIR POWELL-PALM: Amy?

 SECRETARY BRUCH: No.

 CHAIR POWELL-PALM: Kim?

 BOARD MEMBER HUSEMAN: No.

 CHAIR POWELL-PALM: Franklin?

 BOARD MEMBER QUARCOO: No.

 CHAIR POWELL-PALM: Wood?

 BOARD MEMBER TURNER: No.

 CHAIR POWELL-PALM: And the Chair votes no.

 SECRETARY BRUCH: Zero yes, 13 no, zero abstentions,

 zero recusals, 2 absent. The motion fails.

 BOARD MEMBER SMITH: Hold on one second, I have to

 get to my notes. Okay. Phosphoric acid is listed at

 205.605(b)(23), phosphoric acid, cleaning of food contact

 surfaces and equipment only. Phosphoric acid is my material.

 So phosphoric acid is used in organic handling and processing

 as a cleaning agent for food contact surfaces and equipment. 
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 This use spans across many different types of operations from

 dairies, to processed product handlers, to post-harvest

 handling uses, so a wide range of, of uses.

 We received about a dozen comments. All were in

 favor of continuing to list. Some comments focused on the

 difference between the annotations between the livestock list

 and the handling list, noting that because there are two

 listings and that they are annotated differently that for like

 a dairy handler operation there is a fine line to know which

 annotation to follow. Some comments focused on the seemingly

 inaccurate term of, of cleaner in the annotation and how it's

 actually being used. Some comments were a bit more broadly

 focused and applicable to all sanitizers and not specific to

 phosphoric acid. Again, there is a call for the Board to take

 up sanitizers as a work agenda item and do a comprehensive

 review of sanitizers.

 As mentioned during the livestock subcommittee review

 on this material, I did check in with the ACA materials working

 group. And I covered some of the comments that were particular

 to livestock during the discussion there, so I'll focus on what

 was commented on the handling listing. And so it was stated

 that even though there is the use of the term cleaner in the

 annotation, that there is consensus among certifiers to allow

 the substance as a no-rinse sanitizer. There was also

 recognition from that working group of the inconsistency again 
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 broadly on how certifiers are reviewing sanitizers. This is

 described in the ACA best practice document. And again those

 comments are not specific to phosphoric acid, but were made

 broadly. That's it.

 CHAIR POWELL-PALM: Questions for Kyla on phosphoric

 acid? Franklin?

 BOARD MEMBER QUARCOO: Did the committee discuss some

 of the environmental impact that is listed under phosphoric

 acid?

 BOARD MEMBER SMITH: Well, Franklin, I'm having to go

 back into my head. Did that say that? I just don't remember.

 I don't remember us focusing too much on the environmental

 impacts much during the subcommittee review. I will say that

 it does -- in the TR, it does indicate that it is, I mean

 basically what it just says here, that it's relatively benign

 regarding the impact to the environment. But the processing

 steps are where there is more concern. But I don't remember

 that being a big focus of the subcommittee's discussion.

 Anybody who --

 BOARD MEMBER QUARCOO: Thank you.

 BOARD MEMBER SMITH: -- participated in the

 discussion is welcome to weigh in. I just don't remember that

 far back.

 CHAIR POWELL-PALM: Any other questions or comments?

 All right, we'll go to -- oh, Amy? 
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 SECRETARY BRUCH: I was just going to ask you, Kyla,

 thank you for your review on the stakeholder request to get an

 annotation for the handling version, handling listing of

 phosphoric acid to match similarly to livestock.

 BOARD MEMBER SMITH: Yeah. I definitely think that

 is, yeah, possible for sure. It would be -- it will be -- I

 feel like that that's interesting because -- but, yes, I think

 we can certainly talk about it. Just I -- the post-harvest

 handling aspect is always an intriguing part of the organic

 production and certification process to me.

 CHAIR POWELL-PALM: All right. If not further

 discussion, we'll go to the motion.

 BOARD MEMBER SMITH: The motion to remove phosphoric

 acid from the National List was made by myself, Kyla, and

 seconded by Allison.

 CHAIR POWELL-PALM: All right. We'll start the

 voting with Carolyn.

 BOARD MEMBER DIMITRI: No.

 CHAIR POWELL-PALM: Allison?

 BOARD MEMBER JOHNSON: No.

 CHAIR POWELL-PALM: Brian?

 BOARD MEMBER CALDWELL: No.

 CHAIR POWELL-PALM: Nate?

 BOARD MEMBER LEWIS: No.

 CHAIR POWELL-PALM: Dilip? 
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 BOARD MEMBER NANDWANI: No.

 CHAIR POWELL-PALM: Gerry?

 BOARD MEMBER D'AMORE: No.

 CHAIR POWELL-PALM: Kyla?

 BOARD MEMBER SMITH: No.

 CHAIR POWELL-PALM: Amy?

 SECRETARY BRUCH: No.

 CHAIR POWELL-PALM: Kim?

 BOARD MEMBER HUSEMAN: No.

 CHAIR POWELL-PALM: Franklin?

 BOARD MEMBER QUARCOO: No.

 CHAIR POWELL-PALM: Wood?

 BOARD MEMBER TURNER: No.

 CHAIR POWELL-PALM: Logan?

 BOARD MEMBER PETREY: No.

 CHAIR POWELL-PALM: And the Chair votes no.

 SECRETARY BRUCH: Zero yes, 13 no, zero abstentions,

 zero recusals, 2 absent. The motion fails.

 BOARD MEMBER SMITH: Next up is potassium carbonate.

 So this is listed at 205.605(b)(24), potassium carbonate. And

 this is Kim.

 BOARD MEMBER HUSEMAN: Okay. Unlike calcium

 carbonate, potassium carbonate, although still has a lot of

 different uses, it's a little bit more narrow scope. We did

 get a new TR on potassium carbonate in 2023, so we had that for 
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 review as well. I would say, though, there has been some

 modernization into the, the manufacturing process of potassium

 carbonate. That was -- that was mentioned through the TR.

 The spring comments and I'll follow with fall

 comments were very consistent that there's significant support

 for relisting. There, there was one commenter that would

 request that an annotation be made that potassium carbonate

 only be used when sodium carbonate wouldn't be appropriate, as

 it is used to reduce the salt content. Another, another one

 also mentioned that it be listed out by use and then evaluated

 for essentiality. But the other commenters were in support

 without additional information. So I feel like that, that kind

 of covers potassium carbonate.

 CHAIR POWELL-PALM: And 'm the biggest offender here.

 But if everyone brings the mike much closer to their mouth and

 just speaks up a little bit, I think I'm getting notes that the

 folks on zoom can't hear us.

 BOARD MEMBER HUSEMAN: Would you like for me -- I can

 repeat that whole conversation.

 CHAIR POWELL-PALM: I think we have time.

 BOARD MEMBER HUSEMAN: I was extending it out as much

 as I could already, Nate, but --

 CHAIR POWELL-PALM: That is all right.

 BOARD MEMBER HUSEMAN: -- thank you for the reminder.

 CHAIR POWELL-PALM: Questions for Kim from the Board? 
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 With that, we'll go to the motion.

 BOARD MEMBER SMITH: The motion to remove potassium

 carbonate from the National List was motioned by Kim and

 seconded by myself, Kyla.

 CHAIR POWELL-PALM: All right. And we're going to

 start with Allison.

 BOARD MEMBER JOHNSON: No.

 CHAIR POWELL-PALM: Brian?

 BOARD MEMBER CALDWELL: No.

 CHAIR POWELL-PALM: Nate?

 BOARD MEMBER LEWIS: No.

 CHAIR POWELL-PALM: Dilip?

 BOARD MEMBER NANDWANI: No.

 CHAIR POWELL-PALM: Gerry?

 BOARD MEMBER D'AMORE: No.

 CHAIR POWELL-PALM: Kyla?

 BOARD MEMBER SMITH: No.

 CHAIR POWELL-PALM: Amy?

 SECRETARY BRUCH: No.

 CHAIR POWELL-PALM: Kim?

 BOARD MEMBER HUSEMAN: No.

 CHAIR POWELL-PALM: Such a good no. Franklin?

 BOARD MEMBER QUARCOO: No.

 CHAIR POWELL-PALM: Wood?

 BOARD MEMBER TURNER: No. 
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 CHAIR POWELL-PALM: Logan?

 BOARD MEMBER PETREY: No.

 CHAIR POWELL-PALM: Carolyn?

 BOARD MEMBER DIMITRI: No.

 CHAIR POWELL-PALM: And the Chair votes no.

 SECRETARY BRUCH: Zero yes, 13 no, zero abstentions,

 zero recusals, 2 absent. The motion fails.

 BOARD MEMBER SMITH: Next up is sulfur dioxide. This

 is listed at 205.605(b)(35), sulfur dioxide for use only in

 wine labelled, quote, "Made with organic grapes," end quote,

 provided that total sulfite concentration does not exceed

 100 ppm. And this material is Allison's.

 BOARD MEMBER JOHNSON: I have a beautiful story of

 public engagement to tell you all. Very excited. Okay. So

 sulfur dioxide is used to inhibit microbial growth, and prevent

 spoilage and oxidation in wines since Greek and Roman times.

 This is old, old material. Uh-oh, my computer just died.

 Okay, it's back. It's made from elemental sulfur and mineral

 ores, and waste material that contains sulfur. It's most

 difficult to burn it to get the, the gas.

 It's added in various forms to wine. And we were

 trying to get some clarity from our commenters that for made

 with organic lines, it's added as a liquid or a gas. Potassium

 metabisulfite is a powdered form. OMRI states it's prohibited

 and several commenters understood that it is prohibited in made 
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 with organic lines, so the, the powdered form is currently off

 the table. Several commenters actually noted that they

 switched from using potassium metabisulfite to access the made

 with organic lines label.

 We asked in the spring to hear from wineries and

 certifiers, and got no comments. So we asked again and the

 community showed up. So thank you all. We wanted to hear more

 about the, the label theme made with organic grape, and what

 label themes are being used on wine made with organic grapes.

 And also asked about the form of sulfur dioxide, whether other

 forms might be preferable.

 We had really great, detailed comments. We heard

 from the entire supply chain, a grape grower, several wineries,

 a packager, a retailer, a consumer, and several trade and

 advocacy groups. And the comments were really informative, in

 part because they weren't exactly the comments I was expecting

 to get. So that's, that's why we ask these questions.

 In oral comments, we heard from a winery that uses

 sulfur dioxide and would drop certification if this material

 was delisted. And we also heard from a winery that has never

 used sulfur dioxide and sees a lot of growth in the organic

 wine sector that's produced without added sulfur dioxide.

 In the written comments, four major points really

 came through clearly. First is that sulfur dioxide is

 dangerous. It's really had to work with. You have to wear a 
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 respirator. Wineries don't like using this material. One

 commenter actually called it the most dangerous chemical that

 they use. Not great. SO2 is also expensive and hard to find.

 One commenter hadn't been able to expand to working on the East

 Coast because they can't source SO2 in the Greater New England

 area and it's too expensive to ship it from California.

 So you can probably guess this would typically lead

 me to believe we should delist the material, except that it's

 also completely ubiquitous. There is no adequate alternative

 that has equivalent antioxidant and sterilant action. One

 commenter said that essentially the only producers who don't

 use it are those that are seeking the organic label on wine in

 the U.S. and that that is really a different style of

 winemaking, with a different and limited market. So again,

 several said that they would drop the made with organic label

 before they'd drop the SO2.

 So that would leave us in a challenging position,

 except that we also were overwhelming offered a solution, which

 is to allow potassium metabisulfite. A bunch of winemakers

 expressed a really strong preference for that form because it's

 easier to use. It's safer. You don't have to wear a

 respirator. And it's easier to find and less expensive.

 We also got several comments about potential

 annotation changes that we can't deal with this in process, but

 I'll name them just to acknowledge. We had suggestions to look 
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 at the international allowed levels for sulfites that are more

 detailed that the U.S. rules. Suggestion to align labeling

 rules with Europe to improve consistency and simplify

 exporting. And to consider allowing SO2 for all fermented

 fruit beverages. So we can't look at those in sunset, but we

 could take them up if we looked at annotation again in the

 future.

 We did have one consumer who commented that they had

 a reaction to unlabeled sulfate in a medication and wanted

 clear labeling, which sounds like it must have been a terrible

 experience. I'm sorry for that person having to go through

 that. It's not clear if that's the same material that we're

 talking about here, but we do have strict sulfite labeling

 requirements on wine so it's always transparent to consumers

 who are sensitive. And we have the wineries that were

 mentioned in public comment that are making wine without

 sulfites and serving that consumer group.

 So through all of that, I suggest two conclusions

 here. One, that we support relisting SO2 because so many

 wineries rely on it. And the second is to our public that's

 listening, I hope someone petitions potassium metabisulfite.

 It sounds like it's safer. And we'd need to look at a TR and

 dig in, in more detail. But based on the comments so far, it

 seems like a strongly preferable option.

 CHAIR POWELL-PALM: Thank you for that, Allison, that 
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 thorough review. Questions for Allison from the Board? Logan, 

 please go ahead.

 BOARD MEMBER PETREY: That was great work. Thank

 you, Allison. No questions.

 CHAIR POWELL-PALM: Wood?

 BOARD MEMBER TURNER: That was fantastic. I mean I

 wish we would do that more often. That was just great. I mean

 just the data, just the data and the understanding, and just

 the conversations. That said, I was confused until your last

 statement. So --

 CHAIR POWELL-PALM: Buried the lead.

 BOARD MEMBER JOHNSON: Yeah, so two courses of action

 from here. It seems clear that we need to keep SO2 on the

 list, sulfur dioxide, as it's currently listed because so many

 wineries rely on it to get the made with organic claim. But

 also that it's a material with some problems. So one potential

 solution is to add potassium metabisulfite to the list, because

 it's a safer, easier to use alternative that's also cheaper.

 It's unusual that the whole package comes together. So maybe

 there is more information that we haven't seen. But there was

 a pretty resounding call for that material.

 I, I checked in with our NOP advisors this morning and I

 don't think we can spontaneously list it as a Board, so someone

 would have to petition it. So consider this a receptive

 audience, if anyone is open to doing that. 
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 CHAIR POWELL-PALM: Nate?

 BOARD MEMBER LEWIS: Did you determine whether it's

 -- I mean is it one for one like in terms of functionality in

 wine? Like --

 BOARD MEMBER JOHNSON: Yeah. Both deliver sulfur

 dioxide to the wine ultimately. The potassium metabisulfite

 comes as like a tablet or a powder, and the potassium and

 oxygen fall out in solution. I think one commenter said that

 the potassium actually might have nutritive value. But, yeah,

 equivalence and used pretty interchangeably with a strong

 preference for the tablet because it's easy and safer.

 CHAIR POWELL-PALM: Kim?

 BOARD MEMBER HUSEMAN: I know we really can't talk

 about unpetitioned, petitioned, potential petition items. But

 do you see anything in the international community from an

 import product of wines and maybe what other products might be

 being used today?

 BOARD MEMBER JOHNSON: Yeah. Europe allows potassium

 metabisulfite and bisulfite, I think, and Canada does as well,

 I believe. So we're an outlier both in the limitation on the

 label theme and the limitation on the type of delivery of SO2.

 If there's any wines that you'd like to bring to the table, no

 pun intended, in the spring just to validate. Okay.

 CHAIR POWELL-PALM: Kyla?

 BOARD MEMBER SMITH: I mean I suppose it would be 
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 dependent on if we do get a petition and what the petition

 says. But do you think that there -- that potassium

 metabisulfite would have the same made-with annotation or are

 we like opening up an opportunity here for organic wine?

 BOARD MEMBER JOHNSON: It's a good question. I guess

 it would be up to the petitioner. And it would be up to us, I

 guess, if we wanted -- if there was a difference in what was

 petitioned and what we currently have listed, if we wanted to

 try to do some sort of reconciliation in the same process.

 CHAIR POWELL-PALM: Other questions, comments? Okay.

 We'll go to the motion.

 BOARD MEMBER SMITH: The motion to remove sulfur

 dioxide from the National List was motioned by Allison and

 seconded by Wood.

 CHAIR POWELL-PALM: And we're going to start the

 voting with Brian.

 BOARD MEMBER CALDWELL: No.

 CHAIR POWELL-PALM: Nate?

 BOARD MEMBER LEWIS: No.

 CHAIR POWELL-PALM: Dilip?

 BOARD MEMBER NANDWANI: No.

 CHAIR POWELL-PALM: Gerry?

 BOARD MEMBER D'AMORE: No.

 CHAIR POWELL-PALM: Kyla?

 BOARD MEMBER SMITH: No. 
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 CHAIR POWELL-PALM: Amy?

 SECRETARY BRUCH: No.

 CHAIR POWELL-PALM: Kim?

 BOARD MEMBER HUSEMAN: No.

 CHAIR POWELL-PALM: Franklin?

 BOARD MEMBER QUARCOO: No.

 CHAIR POWELL-PALM: Wood?

 BOARD MEMBER TURNER: No.

 CHAIR POWELL-PALM: Logan?

 BOARD MEMBER PETREY: No.

 CHAIR POWELL-PALM: Carolyn?

 BOARD MEMBER DIMITRI: No.

 CHAIR POWELL-PALM: Allison?

 BOARD MEMBER JOHNSON: No.

 CHAIR POWELL-PALM: And the Chair votes no.

 SECRETARY BRUCH: Zero yes, 13 no, zero abstentions,

 zero recusals, 2 absent. The motion fails.

 BOARD MEMBER SMITH: We now move to 205.606. We are

 going to talk about fructoolingo -- ugh.

 CHAIR POWELL-PALM: We had a rhythm there.

 BOARD MEMBER SMITH: FOS. We already did the gums,

 yeah. Fructooligosaccharides. I practiced, guys, I promise.

 Anyway, we're at (g). And I'm going to just say FOS from now

 on and turn it over to Gerry.

 BOARD MEMBER D'AMORE: And I'm just going to say what 
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 she said. Before I get into this, I'd like to share an ah-ha

 moment that, that I've had this morning. It may be just me.

 To my colleagues, I'd like to say that going back all the way

 to the alginates and the glycerides, I was a little bit

 surprised by the nature of the questions and the intensity of

 the questions. And as I proceeded through this, I realized

 that from, from starting with alginate all the way through to

 fructooligosaccharides --

 BOARD MEMBER SMITH: You did it.

 BOARD MEMBER D'AMORE: Wow. That everything else has

 been -- everything's been synthetics allowed. And with the one

 that I'm going to present right now, it is non-agricultural

 substance allowed. And for me anyway and maybe nothing new for

 anybody else, that distinction is important in terms of the

 intensity with which I think we all, but I will share with you

 that I look at it. Does that make sense to you? Okay, thank

 you.

 So I can already use the word -- I can say FOS,

 205.606, a non-organic, agricultural substance allowed as an

 ingredient in or on products labeled as organic. FOS is a

 nondigestible carbohydrate and is not used as a nutrient source

 for humans. It is a source of energy for probiotic bacteria

 residing in the human gut.

 FOS is incorporated into milk products, cake, 

 biscuits, cookies, crackers, yogurt, and ice cream, among other 
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73

 foods. There is no information available from EPA or FDA to

 suggest environmental contamination from the use, misuse, or

 disposal of FOS. Further, there are no known harmful effects

 to human health.

 During the last sunset review, so going back to 2018,

 FOS remained on 205.606 by a vote of 14 to 1. FOS was

 presented and discussed at our -- at our spring meeting, coming

 out of subcommittee with no votes for removal.

 Stakeholder comments were light for this fall season

 or this fall session with about five total comments. Several

 of the stakeholder groups challenged FOS's status as an

 organic, excuse me, as an agricultural product. And they are

 insistent and there's two of them. Going back to the spring of

 2023 session, there were about 10 total comments. The same two

 groups challenged the agricultural status. Two groups took no

 position and six stakeholders were in support of relisting.

 The Handling Subcommittee finds

 fructooligosaccharides compliant with the Organic Food

 Production Act and/or 205.600 and is not proposing removal.

 Thank you.

 CHAIR POWELL-PALM: Questions for Gerry? Anyone?

 Logan? Oh, Amy. I'm sorry. Right out of my field of vision.

 SECRETARY BRUCH: Thank you, Gerry. There was a

 comment that passed, is this an essential -- is this essential

 or is it necessary to make label claims. Do we need this for 
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 product formulation or handling, or is it driven more from a

 marketing standpoint?

 BOARD MEMBER D'AMORE: Actually, were I to answer

 that from -- in readings that I've done subsequent to putting

 this together, I would say that it's actually done for the

 simple reason that it's less calories than the -- than the

 alternatives. And it does not cause a spike in blood sugar.

 So I think there -- I think there is a legitimate reason for

 it.

 CHAIR POWELL-PALM: Other questions? All right, we

 will go to the motion. And then after the motion we're just

 going to take a break. We're a couple of minutes behind our

 break.

 BOARD MEMBER D'AMORE: We've got one more.

 CHAIR POWELL-PALM: Oh, one more.

 BOARD MEMBER D'AMORE: And it's mine. And I'm

 nervous. And I want to get it behind me.

 CHAIR POWELL-PALM: Okay. One more and then we'll

 take our break. So thanks for bearing with us, folks.

 BOARD MEMBER SMITH: Okay. Motion to remove

 fructooligosaccharides, I'm going to say it like that or else

 it doesn't work, form the National List. Motion to -- was made

 by Gerry and seconded by Dilip.

 CHAIR POWELL-PALM: And starting with Nate, I think.

 BOARD MEMBER LEWIS: No. 
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 CHAIR POWELL-PALM: Dilip?

 BOARD MEMBER NANDWANI: No.

 CHAIR POWELL-PALM: Gerry?

 BOARD MEMBER D'AMORE: No.

 CHAIR POWELL-PALM: Kyla?

 BOARD MEMBER SMITH: No.

 CHAIR POWELL-PALM: Amy?

 SECRETARY BRUCH: No.

 CHAIR POWELL-PALM: Kim? Absent. Franklin?

 BOARD MEMBER QUARCOO: No.

 CHAIR POWELL-PALM: Wood?

 BOARD MEMBER TURNER: No.

 CHAIR POWELL-PALM: Logan?

 BOARD MEMBER PETREY: No.

 CHAIR POWELL-PALM: Carolyn?

 BOARD MEMBER DIMITRI: No.

 CHAIR POWELL-PALM: Allison?

 BOARD MEMBER JOHNSON: No.

 CHAIR POWELL-PALM: Brian?

 BOARD MEMBER CALDWELL: No.

 CHAIR POWELL-PALM: Kim. Present.

 BOARD MEMBER HUSEMAN: No.

 CHAIR POWELL-PALM: And the Chair votes no.

 SECRETARY BRUCH: Zero yes, 13 no, zero abstentions,

 zero recusals, 2 absent. The motion fails. 
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76

 CHAIR POWELL-PALM: All right. Last handling

 material.

 BOARD MEMBER SMITH: Last one. Lecithin is at --

 listed at 205.606(l), lecithin de-oiled. And this is also

 Gerry.

 BOARD MEMBER D'AMORE: Thank you. So lecithin

 de-oiled, again it's 205.606, nonorganic agricultural substance

 allowed as an ingredient in or on products labeled as organic.

 The major uses of lecithin include as an emulsifier in

 margarine, chocolates, instantizers powders -- instantizing

 powders, release sprays, and baked goods. It is also used as a

 natural surfactant between oil and water systems, as with

 margarine. Lecithin is affirmed as generally recognized as

 safe, or GRAS, G-R-A-S, with no limitations other than current

 good manufacturing processes -- practices.

 During the last sunset review in 2018, stakeholder

 comments centered around the availability of suitable and

 sufficient supply of organic raw material. Five years ago, it

 was felt that there was not sufficient supply or organic

 supply. This question of suitable and sufficient supply was

 addressed by the 2023 technical report which was received in

 early February of this yar. And while some of it appears to be

 -- and while there appears to be some that are sub -- excuse

 me, alternatives as organic, it was noted that these

 alternatives do not result in the same quality of finished 
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 product.

 There are about 14 written and oral comments provided

 for this 2023 fall session, mostly being written. Not one

 entity came out with a clean no to a relisting. Three,

 however, strongly encouraged us to keep a close watch on

 suitable availability. Of these three comments, two said that

 with the war in Ukraine, this would be not an ideal time to

 delist in any case.

 The Handling Subcommittee finds lecithin de-oiled

 compliant with the Organic Food Productions Act, OFPA, and with

 205.600, and is not proposing removal. Thank you.

 CHAIR POWELL-PALM: Wood and then Kim.

 BOARD MEMBER TURNER: Thanks, Gerry. Amy, question

 for you. Can you put this into context for me about some of

 the issues that you've been raising about Midwest organics, soy

 and corn, and whether this is -- this is just one of those

 issues that I just would love to understand more about sort of

 how and where growers in the Midwest are maybe potentially

 supplying, could be supplying organic lecithin. I mean I just

 don't understand, I don't understand what's going on here.

 SECRETARY BRUCH: That makes two of us because, yes,

 we can grow these. Actually, we heard from one commenter

 through oral comments that he has sunflowers -- organic

 sunflowers sitting in his bin for over 11 months and not

 finding a market for it. So the U.S. is third in sunflower 
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 production. Yes, Ukraine grows a lot of sunflowers. I don't

 know their percentage of organic. Russia grows a lot of

 sunflowers. I think they make up 50 percent of the sunflower

 production. Again, I don't know organic. But sunflowers are

 commonly grown. U.S. is number 3. North Dakota, South Dakota,

 Nebraska, Kansas, Texas. We can all grow those. I've grown

 them. Markets are very challenging, organic ones, to find.

 Obviously, they exist. So we just need to put two people

 together in a room and solve these issues pretty quickly, in my

 opinion. Thank you. And thank you, Gerry, that was a great,

 great review. You shouldn't have been nervous. Oh, Jenny, go

 ahead.

 CHAIR POWELL-PALM: Obviously, I jump the queue for

 Jenny.

 DR. TUCKER: I'm going to ask just a -- and I'm going

 to show probably my naivety here. Which TOPP region are we

 talking about? Because I think -- I mean this is where if

 we're talking about connecting buyers and sellers to identify

 these market gaps is part of what TOPP is here to do. So what

 region are we talking about here?

 SECRETARY BRUCH: Plains.

 DR. TUCKER: Okay. So this is a Plains region.

 Alexis, do you want to note that one down?

 SECRETARY BRUCH: Let's talk, Alexis, at the break.

 DR. TUCKER: Alexis is our project manager with the 
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 TOPP region and I don't know if the Plains region is still in

 the room. But these are the kinds of conversations where --

and this is also part of the reason we have the national

 agreement with Organic Trade Association and Rodale is to do

 kind of the buyer side education. And so if there's some -- I

 don't -- I don't know if there are options here, but this is

 why we have TOPP, part of why we have TOPP.

 CHAIR POWELL-PALM: Go ahead, Kim.

 BOARD MEMBER HUSEMAN: I wish that was an easier

 conversation and it was extremely straightforward, but I do

 hope the community is listening because the process of

 extracting the oil, and then breaking that down and

 individualizing it into its parts is very capital intensive.

 And there has to be a market available for the -- for the

 production to happen. I think that there, there is a component

 that's not quite as straightforward as if you build it, they

 will come.

 But I think that this is a great opportunity. And

 with, with this product, Gerry, you had mentioned in the public

 comment that the organic version of lecithin may have some

 challenges from its counterparts as a conventional. The

 process of -- it's a very simple process to take oil and beans

 or to, to take a bean and divide it. But it's a lot more

 complicated to get down to the chemical components or have it

 -- to strip it further than that. 
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 So was there any more explanation as to why the

 organic form may be subpar?

 BOARD MEMBER D'AMORE: No, excuse me. It was just

 stated that generally speaking the alternatives did not -- did

 not bring forward a comparable product, finished product.

 BOARD MEMBER HUSEMAN: Yeah. I think if we look at

 the overall production and the production capability, I agree

 with Amy that there's -- there should be the availability. But

 it just might not be that simplistic.

 BOARD MEMBER D'AMORE: Well, and I should just leave

 that alone and let us go to lunch. But -- no, seriously, we've

 had the flavors or we had the colors, and now we're again

 talking about trying to get a, a group of potentially different

 things. For instance, we talked about the soy and the corn,

 and now the sunflower. So you've got egg yolks, soybeans,

 sunflower, canola, among other sources.

 But the point is, is that on the supply, supply -- on

 the supply side, what you need is something that's consistent

 on, on a predictable annual basis. And that, to me, is also a

 barrier, as well as the expense of the extraction that you're

 talking about. How do you -- how do you collect it and make it

 centrally or regionally available to those who need it.

 BOARD MEMBER HUSEMAN: So if there were processors of

 oils that might want to be on a panel for future --

 BOARD MEMBER D'AMORE: Mm-hmm. 
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 BOARD MEMBER HUSEMAN: Okay.

 CHAIR POWELL-PALM: Let's go to Logan and then Nate.

 BOARD MEMBER PETREY: Okay. So the non-organic part

 of this reference, it's like could we annotate it to say

 organic soybeans, but realize that the product coming out might

 not be organic, if you're saying that there's extra chemicals

 in the process.

 BOARD MEMBER D'AMORE: That, that --

 BOARD MEMBER PETREY: That's fine, okay.

 BOARD MEMBER D'AMORE: That process, as far as I

 know, does not alter, does not take away its organic status.

 BOARD MEMBER PETREY: Okay, right. Nope, that's

 okay.

 CHAIR POWELL-PALM: Microphone, please. Microphone.

 BOARD MEMBER PETREY: Okay, okay. And so you're

 saying just the organic soybean and the conventional soybean

 inherently have some differences that make this process

 different?

 BOARD MEMBER HUSEMAN: The production of organic oils

 and how the oil seeds are -- like how the oil seeds go through

 the process conventional to organic are, are different.

 There's hexane, essentially. There's a chemical that's used,

 right, to strip the oil.

 BOARD MEMBER PETREY: Right.

 BOARD MEMBER HUSEMAN: And in organic, though, 
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 obviously that's -- it's a very simple process. You take a

 bean. You heat it up. You press it. You have oil. You have

 meal. And I apologize to those that are doing this in the

 industry, to not oversimplify the process. But that being

 said, then you take that oil and you have to be able to remove

 the lecithin from --

 BOARD MEMBER PETREY: Right.

 BOARD MEMBER HUSEMAN: -- from the product. So, and

 it's, it's doable. What I was saying is, is there a reason why

 conventional methodology would provide a superior product to an

 organic methodology of making those two different products, to

 take that product off.

 BOARD MEMBER PETREY: Okay. Could you have an

 organic soybean and a conventional methodology, if that's what

 we're -- is that what we're using?

 BOARD MEMBER HUSEMAN: That would negate the

 situation, because you're still using hexane in the process.

 BOARD MEMBER PETREY: Right. But I was just more

 focusing on the organic soybean marketing potential. To like

 annotate it somehow to say only organic soybeans are, or you

 need to source that, or however that is.

 BOARD MEMBER D'AMORE: Could I step back in? Were

 you suggesting that hexane, itself, sort of messes up the, the

 process on that?

 BOARD MEMBER PETREY: I was just wondering what, what 
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 made the conventional lecithin more superior, because I think

 the comment that was made was that the organic form wasn't as

 viable as an option, if I heard that comment correctly.

 BOARD MEMBER D'AMORE: Right. Well, let's backup on

 the hexane because the hexane's got its issues, but it isn't

 the issue that we're articulating right now, to what I see. I

 think what's being said, the alternative is the source

 alternative. It's the soybean.

 BOARD MEMBER PETREY: The raw material, yes. Can we

 annotate it to say --

 BOARD MEMBER D'AMORE: Just, just the raw material.

 Just that transition from mostly soy to, to sunflower is, is,

 in my eye, in my mind, what they're talking about. But already

 soy, and sunflower, and egg yolk have been identified as

 something that does work. They went outside of that and looked

 at other things that did not produce the quality that was

 necessary.

 BOARD MEMBER PETREY: Okay, thank you.

 BOARD MEMBER D'AMORE: Is that confusing you now?

 BOARD MEMBER HUSEMAN: Yeah, sorry if I --

 BOARD MEMBER D'AMORE: No, I -- hey, I told you I was

 nervous. I got up this morning and looked at some definitions.

 BOARD MEMBER HUSEMAN: And I would -- I would not --

 I would not silo soybeans, specifically. I would put all oil

 seed products as potential --
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 BOARD MEMBER D'AMORE: Okay.

 BOARD MEMBER HUSEMAN: -- sources. And, and then

 that leads into further discussion. But that also lends to

 product availability.

 CHAIR POWELL-PALM: Question from Nate real quick?

 BOARD MEMBER LEWIS: So, Kim, my reading of the TR,

 the hexane step in the process, the removal of the oil from the

 seed, itself, is not the insurmountable barrier to an organic

 lecithin.

 BOARD MEMBER D'AMORE: Correct.

 BOARD MEMBER LEWIS: It's the fractionation to get to

 the lecithin, which requires acetone. And the TR require -- or

 has said there are some alternatives. One is a membrane

 technology and the other is a super critical carbon dioxide

 extraction, which I'm super interested in, but a super critical

 CO2. But these are not -- these are not widespread or widely

 adopted. So I think there is an investment in technology step

 that hasn't really been embraced by the lecithin industry to

 prevent a -- which is preventing an organic -- a suitable

 organic alternative.

 I also seem to recall that while there may be some

 organic lecithin on the market, there are some food safety

 concerns because that is manufactured overseas. And there's

 some incompatibility. That may have changed in the last few

 years. But I recall at the last sunset that there were some 
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 food safety GNPs that were not -- or good manufacturing

 practices that were not being followed in the overseas

 facilities.

 But I think it's that fractionation, that super

 critical or membrane technology that potentially could open the

 door.

 CHAIR POWELL-PALM: Yeah, Kim and then Allison.

 BOARD MEMBER HUSEMAN: Thank you, Nate. I think you

 really honed in on where I was trying to go with that. So

 capital investment and in the production facilities, and gosh

 if we could hear from a processor who might have this equipment

 installed in the U.S. that can speak to it would be really

 wonderful to hear from.

 BOARD MEMBER D'AMORE: Agreed. Thank you.

 CHAIR POWELL-PALM: Allison?

 BOARD MEMBER JOHNSON: Thank you. I just wanted to

 reiterate Logan's suggestion. I think it's a really elegant

 way to start sort of thinking about commercial availability in

 a different way. Like not just is the final product available

 as organic, but is the raw ingredient available as organic,

 even if the output isn't. I guess that would have to be either

 an annotation, annotation change or some sort of direction to

 certifiers about what commercial availability means or is,

 probably messier. But I like the idea of trying to go in that

 direction so at least you're, you're getting at the raw 
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 material. And the process may come along later to get it all

 the way to organic.

 CHAIR POWELL-PALM: Logan, then Nate.

 BOARD MEMBER PETREY: Question about the facility and

 the capital needed. Could you have organic runs in a currently

 conventional facility? Because like we do carrots that way.

 BOARD MEMBER D'AMORE: Probably not.

 BOARD MEMBER PETREY: No? It's too, too much.

 BOARD MEMBER D'AMORE: Well, it would definitely have

 to go through a thorough cleaning process, which is so arduous.

 And most of the time they have a separate run for just the

 organic or conventional.

 BOARD MEMBER PETREY: Separate in machinery? Is that

 what you mean?

 BOARD MEMBER D'AMORE: Not the machinery type. Yeah,

 but -- excuse me, the whole line would have to be --

 BOARD MEMBER PETREY: Would have to be designated?

 BOARD MEMBER D'AMORE: Exactly.

 BOARD MEMBER PETREY: You can't clean -- yeah, I mean

 obviously oil is a lot different. Okay.

 BOARD MEMBER HUSEMAN: The only --

 CHAIR POWELL-PALM: Go ahead, Kim, as the handler.

 BOARD MEMBER HUSEMAN: Thank you, Nate. The only

 U.S. facilities that I have visited that are oil seed

 production facilities, that may have both a convention and an 
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 organic production are two holistically separated -- the piping

 is different and it is very distinct. Now it can be housed

 right next to each other. And there's examples in the U.S. of

 that. But the production of organic soy-extracted, or

 sunflower-extracted, or any oil seed production is holistically

 a different process than conventional. And it's by the

 inclusion, those chemicals are not. Thank you.

 CHAIR POWELL-PALM: Nate, Allison, Gerry.

 BOARD MEMBER D'AMORE: I'm not going to question,

 myself. I'd like to follow-up, though.

 CHAIR POWELL-PALM: Sure, go ahead, guys. I think

 everyone is following up to Kim.

 BOARD MEMBER D'AMORE: Here's the pedantic side of

 me. You said the piping is different. I'm going to say that

 it isn't. It's another one. It's separated. There's not --

 you're not -- we're not driving a distinction in the process.

 We're driving a distinction in delivery and of an end product.

 Correct?

 BOARD MEMBER HUSEMAN: The process is different. But

 to your -- yes, the, the pipes are the same that the product

 travels through, but they are -- they are separate.

 BOARD MEMBER D'AMORE: Separated.

 BOARD MEMBER HUSEMAN: You're not going to flush a

 chemical produced soy line, in my mind, and then run an organic

 version. The equipment to make a product is different. 
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 CHAIR POWELL-PALM: Nate and then Allison.

 BOARD MEMBER LEWIS: I, too, am intrigued by Logan's

 suggestion. And I think that what we would be talking about is

 a conventional facility buying some organic soybeans, and

 running it through a conventional process, and then making the

 exempt label claim of simply indicating organic soybeans on its

 label, which is an exempt claim. So it's a noncertified

 facility using an organic ingredient and making an exempt label

 claim.

 We already have a precedent for that in livestock,

 vitamins, and minerals, which require any agricultural

 ingredient included in that three-pack to be organic. So

 organic livestock, vitamin, and mineral producers are not

 certified entities. But they are required to us an organic

 agricultural carrier if they do use one. And they make the

 exempt claim of simply identifying that agricultural ingredient

 as organic on their label.

 So I think it's possible. And we certainly do

 require it for livestock, vitamins, and minerals. And in that

 way it's intriguing to me, this nudge towards at least buying

 Amy's beans, instead of Amy's neighbor's beans to make this,

 the oiled lecithin.

 BOARD MEMBER HUSEMAN: Can I ask a clarifying

 question, Nate?

 CHAIR POWELL-PALM: Mm-hmm. Go ahead. 
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 BOARD MEMBER HUSEMAN: So if I hear you correctly,

 Nate Lewis, what you are saying is take an organic bean, run it

 through a conventional facility to be able to make lecithin.

 Do -- the, the economics behind that would be very hard for me

 to get behind.

 BOARD MEMBER LEWIS: Yeah. I'm not -- I'm not at all

 indicating it is feasible from an economic or practical

 standpoint. But I think there is a -- there is an eye of the

 needle we could thread from a -- from the rules that would

 allow for that annotation.

 CHAIR POWELL-PALM: Would the wine example be the

 better one to look towards, organic grapes, made with, yeah?

 BOARD MEMBER D'AMORE: Well, no. Made with is a

 certified category, so this would be still in a noncertified

 plant. This is an exempt label claim.

 BOARD MEMBER HUSEMAN: I simply think that there is

 enough organic oil sees in the marketplace to take an organic

 facility and making organic lecithin.

 BOARD MEMBER D'AMORE: As long as we get super

 critical CO2.

 CHAIR POWELL-PALM: Yeah. Allison?

 BOARD MEMBER JOHNSON: Thank you. I was going to

 make the same point that, that Nate made. I think you could

 even -- it wouldn't even have to be labeled necessarily, but

 I'm imagining as a certifier you ask for the Big 3 affidavit, 
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 non-GMO, non-radiated, no sludge. Was it made from organic

 soybeans? Yes. So it seems like it's possible, economics

 aside. And ultimately the goal we'd be working towards is

 getting an actual organic lecithin on the market. But it could

 be an interim step till we start building those markets for the

 organic soybeans.

 CHAIR POWELL-PALM: Amy?

 SECRETARY BRUCH: I really appreciate this

 discussion. I mean I think we've got to -- we've got to make

 some progress here. Source material, organic source material

 is available. And I think creativity and innovation is what we

 need to try to start building these markets, and build out

 organic. We're a $70 billion business and we're growing pretty

 impressively, but we need to have additional innovation to grow

 exponentially now our, our area, instead of just straight line

 a few percent at a time. So I think I really appreciate this.

 Thanks.

 CHAIR POWELL-PALM: Gerry?

 BOARD MEMBER D'AMORE: Quick question, Amy. I agree

 with everything you said. Can we just put a bow around this

 one with the suggestion of agreeing with folks that at this

 particular point in time it may not be the opportune time to,

 to change the sunset.

 SECRETARY BRUCH: Well, correct, because we need an

 annotation. So, yes, you are absolutely right. 
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 BOARD MEMBER D'AMORE: Okay, thank you.

 SECRETARY BRUCH: Thank you, Gerry.

 CHAIR POWELL-PALM: All right. And with that we're

 going to go to the motion.

 BOARD MEMBER SMITH: Okay. Great discussion, guys.

 We were getting into snoozefest over here, so this is really

 awesome. Okay. The motion to remove lecithin from the

 National List was motioned by Gerry and seconded by myself, 

 Kyla.

 CHAIR POWELL-PALM: And we're going to start with

 Dilip.

 BOARD MEMBER NANDWANI: No.

 CHAIR POWELL-PALM: Gerry?

 BOARD MEMBER D'AMORE: No.

 CHAIR POWELL-PALM: Kyla?

 BOARD MEMBER SMITH: No.

 CHAIR POWELL-PALM: Amy?

 SECRETARY BRUCH: Yes.

 CHAIR POWELL-PALM: Kim?

 BOARD MEMBER HUSEMAN: Yes.

 CHAIR POWELL-PALM: Franklin?

 BOARD MEMBER QUARCOO: No.

 CHAIR POWELL-PALM: Wood?

 BOARD MEMBER TURNER: Yes.

 CHAIR POWELL-PALM: Slow down here, folks. This is 
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 the most exciting this whole meeting is going to get, so soak

 it in.

 SECRETARY BRUCH: I can't do math that quick. I want

 to abstain.

 BOARD MEMBER DIMITRI: No.

 CHAIR POWELL-PALM: So I think right now we have

 three yesses. Okay.

 SECRETARY BRUCH: Yes.

 CHAIR POWELL-PALM: Carolyn? I'm sorry.

 BOARD MEMBER DIMITRI: I said no.

 CHAIR POWELL-PALM: Carolyn is a no. Allison?

 CHAIR POWELL-PALM: Allison?

 BOARD MEMBER JOHNSON: Yes.

 CHAIR POWELL-PALM: So four yesses. Brian?

 BOARD MEMBER CALDWELL: I'm going to abstain, because

 now I don't understand the different sides of this question.

 So I'm going to abstain.

 CHAIR POWELL-PALM: Nate?

 BOARD MEMBER LEWIS: No.

 CHAIR POWELL-PALM: The Chair votes no.

 BOARD MEMBER D'AMORE: Do you want to ask me again

 why I got up at 5:00 in the morning?

 (Laughter.)

 SECRETARY BRUCH: Four yes, seven no, two

 abstentions, zero recusals, two absent. The motion fails. 
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 CHAIR POWELL-PALM: All right. Let's take a break,

 everybody.

 (Off the record from 11:58 a.m. to 12:18 p.m.)

 CHAIR POWELL-PALM: We're going to keep the same

 schedule for lunch. We're going to plan to go to lunch at

 1 o'clock, coming back at 2:15. After lunch, we're going to go

 through elections and then we'll move to other business.

 Okay. With that, I'm going to head over to Wood,

 chair of Materials Subcommittee.

 BOARD MEMBER TURNER: Thanks. Before we jump into

 research priorities discussion, I just wanted to flag a couple

 of things. And I appreciate Nate mentioning and it was

 mentioned earlier about what we're doing on excluded methods

 and the process of, of moving, moving towards using an updated

 TR template that allows us to ask these kinds of questions

 about excluded methods as we review materials. So we'll hear

 more about that as we continue on with the process. Many

 people have been tracking this. Know that Mindy has brought a

 lot of leadership to this and, and others have really supported

 that work. So thanks for mentioning that the way you did

 earlier, Nate.

 Also, a reminder to folks that we have an exciting

 process in this subcommittee on inerts that will involve a

 small working group of folks, who will be tasked with moving

 that -- moving that work forward. It will live within this 
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 subcommittee and updates will, will follow. So Nate will say a

 little bit more about that later in the day. But I just wanted

 to acknowledge that work and say to the folks that are involved

 in that work that I appreciate the leadership. Long overdue.

 So with that let's moving into a discussion of

 research priorities. So I've been thinking a lot about

 something Franklin said about how we -- how we incentivize

 research into plastics. And it sort of triggered for me a lot

 of thoughts about this, what we've been doing over the last

 couple of years to try to, I think, lean into what research

 priorities actually mean, and what they mean for the community,

 and what signals they send, and all those -- all those issues

 that we've talked about before.

 And it's interesting, because I think I, I came into

 this thinking it needs to be an exhaustive list of research

 priorities like the one -- like the ones that we have. I think

 it's getting the list gets longer and longer. And as I go into

 this document and this is not me trying to derail us moving

 forward with this document, but I -- but I do want to challenge

 us as we move into the year ahead to think about whether the

 list needs to be shorter. Are there some -- are there some

 research priorities that are really fundamental to what we do.

 I mean it comes up over and over again in the

 comments, people want more research on plastics. Like it needs

 to -- when it's on a list that's as long as ours is, there's a 
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 lot of directions that different researchers could pursue in

 terms of their own -- their own -- some narrow element that --

 I mean I'm not saying those aren't important directions, but

 something that might not be as high priority for, for the

 direction that we want to see organic go as say plastics or any

 number of issues.

 So I don't know what others think about that. But I,

 I just, you know, we can certainly talk about it. I, I do

 wonder if this list of priorities should be something just we

 only want to -- we only want to recommend research in these 5

 or 10 areas and just ensure that it gets done. And I'm really

 thankful to Franklin for mentioning that, making that comment.

 How do we incentivize the work? How do we incentivize the work

 that needs to happen? We probably shorten the list. So anyway

 for --

 CHAIR POWELL-PALM: I was just going to click through

 that real quick, just to sort of get an idea of where we're --

what we're looking at, whatever direction you want to go.

 BOARD MEMBER TURNER: Yeah, sure. No, that's fine.

 And so I just wanted to -- I think we have a -- I just wanted

 to elevate some comments and I appreciate the continued

 comments we get from the community. I want to remind the

 community that by the time we get to this meeting, we're really

 not -- there's not an opportunity, obviously, at this meeting

 to add some new research priorities. 
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 But all the comments that we received in this last

 round certainly tee up this ongoing conversation. So as we

 move into these discussions for next year, all the things that

 came forward from, from the community will certainly be part of

 that consideration. But I also want to suggest that maybe

 it's, it's not -- it's not adding to the list as we move

 forward, it's getting shorter.

 So, again, so many comments from different groups on

 ensuring that we're elevating the work on, on plastics. I

 think there's, there's discussions about or some suggestions of

 other -- of research priorities. We heard from one commenter

 who said we need to be doing these need for updates more

 regularly so that we understand for the feedback groups how

 this research is going to be used and sort of what's going on

 there. I think that's really important as well.

 Great feedback about how to really add more

 specificity, in some cases, to research priorities around

 racial equity and inclusivity, for example. I thought some of

 the -- some of the feedback we heard was, was really good

 there.

 Continued interest in this -- in the issue of

 sanitizers, and I thought we've heard it over and over again

 over the last several days. I mean we don't have a -- we don't

 have a new -- we don't have a different process for evaluating

 sanitizers. We still don't have that process. What does that 
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 look like? How do we drive research into this? These are

 issues that I think we all kind of realize these are sort of

 imperfect materials that we have to sort of continue to keep on

 the list and sort of move forward. But there's got to be some

 other way of thinking about this.

 Obviously, the plastics issue extends over into

 peapots (ph.) issues, which we've talked about over and over

 again. So understanding what's going on here more and more.

 I'm just trying to flag some other issues that, that came up.

 One issue, one group said, hey, can you guys clarify what's

 going on in the annotation process. I think we've all talked

 about that. I think we're going to spend some time today

 talking about that, which will be great.

 Also, continued interest and concern about pork

 research and more comments on poultry research. I'm excited

 about the news that we announced this week, but still

 interested in that issue.

 Interest in copper. I want to elevate for people

 again that there seems to be some belief somehow in comments

 that we're not wanting research into copper sulfate. That's

 not the case. We've tried to -- we've tried to outline very

 clearly that we want comprehensive research into copper, copper

 products, and even specifically mentioning rice applications.

 So I just want to make that -- I want to make that clear,

 again, that that's not -- we haven't excluded that research 
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 priority. We've actually tried to articulate a broader

 interest in, in all copper -- in all copper usage. And a real

 need for that research moving forward.

 Brian, I'm going to ask you if you -- if there is

 anything as a liaison to a couple of these subcommittees that

 you wanted to add to, to kind of overview? Is there anything

 that you saw in the comments that was interesting to you

 relative to what we've done this term?

 BOARD MEMBER CALDWELL: Yeah, thanks, Wood. And I

 think I just wanted to, to basically say again that we take the

 comments very seriously and we incorporated almost all of the

 suggestions from the comments into the, the latest version of

 the research priorities, which does make it longer but makes it

 better. So, so there we go.

 A couple of thoughts I had. There's I think in some

 of the cases of our -- of our listing, research has been done.

 Significant research has been done on the topics that we're

 asking for. But we may not be aware of it and the community at

 large may not be very aware of it. And I haven't run this by

 anybody who can say anything about it, yet, but I'm hoping that

 maybe our, our new technical specialist can, can do some

 targeted literature reviews at some point on some of these

 specific items. And then they may fall off the list, because

 we may know how to -- how to handle some of these questions

 that we don't think we know the answers to. So that would be a 
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 wonderful service.

 And the other part of it is how do we -- how do we in

 general terms make sure that the, the information from the

 researchers gets out to the broader community. And our

 extension system isn't as -- isn't as robust as it once was.

 And so there are -- there are some issues there. eOrganic was

 promoted for quite a while and still, as I understand it,

 exists. Maybe we can breathe some life into that.

 But I think this, you know, again any, any input that

 we can get from you all as to how we can make sure that those

 conduits are open, the researchers need to share what they --

what they learn with the community. It would be very helpful.

 So, yeah, thanks, Wood.

 BOARD MEMBER TURNER: Thanks, Brian. The discussion

 that --

 CHAIR POWELL-PALM: Nice chats, yeah. Other thoughts

 on this before I just turn it over to Carolyn as the academic

 who needs to guide us how we get more engagement.

 BOARD MEMBER DIMITRI: I guess it was really helpful

 when we had Reece come and give that presentation at the last

 board meeting or at the one in Sacramento. But I was thinking

 about this list here. And we have these two new, wonderful

 humans who are going to help us. And I wonder if like what we

 should do is go through here and prioritize like how we --

 which ones we think it would be great for them to even just 
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 take like an initial pass at. And then we could say -- they

 could look and see, yeah, there's a lot on this and there's a

 lot on that, so it could be an iterative process. I think that

 would be helpful.

 But I do think this is like a classic problem of like

 getting academic research out to not to farmers, but also to

 people who are interested in policy and advocacy. And I don't

 know like the best solution. I mean usually there are kind of

 boring solutions, like have a four-day conference or something

 like that. And I don't -- I don't know the best way forward

 with this. I think Brian and I have talked about this

 extensively, like how do you find out what people are doing.

 CHAIR POWELL-PALM: Dilip, then Allison.

 BOARD MEMBER NANDWANI: I don't know if there is

 another slide which had more items, Wood? I see next slide

 icon on my phone. So one of the topic thing I mentioned, I'm

 not sure it's on the list or we talked about on, on any food.

 There is a lot of debate and I don't want to say it's a

 disagreement in the U.S. and Europe in research, but is it that

 organic food is safer, it's nutritious, and all that. So we

 have these two wonderful, as Carolyn said, food technology

 standard person today also, if you can add something about to

 do some literature and present a bit of information in that

 respect to whether organic varied stance really -- is really

 more nutritious or that conventional also helps. So I just 
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 want to draw there if that's something sounds good to the

 committee and as a group. Thank you.

 CHAIR POWELL-PALM: Logan -- or, sorry, Allison, did

 you have some? And then Logan and then Amy.

 BOARD MEMBER JOHNSON: Thank you. I was just trying

 to furiously search to see if I could answer my own question.

 But can you remind me who we present these recommendations to?

 And then my suggestion for feedback, we're continuing to load

 our agenda with fun things and interesting things that we could

 do, but one feedback would be we give it to them in the fall.

 They come back to us the next fall and tell us what has been

 done or have some sort of back and forth, rather than a one-way

 recommendation, if there is a they who actually could do that

 for us.

 And then I just wanted to respond to the idea about

 prioritization. I do think there is some value in having a

 laundry list, one, to help us keep track of things and, two, to

 show the breadth of issues that really do need to be taken on

 in organic. So maybe like an in between solution could be have

 the laundry list, but then offer a prioritization, like these

 are the top three things that we think are crucial to focus on

 or something like that, so we don't lose the big picture, but

 we can also provide some distillation.

 BOARD MEMBER TURNER: That's great, yeah. It goes to

 NIFA. Matt at NIFA is the person that we -- who leads that, 
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102

 leads this process. And we've had him come to speak to the

 Board in the past. I don't know if you were on or not. But

 about this exact -- this exact issue of sort of feedback, sort

 of where, where and how this research is finding -- these

 priorities are finding researchers and leading to real

 knowledge building. He, he reinforced for us that these --

that these are -- this is a powerful process for them on some

 level in terms of sort of sending a signal to the community

 that these are topics that matter.

 CHAIR POWELL-PALM: Logan?

 BOARD MEMBER PETREY: Yeah. Actually, I had the same

 question and comment that Allison did. But the they, to me,

 was universities and didn't know if we could directly

 communicate with the universities and say this is organic

 interest. And if you're conducting -- I don't know if we can

 go around NIFA or how -- or how that works politically, but to

 do that. And then I think that's a great suggestion is to

 follow-up, you know, can we have your results after you're

 done. Anyway --

 BOARD MEMBER TURNER: Yeah, I'll defer to the

 academics on the Board about that process. But I, I don't

 think there is anything we can do to get the word out about

 these, these priorities is key. I mean I think it's a fairly

 passive process for us to just send the -- send the priorities

 over to NIFA and say do something with it. So, Brian? 
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103

 BOARD MEMBER CALDWELL: Well, along those lines, in

 the -- in the -- I mean I'm retired for a little while, so I'm

 a little out of date. But in the OREI projects that we worked

 on, if you could -- if you could point to one of these

 priorities as being accomplished or being worked on with your

 project, that was a plus, definitely a plus. But on the other

 hand, there was -- there was the -- their high priority request

 definitely did not necessarily mirror what, what these research

 priorities were.

 CHAIR POWELL-PALM: Amy?

 SECRETARY BRUCH: Yeah, Brian, you speak a lot more

 eloquently than I'm going to. But I do agree with a lot of

 points being said here. One thing, I did a little background

 research thanks to my buddy Allison. She has a lot of

 information on the Farm Bill and summaries of the Farm Bill in

 her position. And it seems like 1/10th of 1 percent of the --

 of the Farm Bill goes to organic funding. Majority of that

 funding goes to research.

 So I think there is a big opportunity here. We have

 a lot of feedback from the community and have comment process.

 We have this list generated by stakeholder feedback, our own

 feedback. We need to be able to insert ourselves somewhat more

 in this process. I mean if these are our priorities and these

 are not aligning with groups receiving the money, we need to

 either get educated on what those additional priorities are. 
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 I, I think in a previous meeting we were told even prioritizing

 or ranking, shortening this list probably isn't the best

 thought. I think the comment was just get as many things on

 there. Maybe that was for the point maybe something will match

 up here, I don't know.

 But I think there is a big opportunity here. A lot

 of money is going to research. Most of the groups that

 represent organics on the Hill are asking for more money for

 research. As a farmer, like you said, Brian, I don't know

 where to go to get this information. I do my own real farm

 research and share it amongst our communities for ag projects.

 So I think there is just a big opportunity. And to

 understand, I mean, fiscal responsibility, return on

 investment, where is this going, what's happening, how are we

 moving the needle forward I think are really important

 questions. We need to be good stewards of this money. We need

 to take our industry somewhere where, you know, somewhere just

 increasing, continuous improvement every year.

 So I really -- this concerns me a little bit, this

 process, just not being able to feel like we're moving the

 needle. So, yeah, maybe, maybe if we could get more feedback,

 generate this solution loop, I would feel a lot more

 comfortable. But I think there is a lot of challenges to

 solve, a lot of smart people in our industry, and I'd love to

 start crossing these things off the list because there is more 
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 to add, add to the list.

 CHAIR POWELL-PALM: Amen.

 SECRETARY BRUCH: Sorry.

 CHAIR POWELL-PALM: Carolyn.

 BOARD MEMBER DIMITRI: So I currently have an

 OREI-funded project. And the goal is to develop an applied

 economic research and outreach agenda. And so we're coming up

 into our final year. We've collected data. We've talked to

 many people in this room. And I'm planning to hold many

 meetings with people who do research, so the USDA researchers,

 the people at NIFA who fund. I plan to write articles. I'll

 go to conferences where there are other, other economists, to

 try to talk about these are really important questions.

 So I think for us, with this list we need to take --

 well, we don't need to. But one approach could be to take a

 similar form of outreach. But I see like it's a lot of work to

 take this list and turn it into -- break it down by discipline

 and go to, say like Franklin goes to the meetings. I don't

 know if Franklin goes to like those science meetings with, I

 don't know, AAAS or something like that, to make a presentation

 there about here are the priorities that we see in this field.

 So I think it's like getting the word out to the

 people who do research that telling NIFA is helpful, but it

 doesn’t really -- like I don't, when I'm putting in a grant

 proposal, I kind of look for what Brian said, is it a priority. 
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 But I just do what I think is important. So I think it's how

 do we convince researchers that this is important. So, anyway,

 that's my two cents.

 CHAIR POWELL-PALM: Sure. Let's go Franklin, then

 Amy -- go ahead, Wood.

 BOARD MEMBER TURNER: I just -- I appreciate what

 you're saying, Carolyn, and I also worry a little bit, too, I

 think about the role of the stakeholders in this, our, our

 community here and pushing out these priorities, because I

 think it's a challenging -- it's a challenging process. But

 there's all those stakeholders, as I just mentioned in the

 beginning, have -- they have general support for our

 priorities, but then they have other things. And those aren't

 necessarily going -- don't always make it onto the list on our

 cycle every year.

 And so, yeah, if we could all align in each cycle as

 a community and pushing out the same priorities to everybody

 that we could find and not -- and not saying these other

 priorities that maybe haven't made it onto the list yet, but

 maybe will at some point, you know, and could be fundable in

 the future, that we hold off on those for the time being. I

 don't -- I don't know how to say that exactly without sounding

 like I'm stepping on toes. But we all need to align on what

 the priorities stand for and push them out together. I don't

 mean just the Board. I mean the whole community. 
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 CHAIR POWELL-PALM: Franklin.

 BOARD MEMBER QUARCOO: I want to go in a slightly

 different direction. The conventional type companies do a lot

 of funding for conventional agriculture. I'm thinking organic

 type industries or big manufacturers should contribute a little

 bit more to research in universities. Federal funding is

 great. It does the -- for one thing, you have a three year or

 five year grant. You have built this momentum to students,

 post docs, everybody is happy, collect this data. The grant

 comes to an end. Everything comes to an end. Breaks the

 momentum.

 You may not get the next grant you apply for. It's

 not guarantee. So it's a start, stop, you lose momentum, you

 start. If there is private sector support for universities,

 for one thing there is more latitude and flexibility to do

 things. A new research topic comes up. You don't want -- you

 don't have to wait for the next RFE. Endowments, just anything

 that is flexible so when a research topic shows up on this, our

 priority list, somebody can quickly do that without waiting for

 the next RFE, that at the very least they can get preliminary

 data that can help them apply for a much larger grant with the

 federal government. But we'll be more nimble. We'll be able

 to address.

 So I think this is sort of a callout, a call to

 private sector per station, organic -- in the organic for 
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 research. We will generate information that goes to promote

 what we're doing. Flexibility in all of this will help.

 CHAIR POWELL-PALM: Amy, then Wood.

 SECRETARY BRUCH: Franklin, that was a strong point.

 I agree with you completely. Carolyn, I have a question to

 you, okay, so be ready. All right. You said you were a

 recipient of a grant. You're currently working on it. What in

 this grant, and I apologize I don't know, are there

 deliverables, or reporting, or a feedback loop that you have to

 provide for how you use the dollars and what the result was?

 BOARD MEMBER DIMITRI: Yeah. So every year, you have

 to report, give like an update report of what you've done in

 that year. And then there will be a final project report that

 we make to NIFA. But then there are, are publications. And so

 we have -- like we'll have this -- we have a -- we partner with

 NCAD on this, who does our outreach. So we would do podcasts,

 webinars. And then we'll have like a written report type of

 thing that will be on their website. And then as I said, I'll

 try to make -- I'll go to every single person who will talk to

 me about this and give like an oral presentation. And then

 peer review publications.

 SECRETARY BRUCH: And just to follow-up, that sounds

 like you're going above and beyond. So all of the, the

 podcasts, going to every single person, is that unique to you

 and your style or are you seeing that amongst other researchers 
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 as well?

 BOARD MEMBER DIMITRI: So it depends on the work that

 you do. Michelle told me not to touch that, so now I see why.

 I, I -- like my goal is to create a -- okay, so I think there

 is not enough research on post-farm market activities for the

 organic sector. And I don't think there is enough research on

 risk management for the organic sector. So these are common

 areas of research that economists do.

 So I thought, well, if I can tell the research world

 that these are important issues and there is no one else who is

 going to be able to do it, because I've spent my whole life, my

 whole career looking at post-farm organic marketing and the

 post-farm system. So it was like a personal agenda that I was

 just -- I just thought like it's time, people, can't you see

 how this is important.

 So the purpose of his project was actually to develop

 a research agenda, as opposed to understand say like the impact

 of climate on farm risk and what that might mean for crop

 insurance. So that would have like a different set of output.

 So this just by design, I have to do a lot of output, outreach

 to other people to try to stir up interest in understanding the

 economics. Sustainability for organic farms is extremely

 important. And if you don't really look post-farm, then you

 are not really supporting the economic sustainability.

 So it's more of like a push to, yeah, we have --
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 looking at pest control is important and looking at weed

 management is important. But if you can't sell your product

 then what good are you as a farm. Like how long are you going

 to stay in business. So I think it's just specific to this

 type of project.

 CHAIR POWELL-PALM: We're going to go Wood, then

 Nate, then Dilip.

 BOARD MEMBER TURNER: I appreciate the comment from

 Franklin and from Carolyn. But I also want to say -- and I do

 think the role of the private sector in stimulating some of

 these -- some of this research is important. But there is

 nothing more important -- we all know you can smell

 industry-funded research a mile away. And we are good at that.

 So it's really, really important to have this kind of funded

 research, government-funded research to really bolster these

 topics and help support the growth of these markets, because

 that's, that's the heart of the matter.

 So I totally get the point. But I -- but I also feel

 like I can't overstate the importance of to the industry as a

 whole in really advancing these with federal funds.

 CHAIR POWELL-PALM: Nate?

 BOARD MEMBER LEWIS: I'm trying to collect my

 thoughts. But also in reaction to Franklin's comment about

 endowments in particular, I know Clif Bar provided a $1 million

 endowment to Tuskegee. And I'm just sort of curious if there 
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111

 is a role for the Board to play in sort of telling the story on

 how private investment can -- what, what private investment

 does.

 I'm sort of intrigued by just the concept of

 storytelling in general and how much this Board can engage in

 that to showcase to the industry how to participate in a

 meaningful way. So I don't know, it's a little bit of a

 nascent thought. But I'm intrigued by that idea, as opposed to

 very sort of like technical and granular topics for programs.

 And I think our Board is accustomed to that type of activity,

 but I'm hoping to encourage us to think about how we can branch

 out more into the storytelling and to sort of highlight

 successes, and invite the industry to participate in a

 meaningful way. So --

 CHAIR POWELL-PALM: Let's go Dilip and then Carolyn.

 BOARD MEMBER NANDWANI: Thanks, Nate. I want to add

 to what Carolyn and in response to a discussion, and wanted to

 add first about the approval of these grant proposals, when

 researchers and others, they submit to the funding agency from

 as a nationwide. For confidentiality, I won't way the name of

 the agency, because that's how we do. But there is a Ngouajio

 review, grant review panel, and I have served on that. And I'm

 sure others have served.

 From the organic research standpoint, 10 percent of

 those submitted, I don't know you heard, met Ngouajio. And I 
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 know he mentioned this so I can quote him. 102 proposals were

 submitted I think 3 years back and only 10 or 12 were funded.

 So the proposals, they go to where they get responses. And the

 panel is experts. There are experts in organic agriculture

 nationwide. So they go through each nitty-gritty and each

 aspect, and the top 10 organic proposals are accepted.

 Now second point, each grant proposal, they have a

 very also huge farm net and there is one point without that it

 cannot be accepted. That is a stakeholder advisory committee.

 So those proposals have to be based on the stakeholders,

 basically the farmers and the stake leads, they have to

 incorporate into those proposals. After the approval, then

 task -- the real task begin with the researchers and the PIs,

 that they have to deliver these, all those listed items, as

 well as the feedback every 3 months quarterly from the

 stakeholder advisory committee. And that sounds very vigorous,

 because we all are going through with that. And if there is

 anything that is lacking, they have to go back and suggest, and

 we -- all of the experts.

 One point also I want to make about there are several

 center of excellence recently we have seen from funding

 agencies. I have yet to see a center of excellence proposal in

 organic agriculture in the nation. We don't have that yet.

 And that's something we can add, include that, or we cannot ask

 to Nate, also, and I'm sure he will be happy to look into that, 
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 also.

 Just while discussing this thought came to my mind

 and I thought we could have probably a center of excellence in

 organic. And that is a long-term funding. Like we are saying

 3 to 5 years. It could be 5 to 10 years. And in that they can

 have year-wise three years more, those projects, which can

 target all of these research priorities which we are discussing

 here. And that can cover what we are here on the annual basis

 we are soliciting. I just wanted to add that. Thank you.

 CHAIR POWELL-PALM: Let's go Carolyn and then

 Franklin.

 BOARD MEMBER DIMITRI: Okay. I'll try to be very

 brief here. I think as Dilip said, all of these grants are

 reviewed -- grant proposals are reviewed by panels. And I've

 sat on the OREI panel. They do the organic grants. There are

 some industry people in this room, I won't look at them, that

 have sat on panels with me. It's all confidential. And so

 every one of these panels has farmer representatives and they

 have representatives from different parts of the organic

 sector. It's not just academics.

 So I would encourage you or anyone that's interested,

 maybe this is something people on the Board want to do when

 they rotate off the Board, is to participate on these

 particular panels. It's really fun and interesting to see what

 people are working on. 
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114

 And then the other comment, I just wanted to echo

 what Wood said about industry-funded money. I mean one of my

 colleagues is Marion Nestle and so we're like all we do not

 take industry-funded money in my department under any

 circumstances, not even for a lunch. Anyway, thanks.

 BOARD MEMBER QUARCOO: Okay. So that, that's one of

 the things. So with 10 out of 102, there are a lot of

 proposals, very good proposals that don't get funded. So if

 you look at that number, it's just a panel that sits and say,

 okay, these are the 10 best proposal. It's very frustrating.

 If we put together a proposal, it's a lot of work. And then

 nothing.

 So I'm just saying, and we take -- my, we take money

 from industry. Just there is an agreement to sign. I've done

 it a number of times. If you ask me to test a product and I

 tell you have to sign something that says even if your product

 is not good, I still reserve the right to report that it's not

 good. So I can still maintain my credibility, even though I'm

 working with. And if you do not agree to sign that, then I

 take it that is not worth my time to conduct this research.

 But what I'm saying is that that number 10 that I

 mentioned out of 102, it's not unique. It happens often.

 That's a few people get it. We have to increase federal

 funding, it's important. But we have to have other avenues for

 a long list of people who have great ideas are ready to work, 
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115

 but not funding. And then some of this external funding or

 private funding also introduces a lot of flexibility in what

 can be done with, with the funds. Thank you.

 CHAIR POWELL-PALM: Thank you. Thank you, both,

 Dilip, and Franklin, and Carolyn. We really appreciate a

 scientist voice. Allison?

 BOARD MEMBER JOHNSON: Just to underscore Franklin's

 and Dilip's points, I did some research into whether we could

 create an organic center of excellence, and did some outreach

 to a number of historically black colleges and universities.

 And the number one thing that I heard is we're so

 under-resourced, like to have the capacity to apply for money,

 to have enough money to apply for money is the number one

 struggle.

 So any, any source of funding is crucial. And it's

 really this sort of self-perpetuating cycle that a lot of

 universities are stuck in where they are under-resourced and

 that makes it harder to get the resources. So larger

 institutions have access to funding.

 So the more ways that we can find to carve out

 funding streams, create like research criteria that will help

 funnel resources to those institutions that are not getting the

 resources they need to just do the work to begin with, much

 less grow a new big program that's focused on organic is step

 number one in my mind. 
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 CHAIR POWELL-PALM: Thank you for that, yes. Dilip?

 BOARD MEMBER NANDWANI: I'll just quickly add this

 comment. Last couple of years, I'd like to thank Fredrick

 Gorman (ph.) and national organic program. They have released

 huge, huge funding, $100 billion and I heard $300 million in

 other programs. And at least I am all well with these grants,

 six grants and lot of funding. So at this point, I am going to

 be onwards very careful applying for the new grants. Rather, I

 would seek any research priority which is very organic, for

 example, center of excellence is coming, maybe I will look in

 to that. Otherwise, I think I am good for funding. We have

 enough and I don't need anymore funding.

 CHAIR POWELL-PALM: That is the first time a

 scientist has ever said those words. Mark it down, folks.

 We're coming up on lunch. I've been thinking, I, I had a very

 brief career in academia and was always -- I felt like this is

 always a struggle for me as a farmer, when I knew the issues

 that I wanted to address. I've seen them addressed on farms,

 figured out on farms. And so that's the -- going back to

 trying to prove it out in a way that was consistent with the

 scientific process was always a point of frustration, which is

 why I am not an academic.

 But I think when we look through these research

 priorities, I, I just get a sense of a transfer from

 conventional thinking where we're always looking at a supply 
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117

 side problem. That we want producers to produce more, more

 cheaply, with fewer resources, as opposed to saying, and this

 is why I am just so grateful that Carolyn is on this Board,

 saying we don't just have to look to the farmer to fix these

 problems.

 When we say there is not enough money in organic

 milk, we don't need to think produce more organic milk for

 cheap. That's a conventional solution. If we say we can just

 figure out how to derive and drive more revenue to those farms,

 producing less is not an issue. And so it's a choice we each

 have to make of how do we contextualize these requests for

 research.

 And so as I go down the line stuff list, I had a few

 of my colleagues on the Board, and I, when the Ukraine War was

 breaking out, I will see invasion by Russia of Ukraine was

 breaking out. There was a ton of energy behind how do we deal

 with the supply chain problems. What are we looking at for

 addressing high dairy feed prices and chicken feed prices. And

 so when we reached out to several researchers who are in the

 poultry nutrition space, they asked what do we think of ham.

 And I love the curiosity, but I also feel like there

 is a gap in what we have right now and what we have in our

 toolbox. And I think Amy was always bringing this to the floor

 and saying I raise soybeans, I raise corn, we can raise yellow

 peas, we can raise all these things now. We don't need to 
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118

 figure out how to research the agronomy of a new crop. We need

 to figure out how to better use what we already have.

 So as we go through these different things, I want us

 to always try to hopefully check our mindset for are we asking

 -- do we have proof that what we're asking for is a deliverable

 the farmers or anyone else in the supply chain actually needs.

 Or do we have proof that it would be something that would move

 the needle.

 And I think I was -- I was so grateful to see us

 actually take quite a few things off this list that have been

 there for a really long time. And when we talked about it, I

 think a lot of us couldn't really identify who this would

 benefit. It's more theoretical. The idea of developing a cow

 bread that is more suitable to organic dairy production is

 really not our issue right now. We can produce plenty of milk.

 And if we hear from farmers, we're producing too much mil to

 match the market right now.

 So thinking about how do we really identify what's

 going to move the needle and then get the word out there. To

 Carolyn's point and I think to a lot of different commenters'

 points, the communication side of academia is chronically the

 worst part. That there is all this great research out there,

 but there is not a good pipeline to celebrate it and to get it

 into the hands of the folks that need it.

 And so I think similar to why is organic so great, it 
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 is a parallel path for that communication to what research do

 we actually need that's going to move the needle. And so I

 want to thank Wood as we -- as we look to going to the vote

 here. For all the really intentional questions that we've

 asked for how do we use this, well, Michelle sent us recently a

 reminder of the OREI grants that were given out. And I quickly

 put them side by side with our research priorities and I saw

 almost no Venn diagram. It was two different cams of things we

 didn't really ask for that were funded.

 And so we're doing something wrong if we're not able

 to pull those researchers in and have them understand or have

 us understand what they are interested in doing. Pulling the

 labs in, understand their focus, and then saying, okay, we can

 work together and we can have a little bit of crossover here.

 So as we look to the next rotation, I would love for

 the community to help us rank these priorities or come up with

 better priorities, and look at what do we actually need to do,

 give us some numbers for what you think if we solve X problem,

 the good that would come from it. And I think that's going to

 make communicating it a lot easier. And, heck, if we don't get

 federal funding, then private funding.

 But I do want to elevate what Wood said in that

 organic is such a special place because it is owned by the

 public. And I love the idea of us pushing for more federal

 funding, easier access to federal funding, because it keeps it 
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 in that same ethos, that this is a public good we're creating.

 We're not just creating research for private dollars.

 No applause necessary. I was just -- I just really

 appreciate how much we have given to this thinking. And I

 think it's evolved quite a bit since, since I first came on the

 Board. So many thanks to everyone. Dilip, did you have

 something?

 BOARD MEMBER NANDWANI: Sorry. Normally, I don't

 talk much. But I just realized that one of the stakeholder

 recently mentioned and I thought I will share here. What you

 mentioned, excellent, excellent. I'd like to applaud on that

 also, like others. But one of the area which is organic

 breeding, I think other day I mentioned from 2001 and 2023, we

 have come long way. We have organic seeds in almost lot of

 crops what we need, but still probably some of the crops doing

 seeds are not available with the stakeholders farm as they

 need. Maybe in wild crops or some, some other crops.

 So we know that. And we heard Organic Farming

 Research Foundation where last year our top challenges in

 organic farming, and top one we all know that weeds,

 insect-based and disease, those are the top two challenges. Do

 we have -- I don't know where we can fit, fit into this

 priority, Wood, or maybe Franklin, you can help here, to

 produce disease-resistant or weed-resistant tolerant,

 insect-based resistant crops, grow -- genetic engineering is 
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 prohibited below that. And how they are -- I don't want to say

 successful, but how they got attention, because they had this

 chain of insect-based resistant crops.

 We have that here. And I remember now Albert Hubbard

 (ph.) what he mentioned that to make your plants so strong that

 the insect-based and disease, they won't attack. And one of

 the technique or tool we have to breeding, and I don't see a

 lot of research being done. Serving on a lot of these panels,

 again being confidentially, and Carolyn, she was also part of

 this panel, you don't see a lot of research in breeding in

 organic agriculture research.

 So I just want to throw out there that one of that

 area where we can probably put somewhere in this list to focus

 on organic breeding to maybe organic seeds or have these

 insect-based disease and beetles in plants in future. Thank

 you.

 CHAIR POWELL-PALM: I couldn't agree more. A quick

 anecdote before we, we break. But we had fabulous moisture in

 Montanna this year, really good crop growing conditions. And

 conventionally we were getting like 110 bushels, which is dry

 land, no irrigation, which is really banging. And we really

 hit a ceiling in organic, still around 40 bushels, even though

 we had all the water which is normally our limiting ingredient.

 And several buyers, who are very much in the space

 trying to promote organics, lamented that the breeding, and 
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 this is not news to anyone, but the breeding of weeds is really

 oriented towards being a kind of a soft crop. That it wants

 that fertility right there. It's not going to look very hard.

 It doesn't want to forage, to hunt for nitrogen. And they just

 -- they lamented that they don't feel like there would ever be

 enough money in organic to incentivize breeding really strong

 varieties that could perform, maybe not to 110 bushels but to a

 better maximum.

 And I want to tell them that that's not true. I want

 to go back to my people and say that there is a path forward

 for getting good breeding out there in organic seeds. And so I

 put it to the community to help us ideate on how we identify

 that funding, how we identify the right scientist, and how we

 build those relationships. Nate, please go ahead.

 BOARD MEMBER LEWIS: What was the protein, though, on

 that.

 CHAIR POWELL-PALM: It was lower. But, but even with

 -- that's a very good point. With conventional, you can pour

 on hundreds of pounds of nitrogen and keep that protein fairly

 stable where it's still hitting those premium markets. Winter

 wheat would have been down. And this is so in the weeds,

 folks, I'm so sorry. But winter wheat a little bit lower. But

 functionally they're able to capture both the value for the

 bushels and the quality. That's something that we can hope

 for, for organic. Because if we are getting those yields, 
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 again I think we think about our goalpost, when an organic farm

 is producing 110 bushels in optimum circumstances, we will

 probably see lower prices on the shelf. That this will be

 something that makes it so that we can make this food more

 available, along with a host of other opportunities. I think

 to close this out, Wood, before we go to vote on this.

 BOARD MEMBER TURNER: Thanks for the opportunity to

 chair the committee the last couple of years. I look forward

 to supporting the leader moving forward.

 (Laughter.)

 CHAIR POWELL-PALM: I don't like this, this

 trajectory we're going on. It's like a soft resignation. We

 worked my class too hard. All right, well, with that, let's

 see, we will go to the motion for our 2023 research priorities.

 Wood, if you would read it in?

 BOARD MEMBER TURNER: Sure. Motion to accept the

 proposal on 2023 NOSB research priorities, yeah --

 CHAIR POWELL-PALM: Motion by Wood.

 BOARD MEMBER TURNER: Motion by me. Seconded by

 Dilip.

 CHAIR POWELL-PALM: All right. And folks these

 conversations are so good, so I'm just going to guess that

 we're like in this area. So Kyla, we're going to start the

 voting with you.

 BOARD MEMBER SMITH: Yes. 
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 CHAIR POWELL-PALM: Amy?

 SECRETARY BRUCH: Yes.

 CHAIR POWELL-PALM: Kim?

 BOARD MEMBER HUSEMAN: Yes.

 CHAIR POWELL-PALM: Franklin?

 BOARD MEMBER QUARCOO: Yes.

 CHAIR POWELL-PALM: Wood?

 BOARD MEMBER TURNER: Yes.

 CHAIR POWELL-PALM: Logan?

 BOARD MEMBER PETREY: Yes.

 CHAIR POWELL-PALM: Carolyn.

 BOARD MEMBER DIMITRI: Yes.

 CHAIR POWELL-PALM: Allison?

 BOARD MEMBER JOHNSON: Yes.

 CHAIR POWELL-PALM: Brian?

 BOARD MEMBER CALDWELL: Yes.

 CHAIR POWELL-PALM: Nate?

 BOARD MEMBER LEWIS: Yes.

 CHAIR POWELL-PALM: Dilip?

 BOARD MEMBER NANDWANI: Yes, yes.

 CHAIR POWELL-PALM: Gerry?

 BOARD MEMBER D'AMORE: Yes.

 CHAIR POWELL-PALM: And the Chair votes yes. All

 right. And with that we're going to break for lunch. We're

 going to come back at 2:15. And we're going to have an 
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 election. I'm sorry, Michele?

 SECRETARY BRUCH: One second.

 CHAIR POWELL-PALM: Oh, sorry. That was too quick.

 I'm too excited.

 SECRETARY BRUCH: That's okay, no problem. 13 yes,

 zero no, zero abstentions, zero recusals, 2 absent. The motion

 passes. Thank you.

 CHAIR POWELL-PALM: Because we've stolen 8 minutes of

 your time, we're going to come back at 2:20.

 (Whereupon, at 1:08 p.m., a lunch recess was taken.) 
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 A F T E R N O O N S E S S I O N

 (2:26 p.m.)

 CHAIR POWELL-PALM: Welcome back, everybody. To

 finish out the day today, we're going to move onto officer

 elections, talk about our future work agenda items, materials

 update, and other business. Those two are going to be out kind

 of bucket to business other items. And then we're going to

 finish out. Thank you to those who are still hanging on both

 here and online. I hear there are about 50 people online. So

 thanks for going all the way to the end.

 It's -- when I was first coming up, first year NOSB,

 Steve Ela would politely call every semester and say, so, you

 think leadership maybe sometime? And there's always a wide

 open door to say no. But I so appreciated that it was a

 precedent that anybody could be given the chance to lead this

 crowd. I think it's really reflective of the true nature of

 the democratic process for us. But this little talk I want to

 give is mostly a love letter to Mindee Jeffrey. And I'm going

 to cry, so just bear with me, everybody. I mean Carolyn is

 like, wow, NOSB may cry, shocker.

 When we were coming up to fall meeting and, and Steve

 had asked everybody what are your thoughts on leadership,

 checking in with everybody, I had -- I had really gotten

 excited about fenbendazole back in -- back in the day,

 fenbendazole in chickens. And so I wanted to call -- and I 
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 would, I would again give a shoutout to Steve when I said I

 don't know about fenbendazole, but it seems like LISAC (ph.)

 committee is saying, yeah, send it. And he's like I don't

 know, they might be there to say that maybe it's not a good

 idea. And it sort of gave me the inspiration to just start

 calling folks and seeing what they thought.

 And so when I called Mindee, I'm like so what do you

 think about leadership. And she's like I think you need to

 send it, bro. Like you need to step the up and let's do this,

 like let's look at leadership, you and me. And there was a

 certain confidence that she brought to that conversation saying

 it's not going to be handed to you, that you have to earn it.

 And I think she brought this radical empathy that I have only

 begun to understood -- understand in the last little bit, the

 vision that she had for what this team could be.

 And I think since so many boards before us and I hope

 some of the boards after us have been asking this question.

 How do we do the best work possible? I think that we can

 hopefully in the future look back and see Mindee's work as a

 key ingredient to the collegiality and the success that we are

 experiencing with this group today.

 I'm going to wait until next year to give a shoutout

 to each and every one of you, because it has been a true honor

 to serve all of you. I really appreciate the confidence that

 you placed in me over the last two years. It's rare, I think, 
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 that we get the chance to -- I get the chance to be here

 another year and hopefully be as useful to the next group of

 leaders as possible. And I'm just so dang excited about the

 next group of leaders and how we have a pipeline. We've really

 considered a deep bench and again I give a lot of credit to

 Mindee for thinking about not just this election, but over the

 next six years how we set folks up in positions of leadership,

 where they are learning how to be effective, compassionate, and

 truly visionary in how they try to lead this Board into the

 next era.

 Last night we had a few conversations about what is

 the secret sauce that's going on in NOSB these days. And I

 throw no shade at previous boards, but I think we are doing

 pretty well. And I think there's a few things. And I would --

 I would put this out to the community to think about. For me,

 starting with fenbendazole, I got really comfortable calling

 every single member all the time. And probably a little bit

 too much for some of you, but asking your opinions and

 wondering where are you landing on this.

 I think Steve Ela set a tone of collegiality that has

 persisted. And I remember in ammonia extracts that I was

 vice chair then. And I gave Logan a really hard time. She was

 so gracious. And I think we both allowed each other to fight

 it out on Zoom. The second we were off that Zoom call, we'd

 call each other and say nothing personal, right? And, you 
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 know, what do you want to do? How can I help you? Is there

 something else where we can agree on and where to identify not

 our differences but our commonality.

 And I think that diversity of thought and the ability

 to say that this Board, as far as we can take it, is a family.

 That this Board treats each other really well. And that

 whenever anyone comes for any one of you, I've always wanted to

 be ready to say un-un, these are our people. And we can have

 very tough conversations, that I think we experienced

 throughout this week. But we all know that it's a place of

 deep safety, that it'll never devolve into the personal. It

 will never be a place where we can't immediately hop up and go

 to lunch together. And it will always be a place that we hold

 each other sacred. And I think that I am just 1, 1 of 15 and

 trying to do that work that you all have let me do that work.

 And I’m so grateful to you all.

 As we go forward, again, I think that I'm really

 bummed that -- rather, I know I'm really bummed that Mindee

 isn't here. Oh, I hear Mindee is listening, okay. I'm, I'm

 looking at Mindee's -- she always talked about democracy. And

 for the longest time I couldn't quite track where she was going

 with this. I'm talking about years she would talk about

 democracy. I'm like, yeah, we're Americans. We love

 democracy, okay.

 And as I -- as I've gotten to learn from her, looking 
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 at how the biggest piece of the democratic process is that when

 it doesn't go your way -- when it goes go your way, we don't

 question it. When it doesn't go your way, accepting it and

 saying that we put it to a vote amongst all of us, that if it

 doesn't turn out, similar to how we do elections in general,

 when it doesn’t turn out your way that's fine. Let's keep

 going, as opposed to resting, and obsessing, and staying on one

 topic.

 I think that that is something that as Mindee has

 described the power of this Board as a democratic institution,

 I really came to appreciate that everyone in this room has held

 that sacred. That after the vote is done, we move on. And we

 don't leave ideas. We don't lose values. But we do try to

 keep the work going forward. And I think that is something

 that I will always be grateful Mindee taught me.

 So as we move to Board elections, I will give a huge

 shoutout to Mindee Jeffrey. I am very grateful for the chance

 to serve as -- you let a 29 year old be your chair. I'm just

 shocked. As your youngest chair and as a chair who got to

 serve two terms, and then I get a whole year to be a servant to

 whoever is coming next. And I really hope to be of use to you

 all.

 I hope I speak for Mindee as well that this has been

 an opportunity to make a really big tent of leadership. There

 has been no gatekeeping over the last two years. When we say 
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 leadership, we want to invite everybody in. And I think we've

 built a pretty good team. Historically, I think the Chair got

 to meet with Jenny a lot. And I wanted to make it so that the

 Chair, the Vice Chair, the Secretary, everyone who is leading

 this Board sees the program as a partner. And I think we've

 gotten to get -- we've had the chance to get ahead of

 miscommunications, poor communications, blocked communications,

 because we've had everyone in the room, and we can assure

 everyone that there is real partnership with this program.

 And so I am really excited as we go into this next

 year how we can keep this train going. I'm going to do my best

 to keep serving you all in any way I can. And I really thank

 you again for the confidence and the chance to serve. Thank

 you.

 (Applause.)

 CHAIR POWELL-PALM: Thank you. Let's now go to some

 nominations. So we're going to start with the position of

 secretary. I am not running again, so I am, if it's all right

 with everyone, going to be the vote counter. And we're going

 to start with the secretary. We will accept nominations for

 the position. After nominations are confirmed -- we're going

 to start with the pink card. That's going to be our secretary

 card -- oh, let's start with the green card. I didn't have a

 blue card, so I wasn't thinking that. The secretary might be a

 man, you never know. Like good point. 
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 We're going to start secretary with the green card.

 The white card is going to be vice chair. And the pink card is

 going to be chair. So with your green card, I would open the

 floor to nominations for the position of secretary for the

 NOSB. Gerry, please go ahead.

 BOARD MEMBER DIMITRI: I'd like to nominate Nate

 Lewis.

 CHAIR POWELL-PALM: Thank you. Nate, do you accept

 the nomination?

 BOARD MEMBER LEWIS: I just learned how to count to

 15, so, yes, I will accept that nomination.

 CHAIR POWELL-PALM: Kim?

 BOARD MEMBER HUSEMAN: A question for you about two,

 and seven, and four, but we'll skip that for now.

 BOARD MEMBER LEWIS: I know how to play -- I'm a big

 cribbage player, so I'm really good at 15.

 BOARD MEMBER HUSEMAN: Okay, good to know. I would

 like to nominate Allison. The voice that you bring, the

 background that you bring, your viewpoint, I really feel like

 you would be an excellent person on the -- not that there's

 others that aren't as well, but I really appreciate my time

 with you and I would like to nominate you as secretary, also.

 CHAIR POWELL-PALM: All right. Any other

 nominations? Oh, I apologize. We assumed that you're too

 qualified, Allison, so you're automatically accepting. Please 
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 do formally accept it.

 BOARD MEMBER JOHNSON: I do accept. Thank you.

 CHAIR POWELL-PALM: Thank you. Other nominations for

 the position of secretary? All right. So we have Nate Lewis

 and Allison. If you would take your green card and write the

 name of your preferred candidate on the back, fold it in half,

 and pass it to me.

 (Pause.)

 CHAIR POWELL-PALM: Do we announce the tally? No,

 okay. Thank you very much both for running. The winner of

 secretary for this coming year is going to be Nate Lewis.

 (Applause.)

 CHAIR POWELL-PALM: But that doesn't mean you're not

 in the pipeline, Allison. So plan to come to these leadership

 meetings. We appreciate you. All right. We'll move onto the

 position of vice chair. Nominations for the position of vice

 chair?

 BOARD MEMBER PETREY: I'd like to nominate Amy Bruch.

 CHAIR POWELL-PALM: Amy, would you accept that

 nomination?

 SECRETARY BRUCH: Yes. Thank you, Logan.

 CHAIR POWELL-PALM: Carolyn?

 BOARD MEMBER DIMITRI: I would like to nominate

 Allison.

 BOARD MEMBER JOHNSON: I love it. 
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 CHAIR POWELL-PALM: So we have Amy. We have Allison.

 Other nominations? Do you accept, Allison?

 BOARD MEMBER JOHNSON: Sure. Thank you.

 CHAIR POWELL-PALM: All right. With your white card,

 please write the name of your preferred candidate, Amy or

 Allison, for the position of vice chair.

 (Pause.)

 CHAIR POWELL-PALM: With all votes tallied, our next

 vice chair will be Amy Bruch. Congratulations.

 (Applause.)

 CHAIR POWELL-PALM: And lastly we will open for

 nominations to the position of chair. Amy, please go ahead.

 SECRETARY BRUCH: I would like to nominate my

 tablemate, Kyla. I appreciate your technical aptitude, your

 dedication to the community, and just your overall leadership.

 Thank you.

 CHAIR POWELL-PALM: Other nominations for the

 position of chair? With one nomination, I propose we vote by

 unanimous decree, consent. Any dissent for Kyla as the chair

 of the National Organic Standards Board 2023-2024 year? All

 right, congratulations.

 (Applause.)

 BOARD MEMBER SMITH: Thank you. I feel quite honored

 and humble. So I look forward to working with all of you.

 CHAIR POWELL-PALM: All right. We will keep going 
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 with the agenda for the day. Congratulations, all three of

 you. For chair, we have Kyla Smith. For vice chair, Amy

 Bruch. And for secretary, Nate Lewis. I'm really excited for

 this team. This is going to be a great year. So thank you

 again, everybody.

 All right. Next up, we're going -- do we need a

 break? We're doing good? Please, go ahead, Carolyn.

 BOARD MEMBER DIMITRI: I want to thank the three of

 you for being willing and also you, Allison, for being willing

 to provide leadership. I think it's a really hard job and

 probably pretty thankless. So I'm going to thank you in

 advance for everything.

 CHAIR POWELL-PALM: It's a reminder for us all to

 thank them actively throughout the year. Thank you, to start.

 All right, going down into materials update and NOSB work

 agendas. Do we have a slide -- there we go. I'm going to

 start it off with -- let's go back. I'm not going to read it.

 I made that mistake last October. But I'll try to slowly

 scroll. And this is all publicly available, so you can take

 pictures of it. But it's available on the website, as well. 

 (Pause.)

 CHAIR POWELL-PALM: As Kyla mentioned, it's going to

 be a popping handling season. Holy smokes. A lot of materials

 to cover.

 (Pause.) 
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 CHAIR POWELL-PALM: So I'm going to hand it over to

 Nate Lewis for a little update on compost and inerts.

 BOARD MEMBER LEWIS: There should be some slides

 there that I entered. So my, my compost comrade, Mindee

 Jeffries, unfortunately isn't here. So I'm pinch-hitting for

 her. Thanks. So the Board is going to take on the issue of

 compost use in organic agriculture. And this is a topic that

 near and dear to both Mindee and myself. We're both certified

 compost facility operators. Mindee actively manages a

 commercial composting operation and I compost on my farm.

 So right now we're dealing with a number of updates

 that we're looking to discuss as a Board and with the

 stakeholder community. And we and the program has recently

 received a petition for rulemaking from, from BPI, the

 Bioplastics Industry Alliance is the correct acronym descriptor

 there. So let's see. Greenland? Oh, there we go.

 So let's see. Just briefly the areas that we're

 going to be looking at. Currently, compost exists in all parts

 of the rule. So we have compost as a definition. We've got

 compost in practice standard. And we have compost feed stocks

 on the national list. So compost touches all aspects of the --

 of the rule.

 Issues related to compost production that Mindee and

 I are particularly focused on are in the, the definition item

 number 1 and number 3, 1 being the C to N ratio, carbon to 
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 nitrogen ration. These, all these numerics were based on

 composting practices and technology from the '80s, which was

 logical at the time of the promulgation of this rule. But now

 we think it's time to do a revisit.

 You can make good compost with an initial carbon to

 nitrogen ratio of less than 25 to 1. And the wording in

 number 3 around the 15 days is a little bit problematic.

 Oftentimes, turn windrow systems take longer than 15 days for

 those temperatures. And we're going to remain focused on those

 times and temperatures to make sure that they are aligned with

 industry best practices for reduction of human pathogens, which

 is the main -- one of the main benefits of having these times

 and temperatures.

 Again, as I mentioned, it's in 205.203, so we're

 going to be -- which is the soil fertility and crop nutrient

 management practice standard, so we'll be trying to align these

 elements with the definitions. And it's specifically around

 those same issues. So we see these numbers show up both in the

 definitions and in the practice number.

 And then as we saw during this meeting, we just

 renewed the listing for newspaper and other recycled paper as a

 compost feed stock. Compost feed stocks have a place on the

 National List currently. They do not have a definition,

 however. So that is a incongruity that we'd like to resolve.

 But I'm just using this to illustrate that compost is in all 
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 different aspects of the rule.

 I want to acknowledge that the program has received a

 petition for rulemaking. This is a summary. If you -- if

 folks look at the memo that was issued to the Board, the

 petition is referenced as an attachment to that. But as a

 summary, the petition recommends rulemaking to include a new

 definition for compost feed stock. I have it up there. Animal

 and plant materials, and materials meeting compost stability

 specifications, etc., etc. And they recommend replacing plant

 and animal materials with a new proposed term. They do not --

they do not specifically indicate how to address the National

 List category of synthetic compost feed stocks.

 So this is a broad topic, obviously, and a

 foundational one for organic. Compost is a foundational

 material and a foundational principal of organic production and

 touches all areas of the rule. The memo I think appropriately

 but in some way a little bit overwhelmingly reflects that. So

 here is a list of all the stuff that might be included in this

 compost discussion and recommendation, which is pretty much

 everything. Definitions, practice standard, National List,

 guidance, UREC, which is unavoidable residual environmental

 contamination, and then specific contamination and testing.

 Compost as an input in organic agriculture. So the kitchen

 sink approach to a broad topic.

 Any questions from the Board? Otherwise, I can tip 
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 it to inerts.

 BOARD MEMBER NANDWANI: Yeah, this is a -- thanks,

 Nate. I just realized that -- I just realized that reading

 this regulation, which I've been teaching in these workshops

 and often farmers, they ask me a question. These three

 regulations, the points you have mentioned, the turning 5 times

 in 15 days, and the 230 degree Fahrenheit. And so farmers,

 they think that this is a very difficult and cumbersome process

 to making compost. This new recommendation, I'm sorry if I

 missed it, do you think that the process you are going to --

you are proposing or recommending is going to be simpler for

 the end users?

 BOARD MEMBER LEWIS: Hard to -- don't, don't pin me

 down on this, but I would be surprised if we deviated too much

 from that. Those numbers, and the times and temperatures are

 critical for reducing human pathogens found in, in manure. And

 those, those numbers are -- you must follow those numbers in

 order to apply your composted manure outside of the 90 and 120-

-day withholding time.

 So in light of industry best practices and the need

 to make sure that organic food remains safe for consumers to

 eat, I don't anticipate us recommending something that would

 lighten that burden. But in terms of guidance, I think we

 could potentially look at what sort of recordkeeping folks

 would need to, to have. But those, those numbers are widely 
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 accepted and the threat of food borne pathogens, I think, is

 relevant enough that I wouldn't anticipate seeing something to

 loosen those standards.

 BOARD MEMBER NANDWANI: Thank you.

 BOARD MEMBER LEWIS: Okay. What happens if I go --

 okay, we'll just go to -- oh, this is the blank slide. I don't

 have any slides for the inerts group. And I will want to lean

 on other members of the working group. So Brian, Logan,

 Franklin, and myself are taking on, as members of the Materials

 Subcommittee, the memo from the program related to inert

 ingredients and organic pesticide -- or pesticide products

 approved in organic agriculture.

 And as a summary of kind of what we're planning to

 do, our first steps have been to begin to understand the

 options laid out by the program for ways we could move forward.

 So we want to work from an area of common understanding there.

 And we hope to solicit support from Esu and Heather, our newest

 members of the Board and support network to develop a

 comprehensive list of what is currently allowed under List 4,

 and how those would look, and what types of materials would be

 available for use under the various scenarios.

 So we're still in sort of data collection mode so

 that we can develop recommendations based on a common

 understanding and a common set of data. I think I'll leave it

 there. And Brian, Franklin, or Logan want to add any to that, 
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 I would welcome your input. 

 BOARD MEMBER CALDWELL: Just really quickly, I'm

 really excited to be working on this and really excited looking

 forward to getting, getting some serious results. So thanks,

 Nate, for excellent leadership so far. And, you, too, for

 being on that, this effort.

 BOARD MEMBER LEWIS: I think with that I'll turn it

 back over to the chair to discuss other business.

 CHAIR POWELL-PALM: All right. The last thing we're

 thinking about touching on would be annotations. And Kyla,

 would you lead us in that discussion?

 BOARD MEMBER SMITH: Okay. So earlier this year we

 did submit an agenda request that was approved by the program

 for there to be a standing work agenda item in the crops,

 livestock, and handling subcommittees for annotation changes.

 The process that I sort of laid out and we talked

 about at the Executive Committee, so I'm just going to

 reiterate it here is that during the spring write-up of the

 material, we would flag if there is any known annotation

 request by looking back at previous write-ups, or there have

 been public comments that had a little bit more of a

 comprehensive list, so using those two sources or other

 sources. And including that in the spring write-up perhaps as

 a question or here's this annotation wording, does this look

 good, or whatever, you know, we're sort of framing it up to get 
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 feedback.

 Then during the fall write-up, if there was consensus

 around that proposed annotation, there would be two proposals,

 one on the sunset write-up at -- so that we could vote on the

 material that is before us for the sunset process, and a

 separate document that we would vote on that would be the

 annotation change.

 We haven't done that this round, because we thought

 this sort of too late for this group. But I would encourage us

 as we're going into next year, the 2026 sunsets, I know

 Handling has already started work on that, but just to keep an

 eye out for annotation changes and include that as part of your

 write-up so that we could -- we can get feedback and follow

 that process.

 I specifically wrote it this way so that this would

 remain evergreen, like as a process that we are able to do

 ongoing, as opposed to just trying to fix all the things that

 we know and it just not being part of our process. And, again,

 this bakes it in, you know, and it doesn't rely on humans to

 remember or initiate that process, which hasn't seemed to be

 super effective because we have not very many changes, which is

 -- yeah, so here we are.

 I will also just state that as Jenny said earlier I

 think at this meeting just to be cautious with annotation that

 there is an impact to certifiers to verify the annotation, as 
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 well as for farmers, and processors, and other folks in the

 supply chain to implement the annotation. And so we're not

 trying to go annotation happy here and making tons of changes.

 But where they -- where there is clarity needed, we have the

 mechanism to, to do that.

 CHAIR POWELL-PALM: Questions for Kyla? Nate.

 BOARD MEMBER LEWIS: I think I know the answer to

 this, but can you clarify if the annotations would come as a

 parallel to a clean renewal vote for --

 BOARD MEMBER SMITH: Yes.

 BOARD MEMBER LEWIS: So, yes, it would be a parallel.

 BOARD MEMBER SMITH: Yes.

 BOARD MEMBER LEWIS: Okay.

 BOARD MEMBER SMITH: Otherwise, we will find

 ourselves in the sodium nitrate problem, because that, that's

 why they changed the process to not do annotation changes at

 sunset was because that motion didn't pass. And here we are

 having an invalid listing. So we need both motions and votes.

 BOARD MEMBER LEWIS: So we will always have the clean

 sunset motion.

 BOARD MEMBER SMITH: Yes.

 BOARD MEMBER LEWIS: And then there is a possibility

 to have a parallel one that either amends or introduces a new -

-

 BOARD MEMBER SMITH: Yes. 
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 BOARD MEMBER LEWIS: -- annotation.

 BOARD MEMBER SMITH: Yes.

 CHAIR POWELL-PALM: Logan, then Dilip.

 BOARD MEMBER NANDWANI: I'm just trying to

 understand --

 CHAIR POWELL-PALM: I'm sorry. One second. Logan

 first and then Dilip.

 BOARD MEMBER PETREY: Okay. So can we have like a

 template for -- almost like we do for a proposal or discussion

 documents that would be an annotation, so that we can put what

 is the impact of putting this on. Or we notice -- because it

 seems like it has to be done pretty quickly. And so if we can

 make that like clear statement of what needs to be made on like

 a template to, to qualify for that?

 And then also on the sunset, if we can add -- I know

 they were just kind of redone where you have the international

 acceptance, but so that it's easily seen to have annotation

 requests or something like that on our sunsets. That way we

 can -- each person can identify it quickly. That way they're

 not overlooked or anything like that. So having it in the

 language or in the discussion, or something somewhere if that

 becomes kind of a big process. But those are just two

 thoughts.

 BOARD MEMBER SMITH: Thanks, Logan. I would say,

 too, that I think it was Nate Lewis who brought up even trying 
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 to front-end this a little bit more, so as opposed to when

 we're just doing the write-ups. When we're doing the TR

 sufficiency, right? So when we're doing that in the spring for

 the sunset materials that are going to be in like 2027, even

 looking at it then just again to try to like get ahead of it as

 much as possible. Yeah, I thought that was a great suggestion.

 CHAIR POWELL-PALM: Dilip?

 BOARD MEMBER NANDWANI: I think you've already

 answered. What I'm just trying to understand here, are you

 going to work on the new annotations on 2026 sunsets, or some

 materials or the sunsets, they already have annotations we are

 going to read and revise them much?

 BOARD MEMBER SMITH: Yeah. So I'll give an example.

 So phosphoric acid, for example, on the Handling list that we

 just voted on. But let's pretend that that was on our list for

 next year. The community has said that the word cleaner in

 that is inaccurate. And so we would put forth the write-up on

 the sunset as-is in the spring and somewhere in that document

 we would say we're proposing to change the annotation to

 whatever, revise that to no rinse sanitizer or whatever the

 more accurate thing to say versus cleaner is. And that would

 go out. The community would get to weigh in on that as well.

 And then we would have two motions and proposals that we would

 vote on, one the regular listing, one the new annotation.

 BOARD MEMBER NANDWANI: Thank you. 
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 CHAIR POWELL-PALM: Other questions for Kyla? Brian,

 go ahead.

 BOARD MEMBER CALDWELL: Yeah, following up on what

 Logan said. So for the first time around, who, who will find

 out what, what all the suggested annotations are for each, each

 sunset material?

 BOARD MEMBER SMITH: I would say that will be up to

 whoever the lead is. And perhaps the chair of the committee

 could help. I've been tracking things in Handling for a minute

 now, so I'm happy to help.

 BOARD MEMBER CALDWELL: Okay. And I know that, that

 some of our stakeholders have compiled lists, too.

 BOARD MEMBER SMITH: Yes.

 BOARD MEMBER CALDWELL: So we will look for those.

 And if you have any, any suggestions. Michelle should --

 BOARD MEMBER SMITH: Oh, how about this. When the

 open docket is opened after the start of the meeting, anything

 that's on 2026, folks, get in your annotation request changes

 now so we can start building them in.

 CHAIR POWELL-PALM: Carolyn?

 BOARD MEMBER DIMITRI: I mean just to follow-up on

 Brian's question, I suppose we could also, when we put the

 first announcement out for the spring meeting, our questions to

 stakeholders, we could just ask does this need an annotation.

 And I don't know if that would give enough time, but at least 
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 it would get it in the queue and we could write it up in the

 discussion section.

 BOARD MEMBER SMITH: Yeah. That's why, again, we're

 I feel like opening it up to does it. Like in the spring is

 maybe a little bit too late. So I'm trying to get more

 information sooner I think would be better. But yes.

 CHAIR POWELL-PALM: Allison?

 BOARD MEMBER JOHNSON: A though on that point. I

 wonder if we can make a point of posting the list of the

 two-years out sunsets somewhere at the fall meeting or in the

 fall meeting materials. So if there are comments looking

 ahead, people could start to submit those in the fall so we

 have them going into the next spring. I'm not quite sure what

 the right place would be, maybe either materials or, but that

 would be just the reminder. Because I, as a person who was

 outside of this Board, was certainly not thinking about

 materials two years ahead.

 BOARD MEMBER SMITH: Yeah. These are all fabulous

 suggestions. And then one observation question, I guess. The

 order of the motions I think is going to become important,

 because there are a number of materials. I'm thinking of

 liquid fish. If an annotation had changed, that would have

 impacted the decision of whether to sunset it or not. So if we

 vote on the sunset, you don't yet know if the annotation is

 going to be adopted. So whatever we do, we should be clear 
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 going in which order we're going to consider these things in.

 CHAIR POWELL-PALM: Carolyn?

 BOARD MEMBER DIMITRI: Just one more follow-up

 question. I mean I think that we should probably assume it

 will take two cycles for all the annotations to be complete.

 Because I don't know, I just feel like I don't -- this seems

 like a lot of pressure to like identify it before the spring

 meeting. And if we just give ourselves the leeway to say that

 this is a process that might take five years as products go

 through the sunset. And that way, I don't know, it will just

 give us a little bit more room to -- as we move ahead, so we

 can hit the obvious ones right away. Anyway, that would reduce

 my level of anxiety.

 CHAIR POWELL-PALM: Wood.

 BOARD MEMBER TURNER: But technically this is a live

 process. So what Carolyn's saying is -- it makes sense, but it

 could -- there could always be an annotation that could come

 up. This is to make these more relevant in real time. Yeah?

 Is that right?

 BOARD MEMBER SMITH: Yes. I do think, though, that

 like again just to be cautious that I think once we make some

 -- there is definitely clean-up, I think. And I do think once

 we -- whatever, so we're sort of starting with 2026, so once we

 hit 2031, we'll have cleaned up the list in large part.

 Granted, there will be new petition materials, which will then 
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 -- that's why I thought having sort of baked into the process

 was good so that then we didn't have to be like, okay, well, we

 cleaned up the list, but now there's these new things, now

 we've got to do it again. You know what I mean? So --

 CHAIR POWELL-PALM: Nate?

 BOARD MEMBER LEWIS: Allison, your point kind of got

 my head turning about just how those votes impact one another.

 And I think the fish annotation is illustrative of the

 program's ability to decide not to take up an annotation.

 Right? So, yeah, just sort of interesting to start thinking

 about it. It seems like we will be giving them a second option

 for the renewal of these substances, as opposed to a

 substitute. Does that make sense? But it's a really good

 point and got my gears turning. Thank you.

 CHAIR POWELL-PALM: Wood, then Kyla.

 BOARD MEMBER TURNER: This is a little obtuse for me.

 Can we -- can we be clear what we're talking about here? So

 are we saying we want to vote on the annotation first and then

 the listing? I mean I just don't understand what you're

 talking about, sorry.

 BOARD MEMBER LEWIS: And, Allison, join in, too, but

 what I heard Allison say was which vote comes first may impact

 the subsequent vote. If an annotation -- if the annotation

 vote comes first, and that's what you would prefer to see, you

 may vote then on the clean relisting in a different way. And 
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 we just need to be thoughtful about what impact that may have

 one messages we're sending to the community, what the National

 List looks like.

 CHAIR POWELL-PALM: Kyla?

 BOARD MEMBER SMITH: Oh, I was just going to say that

 if the community is submitting things into the open docket,

 providing the, the impact part would be really helpful.

 CHAIR POWELL-PALM: Allison.

 BOARD MEMBER JOHNSON: Yeah, just following up on

 Wood's question. I'm thinking -- and Carolyn's actually also

 about timing. I think the, the logistically correct way to do

 this adding onto the system that we have of sunsets being their

 own thing is the sunset vote should come first. And then the

 annotation is sort of like a bonus. And that allows in the

 case where we don't have the annotation issue worked out in the

 fall, we deal with the sunset and then the annotation

 discussion can bleed into the next meeting.

 But it's not -- it -- it's not an elegant solution.

 It's not a clean way to deal with the issues, because they are

 interrelated votes.

 CHAIR POWELL-PALM: We'll go Gerry, then Kyla.

 BOARD MEMBER D'AMORE: Yeah. Thank you for slowing

 down there, because it struck me that we were going to make a

 presumptive close on something there. And you shook your head.

 If that's what you're retreating from a little bit, then I'm --
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 then I'm satisfied.

 BOARD MEMBER SMITH: I don't -- I don't know that we

 have to decide this today, but I do think we should decide

 before we implement this process.

 BOARD MEMBER D'AMORE: Right. And I think we should

 all be very, very aware. I love this initiative. I think it's

 essential. But I think we should be really, really aware of

 the workload this is going to put on. This is -- this is not

 just a little add-on. And this may sound really strange to say

 right now, but I think we should sort of start of this not with

 the notion that every annotation is evil and consider it almost

 a victory that we can go on with no, no new annotation. Thank

 you.

 CHAIR POWELL-PALM: Kyla?

 BOARD MEMBER SMITH: Yeah. Again, I think that the

 being cautious here is good. And we can try to take it slow

 and just see, because -- what am I trying to say. If, if we

 voted on the annotation change first and then that impacted

 someone's vote on the sunset to not renew it, then it has to go

 to rulemaking. And you could get different stuff in

 rulemaking, where then that annotation we sort of put all of

 our eggs into that basket doesn't go through. And then there

 is no listing. So there is some real impact. Does that -- do

 I need to say that again?

 BOARD MEMBER LEWIS: Say that one more time. 
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 BOARD MEMBER PETREY: Yeah. So for liquid fish, for

 example, if we were to put the annotation that it had to be

 from certain harvested fish and then that was not accepted,

 liquid fish would be off the list. Is that what we're saying

 or --

 BOARD MEMBER SMITH: Right. So if we -- yeah. So if

 there was an annotation change and if we voted it through, then

 the sunset listing we voted to delist it, right? Then the

 annotation change would go to a proposed rule through the

 program. The program would seek comments. They will evaluate

 those comments and decide whether or not to --

 CHAIR POWELL-PALM: Anything the program would like

 to throw in here?

 DR. TUCKER: Okay. This gets really complicated just

 looking at the looks across people's faces. I think -- I think

 I want to build on what Kyla is saying. So if in the same

 meeting that you voted on an annotation, so there's Thing Y and

 we want to annotate Thing Y to do Z, right? And then there was

 another vote that we're going to vote to take Y off the list.

 I'm guessing that we would do one rulemaking that would say

 here are two options with Y, one is to leave it the way it is.

 Another is to do an annotation. A third is to remove it

 entirely. I think that's how -- Jared's nodding. He's not

 kicking me under the table. For the record, the National List

 manager is not kicking me under the table. 
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 So I think we would do -- I think we would end up

 doing rulemaking with multiple options in that case, because I

 think we all learned through the sodium nitrate experience that

 we don't want to go there. And so I think that's how we would

 handle it. And I do want to re-emphasize what Kyla said

 earlier about be careful with annotations. I'm going to just

 give the cautionary tale on how this plays out.

 So let's say a certifier decides to do a

 non-compliance to an operation because they used a material

 incorrectly. And the certifier says, oop, that's prohibited

 material because you didn't use it the say the annotation says,

 so we're going to give you a proposed suspension. And the

 operation appeals that proposed suspension. We haven't seen

 this very often recently.

 However, in the past, those appeals go to the

 administrator's office within AMS. And administrator who, you

 know, may or may not know all the intricacies of the National

 List is going to say I got this poor farmer who saw this

 material on a list, used it, and this -- it's on the list, why

 can't they use it? So he's got the sanitation, but it's on the

 list and why would we hurt farmers.

 And so AMS administrators, and again this has not

 come up under this administrator, so I want to be really clear

 on that. But we did experience this a few years back with an

 administrator who had -- and a couple of administrators who 
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 just had a really hard time with this kind of concept. And I

 promise that if it makes it to an ALJ, administrative law

 judge, they're going to be even more on the farmer's side.

 So that's, that's how this annotation plays out on

 the backend. So those are two different pieces on how this

 plays out. Does that help or make it worse?

 BOARD MEMBER SMITH: No. That makes me feel like so

 much better. I mean especially the like one rule that covers

 different options. Because I was like, oh, man, this could get

 messy quick. So that makes me feel a ton better, thanks.

 BOARD MEMBER PETREY: I'm sorry. I'm not following.

 So you're saying that we could have -- we can vote -- I'm just

 going to use liquid fish since we just went through that. So

 we can vote liquid fish to fail to delist it and then vote the

 annotation to accept it. And then move it on to you. But we

 don't have to delist liquid fish because we want -- we're

 expecting the annotate. But the current listing of liquid fish

 without the annotation, we don't have to delist that. We're

 just trying to --

 DR. TUCKER: Correct. Correct. I was just saying --

 yeah, I was just -- there seemed to be a concern that if we

 delist it that would be weird with also doing an annotation.

 I'm saying that to change the list, we have to do rulemaking.

 So we would consider the delisting recommendation at the same

 time we would consider the annotation. And just have a backup 
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 plan. We'd probably list the third option of just keeping it

 as-is for public comment.

 Now let's take your case. If the Board voted not to

 delist and plain language to keep on, right?

 BOARD MEMBER PETREY: Yes.

 DR. TUCKER: So vote not -- and to keep on the, the

 list, then that would just go through the relisting Federal

 Register notice. That's when they would part ways, where the

 relisting would just happen through a Federal Register notice,

 the annotation then would be considered during rulemaking. So

 that, that would be where the process would split on that.

 Because the material it would be safe to say -- safe to say

 based on the vote. So that part wouldn't require rulemaking

 because you wouldn't be change it. The annotation would go

 through rulemaking to get public comment before that listing

 actually changed.

 BOARD MEMBER PETREY: Okay, thank you.

 DR. TUCKER: Does that help or make it worse?

 BOARD MEMBER PETREY: Yes.

 BOARD MEMBER SMITH: I can make a PowerPoint.

 DR. TUCKER: I feel like an eye doctor, is that

 better or is that worse?

 CHAIR POWELL-PALM: Wood and then Kim.

 BOARD MEMBER TURNER: So ostensibly we're going to

 have more -- there's going to be more things that are going to 
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 need to go to rulemaking. And so we've had a bunch of

 conversations over the course of this meeting about rulemaking

 and delays in rulemaking. And we've celebrated some rules.

 And we've talked about some rules that didn't get made. And I

 just want to make sure that we're not talking about a log jam

 situation here that's going to be -- there's going to be a ton

 of listings here that are going to be sitting there waiting for

 rulemaking, no offense to the program and the process. But

 that's a big issue.

 DR. TUCKER: The program agrees with that concern.

 CHAIR POWELL-PALM: Kim?

 BOARD MEMBER HUSEMAN: Yeah. Kyla, I really commend

 your work in this space, and your understanding and your

 knowledge around it, and the cautionary approach. But I do

 appreciate that we're raising this and that we are discussing

 this, because on the Board I cannot tell you how many times I

 have read a sunset and followed it with and the community

 acknowledges that there should be an annotation that is during

 the sunset process so, and then it just gets -- it gets

 forgotten.

 So I realize this is -- this is not an easy ask. And

 I realize the complexity of it. And then I also appreciate

 the, the thoughts and the aptitude of this Board, because I

 think if we are going to make a stride, we've got a good group

 to, to really do that, to try. 
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 DR. TUCKER: I don’t want my last comment to be heard

 as not supporting this. I just want to make sure that we

 really use it judiciously. I think it's just be careful, I

 think is what the point is from the program.

 CHAIR POWELL-PALM: Amy and then Gerry.

 SECRETARY BRUCH: I think, okay, sorry. Kyla, thank

 you for your work on this. One comment, though, for

 priorities, because this will add additional work and we do

 have a lot going on. One thing the community could do also is

 request a petition for us then to have this on a work agenda

 item for a material in specific that's really ranking high

 correctly. If we're not -- if it's not on our radar, that is

 also another route. I don't see that happening very often that

 we get petition requests from the community for annotations.

 We see it a lot in comments. But that's there can be parallel

 paths here. Because I think still prioritizing is going to be

 important just because we need to manage our other workload as

 well. Okay, thank you.

 CHAIR POWELL-PALM: Gerry?

 BOARD MEMBER D'AMORE: Thank you. I'm just now going

 to have to tail on what you said, because I, I think that the

 first step towards normalization, a manageable situation is to

 have somewhat of a gate, and that's a bad word, gatekeeper

 that, that says this one, this one, this one. When we first

 started talking about it, it almost seemed like each and every 
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 one of us, the lead could say hey. And I think that would be,

 that would, you know, especially out of the gate that we need

 to find a tempo that is satisfying to the workload.

 CHAIR POWELL-PALM: Nate?

 BOARD MEMBER LEWIS: Yeah. In that vein, Gerry, I

 think that may be an area we can build out as an expectation

 for a crop/livestock handling lead or chair, the chair of those

 committees to, to kind of make sure workloads are managed and

 not everyone has every annotation at any one time and sort of,

 yeah, have the discretion to sort of support or encourage to

 delay certain, certain work.

 CHAIR POWELL-PALM: Logan?

 BOARD MEMBER PETREY: So how do we start this next

 year? I guess we're close to April and we don't have any work

 done on that. So, yeah, how do we get started?

 BOARD MEMBER LEWIS: So in handling, I have L-malic

 acid, which it's a little bit of a different issue, but it's a

 classification issue. It's non --

 BOARD MEMBER PETREY: That's right, yeah.

 BOARD MEMBER LEWIS: Non-synthetic, synthetic issue.

 And so handling is a little bit ahead of the other

 subcommittees, but I've already presented on that material.

 BOARD MEMBER PETREY: Yes.

 BOARD MEMBER LEWIS: Outlined the issues and 

 indicated to the subcommittee my interest in bringing forward a 
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 parallel recommendation around classification. So I think just

 as we start doing our sunsets, you can raise the issue.

 BOARD MEMBER PETREY: Okay. We found that issue

 where?

 BOARD MEMBER LEWIS: This one is also -- is a little

 unique, because it was a previous Board agenda item. But there

 are a number of places to look for annotation options. One is

 in the public comments.

 BOARD MEMBER PETREY: Your discussion in the

 previous.

 BOARD MEMBER LEWIS: Discussion in the previous,

 yeah, previous sunset.

 BOARD MEMBER PETREY: Okay. That would be nice in

 the sunset if we do have like kind of an identified area. If

 we can't get some of these on quick enough, that maybe it's

 easy to find. So I need to get to work, is what you're saying.

 I need to read.

 BOARD MEMBER SMITH: So we, you know, because we have

 so many sunsets in handling, we started doing some discussion

 prior to this meeting.

 BOARD MEMBER PETREY: Correct, yes.

 BOARD MEMBER SMITH: And that has been something that

 we have talked about. Like I know I presented on and I don't

 remember what it was at this moment in time, but there wasn't

 any noted annotation. So I would just, you know, we've been 
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 sort of baby-stepping our way in. But, yeah, once new

 subcommittee, not maybe new, subcommittee chairs and vice

 chairs get assigned, I think that could be another just flag

 to, to those folks to help. Because again this is a new

 process.

 BOARD MEMBER PETREY: Okay, thank you.

 CHAIR POWELL-PALM: Any other thoughts or questions?

 All right. Well, thank you for that. I'm really excited about

 this work. Other business, other other business? Okay. Well,

 thank you to the hangers on who stuck with us to the end.

 We're done.

 BOARD MEMBER SMITH: Before we leave, I just wanted

 to give a shoutout and thanks to the outgoing officers.

 CHAIR POWELL-PALM: Thank you.

 BOARD MEMBER SMITH: Nate, you're -- sorry, we'll

 clap, yeah.

 (Applause)

 BOARD MEMBER SMITH: I am, like I said, humbled and

 honored to be able to step into the role as chair. And I have

 some big shoes to fill. I really am so grateful that you and

 Mindee are going to be here as outgoing chair and vice chair to

 help this new crew find their feet. And so, yeah, just big

 thank you and shoutout to Nate and Mindee for their leadership

 for the past two years as chair and vice chair. And Madam

 Secretary, I look forward to being your tablemate soon again or 
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161

 outgoing Madam Secretary, incoming Madam Vice Chair.

 CHAIR POWELL-PALM: I'm very excited for this year to

 come. Allison?

 BOARD MEMBER JOHNSON: I just wanted to pile on and

 specifically thank Nate and Mindee for being whole people here.

 You've really been vulnerable and shared yourselves, in

 addition to demonstrating really strong leadership. So really

 grateful for what you've brought. Hopefully, maybe the next

 meeting we won't cry so much. But I've also appreciated the

 opportunity to cry with you and learn. It's not something

 everyone can do. So thank you for that.

 CHAIR POWELL-PALM: Thank you.

 (Applause.)

 CHAIR POWELL-PALM: Thank you. With that, I'm going

 to hand it over to the Program to close us out.

 DR. TUCKER: First, I do want to thank our I guess

 outgoing team, Nate, Mindee, and Amy. You guys have been a

 delightful trio to work with in leadership. And I want to

 welcome our new leadership, Kyla, Amy, and the other Nate to

 the table. It is truly an honor working with all of you. It's

 nice to have the same kind of group that continuous. I know

 next year we'll start seeing some changes. And I am just

 really thrilled with how this meeting went and the thoughtful

 discourse that this group models and demonstrates all the time.

 It's an honor to be around you. And I just think we are ready 
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162

 to officially close the meeting. Yes? Are you going to do

 your thing? All right, we are closing the meeting.

 CHAIR POWELL-PALM: Final one. I adjourn the

 meeting.

 (Whereupon, at 3:28 p.m., the meeting was concluded.) 
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 at the heari

163

 CERTIFICATION

 This is to certify that the attached proceeding

 before the:

 NATIONAL ORGANIC STANDARDS BOARD

 IN THE MATTER OF: FALL 2023 MEETING

 PLACE: Providence, Rhode Island

 DATE: October 26, 2023

 was held according to the record, and that this is the

 original, complete, true and accurate 

ng.

transcript which has been

 compared to the recording accomplished 

 __________________________

 Elaine M. LaRosee,

 Official Reporter 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 5 

October 26, 2023 

51:18 

accepted (4)

 112:6,9;140:1;

 0:16;34:6,21;68:17;

 95:25;96:16;98:6;

 100:22;105:1,1;

advisory (2)

 112:9,16 

advocacy (3)

agricultural (13)

 7:7,8,23;48:23;

 55:15,17;72:19; $ 

$1 (1) 152:3 111:16,18;112:24; 44:11;65:15;100:7 73:12,15;76:7;88:11,

 110:24 accepting (2) 113:9;116:2;140:25; affect (1) 15,16 

$100 (1) 130:3;132:25 144:15;157:8 13:6 agriculture (9)

 116:5 access (3) added (9) affidavit (1) 33:3;51:5;107:4;

$300 (1) 65:3;115:19;119:25 7:22;13:7;38:1; 89:25 112:4,23;121:11;

 116:5 accommodate (1) 39:3;49:15;52:10; affirmed (1) 136:7;138:23;140:12 

$70 (1) 52:25 64:21,23;65:22 76:13 agronomy (1)

 90:13 accomplished (1)

 103:5 

According (1)

 41:6 

adding (2)

 96:6;150:12 

addition (1)

 161:7 

ag (1)

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Again (46)

 0:16;8:7;31:1;

 118:1 

ahead (22)

 0:21;17:19;44:19;

 68:2;78:12;79:8;

A 

AAAS (1) accurate (2) additional (8) 32:15;40:18;48:25; 86:22;87:11;88:25;

 105:20 34:23;145:21 38:8,19,25;41:15; 55:6,24,24;58:14,25; 94:20;106:5;122:14;

ability (2) accustomed (1) 62:12;90:14;103:25; 59:2;65:6;66:14;67:6; 131:6;132:5;134:12;

 129:4;149:9 111:10 157:8 76:7;78:4;80:12; 135:7;145:5;146:2;

able (14) acetate (1) Additionally (1) 92:21;94:23;96:8,22; 147:12,17;148:11;

 8:1;18:13;37:16; 14:1 7:18 97:8,19,25;98:10; 158:21 

66:4;82:5;89:3; acetone (1) Additives (2) 99:9;121:9;123:1; ah-ha (1)

 103:22;104:20; 84:12 33:12;34:14 127:1;128:5;129:17; 72:1 

107:22;109:11; achieve (1) add-on (1) 131:13,18;135:5; aid (4)

 119:10;122:23; 14:24 151:9 137:14;142:18;145:5; 7:20;32:18,18;50:4 

142:16;160:19 achieved (1) address (4) 147:3;148:21;149:4; aids (1)

above (1) 41:3 12:18;107:23; 151:15,24;153:22; 6:16 

108:23 acid (16) 116:18;138:11 160:4,25 Albert (1)

absent (21) 37:13,14;40:21; addressed (2) against (2) 121:4 

11:22;17:8;23:17; 51:2;57:21,22,23,24; 76:21;116:18 51:10,21 Alexis (3)

 24:23;26:4;27:9; 58:14;59:3,6,9;60:4, addressing (1) agencies (1) 78:23,24,25 

28:15;30:10;32:10; 14;145:14;158:17 117:18 112:22 algae (3)

 40:15;43:5;47:10; acids (1) adequate (1) agency (2) 13:19;32:22;37:6 

55:12;57:19;61:18; 55:22 66:9 111:19,21 algin (2)

 64:7;71:17;75:9,25; acknowledge (3) adjacent (1) agenda (15) 32:21,23 

92:25;125:6 66:25;94:3;138:2 20:15 0:22,22;6:5,7; alginate (9)

absolutely (1) acknowledges (1) adjourn (1) 58:15;101:9;105:7; 33:14,17,20;36:13,

 90:25 156:18 162:3 109:13,17;126:5; 19;37:12,13;38:7;

Abstain (8) acronym (1) adjuvant (1) 135:1;141:13,14; 72:7 

39:19,21;40:4;54:4, 136:15 32:18 157:10;159:6 alginates (19)

 24;92:4,15,17 across (2) Administration (1) agendas (1) 32:11,12,12,15,19,

abstentions (20) 58:1;152:15 38:25 135:16 23;33:8,10,22;35:19;

 11:21;17:7;23:17; Act (2) administrative (1) agent (10) 36:11;37:25;38:15,

 24:22;26:3;27:8; 73:19;77:10 154:2 30:23;32:17;36:5; 18,22;39:1,3,10;72:4 

28:14;30:9;32:9; action (2) administrator (3) 40:20,20;41:15; alginic (1)

 40:14;43:4;47:9; 66:10;68:12 153:16,23,25 47:16;55:21,21;57:25 37:14 

55:11;57:18;61:17; actively (2) administrators (2) agents (3) align (4)

 64:6;71:16;75:24; 135:14;136:9 153:22,25 6:22,22;49:22 67:2;106:16,23;

 92:25;125:6 activities (1) administrator's (1) aggregated (1) 137:16 

ACA (2) 109:5 153:16 19:22 aligned (1)

 58:18;59:2 activity (1) adopted (2) ago (1) 137:10 

academia (2) 111:10 84:17;147:25 76:18 aligning (1)

 116:16;118:21 actual (1) advance (1) agree (8) 103:24 

academic (3) 90:4 135:12 44:20;80:7;90:19; ALJ (1)

 99:17;100:6;116:22 actually (23) advanced (1) 103:12;108:5;114:19; 154:2 

academics (2) 44:21;48:1,6,12; 49:24 121:17;129:2 alleviated (1)

 102:21;113:20 52:24;58:12;65:2; advancing (1) Agreed (1) 37:18 

accept (9) 66:2;69:9;74:3,5; 110:20 85:14 Alliance (1)

 123:16;131:20; 77:22;94:11;98:1; advertise (1) agreeing (1) 136:15 

132:8,11;133:1,2,19; 101:13;102:11; 20:13 90:21 Allison (65)

 134:2;154:15 109:16;118:6,10; advising (1) agreement (2) 11:2;16:4;22:18;

acceptance (2) 119:2,17;150:10; 15:8 79:4;114:14 23:22;25:25;26:7;

 51:16;144:17 155:16 advisors (1) agrees (1) 27:3;28:7;29:25;

acceptances (1) add (18) 68:22 156:10 31:23;35:14;40:1; 

Min-U-Script® Burke Court Reporting & Transcription (1) $1 - Allison 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 5 

October 26, 2023 

42:14;46:17;47:13;

 49:7,13;50:19,21;

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 54:9;55:18;56:12,15,

 22;60:15,19;63:6;

 67:25;68:1,4;70:13;

 71:13;75:17;85:7,15;

 87:8;88:1;89:21;

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 101:3;102:12;103:14;

 115:6;124:13;132:18,

 25;133:5,14,24;134:1,

 2,6;135:9;147:7;

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Allison's (1)

 64:12 

allow (5)

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allowed (13)

 8:19;9:9;30:16;

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 72:11,13,19;76:8;

 128:23;140:19 

allowing (1)

 67:4 

allows (3)

 69:18;93:15;150:14 

almost (8)

 10:2;37:12;98:11;

 119:8;120:14;144:9;

 151:11;157:25 

alone (1)

 80:11 

along (3)

 86:1;103:1;123:5 

alter (1)

 81:11 

alternative (12)

 8:18;33:15;34:4,18;

 49:23;51:7;52:23;

 66:9;68:18;83:7,8;

 84:20 

alternatives (17)

 19:7,20;20:17;

 33:19;34:8,24;41:21;

 43:21;47:22,25;

 48:23;56:1;74:7;

 76:24,25;80:4;84:13 

although (1)

 61:23 

always (17)

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 25;117:23;118:4;

 126:13;129:7,13,20;

 130:15;143:19;

 148:17 

Amen (1)

 105:2 

amends (1)

 143:23 

American (1)

 44:6 

Americans (1)

 129:23 

ammonia (1)

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among (3)

 58:23;72:25;80:16 

amongst (3)

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 130:4 

amount (2)

 9:18;48:16 

AMS (3)

 7:15;153:16,22 

Amy (46)

 11:14;16:16;18:21;

 20:20;23:5;24:9;

 25:13;26:16;27:20;

 29:13;31:11;33:25;

 39:14;43:1;47:4;49:6,

 12;54:21;57:9;59:25;

 61:6;63:18;71:1;

 73:22;75:7;77:13;

 80:8;90:7,19;91:17;

 101:4;103:10;106:5;

 108:3;117:23;124:1;

 133:18,19;134:1,5,9,

 12;135:2;157:5;

 161:17,19 

Amy's (2)

 88:21,21 

and/or (1)

 73:19 

anecdote (1)

 121:18 

angle (1)

 55:4 

Animal (2)

 138:7,10 

animals (1)

 13:19 

annotate (8)

 8:4;10:1;45:17;

 81:4;82:20;83:10;

 152:18;154:17 

annotated (1)

 58:8 

annotation (69)

 7:6;14:17;15:7;

 38:11;45:7,15;58:10,

 11,23;60:3;62:7;

 66:24;67:6;70:3;

 85:22,22;89:10;

 90:25;97:11;141:15,

 19,24;142:3,7,12,24,

 25;143:2,3,16;144:1,

 10,17;145:19,24;

 146:18,24;147:22,24;

 148:17;149:8,9,18,23,

 23;150:14,15,16;

 151:11,12,18,21;

 152:2,7,9,17,22;

 153:11;154:4,15,18,

 22,25;155:10,14;

 156:18;158:9;159:7,

 25 

annotations (12)

 30:20;35:23;45:8;

 58:6;141:10;143:8;

 145:10,11;146:5;

 148:5;153:6;157:14 

announce (1)

 133:9 

announced (1)

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announcement (1)

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annual (2)

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answered (1)

 145:9 

anti-caking (2)

 6:22;55:21 

anticipate (2)

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antioxidant (1)

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anxiety (1)

 148:13 

anymore (1)

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apologize (3)

 82:3;108:8;132:24 

apparently (1)

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appeals (2)

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appear (1)

 7:12 

appears (3)

 8:17;76:22,23 

applaud (1)

 120:11 

applause (7)

 120:3;131:15;

 133:12;134:10,22;

 160:17;161:13 

applicable (1)

 58:13 

application (1)

 56:9 

applications (3)

 9:23;32:20;97:23 

applied (1)

 105:6 

apply (5)

 107:12,21;115:12,

 13;139:18 

applying (1)

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appreciate (19)

 9:14;55:7,10;90:8,

 16;93:12;94:4;95:21;

 106:6;110:8;115:5;

 120:4;127:24;130:11;

 132:21;133:15;

 134:14;156:15,22 

appreciated (2)

 126:14;161:9 

approach (4)

 6:12;105:15;

 138:24;156:14 

appropriate (1)

 62:8 

appropriately (1)

 138:16 

approval (2)

 111:18;112:12 

approvals (1)

 22:7 

approved (2)

 140:12;141:13 

April (1)

 158:14 

aptitude (2)

 134:14;156:23 

arabic (3)

 17:16;24:25;49:21 

arduous (1)

 86:10 

area (9)

 34:9;66:6;90:15;

 120:12;121:13;

 123:23;140:16;158:6;

 159:14 

areas (5)

 35:20;95:11;109:8;

 136:17;138:16 

argument (1)

 48:21 

arm (1)

 51:2 

arms (2)

 51:3,3 

around (16)

 14:3;17:3;18:8;

 48:24;76:17;90:20;

 96:17;102:16;121:22;

 137:7,17;142:3;

 146:4;156:14;159:1;

 161:25 

articles (1)

 105:11 

articulate (1)

 98:1 

articulating (1)

 83:6 

artificial (2)

 12:3,7 

aside (1)

 90:3 

as-is (2)

 145:18;155:2 

aspect (2)

 60:9;112:6 

aspects (2)

 136:21;138:1 

aspirational (1)

 36:3 

assigned (1)

 160:3 

Association (2)

 14:3;79:4 

associations (1)

 41:9 

assume (1)

 148:4 

assumed (1)

 132:24 

assure (2)

 36:22;131:8 

atmosphere (1)

 28:23 

atomization (1)

 7:1 

attachment (1)

 138:5 

attack (1)

 121:6 

attention (3)

 35:18;38:14;121:2 

audience (3)

 0:13;9:14;68:25 

August (2)

 7:14;8:11 

automatically (1)

 132:25 

availability (9)

 18:8;20:23;49:1;

 76:17;77:6;80:8;84:4;

 85:18,23 

available (18)

 12:1;14:5;20:11,18,

 24;22:5;41:21;73:1;

 79:14;80:22;85:19,

 20;90:11;120:16;

 123:5;135:19,20;

 140:21 

avenues (1)

 114:24 

avocado (1)

 45:10 

avocados (1)

 43:14 

avoid (1)

 20:17 

aware (7)

 33:4;41:20;48:1;

 98:18,19;151:6,7 

away (8)

 0:8;47:19;49:16,19;

 51:7;81:11;110:13;

 148:12 

awesome (1)

 91:7 

B 

baby-stepping (1)

 160:1 

back (34) 

Min-U-Script® Burke Court Reporting & Transcription (2) Allison's - back 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 5 

October 26, 2023 

0:11;9:17;17:18; 64:13 55:21 36:2,8;37:5,10,20,23; 7,12;143:7,10,11,12,

 19:18;21:4;38:14; become (2) Bioplastics (1) 38:3,12;39:5,10,17, 13,14,19,21,22,25;

 47:18;52:10,25; 14:15;147:20 136:15 19,21,23,25;40:2,4,6, 144:1,2,4,8,24;145:8,

 59:11,23;64:18;72:3; becomes (1) bio-remediating (1) 8,10,12,16,18;41:25; 13,25;146:3,7,11,13,

 73:5,13;82:22;93:6; 144:22 37:2 42:5,7,9,11,13,15,17, 14,16,21;147:3,8,16,

 101:11,12;112:2,18; beetles (1) bioremediation (3) 19,21,23,25;43:6,11; 18;148:3,15,20;149:6,

 116:19;122:10; 121:15 36:10,15;38:23 44:20;45:6,20,25; 16,21;150:5,9,22;

 124:25;125:9;126:3, begin (3) biscuits (1) 46:6,10,12,14,16,18, 151:2,5,15,25;152:1,

 24,24;127:19;133:6; 112:13;115:23; 72:25 20,22,24;47:1,3,7,11, 6;154:7,11;155:3,5,

 135:17;141:8,20; 140:14 bisulfite (1) 14;49:7,9,18;50:3,5,7, 17,19,20,24;156:12,

 153:24 beginning (1) 69:19 8,9,12,15,18,24; 16,23;157:20;158:5,

backbone (1) 106:12 bit (32) 51:12,14,20,25;52:3, 13,16,19,20,23,24;

 51:2 begun (1) 6:2;7:4;12:6;19:1, 8,12,15,17,21;53:11, 159:3,5,6,9,11,13,18,

backend (1) 127:14 21;34:3;45:9;48:10; 14,17,20,24;54:4,6,8, 21,22;160:6,12,15,18;

 154:5 behind (5) 58:12;61:24;62:16; 10,12,14,16,18,20,24; 161:4 

background (3) 74:12,17;89:4,5; 72:4;94:2;100:23; 55:1,3,13,19;56:14, boards (3)

 9:19;103:13;132:19 117:16 104:19;106:7;107:6; 19,21,23,25;57:2,4,6, 127:16,17;128:13 

backup (2) belief (1) 111:7;119:14;120:5; 8,12,14,16,20;58:14; bolster (1)

 83:4;154:25 97:19 122:22;127:14; 59:7,10,20,21;60:5, 110:15 

backwards (1) below (2) 128:17;137:7;138:17; 13,18,20,22,24;61:1, bonus (1)

 17:19 12:24;121:1 141:21;145:1;147:5; 3,5,9,11,13,15,19,22; 150:14 

bacteria (1) bench (2) 148:11;150:25; 62:18,21,24,25;63:2, boring (1)

 72:22 0:19;128:5 158:17,21 7,9,11,13,15,17,21,23, 100:9 

bad (1) benefit (1) black (1) 25;64:2,4,8,13;68:1,3, borne (1)

 157:23 118:13 115:10 6,12,23;69:2,5,13,18, 140:1 

baked (3) benefits (2) blank (1) 25;70:5,12,17,19,21, botanicals (1)

 13:4;76:11;149:1 51:9;137:12 140:6 23,25;71:4,6,8,10,12, 13:19 

bakes (1) benign (1) bleed (1) 14,18,21,25;72:9,10; both (17)

 142:19 59:15 150:17 74:3,14,16,20,25; 6:2,4,16,21;20:11;

bananas (5) benzaldehyde (1) bless (1) 75:2,4,6,10,12,14,16, 69:5,20;86:25;115:4;

 43:14;44:7,24,25; 14:1 17:10 18,20,22;76:3,6; 122:23;126:8;128:23;

 45:3 besides (1) blocked (1) 77:13;79:9;80:3,6,10, 133:10;136:8,8;

banging (1) 52:19 131:7 23,25;81:1,3,8,9,10, 137:18;143:18 

121:21 best (9) blood (1) 12,15,19,24,25;82:7, bow (1)

Bar (1) 59:2;100:8,10; 74:7 8,13,16,18,22,25; 90:20 

110:24 104:2;114:10;127:18; blue (1) 83:4,9,11,18,19,20,21, BPI (1)

barrier (2) 131:11;137:11; 131:24 23;84:1,2,6,10,11; 136:14 

80:20;84:8 139:20 blur (1) 85:8,14,16;86:4,7,8,9, brain (1)

bars (1) better (11) 52:18 13,15,17,18,19,21,23; 17:1 

32:22 6:11;36:25;89:12; board (581) 87:9,13,19,22,23; branch (1)

based (8) 98:14;118:2;119:17; 0:7,9,11;6:5;7:10; 88:2,23;89:1,6,13,16, 111:11 

6:11;8:6;33:14; 122:8;147:6;154:8, 8:16,22;9:7,11;10:9, 19,22;90:19;91:1,5, brand (1)

 67:23;112:10;137:1; 10;155:22 14,17,20,22,24;11:1, 12,14,16,20,22,24; 49:21 

140:23;155:13 beverages (1) 3,5,7,9,11,13,17,19, 92:5,10,13,15,19,21; branded (2)

basically (7) 67:5 23;12:5;15:12,18,21; 93:10;95:19;98:9; 48:4,6 

8:4;17:24;18:7; beyond (1) 16:1,3,5,7,9,11,13,15, 99:14,19,21;100:14; bread (1)

 47:17;59:15;98:10; 108:23 19,21,23;17:1,5,9,21; 101:5,24;102:2,11,20, 118:14 

112:11 big (14) 19:8,13,25;20:6;21:7, 21;103:1;105:5; breadth (1)

basis (2) 59:18;89:25; 10,15;22:8,11,16,19, 106:6,25;107:2; 101:18 

80:19;113:8 101:22;103:19;104:6, 21,23,25;23:2,4,8,10, 108:11;109:2;110:8, break (10)

basket (1) 12;107:5;115:24; 12,14,19,23,25;24:2, 22;111:1,5,10,16; 18:15;74:12,13,19;

 151:22 130:24;132:15; 4,6,8,12,14,16,18,20, 113:12,22,23;114:6; 78:24;93:1;105:17;

bean (8) 144:22;156:9;160:20, 24;25:4,6,8,10,12,16, 115:7;116:2;117:3, 121:18;124:24;135:7 

17:16,16;18:14; 22 18,20,22,24;26:1,5,9, 14;120:6,8;122:15; breaking (3)

 24:25;25:1;79:23; biggest (2) 11,13,15,19,21,23,25; 123:7,16,19,25;124:4, 79:12;117:15,16 

82:2;89:2 62:14;130:1 27:2,4,6,10,15,17,19, 6,8,10,12,14,16,18,20, Breaks (1)

beans (3) Bill (3) 23,25;28:2,4,6,8,10, 22;128:9;129:5,6; 107:10 

79:22;88:21,21 103:15,15,17 12,17,20;29:6,10,12, 130:10,16;131:5; breathe (1)

bear (1) billion (2) 16,18,20,22,24;30:1, 132:6,10,13,15,17; 99:8 

126:19 90:13;116:5 3,5,7,11,14;31:1,5,10, 133:2,18,23,25;134:3, breeding (8)

bearing (1) bin (1) 14,16,18,20,22,24; 20,23;135:8;136:3,6, 120:13;121:7,10,

 74:19 77:24 32:1,3,5,7,11,14;34:6, 12;138:4,25;139:2, 14,25;122:1,6,11 

beautiful (1) binding (1) 19,22;35:3,9,13,15; 13;140:4,5,18;141:2, Brian (37) 

Min-U-Script® Burke Court Reporting & Transcription (3) backbone - Brian 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 5 

October 26, 2023 

11:4;16:6;22:20;

 23:24;25:3;27:5;28:9;

 30:2;31:25;40:3;

 42:16;46:19;50:17;

 52:7,15,17;53:10,21;

 54:11;55:8;56:24;

 60:21;63:8;70:16;

 75:19;92:14;98:4;

 99:14;100:11;102:25;

 103:11;104:9;105:25;

 124:15;140:8,25;

 146:1 

Brian's (1)

 146:22 

brief (2)

 113:13;116:16 

briefly (1)

 136:17 

bring (4)

 69:22;80:5;132:18,

 19 

bringing (3)

 55:9;117:23;158:25 

brings (2)

 48:9;62:15 

bro (1)

 127:9 

broad (2)

 138:13,24 

broader (2)

 98:1;99:4 

broadly (4)

 12:6;58:12;59:1,4 

brought (6)

 38:14;93:18;

 127:11,13;144:25;

 161:8 

brown (2)

 32:22;33:4 

BRUCH (71)

 11:15,21;16:17;

 40:19 

build (5)

 79:16;90:12;

 122:14;152:16;158:6 

building (4)

 90:5,12;102:6;

 146:19 

built (2)

 107:8;131:2 

bummed (2)

 129:18,18 

bunch (2)

 66:19;156:1 

bundle (1)

 15:17 

burden (1)

 139:23 

burger (1)

 35:16 

Buried (1)

 68:11 

burn (1)

 64:20 

bushels (5)

 121:20,22;122:7,

 24;123:2 

business (9)

 18:19;90:13;93:7;

 110:4;126:6,7;141:8;

 160:9,9 

button (1)

 11:23 

buyer (1)

 79:5 

buyers (2)

 78:18;121:24 

buying (2)

 88:4,20 

0:6;53:3,5;55:6;

 58:14;68:21;107:24;

 126:12,25;128:24,25 

called (3)

 13:13;66:2;127:7 

calling (2)

 127:6;128:16 

callout (1)

 107:24 

calories (1)

 74:6 

came (10)

 49:20;56:9;65:24;

 77:4;94:14;96:4;97:9;

 113:2;120:5;130:11 

cams (1)

 119:8 

can (114)

 0:19;10:2,3;13:2,

 15,16,22;20:1;21:13;

 22:5;34:3,6;35:21;

 36:20;37:6;38:19,20;

 41:14;45:3;48:6,23;

 52:9;53:17;60:8;

 62:18;66:7;68:23;

 72:18,18;77:14,22;

 78:6;83:9;85:12;87:2;

 88:23;90:20;95:8;

 97:10;98:20,21,21;

 99:8,10,10;100:22;

 101:7,23;102:15,18,

 22;107:19,20,21;

 109:9;110:12;111:2,

 5,11;112:1,24;113:5,

 6,8;114:18;115:3,20;

 117:8,24,25;118:15;

 119:13,14;120:22,23;

 121:13;122:18,24;

 123:4;127:18;129:1,

 2,5,8;131:8,11,12;

 135:19;137:5;138:25;

 79:13;85:10;86:5 

capture (1)

 122:23 

carbohydrate (1)

 72:21 

carbon (3)

 84:14;136:25;137:5 

carbonate (27)

 6:1,1,15,15;7:4,10,

 13,16,18;9:8,9,16,20,

 21,23;10:4,10;61:19,

 20,23,23,25;62:3,7,8,

 13;63:3 

card (10)

 131:22,23,23,24;

 132:1,2,2,3;133:5;

 134:4 

career (2)

 109:12;116:16 

careful (3)

 116:8;153:6;157:3 

carob (3)

 17:16;18:14;24:25 

Carolyn (48)

 10:25;16:2;17:10,

 12,19;18:22;22:13,

 15;23:21;24:19;25:1,

 23;26:6;27:1,11;28:5;

 29:23;31:21;37:24;

 39:24;42:12;46:15;

 54:7;56:20;60:17;

 64:3;71:11;75:15;

 92:9,11;99:17;

 100:21;105:4;106:7;

 108:5;110:9;111:15,

 17;113:10;115:5;

 117:3;121:9;124:11;

 126:19;133:22;135:7;

 146:20;148:2 

Carolyn's (3)

 118:20;148:16;

 153:7;156:14 

cautious (3)

 142:24;148:21;

 151:16 

ceiling (1)

 121:22 

celebrate (1)

 118:23 

celebrated (1)

 156:3 

center (5)

 112:21,22;113:3;

 115:9;116:10 

centered (2)

 33:21;76:17 

central (1)

 48:4 

centrally (1)

 80:22 

cents (1)

 106:3 

certain (4)

 127:11;152:3;

 158:11,11 

certainly (6)

 60:8;88:18;95:8;

 96:2,4;147:16 

certification (3)

 45:9;60:10;65:19 

certified (9)

 14:5,10,20;34:24;

 48:12;52:5;88:14;

 89:14;136:8 

certifier (5)

 9:22;21:21;89:25;

 153:8,10 

certifiers (8)

 22:5;41:10;45:12;

 58:23;59:1;65:6;

 85:23;142:25 

chain (7)

C 

17:7;18:22;19:17; cake (1) 140:23;142:13;143:8; 150:10 44:10;51:8;65:13;

 20:21;23:6,16;24:10, 72:24 144:8,10,12,15,19,19; carrageenan (9) 117:17;118:6;121:3;

 22;25:14;26:3,17; Calcium (24) 146:19;147:9;148:12; 18:11,25;19:1,3,4,6, 143:2 

27:8,21;28:14;29:14; 9:8,8,16,20,21,23; 149:17,17;150:17; 10,14;20:14 CHAIR (475)

 30:9;31:12;32:9;34:1, 10:4,9;40:16,18,21, 151:12,16;154:12,14; carrier (2) 0:3,10;8:14;9:5;

 12;35:4,11,18;39:15; 21,25;41:5,7,10,12, 155:20;157:15;158:6; 12:3;88:15 10:7,12,15,18,21,23,

 40:14;43:2,4;47:5,9; 13,14,16,18,23,25; 159:2;161:11 carrots (1) 25;11:2,4,6,8,10,12,

 49:13;50:1;54:22; 61:22 Canada (2) 86:6 14,16,18,20,20;15:11,

 55:11;57:10,18;60:1; CALDWELL (32) 51:17;69:19 carve (1) 19,24;16:2,4,6,8,10,

 61:7,17;63:19;64:6; 11:5;16:7;22:21; Canadian (2) 115:20 12,14,16,18,20,22,24,

 71:2,16;73:23;75:8, 23:25;25:4;27:6; 44:16;51:17 case (5) 25;17:3;18:21;20:5,

 24;77:21;78:21,24; 28:10;30:3;32:1;40:4; candidate (2) 77:8;97:21;150:15; 20;21:6;22:9,14,18,

 90:8,24;91:2,18;92:3, 42:17;46:20;50:18; 133:6;134:5 153:2;155:3 20,22,24;23:1,3,5,7,9,

 8,24;103:11;105:3; 51:12;52:8,12;53:11, candy (1) cases (3) 11,13,15,15,22,24;

 108:4,22;124:2; 14;54:12;56:25; 21:23 50:9;96:17;98:16 24:1,3,5,7,9,11,13,15,

 125:2,5;133:18,21; 60:22;63:9;70:17; canola (1) catch (2) 17,19,21,21;25:3,5,7,

 134:9,13;135:3;157:6 75:20;92:15;98:9; 80:16 38:2,13 9,11,13,15,17,19,21,

bucket (1) 103:1;124:16;141:2; capability (1) category (2) 23,25;26:2,2,8,10,12,

 126:7 146:3,11,14 80:7 89:14;138:12 14,16,18,20,22,24;

buddy (1) California (1) capacity (1) cause (1) 27:1,3,5,7,7,13,16,18,

 103:14 66:6 115:12 74:7 20,22,24;28:1,3,5,7,9,

buffer (1) call (11) capital (3) cautionary (2) 11,13,13;29:4,8,11, 

Min-U-Script® Burke Court Reporting & Transcription (4) Brian's - CHAIR 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 5 

October 26, 2023 

13,15,17,19,21,23,25; 19;158:4,7,7,12; 44:24 close (6) 8:2;9:19;13:7;

 30:2,4,6,8,8;31:3,8, 160:7,14,19,21,21,24, chloride (5) 77:5;123:6;150:24; 21:11;29:2;30:17,18;

 11,13,15,17,19,21,23, 24;161:1,2,12,14; 30:12,12,13,15; 158:14;161:15;162:1 41:15,20;48:22;

 25;32:2,4,6,8,8;33:24; 162:3 31:6 closer (1) 62:11;64:22,25;65:2 

35:14;36:1,7;37:4,9, chairs (2) chocolates (1) 62:15 commenters' (1)

 21;38:2;39:8,13,16, 160:2,3 76:10 closing (1) 118:20 

18,20,22,24;40:1,3,5, chalky (1) choice (1) 162:2 comments (77)

 7,9,11,13,13;41:22; 20:9 117:10 CO2 (2) 7:15,24,25;8:1,2;

 42:3,6,8,10,12,14,16, challenge (1) choose (1) 84:16;89:20 9:5,16,17,18;12:13;

 18,20,22,24;43:1,3,3; 94:19 20:10 Coast (1) 13:20;15:3,3,6;18:7,9,

 44:18;45:5,24;46:4,8, challenged (2) chronically (1) 66:5 21;19:22;22:9;33:7,

 11,13,15,17,19,21,23, 73:11,15 118:21 cold (1) 18;34:15;35:11,19;

 25;47:2,4,6,8,8;49:6, challenges (5) circumstances (2) 13:17 38:6,7,8,16;39:6;41:8,

 12;50:2,17;51:13; 45:7;79:21;104:23; 114:5;123:2 collaborative (1) 12,17,23;45:21;46:4;

 52:2,7,11,13,16,19; 120:19,21 citrus (2) 21:16 52:13;58:4,5,10,12,

 53:4,13,16,19,22; challenging (6) 43:8,14 colleagues (3) 19;59:3,24;62:4,5;

 54:2,5,7,9,11,13,15, 15:2;19:21;66:17; claim (6) 72:3;114:3;117:14 65:6,12,15,16,18,23;

 17,19,21,23,25;55:2, 78:7;106:10,10 68:15;88:6,7,9,16; collect (3) 66:23;67:23;70:10;

 2,6;56:12,17,20,22, chance (6) 89:15 80:21;107:9;110:22 73:9,10,14;76:17;

 24;57:1,3,5,7,9,11,13, 126:15;128:1,1; claims (2) collected (1) 77:2,6,23;94:24;

 15,17,17;59:5,24; 130:17;131:6,13 9:1;73:25 105:8 95:21,22;96:1,8;

 60:11,16,19,21,23,25; change (12) clap (1) collection (1) 97:15,19;98:7,11,12;

 61:2,4,6,8,10,12,14, 20:2;52:23;53:2; 160:16 140:22 141:21;147:11;

 16,16;62:14,20,23,25; 85:22;90:23;142:7; clarification (1) collectively (1) 152:10,11;157:15;

 63:5,8,10,12,14,16,18, 145:19;151:18;152:7, 37:23 6:18 159:8 

20,22,24;64:1,3,5,5; 9;154:23;155:14 clarify (3) colleges (1) commercial (7)

 67:25;68:5,11;69:1, changed (4) 41:13;97:10;143:8 115:10 20:22;32:22;37:11;

 12,24;70:10,15,18,20, 84:24;143:16; clarifying (1) collegiality (2) 49:1;85:18,23;136:10 

22,24;71:1,3,5,7,9,11, 147:22;155:16 88:23 127:20;128:20 commercially (2)

 13,15,15,20;73:21; changes (8) clarity (2) color (1) 12:1;41:21 

74:10,15,18,24;75:1, 66:24;141:15; 64:22;143:4 43:24 committee (8)

 3,5,7,9,11,13,15,17, 142:12,21;143:3,16; class (1) colors (2) 59:7;101:2;112:9,

 19,21,23,23;76:1; 146:18;161:22 123:13 15:13;80:12 16;123:8;127:3;

 77:12;78:13;79:8; chats (1) classic (1) column (1) 141:17;146:8 

81:2,14;84:5;85:7,15; 99:16 100:5 37:15 committees (1)

 86:3,22;87:8,11;88:1, cheap (1) classification (2) comfortable (2) 158:8 

25;89:11,21;90:7,18; 117:8 158:18;159:1 104:23;128:16 common (4)

 91:3,10,13,15,17,19, cheaper (1) clean (6) coming (12) 109:7;140:16,23,24 

21,23,25;92:6,9,11, 68:18 77:4;86:19;143:9, 19:15;34:18;73:7; commonality (1)

 12,14,18,20,20;93:1, cheaply (1) 19;149:25;150:19 81:5;93:6;105:7; 129:3 

4,9;95:16;99:16; 117:2 cleaned (2) 116:10,15;126:11,21; commoners (1)

 100:13;101:3;102:10; check (2) 148:24;149:3 130:21;133:11 12:8 

103:10;105:2,4; 58:18;118:4 cleaner (4) commend (1) commonly (3)

 106:4;107:1;108:3; checked (1) 58:11,22;145:16,21 156:12 18:10;55:20;78:5 

110:6,21;111:15; 68:22 cleaning (4) comment (36) communicate (1)

 113:10;115:4;116:1, checking (1) 7:3;57:22,25;86:10 6:14;8:16,24;9:25; 102:14 

13;121:17;122:17; 126:23 clean-up (1) 12:12;14:2,16;18:24; communicating (1)

 123:8,11,18,21;124:1, chemical (6) 148:22 20:21,25;33:9,10; 119:20 

3,5,7,9,11,13,15,17, 6:21;55:23;66:2; clear (11) 34:2,3;36:2;37:17; communication (2)

 19,21,23,23;125:3,8; 79:24;81:22;87:24 15:5;36:3;45:17; 38:15,18;56:9;67:16; 118:21;119:1 

126:3;128:22;130:18, chemicals (2) 67:10,12;68:13; 73:24;79:20;83:2,3; communications (2)

 19,19;131:2,4,4,16; 81:6;87:7 97:24;144:13;147:25; 95:12;102:12;103:20; 131:7,7 

132:2,3,8,12,23; chicken (1) 149:17;153:23 104:3;110:8,23; communities (1)

 133:3,9,13,16,17,19, 117:18 clearly (2) 114:1;116:3;155:2, 104:11 

22;134:1,4,6,8,9,11, chickens (1) 65:24;97:22 15;157:1,7 community (31)

 12,17,18,19,25;135:2, 126:25 click (1) commented (2) 6:11;21:21;31:2;

 2,13,22;136:1;141:8, chicory (4) 95:16 58:21;67:8 33:14;65:7;69:15;

 9;143:6;144:3,6; 6:23,24;7:1;8:5 clicker (2) commenter (16) 79:11;94:11;95:22,

 145:7;146:1,8,20; child (1) 0:9,10 8:5;13:20,25;41:13; 23;96:4;98:18;99:4,

 147:7;148:2,14; 44:7 Clif (1) 43:23;48:3,12;56:2,5; 12;102:8;103:20;

 149:5,15;150:4,8,21; chips (3) 110:24 62:6;66:2,4,11;69:8; 106:9,17,25;119:16;

 151:14;152:12; 53:6,11,15 climate (1) 77:22;96:11 122:12;128:15;

 155:23;156:11;157:5, Chiquita (1) 109:18 commenters (14) 134:15;136:13; 

Min-U-Script® Burke Court Reporting & Transcription (5) chairs - community 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 5 

October 26, 2023 

145:16,22;150:2,6; 64:11 0:23 116:25;117:8;122:18 90:11 

156:17;157:9,14 concept (2) consistency (1) conventionally (1) credibility (1)

companies (1) 111:4;154:1 67:3 121:20 114:18 

107:3 concern (5) consistent (5) conversation (4) credit (1)

company (1) 21:11;59:17;97:14; 14:9;51:21;62:5; 62:19;79:10;96:2; 128:5 

44:2 154:21;156:10 80:18;116:20 127:11 crew (2)

comparable (1) concerned (1) consistently (1) conversations (6) 0:17;160:22 

80:5 12:8 14:15 68:9;79:2;123:22; cribbage (1)

compared (1) concerning (3) constraint (1) 128:11;129:9;156:2 132:16 

18:24 7:15;50:25;51:10 14:25 converting (2) criteria (1)

compassionate (1) concerns (5) consumed (1) 14:21,24 115:21 

128:8 29:3;37:18;43:16; 46:2 convince (1) critical (5)

compatible (1) 84:23;104:19 consumer (5) 106:2 84:14,15;85:5;

 35:1 concluded (1) 15:5;20:7;65:14; cookies (1) 89:20;139:16 

competence (1) 162:5 67:8,17 72:25 crop (5)

 45:12 conclusions (1) consumers (3) cool (1) 109:18;118:1;

compiled (1) 67:18 20:10;67:14;139:21 53:5 121:19;122:2;137:15 

146:12 conditions (1) consuming (1) co-op (1) crop/livestock (1)

complete (2) 121:19 14:22 20:12 158:7 

8:1;148:5 conduct (1) contact (2) copper (6) crops (9)

completely (3) 114:20 57:22,25 97:18,20,22,22; 30:16;43:9;120:15,

 51:8;66:9;108:5 conducting (1) contagious (1) 98:2,2 15,17,17,25;121:3;

complex (1) 102:15 17:5 corn (3) 141:14 

13:15 conduits (1) contains (1) 77:16;80:14;117:24 crossing (1)

complexity (1) 99:11 64:19 correctly (3) 104:25 

156:22 conference (1) contaminants (1) 83:3;89:1;157:12 crossover (1)

compliance (1) 100:9 37:16 Council (1) 119:14 

21:22 conferences (1) contamination (4) 33:13 crowd (3)

compliant (2) 105:12 38:23;73:2;138:22, count (1) 0:5,12;126:16 

73:18;77:10 confidence (3) 22 132:10 crucial (2)

complicated (2) 127:11,24;131:13 contemplation (1) counter (1) 101:21;115:15 

79:24;152:14 confidential (2) 55:9 131:19 crunchy (1)

complimentary (1) 18:18;113:17 content (1) counterparts (1) 20:12 

19:3 confidentiality (1) 62:9 79:21 cry (4)

component (1) 111:20 context (2) couple (12) 126:19,20;161:9,10 

79:15 confidentially (1) 48:10;77:14 41:20;48:22;56:4,5; cultivation (1)

components (3) 121:9 contextualize (1) 74:12;93:11;94:10; 33:2 

47:15;51:1;79:24 confirmed (1) 117:11 98:5,15;116:3;123:8; cumbersome (1)

comportation (1) 131:21 continue (5) 153:25 139:8 

35:16 confused (1) 14:9;15:8;39:7; course (1) curiosity (1)

composition (1) 68:9 93:17;97:3 156:2 117:21 

22:6 confusing (1) continued (7) courses (1) curious (2)

compost (22) 83:19 30:18;33:6;39:2; 68:12 34:14;110:25 

136:2,4,7,9,10,18, Congratulations (3) 56:11;95:21;96:21; cover (2) current (3)

 19,20,20,21,23;137:5, 134:9,21;135:1 97:14 113:8;135:24 33:21;76:14;154:17 

22,22,25;138:7,8,12, connecting (1) continuing (4) covered (1) currently (12)

 14,19,23;139:9 78:18 35:22;51:10;58:5; 58:19 8:18;33:17;34:24;

composted (1) consensus (2) 101:8 covers (2) 65:1;68:14;70:8;86:5;

 139:18 58:23;142:2 continuous (2) 62:13;154:8 105:5;108:7;136:18;

composting (2) consent (1) 104:18;161:21 cow (1) 137:23;140:19 

136:10;137:2 134:19 continuously (1) 118:13 custom (1)

compound (1) consider (8) 14:19 crackers (1) 13:13 

13:13 35:25;56:10;67:4; contribute (1) 72:25 customers (1)

compounds (2) 68:24;148:1;151:11; 107:5 crashed (1) 18:25 

6:21;12:15 154:24,25 control (1) 14:14 cut (1)

comprehensive (4) consideration (1) 110:1 cream (2) 51:3 

58:15;97:22; 96:5 convention (1) 18:5;72:25 cycle (4)

 140:19;141:22 considered (5) 86:25 create (4) 19:14;106:15,16;

computer (1) 12:20;33:2;41:4; conventional (19) 44:10;109:4;115:9, 115:16 

64:17 128:5;155:10 51:5;79:21;81:16, 21 cycles (1)

comrade (1) considering (1) 21;82:10,14;83:1; creating (3) 148:5 

136:4 39:2 86:6,12;87:6;88:4,5; 47:16;120:1,2 

concentration (1) consisted (1) 89:3;100:25;107:3,4; creativity (1)

Min-U-Script® Burke Court Reporting & Transcription (6) companies - cycles 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 5 

October 26, 2023 

decides (1)

 153:8 

decision (1)

 126:17;130:1,10 

demonstrated (1)

 33:6 

129:11 

di (3)

 47:12,12;53:25 

39:25;42:13;46:16;

 54:8;55:3;56:21;

 60:18;64:4;71:12;

D 

dairies (1) 147:23 demonstrates (1) diagram (1) 75:16;92:5,10;99:19;

 58:2 decisive (1) 161:24 119:8 105:5;108:11;109:2;

dairy (8) 41:4 demonstrating (1) died (1) 113:12;124:12;132:6;

 13:5;14:16;18:6,12, declined (1) 161:7 64:17 133:23;135:8;146:21;

 13;58:9;117:18; 12:17 de-oiled (3) diet (1) 148:3 

118:14 decree (1) 76:4,7;77:9 44:6 dioxide (14)

Dakota (2) 134:19 department (1) dietary (1) 8:17,21;64:8,9,15;

 78:5,5 dedication (1) 114:4 56:4 65:10,19,21,22,24;

damaging (1) 134:15 dependent (1) difference (2) 68:14;69:6;70:13;

 33:5 deemed (1) 70:1 58:6;70:7 84:14 

D'AMORE (59) 8:11 depends (1) differences (2) direction (5)

 11:11;15:12;16:13; deep (5) 109:2 81:17;129:3 85:22,25;95:5,18;

 23:2;24:6;25:10; 0:19;8:12;51:20; derail (1) different (38) 107:3 

26:13;27:17;29:10; 128:5;129:11 94:18 13:17;17:24;36:14, directions (2)

 32:7;36:2;37:5;40:10; defer (1) derive (1) 23;38:24;53:12,18; 95:1,3 

42:23;44:20;45:25; 102:20 117:9 58:1;61:24;66:13,14; directly (2)

 47:1;54:18;57:6;61:3; deferred (1) derived (4) 80:13;81:18,21; 48:19;102:13 

63:15;70:23;71:25; 21:16 12:1,15,23;13:16 82:11;85:19;86:20; disagreement (1)

 72:10;74:3,14,16; defined (1) described (2) 87:2,6,14,19,25; 100:19 

75:4;76:6;80:3,10,25; 12:7 59:2;130:10 92:16;95:1;96:8,24; disasters (1)

 81:8,10;82:22;83:4, definitely (5) describing (1) 107:3;109:19;113:19; 14:13 

11,19,21;84:1,10; 60:5;86:9;103:6,8; 14:3 118:3,20;119:8; discipline (1)

 85:14;86:7,9,15,18; 148:22 descriptor (1) 138:1;149:25;151:20; 105:17 

87:9,13,22;89:13,19; definition (6) 136:15 154:5,9;158:17 disclose (1)

 90:19;91:1,14;92:21; 12:9;45:23;136:19, design (1) differently (1) 18:18 

124:22;150:22;151:5; 24;137:23;138:7 109:20 58:8 discourse (1)

 157:20 definitions (4) designated (1) difficult (4) 161:24 

dang (1) 83:22;137:17,19; 86:17 14:24;20:25;64:20; discretion (1)

 128:3 138:20 desired (1) 139:8 158:10 

dangerous (2) degrading (1) 14:25 dig (2) discuss (3)

 65:25;66:2 43:8 destination (1) 51:20;67:23 59:7;136:12;141:8 

data (9) degree (1) 45:2 digitata (1) discussed (4)

 48:4,4;68:8,8; 139:7 detail (2) 32:24 12:24;36:4;38:21;

 105:8;107:9,21; dehydrated (1) 41:10;67:23 diglycerides (1) 73:7 

140:22,24 50:10 detailed (2) 49:10 discussing (3)

date (1) delay (1) 65:12;67:2 diligent (1) 113:2,7;156:15 

103:3 158:11 details (1) 50:19 discussion (33)

day (7) delays (1) 40:23 diligently (1) 0:24;6:4,7;8:14;

 0:4;94:2;120:13; 156:3 determinations (1) 14:17 9:12;19:2;29:1;30:19;

 126:4,24;135:1; delightful (1) 45:13 Dilip (40) 31:1;33:21;39:7,8;

 139:19 161:18 determine (1) 11:8;16:10;22:24; 55:9;58:20;59:18,22;

days (7) delist (8) 69:2 24:3;25:7;26:10; 60:12;84:3;90:9;91:5;

 35:17;43:25;96:23; 66:8;77:8;152:8; determined (2) 27:14;30:6;32:4; 93:11;94:5;99:14;

 128:12;137:7,8;139:7 154:14,16,18,22; 36:12;38:24 33:24;34:1;37:21; 111:17;138:19;

deal (4) 155:4 determining (1) 38:5;39:9,11;40:7; 141:11;144:9,21;

 66:24;117:16; delisted (2) 21:25 41:23;42:1,20;46:23; 147:2;150:17;159:9,

 150:16,19 52:9;65:20 devastate (1) 54:15;57:3;60:25; 11,19 

dealing (1) delisting (1) 44:2 63:12;70:20;74:23; discussions (3)

 136:11 154:24 develop (4) 75:1;91:11;100:13; 55:7;96:3,10 

dealt (1) deliver (2) 105:6;109:16; 110:7;111:15;113:13; disease (3)

 46:1 69:5;112:14 140:18,23 115:5;116:1;120:6; 120:21;121:6,15 

dear (1) deliverable (1) developed (2) 123:20;124:19;144:3, disease-resistant (1)

 136:8 118:5 13:14;14:8 7;145:7 120:24 

debate (1) deliverables (1) developing (1) Dilip's (3) disposal (1)

 100:18 108:9 118:13 32:13;40:17;115:8 73:3 

decide (4) delivery (2) development (2) DIMITRI (35) disruption (1)

 149:9;151:3,3; 69:21;87:17 14:23;35:2 11:1;16:3;17:21; 44:10 

152:11 democracy (3) deviated (1) 19:8;21:10;22:16; dissent (1)

decided (1) 129:20,23,24 139:14 24:20;25:24;27:2; 134:19 

6:9 democratic (3) devolve (1) 28:6;29:24;31:22; distillation (2) 

Min-U-Script® Burke Court Reporting & Transcription (7) dairies - distillation 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 5 

October 26, 2023 

13:18;101:23 

distinct (2)

 6:20;87:2 

distinction (4)

 53:19;72:14;87:16,

 17 

distinguished (1)

 12:7 

dive (1)

 8:12 

diverse (1)

 9:18 

diversity (1)

 129:4 

divide (1)

 79:23 

doable (1)

 82:9 

docket (3)

 33:9;146:17;150:6 

docs (1)

 107:9 

doctor (1)

 155:21 

document (8)

 13:21;21:12;33:1;

 59:2;94:18,19;142:6;

 145:18 

documents (4)

 0:24;6:4,7;144:10 

doesn’t (2)

 105:24;130:6 

dollars (2)

 108:10;120:2 

domestically (2)

 44:4,8 

don’t (4)

 18,21;156:10;157:1;

 161:16 

draw (2)

 35:18;101:1 

dream (1)

 35:16 

dressings (1)

 9:21 

dried (1)

 53:18 

drive (2)

 97:1;117:9 

driven (1)

 74:1 

driving (2)

 87:16,17 

drop (3)

 65:19;66:15,16 

Drug (1)

 38:25 

drum (3)

 47:13,16;49:24 

dry (1)

 121:20 

drying (4)

 6:22;47:13,16;

 49:24 

during (13)

 6:25;7:9;41:8;

 58:17,20;59:13;73:5;

 76:16;137:20;141:18;

 142:2;155:10;156:18 

dwindling (1)

 0:13 

44:1;89:7;105:7;

 109:24 

economics (3)

 89:4;90:2;109:22 

economists (2)

 105:12;109:8 

ecosystems (1)

 33:5 

edible (1)

 55:23 

educated (1)

 103:25 

education (1)

 79:5 

effect (1)

 36:12 

effective (4)

 6:13;7:14;128:8;

 142:21 

effects (2)

 13:10;73:3 

effort (2)

 21:16;141:6 

egg (2)

 80:15;83:14 

eggs (1)

 151:22 

either (6)

 8:18;29:2;85:21;

 103:25;143:23;

 147:14 

Ela (2)

 126:12;128:20 

election (2)

 125:1;128:6 

elections (4)

 93:7;126:5;130:5,

 32:16,17;36:5;

 47:15;76:9 

emulsifiers (1)

 49:22 

emulsifying (1)

 17:25 

encourage (4)

 111:11;113:21;

 142:9;158:10 

encouraged (1)

 77:5 

end (13)

 7:12,16;8:11;33:15;

 55:17;64:10;87:17;

 107:10,10;126:10;

 139:12;153:1;160:10 

ended (1)

 10:13 

endowment (1)

 110:25 

Endowments (2)

 107:17;110:24 

energy (3)

 0:6;72:22;117:16 

engage (1)

 111:5 

engagement (2)

 64:14;99:18 

engineering (1)

 120:25 

England (1)

 66:5 

enhancer (3)

 30:22;32:17;36:5 

enjoys (2)

 28:21;30:16 

enough (12)

 99:6 

EPA (1)

 73:1 

equal (1)

 36:24 

equipment (4)

 57:23,25;85:11;

 87:25 

equity (1)

 96:18 

equivalence (1)

 69:10 

equivalent (2)

 47:23;66:10 

era (1)

 128:10 

especially (3)

 10:2;154:8;158:2 

essential (5)

 7:12;50:20;73:24,

 24;151:7 

essentiality (3)

 18:8;20:16;62:11 

essentially (2)

 66:11;81:22 

Esu (1)

 140:17 

etc (3)

 36:6;138:9,9 

ethos (1)

 120:1 

ethylene (10)

 14:1;43:6,7,9,13,22,

 25;44:9;46:3,6 

EU (1)

 44:16 

Europe (3)

E 

34:15,23;45:23; earlier (6) 16 49:4;53:3;89:17; 67:3;69:18;100:19 

157:1 52:6;93:13,21; elegant (2) 109:5,6;115:13; evaluate (2)

done (17) 141:12;142:23;153:6 85:17;150:18 116:12;117:6;122:6; 8:8;152:10 

74:4,5;95:11;98:8, early (1) element (1) 140:2;146:25;159:15 evaluated (1)

 16,17;101:12;102:19; 76:22 95:2 ensure (2) 62:10 

108:12;114:14;115:3; earn (1) elemental (1) 36:20;95:11 evaluating (3)

 121:8;130:12;142:8; 127:12 64:18 ensuring (1) 21:21;22:6;96:24 

144:12;158:15; easier (7) elements (1) 96:9 even (15)

 160:11 53:9;66:21,22; 137:17 entered (1) 58:22;85:21;89:24,

door (2) 68:18;79:9;119:20,25 elevate (3) 136:4 24;97:23;99:25;

 85:6;126:14 easily (1) 95:21;97:18;119:22 entire (1) 104:1;114:5,16,18;

down (12) 144:17 elevating (1) 65:13 121:22;122:17;

 20:7;78:23;79:12, East (1) 96:9 entirely (1) 144:25;145:4;154:3 

24;91:25;105:17; 66:4 eliminate (1) 152:23 eventuality (1)

 116:14;117:13; easy (4) 51:8 entities (1) 10:1 

122:21;135:15; 43:11;69:11; eloquently (1) 88:14 evergreen (1)

 139:14;150:23 156:21;159:16 103:12 entity (1) 142:16 

downsides (1) eat (1) else (7) 77:4 everybody (14)

 50:22 139:22 52:19;72:10,14; environment (2) 0:3,11;9:13,14;

downstream (1) eating (1) 74:21;109:10;118:6; 50:25;59:16 28:21;93:2;106:17;

 14:6 21:23 129:2 environmental (6) 107:9;126:3,19,22,23;

dozen (1) eats (1) embraced (1) 35:21;43:16;59:8, 131:1;135:5 

58:4 44:7 84:18 12;73:2;138:21 Everyone (11)

DR (11) echo (1) empathy (1) environmentally (1) 29:2;62:15;87:12;

 78:15,22,25; 114:1 127:13 33:3 120:6;130:11;131:4,

 152:14;154:20;155:6, economic (4) emulsifier (5) eOrganic (1) 8,9,19;158:9;161:11 

Min-U-Script® Burke Court Reporting & Transcription (8) distinct - Everyone 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 5 

October 26, 2023 

everything's (1)

 72:11 

evidence (1)

 33:4 

evil (1)

 151:11 

evolved (1)

 120:5 

exact (2)

 102:3,3 

exactly (3)

 65:16;86:18;106:22 

example (8)

 14:11;18:3;89:11;

 96:18;116:10;145:13,

 14;152:2 

examples (2)

 49:20;87:3 

exceed (1)

 64:11 

excellence (5)

 112:21,22;113:3;

 115:9;116:10 

excellent (4)

 120:11,11;132:20;

 141:5 

except (2)

 66:8,18 

exchange (1)

 37:14 

excited (11)

 64:14;97:15;125:4;

 126:24;128:3;131:10;

 135:3;141:3,3;160:8;

 161:2 

exciting (3)

 0:4;92:1;93:22 

excluded (12)

 12:10,11,20,21,25;

 21:8,19;22:1,2;93:13,

 16;97:25 

excuse (4)

 73:12;76:23;80:3;

 86:16 

Executive (1)

 141:17 

exempt (5)

 88:6,7,8,16;89:15 

exhaustive (1)

 94:15 

exist (3)

 45:4;47:18;78:8 

existing (2)

 14:20;43:21 

exists (4)

 48:8,17;99:8;

 136:18 

exit (1)

 41:3 

expand (1)

 66:4 

expanding (1)

 44:14 

expectation (1)

 158:6 

expecting (2)

 65:16;154:17 

expects (1)

 33:13 

expense (1)

 80:20 

expensive (3)

 66:3,6,22 

experience (3)

 67:11;153:3,24 

experienced (1)

 129:9 

experiencing (1)

 127:21 

experts (3)

 112:4,4,19 

explanation (2)

 53:9;80:1 

explicitly (2)

 22:1;53:1 

exponentially (1)

 90:15 

exporting (1)

 67:4 

expressed (1)

 66:20 

extending (1)

 62:21 

extends (1)

 97:6 

extension (1)

 99:5 

extensively (1)

 100:12 

extent (1)

 51:6 

external (1)

 115:1 

extra (1)

 81:6 

Extract (2)

 14:2;49:21 

extracted (4)

 17:15;18:16;24:25;

 32:22 

extracting (1)

 79:12 

extraction (5)

 13:17;36:10,13;

 80:20;84:15 

extracts (1)

 128:21 

extremely (3)

 45:17;79:10;109:22 

eye (4)

 83:13;89:8;142:12;

 155:21 

121:18;147:18 

faces (1)

 152:15 

facilitate (1)

 13:11 

facilities (4)

 85:3,10;86:24,25 

facility (7)

 86:4,6;88:4,8;89:3,

 18;136:9 

factors (1)

 15:16 

Fahrenheit (1)

 139:7 

fail (1)

 154:14 

fails (19)

 11:22;17:8;23:18;

 24:23;26:4;27:9;

 28:15;30:10;32:10;

 40:15;43:5;47:10;

 55:12;57:19;61:18;

 64:7;71:17;75:25;

 92:25 

fair (1)

 55:9 

fairly (2)

 102:23;122:19 

fall (16)

 47:23;55:24;62:4;

 69:8;73:9,10;77:3;

 98:23;101:10,11;

 126:21;142:2;147:10,

 11,12;150:16 

familiar (2)

 34:4,12 

family (1)

 129:5 

fantastic (1)

 68:6 

far (7)

 14:22;48:11;59:23;

 67:23;81:10;129:5;

 141:5 

Farm (10)

 103:15,15,17;

 104:10;109:18;110:3;

 112:8;120:16;123:1;

 136:10 

farmer (5)

 104:9;113:18;

 116:17;117:4;153:18 

farmers (8)

 100:6;112:11;

 118:6,16;139:5,7;

 143:1;153:21 

farmer's (1)

 154:3 

Farming (2)

 120:18,20 

Farms (5)

 52:4;109:22;

 116:18,19;117:9 

fats (1)

 47:15 

fatty (2)

 51:1;55:22 

favor (3)

 38:17;41:17;58:5 

FDA (5)

 12:8,8,17;38:25;

 73:1 

feasible (1)

 89:7 

features (1)

 20:16 

February (1)

 76:22 

Federal (9)

 107:6,22;110:20;

 114:23;119:21,24,25;

 155:7,9 

feed (7)

 117:18,18;136:20;

 137:22,22;138:7,12 

feedback (14)

 96:13,16,19;101:8,

 10;102:3;103:20,21,

 22;104:21;108:9;

 112:15;142:1,13 

feel (17)

 17:21;20:9,15;60:7;

 62:12;104:20,22;

 110:18;117:21;122:5;

 132:19;134:23;147:4;

 148:6;154:7,10;

 155:21 

feeling (1)

 19:8 

feet (1)

 160:22 

fellow (1)

 0:7 

felt (2)

 76:19;116:16 

fenbendazole (4)

 126:24,25;127:2;

 128:16 

fermentation (10)

 12:9,10,16,23,25;

 13:2,18;18:17;21:7,

 20 

fermented (1)

 67:4 

fertility (2)

 122:3;137:15 

few (13)

 0:23;17:25;18:15;

 19:18;32:25;84:24;

 90:16;114:23;117:13;

 118:10;128:11,14;

 153:24 

fewer (1)

 117:2 

field (3)

 32:20;73:22;105:21 

fight (1)

 128:23 

figure (4)

 48:14;117:9;118:1,

 2 

figured (1)

 116:19 

file (1)

 32:25 

fill (2)

 21:13;160:20 

filtering (1)

 7:19 

final (7)

 6:25;7:14;38:4;

 85:19;105:8;108:13;

 162:3 

Finally (1)

 52:19 

find (16)

 18:13;36:15;48:17;

 52:4;53:4;66:3,22;

 78:7;100:12;106:18;

 115:20;143:14;146:4;

 158:3;159:16;160:22 

finding (3)

 77:25;102:4,5 

finds (2)

 73:17;77:9 

fine (4)

 58:9;81:9;95:19;

 130:6 

finer (1)

 22:3 

finish (2)

 126:4,8 

finished (3)

 13:8;76:25;80:5 

firming (4)

 32:17;36:5;40:20;

 41:15 

first (23)

 15:25;37:23;38:12;

 39:14;40:23;65:24;

 111:18;116:13;120:5;

 126:11,11;140:14;

 144:7;146:4,23;

 149:18,22,24;150:13;

 151:18;157:22,24;

 161:16 

fiscal (1)

 104:13 

fish (9)

 147:22;149:8;

 152:1,3,4;154:13,14,

 16,17 

fit (2)

 120:22,22 

five (6)

 17:23;29:2;73:10;

 76:18;107:8;148:9 

fix (2)

 117:4;142:17 

F 

fabulous (2)

Min-U-Script® Burke Court Reporting & Transcription (9) everything's - fix 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 5 

October 26, 2023 

flag (4)

 93:11;97:9;141:19;

 160:3 

flake (1)

 47:20 

flakes (8)

 47:16,18;49:3,8,10;

 50:11;53:12,13 

flashpoint (1)

 15:1 

flat (2)

 44:23;45:3 

flavor (20)

 12:9,25;13:6,9,10,

 12,13;14:2,8,8,19,25;

 15:8,14,15;30:22,23;

 32:17,17;36:5 

flavoring (3)

 12:24;13:11;30:22 

flavors (27)

 11:24,24,25,25;

 12:1,6,6,18;13:3,7,13,

 14,16,22;14:1,4,5,10,

 18,20,22,24;15:1,7,

 21;21:3;80:12 

flexibility (3)

 107:15;108:2;115:2 

flexible (1)

 107:18 

floor (2)

 117:23;132:4 

Florida (1)

 36:8;87:10;102:18;

 108:22;146:21;148:3 

food (24)

 7:8;13:11;20:12;

 30:24;32:16;33:12;

 38:25;40:19;47:13,

 19;48:4;55:17;57:22,

 25;73:18;77:10;

 84:22;85:1;100:17,

 20,21;123:4;139:21;

 140:1 

foods (2)

 48:4;73:1 

forage (1)

 122:4 

forgot (1)

 44:21 

forgotten (1)

 156:20 

form (12)

 17:13;33:3;38:8,10;

 64:24;65:1,10;66:20;

 74:22;80:2;83:2;

 105:16 

formally (1)

 133:1 

forms (5)

 33:17,21;38:8;

 64:21;65:11 

formula (1)

 41:16 

formulation (2)

 41:2 

fractionation (2)

 84:11;85:4 

framing (1)

 141:25 

Franklin (41)

 8:15;10:18;11:18;

 16:20;21:6;23:9;

 24:13;25:17;26:20;

 27:24;29:17;31:15;

 36:7;37:10;38:22;

 39:18;42:6;46:9;

 54:25;57:13;59:6,10;

 61:10;63:22;71:5;

 75:9;91:21;94:7;

 95:12;105:18,19;

 106:4;107:1;108:4;

 110:9;113:11;115:5;

 120:23;124:5;140:9,

 25 

Franklin's (2)

 110:23;115:7 

Fredrick (1)

 116:3 

free (1)

 37:2 

fresh (2)

 43:24,25 

friendly (1)

 33:3 

front-end (1)

 145:1 

fundamental (1)

 94:22 

funded (4)

 110:14;112:2;

 114:8;119:9 

funding (23)

 103:17,18;107:4,6;

 111:19;112:21;113:4;

 114:24;115:1,1,2,15,

 19,21;116:5,7,11,12;

 119:21,21,25,25;

 122:13 

funds (2)

 110:20;115:3 

fungi (1)

 13:19 

funnel (1)

 115:22 

furiously (1)

 101:6 

furnaces (1)

 40:24 

further (4)

 60:11;73:3;79:25;

 84:3 

future (8)

 34:16;48:9;67:7;

 80:24;106:21;121:15;

 126:5;127:19 

generated (1)

 103:21 

genetic (1)

 120:25 

genetically (2)

 12:17,19 

Gerry (46)

 11:10;15:11;16:12;

 23:1;24:5;25:2,9;

 26:12;27:16;29:9;

 32:6;36:1;37:4;40:9;

 42:2,22;44:18;45:24;

 46:7,25;54:1,17;57:5;

 61:2;63:14;70:22;

 71:24;73:21,23;

 74:23;75:3;76:5;

 77:13;78:10;79:19;

 87:8;90:18;91:2,8,13;

 124:21;132:5;150:21;

 157:5,19;158:5 

gets (7)

 28:21;94:17;95:11;

 99:4;152:14;156:19,

 19 

given (5)

 14:11;33:18;119:6;

 120:4;126:15 

giving (1)

 149:11 

glad (2)

 0:5;45:20 

gluten-free (1)

G 

14:14 32:18;74:1 Fructooligosaccharides (4) gap (1) 18:4 

flush (1) forth (2) 71:22;72:8;73:18; 117:22 glycerides (10)

 87:23 101:12;145:17 74:21 gaps (1) 47:11,12,14,24;

focus (5) fortunate (1) fructoolingo (1) 78:19 48:14,18;49:2,19;

 58:20;59:18; 0:16 71:19 gas (3) 53:24;72:4 

101:21;119:13; forward (20) fruit (5) 41:2;64:20,23 gnarly (1)

 121:13 48:9;80:5;93:25; 15:2;43:8,23;45:11; gate (2) 55:8 

focused (7) 94:19;96:4,7;97:4; 67:5 157:23;158:2 GNPs (1)

 6:23;58:5,10,13; 98:3;100:10;104:15; fruits (7) gatekeeper (1) 85:1 

115:24;136:24;137:9 122:10;123:8,9; 43:15;44:3,4,5,6,8; 157:23 goal (3)

focusing (2) 129:17;130:14; 45:22 gatekeeping (1) 90:3;105:6;109:4 

59:12;82:19 134:24;140:15;141:4; frustrating (1) 130:25 goalpost (1)

fold (1) 158:25;160:25 114:10 gather (1) 123:1 

133:6 FOS (8) frustration (1) 6:10 goes (9)

folks (20) 71:21,23;72:18,20, 116:21 gave (2) 36:16,21;101:24;

 20:17,23;62:17; 24;73:3,6,6 full (4) 127:5;128:22 103:17,18;105:18,19;

 74:19;90:21;91:25; FOS's (1) 6:6;8:1;39:4;43:24 gears (1) 108:1;130:2 

93:22,24;94:3; 73:11 fully (3) 149:14 Good (43)

 116:14;118:24; found (5) 8:8;14:8;36:16 gellan (6) 0:3;9:13,13;20:3;

 122:22;123:21;127:6; 48:17;49:8;53:1; fun (2) 17:13;18:3,11,23, 32:14;34:20;38:2,13;

 128:7;138:4;139:24; 139:16;159:3 101:9;113:24 25;22:12 49:18;50:12;53:19;

 143:1;146:18;160:4 Foundation (1) function (2) gelling (2) 63:22;70:5;76:15;

follow (5) 120:19 13:6,11 17:25;18:4 85:1;96:19;101:1;

 58:10;62:4;94:1; foundational (3) functionality (1) general (5) 104:16;110:3,13;

 139:17;142:13 138:14,14,15 69:3 34:1;99:3;106:12; 114:8,17,18;116:11;

followed (2) four (5) functionally (1) 111:5;130:5 118:23;119:19;120:1;

 85:2;156:17 40:22;65:23;92:14, 122:23 generally (6) 121:19;122:11,18;

following (5) 24;132:14 fund (1) 13:8;30:16,21;56:4; 123:22;127:4;131:2,

 45:19;87:12;146:3; four-day (1) 105:11 76:13;80:4 25;132:16,17;135:7;

 150:9;154:11 100:9 fundable (1) generate (2) 137:5;141:25;149:2,

follow-up (6) fourth (1) 106:20 104:22;108:1 13;151:16;156:24 

Min-U-Script® Burke Court Reporting & Transcription (10) flag - Good 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 5 

October 26, 2023 

goods (2)

 13:5;76:11 

Google (2)

group (18)

 30:17;44:11;58:19,

 25;67:17;80:13;

 93:8;149:7;150:24 

health (4)

 43:16;50:22;51:1;

Hill (1)

 104:8 

hippie (1)

H 

48:16,17 93:24;97:10;101:2; half (1) 73:4 20:12 

Gorman (1) 127:21;128:2,4; 133:6 hear (13) historically (4)

 116:4 140:7,8;142:9; ham (1) 13:22;17:5;28:24; 30:20;43:19;

gosh (1) 156:24;161:21,24 117:20 62:17;65:5,7;85:11, 115:10;131:2 

85:10 groups (10) hand (4) 13;89:1;93:16; history (1)

government (1) 7:8;55:17;65:15; 0:8;103:7;136:1; 118:16;126:9;129:19 7:4 

107:22 73:11,15,15;96:8,13; 161:15 heard (18) hit (3)

government-funded (1) 103:24;104:7 handbook (1) 13:24;29:2;47:25; 121:22;148:12,24 

110:15 grow (5) 9:3 48:19;65:12,18,20; hitting (1)

gracious (1) 77:22;78:6;90:14; handed (1) 77:22;83:3;96:11,19, 122:20 

128:23 115:24;120:25 127:12 22;111:25;115:11; Hold (4)

grades (1) grower (1) handle (2) 116:5;120:18;149:22; 57:20;105:9;

 28:18 65:13 98:24;153:5 157:1 106:21;129:13 

grant (11) growers (1) handler (2) hearing (2) holistically (2)

 105:24;107:8,9,12, 77:18 58:9;86:22 6:12;29:5 87:1,5 

21;108:7,8;111:18, growing (7) handlers (1) heart (2) Holy (1)

 22;112:7;113:14 12:14,24;33:19; 58:2 37:17;110:17 135:23 

Granted (1) 34:7,13;90:13;121:19 handling (35) heat (1) home (1)

 148:25 grown (6) 0:4,12,15;7:12; 82:2 41:3 

grants (6) 36:19,22;37:1; 8:10;12:20;13:1,21; Heather (1) honed (1)

 113:13,15;116:6,7, 45:10;78:5,6 19:6;30:16;32:16; 140:17 85:9 

8;119:6 grows (2) 33:11;36:5;43:10,13; heavily (1) honest (1)

granular (2) 78:1,2 57:24;58:3,7,21;60:3, 51:10 6:13 

35:20;111:9 growth (3) 3,9;73:17;74:1;76:1; heck (1) honor (3)

grape (2) 64:15;65:21;110:16 77:9;135:23;141:15; 119:20 127:23;161:20,25 

65:8,13 guar (5) 142:11;145:14;146:9; held (1) honored (2)

grapefruit (2) 17:16;18:5,12; 158:7,16,21;159:19 130:11 134:23;160:19 

14:11,13 20:13;24:25 hands (1) help (18) hop (1)

grapes (3) guarantee (1) 118:24 0:17;48:14;99:23; 129:12 

64:10;65:9;89:12 107:13 hangers (1) 101:17;107:21;108:2; hope (11)

GRAS (1) guess (16) 160:10 110:16;115:21; 28:20;39:3;48:23,

 76:14 19:9,25;38:9,11; hanging (1) 119:16;120:23; 24;67:21;79:11;

G-R-A-S (1) 46:1;50:5,21;66:7; 126:8 122:12;129:1;146:9, 122:24;127:16;

 76:14 70:5,7;85:21;99:19; happen (4) 10;154:6;155:18; 130:21,23;140:17 

grateful (7) 123:22;147:19; 51:16;79:15;95:14; 160:4,22 hopefully (6)

 117:3;118:9; 158:14;161:16 155:9 helpful (5) 8:23;9:1;118:4;

 129:16;130:15,17; guessing (1) happening (2) 99:12,19;100:4; 127:19;128:2;161:8 

160:20;161:8 152:20 104:14;157:13 105:23;150:7 hoping (2)

great (23) guesswork (1) happens (2) helps (3) 98:20;111:11 

0:15;17:21;45:23; 45:18 114:22;140:5 28:24;30:23;100:25 host (1)

 51:14;65:12;66:3; guidance (4) happy (4) herbs (1) 123:5 

68:3,7;78:10,11; 18:17,18;138:21; 107:9;112:25; 13:19 housed (1)

 79:18;91:5;96:16; 139:23 143:3;146:10 Here's (2) 87:2 

97:13;99:25;101:24; guide (1) hard (11) 87:13;141:24 Hubbard (1)

 102:17;107:7;114:25; 99:18 8:12;53:3,4;66:3; hexane (5) 121:4 

118:22,25;135:4; gum (21) 89:4;122:3;123:13; 81:22;82:17,23; huge (6)

 145:6 17:13,14,17,18; 128:22;135:10; 83:5;84:7 44:5;48:6;112:8;

Greater (1) 18:1,3,4,5,10,12,13, 139:13;154:1 hexane's (1) 116:5,5;130:16 

66:5 14,23,25;20:14; harder (2) 83:5 human (5)

Greek (1) 22:12;23:20,20;26:6; 45:10;115:18 hey (3) 43:15;72:23;73:4;

 64:16 27:11;49:21 harmful (1) 83:21;97:10;158:1 137:11;139:16 

green (5) gums (14) 73:3 hi (1) humans (3)

 44:25;131:23; 17:10,10,15,23; harvested (1) 49:13 72:22;99:23;142:19 

132:1,3;133:5 18:10,16,20;19:4,5,6; 152:3 high (4) humble (1)

greening (1) 21:3,8;24:25;71:21 harvesting (1) 95:4;103:7;117:18; 134:24 

14:12 gut (1) 33:4 157:11 humbled (1)

Greenland (1) 72:23 hazards (1) high-acyl (1) 160:18 

136:16 guys (5) 8:7 17:13 hundreds (1)

grocery (2) 71:22;87:11;91:5; head (6) highlight (1) 122:19 

20:12;34:10 97:10;161:17 19:16;21:4;59:11; 111:12 hunt (1) 

Min-U-Script® Burke Court Reporting & Transcription (11) goods - hunt 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 5 

October 26, 2023 

122:4 

hurt (1)

 153:21 

husband (1)

 17:6 

HUSEMAN (50)

 9:11;11:17;16:19;

 23:8;24:12;25:16;

 26:19;27:23;29:16;

 31:14;39:17;42:5;

 47:7;51:14,25;54:24;

 57:12;61:9,22;62:18,

 21,24;63:21;69:13;

 71:4;75:22;79:9;80:6,

 23;81:1,19,25;82:8,

 16;83:20,23;84:2;

 85:8;86:21,23;87:19,

 23;88:23;89:1,16;

 91:20;124:4;132:13,

 17;156:12 

hydrodate (1)

 40:25 

hydrogenation (1)

 55:22 

hydroxide (15)

 6:1,16;40:17,19,22;

 41:5,7,10,12,14,14,16,

 18,23;42:1 

hyperborea (1)

 32:24 

illustrating (1)

 33:18 

illustrative (2)

 45:7;149:8 

imagining (1)

 89:25 

immediately (1)

 129:12 

impact (12)

 35:21;43:22;59:8,

 16;109:17;142:25;

 144:11;149:7,22;

 150:1,7;151:23 

impacted (2)

 147:23;151:18 

impacts (1)

 59:13 

imperfect (1)

 97:3 

implement (2)

 143:2;151:4 

import (1)

 69:16 

importance (1)

 110:19 

important (19)

 18:4;72:14;95:3;

 96:15;104:15;105:13;

 106:1,2;109:10,15,23;

 110:1,2,11,12,14;

 114:24;147:20;

 157:17 

impressively (1)

 7:21 

incongruity (1)

 137:24 

inconsistency (1)

 58:25 

incorporate (1)

 112:12 

incorporated (2)

 72:24;98:11 

incorrectly (1)

 153:10 

increase (1)

 114:23 

increased (1)

 33:13 

increasing (1)

 104:18 

indicate (3)

 49:25;59:14;138:11 

indicated (1)

 158:25 

indicating (2)

 88:6;89:7 

individual (2)

 13:8;49:5 

individualizing (1)

 79:13 

industrial (1)

 32:19 

industries (1)

 107:5 

industry (18)

 13:4;14:12,13;44:5;

 65:15 

ingredient (16)

 21:22,25;33:10;

 48:14,15;50:4,5;52:6;

 72:20;76:8;85:20;

 88:8,12,16;121:23;

 127:20 

ingredients (12)

 7:8;12:22,25;13:9;

 14:8;18:17;22:6;35:1;

 48:7;49:11;55:16;

 140:11 

inherently (1)

 81:17 

inhibit (1)

 64:15 

inhibitor (2)

 44:14,17 

initial (3)

 21:12;100:1;137:5 

initiate (1)

 142:20 

initiative (1)

 151:6 

innovating (1)

 34:16 

innovation (4)

 34:17;35:7;90:11,

 14 

input (3)

 99:9;138:23;141:1 

inputs (1)

 51:6 

109:19 

insurmountable (1)

 84:8 

integrin (1)

 41:4 

intended (1)

 69:23 

intensity (3)

 14:25;72:5,15 

intensive (1)

 79:13 

intentional (1)

 119:4 

interchangeably (2)

 6:20;69:10 

interest (12)

 33:14,19,20;34:8;

 44:13;96:21;97:14,

 18;98:2;102:15;

 109:21;158:25 

interested (5)

 84:15;97:17;100:7;

 113:21;119:12 

interesting (14)

 18:24;19:24;34:3;

 39:7;45:6;48:5,8;

 53:8;60:7;94:14;98:7;

 101:9;113:24;149:10 

interim (1)

 90:5 

internal (1)

 43:23 

International (6)

I 

I’m (1) 90:14 47:19;49:16;82:4; insect-based (5) 33:12;51:16,18;

 129:16 improve (1) 84:18;104:17,24; 120:21,25;121:3,6, 67:1;69:15;144:16 

ice (2) 67:3 110:19;111:6,13; 15 interrelated (1)

 18:5;72:25 improvement (1) 113:16;114:14; insert (1) 150:20 

icon (1) 104:18 136:15;137:11; 103:22 into (51)

 100:16 impurities (1) 139:20 insistent (1) 0:12,17;6:13;8:12;

idea (7) 37:7 industry-funded (3) 73:13 12:12;17:9;18:16;

 85:24;95:17; inaccurate (2) 110:13;114:2,4 inspiration (1) 40:23;51:17;52:18;

 101:15;111:8;118:13; 58:11;145:17 ineligible (1) 127:5 59:11;62:2;72:1,24;

 119:24;127:5 incentivize (4) 7:22 installations (1) 77:14;79:13;84:3;

ideal (1) 94:7;95:13,13; inert (1) 7:2 91:6;93:10;94:5,8,10,

 77:7 122:6 140:10 installed (1) 14,17,20;96:3;97:1,6,

ideas (2) include (5) inerts (4) 85:12 20,22;98:12;99:8;

 114:25;130:13 14:19;76:9;112:24; 93:23;136:2;139:1; instance (1) 105:8,17;111:12;

ideate (1) 138:6;142:12 140:7 80:14 112:12,25;115:8;

 122:12 included (4) infancy (1) instances (2) 118:24;120:22;128:9;

identification (1) 6:4,6;88:12;138:18 35:10 50:13,14 129:11;131:10;

 12:18 includes (1) infant (1) instant (2) 135:15;142:10;

identified (2) 12:9 41:16 6:24;7:1 147:13;149:1;150:6,

 83:14;159:14 including (1) infer (1) instantizers (1) 17;151:22;160:19 

identify (9) 141:23 37:16 76:10 intricacies (1)

 51:15;78:18; inclusion (2) information (21) instantizing (1) 153:17 

118:12,18;122:12,13; 7:19;87:7 6:10,10;8:20,24; 76:10 intrigued (3)

 129:2;144:19;148:7 inclusivity (1) 9:2;18:19;21:14; instead (2) 88:2;111:4,8 

identifying (1) 96:18 38:19;39:4;49:4; 88:21;90:15 intriguing (2)

 88:16 incoming (1) 51:23;56:6;62:12; institution (1) 60:9;88:20 

IFAC (1) 161:1 68:20;73:1;99:3; 130:10 introduces (2)

 33:13 incompatibility (1) 100:23;103:15; institutions (2) 115:2;143:23 

illustrate (1) 84:24 104:10;108:1;147:6 115:19,22 invalid (1)

 137:25 incomplete (1) informative (1) insurance (1) 143:18 

Min-U-Script® Burke Court Reporting & Transcription (12) hurt - invalid 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 5 

October 26, 2023 

invasion (1)

 117:15 

investment (5)

 84:17;85:10;

 104:14;111:2,2 

invite (2)

 111:13;131:1 

involve (1)

 93:23 

involved (2)

 21:9;94:3 

involves (1)

 37:12 

ion (1)

 37:14 

irrigation (1)

 121:21 

isolated (1)

 32:23 

issue (18)

 12:14;15:13;83:6;

 96:21;97:6,10,17;

 102:3;117:10;118:15;

 136:6;150:15;156:9;

 158:17,18,20;159:2,3 

issued (1)

 138:4 

issues (19)

 18:14;19:10;77:15,

 17;78:9;83:5;94:12;

 95:6;97:2,7,9;99:6;

 101:18;109:10;

 116:17;136:23;

 137:18;150:19;

 158:24 

item (6)

 55:20;58:15;

 136:24;141:14;

 157:11;159:6 

items (6)

 69:14;98:23;

 100:15;112:14;126:5,

 7 

iterative (1)

 100:3 

job (3)

 37:7,7;135:10 

JOHNSON (49)

 11:3;16:5;22:19;

 23:23;26:1;27:4;28:8;

 30:1;31:24;35:15;

 40:2;42:15;46:18;

 47:14;49:9,18;50:5,8,

 12,24;51:20;52:15,17,

 21;53:17;54:10;

 55:19;56:23;60:20;

 63:7;64:13;68:12;

 69:5,18;70:5;71:14;

 75:18;85:16;89:22;

 92:13;101:5;115:7;

 124:14;133:2,25;

 134:3;147:8;150:9;

 161:4 

join (1)

 149:21 

judge (1)

 154:3 

judiciously (1)

 157:3 

juice (1)

 9:20 

juices (1)

 13:5 

jump (3)

 0:25;78:13;93:10 

K 

Kansas (1)

 78:6 

Kayla (1)

 37:22 

keep (17)

 35:22;39:7;52:3;

 68:13;77:5;93:4;97:3;

 101:17;122:19;130:6,

 14;131:11,12;134:25;

 142:11;155:4,6 

keeping (2)

 48:21;155:1 

keeps (1)

 119:25 

key (2)

 156:11 

kind (27)

 8:19;19:18;20:11,

 14,22;35:4;48:23;

 51:4;52:8,21;62:12;

 79:5;97:2;98:6;100:8;

 105:25;110:14;122:2;

 126:6;140:13;144:16,

 22;149:6;154:1;

 158:8;159:14;161:21 

kinds (2)

 79:2;93:15 

kitchen (2)

 41:3;138:23 

knew (1)

 116:17 

knowledge (3)

 19:9;102:6;156:14 

known (3)

 32:19;73:3;141:19 

Kyla (57)

 0:8;8:14;9:11;

 11:12;15:22;16:14;

 19:8,12;23:3;24:7;

 25:11;26:14;27:12,

 18;29:7,11;31:9;

 32:14;34:6,20;39:12;

 40:11;42:24;43:12;

 47:2;53:23;54:19;

 56:16;57:7;59:5;60:1,

 14;61:4;63:4,16;

 69:24;70:24;75:5;

 91:9,15;123:23;

 134:14,19;135:2,22;

 141:10;143:6;146:1;

 149:15;150:4,21;

 151:14;152:16;153:5;

 156:12;157:6;161:19 

laminaria (3)

 32:24,24,24 

land (1)

 121:21 

landing (1)

 128:19 

language (2)

 144:21;155:4 

large (2)

 98:19;148:24 

largely (1)

 33:2 

larger (2)

 107:21;115:18 

last (26)

 10:18;19:1;29:1;

 49:24;53:20;68:9;

 73:5;76:1,3,16;84:24,

 25;94:9;96:1,23;

 99:20;116:3;120:19;

 123:8;127:14,25;

 128:11;130:25;

 135:18;141:9;157:1 

lastly (1)

 134:11 

late (2)

 142:9;147:5 

later (2)

 86:1;94:2 

latest (1)

 98:12 

latitude (1)

 107:15 

Laughter (4)

 17:4;52:20;92:23;

 123:10 

laundry (2)

 101:17,20 

law (1)

 154:2 

lead (10)

 0:24;21:17;66:7;

 68:11;126:15;128:9;

 141:11;146:8;158:1,7 

leader (1)

 123:9 

leaders (2)

 128:3,4 

161:10 

learned (2)

 132:10;153:3 

learning (1)

 128:8 

least (6)

 18:9;85:25;88:20;

 107:20;116:6;146:25 

leave (6)

 66:17;80:10;

 130:13;140:24;

 152:21;160:12 

lecithin (20)

 49:21;76:3,4,6,9,

 13;77:9,19;79:20;

 82:6;83:1;84:9,12,18,

 22;88:22;89:3,18;

 90:4;91:7 

leeway (1)

 148:8 

legitimate (1)

 74:8 

lends (1)

 84:3 

lengthy (1)

 14:2 

less (5)

 66:22;74:6;115:24;

 117:10;137:6 

lesson (1)

 45:17 

letter (1)

 126:18 

level (3)

 35:20;102:8;148:13 

levels (1)

 67:1 

Lewis (68)

 0:16;11:7;16:9;

 20:6;21:15;22:13,23;

 24:2;25:6;26:9;28:12;

 30:5;31:7;32:3;37:10;

 40:6;42:19;45:6;

 46:22;50:3,7,9,15;

 52:3;53:20;54:14;

 57:2;60:24;63:11;

 69:2;70:19;74:25;

 84:6,11;88:2;89:2,6;

L 

lab (1)

 41:7 

label (15)

 50:6,13,14;65:4,8,

 9;66:12,15;69:21;

 73:25;88:6,7,8,17;

 89:15 

J 

jam (1) 102:23;127:20 labeled (7) leadership (17) 92:19;110:22;122:15;

 156:5 kicking (2) 7:7,9;55:16,18; 93:19;94:4;126:13, 124:18;132:7,10,15;

jams (1) 152:24,25 72:20;76:8;89:24 22;127:8,10;128:7; 133:4,11;135:3;

 13:5 Kim (39) labeling (4) 130:24;131:1;133:14; 136:2,3;139:13;

japonica (1) 9:10;10:7,10;11:16; 12:18;67:2,10,13 134:15;135:10;141:5; 140:5;141:7;143:7,

 32:24 16:18;23:7,21;24:11; labelled (1) 160:23;161:7,18,19 11,13,19,22;144:1,25;

Jared's (1) 25:15;26:18;27:22; 64:10 leading (2) 149:6,21;151:25;

 152:23 29:15;31:13;39:16; labs (1) 102:5;131:4 158:5,16,20,24;159:5,

Jeffrey (2) 42:4;47:6;51:13; 119:13 leads (4) 11 

126:18;130:17 54:23;57:11;61:8,21; lacking (1) 84:3;101:25;102:1; liaison (1)

Jeffries (1) 62:25;63:3,20;69:12; 112:18 112:11 98:5 

136:5 71:3;75:9,21;77:12; laid (2) lean (2) life (2)

Jenny (4) 79:8;84:6;85:7;86:22; 140:15;141:16 94:10;140:7 99:8;109:11 

78:11,14;131:3; 87:12;91:19;124:3; lamented (2) learn (3) light (2)

 142:23 132:12;155:23; 121:25;122:5 99:12;129:25; 73:9;139:20 

Min-U-Script® Burke Court Reporting & Transcription (13) invasion - light 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 5 

October 26, 2023 

lighten (1)

 139:23 

likely (3)

 36:12,13;38:24 

lime (1)

 41:1 

limestone (3)

 40:23,24,25 

limit (2)

 8:4;10:2 

limitation (2)

 69:20,21 

limitations (2)

 14:24;76:14 

limited (3)

 14:6;29:1;66:14 

limiting (2)

 15:16;121:23 

line (6)

 41:2;58:9;86:16;

 87:24;90:15;117:13 

lines (5)

 45:14;64:23;65:1,4;

 55:14;56:8;57:21;

 59:8;61:20;62:10;

 64:9;68:14;70:8;76:4;

 112:14 

listening (3)

 67:21;79:11;129:19 

listing (17)

 9:25;10:1;30:18;

 39:3;44:13,16;58:21;

 60:3;98:16;137:21;

 143:18;145:24;

 149:19;151:23;152:8;

 154:17;155:15 

listings (4)

 17:24;18:16;58:8;

 156:7 

lists (1)

 146:12 

literature (2)

 98:22;100:23 

little (33)

 6:2;19:21;45:9;

 48:10;61:24;62:16;

logical (1)

 137:3 

logistically (1)

 150:11 

long (7)

 89:19;94:4,25;

 110:3;114:25;118:11;

 120:14 

longer (6)

 43:22;49:25;94:17,

 17;98:13;137:8 

longest (1)

 129:21 

long-term (1)

 113:4 

look (42)

 17:23;19:6,18;

 20:10,22;21:3,24;

 35:19,20,23;51:15;

 66:25;67:5,22;72:16;

 80:6;89:12;97:1;

 100:2;105:25;109:23;

 112:25;113:16;114:9;

 116:7;118:12,20;

 119:20;120:14;121:8,

 8,10;128:5;131:3;

 135:23;148:7;157:9,

 15 

lots (2)

 0:6,21 

love (11)

 28:22;48:9;77:17;

 104:24;117:21;

 119:15,24;126:18;

 129:23;133:25;151:6 

low (1)

 15:1 

lower (3)

 122:17,22;123:3 

lunch (9)

 80:11;93:5,5,6;

 114:5;116:15;124:24;

 125:10;129:13 

109:7;110:2;137:16 

manager (2)

 78:25;152:25 

manages (1)

 136:9 

mangoes (1)

 43:14 

manufacture (1)

 41:7 

manufactured (1)

 84:23 

manufacturers (5)

 13:20;14:9;21:1;

 41:9;107:5 

manufacturers' (1)

 49:5 

manufacturer's (1)

 48:18 

Manufacturing (7)

 13:16;14:3;37:12;

 43:15;62:2;76:15;

 85:1 

manure (2)

M 

103:1 72:4;94:2;103:2,3,13; 116:10,23;117:4; machinery (2) 139:16,18 

links (1) 104:19;106:7;107:5; 119:3,15,17;122:3; 86:13,15 many (17)

 38:21 111:7;119:14;122:22; 123:8;127:10,19; Madam (3) 8:12;13:18;20:8;

liquid (8) 126:17;127:14; 134:24;138:4;139:24; 160:24;161:1,1 44:8;58:1;67:19;

 64:23;147:22; 128:17;136:2;137:7; 140:20;141:24; made-with (1) 68:14;93:17;96:8;

 152:1,4;154:13,14,16, 138:17;141:21;145:1; 146:14;159:7;160:25 70:3 104:3;105:9,9;120:6;

 17 147:5;148:11;149:16; looked (3) magnesium (15) 127:16;142:21;

LISAC (1) 150:25;151:9;158:17, 67:6;83:15,22 6:1,1,15,15;7:4,10, 156:16;159:19 

127:2 21;159:5 looking (21) 13,16,18;55:13,14,15; margarine (2)

List (96) live (2) 19:14,15,20;21:18; 56:3,13,14 76:10,13 

6:17;7:5,6,11,14,16, 93:25;148:15 51:16,22;95:18; main (5) Marion (1)

 19;10:5,10;15:22; livestock (8) 109:12;110:1,1; 13:5;14:23;20:12; 114:3 

19:15;22:13;23:21; 58:6,17,20;60:4; 116:25;117:17; 137:12,12 Mark (1)

 25:1;26:6;27:11;29:7; 88:10,13,19;141:15 129:20,25;136:12,18; mainly (1) 116:14 

31:6;35:23,24;38:1; L-malic (1) 141:3,20;145:5; 32:23 market (10)

 39:11;42:1;45:22; 158:16 147:11;152:15 maintain (1) 14:7,7;66:14;77:25;

 46:7;47:18;48:6,7; load (1) looks (6) 114:18 78:19;79:14;84:22;

 50:11;52:5,10,24; 101:8 19:3;48:5,25;51:17; major (3) 90:4;109:5;118:17 

53:25;56:8,15;58:5,6, local (1) 150:3;152:15 44:10;65:23;76:9 marketed (1)

 7;60:14;63:3;68:14, 33:5 loop (2) majority (2) 49:3 

17,23;70:13;74:22; locus (2) 104:22;108:9 41:11;103:17 marketing (3)

 91:8;94:15,17,21,25; 17:16;24:25 loophole (1) makes (11) 74:2;82:19;109:12 

95:9,14;96:6;97:4; log (1) 12:11 19:13;37:1;45:9; marketplace (2)

 98:23;99:22;100:17; 156:5 loosen (1) 77:21;98:13;115:18; 20:18;89:17 

101:17,20;103:21; Logan (45) 140:3 123:4;148:16;154:2, Markets (5)

 104:2,25;105:1,14,17; 10:16,23;15:11,19, lose (4) 7,10 78:7;90:5,12;

 106:14,19;107:19; 22,24;16:24;23:13; 43:25;101:22; making (11) 110:16;122:20 

114:25;117:13; 24:17;25:21;26:24; 107:13;130:13 40:20;45:19;48:20; mashed (1)

 118:10;121:13; 28:3;29:21;31:19; losses (1) 67:16;82:11;88:5,8; 53:18 

136:21;137:23; 39:22;42:10;43:9,10; 44:1 89:18;95:12;139:9; match (3)

 138:12,18,20;140:19, 44:18;46:5,7,13;54:5; lot (51) 143:3 60:4;104:4;118:17 

19;141:22;145:14,15; 56:18;61:14;64:1; 19:9,21;20:13; man (2) material (49)

 147:9;148:24;149:3; 68:1;71:9;73:22; 21:23;39:6;44:3,7; 131:25;154:9 7:11;8:8;12:4;13:3;

 150:3;152:4,19,24; 75:13;81:2;86:3; 53:9,14;61:23;65:21; manage (1) 14:7,8;21:17;30:11,

 153:18,19,19,21; 101:3,4;102:10; 78:1,2;79:23;86:20; 157:17 19;32:13;33:7;40:17;

 154:23;155:1,7 124:9;128:22;133:21; 93:19;94:6,8;95:1; manageable (1) 41:10;44:12,16;

listed (20) 140:8,25;144:3,6,24; 100:2,3,18;103:11,12, 157:22 47:11,13,20;48:1;

 7:5;9:9;12:12; 146:4;158:12 14,20;104:6,22,23,24; managed (1) 50:20;55:18;57:23;

 30:16;32:12;33:1; Logan's (3) 105:16;107:3;109:20; 158:8 58:18;64:12,17,19;

 38:4;43:7;51:19; 12:4;85:17;88:2 114:7,11;115:2,16; management (3) 65:19;66:1,8;67:12; 

Min-U-Script® Burke Court Reporting & Transcription (14) lighten - material 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 5 

October 26, 2023 

68:16,21;76:2,18; means (2) 10,12,14,16,18,20,24; memo (3) milk (4)

 83:9,11;86:1;90:10, 13:14;85:23 55:1,3,13,19;56:14, 138:4,16;140:10 72:24;117:7,7;

 10;138:15;141:19; meat (6) 19,21,23,25;57:2,4,6, mentioned (22) 118:15 

142:5;146:6;153:9, 33:15,19;34:4,8,18, 8,12,14,16,20;59:7, 9:22;34:2;38:18; million (2)

 11,19;155:12;157:11; 24 10,20,21;60:5,13,18, 45:20;49:14;58:17; 110:24;116:5 

158:22 mechanism (1) 20,22,24;61:1,3,5,9, 62:3,10;67:16;79:19; mind (5)

materials (27) 143:5 11,13,15,19,22;62:18, 93:13;100:16;106:11; 50:19;83:13;87:24;

 0:5;6:3,14,19,22; medical (1) 21,24;63:2,7,9,11,13, 112:1;114:22;120:10, 113:2;115:25 

14:10,14;50:23; 32:20 15,17,21,23,25;64:2, 11,13;121:5;135:22; Mindee (17)

 58:18;93:9,16;97:3; medication (1) 4,8,13;68:3,6,12;69:2, 137:14;139:6 126:18;127:7;

 126:5;135:15,23; 67:9 5,13,18,25;70:5,12, mentioning (4) 128:6;129:18,19;

 138:8,8,10;140:9,20; meet (1) 17,19,21,23,25;71:4, 93:12,20;95:12; 130:9,15,17,23;136:4,

 145:4,11;147:11,14, 131:3 6,8,10,12,14,18,21,25; 97:23 8,9,23;160:21,23;

 17,21;148:25 meeting (28) 72:9,10;74:3,14,16, mentions (1) 161:5,17 

math (1) 6:7;29:1;33:8;73:7; 20,25;75:2,4,6,10,12, 37:14 Mindee's (2)

 92:3 92:1;95:23,24;99:21; 14,16,18,20,22;76:3, merits (1) 127:19;129:20 

Matt (1) 104:1;126:21;137:20; 6;77:13;79:9;80:3,6, 9:1 mindset (1)

 101:25 138:8;142:24;146:17, 10,23,25;81:1,3,8,9, messages (1) 118:4 

matter (2) 23;147:10,11;148:8; 10,12,15,19,24,25; 150:2 Mindy (2)

 102:9;110:17 150:17;152:17;156:2; 82:7,8,13,16,18,22, messes (1) 21:16;93:18 

maturity (1) 159:20;161:9,23; 25;83:4,9,11,18,19, 82:23 mine (2)

 43:23 162:1,2,4,5 20,21,23;84:1,2,6,10, messier (1) 35:16;74:16 

maximum (1) meetings (4) 11;85:8,14,16;86:4,7, 85:24 mineral (2)

 122:8 105:10,18,19; 8,9,13,15,17,18,19,21, messy (1) 64:18;88:13 

may (29) 133:15 23;87:9,13,19,22,23; 154:10 minerals (2)

 11:25;12:22;22:2; MEMBER (546) 88:2,23;89:1,6,13,16, met (1) 88:11,19 

35:23;37:16;48:23; 0:9,11;8:16,22;9:3, 19,22;90:19;91:1,5, 111:25 minimum (2)

 49:21;52:6;72:2; 7,11;10:9,14,17,20, 12,14,16,20,22,24; metabisulfite (8) 21:2,4 

79:20;80:2;84:21,24; 22,24;11:1,3,5,7,9,11, 92:5,10,13,15,19,21; 64:24;65:3;66:19; mining (2)

 86:1,25;90:22;98:18, 13,17,19,23;12:5; 93:10;95:19;98:9; 67:21;68:17;69:6,19; 40:23,25 

19,23,24;107:12; 15:12,18,21;16:1,3,5, 99:14,19;100:14; 70:3 minute (1)

 126:20;149:22,25; 7,9,11,13,15,19,21,23; 101:5,24;102:11,20; method (1) 146:9 

150:1;151:9;153:17, 17:1,5,9,21;19:8,13, 103:1;105:5;106:6; 12:21 minutes (2)

 17;158:6 25;20:6;21:7,10,15; 107:2;108:11;109:2; methodology (3) 74:12;125:8 

maybe (38) 22:8,11,16,19,21,23, 110:8,22;111:16; 82:10,11,14 mirror (1)

 6:9;8:23;19:21,23; 25;23:2,4,8,10,12,14, 113:12;114:6;115:7; methods (10) 103:8 

21:13;34:6;35:5; 19,23,25;24:2,4,6,8, 116:2;120:8;122:15; 12:10,11,25;13:17; miscommunications (1)

 48:13,24;49:22; 12,14,16,18,20,24; 123:7,16,19,25;124:4, 21:9,19;22:1,2;93:13, 131:7 

51:17;68:19;69:16; 25:4,6,8,10,12,16,18, 6,8,10,12,14,16,18,20, 16 missed (1)

 72:13;77:18;96:5; 20,22,24;26:1,5,9,11, 22;128:17;132:6,10, Michele (1) 139:10 

98:21;99:8;101:19; 13,15,19,21,23,25; 13,15,17;133:2,18,23, 125:1 mistake (1)

 104:4,4,21,21;106:19, 27:2,4,6,10,15,17,19, 25;134:3,23;135:8; Michelle (3) 135:18 

20;113:22;116:10; 23,25;28:2,4,6,8,10, 136:3;139:2,13; 109:3;119:5;146:15 misuse (1)

 120:17,23;121:14; 12,17,20;29:6,10,12, 140:4,5;141:2,7,12; microbial (2) 73:2 

122:7;126:13;127:4; 16,18,20,22,24;30:1, 143:7,10,11,12,13,14, 12:23;64:15 mix (1)

 147:5,14;159:15; 3,5,7,11,14;31:5,10, 19,21,22,25;144:1,2, Microphone (2) 15:15 

160:2;161:8 14,16,18,20,22,24; 4,8,24;145:8,13,25; 81:14,14 mixing (1)

meal (1) 32:1,3,5,7,11,14;34:6, 146:3,7,11,13,14,16, micro-testing (1) 41:1 

82:3 19,22;35:3,9,13,15; 21;147:3,8,18;148:3, 39:1 mixture (1)

mean (40) 36:2,8;37:5,10,20,23; 15,20;149:6,16,21; Midwest (2) 13:12 

19:9,13,18;21:2,10; 38:3,12;39:5,10,17, 150:5,9,22;151:2,5, 77:15,18 mixtures (2)

 35:15;53:5,21;55:7; 19,21,23,25;40:2,4,6, 15,25;152:1,6;154:7, might (15) 13:8,12 

59:14;68:6,7;69:3,25; 8,10,12,16,18;41:25; 11;155:5,17,19,20,24; 6:11;48:8;65:11; Mm-hmm (4)

 77:19;78:17;86:14, 42:5,7,9,11,13,15,17, 156:12;157:20;158:5, 69:9,16;80:9,24;81:5; 52:11;53:16;80:25;

 19;90:9;94:11,11,23; 19,21,23,25;43:6,11; 13,16,19,20,23,24; 85:11;95:4;109:18; 88:25 

95:3;96:23;100:8; 44:20;45:6,20,25; 159:3,5,9,11,13,18,21, 127:4;131:24;138:18; mode (1)

 102:23;103:2,23; 46:6,10,12,14,16,18, 22;160:6,12,15,18; 148:9 140:22 

104:13;106:25,25; 20,22,24;47:1,3,7,11, 161:4 mike (1) models (1)

 109:18;114:2;126:19; 14;49:7,9,18;50:3,5,7, members (7) 62:15 161:24 

133:13;146:21;148:4; 8,9,12,15,18,24; 0:7,13;29:3;56:3; mil (1) modernization (1)

 149:4,19;154:8 51:12,14,20,25;52:3, 140:8,9,18 118:16 62:2 

meaningful (2) 8,12,15,17,21;53:11, membrane (2) mile (1) modification (1)

 111:7,14 14,17,20,24;54:4,6,8, 84:13;85:5 110:13 21:12 

Min-U-Script® Burke Court Reporting & Transcription (15) materials - modification 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 5 

October 26, 2023 

modified (3)

 12:17,19;28:22 

moisture (1)

 121:18 

molecule (1)

 51:4 

moment (3)

 19:16;72:2;159:24 

momentum (3)

 107:8,11,13 

money (12)

 103:24;104:7,8,16;

 114:2,4,13;115:12,13,

 13;117:6;122:6 

mono (4)

 47:12,12;49:10;

 53:25 

mono/diglycerides (1)

 50:11 

mono-diglycerides (1)

 52:5 

Montanna (1)

 121:19 

months (2)

 77:24;112:15 

more (75)

 8:23;9:12;12:10;

 14:8;19:9,22;35:7,20;

 48:10,16;49:23;

 51:23;56:6;58:12;

 59:17;61:24;65:7;

 67:1,23;68:7,20;74:1,

 14,15,18;77:17;

 79:23;80:1;82:18;

 83:1;93:17;94:2,24;

 96:12,16;97:8,8,15;

 99:18;100:15,25;

 103:11,22;104:8,21,

 22,25;107:6,15,22;

 109:25;110:12;

 111:12;113:6;115:20;

 117:1,1,7,9;118:13,

 14;119:24;121:17;

 123:4;141:21;145:1,

 21;147:5;148:3,11,

 18;151:25;154:3;

 155:25,25 

morning (9)

 0:3;9:13,13;32:14;

 38:13;68:22;72:2;

 83:22;92:22 

Most (10)

 7:24;9:18;12:19;

 18:10;55:20;64:19;

 66:2;86:11;92:1;

 104:7 

29:5,6;30:10;31:4,5;

 32:10;39:9,10;40:15;

 41:24,25;43:5;46:5,6;

 47:10;53:24;55:12;

 56:13,14;57:19;

 60:12,13;61:18;63:1,

 2;64:7;70:11,12;

 71:17;74:11,11,20,22;

 75:25;91:4,7;92:25;

 123:14,16,18,19;

 125:6;143:17,20 

motioned (7)

 39:11;42:1;53:25;

 56:15;63:3;70:13;

 91:8 

motions (3)

 143:18;145:23;

 147:20 

mouth (2)

 20:9;62:15 

move (23)

 0:12,17;28:17;

 49:16,17,19;51:7;

 71:18;93:7;94:20;

 96:3,6;97:4;118:7,19;

 119:2;126:4;130:12,

 16;133:15;140:15;

 148:11;154:15 

Moving (13)

 9:7;11:24;47:19;

 93:14,14,24,25;94:5,

 18;98:3;104:15,20;

 123:9 

much (24)

 9:3;10:2;41:18;

 51:12;59:12,13;

 62:15,21;86:8;

 107:21;111:5;115:23;

 118:16;120:4,9;

 121:24;128:18;

 133:10;138:19;

 139:14;145:6,12;

 154:8;161:9 

Multiple (2)

 13:19;153:2 

must (4)

 12:1,2;67:10;

 139:17 

myself (12)

 15:23;27:12;29:7;

 37:24;39:11;56:16;

 60:14;63:4;87:10;

 91:8;136:8;140:9 

NANDWANI (37)

 11:9;16:11;22:25;

 24:4;25:8;26:11;

 27:15;30:7;32:5,14;

 34:6,19;35:3,9,13;

 38:12;40:8,18;42:21;

 46:24;54:16;57:4;

 61:1;63:13;70:21;

 75:2;91:12;100:14;

 111:16;116:2;120:8;

 124:20;139:2;140:4;

 144:4;145:8,25 

Nanotech (2)

 8:22;9:2 

nanotechnology (2)

 8:19,20 

narrow (3)

 55:20;61:24;95:2 

nascent (1)

 111:8 

Nate (69)

 0:16;11:6;16:8;

 20:5;21:13,13;22:13,

 22;24:1;25:5;26:8;

 28:11;30:4;31:7;32:2;

 37:9;40:5;42:18;45:5;

 46:21;50:2;52:2;

 53:19;54:13;55:3;

 57:1;60:23;62:22;

 63:10;69:1;70:18;

 74:24;81:2;84:5;85:8;

 86:3,23;87:8;88:1,24;

 89:2,23;92:18;93:12,

 21;94:1;110:7,21;

 111:16;112:25;

 122:14;124:17;132:6,

 8;133:4,11;135:3;

 136:2;139:3;141:5;

 143:6;144:25;149:5;

 158:4;160:15,23;

 161:5,17,19 

nation (1)

 112:23 

National (39)

 6:17;7:5,5,11,13,16,

 19;10:5,10;15:22;

 22:13;23:20;25:1;

 26:6;27:11;29:7;31:6;

 38:1;39:11;42:1;46:7;

 53:25;56:7,15;60:14;

 63:3;70:13;74:22;

 79:3;91:8;116:4;

 134:20;136:21;

 137:23;138:11,20;

 150:2;152:24;153:17 

nationwide (2)

 108:16 

near (1)

 136:8 

Nebraska (2)

 34:5;78:6 

necessarily (4)

 35:8;89:24;103:8;

 106:14 

necessary (5)

 44:12;48:19;73:25;

 83:17;120:3 

necessity (2)

 20:15;41:11 

need (55)

 19:23;21:3;33:6;

 34:16;48:15;49:25;

 53:1;56:6,8;67:22;

 68:13;73:25;78:8;

 80:18,22;82:21;

 90:12,14,24;96:12,12;

 98:3;99:11;101:18;

 103:22,24;104:16,16;

 105:14,15;106:23;

 115:23;116:12;117:7,

 25;118:1,24;119:2,

 17;120:15,17;127:8,

 9;135:6;139:20,25;

 143:18;146:24;150:1;

 151:24;156:1;157:17;

 158:2;159:16,17 

needed (5)

 7:25;44:15;47:20;

 86:5;143:4 

needle (6)

 89:9;104:15,21;

 118:8,19;119:2 

needs (7)

 94:15,21,24;95:14;

 99:18;118:6;144:13 

negate (1)

 82:16 

neighbor's (1)

 88:21 

nervous (3)

 74:17;78:11;83:22 

Nestle (1)

 114:3 

net (1)

 112:8 

network (1)

 140:18 

neutralizing (1)

 40:19 

new (31)

 14:20,20;15:7;41:5,

 6,7;61:25;66:5;72:13;

newest (1)

 140:17 

news (2)

 97:16;122:1 

newspaper (1)

 137:21 

next (32)

 0:17;30:11;43:6;

 47:11;48:24;55:13;

 61:19;64:8;87:3;96:3;

 100:15;101:11;

 107:12,17,20;119:15;

 127:22;128:2,4,7,10;

 130:21;131:10;134:8;

 135:6;142:10;145:16;

 147:13;150:17;

 158:13;161:8,22 

Ngouajio (2)

 111:21,25 

nice (4)

 18:22;99:16;

 159:13;161:21 

NIFA (7)

 101:25,25;102:16,

 25;105:11,23;108:14 

night (1)

 128:11 

nimble (1)

 107:22 

nitrate (2)

 143:15;153:3 

nitrogen (4)

 122:4,19;137:1,6 

nitty-gritty (1)

 112:5 

nodding (1)

 152:23 

nominate (6)

 132:6,18,22;

 133:18,23;134:13 

nomination (4)

 132:9,11;133:20;

 134:18 

nominations (10)

 131:17,20,21;

 132:4,24;133:3,16;

 134:2,12,17 

non (1)

 158:18 

non-agricultural (2)

 12:22;72:12 

noncertified (2)

 88:7;89:14 

non-compliance (1)

 153:9 

nondigestible (1)

N 

mostly (3) naivety (1) 111:20;112:5 95:25;96:24;98:21; 72:21 

77:3;83:12;126:18 78:16 natural (6) 99:22;107:16;115:24; none (2)

motion (62) name (4) 12:7,9;13:3,22; 116:8;118:1;138:6, 29:5;47:23 

10:8,9;11:22;15:20, 66:25;111:20; 14:12;76:12 10;139:9;143:23; non-GMO (1)

 21;17:8;22:10,12; 133:6;134:5 nature (2) 145:10,24;148:25; 90:1 

23:17,20,21;24:23,24; namely (1) 72:5;126:16 149:3;151:12;160:1, nonmeat (1)

 26:4,5;27:9,10;28:15; 32:23 NCAD (1) 2,4,22;161:19 34:3 

Min-U-Script® Burke Court Reporting & Transcription (16) modified - nonmeat 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 5 

October 26, 2023 

nonorganic (1)

 76:7 

non-organic (2)

 72:19;81:3 

non-radiated (1)

nutritive (1)

 69:9 

oiled (1)

 88:22 

oil-free (1)

 28:18 

oils (2)

onto (9)

 9:7;11:24;28:17;

 52:10;106:14,19;

 126:4;133:15;150:12 

onwards (1)

OREI-funded (1)

 105:6 

ores (1)

 64:19 

organic (184)

O 

90:1 observation (2) 80:24;81:19 116:8 6:23,24;7:7,9,12;

non-synthetic (4) 34:11;147:19 old (3) oop (1) 8:5;9:20;11:25;12:2,

 11:25;12:2,22; obsessing (1) 64:17,17;130:18 153:10 12,20;13:1,4,8,21,22,

 158:20 130:7 OMRI (1) Oops (1) 24,25;14:4,5,7,10,13,

non-synthetics (1) obstacles (1) 64:24 11:23 18,20,22;15:1,8;

 9:9 14:3 once (7) open (8) 17:22;18:8,12,13,14;

NOP (2) obtain (1) 8:9;20:4;99:5; 68:25;85:5;99:11; 20:24;21:23;33:13,

 7:20;68:22 14:9 148:21,22,23;160:1 126:14;132:3;134:11; 17,22;34:3,13,18;

Nope (1) obtained (1) One (118) 146:17;150:6 35:1,16;41:9;47:16,

 81:12 12:18 8:5;9:15,22;13:7, opened (1) 18,24;48:2,12,13,15,

no-rinse (1) obtuse (1) 24;15:5,14,16;18:2,2, 146:17 23;49:3,9;50:10,10;

 58:24 149:16 11,24;19:22;20:15; opening (2) 51:7,8,9;53:6,15,21;

normalization (1) obvious (1) 33:9;35:17,19,24; 70:4;147:4 55:16,18,25;57:24;

 157:22 148:12 38:15,17;41:12; operation (4) 60:9;64:10,23;65:1,4,

Normally (2) Obviously (7) 43:12;44:10,24;48:3, 58:9;136:10;153:9, 8,9,21;66:12,15;

 120:8;121:23 78:8,13;82:1;86:20; 17;49:9;52:4;53:1,2, 13 68:15;70:4;72:20;

north (2) 95:24;97:6;138:13 2;55:11;56:2,2,5; operations (1) 73:12,18;76:8,18,19,

 45:10;78:5 o'clock (1) 57:20;62:6,9;66:1,4, 58:1 24;77:10,19,23;78:2,

NOSB (12) 93:6 10;67:8,19;68:16; operators (1) 4,7;79:4,20;80:2;

 15:8;41:4,13,17,18; October (1) 69:3,3,8;72:11;74:14, 136:9 81:5,6,11,16,19,21,

 47:19;123:17;126:11, 135:18 15,18;76:3;77:3,16, opinion (2) 25;82:11,14,19,20;

 20;128:12;132:5; odorless (1) 22;78:23;84:13; 51:6;78:10 83:2;84:8,19,20,22;

 135:15 28:23 87:15;88:15;89:12; opinions (1) 85:20,20;86:2,5,12;

note (1) off (18) 90:21;94:16;96:11; 128:18 87:1,4,24;88:4,6,8,12,

 78:23 0:5,8;9:8;51:3; 97:10,10;99:21; opportune (1) 13,14,17;89:2,12,17,

noted (6) 52:22,24;65:1;82:12; 100:16;101:10,17; 90:22 17,18;90:1,4,6,10,13;

 38:6;47:19;51:1; 93:3;98:23;104:25; 103:4,13;105:15; opportunities (1) 95:5;100:20,24;

 65:2;76:24;159:25 106:21;113:23; 107:7,15;109:10; 123:5 101:19;102:14;

notes (2) 118:10;128:24; 112:8,20;113:18; opportunity (12) 103:17;107:4,25,25;

 57:21;62:16 135:17;152:4,19 114:2,6;115:11,13,25; 35:2;36:24;53:8; 109:6,7,12,22;111:24;

notice (3) offender (1) 120:9,12,20;121:6,12; 70:4;79:18;95:24; 112:4,6,23;113:4,15,

 144:11;155:8,9 62:14 125:2;127:23;129:7; 103:19;104:6,12; 19;115:9,24;116:4,9;

noticed (2) offense (1) 130:7;134:18;137:12; 123:7;130:24;161:10 117:6,7;118:14,25;

 37:24,25 156:8 138:14;142:4;143:23; opposed (9) 119:23;120:12,14,18,

noting (1) offer (1) 144:6;145:24,24; 44:11;56:5;109:17; 20;121:11,14,14,22;

 58:7 101:20 147:19;148:3;149:7; 111:8;117:2;130:7; 122:6,11,25;123:1;

notion (1) offered (1) 150:2;151:25;152:20, 142:17;145:1;149:12 134:20;136:7;138:14,

 151:11 66:18 21;154:8;157:7,9,24, opposing (1) 15,23;139:21;140:11,

nudge (1) office (2) 24,24;158:1,9;159:5, 15:4 12 

88:20 56:7;153:16 7;162:3 opposition (1) organically (1)

number (18) officer (1) ones (5) 56:11 13:2 

12:14,24;78:5;95:6; 126:4 36:12;78:7;94:16; optimum (1) organics (4)

 114:9,15,21;115:10, officers (1) 99:25;148:12 123:2 21:1;77:15;104:8;

 11,13,25;136:11,25, 160:13 one-way (1) option (5) 121:25 

25;137:7,19;147:21; officially (1) 101:12 49:1;67:24;83:3; organisms (3)

 159:7 162:1 ongoing (2) 149:11;155:1 12:17,19;13:2 

numbers (7) OFPA (1) 96:2;142:17 options (9) organized (1)

 48:11;119:18; 77:10 online (2) 19:23;20:11,13; 18:7 

137:18;139:15,17,17, often (6) 126:9,9 79:6;140:15;152:21; oriented (1)

 25 21:20;68:7;114:22; only (23) 153:2;154:9;159:7 122:2 

numerics (1) 139:5;153:14;157:13 7:6,24;8:4;12:2; oral (5) original (1)

 137:1 Oftentimes (1) 17:13,16;20:21; 13:24;65:18;77:2, 38:4 

nutrient (3) 137:8 24:25;38:10;47:13; 23;108:20 OSPs (1)

 40:21;72:21;137:15 oil (14) 53:5;55:15;57:23; order (3) 30:19 

nutrition (2) 76:12;79:12,22; 62:8;64:9;66:11; 139:18;147:20; ostensibly (1)

 13:6;117:20 81:20,20,23;82:2,5; 82:20;86:21,23; 148:1 155:24 

nutritious (2) 83:24;84:7;86:20,24; 95:10,10;112:2; OREI (3) others (8)

 100:20,25 87:5;89:17 127:13 103:3;113:15;119:6 18:1;36:25;93:19; 

Min-U-Script® Burke Court Reporting & Transcription (17) nonorganic - others 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 5 

October 26, 2023 

95:7;111:19,23;

 120:12;132:21 

Otherwise (3)

 116:11;138:25;

 143:14 

ours (1)

 94:25 

ourselves (5)

 0:21;10:2;103:22;

 143:15;148:8 

out (67)

 6:12;14:19;18:2,16;

 19:20;28:20;37:7;

 45:18;48:15;55:6;

 56:7;62:10,21;69:8;

 73:8,22;77:4;81:5;

 90:12;99:4;100:6,12;

 102:22;103:3;105:22;

 106:9,17,24;111:12;

 114:7,22;115:20;

 116:19,20;117:9,15,

 16,19;118:1,2,19,22;

 119:6;121:12;122:11;

 123:6;126:4,6,8;

 128:15,24;130:5,6;

 140:15;141:16;

overseas (2)

 84:23;85:2 

oversimplify (1)

 82:4 

overstate (1)

 110:19 

overview (1)

 98:6 

overwhelming (1)

 66:18 

overwhelmingly (2)

 9:23;138:17 

own (8)

 18:1;19:10;95:2,2;

 101:6;103:21;104:10;

 150:13 

owned (1)

 119:23 

oxidation (1)

 64:16 

oxygen (7)

 28:17,18,18,20;

 29:4,6;69:8 

13:14;18:23;19:2;

 21:21,22,25;33:14,20;

 36:18;51:9;56:11;

 58:19;90:22;110:24;

 113:24 

particularly (5)

 14:13;38:7;50:25;

 56:5;136:24 

partner (2)

 108:15;131:5 

partners (1)

 51:21 

partnership (1)

 131:9 

parts (3)

 79:13;113:19;

 136:18 

pass (6)

 17:12,12;43:20;

 100:1;133:7;143:17 

passed (1)

 73:24 

passes (1)

 125:7 

passive (1)

 102:24 

per (1)

 107:25 

percent (6)

 14:21;46:2;78:3;

 90:16;103:16;111:24 

percentage (1)

 78:2 

perform (1)

 122:7 

perhaps (3)

 9:1;141:23;146:8 

permitted (2)

 41:14;51:18 

persisted (1)

 128:21 

person (8)

 67:11;100:22;

 101:25;108:19,24;

 132:20;144:19;

 147:15 

personal (4)

 34:11;109:13;

 128:25;129:11 

pest (1)

 110:1 

pesticide (2)

 56:3 

phone (1)

 100:16 

phosphate (1)

 40:21 

Phosphoric (11)

 57:21,22,23,24;

 58:14;59:3,5,8;60:4,

 13;145:14 

picture (1)

 101:22 

pictures (1)

 135:20 

piece (2)

 36:3;130:1 

pieces (1)

 154:5 

pile (1)

 161:4 

pin (2)

 48:24;139:13 

pinch-hitting (1)

 136:5 

pink (2)

 131:22;132:2 

pipeline (3)

P 

142:12;145:22;146:5, package (1) past (6) 140:11,11 118:23;128:4;

 23;147:10;150:15; 68:19 0:15;29:1;30:25; pet (1) 133:14 

153:7;154:4,6;158:2, packager (1) 102:2;153:15;160:24 35:16 pipes (1)

 6;161:15 65:14 pasteurized (1) petition (18) 87:20 

outcome (1) packaging (1) 15:2 0:24;7:20,21;8:3; piping (2)

 20:2 28:23 path (2) 43:19;44:15;52:25; 87:1,14 

outgoing (4) packet (1) 119:1;122:10 68:24;69:14;70:1,1; PIs (1)

 160:13,21;161:1,17 0:25 pathogens (3) 136:14;138:3,5,6; 112:13 

outlier (1) packing (1) 137:11;139:16; 148:25;157:10,14 place (8)

 69:20 7:1 140:1 petitioned (8) 36:23,24;119:23;

outline (1) panel (6) paths (1) 6:2,16,21,23;7:19; 129:10,12,13;137:22;

 97:21 80:24;111:22; 157:16 8:3;69:14;70:8 147:14 

Outlined (1) 112:4;113:15;114:9; Pause (4) petitioner (3) placed (1)

 158:24 121:10 133:8;134:7; 6:25;8:25;70:6 127:25 

output (3) panels (5) 135:21,25 petitions (2) places (2)

 85:21;109:19,20 113:14,17,18,24; PCO (2) 0:23;67:21 36:25;159:7 

outreach (5) 121:8 34:24;52:5 PETREY (59) plain (1)

 105:7,16;108:16; paper (1) peapots (1) 10:24;12:5;15:18; 155:4 

109:20;115:9 137:21 97:7 16:1;17:1,5;22:8; Plains (3)

outside (5) parallel (7) pears (1) 23:14;24:18;25:22; 78:21,22;79:1 

19:6;28:21;83:15; 45:11;119:1;143:9, 43:20 26:25;28:4;29:22; plan (4)

 139:18;147:16 11,23;157:15;159:1 peas (1) 31:20;39:23;42:11; 93:5;105:11;

over (28) parentheses (2) 117:25 43:11;45:20;46:14; 133:14;155:1 

9:22;13:22;19:22; 55:16,17 pedantic (1) 54:6;56:19;61:15; planning (2)

 36:23;43:15;46:2; part (22) 87:13 64:2;68:3;71:10; 105:9;140:13 

71:24;77:24;91:6; 13:10;18:4;37:7; peer (1) 75:14;81:3,9,12,15, plans (1)

 93:8;94:9,23,23; 39:7;44:5,6;60:9; 108:21 24;82:7,13,18,25; 13:21 

96:22,22,23;97:6,7,7; 65:16;78:19;79:3,7; people (24) 83:9,18;86:4,8,13,17, plant (3)

 99:17;102:25;127:25; 81:3;96:4;99:2; 45:19;78:8;93:18; 19;102:11;124:10; 89:15;138:8,9 

128:6;130:25;136:1; 118:22;121:9;142:12, 94:24;97:18;100:7, 133:18;144:8;152:1; plant-based (3)

 141:8;156:2;161:15 18;148:24;150:7; 12;104:24;105:9,10, 154:11;155:5,17,19; 33:19;34:8,24 

overall (3) 155:8,13 11,23;109:14,21; 158:13,19,23;159:3,9, plants (4)

 18:19;80:7;134:15 participate (3) 113:16,22,25;114:23, 13,21;160:6 13:19;37:2;121:5,

overdue (1) 111:6,13;113:23 25;122:10;126:9; ph (6) 15 

94:4 participated (1) 129:8;147:12;161:5 38:24;40:25;97:7; plastics (5)

overlooked (1) 59:21 people's (2) 116:4;121:5;127:2 94:8,24;95:5;96:9;

 144:20 particular (15) 20:3;152:15 pharmaceutical (1) 97:6 

Min-U-Script® Burke Court Reporting & Transcription (18) Otherwise - plastics 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 5 

October 26, 2023 

play (2) 88:18;90:2;127:18; 16,18,20,22,24;28:1, 130:10 pretty (11)

 111:1;132:15 128:3;145:6 3,5,7,9,11,13;29:4,8, powerful (1) 32:15;51:22;68:21;

player (1) possibly (1) 11,13,15,17,19,21,23, 102:7 69:10;78:9;90:13;

 132:16 44:13 25;30:2,4,6,8;31:3,8, PowerPoint (1) 128:14;131:2;135:11;

plays (3) post (1) 11,13,15,17,19,21,23, 155:20 138:19;144:12 

153:7;154:4,6 107:9 25;32:2,4,6,8;33:24; ppm (1) prevent (5)

please (12) post-farm (4) 35:14;36:1,7;37:4,9, 64:12 20:8,16;28:25;

 10:21;29:5;44:19; 109:5,12,13,23 21;38:2;39:8,13,16, practical (1) 64:15;84:19 

53:23;68:2;81:14; post-harvest (5) 18,20,22,24;40:1,3,5, 89:7 preventing (1)

 122:14;132:5,25; 43:7,13;44:9;58:2; 7,9,11,13;41:22;42:3, practice (5) 84:19 

134:5,12;135:7 60:8 6,8,10,12,14,16,18,20, 59:2;136:20; Previous (9)

plenty (1) posting (1) 22,24;43:1,3;44:18; 137:16,19;138:20 33:6;41:8;104:1;

 118:15 147:9 45:5,24;46:4,8,11,13, practiced (1) 128:13;141:20;159:6,

plus (2) potassium (23) 15,17,19,21,23,25; 71:22 10,11,12 

103:6,6 30:11,12,12,14; 47:2,4,6,8;49:6,12; practices (6) previously (3)

pm (4) 31:5;61:19,20,23,25; 50:2,17;51:13;52:2,7, 33:4;76:15;85:2; 7:5;12:15;41:4 

93:3;125:10;126:2; 62:2,7,13;63:2;64:23; 11,13,16,19;53:4,13, 137:2,11;139:20 prices (3)

 162:5 65:3;66:19;67:21; 16,19,22;54:2,5,7,9, precedent (2) 117:18,18;123:3 

podcasts (2) 68:17;69:6,7,9,18; 11,13,15,17,19,21,23, 88:10;126:15 primary (1)

 108:16,24 70:2 25;55:2,6;56:12,17, precipitates (1) 13:9 

point (24) potato (11) 20,22,24;57:1,3,5,7,9, 37:13 principal (1)

 22:3;45:24;80:17; 47:18,20;49:3,8,9; 11,13,15,17;59:5,24; predictable (1) 138:15 

89:23;90:22;98:22; 50:10;53:6,11,12,13, 60:11,16,19,21,23,25; 80:19 Pringles (2)

 103:4;104:4;106:20; 15 61:2,4,6,8,10,12,14, prefer (1) 50:10;53:21 

108:4;110:18;112:7, potatoes (4) 16;62:14,20,23,25; 149:24 prior (2)

 8,20;116:7,21; 44:15,17;49:10; 63:5,8,10,12,14,16,18, preferable (2) 43:24;159:20 

118:20;122:18; 53:18 20,22,24;64:1,3,5; 65:11;67:24 priorities (31)

 131:25;147:8,9; potential (10) 67:25;68:5,11;69:1, preference (3) 93:11;94:6,11,16,

 149:6,14;157:4 12:11;37:16;38:23; 12,24;70:10,15,18,20, 20:7;66:20;69:11 22;95:9,25;96:11,17;

pointed (1) 47:22;49:1;66:23; 22,24;71:1,3,5,7,9,11, preferred (3) 98:13;102:5,23,24;

 56:7 68:16;69:14;82:19; 13,15,20;73:21;74:10, 18:25;133:6;134:5 103:5,9,23,25;105:21;

points (5) 83:25 15,18,24;75:1,3,5,7,9, pregnancy (1) 106:9,13,17,19,24;

 65:23;103:13; potentially (6) 11,13,15,17,19,21,23; 17:1 113:7;116:24;119:7,

 115:8;118:21;139:6 13:1;30:20;77:18; 76:1;77:12;78:13; preliminary (3) 16,17;123:14,17;

poke (1) 80:13;85:5;139:24 79:8;81:2,14;84:5; 8:6,7;107:20 157:8 

51:16 poultry (2) 85:7,15;86:3,22;87:8, premium (1) prioritization (2)

policy (2) 97:15;117:20 11;88:1,25;89:11,21; 122:20 101:16,20 

9:3;100:7 pounds (1) 90:7,18;91:3,10,13, preparation (2) prioritize (1)

politely (1) 122:19 15,17,19,21,23,25; 15:2;40:24 99:24 

126:12 pour (1) 92:6,9,11,12,14,18, prepared (1) prioritizing (2)

politically (1) 122:18 20;93:1,4;95:16; 9:12 104:1;157:16 

102:16 powder (3) 99:16;100:13;101:3; present (4) priority (7)

polluting (1) 6:24;7:1;69:7 102:10;103:10;105:2, 72:12;75:21; 95:4;98:1;103:7;

 36:24 powdered (3) 4;106:4;107:1;108:3; 100:23;101:7 105:25;107:19;116:9;

pollution (1) 55:22;64:24;65:1 110:6,21;111:15; presentation (3) 120:23 

36:23 powders (3) 113:10;115:4;116:1, 99:20;105:20; private (8)

poor (2) 47:17;76:10,11 13;121:17;122:17; 108:20 107:14,25;110:10;

 131:7;153:18 POWELL-PALM (425) 123:11,18,21;124:1,3, presented (3) 111:2,2;115:2;

popping (2) 0:3,10;8:14;9:5; 5,7,9,11,13,15,17,19, 73:7;158:22;159:23 119:21;120:2 

0:5;135:23 10:7,12,15,18,21,23, 21,23;125:3,8;126:3; preservative (1) probably (17)

pork (1) 25;11:2,4,6,8,10,12, 131:16;132:8,12,23; 12:4 19:10;48:16;52:22;

 97:14 14,16,18,20;15:11,19, 133:3,9,13,19,22; press (1) 66:7;78:16;85:24;

position (12) 24;16:2,4,6,8,10,12, 134:1,4,8,11,17,25; 82:2 86:7;95:14;104:2;

 66:17;73:16; 14,16,18,20,22,24; 135:13,22;136:1; pressing (1) 113:3;120:15;121:13;

 103:16;131:17,21; 17:3;18:21;20:5,20; 141:9;143:6;144:3,6; 13:17 123:3;128:17;135:11;

 132:4;133:4,16,16; 21:6;22:9,14,18,20, 145:7;146:1,20; pressure (1) 148:4;155:1 

134:6,12,18 22,24;23:1,3,5,7,9,11, 147:7;148:2,14; 148:7 probiotic (1)

positions (1) 13,15,22,24;24:1,3,5, 149:5,15;150:4,8,21; presumably (1) 72:22 

128:7 7,9,11,13,15,17,19,21; 151:14;152:12; 51:5 problem (7)

possibility (2) 25:3,5,7,9,11,13,15, 155:23;156:11;157:5, presumptive (1) 14:15;19:17;100:5;

 21:8;143:22 17,19,21,23,25;26:2, 19;158:4,12;160:7, 150:24 117:1;119:18;125:5;

possible (8) 8,10,12,14,16,18,20, 14;161:2,12,14;162:3 pretend (1) 143:15 

14:18;49:3;60:6; 22,24;27:1,3,5,7,13, power (1) 145:15 problematic (1) 

Min-U-Script® Burke Court Reporting & Transcription (19) play - problematic 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 5 

October 26, 2023 

137:7 

problems (3)

 68:16;117:5,17 

procedural (1)

 52:9 

proceeded (1)

 72:6 

process (70)

 6:3;7:9;14:22;

 17:24;22:2;35:22;

 36:21;45:1,9;46:3;

 48:19;52:23;60:10;

 62:2;66:24;70:9;

 79:11,22,22;81:7,10,

 17,21;82:1,4,17,24;

 84:7;86:1,10;87:6,16,

 19;88:5;93:14,17,23;

 96:24,25;97:11;

 100:3;102:1,7,21,24;

 103:20,23;104:20;

 79:19;80:5,5;81:5;

 82:8,10,12;84:4;

 85:19;87:17,20,25;

 110:2;114:15,16 

production (30)

 6:24;7:3;8:5;9:20,

 20;12:20,25;13:1;

 32:16;33:18,22;35:1,

 5,20;60:10;73:19;

 78:1,4;79:15;80:7,7;

 81:19;85:10;86:25;

 87:1,4,5;118:14;

 136:23;138:15 

Productions (1)

 77:10 

products (45)

 7:7,9;12:9,12;13:5,

 8,11;14:16,20;17:22;

 18:5,6;19:5;20:9,18,

 24;21:20;28:25;

 137:3 

proof (2)

 118:5,7 

properties (1)

 33:11 

proposal (7)

 105:25;112:7,22;

 114:10,11;123:17;

 144:9 

proposals (11)

 111:18;112:1,3,6,

 10,12;113:14;114:8,

 8;142:3;145:23 

propose (1)

 134:18 

proposed (6)

 7:15;138:10;142:3;

 152:9;153:12,13 

proposing (4)

 73:19;77:11;

 14:18;95:1 

push (3)

 49:1;106:24;109:25 

pushing (4)

 52:3;106:9,17;

 119:24 

put (22)

 19:14;21:3;22:3;

 48:12,24;53:8;77:14;

 78:8;83:24;90:20;

 114:11;119:7;121:13;

 122:12;128:15;130:4;

 144:10;145:17;

 146:22;151:8,21;

 152:2 

putting (3)

 74:4;105:24;144:11 

33:10,15;37:11;

 64:10,10;112:1 

R 

racial (1)

 96:18 

radar (1)

 157:12 

radical (1)

 127:13 

raise (5)

 117:24,24,24,25;

 159:2 

raised (1)

 21:11 

raising (2)

 77:15;156:15 

ran (1)

 48:3 

Q 

106:10;116:21; 30:23,24;33:15;34:4, 139:11;145:19 qualified (1) range (1)

 126:17;130:1;139:8, 10;47:21,24;48:7,13, protein (2) 132:25 58:3 

10;141:16;142:5,14, 13,15;49:2;51:4,17; 122:15,19 qualify (1) rank (1)

 16,18,20;143:16; 55:15,18,22;56:4; prove (1) 144:14 119:16 

144:22;148:9,16; 69:16;72:20,24;76:8; 116:20 quality (4) ranking (2)

 149:1;151:4;155:11; 82:11;83:25;97:23; provide (11) 18:1;76:25;83:16; 104:2;157:11 

156:8,19;160:5 140:11;148:9 8:1;13:10,14;18:17; 122:24 rare (1)

processed (2) profile (1) 30:23;33:11;48:10; quantities (1) 127:25 

17:22;58:2 14:25 82:10;101:23;108:10; 21:4 rate (1)

processes (6) program (17) 135:10 quantity (3) 7:3 

12:10;14:18;47:16; 9:3;115:24;116:4; provided (3) 14:5,10;21:2 rather (3)

 49:5,23;76:15 131:5,9;136:13; 64:11;77:2;110:24 QUARCOO (32) 101:12;116:8;

processing (9) 138:2;140:10,15; providing (1) 8:16;10:14,17,20, 129:18 

6:16;32:18;34:14; 141:13;152:10,10,12; 150:7 22;11:19;16:21;21:7; ratio (2)

 40:19,20;41:11;50:4; 156:8,10;157:4; public (26) 23:10;24:14;25:18; 136:25;137:6 

57:24;59:16 161:15 6:14;7:15,24;8:9; 26:21;27:25;29:18; ration (1)

processor (5) programs (2) 18:7,8;33:7,18;34:2, 31:16;36:8;37:20; 137:1 

18:11,12,12,13; 111:9;116:6 15;35:11;39:6;41:8, 39:19;42:7;46:10; raw (8)

 85:11 program's (1) 11,17;48:21;64:14; 55:1;57:14;59:7,20; 14:6,7,10;76:18;

processors (3) 149:9 67:16,20;79:19; 61:11;63:23;71:6; 83:9,11;85:20,25 

55:25;80:23;143:1 progress (3) 119:24;120:1;141:21; 75:10;91:22;107:2; reach (1)

produce (8) 13:21,25;90:10 155:2,15;159:8 114:6;124:6 45:2 

13:2;14:10;38:22; prohibit (1) publications (2) quarterly (1) reached (1)

 83:16;117:1,7; 45:15 108:14,21 112:15 117:19 

118:15;120:24 prohibited (9) publicly (2) queue (2) reaches (1)

produced (10) 7:8;8:22;9:2;30:15; 22:5;135:19 78:13;147:1 43:23 

12:2,16;22:1;32:21; 55:17;64:24,25; published (1) quick (10) reaching (2)

 40:22;44:4,8;51:5; 121:1;153:10 38:5 41:1;49:13;84:5; 14:19;43:24 

65:22;87:24 prohibition (1) pull (3) 90:19;92:3;95:17; reaction (2)

producer (5) 12:21 48:6;52:22;119:11 121:17;125:3;154:10; 67:9;110:23 

14:16;48:20;53:2,7; project (7) pulled (1) 159:15 reactions (1)

 55:4 35:16;78:25;103:6; 52:24 quickly (7) 55:23 

producers (3) 105:6;108:13;109:16; Pulling (1) 78:9;107:19;116:2; read (13)

 66:11;88:13;117:1 110:5 119:12 119:6;141:2;144:12, 14:2;17:12;29:5;

producing (3) projects (3) pun (1) 19 33:9;35:12;38:19,20;

 117:10;118:16; 103:3;104:11;113:6 69:23 quite (12) 45:14;123:15;135:17;

 123:2 promise (2) purification (3) 9:12;13:15;19:1; 145:12;156:17;

product (32) 71:22;154:2 36:21;37:12,15 47:23;55:20;79:16; 159:17 

10:3;14:23;21:22; promote (2) purifier (1) 99:7;118:10;120:5; reading (3)

 22:6;47:17;48:2,17; 108:1;121:25 37:6 129:21;134:23; 20:8;84:6;139:3 

49:8,10,15;51:18; promoted (1) purpose (2) 147:13 readings (1)

 55:25;58:2;69:16; 99:7 13:10;109:16 quote (10) 74:4 

73:12;74:1;77:1; promulgation (1) pursue (2) 7:11,12,14,17; ready (4) 

Min-U-Script® Burke Court Reporting & Transcription (20) problems - ready 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 5 

October 26, 2023 

108:6;114:25; 108:7 regionally (1) 7:16;44:9;73:8,19; 10,15,22,24;95:10,25;

 129:8;161:25 recognition (1) 80:22 77:11;84:7 96:11,14,17;97:1,15,

real (10) 58:25 Register (2) remove (22) 15,20,22,25;98:3,13,

 50:20;84:5;95:17; recognized (1) 155:8,9 7:10;10:9;15:21; 16,17;100:6,19;

 98:2;102:5;104:10; 76:13 regular (2) 22:12;23:20;24:24; 102:4;103:8,14,18;

 112:13;131:9;148:18; recommend (2) 37:14;145:24 26:5;27:10;29:6;31:5; 104:7,9,11;105:7,10,

 151:23 95:10;138:9 regularly (1) 39:10;41:25;46:6; 23;107:6,16,18;

realize (4) recommendation (6) 96:13 53:24;56:14;60:13; 108:1;109:5,6,8,9,17;

 81:5;97:2;156:21, 20:1;101:13; regulates (1) 63:2;70:12;74:20; 110:11,13,15,15;

 22 138:19;139:9;154:24; 39:1 82:5;91:7;152:22 111:24;113:7;114:20;

realized (4) 159:1 regulation (1) removed (1) 115:8,21;116:9,23;

 72:6;120:9;139:3,3 recommendations (2) 139:4 7:13 117:12;118:1,22;

really (102) 101:7;140:23 regulations (2) removes (1) 119:1,7;120:2,19;

 0:17,18,19;9:14,19; recommending (2) 21:23;139:6 37:15 121:8,10,11;123:14,

 17:22;20:7;34:2; 139:11,22 reinforced (1) renew (1) 17 

47:20;49:1;53:1;55:4; recommends (1) 102:6 151:19 researchers (11)

 65:12,15,23,25;66:13, 138:6 reiterate (2) renewal (2) 95:1;99:4,11;102:5;

 20;69:13;84:18;85:9, reconciliation (1) 85:17;141:18 143:9;149:12 105:10;106:2;108:25;

 12,17;90:8,16;91:6; 70:9 rejected (1) renewed (1) 111:19;112:13;

 93:19;94:22;95:11, record (3) 7:20 137:21 117:19;119:11 

23;96:15,16,19; 44:7;93:3;152:24 related (4) reorganized (1) reserve (1)

 99:19;100:24,24; recordkeeping (1) 21:19;38:9;136:23; 20:2 114:17 

101:18;104:15,19; 139:24 140:10 repeat (1) residing (1)

 105:13,24;109:23,24; recusals (20) relationships (1) 62:19 72:23 

110:14,14,15,20; 11:22;17:8;23:17; 122:14 repeatedly (1) residual (1)

 113:24;115:5,16; 24:23;26:4;27:9; relative (1) 56:10 138:21 

118:11,12,15,18; 28:15;30:10;32:10; 98:8 repetitioned (1) resignation (1)

 119:4,9;120:3; 40:15;43:5;47:10; relatively (1) 52:10 123:12 

121:19,21,21;122:1,6; 55:12;57:19;61:18; 59:15 replaced (1) resistant (2)

 126:16,23;127:24; 64:7;71:17;75:25; release (3) 18:11 120:25;121:3 

128:4,16,22;129:6,17, 92:25;125:6 47:15;49:22;76:11 replacing (1) resolve (1)

 18;130:11,21,24; recycled (1) released (1) 138:9 137:24 

131:10,12;132:16,19, 137:21 116:4 replicate (1) resolved (1)

 21;135:3,10;141:2,3, redone (1) relevant (2) 48:5 52:6 

3;149:13;150:7; 144:16 140:2;148:18 report (6) resounding (1)

 151:7,7,9;152:14; reduce (2) relisted (1) 76:21;108:12,12, 68:21 

153:23;154:1;156:12, 62:9;148:12 28:25 13,17;114:17 resource (2)

 25;157:3,11;160:8, reduces (1) relisting (18) reported (1) 21:24;22:4 

20;161:6,7,7,23 7:3 9:24;15:6;18:20; 18:18 resources (4)

reason (4) reducing (1) 20:19;30:25;33:8,20; reporting (1) 115:18,22,23;117:2 

74:6,8;79:3;82:9 139:16 38:17;41:12,18; 108:9 respect (1)

reasonable (1) reduction (1) 44:12;62:6;67:19; represent (1) 100:24 

48:16 137:11 73:16;77:4;149:25; 104:8 respirator (2)

recall (2) Reece (1) 155:7,9 representatives (2) 66:1,22 

84:21,25 99:20 rely (3) 113:18,19 respond (1)

receive (3) re-emphasize (1) 67:20;68:15;142:19 request (7) 101:15 

6:5;8:10;41:18 153:5 remain (3) 60:2;62:7;103:7; responding (1)

received (12) refer (1) 10:5;137:9;142:16 141:13,20;146:18; 52:15 

7:15,24;18:9,15; 9:17 remained (1) 157:10 response (3)

 38:7,16;41:17;58:4; reference (1) 73:6 requests (3) 33:11;41:19;111:17 

76:21;96:1;136:14; 81:4 remains (1) 117:11;144:18; responses (1)

 138:2 referenced (1) 139:21 157:14 112:3 

receiving (1) 138:5 remember (11) require (4) responsibility (1)

 103:24 referred (1) 10:12;15:12;22:16; 84:12;88:11,19; 104:13 

recently (5) 13:9 59:11,12,17,22;121:4; 155:13 resting (1)

 112:21;119:5; reflective (1) 128:21;142:20; required (1) 130:7 

120:10;136:13; 126:16 159:24 88:14 result (2)

 153:14 reflects (1) remind (2) requirements (1) 76:25;108:10 

receptive (1) 138:17 95:22;101:7 67:14 results (2)

 68:24 regarding (2) Reminder (6) requires (2) 102:18;141:4 

recess (1) 38:20;59:16 30:14;62:24;93:22; 7:2;84:12 retailer (1)

 125:10 region (5) 119:6;135:13;147:15 research (67) 65:14 

recipient (1) 78:16,20,22;79:1,1 removal (6) 14:23;93:11;94:6,8, retired (1) 

Min-U-Script® Burke Court Reporting & Transcription (21) real - retired 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 5 

October 26, 2023 

103:2 

retreating (1)

 150:25 

return (1)

 104:13 

revealed (2)

 8:7;18:9 

revenue (1)

 117:9 

review (25)

 6:6;7:9;8:6;18:23;

 19:4,20;33:6;37:17;

 41:8,19;49:14;51:14;

 58:16,17;59:13;60:2;

 62:1;68:1;73:5;76:16;

 78:11;93:16;108:21;

 111:22,22 

reviewable (1)

 8:1 

reviewed (3)

 19:1;113:14,14 

reviewing (1)

 59:1 

reviews (1)

 98:22 

revise (2)

 145:12,20 

revisit (1)

 137:4 

RFE (2)

 107:17,20 

rhythm (1)

 71:20 

rice (2)

 49:20;97:23 

right (77)

 0:7,8,25;9:6;10:7,

 20;12:5,6;22:10;31:3;

 34:25;35:9;39:13;

 41:23;43:11;46:5;

 50:4,15;53:23;56:13;

 59:25;60:11,16;

 62:23;63:5;72:12;

 73:22;74:10;76:1;

 81:12,23,24;82:7,18;

 83:4,6;87:3;90:25;

 91:3;92:6;93:1;108:6;

 114:17;117:22;

 118:15,17;122:3,13;

 123:13,21;124:24;

 128:25;131:18;

 132:23;133:4,15;

 134:4,21,25;135:6,15;

 136:11;141:9;145:3;

 147:14;148:12,19;

 45:3 

ripener (1)

 45:15 

ripening (4)

 43:8;45:1,3;46:3 

risk (2)

 109:7,18 

riveting (1)

 9:15 

robust (1)

 99:5 

Rodale (1)

 79:4 

role (4)

 106:8;110:10;

 111:1;160:19 

Roman (1)

 64:16 

room (10)

 0:6;45:3;52:17;

 78:9;79:2;105:9;

 113:16;130:11;131:8;

 148:11 

rotate (1)

 113:23 

rotation (1)

 119:15 

round (2)

 96:2;142:8 

route (1)

 157:13 

rule (9)

 7:14;38:4;136:19,

 22;137:3;138:1,16;

 152:9;154:8 

rulemaking (15)

 136:14;138:3,6;

 151:20,21;152:20;

 153:2;154:23;155:10,

 13,15;156:1,2,3,8 

rules (6)

 45:19;67:2,3;89:9;

 156:3,4 

run (6)

 21:2,4;86:11;87:24;

 89:2;98:19 

running (3)

 88:5;131:18;133:10 

runs (1)

 86:5 

Russia (2)

 78:2;117:15 

66:21;67:22;68:18;

 69:11;100:20 

safety (3)

 84:22;85:1;129:11 

Safeway (1)

 20:13 

sake (1)

 43:16 

salt (2)

 32:17;62:9 

salty (1)

 30:23 

same (23)

 6:18,19;15:14;

 17:23;18:18;19:14;

 43:12,17;67:12;70:3,

 9;73:14;76:25;87:20;

 89:23;93:4;102:11;

 106:17;120:1;137:18;

 152:16;154:24;

 161:21 

sand (1)

 32:22 

sanitation (1)

 153:20 

sanitizer (2)

 58:24;145:20 

sanitizers (6)

 58:13,15,16;59:1;

 96:22,25 

sat (2)

 113:15,17 

satisfied (1)

 151:1 

satisfying (1)

 158:3 

sauce (1)

 128:12 

sauces (1)

 9:21 

saw (8)

 9:18;34:15;38:5,13;

 98:7;119:7;137:20;

 153:18 

saying (25)

 81:6,16;82:9;89:2;

 95:3;106:7,18;113:4;

 114:13,21;117:2,4,24;

 119:13;127:3,11;

 130:4;148:16;149:18;

 152:4,16;154:12,20,

 23;159:16 

scenarios (1)

 140:21 

schedule (1)

scope (1)

 61:24 

screening (1)

 14:19 

scroll (1)

 135:19 

search (3)

 48:3,6;101:6 

season (3)

 44:1;73:9;135:23 

seats (1)

 0:7 

Seaweed (7)

 33:2,5;36:9,14,15,

 18;38:22 

second (8)

 39:14;57:20;67:20;

 112:7;125:2;128:24;

 144:6;149:11 

seconded (20)

 10:10;15:22;22:13;

 23:21;25:1;26:6;

 27:11;29:7;31:6;

 39:11;42:2;46:7;54:1;

 56:16;60:15;63:4;

 70:14;74:23;91:8;

 123:19 

secret (1)

 128:12 

SECRETARY (81)

 11:15,21;16:17;

 17:7;18:22;19:17;

 20:21;23:6,16;24:10,

 22;25:14;26:3,17;

 27:8,21;28:14;29:14;

 30:9;31:12;32:9;34:1,

 12;35:4,11,18;39:15;

 40:14;43:2,4;47:5,9;

 49:13;50:1;54:22;

 55:11;57:10,18;60:1;

 61:7,17;63:19;64:6;

 71:2,16;73:23;75:8,

 24;77:21;78:21,24;

 90:8,24;91:2,18;92:3,

 8,24;103:11;105:3;

 108:4,22;124:2;

 125:2,5;131:4,18,20,

 22,24;132:1,4,22;

 133:4,11,21;134:13;

 135:3;157:6;160:25;

 161:1 

section (1)

 147:2 

sector (8)

 34:13;65:22;

seeing (4)

 108:25;127:6;

 140:2;161:22 

seek (2)

 116:9;152:10 

seeking (1)

 66:12 

seem (2)

 35:7;84:21 

seemed (3)

 142:20;154:21;

 157:25 

seemingly (1)

 58:10 

seems (13)

 10:4;48:8;49:3;

 51:23;67:24;68:13;

 90:2;97:19;103:16;

 127:2;144:12;148:6;

 149:11 

sees (3)

 65:21;89:17;131:5 

self-perpetuating (1)

 115:16 

sell (1)

 110:2 

sellers (1)

 78:18 

semester (3)

 0:16,23;126:12 

send (5)

 94:12;102:24,24;

 127:3,9 

sending (2)

 102:8;150:2 

sense (6)

 19:2,13;72:16;

 116:24;148:16;

 149:13 

sensitive (1)

 67:15 

sent (1)

 119:5 

separate (5)

 18:16;86:11,13;

 87:21;142:6 

separated (3)

 87:1,15,22 

separately (2)

 6:21;22:12 

sequence (2)

 19:5,21 

serious (1)

 141:4 

seriously (2)

S 

149:10;151:5,10; Sacramento (1) 93:5 107:14,25;109:6,7; 80:11;98:11 

152:6,8,18;155:4; 99:21 science (1) 110:10;113:20 servant (1)

 158:19;160:8;162:2 sacred (2) 105:19 seed (6) 130:20 

rinse (1) 129:14;130:12 scientific (1) 17:17;26:6;83:25; serve (5)

 145:20 safe (4) 116:21 84:8;86:24;87:5 17:24;127:24;

ripe (1) 76:14;139:21; scientist (3) seeds (6) 130:18,20;131:13 

45:1 155:12,12 115:6;116:14; 81:20,20;120:14, served (2)

ripened (1) safer (5) 122:13 16;121:14;122:11 111:22,23 

Min-U-Script® Burke Court Reporting & Transcription (22) retreating - served 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 5 

October 26, 2023 

service (1) show (5) Slow (2) 140:17 sounding (1)

 99:1 50:13,14;78:16; 91:25;151:16 soliciting (1) 106:22 

serving (3) 101:18;137:18 slowing (1) 113:9 sounds (7)

 67:17;121:8;131:12 showcase (1) 150:22 solution (9) 50:21;51:4;67:10,

session (3) 111:6 slowly (1) 21:12;66:18;68:17; 22;101:1;108:22;

 73:10,14;77:3 showed (1) 135:18 69:8;100:8;101:19; 112:16 

set (5) 65:7 sludge (1) 104:22;117:8;150:18 source (9)

 19:10;109:19; shows (2) 90:1 solutions (1) 36:23;66:5;72:21,

 128:7,20;140:24 50:6;107:18 small (5) 100:9 22;82:21;83:7;90:10,

seven (4) side (8) 20:25;51:22;53:7; solve (3) 10;115:15 

17:23;30:17;92:24; 79:5;80:18;87:13; 55:4;93:24 78:9;104:24;119:18 sources (13)

 132:14 117:1;118:21;119:7, smart (1) solvent (1) 12:2,15,19;13:18,

several (15) 7;154:3 104:24 13:17 24;36:14;38:24;39:6;

 7:2;13:16;21:11; sides (1) smell (1) solvents (1) 55:23;80:16;84:2;

 55:23;64:25;65:2,13, 92:16 110:12 12:3 141:22,23 

14;66:15,23;73:10; sign (3) SMITH (98) somebody (1) sourcing (5)

 96:23;112:20;117:19; 114:14,16,19 0:9,11;8:22;9:7; 107:19 14:3;15:9,14;21:1;

 121:24 signal (1) 10:9;11:13,23;15:21, somehow (2) 44:4 

shade (1) 102:8 23;16:15;17:9;19:13, 82:20;97:19 South (1)

 128:13 signals (1) 25;22:11;23:4,19; someone (5) 78:5 

share (7) 94:12 24:8,24;25:12;26:5, 48:9;52:19;53:6; soy (6)

 43:17;51:24;72:1, significant (3) 15;27:10,19;28:17; 67:21;68:23 49:21;77:15;80:14;

 15;99:11;104:11; 10:4;62:5;98:17 29:6,12;30:11;31:5, someone's (1) 83:12,14;87:24 

120:10 silicon (2) 10;32:11;34:22; 151:19 soybean (5)

shared (1) 8:17,21 37:23;38:3;39:5,10; sometime (1) 81:16,16;82:14,19;

 161:6 silo (1) 40:12,16;41:25; 126:13 83:8 

shelf (2) 83:24 42:25;43:6;46:6;47:3, Sometimes (5) soybeans (9)

 45:4;123:3 similar (6) 11;53:24;54:20; 10:1;15:15;19:19; 80:15;81:5;82:20;

shelf-life (1) 19:4,5;31:1;105:16; 55:13;56:14;57:8,20; 20:10;21:2 83:24;88:4,6;90:2,6;

 30:24 118:25;130:5 59:10,21;60:5,13; somewhat (3) 117:24 

shifting (1) similarly (1) 61:5,19;63:2,17;64:8; 45:9;103:22;157:23 soy-extracted (1)

 51:9 60:4 69:25;70:12,25; somewhere (7) 87:4 

Shiloh (1) simple (3) 71:18,21;72:9;74:20; 36:19;104:17,17; space (7)

 52:4 74:6;79:22;82:1 75:6;76:3;91:5,16; 121:13;144:21; 34:3,12,13,18;

ship (1) simpler (1) 123:25;134:23;135:2; 145:18;147:10 117:20;121:24;

 66:6 139:11 141:12;143:10,12,14, soon (1) 156:13 

shipment (1) simplify (1) 21,25;144:2,24; 160:25 spans (1)

 43:24 67:3 145:13;146:7,13,16; sooner (1) 58:1 

shipments (1) simplistic (1) 147:3,18;148:20; 147:6 speak (4)

 43:25 80:9 150:5;151:2,15; sorry (23) 85:12;102:1;

shipped (1) simply (3) 152:6;154:7;155:20; 9:11;16:24;23:16; 103:11;130:23 

44:25 88:6,16;89:16 159:18,22;160:12,15, 28:24;44:9;51:24; speaking (1)

shipping (2) single (3) 18 52:3;67:11;73:22; 80:4 

44:1,25 108:19,24;128:17 smokes (1) 83:20;92:9;101:3; speaks (1)

shocked (1) sink (1) 135:23 105:3;120:8;122:22; 62:16 

130:19 138:24 snacks (1) 125:1,3;139:9;144:6; special (2)

shocker (1) sits (1) 13:5 149:20;154:11;157:6; 18:1;119:23 

126:20 114:9 snoozefest (1) 160:15 specialist (1)

shoes (1) sitting (2) 91:6 sort (41) 98:21 

160:20 77:24;156:7 SO2 (7) 20:7;45:7;49:23; species (3)

shook (1) situation (3) 66:3,5,16;67:4,19; 52:8;70:9;77:17; 32:23,25,25 

150:24 82:17;156:6;157:22 68:13;69:21 82:23;85:18,22;94:8; specific (10)

shorten (1) six (3) soak (1) 95:17;96:14;97:2,3,4; 13:10;22:6;48:1;

 95:14 73:16;116:7;128:7 92:1 101:12;102:3,3,8; 56:8;58:13;59:3;

shortening (1) skip (1) sodium (9) 107:24;110:25;111:1, 98:23;110:4;138:22;

 104:2 132:14 33:14,19;38:7,15, 4,9,12;115:16;127:5; 157:11 

shorter (2) slide (4) 18;39:1;62:8;143:15; 139:24;140:22; specifically (11)

 94:21;96:7 100:15,15;135:16; 153:3 141:16,25;142:9; 6:23,24;21:18;38:6;

Shout (1) 140:6 soft (2) 148:23;149:1,10; 41:14;83:24;97:23;

 28:20 slides (2) 122:2;123:12 150:14;151:10,21; 137:17;138:11;

shoutout (5) 136:3;140:7 soil (2) 158:9,10;160:1 142:15;161:5 

127:1,22;130:17; slightly (1) 36:16;137:15 sound (1) specifications (1)

 160:13,23 107:2 solicit (1) 151:9 138:9 

Min-U-Script® Burke Court Reporting & Transcription (23) service - specifications 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 5 

October 26, 2023 

specificity (1) stakeholder's (1) 19:18;21:7;37:13; 151:9 substitute (1)

 96:17 18:24 41:2;82:22;84:7,17; streams (1) 149:13 

specified (2) stance (2) 90:5;115:24;127:9; 115:21 success (1)

 7:7;55:16 15:5;100:24 157:22;160:19 strict (1) 127:20 

speed (1) stances (1) stepping (1) 67:13 successes (1)

 28:15 20:3 106:23 stride (1) 111:13 

spend (2) stand (1) steps (5) 156:24 successful (2)

 48:15;97:12 106:24 6:25;37:18;40:22; strip (2) 14:21;121:2 

spent (1) standard (4) 59:17;140:14 79:25;81:23 suffice (1)

 109:11 100:22;136:20; sterilant (1) strong (10) 50:15 

sphere (1) 137:16;138:20 66:10 30:17;31:2;37:8; sufficiency (1)

 36:5 standards (3) Steve (4) 45:23;66:20;69:10; 145:3 

spice (1) 44:16;134:20;140:3 126:12,21;127:1; 108:4;121:5;122:6; sufficient (4)

 12:5 standing (1) 128:20 161:7 8:11;76:18,19,20 

spike (1) 141:14 stewards (1) strongly (2) sugar (1)

 74:7 standpoint (3) 104:16 67:24;77:5 74:7 

spikes (1) 74:2;89:8;111:24 stick (1) struck (2) suggest (5)

 0:18 start (40) 8:3 20:22;150:23 48:22;67:18;73:2;

split (1) 9:8;10:16;22:14; sticking (1) struggle (3) 96:5;112:18 

155:11 23:22;25:3;26:8; 0:14 14:9;115:14;116:17 suggested (2)

spoilage (2) 27:13;31:8;42:3;45:2; sticks (1) stuck (2) 41:13;146:5 

28:25;64:16 46:8;54:2;56:17; 7:1 115:17;160:10 suggesting (1)

spoke (1) 60:16;63:6;70:15; still (25) students (1) 82:23 

9:19 85:18;90:5,12;91:10; 0:6,14;9:14;32:15; 107:8 Suggestion (7)

spontaneously (1) 104:25;107:13,14; 35:9;45:23;46:1; stuff (3) 67:2;85:17;88:3;

 68:23 123:23;127:5;131:17, 47:17,20,25;61:23; 117:13;138:18; 90:21;101:8;102:17;

spot (2) 20,22,23;132:1; 79:1;82:17;89:14; 151:20 145:6 

15:14,15 135:14,17;146:17,19; 96:25;97:16;99:7; style (2) suggestions (6)

sprays (1) 147:12;149:10; 114:17,18;120:15; 66:13;108:25 18:15;66:25;96:10;

 76:11 151:10;158:13;159:2; 121:22;122:20;126:8; sub (1) 98:12;146:15;147:19 

spread (1) 161:22 140:22;157:16 76:23 suitable (5)

 17:3 started (5) stimulating (1) Subcommittee (21) 76:17,20;77:6;

spring (21) 0:4;142:11;157:25; 110:10 0:12,15;8:10;15:13; 84:19;118:14 

9:16,17;33:7;36:9; 158:15;159:19 stir (1) 21:17;33:12,21; sulfate (2)

 41:19;45:21;47:23; starting (6) 109:21 38:21;39:2;58:17; 67:9;97:20 

55:24;62:4;65:5; 29:9;52:18;72:7; stock (2) 59:13;73:8,17;77:9; sulfite (2)

 69:23;73:7,13; 74:24;128:16;148:23 137:22;138:7 93:9,23;94:1;140:10; 64:11;67:13 

141:18,23;145:3,18; state (5) stocks (3) 158:25;160:2,2 sulfites (2)

 146:23;147:4,13; 8:2,2;13:20;44:11; 136:20;137:22; subcommittees (4) 67:1,17 

148:7 142:23 138:12 19:19;98:5;141:15; sulfur (13)

sprout (1) stated (8) stolen (1) 158:22 64:8,9,15,18,19;

 44:17 6:25;7:14,25;8:5; 125:8 subcommittee's (1) 65:10,19,21,22,24;

sprouting (2) 41:15;43:23;58:21; stop (2) 59:18 68:14;69:5;70:12 

44:14,14 80:4 19:12;107:13 submit (3) summaries (1)

stability (1) statement (6) stops (1) 111:19;141:13; 103:15 

138:8 36:11,21;43:20; 7:2 147:12 summarize (1)

stabilizer (1) 48:20;68:10;144:13 storage (1) submitted (3) 15:3 

32:18 states (2) 44:15 41:9;111:25;112:2 summary (3)

stabilizing (2) 9:3;64:24 store (2) submitting (1) 138:3,6;140:13 

17:25;33:11 stating (2) 20:12,13 150:6 sunflower (6)

stable (1) 7:11;13:25 stores (1) subpar (1) 77:25;78:3;80:15,

 122:20 station (1) 34:10 80:2 16;83:12,14 

stake (1) 107:25 story (2) subsequent (2) sunflower-extracted (1)

 112:11 status (3) 64:13;111:1 74:4;149:23 87:5 

stakeholder (9) 73:11,15;81:11 storytelling (2) subset (1) sunflowers (5)

 60:2;73:9,11;76:16; stay (1) 111:5,12 51:22 77:23,24;78:1,3,4 

103:21;112:9,16; 110:4 straight (1) substance (9) sunset (28)

 120:9;136:13 staying (1) 90:15 7:21;19:2,3;28:22; 7:9;33:6;35:22;

stakeholders (10) 130:7 straightforward (2) 30:22;58:24;72:13, 41:8;67:5;73:5;76:16;

 33:16;38:16,17; stearate (6) 79:10,16 19;76:7 84:25;90:23;142:4,5;

 73:16;106:8,11; 55:14,14,15;56:3, straight-forward (1) substances (6) 143:17,20;144:15;

 112:10;120:16; 13,15 32:15 13:9,12;20:7;41:4; 145:4,18;146:6;

 146:12,24 step (12) strange (1) 56:8;149:12 147:23,24;148:10; 

Min-U-Script® Burke Court Reporting & Transcription (24) specificity - sunset 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 5 

October 26, 2023 

150:13,16;151:19;

 152:8;156:17,19;

 159:12,14 

sunsets (11)

 0:23;9:7;19:18;

 142:10;144:18;

 145:10,11;147:10;

 150:12;159:2,19 

super (7)

 6:12;84:14,15,15;

 85:4;89:19;142:21 

superior (3)

 19:22;82:10;83:1 

supplements (2)

 40:21;55:21 

suppliers (1)

 41:10 

supply (16)

 14:7;18:14;44:10;

 51:8;65:13;76:18,19,

 20,20;80:17,17,18;

 116:25;117:17;118:6;

 18:2 

switch (1)

 20:23 

switched (1)

 65:3 

switching (1)

 20:23 

synthetic (6)

 12:3;20:24;41:5;

 51:6;138:12;158:20 

synthetically (1)

 12:16 

synthetics (1)

 72:11 

system (3)

 99:5;109:13;150:12 

systems (4)

 12:3;13:13;76:12;

 137:8 

tasked (1)

 93:24 

taste (2)

 13:14;30:24 

tasteless (1)

 28:23 

taught (1)

 130:15 

teaching (1)

 139:4 

team (6)

 0:15;14:23;127:15;

 131:2;135:4;161:17 

technical (4)

 76:21;98:21;111:9;

 134:14 

technically (1)

 148:15 

technique (1)

 121:7 

techniques (1)

 41:6 

32:14;40:18;49:7,

 14;74:19;77:13;

 90:17;93:10,20;98:9;

 99:13,14;103:14;

 111:16;114:5;120:6;

 123:7;126:10;136:6;

 139:2;141:4;144:24;

 154:10;160:13 

theme (2)

 65:8;69:21 

themes (1)

 65:9 

theoretical (1)

 118:13 

therefore (1)

 39:2 

thickener (1)

 32:19 

thickening (2)

 17:25;18:3 

thinking (17)

 85:18;94:6,15;97:5;

 129:10;135:14 

throw (3)

 121:12;128:13;

 152:13 

till (1)

 90:5 

times (7)

 64:16;114:15;

 137:10,12;139:6,15;

 156:16 

time's (1)

 43:16 

timing (1)

 150:11 

tip (1)

 138:25 

today (11)

 0:22;6:5;21:24;

 28:21;45:4;69:17;

 97:12;100:22;126:4;

 127:21;151:3 

toes (1)

T 

143:2 table (5) technology (7) 99:21;107:4;116:15, 106:23 

supplying (2) 65:2;69:22;152:24, 48:25;49:24;84:14, 25;118:18;120:4; together (10)

 77:19,19 25;161:20 17;85:5;100:21;137:2 128:6;131:24;141:10; 6:20;17:11;48:12;

support (21) tablemate (2) tee (1) 147:16,21;149:10; 68:19;74:5;78:9;

 9:24;10:4;15:6,7; 134:14;160:25 96:2 150:10 106:24;114:11;

 18:19;20:19;30:17, tablet (2) telling (2) third (3) 119:14;129:13 

21;31:2;33:8;56:4; 69:7,11 105:23;111:1 77:25;152:22;155:1 told (3)

 62:5,11;67:19;73:16; tail (1) temperature (1) thorough (2) 83:21;104:1;109:3 

106:12;107:14; 157:21 41:2 68:1;86:10 tolerant (1)

 110:16;140:17,18; tale (1) temperatures (5) though (12) 120:24 

158:10 153:7 41:3;137:9,10,13; 38:5,25;58:22;62:1; tomato (1)

supported (4) talk (19) 139:15 81:25;87:10;114:18; 45:15 

30:18,25;41:12; 0:22;6:2,3,14,17; template (4) 121:22;122:15;147:8; tomatoes (2)

 93:19 17:11;19:11;20:3; 21:18;93:15;144:9, 148:20;157:7 46:1,2 

supporting (3) 60:8;69:13;71:19; 14 thought (19) ton (3)

 109:24;123:9;157:2 78:24;95:8;105:13; tempo (1) 9:12;18:23;19:17; 117:16;154:10;

supports (2) 108:19;120:9;126:5, 158:3 49:15;55:5;96:18,22; 156:6 

29:2;30:23 17;129:22 tent (1) 104:3;109:9,14; tone (1)

suppose (2) talked (13) 130:24 111:8;113:2,3; 128:20 

69:25;146:22 30:18;80:14;94:13; term (4) 120:10;127:6;129:4; tons (1)

sure (26) 97:7,11;100:11,17; 58:11,22;98:8; 142:8;145:6;149:1 143:3 

0:19;20:1,2;21:15; 105:8;118:11;129:20; 138:10 thoughtful (2) took (4)

 37:1;38:12;45:19; 141:16;156:4;159:23 terms (7) 150:1;161:23 17:10;43:9;53:8;

 52:16;53:9;60:6; talking (15) 69:3;72:14;95:2; thoughts (9) 73:15 

87:11;95:19;99:3,10; 19:12;67:13;78:17, 99:3;102:8;130:20; 53:22;94:9;98:15; tool (1)

 100:17;106:4;111:23; 18,20;80:13,21; 139:23 99:16;110:23;126:22; 121:7 

112:25;123:16;134:3; 83:13;88:3;97:13; terrible (1) 144:23;156:23;160:7 toolbox (1)

 137:10;139:21; 129:22;149:17,20; 67:10 thread (1) 117:23 

147:13;156:5;157:2; 156:5;157:25 test (1) 89:9 top (6)

 158:8 tallied (1) 114:15 threat (1) 19:16;101:21;

surfaces (2) 134:8 testing (1) 140:1 112:6;120:19,20,21 

57:23,25 tally (1) 138:22 three (13) topic (8)

surfactant (1) 133:9 Texas (1) 7:24;18:16;51:3; 19:9;100:16;

 76:12 tamarind (2) 78:6 56:3;77:4,6;92:7; 107:16,18;130:8;

surprised (2) 17:17;26:5 texture (1) 101:21;107:7;113:6; 136:7;138:13,24 

72:5;139:14 target (1) 30:24 135:1,8;139:5 topics (4)

suspension (2) 113:7 thankful (1) three-pack (1) 98:17;102:9;

 153:12,13 targeted (1) 95:12 88:12 110:16;111:9 

Sustainability (2) 98:22 thankless (1) thrilled (1) TOPP (5)

 109:22,24 task (2) 135:11 161:23 78:16,19;79:1,7,7 

swap (1) 112:13,13 Thanks (24) throughout (2) total (3) 

Min-U-Script® Burke Court Reporting & Transcription (25) sunsets - total 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 5 

October 26, 2023 

64:11;73:10,14 

totally (1)

 110:18 

touch (1)

 109:3 

touches (2)

 136:21;138:16 

touching (1)

 141:10 

tough (1)

 129:9 

toward (2)

 51:7,9 

towards (7)

 13:21;88:20;89:12;

 90:3;93:14;122:2;

 157:22 

TR (27)

 6:6,8,12;7:25;8:9,

 10,12,24;9:2;12:14;

 21:18;22:1;37:11,11;

 41:5;43:18;48:25;

 49:24;51:1;59:14;

 61:25;62:3;67:22;

 84:6,12;93:15;145:2 

track (2)

 101:17;129:21 

tracking (2)

 126:16;127:23 

truly (2)

 128:9;161:20 

try (17)

 6:10;19:4;51:15;

 70:9;90:12;94:10;

 105:13;108:19;

 109:21;113:12;118:4;

 128:9;130:13;135:18;

 145:5;151:16;156:25 

trying (30)

 10:12;17:3;20:17,

 23;22:3,16;34:17;

 48:17;49:19;53:6;

 64:22;80:13;85:9,24;

 94:18;97:9;101:5;

 110:22;116:20;

 121:25;129:15;

 137:16;142:17;143:3;

 144:4,25;145:9;

 147:5;151:17;154:19 

TUCKER (11)

 78:15,22,25;

 152:14;154:20;155:6,

 18,21;156:10;157:1;

 161:16 

turn (9)

 52:18;55:8;71:24;

 154:5;160:24 

two-years (1)

 147:10 

type (7)

 69:21;86:15;107:3,

 5;108:17;110:5;

 111:10 

types (2)

 58:1;140:20 

typically (1)

 66:7 

typo (3)

 37:24,25;38:14 

14:6 

un-un (1)

 129:8 

unusual (1)

 68:19 

up (56)

 0:18;12:5;36:17;

 49:20;50:6,13,14;

 52:23;55:13;56:9;

 58:15;61:19;62:16;

 64:8;65:7;67:6;70:4,

 6,6;78:3;82:2,23;

 83:22;87:12;92:22;

 94:23;96:2;97:9;

 104:5;105:7;107:16,

 18;109:21;116:15;

 119:16;126:11,21;

 127:9;128:7;129:12;

 135:6;137:18;138:7;

 141:25;144:25;146:3,

 7;147:1,4;148:18,24;

 149:3,9;150:9;153:1,

 23 

update (4)

 108:12;126:6;

 135:15;136:2 

updated (2)

 48:25;93:14 

51:15;55:20,25;

 57:24;58:12;62:8,9;

 64:15;65:9,21;69:10,

 17;72:21;76:11;

 81:22;96:14;153:9,19 

useful (1)

 128:2 

users (1)

 139:12 

uses (13)

 9:19,22;10:1;18:12;

 41:13;43:13;48:1,2;

 58:3,3;61:24;65:18;

 76:9 

using (12)

 12:3,10;22:1;35:8;

 65:3;66:1;82:15,17;

 88:8;93:14;137:25;

 141:22 

usually (2)

 32:21;100:8 

utility (1)

 53:10 

utilize (1)

 22:5 

U 

ubiquitous (1)

 66:9 

ugh (1)

 71:19 

Uh-oh (1)

 64:17 

Ukraine (4)

 77:7;78:1;117:14,

 15 

ultimately (2)

 69:6;90:3 

unanimous (1)

V 

93:18;146:9 99:17;105:17;130:5, 134:19 updates (3) vague (1)

trade (4) 6;137:8;141:7 unanimously (2) 94:1;96:12;136:11 45:9 

41:9;51:21;65:14; TURNER (37) 28:25;30:25 updating (1) validate (1)

 79:4 16:23;23:12;24:16; unavoidable (1) 21:18 69:23 

tragacanth (2) 25:20;26:23;28:2,20; 138:21 UREC (1) value (3)

 17:18;27:10 29:20;30:14;31:18; under (7) 138:21 69:9;101:16;122:23 

train (1) 39:21;42:9;46:12; 59:8;114:4;140:19, usage (1) values (1)

 131:11 49:7;54:4;57:16; 21;152:24,25;153:23 98:2 130:13 

trajectory (1) 61:13;63:25;68:6; underdeveloped (1) USDA (1) varied (1)

 123:12 71:8;75:12;77:13; 14:6 105:10 100:24 

transfer (1) 91:24;93:10;95:19; under-resourced (2) USDA's (1) varieties (1)

 116:24 99:14;101:24;102:20; 115:12,17 48:3 122:7 

transition (1) 106:6;110:8;123:7, underscore (1) use (53) variety (1)

 83:12 16,19;124:8;148:15; 115:7 6:18,23;7:6;8:3,4,5, 9:21 

transparent (1) 149:16;155:24 understated (1) 19,20;9:23;12:25; various (2)

 67:14 turning (3) 44:22 13:3;15:1;21:19; 64:21;140:21 

travels (1) 139:6;149:7,14 understood (3) 30:19,20;32:19; vast (1)

 87:21 Tuskegee (1) 35:5;64:25;127:14 33:15;37:14;41:11, 9:19 

treatment (2) 110:25 unfortunately (1) 16;43:19;44:14;45:8, vein (1)

 37:13;44:9 tweaks (1) 136:5 15;47:13;48:8;55:15, 158:5 

treats (1) 35:23 unique (4) 20;56:3,8,11,11;58:1, vendors (1)

 129:6 twice (1) 33:11;108:24; 22;62:10;64:9;66:3, 14:19 

tried (4) 12:13 114:22;159:6 12,21;68:18;72:18; Venn (1)

 48:5;97:21,21;98:1 two (39) universities (6) 73:2;88:15;108:10; 119:8 

triggered (1) 0:24;8:2,2;13:25; 102:13,14;107:6, 118:2;119:5;130:21; venture (1)

 94:8 48:14;52:23;58:7; 14;115:10,17 136:7;140:21;153:11, 46:1 

trio (1) 67:18;68:12;73:13, unlabeled (1) 20;154:13;157:3 verify (1)

 161:18 14,15;77:6,21;78:8; 67:9 used (47) 142:25 

tropical (5) 82:11;87:1;92:24,25; unless (1) 6:18,19,22;8:18; versatile (1)

 43:8;44:5;45:8,11, 99:22;100:21;101:17; 43:17 10:3;11:25;13:4;18:3, 33:10 

22 106:3;119:8;120:21; Unlike (1) 5,10;20:8;21:20;22:3; version (4)

TRs (3) 126:6;127:25;130:20, 61:22 28:22;32:15;33:17, 60:3;79:20;87:25;

 21:20,24;22:4 25;132:13;141:22; unpetitioned (1) 22;36:4,9,10,13,19; 98:12 

true (4) 142:3;144:22;145:23; 69:14 38:22,22;40:19,20; versus (2)

 45:16;122:9; 147:17;148:5;152:21; unstable (1) 41:15;47:15,24; 6:12;145:21 

Min-U-Script® Burke Court Reporting & Transcription (26) totally - versus 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 5 

October 26, 2023 

via (1)

 13:16 

viable (1)

 83:3 

vice (12)

 128:22;131:4;

 132:2;133:16,16;

 134:6,9;135:2;160:2,

 21,24;161:1 

victory (1)

 151:12 

viewpoint (1)

 132:19 

vigorous (1)

 112:16 

vision (2)

 73:22;127:15 

visionary (1)

 128:9 

visited (1)

 86:24 

vitamin (1)

 88:13 

vitamins (2)

 88:11,19 

voice (2)

 115:6;132:18 

volume (1)

 13:23 

vote (35)

 10:21;15:25;22:11,

 17;23:19;31:8;39:14;

 52:14;53:23;73:6;

 119:3;123:6;130:4,

 12;131:19;134:18;

 142:4,6;143:9;

 145:24;147:24;

 149:18,22,23,24,25;

 150:13;151:19;

 152:19,19;154:12,14,

 14;155:6,13 

voted (8)

 7:10;30:15;145:15;

 151:18;152:7,8,17;

 155:3 

votes (26)

 11:20;16:25;23:15;

 24:21;26:2;27:7;

 28:13;29:8;30:8;32:8;

 40:13;43:3;47:8;55:2;

 57:17;61:16;64:5;

 71:15;73:8;75:23;

 92:20;124:23;134:8;

 143:18;149:7;150:20 

voting (7)

 10:16;27:13;28:16;

 42:3;60:17;70:16;

 123:24 

vulnerable (1)

 161:6 

wait (4)

 7:25;8:8;107:17;

 127:22 

waited (1)

 6:9 

waiting (2)

 107:19;156:7 

walk (1)

 28:21 

walls (1)

 7:2 

wants (1)

 122:2 

war (2)

 77:7;117:14 

waste (1)

 64:19 

watch (1)

 77:5 

water (9)

 17:15;18:16;24:25;

 36:17;37:3,8;41:1;

 76:12;121:23 

wavering (1)

 55:5 

way (34)

 6:19;12:12;21:20;

 72:3,7;85:18,19;86:2,

 6;88:20;93:20;97:5;

 100:10;111:7,14,20;

 116:20;120:14;

 126:10;130:2,2,3,6;

 131:12;138:17;

 142:15;144:18,19;

 148:10;149:25;

 150:11,19;152:21;

 160:1 

ways (3)

 115:20;140:15;

 155:8 

wear (2)

 65:25;66:21 

webinars (1)

 108:17 

website (5)

 48:18;52:25;53:9;

 108:18;135:20 

weed (1)

 110:1 

weed-resistant (1)

 120:24 

weeds (3)

 120:20;122:1,21 

week (2)

 97:16;129:10 

weigh (3)

 51:10;59:22;145:22 

weird (1)

 154:22 

Welcome (5)

 0:11;59:22;126:3;

 141:1;161:19 

weren't (1)

 65:16 

what's (8)

 28:23;77:20;83:7;

 96:14;97:8,10;

 104:14;118:18 

wheat (2)

 122:21,22 

whenever (2)

 14:18;129:7 

wherein (1)

 37:13 

Whereupon (2)

 125:10;162:5 

Wherever (1)

 36:15 

white (2)

 132:2;134:4 

whole (10)

 62:19;68:19;86:16;

 92:1;106:25;109:11,

 12;110:20;130:20;

 161:5 

wholly (1)

 13:22 

whose (1)

 13:9 

wide (3)

 9:21;58:3;126:13 

widely (4)

 10:3;13:4;84:16;

 139:25 

widespread (1)

 84:16 

wild (3)

 12:15;13:18;120:17 

willing (2)

 135:9,9 

windrow (1)

 137:8 

wine (11)

 64:10,21;65:9,22;

 66:12;67:14,16;69:4,

 6;70:4;89:11 

winemakers (1)

 66:19 

winemaking (1)

 66:14 

wineries (6)

 65:5,13;66:1;67:15,

 20;68:15 

winery (2)

 65:18,20 

wines (3)

 64:16;69:16,22 

winner (1)

 133:10 

Winter (2)

 122:20,22 

wish (2)

 68:7;79:9 

withholding (1)

 139:19 

within (3)

 8:17;93:25;153:16 

without (12)

 19:14,15;20:18;

 43:25;45:4;62:12;

 65:22;67:16;106:22;

 107:19;112:8;154:18 

wonder (3)

 95:9;99:23;147:9 

wonderful (4)

 85:13;99:1,22;

 100:21 

wondering (3)

 38:10;82:25;128:19 

Wood (47)

 10:11;16:22;23:11;

 24:15;25:19;26:22;

 28:1,19;29:4,7,19;

 30:13;31:3,6,17;

 39:20;42:8;46:11;

 49:6;54:3;57:15;

 61:12;63:24;68:5;

 70:14;71:7;75:11;

 77:12;91:23;93:8;

 98:9;99:13;100:15;

 106:5;108:3;110:6;

 114:2;119:3,22;

 120:23;123:6,15,18;

 124:7;148:14;149:15;

 155:23 

Wood's (1)

 150:10 

word (6)

 72:18;102:22;

 105:22;118:19;

 145:16;157:23 

wording (2)

 137:6;141:24 

words (2)

 45:8;116:14 

work (44)

 0:20,22;15:8;49:22,

 23;50:19;58:15;

 65:25;68:3;74:22;

 83:15;93:20,25;94:3,

 4;95:13,13;96:9;

 105:16;109:2;114:11,

 25;115:23;119:14;

 126:5;127:18,19;

 129:15,15;130:14;

 135:15;140:16;

 141:14;142:11;

 145:10;156:13;157:7,

 8,10;158:11,14;

 159:16;160:9;161:18 

worked (4)

 103:3,5;123:13;

 150:15 

working (13)

 14:17;58:18,25;

 66:4;90:3;93:24;

 108:7;113:25;114:19;

 134:24;140:8;141:3;

 161:20 

workload (4)

 0:18;151:8;157:17;

 158:3 

workloads (1)

 158:8 

works (1)

 102:16 

workshops (1)

 139:4 

world (3)

 36:24;55:8;109:9 

worldwide (1)

 44:25 

worry (1)

 106:7 

worse (3)

 154:6;155:18,22 

worst (1)

 118:22 

worth (2)

 38:10;114:20 

Wow (2)

 72:10;126:20 

wresting (1)

 52:21 

write (4)

 105:11;133:5;

 134:5;147:1 

write-up (6)

 141:18,23;142:2,4,

 13;145:17 

write-ups (2)

 141:20;145:2 

written (6)

 12:13;13:20;65:23;

 77:2,3;108:17 

wrong (3)

 11:23;28:24;119:10 

wrote (1)

 142:15 

X 

xanthan (5)

 17:14;18:4,10;

 23:20,20 

Y 

yar (1)

 76:22 

year (28)

 0:17;94:20;96:3;

 104:18;105:8;106:15;

 107:7,8;108:11,13;

 120:19;121:19;

 126:11;127:22;128:2;

 130:18,20;131:11;

 133:11;134:20;135:4,

 14;141:12;142:10;

 145:16;158:14;161:2,

 22 

years (19) 

W 

Min-U-Script® Burke Court Reporting & Transcription (27) via - years 

(973) 692-0660 
NATIONAL ORGANIC STANDARDS BOARD (NOSB) - Vol. 5 

October 26, 2023 

44:24;52:23;76:18;

 84:25;94:10;112:2;

 113:5,5,6;116:3;

 123:8;127:25;128:7;

 129:22;130:25;

 147:17;148:9;153:24;

 160:24 

year-wise (1)

 113:6 

yeast (2)

 12:23;13:1 

yellow (1)

 117:24 

yesses (2)

 92:7,14 

yesterday (4)

 10:13;17:2;30:15;

 43:16 

yields (1)

 122:25 

yogurt (2)

 18:5;72:25 

yolk (1)

 83:14 

yolks (1)

 80:15 

youngest (1)

 130:19 

73:14;95:11;111:24;

 112:2,6;113:5;114:7,

 10,21 

10:01 (1)

 0:2 

100 (1)

 64:12 

102 (3)

 112:1;114:7,22 

11 (2)

 41:17;77:24 

11:58 (1)

 93:3 

110 (3)

 121:20;122:7;123:2 

12 (2)

 38:16;112:2 

12:18 (1)

 93:3 

120- (1)

 139:18 

13 (17)

 11:21;17:7;23:16;

 24:22;26:3;27:8;

 28:14;30:9;32:9;43:4;

 47:9;57:18;61:17;

 64:6;71:16;75:24;

 125:5 

14 (2)

 73:6;77:2 

15 (6)

 129:14;132:11,16;

 137:7,8;139:7 

19 (1)

 0:23 

1995 (2)

 47:18;49:14 

7:14 

2018 (2)

 73:5;76:16 

2022 (2)

 38:1,13 

2023 (8)

 33:7;61:25;73:14;

 76:21;77:3;120:13;

 123:14,17 

2023-2024 (1)

 134:20 

2026 (4)

 142:10;145:10;

 146:18;148:23 

2027 (1)

 145:4 

2031 (1)

 148:24 

205.105e (1)

 12:21 

205.203 (1)

 137:14 

205.600 (2)

 73:19;77:11 

205.605 (1)

 6:17 

205.605a12 (1)

 11:24 

205.605a13 (1)

 17:13 

205.605a21 (1)

 28:18 

205.605a23 (1)

 30:12 

205.605a6 (1)

 9:9 

205.605b (2)

 7:6;33:8 

205.605b14 (1)

 43:7 

205.605b16 (1)

 47:12 

205.605b19 (1)

 55:14 

205.605b23 (1)

 57:22 

205.605b24 (1)

 61:20 

205.605b3 (1)

 32:12 

205.605b35 (1)

 64:9 

205.605b37 (1)

 17:14 

205.605b8 (1)

 40:16 

205.605s (1)

 17:18 

205.606 (7)

 7:20,22;17:14;

 71:18;72:19;73:6;

 76:7 

205.606l (1)

 76:4 

205.606r (1)

 17:17 

23 (1)

 45:10 

230 (1)

 139:7 

25 (1)

 137:6 

29 (1)

 130:18 

3 

3 (8)

 40:14;78:5;89:25;

 112:2,15;113:5;

 136:25;137:7 

3:28 (1)

 162:5 

30 (1)

 43:25 

4 

4 (1)

 140:19 

40 (2)

 14:21;121:22 

Z 

5 

Zero (56)

 11:21,21,22;17:7,7,

 8;23:16,16,17,17;

 24:22,22,23;26:3,3,4;

 27:8,8,9;28:14,14,15;

 30:9,9,10;32:9,9,10;

 40:14,15;43:4,4,5;

 47:9,9,10;55:11;

 57:18,18,19;61:17,17,

 18;64:6,6,7;71:16,16,

 17;75:24,24,25;

 92:25;125:6,6,6 

Zoom (4)

 0:14;62:17;128:24,

 24 

5 (4)

 95:10;113:5,5;

 139:6 

5:00 (1)

 92:22 

50 (3)

2 46:2;78:3;126:9

2 (20)

 11:22;17:8;23:17;

 24:23;26:4;27:9;

 28:15;30:10;32:10;

 40:15;43:5;47:10;

 55:11,12;57:19;

 61:18;64:7;71:17;

 75:25;125:6 

2:15 (2)

 93:6;124:25 

2:20 (1)

 125:9 

2:26 (1)

 126:2 

2001 (1)

 120:13 

2002 (1)

 38:4 

2005 (1)

 7:18 

2015 (2)

 7:10;49:25 

2017 (1)

6 

60 (1)

 43:25 

7 

1 7 (1)

 7:14 

70 (1)

 9:22 

1 (8)

 73:6;93:6;103:16;

 129:14,14;136:25,25;

 137:6 

1/10th (1)

 103:16 

1/2 (1)

 45:10 

1/3rd (1)

 44:1 

1:08 (1)

 125:10 

10 (12)

 40:14;44:24;55:11;

8 

8 (1)

 125:8 

80s (1)

 137:2 

9 

90 (1)

 139:18 

Min-U-Script® Burke Court Reporting & Transcription (28) year-wise - 90 

(973) 692-0660